IR 05000285/2015003
| ML15314A273 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun |
| Issue date: | 11/10/2015 |
| From: | Geoffrey Miller NRC/RGN-IV/DRP/RPB-D |
| To: | Cortopassi L Omaha Public Power District |
| GEOFFREY MILLER | |
| References | |
| 4-2014-032, EA-2015-057 IR 2015003 | |
| Download: ML15314A273 (48) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511
November 10, 2015
EA-2015-057
Louis P. Cortopassi, Site Vice President Omaha Public Power District Fort Calhoun Station P.O. Box 550 Fort Calhoun, NE 68023-0550
Subject:
FORT CALHOUN - NRC INTEGRATED INSPECTION REPORT NUMBER 05000285/2015003 AND INVESTIGATION REPORT 4-2014-032
Dear Mr. Cortopassi:
On September 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fort Calhoun Station (FCS). On October 19, 2015, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
These findings involved violations of NRC requirements.
If you contest these violations or significance of the NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Fort Calhoun Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the Fort Calhoun Station.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's
L. Cortopossi-2-Agencywide Documents Access and Management 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 BHagar for/
Geoffrey B. Miller Chief, Project Branch D Division of Reactor Projects
Docket: 50-285 License: DPR-40
Enclosure:
NRC Inspection Report 05000285/2015003 and Investigative Report 4-2014-032 w/Attachment: Supplemental Information
SUNSI Review By: BHagar ADAMS Yes No Publicly Available Non-Publicly Available Non-Sensitive Sensitive OFFICE DRP/SPE DRS/OB DRS/EB1 DRS/PSB2 DRS/TSS DRS/PSB1 NAME BHagar VGaddy TFarnholtz HGepford ERuesch MHaire SIGNATURE
/RA/
/RA/KClayton for
/RA/
/RA/
/RA/
/RA/
DATE 11/10/15 11/3/15 11/3/14 10/30/15 11/1/15 11/2/15 OFFICE DRS/EB2 ACES DRP/BC DRP/SRI NAME GWerner JKramer GMiller MSchneider SIGNATURE
/RA/
/RA/
/RA/
/RA/
DATE 11/3/15 11/9/15 11/10/15 11/5/15
Letter to from Geoffrey B. Miller dated November 10, 2015
Subject:
FORT CALHOUN - NRC INTEGRATED INSPECTION REPORT NUMBER 05000285/2015003 AND INVESTIGATION REPORT 4-2014-032
DISTRIBUTION:
Regional Administrator (Marc.Dapas@nrc.gov)
Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)
DRP Director (Troy.Pruett@nrc.gov)
DRP Deputy Director (Ryan.Lantz@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
DRS Deputy Director (Jeff.Clark@nrc.gov)
RIV Branch Chief, DRP/D (Geoffrey.Miller@nrc.gov)
Senior Resident Inspector (Max.Schneider@nrc.gov)
Resident Inspector (Brian.Cummings@nrc.gov)
Senior Project Engineer, DRP/D (Bob.Hagar@nrc.gov)
Project Engineer, DRP/D (Jim.Melfi@nrc.gov)
Project Engineer, DRP/D (Jan.Tice@nrc.gov)
FCS Administrative Assistant (Janise.Schwee@nrc.gov)
Acting Team leader, DRS/TSS (Eric.Ruesch@nrc.gov)
RIV Public Affairs Officer (Victor.Dricks@nrc.gov)
NRR Project Manager (Fred.Lyon@nrc.gov)
RIV RITS Coordinator (Marisa.Herrera@nrc.gov)
RIV Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)
OEWEB Resource@nrc.gov OEWEB Resource (Sue.Bogle@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
RIV/ETA: OEDO (Cindy.Rosales-Cooper@nrc.gov)
RIV RSLO (Bill.Maier@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
ROPreports
- 1 -
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
50-285 License:
DPR-40 Report:
05000285/2015003 Licensee:
Omaha Public Power District Facility:
Fort Calhoun Station Location:
9610 Power Lane Blair, NE 68008 Dates:
July 1 through September 30, 2015 Inspectors:
S. Schneider, Senior Resident Inspector B. Cummings, Resident Inspector B. Baca, Project Engineer M. Brooks, Physical Security Inspector J. Drake, Senior Reactor Inspector P. Elkmann, Senior Emergency Preparedness Inspector G. Guerra, CHP, Emergency Preparedness Inspector B. Hagar, Senior Project Engineer C. Peabody, Senior Resident Inspector F. Ramirez, Senior Resident Inspector D. You, Resident Inspector S. Makor, Reactor Inspector
Approved By:
Geoffrey B. Miller, Chief, Project Branch D Division of Reactor Projects
- 2 -
SUMMARY
IR 05000285/2015003; 7/01/2015 - 9/30/2015; Fort Calhoun Station, Operability
Determinations, Other Activities.
