ML18162A017
| ML18162A017 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/15/2018 |
| From: | Rajender Auluck Beyond-Design-Basis Engineering Branch |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Auluck R | |
| References | |
| CAC MF4460, CAC MF4461, EPID L-2014-JLD-0054 | |
| Download: ML18162A017 (26) | |
Text
UNITED ST ATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 June 15, 2018 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 & 2-REPORT FOR THE AUDIT OF LICENSEE RESPONSES TO INTERIM STAFF EVALUATIONS OPEN ITEMS RELATED TO NRC ORDER EA-13-109 TO MODIFY LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS (CAC NOS. MF4460 AND MF4461; EPID L-2014-JLD-0054)
Dear Mr. Hanson:
On June 6, 2013 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML13143A334), the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," to all Boiling-Water Reactor licensees with Mark I and Mark II primary containments. The order requirements are provided in Attachment 2 to the order and are divided into two parts to allow for a phased approach to implementation. The order required licensees to submit for review overall integrated plans (OIPs) that describe how compliance with the requirements for both phases of Order EA-13-109 will be achieved.
By letter dated June 30, 2014 (ADAMS Accession No. ML14184A017), Exelon Generation Company, LLC (the licensee) submitted its Phase 1 OIP for Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities). By letters dated December 17, 2014, June 30, 2015, December 16, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 30, 2016, January 26, 2017, June 27, 2017, and December 11, 2017 (ADAMS Accession Nos. ML14351A433, ML15181A330, ML15350A416, ML16182A396, ML17026A366, ML17178A079, and ML17345A778, respectively), the licensee submitted its 6-month updates to the OIP. The NRC staff reviewed the information provided by the licensee and issued interim staff evaluations ( IS Es) for Phase 1 and Phase 2 of Order EA-13-109 for Quad Cities by letters dated April 1, 2015 (ADAMS Accession No. ML15089A421 ), and April 28, 2017 (ADAMS Accession No. ML17109A077), respectively. When developing the ISEs, the staff identified open items where additional information was still needed to complete its review.
The NRC staff is using the audit process described in letters dated May 27, 2014 (ADAMS Accession No. ML14126A545), and August 10, 2017 (ADAMS Accession No. ML17220A328),
to gain a better understanding of licensee activities being performed for compliance with the order. As part of the audit process, the staff reviewed the licensee's closeout of the ISE open
B. Hanson items. The NRC staff conducted a teleconference with the licensee on May 17, 2018. The enclosed audit report provides a summary of that aspect of the audit.
If you have any questions, please contact me at (301) 415-1025 or by e-mail at Rajender.Auluck@nrc.gov.
Sincerely, Rajender Auluck, Senior Project Manager Beyond-Design-Basis Engineering Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket Nos. 50-254 and 50-265
Enclosure:
Audit report cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION AUDIT OF LICENSEE RESPONSES TO INTERIM STAFF EVALUATIONS OPEN ITEMS RELATED TO ORDER EA-13-109 MODIFYING LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS EXELON GENERATION COMPANY, LLC QUAD CITIES NUCLEAR POWER STATION, UNITS 1 & 2 DOCKET NOS. 50-254 AND 50-265 BACKGROUND On June 6, 2013 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML13143A334), the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Condition," to all Boiling-Water Reactor (BWR) licensees with Mark I and Mark II primary containments. The order requirements are divided into two parts to allow for a phased approach to implementation.
Phase 1 of Order EA-13-109 requires license holders of BWRs with Mark I and Mark II primary containments to design and install a Hardened Containment Vent System (HCVS), using a vent path from the containment wetwell to remove decay heat, vent the containment atmosphere (including steam, hydrogen, carbon monoxide, non-condensable gases, aerosols, and fission products), and control containment pressure within acceptable limits. The HCVS shall be designed for those accident conditions (before and after core damage) for which containment venting is relied upon to reduce the probability of containment failure, including accident sequences that result in the loss of active containment heat removal capability or extended loss of alternating current (ac) power (ELAP). The order required all applicable licensees, by June 30, 2014, to submit to the Commission for review an overall integrated plan (OIP) that describes how compliance with the Phase 1 requirements described in Order EA-13-109 will be achieved.
Phase 2 of Order EA-13-109 requires license holders of BWRs with Mark I and Mark II primary containments to design and install a system that provides venting capability from the containment drywell under severe accident conditions, or, alternatively, to develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions. The order required all applicable licensees, by December 31, 2015, to submit to the Commission for Enclosure
review an OIP that describes how compliance with the Phase 2 requirements described in Order EA-13-109, Attachment 2, will be achieved.
By letter dated June 30, 2014 (ADAMS Accession No. ML14184A017), Exelon Generation Company, LLC (Exelon, the licensee) submitted its Phase 1 OIP for Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities). By letters dated December 17, 2014, June 30, 2015, December 16, 2015 (which included the combined Phase 1 and Phase 2 OIP), June 30, 2016, January 26, 2017, June 27, 2017, and December 11, 2017 (ADAMS Accession Nos. ML14351A433, ML15181A330, ML15350A416, ML16182A396, ML17026A366, ML17178A079, and ML17345A778, respectively), the licensee submitted its 6-month updates to the OIP, as required by the order.
