Text

NRC Integrated Inspection Report 05000285/2016004
	ML17018A386
Person / Time
Site:	Fort Calhoun
Issue date:	01/18/2017
From:	Geoffrey Miller; NRC/RGN-IV/DRP/RPB-D
To:	Marik S; Omaha Public Power District
	Geoffrey Miller
References
	IR 2016004
	Download: ML17018A386 (56)
	v • d • e

UNITED STATES ary 18, 2017

SUBJECT:

FORT CALHOUN STATION - NRC INTEGRATED INSPECTION REPORT 05000285/2016004

Dear Mr. Marik:

On December 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fort Calhoun Station. On January 11, 2017, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

Further, inspectors documented three licensee-identified violations, which were determined to be of very low safety significance (Green) or Severity Level IV, in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these 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; and the NRC 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC 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 NRCs 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/

Geoffrey B. Miller, Branch Chief Project Branch D Division of Reactor Projects Docket No. 50-285 License No. DPR-40

Enclosure:

Inspection Report 05000285/2016004 w/ Attachment:

1. Supplemental Information 2. O

REGION IV==

Docket: 50-285 License: DPR-40 Report: 05000285/2016004 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, NE 68008 Dates: October 1 through December 31, 2016 Inspectors: S. Schneider, Senior Resident Inspector P. Voss, Senior Resident Inspector L. Brandt, Acting Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspector S. Hedger, Operations Engineer J. ODonnell, CHP, Health Physicist Approved Geoffrey B. Miller By: Chief, Project Branch D Division of Reactor Projects Enclosure

SUMMARY

IR 05000285/2016004; 10/01/2016 - 12/31/2016; Fort Calhoun Station; Maintenance of

Emergency Preparedness.

The inspection activities described in this report were performed between October 1 and December 31, 2016, by the resident inspectors at Fort Calhoun Station, inspectors from the NRCs Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented in this report three licensee-identified violations of very low safety significance (Green) or Severity Level IV. 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, dated April 29, 2015. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. 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, dated July 2016.

Cornerstone: Emergency Preparedness

Green.

The inspector reviewed a self-revealed non-cited violation associated with Fort Calhoun Stations failure to provide radiological emergency response training to those who may be called upon to assist in an emergency, as required by 10 CFR 50.47(b)(15).

Specifically, in December 2014, 10 shift managers and 6 Technical Support Center and Emergency Operations Facility staff, responsible for making and reviewing protective action recommendations, were not trained on Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and flowchart EP-FC-111-AD-F-02, before they were implemented on December 23, 2014. As immediate corrective actions, the licensee issued a reading package covering the new protective action recommendation process to the 16 individuals who had not been trained. The issue was entered into the licensees corrective action program as Condition Report CR-2015-08951.

The failure to provide radiological emergency response training to those who may be called upon to assist in an emergency is a performance deficiency within the licensees ability to foresee and correct. The performance deficiency was more than minor because it was associated with the procedure quality attribute of Emergency Prepardness Cornerstone and adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015, and was determined to be of very low safety significance (Green) because it was a failure to comply, was not a risk significant planning standard function, was not a loss of the planning standard function, and was a degraded planning standard function. This finding had a cross-cutting aspect in the area of human performance associated with change management because the emergency preparedness department failed to identify all of the emergency response organization staff who required training on revisions to the process for making protective action recommendations [H.3].

(Section 1EP5)

Licensee-Identified Violations

Violations of very low safety significance (Green) or Severity Level IV that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

PLANT STATUS

On October 1, 2016, the Fort Calhoun Station (FCS) was at 97.8 percent power following the commencement of a coastdown on September 29, 2016. On October 24, 2016, FCS completed a final shutdown of the plant to commence a defueling outage in support of the permanent decommissioning of the plant. On November 13, 2016, FCS issued the defueling certification letter to the NRC.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On November 3, 2016, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for cold weather operations and evaluated the licensees implementation of these procedures. The inspectors verified that prior to the onset of cold weather, the licensee had corrected weather-related equipment deficiencies identified during the previous winter.

The inspectors selected three risk-significant systems that were required to be protected from cold weather:

Intake Structure

Raw Water

Control Room Air Conditioning The inspectors reviewed the licensees procedures and design information to ensure the systems would remain functional when challenged by cold 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 cold weather protection features.

