ML12318A319

Issuance of U.S. Nuclear Regulatory Commission Manual Chapter 0350 Panel Fort Calhoun Station Restart Checklist Basis Document

ML12318A319
Person / Time
Site:	Fort Calhoun
Issue date:	11/13/2012
From:	Vegel T Division of Nuclear Materials Safety IV
To:	Leeds E NRC Region 4
Hay M
References
Download: ML12318A319 (52)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I V 1600 EAST LAMAR BLVD ARLINGTON, TEXAS 76011-4511 November 13, 2012 MEMORANDUM TO: Eric Leeds, Director, Office of Nuclear Reactor Regulation Elmo Collins, Regional Administrator, Region IV FROM: Tony Vegel, Chairman, IMC 0350 Panel /RA/

SUBJECT:

Issuance of U.S. Nuclear Regulatory Commission Manual Chapter 0350 Panel Fort Calhoun Station Restart Checklist Basis Document On June 11, 2012, the NRC issued a revised Confirmatory Action Letter (CAL) documenting the actions that Fort Calhoun Station will take prior to restart to address the issues that resulted in prolonged performance decline. Included in the CAL was the Restart Checklist which listed the specific items that will be reviewed by the NRC.

The enclosed document, U.S. Nuclear Regulatory Commission Manual Chapter 0350 Panel Fort Calhoun Station Restart Checklist Basis Document was recently approved by the MC 0350 Panel members. This document provides details and clarification for the scope and breadth of the Restart Checklist items and the minimum actions that the NRC plans to take to verify that Fort Calhoun Station has adequately addressed the specific items. The overall scope of these activities was developed to ensure that the issues that resulted in the prolonged performance decline at Fort Calhoun Station are understood and resolved. The basis document was developed to provide the public a detailed list of items that the NRC will review, as a minimum, to ensure the operational safety of Fort Calhoun Station. In addition, this detailed list of items that the licensee will evaluate, and the NRC will independently assess, will facilitate the planning and scheduling of future inspections.

Additionally, the outcome of NRC actions described in the enclosed basis document will be used by the MC 0350 Panel to assess plant readiness for restart.

This document will be made available to the public both in ADAMS and the Special Oversight at Fort Calhoun Station web site.

This will be a living document that will be periodically updated to reflect status of inspection activities and when new inspection items are added following MC 0350 Panel review.

If you have any questions, please contact myself or Louise Lund, MC 0350 Co-Chair.

1 Enclosure

cc: Electronic Distribution DISTRIBUTION:

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

ACTING DRP Deputy Director (Barry.Westreich@nrc.gov)

ACTING DRS Director (Tom.Blount@nrc.gov)

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

MC0350 Panel Chair (Anton.Vegel@nrc.gov)

MC0350 Panel Co-Chair (Louise.Lund@nrc.gov)

MC0350 Panel Member (Michael.Balazik@nrc.gov)

MC0350 Panel Member (Michael.Markley@nrc.gov)

Director, DIRS (Ho. Nieh @nrc.gov)

Director, DORL (Michelle Evans@nrc.gov)

Deputy Director, DORL (Allen.Howe@nrc.gov)

Branch Chief, IPAB (Rani.Franovich.@nrc.gov)

Senior Resident Inspector (John.Kirkland@nrc.gov)

Resident Inspector (Jacob.Wingebach@nrc.gov)

Branch Chief, DRP/F (Michael.Hay@nrc.gov)

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

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

Physical Security Inspector (Jesse.Rollins@nrc.gov)

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

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

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

Project Manager (Lynnea.Wilkins@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

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

OEMail Resource ML12318A319 R:\_REACTORS\_FCS\2012\ FCS RESTART CHECKLIST BASIS DOCUMENT.DOCX Non Sensitive JMR Publicly Available JMR SUNSI Review JMR Sensitive Non-Publicly Available SRI:DRP/F PM:DORL/LB IV C:DORL/LB IV C:DRP/F DD:DRS JKirkland LWilkins MMarkley MHay JClark

/MCHay for/ /RA via E/ /RA via E/ /RA/ /RA/

11/8/12 11/8/12 11/7/12 11/8/12 11/8/12 DD:DORL D:DRP D:DNMS LLund KKennedy AVegel

/RA/ /RA/ /RA/

11/5/12 11/10/12 11/13/12

U.S. Nuclear Regulatory Commission Manual Chapter 0350 Panel Fort Calhoun Station Restart Checklist Basis Document The Restart Checklist is a list of items that require resolution prior to restart. The purpose of the Restart Checklist is to verify the issues that resulted in the prolonged performance decline at Fort Calhoun Station are resolved. The Restart Checklist includes an assessment of each of the key attributes described in NRC Inspection Procedure (IP) 95003, Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs or One Red Input.

This basis document provides details and clarification of the scope and breadth of the Restart Checklist items and the actions, at a minimum, that the NRC plans to take to verify Fort Calhoun Station adequately addressed the specific items. These actions that the NRC plans to perform were developed to ensure safe operation of the facility following restart. The Restart Checklist includes broad areas for resolution, including the following items that are described in NRC IP 95003:

• involve inspection findings that were determined to be of more than very low safety significance

• address a cited violation of the facilitys license, technical specifications, or regulations

• concern a loss of ability to maintain and operate the facility in accordance with the design and licensing basis

• address a licensing action that is necessary to be completed prior to restart

• address a failure of licensee management controls to effectively address previous significant concerns to prevent their recurrence (for example, repetitive examples of inadequate root cause evaluations and corrective actions that affect risk-significant equipment and plant operation or both)

The outcomes of the Restart Checklist will provide the NRC a thorough assessment of the causes of the performance decline at Fort Calhoun Station, provide assurance that planned corrective actions are sufficient to address the root causes and contributing causes and to prevent their recurrence, and to verify that adequate qualitative or quantitative measures for determining the effectiveness of the corrective actions are in place. These assessments will be used by the NRC to independently determine if plant personnel, equipment, and processes are ready to support the safe restart and continued safe operation of Fort Calhoun Station.

This basis document is a living document and will be updated as necessary. Any additional significant performance deficiencies identified may be added to the Restart Checklist. Items not requiring resolution prior to restart will be evaluated during the NRCs review of the post-restart sustained improvement plan.

This Restart Checklist Basis Document describes the areas to be addressed within each Restart Checklist section.

1 Enclosure

Section 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 the performance deficiencies identified at Fort Calhoun Station for all greater than green findings. 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 will identify 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 will also include an assessment against appropriate NRC Inspection Procedure 95003 key attributes as described in Section 5.

As additional critical areas for improvement are identified during the root cause evaluations and other assessments, it may be necessary to supplement the Restart Checklist or the Restart Checklist Basis Document to reflect those new items.

Item 1.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 as documented in NRC Inspection Report 05000285/2010007, (ML102800342). With respect to this finding the NRC will verify that the licensee adequately identifies the root and contributing causes of the risk significant issue; verify that the extent of condition and extent of causes of the risk significant issue are identified, and verify that the corrective actions adequately address the causes to preclude repetition. The following licensee actions will be reviewed by the NRC:

Item Actions to be Verified Prior to Restart Status 1.a.1 Flooding Yellow Finding root and contributing cause evaluation 1.a.2 Flooding Yellow Finding extent of condition and cause evaluation 1.a.3 Flooding Yellow Finding corrective actions addressing root and contributing causes The NRC will verify that the actions related to the Yellow Finding being implemented by the licensee are adequate to support plant restart. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number Review / observe all external flood barrier configurations and verify 4.2.1.1 that they have not been altered during flood response or outage

activities 4.2.1.2 Issue SO-G-124, Flood Barrier Impairment program Document external flood barrier impairments as applicable in 4.2.1.3 accordance with SO-G-124 Identify flood barriers which will not have adequate qualification 4.2.1.6 basis before leaving Cold Shutdown.

The following NRC open items are specifically related to the Yellow finding and therefore need to be evaluated prior to restart of the facility. For these specific items the NRC will verify that the licensee has performed adequate root cause 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 will verify 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.

Item Description Status LER 2012-001-0 Inadequate Flooding Protection Procedure LER 2012-019-0 Traveling Screen Sluice Gates Found with Dual Indication LER 2011-003-3 Inadequate Flooding Protection Due to Ineffective Oversight LER 2011-001-0 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 Although not a specific plant restart action, the NRC will review the following long term actions planned to be implemented by the licensee.

Action Description Status Item Number 4.4.3.1 Gather flood response lessons learned through CR reviews to determine if procedure or strategy changes should be implemented 4.4.3.2 Review flood design basis and determine if the 2011 flood event provides additional information that should drive design basis changes 4.4.3.3 Implement procedure and strategy changes as indicated by the lessons learned review conducted

Item 1.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 (RPS). This deficiency resulted in a White (low to moderate safety significance) finding as documented in NRC Inspection Report 05000285/2011007, (ML112000064). With respect to this finding the NRC will verify that the licensee adequately identifies the root and contributing causes of the risk significant issue; verify that the extent of condition and extent of causes of the risk significant issue are identified, and verify that the corrective actions adequately address the causes to preclude repetition. The following licensee actions will be reviewed by the NRC:

Item Actions to be Verified Prior to Restart Status 1.b.1 RPS White Finding root and contributing cause evaluation 1.b.2 RPS White Finding extent of condition and cause evaluation 1.b.3 RPS White Finding corrective actions addressing root and contributing causes The following NRC open item is specifically related to the White finding and therefore needs to be evaluated prior to restart of the facility.

