IR 05000285/2008004

IR 05000285-08-004, on 7/1 - 9/30/2008, Fort Calhoun Station, Integrated Resident and Regional Report: Event Follow-Up

ML083080571
Person / Time
Site:	Fort Calhoun
Issue date:	11/03/2008
From:	Paulk C NRC/RGN-IV/DRP/RPB-E
To:	Bannister D Omaha Public Power District
References
IR-08-004
Download: ML083080571 (36)

Text

UNITE D S TATES NUC LEAR RE GULATOR Y C OMMIS SI ON R EG I O N I V 6 12 EAST LAMAR BLVD , S U ITE 4 00 AR L IN GTON , TE X AS 7 6 01 1 - 4125 November 3, 2008 D. Vice President and CNO Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

P.O. Box 550 Fort Calhoun, NE 68023-0550 Subject: FORT CALHOUN STATION NRC INTEGRATED INSPECTION REPORT 05000285/2008004

Dear Mr. Bannister:

On September 30, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fort Calhoun Station. The enclosed integrated inspection report documents the inspection finding, which was discussed on October 6, 2008, with yourself and other members of your staff.

The inspections 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.

This report documents one self-revealing finding of very low safety significance (Green). This finding was determined to involve violations of NRC requirements. Additionally, one licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating this finding as a non-cited violation NCV),

consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the violation or the significance of the NCV, 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, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 East Lamar Blvd.,

Suite 400, Arlington, Texas 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspectors at the Fort Calhoun Station facility.

Omaha Public Power District -2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Charles J. Paulk, Chief Project Branch E Division of Reactor Projects Docket: 50-285 License: DPR-40

Enclosure:

NRC Inspection Report 05000285/200804 w/attachment: Supplemental Information

REGION IV==

Docket: 50-285 License: DPR-40 Report: 05000285/2008004 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: Fort Calhoun Station FC-2-4 Adm.

P.O. Box 399, Highway 75 - North of Fort Calhoun Fort Calhoun, Nebraska Dates: July 1 through September 30, 2008 Inspectors: J. Hanna, Senior Resident Inspector J. Kirkland, Resident Inspector P. Goldberg, Reactor Inspector M. Young, Reactor Inspector P. Elkman, Senior Emergency Preparedness Inspector Approved By: Charles J. Paulk, Acting Chief, Project Branch E Division of Reactor Projects-1-Enclosure

SUMMARY OF FINDINGS

IR 05000285/2008004; 07/01/2008 - 09/30/2008; Fort Calhoun Station, Integrated Resident and

Regional Report; Event Follow-up.

The report covered a 3-month period of inspection by resident inspectors and announced inspection by regional based reactor inspectors. One Green non-cited violation of significance was identified. The significance of most findings is indicated by their color (Green, White,

Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process.

Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Initiating Events

Green.

A Green self-revealing noncited violation of Technical Specification 5.8.1.a (Procedures) was identified for an inadequate maintenance procedure. Specifically, the licensees maintenance procedures did not provide adequate instructions for the craft to re-pack Pressurizer Spray Valve PCV-103-1 that resulted in a 2-3 gpm reactor coolant leak.

This finding was greater than minor because it was similar to non-minor example 4.b in Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, in that a procedural error caused a reactor trip or other transient. The inspectors evaluated this finding using Manual Chapter 0609, Attachment 4. The inspectors determined that it was of very low safety significance (Green) because, assuming worst case degradation, the finding would not result in exceeding the technical specification limit for any reactor coolant system leakage, nor would it have likely affected other mitigation systems resulting in a total loss of their safety function. This finding had a crosscutting aspect in Human Performance, specifically the Decision Making aspect

[H.1.(b)] because licensee personnel failed to use conservative assumptions in decision-making. Specifically, the relevant procedure left the detail of repacking the valves to skill of the craft and licensee personnel failed to challenge or question whether that was appropriate (Section 4OA3.6).

Licensee-Identified Violations

Violations of very low safety significance, which were identified by the licensee, have been review by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and corrective actions are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

The unit began this inspection period in Mode 1 at full rated thermal power and operated at 100 percent until August 21 when power was decreased on the unit to 10 percent. The unit remained at approximately 10 percent power for the next 2 days while repairs were performed to an iso-phase bus duct on the main electrical transformer. On August 23, reactor power was increased to 100 percent, where the plant remained until the end of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Seasonal Susceptibilities

a. Inspection Scope

The inspectors completed a review of licensee personnel's readiness of seasonal susceptibilities involving potential flooding from the Missouri River. The inspectors:

(1) reviewed plant procedures, the Updated Safety Analysis Report and the Technical Specifications to ensure that operator actions defined in adverse weather procedures maintained the readiness of essential systems;

(2) walked down portions of the structure listed below to ensure that adverse weather protection features were sufficient to support operability, including the ability to perform safe shutdown functions;

(3) evaluated operator staffing levels to ensure the licensee could maintain the readiness of essential systems required by plant procedures; and

(4) reviewed the corrective action program to determine if the licensee identified and corrected problems related to adverse weather conditions.

