ML101740240

From kanterella
Jump to navigation Jump to search
Ltr from R. Zuffa IEMA - Bureau of Nuclear Facility Safety, Inspection Report Quarterly Inspection Period: October 1 to December 31, 2007
ML101740240
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 01/02/2008
From: Zuffa R
State of IL, Emergency Management Agency
To: Stocco K
NRC/RGN-III
References
FOIA/PA-2010-0209
Download: ML101740240 (23)


Text

m

  • Jan 02 08 02:49p Mazon Office 815-448-5902 P.i IM Rod R. Blagojevich, Governor Illinois Emergency Management Agency Andrew Velasquez III, Director Divsion of Nuclear Safety Joseph G. Klinger, Acting Assistant Director January 2, 2008 United States Nuclear Regulatory Commission - Region III Quad Cities NuclearStation 22710 2 0 6 1h Avenue North Cordova, I L 61242 Attention: Ms. Karla Stocdter, Senior Resident Inspector

SUBJECT:

IEMA - Bureau of NuclearFacility Safety. Inspection Report Quarterly Inspection Period: October 1 to December 31, 2007

Dear:

Ms. Stoedter, On December 31, 2007 the Illinois Emergency Management Agency-Bureau of Nuclear Facility Safety Resident Inspector completed the quarterly inspection activities at the Quad Cities Nuclear Station, Units I and 2. Per the terms and conditions of the Memorandum of Understanding (MOU) between the NRC and IEMA-BNFS, the enclosed inspection report documents our agency's inspection issues and concerns that were previously discussed with you and members of your resident inspection staff.

The TEMA-BNFS inspection activities were conducted as they relate to nuclear safety and to compliance with the Commission's rules and regulations and with the conditions of the plant license. The inspector(s) reviewed selected licensee procedures and records, observed licensee activities, and interviewed licensee personnel.

Specifically, the IEMA-BNFS inspection activities for this period focused on Adverse Weather Protection (R01). Equipment Alignments (R04), Fire Protection (RO5), Licensed Operator Requalification Program (RI 1), Maintenance Risk Assessment and Emergent Work Evaluation (R] 3), Post Maintenance Testing (R19), Surveillance Testing (R22), Access Control to Radiologically Significant Areas (OS i), Environmental Monitoring Program (REMP) and Radioactive Material Control Program (PS3), Identification and Resolution of Problems (OA2), Event Follow Up (OA3) and other inspection activities as identified herein and as disseminated within the text of the IEMA-BNFS Inspection Report.

/

1 1035 Outer Park Driva Springfield, Illinois 6270U-4462

  • Telephone: (2171783-9900 www.iema.illinois.gov
  • Printed by the Authority of the State of Illinois on Recycled Paper 9 www.ready.illinois.gov

Mazon Office 815-448-5902 p.2

'Jan 02 08 02:45p

  • 1 MA_ Iloagojuvich, Governor Rod. R.

Illinois Emergency Management Agency Andrew Velasquez III, Director oDv*ion of Nucleor Safety Joseph G. Klinger, Acting Assistant Director The following items have been referred to your NRC Resident Inspector Office for potential regulatory action and are summarized below with the appropriately referenced report section ( )*

1. Failure by the licensee to document control rod exercising in the Main Control Room log and failure to maintain permanent records of Activities affecting quality (1R04).

In addition, the. following IEMA Inspector items that were being tracked by IEMA, are considerod closed to further IEMA review and are discussed within their respective report reference ):

1. Inspector's review of licensee's documentation to validate that Epoxy floor coverings meet the flammability requirements of the Station's Fire Hazards Analysis (1R05).

Any issues, open items and/or concerns that are discovered during the course the inspection period arc-normally entered into the IEMA - Bureau of Nuclear Facility Safety Plant Issues Matrix, and by this letter, are considered as disseminated to your NRC staff for disposition in accordance with NRC policies and procedures. In full cooperation with the and at the request of the NRC, IEMA-BNFS will continue to follow and assist the NRC Resident Inspection Staff with resolution and closure of all such issues, open items and/or concerns.

In full cooperation with and at the request of the NRC, IEMA-BNFS will continue to follow and assist the NRC Resident Inspection Staff with resolution and closure of all such issues and concerns.

If you have any questions, please contact me at your earliest convenience.

