Text

Fifth 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.
	ML15240A314
Person / Time
Site:	Quad Cities
Issue date:	08/28/2015
From:	Kaegi G; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, RS-15-215
	Download: ML15240A314 (41)
	v • d • e

Exeton Generation.,

Order No. EA-12-049 RS-1 5-215 August 28, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Fifth 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-1 2-049, "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-201 2-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 25, 2012

5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (RS-1 3-025)

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-1 2-049), dated August 28, 2013 (RS-13-129)

7. Exelon Generation Company, LLC Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1 2-049), dated February 28, 2014 (RS-14-015)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-1 2-049 August 28, 2015 Page 2

8. Exelon Generation Company, LLC Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1 2-049), dated August 28, 2014 (RS-14-213)

9. Exelon Generation Company, LLC Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1 2-049), dated February 27, 2015 (RS-15-024)

10. 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. M171 048 and MF1 049), dated November 22, 2013

11. NRC letter to Exelon Generation Company, LLC, Quad Cities Nuclear Power Station, Units 1 and 2 Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-1 2-049 and EA-12-051 (TAC Nos. MF1 048, MF1 049, MF1 052, and MF1 053), dated June 25, 2015 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 Attachment 2 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. References 6, 7, 8, and 9 provided the first, second, third, and fourth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Quad Cities Station. The purpose of this letter is to provide the fifth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation Open and Confirmatory Items contained in Reference 10, and any NRC Audit Report open items contained in Reference 11.

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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-1 2-049 August 28, 2015 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of August 2015.

Respectfully submitted, 77 Glen T. Kaegi Director Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

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

Enclosure Quad Cities Nuclear Power Station, Units 1 and 2 Fifth 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 (37 pages)

Enclosure Quad Cities Nuclear Power Station, Units 1 and 2 Fifth 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 I 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 The Unit One Modifications have been completed since the last update. All Non-outage Unit Two Modifications have been completed since the last update.

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

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

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

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Complete Update 5 Aug 2015 Complete with Page 1 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Target Revised Target Milestone Completion Activity Status Completion Date Date this submittal Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started Modifications Development &

Implementation:

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

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

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

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

Common Unit Modification Development (Interim Storage Pads and Mar 2015 Started Dec 2015 Deep Well)

Common Unit Modification Implementation (Interim Storage Pads Mar 2015 Started Dec 2015 and Deep Well)

Robust Storage Building Oct 2015 Started ASCE 7-10 FLEX +1 Storage Building Apr 2016 Started Procedures:

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

Apr 2015 Completed Mar 2015 11.4.3)

Create Maintenance Procedures Apr 2015 Completed Mar 2015 Perform Staffing Analysis Nov 2014 Completed Storage Plan and Construction Apr 2015 Started April 2016 FLEX Equipment Acquisition Apr 2015 Completed Mar 2015 Training Completion Apr 2015 Completed Mar 2015 National SAFER Response Center Completed Dec 2014 Operational Page 2 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Target Revised Target Milestone Completion Activity Status Completion Date Date Apr 2017 Unit 1 FLEX Implementation Apr 2015 Started See Section 5 of this enclosure.

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

June 2017 Submit Unit 1 Compliance Report June 2015 Not Started See Section 5 of this enclosure.

June 2018 Submit Unit 2 Compliance Report June 2016 Not Started See Section 5 of this enclosure.

4 Changes to Compliance Method The timeline submitted with the Fifth Six-Month update has been modified based on adjustment of critical times and debris removal. The timeline is enclosed in Attachment 1.

Change 1- Interim FLEX Equipment Storage Alternative Approach:

General Integrated Plan Elements BWR Requirement:

Extent to which the guidance, JLD-ISG-20 12-01 and NEI 12-06, are being followed. Identify any deviations to JLD-ISG-2012-01 and NEI 12-06. The allowed unavailability time requirements are stated in NEI 12-06, Section 11.5.3 and described as: "The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy for core, containment, and SFP should be managed such that risk to mitigating strategy capability is minimized."

Reason for Change:

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

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

Unavailability Alternate Approach

1. The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy for core, containment, and SFP should be managed such that risk to mitigating strategy capability is minimized.

a. The unavailability of plant equipment is controlled by existing plant processes such as the Technical Specifications. When plant equipment which supports FLEX strategies becomes unavailable, then the FLEX strategy affected by this unavailability does not need to be maintained during the unavailability.

b. The required FLEX equipment may be unavailable for 90 days provided that the site FLEX capability (N) is met. If the site FLEX (N) capability is met but not fully protected for the site's applicable hazards, then the allowed unavailability is reduced to 45 days.

c. Connections to plant equipment required for FLEX strategies can be unavailable for 90 days provided the remaining connection remains available such that the site FLEX strategy is available.

d. If FLEX equipment is likely to be unavailable during forecast site specific external events (e.g., flooding), appropriate compensatory measures should be taken to restore equivalent capability in advance of the event.

e. The duration of FLEX equipment unavailability, discussed above, does not constitute a loss of reasonable protection from a diverse storage location protection strategy perspective.

f. If FLEX equipment or connections becomes unavailable such that the site FLEX capability (N) is not maintained, initiate actions within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the site FLEX capability (N) and implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

g. If FLEX equipment or connections to permanent plant equipment required for FLEX strategies are unavailable for greater than 45/90 days, initiate actions to restore the FLEX capability and implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) prior to exceeding the 45/90 days.

Basis for an Alternate Approach:

The interim storage pad design requires use of two separate storage pads separated by a large distance. The lower pad is designed to withstand the seismic event, while the upper pad travel path is not analyzed for seismic capabilities. As a result, the upper pad may become unavailable for accessing FLEX equipment during a seismic event; therefore, the Alternate Approach described herein for a reduced Unavailability Time applied to the interim storage pad equipment will be used to compensate for the upper pad not being analyzed for seismic capabilities. If the remaining N equipment is not protected from the applicable hazards, instead of the 90-day allowed out of service time, an allowed out of service time of 45 days will apply. This is based on 6-week short cycle work scheduling. This will allow the station to continue to manage work associated with equipment important to safety. Placing the FLEX equipment into the site work schedule at the 6-week period still allows proper planning and resource loading while Page 4 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 maintaining schedule compliance and stability. This action will not cause the station to be distracted from other scheduled work.

The probability of an event causing an ELAP and loss of the UHS is low, and reducing the allowed unavailability time will further reduce the probability of an event during this period. Therefore, it is reasonable to expect equipment availability during periods when it is required.

Change 2 Storage, Maintenance and Testing Alternate Approach:

Exelon proposes an alternate approach to NEI 12-06, Revision 0 for protection of FLEX equipment as stated in Section 5.3.1 (seismic,) Section 7.3.1 (severe storms with high winds), and Section 8.3.1 (impact of snow, ice and extreme cold). This alternate approach will be to store "N" sets of equipment in a fully robust building and the +1 set of equipment in a commercial building. For all hazards scoped in for the site, the FLEX equipment will be stored in a configuration such that no one external event can reasonably fail the site FLEX capability (N).

To ensure that no one external event will reasonably fail the site FLEX capability (N), Exelon will ensure that N equipment is protected in the robust building. To accomplish this, Exelon will develop procedures to address the unavailability allowance as stated in NEI 12-06, Revision 0, Section 11.5.3., (see Maintenance and Testing section below for further details). This section allows for a 90-day period of unavailability. If a piece of FLEX equipment stored in the robust building were to become or found to be unavailable, Exelon will impose a shorter allowed outage time of 45 days. For portable equipment that is expected to be unavailable for more than 45 days, actions will be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of this determination to restore the site FLEX capability (N) in the robust storage location and implement compensatory measures (e.g., move the +1 piece of equipment into the robust building) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months where the total unavailability time is not to exceed 45 days. Once the site FLEX capability (N) is restored in the robust storage location, Exelon will enter the 90-day allowed out of service time for unavailable equipment with an entry date and time based on the discovery date and time.

MAINTENANCE AND TESTING

1. The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy for core, containment, and SFP should be managed such that risk to the mitigating strategy capability is minimized.

a. The unavailability of plant equipment is controlled by existing plant processes such as the Technical Specifications. When plant equipment which supports FLEX strategies becomes unavailable, then the FLEX strategy affected by this unavailability does not need to be maintained during the unavailability.

b. The required FLEX equipment may be unavailable for 90 days provided that the site FLEX capability (N) is met. If the site FLEX (N) capability is met but not protected for all of the site's applicable hazards, then the allowed unavailability is reduced to 45 days.'

The spare FLEX equipment is not required for the FLEX capability to be met. The allowance of 90-day unavailability is based on a normal plant work cycle of 12 weeks. In cases where the remaining N equipment is not fully protected for the applicable site hazards, the unavailability allowance is reduced to 45 days to match a 6-week short cycle work period. Aligning the unavailability to the site work management program is important to keep maintenance of spare FLEX equipment from inappropriately superseding other more risk-significant work activities.

