IR 05000254/2011010
| ML111320357 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/13/2011 |
| From: | Ring M NRC/RGN-II/DRP/RPB1 |
| To: | Pacilio M Exelon Nuclear, Exelon Generation Co |
| References | |
| IR-11-010 | |
| Download: ML111320357 (20) | |
Text
May 13, 2011
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 -
NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000254/2011010; 05000265/2011010
Dear Mr. Pacilio:
On April 26, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Quad Cities Nuclear Power Station, Units 1 and 2, using Temporary Instruction 2515/183, Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.
The enclosed inspection report documents the inspection results which were discussed on April 26, 2011, with Mr. Prospero and other members of your staff.
The objective of this inspection was to promptly assess the capabilities of Quad Cities Nuclear Power Station to respond to extraordinary consequences similar to those that have recently occurred at the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, along with the results from this inspection performed at other operating commercial nuclear plants in the United States, will be used to evaluate the U.S. nuclear industrys readiness to safely respond to similar events. These results will also help the NRC to determine if additional regulatory actions are warranted.
All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in the next quarterly report. You are not required to respond to this letter. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Mark A. Ring, Chief Branch 1 Division of Reactor Projects Docket Nos. 50-254; 50-265 License Nos. DPR-29; DPR-30
Enclosure:
Inspection Report 05000254/2011010; 05000265/2011010
REGION III==
Docket Nos: 50-254, 50-265 License Nos: DPR-29, DPR-30 Report No: 05000254/2011010 and 05000265/2011010 Licensee: Exelon Generation Company, LLC Facility: Quad Cities Nuclear Power Station, Units 1 and 2 Location: Cordova, IL Dates: March 23 through April 29, 2011 Inspectors: J. McGhee, Senior Resident Inspector B. Cushman, Resident Inspector C. Mathews, Illinois Emergency Management Agency Approved by: M. Ring, Chief Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000254/2011010; 05000265/2011010, 03/23/2011 - 04/29/2011; Quad Cities Nuclear
Power Station Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.
This report covers an announced Temporary Instruction inspection. The inspection was conducted by Resident and Region III inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,
Reactor Oversight Process, Revision 4, dated December 2006.
INSPECTION SCOPE
The intent of the TI (Temporary Instruction) is to provide a broad overview of the industrys preparedness for events that may exceed the current design basis for a plant. The focus of the TI was on
- (1) assessing the licensees capability to mitigate consequences from large fires or explosions on site,
- (2) assessing the licensees capability to mitigate station blackout (SBO)conditions,
- (3) assessing the licensees capability to mitigate internal and external flooding events accounted for by the stations design, and
- (4) assessing the thoroughness of the licensees walk downs and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. If necessary, a more specific follow-up inspection will be performed at a later date.
INSPECTION RESULTS
All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report.
03.01 Assess the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), Section 02.03 and 03.03 as a guideline. If IP 71111.05T was recently performed at the facility, the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited to, an assessment of any licensee actions to:
Licensee Action Describe what the licensee did to test or inspect equipment.
a. Verify through test or inspection Licensee actions included the identification of equipment (active and passive) utilized that equipment is available and for implementation of B.5.b actions and any additional equipment credited for use in functional. Active equipment Severe Accident Management Guidelines (SAMGs). The scope of the equipment was shall be tested and passive defined as that equipment specifically designated for B.5.b or SAMG implementation equipment shall be walked down (i.e., hoses, fittings, etc.). Permanent plant equipment was not considered in the scope and inspected. It is not since it is normally in service, subjected to planned maintenance, and/or checked on expected that permanently operator rounds. The licensee then identified surveillances for the identified equipment and installed equipment that is reviewed the results of recent tests. Active equipment within the defined scope that had not tested under an existing been tested recently was tested as part of the licensees evaluation. Passive equipment regulatory testing program be within the scope was walked down and inspected.
retested.
Describe inspector actions taken to confirm equipment readiness (e.g., observed a This review should be done for a test, reviewed test results, discussed actions, reviewed records, etc.).
reasonable sample of mitigating strategies/equipment.
The licensees actions as discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensees capabilities by conducting a review of the licensees walkdown activities and reviewed all items entered into the licensees corrective actions program (CAP) as a result of these activities. In addition, the inspectors independently walked down and inspected all major B.5.b equipment on site.
