RS-14-015, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events (Order No. EA-12-049)

From kanterella
Jump to navigation Jump to search
Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events (Order No. EA-12-049)
ML14059A432
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 02/28/2014
From: Kaegi G
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-14-015
Download: ML14059A432 (17)
v • d • e


Text

1 Exelon Generation Order No. EA-12-049 RS-14-015 February 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

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

References:

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

Revision 0, dated August 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 25, 2012
5. Exelon Generation Cornpany, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28,2013 (RS-13-025)
6. Exelon Generation Company, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28,2013 (RS-13-129)
7. NRC letter to Exelon Generation Company, LLC, Quad Cities Nuclear Power Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF1048 and MF1049), dated November 22,2013

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 28,2014 Page 2 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. Reference 5 provided the Quad Cities Nuclear Power Station, Units 1 and 2 overall integrated plan.

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

As described in Reference 5, full implementation of NRC Order EA-12-049 required mitigation strategies is dependent upon implementation of reliable hardened containment venting capability established in accordance with NRC Order EA-12-050. NRC Order EA-13-109 issued by the NRC on June 6, 2013, rescinded the requirements of Order EA-12-050 and established revised schedule timelines and implementation dates for reliable hardened containment vents capable of operation under severe accident conditions. The revised schedule and implementation timeline contained in Order EA-13-109 delays the ability to achieve full implementation of the mitigation strategy requirements of Order EA-12-049. This need for relaxation from the implementation requirements of Order EA-12-049 is described in Section 5 of the enclosed update report. The request for relaxation of the full implementation schedule requirements of Order EA-12-049 will be submitted separately.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28 th day of February 2014.

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 28, 2014 Page 3 Respectfully submitted, Glen T. Kaegi Director - licensing & egulatory Affairs Exelon Generation Company, LLC

Enclosure:

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

Enclosure Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (13 pages)

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

2 Milestone Accomplishments None have been completed since the last update, several have been started.

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

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

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

Update 1 Aug 2013 Complete Complete with Update 2 Feb 2014 this submittal Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started Page 1 of 13

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Target Revised Target Milestone Completion Activity Status Completion Date Date Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started See Section 5 of Submit Completion Report Not Started this enclosure.

Modifications Development &

Implementation:

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

Unit 1 Modification Implementation (All Apr 2015 Not Started Mar 2015 FLEX Phases)

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

Unit 2 Modification Implementation (All Apr 2016 Not Started FLEX Phases)

Procedures:

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

Apr 2015 Not Started Mar 2015 11.4.3)

Create Maintenance Procedures Apr 2015 Not Started Mar 2015 Perform Staffing Analysis Nov 2014 Started Storage Plan and Construction Apr 2015 Started Mar 2015 FLEX Equipment Acquisition Apr 2015 Started Mar 2015 Training Completion Apr 2015 Not Started Mar 2015 Regional Response Center Operational Dec 2014 Started Started March 2015 See Unit 1 FLEX Implementation Apr 2015 Section 5 of this enclosure.

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

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

Page 2 of 13

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28,2014 4 Changes to Compliance Method (OIP pages 5, 6, 11 and 12) Detailed in the OIP, Timeline item 16 and pages 11 and 12, Reactor Water Level control discusses suppression chamber (SC) water temperature limits on RCIC turbine-pump operation. The SC temperature limit for continued RCIC operation changed from 230°F to 240° F when maintaining maximum turbine speed and minimum bearing clearance and analysed in Reference 5.

(alP pages 13, 14, 17) Additional Key Reactor Parameters have been identified external to the Control Room (remote locations) that can be utilized if necessary. These instruments are: Reactor Water Level-LI 1(2)-263-59A, 2201(2)-5 instrument rack; LI 1(2)-263-59B, 2201(2)-6 instrument rack; LI 1(2)-263-151A, 2201(2)-7 instrument rack and LI 1(2)-263-151 B, 2201(2)-8 instrument rack; Reactor Pressure - PI 1(2)-263-60A, 2201 (2)-5 instrument rack; PI 1(2)-263-60B, 2201(2)-6 instrument rack and PI 1(2)-1291-49,2201 (2)-2 instrument rack.

Two seismically protected independent deep wells will provide makeup water via hoses to either of the two RHR system Storz connections. Either one of the two wells will provide clean water to both units.

These full-capacity FLEX deep well pumps will be powered by a portable diesel powered generator, which will be stored in the FLEX storage building. Both wells will be protected from high winds and Local Intense Precipitation (LIP) flood levels. One of the wells will be at an elevated location for use in a maximum flood response. In the event of the loss of downstream river dam and many of the other initiating events, these pumps will be utilized to assure all FLEX response water requirements are met.