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Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015

c. The duration of FLEX equipment unavailability, discussed above, does not constitute a loss of reasonable protection from a diverse storage location protection strategy perspective.

d. If FLEX equipment or connections become unavailable such that the site FLEX capability (N) is not maintained, initiate actions within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the site FLEX capability (N) and implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

e. If FLEX equipment or connections to permanent plant equipment required for FLEX strategies are unavailable for greater than 45/90 days, restore the FLEX capability or implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) prior to exceeding of the 45/90 days.

For Section 5, seismic hazard, Exelon will also incorporate these actions:

1. Large portable FLEX equipment such as pumps and power supplies should be secured as appropriate to protect them during a seismic event (i.e., Safe Shutdown Earthquake (SSE) level).

2. Stored equipment and structures will be evaluated and protected from seismic interactions to ensure that unsecured and/or non-seismic components do not damage the equipment.

For Section 7, severe storms with high winds, Exelon will also incorporate this action:

For a 2-unit site, 3 sets (N+l) of on-site FLEX equipment are required. The plant screens in per Sections 5 through 9 for seismic, flooding, wind (both tornado and hurricane), snow, ice and extreme cold, and high temperatures.

o To meet Section 7.3.1.1.a, either of the following are acceptable:

o All three sets (N+l) in a structure(s) that meets the plant's design basis for high wind hazards, or o Two sets (N) in a structure(s) that meets the plant's design basis for high wind hazards and one set (+1) stored in a location not protected for a high wind hazard.

For Section 8, impact of snow, ice and extreme cold, Exelon will also incorporate this action:

Storage of FLEX equipment should account for the fact that the equipment will need to function in a timely manner. The equipment should be maintained at a temperature within a range to ensure its likely function when called upon. For example, by storage in a heated enclosure or by direct heating (e.g., jacket water, battery, engine block heater, etc.).

Exelon will meet all of the requirements in NET 12-06, Revision 0 for Section 6.2.3.1 for external flood hazard and Section 9.3.1 for impact of high temperatures.

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Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Change 3 N+1 Hoses and Cables Alternative Approach:

Issue:

An alternative is being proposed to the N+1 requirement applicable to hoses and cables as stated in Section 3.2.2 of NET 12-06.

Background

NET 12-06, Section 3.2.2 specifically states that a site will have FLEX equipment to meet the needs of each unit on a site plus one additional spare. This is commonly known as N+1 where N is the number of units at a given site. The relevant text from NET 12-06 is as follows:

NET 12-06, Section 3.2.2 states:

"In order to assure reliability and availability of the FLEX equipment required to meet these capabilities, the site should have sufficient equipment to address all functions at all units on-site, plus one additional spare, i.e., an Ni-i capability, where "N" is the number of units on-site. Thus, a two-unit site would nominally have at least three portable pumps, three sets of portable ac/dc power supplies, three sets of hoses & cables, etc."

NET 12-06, Section 11.3.3 states:

"FLEX mitigation equipment should be stored in a location or locations informed by evaluations performed per Sections 5 through 9 such that no one external event can reasonably fail the site FLEX capability (N)."

Typically the hoses utilized to implement a FLEX strategy are not a single continuous hose but are composed of individual sections of a smaller length joined together to form a sufficient length. In the case of cables, multiple individual lengths are used to construct a circuit such as in the case of 3-phase power.

Alternative:

NET 12-06 currently requires N+1 sets of hoses and cables. As an alternative, the spare quantity of hose and cable is adequate if it meets either of the two methods described below:

Method 1: Provide additional hose or cable equivalent to 10% of the total length of each type/size of hose or cable necessary for the "N" capability. For each type/size of hose or cable needed for the "N" capability, at least 1 spare of the longest single section/length must be provided.

Example 1-1: An installation requiring 5,000 ft. of 5 in. diameter fire hose consisting of one hundreds 50 ft. sections would require 500 ft. of 5 in. diameter spare fire hose (i.e., ten 50 ft.

sections).

Example 1-2: A pump requires a single 20 ft. suction hose of 4 in. diameter, its discharge is connected to a flanged hard pipe connection. One spare 4 in. diameter 20 ft. suction hose would be required.

Example 1-3: An electrical strategy requires 350 ft. cable runs of 4/0 cable to support 480 volt loads. The cable runs are made up of 50 ft. sections coupled together. Eight cable runs (2 Page 7 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 cable runs per phase and 2 cable runs for the neutral) totaling 2800 ft. of cable (56 sections) are required. A minimum of 280 ft. spare cable would be required or 6 spare 50 ft. sections.

Example 1-4: An electrical strategy requires 100 ft. of 4/0 cable (4 cables, 100 ft. each) to support one set of 4 kv loads and 50 ft. of 4/0 (4 cables, 50 ft. each) to support another section of 4 kv loads. The total length of 4/0 cable is 600 ft. (100 ft. x 4 plus 50 ft. x 4). One spare 100' 4/0 cable would be required representing the longest single section/length.

Method 2: Provide spare cabling and hose of sufficient length and sizing to replace the single longest run needed to support any single FLEX strategy.

Example 2-1 A FLEX strategy for a two unit site requires 8 runs each of 500 ft. of 5 in.

diameter hose (4000 ft. per unit). The total length of 5 in. diameter hose required for the site is 8000 ft. with the longest run of 500 ft. Using this method, 500 ft. of 5 in. diameter spare hose would be required.

For either alternative method, both the N sets of hoses or cables and the spare set of hoses or cables would all be kept in a location that meets the reasonable protection requirements for the site.

Basis for an alternative approach:

The NRC has endorsed (ML15125A442) the NET position paper (ML15126A135) for the above stated alternate approach. If using Method 2, per the endorsement letter, Exelon will ensure that the FLEX pumps and portable generators are confirmed to have sufficient capability to meet flow and electrical requirements when a longer spare hose/cable is substituted for a shorter length. Exelon acknowledges the NRC staff has not reviewed and is not endorsing the specific examples included in the NET endorsement request dated May 1, 2015.

Hoses and cables are passive devices unlikely to fail provided they are appropriately inspected and maintained. The most likely cause of failure is mechanical damage during handling provided that the hoses and cables are stored in areas with suitable environmental conditions (e.g., cables stored in a dry condition and not subject to chemical or petroleum products). The hoses and cables for the FLEX strategies will be stored and maintained in accordance with manufacturers' recommendations including any shelf life requirements. Initial inspections and periodic inspections or testing will be incorporated in the site's maintenance and testing program implemented in accordance with Section 11.5 of NET 12-06.

Therefore, the probability of a failure occurring during storage is minimal, resulting in the only likely failure occurring during implementation. Mechanical damage will likely occur in a single section versus a complete set of hose or cable. Therefore, the N+l alternative addresses the longest individual section/length of hose or cable.

Providing either a spare cable or hose of a length of 10% of the total length necessary for the "N" capability or alternatively providing spare cabling or hose of sufficient length and sizing to replace the single longest run needed to support any single FLEX strategy is sufficient to ensure a strategy can be implemented. Mechanical damage during implementation can be compensated for by having enough spares to replace any damaged sections with margin. It is reasonable to expect that an entire set of hoses or cables would not be damaged provided they have been reasonably protected.

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Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Change 4 Seismic Water Source Alternative Approach Issue The station is designing and installing a single Deep Well as a seismically qualified source of water for the FLEX mitigation strategy. This single Deep Well is fully capable of supplying both Units 1 and 2 FLEX requirements simultaneously. Schedule relief for this well has been approved under References 13, 14 and 15. This configuration does not utilize a redundant seismic deep well. As such, Quad Cities will implement an Alternate Approach to meet the Order for allowed unavailability time on the single seismic deep well.

Background

Since only one deep well is being installed, this alternative approach provides the actions that will occur upon unavailability of this deep well during maintenance and testing, or its unavailability during a FLEX event response. The plant circulating water discharge bay will be utilized as a source of backup water during deep well unavailablilty periods. The discharge bay has not been seismically evaluated but there is reasonable assurance that this water supply will remain available as a source of water following a seismic event due to the size of the two diffuser pipes which connect to the main channel of the Mississippi River.

To the extent to which the guidance of JLD-ISG-2012-01 and NET 12-06 is being followed, deviations should be identified. The allowed unavailability time requirements are stated in NET 12-06, Section 11.5.3 and are described as: "The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy for core, containment, and SFP should be managed such that risk to mitigating strategy capability is minimized." As such, this alternative approach is an acceptable deviation from the guidance of JLD-ISG-2012-01 and NET 12-06 as described below.