The inspection activities described in this report were performed between July 1 and September 30, 2015, by the resident inspectors and inspectors from the Nuclear Regulatory Commissions Region IV office. Two findings of very low safety significance (Green) are documented in this report. These findings involved violations of NRC requirements; the significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310,
Aspects within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Mitigating Systems
- Green.
A Green, self-revealing, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI Corrective Action was identified because the licensee failed to identify and evaluate an adverse trend related to boron concentration in Safety Injection Tank (SIT) SI-6A and to take corrective actions to prevent boron concentration from going below the minimum concentration required by Technical Specifications. The licensees immediate corrective actions included documenting this condition in their corrective action program in Condition Report (CR) 2015-10181, declared SI-6A inoperable, and raised SI-6A boron concentration.
The finding is more than minor because it adversely affected the equipment performance attribute of the mitigating systems cornerstone, in that this finding resulted in the SIT becoming inoperable when boron concentration fell below TS limits for approximately 8.5 days prior to August 20, 2015. Analysis conducted by a Senior Reactor Analyst determined the finding to be of very low safety significance (Green), primarily because the SIT function is needed only for mitigation of a postulated large-break loss of coolant accident, and the initiating-event frequency for such accidents is 2.5 x 10-6/year. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution and the Evaluation aspect, because the licensee did not thoroughly evaluate the issue and ensure that resolutions addressed causes and extent of conditions commensurate with their safety significance [P.2]. (Section 1R15)
- Green.
Inspectors identified a Green, Severity Level IV, non-cited violation of 10 CFR 50.9(a),
Completeness and Accuracy of Information, for the licensees failure to maintain the required fire watch logs complete and accurate in all material respects. The licensee entered this into their corrective action program as Condition Reports (CR) 2014-06416 and 2014-06680.
This finding is more than minor because it adversely affected the human performance attribute of the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
This finding has very low safety significance (Green) because it did not impact the ability to achieve safe shutdown. This findings severity level is based on an example in the Enforcement Policy, Section 6.1.d.2, which states, in part, that Severity Level IV violations involve violations of 10 CFR 50.59 [which] result in conditions evaluated as having very low safety significance (i.e., Green) by the Significance Determination Process. That example applies because a violation of 10 CFR 50.9 is similar to a violation of 10 CFR 50.59, and because this finding has very low safety significance. This finding has a cross-cutting aspect in the resources component of human performance cross-cutting area because the licensees process did not allow enough time for the fire watch personnel to obtain their radiation work permit at the start of their shift before they performed their rounds [H.1]. (Section 4OA5)
PLANT STATUS
The unit began the inspection period at approximately 100 percent power. On July 20, 2015 the unit was taken offline to repair a failed seal on a reactor coolant pump. On July 29, 2015 the unit returned online, reached 100 percent power on August 1, 2015, and operated at 100 percent power for the remainder of the inspection period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Summer Readiness for Offsite and Alternate AC Power Systems
a. Inspection Scope
On August 13, 2015, the inspectors completed an inspection of the stations off-site and alternate-ac power systems. The inspectors inspected the material condition of these systems, including transformers and other switchyard equipment to verify that plant features and procedures were appropriate for operation and continued availability of off-site and alternate-ac power systems. The inspectors reviewed outstanding work orders and open condition reports for these systems. The inspectors walked down the switchyard to observe the material condition of equipment providing off-site power sources. The inspectors verified that the licensees procedures included appropriate measures to monitor and maintain availability and reliability of the off-site and alternate-ac power systems.
This activity constituted one sample of summer readiness of off-site and alternate-ac power systems, as defined in Inspection Procedure 71111.01.
a. Findings
No findings were identified.
.2 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
On August 26, 2015, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for seasonal high temperatures, and evaluated the licensees implementation of these procedures.
The inspectors selected two risk-significant systems that were required to be protected from seasonal high temperatures:
- switchgear room supplemental cooling
- raw water system (intake structure)
The inspectors reviewed the licensees procedures and design information to ensure the systems would remain functional when challenged by adverse weather. The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the systems.
This activity constituted one sample of readiness for seasonal adverse weather, 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 three partial system walk-downs of the following risk-significant systems:
- July 23, 2015, standby decay heat removal path while in mid-loop
- July 27, 2015, engineered safety features lineup
- August 14, 2015, motor driven auxiliary feed water pump following maintenance
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.
.2 Complete Walkdown
a. Inspection Scope
On August 14, 2015, the inspectors performed a complete system walk-down inspection of the auxiliary feed water system. The inspectors reviewed the licensees procedures and system design information to determine the correct auxiliary feed water system lineup for the existing plant configuration. The inspectors also reviewed system health tracking, outstanding work orders, open condition reports, and other open items tracked by the licensees operations and engineering departments. The inspectors visually verified that the system was correctly aligned for the existing plant configuration.
