IR 05000254/2006013

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June 2, 2006

Mr. Christopher M. CranePresident and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC Quad Cities Nuclear Power Station 4300 Winfield Road Warrenville, IL 60555

SUBJECT: QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2NRC EMERGENCY PREPAREDNESS INSPECTION REPORT 05000254/2006013(DRS); 05000265/2006013(DRS)

Dear Mr. Crane:

On May 19, 2006, the NRC completed an inspection at your Quad Cities Nuclear PowerStation, Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on May 19, 2006, with Mr. R. Gideon and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, this inspection focused on emergency preparedness, including your staff's determinations of performance indicators for the Emergency Preparedness Cornerstone.On the basis of the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of NRC's C. Crane-2-document system (ADAMS). ADAMS is accessible from the NRC Web site athttp://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/Kenneth Riemer, ChiefPlant Support Branch Division of Reactor SafetyDocket Nos. 50-254; 50-265License Nos. DPR-29; DPR-30

Enclosure:

Inspection Report 05000254/2006013(DRS); 05000265/2006013(DRS)

w/Attachment:

Supplemental Informationcc w/encl:Site Vice President - Quad Cities Nuclear Power StationPlant Manager - Quad Cities Nuclear Power Station Regulatory Assurance Manager - Quad Cities Nuclear Power Station Chief Operating Officer Senior Vice President - Nuclear Services Senior Vice President - Mid-West Regional Operating Group Vice President - Mid-West Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing - Mid-West Regional Operating Group Manager Licensing - Dresden and Quad Cities Senior Counsel, Nuclear, Mid-West Regional Operating Group Document Control Desk - Licensing Vice President - Law and Regulatory Affairs Mid American Energy Company Assistant Attorney General Illinois Emergency Management Agency State Liaison Officer, State of Illinois State Liaison Officer, State of Iowa Chairman, Illinois Commerce Commission D. Tubbs, Manager of Nuclear MidAmerican Energy Company

SUMMARY OF FINDINGS

IR 05000254/2006013(DRS); 05000265/2006013(DRS); 05/15/2006 - 05/19/2006; Quad CitiesNuclear Power Station; Emergency Preparedness Specialist Report.The report covers a 1 week baseline inspection by two regional emergency preparednessinspectors, one resident inspector, and one licensed operator examiner. The inspection focused on the Emergency Preparedness Cornerstone in the Reactor Safety strategic performance area during the biennial emergency preparedness exercise. This inspection also included a review of records related to the three emergency preparedness performance indicators for the period January 1, 2005, through March 31, 2006.The NRC's program for overseeing the safe operation of commercial nuclear power reactors isdescribed in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000. A.Inspector-Identified and Self-Revealed FindingsNone.

B.Licensee-Identified Violations

A violation of very low safety significance (Green), which was identified and corrected bythe licensee, was reviewed by the inspectors. The violation and corrective actions are listed in Section 4OA7 of this report.

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REPORT DETAILS

1.REACTOR SAFETYCornerstone: Emergency Preparedness1EP1Exercise Evaluation (71114.01)

a. Inspection Scope

The inspectors reviewed the May 17, 2006, biennial emergency preparednessexercise's objectives and scenario to ensure that the exercise would acceptably test major elements of the licensee's emergency plan and to verify that the exercise's simulated problems provided an acceptable framework to support demonstration of the licensee's capability to implement its plan. The inspectorsalso reviewed records of emergency preparedness drills, which were conducted in2005 through April 2006, to verify that those drills' scenarios were sufficiently differentfrom the scenario used in the May 2006 exercise.The inspectors evaluated the licensee's exercise performance, focusing on therisk-significant activities of emergency classification, notification, and protective action decision making, as well as implementation of accident mitigation strategies in the following emergency response facilities:*Control Room Simulator (CRS);*Technical Support Center (TSC);

• Operations Support Center (OSC); and

• Emergency Operations Facility (EOF).The inspectors also assessed the licensee's recognition of abnormal plant conditions,transfer of responsibilities between facilities, internal communications, interfaces withoffsite officials, readiness of emergency facilities and related equipment, and overallimplementation of the licensee's emergency plan.The inspectors attended post-exercise critiques in the CRS, TSC, OSC, and EOFto evaluate the licensee's initial self-assessment of its exercise performance. The inspectors later met with the licensee's lead exercise evaluators to obtain the licensee's refined assessments of its exercise participants' performances. These self-assessments were then compared with the inspectors' independent observations and assessments to assess the licensee's ability to adequately critique its exerciseperformance.These activities completed one inspection sample.

b. Findings

No findings of significance were identified.