Item Description Status VIO 2011007-01 Failure to Correct a Degraded Contactor in the Reactor Protective System Item 1.c Electrical Bus Modification and Maintenance - Red Finding Item 1.c is included in the restart checklist for the failure to adequately design, modify, and maintain the electrical power distribution system, resulting in a fire in the safety-related 480 volt electrical switchgear. These deficiencies resulted in a Red (high safety significance) finding as documented in NRC Inspection Report 05000285/2012010, (ML12101A193). With respect to this finding the NRC will verify that the licensee adequately identifies the root and contributing causes of the risk significant issue; verify that the extent of condition and extent of causes of the risk significant issue are identified, and verify that the corrective actions adequately address the causes to preclude repetition. The following licensee actions will be reviewed by the NRC:

Item Actions to be Verified Prior to Restart Status 1.c.1 Electrical Fire Red Finding root and contributing cause evaluation 1.c.2 Electrical Fire Red Finding extent of condition and cause evaluation 1.c.3 Electrical Fire Red Finding corrective actions addressing root and contributing causes

In addition, the NRC will verify that the actions related to the Red Finding being implemented by the licensee are adequate to support plant restart. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Description Status Item Number 1.3.1.1 Rebuild the 1B4A load center 1.3.1.2 Provide documentation for the dedication of the rebuilt load center in accordance with Contract 163495 1.3.1.3 Complete Engineering Change 53257 and obtain PRC approval to authorize the use of the rebuilt load center, 1B4A 1.3.1.4 Test all cables that terminate in 1B4A load center 1.3.1.5 Repair or replace defective cables terminating in 1B4A load center 1.3.1.6 Perform testing on the insulation of the cables that were potentially impacted by the fire located in the cable tray above 1B4A load center using EPRI technology 1.3.1.7 Complete Engineering Change 53517 that details the repair to the cable jackets for cables located in the cable tray above 1B4A load center 1.3.1.8 Repair or replace the cables located in the cable tray above load center 1B4A that have had jacket damage 1.3.1.9 Witness Factory Acceptance Testing of the new Square D circuit breakers that will be used in the 1B4A load center to replace the existing AK-25 breakers and the two Square D input and bus tie breakers 1.3.1.10 Calibration of the internal relays and protection equipment for Bus1B4A 1.3.1.11 Install new 4160 to 480 volt transformer T1B4A 1.3.1.12 Calibrate new Square D circuit breakers 1.3.1.14 Clean equipment in the switchgear room that has been coated with by-products from the fire 1.3.1.15 Provide any required Engineering Change for the non-segregated bus between 1B4A and 1B3A-4A 1.3.1.16 Repair 1B4A to 1B3A-4A non-segregated bus section 1.3.1.17 Perform testing of all circuits associated with 1B4A load center 1.3.1.18 Perform testing of all circuits associated with cabling not associated with the 1B4A load center (i.e. cables located in the cable tray above the load center)

1.3.1.19 Submit, track, and seek approval of procedures that are changed as the result of EC 53257 and are required to be issued before the System Acceptance Process.

1.3.1.21 Declare bus 1B4A Operable 1.3.1.22 Temporary Modification restoration 1.3.1.23 Extent of Condition repair requirements. Provide repair requirements for extent of condition.

1.3.1.24 Implement the requirements supplied by System Engineering regarding the extent of condition.

The following NRC open items are specifically related to the Red finding and therefore need to be evaluated prior to restart of the facility. For these specific items the NRC will verify that the licensee has performed adequate root cause and extent of condition evaluations related to the failure of the 1B4A breaker and associated electrical fire in the vital switchgear. In addition, the NRC will verify 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.

NRC Item Description Status VIO 2012010-01 Failure to Ensure that the 480 VAC Electrical Power Distribution System Design Requirements were Implemented and Maintained VIO 2012007-01 Failure to Provide Adequate Post-Fire Safe Shutdown Actions in the Switchgear Rooms VIO 2012007-02 Failure to Maintain Command and Control Function During Fire Fighting Activities in the Protected Area VIO 2012004-04 Failure to Ensure Breaker Coordination of 480 VAC Electrical Power Distribution System Was Maintained URI 2011014-02 Failure to Perform Adequate 10 CFR 50.59 Review URI 2011014-03 Cause of Breaker 1B3A Trip Not Understood Closed IR 2012004-04 ML12276A456 LER 2011-010-0 Fire Causes a Circuit Breaker to Open Outside Design Assumptions Item 1.d Security - Greater than Green Findings Item 1.d is included in the restart checklist because of greater than green findings that adversely affected the security cornerstone. Information about these findings is located in NRC Inspection Reports 05000285/2011404 (ML111460688) and 05000285/2011406 (ML12108A186).

With respect to these findings, the NRC will verify that the licensee adequately identifies the root and contributing causes of the risk significant issues; verify that the extent of condition and

extent of causes of the risk significant issues are identified, and verify that the corrective actions adequately address the causes to preclude repetition.

A description of the security findings and the specific licensee actions to be reviewed by the NRC are contained in a separate document which contains Security Related Information in accordance with 10 CFR 2.390(d)(1) and its disclosure to unauthorized individuals could present a security vulnerability and will not be made publicly available.

Item 1.e Third Party Safety Culture Assessment Item 1.e is included in the restart checklist because the NRC recognizes the importance of nuclear plant licensees establishing and maintaining a strong safety culturea work environment where management and employees are dedicated to putting safety first. In addition, nuclear power plants should have a work environment where employees are encouraged to raise safety concerns, and where concerns are promptly reviewed, given the proper priority based on their potential safety significance, and appropriately resolved with timely feedback to the originator of the concerns and to other employees.

The NRC will assess and inspect the results of the safety culture assessment performed by an organization independent of Fort Calhoun Station. The scope of the inspection related to safety culture will be based on the results of the validation of the licensees third party safety culture assessment and root cause evaluation. The outcome of this item is an NRC graded safety culture assessment. With respect to the licensees third party safety culture assessment the NRC will assess the following items:

Item Actions to be Verified Prior to Restart Status 1.e.1 Verification of comprehensiveness of licensee third party safety culture assessment 1.e.2 Methods used by the third-party assessment team to collect and analyze the data were adequate and appropriate 1.e.3 Verification that licensee=s assessment team members were independent and qualified 1.e.4 Licensees activities to communicate results of the assessment to various levels of management and staff 1.e.5 Licensees corrective actions to the assessment results If substantial weaknesses are identified with the licensees third-party safety culture assessment or the NRC has low confidence in the validity of the licensees results, the NRC will conduct an independent safety culture assessment in order to gain accurate insights on the contribution of weaknesses in safety culture components to licensee performance.

The site performed an integrated assessment and identified fifteen Fundamental Performance Deficiencies (FPDs) that resulted in the overall performance decline at the station. Nuclear Safety Culture and Safety Conscience Work Environment were identified as areas for improvement. With respect to these Fundamental Performance Deficiencies the NRC will assess the following:

Item Actions to Be Verified Prior to Restart Status 1.e.6 Licensee Assessment of the Fundamental Performance Deficiency associated with Nuclear Safety Culture 1.e.7 Adequacy of extent of condition and extent of causes 1.e.8 Adequacy of corrective actions 1.e.9 Licensee Assessment of the Fundamental Performance Deficiency associated with Safety Conscience Work Environment 1.e.10 Adequacy of extent of condition and extent of causes 1.e.11 Adequacy of corrective actions Item 1.f Integrated Organizational Effectiveness Assessment Item 1.f is included on the restart checklist because organizational effectiveness was identified as a potential key contributor to the overall station performance. Organizational effectiveness can impact multiple activities and programs across multiple functional areas at the facility.

At the completion of the assessments performed under Restart Checklist Items 1.a through 1.e, Fort Calhoun Station will integrate the outcomes of each of those assessments to determine what aspects of its organization and human performance need additional focus and improvement. The integration of the root cause and safety culture assessments under Item 1.f will identify those 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. The licensee will perform this assessment using qualified individuals with independent oversight.

The NRC will review the licensees assessments of organizational effectiveness and any connections to safety culture insights (from Item 1.e). The NRC will ensure that proper corrective actions are established and incorporated to resolve organizational effectiveness issues that adversely affected station performance.

With respect to this item the NRC will review the following:

Item Actions to be Verified Prior to Restart Status 1.f.1 Verification of comprehensiveness of licensee Integrated Organizational Effectiveness assessment 1.f.2 Methods used by assessment team to collect and analyze the data were adequate and appropriate 1.f.3 Verification that licensee=s assessment team members were independent and qualified 1.f.4 Licensees activities to communicate results of the assessment to various levels of management and staff 1.f.5 Licensees corrective actions to the assessment results

The site performed an integrated assessment and identified fifteen FPDs that resulted in the overall performance decline at the station. These deficiencies included Leadership/Organizational Effectiveness, Nuclear Safety Culture, Safety Conscious Work Environment, Corrective Action Program, Site Operational Focus, Resource Management, Processes for Meeting Regulatory Requirements, Equipment Reliability/Work Management, Engineering Design/Configuration Control, Performance Improvement, Procedure Quality/Procedure Management, Nuclear Oversight, Emergency Response Organization, and Security.

The licensee identified that the most significant FPD that resulted in performance decline at the station was Leadership/Organizational Effectiveness. Examples included lack of accountability throughout the organization; standards, policies, and administrative controls are outdated, ineffective, and sometimes ignored; programs such as the Corrective Action Program, Maintenance Rule Program, and Equipment Service Life Program, were not managed to a level ensuring station improvement. The NRC will review the adequacy of licensee actions regarding this FPD.

Item Actions to Be Verified Prior to Restart Status 1.f.6 Licensee Assessment of Leadership/Organizational Effectiveness Fundamental Performance Deficiency 1.f.7 Adequacy of extent of condition and extent of causes 1.f.8 Adequacy of corrective actions

Section 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.

Item 2.a Flood Recovery Plan Actions Associated with Facility and System Restoration Item 2.a is the NRCs independent evaluation of Fort Calhoun Stations Flood Recovery Plan.

An overall flood recovery plan is important to ensure the station takes a comprehensive approach to restoring the facility structures, systems, and components to pre-flood conditions.

