ML13057A287

Fcscal Restart 2-26-13

ML13057A287
Person / Time
Site:	Fort Calhoun
Issue date:	02/26/2013
From:	Collins E Region 4 Administrator
To:	Cortopassi L Omaha Public Power District
References
EA-13-020 EA-13-020
Download: ML13057A287 (9)

Text

UNITE D S TATE S NUC LEAR RE GULATOR Y C OMMI S SI ON RE G IO N I V 1600 EAST LAMAR BLVD AR L INGTON , TEXAS 760 11 - 4511 February 26, 2013 EA-13-020 Lou Cortopassi, 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:

CONFIRMATORY ACTION LETTER - FORT CALHOUN STATION

Dear Mr. Cortopassi:

The purpose of this letter is to revise the enclosed Restart Checklist that describes the actions Omaha Public Power District (OPPD) has committed to take prior to the restart of Fort Calhoun Station. This revision adds three items to the Restart Checklist that was previously issued on June 11, 2012. The purpose of the Restart Checklist is to verify that the issues that resulted in the prolonged performance decline at Fort Calhoun Station are resolved. The Restart Checklist includes an assessment of each of the key attributes described in NRC Inspection Procedure 95003, Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs or One Red Input.

On December 13, 2011, the NRC informed you via letter1 that Fort Calhoun Station transitioned to Inspection Manual Chapter (IMC) 0350, Oversight of Reactor Facilities in a Shutdown Condition Due to Significant Performance and/or Operational Concerns. The IMC 0350 process was implemented at Fort Calhoun Station when the entry conditions were met. These conditions included the plant being in an extended shutdown with significant performance problems, and a significant operational event involving a fire in safety-related electrical switchgear on June 7, 2011.

The NRC recognizes that OPPD conducted a comprehensive review at Fort Calhoun Station to identify the causes for performance issues, identify and review the extent of cause and extent of condition related to these performance issues to fully understand the breadth of performance issues at Fort Calhoun Station, and implement corrective actions to address these performance issues. In addition, OPPD continues to assess any long term flooding effects from the 2011 Missouri River flood on Fort Calhoun Station systems, structures, and components.

On September 2, 2011, the NRC issued Confirmatory Action Letter (CAL) 4-11-0032.

CAL 4-11-003 confirmed OPPDs commitment to complete post-flooding recovery actions and other items important for restart of the facility. On June 11, 2012, the NRC issued CAL 4-12-0023 that incorporated all the committed-actions confirmed by CAL 4-11-003 and expanded the scope of activities to resolve the underlying performance issues at the facility that 1

Agencywide Document Access and Management System (ADAMS) Accession No. ML113470721 2

ADAMS Accession No. ML112490164 3

ADAMS Accession No. ML12163a287

L. Cortopassi were discovered after CAL 4-11-003 was issued. This CAL incorporates all the actions confirmed by CAL 4-12-002 and adds three activities OPPD committed to resolve at the facility prior to restart. This CAL supersedes CAL 4-12-002, therefore CAL 4-12-002 is closed. These letters and other materials associated with IMC 0350 oversight of the Fort Calhoun Station are available at http://www.nrc.gov/info-finder/reactor/fcs/special-oversight.html.

This revision to CAL 4-12-002 is being issued to reflect changes being made to the enclosed Restart Checklist. Specifically, as reported in the 3rd quarter of 2012, the Safety System Functional Failures Performance Indicator transitioned to White. This item will be added to Section 1 of the Restart Checklist, Causes of Significant Performance Defiencies and Assessment of Organizational Effectiveness. Two specific items involving qualification of containment electrical penetrations and containment internal structure deficiencies are being added to Section 2, Flood Restoration and Adequacy of Structures, Systems, and Components.

The actions described in this CAL are based on commitments made through discussions between OPPD and NRC staff during public meetings, onsite inspections, and oversight activities. In a phone conversation on February 15, 2013, I confirmed with you the commitments described below. This CAL confirms that Fort Calhoun Station will not operate above Hot Shutdown Condition (Operating Mode 3), as defined by technical specifications, until the NRC has completed its review of your actions listed below:

1. OPPD will identify the causes and implement corrective actions to address the safety significant NRC inspection findings and the Safety System Funtional Failures Performance Indicator listed in Items 1.a through 1.d and 1.g of the Restart Checklist.