The NRC staff reviewed the information provided by the licensee and issued interim staff
- evaluations (ISEs) for Phase 1 and Phase 2 of Order EA-13-109 for Quad Cities by letters dated April 1, 2015 (ADAMS Accession No. ML15089A421 ), and April 28, 2017 (ADAMS Accession No. ML17109A077), respectively. When developing the ISEs, the staff identified open items where additional information was still needed to complete its review.
The NRC staff is using the audit process in accordance with the letters dated May 27, 2014 (ADAMS Accession No. ML14126A545), and August 10, 2017 (ADAMS Accession No. ML17220A328), to gain a better understanding of licensee activities as they come into compliance with the order. The staff reviews submitted information, licensee documents (via ePortals), and preliminary Overall Program Documents (OPDs)/OIPs, while identifying areas where additional information is needed. As part of this process, the staff reviewed the licensee closeout of the ISE open items.
AUDIT
SUMMARY
As part of the audit, the NRC staff conducted a teleconference with the licensee on May 17, 2018. The purpose of this audit teleconference was to continue the audit review and provide the NRC staff the opportunity to engage with the licensee regarding the closure of open items from the ISEs. As part of the preparation for the audit call, the staff reviewed the information and/or references noted in the OIP updates to ensure that closure of ISE open items and the HCVS design are consistent with the guidance provided in Nuclear Energy Institute (NEI) 13-02, Revision 1, other related documents (e.g., white papers (ADAMS Accession Nos. ML14126A374, ML14358A040, ML15040A038 and ML15240A072, respectively), and frequently asked questions (FAQs), (ADAMS Accession No. ML15271A148)) that were developed and reviewed as part of overall guidance development. The NRC staff audit members are listed in Table 1. Table 2 is a list of documents reviewed by the staff. Table 3 provides the status of the ISE open item closeout for Quad Cities. The open items are taken from the Phase 1 and Phase 2 ISEs issued on April 1, 2015, and April 28, 2017, respectively.
FOLLOW UP ACTIVITY The staff continues to audit the licensee's information as it becomes available. The staff will issue further audit reports for Quad Cities, as appropriate.
Following the licensee's declarations of order compliance, the licensee will provide a final integrated plan (FIP) that describes how the order requirements are met. The NRC staff will evaluate the FIP, the resulting site-specific OPDs, as appropriate, and other licensee documents, prior to making a safety determination regarding order compliance.
CONCLUSION This audit report documents the staff's understanding of the licensee's closeout of the ISE open items, based on the documents discussed above. The staff notes that several of these documents are still preliminary, and all documents are subject to change in accordance with the licensee's design process. In summary, the staff has no further questions on how the licensee has addressed the ISE open items, based on the preliminary information. The status of the NRC staff's review of these open items may change if the licensee changes its plans as part of final implementation. Changes in the NRC staff review will be communicated in the ongoing audit process.
Attachments:
- 1. Table 1 - NRC Staff Audit and Teleconference Participants
- 2. Table 2 -Audit Documents Reviewed
- 3. Table 3- ISE Open Item Status Table
Table 1 - NRC Staff Audit and Teleconference Participants Title Team Member Organization Team Lead/Sr. Project Manaqer Rajender Auluck NRR/DLP Project Manager Support/Technical Support - Containment / Ventilation Brian Lee NRR/DLP Technical Support - Containment/
Ventilation Bruce Heida NRR/DLP Technical Support- Electrical Kerby Scales NRR/DLP Technical Support- Balance of Plant Kevin Roche NRR/DLP Technical Support - l&C Steve Wyman NRR/DLP Technical Support - Dose John Parillo NRR/DRA Attachment 1
Table 2 - Audit Documents Reviewed Calculation QDC-8300-E-2100, "Unit 1(2) 125 VDC Battery Coping Calculation For Beyond Design Basis FLEX Event," Revision 0 Calculation QDC-1600-E-2200, "125 VDC Battery Sizing Calculation for Hardened Containment Vent System for 24 Hour Duty Cycle," Revision 1 Calculation QDC-7300-E-2099, "Unit 1(2) 480 VAC FLEX Diesel Generator and Cable Sizing for Beyond Design Basis FLEX Event," Revision 1 Engineering Change (EC) 392256, "Hardened Containment Vent System (Non-Outage Portion)
As Required by NRC Order EA-13-109 Units 1 & 2 - Fukushima," Revision 2 EC 400666, "Hardened Containment Vent System As Required by NRC Order EA-13-109 Units 2 - Fukushima, Part 2 of 3," Revision 0 Calculation QDC-1600-M-2212, "HCVS Nitrogen Bottle Sizing and Pressure Regulator Set Point Determination," Revision 0 Calculation 2014-02948, "Reactor Building Temperature Analysis Resulting from Extended Loss of AC Power," Revision 0 Calculation QDC-1600-M-2247, "Unit 2 HCVS Vent Line Sizing Calculation," Revision 0 Calculation QDC-1600-M-2188, "HCVS Vent Line Sizing Calculation" Revision 1 (Unit 1)