• July 28, 2008: Intake structure and the raw water vaults contained within Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

.2 Readiness for Impending Adverse Weather Conditions

On August 5, 2008, the inspectors completed a review of licensee personnel's readiness for impending adverse weather involving severe thunderstorms. The inspectors:

(1) reviewed plant procedures, the Updated Safety Analysis Report and the Technical Specifications, to ensure that operator actions defined in adverse weather procedures maintained the readiness of essential systems;

(2) walked down portions of the systems listed below to ensure that adverse weather protection features were sufficient to support operability, including the ability to perform safe shutdown functions;

(3) reviewed maintenance records to determine that applicable surveillance requirements were current before the anticipated severe thunderstorms developed; and

(4) reviewed plant

modifications, procedure revisions, and operator work-arounds to determine if recent facility changes challenged plant operation.

• August 5, 2008, review of preparations for severe thunderstorms and the ability of storm and roof drains to accommodate water runoff Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignments

.1 Partial Equipment Walk-downs

a. Inspection Scope

The inspectors:

(1) walked down portions of the three risk-important systems listed below and reviewed plant procedures and documents to verify that critical portions of the selected systems were correctly aligned; and

(2) compared deficiencies identified during the walk down to the Updated Safety Analysis Report and corrective action program to ensure problems were being identified and corrected.

• August 19, 2008, Review of control room ventilation opposite train equipment (VA-46A and VA-64A) while the 'B' train unit (VA-46B) was out of service for preventive maintenance

• August 19, 2008, Review of opposite train high pressure safety injection pump (SI 2C) while the B train component (SI-2B) was out of service for routine preventative and corrective maintenance

• September 29, 2008, Main feed system while Main Feedwater Pump FW-4A was out of service for maintenance Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed three samples.

b. Findings

No findings of significance were identified.

.2 Complete Equipment Walkdown

The inspectors:

(1) reviewed plant procedures, drawings, the Updated Safety Analysis Report, the Technical Specifications, and vendor manuals to determine the correct alignment of the entire emergency core cooling system;

(2) reviewed outstanding design

issues, operator workarounds, and Updated Safety Analysis Report documents to determine if open issues affected the functionality of the emergency core cooling system; and

(3) verified that the licensee was identifying and resolving equipment alignment problems. Particular emphasis was placed in understanding the licensing/design basis of the system and what requirements applied to maintaining the system in a filled and vented condition.

Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors walked down the four plant areas listed below to assess the material condition of active and passive fire protection features and their operational lineup and readiness. The inspectors:

(1) verified that transient combustibles and hot work activities were controlled in accordance with plant procedures;

(2) observed the condition of fire detection devices to verify they remained functional;

(3) observed fire suppression systems to verify they remained functional and that access to manual actuators were unobstructed;

(4) verified that fire extinguishers and hose stations were provided at their designated locations and that they were in a satisfactory condition;

(5) verified that passive fire protection features (electrical raceway barriers, fire doors, fire dampers, steel fire proofing, penetration seals, and oil collection systems) were in a satisfactory material condition;

(6) verified that adequate compensatory measures were established for degraded or inoperable fire protection features and that the compensatory measures were commensurate with the significance of the deficiency; and

(7) reviewed the Updated Safety Analysis Report to determine if the licensee identified and corrected fire protection problems.

• July 30, 2008, Fire Area 32 compressor area including Rooms 50, 51, 52, and 53

• August 5 - August 8, 2008, Fire Area 20.7, auxiliary building roof, in the vicinity of where both VA-46 condenser units are located

• August 6, 2008, Fire Area 43, auxiliary building fan room, Room 81

• August 14, 2008, Fire Areas 31 and 31A, intake structure Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed four samples.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

.1 Semi-Annual Internal Flooding

a. Inspection Scope

The inspectors:

(1) reviewed the Updated Safety Analysis Report, the flooding analysis, and plant procedures to assess seasonal susceptibilities involving internal flooding;

(2) reviewed the Updated Safety Analysis Report and corrective action program to determine if the licensee identified and corrected flooding problems;

(3) inspected underground bunkers/manholes to verify the adequacy of

(a) sump pumps,

(b) level alarm circuits,

(c) cable splices subject to submergence, and

(d) drainage for bunkers/manholes;

(4) verified that operator actions for coping with flooding can reasonably achieve the desired outcomes; and

(5) walked down the one area listed below to verify the adequacy of:

(a) equipment seals located below the floodline,

(b) floor and wall penetration seals,

(c) watertight door seals,

(d) common drain lines and sumps,

(e) sump pumps, level alarms, and control circuits, and

(f) temporary or removable flood barriers.