2. OPPD will conduct a third-party safety culture assessment (Restart Checklist Item 1.e) and an integrated organizational effectiveness assessment (Restart Checklist Item 1.f) at Fort Calhoun Station and implement actions to address the results of these assessments.

3. OPPD will submit Flood Recovery Plan updates to the NRC for items 2.a and 2.b. That plan will include an assessment of the long term flooding impact at Fort Calhoun Station on plant systems, structures, and components and the basis for their readiness for restart. Additionally, OPPD will identify the causes and address the deficiencies associated with Items 2.c and 2.d.

4. OPPD will assess the Fort Calhoun Station programs and processes listed in Restart Checklist Item 3 to verify that they are adequate to support safe plant operation.

5. OPPD will submit Integrated Performance Improvement Plan updates to the NRC (Restart Checklist Item 4). Additionally, OPPD will implement the Integrated Performance Improvement Plan and provide a schedule for completing the plans actions.

6. OPPD will inform the NRC in writing of the results related to CAL actions 1 through 5 listed above.

L. Cortopassi This CAL will remain in effect until the NRC has (1) reviewed your response to the actions above, including responses to staffs questions and the results of your evaluations, and (2) provided written correspondence that the staff has concluded that OPPD has satisfactorily addressed the commitments contained in the Restart Checklist.

Issuance of this CAL does not preclude the issuance of an order formalizing the above commitments or requiring other actions on the part of OPPD; nor does it preclude the NRC from taking enforcement actions for violations of NRC requirements that may have prompted the issuance of this letter. Failure to take the actions as described in this CAL may also result in an order if the NRC determines that failure to meet that action would result in a loss of reasonable assurance of adequate protection of public health and safety and the environment.

Pursuant to Section 182 of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2232), you are required to:

1. Notify me immediately if your understanding differs from that set forth above;

2. Notify me if for any reason you cannot complete the actions and your proposed alternatives; and

3. Notify me in writing when you have completed the actions addressed in this Confirmatory Action Letter.

In accordance with 10 CFR 2.390 of the NRC's regulations a copy of this letter, its enclosures and your written response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/readingrm/adams.html (the Public Electronic Reading Room). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

L. Cortopassi Please contact Michael Hay at (817) 200-1147 if you have any questions concerning this letter.

Sincerely,

/RA/

Elmo E. Collins Regional Administrator Docket No.: 50-285 License No.: DPR-40

Enclosure:

U.S. NRC Manual Chapter 0350 Panel Fort Calhoun Station Restart Checklist cc w/ encl: Electronic Distribution

L. Cortopassi Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Acting Deputy Regional Administrator (Steve.Reynolds@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

Acting DRS Director (Thomas.Blount@nrc.gov)

Manual Chapter 0350 Panel Chairman (Anton.Vegel@nrc.gov)

Acting DRP Deputy Director (Michael.Scott@nrc.gov)

Acting DRS Deputy Director and Manual Chapter 0350 Panel Member (Jeff.Clark@nrc.gov)

Senior Resident Inspector and Manual Chapter 0350 Panel Member (John.Kirkland@nrc.gov)

Resident Inspector (Jacob.Wingebach@nrc.gov)

Branch Chief, DRP/F and Manual Chapter 0350 Panel Member (Michael.Hay@nrc.gov)

Senior Project Engineer, DRP/F (Rick.Deese@nrc.gov)

Project Engineer, DRP/F (Chris.Smith@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)

Project Manager and Manual Chapter 0350 Panel Member (Lynnea.Wilkins@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

Branch Chief, ORA/ACES (Heather.Gepford@nrc.gov)

Senior Enforcement Specialist, ACES (Ray.Kellar@nrc.gov)

Enforcement Specialist, ACES (Christi.Maier@nrc.gov)