These activities 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

Main article: IP 71111.04

Partial Walk-Down

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

October 21, 2016, control room air conditioning and ventilation system

October 23, 2016, raw water system following raw water pump AC-10B in-service test

October 28, 2016, shutdown cooling system

November 18, 2016, component cooling water system following maintenance on component cooling water pump AC-3C

December 2, 2016, spent fuel pool cooling system 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 five partial system walk-down samples, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05

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 five plant areas important to safety:

October 9, 2016, control room, fire area 42

October 9, 2016, cable spreading room, fire area 41

November 1, 2016, containment, fire area 30

November 15, 2016, room 69 ventilation area, fire area 20-7

November 15, 2016, upper electrical penetration room, fire area 34B-1 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 five quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

Main article: IP 71111.11

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On October 18, 2016, the inspectors observed simulator training for an operating crew preparing for the upcoming plant shutdown. The crew performed the planned down power evolution leading into the shutdown while addressing abnormal conditions included by the evaluation staff. Specifically, the crew was evaluated addressing a malfunction with the chemical volume and control system during a boration, as well as a stuck turbine control valve on the main turbine. 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 training.

These activities constituted 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 or risk. The inspectors observed the operators performance of the following activities:

October 19, 2016, operators preparing for quarterly in-service test of raw water pump AC-10B

October 20, 2016, operators completing containment wide range pressure instrument channel and core reactivity surveillance testing and adjusting nitrogen blanket pressure in the component cooling water expansion tank

October 21, 2016, operators responding to a smoke detector alarm and reports of an acrid odor in one of the plant areas

October 24, 2016, downpower maneuvers, manual trip, and post trip actions

October 26, 2016, power operated relief valve low temperature low pressure surveillance test

November 2, 2016, reactor coolant system drain down to lowered inventory

November 4, 2016, reactor coolant system flood-up brief In addition, the inspectors assessed the operators adherence to plant procedures and other operations department policies.

These activities constituted completion of seven quarterly licensed operator performance samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed three 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:

October 12, 2016, planned yellow risk during emergency diesel generator 1 testing

October 26, 2016, planned yellow risk for power operated relief valve low temperature low pressure surveillance test

November 4, 2016, planned yellow risk for heavy load lift over the reactor vessel 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 constituted completion of three maintenance risk assessment inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed three operability determinations and functionality assessments that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs):

October 4, 2016, operability determination of MasterPact breaker fail to close technical bulletin and impact on Fort Calhoun Station breakers

November 22, 2016, functionality assessment of Allen-Bradley 700 RTC relay susceptibility to electromagnetic interference and radio frequency interference

December 2, 2016, functionality assessment of component cooling water surge tank pressure and level control in manual versus automatic 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 constituted completion of three operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected risk-significant SSCs:

October 7, 2016, penetration M-45 Type C local leak rate post-maintenance test

October 20, 2016, control room air conditioning and air filtration system post-maintenance test

November 17, 2016, component cooling water pump AC-3C post-maintenance test

December 14, 2016, raw water system strainer AC-12B post-maintenance test 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 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 constituted completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

Main article: IP 71111.20

a. Inspection Scope

During the stations defueling outage that concluded on November 11, 2016, 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 plan prior to the outage

Review and verification of the licensees fatigue management activities

Monitoring of shutdown and cooldown activities

Verification that the licensee maintained defense-in-depth during outage activities

Observation and review of reduced-inventory activities

Observation and review of fuel handling activities These activities constituted completion of one defueling outage sample, as defined in Inspection Procedure 71111.20.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors observed seven risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:

In-service tests:

October 13, 2016, raw water system Category C valve in-service test

October 25, 2016, raw water pump AC-10B in-service test Other surveillance tests:

October 13, 2016, reactor coolant system flow rate determination by heat balance

October 14, 2016, auxiliary feedwater pump FW-6 surveillance test

October 20, 2016, emergency diesel generator 2 surveillance test

October 26, 2016, power operated relief valve low temperature low pressure surveillance test

November 3, 2016, personnel access lock o-ring seal surveillance test 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 constituted completion of seven surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP2 Alert and Notification System Testing

Main article: IP 71114.02

a. Inspection Scope

The inspector verified the adequacy of the licensees methods for testing the primary and backup alert and notification system (ANS). The inspector interviewed licensee personnel responsible for the maintenance of the primary and backup ANS and reviewed a sample of corrective action system reports written for ANS problems. The inspector compared the licensees alert and notification system testing program with criteria in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1; FEMA Report REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants; and the licensees current FEMA-approved alert and notification system design report, Updated Design Report to FEMA for the Outdoor Public Warning System and Backup Alert and Notification, as approved in a letter from Mr. R. McCabe, Chief, Technological Hazards Branch, FEMA Region VII, dated December 17, 2012.