Alternative Unavailability Alternate Approach (Consistent with NEI 12-06, Section 11.5.3)

1. The unavailability of the seismic deep well equipment and applicable connections that directly performs a FLEX mitigation strategy for core, containment, and SFP should be managed such that risk to mitigating strategy capability is minimized.

a. The unavailability of installed plant equipment is controlled by existing plant processes such as the Technical Specifications (TS). When installed plant equipment which supports FLEX strategies becomes unavailable, then the FLEX strategy affected by this unavailability does not need to be maintained during the unavailability.

b. The required seismic deep well equipment may he unavailable for 90 days provided that the site seismic water supply capability is met. If the site seismic water supply capability is met but not fully protected for the site's applicable hazards, then the allowed unavailability is reduced to 45 days.

If seismic deep well equipment or connections becomes unavailable such that the site seismic water supply capability is not maintained, initiate actions within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the site Page 9 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 seismic water supply capability and implement compensatory measures (ensure equipment for use of the discharge bay water supply is ready for deployment) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and then initiate a concurrent 45-day period to repair the seismic well to full availability.

d. If seismic deep well permanently installed equipment required for FLEX strategies are expected to be unavailable for greater than 45 days, initiate actions to restore the seismic deep well capability and implement compensatory measures (e.g., use of alternate suitable equipment) prior to exceeding the 45 days.

Actions During a Seismic FLEX Event For an ELAP event with a seismic initiator the station will perform the following actions:

1. Phase 1 Actions:

Initiate RCIC for FLEX RPV water injection. RCIC will operate under these conditions for

> 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This will allow time for station staff to deploy Phase 2 FLEX strategies.

2. Phase 2:

Deploy FLEX generator to power the deep well for primary source of water for FLEX requirements for Suppression Chamber level control, Spent Fuel Pool level and Reactor Pressure Vessel water level control. The deep well pump is powered by one FLEX generator and the well is sufficient to provide water to both Units. Two additional FLEX generators are deployed, one per unit, to restore voltage to the 480V buses.

3. ERO Response Actions:

Following the initial stabilization actions for Phase 2, establish a backup water supply using a FLEX pump taking suction from the discharge bay.

Monitor the condition of Lock and Dam 14 for a potential failure and/or the discharge bay for level change that may be indicating a degradation of this source.

Upon indication or prediction of degradation of the discharge bay level, deploy a submersible pump with the suction placed in low point of the discharge bay with the discharge of the submersible pump connected to the FLEX pump suction to provide additional NPSH should the discharge bay level drop.

4. Continue to operate well pump or the submersible and FLEX pumps as required to supply the FLEX water needs.

Actions 1 4, above can be performed within the minimum time requirements needed for FLEX injection.

The discharge bay used in this strategy provides access for use of NSRC Phase 3 equipment as a backup to Phase 2 equipment and addresses indefinite coping time.

Actions During Maintenance or Testing Should the Deep Well Become Unavailable

1. Initiate actions to restore well pump within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. Verify FLEX and submersible pumps and necessary support components are ready for deployment and are protected from the seismic hazard. This contingency action is required to be completed within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

3. Restore well pump to operation within 45 days.

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Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Basis for An Alternative Approach During times when the single seismic deep well is unavailable, Quad Cities will compensate by use of an Alternate Approach which consists of a FLEX pump and portable submersible pump that will take suction from Quad Cities Station discharge bay. The discharge bay will supply the necessary backup water supply. Access to the river as a water source remains available during this event. This method provides a compensatory separate and diverse FLEX water supply, should the single seismic deep well become unavailable.

As a result, if the single seismic deep well becomes unavailable for a FLEX event (specifically a seismic event), the Alternate Approach described herein, will be utilized. This Approach applies a reduced Unavailability Time to the single seismic deep well which when coupled with the associated compensatory measures, will be used to compensate when the seismic deep is not available. If the equipment is not protected from the applicable hazards, instead of the NET recommended 90-day unavailability period, an allowed unavailability period of 45 days will apply. This is based on the 6-week short cycle work scheduling. This will allow the station to continue to manage work associated with equipment important to safety. Placing the seismic deep well equipment into the site work schedule at the 6-week period still allows proper planning and resource loading while maintaining schedule compliance and stability. This action will not cause the station to be distracted from other scheduled work.

The probability of an event causing an ELAP and loss of the UHS is low and reducing the allowed unavailability time will further reduce the probability of an event during this period. Therefore, it is reasonable to expect equipment availability during periods when it is required.

Supporting Plant Conditions Discharge Bay Water Level:

o Normal discharge bay and Mississippi River level is 572 feet controlled by downstream Lock and Dam 14.

o Per UFSAR 2.4.4, the minimum elevation of the discharge bay is 561 feet, should Lock and Dam 14 fail, which is the normal elevation downstream of Lock and Dam 14.

o Bottom elevation of discharge bay is 557 feet.

o Godwin FLEX pumps will provide the necessary water to a suction level of 565 feet which will be reached 90 hours0.00104 days 0.025 hours 1.488095e-4 weeks 3.4245e-5 months after the Lock and Dam 14 failure per UFSAR 2.4.4.

o At 565 feet or lower, the station plans to use a submersible booster pump to provide additional required NPSH for the FLEX Godwin pump.

Torus and Reactor:

o Per EC 395980 and calc QDC-1300-M-2074 analysis, the RCIC system pump will have sufficient NPSET and is capable of operation greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Spent Fuel Pool:

o From Calculation QDC-1900-M-2079 for a Full Core Offload time to 12 ft. above fuel is 31.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months and the time to 10 ft. is 38.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The more restrictive time of 31.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months will be utilized for this alternate approach.

Therefore, the shortest time that Phase 2 FLEX water injection is required is 31.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months based on Spent Fuel Pool water needs.

Page 11 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015

Discharge bay remains open to the river following the event. The diffuser piping (Two-16 ft.

pipes) remains open to allow sufficient backflow from the Mississippi River main channel to the discharge bay and remains open to the river following the event.

The discharge bay bottom elevation is 557 feet. The minimum water level is 561 feet which is consistent with the normal water level downstream of Lock and Dam 14, should it fail.

Therefore, a depth of 4 feet of usable water will remain available in the Discharge bay and will be maintained by open path to the Mississippi River main channel via the diffuser piping.

The discharge bay is expected to remain accessible following the event due to its construction that utilizes a sheet pile enclosure reinforced with rip-rap slope stabilization.

The discharge bay pump pad was designed and installed to be seismically robust.

The travel path to the discharge bay was evaluated for liquefaction.

The station stores one FLEX pump in the FLEX storage building and one FLEX pump in the ASCE 7-10 building.

The station will provide a booster pump or utilize the Dresden Station, diesel driven hydraulic submersible booster pump to provide the additional NPSH for the FLEX pump if the Discharge bay level continues to drop below or is expected to degrade below 565 feet.

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

By letter dated March 4, 2015 (Ref. 13) and supplemented by a letter dated March 6, 2015 (Ref. 14) Quad Cities Station requested schedule relaxation of the requirements of Order EA-12-049 (Ref. 2) related to the completion of installation of the mitigating strategies equipment and modifications to implement the strategies. The NRC granted the schedule relief via letter dated March 11, 2015 (Ref. 15).

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

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

I Section Overall Integrated Plan Open Item Status Reference Page 12 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Section Overall Integrated Plan Open Item Status Reference Sequence of 1. The times to complete actions in the Completed this update.

Events (p. 4) Events Timeline are based on operating Closed during Site FLEX Audit 1/29/15 judgment, conceptual designs, and current In the Sequence of Events timeline on page 56-59 of supporting analyses. The final timeline will the QC OIP, ERVs are used to control reactor be time validated once detailed designs are pressure through manual operation. Specifically completed and procedures are developed, steps 6, 10 and 19 are in alignment with the existing Emergency Operating Procedures, QUA 100 RPV and the results will be provided in a future Control and QGA 200 Primary Containment 6-month update. Control. As part of pressure control in the EOPs reactor pressure is first stabilized using ERVs (Timeline step 6), then a depressurization of the RPV is started (this is not time critical) with cool down rate limit specified of less than 100°F per hour (Timeline step 10), and finally a RVP Blow down is initiated when the Torus Heat Capacity Limit is reached (Timeline step 19). Step 19 is the only time critical step as explained on page 6 of the QC OIP. These steps were developed within the EOPs to provide procedural guidance to the operators to perform a controlled cool down of the RPV, less than 100°F per hour, and avoid a rapid depressurization of the RPV which is required if containment parameters warrant (the Heat Capacity Limit is reached). Step 10 of the timeline specifies less than or equal to 80 °F per hour to add margin.