Sincerely yours, Richard J. Zuffa IEMA-BNFS/RI Unit Supervisor Resident Inspection Staff

'2 10315 Outer Park Drive - Springfield, Illinois 62704.4462

  • Toelphone; (217)785-9900 wwwierno.illinois.gov - Printed by the Authority of the Slate of Illinois on Recycled Paper & www.rmady.illinois.gov

ýjan 02 00 02:49p Mazon Office 815-448-5902 p. 3 ji ,

IEMA Illinois Emergency Management Agency Rod R. Blagojevich, Governor Andrew Velasquez III, Director Division oF Nuclear Saofly Joseph G. Klinger, Acting Assistant Director Docket Nos. 50-254; 50-265 License Nos. DPR-29; DPR-30 Enclosure(s): Inspection Report: 07QC-4QIR cc w/o encl: A.C. Settlcs, Chief Division of RICC C.H. Mathews, IEMA-BNFS-RI 3

1035 Outer Park Drive Sprirsfeld, Illinois 62704-4462 Telephone: 1217)785-9900 www.iomo,illinois.gov P Printedby the Authority of the State of Illinois on Recycled Paper

  • www.ready.illinoia.gov

IEMA INSPECTION REPORT

SUMMARY

07QC-4QIR STATION: Quad Cities UNIT 1 - DOCKET NO: 50-254 UNIT 2 - DOCKET NO: .50-265 IEMA INSPECTORS: Robert Ganser Charlie Mathews INSPECTION DATES: October 1 through December 31, 2007 NRC REPORT NUMBER: 2007-05 INSPECTION HOURS: 110 INSPECTION

SUBJECT:

Safety Inspection of the Quad Cities Nuclear Power Station VIOLATIONS: One:

Failure by the licensee to document control rod exercising in the Main Control Room log and failure to maintain permanent records of Activities affecting quality [Section 1R041 OPEN ITEMS: None UNRESOLVED ITEMS: None ITEMS CLOSED: [07QC-3QIR-02] Inspector's review of licensee's,documentation to validate that Epoxy floor coverings meet the flammability requirements of the Station's Fire Hazards Analysis [Section 1R051 I

Report Details Plant Status Unit 1 Unit 1 began the inspection period operating at funl rated electrical load of 912 MWe and operated at or near full power through the inspection period with the following exceptions. Small power reductions were performed as required to facilitate planned control rod maintenance activities.

On December 15, 2007, unit power was reduced to approximately 750 MWe to facilitate main turbine testing. Upon completion of turbine testing, the unit was restored to full power operations.

Unit 2 Unit 2 began the inspection period operating at full rated electrical load of 912 MWe and operated at or near full power through the inspection period with the following exceptions. Small power reductions were performed as required to facilitate control rod maintenance activities.

On October 25, 2007, unit power was reduced to approximately 785 MWe to facilitate an emergent repair to the 2D Condensate Pump. The unit was-returned to full power on October 26, 2007.

-On December 16, 2007, unit power was reduced to approximately 725 MWe to facilitate control rod pattern adjustment and restored to full power operations.

1. REACTOR SAFETY Initiating Events, Mitigating Systems, Barrier Integrity 1R01 Adverse Weather Protection (IEMA Keystone: Reactor Safety) (71111.01)
a. Inspection ScoRe The inspector monitored the licensee's activities in preparation for cold winter weather conditions and severe weather during pending storm activity.
b. Observations and Findings 2

Several high wind periods occurred, one involving server icing conditions, during the inspection period. The inspectors monitored the licensee's preparations to ensure that there was no impact to the plant due to loose debris that could become airborne missile hazards in high wind conditions.

There were no missile hazard events due to improper placement of outdoor materials. The licensee's vigilance in the control of potential missile hazards was maintained at an appropriate level.

During severe icing conditions on December 1, 2007, the station experienced the loss of a number of the required Emergency Sirens; however, restoration efforts were conducted such that the sirens were restored in a timely manner. No emergency notification system (ENS) reporting was required. Winter ice storm conditions again occurred on December 10 through December 12, 2007. There were no failed sirens reported and power was maintained to the grid with no significant local power outages in the area.

c. Conclusions There were no apparent degraded conditions associated with this inspection activity.

1R04 Equipment Alignment (IEMA Keystone: Reactor Safety) (71111.04)

a. Inspection Scope S1 The inspectors performed equipment configuration alignment inspections in the following plant areas:
  • Mafin Control Room and Back Panel Areas
  • Auxiliary Electrical Equipment Room 9 River Intake Structure

' Both Unit Reactor Feed Water Pump Rooms

  • Both Unit 4 KV Buses (safety and non-safety)

-Both Unit Condensate Pump Bays

  • Both Unit HPCI Rooms
  • Unit 2 ECCS Pump Rooms
  • Unit 1, Unit 2, and Unit 1/2/ EDG Rooms
  • Refuel Floor 3
  • e Outside areas including river Intake/Discharge flume

.2 The inspectors performed a review of plant activities during the September 8-10 Unit 1 forced outage. Main Control Room logs, procedures, and Technical Specifications were reviewed.

b. Observations and Findings
  • 1 During walk down inspections of plant equipment areas, the inspector verified equipment configuration and observed for any material condition deficiencies that could prevent proper equipment operation. Equipment areas were inspected for system leakage, personnel safety hazards, potential interference with system components and controls, fire hazards, water intrusion, and the integrity of system structural supports. The inspector monitored equipment areas for abnormal vibration, odors, sounds, or other conditions that could impact proper equipment operation and plant safety.

