IR 05000285/2014003
| ML14239A654 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/27/2014 |
| From: | Hay M NRC/RGN-IV/DRP |
| To: | Cortopassi L Omaha Public Power District |
| Hay M | |
| References | |
| IR-2014-003 | |
| Download: ML14239A654 (44) | |
Text
ust 27, 2014
SUBJECT:
ERRATA FOR FORT CALHOUN STATION - NRC INTEGRATED INSPECTION REPORT 05000285/2014003
Dear Mr. Cortopassi:
An administrative error was discovered in the Nuclear Regulatory Commission Inspection Report 05000285/2014003, dated July 29, 2014 (ML14211A602). It was identified that the completion of Temporary Instruction 182, Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks was not included in the report. Please replace the inspection report with the enclosure to this letter.
Sincerely,
/RA/
Michael C. Hay, Chief Reactor Project Branch F Division of Reactor Projects Docket No.: 50-285 License No.: DPR-40 Enclosure:
ERRATA for NRC Inspection Report 05000285/2014003
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000285 License: DPR-40 Report: 05000285/2014003 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, NE 68008 Dates: April 1 through June 30, 2014 Inspectors: J. Kirkland, Senior Resident Inspector S. Schneider, Senior Resident Inspector J. Wingebach, Resident Inspector C. Alldredge, Health Physicist N. Greene, Ph.D., Health Physicist P. Hernandez, Health Physicist J. Larsen, Senior Physical Security Inspector R. Latta, Senior Reactor Inspector C. Speer, Resident Inspector L. Willoughby, Senior Reactor Inspector J. Drake, Senior Reactor Inspector Approved By: Michael C. Hay, Chief, Project Branch F Division of Reactor Projects-1- Enclosure
SUMMARY
IR 05000285/2014003; 04/01/2014 - 06/30/2014; Fort Calhoun Station; Radiological Hazard
Assessment and Exposure Control.
The inspection activities described in this report were performed between April 1 and June 30, 2014, by the resident inspectors at the Fort Calhoun Station and inspectors from the Nuclear Regulatory Commission (NRC) Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red), and determined using Inspection Manual Chapter 0609, Significance Determination Process dated June 2, 2011. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310; Components Within the Cross-Cutting Areas dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, Reactor Oversight Process revision 5.
Cornerstone: Occupational Radiation Safety
- Green.
The inspectors reviewed a self-revealing, non-cited violation of Technical Specification 5.11.1.b, which resulted from an individual entering a high radiation area without being aware of the radiological conditions. Specifically, on July 19, 2013, an operator was performing valve lineup work in the reactor building. Although the operator was on a radiation work permit that allowed access to high radiation areas, access was only allowed with knowledge of the dose rates in the areas entered. As immediate corrective actions, the radiation protection supervisors coached the operator on properly informing Radiation Protection of his planned work areas; and coached the radiation protection technician on having a more intrusive questioning attitude during briefings so that radworkers are properly informed of all hazards and radiological conditions.
This issue was documented in the licensees corrective action program as Condition Report (CR) 2014-14693.
The entry into a high radiation area without knowledge of the radiological conditions is a performance deficiency and is a violation of Technical Specification 5.11.1.b. The performance deficiency is more than minor because it is associated with the Occupational Radiation Safety cornerstone attribute of program and process (exposure control) and adversely affects the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation. Using Inspection Manual Chapter 0609, Appendix C,
Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, the inspectors determined the violation has very low safety significance because: (1) it was not an as low as is reasonably achievable finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. This violation has a cross-cutting aspect in the human performance area, associated with teamwork, because the operator did not properly communicate his work locations to the radiation protection technician for briefing and the technician did not display a questioning attitude to understand the work locations for the operator to properly brief him and ensure nuclear safety was maintained [H.4].
