IR 05000285/2015004

NRC Integrated Inspection Report Numbers 05000285/2015004 and 07200054/2015001

ML16008A820
Person / Time
Site:	Fort Calhoun
Issue date:	01/08/2016
From:	Geoffrey Miller NRC/RGN-IV/DRP/RPB-D
To:	Cortopassi L Omaha Public Power District
Hagar B
References
IR 2015001, IR 2015004
Download: ML16008A820 (46)

Text

January 8, 2016

SUBJECT:

FORT CALHOUN STATION - NRC INTEGRATED INSPECTION REPORT NUMBERS 05000285/2015004 AND 07200054/2015001

Dear Mr. Cortopassi

On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed inspection s at your Fort Calhoun Station (FCS). On January 7, 201 6 , NRC inspectors discussed the results of these inspection s with you and other members of your staf Inspectors documented the results of these inspection s in the enclosed inspection repor In this report , NRC inspectors documented three licensee-identified violations, which were determined to be of very low safety significance (Green) or Severity Level I The NRC is treating these violation s as non-cited violation s (NCV s) consistent with Section 2.3.2.a. of the NRC Enforcement Polic 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 NRC's 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/ Geoffrey Miller, Chief Project Branch D Division of Reactor Projects Docket: 50-285;72-054 License: DPR-40 L. Cortopossi

- 2 - Enclosure:

NRC Inspection Reports 05000 285/2015004 and 07200054/2015001 w/Attachment: Supplemental Information Electronic Distribution to Fort Calhoun Station

Enclosure:

NRC Inspection Reports 05000 285/2015004 and 07200054/2015001 w/Attachment: Supplemental Information

ML16008A820 SUNSI Review By: BHagar ADAMS Yes No Non-Sensitive Sensitive Publicly Available Non-Publicly Available Keyword: NRC-002 OFFICE SRI:DRP RI:DRP SPE:DRP C:DR S C:DRS C:DRS C:DRS NAME MSchneider BCummings BHagar HGepford TFarnholtz GWerner VGaddy SIGNATURE E - GBM E - GBM /RA/ /RA/ /RA/ /GAP for/ /RA/ DATE 1/8/16 1/8/16 1/7/16 1/8/16 1/7/16 1/8/16 1/8/16 OFFICE C:DNMS C:DRP NAME RKellar GMiller SIGNATURE /R SB for/ /RA/ DATE 1/8/16 1/8/16 L. Cortopossi

- 3 - Letter to Lou Cortopossi from Geoffrey Miller dated January 8, 2016

SUBJECT: FORT CALHOUN STATION - NRC INTEGRATED INSPECTION REPORT NUMBER s 05000285/2015004 AND 07200054/2015001

DISTRIBUTION

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

DNMS Director (Mark.Shaffer@nrc.gov

) DNMS Deputy Director (Linda.Howell@nrc.gov

) DNMS Technical Assistant (Vivian.Campbell@nrc.gov

) RSFS Branch Chief (Ray.Kellar@nrc.gov

) RSFS Senior Inspector (Lee.Brookhart@nrc.gov

) RSFS Inspector (Eric.Simpson@nrc.gov

) Project Manager, DSFM (William.Allen@nrc.gov

) Spent Fuel Licensing BC, DSFM (Michele.Sampson@nrc.gov

) RIV Branch Chief, DRP/D (Geoffrey.Miller@nrc.gov)

Senior Resident Inspector (Max.Schneider@nrc.gov)

Resident Inspector (Brian.Cummings@nrc.gov)

Senior Project Engineer, DRP/D (Bob.Hagar@nrc.gov) Project Engineer, DRP/D (Jim.Melfi@nrc.gov)

Project Engineer, DRP/D (Jan.Tice@nrc.gov)

FCS Administrative Assistant (Janise.Schwee@nrc.gov)

Acting Team leader, DRS/TSS (Eric.Ruesch@nrc.gov)

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

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

NRR Project Manager (Fred.Lyon@nrc.gov)

RIV RITS Coordinator (Marisa.Herrera@nrc.gov)

RIV Regional Counsel (Karla.Fuller@nrc.gov)

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

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

OEWEB Resource@nrc.gov OEWEB Resource (Sue.Bogle@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

RIV/ETA: OEDO (Cindy.Rosales-Cooper@nrc.gov)

RIV RSLO (Bill.Maier@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

ROPreports

- 1 - Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 50-285 & 72-054 License: DPR-40 Report: 05000 285/2 015 0 04 & 07200054/2015001 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, NE 68008 Dates: October 1 through December 31, 2015 Inspectors:

S. Schneider, Senior Resident Inspector B. Cummings, Resident Inspector L. Carson II, Senior Health Physicist M. Chambers, Physical Security Inspector J. Kirkland, Senior Operations Engineer J. Melfi, Project Engineer J. O'Donnell, CHP, Health Physicist P. Jayroe, Reactor Inspector L. Brookhart, Senior ISFSI inspector E. Simpson, ISFSI Inspector Approved By:

Geoffrey Miller, Chief, Project Branch D Division of Reactor Projects

- 2 -

SUMMARY

IR 05000 285/2015004; 10/01/2015

- 12/31/2015

Fort Calhoun Station

Integrated Inspection Report The inspection activities described in this report were performed between October 1 and December 31, 2015 , by the resident inspectors at Fort Calhoun Station and inspectors from the NRC's Region IV office

. NRC inspectors documented in this report three licensee-identified violation s 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, "Aspects within the Cross-Cutting Areas." Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process."

=

Licensee-Identified Violations===

Three violation s of very low safety significance that were identified by the licensee ha ve been reviewed by the inspectors.

Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. These violation s and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

PLANT STATUS

The unit began and ended the inspection period at approximately 100 percent power.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1 R 01 Adverse Weather Protection (71111.01)

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On November 24, 2015, the inspectors completed an inspection of the station's readiness for seasonal extreme weather conditions. The inspectors reviewed the licensee's adverse weather procedures for cold weather operations and evaluated the licensee's implementation of these procedures. The inspectors verified that prior to the onset of cold weather, the licensee had corrected weather-related equipment deficiencies identified during the previous winter.

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

Emergency Diesel Generator Auxiliary Feedwater The inspectors reviewed the licensee's procedures and design information to ensure the systems would remain functional when challenged by cold weather. The inspectors verified that operator actions described in the licensee's procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of cold weather protection features.

These activities constitute d one sample of readiness for seasonal adverse weather , a s defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On November 20, 2015, and November 29, 2015, the inspectors completed an inspection of the station's readiness for impending adverse weather conditions. The inspectors reviewed plant design features, the licensee's procedures to respond to high winds, freezing conditions, and snow accumulation, and the licensee's implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.

These activities constituted two sample s of readiness for impending ad verse weather conditions, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identifi ed. 1 R 04 Equipment Alignment (71111.04)

.1 Partial Walk

down

a. Inspection Scope

The inspectors performed partial system walk

-downs of the following risk

-significant system s: Octobe r 27, 2015, raw water system with component cooling water heat exchanger C out of service for maintenance November 19, 2015, steam driven auxiliary feedwater pump following surveillance testing November 25, 2015, emergency diesel generator number 2 following maintenance December 9, 2015, containment spray train B when containment spray train A was taken out of service for maintenance The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration

. These activities constitute d four partial system walk

-down sample s as defined i n Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On October 15, 2015, the inspectors performed a complete system walk-down inspection of number 1 emergency diesel generator

. The inspectors reviewed the licensee's procedures and system design information to determine the correct emergency diesel generato r lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, and other open items tracked by the licensee's operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constitute d one complete system walk

-down sample , as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1 R 05 Fire Protection (71111.05)

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensee's fire protection program for operational status and material condition. The inspectors focused their inspection on five plant areas important to safety

October 29, 2015, basement and personnel corridor area, fire area 6-3 November 8, 2015, diesel generator room 1, fire area 35A November 19, 2015, main control room, fire area December 10, 2015, health physics corridor, fire area 19 December 10, 2015, east personnel corridor and personal air lock area, fire area 20-1 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constitute d five quarterly inspection sample s , as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1 R 06 Flood Protection Measures (71111.06)

a. Inspection Scope

O n December 4, 2015, the inspectors completed an inspection of underground bunkers susceptible to flooding. The inspectors selected two underground bunkers that contained risk

-significant or multiple

-train cables whose failure could disable risk

-significant equipment

Manhole 5A Manhole 31 The inspectors observed the material condition of the cables and splices contained in the bunkers and looked for evidence of cable degradation due to water intrusion.

The inspectors verified that the cables and vaults met design requirements.

These activities constitute completion of one bunker/manhole sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1 R 07 Heat Sink Performance (71111.07)

a. Inspection Scope

On December 16, 2015, the inspectors completed an inspection of the readiness and availability of a risk-significant heat exchanger. The inspectors reviewed the data from the performance of Component Cooling Water/Raw Water heat exchanger AC-1D disassembly, cleaning, visual inspection and reassembly activities as outlined in EPRI NP-7552.