These activities constituted one complete system walk-down sample, 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 six plant areas important to safety:
- August 10, 2015, battery room 2, fire area 38
- August 10, 2015, battery room 1, fire area 37
- August 10, 2015, start-up pump FW-54 enclosure, fire area 46.3
- August 21, 2015, mechanical penetration room, fire area 13
- August 21, 2015, safety injection and containment spray pump room 22, fire area 2
- August 21, 2015, component cooling water heat exchanger room 18, fire area 33
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 six quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
.2 Annual Inspection
a. Inspection Scope
On August 12, 2015, the inspectors completed their annual evaluation of the licensees fire brigade performance. This evaluation included observation of an announced fire drill on August 12, 2015. During this drill, the inspectors evaluated the capability of the fire brigade members, the leadership ability of the brigade leader, the brigades use of turnout gear and fire-fighting equipment, and the effectiveness of the fire brigades team operation. The inspectors also reviewed whether the licensees fire brigade met NRC requirements for training, dedicated size and membership, and equipment.
This activity constituted one annual inspection sample, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
On August 12, 2015, 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 one plant area containing risk-significant structures, systems, and components that were susceptible to flooding:
- Room 18, component cooling water heat exchangers
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.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Review of Licensed Operator Requalification
a. Inspection Scope
The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the training.
- July 22, 2015, the inspectors observed simulator training for an operating crew in preparation for mid-loop operations
- August 25, 2015, the inspectors observed an evaluated simulator scenario performed by an operating crew
These activities constitute completion of two quarterly licensed operator requalification program samples, 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 or risk. The inspectors observed the operators performance of the following activities:
- July 6, 2015, operations response following indications of a reactor coolant pump malfunction coincident with a minor reactor coolant leak. The inspectors observed the operators performance related to adherence to abnormal operating procedures, assessment of Technical Specification applicability, evaluation of plant risk, and assessment of Emergency Action Level criteria.
- July 27, 2015, operations response following the closure of main steam isolation valves and the resultant lift of one or more main steam safety valves. The inspectors observed the operators performance related to the assessment of plant risk, abnormal operating procedure entry, and assessment of Emergency Action level criteria.
- September 17, 2015, operations response to a failure of an undervoltage relay that affected a vital 4160VAC bus.
In addition, the inspectors assessed the operators adherence to plant procedures and other operations department policies.
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):
- September 9, 2015, pressurizer safety valve leak during plant heat-up
- September 16, 2015, control room air conditioning refrigerant leak
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 four 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:
- July, 8, 2015, planned yellow risk during channel B testing of safety injection, containment spray, and recirculation actuation signals
- July 23, 2015, planned yellow risk during mid-loop operations
- August 28, 2015, planned yellow risk during #2 emergency diesel generator maintenance
- September 10, 2015, planned yellow risk during diesel driven auxiliary feed water pump operability verification
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.
These activities constitute completion of four 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 and functionality assessments that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs):
- July 16, 2015, operability assessment of a reactor coolant system leak from reactor coolant pump 3A
- August 7, 2015, reactor coolant pump RC-3A, adverse condition monitoring and contingency plan due to high RC-3A shaft displacement vibration levels
- August 19, 2015, functionality assessment of battery room ventilation
- August 21, 2015, operability assessment of safety injection tank boron concentration
The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC.
These activities constitute completion of four operability and functionality review samples, as defined in Inspection Procedure 71111.15.
b. Findings
Failure to Maintain Safety Injection Tank Boron Concentration within Technical Specifications
Introduction.
The inspectors reviewed a self-revealing, non-cited violation of very low safety significance of 10 CFR Part 50, Appendix B, Criterion XVI Corrective Action because the licensee failed to identify an adverse trend related to boron concentration in Safety Injection Tank (SIT) SI-6A and to take corrective actions to prevent boron concentration from falling below the minimum concentration required by Technical Specifications (TS).
Description.
On June 25, 2015, during performance of monthly surveillance test CH ST SI-0002, Safety Injection Tank Boron Sampling and Analysis, the licensee identified that boron concentration in all four SITs was below the administrative limit of 2260 parts per million (ppm). CH-ST-SI-0002 requires the licensee to take corrective actions when boron is measured below administrative limits, to ensure that the SITs remain operable and meet the minimum TS requirement of 2160 ppm, as specified in the licensees Core Operating Limits Report. The licensee documented this condition in their corrective action program in Condition Report (CR) 2015-8252, adjusted sample frequency to a two-week interval, and assigned an action item to monitor for an adverse trend.
On July 7, 2015, the licensee sampled the SITs at the two-week interval, as described in CR 2015-8252. The licensee did not identify either an appreciable change in boron concentration or an adverse trend. The licensee then closed the action item to increase sample frequency and monitor for adverse trending, even though boron concentration remained below administrative levels. The justification for closing this action item was that no adverse trend had been identified, regular scheduled samples would be taken in two weeks, and any adverse trend would be identified during the next scheduled sample.
On July 25, 2015, the licensee sampled the SITs again and noted a significant decrease in boron concentration in all four SITs. The tank most affected was tank SI-6A, which experienced a change in boron concentration from 2248 ppm on 7/7/15 to 2216 ppm on 7/25/15. The licensee should have identified this significant boron concentration change as a negative trend, and should have taken corrective actions to address that trend.