• July 28, 2008, various areas in the non-radiologically controlled portion of the auxiliary building, including the emergency diesel generator rooms and the upper mechanical piping penetration room Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance

a. Inspection Scope

Inspection Module 71111.07, Heat Sink Performance, requires that two to three safety-related heat exchangers, either directly or indirectly connected to the safety-related service water system, be reviewed to ensure they are either tested or inspected and cleaned. The inspectors selected the following two heat removal sources, which ranked high in the plant-specific risk assessment and are connected to the safety-related service water system:

• Component cooling water heat exchangers

• Raw water system (Missouri River), which performs the function of the ultimate heat sink

For the heat exchangers directly connected to the safety-related service water system, the inspectors reviewed whether testing, cleaning, maintenance, and the fouling monitoring program provided sufficient controls to ensure proper heat transfer. The inspectors noted that the component cooling water heat exchangers were the only heat exchangers in the plant cooled by the raw water system. The inspectors reviewed chemistry controls used to avoid fouling, heat exchanger testing results, and inspection and cleaning results. The inspectors walked down the two chosen samples.

For the component cooling water heat exchangers, which were tested every 6 months and cleaned every 18 months, the inspectors verified the proper extrapolation of test conditions to design conditions, appropriate use of test instrumentation, and appropriate accounting for instrument inaccuracies. The inspectors reviewed the methods and results of heat exchanger inspection and cleaning, verified that the methods used to inspect and clean were consistent with industry standards, and ensured that the as-found results were appropriately dispositioned such that the final conditions were acceptable. The inspectors verified that the licensee appropriately trended these inspections and cleaning results, assessed the causes of the trends, and took necessary actions for changes in these trends.

The inspectors reviewed the ultimate heat sink, which includes the raw water supply from the Missouri River with screens and strainers used to keep debris away from the component cooling water heat exchanger tubes. The inspectors reviewed the most recent in-service testing results of the raw water pumps. The inspectors reviewed condition reports that discussed past problems concerning the raw water system plugging the tube side of the component cooling water system. The inspectors discussed the improvements the licensee was planning to improve the raw water system. The improvements included adding a weir wall in front of the pump suction to avoid sand and other debris from entering the pumps and suction. In addition, the licensees improvement plan consists of replacing screens and strainers with better designs.

For the selected heat exchangers and ultimate heat sink, the inspectors verified that licensee personnel established heat sink and heat exchanger conditions that were consistent with the design assumptions. Specifically, the inspectors reviewed the applicable calculations to ensure that the thermal-performance test acceptance criteria for the heat exchangers and heat sink were being applied consistently throughout the calculations. In addition, the inspectors reviewed test data for the heat exchangers and design and vendor-supplied information to ensure that the heat exchangers were maintained within their design bases. The inspectors reviewed the raw water ultimate heat sink to ensure sufficient water would reach the component cooling water heat exchanger and not cause excessive fouling. In addition, the inspectors walked down the component cooling water heat exchangers and the raw water system, which included raw water pumps, screens and strainers.

The inspectors verified that licensee personnel had identified and entered heat exchanger/heat sink performance problems into the corrective action program. The inspectors reviewed 16 condition reports, which are listed in the attachment.

The inspectors completed two inspection samples.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

a. Inspection Scope

The inspectors observed testing and training of senior reactor operators and reactor operators to identify deficiencies and discrepancies in the training, to assess operator performance, and to assess the evaluator's critique. The training scenario involved a main steam line break inside containment including several electrical failures.

Documents reviewed by the inspectors are listed in the attachment The inspectors completed one sample.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the three maintenance activities listed below to:

(1) verify the appropriate handling of structure, system, and component performance or condition problems;

(2) verify the appropriate handling of degraded structure, system and component functional performance;

(3) evaluate the role of work practices and common cause problems; and

(4) evaluate the handling of structure, system and component issues reviewed under the requirements of the maintenance rule, 10 CFR Part 50 Appendix B, and the Technical Specifications.

• May 2008, Safety injection water recirculation tank suction Valves LCV-383-1/2, specifically the functional failure determination

• October 2007, Raw water Pump AC-10D failure, specifically the maintenance rule a(1) goal setting

• September 2008, Review of the actions taken while instrument air Compressor CA 1B has been in the maintenance rule a(1) category Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed three samples.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Risk Assessments and Management of Risk

a. Inspection Scope

The inspectors reviewed the two assessment activities listed below to verify:

(1) performance of risk assessments when required by 10 CFR 50.65 (a)(4) and licensee procedures prior to changes in plant configuration for maintenance activities and plant operations;

(2) the accuracy, adequacy, and completeness of the information considered in the risk assessment;

(3) that the licensee recognizes, and/or enters as applicable, the appropriate licensee established risk category according to the risk assessment results and licensee procedures; and

(4) the licensee identified and corrected problems related to maintenance risk assessments.

• July 30, 2008, Review of yellow risk color configuration and the associated risk management actions taken while high pressure safety injection Pump SI-2A, containment spray Pump SI-3A, and the motor-driven auxiliary feedwater Pump FW-6 were out of service

• August 19, 2008, Review of the assessment resulting in a yellow risk color and the associated risk management actions while high pressure safety injection Pump SI-2B was out of service Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed two samples.

b. Findings

No findings of significance were identified.