EC 402709, "Temperature in Proposed Location of HCVS Remote Operating Station Battery Racks and Gas Bottles," Revision 0 Calculation QDC-OOOO-M-2199, "HCVS 7 Day Dose Analysis," Revision O Calculation QDC-0020-S-2192, "HCVS Steel Tower Structural Calculation," Revision O Procedure QCOP 0050-09 "FLEX Response Instrumentation and Communication Equipment,"
Revision 4 Calculation QDC-1600-2190, "Hardened Containment System Design Calculation," Revision 0 Calculation QDC-OOOO-M-2097, "PIPE FLO Analysis of FLEX Strategy," Revision 0 Calculation QDC-OOOO-M-2223, "HCVS Phase II 7 Day Dose Analysis," Revision O BWROG-TP-008, "Severe Accident Water Addition Timing" BWROG-TP-011, "Severe Accident Water Management Supporting Evaluations" Attachment 2
Quad Cities Nuclear Power Station, Units 1 and 2 Vent Order Interim Staff Evaluation Open Items:
Table 3 - ISE Open Item Status Table ISE Open Item Number Licensee Response - Information NRC Staff Close-out notes Safety Evaluation (SE) provided in 6 month updates and on the status Requested Action ePortal Closed; Pending; Open (need additional information from licensee)
Phase 1 ISE 01 1 Complete - Supplied to NRC Audit team The NRC staff reviewed the Closed during onsite FLEX evaluation (Jan 2015). information provided in the Make available for NRC staff (Ref. 13). Calculation QDC-8300-E-2100 6-month updates and on the [Staff evaluation to be audit the calculation confirms that Order EA-12-49 actions to ePortal. included in SE (QDC-8300-E-2100) that restore power are sufficient to ensure; Section 3.1.2.6]
confirms that Order EA-12-49 continuous operation of non-dedicated Calculation QDC-8300-E-2100, actions to restore power are containment instrumentation. "Unit 1(2) 125 voe [volts direct sufficient to ensure continuous current]Battery Coping operation of non-dedicated Reference 13 has been provided in Calculation For Beyond Design containment instrumentation. e-portal. Basis FLEX Event," Revision 0, shows that 125 voe Battery is capable of providing power for the continuous operation of non-dedicated containment instrumentation.
No follow-up questions.
Phase 1 ISE 01 2 Started - HCVS Battery design has been The NRC staff reviewed the Closed completed. (Refs. 14 and 17) information provided in the Make available for NRC staff 6-month updates and on the [Staff evaluation to be audit the final sizing evaluation Calculation QDC-1600-E-2200 evaluates ePortal. included in SE for HCVS batteries/battery the sizing of the HCVS battery. (Ref. 28) Section 3.1.2.6]
charger including incorporation The licensee stated that all into FLEX DG loading References have been provided in electrical power required for calculation. e-portal. operation of HCVS components is provided by the 125 Vdc Incorporation into FLEX DG loading battery/battery charger.
calculations is in progress.
The battery sizing calculation (QDC-1600-E-2200) confirmed Attachment 3
that the HCVS batteries have a minimum capacity capable of providing power for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without recharging, and therefore is adequate.
The licensee provided EC 392256 and EC 400666, which discusses re-powering of the HCVS battery charger using a FLEX DG.
No follow-up questions.
Phase 1 ISE 01 3 Started- Unit 1 nitrogen system installed. The NRC staff reviewed the Closed Calculation QDC-1600-M-2212 for sizing information provided in the Make available for NRC staff approved and applicable to both Units. 6-month updates and on the [Staff evaluation to be audit documentation of the Unit 2 system installation in progress. ePortal. included in SE HCVS nitrogen pneumatic Section 3.1.2.6]
system design including sizing The Staff reviewed the and location. Calculation QDC-1600-M-2212, "HCVS Nitrogen Bottle Sizing and Pressure Regulator Set Point Determination," Revision O and noted that 2 nitrogen bottles can operate an air-operated valave (AOV) 1-1601-60 one time and AOV 1699-98 16 times (12 required). The calculation credited the bottle pressures starting at 2000per square inch gauge (psig) down to 200 psig.
No follow-up questions.
Phase 1 ISE 01 4 Complete- Temperature evaluation The NRC staff reviewed the Closed (Calculation 2014-02948) was made information provided in the Make available for NRC staff available to NRC Audit team during onsite 6-month updates and on the [Staff evaluation to be audit an evaluation of FLEX evaluation (Jan 2015)(Ref. 21). ePortal. included in SE temperature and radiological Sections 3.1.1.2 and conditions to ensure that Phase 1 Radiological evaluation has been Main control room (MCR) 3.1.1.3]
operating personnel can safely completed. (Ref. 16). temperatures have been addressed as part of the FLEX
access and operate controls Phase 2 Radiological evaluation has been order and were found to be and support equipment completed (Ref. 6). acceptable by the NRC staff.
