ML14042A238
| ML14042A238 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/10/2014 |
| From: | Hay M NRC/RGN-IV/DRP |
| To: | Cortopassi L Omaha Public Power District |
| Hay M | |
| References | |
| IR-13-019 | |
| Download: ML14042A238 (60) | |
See also: IR 05000285/2013019
Text
N U C LE AR R E GU LA TOR Y C OM MI S S I ON
R E G IO N I V
1600 EAST LAMAR BLVD
AR L I NG TO N , TE X AS 7 60 1 1 - 4511
February 10, 2014
Louis P. Cortopassi, Site Vice President
Omaha Public Power District
Fort Calhoun Station FC-2-4
P.O. Box 550
Fort Calhoun, NE 68023-0550
Subject: FORT CALHOUN - NRC INTEGRATED INSPECTION REPORT
NUMBER 05000285/2013019
Dear Mr. Cortopassi:
On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at the Fort Calhoun Station. On January 24, 2014, the NRC inspectors discussed the
results of this inspection with you and other members of your staff. Inspectors documented the
results of this inspection in the enclosed inspection report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements.
Further, inspectors documented a licensee-identified violation which was determined to be of
very low safety significance in this report. The NRC is treating this violation as non-cited
violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance of the NCV, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement,
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident
inspector at the Fort Calhoun Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region IV, and the NRC resident inspector at the
Fort Calhoun Station.
L. Cortopassi -2-
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your
response (if any) will be available electronically for public inspection in the NRCs Public
Document Room or from the Publicly Available Records (PARS) component of the NRC's
Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible
from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic
Reading Room).
Sincerely,
/RA/
Michael C. Hay, Chief
Project Branch F
Division of Reactor Projects
Docket No: 50-285
License No: DPR-40
Enclosure: NRC Inspection Report 05000285/2013019
w/Attachment: Supplemental Information
cc w/ encl: Electronic Distribution
[Accession Number]
SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials MCH
Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials MCH
SRI:DRP/F RI:DRP/F C:DRP/F
JKirkland JWingebach MHay
/RA/E-Hay /RA/E-Hay /RA/
2/10/14 2/10/14 2/10/14
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000285
License: DPR-40
Report: 05000285/2013019
Licensee: Omaha Public Power District
Facility: Fort Calhoun Station
Location: 9610 Power Lane
Blair, NE 68008
Dates: November 16 through December 31, 2013
Inspectors: J. Kirkland, Senior Resident Inspector
J. Wingebach, Resident Inspector
R. Deese, Senior Reactor Analyst
B. Larson, Senior Operations Engineer
P. Elkmann, Senior Emergency Preparedness Inspector
S. Sanchez, Senior Emergency Preparedness Inspector, Region II
B. Larson, Senior Operations Engineer
G. Skaggs Ryan, Reactor Inspector
C. Zoia, Operations Engineer (RIII/DRS/OB)
G. Apger, Operations Engineer
W. Sifre, Senior Reactor Inspector
D. Kern, Senior Reactor Inspector (RI/DRS/EB2)
J. Dean, Senior Reactor Engineer (NRR/DSS/SNPB)
J. Drake, Branch Chief
C. Norton, Project Manager (NRR/JLD/JPSB)
D. Stearns, Health Physicist
Approved By: Michael Hay, Chief
Project Branch F
Division of Reactor Projects
-1- Enclosure
SUMMARY
IR 05000285/2013019; 11/16/2013 - 12/31/2013; Fort Calhoun Station, Integrated Resident and
Regional Report; Annual Inspection of Operator Requalification Program; Emergency Plan
Biennial; and IMC 0350 Confirmatory Action Letter Inspections
The inspection activities described in this report were performed between November 16, 2013,
and December 31, 2013, by the resident inspectors at the Fort Calhoun Station and five
inspectors from the NRCs Region IV office and other NRC offices. One finding of very low
safety significance (Green) is documented in this report. This finding involved a violation of
NRC requirements. Additionally, NRC inspectors documented one licensee-identified violation
of very low safety significance. The significance of inspection findings is indicated by their color
(Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609,
Significance Determination Process. Their cross-cutting aspects are determined using
Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. Violations of
NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy. The
NRC's program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG 1649, Reactor Oversight Process.
Cornerstone: Emergency Preparedness
Green. A Green noncited violation was identified for the failure of the licensee to correct
deficiencies identified as a result of four exercises conducted between March 27, 2012, and
May 7, 2013, as required by 10 CFR 50.47(b)(14). Specifically, the licensee failed to correct
deficiencies associated with team briefing and tracking in the Operations Support Center
(OSC) identified as a result of exercises conducted March 27, 2012; July 17, 2012;
March 5, 2013; and May 7, 2013.
The inspectors determined that the licensees failure to correct deficiencies identified by
licensee evaluators is a performance deficiency within the licensees control. This finding is
more than minor because it affected the emergency preparedness cornerstone objective
and the Emergency Response Organization Performance cornerstone attribute. This finding
was evaluated using the Emergency Preparedness Significance Determination Process and
was determined to be of very low safety significance because it was a failure to comply with
NRC requirements, was not a risk significant planning standard function, and was not a loss
of planning standard function. The finding was not a loss of planning standard function
because the licensee adequately corrected some deficiencies identified in exercises
conducted in 2012 and 2013. The finding was entered into the licensees corrective action
system as Condition Report 2013-22495. The finding was assigned a cross-cutting aspect
of Problem Identification and Resolution because the finding was reflective of current
performance and the licensee did not take appropriate corrective action to address safety
issues and adverse trends P.1(d). (Section 1EP1)
-2-
Licensee-Identified Violations
A violation of very low safety significance that was identified by the licensee has been reviewed
by the inspectors. Corrective actions taken or planned by the licensee have been entered into
the licensees corrective action program. This violation and associated corrective action
tracking numbers are listed in Section 4OA7 of this report.
-3-
PLANT STATUS
The plant began the inspection period in mode 5, with all fuel in the reactor vessel. On
December 18, 2013, the plant reached criticality, and the generator output breakers were closed
on December 21, 2013. The plant reached 100% power on December 26, 2013, where it
remained for the rest of the reporting period.
REPORT DETAILS
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
(71111.11)
.1 Review of Licensed Operator Performance
a. Inspection Scope
On December 17 through December 24, 2013, the inspectors observed the performance
of on-shift licensed operators in the plants main control room. At the time of the
observations the plant was in a period of heightened activity due to the plant
startup. The inspectors provided continuous observation of the operators performance
of the plant startup and power ascension up to approximately 98% power. Additionally,
the inspectors observed non-licensed operator performance in the turbine and auxiliary
buildings, as well as the intake structure, during component startup to support the plant
startup. Over 350 hours0.00405 days <br />0.0972 hours <br />5.787037e-4 weeks <br />1.33175e-4 months <br /> of continuous observations were conducted.
In addition, the inspectors assessed the operators adherence to plant procedures,
including conduct of operations procedure and other operations department policies.
These activities constitute completion of one quarterly licensed operator performance
sample(s), as defined in Inspection Procedure 71111.11.
b. Observations
During these observations, inspectors regularly communicated observed behaviors to
management at Fort Calhoun Station and to the NRC. Positive behaviors observed
included adequate pre-job briefings, shift turnovers, control room supervision by station
management, reactivity control, surveillance testing, identification and control of new
operators and conservative decision making.
Several areas for improvement were identified that in some instances involved
unnecessary challenge to plant operators. These observations were discussed with
OPPD management as they were identified and included:
-4-
Inadequate vendor and station engineering support for turbine control system testing.
Operations staff did not receive the level of support expected when the newly
installed turbine control system operated erratically during power ascension. The
licensee was eventually able to make system adjustments and stabilize turbine
operation, but the delay in getting adequate technical support was an unnecessary
challenge to the operators.
The quality of the procedure used for testing of the new turbine control system was
poor, which slowed down test sequence.
Poor communications between the licensees Outage Control Center and Control
Room operators resulted in unnecessary delays in getting problems fixed (such as
malfunctioning control room annunciators).
The inspectors observed one example of a newly qualified operator
misunderstanding the operation of large feedwater system valve.
The inspectors observed one example of maintenance personnel not using
procedurally-required placekeeping tools (i.e. circle/slash), which resulted in a
missed procedural step and the need to re-perform the maintenance activity on a
non-safety related system.
Some inconsistencies were noted in documentation of control room and fire
impairment logs.
c. Findings
No findings were identified.
.2 Annual Inspection
The licensed operator requalification program involves two training cycles that are
conducted over a 2-year period. In the first cycle, the annual cycle, the operators are
administered an operating test consisting of job performance measures and simulator
scenarios. In the second part of the training cycle, the biennial cycle, operators are
administered an operating test and a comprehensive written examination. For this annual
inspection requirement, Fort Calhoun Station was in the first part of the training cycle.
a. Inspection Scope
The inspector reviewed the results of the operating tests for the station to satisfy the
annual inspection requirements.
On December 20, 2013, the licensee informed the lead inspector of the results,
11 of 11 crews passed the simulator portion of the operating test
-5-
46 of 49 licensed operators passed the simulator portion of the operating test
48 of 49 licensed operators passed the job performance measure portion of the
examination
The individuals that failed the simulator scenario portion of their operating test and the
individual who failed the job performance measure portion of their operating test were
successfully remediated, retested, and passed their retake operating test prior to
returning to licensed operator duties.
The inspector completed one inspection sample of the annual licensed operator
requalification program.
b. Findings
No findings were identified.
1R18 Plant Modifications (71111.18)
a. Inspection Scope
On December 4, 2013, the inspectors reviewed a temporary plant modification to provide
a furmanite repair of HCV-1108A, Steam Generator RC-2B Auxiliary Feedwater Inlet
Valve.
The inspectors verified that the licensee had installed this temporary modification in
accordance with technically adequate design documents. The inspectors verified that
this modification did not adversely impact the operability or availability of affected SSCs.
The inspectors reviewed design documentation and plant procedures affected by the
modification to verify the licensee maintained configuration control.
These activities constitute completion of one sample of temporary modifications, as
defined in Inspection Procedure 71111.18
b. Findings
No findings were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors observed one risk-significant surveillance test and reviewed test results
to verify that these tests adequately demonstrated that the structures, systems, and
components (SSCs) were capable of performing their safety functions,
December 4 2013, OP-ST-ESF-0001, Diesel Auto Start Initiating Circuit Check
-6-
The inspectors verified that this test met technical specification requirements, that the
licensee performed the tests in accordance with their procedures, and that the results of
the test satisfied appropriate acceptance criteria. The inspectors verified that the
licensee restored the operability of the affected SSCs following testing.
These activities constitute completion of one surveillance testing inspection sample, as
defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP1 Exercise Evaluation (71114.01)
a. Inspection Scope
The inspectors observed the biennial emergency preparedness exercise conducted
December 3, 2013, to determine if the exercise acceptably tested major elements of the
emergency plan and provided opportunities to demonstrate key emergency response
organization skills. The scenario simulated:
A vehicle crash affecting vital equipment in the intake structure;
A loss of offsite power to the site;
Failure of a diesel generator to start with a second diesel generator unavailable
due to maintenance, resulting in a station blackout condition;
A large-break loss of coolant accident inside containment;
Uncovering of the fuel leading to fuel damage and a zirconium-water reaction
producing an explosive atmosphere inside containment; and,
A hydrogen gas burn damaging the containment purge system to create a
release path to the environment,to demonstrate the licensee personnels
capability to implement their emergency plan.
The inspectors evaluated exercise performance by focusing on the risk-significant
activities of event classification, offsite notification, recognition of offsite dose
consequences, and development of protective action recommendations, in the Control
Room Simulator and the following dedicated emergency response facilities:
Operations Support Center
Emergency Operations Facility
-7-
The inspectors also assessed recognition of, and response to, abnormal and emergency
plant conditions, the transfer of decision making authority and emergency function
responsibilities between facilities, 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. The inspectors
also attended a subsequent formal presentation of critique items to plant management to
understand the performance issues observed by licensee evaluators.
The inspectors also reviewed nine licensee event after-action reports and exercise
evaluation reports to identify weaknesses and deficiencies previously evaluated by the
licensee.
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
Introduction. A Green noncited violation was identified for the failure of the licensee to
correct deficiencies identified as a result of four exercises conducted between
March 27, 2012, and May 7, 2013, as required by 10 CFR 50.47(b)(14).
Description. The NRC identified that Fort Calhoun Station had not corrected deficiencies
associated with the Operations Support Center (OSC) identified as a result of exercises
conducted March 27, 2012; July 17, 2012; March 5, 2013; and May 7, 2013.