The inspectors independent walkdowns confirmed the results obtained by the licensee.
Discuss general results including corrective actions by licensee.
All equipment designated for use in the SAMGs is considered permanent plant equipment.
The licensee verified all equipment credited for B.5.b, and the SAMGs was able to be implemented using approved procedures. All passive equipment was walked down and verified to be in place and ready for use. Passive equipment which had surveillance and/or preventative maintenance tasks had those activities reviewed to verify readiness for use.
All active equipment was verified in place by the licensee. The licensee performed a 24-hour endurance run of the B.5.b pump as well as performing a surveillance to run the portable diesel-driven direct current generator.
No loss of function or inability to perform was identified. No performance deficiencies that relate to the state of readiness were identified. Minor enhancements were entered into the licensees CAP.
Describe the licensees actions to verify that procedures are in place and can be Licensee Action executed (e.g., walkdowns, demonstrations, tests, etc.).
b. Verify through walkdowns or Licensee actions included the identification of the procedures utilized to mitigate the demonstration that procedures consequences of a B.5.b and 10 CFR 50.54(hh) related events and severe accidents.
to implement the strategies The licensee verified procedures were current, and personnel were assigned to conduct associated with B.5.b and walkdowns of applicable procedures to verify the ability of the procedures to be executed.
10 CFR 50.54(hh) are in place and are executable. Licensees Describe inspector actions and the sample strategies reviewed. Assess whether may choose not to connect or procedures were in place and could be used as intended.
operate permanently installed equipment during this verification.
The licensees actions as discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensees capabilities by conducting a This review should be done for a review of the licensees walkdown activities and reviewed all items entered into the reasonable sample of mitigating licensees CAP as a result of these activities. In addition, the inspectors selected a sample strategies/equipment.
of the procedures walked down by the licensee and walked those down to independently verify the licensees conclusions.
Discuss general results including corrective actions by licensee.
The licensee reviewed SAMG strategies and did not identify any issues. Procedures used for B.5.b and SAMG implementation were reviewed by the licensee, and walkdowns were performed to ensure actions taken could be performed. Minor enhancements were identified by the licensee and entered into the CAP.
Describe the licensees actions and conclusions regarding training and qualifications Licensee Action of operators and support staff.
c. Verify the training and Licensee actions included the identification of training/qualification requirements for qualifications of operators and operators for the implementation of actions needed to mitigate a B.5.b-related event and for the support staff needed to the implementation of actions needed for the SAMGs. In addition, the licensee identified implement the procedures and the training/qualification requirements for applicable emergency response organization work instructions are current for (ERO) command and support staff for the implementation of actions needed to mitigate a activities related to Security B.5.b related event, and for the implementation of actions needed for the SAMGs, and Order Section B.5.b and severe documented that ERO command and support staff training requirements were current.
accident management guidelines as required by 10 CFR 50.54 (hh).
Describe inspector actions and the sample strategies reviewed to assess training and qualifications of operators and support staff.
The licensees actions as discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensees training and qualification activities by conducting a review of training and qualification materials and records related to B.5.b and SAMG event response.
Discuss general results including corrective actions by licensee.
The training requirements, qualifications, and associated records needed for operators for the implementation of SAMGs and B.5.b event response were reviewed by the licensee.
Training was identified for shift managers, shift engineers, and unit supervisors.
Verification was made that the training requirements were embedded within the position qualifications for the operators. The licensee confirmed that all shift operators are required to verify their qualifications prior to assuming a shift position. The training requirements, qualifications, and associated records needed for ERO command and support staff for the implementation of actions needed to mitigate a B.5.b event or implement the SAMGs were also reviewed. All ERO command and support staff training requirements were verified as current by the licensee.
Describe the licensees actions and conclusions regarding applicable agreements Licensee Action and contracts are in place.
d. Verify that any applicable Licensee actions included the identification of all applicable contracts and agreements agreements and contracts are in committed to be in place for the mitigation of a B.5.b related event. The licensee verified place and are capable of that the contracts and agreements were current, and documented whether or not the meeting the conditions needed contracts/agreements were capable of meeting the mitigation strategy.
to mitigate the consequences of these events.