These activities constituted completion of one alert and notification system evaluation sample, as defined in Inspection Procedure 71114.02.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Staffing and Augmentation System

Main article: IP 71114.03

a. Inspection Scope

The inspector verified that the licensees emergency response organization on-shift and augmentation staffing levels were in accordance with the licensees emergency plan commitments. The inspector reviewed documentation and discussed with licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to verify the adequacy of the licensees methods for staffing emergency response facilities, including the licensees ability to staff pre-planned alternate facilities.

The inspector also reviewed records of emergency response organization augmentation tests and events to determine whether the licensee had maintained a capability to staff emergency response facilities within emergency plan timeliness commitments.

These activities constituted completion of one emergency response organization staffing and augmentation testing sample, as defined in Inspection Procedure 71114.03.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

Main article: IP 71114.04

a. Inspection Scope

The inspector performed an on-site review of the Fort Calhoun Radiological Emergency Response Plan, Sections A, B, F, G, H, J, K, and O, and Appendix A, Revision 0; Procedure EP-FC-110-200, Dose Assessment, Revision 0; and EP-FC-1001, Addendum 3, Emergency Action Levels, Revision 2. These revisions:

Removed references to the security department staffing the fire brigade

Removed references to the Blair Industrial Park Co-op phone

Replaced references to Stone and Webster Engineering Corporation with Tierney-Blair LLC

Replaced references to the Fremont fire department with references to the Elkhorn Decontamination Center

Added making initial notifications to the NRC to the shift technical advisors duties

Added satellite phones as required communication systems

Reassigned the maintenance and replacement of radiation protection equipment inventories from emergency planning to the radiation protection department

Revised the frequency of CPR training

Implemented the utility revision of the Radiological Assessment System for Consequence Analysis (RASCAL) dose assessment program

Revised external radiation levels in emergency action level E-HU1

Revised procedure titles and procedure numbers throughout the document These revisions were compared to their previous revisions; 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; to NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6, dated November 2012; 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 revisions 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, these revisions are subject to future inspection.

These activities constituted completion of three emergency action level and emergency plan changes samples, as defined in Inspection Procedure 71114.04.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness

Main article: IP 71114.05

a. Inspection Scope

The inspector reviewed the following for the period November 2014 through November 2016:

After-action reports for emergency classifications

After-action evaluation reports for licensee drills and exercises

Independent audits and surveillances of the licensees emergency preparedness program

Self-assessments of the emergency preparedness program conducted by the licensee

Licensee evaluations of changes made to the Emergency Plan and Emergency Plan Implementing Procedures

Drill and exercise performance issues entered into the licensees corrective action program

Emergency preparedness program issues entered into the licensees corrective action program

Maintenance records for equipment supporting the emergency preparedness program

Emergency response organization and emergency planner training records The inspector reviewed summaries of 356 corrective action program reports associated with emergency preparedness and selected 15 to review against program requirements, to determine the licensees ability to identify, evaluate, and correct problems in accordance with the requirements of planning standard 10 CFR 50.47(b)(14) and 10 CFR Part 50, Appendix E, Section IV.F. The inspector verified that the licensee accurately and appropriately identified and corrected emergency preparedness weaknesses during critiques and assessments.

The inspector reviewed summaries of 30 licensee evaluations of the impact of changes to the emergency plan and implementing procedures, and selected five to review against program requirements to determine the licensees ability to identify reductions in the effectiveness of the emergency plan, in accordance with the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that evaluations of proposed changes to the licensee emergency plan appropriately identified the impact of the changes prior to being implemented.

These activities constituted completion of one sample of the maintenance of the licensees emergency preparedness program, as defined in Inspection Procedure 71114.05.

b. Findings

Introduction.

The inspector reviewed a self-revealed, Green, non-cited violation associated with Fort Calhoun Stations failure to provide radiological emergency response training to those who may be called upon to assist in an emergency, as required by 10 CFR 50.47(b)(15). Specifically, in December 2014, 10 shift managers and 6 Technical Support Center and Emergency Operations Facility staff members, responsible for making and reviewing protective action recommendations, were not trained on Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and flowchart EP-FC-111-AD-F-02, before they were implemented on December 23, 2014.

