IR 05000254/2013007
| ML13164A176 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/12/2013 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| Ronald Langstaff | |
| References | |
| IR-13-007 | |
| Download: ML13164A176 (16) | |
Text
June 12, 2013
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION EVALUATIONS OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000254/2013007; 05000265/2013007
Dear Mr. Pacilio:
On May 17, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications inspection at your Quad Cities Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on May 17, 2013, with Mr. T. Hanley, Site Vice-President, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
One NRC identified finding of very low safety significance (Green) was identified during this inspection.
This finding was determined to involve a violation of NRC requirements. However, because of its very low safety significance and because the issue was entered into your Corrective Action Program, the NRC is treating the issue as a Non-Cited Violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy.
If you contest the subject or severity of any Non-Cited Violation you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector office at Quad Cities Nuclear Power Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at Quad Cities Nuclear Power Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by G. M. Hausman for/
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-254; 50-265 License Nos. DPR-29; DPR-30
Enclosure:
Inspection Report 05000254/2013007; 05000265/2013007 w/Attachment: Supplemental Information
REGION III==
Docket No:
50-254; 50-265 License No:
05000254/2013007; 05000265/2013007 Licensee:
Exelon Generation Company, LLC Facility:
Quad Cities Nuclear Power Station Location:
Cordova, IL Dates:
April 22 - May 17, 2013 Inspectors:
R. Langstaff, Senior Reactor Inspector, lead
D. Szwarc, Reactor Inspector
R. Winter, Reactor Inspector Observer:
D. Oliver, Reactor Inspector Approved by:
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety
Enclosure
SUMMARY
IR 05000254/2013007, 05000265/2013007; 04/22/2013-05/17/2013; Quad Cities Nuclear
Power Station; Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications.
This report covers a two-week announced baseline inspection on evaluations of changes, tests, or experiments and permanent plant modifications. The inspection was conducted by Region III based engineering inspectors. One finding was identified by the inspectors. The finding was considered a Non-Cited Violation (NCV) of NRC regulations. The significance of most findings is indicated by their color (i.e. greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Cross-cutting aspects were determined using IMC 0310, Components Within the Cross Cutting Areas. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated June 7, 2012. 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.
NRC-Identified
and Self-Revealed Findings
Cornerstone: Mitigating Systems
- Green.
A finding of very low safety significance and associated NCV of 10 CFR Part 50,
Appendix B, Criterion III, Design Control, was identified by the inspectors for the licensees failure to translate the design basis correctly into procedures and instructions for the operators. Specifically, the licensee did not update procedures and instructions to ensure that operators would don respirators within two minutes of detection of a toxic chemical, ammonia, as determined in a calculation. The licensee entered the issue into their corrective action program and planned to revise the calculation using detection of odor as an entry condition for donning of respirator protection and update the operating procedures accordingly.
The finding was determined to be more than minor because the failure to provide procedures or instructions to operators to don respirators could result in the operators becoming incapacitated and not being able to respond to an accident or event that had a possibility of radionuclide releases. The finding was determined to be of very low safety significance (Green) due to the low probability of an ammonia release associated with a barge accident. The finding had a cross-cutting aspect in the area of human performance, work control, because the licensees engineering organization did not coordinate with the operations organization on the need to don respirators within two minutes of detection of ammonia gas following a postulated toxic chemical accident.
H.3(b) (Section 1R17.2(b)(1))
Licensee-Identified Violations
No violations of significance were identified.
REPORT DETAILS
REACTOR SAFETY
Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity
1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications
.1 Evaluation of Changes, Tests, or Experiments
a. Inspection Scope
From April 22, 2013 through May 17, 2013, the inspectors reviewed six safety evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR) 50.59 to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 14 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:
- the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;
- the safety issue requiring the change, tests or experiment was resolved;
- the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59; and
- the design and licensing basis documentation was updated to reflect the change.
The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.
This inspection constituted six samples of evaluations and 14 samples of changes as defined in Inspection Procedure (IP) 71111.17-04.
b. Findings
No findings of significance were identified.