Evaluations of temperature and EC 398588 and EC 402709 radiological conditions ensure that discusses the environmental operating personnel can safely access conditions for the remote and operate controls and support operating station (ROS) as it equipment. References have been relates to personnel habitability provided in e-portal. and equipment operability.
EC 398588 was specifically meant as a bounding input for a calculation (2014-05860) for qualification of the Station batteries, which are located on the 639' elevation of the Turbine Building. The highest temperature was 135 degrees Fareneit (°F), from EC 398588, which was the temperature recorded at the highest point in the Turbine Building exhaust.
Quad Cities used this same maximum temperature as an input for the travel paths from the MCR to the ROS. The MCR and the ROS are elevation 611 ', with the travel path dropping to 595' elevation between them. The expected temperature is much below the maximum temperature used for design of the system (135°F).
EC 402709 was a specific input to the design of the ROS. For both Units, the ROS area is generally surrounded by concrete walls except for the access path. As a result, temperatures exceeding 125°F was not a concern for the design of the ROS. Also of note, the High Pressure (HP) Heater Bay is separated from the ROS area by concrete walls.
As a result of the evaluation of the above paragraphs, 135°F was chosen as the maximum temperature used for qualification of equipment and personnel habitability.
If the Turbine Building were to reach the maximum temperatures of 135°F, Operations has chosen to use toolbox approach, including the use of ice vests.
Also of note, a complete manual operation of the HCVS system using bypass valves around solenoids to operate the primary containment isolation valves (PCIVs) and argon purge system would not need more than 15 minutes in an hour between cycles. The Quad Cities design does not require Operators continuously occupy the ROS.
Calculation QDC-OOOO-M-2199, "HCVS 7 Day Dose Analysis,"
Revision O was performed to determine the integrated radiation dose due to HCVS operation.
The NRC staff reviewed this calculation and determined that the licensee used conservative assumptions and followed the guidance outlined in NEI 13-02
Rev.1 and HCVS-WP-02 Rev. 0.
Based on the expected integrated whole body dose equivalent in the MCR and ROS and the expected integrated whole body dose equivalent for expected actions during the sustained operating period, the NRC staff believes that the order requirements are met.
Based on the these evaluations, the temperature and radiological conditions should not inhibit operator actions needed to initiate and operate the HCVS during an ELAP with severe accident conditions.
No follow-up questions.
Phase 1 ISE 01 5 Complete. Refer to the response to ISE The NRC staff reviewed the Closed open item 6. information provided in the Make available for NRC staff 6-month updates and on the [Staff evaluation to be review documentation that ePortal. included in SE confirms the final design Section 3.1.2.1]
diameter of the HCVS piping. The final design diameter of the HCVS piping was determined to be 12 inches.
No follow-up questions.
Phase 1 ISE 01 6 Complete. Calculation QDC-1600-M-2188 The NRC staff reviewed the Closed for Unit 1 line sizing approved (Ref. 19). information provided in the Make available for NRC staff Calculation QDC-1600-M-2247 for Unit 2 6-month updates and on the [Staff evaluation to be audit analyses demonstrating line sizing approved. (Ref. 30) ePortal. included in SE Section that HCVS has the capacity to 3.1.2.1]
vent the steam/energy In addition, MAAP [Modular Accident Calculation QDC-1600-M-2247, equivalent of one (1) percent Analysis Program] analyses (Ref. 12) are "Unit 2 HCVS Vent Line Sizing of licensed/rated thermal credited to verify that (1) venting can be Calculation," Revision O used a power (unless a lower value is delayed for at least three hours and (2) rated thermal power of 2,957 MWt justified), and that the anticipatory venting sufficiently limits the [meqawatt thermall. The flow rate
suppression pool and the suppression pool heat up to maintain equivalent of 1% reactor power HCVS together are able to RCIC [reactor core isolation cooling] thermal energy is 110,453 lbm/hr absorb and reject decay heat, functional. at 47.7 psig. 47.7 psig is the such that following a reactor primary containment pressure shutdown from full power MAAP also confirms the HCVS is of limit (PCPL) limit with the torus containment pressure is sufficient size to prevent the Suppression water level at the vent line restored and then maintained Pool from reaching PCPL. opening. The 12" vent has the below the primary containment capacity of -109,800 lbm/hr at 25 design pressure and the References have been provided in psig, -124,400 lbm/hr at 30 psig, primary containment. e-portal. and -173,000 lbm/hr at 47. 7 psig.
Calculation QDC-1600-M-2188, "HCVS Vent Line Sizing Calculation," Revision O for Unit 1, shows the venting capacity at 47.9 psig PCPL (with torus filled with water up to the vent elevation) is 167,000 lbm/hr. The flow rate equivalent of 1% reactor power thermal energy is 110,465 lbm/hr. Vent capacity at 5 psig is 39,700 lbm/hr and 59,100 lbm/hr at 10 psig.
No follow-up questions.