Description.

Fort Calhoun Station implemented Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and associated flowchart EP-FC-111-AD-F-02 on December 23, 2014 (ML15023A126). The emergency preparedness department had previously determined that training on the procedure revision was required for emergency response organization personnel responsible for making or reviewing protective action recommendations made to offsite authorities for protecting the health and safety of the public. Emergency preparedness staff conducted two classroom training sessions for Technical Support Center and Emergency Operations Facility staff prior to implementing the procedure change, training 23 persons. The emergency preparedness department did not verify that all required individuals attended the training.

Subsequent to implementing Procedure EPIP-EOF-7, Revision 26, a senior reactor operator failed to correctly make a protective action recommendation during routine licensed operator training in the control room simulator. Following the operators failure to correctly recommend protective actions, the licensee determined that six Technical Support Center and Emergency Operations Facility staff failed to attend the training on Procedure EPIP-EOF-7, and therefore, lacked training before the procedure was implemented. In addition, the licensee determined the emergency preparedness staff relied on the routine licensed operator training program to train the shift managers on the revised procedure. As a result, none of the licensees 10 shift managers (on-shift emergency coordinators) received the training. The licensee entered this issue into their corrective action program as Condition Report CR-2015-08951. As immediate corrective action, the licensee issued a reading package covering the new protective action recommendation process to the 16 individuals who had not been trained.

Analysis.

The failure to provide radiological emergency response training to those who may be called upon to assist in an emergency is a performance deficiency within the licensees ability to foresee and correct. The performance deficiency was more than minor because it was associated with the procedure quality attribute of Emergency Prepardness Cornerstone and adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, personnel unfamiliar with procedures for making protective action recommendations may not make accurate or timely recommendations to protect the health and safety of the public. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015, and was determined to be of very low safety significance (Green) because it was a failure to comply, was not a risk significant planning standard function, was not a loss of the planning standard function, and was a degraded planning standard function. The planning standard function was degraded because training was only provided to 23 of 39 individuals requiring training. This finding had a cross-cutting aspect in the area of human performance associated with change management because the emergency preparedness department failed to do a thorough analysis of the emergency response organization staff who were required to be trained on revisions to the process for making protective action recommendations to offsite authorities [H.3].

Enforcement.

Title 10 CFR 50.47(b)(15), requires that radiological emergency response training is provided to those who may be called upon to assist in an emergency.

Contrary to above, on December 23, 2014, Fort Calhoun Station failed to provide radiological emergency response training to those who may be called upon to assist in an emergency. Specifically, the licensee failed to provide training to 16 emergency response organization staff on Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and associated flowchart EP-FC-111-AD-F-02. The licensee restored compliance by issuing a reading package covering the new protective action recommendation process to the 16 persons who had not been trained in December 2014 and verified that each person reviewed the package. Because this violation is of very low safety significance (Green) and was entered into the licensees corrective action program as Condition Report CR-2015-08951, this violation is being treated as a non-cited violation in accordance with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000285/2016004-01, Failure to Provide Training on Changes to Protective Action Recommendation Procedures)

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS2 Occupational ALARA Planning and Controls

Main article: IP 71124.02

a. Inspection Scope

The inspector assessed licensee performance with respect to maintaining individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspector performed this portion of the attachment during the defueling outage in order to directly observe the licensees ALARA process activities, including planning, implementation of radiological work controls, execution of work activities, and ALARA review of work-in-progress. During the inspection, the inspector interviewed licensee personnel, reviewed licensee documents, and evaluated licensee performance in the following areas:

Implementation of ALARA and radiological work controls. The inspector observed pre-job briefings, reviewed planned radiological administrative, operational, and engineering controls, and compared the planned controls to field activities.

Radiation worker and radiation protection technician performance during work activities performed in radiation areas, airborne radioactivity areas, or high radiation areas.

Problem identification and resolution for ALARA and radiological work controls.

The inspector reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constituted completion of two of the five required samples of the occupational ALARA planning and controls program, as defined in Inspection Procedure 71124.02.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

Main article: IP 71124.03

a. Inspection Scope

The inspector evaluated whether the licensee controlled in-plant airborne radioactivity concentrations consistent with ALARA principles and that the use of respiratory protection devices did not pose an undue risk to the wearer. During the inspection, the inspector interviewed licensee personnel, walked down various areas in the plant, and reviewed licensee performance in the following areas:

Engineering controls, including the use of permanent ventilation systems to control airborne radioactivity. The inspector evaluated installed ventilation systems, including review of procedural guidance, verified the systems were used during high-risk activities, and verified airflow capacity, flow path, and filter/charcoal unit efficiencies. Additionally, the inspector evaluated the licensees airborne monitoring protocols, including verification that alarms and set points were appropriate.

