ML093170424
| ML093170424 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/13/2009 |
| From: | Clark J NRC/RGN-IV/DRP/RPB-E |
| To: | Bannister D Omaha Public Power District |
| References | |
| IR-09-001, IR-09-004 | |
| Download: ML093170424 (52) | |
See also: IR 05000285/2009004
Text
UNITED STATES
NUC LE AR RE G UL AT O RY C O M M I S S I O N
R E GI ON I V
612 EAST LAMAR BLVD , SU I TE 400
AR LI N GTON , TEXAS 76011-4125
November 13, 2009
David J. Bannister, Vice President
and Chief Nuclear Officer
Omaha Public Power District
Fort Calhoun Station FC-2-4
P. O. Box 550
Fort Calhoun, NE 68023-0550
Subject: FORT CALHOUN STATION NRC INTEGRATED INSPECTION REPORT
05000285/2009004 and 072000054/2009001
Dear Mr. Bannister:
On September 30, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Fort Calhoun Station. The enclosed integrated inspection report documents
the inspection findings, which were discussed on October 7, 2009, with Jeff Reinhart, Site Vice
President, and other members of your staff.
The inspections examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
This report documents one NRC-identified finding, and two self-revealing findings of very low
safety significance (Green), and one NRC-identified Severity Level IV violation. Three of these
findings were determined to involve violations of NRC requirements. If you contest these
violations or the significance of the noncited violations, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with
copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E.
Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident
Inspector at the Fort Calhoun facility. In addition, if you disagree with the characterization of any
finding 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 Fort Calhoun. The information you provide will be considered in
accordance with Inspection Manual Chapter 0305.
Omaha Public Power District -2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its
enclosure, will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records component of NRCs document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room).
Sincerely,
/RA/
Jeffrey A. Clark, P.E.
Chief, Project Branch E
Division of Reactor Projects
Docket: 50-285
License: DPR-40
Enclosure:
NRC Inspection Report 05000285/200904 and 072000054/2009001
w/Attachment: Supplemental Information
cc w/Enclosure:
Jeffrey A. Reinhart
Site Vice President
Omaha Public Power District
Fort Calhoun Station FC-2-4 Adm
P.O. Box 550
Fort Calhoun, NE 68023-0550
Mr. Thomas C. Matthews
Manager - Nuclear Licensing
Omaha Public Power District
Fort Calhoun Station FC-2-4 Adm.
P.O. Box 550
Fort Calhoun, NE 68023-0550
Winston & Strawn
Attn: David A. Repke, Esq.
1700 K Street, NW
Washington, DC 20006-3817
Chairman
Washington County Board of Supervisors
P.O. Box 466
Blair, NE 68008
Omaha Public Power District -3-
Ms. Julia Schmitt, Manager
Radiation Control Program
Nebraska Health & Human Services R & L
Public Health Assurance
301 Centennial Mall, South
P.O. Box 95007
Lincoln, NE 68509-5007
Ms. Melanie Rasmussen
Radiation Control Program Officer
Bureau of Radiological Health
Iowa Department of Public Health
Lucas State Office Building, 5th Floor
321 East 12th Street
Des Moines, IA 50319
Chief, Technological Hazards Branch
FEMA, Region VII
9221 Ward Parkway
Suite 300
Kansas City, MO 64114-3372
Omaha Public Power District -4-
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Chuck.Casto@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRP Deputy Director (Anton.Vegel@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (John.Kirkland@nrc.gov)
Resident Inspector (Jacob.Wingebach@nrc.gov
Branch Chief, DRP/E (Jeff.Clark@nrc.gov)
Senior Project Engineer, DRP/E (Ray.Azua@nrc.gov)
FCS Site Secretary (Berni.Madison@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Team Leader, TSS (Chuck.Paulk@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
W. A. Maier, RSLO (Bill.Maier@nrc.gov)
R. E. Kahler, NSIR (Robert.Kahler@nrc.gov)
OEDO RIV Coordinator (Leigh.Trocine@nrc.gov)
ROPreports (ROPreorts.Resource@nrc.gov)
OEMail Resource (OEMAIL.Resource@nrc.gov)
File located: R:\_REACTORS\_FCS\2009\FC 2009-04 RP-JCK.doc ML 093170424
SUNSI Rev Compl. : Yes No ADAMS : Yes No Reviewer Initials
Publicly Avail : Yes No Sensitive Yes : No Sens. Type Initials
PE:DRP/E SRI:DRP/E SPE:DRP/E RIV:SRI:DNMS C:DRS/EB2
WSchaup JKirkland RAzua LMWilloughby NFOKeefe
/RA - E/ /RA/via Email /RA/ /RA - E/ /RA/
11/09/09 10/16/09 10/07/09 11/09/09 11/09/09
C:DRS/OB C:DRS/PSB1 C:DRS/PSB2 C:DRP/E
RELantz MPShannon GEWerner JAClark
/RA/ /RA/ /RA/ /RA/
11/10/09 11/12/09 11/09/09 11/13/09
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 50-285
License: DPR-40
Report: 05000285/2009004 and 072000054/2009001
Licensee: Omaha Public Power District
Facility: Fort Calhoun Station
Location: Fort Calhoun Station FC-2-4 Adm.
P.O. Box 399, Highway 75 - North of Fort Calhoun
Fort Calhoun, Nebraska
Dates: July 1 through September 30, 2009
Inspectors: J. Kirkland, Senior Resident Inspector
W. Schaup, Project Engineer
P. Elkman, Senior Emergency Preparedness Inspector
C. Osterholtz, Senior Operations Engineer
G. Guerra, CHP, Emergency Preparedness Inspector
L. Willoughby, Senior Resident Yucca Mountain Project
L. Brookhart, Project Engineer
Approved By: Jeff A. Clark, Chief, Project Branch E
Division of Reactor Projects
-1- Enclosure
SUMMARY OF FINDINGS
IR 05000285/2009004 and 072000054/2009001; 07/01/2009 - 09/30/2009; Fort Calhoun
Station, Integrated Resident and Regional Report, and Emergency Plan Biennial Exercise
Evaluation.
The report covered a three-month period of inspection by resident inspectors and an announced
baseline inspections by a regional based inspectors. The significance of most findings is
indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609,
Significance Determination Process. Findings for which the significance determination
process does not apply may be Green or be assigned a severity level after NRC management
review. The NRC's program for overseeing the safe operation of commercial nuclear power
reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated
December 2006.
A. NRC-Identified Findings and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green. A self-revealing, Green noncited violation of Technical Specification 5.8.1.a (Procedures) was identified for failure to provide an adequate
maintenance work instruction. While performing maintenance on the motor, the
HPSI Header - Charging Header Crosstie Valve, HCV-308, the maintenance
work instruction failed to ensure that the HPSI Alternate Header Isolation Valve,
HCV-2987, was closed, resulting in unexpected pressurization of the Number 2
The failure to provide an adequate maintenance work instruction was a
performance deficiency. This finding was greater than minor because the finding
was associated with the Mitigating Systems Cornerstone objective (procedure
quality attribute) to ensure the availability, reliability, and capability of systems
that respond to initiating events to prevent undesirable consequences. Using
Manual Chapter 0609, Appendix A, Determining the Significance of Reactor
Inspection Findings for At-Power Situations, Phase 1 screening worksheet, the
inspectors determined that the finding was of very low safety significance (Green)
because it was not: (1) a design or qualification deficiency; (2) a loss of system
safety function; (3) an actual loss of safety function for greater than its technical
specification allowed outage time; (4) a loss of safety function of a nontechnical
specification train; or (5) a seismic, flooding or severe weather related finding.
There is no crosscutting aspect associated with this finding since the root cause
of the performance deficiency was not indicative of current plant performance.
(Section 4OA2)
- Severity Level IV. The NRC identified a Severity Level IV noncited violation of
10 CFR Part 21.21(a), Notification of failure to comply or existence of a defect
and its evaluation for the licensees failure to adopt appropriate procedures to
evaluate deviations and failures to comply associated with substantial safety
hazards. Specifically, the procedure fails to adequately assess the extent of
deviations, which are discovered, and the potential impact on other components
-2- Enclosure
either installed in the plant or stored in the warehouse. Additionally, the procedure
failed to adequately evaluate defects in components, which have never been
installed or used in the nuclear plant.
The inspectors determined that the failure to adopt appropriate procedures to
evaluate deviations and failures to comply associated with substantial safety
hazards was a performance deficiency. This finding was more than minor
because if the procedure were left uncorrected it could become a more serious
safety concern. Specifically, failure to notify the vendor upon discovery of a
deviation does not allow for adequate evaluation of other components that could
be subject to the deviation. Additionally, components with deviations could be
located in the licensees warehouse and subsequently installed in the plant
without the licensees knowledge, potentially creating a substantial safety hazard.
Because this issue affected a potential reporting requirement and NRCs ability
to perform its regulatory function, it was evaluated with the traditional
enforcement process. Consistent with the guidance in Section IV.A.3 and
Supplement VII paragraph D.4 of the NRC Enforcement Policy, this violation was
categorized at Severity Level IV noncited violation. There is no crosscutting
aspect associated with this finding because it is not indicative of current
performance in that the procedure is many years old. (Section 4OA3)
Cornerstone: Barrier Integrity
- Green. The inspectors identified a finding of having very low safety significance
(Green) for failure to perform checks at the beginning of each shift on the main
hoist limit switches of the refueling area crane (HE - 2) in the spent fuel pool
area as specified in ANSI B30.2 - 1976, Overhead and Gantry Cranes, section
2-2.1.2 Frequent Inspections a.2, prior to using the crane to perform dry fuel
storage activities on June 29, 2009.
The failure to perform checks on the main hoist limit switches at the beginning of
each work shift is a performance deficiency because the dry cask personnel
used the crane to perform dry cask storage operations to lift items over the spent
fuel pool without performing the required checks per shift change. The
inspectors determined that the performance deficiency was more than minor in
accordance with Inspection Manual Chapter 0612, Appendix B, Issue
Screening, minor question 2 because if left uncorrected the performance
deficiency could lead to a more significant safety issue. Specifically, the main
hoist limit switches are installed to limit the main hoist travel and to prevent a two
blocking event. Preventing two blocking events ensures safe load handling of
heavy loads over the spent fuel pool. Using the NRC Manual Chapter 0609,
Phase 1 screening worksheet under the Barrier Cornerstone for spent fuel pool
issues, the finding screened as having very low safety significance because it did
not result in loss of cooling to the spent fuel pool, did not cause damage to the
fuel cladding or result in dropped fuel assembly or result in a loss of spent fuel
pool volume of greater than 10 percent. The finding had a crosscutting aspect in
human performance because the licensee failed to provide a complete and
accurate procedure to assure nuclear safety [H.2 (c)]. (Section 1R15)
-3- Enclosure
- Green. A self-revealing Green noncited violation (NCV) of 10 CFR 50,
Appendix B, Criterion V, was identified for the failure of personnel to follow an
auxiliary building crane operating procedure. This resulted in the crane
contacting the fuel handling bridge and moving it approximately eight feet.
The failure to follow the prerequisites of the auxiliary building crane operating
procedure is a performance deficiency. The finding is greater than minor
because it would become a more significant safety concern if left uncorrected in
that a collision with the fuel handling bridge could cause damage such that
pieces of the mast could fall into the spent fuel pool and damage the spent fuel.