Additionally, the inspectors walked down Component Cooling Water/Raw Water Heat Exchanger AC-1D to observe its performance and material condition and verified that the heat exchanger was correctly categorized under the Maintenance Rule and was receiving the required maintenance.

These activities constitute completion of one heat sink performance annual review sample , as defined in Inspection Procedure 71111.07.

b. Findings

No findings were identified.

1 R 11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11)

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On November 13, 2015, the inspectors observed simulator training for an operating crew in response to an Au xiliary Feedwater Actuation System malfunction and an Armed Attack. The inspectors assessed the performance of the operators and the evaluators' critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the training.

These activities constitute completion of one quarterly licensed operator requalification program sample , as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

On October 2, 2015, the inspectors observed the performance of on

-shift licensed operators in the plant's main control room. At the time of the observations, the plant was in a period of heightened activity due to the declaration of a Notification of Unusual Event due to a suspicious device found in a security vehicle. The inspectors observed the operators' performance related to adherence of abnormal operating procedures, evaluation of plant risk, and assessment of Emergency Action Level criteria. These activities constitute completion of one quarterly licensed operator performance sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Annual Review

a. Inspection Scope

The inspector s conducted an in

-office review of the annual requalification training program to determine the results of this program.

On December 9, 2015, the licensee informed the inspector s of the Fort Calhoun Station operating test results:

7 of 7 crews passed the simulator portion of the operating test 31 of 33 licensed operators passed the simulator portion of the operating test

31 of 33 licensed operators passed the job performance measure portion of the operating test No remediation was performed for the Fort Calhoun Station operating tests. Two licensed operators who did not pass the simulator or job performance measure portions of the operating test were unavailable for personal reasons and will meet the requalification exam requirements in 2016.

The inspector s completed one inspection sample of the annual licensed operator requalification program.

b. Findings

No findings were identified.

1 R 12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors reviewed three instances of degraded performance or condition of safety

-related structures, systems, and components (SSCs): November 10, 2015, inadvertent cross

-connecting of the main feedwater system with the auxiliary feedwater system November 23, 2015, identification of cracked pressurizer heater cables December 7, 2015, inadvertent closure of shutdown cooling isolation valves The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensee's corrective actions. The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constitute d completion of three maintenance effectiveness sample s , a s defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1 R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed four risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

October 28, 2015, planned yellow risk during number 2 emergency diesel generator testing

November 2, 2015, planned yellow risk during west raw water header maintenance outage November 5, 2015, planned yellow risk during diesel drive n auxiliary feedwater pump operability verification November 23, 2015, planned yellow risk during number 2 emergency diesel generator maintenance The inspectors verified that these risk assessment were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensee's risk assessment s and verified that the licensee implemented appropriate risk management actions based on the result of the assessment s.

These activities constitute completion of four maintenance risk assessments, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1 R 15 Operability Determinations and Functionality Assessments (71111.15)

a. Inspection Scope

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

October 21, 2015, operability determination of blowdown isolation valve non

-conservative component specifications October 22, 2015, operability determination of pressurizer heater bank number 4 due to hot short potential circuit failure following discovery of an unanalyzed condition October 26, 2015, operability determination of instrument air accumulator leak on component cooling water valve HCV

-401C October 29, 2015, operability determination of containment spray discovery of non-conformances with design November 4, 2015, functionality determination of raw water flow instrumentation

following discovery of a degraded condition December 8, 2015, assessment of operator work arounds The inspectors reviewed the timeliness and technical adequacy of the licensee's evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensee's compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC

. The inspectors reviewed operator actions taken or planned to compensate for degraded or nonconforming conditions.

The inspectors verified that the licensee effectively managed these operator workarounds to prevent adverse effects on the function of mitigating systems and to minimize their impact on the operators' ability to implement abnormal and emergency operating procedures.

These activities constitute completion of s ix operability review sample s, which included one operator work

-around sample, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1 R 18 Plant Modifications (71111.18)

a. Inspection Scope

On October 29, 2015, the inspectors reviewed one permanent plant modification to the containment spray ring riser piping and rings to restore operability. The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event.

These activities constitute completion of one sample of permanent modifications , a s defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1 R 19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

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

-significant structures, systems, or components (SSCs):

October 27, 2015, replace control relay for containment air cooling fan VA-7D November 5, 2015, charging pump CH-1B discharge drain valve weld repair November 16, 2015, charging pump CH-1A rebuild December 15, 2015, emergency diesel generator damper actuator replacement The inspectors reviewed licensing- and design

-basis documents for the SSCs and the maintenance and post-maintenance test procedures.