(Section 2RS1)
PLANT STATUS
The unit began the inspection period at 100 percent power. On April 15, 2014, the unit commenced a plant shutdown in accordance with Technical Specification 2.0.1 due to two inoperable control room air conditioners. One air conditioner was restored to operable status on April 15, 2014, with reactor power at approximately 36 percent power and the shutdown was halted. The unit returned to 100 percent power on April 18, 2014. On April 20, 2014, reactor power was decreased to approximately 85 percent to perform condenser cleaning. The unit returned to 100 percent power on April 26, 2014. On May 14, 2014, reactor power was decreased to 90 percent power to repair leaking gaskets on the heater drain pump suction piping. The unit returned to 100 percent power on May 16, 2014. On June 20, 2014, due to rising Missouri river levels the station commenced a downpower to 30 percent. On June 23, 2014, high Missouri river levels were determined to not be an operational restraint and reactor power was raised to 100 percent where it remained for the rest of the inspection period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
On May 12, 2014, the inspectors completed an inspection of the stations readiness for impending adverse weather conditions due to severe thunderstorms in the area. The inspectors reviewed plant design features, the licensees procedures to respond to tornadoes and high winds, and the licensees planned implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.
On June 16, 2014, the inspectors completed an inspection of the stations readiness for impending adverse weather conditions during a tornado watch. The inspectors reviewed plant design features, the licensees procedures to respond to tornadoes and high winds, and the licensees planned implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.
These activities constituted two samples of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
.2 Readiness to Cope with External Flooding
a. Inspection Scope
From June 17 through June 23, 2014, the inspectors completed an inspection of the stations readiness to cope with external flooding due to expected flooding on the Missouri River.
The inspectors reviewed plant design features and licensee procedures for coping with flooding. The inspectors walked down selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether credited operator actions could be successfully accomplished.
These activities constituted one sample of readiness to cope with external flooding, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walk-downs of the following risk-significant systems:
- April 30, 2014, partial alignment of the diesel generator system while DG-1 was under a surveillance activity,
- May 28, 2014, partial system alignment of the spent fuel cooling system while spent fuel cooling pump AC-5A was out of service for maintenance, and
- June 18, 2014, partial system alignment of the intake cell level control system when the site anticipated river level would require their use.
The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.
These activities constituted three partial system walk-down samples as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:
- May 21, 2014, Room 56E, East Switchgear Area, Fire Area 36A
- May 21, 2014, Room 56W, West Switchgear Area, Fire Area 36B
- May 28, 2014, Room 59, Pipe Penetration Area, Fire Area 23
- June 19, 2014, Intake Structure, Fire Area 31 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
On April 29, 2014, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose two plant areas containing risk-significant structures, systems, and components that were susceptible to flooding:
- Corridor 4, Basement and Personnel Corridor Area
- Room 21, Safety Injection and Containment Spray Pump Area I The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.
These activities constitute completion of one flood protection measures sample as defined in Inspection Procedure 71111.06.
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed licensee programs to verify heat exchanger performance and operability for the following heat exchangers:
- Raw Water/Component Cooling Water Heat Exchanger - AC-1B
- Shutdown Cooling Heat Exchanger - AC-4A
- Spent Fuel Pool Heat Exchanger - AC-8 The inspectors verified whether testing, inspection, maintenance, and chemistry control programs were adequate to ensure proper heat transfer. The inspectors verified that the periodic testing and monitoring methods, as outlined in commitments to NRC Generic Letter 89-13, utilized appropriate industry heat exchanger guidance. Additionally, the inspectors verified that the licensees chemistry program ensured that biological fouling was properly controlled between tests. The inspectors reviewed previous maintenance records of the heat exchangers to verify that the licensees heat exchanger inspections adequately addressed structural integrity and cleanliness of their tubes. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of three triennial heat sink inspection samples as defined in Inspection Procedure 71111.07-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On April 17, 2014, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance.
These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
a. Inspection Scope
The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity. The inspectors also assessed the operators adherence to plant procedures, including conduct of operations procedure and other operations department policies. The inspectors observed the operators performance of the following activities:
- April 15, 2014, Technical Specification required shutdown due to inoperable control room air conditioning units
- May 12, 2014, Plant downpower to 90 percent power due to leaking gaskets in heater drain pump suction piping
- Reactor Plant power maneuvers to support power ascension on June 22 and 23, 2014 These activities constitute completion of three quarterly licensed operator performance samples, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed two instances of degraded performance or condition of safety-related structures, systems, and components (SSCs):
- April 15, 2014, failure of control room air conditioning Unit VA-46A
- May 2, 2014, charging Pump CH-1A packing failure The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.