The NRC will verify that the following flood recovery actions being implemented by the licensee adequately address the physical restoration of the facility to design basis conditions that were in place prior to the 2011 flood. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number 1.2.1.1 Determine if equipment in the intake structure and cells has been damaged 1.2.1.4 Return B.5.b materials to proper location 1.4.1.2 Inspect 13.8kV underground pad mount T&D switch Closed SW1062 IR 2012-003 ML12226A630 1.4.1.3 Inspect and/or test T&D 13.8 kV transformer T1B-3C-1 (T&D Closed 13TN43G) IR 2012-003 ML12226A630 1.4.1.4 Inspect manholes and ducts for MH01 through MH04 from Closed T&D switch SW1062 to transformer T1B-3C-1 to facilitate IR 2012-003 pulling new 1/0 cable ML12226A630 1.4.1.5 Inspect ducts associated with manholes MH1 through MH4 Closed between T&D switch SW1062 to T&D transformer 13TN43G IR 2012-003 and repair as necessary ML12226A630 1.4.1.6 Inspect and/or test Circuit 231 from T&D switch SW1062 to Closed T&D transformer 13TN43G and repair as necessary IR 2012-003 ML12226A630 Repair any damaged or non-functional fire hydrants located inside the protected area or connected to the main fire 2.1.1.2 protection header ring Flush fire protection system piping connected to the fire protection header ring which flowed river water during flood 2.1.1.3 mitigation actions

Inspect all SO-G-103 fire barriers in plant buildings affected Closed by flood waters. Includes Pyrocrete barriers in Intake IR 2012-003 2.1.1.4 Structure. ML12226A630 Restore the exterior fire hose houses impacted by flooding 2.1.1.6 to functional condition 2.1.1.7 Verify proper functioning of flood affected fire hose houses Complete FP System PMs and STs on flood impacted equipment which was not accessible for inspection and 2.1.1.8 testing 2.1.1.9 Complete full flow testing of fire pumps Closed Remove the plugs that were installed in the transformer pits IR 2012-003 2.1.1.10 for drainage from the rocks ML12226A630 Assess whether wetted motors are to be tested for possible use, refurbished or replaced. Motors that were wetted for a short timeframe will be Tested for Possible Use. Motors that were wetted for an extended period of time will be 2.3.1.1 Refurbished or Replaced.

2.3.1.2 Take oil sample from bearing housings of wetted motors.

2.3.1.3 Evaluate if water has gotten in contact with bearings.

Refurbish motor if water contamination is present in oil.

2.3.1.4 Replace motor in whole is an additional option.

Perform visual and boroscope inspection of wetted motor internals (to included termination box) looking for slit, pools 2.3.1.5 of water, corrosion, etc.

Evaluate visual inspection results for possible actions 2.3.1.6 (removal of moisture, cleaning, refurbishment of motor)

If bearing are in good condition and wetted motor is visibly in 2.3.1.7 good condition, static test motor If static test results are SAT, motor can be started.

Maintenance oversight of initial run. Vibration data to be 2.3.1.8 taken during initial run.

Closed IR 2012-003 2.3.1.9 Remove wetted motor and prepare for shipment to vendor. ML12226A630 Closed IR 2012-003 2.3.1.10 Refurbish wetted motor ML12226A630 Closed IR 2012-003 2.3.1.11 Install refurbished motor ML12226A630 Closed IR 2012-003 2.3.1.12 Post Maintenance Testing of motor ML12226A630 Closed IR 2012-004 2.3.1.13 Ensure spare motor is available or order new motor ML12276A456 Closed IR 2012-004 2.3.1.14 Remove degraded motor ML12276A456

Closed IR 2012-004 2.3.1.15 Install new motor ML12276A456 Closed IR 2012-004 2.3.1.16 Post Maintenance Testing of motor ML12276A456 3.1.1.1 Document review of all Engineering Programs Test Maintenance Rule Medium Voltage Power Cables 3.2.1.1 subjected to wetting/ submergence Test Maintenance Rule Low Voltage Power Cables 3.2.1.2 subjected to wetting/ submergence Test Maintenance Rule Low Voltage Control and 3.2.1.3 Instrumentation Cables subjected to wetting/ submergence Test or replace 13.8kV medium voltage cable for emergency 3.2.2.1 power feed and met tower feed Inspect manholes and vaults for damage and integrity of 3.2.2.2 water seals at penetrations Contingency cable replacement (if identified defective cable 3.2.2.3 during testing)

Testing of contingency cables installed after replacement (if 3.2.2.4 needed) 3.3.1.2 Assess results of ground penetrating radar (GPR)

Perform walkdown of all flood mitigation devices (i.e., berms, sandbags, HESCO barriers, to determine if each device is to 4.2.1.4 be removed or is to remain Initiate actions to remove flood mitigation devices which 4.2.1.5 have been determined to not be permanent fixtures 4.2.2.1 Identify degraded flood barriers 4.2.2.2 Repair flood barriers as required Prepare SO-G-124 documentation for all flood barriers which 4.2.2.4 do not have adequate qualification Review restoration plans for each impaired flood barrier per 4.2.2.5 SO-G-124 form FC-1411 Review impaired flood barriers as identified in accordance 4.2.2.6 with SO-G-124 form FC-1411 Removal of all flood mitigation devices which have been 4.2.2.7 determined to not be permanent fixtures 4.3.2.1 Completion of all ECs/restoration required for plant start-up The NRC will verify that the licensee adequately addresses systems that were potentially affected by the flood of 2011. These activities will verify the capability of selected systems to fulfill their intended functions. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number Assess the effects of the flood on the Auxiliary Cooling 2.2.1.1 System (ACS) and identify actions to restore the system.

Assess the effects of the flood on the Auxiliary Feedwater 2.2.1.2 System (AFW) and identify actions to restore the system.

Assess the effects of the flood on the Auxiliary Instrumentation 2.2.1.3 System (AIS) and identify actions to restore the system.

Assess the effects of the flood on the Control Rod Drive 2.2.1.4 System (CRD) and identify actions to restore the system.

Assess the effects of the flood on the Chemical and Volume Control System (CVC) and identify actions to restore the 2.2.1.5 system.

Assess the effects of the flood on the Circulating Water 2.2.1.6 System (CWS) and identify actions to restore the system.

Assess the effects of the flood on the Emergency Core Cooling System (ECC) and identify actions to restore the 2.2.1.7 system.

Assess the effects of the flood on the Emergency Diesel Generator System (EDG) and identify actions to restore the 2.2.1.8 system.

Assess the effects of the flood on the Electrical Distribution 2.2.1.9 System (EDS) and identify actions to restore the system.

Assess the effects of the flood on the Engineered Safety Features System (ESF) and identify actions to restore the 2.2.1.10 system.

Assess the effects of the flood on the Fuel Handling System 2.2.1.11 (FHS) and identify actions to restore the system.

Assess the effects of the flood on the Fire Protection System 2.2.1.12 (FPS) and identify actions to restore the system.

Assess the effects of the flood on the Hoisting Equipment 2.2.1.13 System (HES) and identify actions to restore the system.

Assess the effects of the flood on the Instrument Air System 2.2.1.14 (IAS) and identify actions to restore the system.

Assess the effects of the flood on the Main Feedwater System 2.2.1.15 (MFW) and identify actions to restore the system.

Assess the effects of the flood on the Reactor Coolant System 2.2.1.16 (RCS) and identify actions to restore the system.

Assess the effects of the flood on the Radiation Monitoring 2.2.1.17 System (RMS) and identify actions to restore the system.

Assess the effects of the flood on the Reactor Protection 2.2.1.18 System (RPS) and identify actions to restore the system.

Assess the effects of the flood on the Spent Fuel Pool System 2.2.1.19 (SFP) and identify actions to restore the system.

Assess the effects of the flood on the Steam Generator 2.2.1.20 System (SGS) and identify actions to restore the system.

Assess the effects of the flood on the Sampling System (SLS) 2.2.1.21 and identify actions to restore the system.

Assess the effects of the flood on the Structures System 2.2.1.22 (STR) and identify actions to restore the system.

Assess the effects of the flood on the Turbine Generator 2.2.1.23 System (TGS) and identify actions to restore the system.

Assess the effects of the flood on the Turbine Plant Cooling 2.2.1.24 System (TPC) and identify actions to restore the system.

Assess the effects of the flood on the Ventilating Air Conditioning System (VAC) and identify actions to restore the 2.2.1.25 system.

Assess the effects of the flood on the Waste Disposal System 2.2.1.26 (WDS) and identify actions to restore the system.

Assess the effects of the flood on the Demineralized Water /

Potable Water System (DW/PW) and identify actions to 2.2.1.27 restore the system.

Assess the effects of the flood on the Vents and Drains System (VDS) and identify actions to restore the system. This 2.2.1.28 will include Sanitary and Storm Drains.

Assess the effects of the flood on the Auxiliary Steam System (AUS) and identify actions to restore the system. This will 2.2.1.29 include the Auxiliary Boiler.

Assess the effects of the flood on the Meteorological Monitoring System (MMS) and identify actions to restore the 2.2.1.30 system.

Assess the effects of the flood on the Plant Security Systems 2.2.1.31 (SEC) and identify actions to restore the system.

Assess the effects of the flood on the Communications 2.2.1.32 Systems (COM) and identify actions to restore the system.

Although not a specific plant restart action, the NRC will review the following long term actions planned to be implemented by the licensee.

Action Actions to Be Reviewed Status Item Number 1.2.3.21 Inspect tank and equipment on DI tank for damage 1.2.3.58 Repair, replace and test B.5.b equipment as necessary 1.2.3.82 Perform ISFSI route load test Item 2.b System Readiness from Extended Shutdown Systems that have been shut down for prolonged periods may be subject to different environments than those experienced during power operations. The NRC will evaluate the effects of the extended shutdown, and verify that the structures, systems, and components are ready for plant restart and they conform to the licensing and design bases requirements.

Item 2.b.1 System Health Reviews The purpose of this item is to validate structures, systems, and components are in satisfactory working order. The licensee plans to perform system health reviews on safety significant and maintenance rule systems.

The NRC will inspect the system health reviews conducted by Fort Calhoun Station. These include comprehensive system walkdowns and reviews of key information regarding system health (e.g. commitments, open and closed condition reports, open and closed work orders, preventative maintenance activities, modifications, operating experience, violations of NRC requirements, open change-initiating documents, open operational concerns, etc.)