The inspectors conducted equipment area inspections of equipment in protected status when possible during periods when on-line maintenance activities were in progress on redundant trains of safety significant equipment.

.2 On September 8, 2007, at 12:04 AM Unit 1 separated from the grid for Forced Outage Q1F58. The purpose of the outage was to repair an electrical short associated with High Pressure Core Injection System inboard steam line isolation valve.

On September 10 while reviewing the Main Control Room logs, the inspector identified that on September 8, at 4:07 am, that Unit 1 reached Mode 3 (Hot Shutdown). Thirteen minutes later, at 4:20 am, the mode switch was moved, by procedure, from the SHUTDOWN to the REFUEL position.; The mode switch remained in the REFUEL position until September 10 at 6:40 pm when the unit entered mode 2 for reactor restart.

The Mode switch was in the REFUEL position for approximately 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br /> and 20 minutes.

An inspector review of Technical Specifications (T.S.) section 1.1, Definitions; MODE is defined as:

A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel 4

head closure bolt tensioning as specified in Table 1.1-1 of the technical specifications with fuel in the reactor vessel.

For HOT and COLD SHUTOWN, T.S. Table 1.1-1 indicates that the applicable mode switch position shall be the SHUTDOWN position. There are three T.S. Special Operations LCOs that permit the movement of the Reactor Mode switch out of the SHUTDOWN position when in Modes 3 and 4 to allow for testing instrumentation associated with the reactor mode switch interlock functions and for exercising control rods. They are as follows:

  • 3.10.1, Reactor Mode Switch Interlock Testing; The reactor mode switch position specified in Table 1.1-1 for MODES 3, 4, and 5 may be changed to include the run, startup/hot standby, and refuel position, and operation considered not to be in MODE 1 or 2, to allow testing of instrumentation associated with the reactor mode switch interlock functions, provided:
a. All control rods remain fully inserted in core cells containing one or more fuel assemblies; and
b. No CORE ALTERATIONS are in progress.

APPLICABILITY: MODES 3 and 4 with the reactor mode switch in the run, startup/hot standby, or refuel position, MODE 5 with the reactor mode switch in the run or startup/hot standby position.

  • 3.10.2, Single Control Rod Withdrawal-Hot Shutdown; The reactor mode switch position specified in Table 1.1-1 for MODE 3 may be changed to include the refuel position, and operation considered not to be in MODE 2, to allow withdrawal of a single control rod, provided the following requirements are met:
a. LCO 3.9.2, "Refuel Position One-Rod-Out Interlock";
b. LCO 3.9.4, "Control Rod Position Indication";
c. All other control rods are fully inserted; and d.

Instrumentation," MODE 5 requirements for Functions 1.a, L.b, 7.a, 7.b, 11, and 12 of Table 3.3.1.1-1, 9 LCO 3.3.8.2, "Reactor Protection System (RPS) Electric Power Monitoring," MODE 5 requirements, and

OR 5

, All other control rods in a five by five array centered on the control rod being withdrawn are disarmed; at which time LCO 3.1.1, "SHUTDOWN MARGIN (SDM),"

MODE 3 requirements, may be changed to allow the single control rod withdrawn to be assumed to be the highest worth control rod.

APPLICABILITY: MODE 3 with the reactor mode switch in the refuel position.

3.10.3, Single Control Rod Withdrawal-Cold Shutdown; LCO 3.10.3 The reactor mode switch position specified in Table 1.1-1 for MODE 4 may be changed to include the refuel position, and operation considered not to be in MODE 2, to allow withdrawal of a single control rod, and subsequent removal of the associated control rod drive (CRD) if desired, provided the following requirements are met:

a. All other control rods are fully inserted;
b. 1. LCO 3.9.2, "Refuel Position One-Rod-Out Interlock," and LCO 3.9.4, "Control Rod Position Indication,"

OR

2. A control rod withdrawal block is inserted; and
c. 1. LCO 3.3.1.1, "Reactor Protection System (RPS)

Instrumentation," MODE 5 requirements for Functions 1.a, 1.b, 7.a, 7.b, 11, and 12 of Table 3.3.1.1-1,

2. LCO 3.3.8.2, "Reactor Protection System (RPS) Electric Power Monitoring," MODE 5 requirements, and LCO 3.9.5, "Control Rod OPERABILITY-Refueling,"

OR

2. All other control rods in a five by five array centered on the control rod being withdrawn are disarmed; at which time LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," MODE 4 requirements, may be changed to allow the single control rod vi~thdrawn to be assumed to be the highest worth control rod.