.2 Permanent Plant Modifications
a. Inspection Scope
From April 22, 2013 through May 17, 2013, the inspectors reviewed 13 permanent plant modifications that had been installed in the plant during the last three years. This review included in-plant walkdowns for portions of the modified 345 kiloVolt relaying, control room ventilation, emergency diesel generator, nuclear instrumentation, reactor protection, residual heat removal, and residual heat removal service water systems. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:
- the supporting design and licensing basis documentation was updated;
- the changes were in accordance with the specified design requirements;
- the procedures and training plans affected by the modification have been adequately updated;
- the test documentation as required by the applicable test programs has been updated; and
- post-modification testing adequately verified system operability and/or functionality.
The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an Attachment to this report.
This inspection constituted 13 permanent plant modification samples as defined in IP 71111.17-04.
b. Findings
- (1) Failure to Translate Design Basis Into Toxic Chemical Response Procedures
Introduction:
The inspectors identified a finding of very low safety significance (Green)and associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate the design basis correctly into procedures and instructions for the operators. Specifically, the licensee did not update procedures and instructions to ensure that operators would don respirators within two minutes of detection of a toxic chemical, ammonia, as determined in a calculation.
Description:
The licensee developed calculation number QDC-5700-M-1767, Control Room Habitability Analysis of Offsite Hazardous Chemicals, Revision 0, to document the triennial offsite survey of chemicals near the plant and to evaluate the offsite toxic chemical hazards for control room habitability. Based on the calculation, the licensee determined that the ammonia gas concentration in the control room could exceed the Immediately Dangerous to Life or Health (IDLH) limits, 300 parts per million (ppm), after automatic detection and associated isolation of the control room ventilation system.
However, the ammonia gas did not pose a threat to the control room operators provided they donned respirators within two minutes of detection The licensees Updated Final Safety Analysis Report (UFSAR) described the toxic gas protection for the control room as including ammonia detectors which will cause automatic isolation of the control room heating, ventilation, and air conditioning (HVAC)system upon detection of ammonia gas. Section 6.4.4.2.3 of the UFSAR, Revision 11 stated that, A monitor is provided for ammonia detection since the control room concentrations for this chemical reach the toxicity limits faster that the operator can manually isolate the system after detection of odor.
The calculation established an acceptance criterion of more than two minutes must elapse between the time of detection and the time when the concentration reaches the IDLH limit for their review of offsite toxic chemical hazards. The calculation considered the use of the IDLH limits as appropriate because it provided an adequate margin of safety as long as operators used protective measures within two minutes after the detection of hazardous chemicals. Two minutes was considered sufficient for a trained operator to be able to don a respirator.
The licensee analyzed in detail eight sources of ammonia near the plant. The licensee identified several sources of ammonia that during an accident would result in the control room concentrations exceeding 300 ppm. For most of these cases, it would take over 10 minutes to reach a concentration of over 300 ppm in the control room. However, for barge accidents on the Mississippi River, the 300 ppm threshold could be exceeded in slightly more than two minutes in certain cases. For the worst case, the licensee determined that control room operators would have 135 seconds to don respirators after automatic detection of ammonia by the ammonia detectors before the control room ammonia gas concentration would exceed 300 ppm.
Although the licensee determined that operators had 135 seconds to don respirators upon receipt of an ammonia detection alarm, the licensee failed to update procedures to direct operators to take protective actions (such as donning a respirator) upon receipt of ammonia detection alarm. Instead, the applicable procedure, QOA 5750-13, Toxic Air or Smoke in the Control Room, Revision 18, stated IF atmosphere in Control Room is NOT breathable, THEN don air packs. The licensee stated that operators did receive periodic training on the donning of respirators, but that no specific training was given on the response to a toxic gas event. The licensee stated that operators would don respirators upon smelling ammonia in the control room. However, the inspectors were concerned that if operators waited until they smelled ammonia, IDLH limits could be exceeded before operators donned respirators. The inspectors determined that Procedure QOA 5750-13 did not ensure that the calculation assumption that operators would take protective measures within two minutes was valid.
The licensee entered this issue into their Corrective Action Program as Issue Report (IR) 01513794, Mods/50.59 - Control Room Toxic Air Room Response Procedure, dated May 14, 2013, and IR 01515014, Mods/50.59: Control Room Toxic Air Response, dated May 17, 2013. The licensee planned to revise the calculation using detection of odor as an entry condition for donning of respirator protection and update the operating procedures accordingly.