The inspectors reviewed the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constitute completion of four post-maintenance testing inspection sampl es , as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1 R 22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors observed four risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components (SSCs) were capable of performing their safety functions:

Containment isolation valve surveillance tests: October 26, 2015, Component Cooling Category A and B Valve Exercise Test Other surveillance tests:

October 16, 2015, automatic load sequencer test November 19, 2015 steam driven auxiliary feedwater flow verification December 9, 2015, number 1 emergency diesel generator surveillance test The inspectors verified that these test s 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 four surveillance testing inspection sample s , a s defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones:

Public Radiation Safety and Occupational Radiation Safety 2 RS 2 Occupational ALARA Planning and Controls (71124.02)

a. Inspection Scope

The inspectors assessed licensee performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). During the inspection, the inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site

-specific trends in collective exposures, and source-term measurements ALARA work activity evaluations/post

-job reviews, exposure estimates, and exposure mitigation requirements The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man

-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas Audits, self

-assessments, and corrective action documents related to ALARA planning and controls since the last inspection These activities constitute completion of one sample of occupational ALARA planning and controls as defined in Inspection Procedure 71124.02.

b. Findings

No findings were identified.

2 RS 4 Occupational Dose Assessment (71124.04)

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the licensee's personnel monitoring equipment, verified the accuracy and effectiveness of the licensee's methods for determining total effective dose equivalent, and verified that the licensee was appropriately monitoring occupational dose.

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

External dosimetry accreditation, storage, issue, use, and processing of active and passive dosimeters The technical competency and adequacy of the licensee's internal dosimetry program Adequacy of the dosimetry program for special dosimetry situations such as declared pregnant workers, multiple dosimetry placement, and neutron dose assessment Audits, self

-assessments, and corrective action documents related to dose assessment since the last inspection These activities constitute completion of one sample of occupational dose assessment as defined in Inspection Procedure 71124.04.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security 4OA 1 Performance Indicator Verification (71151)

.1 Mitigating Systems Performance Index:

Emergency AC Power System s (MS06)

a. Inspection Scope

The inspectors reviewed the licensee's mitigating system performance index data for the period of October 1, 2014 through September 30, 2015 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for emergency ac power systems as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index

Residual Heat Removal System s (MS09)

a. Inspection Scope

The inspectors reviewed the licensee's mitigating system performance index data for the period of October 1, 2014 through September 30, 2015 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data. These activities constituted verification of the mitigating system performance index for residual heat removal systems as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Reactor Coolant System Specific Activity (BI01)

a. Inspection Scope

The inspectors reviewed the licensee's reactor coolant system chemistry sample analyses for the period of October 1, 2014 through September 30, 2015 to verify the accuracy and completeness of the reported data.

The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system specific activity performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA 2 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 licensee's corrective action program and periodically attended the licensee's 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 licensee's problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semi annual Trend Review

a. Inspection Scope

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

These activities constitute completion of one semiannual trend review sample , a s defined in Inspection Procedure 71152.

b. Findings and Observations

No findings were identified.

Equipment Reliability In NRC Inspection Report 05000285/201500 2 , the inspectors identified a continuing adverse trend in equipment reliability at Fort Calhoun Station. The inspectors reviewed equipment reliability challenges from 2014 and 2015 through completion of the refueling outage in June, 2015. These challenges resulted in equipment unavailability, unplanned technical specification entries, operator burdens, and in some cases, plant transients. Of more recent concern wer e a number of equipment reliability issues during the refuelin g outage that affected safety system availability and plant performance. The licensee took specific actions to correct the individual equipment performance issues during the observed timeframe.

In addition, the licensee conducted a start

-u p challenge review of the events that occurred during the outage prior to plant start-up. Finally, the licensee senior leadership team had implemented engineering department excellence plans, equipment reliability improvement activities with engineering in partnership with the maintenance and operating departments, focus ed on operating experience

, self-assessment activities and benchmarking, and u tilized a plant health committee T op 10 list to improve critical system health.

Since that time, the licensee has continued to reduce backlogs in open operability determinations and temporary configuration changes. In addition, the licensee's plant health committee continues to focus on their Top 10 equipment list to resolve those critical items. The licensee engineering leadership team is also committed to the continuing improvement of the boric acid corrosion control and maintenance rule programs.