Remarks associated with the surveillance test indicated that boron concentration was below administrative limits and referenced corrective actions associated with CR 2015-8252. However, as noted above, the licensee had already closed the referenced corrective actions, and had not specified additional actions.
On August 20, 2015, when the licensee sampled the SITs, boron concentration in SIT SI 6A was 2132 ppm, well below the minimum concentration of 2160 ppm required by Technical Specification. The licensee subsequently declared SIT SI-6A inoperable and entered Technical Specification 2.3, Emergency Core Cooling System, which requires the licensee to either restore SIT boron concentration within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or shut down the plant. The licensee then took action to raise the boron concentration of SIT SI-6A above TS limits, and exited the requirement to shut down within the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> timeframe.
Following the event, the licensee determined that the combination of check-valve leakage from the reactor coolant system to the SITs and periodic draining activities to maintain the required volume in the SITs had diluted the boron in the tanks. Although the licensee had previously identified and documented check valve leakage in Condition Report 2015-8668, they had not assessed the effects on boron concentration in the SITs.
The inspectors determined that the primary cause of this finding was that the licensee did not evaluate either the back leakage condition that was originally described in CR 2015-8668, or the SIT trending data. If they had, the inspectors considered that they would have initiated additional monitoring and corrective actions before boron concentration lowered to below the TS limit.
Analysis.
The licensees failure to identify an adverse trend in boron concentration in SIT SI-6A and to take action to prevent an out-of-specification condition was a performance deficiency within the licensees ability to foresee and correct and therefore should have been prevented. The finding is more than minor because it adversely affected the equipment performance attribute of the mitigating systems cornerstone.
Specifically, the failure to identify an adverse trend in SIT SI-6A boron concentration and to take corrective actions to arrest the trend resulted in the SIT becoming inoperable when boron concentration fell below TS limits.
Using NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2 Mitigating System Screening Questions Part A, dated July 1, 2012, and through linear trending of the SIT boron concentration from the July 25, 2015 known concentration through the August 20, 2015 known concentration, the inspectors determined the finding represented an actual inoperability of SIT SI-6A for greater than its TS-allowed outage time (AOT). That is, assuming that boron concentration decreased in an approximately linear manner with time, the SIT SI-6A boron concentration would have been below the TS requirement for approximately 8.5 days prior to the August 20, 2015 confirmation sample. That duration exceeds the TS AOT for SIT boron concentration below the TS limit of 3 days. As a result, a more detailed analysis was conducted by a Senior Reactor Analyst using the plant-specific standardized plant analysis risk model. That analysis determined the finding to be of very low safety significance (Green), primarily because the SIT function is needed only for mitigation of a postulated large-break loss of coolant accident, and because the initiating event frequency for such accidents is 2.5 x 10-6/year. Given the 8.5-day exposure period, the likelihood of having a large-break loss of coolant accident during this time was 5.8 x 10-8. This incremental probability is well below the 1 x 10-6 threshold for a significant change in core damage frequency.
Because the primary cause of this finding was that the licensee did not evaluate either the back leakage condition that was originally described in CR 2015-8668, or the SIT trending data, the finding has a cross-cutting aspect in the area of Problem Identification and Resolution, the Evaluation aspect, because the licensee did not thoroughly evaluate the issue and ensure that resolutions addressed causes and extent of conditions commensurate with their safety significance (P.2).
Enforcement.
Title 10 CFR Part 50 Appendix B, Criterion XVI requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, between June 25 and August 20, 2015, measures established by the licensee did not assure that conditions adverse to quality were promptly identified and corrected. Specifically, measures established by the licensee did not identify an adverse trend related to boron concentration in SIT SI-6A and therefore did not correct that trend to prevent boron concentration from going below the minimum concentration required by TS. Corrective actions to address this violation include implementing procedural revisions to CH-ST-SI-0002 that include trending methods and additional guidance when boron concentrations are discovered below administrative limits. In addition, the licensee developed an adverse condition monitoring plan to ensure that reactor coolant system leakage into the safety injection tanks is adequately monitored and the effects of boron dilution are anticipated to prevent an out-of-specification condition. Because this violation was of very low safety significance and was entered into the licensees corrective action program as Condition Report 2015-10181, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRCs Enforcement Policy: NCV 05000285/2015003-001, Failure to Maintain Safety Injection Tank Boron Concentration within Technical Specification Limits.
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed two temporary plant modifications that affected risk-significant structures, systems, and components (SSCs):
- August 21, 2015, A qualified safety parameter display system
- September 17, 2015, temporary cap on refrigerant line for the A control room air conditioner
The inspectors verified that the licensee had installed these temporary modifications in accordance with technically adequate design documents. The inspectors verified that these modifications did not adversely impact the operability or availability of affected SSCs. The inspectors reviewed design documentation and plant procedures affected by the modifications to verify the licensee maintained configuration control.