Use of respiratory protection devices, including an evaluation of the licensees respiratory protection program for use, storage, maintenance, and quality assurance of National Institute for Occupational Safety and Health (NIOSH)certified equipment, air quality and quantity for supplied-air devices and self-contained breathing apparatus (SCBA) bottles, qualification and training of personnel, and user performance.

Self-contained breathing apparatus for emergency use, including the licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, hydrostatic testing of SCBA bottles, status of SCBA staged and ready for use in the plant including vision correction, mask sizes, etc., SCBA surveillance and maintenance records, and personnel qualification, training, and readiness.

Problem identification and resolution for airborne radioactivity control and mitigation. The inspector reviewed audits, self-assessments, and corrective action documents to verify problems were being identified and properly addressed for resolution.

These activities constituted completion of the four required samples of the in-plant airborne radioactivity control and mitigation program, as defined in Inspection Procedure 71124.03.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

Main article: IP 71124.04

a. Inspection Scope

The inspector 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 inspector interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:

Source term characterization, including characterization of radiation types and energies, hard-to-detect isotopes, and scaling factors.

External dosimetry including National Voluntary Laboratory Accreditation Program (NVLAP) accreditation, storage, issue, use, and processing of active and passive dosimeters.

Internal dosimetry, including the licensees use of whole body counting and dose assessments based on airborne monitoring.

Special dosimetry situations, including declared pregnant workers, dosimeter placement, and neutron dose assessment.

Problem identification and resolution for occupational dose assessment. The inspector reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constituted completion of the five required samples of the occupational dose assessment program, as defined in Inspection Procedure 71124.04.

b. Findings

No findings were identified.

The inspector reviewed the licensees records of alert and notification system tests conducted between April 2015 and September 2016 to verify the accuracy of the licensees data for siren system testing opportunities. The inspector reviewed procedural guidance on assessing alert and notification system opportunities and the results of periodic alert and notification system operability tests. The inspector 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.

4OA2 Problem Identification and Resolution

Main article: IP 71152

.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 Semiannual Trend Review

a. Inspection Scope

The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends.

These activities constituted completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.

b. Observations and Assessments In NRC Inspection Report 05000285/2016002, the inspectors documented a continuing adverse trend in equipment reliability at Fort Calhoun Station. The inspectors reviewed equipment reliability challenges in 2016 through the fourth quarter. These challenges resulted in equipment unavailability, unplanned technical specification entries, and operator burdens. Examples of equipment reliability issues during 2016 included a chemical and volume control system leak in January, a component cooling water pump motor failure in February, and a high pressure safety injection pump suction valve weld failure in March. In 2016, the licensee continued to reduce backlogs in open operability determinations and temporary configuration changes. In addition, the licensees plant health committee continued to focus on their Top 10 equipment list to resolve critical items. The inspectors have determined that the licensees progress in improving equipment reliability at the Fort Calhoun Station is sufficient to warrant closure of this trend.

c. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

The licensee reported this issue at the time of the event under 10 CFR 50.72(b)(2)(iv)(B)as a 4-hour report for an RPS actuation while the reactor was critical, and under 50.72(b)(3)(iv)(A) as an 8-hour report for a valid specified system actuation (RPS). In addition, on August 22, 2016, the licensee reported the event under 10 CFR 50.73(a)(2)(iv)(A), as a licensee event report (LER) for a valid specified system actuation (RPS). The inspectors reviewed the root cause evaluation, the corrective actions, and the LER for the event to determine whether the causal analysis was thorough, the corrective actions appropriately addressed the condition and causes, and the appropriate NRC reporting requirements were met.

This LER is closed.

b. Findings

One finding associated with this event was previously documented in the second quarter resident inspector NRC Integrated Inspection Report (05000285/2016002-02, Failure to Develop Adequate Procedures for Post-Modification Testing). No additional findings were identified.