These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:
- April 3, 2014, risk management actions associated with the turbine driven auxiliary feedwater Pump FW-10 being out of service for maintenance
- April 29, 2014, risk management actions associated with the performance of OP-ST-ESF-009, Channel A Safety Injection, Containment Spray and Recirculation Actuation Signal Test The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.
In addition, on April 5, 2014, the inspectors also observed portions of one emergent work activities that had the potential to affect the functional capability of the Chemical and Volume Control System. Specifically, the inspectors observed portions of the emergent rebuild of the A Charging Pump, CH-1A.
The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components (SSCs).
These activities constitute completion of three maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed four operability determinations that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs):
- April 15, 2014, operability determination of control room air conditioning Unit VA-46A after installation of a modification to bypass the low lube oil pressure switch
- April 23, 2014, operability determination of charging Pump CH-1B
- May 2, 2014, operability determination of reactor coolant system Loop 1A charging line stop Valve HCV-238
- June 4, 2014, operability determination of the auxiliary building while allowing access down the main access gate while under a tornado warning The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded SSC.
These activities constitute completion of four operability review samples, as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed five post-maintenance testing activities that affected risk-significant structures, systems, or components (SSCs):
- May 23, 2014, post-maintenance testing following maintenance on Emergency Diesel Generator 1 (EDG-1)
- June 2, 2014, post-maintenance testing following maintenance on the diesel driven auxiliary feedwater Pump, FW-54
- April 17, 2014, post-maintenance testing following maintenance on control room Air Conditioner VA-46A
- May 1, 2014, post-maintenance testing following maintenance on raw water piping
- June 6, 2014, post-maintenance testing following maintenance on raw water Strainer AC-12B The inspectors reviewed licensing and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.
These activities constitute completion of five post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed four risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components (SSCs) were capable of performing their safety functions:
In-service tests:
- May 1, 2014, Safety Injection System Category A and B Valve Exercise Test, OP-ST-3001 Other surveillance tests:
- April 4, 2014, Component Cooling Water Pump Base Line Curve Procedure, SE-ST-CCW-3002
- April 22, 2014, Quarterly Functional Test of Steam Generator Low Water Level Trip Units, IC-ST-RPS-0014
- April 10, 2014, Channel Functional Test of Containment Pressure High Signal (CPHS) Switches The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.
These activities constitute completion of four surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed an emergency preparedness drill on May 13, 2014, to verify the adequacy and capability of the licensees assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the technical support center, operations support center, simulator, emergency operations facility, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.
These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors assessed the licensees performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensees implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. The inspectors walked down various portions of the plant and performed independent radiation dose rate measurements. The inspectors interviewed the Radiation Protection (RP) manager, RP supervisors, and radiation workers. The inspectors reviewed licensee performance in the following areas:
- The hazard assessment program, including a review of the licensees evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels
- Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions
- Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability
- Radiological hazards control and work coverage, including the adequacy of surveys, RP job coverage, and contamination controls, the use of electronic dosimeters in high noise areas, dosimetry placement, airborne radioactivity monitoring, controls for highly activated or contaminated materials (non-fuel)stored within spent fuel and other storage pools, and posting and physical controls for high radiation areas and very high radiation areas
- Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection These activities constitute completion of one sample of radiological hazard assessment and exposure controls as defined in Inspection Procedure 71124.01.
b. Findings
Introduction.
The inspectors reviewed a self-revealing, Green, non-cited violation of Technical Specification 5.11.1.b, which resulted from the licensees failure to control entry into a high radiation area (HRA) when an operator entered a posted HRA without knowledge of the dose rates. As a result, the operator received a high dose rate alarm upon entry into an area with greater than anticipated dose rates.