APPLICABILITY: MODE 4 with the reactor mode switch in the refuel position.

Based upon the above three TS., operations may place the mode switch into the REFUEL position if they are moving control rods or testing instrumentation associated with the reactor mode switch.

The inspector reviewed the main control room logs on Monday September 10, and seeing no main control room log entries describing control rod 6

movement, questioned main control room operators about the current mode switch position and if any control rod movement was occurring. The inspector was informed that they had been "stroking rods" and that they were having problems with the Rod Position Indicating System (RPIS) that might require them to move control rods for post maintenance (PM) testing.

No mention of control rod motion was ever recorded in the Main Control Room log.

The inspector reviewed Exelon corporate procedure OP-AA-1 11-101, revision 6. OPERATING NARRATIVE LOGS AND RECORDS, to determine the requirements that Exelon required for the level of detail for main control room logs. Exelon procedure OP-AA-11-101, step 4.1.1 states "Maintain records at a level of detail that will allow reconstruction of shift activities by oncoming personnel that do not have the benefit of a face-to-face discussion of the shift." Contrary to this requirement, the main control logs for September 8-10, 2007 made no mention of any control rod movement even though main control room operators stated that they were moving control rods intermittently through out the entire outage. In response to this issue generated by the inspector, IR # 692880 was initiated.

On September 20 and 21, the inspector attempted to obtain documentation corroborating the intentional movement of control rods during the Unit 1 outage September 8-10, 2007. The inspector talked to the Control Rod Drive (CRD) System Engineer, the Operations Records Coordinator, and Station Nuclear Engineers looking for verbal and documented evidence of control rod movement. All three personnel thought that control rods had been exercised, but none had any documentation. The CRD System Engineer stated that procedure QCOP 0300-18, rev. 18. CONTROL ROD EXERCISING should have been performed and she would continue to look for a copy. The inspector was later informed that the completed procedure, QCOP 0300-18, had been inadvertently shredded. The inspector was informed by operations personnel that procedure QCOP 0300-18 has a "life of plant" retention requirement. In response to this issue, IRs #,692865 and

  1. 680638 were initiated.

On October 2, 2007, the inspector, along with the NRC Senior Resident Inspector, determined that procedure Q X-"30TTýi' step F.4, directed the operators to place-the ode switch in to the REFUEL position per procedurO760P 050_0-6,jv. 7, MOVING THE REACTOR MODE SWITCH OU fSITUTDOWN POSITION, but QCOP 0300-18 did not Y-O7 contain a step to return the mode switch to SHUTDOWN per QCOP 0500-

06. Thus procedure QCOP 0300-18 did not contain steps to return the mode switch to the SHUTDOWN position following completion of control 7

rod exercising.. This procedure shortcoming resulted in the procedure not being capable of maintaining compliance with T.S. 3.10.2 & 3 and the reactor mode definition.

c. Conclusions

.1 There were no apparent degraded conditions during the equipment walk down portion of this inspection activity.

.2 The inspector attempted to verify, that control rod exercising or Mode Switch testing occurred during the September 8-10 Unit 1 forced outage, but no paperwork existed. Interviews with Main Control Room operators indicated that control rod exercising did occur over the duration of the 62 hour7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br /> shutdown; however there,.was no documentation to support the Main Control Room operator's comments. Failure to maintain documentation in support of T.S. 3.10.1, 2, & 3 is an apparent failure to follow those actions and definitions as prescribed by the Technical Specifications. Failure to maintain mode switch position per the T.S. indicates an apparent lack of reactivity control by the licensee.

The inspector identified three issues relating to maintaining the correct Modes Switch position as required per the T.S.: 1. The Main Control Room logs did not contain enough information to allow a knowledgeable individual to reconstruct shift activities in relation to control rod movement and exercising, as required by plant procedures. 2. Plant personnel shredded the original copy of procedure QCOP 0300-18, rev 18, CONTROL ROD EXERCISING. This procedure documented control rod exercising during the plant shutdown. Therefore, two levels of documentation failed to provide evidence of compliance with T.S. 3.10.2, and 3.10.3.

Criterion XVII of IOCFR50 Appendix B, "Quality Assurance Records",

states in part that, "Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses.. The records shall also include closely-related data such as qualifications of personnel, procedures, and equipment. Inspection and test records shall, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted. Records shall be identifiable and retrievable. Consistent with applicable regulatory requirements, the applicant shall establish 8

requirements concerning record retention, such as duration, location, and assigned responsibility."