The inspectors reviewed the licensees post-exercise evaluation reports and associated
corrective action program entries for exercises conducted March 27, 2012;
July 17, 2012; March 5, 2013; and May 7, 2013. The inspectors noted that Fort Calhoun
Station had identified that the following performance deficiencies had occurred during
previous exercises:
Weak implementation of priorities to mitigate the accident (March 27, July 17,
March 5, and May 7);
-8-
Delays in dispatching Operations Support Center teams to mitigate the accident
(March 27 and March 5); and
Pre-job and post-job briefings for Operations Support Center teams to mitigate
the accident that were incomplete or not performed (July 17, March 5, and
May 7)
The inspectors reviewed six condition reports (corrective action program entries)
generated by the licensee following the March 27, 2012; July 17, 2012; March 5, 2013;
and May 7, 2013, exercises and noted the following:
CR 2012-02381, Lack of Repair Team Control, opened March 28, 2012, closed
November 6, 2012. The licensee delivered refresher training for Non-Licensed
Operators (Action 2, closed June 21, 2012), delivered refresher training for
Maintenance Department work planners (Action 3, closed August 27, 2012), and
sent a post-exercise lessons-learned email to OSC staff reminding them to
review Procedure OSC-9, Emergency Team Briefings (Action 5, closed
October 19, 2012);
CR 2012-07779, Examples of teams dispatched from the OSC without
emergency work instructions being completed, opened July 17, 2012, closed
September 19, 2012. The licensee sent OSC staff an email, dated
September 6, 2012, reminding them to review Procedure OSC-9, Emergency
Team Briefings (Action 3, closed September 6, 2012);
CR 2013-05146, TSC Bypasses OSC Director to Brief Electricians, opened
March 7, 2013, closed April 1, 2013. Performance was discussed at the
licensees post-exercise critique and no additional action was taken (Action 2,
closed April 1 2013);
CR 2013-05263, Lack of OSC Team Debriefs, opened March 8, 2013, closed
May 3, 2013. The licensee sent post-exercise lessons-learned email, dated
March 29, 2013, to OSC staff reminding them to review Procedure OSC-9,
Emergency Team Briefings. The issue of a lack of post-job briefings was not
addressed in the March 29, 2013, email;
CR 2013-05363, Control Room directed OSC teams without going through the
OSC process, opened March 11, 2013, closed March 26, 2013. The licensee
conducted a coaching session on March 15, 2013, for the Shift Manager and
Control Room Supervisor participating in the March 5, 2013, exercise. No
additional corrective actions were taken, and
CR-2013-10486, Concens over OSC Priority Setting, opened May 10, 2013,
closed May 30, 2013. This condition report was administratively closed without
taking corrective action.
-9-
The inspectors subsequently observed emergency response organization performance
in the Operations Support Center during the December 3, 2013, exercise and identified
the following performance deficiencies:
Non-Licensed Operators present in the Operations Support Center were
assigned work by the Control Room and not by the Operations Support Center
Director;
Delays in forming and briefing repair and mitigation teams to be dispatched into
the plant;
Ineffective tracking of repair and mitigation teams in the plant, including,
o No documentation by Control Room staff of tasks assigned Non-Licensed
Operators;
o No tracking method for Non-Licensed Operators leaving the Operations
Support Center;
o A single team dispatched three times, each time with different individuals,
without appropriate records; and,
o Incomplete documentation as evidenced by log and/or tracking board
records documenting 12 repair and mitigation teams dispatched into the
plant, records of 15 repair and mitigation teams returning from the plant,
and 8 pre-job briefing forms completed in the Operations Support Center.
Ineffective pre-job briefings, including:
o One team leaving the Operations Support Center with direction to receive
its pre-job briefing from the Control Room;
o A lack of discussion of safety hazards in the plant during station blackout
conditions; for example, a lack of discussion of available lighting, and not
ensuring that flashlights and other portable lighting were taken into the
plant;
o A lack of discussion of other plant safety requirements; for example,
repair teams were not briefed to transport flammable liquids in approved
metal containers, and subsequently {simulated} the transport of
flammable liquids in open buckets; and,
o A lack of any pre-job briefings for Non-Licensed Operators.
The Operations Support Center did not conduct post-job briefings for repair and
mitigation teams returning to the facility after performing simulated work on plant
equipment.
- 10 -
The inspectors observed the licensees preliminary critique of emergency response
organization performance in the December 3, exercise, conducted December 5, 2013.
The licensee identified and entered into the corrective action program, instances of
Technical Support Center staff directing repair and mitigation teams without going
through the Operations Support Center Director, failures to brief repair and mitigation
teams about changing plant and radiological conditions, and shortcuts in the work
planning process for repair and mitigation teams.
The inspectors determined that the performance deficiencies observed by the licensee in
the exercises conducted March 27, 2012; July 17, 2012; March 5, 2013; and
May 7, 2013, would preclude the effective implementation of the emergency plan if they
were to occur during an actual radiological emergency. Specifically, a lack of adequate
pre-job and post-job work briefings, lack of adequate controls over Non-Licensed
Operators, and delays in dispatching repair and mitigation teams could prevent the
licensee from bringing the plant into a safe and stable condition and terminating
radiological releases affecting the public. Inspectors also determined the licensee relied
on individual coaching and post-exercise emails as corrective actions for deficiencies
observed during exercises, with an emphasis on individual (e.g. non-directed) review of
Procedure OSC-9, Emergency Team Briefings. The inspectors concluded that
corrective actions for the exercises conducted March 27, 2012; July 17, 2012;
March 5, 2013; and May 7, 2013; were ineffective, in that the issues continued to re-
occur, and also recurred during the December 3, 2013, exercise. In addition, the
licensee repeated the same corrective actions multiple times without achieving results,
and did not evaluate their effectiveness. The inspectors concluded from the above
information that deficiencies identified as a result of exercises had not been
appropriately corrected as required by 10 CFR 50.47(b)(14).
The inspectors determined that some deficiencies identified by the licensee following the
exercises conducted March 27, 2012; July 17, 2012; March 5, 2013; and May 7, 2013,
had been corrected and did not recur during the December 3, 2013, exercise. These
deficiencies included a lack of sufficient Radiation Protection Technician support in the
Operations Support Center, emergency worker briefings for issuance of potassium
iodide that were ineffective or not performed, poor strategies for directing offsite
environmental monitoring, and degraded radiation protection for emergency workers in
the Technical and Operations Support Centers.
Analysis. A deficiency (weakness) is defined in Manual Chapter 0609, Appendix B,
Section 2.(o), as a level of performance by the emergency response organization
demonstrated during an exercise that would preclude effective implementation of the
emergency plan if it were to occur during an actual radiological emergency. The
inspectors determined that the licensees failure to correct deficiencies identified by
licensee evalutors as a result of four exercises conducted in 2012 and 2013 is a
performance deficiency within the licensees control. Specifically, the licensee did not
correct deficiencies in its ability to assign work to Operations Support Center teams, and
to dispatch and track work teams. This finding is more than minor because it affected
the emergency preparedness cornerstone objective and the Emergency Response
- 11 -
Organization Performance cornerstone attribute. The finding affected the emergency
preparedness cornerstone objective because an inability to dispatch and track
emergency work teams may prevent the licensee from implementing adequate
measures to protect the health and safety of the public during a radiological emergency.
The finding was associated with a violation of NRC requirements. This finding was
evaluated using the Emergency Preparedness Significance Determination Process and
was determined to be of very low safety significance because it was a failure to comply
with NRC requirements, was not a risk significant planning standard function, and was
not a loss of planning standard function. The finding was not a loss of planning standard
function because the licensee adequately corrected some deficiencies identified as a
result of exercises conducted in 2012 and 2013. The finding was assigned a cross-
cutting aspect in the area of Problem Identification and Resolution because the finding
was reflective of current performance and the licensee did not take appropriate
corrective action to address safety issues and adverse trends P.1(d).
Enforcement. Title 10 of the Code of Federal Regulations, Part 50.47(b)(14) states, in
part, that Periodic exercises are conducted to evaluate major portions of emergency
response capabilitiesdeficiencies identified as a result of exerciseswill be corrected.
Contrary to the above, Fort Calhoun Station failed to correct deficiencies identified as a
result of exercises. Specifically, Fort Calhoun did not correct deficiencies in the
assignment of work to Operations Support Center teams, and the dispatch and tracking
of in-plant work teams, identified in four exercises between March 27, 2012, and
May 7, 2013. Because this failure is of very low safety significance and has been
entered into the licensees corrective action system as Condition Report 2013-22495,
this violation is being treated as an NCV, consistent with Section 2.3.2(a) of the NRC
Enforcement Policy: 05000285/2013019-01, [Failure to Correct Deficiencies in
Operations Support Center Functions].
4. OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
Security
4OA2 Problem Identification and Resolution (71152)
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items
entered into the licensees corrective action program and periodically attended the
licensees condition report screening meetings. The inspectors verified that licensee
personnel were identifying problems at an appropriate threshold and entering these
problems into the corrective action program for resolution. The inspectors verified that
the licensee developed and implemented corrective actions commensurate with the
significance of the problems identified. The inspectors also reviewed the licensees
- 12 -
problem identification and resolution activities during the performance of the other
inspection activities documented in this report.
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)
.1 (Closed) Licensee Event Report 05000285/2012-017-01: Containment Valve Actuators
Design Temperature Ratings Below those Required for Design Basis Accidents
While performing an extent of condition review associated with the adequacy of air
operated equipment inside containment to withstand containment main steam line break
(MSLB) and loss of coolant accident (LOCA) temperatures, it was discovered that the
Reactor Coolant System (RCS) Loop 1A Charging Line Stop Valve, the RCS Loop 2A
Charging Line Stop Valve, and the Pressurizer RC-4 Auxiliary Spray Inlet Valve have nitrile
based elastomers used in the air filter regulator and actuator. The design temperature limit
for the nitrile elastomers used in the valves is 180°F which is acceptable for the normal
operating conditions inside containment of 120°F. However, during the main steam line
break and loss of coolant accident the temperature inside containment is analyzed to
reach 370°F. Since these valves have both open and close functions supported by an air
accumulator, failure of the nitrile based elastomers could prevent the valves from fulfilling
their intended safety function.
The causal analysis did not determine why the nitrile elastomers were installed during
original plant construction. However, it was determined that a procedural deficiency and
human error resulted in the wrong type of elastomer material being used in the instrument
air filter regulators when the air accumulators were added to the valves to support their
safety function.
The licensee event report is closed. Revision 2 of this licensee event report was submitted
on December 6, 2013.
.2 (Opened) Licensee Event Report 05000285/2012-017-02: Containment Valve Actuators
Design Temperature Ratings Below those Required for Design Basis Accidents
On July 26, 2012, while performing an extent of condition review associated with air
operated valves (AOV), it was discovered that several valves had nitrile based elastomers
used in the air filter regulator and actuator that may not be acceptable for harsh environment
conditions. On September 6, 2012, it was also identified that due to a lack of
documentation, the States terminal blocks associated with the AOV's control circuit may not
be acceptable for harsh environment conditions. These were entered into the station's
corrective action program as Condition Report 2012-08621 and 2012-12739.
During design basis accidents, the limiting analysis temperature inside containment
is 374.2 degrees Fahrenheit (F). The design service temperature for the nitrile elastomers
is 180 degrees Fahrenheit and the testing performed on the States terminal blocks did not
- 13 -
bound the required accident conditions. Since these valves have both open and/or close
functions, failure of the nitrile based elastomers or the States terminal blocks could prevent
the valves from fulfilling their intended safety function.
A causal analysis was conducted and found that the station did not fully implement and or
maintain the electrical equipment qualification program. This resulted in a lack of
qualification documentation and equipment not qualified for expected design basis accident
conditions.
.3 (Closed) Licensee Event Report 05000285/2013-001-00: Mounting of GE HFA Relays does
not Meet Seismic Requirements
On January 15, 2013, while reviewing a previous condition report, it was identified that a
previous operability determination (OD) completed for General Electric (GE) model HFA
relays was incorrect in that it did not appear to fully address the condition of the mounting
screws that required torqueing. The seismic test results stated that the GE HFA relays
passed the seismic testing, but the relays required two screws to be torqued to 5 foot-
pounds. This condition of the additional required torqueing was initially entered into the
corrective action program on December 21, 2012.
Currently, approximately 136 relays, that provide various indication and control functions in
systems such as high pressure safety injection, charging, containment ventilation, and the
emergency diesel generator, have been identified as potentially affected. Relay
replacement/torqueing is in progress. A cause analysis is in progress, the results of which
will be published in a supplement to this LER.
The licensee event report is closed. Revision 1 of this licensee event report was submitted
on December 5, 2013.
.4 (Opened) Licensee Event Report 05000285/2013-001-01: Mounting of GE HFA Relays
does not Meet Seismic Requirements
On January 15, 2013, while reviewing a previous condition report, it was identified that the
initial I operability determination (OD) completed for General Electric (GE) model HFA relays
was incorrect in that it did not appear to fully address the condition of the mounting screws
that required torqueing. The seismic test results stated that the GE HFA relays passed the
seismic testing, but the relays required two back plate mounting screws to be torqued
to 5 foot-pounds. The condition of the additional required torqueing had been initially
entered into the corrective action program on December 21, 2012.
Approximately 136 relays that provide various indication and control functions in systems
such as high pressure safety injection, charging, containment ventilation, and the
emergency diesel generator, were identified as potentially affected. Relay replacement
torqueing has been completed for all identified relays. An investigation found that poor
communication (both in writing of technical documents and in interfacing between
individuals) was the cause of not identifying the need for the two back plate mounting
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screws to be torqued to 5 foot-pounds when first reported by the vendor. Corrective actions
to provide training on the event and revise procedures have been initiated.
.5 (Closed) Licensee Event Report 05000285/2013-003-00: Calculations Indicate the HPSI
Pumps will Operate in Run-out During a DBA
At approximately 1721 Central Standard Time, on January 30, 2013, during hydraulic
evaluations for the alternate hot leg injection project, Design Engineering determined that
design basis calculations indicated that the high pressure safety injection (HPSI) pumps
would operate in a run-out condition under worst case design basis accident conditions.
Previous changes to the operation of the HPSI pumps and the containment spray pumps
have resulted in an increase in the injection phase time and an increase in HPSI pump flow
during the accident. This could have resulted in the HPSI pumps operating in run-out for
longer than the one hour manufacturer's recommended time limit.