.2 Emergent Work Control

a. Inspection Scope

The inspectors:

(1) verified that licensee personnel performed actions to minimize the probability of initiating events and maintained the functional capability of mitigating systems and barrier integrity systems;

(2) verified that emergent work-related activities such as troubleshooting, work planning/scheduling, establishing plant conditions, aligning equipment, tagging, temporary modifications, and equipment restoration did not place the plant in an unacceptable configuration; and

(3) reviewed the Updated Safety Analysis Report to determine if licensee personnel identified and corrected risk assessment and emergent work control problems.

• August 21 - August 22, 2008, Emergent elevated risk condition due to placing both T1A1 and T1A2 transformers out of service during repairs to an iso-phase bus duct boot

• August 27 - August 28, 2008, Risk management actions associated with a small leak on the east raw water header piping Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed two samples.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors:

(1) reviewed plants status documents such as operator shift logs, emergent work documentation, deferred modifications, and standing orders to determine if an operability evaluation was warranted for degraded components;

(2) referred to the Updated Safety Analysis Report and design basis documents to review the technical adequacy of licensee operability evaluations;

(3) evaluated compensatory measures associated with operability evaluations;

(4) determined degraded component impact on any Technical Specifications;

(5) used the Significance Determination Process to evaluate the risk significance of degraded or inoperable equipment; and

(6) verified that the licensee has identified and implemented appropriate corrective actions associated with degraded components.

• August 13, 2008, Operability evaluation on jacket water temperature control Valve JW-116 associated with degraded O-rings on diesel Generator-2

• August 18, 2008, Review of multiple condition reports written on the technical support center/security emergency diesel generator, and their potential cumulative effect on the operability of the component

• August 20, 2008, Review of the immediate operability issue associated with the failure of the licensee to fill and vent emergency core cooling system Train A suction piping

• August 21, 2008, Operability evaluation on the fire protection piping located within the control room envelope and the potential effect of spray on electrical cabinets Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed four samples.

b. Findings

No findings of significance were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed the following temporary/permanent modifications to verify that the safety functions of important safety systems were not degraded:

• August 15, 2008, Installation of a temporary jumper to remove a fire detector from service on the reactor vessel head The inspectors reviewed the temporary modification and the associated safety evaluation screening against the system design bases documentation, including the Updated Safety Analysis Report and the Technical Specifications, and verified that the modification did not adversely affect the system operability/availability. The inspectors also verified that the installation and restoration was consistent with the modification documents and that configuration control was adequate. Additionally, the inspectors verified that: the temporary modification was identified on control room drawings; appropriate tags were placed on the affected equipment; and licensee personnel evaluated the combined effects on mitigating systems and the integrity of radiological barriers.

Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

b. Findings

No findings of significance were identified.

1R19 Postmaintenance Testing

a. Inspection Scope

The inspectors selected the five post-maintenance test activities listed below of risk-significant systems or components. For each item, the inspectors:

(1) reviewed the applicable licensing basis and/or design-basis documents to determine the safety functions;

(2) evaluated the safety functions that may have been affected by the maintenance activity; and

(3) reviewed the test procedure to ensure it adequately tested the safety function that may have been affected. The inspectors either witnessed or reviewed test data to verify that acceptance criteria were met, plant impacts were evaluated, test equipment was calibrated, procedures were followed, jumpers were properly controlled, the test data results were complete and accurate, the test equipment was removed, the system was properly re-aligned, and deficiencies during testing were documented. The inspectors also reviewed the Updated Safety Analysis Report to determine if licensee personnel identified and corrected problems related to post-maintenance testing.

• August 8, 2008, In-office review of containment spray pump test conducted on August 6, 2008

• August 21, 2008, In-office review of postmaintenance test conducted on control room air conditioning Unit VA-46B following regularly scheduled preventative maintenance

• September 10, 2008, Observation of the monthly surveillance run of emergency diesel generator DG-2 following maintenance

• September 18, 2008, Observation of the testing of diesel-driven auxiliary feedwater Pump FW-54 following annual inspection and preventive maintenance

• September 18, 2008, Postmaintenance testing of containment cooling Unit VA-8B CCW outlet Valve HCV-403C Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed five samples.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the Updated Safety Analysis Report, procedure requirements, and the Technical Specifications to ensure that the six surveillance activities listed below demonstrated that the structure, system and components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the following significant surveillance test attributes were adequate:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated Technical Specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME code requirements

• Updating of performance indicator data

• Engineering evaluations, root causes, and bases for returning tested structure, system and components not meeting the test acceptance criteria were correct

• Reference setting data

• Annunciators and alarms setpoints The inspectors also verified that the licensee identified and implemented any needed corrective actions associated with the surveillance testing.