31EP4Emergency Action Level and Emergency Plan Changes (71114.04)

a. Inspection Scope

The inspectors reviewed Revisions 21, 22, and 23 of the Quad Cities Station Annex tothe Exelon Standardized Emergency Plan to determine whether any changes made in these revisions reduced the effectiveness of the emergency plan and to verify that the licensee adequately incorporated Emergency Action Level (EAL) and terminology changes associated with NRC Bulletin 2005-02. Inspectors also reviewed a sample ofletters of agreement with local offsite support organizations to verify that these agreements were current and consistent with emergency plan statements. The inspectors also reviewed a sample of licensee evaluations of the changes in the Annex revisions, which were performed in accordance with 10 CFR 50.54(q) and the licensee's corrective action program, to determine if the 10 CFR 50.54(q) reviews were adequate.

The inspector also verified that minor corrections made to several numerical values in Table F-2, which was associated with the site-specific EALs' fission product barrier matrix, were editorial in nature.

b. Findings

A violation of very low safety significance, which was identified and corrected by thelicensee, is summarized in Section 4OA7.4.OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

Cornerstone: Emergency Preparedness.1Reactor Safety Strategic Area

a. Inspection Scope

The inspectors reviewed the licensee's records associated with each of the threeemergency preparedness PIs to verify that the licensee's program was implemented consistent with the industry guidelines in Nuclear Energy Institute Publication No. 99-02,

"Regulatory Assessment Performance Indicator Guideline," Revisions 2 and 3, and related licensee procedures. Specifically, licensee records related to the performance of the Alert and Notification System (ANS), key Emergency Response Organization (ERO)members' drill participation, and Drill and Exercise Performance (DEP) were reviewed toverify the accuracy and completeness of the PI data submitted to NRC for the periodfrom January 1, 2005 through March 31, 2006. The following three PIs were reviewed:Common

• ANS;*ERO Drill Participation; and

• DEP.These activities completed three PI samples.

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b. Findings

No findings of significance were identified.4OA7Licensee-Identified ViolationsThe following violation of very low safety significance (Green) was identified by thelicensee and is a violation of NRC requirements which meets the criteria of Section VI ofthe NRC Enforcement Policy, NUREG 1600, for being dispositioned as a Non-CitedViolation.Per 10 CFR 50.54(q), the licensee is required to follow its emergency plan. Section 3 ofthe Quad Cities Station Annex to the Exelon Standardized Emergency Plan stated thatthe site-specific EALs scheme was based on the NRC-endorsed guidance of NuclearManagement and Resources Council/National Environmental Studies Project-007 document, "Methodology for Development of Emergency Action Levels." This guidance included criteria for classifying an Unusual Event due to an inability to maintain waterlevel in the plant's spent fuel pool that would be at or above a numerical value listed inthe Station's Technical Specifications. In late 2004, the licensee revised the wording of corresponding site-specific EAL MU-11as part of a project to improve the standardization of the wording of a number of EALs at its nuclear stations. Specifically, the words "above the fuel" were added to EAL MU-11's threshold value statement. However, the numerical value listed in the EAL's threshold value statement was not adjusted to refer to the minimum water level above the spent fuel that was listed in the Technical Specifications. Instead, the numerical valuecontained in EAL MU-11's threshold value statement incorrectly referred the pool's water level as measured from the bottom of the pool. The incorrect wording of revised EAL MU-11 was not identified in the licensee's internal review processes prior to incorporating this incorrectly worded EAL in Revision 19 of the Quad Cities Station Annex, which became effective in December 2004.The licensee identified the aforementioned error in the wording of EAL MU-11 during itsongoing preparations to update its nuclear stations' EAL schemes to the guidance of Revision 4 of the Nuclear Energy Institute 99-01 publication, which NRC endorsed in2003. The inspectors verified that the licensee adequately used its corrective action program to document its identification of the incorrectly worded EAL MU-11, and to adequately assess the causes of this erroneously worded EAL. The inspectors also verified that the licensee completed its planned corrective actions, as were indicated in corrective action program. These actions included promptly issuing a standing order to Control Room personnel to inform them of the incorrectly worded EAL MU-11 pending its correction in December 2005's Revision 22 of the Quad Cities Station Annex to the licensee's standardized emergency plan. The licensee also enhanced its administrative practices for processing proposed changes to its EALs.The inspectors assessed the significance of the incorrect wording of EAL MU-11,which existed between December 2004 and December 2005, using NRC ManualChapters 0612 and 0609, Appendix B. The inspectors concluded that this licensee-identified, incorrectly worded EAL was a violation of very low safety significance

5(Green). The inspectors verified that adequate interim and longer-term correctiveactions were completed as described in the corrective action program records.4OA6Meetings.1Exit MeetingAn exit meeting was conducted for:

• Emergency Preparedness with Mr. R. Gideon and other members of licenseemanagement and staff at the conclusion of the inspection on May 19, 2006. The licensee acknowledged the information presented. No proprietary information was identified..2Public and Media Briefing*On May 19, 2006, an inspector was prepared to summarize NRC's preliminaryexercise inspection conclusions at separate public and media briefings hosted by Department of Homeland Security (DHS) Region V and Region VII staffs in Cordova, Illinois. However, DHS staff cancelled both meetings due to no members of the public or media being present.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Armitage, Training Director