Phase 1 !SE 01 7 Complete - The HCVS stack seismic The NRG staff reviewed the Closed design meets the Station's design basis information provided in the Make available for NRG staff earthquake design criteria. (Ref. 20) 6-month updates and on the [Staff evaluation to be audit the seismic and tornado ePortal. included in SE missile final design criteria for Reference has been provided in e-portal. Section 3.2.2]
the HCVS stack. Calculation QDC-0020-S-2192, The information provided in December "HCVS Steel Tower Structural 2015 OIP (Ref. 7) demonstrates that the Calculation," Revision 0, shows external piping meets the tornado missile that the HCVS stack seismic protection criteria of HCVS-WP-04. design meets the Quad Cities design basis earthquake design criteria.
EC 392256 and EC 400266 addresses the tornado missile design. For the tornado missile design the licensee relies on NRG-endorsed HCVS-WP-04.
The HCVS external piping is all above 30-feet from ground level, except for two berms that will not have potential tornado missiles.
The piping consists solely of large bore (12-inches nominal diameter) piping and its piping supports, and the pipe has less than 300 square feet of vertical cross section. The HCVS external piping meets the reasonable protection requirements of HCVS-WP-04. The external support structure used to support the HCVS piping is analyzed to the Quad Cities design basis tornado missiles to preclude a failure of the tower due to tornado winds and missiles.
No follow-up questions.
Phase 1 ISE 01 8 Complete - Component location design The NRC staff reviewed the Closed has been determined. The ROS, gas information provided in the Make available for NRC staff bottles, dedicated battery, and most 6-month updates and on the [Staff evaluation to be audit the descriptions of local equipment are in the Turbine Building. ePortal. included in SE conditions (temperature, The HCVS primary control panel is in the Sections 3.1.1.4 and radiation and humidity) MCR (Refs. 14, 15, and 17). EC 402709 and EC 392257, and 3.1.2.6]
anticipated during ELAP and QDC-OOOO-M-2199, "HCVS 7 Day severe accident for the Reactor Building temperatures are as Dose Analysis," Revision 0 components (valves, noted in calculation 2014-02948 (Ref. 21 ). discusses the environmental instrumentation, sensors, conditions during an accident at transmitters, indicators, Turbine Building temperatures at the ROS the locations containing electronics, control devices, are as noted in evaluation EC 402709 instrumentation and controls and etc.) required for HCVS (Ref. 22). (l&C) components. The staff's ventinq includinq confirmation review indicated that the
that the components are Limiting radiation conditions for environmental qualification met capable of performing their equipment as per calculation the order requirements.
functions during ELAP and QDC-OOOO-M-2199, HCVS 7-Day Dose severe accident conditions. Analysis (Ref. 16). The HCVS Battery and Charger are in the center of the Mezzanine References have been provided in Level (611' elevation) of the e-portal. Turbine Building. The HCVS battery and charger are designed for 120°F, which based on operating data is the applicable upper bound for this area. The temperature of this area is bounded by the north and south ends, which are the locations of the areas occupied by Bus 13/14 and Bus 23/24. The heat loads in those areas are much higher than the center area, and so the center area is always cooler, even though not directly measured.
Temperature data from the Bus 13/14 area records a highest-ever temperature of 121.6°F on 7/7/12 at 16:48. Local weather history for the Quad Cities had a max atmospheric temperature of 104°F on that day. The temperature data for the Bus 23/24 area is generally less than the area for Bus 13/14, and all records below 120°F. It should be noted that 121.6°F was the single instance of temperature over 120°F in 10 years of temperature records. Based on the fact that this data was taken with operating heats loads and in a region hotter than the area where the HCVS battery and
charger are installed, this supports 120°F as the upper bound for this location.
No follow-up questions.
Phase 1 ISE 01 9 Complete - QCOP 0050-09 FLEX The NRC staff reviewed the Closed Response Instrumentation and information provided in the Make available for NRC staff Communication Equipment provides a 6-month updates and on the [Staff evaluation to be audit documentation that detailed description of Communications ePortal. included in SE demonstrates adequate equipment dedicated to FLEX response Section 3.1.1 .1]
communication between the utilized for Severe Accident Response. The communication methods are remote HCVS operation This equipment includes radios the same as accepted in Order locations and HCVS decision programed for talk around mode with EA-12-049.
makers during ELAP and additional batteries and Sound powered severe accident conditions. phones which can be used for No follow-up questions.
communications between the Main Control Room and local control stations.
QCOS 0050-04 FLEX Sound Powered Phone Surveillance is being revised to test two additional connection points that can be utilized for Severe Accident response and control of SAWA/SAWM
[severe accident water addition/ severe accident water management] flow and local operation of the HCVS valves.
References have been provided in e-portal.
Phase 1 ISE 01 10 Complete-As stated in the December The NRC staff reviewed the Closed 2015 01 P, Quad Cities will utilize Argon information provided in the Provide a description of the purge system to address combustible 6-month updates and on the [Staff evaluation to be final design of the HCVS to gases in the HCVS piping. A summary of I ePortal. included in SE address hydrogen detonation the design features is included in the Section 3.1.2.11]
and deflagration. December 2015 01 P (Ref. 7). The HCVS design will include an Argon purge system that will be connected just downstream of the second PCIV. It will be designed to prevent hydrogen detonation downstream of the second PCIV.