Item Actions to Be Verified Prior to Restart Status 2.b.1.1 Auxiliary Cooling System 2.b.1.2 Auxiliary Feedwater System 2.b.1.3 Spent Fuel Pool System 2.b.1.4 Sampling System 2.b.1.5 Chemical and Volume Control System 2.b.1.6 Emergency Core Cooling System 2.b.1.7 Hoisting Equipment System 2.b.1.8 Waste Disposal System 2.b.1.9 Control Rod Drive System 2.b.1.10 Reactor Coolant System 2.b.1.11 Demineralized and Potable Water Systems 2.b.1.12 Circulating Water System 2.b.1.13 Emergency Diesel Generator

2.b.1.14 Ventilation, Heating and Air Conditioning System 2.b.1.15 Main Feedwater System 2.b.1.16 Structures 2.b.1.17 Steam Generator System 2.b.1.18 Steam Generator Blowdown Turbine Plant Cooling 2.b.1.19 Instrument Air System 2.b.1.20 Turbine Generator and Support Systems 2.b.1.21 Auxiliary Instrumentation System 2.b.1.22 Electrical Distribution System 2.b.1.23 Engineered Safeguards System 2.b.1.24 Radiation Monitoring System 2.b.1.25 Fuel Handling System 2.b.1.26 Reactor Protective System 2.b.1.27 Fire Protection System Item 2.b.2 Detailed Review of Alternating and Direct Current Electrical Distribution, High Pressure Safety Injection System, Emergency Diesel Generator System, and Reactor Protection System Fort Calhoun Station will perform 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 identify broad-based safety, organizational, and performance issues. The review is structured consistent with NRC Inspection Procedure 95003 (Sections 02.03 and 03.03), and is accomplished by review in the six key attributes.

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 will perform 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.

• High Pressure Injection System. This system is important to provide mitigation for postulated accident conditions in the reactor plant. This review will assess and validate key aspects of the suction and discharge pathways, system alignments, power sources, and emergency actuation.

• The Emergency Diesel Generator System (EDGs) furnish a reliable source of 4160V AC power for safe plant shutdown and operation of engineered safeguards when the normal sources of off-site power are lost. The EDGs are safety related and are required to mitigate the consequences of events that have the potential to cause a release of radioactivity. The emergency diesel generators function as an emergency power source during all phases of reactor operation.

• The Reactor Protection System (RPS) is designed to rapidly shut down the nuclear chain reaction prior to reaching a condition that could damage the reactor core.

The NRC will assess the adequacy for each of the licensees detailed reviews and select samples for independent verification that the licensee properly assessed each system.

Item Actions to Be Verified Prior to Restart Status 2.b.2.1 Detailed review of Alternating and Direct Current Electrical Distribution 2.b.2.2 Detailed review of High Pressure Safety Injection System 2.b.2.3 Detailed review of Emergency Diesel Generating System 2.b.2.4 Detailed review of Reactor Protection System Item 2.b.3 Impact of Sub-Surface Water on Soils and Structures Fort Calhoun Station was subjected to flood waters for several months. The licensee will perform an assessment to evaluate:

• functionality of site systems, structures, and components, (SSCs) affected by the flood

• condition of subsurface soil

• floodwater impacts on subsurface SSCs.

The NRC will verify that the following actions being implemented by the licensee adequately address the flooding impact of sub-surface water on soils and structures. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Item Actions to be Verified Prior to Restart Status Number 1.2.1.3 Repair any structural damage identified in the intake structure Ensure underground FP piping is intact and no unacceptable 2.1.1.1 voids are present near FP piping Verify soil compaction and moisture content in areas of underground fire protection main header ring and attached 2.1.1.5 piping is per NFPA requirements Inspect underground Raw Water, EDG Fuel Oil and Fire Protection piping and tanks using GPR (Ground Penetrating 3.3.1.1 Radar)

Resolve any deficiencies affecting operability or functionality (if 3.3.1.3 needed)

Review structure design features to assess potential for 4.1.1.12 damage due to flooding 4.1.1.14 Assess post-inundation condition of structures 4.1.1.15 Prepare remediation alternatives (if appropriate) 4.1.1.16 Create report of findings Review findings and recommendations with FCS and document 4.1.1.17 results 4.1.1.20 Inspect Non-Class 1 Priority 1 Structures 4.1.1.21 Assess post-inundation condition of structures 4.1.1.22 Prepare remediation alternatives (if appropriate) 4.1.1.23 Create report of findings Review findings and recommendations with FCS and document 4.1.1.24 results 4.1.1.25 Post-Flood River Channel Evaluation Verify no geotechnical or structural impact to Turbine Building 4.1.1.30 and Auxiliary Building/Containment as a result of the 2011 flood 4.1.1.32 Remediation of the Turbine Building and Class 1 structure void 4.1.2.2 Verify no geotechnical or structural impact to site structures Remediation of the loose soils area under the Turbine Building 4.1.3.10 and Class 1 structures if required Although not a specific plant restart action, the NRC will review the following long term actions planned to be implemented by the licensee.

Action Actions to be Reviewed Status Item Number 1.2.3.57 Repair ISFSI as necessary (structural) 1.2.3.79 Repair the ISFSI haul route as necessary

Section 3: Adequacy of Significant Programs and Processes Section 3 of the Restart Checklist addresses major programs and processes in place at Fort Calhoun Station. Section 3 reviews will also include an assessment of the adequacy of licensee reviews in context of NRC Inspection Procedure 95003 key attributes as described in Section 5.

Item 3.a Corrective Action Program The Corrective Action Program and the use of industry Operating Experience at a nuclear power plant is a key element in ensuring the licensees ability to effectively detect, correct, and prevent problems. Based upon problems with Corrective Action Program effectiveness the licensee is performing a comprehensive review of this program.

The NRC will assess the licensees evaluations and associated improvement actions related to the Corrective Action Program. The NRC will also conduct independent inspections to validate whether the Corrective Action Program is appropriately functioning. Additionally, the NRC will verify that the licensee has established appropriate effectiveness measures to monitor the effectiveness of program improvements.

Item Actions to Be Verified Prior to Restart Status 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 3.a.4 Adequacy of effectiveness measures to monitor program improvements The site performed an integrated assessment and identified fifteen Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. The Corrective Action Program was identified as one of these areas for improvement. Examples identified by the licensee included problems not being thoroughly evaluated to determine the causes; corrective actions lack clarity or dont correlate to the root and contributing causes, condition reports are assigned incorrect significance levels, and corrective actions are not completed in a timely manner. With respect to this FPD the NRC will assess the following:

Item Actions to Be Verified Prior to Restart Status 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 3.a.7 Adequacy of corrective actions

Licensee evaluations identified that the site Operating Experience Program is not effectively implemented to enhance the performance of the Station. The practice of learning from internal and external industry events has not been internalized. The screening process is not being consistently applied to preclude events. There are weaknesses in the training and qualification of individuals assigned to administer and implement the program. Program expectations are unclear and there is a lack of management oversight to ensure adequate implementation. To assess the licensees actions in regards to these deficiencies the NRC will review the following:

Item Actions to Be Verified Prior to Restart Status 3.a.8 Licensee Assessment of Operating Experience Program 3.a.9 Adequacy of extent of condition and extent of causes 3.a.10 Adequacy of corrective actions 3.a.11 Adequacy of effectiveness measures to monitor program improvements Specific independent inspections will include assessing the Corrective Actions Program effectiveness in resolving the following previously identified non-cited violations of NRC requirements. The NRC will verify that adequate corrective actions were identified associated with the licensees casual analysis and extent of condition evaluations and that implementation of corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status NCV 2012004-01 Failure to report an event to the NRC within 60 days for an operation prohibited by Technical Specifications 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 2011004-01 Failure to Incorporate Design Information into Procedures NCV 2011002-02 Failure to Determine the Cause of the Out Of Tolerance Condition Regarding Reactor Protection System Channel A Trip Unit 6 NCV 2011002-03 Failure to Submit a Timely Licensee Event Report NCV 2011002-04 Failure to Verify Design Adequacy of Refueling Water Tank Vortex Eliminator NCV 2010002-01 Inadequate Reportability Guidance NCV 2010003-01 Failure to Provide Adequate Limiting Condition for Operation for High River Level NCV 2010003-05 Failure to Submit a Required Licensee Event Report NCV 2010004-02 Failure to Submit a Required Licensee Event Report NCV 2010004-04 Failure to Translate Calculation into Calibration Procedure Specific independent inspections will include assessing the Corrective Actions Program effectiveness in resolving the issues submitted in the following Licensee Event Reports.

Item Description Status LER 2012-011-0 Emergency Diesel Inoperability Due to Bus Loads During a LOOP LER 2012-010-0 Seismic Qualification of Instrument Racks LER 2012-007-0 Failure of Pressurizer Heater Sheath LER 2012-006-0 Operation of Component Cooling Pumps Outside Manufacturers Recommendation LER 2012-004-1 Inadequate Analysis of Drift Affects Safety Related Equipment LER 2012-003-0 Non-Conservative Error in Calculation for Alternate Hot Leg Injection Results in Hot Leg Injection Results in Unanalyzed Condition Because the overall health of a licensees corrective action program is key to sustaining operational safety the NRC will not only be performing routine inspections of this program, but will also perform a Team inspection following the guidance in NRC Inspection Procedure 71152, Problem Identification and Resolution. This inspection will focus on ensuring that the corrective action program is effectively being implemented and addressing those items related to design, human performance, procedure quality, equipment performance, configuration control, emergency response, occupational radiation safety, and public radiation safety. These items are defined as Key Attributes in NRC Inspection Procedure 95003. Additionally, the NRC will follow up on the resolution of specific equipment issues that are known to exist.

Item Description Status 3.a.12 Perform NRC Team Problem Identification and Resolution inspection 3.a.13 Raw Water Pump C high vibrations 3.a.14 Reactor cavity leakage 3.a.15 Effects on equipment impacted by reactor cavity leakage Item 3.b Equipment Design Qualifications This item of the Restart Checklist verifies that plant components are maintained within their licensing and design basis. Additionally, this item provides monitoring of the capability of the selected components and operator actions to perform their functions. As plants age, modifications may alter or disable important design features making the design bases difficult to determine or obsolete. The plant risk assessment model assumes the capability of safety systems and components to perform their intended safety function successfully.