The inspectors monitored equipment reliability over the past two quarters. Although some improvement has been note d , such as the apparent resolution of air voids in the component cooling water system and a reduction in the number of long term operability evaluations, the inspectors continue to observe equipment reliability issues at Fort Calhoun Station. Examples include: control room air conditioning failures, continuing safety injection tank (SIT) check valve leakage requiring frequent SIT drain and refills, reactor coolant pump RC

-3A seal performance and vibration issues, and a pressurizer level charging pump control circuit failure. The inspectors have determined that additional monitoring of the licensee's progress in improving equipment reliability at the Fort Calhoun Station is warranted and will be evaluated with the results documented in the next semiannual trend review.

.3 Annual Follow

-up of Selected Issues

a. Inspection Scope

The inspectors selected one issue for an in

-depth follow

-up: On November 30, 2015, gas voiding in the component cooling water system The inspectors assessed the licensee's problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to minimize the likelihood of voids developing in the component cooling water system.

These activities constitute completion of one annual follow

-up sample as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA 3 Follow-up of Events and Notices of Enforcement Discretion (71153)

.1 Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating sys tems as applicable. The inspectors communicated the plant events to appropriate regional personnel, and compared the event det ails with criteria contained in Ins pection Manual Chapter 0309, "Reactive Inspection Decision Basis for Reactors," for consideration of potential reactive inspection activities. As applicable, the in spectors verified that the licensee made appropr ia te emergency classification assessmen ts and properly re ported the event in accordance wit h 10 CFR Parts 50.72 and 50.73. The inspectors reviewed the licensee's follow

-up actions related to the event to assure that the licensee implemented a p propriate corrective actions commensurate with their safety significance.

Operator response to the declaration of an unusual event due to a security condition on October 2, 2015 Operator response to an unanalyzed condition due to inadequate electrical isolation between the main control room and local operation of pressurizer heater bank 4, on October 21, 2015

b. Findings

No findings were identified.

0. "Inadequate Design of High Energy Line Break Barriers"

The licensee submitted this report after they discovered that an inadequate High Energy Line Break (HELB) barrier had not been reported when it was originally discovered on September 30, 2013. The degraded barrier has been repaired and this LER was issued to document the original unanalyzed condition. The inspectors considered the licensee's previous actions to repair the HELB barrier and the documentation of this issue in the LER to be adequate and appropriate. The failure to report this condition in a timely manner is considered a minor violation in accordance with Section 2.3.1 of the Enforcement Policy. This failure to comply with the 10 CFR 50.73 reporting requirements in a timely manner constitutes a minor violation that is not subject to enforcement action in accordance with the NRC's Enforcement Policy. Therefore, this LER is closed. Documents reviewed are listed in the attachments.

0. "Inoperable Auxiliary Feedwater System Due to Inadequate Procedure Change

" The licensee submitted this report after they discovered that a procedure momentarily cross-tied Main Feed water (MFW) with Auxiliary Feedwater (AFW) during system restoration steps. The failure to maintain qualified boundaries between these two systems resulted in the inoperability of the AFW system. The licensee causal analysis determined that procedure reviewers did not understand piping class separation requirements. To address this condition, the licensee conducted an extent of condition review and identified that additional AFW system p rocedure s were affected. T hese AFW procedures were administratively restricted for use until they were subsequently revised to correct the lineups. No system procedures other than AFW were found to have similar cross connecting issues. In addition, the licensee has submitted a Training Request Form to address operators understanding of the operability impact of cross

-tying class and non

-class piping systems.

NRC inspectors reviewed the details of this condition including corrective action documents, procedure revisions, and training documentation. Based on a review of the condition, the inspectors determined that during the period that the MFW and AFW systems were cross

-tied that the licensee was in violation of Technical Specification 2.5(1) which requires two AFW trains to be operable when cold leg temperature is above 300F. This violation was identified by the licensee and is discussed in further detail in section

4OA7 of this report.

Therefore, this LER is closed. Documents are listed in the attachment.

.4 (Closed) Licensee Event Report (LER) 05000285/2015

00, "Containment Spray Inoperable due to Original Design Error" On April 16, 2015, during a refueling outage the licensee identified that because the original design of the plant failed to consider the thermal effects of a main steam line break or loss of coolant accident on containment spray piping, modifications were necessary to ensure the operability of the containment spray system during one of these postulated events. This condition existed because the original design of the plant did not account for the rise in the temperature of the dry containment spray piping inside containment. During a main steam line break or loss of coolant accident this piping would heat up more rapidly than piping that contains water and could reach temperatures of up to 290 degrees Fahrenheit. This rise in temperature would impose previously unaccounted for thermal stresses on the piping which in turn would transmit those stresses to the containment liner via certain pipe supports. The licensee corrected the problem by performing modifications to the containment spray pipe supports to ensure that stress limits would not be exceeded in the event of the aforementioned condition. The licensee also performed calculations and determined that prior to the modifications, if the postulated event were to occur, the containment spray piping and supports would have been able to deliver adequate flow despite exceeding ASME Section III Appendix F stress limits for one pipe support.