(alP page 15) The second Storz connection design has changed from the alP, pages 15,25, 17 and 26.

The second Storz connection location is to be installed on each unit's condensate transfer system piping, which is normally used to refill the RHR system following system piping draining for maintenance.

Located on the ground floor (595') reactor building on the central wall between Units 1 and 2, the piping provides multiple fill points to both loops of the RHR system. Functioning like the original, this connection will allow supplying water to both the RPV and the Suppression Chamber. Hose routing to this connection point will not require use of the stairwell to access second floor (623') of the reactor building. This connection will no longer be located above the maximum flood level (change to Flooding section on pages 18,27,36 and 44); however, the Quad Cities river flood strategy does not solely rely on use of this connection and necessary connections will be made prior to reaching the maximum flood level.

This connection is located in the Reactor Building. (See revised Attachement 3, Conceptual sketch.)

(alP page 23,26) Modification changes to the Severe Accident Capable Vent per NRC Order Number EA-13-109 are in conceptual phase; further detail will be provided in a subsequent six-month update.

(alP page 23, 26) For Key Containment Parameters, DW pressure instrument 1(2)-1001-100 on instrument rack 2201(2)-5 is added.

(alP page 25) Suppression Pool Makeup: Suppression Pool makeup can also be supplied by the FLEX deep well pumps similar to the RPV makeup, via the existing A RHR loop connection or new Condensate Transfer to RHR system connection.

Page 3 of 13

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status RepOlt for the Implementation of FLEX February 28, 2014 (OIP page 34) The Spent Fuel Pool Makeup strategy has changed. A Storz connection will be added to the Unit 1 Fuel Pool assist located in the Reactor Building ground floor (595') and the lower connection to bypass the fuel pool assist spool piece has been deleted. This will allow connections of FLEX pump or previously discussed FLEX deep well pump directly to the Fuel Pool assist piping for addition of water for makeup to the spent fuel pools. The Fuel Pool Assist piping will be treated as an alternate path. The primary and seismic path will be through the use of hoses to add water to the fuel pool.

(OIP page 41) For Key Parameters, battery voltage local indicators U1(2) 125 VDC Dist panel cubicle COl, U1(2) 250 VDC Dist panel B01 are added.

(OIP page 42) The Quad Cities OIP utilized staged diesel generators with connections via the 480V Switchgear. This connection method was changed to add 480V Diesel Generator connection points to the Switchgear for connection of pOltable Diesel Generators to repower the 480V AC distribution system. The 480V Diesel Generators will be deployed from the FLEX storage building and will make connections to the Switchgear via pOltable cables.

5 Need for ReliefIRelaxation and Basis for the ReliefIRelaxation NRC Order EA-12-049 (Reference 2) requires implementation of Mitigation Strategies to include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies. The Overall Integrated Plan (Reference 1) provided the Quad Cities Station response to the NRC Order EA-12-049. The cover letter identifies that delays in implementing the Hardened Containment Vent System as required by NRC order EA-13-109 will also affect implementation of the Mitigation Strategies Order EA-12-049 actions. The Reference 1 enclosure describes the Quad Cities Station Mitigation Strategies that is based on venting the containment using the Hardened Containment Vent System. It also describes that a modification to install a Hardened Containment Vent System (HCVS) is required. Thus the Quad Cities Station NRC Order EA-12-049 response provided in Reference I was premised on installation and use of a Hardened Containment Vent System as required by NRC Order EA-12-050.

Upon issuance of NRC Order EA-13-1 09 (Reference 3), the NRC staff changed technical and schedule requirements applicable to the Hardened Containment Vent System and rescinded the requirements of the NRC Order EA-12-050. As a result, full compliance to the Mitigation Strategies required by NRC Order EA-12-049 and described in Reference 1 for Quad Cities Station Units 1 and 2 will not be achieved until compliance to NRC Order EA-13-109 is achieved. Therefore, relaxation from the Mitigation Strategies (FLEX) full implementation date, as specified in NRC Order 12-049, Section IV.A.2 requirements is needed. The associated request for relaxation (including the need and basis) is being submitted separatel y.

The FLEX equipment and modifications required to implement the mitigation strategies required by NRC Order EA-12-049 will be completed and available for use in accordance with the implementation schedule requirements specified in NRC Order EA-12-049 except (per the upcoming request for relaxation) primary containment wetwell (torus) venting capability. Until full containment wetwell venting capability is installed to meet the requirements of NRC Order EA-13-109, Quad Cities Nuclear Page 4 of 13

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Power Station, Units 1 and 2 will maintain the current primary containment venting strategy in accordance with existing Emergency Operating Procedures.