The NRC will verify that the following actions being implemented by the licensee adequately address equipment design concerns. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number 4.6.1.1 Address concerns identified with the Reactor Coolant Pump oil collection system 4.6.1.2 Address non-conservative 161 kV minimum voltage to support operation of a main feedwater pump in a Safety Injection Actuation Signal (SIAS)-only scenario (CR 2011-6725) 4.6.1.3 Provide analysis of Steam Generator accident ring (CR 2011-6825)

The following NRC items are specifically related to maintaining systems, structures, and components within their licensing and design basis. For these specific items the NRC will verify that the licensee has performed adequate casual analysis and extent of condition evaluations related to the issues. The NRC will verify that adequate corrective actions were identified associated with the licensees casual analysis and extent of condition evaluations and that implementation of corrective actions are either implemented or appropriately scheduled for implementation. These assessments will provide the NRC insights regarding the licensees ability to effectively resolve equipment design qualification problems.

Item Description Status LER 2012-016-0 Unanalyzed Charging System Socket Welds to the Reactor Coolant System LER 2012-014-0 Containment Beam 22 Loading Conditions Outside of the Allowable Limits LER 2012-013-0 Inadequate Calculation of Uncertainty Results in a Technical Specification Violation LER 2012-002-0 Inadequate Qualifications for Containment Penetrations Renders Containment Inoperable NCV 2011003-01 Failure to Adequately Design a Reactant Coolant Pump Lube Oil Collection System Item 3.b.1 Safety Related Parts Program A number of instances have been identified where non-safety-related parts have been installed into safety-related applications. Fort Calhoun Station will perform reviews to identify conditions where a non-safety-related component or subcomponent were improperly used in a safety-related application.

The NRC will assess the licensees equipment design quality classifications review for inconsistent quality classifications. Additionally, the NRC will assess the licensees review of the use of non-safety-related parts in safety-related applications. This will ensure proper design attributes have been incorporated and implemented.

Item Actions to Be Verified Prior to Restart Status 3.b.1.1 Licensee Assessment of equipment design quality classifications 3.b.1.2 Adequacy of extent of condition and extent of causes 3.b.1.3 Adequacy of corrective actions Item 3.b.2 High Energy Line Break Program and Equipment Qualifications Fort Calhoun Station recently reviewed high energy line break calculations and identified examples of inadequate documentation and calculations associated with high energy line break effects in some areas. The NRC will assess and inspect the high energy line break analyses and documents to ensure the plant is within their license and design basis for high energy line break effects.

The NRC will also inspect the licensees qualifications and documentation to certify equipment for harsh environments. These equipment qualifications are required by regulations (e.g., 10 CFR 50.49).

The NRC will verify that the following actions being implemented by the licensee adequately address high energy line break and equipment qualification concerns. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number 4.5.1.8 Complete EEQ Harsh Environment analysis for Room 13 crack in Steam Generator Blowdown system 4.5.1.9 Develop plan to address Room 13 EEQ harsh environment qualification of electrical equipment 4.5.1.10 Initiate actions to resolve Room 13 EEQ harsh environment qualification of equipment which must be addressed prior to leaving cold shutdown 4.5.1.11 Resolve Room 13 EEQ harsh environment qualification of equipment which must be addressed prior to leaving cold shutdown 4.5.1.12 Perform analysis to address HCV-1385/1386 Main Steam Line Break/Feedwater isolation concern (CR 2011-6757)

4.5.1.13 Implement resolution of HCV-1385/1386 Main Steam Line Break/Feedwater isolation concern 4.5.1.14 Perform HELB analysis of Auxiliary Steam piping in the auxiliary building 4.5.1.15 Implement resolution of Auxiliary Steam piping in the auxiliary building The following NRC open items are specifically related to high energy line break and equipment qualification concerns. For these specific items the NRC will verify that the licensee has performed adequate root cause and extent of condition evaluations related to the failures resulting in the event. In addition, the NRC will verify 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.

Item Description Status LER 2012-017-0 Containment Valve Actuators Design Temperature Ratings Below those Required for Design Basis Accidents LER 2012-015-0 Electrical Equipment Impacted by High Energy Line Break Outside Containment LER 2012-009-0 Inoperable Equipment Due to Lack of Environmental Qualifications Item 3.c Design Changes and Modifications Modifications to risk-significant structures, systems, and components can adversely affect their availability, reliability, or functional capability. Modifications to one system may also affect the design bases and functioning of interfacing systems. Similar modifications to several systems could introduce potential for common cause failures that affect plant risk. A temporary modification may result in a departure from the design basis and system success criteria.

Modifications performed during increased risk configurations could place the plant in an unsafe condition.

This item assesses the effectiveness of the licensees implementation of changes to facility structures, systems, and components, risk significant normal and emergency operating procedures, test programs, evaluations required by 10 CFR 50.59, and the updated final safety analysis report. The NRC will inspect to provide assurance that changes have been appropriately implemented.

The NRC will verify that the following actions being implemented by the licensee adequately address design changes and modifications to the facility. These items are listed in the Fort

Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number 4.5.1.1 Review of EC 53202; FW-10 Steam Line HELB Modification 4.5.1.2 Final SMART Review of EC 53202; FW-10 Steam Line HELB Modification 4.5.1.3 Plant Review Committee review of EC 53202; FW-10 Steam Line HELB Modification 4.5.1.4 Develop Construction Work Orders for EC 53202; FW-10 Steam Line HELB Modification 4.5.1.5 Complete installation of EC 53202; FW-10 Steam Line HELB Modification 4.5.1.6 Prepare EC 52662; Add a new Pipe Support on the SGBD vertical line above FW-1020 4.5.1.7 Install EC 52662; Add a new Pipe Support on the SGBD vertical line above FW-1020 Item 3.c.1 Vendor Modification Control NRC inspections and licensee evaluations have identified that vendor modification packages do not consistently ensure critical characteristics are identified and properly addressed.

Additionally, examples exist that demonstrate an engineering overreliance on vendor knowledge and skill and the failure to provide the appropriate level of oversight for vendor related activities.

The NRC will evaluate the adequacy of the licensees assessment of the vendor modification control processes, the thoroughness of their extent of condition and causal analysis, and adequacy of corrective actions being implemented to address the deficiencies.

Item Actions to Be Verified Prior to Restart Status 3.c.1.1 Licensee assessment of vendor modification control processes 3.c.1.2 Adequacy of extent of condition and extent of causes 3.c.1.3 Adequacy of corrective actions

Item 3.c.2 10 CFR 50.59 Screening and Safety Evaluations NRC inspections indicated that several changes to the facility were not properly screened or evaluated per the requirements 10 CFR 50.59. Plant and procedure modifications will be reviewed to determine if modifications required a 10 CFR 50.59 review. The licensee also determined that the 50.59 Program is not being effectively implemented consistently and is performing a root cause analysis. The NRC will evaluate the adequacy of the licensees assessment, the thoroughness of their extent of condition and causal analysis, and the adequacy of identified corrective actions to ensure proper treatment of changes to the facility.

Item Actions to Be Verified Prior to Restart Status 3.c.2.1 Licensee Assessment of the 50.59 process 3.c.2.2 Adequacy of extent of condition and extent of causes 3.c.2.3 Adequacy of corrective actions The following NRC items are specifically related to 10 CFR 50.59 concerns. For these specific items the NRC will verify that the licensee has performed adequate root cause and extent of condition evaluations related to the event. In addition, the NRC will verify 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.

Item Description Status URI 2011014-02 Failure to Perform Adequate 10 CFR 50.59 Review NCV 2010004-05 Failure to Perform a 10 CFR 50.59 Evaluation Item 3.d Maintenance Programs Inadequate maintenance activities that are not detected prior to returning the equipment to service can result in a significant increase in unidentified risk for the subject system.

The Maintenance Rule (10 CFR 50.65) requires licensees to monitor the performance or condition of structures, systems and components within the scope of the rule against licensee-established goals to provide reasonable assurance that these structures, systems, and components are capable of fulfilling their intended functions. These goals are to be commensurate with safety and, where practical, should take into account industry-wide operating experience.

The site performed an integrated assessment and identified fifteen Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. Equipment

Reliability/Work Management was identified as one of the areas for improvement. Examples identified by the licensee included intolerance to equipment failures has not been established; engineering and maintenance strategies are not focused on critical components; long term strategies have not been developed for age related degradation; the maintenance rule function to monitor the performance of plant equipment has not been effectively implemented. With respect to this FPD the NRC will assess the following:

Item Actions to Be Verified Prior to Restart Status 3.d.1 Licensee Assessment of the Fundamental Performance Deficiency associated with Equipment Reliability/Work Management 3.d.2 Adequacy of extent of condition and extent of causes 3.d.3 Adequacy of corrective actions Item 3.d.1 Vendor Manuals and Vendor Informational Control Programs NRC inspections and licensee evaluations identified that vendor manuals and information have not been adequately maintained, which resulted in adverse conditions at Fort Calhoun Station.

The licensee will perform a review to identify and incorporate updates to vendor manual technical documentation. This review applies to all equipment and components classified as a Critical Quality Element (safety-related).

Changes in vendor guidance will be evaluated to determine what impact, if any, the new information has on scheduled work, work completed since the last vendor manual update was made, and changes to plant documentation.

The NRC will evaluate the effectiveness of the licensees incorporation of vendor information into applicable plant procedures and design documents to ensure proper maintenance and operation of facility equipment.

Item Actions to Be Verified Prior to Restart Status 3.d.1.1 Licensee Assessment of Vendor Informational Control Program 3.d.1.2 Adequacy of extent of condition and extent of causes 3.d.1.3 Adequacy of corrective actions The following NRC item is specifically related to vendor manual and vendor information control concerns. For this specific item the NRC will verify that the licensee has performed adequate casual analysis and extent of condition evaluations related to the issue. In addition, the NRC will verify that adequate corrective actions were identified associated with the causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status NCV 2011006-05 Failure to Establish Adequate Measures to Maintain Vendor Manual Design Control Information Item 3.d.2 Equipment Service Life NRC inspections determined that the licensee opted to keep some plant equipment in service beyond the vendor recommended service life or standard industry guidelines. Operating equipment past the recommended replacement timeline has resulted in age-related failures at Fort Calhoun Station. In response, the licensee will perform an assessment to evaluate the service life of safety-related plant equipment and the effectiveness of programs used to implement service life requirements. The NRC will inspect and assess the adequacy of this evaluation and the associated corrective actions.