A preliminary causal analysis identified that the station failed to obtain vendor technical
information on HPSI pump performance in a 10 CFR 50, Appendix B, Quality Assurance
validated format. An analysis of HPSI pump performance during the injection phase will be
performed and design or procedural actions to prevent HPSI pump operation in the
extended flow region and to ensure that sufficient net positive suction head is available will
be taken.
The licensee event report is closed. Revision 1 of this licensee event report was submitted
on November 27, 2013.
.6 (Opened) Licensee Event Report 05000285/2013-003-01: Calculations Indicate the HPSI
Pumps will Operate in Run-out During a DBA
At approximately 1721 Central Standard Time, on January 30, 2013, during hydraulic
evaluations for the alternate hot leg injection project, Design Engineering determined that
the high pressure safety injection (HPSI) pumps would operate in a run-out condition under
worst case design bases accident conditions. The calculated HPSI pump flow is beyond the
manufacturer's head-flow curves developed from original pump testing. The station was
shutdown in Mode 5 when discovered and the condition was entered into the station's
corrective action program as Condition Report 2013-02100. The HPSI pumps were
declared inoperable.
A causal analysis identified that the initial HPSI pump cross-tie valve (HCV-304 and HCV-
305) required position, impeller design, and runout characteristics identified during pre-
operational testing were not translated into design and licensing basis documents. This
allowed several HPSI system configuration and procedural changes that reduced the margin
to reliable pump operation. A new analysis shows that a new design flow rate of 450 gpm is
acceptable for up to 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />. Orifices have been installed and tested that limits
maximum flow to prevent the HPSI pumps from operating beyond 450 gpm during a design
basis accident.
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.7 (Closed) Licensee Event Report 05000285/2013-008-00: Previously Installed GE IVA
Relays Failed Seismic Testing
On April 11, 2013, the test results of seven General Electric (GE) IAV relays indicated that
three safety-related, seismically qualified, relays did not pass seismic testing. The condition
was entered in to the Station's corrective action program. A causal analysis determined that
the failure was caused by the control spring in the relay contacting either the disk or the drag
magnet during seismic testing resulting in a short. A wire used to support the spring was not
installed in the relays that failed the testing, allowing the control spring to sag and make
electrical contact.
There are a total of 45 GE IAV relays identified in the plant, of which 32 are safety-related.
Twelve of these had previously been replaced and two more were verified to have the
support wire installed. The remaining 18 relays will be inspected, and if the support wire is
missing, they will be replaced prior to plant startup.
The licensee event report is closed. Revision 1 of this licensee event report was submitted
on December 18, 2013.
.8 (Opened) Licensee Event Report 05000285/2013-008-01: Previously Installed GE IVA
Relays Failed Seismic Testing
On April 11, 2013, the test results of seven General Electric (GE) IVA relays, indicated that
three safety-related, seismically qualified, relays did not pass seismic testing. The condition
was entered into the Station's corrective action program. A causal analysis determined that
the failure was caused by the control spring in the relay contacting either the disk or the drag
magnet during seismic testing resulting in a short. A wire used to support the spring was not
installed in the relays that failed the testing allowing the control spring to sag and make
electrical contact.
There are a total of 4 GE IAV relays identified in the plant, of which 32 are safety-related.
Twenty-seven of the relays required replacement due to missing the support wire.
.9 (Opened) Licensee Event Report 05000285/2013-014-00: Unqualified Components used in
Safety System Control Circuit
On October 3, 2013 station personnel identified that a condition with the control loop for
HCV-1369, Turbine-Driven Auxiliary Feedwater Pump FW-10 Recirculation Valve, was
incorrectly evaluated as not reportable. The original condition was identified on
October 18, 2012, which identified unqualified components in the control loop whose failure
could cause a spurious closure of HCV-1369 and result in pump damage. The station was
shutdown in MODE 5 when discovered.
The condition was entered in to the station's corrective action program as Condition
Report 2013-18752. Engineering is reviewing this condition and the results of this review
will be used to update this report. This report was previously submitted on
December 9, 2013 with a duplicate LER number.
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.10 (Opened) Licensee Event Report 05000285/2013-017-00: Containment Spray Pump
Design Documents do not Support Operation in Runout
Fort Calhoun Station (FCS) has identified that design basis documents for the containment
spray (CS) pumps SI-3A, SI-3B and SI-3C did not fully support pump operation during
runout conditions which could occur under certain system configurations. On
October 31, 2013, additional design work was completed which showed that the
containment spray pumps would not meet their required mission time under specific
accident scenarios. However, the analysis also showed that the containment peak pressure
for the limiting design basis accident occurs at 202.3 seconds, which is prior to the
containment spray delay time of 228.2 seconds. Therefore, the peak containment pressure
would not be affected by this failure.
Fort Calhoun Station has completed a calculation necessary to support a temporary
modification which throttles the containment spary pump discharge valves to increase
system resistance. A new containment spray pump curve has been issued to include
operation in the extended pump operating range. A permanent modification to prevent
containment spray pump runout is being pursued.
.11 (Opened) Licensee Event Report 05000285/2013-018-00: Postulated Fire Event Could
Result in Shorts Impacting Safe Shutdown
On October 9, 2013, an event notification applicable to Callaway Nuclear Power Plant was
posted that documented a postulated fire event regarding the impact of unfused direct
current (DC) ammeter circuits in the control room (CR). In the postulated event, a fire in the
control room could cause one of the ammeter wires to short to the ground plane.
Simultaneously, if the fire causes another direct current wire from the opposite polarity on
the same battery to also short to the ground plane, a ground loop would be established
through the unprotected ammeter wiring. This event could result in excessive current flow
(heating) in the ammeter wiring to the point of causing a secondary fire in the raceway
system. The secondary fire could adversely affect safe shutdown equipment and potentially
result in the loss of the ability to conduct a safe shutdown as required by 10 CFR50
Appendix R. Plant engineering personnel reviewed the information against station electrical
schematics and at approximately 1230 central daylight time on October 28, 2013, an 8-hour
notification was made pursuant to 10 FR 50.72(b)(3)(ii)(8). The station was in Mode 5 when
the condition was identified.
An hourly fire watch was established in the affected locations of the station. Fort Calhoun
Station will install fuses in the direct current ammeter circuitry as determined by Engineering
Change 62826, Add Fuses to the direct current Ammeter Circuitry for Ammeters.
4OA4 IMC 0350 Inspection Activities (92702)
Inspectors continued implementing IMC 0350 inspection activities, which include follow-up on
the restart checklist items contained in the Confirmatory Action Letter (CAL) issued
February 26, 2013 (EA-13-020, ML 13057A287). The purpose of these inspection activities is to
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assess the licensees performance and progress in addressing its implementation and
effectiveness of Fort Calhoun Stations Integrated Performance Improvement Plan (IPIP),
significant performance issues, weaknesses in programs and processes, and flood restoration
activities.
Inspectors used the criteria described in baseline and supplemental inspection procedures,
various programmatic NRC inspection procedures, and IMC 0350 to assess the licensees
performance and progress in implementing its performance improvement initiatives. Inspectors
performed on-site and in-office activities, which are described in more detail in the following
sections of this report. This report covers inspection activities from November 16 through
December 31, 2013. Specific documents reviewed during this inspection are listed in the
attachment.
The following inspection scope, assessments, observations, and findings are documented by
CAL restart checklist item number.
.1 Causes of Significant Performance Deficiencies and Assessment of Organizational
Effectiveness
Section 1 of the restart checklist contains those items necessary to develop a
comprehensive understanding of the root causes of safety-significant performance
deficiencies identified at Fort Calhoun Station. In addition, Section 1 includes the
independent safety culture assessment with the associated root causes and findings. The
integration of the assessments under Item 1.f identifies the fundamental aspects of
organizational performance in the areas of organizational structure and engagement,
values, standards, culture, and human behaviors that have resulted in the protracted
performance decline and are critical for sustained performance improvement. Section 1
reviews also include an assessment against appropriate NRC Inspection Procedure 95003
key attributes. These assessments are documented in section 4OA4.5.
.a Flooding Issue - Yellow Finding
Item 1.a is included in the restart checklist for the failure of Fort Calhoun Station to
maintain procedures and equipment that protects the plant from the effects of a design
basis flood. These deficiencies resulted in a yellow (substantial safety significance)
finding.
(1) Inspection Scope
i. The team assessed the licensees actions taken since NRC Inspection
Report 05000285/2013008. As documented in NRC Inspection
Report 05000285/2013008, the inspectors reviewed this area for closure and noted
discrepancies in the extent of condition area and a number of deficiencies noted in
the technical bases for the flooding procedure which led to restart checklist
items 1.a.1, 1.a.2, and 1.a.3 remaining open. The inspectors reviewed licensee
actions to address the inspectors concerns to ascertain whether they were sufficient
to ensure plant safety and support closure of the restart checklist items.
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ii. Open items (Licensee Event Reports (LER) and violations (VIO) for this portion of
the restart checklist) specifically related to the Yellow finding were reviewed by the
team. The team reviewed the adequacy of the licensees causal analyses and extent
of condition evaluations related to the associated deficiencies that protect the plant
from the effects of a design basis flood. In addition, the NRC verified that adequate
corrective actions were identified associated with the licensees causal analyses and
extent of condition evaluations and that implementation of these corrective actions
were either implemented or appropriately scheduled for implementation.
Open items reviewed were:
LER 2012-001, Inadequate Flooding Protection Procedure
LER 2012-019, Traveling Screen Sluice Gates Found with Dual Indication
LER 2011-003, Inadequate Flooding Protection Due to Ineffective Oversight
VIO 2012002-01, Inadequate Procedures to Mitigate a Design Basis Flood Event
VIO 2012002-02, Failure to Classify Intake Structure Sluice Gates as Safety
Class III
VIO 2012002-03, Failure to Meet Design Basis Requirements for Design Basis
Flood Event
VIO 2010007-01, Failure to Maintain External Flood Procedures
(2) Observations and Findings
i. Resolution of Root Cause, Corrective Action, and Extent of Condition Issues
a) Licensees Evaluations and Associated Improvement Actions Related to the Yellow
Flooding Finding
From previous inspections, the major aspects which the licensee had not adequately
addressed for the root cause analyses and associated efforts for the Yellow flooding
finding were extent of condition review and addressing deficiencies in the technical
bases for the licensees flood mitigation procedures. The inspectors reviewed
licensee actions below.
Resolution of Extent of Condition Review Weaknesses. In NRC Inspection
Report 05000/285/2013008, the team noted several areas where the licensee had
not adequately addressed the extent of condition of the inadequate flooding
procedure. Inspectors identified the following observations which were previously
documented related to extent of condition.
URI 05000285/2013008-01, Inadequate Procedure for Combatting Frazil Ice
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FIN 05000285/2013008-02, Frazil Ice Monitor Not Operational
NCV 05000285/2013008-03, Lack of Safety-Related Equipment For Design
Basis Low River Level
NCV 05000285/2013008-04, Non-conservative Value for Declaring An Alert
on Low River Level
NCV 05000285/2013008-05, Inadequate Procedure for Combating Loss of
Raw Water
The inspectors observed that the licensee had entered each of these conditions into
their corrective action program for resolution.
To address the overall concern that the licensees review of the extent of condition
for the inadequate procedure which led to the Yellow flooding finding, the licensee
performed additional reviews of their abnormal operation procedures. Additionally,
the licensee has post-restart actions in place to perform additional reviews
associated with a procedural quality improvement effort that is part of the licensees
Performance Improvement Integrated Matrix (PIIM). Action Numbers 2013-0031
and 2013-0086 of the PIIM cover the procedural improvement program by the
licensee.
The inspectors determined that the licensees actions addressing the identified
deficiencies associated with the extent of condition coupled with the licensee
conducting a procedure improvement initiative were adequate to address the
weaknesses in the licensees extent of condition review for the Yellow flooding
finding.
Resolution of Procedural Technical Bases Observations. In NRC Inspection
Report 05000/285/2013008, the team noted several areas where the licensee had
not adequately addressed weaknesses in the technical bases of the flooding
mitigation procedures. The team reviewed the technical bases for procedural steps
in the revised flooding procedure. The technical bases prove that the procedures
and the equipment they call upon would work when demanded under a design basis
flood. In Inspection Report 05000285/201008, the team identified the following
issues related to FCS personnels ability to adequately address technical
inadequacies in the procedures to mitigate flooding:
NCV 05000285/2013008-06, Failure to Account for Worst Case Conditions
in Fuel Oil Inventory Calculation
URI 05000285/2013008-07, Administrative Controls for a Technical
Specification for Low River Level
NCV 05000285/2013008-08, Sluice Gate Leakage Not Periodically Verified
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NCV 05000285/2013008-09, Failure to Prevent Failures of the Sluice Gates
to Close
NCV 05000285/2013008-10, Failure to Accurately Model Raw Water Flow
into the Intake Structure
NCV 05000285/2013008-11, Failure to Account for Usable Fuel Oil Tank
Level in Inventory
The inspectors observed that the licensee had entered each of these conditions into
their corrective action program for resolution.
To address the overall concern with inadequacies in the technical bases of their
flooding mitigation procedures, the licensee performed additional reviews of their
abnormal operation procedure for acts of nature, their emergency plan implementing
procedures, and their second level support procedures called on in their flooding
procedure AOP-01, Acts of Nature. This review and future reviews were and will
be part of the larger review performed for the procedural quality improvement effort
post restart as part of the PIIM. Action Numbers 2013-0031 and 2013-0086 of the
PIIM cover the procedural improvement program by the licensee.