Sequence of 2. Issuance of BWROG document NEDC- Completed See August 2013 Six-Month Events (p. 33771P, "GEH Evaluation of FLEX update 4,5) Implementation Guidelines," on 01/31/2013 did not allow sufficient time to perform the analysis of the deviations between Exelon's engineering analyses and the analyses contained in the BWROG document prior to submittal of this Integrated Plan. This analysis is expected to be completed, documented on Attachment 1 B, and provided to the NRC in the August 2013 Six-Month status update.

Sequence of 3. Additional work will be performed Completed See August 2014 Six-Month Events (p. 6) during detailed design development to update ensure Suppression Pool temperature will support RCIC operation, in accordance with approved BWROG analysis, throughout the event.

Page 13 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Section Overall Integrated Plan Open Item Status Reference Sequence of 4. Initial calculations were used to Completed See August 2014 Six-Month Events (p. 7) determine the fuel pool timelines. Formal update 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 6-month update.

Multiple 5. Procedures and programs will be Completed this update Sections developed to address storage structure Closed during Site FLEX Audit 1/29/15 requirements, haul path requirements, and QCOS 0050-02 FLEX Haul Path Inspection has FLEX equipment requirements relative to been drafted to inspect the areas both external to the the external hazards applicable to Quad buildings and internal that if blocked could hamper Cities the deployment of equipment in response to an ELAP event. Included are actions to be taken when the surveillance is found unsatisfactory. The debris removal equipment includes the plow on the F-750 truck, a 4 wheel drive tractor with a front bucket and battery and AC powered tools for cutting of debris for removal. Also there is additional hose and cable to allow traversing the debris if the capability of the P750 truck and/or tractor are exceeded.

Validation of deployment procedures is in progress and will provide times for non-debris deployment.

An assessment of these times will then determine what impact debris removal will have on overall completion times.

Programmatic 6. Quad Cities Nuclear Power Station will Complete this update controls (p. 8) implement an administrative program for The site FLEX Program Document which contains FLEX to establish responsibilities, and Preventative Maintenance and Surveillances has been completed.

testing and maintenance requirements.

Page 14 of 37

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

Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for Quad Cities Nuclear Power Station during a scheduled 6-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 Completed this update Core Cooling sufficient area is available for deployment Closed during Site FLEX Audit 1/29/15 Phase 1 and that haul paths remain accessible The approved QCOS 0050-02 for FLEX haul path (p.13) without interference from outage equipment deployment path inspection designates the area that during refueling outages. could affect the successful deployment of FLEX if required.

Maintain 9. Evaluation of the spent fuel pool area for Completed this update Spent Fuel steam and condensation has not yet been Closed during Site FLEX Audit 1/29/15 Pool Cooling performed. The results of this evaluation Phase 1 and the vent path strategy, if needed, will be EC 395698 has been installed and QCOP 0050-04 (p.32) provided in a future 6-month update. FLEX Refuel Floor Actions and QCOP 0050-05,06 provide direction for hose deployment and establishing restoration of water to the spent fuel pool.

Approved FSGs: QCOP 0050-04 FLEX Refuel Floor Actions, QCOP 0050-05 FLEX Hose Deployment, and QCOP 0050-06 FLEX RPV, Suppression Pool, Spent Fuel Pool Level Control, all have elements that support habitability of the area and actions to supply the SFPs with makeup.

Page 15 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Section Overall Integrated Plan Open Item Status Reference Safety 10. Habitability conditions will be Completed this update Function evaluated and a strategy will be developed Closed during Site FLEX Audit 1/29/15 Support (p. to maintain RCIC habitability.

Calculation 2014-02948, Reactor Building 42/

Temperature Analysis Resulting from Extended Loss of AC Power, has been approved under EC 400393. The implementing procedure is QCOP 0050-17, Rev. 0, issued 01/20/15. The following is from the EC Scope for EC 400393:

The results of calculation 2014-02948 show that the RCIC room will reach 150°F in approximately 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months . All analyzed BDBEEs except Localized Intense Precipitation (LIP) allow FLEX equipment deployment before this duration, and are thus bounded by this result. (Reference the FLEX Overall Integrated Plan and MAAP analysis QC-MISC-013.) A LIP event may prevent external equipment deployment up to 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months . These results assume doors opened to start natural circulation, which are already implemented in QCOP 0050-04.

There are no other compensating actions planned.

Note that even if Localized Intense Precipitation (LIP) were to prevent FLEX deployment for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , the ELAP is an extended version of the Station Blackout evaluated in NUMARC 87-00, Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Nuclear Power Plants. In Appendix G of that report, the topical report on the relevant equipment shows reasonable assurance of operability up to 180°F. Per the RB habitability study Appendix M, chart Ml, the RCIC Pump Room never reaches 180°F for the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the event that were analyzed. Based on this, there is reasonable assurance of RCIC operability throughout all BDBEEs.

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

42) habitability.

Page 16 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Section Overall Integrated Plan Open Item Status Reference Safety 12. Battery Room Ventilation: Alternate Completed this update Function ventilation will be provided to address Closed during Site FLEX Audit 1/29/15 Support (p. Hydrogen generation and cold weather, as

43) required. Calculation 2014-05860, Battery and Charger Room Heat Up for FLEX Evaluation, has been accepted by the site under EC 399874. The results report that battery electrolyte temperature reaches 67°F in Unit 1 in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and 65°F in Unit 2 in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Unit 1 will reach 65°F in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , which is enough time for FLEX deployment with no need for a compensating action to mitigate cold in Unit 1. This is reflected in Quad Cities FLEX Program document, EC 394892, Modify the Battery Room Exhaust Fan Electrical Supply from Emergency Lighting Cabinets, has been installed. Procedure QCOP 0050-10, FLEX Battery Room Ventilation, implements starting the fan, and displaced air is made up from the Turbine Building through the door to the Battery Room. The function of the fan is to prevent hydrogen buildup, and the modification allows powering the fan by a source that will survive a BDBEE.

Safety 13. Fuel Oil Supply to Portable Equipment: Completed this update.

Function A detailed fuel oil supply plan will be Closed during Site FLEX Audit 1/29/2015 Support (p. developed.

43) EC 399944, FLEX Fuel Oil Plan, has been approved as a detailed fuel oil supply plan. 4.Provide alternate cooling to the RCIC Completed this update.

1A Item 20 rooms. Procedure to be developed.

(p.59) Closed during Site FLEX Audit 1/29/2015 Procedure QCOP 0050-17, FLEX RCIC Room Cooler Lineup, has been issued and time validated per the NEI validation process.

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

the BWROG EPG/SAG [Emergency Closed during Site FLEX Audit 1/29/15 Procedure Guidelines/Severe Accident Guidelines] relating to potential detrimental On January 9, 2014, the NRC informed NEI (see effects on containment response. ML13358A206) that changes to the containment venting strategies as described in the BWROG information report "BWR Containment Venting" Page 17 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Revision 1, dated 10/29/13 (ML13352A061, ML13352A066, ML13352A079) are acceptable for Order EA-12-049 3.2.4.6.A OPEN Item Licensee asserts 120 °F used Completed this update for habitability in SBO is adequate for Closed during Site FLEX Audit FLEX. Habitability of the control room 1/29/2015 should consider 110 degree F temperature limits of NUMARC 87-00 and MIL-STD- Regarding a maximum temperature limit of 120 degrees F for habitability of the main control room, 1472C. the station is using 120 degrees F as the upper limit for the Control Room based on plant's current design and licensing basis for compliance to the SBO. Applicable discussion of this limit is documented in the SER for the SBO rule, dated December 11, 1990.

Quad Cities Station will employ a "Toolbox Approach" for coping with extreme temperatures during FLEX implementation. Examples of acceptable toolbox actions to cope with extreme temperatures are:

-Opening doors when room temperatures become elevated

-Rotation of personnel

-Use of ice vests, etc. when tasks are in high heat and humidity

-Utilizing small fans for air movement

-Warming/cooling in available vehicles

-Utilizing firefighting turn-out gear to cope with extreme low temperatures Procedure QCOP 0050-11, FLEX Control Room Ventilation, provides the primary means to ventilate the room and will open the doors and use of portable fans.

3.3.2.A OPEN Item Control of equipment and Complete this update connections for unavailability needs to be addressed. Closed during Site FLEX Audit 1/29/15 The equipment and connections for unavailability is addressed by QCAP 1500-07, "Administrative Tracking Requirements for Non-Functional FLEX Equipment". Procedure QCAP 1500-07 provides a list of FLEX equipment required to be maintained available and action to be taken to restore availability of equipment in accordance with guidance set forth in NEI 12-06. The procedure has been updated to separate the unavailability of equipment by event for which it is used.