Using the NRC Manual Chapter 0609, Phase 1 screening worksheet under the
Barrier Integrity Cornerstone for spent fuel pool issues, the finding screened as
having very low safety significance because it did not result in loss of cooling to
the spent fuel pool, did not cause damage to the fuel cladding or result in
dropped fuel assembly or result in a loss of spent fuel pool volume of greater
than 10 percent. This finding has a crosscutting aspect in the area of human
performance associated with work practices because personnel failed to use
human error prevention techniques commensurate with the risk of the assigned
task, such that work activities were performed safely [H.4.(a)]. (Section 4OA2)
B. Licensee-Identified Violations
None
-4- Enclosure
REPORT DETAILS
Summary of Plant Status
The unit began this inspection period in Mode 1 at full rated thermal power and operated at
approximately 100 percent until July 24, 2009, when reactor power was reduced to 98 percent
for Moderator Temperature Coefficient Testing. Reactor power was returned to 100 percent
power on July 27, 2009, where it remained for the remainder of the inspection period.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R01 Adverse Weather Protection (71111.01)
.1 Summer Readiness for Offsite and Alternate AC Power
a. Inspection Scope
The inspectors performed a review of the licensees preparations for summer weather for
selected systems, including conditions that could lead to loss-of-offsite power and
conditions that could result from high temperatures. The inspectors reviewed the
licensees procedures affecting these areas and the communications protocols between
the transmission system operator and the plant to verify that the appropriate information
was being exchanged when issues arose that could affect the offsite power system.
Examples of aspects that were considered in the inspectors review included:
- The coordination between the transmission system operator and the plant
during off-normal or emergency events
- The explanations for the events
- The estimates of when the offsite power system would be returned to a
normal state
- The notifications from the transmission system operator to the plant when
the offsite power system was returned to normal
During the inspection, the inspectors focused on plant-specific design features and the
licensees procedures used to mitigate or respond to adverse weather conditions.
Additionally, the inspectors reviewed the Updated Safety Analysis Report and
performance requirements for systems selected for inspection, and verified that operator
actions were appropriate as specified by plant-specific procedures. Specific documents
reviewed during this inspection are listed in the attachment. The inspectors also
reviewed corrective action program items to verify that the licensee was identifying
adverse weather issues at an appropriate threshold and entering them into their
-5- Enclosure
corrective action program in accordance with station corrective action procedures. The
inspectors reviews focused specifically on the following plant systems:
- Raw Water System
- Auxiliary Feedwater System
These activities constitute completion of one readiness for summer weather affect on offsite
and alternate ac power sample as defined in Inspection Procedure 71111.01-05.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignments (71111.04)
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant
systems:
- August 10, 2009, Shutdown Cooling Heat Exchangers
- August 26, 2009, Auxiliary Feedwater System associated with the Turbine-
Driven Auxiliary Feedwater Pump, FW-10
- September 21, 2009, Compressed Air and Instrument Air Systems
The inspectors selected these systems based on their risk significance relative to the
reactor safety cornerstones at the time they were inspected. The inspectors attempted
to identify any discrepancies that could affect the function of the system, and, therefore,
potentially increase risk. The inspectors reviewed applicable operating procedures,
system diagrams, Updated Final Safety Analysis Report, technical specification
requirements, administrative technical specifications, outstanding work orders, condition
reports, and the impact of ongoing work activities on redundant trains of equipment in
order to identify conditions that could have rendered the systems incapable of
performing their intended functions. The inspectors also walked down accessible
portions of the systems to verify system components and support equipment were
aligned correctly and operable. The inspectors examined the material condition of the
components and observed operating parameters of equipment to verify that there were
no obvious deficiencies. The inspectors also verified that the licensee had properly
identified and resolved equipment alignment problems that could cause initiating events
or impact the capability of mitigating systems or barriers and entered them into the
corrective action program with the appropriate significance characterization. Specific
documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of three partial system walkdown samples as
defined in Inspection Procedure 71111.04-05.
-6- Enclosure
b. Findings
No findings of significance were identified.
.2 Complete Walkdown
a. Inspection Scope
On September 11, 2009, the inspectors performed a complete system alignment
inspection of diesel generator 1 to verify the functional capability of the system. The
inspectors selected this system because it was considered both safety-significant and
risk-significant in the licensees probabilistic risk assessment. The inspectors walked
down the system to review mechanical and electrical equipment line ups, electrical
power availability, system pressure and temperature indications, as appropriate,
component labeling, component lubrication, component and equipment cooling, hangers
and supports, operability of support systems, and to ensure that ancillary equipment or
debris did not interfere with equipment operation. The inspectors reviewed a sample of
past and outstanding work orders to determine whether any deficiencies significantly
affected the system function. In addition, the inspectors reviewed the corrective action
program database to ensure that system equipment-alignment problems were being
identified and appropriately resolved. Specific documents reviewed during this
inspection are listed in the attachment.
These activities constitute completion of one complete system walkdown sample as
defined in Inspection Procedure 71111.04-05.
b. Findings
No findings of significance were identified.
1R05 Fire Protection (71111.05)
.1 Quarterly Fire Inspection Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns that were focused on availability,
accessibility, and the condition of firefighting equipment in the following risk-significant
plant areas:
- July 17, 2009, Fire Area 34A (Electrical Penetration Area Basement,
Room 20)
- July 20, 2009, Fire Area 1 (Safety Injection and Containment Spray Pump
Area I, Room 21)
- July 20, 2009, Fire Area 2 (Safety Injection and Containment Spray Pump
Area II, Room 22)
-7- Enclosure
- July 20, 2009, Fire Area 13 (Mechanical Penetration Area, Room 13)
The inspectors reviewed areas to assess if licensee personnel had implemented a fire
protection program that adequately controlled combustibles and ignition sources within
the plant; effectively maintained fire detection and suppression capability; maintained
passive fire protection features in good material condition; and had implemented
adequate compensatory measures for out of service, degraded or inoperable fire
protection equipment, systems, or features, in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk
as documented in the plants Individual Plant Examination of External Events with later
additional insights, their potential to affect equipment that could initiate or mitigate a plant
transient, or their impact on the plants ability to respond to a security event. Using the
documents listed in the attachment, the inspectors verified that fire hoses and
extinguishers were in their designated locations and available for immediate use; that
fire detectors and sprinklers were unobstructed, that transient material loading was
within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
be in satisfactory condition. The inspectors also verified that minor issues identified
during the inspection were entered into the licensees corrective action program.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four quarterly fire-protection inspection samples
as defined in Inspection Procedure 71111.05-05.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program (71111.11)
a. Inspection Scope
On September 8, 2009, the inspectors observed a crew of licensed operators in the
plants simulator to verify that operator performance was adequate, evaluators were
identifying and documenting crew performance problems and training was being
conducted in accordance with licensee procedures. The inspectors evaluated the
following areas:
- Licensed operator performance
- Crews clarity and formality of communications
- Crews ability to take timely actions in the conservative direction
- Crews prioritization, interpretation, and verification of annunciator alarms
- Crews correct use and implementation of abnormal and emergency
procedures
- Control board manipulations
-8- Enclosure
- Supervisors oversight and direction
- Crews ability to identify and implement appropriate technical specification
actions and emergency plan actions and notifications
The inspectors compared the crews performance in these areas to pre-established
operator action expectations and successful critical task completion requirements.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one quarterly licensed-operator requalification
program sample as defined in Inspection Procedure 71111.11.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk
significant systems:
- July 13, 2009, Maintenance Rule function of the security diesel generator
and the Technical Support Center
- September 28, 2009, a(1) status of the containment sump outlet strainer
SI-12A
The inspectors reviewed events such as where ineffective equipment maintenance has
resulted in valid or invalid automatic actuations of engineered safeguards systems and
independently verified the licensee's actions to address system performance or condition
problems in terms of the following:
- Implementing appropriate work practices
- Identifying and addressing common cause failures
- Scoping of systems in accordance with 10 CFR 50.65(b)
- Characterizing system reliability issues for performance
- Charging unavailability for performance
- Trending key parameters for condition monitoring
- Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or
(a)(2)
-9- Enclosure
- Verifying appropriate performance criteria for structures, systems, and
components classified as having an adequate demonstration of
performance through preventive maintenance, as described in 10 CFR
50.65(a)(2), or as requiring the establishment of appropriate and adequate
goals and corrective actions for systems classified as not having adequate
performance, as described in 10 CFR 50.65(a)(1)
The inspectors assessed performance issues with respect to the reliability, availability,
and condition monitoring of the system. In addition, the inspectors verified maintenance
effectiveness issues were entered into the corrective action program with the appropriate
significance characterization. Specific documents reviewed during this inspection are
listed in the attachment.
These activities constitute completion of two quarterly maintenance effectiveness
samples as defined in Inspection Procedure 71111.12-05.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a. Inspection Scope
The inspectors reviewed licensee personnel's evaluation and management of plant risk
for the maintenance and emergent work activities affecting risk-significant and safety-
related equipment listed below to verify that the appropriate risk assessments were
performed prior to removing equipment for work:
- July 22, 2009, Yellow risk condition while replacing Condenser FW-1A
Hotwell Level Controller LC-1190 while Containment Spray Pump SI-3B
and Air Compressor CA-1C were both out of service for maintenance
- August 10, 2009, Emergent inspection activities in the switchyard by
substation personnel
- August 17, 2009, Daily and activity risk associate with shutdown cooling
heat exchanger AC-4A being out of service for maintenance
- September 8, 2009, Orange risk activity associated with the Diesel
Generator DG-2 mini-overhaul
The inspectors selected these activities based on potential risk significance relative to
the reactor safety cornerstones. As applicable for each activity, the inspectors verified
that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)
and that the assessments were accurate and complete. When licensee personnel
performed emergent work, the inspectors verified that the licensee personnel promptly
assessed and managed plant risk. The inspectors reviewed the scope of maintenance
- 10 - Enclosure
work, discussed the results of the assessment with the licensee's probabilistic risk
analyst or shift technical advisor, and verified plant conditions were consistent with the
risk assessment. The inspectors also reviewed the technical specification requirements
and inspected portions of redundant safety systems, when applicable, to verify risk
analysis assumptions were valid and applicable requirements were met. Specific
documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four maintenance risk assessments and
emergent work control inspection samples as defined in Inspection
Procedure 71111.13-05.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations (71111.15)
a. Inspection Scope
The inspectors reviewed the following issues:
- July 24, 2009, Operability of the Auxiliary Building Crane HE-2 following the
failure of the upper electrical limit switch and the overweight trip
- August 10, 2009, Operability of the Turbine-Driven Auxiliary Feedwater
Pump FW-10 after steam passing by ST-16, requiring ST-16 to be taken
offline and ST-15 placed online
- August 15, 2009, Operability on Diesel Generator DG-2 after fuel rack failed
to reset
- August 20, 2009, Operability on HCV-506A and B after discovery of non-
CQE diaphragms
- September 3, 2009, Operability of HCV-400A following air regulator setpoint
being out of specification low
The inspectors selected these potential operability issues based on the risk-significance
of the associated components and systems. The inspectors evaluated the technical
adequacy of the evaluations to ensure that technical specification operability was
properly justified and the subject component or system remained available such that no
unrecognized increase in risk occurred. The inspectors compared the operability and
design criteria in the appropriate sections of the technical specifications and Updated
Safety Analysis Report to the licensees evaluations, to determine whether the
components or systems were operable. Where compensatory measures were required
to maintain operability, the inspectors determined whether the measures in place would
function as intended and properly controlled. The inspectors determined, where
appropriate, compliance with bounding limitations associated with the evaluations.