Item Actions to Be Verified Prior to Restart Status 3.d.2.1 Licensee Assessment of equipment service life program 3.d.2.2 Adequacy of extent of condition and extent of causes 3.d.2.3 Adequacy of corrective actions The NRC will verify that the following actions being implemented by the licensee adequately address equipment service life issues at the facility. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number 3.4.1.1 Replace Non-RPS CQE (reactor protection system critical quality equipment) power supplies that will be beyond their recommended service life 3.4.2.1 Establish High Impact Team with a Charter 3.4.2.2 Identify all CQE power supplies; priority will be on RPS CQE power supplies and then non-RPS CQE power supplies 3.4.2.3 Determine the installation date for FCS CQE power supplies; these dates will be used to define those CQE power supplies that are beyond their service life

3.4.2.4 Conduct an industry and FCS specific analysis of historical performance for CQE power supplies; determine the effectiveness of the current Equipment Reliability (ER) Strategies at the FCS component level 3.4.2.5 Conduct an analysis of the current FCS ER Strategy for power supplies; contact vendors, review industry documentation, benchmark other plants 3.4.2.6 Determine the recommended service life for CQE power supplies based on analyses performed earlier in this action plan.

These service lives will be based on: (1) manufacturer and model, (2) qualified life testing, (3) vendor recommendations and communication with vendors, (4) remnant life based on stress testing of removed power supplies, (5) industry and FCS specific historical performance and (6) actual duty cycle and service condition where these power supplies are installed 3.4.2.7 Conduct a failure modes and effects analysis on each power supply to ensure the impact of failures is understood 3.4.2.8 Document the time based replacement strategy and basis for CQE and RPS power supplies This strategy and basis will provide the tasks to be performed and the basis for the scope and frequency of those tasks. This action is being completed before start up to ensure each power supply has been analyzed and a recommended service life defined 3.4.2.9 Define those power supplies that are beyond their service life.

This will include power supplies that will be beyond their service life before the next planned refueling outage 3.4.2.10 Replace RPS CQE power supplies beyond their service life 3.4.2.11 Replace Non-RPS CQE power supplies that will be beyond their recommended service life The following NRC open item is specifically related equipment service life concerns and therefore will be reviewed by the NRC prior to restart of the facility. For this specific item the NRC will verify that the licensee has performed adequate casual analysis and extent of condition evaluations related to the failures. In addition, the NRC will verify that adequate corrective actions were identified associated with the causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status NCV 2011003-04 Failure to Provide Procedural Guidance to Replace or Evaluate Age Degraded Components

Although not a specific plant restart action, the NRC will review the following long term actions planned to be implemented by the licensee.

Action Description Status Item Number 3.4.3.1 Complete the development of the ER strategy for CQE power supplies. This action will include all tasks to be performed and basis for those tasks and PM (Preventative Maintenance) Change Requests for any PM change 3.4.3.2 Implement PM (Preventative Maintenance) Change Requests by changing PMs in Asset Suite. Validate PM changes in Asset Suit to be correct 3.4.3.3 Schedule new and revised PMs Item 3.e Operability Process Improper evaluations of degraded and/or non-conforming conditions may result in continued operation with a structure, system, or component that is not capable of performing its design function.

NRC inspections activities and site assessment activities have determined that Fort Calhoun Station did not consistently conduct adequate Operability Evaluations to ensure that the impacts of degraded conditions on plant operations are fully understood. Additionally, NRC inspection determined that some equipment identified as operable but degraded remained degraded until subsequent failure occurred. Fort Calhoun Station processes did not adequately identify degraded equipment or restore equipment from a degraded condition to full qualifications in a timely manner.

The site performed an integrated assessment and identified fifteen Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of the deficiencies identified was Processes to Meet Regulatory Requirements. Examples in this area included the site does not consistently recognize degraded-nonconforming conditions; and operability determinations and functional assessments are not sufficiently rigorous.

The NRC will evaluate the effectiveness of the licensees assessment of the Operability Determination Process, extent of condition and extent of causal analysis, and adequacy of associated corrective actions.

Item Actions to Be Verified Prior to Restart Status 3.e.1 Licensee Assessment of the Fundamental Performance Deficiency associated with Processes to Meet Regulatory Requirements specifically related to the Operability Determination Process

3.e.2 Adequacy of extent of condition and extent of causes 3.e.3 Adequacy of corrective actions Item 3.f Quality Assurance Quality Assurance is an important program at nuclear power plants. It is designed to be an independent group that assesses plant workers in the performance of a broad range of safety-related work or evaluations. Through quality assurance assessments or audits, problems and tends can be identified before they become significant plant problems.

The site performed an integrated assessment and identified fifteen Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of these deficiencies involved the effectiveness of Nuclear Oversight (NOS). Examples included NOS did not identify many of the substantive issues that have resulted in the decline in station performance; NOS has not performed critical and intrusive reviews focused on behaviors; NOS neither collected nor integrated performance data from line organizations; and issues identified by NOS are not communicated in a manner that compels site leaders to act.

The NRC will review the adequacy of the licensees assessment, extent of condition and causes, and corrective actions being implemented to improve performance of the Nuclear Oversight function. This will include a review of the Quality Assurance processes and a review of sampled assessments or audits performed by the Quality Assurance department. In addition, the NRC will assess the effectiveness of the oversight provided by the Safety Audit and Review Committee.

Item Actions to Be Verified Prior to Restart Status 3.f.1 Licensee assessment of the Fundamental Performance Deficiency associated with Nuclear Oversight effectiveness 3.f.2 Adequacy of extent of condition and extent of causes 3.f.3 Adequacy of corrective actions 3.f.4 Adequacy of recent Nuclear Oversight audits 3.f.5 Effectiveness of Safety Audit and Review Committee

Section 4: Review of Integrated Performance Improvement Plan Section 4 of the Restart Checklist is provided to assess Fort Calhoun Stations Integrated Performance Improvement Plan. OPPD has docketed the Integrated Performance Improvement Plan, which details the plans and actions needed to address the conditions that transitioned FCS to NRC oversight under IMC 0350.

The Integrated Performance Improvement Plan (IPIP) should address pre-restart and post-restart actions. The IPIP should have a sufficient level of detail so that the NRC staff will be capable of developing inspections plans to assess and review the plans actions.

The NRC will review the IPIP and all changes to the IPIP to ensure its pre-startup and post-startup actions and plans are adequate to address the conditions that led to the protracted decline in plant performance.

Item Description Status 4.1 Review of Integrated Performance Improvement Plan

Section 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. 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. In addition, the NRC will review the effectiveness of licensee short term and long term corrective actions associated with these areas to ensure they are adequate to support sustained plant performance improvement.

Item 5.a Design The NRC will independently assess the extent of risk significant design issues. The review will cover the as-built design features of the auxiliary feedwater system. This review will verify its capability to perform its intended functions with a sufficient margin of safety. The basis for selecting the auxiliary feedwater system was its high risk significance in the specific individual plant evaluation, and input from system health reports, performance indicators, condition reports, and licensee event reports. Focus will be on modifications rather than original system design. Information from this inspection will be used to assess the licensees ability to maintain and operate the facility in accordance with the design basis. The NRC review includes the following:

• assessment of effectiveness of corrective actions for deficiencies involving design

• selection of several modifications to the auxiliary feedwater system to determine if the system is capable of functioningas specified by the current design and licensing documents, regulatory requirements, and commitments for the facility

• determination if the auxiliary feedwater system is operated consistent with the design and licensing documents

• evaluation of the interfaces between engineering, plant operations, maintenance, and plant support groups Item Description Status 5.a.1 Perform NRC design engineering team inspection of the Auxiliary Feedwater System The site performed an integrated assessment and identified fifteen Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of the deficiencies identified was Engineering Design/Configuration Control. Examples in this area included changes to plant configuration and design and licensing basis are not effectively analyzed, controlled, and implemented; incomplete documentation and poorly written justifications in modification packages; and evaluations of fit, form, and function have been inadequate.

The NRC will evaluate the thoroughness of the licensees Engineering Design/Configuration Control assessment, adequacy of extent of condition and extent of causal analysis, and adequacy of associated corrective actions.

Item Description Status 5.a.2 Licensee Assessment of the Fundamental Performance Deficiency associated with Engineering/Configuration Control 5.a.3 Adequacy of extent of condition and extent of causes 5.a.4 Adequacy of corrective actions The following NRC items are specifically related to design concerns associated with the auxiliary feedwater system and therefore will be reviewed by the NRC to assess the effectiveness of the licensees ability to resolve design issues. For these specific items the NRC will verify that the licensee has performed adequate casual analysis and extent of condition evaluations related to the failures. In addition, the NRC will verify that adequate corrective actions were identified associated with the causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status NCV 2010006-01 Failure to Correct Repeated Tripping of the Turbine-driven Auxiliary Feedwater Pump FW-10 NCV 2010006-02 Failure to Verify that the Turbine-driven Auxiliary Feedwater Pump Exhaust Backpressure Trip Lever was Fully Latched NCV 2010006-03 Failure to Vent Control Oil Following Maintenance Results in Failure of the Turbine-driven Auxiliary Feedwater Pump to Start NCV 2010006-04 Turbine-driven Auxiliary Feedwater Pump Trip Due to Inadequate Design Margin Item 5.b Human Performance By nature of the design of nuclear power plants and the role of plant personnel in maintenance, testing and operation, human performance plays an important part in normal, off-normal and emergency operations. Human performance impacts each of the cornerstones and therefore should be considered across all inspections conducted at FCS.