OPEN Item Details not provided to Complete See February 2014 Six-Month demonstrate the minimum capabilities for update offsite resources will be met per NEI 12-06, Section 12.2. Closed during Site FLEX Audit 1/29/15 Page 18of37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 The NRC endorsement (ML14265A107) of the NET white paper on this topic covers Section 12.2.

Procedure CC-QC-1 18-100lis the Quad Cities SAFER Response Plan. QCOP 0050-16, FLEX National SAFER Response Center Interface, has been issued to address the use of SAFER equipment. Staging area C is the Whiteside County airport. Staging area B is the contractor parking lot, which has helicopter landing capability. Staging area D is the Quad Cities (Moline) airport. SAFER is notified of an event as follows: Loss of all A/C initiates procedure QCOA 6100-04, Station Blackout. Step D10 performs Attachment D. Att. D has the SM initiate the E-plan and notify the Exelon Nuclear Duty officer. The NDO directs the Corporate Supply Duty person to contact SAFER and request equipment delivery, see NDO checklist EP-AA-1 12-400-F-01. When the EOF (at Cantera) is activated, the Corporate Emergency Director checklist also has the ED contact SAFER, checklist EP-AA-1 12-400-F-02. Other EP checklists also direct contact with SAFER.

3.1.1.2.A Confirmatory Item Studies for liquefaction Complete this update and the effects on haul paths and storage location(s) are not complete. Closed during Site FLEX Audit 1/29/15 The use of two interim temporary storage pads until the Robust FLEX building is completed, has been submitted formally to NRC as an Alternate Strategy which has been inserted into the FLEX 4th 6 Month OIP Update Report (2/27/15) (RS-15-024) to allow a 45-day (vs 90-day) unavailability period if equipment on the seismic pad becomes unavailable. The basis for this Alternate Strategy is provided in FLEX Storage Pad Summary R4 Changes. Liquefaction evaluations on the upper pad haul path and pad impacts are addressed in Quad Cities calculation QDC-0000-S-2134 (FLEX Travel Path Liquefaction Evaluation).

The Alternate Strategy discussion from the FLEX 4th 6 Month OIP Update Report (2/27/15) (RS 024) to allow a 45-day (vs 90-day) unavailability period if equipment on the seismic pad becomes unavailable, is provided below:

See Changes to Compliance Method Section 4, Change 1 Interim FLEX Equipment Storage Alternative Approach, in this document.

3.1.1.2.13 Confirmatory Item A postulated Complete this update downstream dam failure from a seismic See Changes to Compliance Method Section 4, event is still being evaluated. Change 4 Seismic Water Source Alternative Approach 3.1.1.2.0 Confirmatory Item Need to confirm Complete this update implementation of strategy for power to move or deploy FLEX equipment and Closed during Site FLEX Audit 1/29/15 Page 19 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 opening of doors. All FLEX response equipment; pumps, generators, and hoses are located on trailers which will be connected and hauled to the deployment location with capable haul vehicle(s). Power for starting the diesel engine powered portable equipment will be from contained batteries. Therefore, no external power will be necessary for deployment or operation of the FLEX equipment. The FLEX storage building(s) design is being finalized. The door operation will not require external power. One of the deployment paths via the 1/2 Equipment Trackway does have a closing wedge that could block door opening. The hydraulic circuit was modified under EC 398254 to allow retracting the wedge to allow door opening.

3.1.1.3.A Confirmatory Item Plans for strategies Complete this update have insufficient information to demonstrate alternate sources of instrument Closed during Site FLEX Audit 1/29/15 readings and adequate tolerances/accuracies QCOP 0050-09, FLEX Response Instrumentation, if there is seismic impact to primary provides detailed lists of all instrumentation including Main Control Room and Local sources. Also, need identification of Instrument Racks and the power supplies.

installed instrumentation location and Additionally indicators on local racks that are not power source. power dependent are provided. Alternate methods for obtaining the necessary pressure and reactor levels are also provided in the procedure. FLUKE instruments for execution of these procedural steps have also been procured.

3.1.1.3.B Confirmatory Item Need identification of Complete See August 2014 Six-Month instrumentation used to monitor FLEX update electrical power equipment including measurement tolerance/accuracy. Closed during Site FLEX Audit 1/29/15 The FLEX 480VAC generators are supplied by Cummins Power Generation. The instruments supplied with the generator measure line to line and line to neutral voltage, phase current, and power output. Specifications are provided in the engineering submittal provided by the vendor.

3.1.2.2.A Confirmatory Item A detailed fuel supply Complete this update plan is to be provided in a future 6-month status update including what is needed, Closed during Site FLEX Audit 1/29/15 what is available, and how it will be Closed to 3,2.4.9.A transported.

3.1.3.2.A Confirmatory Item Completion of Complete this update development of an administrative program to ensure pathways remain clear or Closed during Site FLEX Audit 1/29/15 compensatory actions will be implemented QCOS 0050-02 FLEX Haul Path Inspection, to to ensure all strategies can be deployed inspect the areas both external to the buildings and internal that if blocked could hamper the during all modes of operation. Procedures deployment of equipment in response to an ELAP and programs are to be developed, event. Included are actions to be taken when the surveillance is found unsatisfactory. The debris removal equipment includes the plow on the F-750 truck, a 4 wheel drive tractor with a front bucket and battery and AC powered tools for cutting of Page 20 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 debris for removal. Also there is additional hose and cable to allow traversing the debris if the capability of the F750 truck and/or tractor are exceeded. Validation of deployment procedures is complete and provides times for non-debris deployment. An assessment of these times determined impact debris removal has on overall completion times. See Attachment 1 for updated timeline with debris removal impact.

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

3.2.1.1.A Confirmatory Item Need benchmarks to Complete See August 2014 Six-month demonstrate Modular Accident Analysis update Program (MAAP)4 is the appropriate code Closed during Site FLEX Audit 1/29/15 for simulation of ELAP.

The generic response provided by EPRI BWR Roadmap "Technical Basis for Establishing Success Timelines in Extended Loss of AC Power Scenarios in Boiling Water Reactors Using MAAP4," (EPRI Product ID 3002002749).

Acceptability of MAAP was analyzed in EPRI Technical Report 3002001785, Use of Modular Accident Analysis Program (MAAP) in Support of Post Fukushima Applications" and QC-MISC-014, Use of MAAP in Support of FLEX Implementation. Reference Att. 4 of the August 2014 6-month update.

3.2.l.1.B. Confirmatory Item The collapsed level Complete See August 2014 Six-Month must remain above Top of Active Fuel update (TAF) and the cool down rate must be Closed during Site FLEX Audit 1/29/15 within technical specification limits in the MAAP4 analysis. The Quad Cities Overall Integrated Plan (August 2014 Six-Month Update), states that the operators would commence a cooldown of the RPV after the RPV water level reaches +40' at a rate of 80°F/hr which is within the technical specifications limit of 100°F/hr. The plot of the RPV pressure from the MAAP analysis uses a cooldown initiation setpoint of +40" water level in the RPV.

For the representative MAAP run (Case 6), the collapsed RPV water level inside the shroud remains above TAF for the duration of the analysis.

The plot below shows that the lowest RPV level, calculated by MAAP, was approximately -40" below instrument zero. (TAP is located at -142" relative to instrument zero, Instrument zero is at

+503" above vessel zero.) The collapsed RPV water level remains at least 8.5' above TAF for the duration of the analysis.

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Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 3.2.1.1I.C. Confirmatory Item MAAP4 must be used Complete See August 2014 Six-Month in accordance with Sections 4.1,4.2,4.3, update 4.4, and 4.5 of the June 2013 position Closed during Site FLEX Audit 1/29/15 paper. The MAAP analysis performed for Quad Cities was carried out in accordance with Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 position paper, EPRI Technical Report 3002001785, "Use of Modular Accident Analysis Program (MAAP) in Support of Post-Fukushima Applications'.

Preparation and Review of the MAAP analysis was conducted under engineering training certification guide ENANRM08.

3.2.1.1I.D. Confirmatory Item In using MAAP4, the Complete See August 2014 Six-Month licensee must identify and justify the subset update of key modeling parameters cited from Closed during Site FLEX Audit 1/29/15 Tables 4-1 through 4-6 of the "MAAP4 Application Guidance, Desktop Reference See 3,2.1,1.A for Using MAAP4 Software, Revision 2" (Electric Power Research Institute Report 1 020236).

3.2.1.1.E. Confirmatory Item The specific MAAP4 Complete See August 2014 Six-Month analysis case that was used to validate the update timing of mitigating strategies in the integrated plan must be identified and Closed during Site FLEX Audit 1/29/15 available on thee-Portal for NRC staff to view. Alternately, a comparable level of The MAAP analysis performed in support of the Quad Cities Integrated Plan is documented in information may be included in the calculation QC-MISC-013 Rev. 2. Case 6 was the supplemental response. specific MAAP run selected to represent the scenario as described in Attachment 1A of the August 2014 6-month update.