NRC inspectors reviewed the details of this condition including pertinent calculations, corrective action documents, procedures, and completed work documentation associated with the modifications to the containment spray pipe supports. Based on a review of the condition inspectors determined that during the period prior to the modifications of the containment spray supports the licensee was in violation of Technical Specification 2.4(1)a.iv which requires all piping associated with the containment spray pumps to be operable while the reactor is in operation. This violation was identified by the licensee and is discussed in further detail in section

4OA7 of this report.

Therefore, this LER is closed. Documents are listed in the attachment

. These activities constitute completion of five event follow

-up sample s, as defined in Inspection Procedure 71153.

OTHER ACTIVITIES

.1 Operation of an Independent Spent Fuel Storage Facility Installation (ISFSI) at Operating Plants (60855.1)

a. Operation of an ISFSI Inspection Scope A routine ISFSI inspection was conducted of the Fort Calhoun Station (FCS) ISFSI on September 21

-24, 2015, by Region IV Division of Nuclear Material Safety inspectors. The inspectors observed and evaluated select licensee loading, processing, and heavy load procedures associated with the licensee's ISFSI program. Inspectors performed a review of the dry fuel storage records for the casks loaded at the ISFSI to verify that the licensee had loaded fuel in accordance with the Technical Specifications (TS) for approved contents.

A document review of routine ISFSI activities since the last NRC ISFSI inspection (April 2013) was performed by the inspectors. The licensee had not loaded any new canisters since the last NRC routine ISFSI inspection.

The inspectors requested documentation related to maintenance of the fuel building cask handling crane. Documents were provided that demonstrated the fuel building cask handling crane was inspected on an annual basis in accordance with the American Society of Mechanical Engineers (ASME) B30.2 safety requirements.

The inspectors reviewed the r adiological conditions at the FCS ISFSI through a document review of the most recent radiological survey and three years of thermoluminescent dosimeter (TLD) monitoring data from around the ISFSI. A dry

-cask-loading supervisor and one radiation protection (RP) technician accompanied the NRC inspector s during a walk

-down of the ISFSI pad. A radiological survey was performed by one RP technician to record gamma exposure rates. The measurements taken by the RP technician and independently confirmed by the NRC inspector s were consistent with measurements recorded on the most recent ISFSI site survey. The radiological conditions in and around the ISFSI were as expected for the age, heat

-load, and number of casks currently loaded at the ISFSI. The inspectors reviewed Annual Radiological Environmental Operating Reports for the FCS site for the last three years. The reports documented the dose equivalent to any real individual located beyond the site controlled area had been well below the 10 CFR 72.104(a)(2) requirement of less than 25 mrem per year.

The NRC inspectors review ed the Corrective Action Program (CAP) associated with the ISFSI. A list of condition reports issued since the last NRC inspection conducted in April 2013, was provided by the licensee for the cask handling crane and ISFSI operations.

Of the list of Condition Reports (CRs) provided relating to the ISFSI and the cask handling cranes, the inspectors selected 3 7 for further review. The CRs were related to a variety of issues. The condition reports reviewed were well documented and properly categorized based on the safety significance of the issue. The corrective actions taken were appropriate for the situations.

The inspectors reviewed the licensee's 10 CFR 72.48 screenings and evaluations for ISFSI program changes since the last NRC routine ISFSI inspection. Of the list of screenings provided by the licensee, the inspectors selected five for further review.

Fort Calhoun Station had not performed any full 72.48 evaluations since the last NRC ISFSI inspection. The inspectors determined that the licensee had adequately evaluated the screenings reviewed.

The inspectors performed an on-site review of the Quality Assurance (QA) audits and QA surveillance reports related to dry cask storage activities at the FCS ISFSI. The QA audit reports and surveillances resulted in several condition reports. The inspectors reviewed the corrective actions resulting from the CRs to ensure that the identified deficiencies were properly categorized based on its safety significance and were properly resolved.

b. Findings

Adequate Analysis that Documents Protection of the ISFSI from Fires and Explosions Introduction

. The inspectors identified an unresolved issue associated with the licensee's ISFSI Fire and Explosion Hazard

Analysis.

Federal Regulations 10 CFR 72.212(b)(3) required general licensees to ensure that each cask used conforms to the terms, conditions, and specifications of the Certificate of Compliance. During a review of FCS Updated Fire Hazards Analysis (UFHA) EA97

-001 Appendix D "ISFSI Fire and Explosion Hazards Review," further information was required to determine if FCS was in compliance with the analysis.