The Argon purge system will have
a switch for the control valve in the MCR to allow opening the purge for the designated time, but it will also allow for local operation in the ROS in case of a de power or control circuit failure. The installed capacity for the Argon purge system will be sized for at least 8 purges within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the ELAP.
Calculation QDC-1600-2190, "Hardened Containment System Design Calculation," Revision O determined that 16 Argon bottles for each unit (32 total) maintained at a minimum pressure of 2350 at 70°F, can provide necessary Argon to purge the HCVS following 8 venting evolutions during a severe accident scenario.
The licensee's design is consistent with Option 3 of the NRG-endorsed white paper HCVS-WP-03.
No follow-up auestions.
Phase 1 ISE 01 11 Complete - As described in the December The NRC staff reviewed the Closed 2015 OIP (Ref. 7), the HCVS torus vent information provided in the Provide a description of the path in each Quad Cities unit, starting at 6-month updates and on the [Staff evaluation to be strategies for hydrogen control and including the downstream PCIV, will ePortal. included in SE that minimizes the potential for be a dedicated HCVS flow path. There Section 3.1.2.12]
hydrogen gas migration and are no interconnected systems The HCVS wetwell pipe in each ingress into the reactor downstream of the downstream, each unit provides a dedicated building or other buildings. dedicated HCVS PCIV. Interconnected HCVS flowpath from the wetwell systems are upstream of the downstream penetration PCIVs to the outside HCVS PCIV and are isolated by normally with no interconnected shut, fail shut PCIVs which, if open, would downstream oioinQ. The staffs
shut on an FLAP. There is no shared review of the proposed system HCVS piping between the two units. indicates that the licensee's design appears to maintain The vent path will rely on Argon purge hydrogen below flammability system to prevent the formation of a limits.
combustible gas mixture from forming within the line (Refs. 14, 15 and 17). No follow-up questions.
References have been provided in e-portal Phase 1 ISE 01 12 Started-The Quad Cities seismic The NRC staff reviewed the Closed evaluation is based on the Quad Cities information provided in the Make available for NRC staff safe shutdown earthquake (SSE), which 6-month updates and on the [Staff evaluation to be audit documentation of a is sufficient by Exelon HCVS Position ePortal. included in SE seismic qualification evaluation Paper EXC-WP-15. A list of component Section 3.2.2]
of HCVS components. evaluations is uploaded to ePortal. Due to The licensee provided several the size of the evaluation, they are qualification reports which available upon request. demonstrate the seismic adequacy of the HCVS components. These seismic qualification reports indicates the HCVS piping, components, supports, and wall penetrations are based on the Quad Cities SSE. The NRC staff reviewed these reports and confirmed that the components required for HCVS venting remain functional following a design basis earthquake.
No follow-up questions.
Phase 1 ISE 01 13 Complete. Instrument design is complete The NRC staff reviewed the Closed with approval of modifications for information provided in the Make available for NRC staff construction. (Refs. 14, 15 and 17). 6-month updates and on the [Staff evaluation to be audit descriptions of all ePortal. included in SE instrumentation and controls References have been provided in Section 3.1.2.8]
(existing and planned) e-portal. The existing plant instuments necessary to implement this required for HCVS (i.e. wetwell level instruments and drywell
order including qualification pressure instruments) meet the methods. requirements of RG 1.97.
EC 392256, EC 392257 and EC 400666 discusses the qualifications for new HCVS l&C components. The NRC staff's review indicated that the qualification met the order requirements.
No follow-up questions.
Phase 1 ISE 01 14 Started. Procedures are under The NRC staff reviewed the Closed development by Operations. information provided in the Make available for NRC staff 6-month updates and on the [Staff evaluation to be audit the procedures for HCVS ePortal. included in SE operation. Section 5.1]
The guidelines and procedures for HCVS operation will be developed and will be consistent with the guidance in NEI 13-02.
No follow-up questions.
Phase 2 ISE 01 1 Complete. FLEX calculation The NRC staff reviewed the Closed QDC-0000-M-2097 (Ref. 11) is revised information provided in the Licensee to demonstrate that with hydraulic parameters for addition of 6-month updates and on the [Staff evaluation to be the hydraulic analysis for the SAWA scenarios. ePortal. included in SE FLEX pump is capable to Section 4.1.1.2]
support the required 400 gpm References have been provided in Calculation QDC-OOOO-M-2097, SAWA flow rate. e-portal. "Pipe Flo Analysis of FLEX Strategy," Revision 1, determined the FLEX pumps should be able to provide the required SAWA flow of 400 gallons per minute (gpm) for 1 unit while the providing FLEX flow of 196 gpm and 92 gpm to the SFP with a 10% margin.
No follow-up questions.