The site performed an integrated assessment and identified fifteen Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of the deficiencies identified was Human Performance. Examples in this area included the station

lacks an integrated approach to solving human performance issues; station leaders do not reinforce use of the tools that reduce human performance errors, human performance improvement tools are not consistently utilized; and weaknesses in the site observation program are contributing to ongoing human performance problems.

The NRC will evaluate the thoroughness of the licensees Human Performance assessment, adequacy of extent of condition and extent of causal analysis, and adequacy of associated corrective actions.

Item Description Status 5.b.1 Licensee Assessment of the Fundamental Performance Deficiency of Human Performance 5.b.2 Adequacy of extent of condition and extent of causes 5.b.3 Adequacy of corrective actions Item 5.c Procedure Quality Inadequate procedures can cause initiating events by inducing plant personnel to take inappropriate actions during plant operations, maintenance, calibration, testing, or event response. Adequate procedures also assure proper functioning of mitigating systems during operation, maintenance, and testing. Emergency and abnormal operating procedures are also essential for mitigating system performance and assuring appropriate actions will be taken to preserve reactor coolant system (RCS) and containment integrity.

The site performed an integrated assessment and identified fifteen Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of the deficiencies identified was Procedure Quality/Procedure Management. Examples in this area included inaccurate or incomplete procedures have contributed to multiple significant events; some emergency and abnormal operating procedures are technically inaccurate; discrepancies occur within and between procedures; verification and validation of station procedures is not always rigorous; and the procedure maintenance group suffers from funding, training, personnel resources, and management support.

The NRC will evaluate 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.

Item Description Status 5.c.1 Licensee Assessment of the Fundamental Performance Deficiency of Procedure Quality/Procedure Management 5.c.2 Adequacy of extent of condition and extent of causes 5.c.3 Adequacy of corrective actions

The following NRC items are specifically related to procedural quality concerns and therefore will be evaluated by the NRC to assess the effectiveness of the licensees ability to resolve procedural issues. For these specific items the NRC will verify that the licensee has performed adequate casual analysis and extent of condition evaluations related to the deficient procedural guidance. In addition, the NRC will verify that adequate corrective actions were identified associated with the causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status 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 NCV 2012301-06 Inadequate Procedures with Four Examples for the Barrier Integrity Cornerstone NCV 2011002-01 Inadequate Operating Instruction Results in a Loss of Auxiliary Feedwater NCV 2010004-10 Inadequate Maintenance Procedure Results in a Plant Shutdown Item 5.d Equipment Performance Equipment failure or degradation can cause initiating events during power operation and losses of decay heat removal during shutdowns. To limit challenges to safety functions due to equipment problems, licensees should have programs to achieve a high degree of availability and reliability of equipment that can cause initiating events. The availability and reliability of equipment is also critical to mitigating the impact of initiating events on plant safety. Strong preventive and corrective maintenance programs are an integral part of assuring equipment availability and reliability.

As discussed in other sections of this basis document the NRC will:

• Assess the effectiveness of corrective actions for deficiencies involving equipment performance, including equipment designated for increased monitoring via implementation of the Maintenance Rule.

• Assess the operational performance of the auxiliary feedwater system to verify its capability of performing the intended safety functions.

• Review a sample of Emergency Preparedness related equipment and facilities (including communications gear) against Plan commitments. Review the adequacy of the surveillance program to maintain equipment and facilities. Review the correction of deficiencies identified by the surveillance program.

• Assess licensee corrective actions associated the significant equipment deficiencies involving flooding concerns, reactor protection system failures, and electrical bus deficiencies.

The following NRC items are specifically related to equipment performance concerns and therefore will be reviewed by the NRC to assess the effectiveness of the licensees ability to resolve these issues. For these specific items the NRC will verify that the licensee has performed adequate casual analysis and extent of condition evaluations related to the failures.

In addition, the NRC will verify that adequate corrective actions were identified associated with the causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status LER 2012-018-0 Containment Air Cooling Units Operated Outside of Technical Specification during Cycle 26 LER 2012-005-1 Technical Specification Violation Due to Inadequate Testing of Emergency Diesel Fuel Pumps NCV 2010004-09 Failure to perform vendor and industry recommended testing on safety-related and risk significant 4160 V and 480 V circuit breakers Item 5.e Configuration Control The NRC will inspect and assess the licensees ability to maintain risk-significant systems and the principle fission product barriers in configurations which support their safety functions by completing the following inspection activities discussed in this basis document:

• Assess the effectiveness of corrective actions for deficiencies involving configuration control.

• Assess licensee actions ensuring systems are ready to support safe plant operation following an extended shutdown

• Perform walkdowns of selected systems (AC and DC Electrical Distribution Systems, High Pressure Injection System, Emergency Diesel Generators, Reactor Protection System, and the Auxiliary Feedwater System) to validate they are ready for safe operation.

• Review licensee actions regarding the identified Fundamental Performance Deficiency involving Engineering Design/Configuration Control The NRC will verify that the following actions being implemented by the licensee adequately address configuration control issues at the facility. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number Finalize identification of all configuration changes for 4.3.1.1 restoration Finalize identification of configuration changes to be made 4.3.1.2 permanent 4.3.1.3 Establish Priority/Schedule for restoration Initiate actions to remove non-permanent configuration 4.3.1.4 changes The following NRC items are specifically related to configuration control concerns and therefore will be reviewed by the NRC to assess the effectiveness of the licensees ability to resolve these issues. For these specific items the NRC will verify that the licensee has performed adequate root cause and extent of condition evaluations related to the failures. In addition, the NRC will verify 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.

Item Description Status LER 2012-012-0 Multiple Safety Injection Tanks Rendered Inoperable LER 2012-008-0 Technical Specification Violation for Fuel Movement (VA-66)

Item 5.f Emergency Response Implementation of the Emergency Response Plan is dependent on the readiness of the emergency response organization to respond to an emergency. In this usage, readiness means the ability of the licensee to activate timely Emergency Response Organization augmentation of on shift personnel as necessary to implement the emergency plan. Self-assessments of readiness during drills and activation tests are used to identify areas for improvement. Self-assessment and corrective action resolution is critical to Emergency Response Organization readiness. The NRC review includes the following inspection requirements:

• Assess the effectiveness of corrective actions for deficiencies involving Emergency Response Organization readiness.

• Verify that adequate staffing is available on shift for emergencies.

• Verify the capability to activate and staff the emergency response facilities and augment the response organization within the requirements of the licensee emergency response plan

The NRC will implement the following NRC Emergency Preparedness Inspection Procedures.

Item Description Status 5.h.1 IP 71114.01, Exercise Evaluation Completed IR2012-002 ML12132A395 5.h.2 IP 71114.02, Alert and Notification System Testing 5.h.3 IP 71114.03, Emergency Preparedness Organization Staffing and Augmentation System 5.h.4 IP 71114.04, Emergency Action Level and Emergency Plan Completed Changes IR2012-002 ML12132A395 5.h.5 IP 71114.05, Maintenance of Emergency Preparedness Completed IR2012-002 ML12132A395 5.h.6 IP 71114.06 Drill Evaluation Completed IR2012-002 ML12132A395 The NRC will verify that the following licensee actions in the area of emergency response are adequately addressed. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number 5.1.2.1 Procure 10 solar charging kits for nine affected sirens Perform fly over of flood affected sirens to determine status 5.1.2.2 and potential condition of the equipment Closed Based on siren inspection procure replacement siren heads, IR 2012-004 5.1.2.3 poles, electronics, and power supplies ML12276A456 If siren damage and/or infrastructure is such that timely repair Closed of sirens is not possible, work with FEMA, state, and local IR 2012-003 5.1.2.4 governments for potential exemptions or long term plan ML12226A630 Closed IR 2012-004 5.1.2.5 Replace batteries in the affected sirens ML12276A456 5.1.2.6 Install solar charging kits on the affected sirens

Closed Conduct siren inspections using the communications IR 2012-004 5.1.2.7 developed check list ML12276A456 Conduct a full siren test after sirens have been restored to 5.1.2.8 functional status Closed Conduct Emergency Planning Test EP-37, Emergency Sign IR 2012-004 5.1.3.1 Verification ML12276A456 Closed IR 2012-003 5.2.1.1 Develop a field monitoring and environmental sampling plan ML12226A630 Closed Conduct a Protective Measure table top with the states of IR 2012-003 5.2.2.1 Nebraska and Iowa ML12226A630 Closed IR 2012-003 5.3.2.1 Perform ERDS testing ML12226A630 Closed IR 2012-004 5.3.2.2 Perform normal communications testing ML12276A456 Closed IR 2012-004 5.3.2.3 Restore area radiation monitors ML12276A456 Closed IR 2012-004 5.3.2.4 Ensure effluent radiation monitors are functional ML12276A456 Closed IR 2012-004 5.3.2.5 Restore equipment used for emergency classification ML12276A456 5.3.2.6 Perform normal facility inventories and assessments Closed Conduct Meeting with FEMA, NRC, local Emergency Manager, IR 2012-003 5.3.2.7 and State Emergency Managers ML12226A630 Closed IR 2012-004 5.3.2.18 Obtain statement of Reasonable Assurance from FEMA ML12276A456 5.4.2.1 MET tower restoration 5.4.2.2 MET tower building restoration Closed IR 2012-003 5.4.2.3 Secondary Evacuation Route restoration ML12226A630

Closed IR 2012-004 5.4.2.4 Critique Flooding event ML12276A456 The site performed an integrated assessment and identified fifteen Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of the deficiencies identified was Emergency Response Organization. Examples in this area included important emergency response equipment (ERO) are experiencing repeat failures; inadequate implementation and documentation of important ERO activities; and some emergency preparedness deficiencies are not effectively identified and corrected.

The NRC will evaluate the thoroughness of the licensees Emergency Response Organization evaluation, adequacy of extent of condition and extent of causal analysis, and adequacy of associated corrective actions.

Item Description Status 5.f.1 Licensee Assessment of the Fundamental Performance Deficiency of Emergency Response Organization 5.f.2 Adequacy of extent of condition and extent of causes 5.f.3 Adequacy of corrective actions The following NRC items are specifically related to emergency response concerns and therefore will be reviewed by the NRC to assess the effectiveness of the licensees ability to resolve these issues. For these specific items the NRC will verify that the licensee has performed adequate root cause and extent of condition evaluations related to the failures. In addition, the NRC will verify 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.