The team concluded that Fort Calhoun Station had adequately resolved the identified
technical issues associated with technical bases for their flooding mitigation
procedures by their actions to address the identified deficiencies coupled with the
effort to conduct a procedure improvement initiative as described in the their PIIM.
Conclusion
The inspectors determined that the licensee had adequately addressed the extent of
condition and procedural technical bases areas which had previously been of
concern associated with Restart Checklist Bases Document Items 1.a.1, Flooding
Yellow Finding root and contributing cause evaluation, 1.a.2, Flooding Yellow
Finding extent of condition and cause evaluation, and 1.a.3, Flooding Yellow
Finding corrective actions addressing root and contributing causes.
Items 1.a.1, 1.a.2, and 1.a.3 are closed.
ii. Resolution of Open Items Related to the Yellow Flooding Finding on the Restart
Checklist Basis Document
a) LER 2012-001, Inadequate Flooding Protection Procedure
Licensee Event Report LER 2012-001 documented the deficiencies in Procedure
AOP-01, Acts of Nature, that were associated with the NRC Yellow finding.
The inspectors reviewed and closed the causal analyses, corrective actions, and
extent of condition for this issue in Section a above.
This LER is closed.
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b) LER 2012-019, Traveling Screen Sluice Gates Found with Dual Indication
Licensee Event Report LER 2012-019 documented a condition where intake
sluice gates were found with dual indication. With this indication, the position of
the sluice gates could not be positively confirmed to be closed as required by the
licensees flood procedure. The licensee entered this condition into their CAP
and reviewed the licensees corrective actions. The licensee took action to close
the sluice gates and ensure the flooding mitigation feature was restored. The
inspectors began inspection of this item in NRC Inspection
Report 05000285/2012012 and included its review under Finding
FIN 5000285/2012012-03, Failure to Properly Manage the Functionality of the
River Sluice Gates. To address any future concerns with conflicting information
for the position of the sluice gates, the licensee revised their maintenance
procedure to provide an affirmative method of ensuring the sluice gates were
closed. The inspectors reviewed this method and considered the method
adequate.
This LER is closed.
c) LER 2011-003, Inadequate Flooding Protection Due to Ineffective Oversight
Licensee Event Report LER 2011-003 documented that the predominant cause
of the Yellow flooding finding for an inadequate flooding mitigation procedure was
historical ineffective oversight by station management. The licensee came to this
conclusion as a result of their root cause analyses. The inspectors noted that
station management had been changed and new managers in the principal
positions were supplied in an operating agreement with Exelon Nuclear. The
remaining aspects for the inadequate flooding protection were addressed under
CR 2010-2387. The inspectors reviewed this and the licensees actions during
the review of the causal analyses, corrective actions, and extent of condition for
this issue in Section a above.
This LER is closed.
d) VIO 2012002-01, Inadequate Procedures to Mitigate a Design Basis Flood
Event
Violation VIO 2012004-01 documented multiple examples of a violation of
Technical Specification 5.8.1.a, Procedures, for failure to establish and maintain
procedures to mitigate an external flooding event. The procedural guidance for
flooding was inadequate to mitigate the consequences of external flooding. The
inadequacies were a failure to provide operators with sufficient information to
ensure a transfer of power from offsite to an onsite emergency diesel generator
prior to a loss of offsite power; a failure to identify that the class-1E powered
motor operators of the six intake structure sluice gates were located at an
elevation of 1,010 feet mean sea level (below the design basis flood level); a
failure to identify that three of the six sluice gate motor operators would be de-
energized when offsite power was transferred from offsite to one onsite
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emergency diesel generator; and a failure to adequately ensure the fuel transfer
hose to emergency diesel generator day tanks was staged prior to river level
exceeding 1,004 feet mean sea level. The licensee entered these conditions into
their CAP as Condition Report CR 2010-2387. The inspectors reviewed the
licensees corrective actions.
The failures were adequately corrected by the licensee with procedure revisions.
The inspectors conducted walkthroughs with licensee operators and
maintenance personnel in the simulator to ensure the revisions adequately
addressed the issues.
This violation is closed.
e) VIO 2012002-02, Failure to Classify Intake Structure Sluice Gates as Safety
Class III
Violation VIO 2011002-02 documented a violation of 10 CFR Part 50, Appendix
B, Criterion III, Design Control, for failure of the licensee to classify the six
intake structure exterior sluice gates and their motor operators as Safety Class
III. Inspectors identified that the licensees previous mitigation scheme to raise
and lower the intake cell sluice gates as a method to control level in those cells
would require the sluice gates to be classified as safety class equipment. The
licensee originally denied this violation, but the NRCs further independent review
re-affirmed the validity of the original violation. The licensee entered this
condition into their CAP as Condition Report CR 2010-2387. The inspectors
reviewed the licensees corrective actions. These actions included a modification
to the plant and the licensees submittal of license amendment request that is
currently under review.
The new method uses four new lines which tap off of the circulating water system
trash rack blowdown piping. This method requires all sluice gates to be fully
closed and not used for controlling cell level. Four new valves in the blowdown
piping would be used to control the intake cell level during a flood. Inspectors
reviewed the modification and the licensees operability determination to use this
new method while the licensing amendment is under review and found them
adequate to support plant safety.
This violation is closed.
f) VIO 2012002-03, Failure to Meet Design Basis Requirements for Design Basis
Flood Event
Violation VIO 2012002-03 documented a violation of 10 CFR 50, Appendix B,
Criterion III, Design Control, for the failure to meet design basis requirements
for protection of the safety related raw water system during a design basis flood
for flood levels between 1,010-1,014 feet mean sea level (msl) as identified in
Updated Safety Analysis Report, Section 9.8, Raw Water System. Specifically,
the design basis states, in part, that water level inside the intake cells can be
- 23 -
controlled during a design basis flood by positioning the exterior sluice gates to
restrict the inflow into the cells. Inspectors identified that the sluice gate motor
operators would be submerged below 1,014 feet msl adversely affecting the
abilty to position the sluice gates. The licensee entered this condition into their
CAP as Condition Report CR 2010-2387. The inspectors reviewed the licensees
corrective actions. These actions, as previously discussed, included a
modification to the plant and the licensees submittal of license amendment
request, both related to a change in the licensees method of controlling intake
cell level during flooding conditions up to the design basis flood.
This violation is closed.
g) VIO 2010007-01, Failure to Maintain External Flood Procedures
Violation VIO 2010007-01 documented the original concern the NRC identified
with the licensees ability to mitigate a design basis flood. The NRC conducted
numerous follow-up inspections of the licensees actions to address their
readiness for a design basis flood event. The root cause analyses for the
condition were reviewed during the inspections of Sections 1.a.1, 1.a.2, and 1.a.3
of the Restart Checklist Basis Document. Inspection Report 05000285/2013008
identified areas of concern which were re-inspected and deemed to be
satisfactorily addressed by the licensee as previously documented in this report.
This violation is closed.
(3) Assessment Results
i. Licensees Evaluations and Associated Improvement Actions Related to the Yellow
Flooding Finding
Based on the licensees efforts to address the discrepancies previously identified by
the inspectors in the extent of condition area and the in the technical bases for the
flooding procedure, restart checklist items 1.a.1, 1.a.2, and 1.a.3 were closed.
ii. Resolution of open Items associated with the Yellow Flooding Finding
Based on the reviews the team conducted, the following items were closed:
a) LER 2012-001, Inadequate Flooding Protection Procedure
b) LER 2012-019, Traveling Screen Sluice Gates Found with Dual Indication
c) LER 2011-003, Inadequate Flooding Protection Due to Ineffective Oversight
d) VIO 2012002-01, Inadequate Procedures to Mitigate a Design Basis Flood
Event
e) VIO 2012002-02, Failure to Classify Intake Structure Sluice Gates as Safety
Class III
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f) VIO 2012002-03, Failure to Meet Design Basis Requirements for Design
Basis Flood Event
g) VIO 2010007-01, Failure to Maintain External Flood Procedures
iii. Overall Assessment of Item 1.a: Flooding Issue - Yellow Finding (CLOSED)
Closure of all individual items in Section 1.a, Yellow Flooding Finding, of the
Restart Checklist are closed.
.b Reactor Protection System Contactor Failure - White Finding
Item 1.b is included in the restart checklist for the failure of Fort Calhoun Station to
correct a degraded contactor, which subsequently failed, in the reactor protection
system. These deficiencies resulted in a white (low to moderate safety significance)
finding.
(1) Inspection Scope
The team reviewed the licensees assessment of the failure of the M-2 contactor in the
reactor protection system that occurred June 14, 2010. The team verified that the
licensee adequately identified the root and contributing causes of the risk significant
issue; verified that the extent of condition and extent of causes of the risk significant
issue were identified, and verified that the corrective actions adequately addressed the
causes to preclude repetition. (Restart Checklist Basis Document Items 1.b.1; 1.b.2;
1.b.3)
An open item specifically related to the White finding was reviewed by the team. The
team verified that the licensee had performed adequate root cause and extent of
condition evaluations related to the associated deficiencies. In addition, the NRC
verified that adequate corrective actions were identified associated with the licensees
root and contributing causes and extent of condition evaluations and that implementation
of these corrective actions are either implemented or appropriately scheduled for
implementation. (VIO 2011007-01)
Specifically, the team assessed Revision 4 of the Root Cause Analysis (RCA) for CR
2011-00451, for which the problem statement was:
Reactor Protection System M-2 contractor was identified as chattering on
November 3, 2008 and non-conforming maintenance was performed. The M-2
contractor remained in a degraded and non-conforming condition without an
appropriate analysis to evaluate until it failed surveillance testing on June 14, 2010.
This revision to the root cause changed the wording significantly.
- 25 -
The teams assessment was based on the evaluation criteria from Section 02.02 of NRC
Inspection Procedure 95001, which aligned with this item. The inspection objectives
were to:
Provide assurance that the root and contributing causes of risk-significant issues
were understood;
Provide assurance that the extent-of-condition and extent-of-cause of risk-
significant issues were identified;
Provide assurance that the licensee's corrective actions for risk-significant
performance issues were, or will be, sufficient to address the root and
contributing causes and to preclude repetition.
(2) Observations and Findings
Determine that the problem was evaluated using a systematic methodology to identify
the root and contributing causes.
The team determined that the licensee evaluated this problem using a systematic
methodology to identify the root and contributing causes. Specifically, RCA 2011-00451
employed the use of event and causal factor charting, barrier analysis, comparative
analysis, and causal factor test, root and contributing cause statements, and the root
and contributing cause testing. The barrier analysis and event and causal factor chart
associated with RCA 2011-00451 identified a number of failed barriers that appeared to
play a significant role in the events leading to the failure of the reactor protection system
M-2 contactor. Included in the analysis were failures of the Preventive maintenance
program, operations procedures, system engineering, operations degraded non-
conforming process, work control process, and the Plant Review Committee Process.
Based on the analysis, the licensee concluded the following were the root and
contributing causes of the failure to address the degraded M-2 contactor in the reactor
protection system:
RC-1: Electrical Maintenance workers did not follow the procedure / work order
instructions for the M-2 contactor issue. When presented with conditions outside
of the expected, they did not use the Human Performance Tool DUCS
(Distracted, Uncertain, Confused, Stop) to obtain the necessary guidance to
correct the issue.
RC-2: The Operations Department did not have an effective nuclear safety
culture and ownership of plant equipment necessary to challenge unexpected
events and take prompt action to drive the action to restore degraded equipment
to reliable operation.
- 26 -
CC-1: System Engineering did not recognize and implement their responsibility to
perform appropriate evaluations to address plant technical issues and act as the
site technical conscience.
CC-2: Preventive Maintenance strategies were not implemented to replace the
M-contactors before they exhibited degradation and did not consider the
increased failure rate associated with their reaching end of service life.
CC-3: Engineering judgment used to support Operability Evaluations was not
rigorous or formally documented.
CC-4: The Plant Review Committee Degraded / Nonconforming condition
subcommittee process was allowed to change operations department decisions
on whether equipment was degraded without operations concurrence or formal
documentation of the basis.
CC-5: Operations surveillance test guidance allowed pausing surveillance tests
to perform repairs, which is a practice that is contrary to industry practices and
regulatory guidance.
CC-6: Operations knowledge of Technical Specification requirements related to
the M-contactors was inadequate resulting in entry into TS 2.15(1) instead of TS 2.0.1.
Determine that the root cause evaluation was conducted to a level of detail
commensurate with the significance of the problem.
The team determined that the RCA was conducted to a level of detail commensurate
with the significance of the problem. Specifically, the licensee performed a significant
revision to the RCA based on the inspection concerns documented in IR 2013-008. The
licensee systematically used Methods 1 and 2 for cause testing as defined by
FCSG 24 5, Condition Report and Cause Evaluation. The eight causal statements,
developed from merged causal factors, were evaluated using the flow chart. Two causal
statements were identified as Root Causes and the other six were determined to be
Contributing Causes.
Determine that the root cause evaluation included a consideration of prior occurrences
of the problem and knowledge of prior operating experience.
The team determined that the RCA included evaluation of both internal and industry
operating experience as documented in Attachment 4 to RCA 2011-00451.
Determine that the root cause evaluation addressed the extent of condition and the
extent of cause of the problem.
The team reviewed the licensees RCA as it relates to extent of condition and extent of
cause.