Description.
On July 19, 2013, an operator entered a posted HRA without adequate knowledge of the radiological conditions (dose rates) in the area. As a result, the electronic alarming dosimeter (EAD) worn by the operator alarmed due to a high dose rate. This unanticipated dose rate alarm was received while performing valve lineups on the 1013 foot elevation of the reactor building, B steam generator (S/G) bay area. This work was performed while signed onto Radiation Work Permit (RWP) 11-0020, Task 2, OPS support (STs, walkdowns etc.), with alarm setpoints of 35 millirem for dose and 375 millirem per hour for dose rate. However, the inspectors determined that the operator should have been signed onto Task 1, Valve Line-Up and Tag Outs, to perform the specific duties of valve lineup; the Task 1 alarm setpoints were 30 millirem for dose and 150 millirem per hour for dose rate. Both tasks of RWP 11-0020 allowed access to an HRA, but only after being made knowledgeable of the dose rates in the areas to be entered.
An RP technician briefed the operator on the general area radiological conditions of the walk path for the job, but failed to provide detailed information on the work areas surrounding the walk path. Per discussion with the licensee, the operator informed the RP technician that he was performing valve lineup work in the B S/G bay area, but he did not specify that he would veer from the walk path for which he was briefed.
The RP technician briefed the operator of the radiological conditions using Survey M-20130625-5, dated June 25, 2013. The survey showed a maximum general area dose rate of 20 millirem per hour on the walk path of the B S/G bay area. The operator veered from this path to access a valve atop the reactor coolant pump volute area, which was located a few feet away from the walk path below the shroud level of the pump. Upon entry to this area, he received a high dose rate alarm of 476 millirem per hour. As required, the operator stopped work and immediately exited the radiation controlled area (RCA) to inform RP of the alarming dosimeter. A follow-up survey, M-20130719-2, dated July 19 2013, was completed and showed a maximum of 1,000 millirem per hour on contact and 450 millirem per hour at 30 cm in this specific location.
The licensee determined in their investigation of the event that if better communication had occurred between the operator and RP technician performing the briefing, this issue could have been avoided. There are procedural requirements, developed and maintained for the purpose of radiological protection of personnel, which also could have also prevented this event. Section 7.12.3.A of Procedure RP-204, Radiological Area Controls, Revision 66, states, in part, that a briefing shall be conducted PRIOR to initial entry:
- (1) with the most recent survey data available, BRIEF workers on current radiological conditions in the work area and travel path;
- (2) INFORM the workers of areas to avoid;
- (3) BRIEF on EAD alarm settings and ENSURE they are adequate for the work area; and
- (4) ENSURE workers are aware of entry only to briefed HRAs. In addition, Section 4.5.3.B.1 of Procedure SO-G-101, Radiation Worker Practices, Revision 39, states, in part, that entry into HRAs with an alarming dosimeter shall be made only after the dose rate level(s) in the area have been established and personnel have been made knowledgeable of the radiological conditions. These steps were not followed by either the RP technician or the operator. Records show that the radworker received a total of 9.9 millirem dose during the radiological controlled area (RCA) entry.
As immediate corrective actions, the RP supervisors coached the operator on properly informing RP of his planned work areas and coached the RP technician on having a more intrusive questioning attitude during briefings so that radworkers, in general, are properly informed of all hazards and radiological conditions. In addition to these immediate corrective actions, per discussion with the NRC inspectors, the licensee also planned to post more detailed surveys at the entrance to large areas posted as HRAs to better inform radworkers of the radiological conditions which they may encounter. This issue was documented in the licensees corrective action program as Condition Report (CR) 2014-14693.
Analysis.