Additionally, the inspectors also reviewed a sampling of corrective action documents to
- 11 - Enclosure
verify that the licensee was identifying and correcting any deficiencies associated with
operability evaluations. Specific documents reviewed during this inspection are listed in
the attachment.
These activities constitute completion of five operability evaluations inspection samples
as defined in Inspection Procedure 71111.15-04
b. Findings
Introduction. The inspectors identified a finding of having very low safety significance
(Green) for failure to perform checks at the beginning of each shift on the main hoist limit
switches of the refueling area crane (HE - 2) in the spent fuel pool area as specified in
ANSI B30.2 - 1976, Overhead and Gantry Cranes, section 2-2.1.2 Frequent
Inspections a.2, prior to using the crane to perform dry fuel storage activities on
June 29, 2009.
Description. On June 29, 2009, during dry fuel storage activities, dry fuel storage
personnel attempted to lift the transfer cask from the staging location in room 68 and
place it into the spent fuel pool. During the lift, the transfer cask could not be raised
enough to clear interferences between the bottom of the transfer cask and the spent fuel
pool floor. An investigation determined the hoist was actuating the upper rotary limit
switch, which prevents the hoist from rising any higher. It was determined that the upper
rotary limit switch had been set too low during a recent replacement of the switch.
Condition Report 2009-2997 was written to document the occurrence. The shift
manager stopped all dry fuel storage activities in order to correct the problem and dry
fuel storage personnel stopped work.
On June 30, 2009, licensee personnel determined that the upper limit rotary switch could
be bypassed using an installed bypass switch and that the mechanical limit switch would
provide sufficient protection from a two blocking event. During a subsequent crew
briefing of dry fuel storage personnel to recommence work, bypassing the upper limit
rotary switch was discussed and the licensee emphasized to not inadvertently test the
mechanical limit switch.
After the upper rotary limit switch was bypassed, the yoke assembly used to lift the
transfer cask was on the hoist and the crane was being positioned to rig to the transfer
cask when another problem with the crane occurred and dry fuel storage activities were
again stopped. The upper limit rotary switch was subsequently adjusted to the required
setting to provide sufficient hook height for dry fuel activities over the spent fuel pool.
During review of the events on the evening of June 29, 2009, the inspectors determined
that the once-per-shift checks on the main hoist limit switches had not been performed
by either shift, nor was the mechanical limit stop checked with no load on the hook prior
to use after the upper rotary limit switch was bypassed in accordance with ANSI B30.2 -
1976.
Analysis. The failure to perform checks on the main hoist limit switches at the beginning
of each work shift is a performance deficiency because the dry cask personnel used the
crane to perform dry cask storage operations to lift items over the spent fuel pool without
- 12 - Enclosure
performing the required checks per shift change. The inspectors determined that the
performance deficiency was more than minor in accordance with Inspection Manual
Chapter 0612, Appendix B, Issue Screening, minor question 2 because if left
uncorrected the performance deficiency could lead to a more significant safety issue.
Specifically, the main hoist limit switches are installed to limit the main hoist travel and to
prevent a two blocking event. Preventing two blocking events ensures safe load
handling of heavy loads over the spent fuel pool. Using the NRC Manual Chapter 0609,
Phase 1 screening worksheet under the Barrier Cornerstone for spent fuel pool issues,
the finding screened as having very low safety significance because it did not result in
loss of cooling to the spent fuel pool, did not cause damage to the fuel cladding or result
in dropped fuel assembly or result in a loss of spent fuel pool volume of greater than
10 percent. The finding had a crosscutting aspect in problem identification and
resolution because the licensee failed to take appropriate corrective actions to address
safety issues [P.1 (d)].
Enforcement. In Section 2-2.1.2 in ANSI B30.2 - 1976, Frequent Inspections, a.2,
states, in part, that all limit switches should be checked, without a load on the hook, at
the beginning of each shift. Contrary to the above, on June 29 2009, dry cask
personnel did not perform the once-per-shift checks of the limit switches on either shift,
nor was a check performed on the mechanical limit switch after the upper rotary limit
switch was bypassed.
Enforcement action does not apply because the performance deficiency did not involve
a violation of a regulatory requirement. The finding is of very low safety significance and
the issue was addressed in the corrective action program as Condition Report
CR 2009-3063. This finding will be identified as FIN 05000285/2009004-03, Failure to
perform checks at the beginning of each work shift on the main hoist limit switches.
1R18 Plant Modifications (71111.18)
a. Inspection Scope
The inspectors reviewed the following temporary modifications to verify that the safety
functions of important safety systems were not degraded:
- August 26, 2009, Patch on 18-inch grid backwash piping (Circulating Water
System)
The inspectors reviewed the temporary modification and the associated safety
evaluation screening against the system design bases documentation, including the
Updated Final Safety Analysis Report and the technical specifications, and verified that
the modification did not adversely affect the system availability. The inspectors also
verified that the installation and restoration were consistent with the modification
documents and that configuration control was adequate. Additionally, the inspectors
verified that the temporary modification was identified on control room drawings,
appropriate tags were placed on the affected equipment, and licensee personnel
evaluated the combined effects on mitigating systems and the integrity of radiological
barriers.
- 13 - Enclosure
These activities constitute completion of one sample for temporary plant modifications as
defined in Inspection Procedure 71111.18-05
b. Findings
No findings of significance were identified.
1R19 Postmaintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed the following postmaintenance activities to verify that
procedures and test activities were adequate to ensure system operability and functional
capability:
- July 16, 2009, Postmaintenance testing of Heat Exchanger Component
Cooling Water inlet valve HCV-481 following work on Shutdown Cooling
Heat Exchanger AC-4B
- July 28, 2009, Postmaintenance testing of Cooling Coil VA-8B Component
Cooling Water inlet valve HCV-403A following flowscan maintenance
- July 31, 2009, Postmaintenance testing of Charging Pump CH-1C following
maintenance
- August 6, 2009, Postmaintenance testing of Refueling Area Crane HE-2
following resetting of pressure switch PS-2
- September 4, 2009, Postmaintenance testing of Boric Acid Pump CH-4A
following pump replacement
The inspectors selected these activities based upon the structure, system, or
component's ability to affect risk. The inspectors evaluated these activities for the
following (as applicable):
- The effect of testing on the plant had been adequately addressed; testing
was adequate for the maintenance performed
- Acceptance criteria were clear and demonstrated operational readiness;
test instrumentation was appropriate
The inspectors evaluated the activities against the technical specifications, the Updated
Safety Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and various
NRC generic communications to ensure that the test results adequately ensured that the
equipment met the licensing basis and design requirements. In addition, the inspectors
reviewed corrective action documents associated with postmaintenance tests to
determine whether the licensee was identifying problems and entering them in the
corrective action program and that the problems were being corrected commensurate
with their importance to safety. Specific documents reviewed during this inspection are
listed in the attachment.
- 14 - Enclosure
These activities constitute completion of five postmaintenance testing inspection samples as
defined in Inspection Procedure 71111.19-05.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors reviewed the Updated Final Safety Analysis Report, procedure
requirements, and technical specifications to ensure that the surveillance activities listed
below demonstrated that the systems, structures, and components tested were capable
of performing their intended safety functions. The inspectors either witnessed or
reviewed test data to verify that the significant surveillance test attributes were adequate
to address the following:
- Preconditioning
- Evaluation of testing impact on the plant
- Acceptance criteria
- Test equipment
- Procedures
- Test data
- Testing frequency and method demonstrated technical specification
operability
- Test equipment removal
- Restoration of plant systems
- Engineering evaluations, root causes, and bases for returning tested
systems, structures, and components not meeting the test acceptance
criteria were correct
- Reference setting data
- Annunciators and alarms setpoints
The inspectors also verified that licensee personnel identified and implemented any
needed corrective actions associated with the surveillance testing.
- 15 - Enclosure
- August 11, 2009, Diesel Generator DG-2 starting air compressors
discharge check valve exercise test
- August 17, 2009, Component Cooling Category B Valve Exercise Test
(OP-ST-CCW-3001A)
- August 28, 2009, AC-3C Component Cooling Water Pump Inservice Test
- September 1, 2009, Component Cooling Category A and B Valve Exercise
Test (OP-ST-CCW-3005B)
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four surveillance testing inspection sample(s) as
defined in Inspection Procedure 71111.22-05.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP1 Exercise Evaluation (71114.01)
a. Inspection Scope
The inspectors reviewed the objectives and scenario for the 2009 Biennial Emergency
Plan Exercise to determine if the exercise would acceptably test major elements of the
emergency plan. The scenario simulated a tornado touchdown within the site protected
area, an unanticipated closing of main steam isolation valves, failures of automatic and
manual systems to shut down the reactor, a small reactor coolant leak in containment, a
steam generator tube leak, fission product barrier failures, core damage, a radiological
release to the environment via a stuck-open main steam line relief valve, and changes in
wind direction vectors, to demonstrate licensee personnels capability to implement their
The inspectors evaluated exercise performance by focusing on the risk-significant
activities of event classification, offsite notification, recognition of offsite dose
consequences, development of protective action recommendations in the control room
simulator, and the following dedicated emergency response facilities:
- Operations Support Center
- Emergency Operations Facility
The inspectors also assessed recognition of, and response to, abnormal and emergency
plant conditions, the transfer of decision-making authority and emergency function
- 16 - Enclosure
responsibility between emergency response facilities, onsite and offsite communications,
protection of emergency workers, 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 emergency response facilities, procedures for the performance of associated
emergency functions, and other documents as listed in the attachment to this report.
The inspectors compared the observed exercise performance with the requirements in
the facility emergency plan, 10 CFR 50.47(b), 10 CFR Part 50, Appendix E, and with the
guidance in the emergency plan implementing procedures and other federal guidance.
The inspectors attended the post-exercise critiques in each emergency response facility
to evaluate the initial licensee self-assessment of exercise performance, and attended a
subsequent formal presentation of critique items to plant management. The specific
documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one sample as defined in Inspection
Procedure 71114.01-05.
b. Findings
No findings of significance were identified.
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
a. Inspection Scope
The inspectors performed an in-office and on-site reviews of:
- Emergency Plan Implementing Procedure EPIP-OSC-1, Emergency
Classification, Revision 46, issued May 14, 2009
- TBD-EPIP-OSC-1A, Technical Basis Document, Revision 0, issued
May 14, 2009
- Radiological Emergency Response Plan, Section B, Organizational Control
of Emergencies, Revision 29, issued May 14, 2009
- Radiological Emergency Response Plan, Section D, Emergency
Classification System, Revision 14, issued May 14, 2009
- Radiological Emergency Response Plan, Section E, Notification Methods
and Procedures, Revision 25, issued May 14, 2009
- Radiological Emergency Response Plan, Section H, Emergency Facilities
and Equipment, Revision 37, issued May 14, 2009
- 17 - Enclosure
- Radiological Emergency Response Plan,Section I, Accident Assessment,
Revision 14, issued June 23, 2009
These revisions implemented an emergency action level scheme based on Nuclear
Energy Institute (NEI) Report 99-01, Emergency Action Level Methodology, Revision 5,
transferred some oversight responsibilities during medical emergencies from the Shift
manager to the medical coordinator, updated emergency response organization titles,
and made minor editorial corrections. The licensees revised emergency action level
scheme was approved by the NRC in a safety analysis report dated
September 22, 2008, (Agency Document and Management System Accession Numbers
ML0826605731 and ML082320484).
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
Nuclear Energy Institute Report 99-01, Emergency Action Level Methodology,
Revision 5, 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). These reviews were not
documented in safety evaluation reports and did not constitute approvals of licensee
generated changes; therefore, these revisions are subject to future inspection. The
specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four samples as defined in Inspection
Procedure 71114.04-05.
b. Findings
No findings of significance were identified.
4. OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151)
.1 Data Submission Issue
a. Inspection Scope
The inspectors performed a review of the performance indicator data submitted by the
licensee for the third quarter 2008, fourth quarter 2008, first quarter 2009, and second
quarter 2009 for any obvious inconsistencies prior to its public release in accordance
with Inspection Manual chapter 0608, Performance Indicator Program.
This review was performed as part of the inspectors normal plant status activities and,
as such, did not constitute a separate inspection sample.
b. Findings
No findings of significance were identified.
- 18 - Enclosure
.2 Safety System Functional Failures (MS05)
a. Inspection Scope
The inspectors sampled licensee submittals for the Safety System Functional Failures
performance indicator for the period from the third quarter 2008 through the fourth
quarter 2009. To determine the accuracy of the performance indicator data reported
during those periods, performance indicator definitions and guidance contained in
NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
Revision 5, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73"
definitions and guidance were used. The inspectors reviewed the licensees operator
narrative logs, operability assessments, maintenance rule records, maintenance work
orders, issue reports, event reports and NRC integrated inspection reports for the period
of July 1, 2008 through June 30, 2009 to validate the accuracy of the submittals. The
inspectors also reviewed the licensees issue report database to determine if any
problems had been identified with the performance indicator data collected or
transmitted for this indicator and none were identified. Specific documents reviewed are
described in the attachment to this report.
These activities constitute completion of one safety system functional failures sample as
defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
.3 Mitigating Systems Performance Index - Emergency ac Power System (MS06)
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance
Index - Emergency ac Power System performance indicator for the period from the third
quarter 2008 through the fourth quarter 2009. To determine the accuracy of the
performance indicator data reported during those periods, performance indicator
definitions and guidance contained in NEI Document 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 5, was used. The inspectors reviewed the
licensees operator narrative logs, mitigating systems performance index derivation
reports, issue reports, event reports and NRC integrated inspection reports for the period
of July 1, 2008 through June 30, 2009 to validate the accuracy of the submittals. The
inspectors reviewed the mitigating systems performance index component risk
coefficient to determine if it had changed by more than 25 percent in value since the
previous inspection, and if so, that the change was in accordance with applicable
NEI guidance. The inspectors also reviewed the licensees issue report database to
determine if any problems had been identified with the performance indicator data
collected or transmitted for this indicator and none were identified. Specific documents
reviewed are described in the attachment to this report.
These activities constitute completion of one mitigating systems performance index
emergency ac power system sample as defined in Inspection Procedure 71151-05.
- 19 - Enclosure
b. Findings
No findings of significance were identified.
.4 Mitigating Systems Performance Index - High Pressure Injection Systems (MS07)
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance
Index - High Pressure Injection Systems performance indicator for the period from the
third quarter 2008 through the fourth quarter 2009. To determine the accuracy of the
performance indicator data reported during those periods, performance indicator
definitions and guidance contained in NEI Document 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 5, was used. The inspectors reviewed the
licensees operator narrative logs, issue reports, mitigating systems performance index
derivation reports, event reports and NRC integrated inspection reports for the period of
July 1, 2008 through June 30, 2009 to validate the accuracy of the submittals. The
inspectors reviewed the mitigating systems performance index component risk
coefficient to determine if it had changed by more than 25 percent in value since the
previous inspection, and if so, that the change was in accordance with applicable
NEI guidance. The inspectors also reviewed the licensees issue report database to
determine if any problems had been identified with the performance indicator data
collected or transmitted for this indicator and none were identified. Specific documents
reviewed are described in the attachment to this report.
These activities constitute completion of one mitigating systems performance index
high-pressure injection system sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
.5 Mitigating Systems Performance Index - Heat Removal System (MS08)
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance
Index - Heat Removal System performance indicator for the period from the third quarter
2008 through the fourth quarter 2009. To determine the accuracy of the performance
indicator data reported during those periods, performance indicator definitions and
guidance contained in NEI Document 99-02, Regulatory Assessment Performance
Indicator Guideline, Revision 5, was used. The inspectors reviewed the licensees
operator narrative logs, issue reports, event reports, mitigating systems performance
index derivation reports, and NRC integrated inspection reports for the period of
July 1, 2008 through June 30, 2009 to validate the accuracy of the submittals. The
inspectors reviewed the MSPI component risk coefficient to determine if it had changed
by more than 25 percent in value since the previous inspection, and if so, that the
change was in accordance with applicable NEI guidance. The inspectors also reviewed
- 20 - Enclosure
the licensees issue report database to determine if any problems had been identified
with the performance indicator data collected or transmitted for this indicator and none
were identified. Specific documents reviewed are described in the attachment to this
report.
These activities constitute completion of one mitigating systems performance index heat
removal system sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
.6 Mitigating Systems Performance Index - Residual Heat Removal System (MS09)
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance
Index - Residual Heat Removal System performance indicator for the period from the
third quarter 2008 through the fourth quarter 2009. To determine the accuracy of the
performance indicator data reported during those periods, performance indicator
definitions and guidance contained in NEI Document 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 5, was used. The inspectors reviewed the
licensees operator narrative logs, issue reports, mitigating systems performance index
derivation reports, event reports and NRC integrated inspection reports for the period of
July 1, 2008 through June 30, 2009 to validate the accuracy of the submittals. The
inspectors reviewed the mitigating systems performance index component risk
coefficient to determine if it had changed by more than 25 percent in value since the
previous inspection, and if so, that the change was in accordance with applicable
NEI guidance. The inspectors also reviewed the licensees issue report database to
determine if any problems had been identified with the performance indicator data
collected or transmitted for this indicator and none were identified. Specific documents
reviewed are described in the attachment to this report.
These activities constitute completion of one mitigating systems performance index
residual heat removal system sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
.7 Mitigating Systems Performance Index - Cooling Water Systems (MS10)
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance
Index - Cooling Water Systems performance indicator for the period from the third
quarter 2008 through the fourth quarter 2009. To determine the accuracy of the
performance indicator data reported during those periods, performance indicator
definitions and guidance contained in NEI Document 99-02, Regulatory Assessment
- 21 - Enclosure
Performance Indicator Guideline, Revision 5, was used. The inspectors reviewed the
licensees operator narrative logs, issue reports, mitigating systems performance index
derivation reports, event reports and NRC integrated inspection reports for the period of
July 1, 2008 through June 30, 2009 to validate the accuracy of the submittals. The
inspectors reviewed the mitigating systems performance index component risk
coefficient to determine if it had changed by more than 25 percent in value since the
previous inspection, and if so, that the change was in accordance with applicable
NEI guidance. The inspectors also reviewed the licensees issue report database to
determine if any problems had been identified with the performance indicator data
collected or transmitted for this indicator and none were identified. Specific documents
reviewed are described in the attachment to this report.
These activities constitute completion of one mitigating systems performance index
cooling water system sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
.8 Drill and Exercise Performance (EP01)
a. Inspection Scope
The inspectors sampled licensee submittals for the Drill and Exercise Performance,
performance indicator for the period from the third quarter 2008 through the fourth
quarter 2009. To determine the accuracy of the performance indicator data reported
during those periods, performance indicator definitions and guidance contained in
Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance
Indicator Guideline, Revision 5, was used. The inspectors reviewed the licensees
records associated with the performance indicator to verify that the licensee accurately
reported the indicator in accordance with relevant procedures and the Nuclear Energy
Institute guidance. Specifically, the inspectors reviewed licensee records and processes
including procedural guidance on assessing opportunities for the performance indicator;
assessments of performance indicator opportunities during predestinated control room
simulator training sessions, and other licensee drills. The specific documents reviewed
are described in the attachment to this report.
These activities constitute completion of the drill/exercise performance sample as
defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
.9 Emergency Response Organization Drill Participation (EP02)
a. Inspection Scope
- 22 - Enclosure
The inspectors sampled licensee submittals for the Emergency Response Organization
Drill Participation performance indicator for the period the third quarter 2008 through the
fourth quarter 2009. To determine the accuracy of the performance indicator data
reported during those periods, performance indicator definitions and guidance contained
in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance
Indicator Guideline, Revision 5, was used. The inspectors reviewed the licensees
records associated with the performance indicator to verify that the licensee accurately
reported the indicator in accordance with relevant procedures and the Nuclear Energy
Institute guidance. Specifically, the inspectors reviewed licensee records and processes
including procedural guidance on assessing opportunities for the performance indicator,
rosters of personnel assigned to key emergency response organization positions, and
exercise participation records. The specific documents reviewed are described in the
attachment to this report.
These activities constitute completion of the emergency response organization drill
participation sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
.10 Alert and Notification System (EP03)
a. Inspection Scope
The inspectors sampled licensee submittals for the Alert and Notification System
performance indicator for the period July 2008 through June 2009. To determine the
accuracy of the performance indicator data reported during those periods, performance
indicator definitions and guidance contained in Nuclear Energy Institute
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5,
was used. The inspectors reviewed the licensees records associated with the
performance indicator to verify that the licensee accurately reported the indicator in
accordance with relevant procedures and the Nuclear Energy Institute guidance.
Specifically, the inspectors reviewed licensee records and processes including
procedural guidance on assessing opportunities for the performance indicator and the
results of periodic alert notification system operability tests. The specific documents
reviewed are described in the attachment to this report.
These activities constitute completion of the alert and notification system sample as
defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
- 23 - Enclosure
4OA2 Identification and Resolution of Problems (71152)
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
.1 Routine Review of Identification and Resolution of Problems
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of
this report, the inspectors routinely reviewed issues during baseline inspection activities
and plant status reviews to verify that they were being entered into the licensees
corrective action program at an appropriate threshold, that adequate attention was being
given to timely corrective actions, and that adverse trends were identified and
addressed. The inspectors reviewed attributes that included (1) the complete and
accurate identification of the problem; (2) the timely correction, commensurate with the
safety significance; (3) the evaluation and disposition of performance issues, generic
implications, common causes, contributing factors, root causes, extent of condition
reviews, and previous occurrences reviews; and (4) the classification, prioritization,
focus, and timeliness of corrective actions. Minor issues entered into the licensees
corrective action program because of the inspectors observations are included in the
attached list of documents reviewed.
These routine reviews for the identification and resolution of problems did not constitute
any additional inspection samples. Instead, by procedure, they were considered an
integral part of the inspections performed during the quarter and documented in
Section 1 of this report.
b. Findings
No findings of significance were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific
human performance issues for follow-up, the inspectors performed a daily screening of
items entered into the licensees corrective action program. The inspectors
accomplished this through review of the stations daily corrective action documents.
The inspectors performed these daily reviews as part of their daily plant status
monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings of significance were identified.
- 24 - Enclosure
.3 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a review of the licensees corrective action program and
associated documents to identify trends that could indicate the existence of a more
significant safety issue. The inspectors focused their review on repetitive equipment
issues, but also considered the results of daily corrective action item screening
discussed in Section 4OA2.2, above, licensee trending efforts, and licensee human
performance results. The inspectors nominally considered the period of
January 1, 2009, through August 31, 2009, although some examples expanded beyond
those dates where the scope of the trend warranted.
The inspectors also included issues documented outside the normal corrective action
program in major equipment problem lists, repetitive and rework maintenance lists,
departmental challenges lists, system health reports, quality assurance audit reports,
self-assessment reports, and Maintenance Rule assessments. The inspectors
compared and contrasted their results with the results contained in the licensees
corrective action program trending reports. Corrective actions associated with a sample
of the issues identified in the licensees trending reports were reviewed for adequacy.