- 27 -
For extent of condition, the licensee used same-same, same-similar, similar-same, and
similar-similar evaluation method which is documented as Attachment 3 to
RCA 2011-00451. Based on this analysis, the licensee determined that an extent of
condition does exist. The licensee based this conclusion, in part, on the findings of
Condition Report CR 2012-09494, related to deficiencies in identifying
degraded/nonconforming conditions and in the performance of operability
determinations.
For extent of cause, the licensee determined an extent of cause does exist for the root
causes identified in this analysis. They believe the extent of causes have been
addressed by the collective sum of all corrective actions from the following RCAs:
2011-01719, Incorrect Technical Specification Entered when AI-3-M2 Contactor
failed
2011-03025, Area for Improvement (EN 1-1)
2012-03986, Organizational Ineffectiveness
2012-08125, Engineering Design / Configuration Control
2012-08132, Site Operational Focus and Conservative Decision Making
2012-08135, Human Performance
2012-08134, Equipment Reliability / Work Mangement
2012-08137, Regulatory Process and Infrastructure
2012-09491, End of Service Life
2012-09494, Deficiencies in Identifying Degraded and Non-Conforming Condition
and Performing Operability Determinations
2013-05570, Design and Licensing Bases Configuration Control
The team concluded that RCA 2011-00451 determined an appropriate extent of
condition and appropriate extent of cause for the root cause related to the reactor
protection system M-2 contactor issue.
Determine that the root cause, extent of condition, and extent of cause evaluations
appropriately considered the safety culture components as described in IMC 0310.
The root cause, extent of condition, and extent of cause evaluations appropriately
considered the safety culture components as described in IMC 0310. Specifically, the
licensee documented their consideration of the IMC 0310 cross-cutting aspects in
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Attachment 9 of RCA 2011-00451. The licensee identified several cross-cutting aspects
in the area of human performance, problem identification and resolution (PI&R), and
other components that were applicable to issues related to deficiencies in
degraded/nonconforming condition review and operability evaluations. The final
evaluation concluded that only a small number of the safety culture attributes were not to
be applicable to RCA 2011-00451.
Determine that appropriate corrective actions are specified for each root and contributing
cause.
The team reviewed Attachment K to 2011-00451 and determined that generally the
licensees proposed corrective actions were appropriate to address the root and
contributing causes identified.
Determine that a schedule has been established for implementing and completing the
corrective actions.
The team determined that due dates have been established for implementation and
completion of corrective actions.
Determine that quantitative or qualitative measures of success have been developed for
determining the effectiveness of the corrective actions to prevent recurrence.
The team determined that quantitative or qualitative measures of success have been
developed for determining the effectiveness of the corrective actions to prevent
recurrence.
(3) Assessment Results
The team concluded that for Item 1.b: Reactor Protection System Contact
Failure - White Finding, the root and contributing causes of risk-significant issues were
understood; the extent-of-condition and extent-of-cause of risk-significant issues were
identified; and, the licensees corrective actions for risk-significant performance issues
were, or will be, sufficient to address the root and contributing causes and to preclude
repetition.
All items in Section 1.b, Reactor Protection System Contactor Failure - White Finding,
are closed.
.2 Flood Restoration and Adequacy of Structures, Systems, and Components
Section 2 of the Restart Checklist contains those items necessary to ensure that important
structures, systems, and components affected by the flood and safety significant structures,
systems and components at Fort Calhoun Station are in appropriate condition to support
safe restart and continued safe plant operation.
.b System Readiness for Restart Following Extended Plant Shutdown
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Systems that have been shut down for prolonged periods may be subject to different
environments than those experienced during power operations. The NRC verified that
the licensee adequately evaluated the effects of the extended shutdown to ensure that
the structures, systems, and components are ready for plant restart and they conform to
the appropriate licensing and design bases requirements.
(1) Inspection Scope
.ii Detailed Review of Alternating and Direct Current Electrical Distribution, and High
Pressure Safety Injection Systems
The licensee performed a comprehensive review to evaluate and verify the capability
of selected systems to fulfill their intended safety functions as defined by the
licensing and design basis and identified broad-based safety, organizational, and
performance issues. The review was structured consistent with NRC Inspection
Procedure 95003 (Sections 02.03 and 03.03). The selected systems for detailed
review (vertical slice) as part of the Reactor Safety Strategic Performance Area were
based on their high risk significance, input from system health reports, performance
indicators, condition reports, and licensee event reports. Teams of Omaha Public
Power District and independent external experts performed the Reactor Safety
Strategic Performance Area reviews.
Systems selected are:
AC and DC Electrical Distribution Systems. These systems include the 4160V
breakers, 480V breakers, batteries, and battery chargers. Electrical distribution
systems at Fort Calhoun Station provide necessary power for Mitigating
Systems. The AC and DC systems provide power to key pumps, motors, valves,
and instruments required to monitor and respond to plant conditions. From the
plants probabilistic assessment, the AC and DC electrical systems account for a
substantial portion of plant risk. The electrical distribution system was selected
for self assessment by the licensee based on both identified issues and their
importance to safety.
Emergency Core Cooling System. This includes the high pressure injection
system. This system is important to provide mitigation for postulated accident
conditions in the reactor plant. This review assessed and validated key aspects
of the suction and discharge pathways, system alignments, power sources, and
emergency actuation.
Results and insights from these reviews were incorporated into the Integrated
Performance Improvement Plan that supported the restart of Fort Calhoun Station.
The NRC inspected each of the licensees detailed reviews and select samples for
independent verification that the licensee properly assessed each system.
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(2) Observations and Findings
No findings or observations.
(3) Assessment Results
Inspectors concluded that based on their reviews of the cause evaluations, and the
extent of cause/extent of condition reviews, that this area has been reviewed by the
licensee to a sufficient level of detail.
Items 2.b.2.1, 2.b.2.2, 2.b.2.3, and 2.b.2.4 are closed.
.3 Adequacy of Significant Programs and Processes
Section 3 of the Restart Checklist addresses major programs and processes in place at
FCS. Section 3 reviews will also include an assessment of how the licensee appropriately
addressed the NRC Inspection Procedure 95003 key attributes as described in Section 6.
.a Corrective Action Program
(1) Inspection Scope
i. The team assessed the licensees actions taken since NRC Inspection
Report 05000285/2013008. In Inspection Report 05000285/2013008, the inspectors
reviewed this area for closure and observed that because the licensee was
continuing implementation of corrective actions to improve the effectiveness of the
CAP, the licensee had unsatisfactory results on effectiveness reviews, and because
the licensee was still generating additional corrective actions to address CAP
effectiveness, items 3.a.1, 3.a.2, 3.a.3, and 3.a.4 remained open.
The inspectors reviewed licensee actions to address the inspectors concerns to
ascertain whether they were sufficient to ensure the CAP was adequate to support
plant restart. Also, the team reviewed the licensees assessment of the Fundamental
Performance Deficiency associated with the CAP.
In addition, the team reviewed the licensees assessment of the past issues involving
inadequate operating experience reviews identified in NRC Inspection
Report 05000285/2013008. In that report, the team determined that the effort by the
licensee to lump operating experience weaknesses in the RCA did not provide for
the proper analysis needed to address this deficiency which was prevalent in nearly
all of the Fundamental Performance Deficiency RCAs. Therefore, restart checklist
items 3.a.8, 3.a.9, 3.a.10, and 3.a.11 remained open pending the verification of the
effective resolution. The inspectors reviewed licensee actions to ascertain whether
they were sufficient to ensure that operating experience reviews by the licensee were
adequate.
Finally, in NRC Inspection Report 05000285/2013008, the team performed a
problem identification and resolution team inspection. That team concluded that
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overall, the CAP at FCS was functional in identifying, evaluating, and correcting
issues with various degrees of effectiveness. The team had a large number of
observations provided in each of the areas of CAP, and observed that there was
significant room for improvement. Based on all the observations identified by the
team, in all 3 areas of CAP, restart checklist item 3.a.12 remained open for additional
inspections to ensure an improved implementation of the CAP was in place. The
inspectors reviewed licensee actions to address the inspectors concerns to
ascertain whether they were sufficient to ensure the CAP was being adequately
implemented.
ii. Open items (Licensee Event Reports (LER), noncited violations (NCV), and
violations (VIO) specifically related to the corrective action program were reviewed
by the team. The team reviewed the adequacy of the licensees causal analyses and
extent of condition evaluations related to the associated deficiencies noted in the
licensees corrective action program. In addition, the NRC verified that adequate
corrective actions were identified associated with the licensees causal analyses and
extent of condition evaluations and that implementation of these corrective actions
were either implemented or appropriately scheduled for implementation.
Open items reviewed were:
VIO 2011006-02, Inadequate Corrective Actions to Ensure Reliability of Raw
Water Pump Power
NCV 2011006-06, Failure to Implement an Adequate Trending Program
NCV 2010003-01, Failure to Provide Adequate Limiting Condition for
Operation for High River Level
LER 2012-007, Failure of Pressurizer Heater Sheath
LER 2012-004, Inadequate Analysis of Drift Affects Safety Related
Equipment
LER 2012-010, Seismic Qualification of Instrument Racks
(2) Observations and Findings
i. Corrective Action and Operational Experience Programs Assessment
a) Resolution of Corrective Action Program Deficiencies
NRC Inspection Report 05000/285/2013008 documented that based on the
ongoing implementation of corrective actions, the licensees unsatisfactory
results on effectiveness reviews, and because the licensee was still generating
additional corrective actions to address CAP effectiveness, restart checklist
items 3.a.1, 3.a.2, 3.a.3, and 3.a.4 would remain open.
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The inspectors assessed licensee actions addressing the noted deficiencies.
The inspectors reviewed CR 2013-08675 which was initiated after the inspection
documented in Inspection Report 05000285/2013008. The licensee performed a
root cause analysis to evaluate the quality and timeliness of CAP actions and the
fact that prior actions taken to prevent recurrence of problems had not been fully
effective.
The root cause was determined by the licensee to be:
Station personnel have not consistently followed CAP procedures and station
leadership has not reinforced CAP procedure compliance, as a result
improvements in CAP performance have been limited.
Corrective actions taken to address this were the establishment of a CAP
oversight function and to develop and implement CAP Fundamentals reinforced
through an accountability model for specific CAP behaviors. Each of these
actions were put in place with periodic effectiveness measures being used to
monitor progress. The inspectors reviewed the first effectiveness measurement
results and noted continued improvement in the functioning of the CAP. The final
effectiveness measures and continued actions for improvement of the CAP are
contained in the PIIM in Action Plan Numbers 2013-0055, CAP Excellence
Plan - Problem Identification, 2013-0065, CAP Excellence Plan - Root Cause
and Apparent Cause Quality, and 2013-0062, CAP Excellence Plan - Corrective
Action Closure.
The licensee also identified six contributing causes that included:
CAP volume has significantly increased without significant process or
prioritization changes to ensure quality and timeliness requirements can be
maintained.
The CAP strategy for improving performance was not well implemented and
understood at all levels in the organization.
The ActionWay software is not being used as an effective barrier to ensure
that certain required actions within the CAP process are performed and that
certain prohibited actions are prevented.
Inadequate procedure guidance for action types in ActionWay has led to
inappropriate use and untimely resolution of conditions adverse to quality.
Station personnel have not received the requisite training to assure that
station leadership and staff have the knowledge and skills to effectively and
efficiently implement the CAP program.
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Station trending has been time consuming and ineffective due a large number
of flat level codes, the inability to trend on common subjects, and the lack of
connectivity between event and cause codes.
The inspectors reviewed the licensees actions to address these contributing
causes. The inspectors determined that the corrective actions to address the
contributing causes appeared to adequately address the deficiencies. Based on
the licensees improvements in CAP performance, continued effectiveness
measurement to monitor sustained improvement and make corrections when
needed, and the continued station focus on CAP improvements contained in the
PIIM, the inspectors considered that the CAP was adequately healthy and should
continue to improve.
Based on this assessment Restart Checklist Basis Document Items 3.a.1,
Licensee Assessment of Corrective Action Program, 3.a.2, Adequacy of
Extent of Condition and Extent of Causes, 3.a.3, Adequacy of Corrective
Actions, and 3.a.4, Adequacy of Effectiveness Measures to Monitor Program
Improvements, are closed.
b) Resolution of the Functional Performance Deficiency Associated with the CAP
In NRC Inspection Report 05000/285/2013008, the team noted that the licensee
had chartered a team to perform another root cause analysis in this area and
therefore assessing closure of this area would not be appropriate until that effort
was completed and inspected by the NRC. The licensee completed the root
cause analysis as part of CR 2013-08675. This root cause addressed both the
CAP deficiencies and the functional performance deficiency associated with the
CAP since both were closely related. Actions to correct the fundamental
performance deficiency were reviewed and found to be adequate. The
inspectors noted the actions were bounded by the actions to improve the
effectiveness of the CAP, including the emphasis of the continued CAP
improvements contained in the PIIM.
Based on this assessment Restart Checklist Basis Document Items 3.a.5,
Licensee Assessment of the Fundamental Performance Deficiency Associated
with the Corrective Action Program, 3.a.6, Adequacy of Extent of Condition and
Extent of Causes, and 3.a.7, Adequacy of Corrective Actions, are closed.
c) Resolution of Operational Experience Program Deficiencies
In NRC Inspection Report 05000/285/2013008, the team concluded that the
licensees assessment of Performance Improvement initiatives, specific to
operating experience, was too general to effectively address the operating
experience portion of the CAP. The NRCs concern with the licensees practices
with operating experience was that the site Operating Experience Program was
not effectively being implemented to enhance the performance of FCS.