These activities constitute completion of two samples of plant modifications, as defined in Inspection Procedure 71111.18.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed seven post-maintenance testing activities that affected risk-significant structures, systems, or components (SSCs):
- August 18, 2015, diesel driven auxiliary feed water pump bearing replacement and shaft seal replacement
- August 20, 2015, A qualified safety parameter display system troubleshooting
- August 28, 2015, control room air conditioning maintenance
- September 9, 2015, charging pump replacement of top caps and drip rings
- September 17, 2015, component cooling water pump following installation of accumulator tank
- September 21, 2015, 4160VAC breaker 1A2 replacement
- September 29, 2015, component cooling water heat exchanger AC-1D inlet valve maintenance
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 or reviewed the test results 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 seven post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
During the stations forced outage due to a failed reactor coolant pump seal that concluded on July 30, 2015, the inspectors evaluated the licensees outage activities.
The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following:
- Review of the licensees outage schedule
- Review and verification of the licensees fatigue management activities
- Monitoring of shut-down and cool-down activities
- Verification that the licensee maintained defense-in-depth during outage activities
- Observation and review of reduced-inventory
- Monitoring of heat-up and startup activities
These activities constitute completion of one outage sample as defined in Inspection Procedure 71111.20.
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 addition, the inspectors reviewed one reactor coolant system leak rate test:
In-service tests:
- September 1, 2015,raw water pump AC-10B quarterly in-service test Reactor coolant system leak detection tests:
- September 10, 2015, reactor coolant system daily leak rate test
Other surveillance tests:
- August 3, 2015, motor driven auxiliary feed water pump operability test
- August 20, 2015, third auxiliary feed water pump operability test
- September 30, 2015, quarterly functional test of reactor protective system trip logic
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 tests satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.
These activities constitute completion of five surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The inspector performed an in-office review of Radiological Emergency Response Plan, Section E, Revision 30, and Section P, Revision 14, implemented July 7, 2015. This revision,
- Required the automatic callout system for the emergency response organization to be capable of activating telephones, sending emails, and sending text messages to the response organization; and,
- Updated titles and references in the emergency plan.
This revision was compared to its previous revision, to the criteria of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, and to the standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that the revision did not decrease the effectiveness of the emergency plan. This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection.
These activities constitute completion of one emergency action level and emergency plan changes sample as defined in Inspection Procedure 71114.04.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed an emergency preparedness drill on September 22, 2015, to verify the adequacy and capability of the licensees assessment of drill performance.
The inspectors reviewed the drill scenario, observed the drill from the simulator, 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.
.2 Training Evolution Observation
a. Inspection Scope
On August 25, 2015, the inspectors observed simulator-based licensed operator requalification training that included implementation of the licensees emergency plan.
The inspectors verified that the licensees emergency classifications and off-site notifications, were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the evaluators and entered into the corrective action program for resolution.
These activities constitute completion of one training evolution observation sample as defined in Inspection Procedure 71114.06.
b. Findings
No findings were identified.
1EP7 Exercise Evaluation - Hostile Action Event
a. Inspection Scope
The inspectors observed the August 4, 2015, biennial emergency plan exercise to verify the exercise acceptably tested the major elements of the emergency plan, provided opportunities for the emergency response organization to demonstrate key skills and functions, and demonstrated the licensees ability to coordinate with offsite emergency responders. The scenario simulated,
- a partial loss of offsite power escalating to a complete loss of offsite power;
- land and water-based attacks against the licensee;
- unexploded ordinance;
- damage to a reactor feed water pump;
- a loss of the service water system (plant cooling water supply); and,
- injured plant employees;
to demonstrate the licensees capability to implement its emergency plan under conditions of uncertain physical security. During the exercise the inspectors observed activities in the control room simulator and the following emergency response facilities:
- Operations Support Center;
- Central and Secondary Alarm Stations; and,
- Incident Command Post.
The inspectors focused their evaluation of the licensees performance on event classification, offsite notification, recognition of offsite dose consequences, development of protective action recommendations, staffing of alternate emergency response facilities, and the coordination between the licensee and offsite agencies to ensure reactor safety under conditions of uncertain physical security.
The inspectors also assessed recognition of, and response to, abnormal and emergency plant conditions, the transfer of decision-making authority and emergency function responsibilities between facilities, on-site and offsite communications, protection of plant employees and emergency workers in an uncertain physical security environment, emergency repair evaluation and capability, and the overall implementation of the emergency plan to protect public health and safety and the environment. The inspectors reviewed the current revision of the facility emergency plan, emergency plan implementing procedures associated with operation of the licensees primary and alternate emergency response facilities, and procedures for the performance of associated emergency and security functions.
The inspectors attended the post-exercise critiques in each emergency response facility to evaluate the initial licensee self-assessment of exercise performance. The inspectors also attended a subsequent formal presentation of critique items to plant management.