These activities constitute completion of one single semi-annual trend inspection sample
as defined in Inspection Procedure 71152-05.
b. Findings
No findings of significance were identified.
.4 Selected Issue Follow-up Inspection
a. Inspection Scope
During a review of items entered in the licensees corrective action program, the
inspectors recognized a corrective action item documenting repetitive problems
associated with the auxiliary building crane during the spent fuel pool campaign. The
inspectors reviewed the individual incidents to ascertain any commonalities to the
incidents.
The inspectors reviewed items entered in the licensees corrective action program; the
inspectors recognized a corrective action item documenting an inadequate maintenance
work order. The inspectors reviewed the events leading to the discovery of the
inadequate work order, a review of their apparent cause analysis, and the proposed
corrective actions.
These activities constitute completion of two in-depth problem identification and
resolution samples as defined in Inspection Procedure 71152-05.
- 25 - Enclosure
b. Findings
i. Introduction. A self-revealing Green noncited violation (NCV) of 10 CFR Part 50,
Appendix B, Criterion V, was identified for the failure of personnel to follow an
auxiliary building crane operating procedure. This resulted in the crane contacting
the fuel handling bridge and moving it approximately eight feet.
Description. On June 30, 2009, activities were taking place in the fuel building
associated with dry fuel storage campaign. Personnel were preparing to move the
dry fuel transfer cask from its storage location in Room 68 into the spent fuel pool.
This activity required rigging the transfer cask yoke with the Refueling Area Crane
(HE-2), attaching the yoke to the transfer cask, then lifting the transfer cask from its
storage location and placing it in the spent fuel pool.
The crane is normally operated from the cab control with the crane operator
physically inside the cab; but can also be operated by radio control where the crane
operator manipulates the crane using a portable radio transmitter. On June 30,
2009, the crane operator was using the radio transmitter to operate the crane. The
crane operator lifted the transfer cask yoke, and was in the process of moving the
yoke to the storage area of the transfer cask. Since the crane operator was
operating the crane with the radio transmitter, he did not have a direct line of sight to
the cranes cab. While moving the yoke laterally with the crane, the cab struck the
mast of the fuel handling bridge (FH-12), moving the bridge approximately eight
feet.
The crane was being operated in accordance with operating instruction
GM-OI-HE-2, Auxiliary Building Crane Normal Operation. Both the crane cab and
the fuel handling bridge are equipped with proximity detectors. The operating
instruction prerequisites require energizing the proximity detectors on the crane cab
and on the fuel handling bridge. There is an additional prerequisite to move and
park the fuel handling bridge with its mast at the west end of the bridge.
Section 6.31 of the precautions and limitations section of the operating instruction
states: During radio controlled operation of HE-2, the Crane Operator may be
located in such a way that the FH-12 proximity detector indications are not visible.
To avoid the risk of a collision, FH-12 shall be parked with the mast at the west end
of the bridge. When the crane struck the fuel handling bridge, the mast was parked
on the east end of the bridge, and the proximity detectors were energized neither on
the crane nor on the fuel handling bridge.
Analysis. The failure to follow the prerequisites of the auxiliary building crane
operating procedure is a performance deficiency. The finding is greater than minor
because it would become a more significant safety concern if left uncorrected in that
a collision with the fuel handling bridge could cause damage such that pieces of the
mast could fall into the spent fuel pool and damage the spent fuel. Using the
NRC Manual Chapter 0609, Phase 1 screening worksheet under the Barrier
Integrity Cornerstone for spent fuel pool issues, the finding screened as having very
low safety significance because it did not result in loss of cooling to the spent fuel
pool, did not cause damage to the fuel cladding or result in dropped fuel assembly
or result in a loss of spent fuel pool volume of greater than 10 percent. This finding
- 26 - Enclosure
has a crosscutting aspect in the area of human performance associated with work
practices because personnel failed to use human error prevention techniques
commensurate with the risk of the assigned task, such that work activities were
performed safely [H.4.(a)].
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, require that activities affecting Quality shall be
prescribed by documented procedures of a type appropriate to the circumstances
and shall be accomplished in accordance with these procedures. Operating
Instruction GM-OI-HE-2, Auxiliary Building Crane Normal Operation Revision 18,
contained the requirements for positioning of the fuel handling bridge mast and
energizing the proximity detectors on the cranes cab and the fuel handling bridge.
Contrary to the above, on June 30, 2009, personnel failed to park the mast of the
fuel handling bridge at the west end of the bridge and failed to energize the
proximity detectors in accordance with Operating Instructions GM-OI-HE-2. This
failure resulted in the crane colliding with the fuel handling bridge mast. Because
the finding is of very low safety significance and has been entered into the
licensees corrective action program as Condition Report CR-2009-3002, this
violation is being treated as an NCV consistent with Section VI.A of the Enforcement
Policy: NCV 05000285/2009004-04, Failure to Follow Auxiliary Building Crane
Operating Instructions.
ii. Introduction. A self-revealing, Green noncited violation of Technical Specification 5.8.1.a (Procedures) was identified for failure to provide an adequate maintenance
work instruction. While performing maintenance on the motor, the HPSI Header -
Charging Header Crosstie Valve, HCV-308, the maintenance work instruction failed
to ensure that the HPSI Alternate Header Isolation Valve, HCV-2987, was closed,
resulting in unexpected pressurization of the Number 2 HPSI Header.
Description. On July 17, 2009, the licensee was performing Motor Control Center
and Fast Fourier Transform testing on the, HPSI Header - Charging Header
Crosstie Valve motor of HCV-308. The work instructions consisted of seven
sections contained on one page. Section 3.0 Impact Statement noted HCV-308
will be out of service for this work task, and Valve will be cycled throughout
testing. Section 6.0 Work Instructions stated Perform MC2 Diagnostic Testing
on HCV-308 per the procedure EM-RR-VX-0406, (MC2 Diagnostic Test Procedure
for Motor Operated Valves).
The Motor Control Center diagnostic equipment and data acquisition system were
installed on HCV-308. Step 7.3.2 of the diagnostic test procedure then directed
stroke the valve in the desired direction. Though not specifically referenced in the
maintenance work instruction, the operator referenced Surveillance Test
Procedure OP-ST-SI-3001, Safety Injection System Category A and B Valve
Exercise Test to open HCV-308. Details on opening this specific valve are
included in Attachment 8, Section 5 of the Surveillance Test Procedure.
After opening HCV-308, control room personnel noted a steady increase in the
Reactor Coolant Drain Tank level. While investigating the source of water into the
tank, the control room noted that the differential pressure across the Number 2
- 27 - Enclosure
HSPI header injection valves exceeded 1300 psig below the valve seat. Nominally,
the differential pressure across these valves is 250 psi above the valve seat.
Further investigation determined that the HPSI Alternate Header Isolation Valve,
HCV-2987, was open, and provided charging pump discharge pressure to the
header injection valves once HCV-308 was opened.
Though the maintenance work instruction did not provide adequate guidance to
open HCV-308, the Surveillance Test Procedure should provide the needed
guidance. There is a note in Attachment 8 of the surveillance test that states HCV-
2987 should remain closed during stroke testing of HCV-308 However, this note
is contained in the section of the procedure to stroke HCV-2987, and could go
unnoticed when using the procedure only to stroke HCV-308.
Analysis. The failure to provide an adequate maintenance work instruction was a
performance deficiency. This finding was greater than minor because the finding
was associated with the Mitigating Systems Cornerstone objective (procedure
quality attribute) to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences. Using Manual
Chapter 0609, Appendix A, Determining the Significance of Reactor Inspection
Findings for At-Power Situations, Phase 1 screening worksheet, the inspectors
determined that the finding was of very low safety significance (Green) because it
was not: (1) a design or qualification deficiency; (2) a loss of system safety
function; (3) an actual loss of safety function for greater than its technical
specification allowed outage time; (4) a loss of safety function of a nontechnical
specification train; or (5) a seismic, flooding or severe weather related finding.
There is no crosscutting aspect associated with this finding since the inadequacy of
the surveillance test procedure was a significant contributor to the result, not the
performance deficiency.
Enforcement. Fort Calhoun Technical Specification 5.8.1.a states, in part, Written
procedures... shall be established, implemented and maintained covering the
following activities... The applicable procedures recommended in Regulatory
Guide 1.33, Revision 2, Appendix A, 1978. Regulatory Guide 1.33, Revision 2,
Appendix A, 1978, Section 9(a), recommends, in part, maintenance that can affect
the performance of safety-related equipment should be properly preplanned and
performed in accordance with written procedures, documented instructions, or
drawings appropriate to the circumstances. The licensee performed maintenance
on the motor of HCV-308 in accordance with Work Order 00333467-01. Contrary to
the above, as of July 17, 2009, the maintenance work instruction for performing
motor testing on HCV-308 was not adequate to satisfy this requirement because the
instruction failed to provide adequate steps to ensure that HCV-2987 was closed
prior to opening HCV-308. Since this finding was of very low safety significance
and was documented in the licensees corrective action program as Condition
Report CR2009-3256, this violation is being treated as a noncited violation (NCV),
consistent with Section VI.A of the NRC Enforcement Policy (NCV 05000285/2009004-01), Inadequate Valve Motor Maintenance Work Instructions.
- 28 - Enclosure
.5 In-Depth Review of Operator Workarounds
a. Inspection Scope
The inspectors selected this issue for review to verify that licensee personnel were
identifying operator workaround problems at an appropriate threshold and entering them
in the corrective action program, and has proposed or implemented appropriate
corrective actions. The inspectors considered the following, as applicable, during the
review of the licensee's actions: (1) complete and accurate identification of the problem
in a timely manner; (2) evaluation and disposition of operability/reportability issues;
(3) consideration of extent of condition, generic implications, common cause, and
previous occurrences; (4) classification and prioritization of the resolution of the problem;
(5) identification of root and contributing causes of the problem; (6) identification of
corrective actions; and (7) completion of corrective actions in a timely manner.
b. Findings
No findings of significance were identified.
4OA3 Event Follow-up (71153)
.1 (Opened) LER 05000285/2009003-00, Void in Safety Injection Piping During
Operation Due to Inadequate Procedural Guidance
On April 30, 2009, a void was discovered on the cooled suction line to High
Pressure Safety Injection Pump SI-2B. Based on the period from the end of the
2008 Refueling Outage to the time of the discovery of the void, this made SI-2B
inoperable for greater than the Technical Specification allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Actions
were taken to successfully vent the void. Follow-up ultrasonic testing was done to
confirm the location was water filled.
.2 (Opened and Closed) LER 05000285/2009002-00, Technical Specification Violation
due to Installation of an Unqualified Part in a Radiation Monitor
On November 21, 2008, a non-qualified relay was mistakenly installed in the pump
control circuit of a process radiation monitor, rendering it inoperable. The licensee
discovered the condition on April 13, 2009. In the intervening 143 days, a stack
radiation monitor was inoperable at the same time in Violation of Technical
Specification 2.15. The LER was reviewed by the inspectors, no findings of
significance were identified, and no violation of NRC requirements occurred. The
licensee documented the failed equipment in Condition Report CR 2009-2537.
This LER is closed.
.3 (Closed) URI 05000285/2009007-04, Failure to Report a Potential Defect of
Breaker Trip Bars per 10 CFR Part 21
a. Inspection Scope.