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During this inspection the inspectors noted actions by the licensee to enhance
the use of operating experience. An example of this was in CR 2013-02062
where the licensee noted the operating experience program should be reviewed
to determine if any changes can be made to enhance the security organization
use of operating experience. The inspectors noted similar instances in other
areas, including improved use of operating experience in root cause analyses.
The inspectors noted that improvement in the use of operating experience was
incoroporated into the PIIM in Action Plan Number 2013-0061, Human
Performance, to improve human performance at the station. Operating
Experience was also included in the PIIM as part of the Performance
Improvement Program ensuring the CAP Coordinators for each department drive
the use of operating experience. Based on these observations, the inspectors
concluded that the licensee had taken adequate actions to increase the use of
operating experience in various station work processes and had inititiatives in
their PIIM to continue improvements in this area.
Based on this assessment Restart Checklist Basis Document Items 3.a.8,
Licensee Assessment of Operating Experience Action Program, 3.a.9,
Adequacy of Extent of Condition and Extent of Causes, 3.a.10, Adequacy of
Corrective Actions, and 3.a.11, Adequacy of Effectiveness Measures to Monitor
Program Improvements, are closed.
d) NRC Problem Identification and Resolution Team Inspection
In NRC Inspection Report 05000/285/2013008, it was documented that the NRC
performed a problem identification and resolution team inspection but did not
close Item 3.a.12, noting the need for additional inspections to ensure an
improved implementation of the CAP was in place. Since that inspection, the
licensee performed the additional root cause in CR 2013-08675 and
implemented corrective actions. These corrective actions were reviewed by the
NRC and it was determined that they adequately addressed the main
deficiencies noted during the previous inspection.
Based on the extensive NRC inspection efforts to assess the licensees actions
addressing improvements to the CAP that determined adequate actions have
been taken by the licensee and future actions will continue to be implemented
and effectiveness monitored, Restart Checklist basis Document Item 3.a.12,
Perform NRC Team Problem Identification and Resolution inspection, is
complete.
e) Overall Assessment
The inspectors determined that the corrective actions to address the root and
contributing causes addressing the CAP deficiencies appeared comprehensive
and were resulting in performance improvements. Additionally, the licensee has
implemented measurement processes to monitor the effectiveness of
improvements so that corrections can be implemented when needed. The
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station has in place CAP improvements initiatives contained in the PIIM that will
drive continued improvements to the program.
ii. Resolution of Open Items Related to the Correction Action Program Area in the
Restart Checklist Basis Document
a) (Discussed) VIO 05000285/2011006-02, Inadequate Corrective Actions to Ensure
Reliability of Raw Water Pump Power
This violation inovled the failure to take effective corrective action following the initial
discovery of water intrusion in cable vault manholes MH-5 and MH-31 in 1998,
2005, 2009, and 2011. Specifically, the licensee failed to take effective corrective
action to establish an appropriate monitoring frequency which took into account
variable environmental conditions to mitigate potential common mode failure of raw
water 4160 V motor cables in underground ducts and manholes identified during the
Component Design Basis Inspection performed in 2009.
This item was inspected as part of the 2013 License Renewal inspection and was
documented in Inspection Report 05000285/2013009. That team determined that
the licensee initiated Condition Report 2013-11857 for the condition. The team
concluded that, although the licensee had installed an alarm system to identify a high
water level, the licensee had insufficient time to demonstrate reliability and
effectiveness of the system.
This violation remains open pending future inspection of completed corrective
actions. The inspectors determined the corrective actions appeared adequate and
closed this item on the Restart Checklist Basis Document.
b) NCV 05000285/2011006-06, Failure to Implement an Adequate Trending Program
This item was identified as a Green non-cited violation as part of the 2011 Problem
Identification and Resolution Team Inspection and documented in NRC Inspection
Report 05000285/2011006. That team identified a deficiency regarding the
licensees inability to implement adequate procedures for gathering, analyzing, and
communicating information related to low-level performance vulnerabilities and
repeat occurrences prior to the emergence of more significant events. Inspectors
originally reviewed licensee actions as part of the team inspection documented in
Inspection Report 05000285/2013008 from which they concluded the licensee still
had performance gaps in effective trending to resolve issues at lower levels,
especially equipment trending. The inspectors noted that the licensee took action to
address this condition as part of Condition Report CR 2013-08675 in April 2013. The
root cause found that trending was not effective due to the lack of configuration of
the CAP software to provide the functionality to efficiently and accurately code and
trend condition reports. The inspectors reviewed the licensees actions which
included software changes to the CAP software to establish a tiered coding structure
and utilize the existing Exelon fleet model for trending codes. The inspectors
reviewed recent examples of trends and noted improvement in trending within the
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CAP. From this, the inspectors considered that the licensee had adequately
addressed this noncited violation and this Restart Checklist Basis Document item is
closed.
c) NCV 05000285/2010003-01, Failure to Provide Adequate Limiting Condition for
Operation for High River Level
This NCV documented a failure to include an adequate limiting condition for
operation in the technical specification. Specifically, the reactor could not be placed
in a cold shutdown condition using normal operating procedures when the river level
exceeded 1009 feet mean sea level, as required by Technical Specification 2.16.
The inspectors confirmed that licensee entered this condition into their corrective
action program. The inspectors noted that the licensee had changed procedure
AOP-01, Acts of Nature, to administratively shutdown the reactor and place it in
cold shutdown at a time where plant and flood conditions permitted. The inspectors
also confirmed that the licensee submitted a license amendment request to change
Technical Specification 2.16, River Level to require plant shutdown at 1004 feet
mean sea level. The inspectors reviewed this level relative to the actions and time
needed to place the plant in cold shutdown and considered them adequate. On
January 28, 2014, the NRC issued Amendment No. 274 to OPPD approving the
changes to Techncial Specification 2.16, River Level, (ADAMS ML 14003A003).
This NCV is closed on the Restart Checklist Basis Document.
d) (Closed) Licensee Event Report 05000285/2012-007, Failure of Pressurizer Heater
Sheath
This LER documented a condition where a pressurizer heater sheath
(Number 26 heater) was found cracked after it had failed. This condition was
considered a degradation of the reactor coolant system boundary. The licensee
conducted a root cause for the condition and concluded that fabrication of the heater
sheath during the manufacturing process induced high tensile residual stresses on
the outer surface of the sheaths which led to the failure. The inspectors reviewed
this causal analysis and the corrective actions associated with it. The inspectors
observed that the heater sheath has been removed and replaced, and that other
heater sheaths have been inspected and none of them had indications of cracking.
The inspectors also concluded that the heater design, which included a secondary
seal (not the RCS pressure boundary) prevented any leakage from the reactor
coolant system, and functioned as anticipated for such a condition. The inspectors
also confirmed that future inspections of heaters were included as corrective actions
for this condition. This LER and Restart Checklist Basis Document item is closed.
e) (Closed) Licensee Event Report 05000285/2012-004, Inadequate Analysis of Drift
Affects Safety Related Equipment
This LER documented a condition where Static "0" Ring pressure switches with
certain housing styles exhibit a setpoint shift when exposed to a change in
temperature if the switch body is not vented. These pressure switches that provide
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signals for high containment pressure to the reactor protection system and
engineered safeguards actuation circuitry had this configuration. The inspectors
determined that from a review of an evaluation of actual data that safety analysis
limits were not exceeded. The inspectors also examined the instruments and
confirmed that as corrective action the licensee had removed the vent plugs. Also,
the inspectors confirmed that the causal factor of inadequate vendor documentation
was addressed by the licensee. This LER and Restart Checklist Basis Document
item is closed.
f) (Closed) Licensee Event Report 05000285/2012-010, Seismic Qualification of
Instrument Racks
This LER documented an incident where safety-related reactor coolant system
pressure instruments were installed in non-seismically qualified instrument racks.
The licensee performed an analysis and demonstrated that the instrument racks
were designed to withstand the loads from a seismic event, and retracted the event
report. The enforcement aspects of this finding are discussed in Section 4OA7. This
LER and Restart Checklist Basis Document item is closed.
.5 Assessment of NRC Inspection Procedure 95003 Key Attributes
Section 5 of the Restart Checklist is provided to assess the key attributes of NRC Inspection
Procedure 95003. Performing Inspection Procedure 95003 will provide the NRC with
supplemental information regarding licensee performance, as necessary to determine the
breadth and depth of safety, organizational, and programmatic issues. While the procedure
does allow for focus to be applied to areas where performance issues have been previously
identified, the procedure does require that some sample reviews be performed for all key
attributes of the affected strategic performance areas. The key attributes are listed as separate
subsections below. It is intended that the activities in these subsections be conducted in
conjunction with reviews and inspections for Sections 1 - 4, rather than a stand-alone review.
.c Procedure Quality
Item 5.c is included in the restart checklist because the licensee performed an integrated
assessment and identified 15 Fundamental Performance Deficiencies (FPD) that
resulted in the overall performance decline at the station. One of the deficiencies
identified was Procedure Quality/Procedure Management. This FPD was entered into
the licensees corrective action program as CR 2012-08136.
The NRC assessed the thoroughness of the licensees Procedure Quality/Procedure
Management evaluation, adequacy of extent of condition and extent of causal analysis,
and adequacy of associated corrective actions.
a. Inspection Scope
During April 2013, a two-week NRC onsite inspection was conducted to review the
thoroughness of the licensees Procedure Quality/Procedure Management evaluation.
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The inspectors conducted a review of the status of operations department procedures,
including Emergency Operating Procedures (EOPs), Abnormal Operating Procedures
(AOPs), Operating Procedures (OPs), Alarm Response Procedures (ARPs) and
Operating Instructions (OIs).
In addition, the inspectors also reviewed several internal and external
assessments conducted for Operations Department procedures, condition
reports, root cause analyses and apparent cause analyses. These reviews were
conducted to provide the inspection team an insight into the current quality of
operations procedures as well as the anticipated quality of procedures required
to support restart of the unit.
The observations and findings of this inspection were documented in NRC
IMC 0350 Inspection Report 05000285/2013010, dated July 11, 2013. Overall,
the inspection team concluded that the status of procedures used by Operations
was not of sufficient quality to support closure of this area.
The scope of this inspection was to 1) evaluate known deficiencies in Operations
procedures and verify the licensee implemented adequate corrective actions
commensurate with their importance to safety, and 2) assess the adequacy of
licensee actions to be taken prior to restart to gain assurance that Operations
procedures are adequate.
This inspection reviewed the following Restart Checklist Basis Document items:
5.c.1 - Licensee Assessment of the Fundamental Performance Defiency
of Procedure Quality/Procedure Management,
5.c.2 - Adequacy of extent-of-condition and extent of cause, and
5.c.3 - Adequacy of corrective actions.
b. Observations and Findings
Following the inspection in April 2013, the licensee initiated and completed a
Procedure Recovery project (CR 2013-08856) to address procedure quality
concerns. This project included almost 300 procedures, identified by six Priority
definitions:
Priority 1: procedures included all safety related ARPs, EOPs and AOPs that
branch to OIs, OIs associated with the EOP/AOP set, and procedures with
prior NRC concerns.
Priority 2: procedures included EOPs and AOPs without present OI
branching, and AOPs associated with safety systems.
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Priority 3: procedures included OIs associated with safety related systems
Priority 4: procedures included AOPs and OIs associated with only non-safety
related systems.
Priority 5: procedures included OIs associated with systems that will neither
be used nor conditions encountered before completion of the review process.
Priority 6: procedures included OIs designated as non-safety related.
The process used to conduct the recovery project included the following
elements:
Verification - process of ensuring procedures are technically correct,
operational correctness, and procedures accurately adhere to guidance in the
procedure writers guide, including human factors.
Validation - process of confirming procedures are compatible with expected
operator responses and plant equipment. Validation methods included walk-
through, table-top, simulator, and reference.
To assess the adequacy of the Procedure Recovery project in meeting the
inspection requirements, a sample of each procedure type was selected and
reviewed. The review consisted of the procedure revision in use prior to the
upgrade project, the electronic change package (including requisite forms,
markups, reviews, comments, etc.) and the new procedure revision issued.
In addition, condition reports, root and apparent cause analyses, external and
internal procedure assessments, and procedure related training documentation
were reviewed.
c. Assessment Results
The inspector concluded that the licensee adequately scoped the set of
Operations procedures to be reviewed and upgraded prior to plant restart. The
licensee adequately evaluated and corrected known procedure deficiencies as
well as identified and corrected a substantial number of deficiencies identified
during implementation of the Procedure Recovery project. Based on the results
of the NRC reviews it was determined that the licensees Procedure Recovery
Project effectively improved Operations procedures to support a safe plant
restart. Restart Checklist Basis Document items 5.c.1, 5.c.2 and 5.c.3 are
closed.
(1) Restart Checklist Basis Document Items 5.c - NCV 2012301-01, 04 and 06
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a. Inspection Scope
The inspectors reviewed the adequacy of licensees actions in resolving the
following non-cited violations that were specific items in the Restart Checklist
Basis Document:
NCV 2012301-01, Seven Examples of Inadequate Procedures for the
Mitigating Systems Cornerstone,
NCV 2012301-04, Five Examples of Inadequate Procedures for the
Initiating Events Cornerstone, and
NCV 2012301-06, Inadequate Procedures with Four Examples for the
Barrier Integrity Cornerstone.
During April 2013, a two-week onsite inspection was conducted to review the
three NCVs as part of the overall assessment of the procedural quality attribute.