In summary, the Quad Cities Overall Integrated Plan for Mitigation Strategies (Reference 1) will be met as planned and scheduled, except for areas impacted by the NRC Order EA-13-109 on the Hardened Containment Vent System, which will be discussed in the request for relaxation being submitted separately.

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

Section Overall Integrated Plan Open Item Status Reference Sequence of 1. The times to complete actions in the Not Started Events (p. 4) Events Timeline are based on operating judgment, conceptual designs, and current supporting analyses. The final timeline will be time validated once detailed designs are completed and procedures are developed, and the results will be provided in a future six-month update.

Sequence of 2. Issuance of BWROG document NEDC- Completed Events (p. 33771 P, "GEH Evaluation of FLEX 4,5) Implementation Guidelines," on 0 1/31/20 13 did not allow sufficient time to perform the analysis of the deviations between Exelon's engineering analyses and the analyses contained in the BWROG document prior to submittal of this Integrated Plan. This analysis is expected to be completed, documented on Attachment lB, and provided to the NRC in the August 2013 six-month status update.

Sequence of 3. Additional work will be performed Started Events (p. 6) during detailed design development to ensure Suppression Pool temperature will support RCIC operation, in accordance with approved BWROG analysis, throughout the event.

Page 5 of 13

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Section Overall Integrated Plan Open Item Status Reference Sequence of 4. Initial calculations were used to Started Events (p. 7) determine the fuel pool timelines. Formal calculations will be performed to validate this information during development of the Spent Fuel Pool Cooling strategy detailed designs, and will be provided in a future six-month update.

Multiple 5. Procedures and programs will be Started Sections developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Quad Cities Programmatic 6. Quad Cities Nuclear Power Station will Started controls (p. 8) implement an administrative program for FLEX to establish responsibilities, and testing and maintenance requirements.

Multiple 7. Detailed designs based on the current Started Sections conceptual designs will be developed to determine the final plan and associated mitigating strategies. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06.

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

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

Page 6 of 13

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Section Overall Integrated Plan Open Item I Status Reference Maintain 9. Evaluation of the spent fuel pool area for Started Spent Fuel steam and condensation has not yet been Pool performed. The results of this evaluation Coooling and the vent path strategy, if needed, will be Phase 1 provided in a future six-month update.

(p.32)

Safety 10. Habitability conditions will be Started Function evaluated and a strategy will be developed Support (p. to maintain RCIC habitability 42)

Safety 11. Habitability conditions will be Started Function evaluated and a strategy will be developed Support (p. to maintain Main Control Room

42) habitability.

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

43) required.

Safety 13. Fuel Oil Supply to Portable Equipment: Started Function A detailed fuel oil supply plan will be Support (p. developed.

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

(p.59)

Section Draft Safety Evaluation / Audit Questions Status Reference Open Item 3.2.3.A SIGNIFICANT OPEN Item. Generic On January 9, 2014, the NRC informed concern related to adoption of Revi sion 3 to NEI that changes to the containment the BWROG EPG/SAG [Emergency venting strategies as described in the Procedure Guidelines/Severe Accident BWROG information report "BWR Guidelines] relating to potential detrimental Containment Venting" Revision 1 dated effects on containment response. 1012912013 are acceptable for Order EA-12-049. Completed 3.2.4.6.A OPEN Item Licensee asserts 120 OF used Started for habitability in SBO is adequate for FLEX. Habitability of the control room should consider 110 degree F tempt!rature Page 7 of 13

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 limits of NUMARC 87-00 and MIL-STD-1472C.

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

3.4.B OPEN Item Details not provided to Quad Cities has established a contract demonstrate the minimum capabilities for with Pooled Equipment Inventory offsite resources will be met per NE112-06 Company (PEICo) and has joined the Section 12.2.

Strategic Alliance for FLEX Emergency Response (SAFER) Team Equipment Committee for off-site facility coordination. The contract with SAFER addresses items in NEI 12-06 section 12.2.

Completed 3.l.1.2.A Confirmatory Item Studies for liquefaction Started and the effects on haul paths and storage location(s) are not complete.

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

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

3.l.1.3.A Confirmatory Item Plans for strategies have Started insufficient information to demonstrate alternate sources of instrument readings and adequate tolerances/accuracies if there is seismic impact to primary sources. Also, need identification of installed instrumentation location and power source.

3.1.1.3.B Confirmatory Item Need identification of Started instrumentation used to monitor FLEX electrical power equipment including measurement tolerance/accuracy.

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

3.1.3.2.A Confirmatory Item Completion of Started development of an administrative program to ensure pathways remain clear or compensatory actions will be implemented to ensure all strategies can be deployed during all modes of operation. Procedures Page 8 of 13

Quad Cities Nuclear Power Station, Units I and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 and programs are to be developed.