Analysis:
The inspectors determined that the failure to translate the design basis correctly into procedures and instructions for operators was contrary to 10 CFR Part 50, Appendix B, Criterion III, and was a performance deficiency. Specifically, the licensee determined in calculation QDC-5700-M-1767 that the toxic chemicals analyzed did not pose a threat to the site, provided the control room operators donned respirators within two minutes of detection for ammonia. However, the licensees toxic gas response procedure did not ensure that operators would don respirators within two minutes of detection for ammonia.
The finding was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attributes of protection against external hazards (toxic hazard) and procedure quality and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to provide procedures or instructions to operators to don respirators could result in the operators becoming incapacitated and not able to respond to an accident or event that had a possibility of radionuclide releases.
In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, Table 2, the inspectors determined the finding affected the Mitigating Systems cornerstone. As a result, the inspectors evaluated the finding using Appendix A, The Significance Determination Process (SDP)for Findings At-Power, Exhibit 2 for the Mitigating Systems cornerstone and determined that a detailed risk evaluation was required. However, existing SDP methods and tools were not available to determine the significance of the finding. Therefore, the risk significance was evaluated in accordance with the qualitative criteria of Appendix M of IMC 0609. The inspectors noted that most ammonia gas accident scenarios provided the control room operators with over ten minutes of response time from automatic detection until they would be required to don respirators. For the cases involving barge accidents, the licensee determined the probability of an ammonia release was less than 1 x 10-6 per year using the guidance of NUREG/CR-6624, Recommendations for Revision of Regulatory Guide 1.78, dated November 1999. Therefore, based upon a qualitative measure of risk determined in accordance with Appendix M, the inspectors concluded that the issue was of very low safety significance (Green).
This finding has a cross-cutting aspect in the area of human performance, work control, because the licensee did not appropriately coordinate work activities by incorporating actions to address the need for work groups to communicate and coordinate with each other during activities in which interdepartmental coordination is necessary to assure plant and human performance. Specifically, the licensees engineering organization did not coordinate with the operations organization on the need to don respirators within two minutes of detection of ammonia gas following a postulated toxic chemical accident.
Enforcement:
Title 10 CFR Part 50, Appendix B, Criterion III, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.
Contrary to the above, from October 3, 2011 through May 17, 2013, the licensee failed to translate the design basis correctly into procedures and instructions for the operators.
Specifically, the licensee determined in calculation QDC-5700-M-1767 that toxic chemicals that were analyzed did not pose a threat to the site provided the control room operators donned respirators within two minutes of detection. However, the licensee did not develop procedures and instructions to assure that operators would don respirators within two minutes of detection of a toxic chemical.
This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very low safety significance and was entered into the licensees Corrective Action Program as IR 01513794. In addition, the licensee planned to revise the calculation using detection of odor as an entry condition for donning of respirator protection and update the operating procedures accordingly.
(NCV 05000254/2013007-01; 05000265/2013007-01, Failure to Translate Design Basis Into Toxic Chemical Response Procedures).
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
.1 Routine Review of Condition Reports
a. Inspection Scope
From April 22, 2013 through May 17, 2013, the inspectors reviewed 11 corrective action process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent plant modifications and evaluations of changes, tests, or experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.
b. Findings
No findings of significance were identified.
4OA6 Meetings
.1
Exit Meeting Summary
On May 17, 2013, the inspectors presented the inspection results to Mr. T. Hanley, Site Vice-President, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- T. Hanley, Site Vice-President
- R. Alkan, Engineer, Design Engineering
- C. Alguire, Acting Director, Engineering
- W. Beck, Manager, Regulatory Assurance
- D. Collins, Manager, Design Engineering
- M. Dunlay, Engineer, Design Engineering
- K. OShea, Director, Operations
- B. Stedman, Senior Manager, Design Engineering
- M. Wagner, Licensing Engineer, Regulatory Assurance
- T. Wojcik, Manager, Nuclear Oversight
Nuclear Regulatory Commission
- J. McGhee, Senior Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened and Closed
- 05000265/2013007-01 NCV Failure to Translate Design Basis Into Toxic Chemical Response Procedures (Section 1R17.2(b)(1))
Discussed
None