The entry into a HRA without knowledge of the radiological conditions is a performance deficiency and is a violation of Technical Specification 5.11.1.b. The performance deficiency is more than minor because it is associated with the Occupational Radiation Safety cornerstone attribute of program and process (exposure control) and adversely affects the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation. Additionally, this issue resembles IMC 0612, Appendix E, Example 6(h). Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, the inspectors determined the violation has very low safety significance because:
- (1) it was not an as low as is reasonably achievable (ALARA) finding;
- (2) there was no overexposure;
- (3) there was no substantial potential for an overexposure, and
- (4) the ability to assess dose was not compromised. This violation has a cross-cutting aspect in the human performance area, associated with teamwork, because the operator did not properly communicate his work locations to the RP technician for briefing and the RP technician did not display a questioning attitude to understand the work locations for the operator to properly brief him and ensure nuclear safety was maintained (H.4).
Enforcement.
Technical Specification (TS) 5.11.1.b states, in part, that any individual or group of individuals permitted to enter a HRA shall be provided with a radiation monitoring device which continuously integrates the radiation dose rates in the area and alarms when a preset integrated dose is received and that entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them. Contrary to the requirement of TS 5.11.1.b, on July 19, 2013, an operator entered a HRA with a radiation monitoring device (electronic alarming dosimeter), but was not knowledgeable of the dose rate levels in the area. Specifically, the operator veered from the walk path, on which he was briefed for a maximum dose rate level of 20 millirem per hour, and entered a HRA with dose rates of 450 millirem per hour at 30 cm. As a result, the operator received a high dose rate alarm of 476 millirem per hour on his EAD.
Because this violation is of very low safety significance and was entered into the licensees corrective action program as CR 2014-14693, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy:
NCV 05000285/2014003-01: Failure to Control an Entry to a High Radiation Area Resulting in a Dose Rate Alarm.
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
The inspectors assessed licensee performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). During the inspection, the inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:
- Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements
- ALARA work activity evaluations/post-job reviews, exposure estimates, and exposure mitigation requirements
- The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies
- Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry
- Radiation worker and RP technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas
- Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection These activities constitute completion of one sample of occupational ALARA planning and controls as defined in Inspection Procedure 71124.02.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspectors evaluated the accuracy and operability of the licensees personnel monitoring equipment, verified the accuracy and effectiveness of the licensees methods for determining total effective dose equivalent, and verified that the licensee was appropriately monitoring occupational dose. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:
- External dosimetry accreditation, storage, issue, use, and processing of active and passive dosimeters
- The technical competency and adequacy of the licensees internal dosimetry program
- Adequacy of the dosimetry program for special dosimetry situations, such as declared pregnant workers, multiple dosimetry placement, and neutron dose assessment
- Audits, self-assessments, and corrective action documents related to dose assessment since the last inspection These activities constitute completion of one sample of occupational dose assessment as defined in Inspection Procedure 71124.04.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Reactor Coolant System Specific Activity (BI01)
a. Inspection Scope
The inspectors reviewed the licensees reactor coolant system chemistry sample analyses for the period of December 1, 2013, through March 31, 2014, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the reactor coolant system specific activity performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Reactor Coolant System Total Leakage (BI02)
a. Inspection Scope
The inspectors reviewed the licensees records of reactor coolant system total leakage for the period of December 1, 2013, through March 31, 2014, to verify the accuracy and completeness of the reported data. The inspectors observed the performance of OP-ST-RC-3001, Reactor Coolant System (RCS) Leak Rate Test on February 4, 2014.
The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the reactor coolant system leakage performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Occupational Exposure Control Effectiveness (OR01)
a. Inspection Scope
The inspectors verified there were no unplanned exposures or losses of radiological control over locked high radiation areas and very high radiation areas during the period of April 1, 2013, to March 31, 2014. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than 100 millirem. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the occupational exposure control effectiveness performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.4 Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual
(ODCM) Radiological Effluent Occurrences (PR01)
a. Inspection Scope
The inspectors reviewed corrective action program records for liquid or gaseous effluent releases that occurred between April 1, 2013, and March 31, 2014, and were reported to the NRC to verify the performance indicator data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual (ODCM) radiological effluent occurrences performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
b. Findings
No findings were identified.