.4 (Closed) Licensee Event Report 05000285/2016-004-00, Unanalyzed Condition for

Potential Tornado-Borne Missile Impact to the Raw Water System

a. Inspection Scope

On August 25, 2016, the licensee identified that a tornado missile strike on diesel-driven fire water pump FP-1B or associated piping had not been addressed during the 2013 tornado missile project. As such, a missile strike affecting pump FP-1B or its associated piping could cause a larger volume of water to enter the raw water pump vault than had previously been analyzed. An operability evaluation was conducted and compensatory measures were implemented to disable pump FP-1B and isolate associated piping upon entering a severe thunderstorm or tornado watch per their Abnormal Operating Procedure AOP-01, Acts of Nature.

The NRC inspectors reviewed the details of this condition including corrective actions and compensatory measures implemented to maintain operability. Based on review of the condition, the inspectors determined that the licensee was previously ineffective in implementing corrective actions to address all missile hazards that could impact safety-related equipment when this was originally identified as a concern in 2013.

Specifically, the vulnerability to a missile strike upon pump FP-1B and associated piping was discussed during the 2013 tornado missile project. However, the postulated tornado missile strike on the intake structure which impacts the pump and associated piping was not addressed nor were corrective actions taken to protect the raw water pump vault at that time.

This LER is closed.

b. Findings

This violation was identified by the licensee and is discussed in further detail in Section 4OA7 of this report.

These activities constituted completion of four event follow-up samples, as defined in Inspection Procedure 71153.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On November 10, 2016, the inspector presented the radiation safety inspection results to Mr. T. Tierney, 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 inspector had been returned or destroyed.

On December 2, 2016, the inspector presented the results of the onsite inspection of the licensees emergency preparedness program to Mr. S. Marik, Vice President and Chief Nuclear Officer, 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 January 11, 2017, the inspectors presented the inspection results to Mr. S. Marik, Vice President and Chief Nuclear Officer, 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.

4OA7 Licensee-Identified Violations

The following licensee-identified violations of NRC requirements were determined to be of very low safety significance (Green) or Severity Level IV and meet the NRC Enforcement Policy criteria for being dispositioned as non-cited violations:

Technical Specification 2.0.1 requires the unit to be shut down within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in the event a limiting condition for operation and/or associated action requirement cannot be satisfied because of circumstances in excess of those addressed in the specification.

Contrary to the above, the licensee failed to enter Technical Specification 2.0.1 and take the prescribed actions on several occasions when shutdown cooling heat exchanger valves were opened which impacted component cooling water (CCW) flow to the containment air cooling units under certain accident conditions.

On May 10, 2016, an unanalyzed condition was discovered during scheduled maintenance on the shutdown cooling heat exchanger valves. As part of the maintenance, HCV-484, Shutdown Heat Exchanger AC-4A Component Cooling Water Outlet Valve, and HCV-481, Shutdown Cooling Heat Exchanger AC-4B Component Cooling Water Inlet Valve, were failed open which rendered both valves inoperable.

Under these conditions, with the assumed single failure loss of DC control power during a loss of coolant accident (LOCA), CCW would be allowed to flow through both shutdown cooling heat exchangers, effectively reducing CCW system flow to the containment air cooling units. These conditions are not assumed under plant design basis calculations and placed the plant in an unanalyzed condition. It has not been demonstrated that the CCW system would adequately perform its design function of providing a cooling medium for the containment atmosphere under LOCA conditions with CCW flow diverted through the shutdown cooling heat exchangers. With two containment air cooling units inoperable, Technical Specification 2.4, does not provide an associated action; therefore, Technical Specification 2.0.1 applies. Upon completion of the maintenance activity, both valves were returned to service which eliminated the condition. The licensee conducted an extent of condition review and identified that they had created this unanalyzed condition six times within the last 3 years and had exceeded the Technical Specification 2.0.1 6-hour shutdown action statement on March 8, 2016; April 21, 2016; and May 10, 2016. In addition, the licensee determined this condition was first identified on February 3, 2015, in Condition Report 2015-01388.

Procedure TDB-VIII, Equipment Applicability Guidance, Revision 64, incorrectly stated the valves had a required safety function in the open direction. The licensee initiated procedure change EC-68088 on September 26, 2015, to correct the procedure; however, the proposed change did not accurately reflect the safety function of the valves to remain closed for all LOCA conditions. This procedure change was still under review on May 10, 2016. The failure to promptly correct Procedure TDB-VIII was a contributing cause of the violation.