Contrary to the above, failure by the licensee to document control rod exercising in the Main Control Room log and failing to maintain control of procedure QCOP 0300-18, rev 18, CONTROL ROD EXERCISING, is an apparent violation of 10CFR50 Appendix B criterion XVII Quality Assurance Records per T.S. for failing to document compliance with T.S.

Criterion V of 10CFR50 Appendix B, "Instructions, Procedures, and Drawings" states in part that, "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

Contrary to the above, Procedure QCOP 0300-18 rev 1-8, CONTROL ROD EXERCISING, does not contain procedure steps to restore the Mode Switch to SHUTDOWN or reference back to procedure QCOP 0500-06, rev 7, MOVING THE REACTOR MODE SWITCH OUT OF SHUTDOWN POSITION. This is an apparent violation of 10CFR50 Appendix B criterion V for failure to provide procedure guidance.

There were no apparent degraded conditions identified in this inspection area and one apparent violation of the criteria of IOCFR50 Appendix B.

1R05 Fire Protection (IEMA Keystone: Reactor Safety) (71111.05)

(Closed): Open Item [07QC-3QIR-02]; Verify that licensee's Epoxy floor coverings meet the flammability requirements for the Station's Fire Hazards Analysis.

In the previous inspection period, the inspector had questioned the licensee as to whether the application of Epoxy floor coverings had met the Station's Fire Hazards Analysis requirements. The station had applied considerable amounts of Epoxy floor covering material in recent years.

Initial review of the NRC Information Notice, IN 2007-26, indicated to the inspectors that there were relevant issues at several nuclear stations concerning the flammability of Epoxy floor coverings. The initial documentation, provided by the licensee's Station Maintenance Specialist 9

responsible for floor painting work, included the Material Safety Data Sheets (MSDS) for the sub-components of the Epoxy floor covering mixture; however, documentation of the developed product was unavailable at that time. Additionally, the licensee's corporate level evaluation of the NRC Information Notice was in also progress and has since been completed.

Subsequently, the inspector performed a final review the licensee's evaluation documents supporting the use of Epoxy floor coverings. In this review, the inspector verified that the licensee's evaluation, EC 350993RO, to revise EC 342987, and in response to Action Request, AR 661700661700 has adequately addressed the NRC Information Notice, IN 2007-26, assuming that the proposed licensee recommendations are implemented as stated.

These required actions, documented in Action Request, AR 661700661700 required the licensee to include the following:

  • Revision of the Exelon coating procedure, MA-AA-716-016, Control of In-Plant Non-Safety-Related Paintings / Coatings, to provide the controls needed to address the non-safety related work activities. This included the majority of the risk area and would enforce that the coatings were installed to meet the NRC's Branch Technical Position commitments or provide documented evaluations to exceptions to MA-AA-716-016 in accordance with procedure, CC-AA-209.

Provide modification to the language in the controls provided by ER-P AA-330-008, Exelon Service Level 1 and Safety-Related (Service Level III) Protective Coatings, to ensure consistency with the final approach recommended by NRC Information Notice, IN 2007-26.

  • Provide more qualified statements to reflect actual site practices in the application of Epoxy floor coverings.
  • Review and revise site combustible loading calculations as required to add combustible floor paint to the calculations if the floor covering does not meet the NRC's definition of "Non-combustible."

Review the site coating application procedures and specifications to ensure that they are sufficiently prescriptive regarding the Station's Fire Hazards Analysis. This item is considered closed. /

a. Inspection Scope During the conduct of plant walk down inspections to verify equipment alignment, the inspectors observed station fire protection systems for any adverse material conditions that could impair the systems emergency function. The inspector also monitored the licensee's fire protection 10

equipment staging areas to verify proper equipment storage and condition and to verify proper access to all required fire protection equipment.

b. Observations and Findings During performance of plant walk-own inspections the inspector observed that fire protection systems were properly aligned. Fire equipment staging areas were accessible and no deficient equipment was identified.
c. Conclusions There were no apparent degraded conditions associated with this inspection activity.

1R13 Maintenance Risk Assessment & Emergent Work EValuation (IEMA Keystone: Reactor Safety) (71111.13)

a. Inspection Scope The inspector monitored the licensee's on-line risk assessment on a continued basis.
b. Observations and Findings The inspector monitored the on duty shift activities concerning risk assessment practices during schedule alterations and emergent work situations. The on-shift supervisors updated the on-line risk assessments appropriately when plant conditions warranted and stated that their accepted practice was to consult the Station Risk Coordinator in the event they would encounter an equipment configuration not previously evaluated.

On December 10, 2007, severe ice storms developed and were predicted to prevail while planned maintenance had been scheduled to begin on the Unit 2 Station Blackout (SBO) Diesel Generator (DG). The on-line risk assessment indicated that there minimal risk with the SBO DG out of service for scheduled maintenance. However, the station management decided to postpone the scheduled maintenance in order to maintain the availability of the SBO DG while icing conditions persisted.