.2 Annual Follow-up of Selected Issues
a. Inspection Scope
The inspectors selected one issue for an in-depth follow-up:
- On March 13, 2014, the inspectors assessed the licensees operator work-arounds to determine if the mitigating system function is affected or the operators ability to implement abnormal and emergency operating procedures were affected. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate.
These activities constitute completion of one annual follow-up sample, which included one operator work-around sample, as defined in Inspection Procedure 71152.
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
.1 (Opened) Licensee Event Report 05000285/2014-003-00: Reactor Trip Due to Stator Water
Cooling Leak During Maintenance On March 17, 2014, at 12:02 Central Daylight Time (CDT), a turbine trip, and subsequent reactor trip occurred while operating at nominal 100 percent power. Maintenance was in progress on the main generator stator cooling system when system inventory was lost resulting in an automatic turbine trip due to low system pressure. Immediate response by operations personnel included implementing procedure emergency operating procedure (EOP)-00, Standard Post Trip Actions, and subsequent entry into Procedure EOP-01, Reactor Trip Recovery. Based on plant system response this is considered an uncomplicated trip.
The station determined that the root cause of the plant trip was that operational risk was not effectively identified or mitigated by individuals throughout the organization.
The leak was isolated shortly after the trip by fully removing the probe and closing the isolation valve. Fort Calhoun Station will be implementing the Exelon Risk Management Procedure, WC-AA-104, Integrated Risk Management. This procedure provides direction consistent with industry best practices, and requires individual review of each category of risk identification and mitigation.
.2 Operator Response During Unplanned Events
For the plant event listed below, the inspectors reviewed and observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant event to appropriate regional personnel. The inspectors verified that Fort Calhoun made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Fort Calhouns follow-up actions related to the event to assure that Fort Calhoun implemented appropriate corrective actions commensurate with their safety significance.
- Operator conduct of a plant downpower to approximately 30 percent power to prepare for a potential plant shutdown due to rising Missouri river water level on June 20, 2014, and Fort Calhoun actions to ready the plant to mitigate the consequences of a significant flooding event from June 17 through June 22, 2014.
These activities constitute completion of two event follow-up samples, as defined in Inspection Procedure 71153.
4OA4 IMC 0350 Inspection Activities
On December 17, 2013, the Nuclear Regulatory Commission issued a Confirmatory Action Letter to Fort Calhoun Station (ML13351A395). The Confirmatory Action Letter confirms the commitments in the December 2, 2013, Omaha Public Power District (OPPD), Integrated Report to Support Restart of Fort Calhoun Station and Post-Restart Commitments for Sustained Improvement. In the report, OPPD committed to take actions following restart of the Fort Calhoun Station to ensure the improvements realized during the extended outage remain in place and performance continues to improve at the facility. Included in the commitments are completing actions detailed in the Flooding Recovery Action Plan.
Flood Recovery Action Item Plan 1.2.3.21, Inspect tank and equipment on demineralized water tank for damage
a. Inspection scope
A water filled barrier was installed prior to the 2011 flood to protect the Deionized (DI)
Water Storage Tank and its associated utility building. Due to excessive stress on the barrier in the tight installation configuration, the barrier failed and the tank was exposed to flood water for several months.
A structural assessment of the DI Water Tank was conducted. The inspectors reviewed the structural assessment, and performed visual inspection of the tank and concluded that there was no damage to the tank or associated utility building.
The inspectors previously performed a review of the Demineralized and Potable Water Systems. The scope of these reviews determined that the only equipment affected were to the Reverse Osmosis Unit Water Storage Tank Inlet and Outlet Pumps, DW-69, and DW-70. These pump motors were damaged after being submerged in flood waters.
These pump motors were replaced in accordance with Flood Recovery Action Plan items 2.3.1.13, 2.3.1.14, 2.3.1.15, and 2.3.1.16, and documented in Inspection Report 05000285/2012004 (ML12276A456).
This activity constitutes completion of action item 1.2.3.21 as described in the Flood Recovery Action Plan and the December 17, 2013 Confirmatory Action Letter.
b. Findings
No findings were identified.