For a sample of mitigating strategies involving contracts or agreements with offsite entities, describe inspector actions to confirm agreements and contracts are in place This review should be done for a and current (e.g., confirm that offsite fire assistance agreement is in place and reasonable sample of mitigating current).
strategies/equipment.
The licensees actions as discussed above were completed prior to the issuance of NRC TI 2515/183. The licensee currently has one contract and one Memorandum of Understanding (MOU) within this scope. The licensee has a MOU with the Cordova Fire Protection District that is renewed annually and was signed on October 19, 2010.
The licensee has a contract with Kidde Fire Fighting to be supplied with aqueous film forming foam; that contract will expire in 2021. The inspectors review of the agreements verified that they were current, and that they were adequate for meeting the licensees mitigation strategy.
Discuss general results including corrective actions by licensee.
The licensee reviewed their agreements with the Cordova Fire Protection District and Kidde Fire Fighting. Both agreements were verified current and adequate for meeting the licensees mitigation strategy.
Document the corrective action report number and briefly summarize problems noted Licensee Action by the licensee that have significant potential to prevent the success of any existing mitigating strategy.
e. Review any open corrective The inspectors reviewed each issue report (IR) that was generated as a result of these action documents to assess walkdowns for potential impact to the licensees mitigation strategies. No items of problems with mitigating significance were identified. No loss of function or inability to perform was identified.
strategy implementation No performance deficiencies that relate to the state of readiness were identified.
identified by the licensee.
Assess the impact of the problem on the mitigating capability and the remaining capability that is not impacted.
03.02 Assess the licensees capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, Loss of All Alternating Current Power, and station design, is functional and valid. Refer to TI 2515/120, Inspection of Implementation of Station Blackout Rule Multi-Plant Action Item A-22, as a guideline. It is not intended that TI 2515/120 be completely reinspected.
The inspection should include, but not be limited to, an assessment of any licensee actions to:
Describe the licensees actions to verify the adequacy of equipment needed to Licensee Action mitigate a SBO event.
a. Verify through walkdowns and Licensee actions included the identification of equipment utilized/required for mitigation of a inspection that all required SBO. The licensee then conducted walkdowns of this equipment to ensure they were materials are adequate and adequate and properly staged. Additionally, the licensee also conducted a review of open properly staged, tested, and CAP items for potential SBO equipment impact.
maintained.
Describe inspector actions to verify equipment is available and useable.
The inspectors assessed the licensees capability to mitigate SBO conditions by conducting a review of the licensees walkdown activities. In addition, the inspectors selected a sample of equipment utilized/required for mitigation of a SBO and conducted independent walkdowns of that equipment to verify that the equipment was properly aligned and staged.
Discuss general results including corrective actions by licensee.
The licensees reviews verified that SBO equipment was ready to respond to a SBO condition.
The inspectors reviewed each IR that was generated as a result of these walkdowns for potential impact to the licensees mitigation strategies. No loss of function or inability to perform was identified. No performance deficiencies that relate to the state of readiness were identified. Minor enhancements were entered into the licensees CAP.
Licensee Action Describe the licensees actions to verify the capability to mitigate a SBO event.
b. Demonstrate through Licensee actions included the identification of procedures required for response to a SBO, walkdowns that procedures for along with verification that the identified procedures were current and that no critical revision response to a SBO are requests were in place. The licensee then verified that the mitigating procedures had been executable.
properly validated.
Describe inspector actions to assess whether procedures were in place and could be used as intended.
The inspectors assessed the licensees capabilities by conducting a review of the licensees walkdown activities. In addition, the inspectors selected a sample of the procedures walked down by the licensee and walked those down to independently verify the licensees conclusions.
Discuss general results including corrective actions by licensee.
Actions to start the SBO diesel generators and supply electrical power to essential buses are performed from the control room with permanently installed plant equipment.
All procedures credited for mitigation of a SBO event were able to be performed. No current issues were identified by the licensee.
The inspectors reviewed each IR that was generated as a result of these walkdowns for potential impact to the licensees mitigation strategies. No loss of function or inability to perform was identified. No performance deficiencies that relate to the state of readiness were identified. Minor enhancements were entered into the licensees CAP.