• August 4, 2008, Field observation of quarterly full-flow test of fire Pump FP-1A

• September 2, 2008, Field observation of monthly surveillance test on station Batteries EE-8A/B

• September 4, 2008, Field observation of operability run of steam driven auxiliary feedwater Pump FW-10

• September 10, 2008, In-office review of the failed surveillance test on the power operated relief valve/safety valve tailpipe temperatures which had been performed on September 7, 2008

• September 12, 2008, In-office review of the performance of the daily reactor coolant leak detection procedure (reactor coolant leakage testing)

• September 15, 2008, Field observation of quarterly in-service test of raw water Pump AC-10A (inservice testing)

Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed six samples.

b. Findings

No findings of significance were identified.

1EP2 Alert Notification System Testing

a. Inspection Scope

The inspectors discussed with licensee staff the operability of offsite siren and tone alert radio systems to determine the adequacy of licensee methods for testing the alert and notification system in accordance with 10 CFR Part 50 Appendix E. The licensee=s alert and notification system testing program was compared with criteria in NUREG-0654, ACriteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,@ Revision 1, Federal Emergency

Management Agency (FEMA) Report REP-10, AGuide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants,@ and the licensee=s current FEMA-approved alert and notification system design report, Public Alert and Notification Siren System, Revision 1, approved December 9, 2004. The inspectors also reviewed the following procedures:

$ Emergency Preparedness Department Manual, EPDM-02, Emergency Preparedness Test Program, Revision 16

$ Emergency Preparedness Test, EPT-01, Alert Notification System Silent Test, Revisions 14 and 15

• Emergency Preparedness Test, EPT-02, Alert Notification System Growl Test, Revision 18 The inspectors completed one sample during the inspection

b. Findings

No findings of significance were identified.

1EP3 Emergency Response Organization Augmentation Testing

a. Inspection Scope

The inspectors discussed with licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to determine the adequacy of licensee methods for staffing emergency response facilities. The inspectors reviewed the following licensee procedures, and the references listed in the to this report related to licensees emergency response organization augmentation system, to evaluate the licensee=s ability to staff the emergency response facilities in accordance with the licensees emergency plan and the requirements of 10 CFR Part 50, Appendix E:

$ Emergency Preparedness Test, EPT-34, Perform Augmentation or Notification Drills, Revisions 26, 27, and 28

$ Emergency response organization activation checklist, dated March 11, 1999

• Emergency response organization activation - short form checklist, dated July 22, 2008 The inspectors completed one sample during the inspection.

b. Findings

No findings of significance were identified.

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies

a. Inspection Scope

The inspectors reviewed the licensee=s corrective action program requirements in Procedure SO-R-2, Condition Reporting and Corrective Action, Revision 40, and FSCG-24, Corrective Action Program Expectations, Revision 11. The inspectors reviewed summaries of 193 corrective action requests (condition reports) assigned to the emergency preparedness department between July 2006, and September 2008, and selected twelve for a detailed review against program requirements. The inspectors evaluated the response to the corrective action requests to determine the licensee=s ability to identify, evaluate, and correct problems in accordance with the licensee program requirements and 10 CFR 50.47(b)(14) and 10 CFR Part 50, Appendix E. The inspectors also reviewed other documents as listed in the Attachment to this report.

The inspectors completed one sample during the inspection.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

a. Inspection Scope

Below is listed one drill and simulator-based training evolution contributing to drill/exercise performance and emergency response organization performance indicators. The inspectors:

(1) observed the training evolution to identify any weaknesses and deficiencies in classification, notification, and protective action requirements (PAR) development activities;

(2) compared the identified weaknesses and deficiencies against licensee identified findings to determine whether the licensee is properly identifying failures; and

(3) determined whether licensee performance is in accordance with the guidance of the Nuclear Energy Institute 99-02, "Voluntary Submission of Performance Indicator Data," Revision 5 acceptance criteria.

• August 26, 2008, Full scale drill with participation by state and local authorities; the scenario included a loss of offsite power, a subsequent reactor trip, and a reactor coolant pump seal loss of coolant accident, with a loss of containment integrity Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

Cornerstone: Mitigating Systems

The inspectors sampled submittals for the performance indicators listed below for the period July 1, 2007, through June 30, 2008. The definitions and guidance of Nuclear Energy Institute 99-02, Regulatory Assessment Indicator Guideline, Revision 5, were used to verify the licensees basis for reporting each data element in order to verify the accuracy of performance indicator data reported during the assessment period.

• MS05, Safety system functional failures

• MS07, Mitigating system performance index, high pressure injection systems

• MS09, Mitigating system performance index, residual heat removal systems Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed three samples.

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

a. Inspection Scope

The inspectors reviewed licensee evaluations for the three emergency preparedness cornerstone performance indicators of drill and exercise performance, emergency response organization participation, and alert and notification system reliability, for the period October 2007, through June 2008. The definitions and guidance of Nuclear Energy Institute Report 99-02, ARegulatory Assessment Indicator Guideline,@ Revisions 4 and 5, and the licensees performance indicator procedures emergency planning department Manual, EPDM-14, Emergency Preparedness Performance Indicator Program, Revisions 9 and 10, and Form EP-47, NRC Performance Indicator Verification Checklist, Revision 4, were used to verify the accuracy of the licensee=s evaluations for each performance indicator reported during the assessment period. The inspectors also performed Temporary Instruction 2515\175, Emergency Response Organization, Drill/Exercise Performance Indicator, and Program Review.