The inspectors reviewed condition reports associated with these violations and
procedural changes incorporated as a result of these violations. The assessment
documented that Condition Report 2012-03140 was written to encompass all of
the examples of procedural deficiencies in the alarm response procedures that
were identified in non-cited violations NCV 2012301-01, NCV 012301-04, and
NCV 2012301-06. However, a revised apparent cause analysis was in progress
and therefore could not be inspected. Although the specific procedural
deficiencies documented in the three non-cited violations had been corrected, it
was decided these checklist items would remain open pending a future
inspection of the revised apparent cause analysis and any associated corrective
actions. Inspection results were documented in NRC IMC 0350 Inspection
Report 05000285/2013010, dated July 11, 2013.
The scope of this follow-up inspection is a review of the revised apparent cause
analysis for CR 2012-03140 and associated corrective actions.
b. Observations and Findings
Apparent Cause Analysis Report, Annunciator Response Procedure (ARP)
Quality Issues, Revision 1, was approved May 1, 2013. The revised Apparent
Cause Analyis concluded that there was a flaw in the original analysis. As a
result, the Apparent Cause Analysis identified apparent cause was changed; the
Extent of Condition was revised to bring this section into compliance with
FCSG 24-4, Condition Report and Cause Analysis, and FCSG-24-5, Cause
Evaluation Manual; and corrective actions were updated and revised based on
the completed actions and revised analysis.
Extent of Cause analysis and corrective actions resulted in improved verification
and validation processes through changes to procedures SO-G-30, Procedure
Change and Generation, and SO-G-74, EOP/AOP Procedure Generation
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Program. Extent of Condition analysis identified some operating procedures
(EOPs, AOPs, Operating Instructions, Operating Procedures and Annunciaor
Response Procedure) were technically inaccurate, lacked clarity, and deviated
from the owner's group guidelines. Corrective actions included a Procedure
Recovery Project that included a review and validation of procedure technical
accuracy and clarity for all operating documents.
c. Assessment Results
The inspector concluded that the licensee adequately addressed the Apparent
Cause and Contributing Causes, Extent of Condition and Extent of Cause
through the revision of the Apparent Cause Analysis for CR 2012-03140.
Therefore, Restart Checklist Items 5.c - NCV 2012301-01, 04, and 06 are
closed.
(2) Restart Checklist Basis Document Item 5.c - NCV 2011002-01, Inadequate
Operating Instruction Results in a Loss of Auxiliary Feedwater
a. Inspection Scope
During April 2013, a two-week onsite inspection was conducted to review this
NCV as part of the overall assessment of the procedural quality attribute. The
inspectors reviewed Condition Report 2011-0839 and the associated Root Cause
Analysis. The inspectors documented one concern from this review associated
with Contributing Cause 8.2 (insufficient criteria to ensure periodic V&V
(verification and validation) of infrequently used procedures or procedure
sections) that did not have an associated corrective action. The licensee
documented this issue in Condition Report 2013-08677. It was decided this
checklist item would remain open until a corrective action for Contributing
Cause 8.2 was developed and implemented.
The scope of this follow-up inspection is a review of the corrective action for
Contributing Cause 8.2.
b. Observations and Findings
CR 2013-08677 was reviewed. Action Item 3, "Establish and implement criteria
to ensure periodic V&V of infrequently used procedures and procedure sections
is performed" was completed and approved by the station on July 18, 2013.
c. Assessment Results
The inspector reviewed the criteria and its implementation and concluded that the
licensee adequately addressed the corrective action for Contributing Cause 8.2
of CR 2011-0839. Therefore, Restart Checklist Item 5.c - NCV 2011002-01 is
closed.
- 42 -
(3) Restart Checklist Basis Document items 5.c - NCV 2010004-10, Inadequate
Maintenance Procedure Results in a Plant Shutdown
a. Inspection Scope
During April 2013, a two-week onsite inspection was conducted to review this
NCV as part of the overall assessment of the procedural quality attribute. The
inspectors reviewed LER 2010-002, Failed Feeder Cable Due to Inadequate
Procedure Causes Station Shutdown, and associated documents (condition
reports, causal analyses, procedures) to verify the licensee had performed
adequate casual analyses and extent of condition/extent of cause evaluations
related to this issue. In addition, the inspectors verified adequate corrective
actions were identified for the associated causes and extent of condition/extent of
cause evaluations and that implementation of these corrective actions were
either implemented or appropriately scheduled for implementation.
b. Observations and Findings
LER 2010-002 and CR 2010-1704 (including causal analysis and extent of
condition/extent of cause) were reviewed. Changes to procedure EM-PM-EX-
1100, 480 Volt Motor Control Center Maintenance, were reviewed and found to
adequately address the deficiencies.
c. Assessment Results
The inspector concluded that the licensee adequately identified Root and
Contributing Causes, and adequately addressed corrective actions to preclude
recurrence. Therefore, Restart Checklist Item 5.c - NCV 2010004-10 will be
closed.
.d Equipment Performance
a. Inspection Scope
The NRC issued NCV 2010004-09 for the failure of the licensee to perform vendor and
industry recommended testing on safety-related and risk significant 4160V and 480V
circuit breakers. The purpose of this review was to verify the licensee performed an
adequate cause analysis and established appropriate corrective actions to address the
issues.
b. Observations and findings
The inspectors reviewed the documentation of the licensees efforts. The licensees
cause analysis determined the causes of the issue were the lack of detail in the
Reliability Centered Maintenance (RCM) basis documentation for prescribing adequate
circuit breaker maintenance, failure to incorporate all sources of maintenance
recommendations, and insufficient coordination and ownership by separate engineering
- 43 -
groups to adequately trend breaker performance and identify all required maintenance
activities. The licensee corrective actions included completion of a gap analysis to
identify vendor and industry recommended breaker maintenance and deficiencies in the
FCS program. The licensee developed a detailed preventive maintenance basis
document for switchgear and breaker maintenance based on the results of the gap
analysis. The licensee revised applicable maintenance procedures to capture the new
maintenance requirements and also revised procedures for trending and monitoring
breaker performance, to include a system engineer review. The inspectors concluded
the cause analysis and corrective actions appear adequate to minimize recurrence of the
issue.
c. Assessment Results
This activity constitutes closure of NCV 2010004-09 as listed in the Restart Checklist
Basis Document.
.e Configuration Control
Review of LER 2012-008, Technical Specification Violation for Fuel Movement (VA-66)
a. Inspection Scope
The inspectors reviewed the licensee actions associated with LER 2012-008, Technical
Specification Violation for Fuel Movement (VA-66), that included associated documents
(condition reports, causal analyses, procedures) to verify the licensee had performed
adequate casual analyses and extent of condition/extent of cause evaluations related to
this issue. In addition, to verify adequate corrective actions were identified associated
with the causes and extent of condition/extent of cause evaluations and that
implementation of these corrective actions were either implemented or appropriately
scheduled for implementation.
b. Observations and Findings
A review of LER 2012-008, Condition Report 2011-07800 and Apparent Cause Analysis
Summary Report, Spent Fuel Storage Pool Area Charcoal Filter V A-66 Elemental
Iodine Removal Efficiency Test Failure, Revision 1 was conducted.
The Apparent Cause identified was lack of Management Oversight and failure of
Engineering to take a pro-active approach in the prevention of future test failures. Action
Items (AI) included:
1. Revision of procedure SE-ST-VA-0010, Spent Fuel Storage Pool Area
Charcoal Filter VA-66 Elemental Iodine Removal Efficiency Test to trend
charcoal sample results and predict replacement,
2. Replacement of the depleted charcoal currently installed, and
3. Change the frequency of the charcoal testing from eighteen months to 1 year.
- 44 -
Action Items 1 and 2 have been completed. Action Item 3 is scheduled to be completed
under EC 57850. The Apparent Cause Analysis Summary Report documented that the
Extent of Condition will be addressed under Condition Report 2011-7798.
c. Assessment Results
The inspector concluded that the licensee adequately assessed and developed
corrective actions to address the apparent cause of the performance deficiency
associated with this Licensee Event Report. Therefore, Restart Checklist Basis
Document Item 5.e (LER 2012-008) will be closed. However, LER 2012-008 will remain
OPEN until Action Item 3 is verified complete by inspection.
Review of LER 2012-012, Multiple Safety Injection Tanks Rendered Inoperable
a. Inspection Scope
The inspectors reviewed the licensees actions associated with LER 2012-012 that
included documents (condition reports, causal analyses, procedures) to verify the
licensee had performed adequate casual analyses and extent of condition/extent of
cause evaluations related to this issue. In addition, the inspectors verified that adequate
corrective actions were identified associated with the causes and extent of
condition/extent of cause evaluations and that implementation of these corrective actions
were either implemented or appropriately scheduled for implementation.
b. Observations and Findings
A review of LER 2012-012, Condition Reports 2012-01956, 2012-03140, 2012-04815
and 2013-09711, and Apparent Cause Analysis Report, Lack of Extent of Condition and
Extent of Cause Action for NRC Non-cited Violation, Revision 0 was conducted.
The Apparent Cause Analysis (ACA) from CR 2013-09711 identified the original
Apparent Cause Analysis for CR 2012-03140 (deficiencies in several ARPs found during
NRC Initial Licensed Operator exam - conducted in August 2012) was inaccurate in that
the ACA faulted the writers guide rather than an incorrect ARP validation process. The
ACA from CR 2013-09711 also documented the following causes and extent of
conditions:
Apparent Cause #1 (AC-1) - Operations Department corrective action program
prioritization valued correcting the specified condition to a much greater degree
than investigating the extent of condition and ensuring corrective action in a
timeframe commensurate with the risk of the problem recurring or extending to
other procedures.
Contributing Cause #1 (CC-1) - The original Apparent Cause Analysis for
CR 2012-03140 was inaccurate in that the Apparent Cause Analysis faulted the
writers guide rather than an incorrect ARP validation process.
- 45 -
An Extent of Condition exists with all ARPs.
An Extent of Cause exists with most EOPs, AOPs, and Operating Instructions.
The findings in the Apparent Cause Analysis contributed to the decision to conduct a
procedure upgrade project that included the Alarm Response Procedures identified
affected by LER 2012-012.
The Alarm Response Procedure (ARP-CB-4/A7, Annunciator Response Procedure A7
Control Room Annunciator A7) and Operating Instruction (OI-SI-1, Safety Injection -
Normal Operation) that were associated with sluicing of Safety Injection Tanks were
reviewed and compared with the revision prior to the changes identified by the upgrade
project.
c. Assessment Results
The inspector concluded that the licensee adequately assessed and developed
corrective actions to address the apparent cause of the performance deficiency
associated with this Licensee Event Report. Therefore, Restart Checklist Basis
Document Item 5.e (LER 2012-012) is closed.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On December 5, 2013, the inspectors presented the results of the onsite inspection of the
licensees biennial emergency preparedness exercise to Mr. L. Cortopassi, Site Vice President,
and other members of the licensees 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.
The lead inspector obtained the final annual examination results and telephonically exited with
Mr. R. Cade, Manager, Operations Training, on December 30, 2013. The inspector did not
review any proprietary information during this inspection.
On January 24, 2014, the inspectors presented the inspection results to Mr. L. Cortopassi, Site
Vice President, and other members of the licensee staff. The licensee acknowledged the issues
presented. The licensee confirmed that any proprietary information reviewed by the inspectors
had been returned or destroyed.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee and
is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for
being dispositioned as a non-cited violation.
- 46 -
Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires that measures shall be
established to assure that the design basis for those structures, systems, and components
to which this appendix applies are correctly translated into specifications, drawings,
procedures, and instructions. Contrary to this requirement, the licensee failed to assure that
the design basis for safety related instrument racks inside containment were correctly
translated into specifications, drawings, procedures, and instructions. The licensee initially
identified and documented this violation in CR 2012-03100 and CR 2013-10935. This
violation was of very low safety significance because it did not result in the loss of operability
or functionality of any system or train.