3.2.1.2.A. Confirmatory Item Questions remain Complete this update.

unanswered regarding recirculation pump seal leakage rates. Aspects such as pressure Closed during Site FLEX Audit 1/29/15 dependence, leakage phase assumptions (single phase liquid, steam, mixed) are not The Reactor Recirculation pump seal leakage is discussed assumed to be 42 gpm. This includes 5 gpm of unidentified leakage, 1 gpm of identified leakage, and 18 gpm recirculation pump seal leakage per pump. Per QC-MISC-013, Rev 2, this is modeled in MAAP as a hole of fixed size which yields 42 gpm leakage at 1000 psig. Therefore, the leakage is reactor pressure limited. For phase flow, ERIN report QC-MISC-014, Rev. 0, discusses the phase flow from reactor vessel leakage. Reactor recirculation seal leakage is single-phase liquid due to the location of the break low in the RPV with RPV level continued to be maintained above TAF.

Recirc Pump Model: Byron Jackson/Flowserve, DVSS 28x28x30. Quad Cities has Generation 2 and Generation 4 pumps installed. Recirc Pump I Seals: All pumps use the Flowserve N-7500 Page 22 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 mechanical seals.

QCOS 1600-07, Reactor Coolant System Leakage in the Drywell (DWFDS and DWEDS Available),

demonstrates administrative controls in place for monitoring and responding to changes in Drywell leakage rates. Historical data provided to demonstrate normal Drywell Leakage rates at Quad Cities Station relative to NEI 12-06, Rev. 0, Section 3.2.1.5, Reactor Coolant Inventory Loss.

QCOP 0050-08, FLEX Electrical Isolation provides direction to isolate Recirc Pump Seals upon restoration of 480VAC via the FLEX Generators.

3.2.1.3.A. Confirmatory Item Need gap analysis Complete this Update.

between results of the licensee's analysis results and those of BWROG document Closed during Site FLEX Audit 1/29/15 NEDC-33771 P. Results are presented in 6- month update; however, there is no The generic MAAP response template is CaIc. QC-analysis of the relevance of differences. M1SC-013, (MAAP analysis to support FLEX Initial Strategy).

The current MAAP 4.0.5 calculations were performed to estimate the containment pressure and temperature response to a variety of extended Station Blackout (SBO) events.

Case 6 was the specific MAAP run selected to represent the scenario as described in Attachment 1A of the August 2014 6-month update to the overall integrated plan.

3.2.1.3.B. Confirmatory Item Licensee plans further Complete this Update.

review and analysis to ensure suppression pool temperature will support RCIC Closed during Site FLEX Audit 1/29/15 operation.

Evaluation of RCIC NPSH under ELAP conditions has been performed as documented in QDC 1300-M-2074 and QC-MISC-013, Rev. 2. Additional supporting information is provided in BWROG-TP- 14-018, Beyond Design Basis RCIC Elevated Temperature Functionality Assessment.

3.2.1.3.C. Confirmatory Item Need identification of Complete See February 2014 Six-Month the minimum voltage required for the dc update.

buses and the basis of that determination.

Closed during Site FLEX Audit 1/29/15 The minimum voltage required for DC Buses and basis is contained in Quad Cities UFSAR Section 8.3.2. UFSAR 8.3.2. defines 105 VDC as the limiting voltage for the 125 VDC battery, and 210 VDC for the 250 VDC battery. These are the values that were utilized for the FLEX event analyses. Calculations QDC-8300-E-2100, Rev. 0 and QDC-8350-E-2 101, Rev. 0 are for the 125 and 250 Volt systems respectively. There is not a specific limiting component.

Page 23 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 3.2.1.4.A. Confirmatory Item Water quality issue and Complete this Update.

guidance on priority of water source usage need to be addressed. Closed during Site FLEX Audit 1/29/15 Procedure QCOP 0050-12, "FLEX RCIC System Operation" provides guidance on using available water sources for injection into the RPV using RCIC.

The water for phase 1 operations will be Torus water or/and CCST water if available (the CCSTs tanks are not seismic or tornado proof). These are the normal water sources used for RPV makeup via RCIC. Phase 2 operations will use the deep well or river water. Due to the use of raw water the core inlet filters could become blocked not allowing sufficient flow for adequate core cooling. Raising the water level to the point that water enters the core via passages in the moisture separators will assure core cooling. Quad Cities incorporated EPG Rev. 3 guidance into the station EOPs (QGA5), to allow RPV water level to be controlled high enough to facilitate top-down cooling via spillover at the moisture separators if necessary.

3.2.1.4.B. Confirmatory Item Need completion of Complete this Update.

current evaluation of FLEX generator sizing calculation. Closed during Site FLEX Audit 1/29/15 Calculation QDC-7300-E-2099, Rev. 0 contains the basis of the FLEX Generator sizing including the list of plant loads. This calculation also includes key excerpts of the Cummins Diesel Specifications.

3.2.1.4.C. Confirmatory Item Need design and Complete this Update.

working pressure of hoses and fittings. Closed during Site FLEX Audit 1/29/15 The lowest rated pressure identified for the components being deployed to support FLEX injection is 225 psig and that current FLEX flow models show that these components would be exposed to less than 200 psig at all times.

Procedure 0050-06, FLEX RPV, Suppression Pool, and Spent Fuel Pool Level Control, has been revised to assure a dead head condition does not exist. In addition a relief valve has been added to the discharge piping at the well head.

3.2.1.6.A. Confirmatory Item Licensee identified Complete this Update.

protection of equipment for Hardened Vent is to Order EA-13-109 (Reference 22). Closed during Site FLEX Audit 1/29/15 Explain if this is equivalent to Order EA- All credited Phase 2 FLEX equipment, including 12-049, as Order EA-1 3-109 does not equipment needed for the Hardened Vent (Order EA-13-109) would be protected in the robust require protection from external events.

storage building. The Quad Cities EA 13-109 Phase 1 OW, June 2014, identified and screened in all external events from EA 12-049. Part 2, page 24, identifies handling of portable equipment.

Page 24 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Portable equipment is to be deployed as per EA 12-049, and connections protected as per EA 12-049.

Detailed design of the HCVS system started January 2015, with a parameter of operation without portable equipment for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The portable equipment for HCVS operation beyond 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months will be stored in the FLEX building and protected in the same manner as equipment protected under EA 12-049.

3.2.2.A. Confirmatory Item The licensee identified Complete this Update.

modifications and procedures for SFP cooling are in development. Closed during Site FLEX Audit 1/29/15 The Fuel Pool FLEX connection has been installed and QCOP 0050-04, FLEX Refuel Floor Actions, and QCOP 0050-05, 06 provide direction for hose deployment and establishing restoration of water to the spent fuel pool.

Approved FSGs: QCOP 0050-04 FLEX Refuel Floor Actions, QCOP 0050-05 FLEX Hose Deployment, and QCOP 0050-06 FLEX RPV, Suppression Pool, Spent Fuel Pool Level Control, all have elements that support habitability of the area and actions to supply the SFPs with makeup.

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

the licensee.

Closed during Site FLEX Audit 1/29/15 U 1 ECCS Room Cooler FLEX connection has been installed. U2 ECCS Room Cooler is scheduled to be installed during Q2R23. QCOP 0050-17, FLEX RCIC Room Cooler Lineup, will provide direction for use.

3.2.4.2.13. Confirmatory Item Modifications to restore Complete See August 2004 Six-Month ventilation to the battery rooms via use of update.

the portable FLEX generators to address hydrogen and cold weather are being Closed during Site FLEX Audit 1/29/15 developed by the licensee.

Calculation 2014-05860, Battery and Charger Room Heat Up for FLEX Evaluation, has been accepted by the site under EC 399874. The results report that battery electrolyte temperature reaches 67°F in Unit 1 in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and 65°F in Unit 2 in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , Unit 1 will reach 65°F in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , which is enough time for FLEX deployment with no need for a compensating action to mitigate cold temperature in Unit 1 and Unit 2. This is reflected in the Quad Cities FLEX program document.

EC 394892, Modify the Battery Room Exhaust Fan Electrical Supply from Emergency Lighting Cabinets, has been installed. Procedure QCOP 0050-10, FLEX Battery Room Ventilation, implements starting the fan, and displaced air is made up from the Turbine Building through the door to the Battery Room. The function of the fan is to prevent hydrogen buildup, and the Page 25 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 modification allows powering the fan by a source that will survive a BDBEE.

3.2.4.4.A. Confirmatory Item Procedures for Complete this Update.

emergency lighting are to be developed for deployment of hands free flashlights. Closed during Site FLEX Audit 1/29/15 QCOP 0050 procedures to be used for ELAP event response provide direction for the use of the Appendix R tools which includes hands free flashlights. Additionally, Equipment Operators are provided hands free hard hat lights as part of their normal complement of equipment for job performance, and there are staged flashlights in the Operations Ready Room.