The inspectors reviewed the scenario of previous biennial exercises and licensee drills conducted between August 2013 and July 2015, to determine whether the August 4, 2015, exercise was independent and avoided participant preconditioning, in accordance with the requirements of 10 CFR 50, Appendix E, IV.F(2)(g). The inspectors also compared observed exercise performance with corrective action program entries and after-action reports for drills and exercises conducted between January 2014 and July 2015 to determine whether identified weaknesses had been corrected in accordance with the requirements of 10 CFR 50.47(b)(14), and 10 CFR 50, Appendix E, IV.F. The specific documents reviewed during this inspection are listed in the attachment.
These activities constituted completion of one exercise evaluation sample as defined in Inspection Procedure 71114.07.
b. Findings
No findings were identified.
1EP8 Exercise Evaluation - Scenario Review
a. Inspection Scope
The licensee submitted the preliminary exercise scenario for the August 4, 2015, biennial exercise to the NRC on June 3, 2015, in accordance with the requirements of 10 CFR 50, Appendix E, IV.F(2)(b). The inspectors performed an in-office review of the proposed scenario to determine whether it would acceptably test the major elements of the licensees emergency plan and provide opportunities for the emergency response organization to demonstrate key skills and functions.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Mitigating Systems, Emergency Preparedness
4OA1 Performance Indicator Verification
.1 Drill/Exercise Performance (EP01)
a. Inspection Scope
The inspectors reviewed the licensees evaluated exercises and selected drill and training evolutions that occurred between October 2014 and June 2015 to verify the accuracy of the licensees data for classification, notification, and protective action recommendation (PAR) opportunities. The inspectors reviewed a sample of the licensees completed classifications, notifications, and PARs to verify their timeliness and accuracy. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.
These activities constituted verification of the drill/exercise performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Emergency Response Organization Drill Participation (EP02)
a. Inspection Scope
The inspectors reviewed the licensees records for participation in drill and training evolutions between October 2014 and June 2015 to verify the accuracy of the licensees data for drill participation opportunities. The inspectors verified that all members of the licensees emergency response organization (ERO) in the identified key positions had been counted in the reported performance indicator data. The inspectors reviewed the licensees basis for reporting the percentage of ERO members who participated in a drill.
The inspectors reviewed drill attendance records and verified a sample of those reported as participating. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.
These activities constituted verification of the emergency response organization drill participation performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Alert and Notification System Reliability (EP03)
a. Inspection Scope
The inspectors reviewed the licensees records of alert and notification system tests conducted between October 2014 and June 2015 to verify the accuracy of the licensees data for siren system testing opportunities. The inspectors reviewed procedural guidance on assessing alert and notification system opportunities and the results of periodic alert and notification system operability tests. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.
These activities constituted verification of the alert and notification system reliability performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.4 Mitigating Systems Performance Index: High Pressure Injection Systems (MS07)
a. Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the period of July 1, 2014 through June 30, 2015 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 mitigating system performance index for high pressure injection systems as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.5 Mitigating Systems Performance Index: Heat Removal Systems (MS08)
a. Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the period of July 1, 2014 through June 30, 2015 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.
This activity constituted verification of the mitigating system performance index for heat removal systems as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.6 Mitigating Systems Performance Index: Cooling Water Support Systems (MS10)
a. Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the period of July 1, 2014 through June 30, 2015 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 mitigating system performance index for cooling water support systems, 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 two issues for an in-depth follow-up:
- On July 21, 2015, in-service testing program classification of auxiliary feed water system valves
The inspectors assessed the licensees design reviews and extent of condition associated with a condition report generated during an NRC component design basis inspection in February, 2015, that potentially identified valves in the auxiliary feed water system that may have been misclassified under the in-service testing program. The inspectors verified that the licensee appropriately prioritized corrective actions and that these actions were adequate to address any discrepancies.
- August 15, 2015, issues related to diesel generator damper performance
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and corrective actions from a condition report documenting failures to close or long closure times associated with emergency diesel generators inlet dampers since 2012. The inspectors identified that the licensee had corrective actions to ensure that the dampers were in an appropriate preventive maintenance program and that the dampers were opening to the correct position. The inspectors verified that the licensee appropriately prioritized corrective actions and that these actions were adequate to ensure that the dampers were opening and would not challenge operability of the diesel generators.
These activities constitute completion of two annual follow-up samples as defined in Inspection Procedure 71152.
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
Plant Events
a. Inspection Scope
For the plant events listed below, the inspectors reviewed and observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems as applicable. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in Inspection Manual Chapter 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that the licensee made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed the licensees follow-up actions related to the event to assure that the licensee implemented appropriate corrective actions commensurate with their safety significance.
- Operator response to a leak from a reactor coolant pump instrumentation line on July 6, 2015
- Operator response to a closure of main steam isolation valves while in mode 3 and the resultant lift of one or more main steam safety valves on July 27, 2015
- Operator response to a failed undervoltage relay affecting electrical bus transfer capability on September 17, 2015
These activities constitutes completion of three event follow-up samples, as defined in Inspection Procedure 71153.
b. Findings
No findings were identified.