On July 14, 2009, Inspection Report 05000285/2009007 documented an unresolved
- 29 - Enclosure
item concerning the extent of a deviation originally discovered in a failed safety-related
breaker. An inadequate evaluation of the deviation was performed that could result in an
event or condition not being properly reported under 10 CFR Part 21, 10 CFR Part
50.72, 10 CFR Part 50.73 or 10 CFR Part 73.71.
b. Finding
. Failure To Adopt Appropriate Procedures To Evaluate Deviations And Failures To Comply
With 10 CFR Part 21
Introduction. The NRC identified a Severity Level IV noncited violation of
10 CFR Part 21.21(a), Notification of failure to comply or existence of a defect and its
evaluation for the licensees failure to adopt appropriate procedures to evaluate
deviations and failures to comply associated with substantial safety hazards.
Specifically, the procedure fails to adequately assess the extent of deviations, which are
discovered, and the potential impact on other components either installed in the plant or
stored in the warehouse. Additionally, the procedure failed to adequately evaluate
defects in components, which have never been installed or used in the nuclear plant.
Description. On August 24, 2007, a safety related breaker (MCC-4B1-B01, Pressurizer
Backup Heaters Bank 3 Group 8) failed its instantaneous trip setting on one phase. A
failure analysis was performed by a third party vendor who determined the failure to be
curvature of the trip bar was likely due to a material defect. This failure is a deviation as
defined by 10 CFR Part 21 (a departure from the technical requirements included in a
procurement document) and the licensees governing procedure SO-R-1, Reportability
Determinations. The licensee arbitrarily determined the extent of the deviation to be
limited to breakers with the same date code as the failed breaker. This determination
was made with no engineering basis. In instances where deviations are attributed to the
vendor, only the vendor can fully determine the extent of the deviation and its potential
effect on similar components. Since procedure SO-R-1 did not direct vendor notification
unless the initial deviation is potentially associated with a substantial safety hazard, it is
not possible to fully determine whether the deviation occurred in other components.
The licensee determined there were no other breakers with the same date code located
anywhere on site, thus the only breaker assumed to have the deviation was the initial
breaker that failed. Due to the safety-related function of the particular breaker, there was
no substantial safety hazard, and the event was not reportable under 10 CFR 50.72 or
10 CFR 50.73. Thus, the licensee determined that any reporting requirements under
10 CFR Part 21 were satisfied, as described in 10 CFR 21.2(c). The inspectors noted
Step 1.3 in Procedure SO-R-1 which states, in part, for in-service components, if the
event or condition is appropriately evaluated under 10 CFR 50.72, 50.73 or 73.71 (e.g.,
via the use of Reportability Evaluation Checklist Part 1 and/or Part 6, as appropriate) no
additional evaluation is needed with respect to 10 CFR Part 21. In addition, no specific
guidance is included in the procedure to address affected components, which may be
located in the warehouse.
On July 31, 1991, the NRC published Statements of Consideration in the Federal
Register (56 FR 36081) Criteria and Procedures for the Reporting of Defects and
Conditions of Construction Permits. This publication noted, One category of defects,
- 30 - Enclosure
which will still be reported by power plant operating license holders under Part 21 rather
than Sections 50.72 and 50.73, are those defects discovered by licensees in equipment
that has never been installed or used in the nuclear plant. This category of defects is
normally associated with components stored in the licensee's warehouse. Following
Step 1.3 in Procedure SO-R-1, conditions could exist where a deviation is evaluated
under 10 CFR 50.72 or 10 CFR 50.73 and determined to be not reportable, then no
further evaluation would be required, even though the defect may occur in a component
or components in the warehouse.
Analysis. The inspectors determined that the failure to adopt appropriate procedures to
evaluate deviations and failures to comply associated with substantial safety hazards
was a performance deficiency. This finding was more than minor because if the
procedure were left uncorrected it could become a more serious safety concern.
Specifically, failure to notify the vendor upon discovery of a deviation does not allow for
adequate evaluation of other components that could be subject to the deviation.
Additionally, components with deviations could be located in the licensees warehouse
and subsequently installed in the plant without the licensees knowledge, potentially
creating a substantial safety hazard. Because this issue affected a potential reporting
requirement and NRCs ability to perform its regulatory function, it was evaluated with
the traditional enforcement process. Consistent with the guidance in Section IV.A.3 and
Supplement VII paragraph D.4 of the NRC Enforcement Policy, this violation was
categorized at Severity Level IV noncited violation. There is no crosscutting aspect
associated with this finding because it is not indicative of current performance in that the
procedure is many years old.
Enforcement. Title 10 CFR Part 21.21(a), Notification of failure to comply or existence
of a defect and its evaluation, states, in part, that each individual corporation subject to
the regulations in this part shall adopt appropriate procedures to evaluate deviation and
failures to comply associated with substantial safety hazards. Contrary to the above, as
of May 15, 2009, the licensee failed to adequately address the evaluation of defects
discovered in equipment that has never been installed or used in the nuclear plant.
Additionally, there is no guidance to evaluate the extent of the deviation to determine if
defective components are located in the warehouse. This is a Severity Level IV violation
consistent with Section IV.A.3 and Supplement VII, paragraph D.4, of the NRC
Because this finding was of very low safety significance and has been entered into the
corrective action program as Condition Report CR 2009-2276, this violation is being
treated as a noncited violation, consistent with section VI.A of the NRC Enforcement
Policy: NCV 05000285/2009004-02, "Failure to Adopt Appropriate Procedures to
Evaluate Deviations and Failures to Comply with 10 CFR Part 21 Evaluations."
- 31 - Enclosure
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors performed observations of security force
personnel and activities to ensure that the activities were consistent with Fort Calhouns
security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities
did not constitute any additional inspection samples. Rather, they were considered an
integral part of the inspectors normal plant status review and inspection activities.
b. Findings
No findings of significance were identified.
.2 Operation of an Independent Spent Fuel Storage Installation at Operating
Plants (60855.1); Review of 10 CFR 72.212(b) Evaluations at Operating
Plants (60856.1)
a. Inspection Scope
Inspectors reviewed aspects of the stations 10 CFR 72 specific license. At the time of
this inspection, Fort Calhoun Stations independent spent fuel storage installation
contained five loaded Transnuclear Standardized NUHOMS Horizontal Modular Storage
units. The licensee was loading casks in compliance with the requirements contained in
Transnuclear Standardized NUHOMS Horizontal Modular Storage System Certificate of
Compliance 1004, License Amendment 9, and the Standardized NUHOMS Horizontal
Modular Storage System Final Safety Analysis Report, Revision 7, for use during the
current cask loading campaign.
Portions of the operations associated with loading of canister 7 were observed. (Note:
Canister numbers do not reflect actual loading sequence.) Activities in process included
the use of the forced helium to remove the moisture from the dry shielded canister,
helium backfill operation, dry shielded canister closure welding, nondestructive testing of
weld joints, and the loading of the canister into the Standardized NUHOMS Horizontal
Module.
The characteristics of the spent fuel assemblies selected for loading into dry shielded
canister 7 were reviewed and found to be in compliance with Certificate of
Compliance 1004 technical specification requirements. The fuel assemblies had been
selected for loading in accordance with the requirements contained in licensee
Procedure RE-AD-0005, Fuel Selection and DSC Planning for Dry Cask Storage,
Revision 2.
- 32 - Enclosure
A tour of the independent spent fuel storage installation was performed by the
inspectors. The condition of the Standardized NUHOMS Horizontal Modular Storage
units and the associated vents were determined to be adequate. Material being stored
on the independent spent fuel storage installation pad, and used for supporting
independent spent fuel storage operations, met the fire hazard analysis requirements.
The Transnuclear Standardized NUHOMS Horizontal Modular Storage System
Technical Specification 1.3 provides the licensee two methods, Technical Specification 1.3.1 or 1.3.2, for monitoring the thermal performance of the horizontal storage modules
on a daily basis. The licensee chose Technical Specification 1.3.2 as their thermal
performance monitoring method that monitors the inlet and outlet air temperature of
each horizontal storage module. The licensee has incorporated the requirements to
obtain these daily readings in the plant operations logs.
b. Findings
No findings of significance were identified.
4OA6 Meetings
Exit Meeting Summary
On July 24, 2009, the inspectors presented the results of the inspection of the onsite emergency
preparedness exercise and the onsite review of licensee changes to the Radiological
Emergency Response Plan and emergency plan implementing procedures, to
Mr. T. Nellenbach, Division Manager, Nuclear Operations/Plant Manager, and other members of
the licensees staff. The licensee acknowledged the issues presented. The inspector asked the
licensee whether any materials examined during the inspection should be considered
proprietary. No proprietary information was identified.
On August 7, 2009, the inspectors presented the inspection results of the Dry Fuel Storage
Campaign inspection activities to Mr. J. Reinhart, Site Vice President, and other members of the
licensee staff. The licensee acknowledged the issues presented. The inspectors asked the
licensee whether any materials examined during the inspection should be considered
proprietary. No proprietary information was identified.
On October 7, 2009, the inspectors presented the inspection results to Mr. J. Reinhart,
Site Vice President, and other members of the licensee staff. The licensee acknowledged the
issues presented. The inspector asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was identified.