The equipment purchased for the initial Fukushima response includes bar lights.

3.2.4.4.B. Confirmatory Item Confirm upgrades to Complete this Update.

communication system that resulted from the licensee communications assessment. Closed during Site FLEX Audit 1/29/15 (ADAMS Accession Nos. ML12306A199 Communications upgrades are being implemented and ML13056A135.) consistent with the guidance contained in Exelon Position Paper "BDBEE Communications Strategy and Equipment Readiness, dated 12/19/14.

3.2.4.5.A. Confirmatory Item Verify completion of Complete this Update.

drafted procedures for protected and internal locked area access. Closed during Site FLEX Audit 1/29/15 QCOP 0050 procedures to be used for ELAP event response provide direction for the use of the Appendix R tools which includes necessary keys for access.

SY-QC-101 -411, Active Vehicle Barrier System/Motorized Gate Manual Operation, provides direction for opening vehicle access points to the protected area without any power available.

3.2.4.6.B. Confirmatory Item Site industrial Complete See February 2014 Six-Month procedures and identification of protective update clothing, ice vests/packs, bottled water, etc.

is needed. Closed during Site FLEX Audit 1/29/15 Per the February 2014 6-month update, ML14059A432, Procedure SA-AA-1 11, HEAT STRESS CONTROL, addresses use of protective clothing, cooling garments and water use for rehydration and addresses protecting employees from adverse effects of performing work in high temperature environments. QCOS 0010-03, Safe Shutdown Equipment Inspection, documents some of the equipment that is maintained available including ice vests. Additionally, personal habitability supplies identified as part of the station FLEX response are being maintained via use of the storeroom inventory process.

Page 26 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 3.2.4.6.C. Confirmatory Item Need to address the use Complete this Update.

of appropriate human performance aids (e.g., component marking, connection Closed during Site FLEX Audit 1/29/15 schematics, installation sketches, QCOP 0050 procedures to be used for ELAP event photographs, etc.) which shall be included response contain attachments that include RU tools such as layout diagrams, illustrations, and drawings in the FLEX guidance implementing the to provide visual directions as well as written FLEX strategies. directions. Components used within the FLEX response procedures will be designated using reflective green FLEX stickers, similar to Appendix R response or B.5.b response. OP-QC-116-101-1001 has been implemented to document component labeling requirements for FLEX equipment.

3.2.4.8.A, Confirmatory Item The licensee did not Complete this Update.

provide any information regarding loading/sizing calculations of portable Closed during Site FLEX Audit 1/29/15 diesel generators(s) and strategy for QCOP 0050-08, FLEX Electrical Restoration, electrical isolation for FLEX electrical provides direction for electrical isolation and generator connection and operation. Loading generators from installed plant equipment.

evaluation performed by calculation QDC-7800-E-2099. This calculation does assume that load shed has been completed per QCOP 0050-08, FLEX Electrical Restoration.

3.2.4.9.A. Confirmatory Item Need detailed fuel plan Complete this Update.

including fuel storage tank, truck, and day tank volumes and how fuel quality is Closed during Site FLEX Audit 1/29/15 maintained in the day tanks and in portable The detailed fuel oil plan has been completed, EC FLEX equipment. 399944, FLEX Fuel Oil Plan, and QCOP 0050-13, FLEX Generator/Pump Refueling, has been issued.

3.2.4. 10.A. Confirmatory Item Need detailed battery Complete this Update.

load profile for all mitigating strategies and a detailed discussion of loads that will be Closed during Site FLEX Audit 1/29/15 shed, how they will be shed, and what are Quad 1/23/15: Battery load profiles have been the effects of the load shed. evaluated and documented in Calculations QDC-8300-E-2100 and QDC-8350-E-2102. QCOP 0050-01 and 02, Unit 1(2) FLEX DC Load Shed, have been issued to provide procedural guidance for performance of the FLEX load shed of both the 125V and 250V batteries 3.4.A. Confirmatory Item Procedures for interface Complete this Update.

with the NSRC need to be developed.

Closed during Site FLEX Audit 1/29/15 QCOP 0050-16, FLEX National SAFER Response Center Interface, has been issued to provide direction for the use of NSRC equipment in support of the Quad Cities Station FLEX strategy. The SAFER Playbook has been developed and contains details of the equipment that will be provided and delivery methods.

Page 27 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 NRC FLEX Audit Report Open Items 3.1.1.2.13 Confirmatory Item A postulated Complete this update downstream dam failure from a seismic See Changes to Compliance Method Section 4, event is still being evaluated. Change 4 Seismic Water Source Alternative Approach FLOWN The licensee stated that it can mitigate the Complete this Update effects of an ELAP indefinitely using phase See Changes to Compliance Method Section 4, two portable equipment and utilizing the Change 4 Seismic Water Source Alternative Approach Phase 3 NSRC equipment as back-up for reliability if needed. However, for a seismic event the licensee only has one seismically qualified well pump, and there is no NSRC equipment that can substitute for the well pump. Although there will be a spare well pump at the site, the replacement time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AQ 49-13, SE Provide details of the maintenance and Complete this Update 3-E testing plan for portable/FLEX electrical The Site specific Quad Cities FLEX Program equipment that is credited for events that Document which contains Preventative Maintenance actions and Surveillances has been require mitigating strategies. Please completed.

describe how Regulatory Guidance documents, IEEE Standards, manufacturer recommendations, etc. will be used to establish the maintenance and testing programs for the portable/FLEX electrical equipment, especially for batteries and diesel generators.

SE 9-E For a design basis Mississippi River flood, I Complete this Update most of the site will have several feet of Timeline for getting to cold shutdown and water. The license's plan is to remove the removing the heads and flooding the refueling cavity:

drywell heads, and the RPV heads, and UFSAR Section 3.4.1.1 provides the design basis flood the refueling cavity, connecting both flooding scenario and mitigation efforts and RPVs and both SFPs. There will be a loss includes the timeline for getting to cold shutdown and removing the heads and flooding the refueling of all AC power due to the flood. Gasoline cavity. These mitigation steps will be initiated a powered pumps will be used to refill the minimum of three days prior to the predicted refueling cavity. Please provide an arrival of a flood of elevation 594.5 feet or greater, and both units will be shut down and decay heat assessment of the reliability of this action, will be removed using the normal procedures as including the timeline for getting to cold specified for the RHR system. Quad Cities Station shutdown and removing the heads and utilizes a 96-hour warning time per procedure, QCOA 0010-16, Flood Emergency Procedure, in flooding the refueling cavity, the reliability which plant actions are taken in response to a of offsite power to perform these actions, Design Basis River Flood prior to flood waters the availability of backup power supplies, reaching plant grade. The UFSAR flood mitigation timeline was time validated during the NRC On-and the availability of critical equipment site Flooding Walkdown Audit (July 9-11, 2013),

such as the crane for head removal and stud and this timeline validation is described in the NRC Page 28 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 detensioners. Flooding Walkdown Audit Report of February 21, 2014.

Reliability of offsite power to perform flood mitigation actions for a design basis flood:

Quad Cities Station has 5 diverse overhead 345KV Lines that are connected to the station switchyard as part of a "Ring Bus" configuration. The Lines are designated as Line 0401, 0402, 0403, 0404, 0405, respectively, and originate from diverse locations geographically both to the East in Illinois as well as to the West in Iowa. Additionally, there are two independent Reserve Aux Transformers connected to the Ring Bus, designated as T-12 and T-22, which provide the normal source of power for the Division 1 4KV and 480VAC electrical distribution systems and are capable of providing power for the entire on-site AC Electrical Distribution System via fast transfer in the case of a Main Generator trip event. Given this switchyard configuration it would require a Grid Event that simultaneously de-energized all 5 overhead 345KV Lines, or a simultaneous failure of both T-12 and T-22 in order for there to be a complete loss of offsite power to the station AC Electrical Distribution System. Based on this, a Mississippi River flooding event that originates upstream of Quad Cities Station does not present the threat of causing a complete loss of offsite power to Quad Cities Station during the 96-hour warning time (QCOA 0010-16, Flood Emergency Procedure) in which plant actions are taken in response to a Design Basis River Flood prior to flood waters reaching plant grade.

Availability of backup power supplies:

Backup on-site power supplies capable of powering the reactor building overhead crane (OHC) and stud detensioners can be provided by use of AC power from the station Emergency Diesel Generators (3 total), and SBOs (2 total).

Furthermore portable FLEX generators are also capable of powering the OHC and stud detensioners.