Phase 2 ISE 01 2 Complete. The NRC staff reviewed the Closed information provided in the Licensee to evaluate the Egui~ment and Controls 6-month updates and on the [Staff evaluation to be SAWA equipment and ePortal. included in SE controls, as well as the ingress Plant instrumentation for SAWM that is Sections 4.1.1 .4 and and egress paths for the qualified to RG 1.97 or equivalent is For temperature review of the 4.2.1.4]
expected severe accident considered qualified for the sustained MCR and ROS, see Phase 1 ISE conditions (temperature, operating period without further Open ltem-4 above. As noted in humidity, radiation) for the evaluation. The following plant Phase 1 ISE Open ltem-4, above, sustained operating period. instruments are qualified to RG 1.97: if required, operating personnel working in high temperature areas DW Pressure Pi 1(2)-1640-11A/B will be protected using a toolbox Suppression Pool Level LI approach, including the use of ice 1(2)-1640-1 OA/B vests. With the use of the toolbox approach, it is reasonable to Passive components that do not need to assume the operator actions change state after initially establishing required to implement the HCVS SAWA flow do not require evaluation and SAWA/SAWM strategies can beyond the first 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, at which time be accomplished.
they are expected to be installed and ready for use to support SAWA/SAWM. The NRC staff reviewed calculation QDC-OOOO-M-2223, The following additional equipment "HCVS Phase II 7 Day Dose performing an active SAWA/SAWM Analysis," Revision O and function is considered: determined that the licensee used conservative assumptions and SAWA/SAWM flow instrument. followed the guidance outlined in SAWA/SAWM pump NEI 13-02 Rev.1 and SAWA/SAWM generator (the FLEX HCVS-WP-02 Rev.O. Based on generator for the associated Unit) the expected integrated whole body dose equivalent in the MCR Ingress and Egress and ROS and the expected integrated whole body dose For locations outside the Reactor Building equivalent for expected actions between 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 7 days when SAWA during the sustained operating is being utilized, a quantitative evaluation period, the NRC staff believes of expected dose rates has been that the order requirements are performed per HCVS-WP-02 and found met.
the dose rates at deployment locations
including ingress/egress paths are Temperature and radiological acceptable. (QDC-OOOO-M-2223, Ref. 6) conditions should not inhibit operator actions or SAWA References have been provided in equipment and controls needed to e-portal. initiate and operate the HCVS during an ELAP with severe accident conditions.
No follow-up questions.
Phase 2 ISE 01 3 Complete. The NRG staff reviewed the Closed information provided in the Licensee to demonstrate how EguiQment and Controls 6-month updates and on the [Staff evaluation to be instrumentation and equipment ePortal. included in SE being used for SAW A and Plant instrumentation for SAW A that is Sections 4.4.1.3 and supporting equipment is qualified to RG 1 .97 or equivalent is The drywall pressure and torus 4.5.1.2]
capable to perform for the considered qualified for the sustained level indications are RG 1 .97 sustained operating period operating period without further compliant and are acceptable as under the expected evaluation. The following plant qualified.
temperature and radiological instruments are qualified to RG 1.97:
conditions. Calculation QDC-OOOO-M-2223, DW Pressure Pl 1(2)-1640-11A/B "HCVS Phase II 7 Day Dose Suppression Pool Level LI Analysis," Revision O was 1(2)-1640-1 OA/B performed to determine the integrated radiation dose due to Passive components that do not need to HCVS operation.
change state after initially establishing SAWA flow do not require evaluation No follow-up questions.
beyond the first 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, at which time they are expected to be installed and ready for use to support SAWA/SAWM.
The following additional equipment performing an active SAWA/SAWM function is considered for temperature and radiation effects:
SAWA/SAWM flow instrument.
SAWA/SAWM pump (maybe the FLEX pump}
SAWA/SAWM generator (may be the FLEX generator)
Temperature The location of the distribution manifold is one floor below the ROS, and has similar or better temperature conditions as at the ROS. The location of the SAWA pump is similar to the FLEX pump, i.e. outside, but on the West side of the Site vs. east side.
The location of SAWA equipment and controls are the same or similar as FLEX, and are bounded by the FLEX evaluations for temperature.
Radiation For equipment locations outside the Reactor Building between 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 7 days when SA WA is being utilized, a quantitative evaluation of expected dose rates has been performed per HCVS-WP-02 and found the dose rates at deployment locations are acceptable.
(QDC-OOOO-M-2223, Ref. 6)
References have been provided in e-portal.
Phase 2 ISE OI 4 Complete. The NRG staff reviewed the Closed information provided in the Licensee to demonstrate that The Wetwell vent has been designed and 6-month updates and on the [Staff evaluation to be containment failure as a result installed to meet NEI 13 -02 Rev 1 ePortal. included in SE of overpressure can be guidance, which will ensure that it is Sections 4.1 and 4.2]
prevented without a drywell adequately sized to prevent containment BWROG-TP-15-008 vent during severe accident overpressure under severe accident demonstrates adding water to the conditions. conditions. reactor vessel within 8-hours of the onset of the event will limit the peak containment drywell
The SAWM strategy will ensure that the temperature significantly reducing Wetwell vent remains functional for the the possibility of containment period of sustained operation. Quad failure due to temperature.