- 47 -
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
D. Bakalar, Manager, Security
J. Bousum, Manager, Emergency Planning and Administration
C. Cameron, Supervisor Regulatory Compliance
L. Cortopassi, Site Vice President
K. Ihnen, Manager, Site Nuclear Oversight
T. Leeper, Manager, Human Resource Services
T. Lindsey, Director, Training
E. Matzke, Senior Licensing Engineer, Regulatory Assurance
B. Obermeyer, Manager, Corrective Action Program
T. Orth, Director, Site Work Management
E. Plautz, Supervisor, Emergency Planning
R. Short, Assistant Director, Engineering
T. Simpkin, Manager, Site Regulatory Assurance
S. Swanson, Manager, Operations
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
Containment Valve Actuators Design Temperature Ratings
05000285-2012-017-02 LER Below those Required for Design Basis Accidents (Section
4OA3)
Mounting of GE HFA Relays does not Meet Seismic
05000285-2013-001-01 LER
Requirements (Section 4OA3)
Calculations Indicate the HPSI Pumps will Operate in Run-
05000285-2013-003-01 LER
out During a DBA (Section 4OA3)
Previously Installed GE IVA Relays Failed Seismic Testing
05000285-2013-008-01 LER
(Section 4OA3)
Unqualified Components used in Safety System Control
05000285-2013-014-00 LER
Circuit (Section 4OA3)
Containment Spray Pump Design Documents do not Support
05000285-2013-017-00 LER
Operation in Runout (Section 4OA3)
Postulated Fire Event Could Result in Shorts Impacting Safe
05000285-2013-018-00 LER
Shutdown (Section 4OA3)
A-1 Attachment
Opened and Closed
Failure to Correct Deficiencies in Operations Support Center
Functions (Section 1EP1)
Discussed
05000285/2011006-02 VIO Inadequate Corrective Actions to Ensure Reliability of Raw
Water Pump Power
Closed
Inadequate Flooding Protection Due to Ineffective Oversight
05000285-2011-003-03 LER
(Section 4OA4)
05000285-2012-001-00 LER Inadequate Flooding Protection Procedure (Section 4OA4)
Inadequate Analysis of Drift Affects Safety Related
05000285-2012-004-02 LER
Equipment (Section 4OA4)
05000285-2012-007-01 LER Failure of Pressurizer Heater Sheath (Section 4OA4)
Technical Specification Violation for Fuel Movement (VA-66)
05000285-2012-008-01 LER
(Section 4OA4)
05000285-2012-010-00 LER Seismic Qualification of Instrument Racks (Section 4OA4)
Multiple Safety Injection Tanks Rendered Inoperable (Section
05000285-2012-012-01 LER
4OA4)
Containment Valve Actuators Design Temperature Ratings
05000285-2012-017-01 LER Below those Required for Design Basis Accidents (Section
4OA3)
Traveling Screen Sluice Gates Found with Dual Indication
05000285-2012-019-00 LER
(Section 4OA4)
Mounting of GE HFA Relays does not Meet Seismic
05000285-2013-001-00 LER
Requirements (Section 4OA3)
Calculations Indicate the HPSI Pumps will Operate in Run-
05000285-2013-003-00 LER
out During a DBA (Section 4OA3)
Previously Installed GE IVA Relays Failed Seismic Testing
05000285-2013-008-00 LER
(Section 4OA3)
Failure to Maintain External Flood Procedures (Section
4OA4)
Inadequate Procedures to Mitigate a Design Basis Flood
Event (Section 4OA4)
Failure to Classify Intake Structure Sluice Gates as Safety
Class III (Section 4OA4)
A-2
Closed
Failure to Meet Design Basis Requirements for Design Basis05000285/2012002-03 VIO
Flood Event (Section 4OA4)
Failure to Correct a Degraded Contactor in the Reactor
Protective System (Section 4OA4)
LIST OF DOCUMENTS REVIEWED
Section 1R11: Licensed Operator Requalification Program and Licensed Operator
Performance
Condition Reports (CRs)
2013-23048
Miscellaneous Documents
Number Title Revision
TQ-AA-150-F25 LORT Annual Exam Status Report 5
Section 1R18: Plant Modifications
Procedures
Number Title Revision
OP-ST-AFW-3010 Auxiliary Feedwater System Quarterly Category A and B 9
Valve Exercise Test
Work Orders (WO)
503315
Section 1R22: Surveillance Testing
Procedures
Number Title Revision
OP-ST-ESF-0001 Diesel Auto Start Initiating Circuit Check 42
Work Orders (WO)
360607
A-3
Section 1EP1: Exercise Evaluation
Procedures
Number Title Revision
TBD-EPIP-OSC- Technical Basis Document for the Emergency Action Levels, 2A
1A November 21, 2013
EPIP-EOF-1 Activation of the Emergency Operations Facility, June 6, 2013 19
EPIP-EOF-6 Dose Assessment, September 20, 2013 47
EPIP-EOF-7 Protective Action Guidelines, March 16, 2012 25
EPIP-EOF-11 Dosimetry Records, Exposure Extensions, and Habitability, April 29
2, 2013
EPIP-EOF-21 Potassium Iodide Issuance, June 25, 2009 9
EPIP-OSC-2 Command and Control Position, Actions/Notifications, June 26, 57
2012
EPIP-OSC-7 Emergency Response Organization Activation at the Emergency 4
Operations Facility, March 26, 2013
EPIP-OSC-9 Emergency Team Briefings, September 13, 2012 15
EPIP-OSC-15 Communicator Actions, July 19, 2013 30
EPIP-OSC-21 Activation of the Operations Support Center, May 5, 2011 20
EPIP-RR-11 Technical Support Center Director Actions, November 8, 2008 3
EPIP-TSC-1 Activation of the Technical Support Center, May 5, 2011 32
EPIP-TSC-8 Core Damage Assessment, September 29, 2011 20
EPT-20 Exercise Preparation and Control, November 20, 2012 36
EPT-48 Change Out of Protective Clothing in Emergency Facilities, 3
February 18, 2009
Evaluation Report for the June 6, 2011, Alert Classification
Evaluation Report for the Exercise conducted February 27, 2012
Evaluation Report for the Exercise conducted March 27, 2012
Evaluation Report for the Exercise conducted May 22, 2012
Evaluation Report for the Exercise conducted July 17, 2012
Evaluation Report for the Exercise conducted November 10,
2012
Evaluation Report for the Exercise conducted March 5, 2013
Evaluation Report for the Exercise conducted May 7, 2013
A-4
Section 1EP1: Exercise Evaluation
Procedures
Number Title Revision
Evaluation Report for the Exercise conducted June 18, 2013
Condition Reports (CR)
2012-02381 2012-07779 2013-05146 2013-05263 2013-05363
2013-10486 2013-22153 2013-22169 2013-22172 2013-22177
2013-22181 2013-22193 2013-22194 2013-22201 2013-22206
2013-22209 2013-22220 2013-22226 2013-22247 2013-22252
2013-22253 2013-22261 2013-22262 2013-22264 2013-22265
2013-22269 2013-22270 2013-22271 2013-22288 2013-22491
2013-22492 2013-22495 2013-22498
Miscellaneous Documents
Number Title
Fort Calhoun Station Radiological Emergency Response Plan
(revision by section)
Section 4OA2: Problem Identification and Resolution (71152)
Procedures
Number Title Revision
FCSG-24-1 Condition Report Initiation 5
FCSG-24-3 Condition Report Screening 7
FCSG-24-4 Condition Report and Cause Evaluation 7
FCSG-24-6 Corrective Action Implementation and Condition Report 10
Closure
SO-R-2 Condition Reporting and Corrective Action 53b
Section 4OA4: IMC 0350 Inspection Activities
Condition Reports (CR)
2010-05140 2013-03024 2013-00620 2013-11203 2013-11736
2013-02041 2009-02306 2012-17533 2009-02306 2013-03024
A-5
2012-05854 2012-05855 2013-08856 2013-09711 2012-08136
2010-1704 2010-2387 2011-0839 2012-03140 2013-08677
2011-07800 2011-07798 2012-01956 2012-03140 2012-04815
2013-08856 2013-09711 2013-10935 2012-04914 3023-03100
2012-00307 2012-00600 2012-00871 2012-00875 2012-00882
2012-00882 2012-00899 2012-00901 2012-00906 2012-00929
2012-00945 2012-00949 2012-00965 2012-00967 2012-00980
2012-00986 2012-00996 2012-00998 2012-01000 2012-01003
2012-01010 2012-01012 2012-01021 2012-01330 2012-02142
Work Orders (WO)
00484596
Procedures
Number Title Revision
FCSG-24-1 Condition Report Initiation 3
AOP-01 ACTS OF NATURE 37, 38
AOP-05 EMERGENCY SHUTDOWN 11, 12
AOP-17 LOSS OF INSTRUMENT AIR 14, 15
AOP-18 LOSS OF RAW WATER 7a, 8
ARP-AI-66A/A66A ANNUNCIATOR RESPONSE PROCEDURE A66A 15, 16
CONTROL ROOM ANNUNCIATOR A66A,
AFWAS/DSS
ARP-CB-1,2,3/A1 ANNUNCIATOR RESPONSE PROCEDURE A1 36, 37
CONTROL ROOM ANNUNCIATOR A1
ARP-CB-4/A20 ANNUNCIATOR RESPONSE PROCEDURE A20 45, 46
CONTROL ROOM ANNUNCIATOR A20
ARP-CB-4/A7 ANNUNCIATOR RESPONSE PROCEDURE A7 17, 18
CONTROL ROOM ANNUNCIATOR A7
EM-PM-EX-1100 480 Volt Motor Control Center Maintenance 23, 37
EOP/AOP EOP/AOP ATTACHMENTS 34
ATTACHMENTS
A-6
Procedures
Number Title Revision
EOP/AOP HEAT REMOVAL 0
ATTACHMENTS-HR
EOP/AOP MAINTENANCE OF VITAL AUXILIARIES 0
ATTACHMENTS-MVA
EOP/AOP FLOATING EOP/AOP FLOATING STEPS 3c, 4
STEPS
EOP-00 STANDARD POST TRIP ACTIONS 29, 30
EOP-03 LOSS OF COOLANT ACCIDENT 36, 37
EOP-20 FUNCTIONAL RECOVERY PROCEDURE 25a, 26
EPIP-TSC-2 Catastrophic Flooding Preparations 14
FCSG-20 Abnormal Operating Procedure and Emergency 9
Operating Procedure Writers Guide
FCSG-24-3 Condition Report Screening 6a
FCSG-24-4 Condition Report and Cause Evaluation 6a
FCSG-24-4 Condition Report and Cause Evaluation 5
FCSG-24-5 Cause Evaluation Manual 5, 6
FCSG-64 External Flooding of Site 1
M8145WD Flood Control Walk-down Exercise
NOD-QP-19 Cause Analysis Program 4
OI-AFW-4 AUXILIARY FEEDWATER STARTUP AND SYSTEM 87, 88
OPERATION
OI-CW-1 Circulating Water System Normal Operation 65 and 66
OI-RC-9 REACTOR COOLANT PUMP OPERATION 75, 76
OI-SI-1 SAFETY INJECTION - NORMAL OPERATION 136, 137
OP-1 MASTER CHECKLIST FOR PLANT STARTUP 111
OP-2A PLANT STARTUP 114
OPD-4-09 EOP/AOP Users Guidelines 12, 19
A-7
Procedures
Number Title Revision
OP-ST-SI-3001 SAFETY INJECTION SYSTEM CATEGORY A AND B 35a, 36
VALVE EXERCISE TEST
OP-ST-VX-3018 SAFETY INJECTION SYSTEM REMOTE POSITION 10, 11
INDICATOR VERIFICATION
SURVEILLANCE TEST
QC-ST-SI-3006 SAFETY INJECTION LEAKOFF PIPING FORTY 5, 6
MONTH FUNCTIONAL TEST
SE-ST-VA-0010 SPENT FUEL STORAGE POOL AREA CHARCOAL 6, 7
FILTER
VA-66 ELEMENTAL IODINE REMOVAL EFFICIENCY
TEST
SO-G-30 Procedure Changes and Generation 136
SO-G-74 Fort Calhoun Station EOP/AOP Generation Program 20
SO-O-1 CONDUCT OF OPERATIONS 84, 101
TBD-AOP-01 ACTS OF NATURE 37, 38
TBD-AOP-05 EMERGENCY SHUTDOWN 11, 12
TBD-AOP-17 LOSS OF INSTRUMENT AIR 14, 15
TBD-EOP/AOP TBD-EOP/AOP ATTACHMENTS 34
ATTACHMENTS
TBD-EOP/AOP TBD-EOP/AOP FLOATING STEPS 4
FLOATING STEPS
TBD-EOP-00 STANDARD POST TRIP ACTIONS 30
TBD-EOP-06 LOSS OF ALL FEEDWATER 17b, 18
TBD-EOP-20 FUNCTIONAL RECOVERY PROCEDURE 25a, 26
Calculations
Number Title Revision/Date
CN-OA-11-7 Intake Cell Level Control Using the Intake Sluice Gate April 21, 2011
During Flooding Conditions at the Ft. Calhoun Plant
CN-SEE-II-11-2 Intake Cell Level Control - Flood Alternate Flow Path April 5, 2011
Evaluation for Fort Calhoun Station
FC08030 Intake Structure Cell Level Control Using the Intake April 25, 2011
Structure Sluice Gates
A-8
FC08070 Validation of Backup Fuel Oil Transfer During Flooding
Conditions
FC08142 Seismic Evaluation of Instrument Racks 12
FC08174 Seismic Analysis of Rack AI-135C 13
FC05153 CQE Instrument Rack Analysis 02
EA93-084 Criteria For Anchors Installed In Concrete Toppings 0
Engineering Change (EC)
Number Title Revision
60326 Procedure Upgrade 0
57850 SE-ST-VA-0010 Procedure Change 0
58676 Containment 994' Elev. Instrument Rack Bolt 1
Replacement
FDCR 61877 Replace additional anchors securing instrument racks 8
on the 994' elevation
Miscellaneous Documents
Number Title Revision/Date
VERIFICATION PROCESS TO ADDRESS June 13, 2013
PROCEDURE QUALITY CONCERNS
Simulator Scenario Guide 82103e - Cable Spreading 1
Room Fire and Control Room Evacuation
Simulator Scenario Guide 82103f - 480VAC Bus 1B4A 0
Fire
EONT Qualification Manual
LER 2012-008 Technical Specification Violation for Fuel Movement 0, 1
(VA-66)
LER 2012-012 Multiple Safety Injection Tanks Rendered Inoperable 0, 1
FCS-95003-IACPD- IACPD - FCS Performance Goals Assessment
03 Performance Area
FCS-95003-IACPD- IACPD - FCS Audits and Assessments Assessment
08 Performance Area
A-9
Miscellaneous Documents
FCS-95003-IACPD- IACPD - FCS Significant Performance Deficiencies
02 Assessment Performance Area
Corrective Action Program CR 2012-08124
Fundamental Performance Deficiency Analysis
Security Self Assessment Report, August 2012
A-10