03.03 Assess the licensees capability to mitigate internal and external flooding events required by station design. Refer to IP 71111.01, Adverse Weather Protection, Section 02.04, Evaluate Readiness to Cope with External Flooding, as a guideline.
The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.
Describe the licensees actions to verify the capability to mitigate existing design Licensee Action basis flooding events.
a. Verify through walkdowns and Licensee actions included the identification of equipment and penetration seals inspection that all required utilized/required for mitigation of internal and external flooding. The licensee then materials are adequate and conducted walkdowns of this equipment to ensure it was adequate and properly staged.
properly staged, tested, and Doors, barriers, and penetration seals that were utilized for mitigation of flooding were maintained.
identified and inspected to ensure functionality. Where routine inspections were not performed or could not be relied upon to ensure functionality, the licensee performed walkdowns and inspections to ensure that the components were functional.
Describe inspector actions to verify equipment is available and useable.
Assess whether procedures were in place and could be used as intended.
The inspectors assessed the licensees capabilities to mitigate flooding by conducting a review of the licensees walkdown activities. The inspectors conducted independent walkdowns of selected flood mitigation equipment. Licensee flood mitigation procedures were reviewed to verify usability.
Discuss general results including corrective actions by licensee.
The licensees reviews confirmed that all flood doors were inspected as part of a routine maintenance program. Flood barriers and penetrations that also serve as fire barriers were determined by the licensee to have been inspected on a routine basis as part of the sites fire protection program. However, the barriers and penetrations, that were not part of the fire protection program, were identified as not being routinely inspected. Where accessible, the licensee walked down these flood barriers and penetrations as part of their review for this item. All of the flood doors were inspected and found to have no noted deficiencies.
The inspectors reviewed each IR that was generated as a result of these walkdowns for potential impact to the licensees mitigation strategies. No loss of function or inability to perform was identified. No performance deficiencies that relate to the state of readiness were identified. Minor enhancements were entered into the licensees CAP.
03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site.
Assess the licensees development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary), such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use IP 71111.21, Component Design Basis Inspection, Appendix 3, Component Walkdown Considerations, as a guideline to assess the thoroughness of the licensees walkdowns and inspections.
Describe the licensees actions to assess the potential impact of seismic events on Licensee Action the availability of equipment used in fire and flooding mitigation strategies.
a. Verify through walkdowns that Licensee actions included the identification of equipment utilized/required for mitigation of all required materials are fire and flood events. An engineering inspection plan was established by the licensee to adequate and properly staged, govern the conduct of walkdowns and inspections. Licensee engineering personnel tested, and maintained.
determined if the equipment was seismically qualified and assessed the resulting damage if the equipment failed during a seismic event. Seismic vulnerabilities, including storage locations, were identified, along with mitigating strategies for equipment that was not seismically qualified.
Describe inspector actions to verify equipment is available and useable.
Assess whether procedures were in place and could be used as intended.
Licensee flood and fire mitigation procedures were reviewed to verify usability.
The inspectors assessed the licensees capabilities by conducting a review of the licensees walkdown activities and reviewed all items entered into the licensees CAP as a result of these activities. The inspectors performed an independent assessment of any potential vulnerabilities of non-seismic fire protection equipment impacting the operation of safety-related equipment.
Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.
The licensees reviews determined that non-safety related structures, systems, and components were not considered to be seismically qualified due to a variety of issues.
The majority of room flood mitigation sump pumps and flooding detectors were not designed as seismically qualified. Similarly, the fire protection system was not designed as seismically qualified, and the B.5.b equipment is not stowed in a seismically qualified building.
The inspectors reviewed each IR that was generated as a result of these walkdowns for potential impact to the licensees mitigation strategies. No loss of function or inability to perform was identified. No performance deficiencies that relate to the state of readiness were identified. Minor enhancements were entered into the licensees CAP.
Meetings
.1 Exit Meeting
The inspectors presented the inspection results to Mr. Prospero, and other members of licensee management, at the conclusion of the inspection on April 26, 2011.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- M. Prospero, Plant Manager
- D. Collins, Radiation Protection Manager
- S. Darin, Engineering Director
- K. Moser, Training Director
- P. Summers, Maintenance Director
- D. Thompson, Security Manager
Nuclear Regulatory Commission
- M. Ring, Chief, Reactor Projects Branch 1
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None Enclosure