Cities will follow the guidance (flow rate Drywell pressure can be and timing) for SHWA/SAWM described controlled by venting the in [Boiling Water Reactor Owners Group] suppression chamber through the BWROG-TP-15-008 and suppression pool.
BWROG-TP-15-011. These documents have been posted to the ePortal for NRC BWROG-TP-011 demonstrates staff review. The Wetwell vent will be that starting water addition at a opened prior to exceeding the PCPL high rate of flow and throttling value of 52 PSIG. Therefore, after approximately 4-hours will containment over pressurization is not increase the suppression pool prevented without the need for a drywell level to that which could block the vent. suppression chamber HCVS.
As noted under Phase 1, the vent is sized to pass a minimum steam flow equivalent to 1% rated core power. This is sufficient permit venting to maintain containment below the lower of PCPL or of design pressure.
No follow-up questions.
Phase 2 ISE 01 5 Complete. The NRC staff reviewed the Closed information provided in the Licensee shall demonstrate Reference Plant: 6-month updates and on the [Staff evaluation to be how the plant is bounded by ePortal. included in SE the reference plant analysis Torus free board volume is 525,000 Section 4.2.1.1]
that shows the SAWM strategy gallons Quad Cities based its SAWA flow is successful in making it rates on the RCIC flow rates per unlikely that a drywell vent is SAWA flow is 500 GPM [gallons per the guidance in NEI 13.02, needed. minute] at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> followed by 100 GPM Revision 1, Section 4.1.1.2.2.
from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> The reference plant has a Torus freeboard of 525,000 gallons and Qud Cities: Quad Cities has a Torus freeboard of 619, 190 gallons.
Torus freeboard volume is 619, 190 The reference plant assumes qallons SAWA flow of 500 qpm starting at
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and Quad Cities assumes SAWA flow is 400 GPM at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> a 400 gpm flow starting at 8 followed by 80 GPM from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 168 hours. The reference plant hours. reduces SAW A flow to 100 gpm at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Quad Cities The above parameters for Quad Cities reduces SAW A flow to 80 gpm at compared to the reference plant that 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. BWROG TP-15-011, determine success of the SAWM strategy evaluation demonstrates that the demonstrate that the reference plant Mark I (and Mark II) fleet is values are bounding. SAWA flow rates bounded by the reference plant are based on RCIC design flow as analyses. This study addressed allowed by NEI 13-02, Rev. 1, how suppression pool level Section 4.1.1.2.2. Therefore, the SAWM control could be achieved in a strategy implemented at Quad Cities manner that maintains long term makes it unlikely that a DW vent is function of the wetwell vent, and needed to prevent containment determined if there would be overpressure related failure. adverse effects by controlling (limiting) flow rate. The study concludes that plants with Mark I containments, with injection into the RPV, can maintain containment cooling and preserve the wetwell vent without a plant specific analysis. The evaluation bounds the parameters at Quad Cities. Quad Cities plans to flow this strategy and is bounded by the conclusions of the BWROG evaluation.
No follow-up questions.
Phase 2 ISE 01 6 Complete. Quad Cities utilizes handheld The NRC staff reviewed the Closed radios to communicate between the MCR, information provided in the Licensee to demonstrate that the operator at the FLEX pump, and the 6-month updates and on the [Staff evaluation to be there is adequate operator at the SAWA flow control ePortal. included in SE communication between the location. This communication method is Section 4.1]
MCR and the operator at the the same as accepted in Order The communication methods are FLEX pump during severe EA-12-049. These items will be powered the same as accepted in Order accident conditions. and remain powered using the same EA-12-049.
methods as evaluated under EA-12-049
for the period of sustained operation, No follow-up questions.
which may be longer than identified for EA-12-049.
Phase 2 ISE 01 7 Complete. For locations outside the The NRC staff reviewed the Closed Reactor Building between 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 7 information provided in the Licensee to demonstrate the days, when SAWA is being utilized, a 6-month updates and on the [Staff evaluation to be SAWM flow instrumentation quantitative evaluation of expected dose ePortal. included in SE qualification for the expected rates has been performed per Sections 4.1.1.3 and environmental conditions. HCVS-WP-02, and found the dose rates The licensee provided 4.2.1.3]
at deployment locations including environmental conditions for ingress/egress paths are acceptable. The radiation and temperature as well selected instrument is designed for the as the qualified temperature expected flow rate, temperature, and range for the flow instrument.
pressure for SAWA over the period of sustained operation. The NRC staff found the instrument appears to be qualified SAWA Flow Instrument Qualification for the anticipated conditions during an ELAP for the proposed 2.21 to 736 GPM, -4 to 140 °F fluid location.
temperature, 0-to 285 PSI No follow-up questions.
Expected SAWA Parameter Range Oto 400 GPM, 32 to 120 °F fluid temperature, 0 to 120 PSI
ML18162A017 OFFICE NRR/DLP/PBEB/PM NRR/DLP/PBMB/LA NRR/DLP/PBEB/BC (A) NRR/DLP/PBEB/PM NAME RAuluck Slent BTitus RAuluck DATE 6/13/18 6/13/18 6/15/18 6/15/18