The inspectors reviewed a 100 percent sample of drill and exercise scenarios and licensed operator simulator training sessions, notification forms, and attendance and critique records associated with training sessions, drills, and exercises conducted during the verification period. The inspectors reviewed selected emergency responder qualification, training, and drill participation records. The inspectors reviewed alert and notification system testing procedures, maintenance records, and a 100 percent sample of siren test records. The inspectors also reviewed other documents as listed in the to this report.

The inspectors completed three samples during the inspection.

b. Findings

No findings of significance were identified.

4OA2 Problem Identification and Resolution

.1 Annual Sample Review

a. Inspection Scope

The emergency preparedness inspectors selected twelve condition reports generated between July 2006, and September 2008 for detailed review. The condition reports were reviewed to ensure the full extent of issues was identified, an appropriate evaluation was performed, and appropriate corrective actions was specified and prioritized. The inspectors evaluated the condition reports against the requirements of Procedures SOR-2, Condition Reporting and Corrective Action, Revision 40, and FSCG-24, Corrective Action Program Expectations, Revision 11. The inspectors also reviewed one condition report generated during the inspection to ensure the full extent of issues was identified.

b. Findings and Observations

No findings of significance were identified.

4OA3 Event Follow-up

.1 (Closed) Licensee Event Repport (LER) 05000285/2006002-01; Inadequate Design

Control Results in Potentially Insufficient Auxiliary Feedwater Flow The licensee revised this LER to reflect a more accurate understanding of the root cause to the event. This issue was initially documented in NRC Inspection Report 05000285/2006-04, Section 4OA7. The revised LER was reviewed by the inspectors, no new findings of significance were identified, and no additional violations of NRC requirements occurred. The licensee documented this issue in Condition Report 2006002855. This LER is closed.

.2 (Closed) LER 05000285/2007003-01, Inoperability of a Diesel Generator with an

Inoperable Containment Cooling Fan from the Opposite Bus The licensee revised this LER to reflect a more accurate understanding of the root cause to the event. This issue was initially documented in NRC Inspection Report 05000285/2007-05, Section 4OA3.3. The revised LER was reviewed by the inspectors, no new findings of significance were identified, and no additional violations of NRC requirements occurred. The licensee documented this issue in Condition Reports 200700725 and 200700756. This LER is closed.

.3 (Closed) LER 05000285/2006008-01, Loss of Shutdown Cooling Due to Repressurizing

Reactor Coolant System The licensee revised this LER to reflect a more accurate understanding of the root cause to the event. This issue was initially documented in NRC Inspection Report 05000285/2007-02, Section 4OA3.2. The revised LER was reviewed by the inspectors, no new findings of significance were identified, and no additional violations of NRC requirements occurred. The licensee documented this issue in Condition Report 2006005629. This LER is closed.

.4 (Closed) LER 05000285/2007-002-00, Common Mode Failure of Medium Voltage (4160)

Circuit Breaker On January 25, 2007, the 4160 volt circuit breaker for raw water Pump AC-10B closed on demand, but the auxiliary contacts failed to actuate. A visual inspection of the other three raw water pumps circuit breakers did not identify an extent of condition problem.

On February 8, 2007, an identical failure of the circuit breaker for raw water Pump AC-10C occurred. Both failures were due to a mechanical linkage rod that broke due to cyclical fatigue. On April 9, 2007, a special inspection into the circumstances of this event was concluded and was documented in NRC Inspection Report 05000285/2007-06. No findings or violations of significance were determined at that time. This LER was reviewed by the inspectors and no findings or violations were identified by the inspectors. The licensee documented the failed equipment in Condition Report 20070618. This LER is closed.

.5 (Closed) LER 05000285/2007004-00, Inadvertent Isolation of All Containment Spray

Due to an Inadequate Test Procedure On April 12, 2007, the licensee discovered that during certain testing, performed using Procedure OP-ST-ESF-0090/10, Channel A/B Safety Injection, Containment Spray and Recirculation Actuation Signal Test, that both trains of containment spray had been inadvertently rendered inoperable. Further investigation revealed that the licensee had introduced this condition repeatedly over the recent past (since 1996 when one train was tested, and since 2006 for the other). Making both trains inoperable simultaneously would require the licensee to enter Technical Specification 2.0.1, General Requirements. Technical Specification 2.0.1 required that the plant be shutdown in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or less. The enforcement aspects of the violation are discussed in Section 4OA7 of this report. This LER is closed.

.6 Reactor Coolant System Leak During Plant Heatup Due to Inadequate Valve Packing

a. Inspection Scope

The inspectors reviewed the circumstances surrounding and licensee response to a reactor coolant system (RCS) leak during plant heat up on June 9, 2008. The inspectors reviewed the licensees condition reports, logs, and graphs of key plant parameters, related operating experience, and associated procedures. The documents reviewed during this inspection are listed in the attachment.