OEMail Resource RIV/ETA: OEDO (John.Cassidy@nrc.gov)

Manual Chapter 0350 Panel Vice-Chairman (Louise.Lund@nrc.gov)

Manual Chapter 0350 Panel Member (Michael.Markley@nrc.gov)

Manual Chapter 0350 Panel Member (Joseph.Sebroski@nrc.gov)

Manual Chapter 0350 Panel Non-voting Member (Michael.Balazik@nrc.gov)

Incident Responsie Deputy Director/NSIR(Scott.Morris@nrc.gov)

DIRS Director/NRR(Ho.Nieh@nrc.gov)

DIRS Deputy Director/NRR(Allen.Howe@nrc.gov)

File located: R:\_REACTORS\_FCS\2012\CAL Restart Rev1 ADAMS: ML13057A287 SUNSI Rev Comp Yes No ADAMS Yes No Reviewer Initials MCH Publicly Avail Yes No Sensitive Yes No Sens. Type Initials MCH KEYWORD: 0350 PANEL, FORT CALHON STATION MC0350 Panel C:ORA/ACES RC:ORA C:DRP/F DRP: D MBalazik HGepford KFuller MCHay KMKennedy

/RA via Email/ /RA/ /RA/ /RA/ /RA/

2/13/13 2/11/13 2/12/13 2/11/13 2/8/13 MC 0350 Panel MC 0350 Panel MC 0350 Panel MC 0350 Panel MC 0350 Panel JClark MMarkley JSebroski JKirkland LWilkins

/RA/ /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/

1/30/13 2/10/13 2/12/13 2/11/13 2/11/13 MC 0350 V. Chmn MC 0350 Chmn RA D:NRR LLund AVegel ECollins ELeeds

/RA via Email/ /RA/ /RA/ /RA via Email/

2/8/13 2/14/13 2/26/13 2/15/13 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

U.S. Nuclear Regulatory Commission Manual Chapter 0350 Panel Fort Calhoun Station Restart Checklist Item Number Description Closure Date Causes of Significant Performance Deficiencies and 1

Assessment of Organizational Effectiveness 1.a Flooding Issue - Yellow finding 1.b Reactor Protection System contact failure - White finding 1.c Electrical bus modification and maintenance - Red finding 1.d Security - Greater than green findings 1.e Third-Party Safety Culture Assessment 1.f Integrated Organizational Effectiveness Assessment Safety System Functional Failures White Performance 1.g Indicator Flood Restoration and Adequacy of Structures, 2

Systems, and Components Flood Recovery Plan actions associated with facility and 2.a system restoration System readiness for restart following extended plant 2.b shutdown Enclosure

2.c Qualification of containment electrical penetrations 2.d Containment internal structure 3 Adequacy of Significant Programs and Processes 3.a Corrective Action Program 3.b Equipment design qualifications 3.c Design changes and modifications 3.d Maintenance programs 3.e Operability process 3.f Quality assurance 4 Review of Integrated Performance Improvement Plan Assesment of NRC Inspection Procedure 95003 Key 5

Attributes 5.a Design 5.b Human performance 5.c Procedure quality 5.d Equipment performance 5.e Configuration control 5.f Emergency response 5.g Occupational radiation safety 5.h Public radiation safety 5.i Security 6 Licensing Issue Resolution 6.a Review of necessary licensing amendments or actions 6.b Review of licensing commitments necessary for restart 7 Readiness for Restart 7.a Operations organization ready for restart Systems ready for restart and Mode restraints properly 7.b addressed 7.c Final review of corrective action program for restart items 8 Confirmatory Action Letter Resolution Verification that all restart-related Confirmatory Action Letter 8.a items are appropriately resolved 8.b Conduct public meeting regarding plant readiness for restart 9 Final Recommendation for Restart Manual Chapter 0350 Panel recommends restart to Region IV Administrator. Region IV Administrator obtains 9.a concurrence for restart from the Deputy Executive Director for Reactor and Preparedness Programs and the Director of the Office of Nuclear Reactor Regulation.