- 33 - Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
R. Acker, Station Licensing Engineering
R. Clemens, Division Manager, Nuclear Engineering
P. Cronin, Manager, Operations
K. Erdman, Supervisor Materials Engineering
H. Faulhaber, Division Manager, Nuclear Asset Management
M. Frans, Manager, System Engineering
J. Gasper, Manager, Design Engineering
S. Gebers, Manager, Emergency Preparedness and Health Physics
D. Guinn, Supervisor Regulatory Compliance
J. Herman, Manager, Engineering Programs
R. Hodgson, Manager, Radiation Protection
T. Hutchinson, Reliability Engineer
T. Matthews, Manager, Nuclear Licensing
E. Matzke, Senior Nuclear Licensing Engineer
T. Nellenbach, Division Manager, Nuclear Operations/Plant Manager
T. Pilmaier, Manager, Performance Improvement
J. Reinhart, Site Vice President
G. Roets, Manager Major Projects
R. Short, Manager, Major Projects
C. Simmons, Supervisor, Emergency Preparedness
M. Tesar, Division Manager, Nuclear Support
T. Uehling, Manager, Chemistry
B. VanSant, Manager, Nuclear Projects
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000285/2009003-00 LER Void in Safety Injection Piping During Operation Due to
Inadequate Procedural Guidance (4OA3)05000282/2009004-01 NCV Inadequate Valve Motor Maintenance Work Instructions (4OA2)05000285/2009004-02 NCV Failure to Adopt Appropriate Procedures to Evaluate Deviations
and Failures to Comply with 10 CFR Part 21 Evaluations (4OA3)05000285/2009004-03 FIN Failure to perform checks at the beginning of each work shift on
the main hoist limit switches (1R15)05000285/2009004-04 NCV Failure to Follow Auxiliary Building Crane Operating Instructions
(40A2)
Opened and Closed
05000282/2009002-00 LER Technical Specification Violation Due to Installation of an
Unqualified Part in a Radiation Monitor (4OA3)
A-1 Attachment
Closed
05000285/2009007-04 URI Void in Safety Injection Piping During Operation Due to
Inadequate Procedural Guidance (4OA3)
LIST OF DOCUMENTS REVIEWED
Section 1RO1: Adverse Weather Protection
DOCUMENT TYPE
NUMBER TITLE REVISION
AOP-31 161 kV Grid Malfunctions 9
NOD-QP-36 Grid Operations and Control of Switchyard at FCS 18
OI-EG-3 EMS Post-FCS-Trip 161 KV Voltage Prediction and Switchyard 7
Status
Section 1RO4: Equipment Alignment
DRAWINGS
NUMBER TITLE REVISION
11405-M-10, Sheet 1 Auxiliary Cooling Component Cooling System Flow 66
Diagram P&ID
11405-M-10, Sheet 2 Auxiliary Cooling Component Cooling System Flow 17
Diagram P&ID
11405-M-10, Sheet 3 Auxiliary Cooling Component Cooling System Flow 24
Diagram P&ID
11405-M-10, Sheet 4 Auxiliary Cooling Component Cooling System Flow 11
Diagram P&ID
11405-M-10, Sheet COV Composite Flow Diagram Auxiliary Cooling Component 29
Cooling System P&ID
11405-M-253, Sheet 1 Condensate Flow Diagram Steam Generator Feedwater 92
and Blowdown P&ID
11405-M-253, Sheet 2 Condensate Flow Diagram Steam Generator Feedwater 24
and Blowdown P&ID
11405-M-253, Sheet 3 Condensate Flow Diagram Steam Generator Feedwater 16
and Blowdown P&ID
11405-M-253, Sheet 4 Condensate Flow Diagram Steam Generator Feedwater 39
and Blowdown P&ID
A-2 Attachment
Section 1RO4: Equipment Alignment
DRAWINGS
NUMBER TITLE REVISION
11405-M-253, Sheet COV Condensate Flow Diagram Steam Generator Feedwater 46
and Blowdown P&ID
11405-M-263, Sheet 1 Flow Diagram Compressed Air P&ID 69
11405-M-263, Sheet 2 Flow Diagram Compressed Air P&ID 26
11405-M-263, Sheet COV Composite Flow Diagram Compressed Air P&ID 41
11405-M-264, Sheet 1 Flow Diagram Instrument Air Diagram Aux Building & 61
Containment P&ID
11405-M-264, Sheet COV Composite Flow Diagram Instrument Air Diagram Aux 30
Building & Containment P&ID
B120F04002, Sheet 1 Jacket Water Schematic for DG-1 P&ID 25
B120F07001, Sheet 1 Starting Air System Schematic for DG-1 (Rm 63) P&ID 34
D-4665 DG-1 Diesel Generator One Line Diagram P&ID 6
E-23866-210-130, Sheet 1 Safety Injection and Containment Spray System Flow 100
Diagram P&ID
E-23866-210-130, Sheet 2 Safety Injection and Containment Spray System Flow 64
Diagram P&ID
E-23866-210-130, Sheet 2A Safety Injection and Containment Spray System Flow 20
Diagram P&ID
E-23866-210-130, Sheet 2B Safety Injection and Containment Spray System Flow 12
Diagram P&ID
E-23866-210-130, Sheet 3 Safety Injection and Containment Spray System Flow 18
Diagram P&ID
E-23866-210-130, Sheet Composite Flow Diagram Safety Injection and 53
COV Containment Spray System P&ID
A-3 Attachment
PROCEDURES
NUMBER TITLE REVISION
OI-AFW-1 Auxiliary Feedwater Actuation System Normal Operation 72
OI-CA-1 Compressed Air Normal Operation 62
OI-CC-1 Operating Instruction, Component Cooling System Normal Operation 65
OI-DG-1 Diesel Generator No. 1 47
OI-SC-1 Operating Instruction, Shutdown Cooling Initiation 48
OI-SI-1 Operating Procedure, Safety Injection - Normal Operation 115
OP-1 Operating Procedure, Master Checklist For Plant Startup 97
Section 1RO5: Fire Protection
PROCEDURES
NUMBER TITLE REVISION
AOP-6 Fire Emergency 21
EA-FC-97-001 Fire Hazards Analysis Manual 14
SO-G-28 Standing Order, Station Fire Plan 76
SO-G-58 Standing Order, Control of Fire Protection System Impairments 36
SO-G-91 Standing Order, Control and Transportation of Combustible 25
Materials
SO-G-102 Standing Order, Fire Protection Program Plan 8
SO-G-103 Standing Order, Fire Protection Operability Criteria And 23
Surveillance Requirements
FC05814 UFHA Combustible Loading 8
AOP-6-01 Fire Emergency, Auxiliary Building Radiation Controlled Areas 1
and Containment
AOP-6-02 Fire Emergency, Uncontrolled Areas of Auxiliary Building 0
AOP-6-03 Fire Emergency, Miscellaneous Areas 0
USAR 9.11 Updated Safety Analysis Report Fire Protection Systems 19
DRAWINGS
NUMBER TITLE REVISION
D-4147, Sheet 1 Containment & Auxiliary Building Elevation 1036 Portable Fire 8
Extinguisher Locations
A-4 Attachment
DRAWINGS
NUMBER TITLE REVISION
D-4147, Sheet 1 Containment & Auxiliary Building Roof Elevations Portable Fire 0
Extinguisher Locations
D-4147, Sheet 2 Auxiliary Building & Containment Elevation 1025-0 Portable Fire 6
Extinguisher Locations
Section 1R11: Licensed Operator Requalification Program
MISCELLANEOUS DOCUMENTS
TITLE DATE
Class Attendance Records for Simulator Evaluations September 8, 2008
Current operator license list from Fort Calhoun Station
Current Simulator Differences List
Open Simulator Discrepancy Reports (All)
Section 1R12: Maintenance Effectiveness
CONDITION REPORTS
200604163
PROCEDURES
NUMBER TITLE REVISION
PBD-16 Program Basis Document, Maintenance Rule 8
PED-SEI-34 Maintenance Rule Program 6
MISCELLANEOUS DOCUMENTS
Maintenance Rule Scoping Data Sheet CNTSMP
Maintenance Rule Scoping Data Sheet TSCBLG
Maintenance Rule Scoping Data Sheet TSCVAC
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
Work Orders
00326453 00335922 00331001
A-5 Attachment
PROCEDURES
NUMBER TITLE REVISION
DATE
ANSI N18.7 Administrative Controls for Nuclear Power Plants 1972
NOD-QP-36 Grid Operations and Control of Switchyard at Fort Calhoun Station 18
SO-M-100 Standing Order, Conduct of Maintenance 52
SO-M-101 Standing Order, Maintenance Work Control 83
MISCELLANEOUS DOCUMENTS
TITLE DATE
Summary of scheduled activities affecting plant risk week of July 20, 2009
Summary of scheduled activities affecting plant risk week of August 17, 2009
Summary of scheduled activities affecting plant risk week of Sept 6, 2009
Section 1R15: Operability Evaluations
Condition Reports
200303491 200303522 2009-2997 2009-3113 2009-3661
2009-3702 2009-3792
PROCEDURES
NUMBER TITLE REVISION
AOP-12 Loss of Containment Integrity 6
NOD-QP-31 Operability Determination Process (ODP) 40
OP-ST-DG-0001 Diesel Generator 1 Check 65
TDB VIII Technical Data Book, Equipment Operability Guidance 40
DRAWINGS
NUMBER TITLE REVISION
11405-M-252, Sheet COV Composite Flow Diagram Main Steam P&ID 42
11405-M-252, Sheet 1 Flow Diagram Steam P&ID 100
11405-M-252, Sheet 2 Flow Diagram Steam P&ID 14
11405-M-252, Sheet 3 Flow Diagram Steam P&ID 23
A-6 Attachment
MISCELLANEOUS DOCUMENTS
TITLE REVISION
ANSI B302.2.0-1976, Overhead and Gantry Cranes (Top Running Bridge, Multiple
Girder)
Updated Safety Analysis Report Section 9.4, Auxiliary Feedwater System 17
Various Control Room Operating Logs
Section 1R18: Plant Modifications
MISCELLANEOUS DOCUMENTS DATE
Temporary Modification Number EC47000, Soft Patch on 18 E Trash Grid August 24, 2009
Backwash Piping (CW System),
Section 1R19: Post Maintenance Testing
WORK ORDERS
00240532 00247270 00286329 00312810 00339628
003348570
PROCEDURES
NUMBER TITLE REVISION
IC-RR-VX-0409 Diagnostic Testing of Air Operated Valves 0
IC-ST-CCW-3001 Instrument Air Accumulator Check Valve Operability Test 7
IC-ST-IA-3010B Accumulator, Check Valve and Trip Valve Testing for Train 0
B 400 Series Containment Fan Cooler Inlet and Outlet
Valves
MD-AD-0013 Post Maintenance Testing Selection Instructions 3
MM-RR-CH-001 Inspection and Repair of Charging Pump Hydraulic Section 7
OP-ST-CCW-3001A Component Cooling Category B Valve Exercise Test 13
OP-ST-CCW-3005A Component Cooling Category A and B Valve Exercise Test 10
(for the A and B valves)
OP-ST-CH-3003 Chemical & Volume Control System Pump/Check Valve 51
Inservice Test
OP-ST-VX-3005A Component Cooling Water System Remote Position 4
Indicator Verification Surveillance Test
OP-ST-VX-3007A Component Cooling Water System Remote Position 3
Indicator Verification Surveillance Test
A-7 Attachment
PROCEDURES
NUMBER TITLE REVISION
PE-RR-VX-0424 Inspection and repair of Dresser industries Hancock Type 4
7150/7250 Globe valves
SO-M-100 Standing Order, Conduct of Maintenance 52
SO-M-101 Standing Order, Maintenance Work Control 84
DRAWINGS
NUMBER TITLE REVISION
11405-M-10, Sheet 1 Auxiliary Cooling Component Cooling System 66
Flow Diagram P&ID
11405-M-10, Sheet 2 Auxiliary Cooling Component Cooling System 17
Flow Diagram P&ID
11405-M-10, Sheet 3 Auxiliary Cooling Component Cooling System 24
Flow Diagram P&ID
11405-M-10, Sheet 4 Auxiliary Cooling Component Cooling System 11
Flow Diagram P&ID