The inspectors completed one sample during the inspection.

b. Findings

Introduction.

The inspectors identified a Green noncited violation of Technical Specification 5.8.1.a (procedures) for an inadequate maintenance procedure.

Specifically, the licensees maintenance procedures did not provide adequate instructions for the craft to re-pack Pressurizer Spray Valve PCV-103-1, which resulted in a 2-3 gpm reactor coolant leak.

Description.

During the Spring 2008 refueling outage, licensee maintenance personnel refurbished Pressurizer Spray Valve PCV-103-1 using Procedure PE-RR-VX-0410, Inspection and Repair of Fisher ES Control Valves, Revision 9. On June 9-10, 2008, during heat up of the plant, a 2-3 gpm leak of reactor coolant occurred. The inspectors reported to the control room and evaluated licensee operators response to the event.

The operators entered Procedure AOP-22, Reactor Coolant Leak, Revision 29, and determined the location of the leak to be the Pressurizer Spray Valve PCV-103-1. The operators cooled the plant down in order to affect repairs. (Please refer to NRC Inspection Report 05000285/2008003 for a description of a related violation involving voiding of the reactor vessel head and steam generator U-tubes during the cool down.)

Licensee personnel entered containment and discovered that the leakage was from the packing leakoff line of Valve PCV-103-1.

Further investigation revealed that the valve had not been adequately repacked during the outage when maintenance was performed on May 20, 2008. The procedure did not prescribe a specific sequence to consolidate a dual set of packing. The packing sequence used on May 20 was to install the packing in the stuffing box, place the gland follower on top and finger tighten the gland nuts. Monitoring equipment was then used to monitor stem friction while tightening the gland nuts to a calculated torque value. The inspectors also noted that the industry standard for valve packing replacement, as described in EPRI Report 1000923, Valve Packing Performance Improvement Sealing Technology & Plant Leakage Reduction, is to consolidate the packing individually and then assemble them together. Accordingly, the root cause of the inadequate packing was determined to be an inappropriate sequence to consolidate a dual packing set.

Analysis.

The inspectors determined that the failure to have an adequate procedure for repacking of valves was a performance deficiency. This finding was greater than minor because it was similar to non-minor Example 4.b in Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, in that a procedural error caused a reactor trip or other transient. The inspectors evaluated this finding using Manual Chapter 0609, 4, and determined that it was of very low safety significance (Green)because, assuming worst case degradation, the finding would not result in exceeding the Technical Specification limit for any RCS leakage nor would it have likely affected other mitigation systems resulting in a total loss of their safety function. This finding had a crosscutting aspect in human performance, specifically the decision making aspect

[H.1.(b)] because licensee personnel failed to use conservative assumptions in decision-making. Specifically, the relevant procedure left the detail of repacking the valves to skill of the craft and licensee personnel failed to challenge or question whether that was appropriate.

Enforcement.

Technical Specification 5.8.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, 1978. Regulatory

Guide 1.33, Appendix A, requires, in part, Written Procedures for Performing Maintenance. Specifically, Item 9.a requires Maintenance that can affect the performance of safety-related equipment should be properly performed in accordance with written procedures appropriate to the circumstances. Contrary to the above, the maintenance of Valve PCV-103-1 (a safety-related component) was done with a procedure (PE-RR-VX-0410) that had insufficient detail regarding repacking which resulted in a significant RCS leak. This violation of Technical Specification 5.8.1.a is being treated as a noncited violation, consistent with Section VI.A of the Enforcement Policy: NCV 05000285/2008004-01, "Reactor Coolant System Leak During Plant Heat up Due to Inadequate Valve Packing." This violation was entered into the licensees corrective action program as Condition Report 2008-4059.

4OA5 Other Activities

.1 Quarterly Resident Inspectors Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors performed observations of security force personnel and activities to ensure that the activities were consistent with Fort Calhoun security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspectors observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.

b. Findings and Observations

No findings of significance were identified.

.2 (Discussed) URI 05000285/2005011-05, Intake Structure Design

From August 11-22, 2008, Division of Reactor Safety Inspectors reviewed the open unresolved item involving intake structure design. The inspectors reviewed condition reports and met with the licensee in order to understand the status of the technical issue. Currently, licensee personnel are re-performing the calculation for the intake structure design and are projected to be finished by 2008 calendar year end.

.3 (Closed) Deviation 05000285/2007007-06, Failure to Install Temperature Monitoring of

the Safety Injection Pump Rooms During an NRC inspection conducted from May 21 through July 25, 2007, the team identified a Notice of Deviation for failure to install temperature monitoring of the safety injection pump room as committed to in a letter to the NRC, dated September 6, 1979.