4OA5 Other Activities
1. Temporary Instruction 2515/182 - Review of the Industry Initiative to Control Degradation
of Underground Piping and Tanks
a. Inspection scope
Leakage from buried and underground pipes has resulted in groundwater contamination incidents with associated heightened NRC and public interest. The industry issued a guidance document, NEI 09-14, Guideline for the Management of Buried Piping Integrity, (ML1030901420) to describe the goals and required actions (commitments made by the licensee) resulting from this underground piping and tank initiative. On December 31, 2010, NEI issued Revision 1 to NEI 09 14, Guidance for the Management of Underground Piping and Tank Integrity, (ML110700122) with an expanded scope of components which included underground piping that was not in direct contact with the soil and underground tanks. On November 17, 2011, the NRC issued Temporary Instruction 2515/182, Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks, to gather information related to the industrys implementation of this initiative.
b.
Observations The licensees buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.a of the Temporary Instruction and it was confirmed that activities which correspond to completion dates specified in the program which have passed since the Phase 1 inspection was conducted, have been completed.
Additionally, the licensees buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.b of the Temporary instruction and responses to specific questions were submitted to the NRC headquarters staff. Based upon the scope of the review described above, Phase II of TI-2515/182 was completed.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On April 24, 2014, the inspectors presented the radiation safety inspection results to Mr. M. Prospero, Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed. One document, which remained in the possession of an NRC inspector, was identified as proprietary after we left site. The NRC inspector informed the licensee that this document was later identified as proprietary and the licensee informed the NRC inspector to shred the document. Thus, the proprietary document was shredded in an official security waste bin at the NRC office.
On May 6, 2014, the inspector presented the results of Temporary Inspection 2515/182, Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks, to Mr. M. Prospero, and other members of your staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. The proprietary information identified was deleted from the NRC computer.
On June 12, 2014, the inspectors presented the final inspection results Mr. E. Dean, Plant Manager and other members of the licensees staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
On July 16, 2014, the inspectors presented the inspection results for the Heat Sink Performance Inspection to Mr. E. Dean, Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- S. Anderson, Manager, Design Engineering
- D. Bakalar, Manager, Security
- J. Bousum, Manager, Emergency Planning and Administration
- D. Brehm, Engineer, Radiation Protection
- C. Cameron, Supervisor Regulatory Compliance
- L. Cherko, Health Physicist
- L. Cortopassi, Site Vice President
- S. Coufal, Health Physicist
- E. Dean, Plant Manager
- E. Durboraw, Health Physicist, Radiation Protection
- M. Ferm, Manager, System Engineering
- H. Goodman, Site Engineering Director
- P. Gunderson, Supervisor, Radiological Operations
- S. Hamm, Unit Supervisor
- R. Hugenroth, Supervisor Nuclear Oversight
- K. Ihnen, Manager, Site Nuclear Oversight
- P. Kellogg, Supervisor, ALARA
- J. Lindsey, Director, Training
- D. Little, Rad Health Specialist
- K. Maassen, Program Engineer, GL 89-13
- T. Maine, Manager, Radiation Protection
- E. Matzke, Senior Licensing Engineer
- W. McCall, Health Physicist, Radiation Protection
- J. McManis, Manager Engineering Programs
- B. Obermeyer, Manager, Corrective Action Program
- T. Orth, Director, Site Work Management
- D. Pier, Shift Manager
- M. Prospero, Plant Manager
- S. Shea, Supervisor, Operations Training
- T. Simpkin, Manager, Site Regulatory Assurance
- M. Stewart, Sr. Radiation Protection Technician
- S. Swanson, Director, Operations
- D. Whisler, Supervisor, ALARA
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
Reactor Trip Due to Stator Water Cooling Leak During
- 05000285/2014-003-00 LER Maintenance (Section 4OA3)
Closed
Review of Implementation of the Industry Initiative to Control 2515/182 TI Degradation of Underground Piping and Tanks
Opened and Closed
- 05000285/2014003-01 NCV Failure to Control an Entry to a High Radiation Area Resulting in a Dose Rate Alarm