On December 11, 2007, the inspector accompanied the NRC Interim Resident Inspector on a plant tour to verify the protected equipment configuration during planned maintenance on the Safe Shutdown Makeup 11

Pump (SSMP). The areas checked by the inspectors included the Residual Heat Removal heat exchangers on both units, the Unit 1 and Unit 1/2 Emergency Diesel Generators (EDG) including the respective EDG Cooling Water pumps, and Transformer 12. All postings for the protected equipment were appropriately placed. The inspectors also verified the protected equipment standby status at the main control room panels. All indications were as required and no problems were identified. During the plant walk down, the inspectors noted several water leaks that appeared to be the result of roof leakage and reported these to the Unit 1 Unit Supervisor.

c. Conclusions The inspector assessed that the licensee's decision to reschedule the maintenance work on the Unit 2 SBO Diesel Generator was appropriately executed and minimized the plant risk during severe weather conditions.

There were no apparent degraded conditions associated with this inspection activity.

1R19 Post Maintenance Testing (IEMA Keystone: Reactor Safety) (71111.19)

a. Inspection Scope On November 15, 2007, the inspector reviewed the proposed post maintenance testing (PMT) package scheduled to be performed on the evening shift prior to placing the Unit 1 Station Blackout Diesel Generator back into standby service following extensive maintenance.
b. Observations and Findings Based on the inspector's review of the work performed, the inspector concluded that the licensee's scheduled PMT tasks met the requirements for returning the Unit 1 SBO Diesel Generator to available status. The licensee performed the required testing on the evening shift on November 15, 2007 satisfactory and the SBO DG was returned to service.
c. Conclusions" There were no apparent degraded conditions associated with this inspection activity.

12

1R22 ( Surveillance Testing (IEMA Keystone: Reactor Safety) (71111.22)

a. Inspection Scope On October 19, 2007, the inspector observed the licensee conduct the pre-job briefing, perform portions of surveillance test, QCOS 2300-11, CCST/TORUS Level Switch Functional Test, and review completed test documentation.

On December 4, 2007, the inspector observed a portion QCIS 700-30, OPRM Division II Functional Test.

b. Observations and Findings The pre-job briefing conducted prior to QCOS 2300-11 on October 19, 2007, was thorough. Good engagement in the briefing process was demonstrated by the operators and technicians. Following test completion, the inspector verified the completed test documentation for QCOS 2300-11 and no problems or issues were identified.

On December 4, 2007, the inspector verified installation of the test box during the conduct of QCIS 700-30. The portions of the tests observed by the inspector were properly conducted and there were no issues.

c. Conclusions There were no apparent degraded conditions associated with this inspection activity.
2. RADIATION SAFETY 20S Occupational Radiation Safety 20S1 Access Control to Radiologically Significant Areas: (IEMA Keystone:

Occupational Radiation Safety) (71121.01)

Throughout the inspection period, during performance of general plant inspection and equipment alignment verification activities, the inspector observed the licensee's posting of radiation areas in the plant. Areas observed were properly posted and no issues were identified with the licensee's access controls.

13

There were no apparent degraded conditions associated with this inspection activity.

20S2 ALARA Planning and Controls: IEMA Keystone:. Occupational Radiation Safety) (71121.02)

The inspector continued to monitor the licensee's ALARA activities to ensure thatthe licensee minimized the radiation exposure to plant workers.

The licensee had recently achieved significant reduction in personnel exposure. These gains were due primarily to the reduction in the plant source term which had been an ongoing effort conducted over the past years.

Achieving improvements in personnel radiation exposure was also attributed to the continued diligence of the plant workers in job planning and execution. Throughout the inspection period, the inspector continued to challenge Station personnel on their attention to ALARA practices. As an example, on November 27, 2007, the inspector interviewed a Station engineer who had given the morning management overview report at the Plan of the Day meeting. As the person reporting out on the overview activity noted several opportunities for improvement, the inspector questioned the engineer as to whether he had followed up to ensure that the areas for improvement were adequately implemented. Based on the engineers account, the inspector was satisfied that the ALARA practice improvements would be sustained and that the engineer had performed appropriate follow up. The primary benefit to this activity provided more active use of the licensee's ALARA micro-brief checklist tool as part of the Radiation Work Permit pre-job Radiation Protection briefing.

There were no apparent degraded conditions associated with this inspection activity.'

2PS Public Radiation Safety 2PS3 Environmental Monitoring Program (REMP) and Radioactive Material Control Program: (IEMA Keystone: Public Radiation Safety) (71122.03)

Based on the detection of Tritium in ground water, the Quad Cities Station

.had elevated the actions of the Station Tritium monitoring program by increased sampling and the recent installation of additional monitoring 14

wells. The licensee's initial sample results from the newly installed monitoring wells indicated an active Tritium leak.