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

3.2.1.l.A Confirmatory Item Need benchmarks to StaIied demonstrate Modular Accident Analysis Program (MAAP)4 is the appropriate code for simulation of ELAP.

3.2.1.1.B. Confirmatory Item The collapsed level StaIted must remain above Top of Active Fuel (TAF) and the cool down rate must be within technical specification limits in the MAAP4 analysis.

3.2.1.1.C. ConfirmatOlY Item MAAP4 must be used Started in accordance with Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper.

3.2.1.1.D. Confirmatory Item In using MAAP4, the Started licensee must identify and justify the subset of key modeling parameters cited from Tables 4-1 through 4-6 of the "MAAP4 Application Guidance, Desktop Reference for Using MAAP4 Software, Revision 2" (Electric Power Research Institute Report 1020236).

3.2.1.1.E. Confirmatory Item The specific MAAP4 Started analysis case that was used to validate the timing of mitigating strategies in the integrated plan must be identified and available on the e-Portal for NRC staff to view. Alternately, a comparable level of information may be included in the s~~ementalresponse.

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

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

Page 9 of 13

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 3.2.1.3.B. Confirmatory Item Licensee plans further Started review and analysis to ensure suppression pool temperature will support RCIC operation.

3.2.1.3.C. Confirmatory Item Need identification of The minimium design voltages for the DC the minimum voltage required for the dc battery systems are 105V for the 125 VDC buses and the basis of that determination. system and 210 V for the 250 VDC system. This is provided in the Quad Cities Technical Specifications B 3.8.4 DC Sources-Operating Completed 3.2.1.4.A. Confirmatory Item Water quality issue and Started guidance on priority of water source usage need to be addressed.

3.2.1.4.B. Confirmatory Item Need completion of Started cunent evaluation of FLEX generator sizing calculation.

3.2.1.4.C. Confirmatory Item Need design and Started working pressure of hoses and fittings.

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

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

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

3.2.4.2.A. Confirmatory Item Modifications to restore Started RCIC room cooling are being developed by the licensee.

3.2.4.2.B. Confirmatory Item Modifications to restore Started ventilation to the battery rooms via use of the portable FLEX generators to address hydrogen and cold weather are being developed by the licensee.

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

3.2.4.4.B. Confirmatory Item Confirm upgrades to Started communication system that resulted from the licensee communications assessment.

(ADAMS Accession Nos. ML12306A199 and ML13056A135.)

Page 10 of 13

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 3.2.4.5.A. Confirmatory Item Verify completion of Started drafted procedures for protected and internal locked area access.

3.2.4.6.B. Confirmatory Item Site industrial Procedure SA-AA-111 HEAT STRESS procedures and identification of protective CONTROL addresses use of protective clothing, ice vests/packs, bottled water, etc. clothing, cooling garments and water use is needed.

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

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

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

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

3.4.A. Confirmatory Item Procedures for interface Started with the RRC need to be developed.

7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

Page 11 of 13

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Quad Cites Overall Integrated Plan in Response to March 12,2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28,2013.
2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012.
3. NRC Order EA-13-109, "Issuance of Order to Modify Licenses with Regard to reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6,2013.
4. Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated August 28,2013.
5. RCIC Pump and Turbine Durability Evaluation - Pinch Point Study, February 2013, 0000-0155-l545-RO, DRF 0000-0155-1541, Revision 0
6. Quad Cities Nuclear Power Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NOS.MF 1048 and MF 1049), dated November 22,2013.

9 Attachments OIP Attachment 3 - Revised Conceptual Sketch Page 12 of 13

Quad Cities Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of FLEX February 28, 2014 Attachment 3 Concvplual Sketcbes

- .<1""".

I~M

-..~.

""~ "," ~

~'" ..,w.

~'M".~

. II.... CfOII.

.. I III ~.~

_ ....... 1:11)

II MII _ _

--,~'

.. ~_._J!l ... __ ~_-, M~__ ~~_ _._

'... ~/

- ... 1.

0II0_t..

.~

It_a I.f.liW.ft t::Qt1 ..... f:I&lllIId.l4lt

.... ".u.DIIM1'.~'""

..,.CIQ"'.QtE n.t:X1(U,CIW'IW

.... WWtalt:mi'4f:UJr:.tIII Page 13 of 13

Retrieved from "https://kanterella.com/w/index.php?title=RS-14-015,_Second_Six-Month_Status_Report_in_Response_to_March_12,_2012_Commission_Order_Modifying_Licenses_with_Regard_to_Requirements_for_Mitigation_Strategies_for_Beyond_Design-Basis_External_Events_(Order_No._EA-12-049)&oldid=2453697"