The violation is more than minor because it is associated with the configuration control attribute of the Mitigating Systems Cornerstone. On March 8, 2016; April 21, 2016; and May 10, 2016, the plant was placed in a condition prohibited by technical specifications and exceeded the Technical Specification 2.0.1, 6-hour shutdown action statement.

This adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. A senior reactor analyst qualitatively determined that this finding was of very low safety significance (Green) for increases in core damage frequency and large early release frequency because of the short exposure time of less than 3 days and because of the low frequency of events where a LOCA with an independent and coincidental loss of DC control power would occur. Therefore, this finding screens to Green. The licensee entered the issue into their corrective action program as Condition Reports 2016-05340 and 2016-04468.

Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, though the licensee identified a potential vulnerability to raw water pumps from a missile hazard striking diesel driven fire pump FP-1B or associated piping during review of missile hazards during the 2013 tornado missile project, the licensee failed to evaluate this condition or specify a modification to the plant to protect the raw water pumps at that time. This was discovered on August 25, 2016, by the licensee during a design review. This finding is of very low safety significance (Green) considering compensatory measures that were put in place to disable pump FP-1B and isolate associated piping when severe weather is forecast and the very low probability of the postulated event. This issue was entered into the licensees corrective action program as CR 2016-06972.

Title 10 of the Code of Federal Regulations, Part 50.9(a), requires that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on December 26, 2014, Fort Calhoun Station provided information to the Commission which was not complete and accurate in all material respects. Specifically, a license amendment request (ML14365A123) to adopt a scheme of emergency action levels based on Nuclear Energy Institute Document 99-02, Revision 6, contained inaccurate information about the characteristics of the cask used in the licensees Independent Spent Fuel Storage Installation and, as a result, incorrect external radiation levels were incorporated into emergency action level E-HU1.

Subsequently, while preparing another emergency action level submittal, the emergency preparedness staff discovered the incorrect information that had previously been submitted. The issue was determined to be a Severity Level IV violation of NRC requirements, in accordance with Section 6.9 of the Enforcement Policy, dated November 1, 2016, because the inaccurate information would not have caused the NRC to reconsider a regulatory position or undertake substantial further inquiry. The issue was documented in the licensees corrective action program as Condition Report CR-2016-08400. Because the Severity Level IV violation has been entered into the licensees corrective action program, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

C. Beck, Director, Training, (Acting)

R. Beck, Manager Chemistry, Environmental, and Radwaste

B. Blome, Manager, Regulatory Assurance

E. Breault, Supervisor, Radiation Protection

D. Brehm, Supervisor, Radiation Protection

C. Cameron, Principal Regulatory Specialist, Licensing

J. Cate, Manager, Engineering Projects

H. Childs, Manager, Security

B. Currier, Director, Site Engineering

S. Dixon, Respiratory Specialist, Radiation Protection

A. Hansen, Licensing Engineer

R. Hugenroth, Manager, Nuclear Oversight

T. Leaf, Director, Operations

D. Little, Dosimetry Specialist, Radiation Protection

S. Marik, Vice President and Chief Nuclear Officer

E. Matzke, Senior Licensing Engineer

J. Mise, Engineer, Systems Engineering

J. Musser, Superintendent, Operations

B. Pearson, Supervisor, Radiation Protection

E. Plautz, Manager, Emergency Planning

J. Shuck, Manager, Systems Engineering

N. Thompson, Engineer, System Engineering

T. Tierney, Plant Manager

T. Uehling, Plant Manager, Decommissioning

C. Verdoni, Operation Training

B. Ward, Nuclear Engineer, Rapid Response

D. Weaver, Director, Work Management

D. Whisler, Manager, Radiation Protection

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

Failure to Provide Training on Changes to Protective Action

05000285/2016004-01 NCV Recommendation Procedures (Section 1EP5)

Closed

Unanalyzed Condition Shutdown Heat Exchanger Isolations

05000285/2016002-00 LER (Section 4OA3)

Unanalyzed Condition Shutdown Heat Exchanger Isolations

05000285/2016002-01 LER (Section 4OA3)

Unplanned Turbine Trip during DCS Modification due to Failure

05000285/2016003-00 LER to Identify and Disable the Transmitter Deviation Based Trip (Section 4OA3)

Unanalyzed Condition for Potential Tornado-Borne Missile

05000285/2016004-00 LER Impact to the Raw Water System (Section 4OA3)

LIST OF DOCUMENTS REVIEWED