Item Description Status NCV 2010003-02 Failure to conduct an adequate audit of emergency preparedness interfaces with offsite authorities NCV 2010003-03 Failure to Conduct Drills to Maintain Environmental Monitoring Skills NCV 2010003-04 Protective Action Recommendation processes allow for the unnecessary evacuation of the public

Item 5.g Occupational Radiation Safety The goal for the Occupational Radiation Safety cornerstone is to ensure adequate protection of worker health and safety from exposure to radiation or radioactive material during routine civilian nuclear reactor operations. The facility is required to maintain fixed and portable radiation survey equipment (for airborne and external hazards), respiratory protection, communication equipment, temporary ventilation and shielding, and anti-contamination clothing to protect workers. This equipment is also needed to conduct adequate radiation monitoring and surveillance activities. Routine calibration and maintenance of this equipment ensures its continued operability. The NRC will inspect and assess the plant facilities, equipment, and instrumentation for occupational radiation safety.

Worker performance has an obvious, important impact on work activities in radiological areas.

Two of the major components are health physics technician and general radiation worker (crafts) groups. Human performance is impacted by several vital factors - qualification and training. The selection, qualification, and training requirements for facility personnel are generally governed by a licensing commitment in the plant technical specifications (to an American Nuclear Society standard). The NRC will inspect and assess the human performance attributes of occupational radiation safety.

The following NRC Inspection Procedures will be implemented:

Item Description Status 5.g.1 IP 71124.01, Radiological Hazard Assessment and Exposure Controls 5.g.2 IP 71124.02, Occupational ALARA Planning and Controls Item 5.h Public Radiation Safety To prevent the inadvertent release of licensed radioactive material from the licensees control requires the use of sensitive radiation survey equipment that is properly setup and calibrated.

The NRC will assess and inspect the plant equipment, systems, and instrumentation of public radiation safety.

The performance of radiation surveys on equipment and material to be released from the licensees facility requires appropriate policy and technical procedural guidance for handling and processing a wide variety of potentially contaminated materials. The NRC will inspect and assess the procedures and programs of public radiation safety.

Human performance can directly affect radioactive waste processing, radioactive effluent processing, and transportation programs. It is important to ensure that plant workers are adequately trained and qualified to perform their job function. Periodic retraining is also needed to ensure that workers maintain their qualifications and are updated with new information and requirements. The NRC will inspect and assess the human performance elements of public radiation safety.

The following NRC Inspection Procedures will be implemented:

Item Description Status 5.h.1 IP 71124.06, Radioactive Gaseous and Liquid Effluent Completed Treatment IR 2012-004 ML12276A456 5.h.2 IP 71124.07, Radiological Environmental Monitoring Completed Program IR 2012-004 ML12276A456 5.h.3 IP 71124.08, Radioactive Solid Waste Processing and Completed Radioactive Material Handling, Storage, and Transportation IR 2012-004 ML12276A456 Although not a specific plant restart action, the NRC will review the following long term action planned to be implemented by the licensee.

Action Description Status Item Number 1.2.3.42 Tritium groundwater sampling Closed IR 2012-003 ML12226A630 Item 5.i Security The objective of the security cornerstone is to assure that security systems use a defense-in-depth approach and can protect against the design basis threat of radiological sabotage from external and internal threats. The NRC will assess the licensees ability to satisfy the cornerstone objective by inspecting the security cornerstone attributes of access control, physical protection, contingency response and material control and accounting.

The NRC will also verify that the security related licensee actions listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, are adequately addressed.

A description of the actions to be reviewed by the NRC is contained in a separate document which contains Security Related Information in accordance with 10 CFR 2.390(d)(1) and its disclosure to unauthorized individuals could present a security vulnerability and will not be made publicly available.

Section 6: Licensing Issue Resolution This section of the Restart Checklist encompasses the regulatory activities needed to bring Fort Calhoun Station into current compliance. While no current licensing issues are applicable, this section provides the avenue to address them as they may arise out of other restart reviews and actions. These may include historical, pending, or items discovered during the inspection phases described in Sections 1 - 3, and Section 6.

Item 6.a Review of Necessary Licensing Amendments or Actions The NRC has no current licensing issues. If licensing actions are identified, they will be added to this item in the Restart Checklist.

Item 6.b Review of Licensing Commitments Necessary for Restart The NRC will conduct a commitment management audit, focusing on the implementation of regulatory commitments.

Item Description Status 6.b.1 Perform commitment management audit

Section 7: Readiness for Restart Fort Calhoun Station has been shut down for a prolonged period of time (since April 2011). This section is provided to ensure final restart items are appropriately addressed to allow for power operation to recommence.

Item 7.a Operations Organization Ready for Restart After long periods in a shutdown condition, particularly where significant performance issues were also identified, a performance-based and risk-informed inspection should be conducted by the NRC. The NRC performs such inspections using Operational Readiness Assessment Team inspections, under the guidance of Inspection Procedure 93806, Operational Readiness Assessment Team Inspections. The NRC plans to perform an operational readiness inspection during plant heat up prior to start up to assess operational performance.

Item Description Status 7.a.1 Perform Operational Readiness Assessment Team inspection The site performed an integrated assessment and identified fifteen Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. Site Operational Focus was identified as one of these areas for improvement. Examples identified by the licensee included decisions do not demonstrate the use of a systematic process; station personnel lack understanding of the design and licensing basis of the plant in a manner that drives conservative, operational decision making; inconsistent recognition and evaluation of risk significant conditions; and excessive backlogs in preventative maintenance, surveillances, procedure revisions, drawing changes, corrective maintenance, and low margin issues.

The NRC will evaluate the thoroughness of the licensees evaluation involving Site Operational Focus, adequacy of extent of condition and extent of causal analysis, and adequacy of associated corrective actions.

Item Description Status 7.a.2 Licensee Assessment of the Fundamental Performance Deficiency associated with Site Operational Focus 7.a.3 Adequacy of extent of condition and extent of causes 7.a.4 Adequacy of corrective actions

Item 7.b Systems Ready for Restart and Mode Restraints Properly Addressed This item is a final review, by the NRC, of system lineups and preparations for restart. This will also include a specific review of how Fort Calhoun Station addressed, reviewed, and closed particular mode restraints.

Item Description Status 7.b.1 Final system readiness and mode restraint review Item 7.c Final Review of Corrective Action Program for Restart Items This item is a final NRC review of the Corrective Action Program actions that were required prior to facility restart. The NRC will inspect to ensure corrective actions associated with equipment operability, design, or qualification were appropriately addressed and closed prior to restart, or that they are specifically tied to a restart or mode restraint.

Item Description Status 7.c.1 Final corrective action program review for restart items prior to restart

Section 8: Confirmatory Action Letter Resolution Item 8.a Verification that all Restart-Related Confirmatory Action Letter Items are Appropriately Resolved The NRC will inspect and independently verify that the required actions in the Confirmatory Action Letter are completed prior to restart.

Item Description Status 8.a.1 All Confirmatory Action Letter items addressed Item 8.b Conduct Public Meeting Regarding Plant Readiness for Restart Item Description Status 8.b.1 Conduct public meeting to discuss plant readiness for restart

Section 9: Final Recommendation for Restart Item 9.a Final Recommendation for Restart If warranted, the Manual Chapter 0350 Panel recommends restart to the Region IV Administrator. The Region IV Administrator obtains concurrence for restart from the Deputy Executive Director for Reactor and Preparedness Programs, and the Director of the Office of Nuclear Reactor Regulation. Plant restart will be recommended when the NRC has determined that Fort Calhoun Station can operate safely, and has completed the required sections of the Confirmatory Action Letter and Restart Checklist.

LIST OF ACRONYMS USED AAP Auxiliary Access Point ACS Auxiliary Cooling System AFW Auxiliary Feedwater System AIS Auxiliary Instrumentation System ALARA As Low As Reasonably Achievable AUS Auxiliary Steam System CFR Code of Federal Regulations COM Communications System CQE Critical Quality Equipment CR Condition Report CRD Control Rod Drive System CVC Chemical and Volume Control System CWS Circulating Water System DI Deionized DW/PW Demineralized Water/Potable Water System EAO Exclusion Area Opening EC Engineering Change ECC Emergency Core Cooling System EDG Emergency Diesel Generator EDS Electrical Distribution System EEQ Equipment Environmental Qualification EP Emergency Planning EPRI Electric Power Research Institute ER Equipment Reliability ERDS Emergency Response Data System ERO Emergency Response Organization ESF Engineered Safety Features System FEMA Federal Emergency Management Agency FHS Fuel Handling System FP Fire Protection FPD Fundamental Performance Deficiency FPS Fire Protection System GPR Ground Penetrating Radar HCV Hydraulic Control Valve HELB High Energy Line Break HES Hoisting Equipment System IAS Instrument Air System IP Inspection Procedure IPIP Integrated Performance Improvement Plan ISFSI Independent Spent Fuel Storage Installation LER Licensee Event Report LOOP Loss of Offsite Power MET Meteorological MFW Main Feedwater System MMS Meteorological Monitoring System NCV Noncited Violation NFPA National Fire Protection Association

NOS Nuclear Oversight NRC Nuclear Regulatory Commission OCA Owner Controlled Area OPPD Omaha Public Power District PA Protected Area PAP Primary Access Point PM Preventative Maintenance PRC Plant Review Committe RCS Reactor Coolant System RMS Radiation Monitoring System RPS Reactor Protection System RPS Reactor Protection System SAT Satisfactory SEC Plant Security System SFP Spent Fuel Pool System SGI Safeguards Information SGS Steam Generator System SIAS Safety Injection Actuation Signal SLS Sampling System SMART Station Modification Acceptance Review Team SSC Systems, Structures, and Components ST Surveillance Test STR Structures System T&D Transmission and Distribution TGS Turbine Generator System TPC Turbine Plant Cooling System VAC Ventilating Air Conditioning System VDS Vents and Drains System VIO Violation WDS Waste Disposal System