Description

. The FCS UFHA EA97

-001 Appendix D was dated March 28, 2006. Section 3.3.2 of the Appendix documented that the analysis was based on a walk

-down of the station that took place in June of 2005. Many examples were found during the review of the UFHA such that the NRC was unable to substantiate whether or not the licensee's analysis bounded the current operations and site configuration around the ISFSI.

Many referenced analyses and sections in the UFHA referred to use of the light

-weight transfer cask and not the heavier OS197 Transfer Cask that is currently used by the licensee. A walk down of the storage yard to the south of the ISFSI identified a few office trailers and other miscellaneous combustible equipment that was not discussed in the UFHA. In 2007, Engineering Change 29295 replaced the main transformer. It was undetermined if this transformer was the same transformer that was analyzed in Section 3.3.2 of the ISFSI Fire and Explosion Hazards Review.

The licensee's review of this issue will be tracked as an Unresolved Item (URI) until the NRC is provided sufficient information to determine if ISFSI operations are bounded by the site's UFHA. (URI 07200054/5015004

-01, "Adequate Analysis that Documents Protection of the ISFSI from Fires and Explosions

"). 4OA 6 Meetings, Including Exit On September 24, 2015 , the inspectors debriefed Mr. S. Dean, Plant Manager, and other members of the licensee's staff of the results of the ISFSI inspection documented in Section 4OA5.

On October 23, 2015, and after the Regional staff received consultation from NRC Headquarters Division of Spent Fuel Management's Spent Fuel Licensing Branch, regarding the Licensee identified violation discussed in Section 4OA7.1, the inspectors conducted a telephonic exit with Mr. S. Dean, Plant Manager, and other staff members. The inspectors presented the inspection results to members of the licensee management and staff. Licensee personnel acknowledged the information presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered propriety. No propriety information was identified.

On November 19, 2015, 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.

On December 9, 2015, the inspector s obtained the final annual cycle results and exited with Mr. B. Blessie, Operator Training Instructor. The inspector s did not review any proprietary information during this inspection.

On January 7, 2016, 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.

4OA 7 Licensee-Identified Violations The following violation s of very low safety significance (Green) were identified by the licensee and were violation s of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as non-cited violation s.

.1 Title 10 CFR 72.174 requires that each licensee maintain sufficient records to furnish evidence of activities affecting quality.

Records pertaining to the design, fabrication, erection, testing, maintenance, and use of structures, systems, and components important to safety must be maintained by or under the control of the licensee until the NRC terminates the license. Contrary to the above, as of June 21, 2013, Fort Calhoun failed to maintain sufficient records to furnish evidence of activities affecting quality. Specifically, the licensee did not maintain records for loading activities associated with DFS

-HSM-06 that was placed on the ISFSI pad in July of 2009. This violation was identified by FC S and placed in their corrective action program (CR 2013

-12884). The fuel assembly data was reconstituted based on records from the Reactor Engineering group

, and the canister helium leak

-test data was reconstituted based on the helium leak

-test technician's field notes. The remaining canister records associated with the canister processing, sealing, and transpor tation to the ISFSI, including several TS requirements, were not found. Fort Calhoun reconstituted the fuel and helium leak test data and conducted interviews with cask loading personnel to conclude that there was no evidence to suggest that loading activities did not comply with the licensee's procedures and the licensed Technical Specifications. This violation did not have any safety impact because all fuel assemblies met the requirements for burn

-up, decay heat, and cooling time and the licensee demonstrated that the canister integrity was intact based on the reconstituted helium leak test records. All the fuel inside the canister and the cask remain in a safe condition. This finding was reviewed by NRC Headquarters Division of Spent Fuel Management's Spent Fuel Licensing Branch. Based on the reconstituted records and interviews with the dry fuel loading staff, the NRC found no evidence to demonstrate that the canister did not meet the required license conditions and as such, found the canister acceptable for continued storage under FCS's general Part 72 license. However, though the canister is acceptable for storage, the licensee must track this issue to identify that further analyses may be required for this canister to meet all applicable Part 71 requirements to be acceptable for transportation.

In accordance with the NRC Enforcement Policy Section 2.2 and IMC 0612 Section 03.23, Part 72 ISFSI inspection findings follow the traditional enforcement process and are not disposition ed through the Reactor Oversight Process or the Significance Determination Process. The violation screened as having very low safety significance, Severity Level IV, and is being treated as a non

-cited violation, consistent with Section 2.3.2.a. of the Enforcement Policy.