11405-M-10, Sheet COV Composite Flow Diagram Auxiliary Cooling 29
Component Cooling System P&ID
11405-M-40, Sheet 1 Auxiliary Cooling Component Cooling System 36
11405-M-40, Sheet 2 Auxiliary Cooling Component Cooling System 34
11405-M-40, Sheet 3 Auxiliary Cooling Component Cooling System 23
11405-M-40, Sheet COV Composite Flow Diagram Auxiliary Cooling 9
Component Cooling System P&ID
E-23866- 2A210-120, Sheet 2B Chemical & Volume Control System P&ID 18
E-23866-210-120, Sheet 1 Chemical & Volume Control System P&ID 70
E-23866-210-120, Sheet 1A Chemical & Volume Control System P&ID 22
E-23866-210-120, Sheet 2A Chemical & Volume Control System P&ID 13
A-8 Attachment
DRAWINGS
NUMBER TITLE REVISION
E-23866-210-120, Sheet COV Composite Flow Diagram Chemical & Volume 42
Control System P&ID
E-23866-210-121, Sheet 1 Chemical & Volume Control System P&ID 50
E-23866-210-121, Sheet 2 Chemical & Volume Control System P&ID 13
E-23866-210-121, Sheet COV Composite Flow Diagram Chemical & Volume 13
Control System P&ID
Section 1R22: Surveillance Testing
CONDITION REPORTS
2009-3677 2009-0285 2009-0487 2009-0507 2009-1023
2009-1035 2009-1111 2009-2477 2009-3766
PROCEDURES
NUMBER TITLE REVISION
IC-ST-SA-3001B Starting Air Compressors Discharge Check Valve Exercise 0
Test
OI-CC-1 Component Cooling System Normal Operation 65
OP-ST-CCW-3001A Component Cooling Category B Valve Exercise Test 13
OP-ST-CCW-3005B Component Cooling Category A And B Valve Exercise Test 15
(for the C and D valves)
OP-ST-CCW-3022 AC-3C Component Cooling Water Pump Inservice Test 16
PBD-2 Program Basis Document, Inservice Inspection Program 11
PED-QP-33 Inservice Inspection and Inservice Test Program 7
SO-G-23 Standing Order, Surveillance Test Program 54
DRAWINGS
NUMBER TITLE REVISION
11405-M-10, Sheet 1 Auxiliary Cooling Component Cooling System Flow 66
Diagram P&ID
11405-M-10, Sheet 2 Auxiliary Cooling Component Cooling System Flow 17
Diagram P&ID
A-9 Attachment
11405-M-10, Sheet 3 Auxiliary Cooling Component Cooling System Flow 24
Diagram P&ID
11405-M-10, Sheet 4 Auxiliary Cooling Component Cooling System Flow 11
Diagram P&ID
11405-M-10, Sheet COV Composite Flow Diagram Auxiliary Cooling Component 29
Cooling System P&ID
B120F070001, Sheet 2 DG-2 Starting Air System 25
MISCELLANEOUS DOCUMENTS
TITLE Revision
Apparent Cause Analysis Report, Air Leak on Positioner for HCV-400C, CCW Outlet 1
Valve, Condition Report 2009-0487
Apparent Cause Analysis Report, VA-1A CCW Outlet Valve, HCV-400C, Failed to 0
Close During OP-ST-CCW-3005B, Condition Report 2009-1023
Updated Safety Analysis Report Section 4.5, Reactor Coolant System Test and 14
Inspections
Updated Safety Analysis Report Section 6.5, Engineered Safeguards Specific 15
References
Updated Safety Analysis Report Section 9.7, Component Cooling Water System 15
Section 1EP1: Exercise Evaluation
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION/DATE
Lesson Plan 1070-011: Exercise Controller and Evaluator 5
Training Student Handbook
Emergency Plan Implementation Refresher (Slide Show)
EP-08-022 Drill Evaluation Report: February 5, 2008
EP-08-066 Drill Evaluation Report: June 24, 2008
EP-08-129 Drill Evaluation Report: August 26, 2008
EP-08-185 Drill Evaluation Report: Hostile Action Drill November 6, 2008
EP-09-044 Drill Evaluation Report: First Quarter 2009 Training Drills January 20, 27,
and
February 10, 2009
A-10 Attachment
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION/DATE
EP-09-070 Drill Evaluation Report: May 19, 2009
EPIP-EOF-1 Activation of the Emergency Operations Facility 18
EPIP-EOF-21 Potassium Iodide Issuance 8
EPIP-EOF-6 Dose Assessment 38
EPIP-EOF-7 Protective Action Guides 19
EPIP-OSC-1 Emergency Classification 46
EPIP-OSC-15 Communicator Actions 23
EPIP-OSC-2 Command and Control Position Actions and Notifications 50
EPIP-OSC-21 Activation of the Operations Support Center 21
EPIP-OSC-9 Emergency Team Briefings 13
EPIP-RR-11 Technical Support Center Director Actions 17
EPIP-RR-21 Operations Support Center Director Actions 17
EPIP-TSC-1 Activation of the Technical Support Center 31
EPIP-TSC-8 Core Damage Assessment 19
FCSG-32 Work Week Management 18
CORRECTIVE ACTION DOCUMENTS
2009-1454 2009-2537 2009-3308 2009-3320 2009-3324
2009-3330 2009-3403
Section 4OA1: Performance Indicator Verification
PROCEDURE/DOCUMENTS
NUMBER TITLE REVISION/DATE
Condition Report 2009-0687 February 13, 2009
EPDM-14 Emergency Preparedness Performance Indicator Program 11
EPIP-EOF-7 Protective Action Guides 18,19
EPIP-OSC-1 Emergency Classification 44, 45, 46
EPIP-OSC-2 Command and Control Position Actions and Notifications 50
EPT-1 Alert Notification System Silent Test 15, 16
EPT-2 Alert Notification System Growl Test 19, 20
EPT-3 Alert Notification System Complete Cycle Test 14, 15
A-11 Attachment
MISCELLANEOUS DOCUMENTS
NUMBER TITLE REVISION
TDB-IV.7 Technical Data Book, Process Monitor Setpoints 215
CONDITION REPORTS
2008-4506 2008-4516 2008-4517 2008-4518 2008-4551
2008-4626 2008-4659 2008-4662 2008-4707 2008-4711
2008-4716 2008-4765 2008-4767 2008-4800 2008-4943
2008-4973 2008-5030 2008-5048 2008-5064 2008-5065
2008-5086 2008-5087 2008-5104 2008-5155 2008-5160
2008-5172 2008-5186 2008-5201 2008-5218 2008-5224
2008-5238 2008-5256 2008-5272 2008-5281 2008-5381
2008-5382 2008-5383 2008-5384 2008-5386 2008-5387
2008-5388 2008-5475 2008-5477 2008-5497 2008-5529
2008-5558 2008-5607 2008-5623 2008-5641 2008-5667
2008-5674 2008-5695 2008-5741 2008-5793 2008-5797
2008-5833 2008-5848 2008-5986 2008-6022 2008-6065
2008-6112 2008-6135 2008-6143 2008-6326 2008-6335
2008-6350 2008-6429 2008-6439 2008-6460 2008-6470
2008-6503 2008-6548 2008-6550 2008-6590 2008-6649
2008-6753 2008-6763 2008-6770 2008-6781 2008-6794
2008-6800 2008-6833 2008-6836 2008-6838 2008-6924
2008-6941 2008-6966 2008-6985 2008-7010 2008-7060
2008-7075 2008-7083 2008-7085 2008-7086 2008-7111
2008-7251 2008-7257 2009-0031 2009-0089 2009-0092
2009-0102 2009-0109 2009-0135 2009-0209 2009-0250
2009-0329 2009-0339 2009-0409 2009-0413 2009-0424
2009-0470 2009-0475 2009-0480 2009-0536 2009-0540
2009-0541 2009-0550 2009-0552 2009-0559 2009-0596
2009-0608 2009-0639 2009-0724 2009-0729 2009-0760
2009-0763 2009-0791 2009-0833 2009-0871 2009-0872
2009-0882 2009-0902 2009-0903 2009-0905 2009-0947
2009-0948 2009-0984 2009-1001 2009-1080 2009-1082
2009-1179 2009-1272 2009-1378 2009-1406 2009-1413
2009-1461 2009-1471 2009-1476 2009-1477 2009-1478
2009-1493 2009-1503 2009-1603 2009-1611 2009-1611
2009-1622 2009-1625 2009-1656 2009-1683 2009-1686
2009-1690 2009-1706 2009-1713 2009-1717 2009-1729
2009-1750 2009-1802 2009-1812 2009-1817 2009-1818
2009-1821 2009-1865 2009-1873 2009-1891 2009-1899
2009-1900 2009-1922 2009-1935 2009-2005 2009-2017
2009-2023 2009-2024 2009-2025 2009-2029 2009-2037
2009-2069 2009-2111 2009-2123 2009-2165 2009-2194
2009-2205 2009-2219 2009-2238 2009-2247 2009-2265
2009-2275 2009-2278 2009-2283 2009-2298 2009-2304
2009-2438 2009-2465 2009-2466 2009-2468 2009-2537
2009-2601 2009-2613 2009-2614 2009-2615 2009-2617
2009-2677 2009-2690 2009-2803 2009-2866 2009-2867
A-12 Attachment
CONDITION REPORTS
2009-2901 2009-2902 2009-2904 2009-2979 2009-2990
2009-3006 2009-3019
MISCELLANEOUS DOCUMENTS
TITLE REVISION/DATE
MSPIBD, Mitigating Systems Performance Index Basis 1
Document for Fort Calhoun Station
NEI 99-02, Regulatory Assessment Indicator Guideline 5
Procedure NOD-QP-37, Performance Indicators Program 16
Various Operator logs July 1, 2008 through June 30, 2009
Section 4OA2: Identification and Resolution of Problems
CONDITION REPORTS
2008-5514 2008-6481 2008-6511 2008-6485 2008-7425
2009-0181 2009-0019 2008-6824 2009-1446 2009-2070
2009-2096 2009-2118 2009-2607 2009-2614 2009-2892
2009-2732 2009-2997 2009-3002 2009-3063 2009-3089
2009-3108 2009-3113 2009-3148 2009-3186 2009-3243
2009-3177 2009-3915 2009-2466 2009-2468 2009-4236
2009-3294 2009-3300 2009-3305 2009-3394 2009-3476
2009-3501 2009-3507 2009-3547 2009-3570 2009-3576
2009-3583 2009-3622 2009-3802 2009-3843 2009-4031
2009-4257 2009-4258 2009-4308 2008-4922 2008-4936
2009-4521 2009-3873 200503564 200606023 2008-4865
2009-3964
WORK ORDERS
00263046 00345039
PROCEDURES
NUMBER TITLE REVISION
FCSG-45 Operator Challenge Program 2
GM-OI-HE-2 Auxiliary Building Crane Normal Operation 18
MISCELLANEOUS DOCUMENTS
TITLE REVISION/DATE
ANSI B302.2.0-1976, Overhead and Gantry Cranes (Top Running Bridge,
Multiple Girder)
A-13 Attachment
MISCELLANEOUS DOCUMENTS
TITLE REVISION/DATE
Dry Fuel Storage Recovery Action Plan July 2, 2009
EC41654, Site Acceptance Test, OPPD Fort Calhoun Aux Building 106 Ton X- 0
SAM Crane Upgrade
FC07539, NUHOMS 32PT-S100 Operational Lift Weight Calculation with 0
OS197-3 (OS197H) Cask
NUREG 0554, Single-Failure Proof Cranes for Nuclear Power Plants May, 1979
Operator Challenge List
Root Cause Analysis Report, HE-2, Auxiliary Building Crane Contacting FH- 0
12, Spent Fuel Handling Machine, Condition Report 2009-3302
Section 4OA5: Other Activities
CONDITION REPORTS
2007-1082 2007-1525 2008-4253 2008-6668 2009-0569
2009-1039 2009-2269 2009-2363 2009-2625 2009-2888
2009-2988 2009-3062
PROCEDURES
NUMBER TITLE REVISION
GM-OI-HE-2 Auxiliary Building Crane Normal Operation 20
OP-12 Fueling Operations 55
RE-AD-0005 Fuel Selection and DSC Planning for Dry Cask Storage 2
RE-RR-DFS-0001 DSC/TC Prep for Fuel Loading Operations 5
RE-RR-DFS-0002 Dry Shielded Canister Sealing Operations 8
RE-RR-DFS-0003 Loaded DSC/TC from Auxiliary building to ISFSI Operations 7
RE-RR-DFS-0004 DSC from TC to HSM Transfer Operations 6
MISCELLANEOUS DOCUMENTS
NUMBER TITLE REVISION
Fort Calhoun Station Independent Spent Fuel Storage 1
Installation 10 CFR 72.212 Evaluation Report, Docket 72-054
1004 Certificate of Compliance for Spent Fuel Storage Casks, 9
Docket 72-1004
1004 Attachment A Technical specifications - Transnuclear, Standardized 9
NUHOMS Horizontal Modular Storage System, Docket
72-1004
LR 721004-399 10 CFR 72.48 Applicability and 10 CFR 71 Review Form 1
A-14 Attachment
A-15 Attachment