4OA5 Other Activities
.1 Institute of Nuclear Power Operations (INPO) Plant Assessment Report Review
a. Inspection Scope
The inspectors reviewed the report for an INPO special focus visit conducted at Fort Calhoun Station on March 16-20, 2015. The inspectors reviewed the report to ensure that issues identified were consistent with the NRC perspectives of licensee performance and to verify if any significant safety issues were identified that required further NRC follow-up.
b. Findings
No findings were identified.
.2 Failure to Maintain Fire Watch and Fire Watch Logs
a. Inspection Scope
On June 11, 2014, the Office of Investigations initiated an investigation to look at the possible falsification of fire watches and fire watch records. Based on the evidence developed during the Office of Investigations Investigation 4-2014-032, the NRC determined that three individuals deliberately failed to conduct fire watch rounds and falsified fire watch records showing that they had actually completed the required inspection of the fire watch areas. As part of their review, the inspectors reviewed the investigation report, licensee procedures, fire watch records, other licensee records, and associated corrective action documents.
b. Findings
Introduction.
Inspectors identified a Green, Severity Level IV, non-cited violation of 10 CFR 50.9(a), Completeness and Accuracy of Information, for the licensees failure to maintain required fire watch logs complete and accurate in all material respects. On May 24, 2014, the fire marshal observed a fire watch contractor not performing a required hourly fire watch and upon initiating an investigation, the licensee determined that other contractors did not perform required fire watches and falsified fire watch logs.
The licensee entered this into their corrective action program as Condition Reports (CR)2014-06416 and 2014-06680.
Description.
Licensee Procedure OP-MW-201-007, Fire Protection System Impairment Control, Revision 7, Section 4.6.1, requires, in part, that the individual assigned the fire watch duty shall perform the assigned fire watch and continuously complete Section IV (Attachment 2) and record the actual time and date each time the fire watch inspection is performed. On May 24, 2014, the fire marshal observed one of the fire watch contract personnel at a computer during the time that they should have been performing hourly fire watches. The fire marshal observed that the fire watch logs had been predated and identified that a contractor had failed to perform hourly fire watch inspections and falsified fire watch inspection log records. The individual admitted to not performing the hourly fire watch on May 24, 2014, and falsifying the fire watch log by predating the log during the previous hourly fire watch.
As a result of this observation, the licensee notified the NRC and initiated an investigation to identify the extent of condition. The licensee identified from their investigation, additional instances of incomplete and inaccurate fire watch logs by three additional contract fire watch personnel. Specifically, the actions by the individuals to not perform all of the required fire watches was of a limited extent as compared to the numerous fire watches that were performed over the same period of time. Based on the details provided by both the licensee and the Office of Investigations, it appeared that the reason one of the fire watch locations (Room 66) was missed was because the room was located in the radiologically controlled area, and based on the start time of the fire watch shifts (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) there was not enough time to obtain a radiological work permit and get entry into the area during the first hour of the fire watch shift and complete all of the required fire watch locations within the hour. In another case, an individual deliberately skipped an entire hourly fire watch on three different occasions to apparently utilize that time for personal activities.
Also, the Region IV office initiated an investigation to determine whether contract personnel willfully failed to perform hourly fire watch inspections and willfully falsified fire watch inspection log records to indicate that the fire watches were completed. Based on the evidence, the NRC deteremined that three contract personnel willfully failed to perform hourly fire watch inspections and then willfully falsified fire watch inspection log records.
The inspectors noted that
- (1) the apparent violation was licensee-identified;
- (2) the licensee promptly notified the NRC regarding the violation and the licensee's investigation;
- (3) the violation involved acts by individuals who were not considered to be licensee officials;
- (4) the apparent violation was limited acts by the individuals; and (5)the licensee took prompt and comprehensive corrective actions that were commensurate with the circumstances, thereby creating a deterrent effect within the licensee's organization.
The inspectors determined that the primary cause of the failure to perform hourly fire watch inspections and to willfully falsify fire watch inspection log records was that the licensees process for dispatching fire watch personnel did not allow enough time for the fire watch personnel to obtain their radiation work permit at the start of their shift before they performed their rounds.
Analysis.
The failure of the licensee to perform the required fire watches and maintain complete and accurate fire watch logs in all material respects was a performance deficiency. The failure constitutes a violation of 10 CFR 50.9(a), which was evaluated through the traditional enforcement process. The significance determination process, which was used to evaluate this performance deficiency, does not specifically consider a performance deficiencys impact on the regulatory process. This violation is associated with a finding that has been evaluated by the Significance Determination Process and communicated with a Significance Determination Process color reflective of the safety impact of the deficient licensee performance. The Significance Determination Process, however, does not specifically consider willfulness. Thus, although related to a common regulatory concern, it is necessary to address the violation and finding using different processes to correctly reflect both the regulatory importance of the violation and the safety significance of the associated finding.