The violation was determined to be more than minor since the licensee failed to establish, maintain, or implement adequate controls over procurement, construction, examination, or testing processes that are important to safety. The violation was entered into the licensee's corrective action program as CR 2013-12884. Following identification of the issue the licensee performed an assessment that showed the cask would continue to perform its design function. Corrective actions for this issue included performing an extent of condition review, performing an apparent cause analysis report, reconstitution of the missing documents, conducting interviews with the dry cask loading personnel, providing training to the staff involved, and changing processes and responsibilities within FCS Records Management Group.

.2 Technical Specification (TS)

2.4(1)a.iv requires that all valves, piping, and interlocks associated with the components of the containment cooling system required to function during accident conditions be operable

. In the event that any of these components

, required to function during accident conditions become inoperable, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The containment spray pumps and the associated piping are part of the containment cooling system. Prior to making modifications to containment spray piping in 2015 , the operability of this piping would have been challenged by a main steam line break or a loss of coolant accident due to thermal stresses induced in the piping after a rise in containment temperature after the postulated event. Operation prior to the implementation of the modifications was a violation of the technical specification requirements to maintain operability of containment cooling systems.

The violation is more than minor because it is associated with the design control attribute of the mitigating systems cornerstone because the failure to anticipate the rise in containment spray piping temperature dates back to the original design of the plant. This adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The violation was of very low safety significance because although the subject piping was inoperable due to exceeding code specified stress limits, analysis showed that the piping would have been able to perform its safety function to deliver adequate containment spray flow in the event of an accident. The licensee entered the issue into their corrective action program as Condition Report 2015-04578.

.3 Technical Specification (TS)

2.5(1) requires two trains of auxiliary feedwater (AFW) to be operable when cold leg temperature is above 300F. In the event that both trains become inoperable, immediate action is required to restore one AFW train to operable status. Technical Specification 2.0.1 and all TS actions requiring mode changes are suspended until one AFW train is restored to operable status. Operation with the main and auxiliary feedwater cross-tied was a violation of the technical specification requirements to maintain operability of AFW systems. The violation is more than minor because it is associated with the configuration control attribute of the mitigating systems cornerstone because the failure to prevent cross

-tying these systems resulted in unrecognized inoperability of both trains of AFW. This adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The violation was of very low safety significance because although MFW and AFW were momentarily cross

-tied, this condition existed for only a brief period of time as operators restored system line

-ups following system testing. In addition, a Senior Reactor Analyst evaluated the postulated main feedwater line break frequency and exposure time of the condition and determined the likelihood of this event during the exposure time is less than the Green/White threshold and of very low safety significance. The licensee entered the issue into their corrective action program as Condition Report 2015 03698.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Beck, Manager, Chemistry, Environmental, and Radwaste

B. Blome, Manager, Regulatory Assurance

D. Brehm, Supervisor, Radiation Protection

C. Cameron, Principal, Regulatory Specialist

H. Childs, Manager, Security

L. Cortopassi, Site Vice President

S. Dean, Plan

t Mana g er

A. Dudas, Radiation Health Specialist, Radiation Protection

L. Eaton, Licensed Operator

S. Fatora, Director, Site Work Management

H. Goodman, Director, Site Engineering

M. Holaway, Licensed Operator

R. Hugenroth, Manager, Nuclear Oversight

T. Jantzi, Unit Supervisor

D. Little, Health Physicist, Radiation Protection

T. Maine, Manager, Radiation Protectio

n

E. Matzke, Senior Licensing Engineer

D. Ortiz, Shift Technical Advisor

A. Pallas, Shift Manager

T. Parent, Engineering

M. Peak, Operator Burdens Coordinator

B. Pearson, Supervisor, Radiation Protection

E. Plautz, Manager, Emergency Planning

C. Scofield, Design Engineering

S. Swanson, Director, Operations

R. Swerczek II, Engineering

P. Turner, ISFSI Manager

T. Uehling, Manager, Training

NRC Personnel

M. Sampson, Division of Spent Fuel Management

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened 07200054/2015001

-01 URI Adequate Analysis that Documents Protection of the ISFSI from Fires and Explosions

(Section 4OA5) Closed 05000 285/2015-001-0 0 LER Inadequate Design of High Energy Line Break Barriers

(Section 4OA3)

05000285/2015-002-00 LER Inoperable Auxiliary Feedwater System Due to Inadequate Procedure Change

(Section 4OA3)

05000285/2015-003-00 LER Containment Spray Inoperable Due to Original Design Error

(Section 4OA3)