The commitment was submitted to support the licensees application for License Amendment 52. During the inspectors review of other issues related with the safety injection pump room temperature, it was identified on June 6, 2007, that the temperature monitoring instrumentation was never installed, as committed in the 1979 letter. Since the proposed modification was never completed, the inspectors concluded that the

licensee failed to satisfy a written commitment, as documented in the September 6, 1979, letter. In addition, on November 1, 1999, after modifying operating procedures to restore ventilation to the safety injection pump rooms after an accident, the licensee missed an opportunity to notify the NRC that the commitment had not been implemented. This issue was entered into the licensees corrective action program as Condition Report 2007-2448.

The inspectors reviewed the licensees Reply to a Notice of Deviation letter and analysis. The Licensee has addressed the causes of the Deviation by actions taken place in procedural changes and enhancements in the tracking and resolution of NRC commitments. The licensee will address this issue in the next 10 CFR 50.59 Report, Updated Safety Analysis Report Revision, and Technical Specification Basis Change letter submitted for Fort Calhoun Station. The inspectors did not identify any finding of significance. Therefore, Deviation 05000285/2007007-06 is closed.

4OA6 Meetings

Exit Meeting Summary

On July 11, 2008, the inspectors presented the results of the heat exchanger inspection to Mr. R. Clemens, Manager, Nuclear Engineering Division, and other members of the licensee staff who acknowledged the findings. The inspectors did not review any proprietary information.

On September 25, 2008, the inspectors presented the results of the onsite and in-office inspection of the licensees emergency preparedness program to Mr. T. Nellenbach, Division Manager, Nuclear Operations/Plant Manager, and other members of his staff, who acknowledged the findings. The inspectors confirmed that proprietary, sensitive, or personal information examined during the inspection had been returned to their identified custodian(s).

On October 6, 2008, the resident inspectors presented the inspection results to Mr. J. Reinhart, Site Vice President, and other members of licensee management, who acknowledged the inspection findings. The inspectors confirmed that no proprietary information had been provided.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as NCVs.

• Technical Specification 2.0.1, General Requirements, states in part, In the event a Limiting Condition for Operation and/or associated action requirements cannot be satisfied because of circumstances in excess of those addressed in the specification, the unit shall be placed in at least HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Contrary to the above, the licensee repeatedly rendered both trains of Containment Spray inoperable during testing conducted per OP-ST-ESF-0090/10, Channel A/B Safety Injection, Containment Spray and Recirculation Actuation Signal Test, and failed to commence a shutdown of the plant. This finding only had very low safety significance because the containment cooling safety function could have been

provided, if called upon, by the redundant containment coolers. The duration of this condition was approximately 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per occurrence. Further, the licensee had the ability to promptly restore the containment spray system during a hypothetical event.

This finding was identified in the licensees corrective action program as Condition Report 2007-1647 and was reported as LER 05000285/2007-04.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Acker, Station Licensing Engineer

A. Clark, Manager Nuclear Security

O. Clayton, Manager, Nuclear Procurement Services

R. Clemens, Manager, Nuclear Engineering Division

P. Cronin, Manager Operations

M. Frans, Manager, System Engineering

J. Gasper, Manager, Design Engineering

S. Gebers, Manager, Emergency Preparedness and Health Physics

D. Guinn, Supervisor, Regulatory Compliance

J. Herman, Manager, Program Engineering

R. Hodgson, Acting Manager, Integrated Work Management

T. Maine, Acting Manager, Radiation Protection

T. Matthews, Manager Nuclear Licensing

E. Matzke, Regulatory Compliance Engineer

T. Nellenbach, Division Manager, Nuclear Operations/Plant Manager

T. Pilmaier, Manager, Performance

J. Reinhart, Site Vice President

G. Roets, Manager Major Projects

L. Schnetofer, Quality Specialist

C. Simmons, Supervisor, Emergency Planning

M. Tesar, Division Manager, Nuclear Support

D. Trausch, Assistant Plant Manager

R. Westcott, Manager, Quality

NRC

T. Pruett, Deputy Director, Division of Reactor Safety

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000285/2008004-01 NCV Reactor Coolant System Leak During Plant Heat up Due to Inadequate Valve Packing (Section 4OA3.6)

Closed

05000285/2006002-01 LER Inadequate Design Control Results in Potentially Insufficient Auxiliary Feedwater Flow (Section 4OA3.1)

-1-

05000285/2007-003-01 LER Inoperability of a Diesel generator with an Inoperable Containment Cooling Fan from the Opposite Bus (Section 4OA3.2)

05000285/2006-008-01 LER Loss of Shutdown Cooling Due to Repressurizing Reactor Coolant System (Section 4OA3.3)

05000285/2007-002-00 LER Common Mode Failure of Medium Voltage (4160) Circuit Breaker (Section 4OA3.4)

05000285/2007-004-00 LER Inadvertent Isolation of All Containment Spray Due to an Inadequate Test Procedure (Section 4OA3.5)

05000285/2007007-06 NOD Failure to Install Temperature Monitoring of the Safety Injection Pump Rooms (Section 4OA5.3)

Discussed

05000285/2005011-05 URI Intake Structure Design (Section 4OA3.1)