With these sample indicators confirmed, on October 12, 2007, the Station notified the IEMA and IEPA and NRC (Event Notification 43720) of elevated Tritium samples that were discovered in the newly installed monitoring well (QC-GP-2) located outside the Unit 1 track Way. On October 15, 2007, the Station issued a press release to inform the public of this new information concerning active Tritium leakage on site.

Station representatives conducted a good-neighbor action to go door-to-door in the vicinity of the plant to update the residents living near the facility of the recent discovery. The inspector observed the licensee's Tritium Task Force activities throughout the inspection period to assess the licensee's public safety awareness since there was increased potential for ground water contamination from leakage from underground piping systems to migrate to off-site locations.

The sample results from newly installed monitoring wells indicated that the source of Tritium appeared to be originating in the area directly beneath plant buildings in the vicinity of the'under ground piping routed from the Contaminated Condensate Storage Tanks (CCSTs), beneath the service building, and into the plant systems'. The most recently installed monitoring wells, indicating more elevated Tritium levels, were placed as near to the suspect piping as possible. New monitoring wells were installed south of the service building and samples from these wells have indicated Tritium levels significantly lower than the highest well near the suspected leakage source. No detectable levels of Tritium were found near the outer monitoring wells or at plant property boundaries.

The licensee implemented an action plan to locate active leakage, execute repairs, and remediate underground Tritium water. The licensee's leakage identification plan included sequential plugging of the supply lines to the ECCS inside the CCSTs, draining the sections of line, and obtaining samples to observe for a drop in the Tritium activity. The licensee also conducted Guided Wave Testing and Tracer Gas Testing.

A high station priority was assigned to support of the Tritium Remediation Project. Station management and the Tritium Project Team held conference calls with Exelon Corporate to present status and plan activities on a periodic basis. Options for long term resolution included excavation beneath the Service and Turbine Buildings, repairs, pipe replacement, and 15

CCST relocation. At the time of this summary, leak detection efforts continued on schedule with no definitive leak locations identified thus far.

.2 On November 14, 2007, the inspector participated in the IEPA/IEMA Joint Inspection at the Station. Licensee attendees included the Chemistry Manager and the Station Environmental Analyst. On October 12, 2007, the licensee had notified the IEMA and IEPA of elevated Tritium monitoring well sample results, their continued installation and subsequent sampling of new monitoring wells, and pursuit of underground piping integrity testing.

Based on additional elevated readings from the new monitoring wells in the proximity of the underground piping from the CCSTs to the Reactor Building, the licensee assessed that the probability of an active Tritium leak was higher than previously indicated. The IEPA Inspector conducted interviews with the licensee to review and assess the current conditions and the licensee's plan to locate and repair the current Tritium leak and subsequently remediate the ground water contamination on the site. The inspection activity included interview of licensee attendees and review of the station's most current Tritium monitoring well sample results. The inspector compiled summary information for the IEMA Supervisors following this inspection. The IEPA inspector had no open issues or concerns as a-result of this inspection.

The licensee had methodically proceeded through their leak identification plan and had collected numerous data to develop an assessment of which of the suspect buried piping was leaking into the ground beneath the service building. At the time of this sunmmary the data was not conclusive.

4 OTHER ACTIVITIES 40A2 Identification and Resolution of Problems: (IEMA Keystone: Other Activities) (7!152)

a. Inspection Scope The inspector reviewed the licensee's corrective action program activities to assess the program effectiveness.
b. Observations and Findings The inspector routinely reviewed the licensee's issue reports as the licensee continued to lower the expectation threshold for employees to generate issue reports. There were occurrences where there were missed 16

opportunities for employees to originate an issue report until reminded by management personnel. Nuclear Oversight originated issue reports when it was identified that a plant worker failed to originate an issue report.

c. Conclusions There were no apparent degraded conditions associated with this inspection activity.

40A5 Other Activities The inspector provided input to the IEMA analysts to address remote monitoring system issues.

The inspector assisted the GEMS field technician in communication with the licensee to provide Nitrogen to the GEMS Building as necessary to, maintain the continuity monitoring equipment operation.

Following the partial loss of Station emergency sirens on Decemberl, 2007, during ice storm conditions, 'the inspector interfaced with the Exelon equipment coordinator concerning system upgrades and provided the information to IEMA supervision.

The inspector developed turnover information to facilitate a smooth transition to the BWR Coordinator who is designated to fill the Station Resident Inspector position between the time of retirement of the current Resident Inspector and the installation of a new inspector.

40A6 Meetings, Including Exit On October 4, 2007, the inspector attended the licensee's annual EP participant's dinner meeting. The guest speaker was Mr. Roland Lickus from NRC Region III who gave a presentation on the NRC's participation in the Emergency Preparedness process.