Availability of critical equipment such as the crane for head removal:

During the NRC Flooding Walkdown Audit at Quad Cities (Exit on July 11, 2013), an observation was noted that the reactor building overhead crane is a single point vulnerability. The NRC requested how reliability of the reactor building overhead crane is assured. In that Audit the following response was provided: The site reviewed the available crane performance metrics. Based on a review of the system health report and crane performance over the past three years, the crane was determined to be a very reliable piece of equipment with all applicable system health windows being green. While reviewing the performance metrics, the restricted mode limit Page 29 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 switches were one single point vulnerability identified where the station decided that a contingency work-order was warranted to help assure the capability to promptly repair the crane if required in the flooding event.

Availability of critical equipment such as stud detensioners:.

The Station maintains at all times on the refuel floor four (4) reactor head detensioners for reactor head disassembly used in refueling outages. Spare detensioners are available from other Exelon sites which are within a 2 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months driving distance.

Current Industry efforts concerning FLEX mitigation during flooding scenarios:

The planned Rev. 1 t NET 12-06 will add Appendix G, Mitigating Strategies Flood Hazard Information (MSFHI). The planned Appendix 0 contains options for a "targeted mitigation strategy," for coping with floods. As such, Quad Cities plans to follow the industry efforts in the development and implementation of Appendix 0; this will support any future changes to mitigating a FLEX/ELAP event during a design basis river flood scenario.

In addition, Rev. Ito NEI 12-06 will add Appendix E, Validation. This Appendix will modify the validation process to include flooding actions validation. This will also include validation of actions that need to be performed during the flood warning time period. As such, Quad Cities plans to follow the industry efforts in the development and implementation of Appendix E; this will support any future changes to the flooding timeline, warning time, and any time constraints.

SE 10-E Final robust FLEX building configuration - Complete this update Current plan using one robust building with See Section 4, Changes to Compliance Method, N equipment and one commercial building Change 2 Storage, Maintenance and Testing with the +1 equipment is an Alternate Alternate Approach Strategy approach to NET Guidelines NEI 12-06.

NOTE: The status of all of ISE Open and Confirmatory items are updated in this Six-Month Update based on information contained in the Quad Cities NRC FLEX Audit of January 29, 2015, and its associated Report (Reference 16) 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

Page 30 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 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, Quad Cites Nuclear Power Station's Request for Relaxation from NRC Order EA42-049, 'Order Modifying Licenses With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 27, 2014.

6. RCIC Pump and Turbine Durability Evaluation - Pinch Point Study, February 2013, 0000-0155-1545-RO, DRF 0000-0155-1541, Revision 0.

7. Quad Cities Nuclear Power Station, Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA- 12-049 (Mitigation Strategies) (TAC NOS.MF 1048 and MF 1049), dated November 22, 2013.

8. Quad Cities Nuclear Power Station, Units I and 2 Second Six Month Status Report for the Implementation of Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2014.

9. NRC Approval of Exelon/Quad Cities Request for Relaxation from NRC Order EA-12-049, dated April 15, 2014 (ADAMS Accession No. ML14071A531).

10. Quad Cities Nuclear Power Station, Units 1 and 2 Third Six Month Status Report for the Implementation of Order EA- 12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated August 28, 2014.

11. Quad Cities MAAP Analysis to Support FLEX Initial Strategy, QC-MISC-013 Rev. 2, dated February 14, 2014.

12.Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six Month Status Report for the Implementation of Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 27, 2015.

13. Quad Cites Nuclear Power Station's Request for Relaxation from NRC Order EA-12-049, "Order Modifying Licenses With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 4, 2015 (ADAMS Accession No. ML15064A090).

Page 31 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015

14. Quad Cites Nuclear Power Station's Request for Relaxation from NRC Order EA-12-049, "Order Modifying Licenses With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 6, 2015 (ADAMS Accession No. ML15068A064).

15. NRC Approval of Exelon/Quad Cities Unit 1 Request for Relaxation from NRC Order EA-12-049, dated March 11, 2015 (ADAMS Accession No. ML15068A206).

16. NRC Report for the Onsite Audit regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation related to Orders BA- 12-049 and BA- 12-51, dated June 25, 2015 (ADAMS Accession No. ML15156B134).

9 Attachments

1. Quad Cities Station Sequence of Events Timeline Page 32 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six Month Status Report for the Implementation of FLEX August 2015 Attachment 1 Quad Cities Station Sequence of Events Timeline Page 33 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six Month Status Report for the Implementation of FLEX August 2015 Action Elapsed Action Time Remarks Applicability item rime Constr aint YIN' 1 0 Event Starts. NA Plant at 100% power 2 0 Reactor Scram and SBO. NA Event Initiation 3 0 min Group I isolation due to loss of power to N Loss of AC power causes Group 1 isolation due to loss of power to trip instrumentation. system [UFSAR 7.3.2.2]

4 2 min Operating crew enters applicable EOPs and N QGA 100 RPV Control abnormal procedures for LOOP. EOP entry QCOA 6100-03 Loss of Offsite Power conditions; Low Reactor water level and High Reactor pressure.

5 2 min RCIC Manually started and injects to restore N Reactor operator initiates or verifies initiation of reactor water level level to normal operating band. restoration with steam driven high pressure injection. [IJFSAR Section 1.2.2.51 QGA 100 RPV Control QCOP 1300-02 RCIC System Manual Startup This is not time critical because if not completed automatic initiation will occur at the Low-Low level setpoint.

6 2 rain ERV valves operation is monitored and manual N QGA 100 RPV Control operation initiated to control RPV pressure. QCOP 0203-01 Reactor Pressure Control Using Manual Relief Valve Actuation.

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

1 Instructions: Provide justification in the remark column if No or NA is selected for Time Constraint. If YES, include technical basis discussion as required by NEI 12-06, Section 3.2.1.7 Page 34 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Action Elapsed Action Time Remarks / Applicability item Time Constr aint YIN' 7 5 mins - Attempt to manually start emergency diesel N QCOA 6100-03 Loss of Offsite Power.

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

procedure.

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

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

10 10 mins Commence RPV depressurization using ERVs at N QCOP 0203-01 less than or equal to 80 deg F per hour. Not time c it cal as n t ation of depressurization controls the RPV pressure r i i ii prior to EOP directed operation due to HCTL of suppression chamber temperature requiring an emergency depressurization.

11 30 mins DC load shedding completed. Y QOA 6900-07 12 30 mins Defeat RCIC Low Pressure Isolation Logic. N Not time critical since RPV depressurization will be stopped prior to the RCIC Low Pressure Isolation setpoint per QGA 100 (in accordance with EPG Rev 3).

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

Power (ELAP) event. QCOA 6100-04 Page 35 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the Implementation of FLEX August 2015 Action Elapsed Action Time Remarks / Applicability item Time Constr aint YIN' 14 60 mins Equipment Operators dispatched to begin Y QCOP 0050-01,02 setup/connection of FLEX equipment (480VAC QCOP 0050-05, 07 generators to power battery chargers and FLEX DC coping analysis shows the following DC battery capabilities:

pump), and commence FLEX DC load shed.

125 VDC/ 10 hrs 250 VDC /9 hrs 15 90 mins FLEX DC load shed complete. Y DC coping analysis assumes FLEX load shed is complete by 90 minutes.

Therefore, this action is time critical.

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

17 5 hrs 480 VAC FLEX generators connected to the Y Restore AC power to battery chargers prior to loss of each battery at:

Safety Related Busses. This supplies battery 125 VDC / 10 hrs chargers for I 25VDC (Div. 1 and 2) and 250VDC buses. 250 VDC /9 hrs 18 5 hrs FLEX pumps connected and alignment for N QCOP 0050-06 suppression pool injection established. This action becomes i me cntical when early containment venting is t

initiated.

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

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

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

Page 36 of 37

Quad Cities Nuclear Power Station, Units 1 and 2- Fifth Six-Month Status Report for the implementation of FLEX August 2015 Action Elapsed Action Time Remarks / Applicability item Time Constr aint

%IN' 20 -5.5 hrs Heat Capacity Temperature Limit (HCTh) curve Y QGA 200 (EPG Rev 3) projected to be exceeded via MAAP analysis, RPV blowdown stops at -200 psig in RPV to preserve RCIC operation.

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

21 -5.5 hrs FLEX pumps connected and alignment for RPV N QCOP 0050-06 injection established. RPV blowdown is completed and RCIC is shut down.

22 12 hrs Begin makeup to SFP with the FLEX pump to Y QCOP 0050-06 maintain level above top of fuel. QUA 300, Secondary Containment Control (EPG Rev 3)

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

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

23 24 hrs Initial equipment from National SAFER N Per NET 12-06, Section 12 (NSRC).

Response Center becomes available.

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

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

Page 37 of 37

RS-15-215, Fifth 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.

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