The performance deficiency was determined to be more than minor and therefore is a finding because it adversely affected the human performance attribute of the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors used Inspection Manual Chapter 0609, Appendix F, Attachment 1, and characterized the finding in the Fire Prevention and Administrative Controls category to determine that the finding has very low safety significance (Green) because it did not impact the ability to achieve safe shutdown. The severity level IV finding is based on a similar example in the Enforcement Policy, Section 6.1.d.2, which states, in part, violations of 10 CFR 50.59 result in conditions evaluated as having very low safety significance (i.e., Green) by the Significance Determination Process. This example applies because this violation of 10 CFR 50.9 is similar to a violation of 10 CFR 50.59 and because this violation also has very low safety significance.
Because licensees process for dispatching fire watch personnel did not allow enough time for the fire watch personnel to obtain their radiation work permit at the start of their shift before they performed their rounds, this finding has a cross-cutting aspect in the resources component of human performance cross-cutting area because the licensee failed to ensure that processes and procedures are adequate to ensure nuclear safety (H.1).
Enforcement.
Title 10 of the Code of Federal Regulations, Section 50.9(a)
Completeness and Accuracy of Information, requires, in part, that information required by statute or by the Commissions regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects.
Technical Specification 5.8.1.c states, in part, that written procedures shall be established, implemented, and maintained covering fire protection program implementation.
Licensee Procedure OP-MW-201-007, Fire Protection System Impairment Control, Revision 7, Section 4.6.1, requires, in part, that the individual assigned the fire watch duty shall perform the assigned fire watch and continuously complete Section IV (Attachment 2) and record the actual time and date each time the fire watch inspection is performed.
Contrary to the above, from March 1 to May 24, 2014, individuals assigned the fire watch duty failed to perform the assigned fire watch and continuously complete Section IV (Attachment 2) and record the actual time and date each time the fire watch inspection is performed. Specifically, three contract fire watch employees did not perform certain assigned fire watches and falsified fire watch logs by submitting documentation to the licensee that indicated the respective hourly fire watch rounds had been performed. This is material to the NRC because the review of fire watch documents is performed as part of NRCs inspection of the licensees fire protection program (NRC Inspection Procedure 71111.05AQ, "Fire Protection Annual/Quarterly"). Additionally, because the licensee was not aware of the deliberate actions of three contract employees, the licensee failed to implement Procedure OP-MW-201-007 as required by Technical Specification 5.8.1.c.
The inspectors determined that the falsification of fire watch logs did not result in an actual consequence. Because this finding is of very low safety significance and the licensee
- (1) entered the issue into its corrective action program as CR 2014-06416 and CR 2014-06680 and took a number of corrective actions including taking disciplinary actions against the individuals; changing the start times of the fire watch rounds; and, providing additional fire watch training;
- (2) compliance was promptly restored after identification of the issue; and
- (3) the violation was not repetitive as a result of inadequate corrective action. Additionally, although the violation was willful,
- (1) the violation was identified by the licensee and reported to appropriate NRC personnel;
- (2) the violation involved the act of an individual in a low-level position;
- (3) the violation did not involve a lack of management oversight and was the isolated action of the former employees; and
- (4) significant remedial action commensurate with the circumstances was taken by the licensee. Therefore, this violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000285/2015003-002, Failure to Maintain Fire Watch and Fire Watch Logs.
4OA6 Meetings
Exit Meeting Summary
On July 7, 2015, the inspectors discussed the in-office review of the preliminary scenario for the 2015 biennial exercise, submitted June 3, 2015, with Mr. E. Plautz, Manager, Emergency Planning, and other members of the licensee staff. The licensee acknowledged the issues presented.
On August 6, 2015, the inspectors presented the results of the onsite inspection of the biennial emergency preparedness exercise conducted August 4, 2015, to Mr. L. Cortopassi, Site Vice President, 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.
On October 19, 2015, the inspectors presented the inspection results to Mr. L. Cortopassi, 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
- D. Bakalar, Manager, Security
- R. Beck, Manager, Chemistry, Environmental, and Radwaste
- B. Blome, Manager, Regulatory Assurance
- C. Cameron, Principle, Regulatory Specialist
- L. Cortopassi, Site Vice President
- S. Dean, Plant Manager
- S. Fatora, Director, Site Work Management
- M. Frans, Manager, Design and Licensing Basis Reconstitution
- H. Goodman, Director, Site Engineering
- R. Hugenroth, Manager, Nuclear Oversight
- E. Matzke, Senior Licensing Engineer
- T. Parent, Engineering
- E. Plautz, Manager, Emergency Planning
- S. Swanson, Director, Operations
- T. Uehling, Manager, Training
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000285/2015003-001 NCV Failure to Maintain Safety Injection Tank Boron Concentration within Technical Specification Limits (Section 1R15)
- 05000285/2015003-002 NCV Failure to Maintain Fire Watch and Fire Watch Logs (Section 4OA5)