On November 30, 2007, the inspector attended the NRC exit meeting for the Region III one-week Radiation Protection Inspection conducted in accordance with IP 71111.04. The inspector compiled summary information for the IEMA Staff following this event.

17

On December 6, 2007, the inspector attended the NRC Region III Resident Inspector Seminar.

40A8 Independent Fuel Storage Facility Inspection and Observations: (IP 60854)

The inspectors continued to observe licensee activities related to the Dry Cask Storage (DCS) of spent nuclear fuel at the site. In this inspection period, the licensee conducted DCS Campaign 3, involving the loading of 68 spent fuel bundles into each of five Multi-Purpose Canisters (MPCs),

their'transfer to HI-STORMs, and the movement of the five loaded HI-STORMs to the Independent Spent Fuel Storage Installation (ISFSI) pad located-at the south end of the site. The DCS loading and movement events were as follows:

  • The first MPC was loaded on September 28, 2007 and transferred to the ISFSI Pad on October 11, 2007.

9 The second MPC was loaded on October 17, 2007 and transferred to the ISFSI Pad on October 23, 2007.

  • The third MPC was loaded on October 26, 2007 and transferred to the ISFSI Pad on October 31, 2007.

o The fourth MPC was loaded on November 2, 2007 and transferred to the ISFSI Pad on November 7, 2007.

e The fifth MPC was loaded on November 9, 2007 and transferred to the ISFSI Pad on November 16, 2007.

DCS Campaign 1, storage of three fully loaded HI-STORM casks (204 fuel bundles) was completed January 5, 2006. DCS Campaign 2, storage of six fully loaded HI-STORM casks (408 fuel bundles), was completed August 13, 2006. DCS Campaign 3, storage of five fully loaded HI-STORM casks (340 fuel bundles), was completed on November 16, 2007. As of this date, there were a total of 952 spent fuel bundles on the ISFSI Pad.

18

, I INSPECTION PROCEDURES USED The following procedures were used to perform inspections during the report period. Documented findings are contained in the body of the report.

Inspection Procedure Number Title Section IP MC2515 Plant Status IP 71111-01 Adverse Weather Protection RO1 IP 71111-04 Equipment Alignment R04 IP 71111-05 Fire Protection R05 IP71111-11

  • Licensed Operator Requal Program R11 IP 71111-13 Maintenance Risk Assessments and Emergent Work Evaluation R13 IP71111-15
  • Operability Evaluations R15 IP 71111-19 Post Maintenance Testing R19 IP 71111-22 Surveillance Testing R22 IP 71111-23
  • Temporary Plant Modifications R23 IP 71114-06
  • Emergency Preparedness Drill Evaluation 1EP6 IP 71121-01 Access Control to Radiologically Significant Areas OSi PI 71121-02 ** ALARA Planning and Controls OS2 IP 71121-03
  • Radiation Monitoring Instrumentation and Protective Equipment OS3 IP 71122-01
  • Radiation Gaseous and Liquid Effluent Treatment and Monitoring System PSI IP 71122-03 Environmental Monitoring Program (REMP) and Radioactive Material Control Program PS3 IP 71152 Identification and Resolution of Problems OA2 IP 71153
  • Event Follow Up OA3 Chapter 2515 Other Activities OA5 Meetings, including Exit OA6 IP 60854 Independent Fuel Storage Facility Inspection 0A8 Inspection Modules marked with an (*) were included in the IEMA plan submittal, however, were not completed in this period due to the inspector's time restraints.

Inspection Modules marked with two (**) were not included in the IEMA plan submittal, however, were completed in this period due to inspection opportunity.

19

p*

LIST OF ACRONYMS AND INITIALISMS USED IN REPORT ALARA As Low As Reasonably Achievable BWR Boiling Water Reactor CCST Contaminated Condensate Storage Tank CRD Control Rod Drive DCS Dry Cask Storage D`G Diesel Generator ECCS Emergency Core Cooling System EDG Emergency Diesel Generator ENS Emergency Notification System GEMS Gaseous Effluent Monitoring System HPCI High Pressure Coolant Injection IEMA Illinois Emergency Management Agency IEPA Illinois Environmental Protection Agency IN Information Notice ISFSI Independent Spent Fuel Storage Installation KV Kilo-volt LCO Limiting Condition for Operation MPC Multi Purpose Container MSDS Material Safety Data Sheet NRC Nuclear Regulatory Commission QCIS Quad Cities Instrument Surveillance QCOP Quad Cities Operating Procedure QCOS Quad Cities Operating Surveillance RHRSW Residual Heat Removal Service Water RPIS Reactor Process Instrumentation System SBO Station Black Out 20