W. Beck, Regulatory Assurance Manager

A. Fuhs, Regulatory Assurance Engineer

R. Gideon, Plant Manager

K. Kemper, Exelon Emergency Preparedness Director

R. Mika, Emergency Preparedness Drill and Exercise Coordinator

D. Moore, Nuclear Oversight Manager

K. Ohr, Radiation Protection Manager

M. Perito, Operations Manager

W. Stoermer, Communications Manager

P. Sunderland, Emergency Preparedness Coordinator

D. Tubbs, MidAmerican Energy

C. Tzomes, Emergency Preparedness ManagerIllinois Emergency Management Agency

R. Ganser, Resident Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and DiscussedNone.

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list doesnot imply that the NRC inspectors reviewed the documents in their entirety but rather that selected sections of portions of the documents were evaluated as part of the overall inspection effort.

Inclusion of a document on this list does not imply NRC acceptance of the document orany part of it, unless this is stated in the body of the inspection report.1EP1Exercise EvaluationQuad Cities Station May 2006 Exercise Scenario Manual Quad Cities Station April 2006 Pre-Exercise Drill Findings and Observations Report;dated May 12, 2006Quad Cities Station 2005 Off-Year Exercise Scenario Narrative Summary and Time Line

2Draft Quad Cities Station 2006 Exercise Findings and Observations Report; undatedQuad Cities Station Annex to the Exelon Standardized Emergency Plan; Section 3;Revision 23EP-AA-110; Assessment of Emergencies; Revision 6

EP-AA-111; Emergency Classification and Protective Action Recommendations;Revision 11EP-AA-112; Emergency Response Organization and Emergency Response FacilityActivation and Operation; Revision 9EP-AA-112-100; Control Room Operation; Revision 7

EP-AA-112-200; TSC Activation and Operation; Revision 5

EP-AA-112-300; OSC Activation and Operation; Revision 5

EP-AA-112-400; EOF Activation and Operation; Revision 6

EP-AA-113; Personnel Protective Actions; Revision 7

EP-AA-114; Notifications; Revision 6

EP-MW-110-200; Dose Assessment; Revision 4

EP-MW-114-100; Midwest Region Offsite Notifications; Revision 51EP4Emergency Action Level and Emergency Plan ChangesQuad Cities Station Annex to the Exelon Standardized Emergency Plan; Revisions 21,22, and 23IR

00475146; Minor Errors Identified in Four Maximum Normal Area Radiation AlarmValues in Table F-210

CFR 50.54(q) Evaluation and Effectiveness Review 06-27; Revision 23 ofQuad Cities Station Annex to Exelon Standardized Emergency Plan Site-Specific Letters of Agreement with Four Offsite Support Organizations 4OA1Performance Indicator VerificationEP-AA-125-1001; Emergency Preparedness Performance Indicator Guidance; Revision 3EP-AA-125-1002; ERO Drill/Exercise Performance - Performance Indicator Guidance;Revision 3

Attachment3EP-AA-125-1003; ERO Readiness - Performance Indicator Guidance; Revision 4Quad Cities Station Emergency Planning Zone Sirens' Daily and Monthly OperabilityReports - January 2005 through March 2006

LS-AA-2110; Monthly PI Data Elements for ERO Drill Participation - January 2005through March 2006LS-AA-2120; Monthly PI Data Elements for Drill/Exercise Performance - January 2005through March 2006LS-AA-2130; Monthly PI Data Elements for ANS Reliability - January 2005 throughMarch 2006Sequence of Events for Scenario Used in Several First Quarter 2006 IntegratedResponse Facility DrillsIR

00465594; Two Unsuccessful DEP Opportunities During First Quarter 2006 DrillsERO Required Reading Package 2006-03; Missed PI Opportunities in 2006 FirstQuarter Drills4OA7Licensee-Identified ViolationsIR

00433896; Wording Error Apparent in EAL MU-11

IR 00434537; Wording Error in Unusual Event EAL MU-11

Apparent Cause Report; EAL

MU-11 Wording Error Quad Cities Station Annex to the Exelon Standardized Emergency Plan; Section 3;Revisions 21, and 22Procedure

EP-AA-120; Emergency Plan Administration; Revisions 5, and 6

Standing Order 05-12; EAL MU-11

LIST OF ACRONYMS

USEDAN [[]]

SA lert and Notification SystemCFRCode of Federal Regulations

CR [[]]

SC ontrol Room Simulator

DEPD rill and Exercise Performance

DHSD epartment of Homeland Security

EA [[]]

LE mergency Action Level

EO [[]]

FE mergency Operations Facility

ER [[]]

OEmergency Response Organization

IRI ssue Report

NR [[]]

CUnited States Nuclear Regulatory Commission

Attachment4NUREGNuclear Regulatory GuideOSCOperations Support Center

PIP erformance Indicator

TS [[]]

CT echnical Support Center