ML12132A395

IR 05000285-12-002; 01/01/2012 - 03/31/2012; Fort Calhoun Station, Integrated Resident and Regional Report; Adverse Weather Protection, Emergency Plan Biennial Exercise, Mc 0350

ML12132A395
Person / Time
Site:	Fort Calhoun
Issue date:	05/11/2012
From:	Clark J NRC/RGN-IV/DRP
To:	Bannister D Omaha Public Power District
References
EA-12-095 IR-12-002
Download: ML12132A395 (48)

See also: IR 05000285/2012002

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I V

1600 EAST LAMAR BLVD

ARLINGTON, TEXAS 76011-4511

May 11, 2012

EA-2012-095

David J. Bannister, Vice President

and Chief Nuclear Officer

Omaha Public Power District

Fort Calhoun Station FC-2-4

P.O. Box 550

Fort Calhoun, NE 68023-0550

Subject: FORT CALHOUN - NRC INTEGRATED INSPECTION REPORT NUMBER

05000285/2012002

Dear Mr. Bannister:

On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Fort Calhoun Station. The enclosed inspection report documents the inspection results

which were discussed on April 11, 2012, with you and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

Two NRC identified findings of very low safety significance (Green) were identified during this

inspection. Both of these findings were determined to involve violations of NRC requirements.

Further, a licensee-identified violation which was determined to be of very low safety

significance is listed in this report. The NRC is treating these violations as non-cited violations

consistent with Section 2.3.2 of the Enforcement Policy.

Additionally, three other violations of NRC requirements were identified. These findings were

determined to be violations related to a previously issued Yellow finding regarding the ability to

mitigate an external flooding event (Inspection Reports 05000285/2010007 and

05000285/2010008; ML101970547 and ML102800342, respectively). The significance of these

findings was bounded by the Yellow finding and therefore were not characterized by color

significance. All three of these findings were determined to involve violations of NRC

requirements. Separate citiations will not be issued as these items associated with flood

mitigation are being evaluated by the NRC under the Manual Chapter 0350, Oversight of

Reactor Facilities in a Shutdown Condition Due to Significant Performance and/or Operational

Concerns, process (EA-2012-095).

If you contest these violations, you should provide a response within 30 days of the date of this

inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington DC 20555-0001; with copies to the Regional

D. Bannister -2-

Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory

Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Fort Calhoun

Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the Regional Administrator, Region IV; and the NRC Resident Inspector at Fort

Calhoun Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA/

Jeffrey A. Clark, P.E.

Chief, Project Branch F

Division of Reactor Projects

Docket: 50-285

License: DPR-40

Enclosure: NRC Inspection Report 05000285/2012002

w/Attachment: Supplemental Information

cc w/encl: Electronic Distribution

[Accession Number]

SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials RWD

Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials RWD

SRI:DRP/F RI:DRP/F SPE:DRP/F C:DRS/EB1 C:DRS/EB2 C:DRS/OB

JCKirkland JFWingebach RWDeese TRFarnholtz GBMiller MSHaire

/RWDeese via E/ /RWDeese via E/ /RA/ /RA/ /RA/ /COsterholtz for/

5/11/12 5/11/12 5/4/12 5/2/12 5/3/12 5/4/12

C:DRS/PSB1 C:DRS/PSB2 C:DRS/TSB C:ORA/ACES BC:DRP/F

MCHay GEWerner DAPowers HGepford JAClark

/RA/ /RA/ /RAlexander for/ /RA/ /RA/

5/2/12 5/3/12 5/3/12 5/11/12 5/11/12

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000285

License: DPR-40

Report: 05000285/2012002

Licensee: Omaha Public Power District

Facility: Fort Calhoun Station

Location: 9610 Power Lane

Blair, NE 68008

Dates: January 1 through March 31, 2012

Inspectors: J. Kirkland, Senior Resident Inspector

J. Wingebach, Resident Inspector

K. Clayton, Senior Operations Engineer

R. Kopriva, Senior Reactor Inspector,

B. Larson, Senior Operations Engineer

G. Apger, Operations Engineer

P. Elkmann, Senior Emergency Preparedness Inspector

G. Guerra, CHP, Emergency Preparedness Inspector

D. Strickland, Operations Engineer

C. Henderson, Resident Inspector

J. Laughlin, Emergency Preparedness Inspector, NSIR

Approved By: Jeffrey Clark, P.E., Chief, Project Branch F

Division of Reactor Projects

-1- Enclosure

SUMMARY OF FINDINGS

IR 05000285/2012002; 01/01/2012 - 03/31/2012; Fort Calhoun Station, Integrated Resident and

Regional Report; Adverse Weather Protection, Emergency Plan Biennial Exercise, MC 0350

The report covered a 3-month period of inspection by resident inspectors and announced

baseline inspections by region-based inspectors. Two violations were identified. The

significance of most findings is indicated by their color (Green, White, Yellow, or Red) using

Inspection Manual Chapter 0609, Significance Determination Process. Additionally, three

violations were identified, and were determined to be violations related to and bounded by a

previously issued Yellow finding regarding the ability to combat an external flooding event

(Inspection Report 05000285/2010008) and therefore were not characterized by color

significance. The cross-cutting aspect is determined using Inspection Manual Chapter 0310,

Components Within the Cross Cutting Areas. Findings for which the significance

determination process does not apply may be Green or be assigned a severity level after NRC

management review. The NRC's program for overseeing the safe operation of commercial

nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4,

dated December 2006.

A. NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Mitigating Systems

• N/A. The inspectors identified four examples of a violation of Technical

Specification 5.8.1.a, Procedures, for failure to establish and maintain procedures

to mitigate an external flooding event. The procedural guidance for flooding was

inadequate to mitigate the consequences of external flooding. This finding, and its

corrective actions, will be managed by the Manual Chapter 0350 Oversight Panel.

This finding was more than minor because it adversely impacted the procedure

quality, human performance and protection against external events attributes of the

Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences. The significance of this finding is bounded by the significance of a

related Yellow finding regarding the ability to mitigate an external flooding event

(Inspection Report 05000285/2010008). This finding has a cross-cutting aspect in

the area of problem identification and resolution, corrective action program, for failure

to thoroughly evaluate problems such that the resolutions address causes and extent

of conditions. This also includes, for significant problems, conducting effectiveness

reviews of corrective actions to ensure that the problems are resolved P.1(c).

(Section 1R01)

• N/A. The inspectors identified a violation of 10 CFR Part 50, Appendix B, Criterion

III, Design Control, for failure of the licensee to classify the six intake structure

exterior sluice gates and their motor operators as Safety Class III. This finding, and

its corrective actions, will be managed by the Manual Chapter 0350 Oversight Panel.

-2- Enclosure

This finding was more than minor because it adversely impacted the protection

against external events attribute of the Mitigating Systems Cornerstone objective of

ensuring the availability, reliability and capability of systems that respond to initiating

events to prevent undesirable consequences. The significance of this finding is

bounded by the significance of a related Yellow finding regarding the ability to

mitigate an external flooding event (Inspection Report 05000285/2010008). This

finding has a cross-cutting aspect in the area of problem identification and resolution,

corrective action program, for failure to thoroughly evaluate problems such that the

resolutions address causes and extent of conditions. This also includes, for

significant problems, conducting effectiveness reviews of corrective actions to ensure

that the problems are resolved P.1(c). (Section 1R01)

• N/A. The inspectors identified a violation of 10 CFR 50, Appendix B, Criterion III,

Design Control, for failure to meet design basis requirements for protection of the

safety related raw water system during a design basis flood for flood levels between

1,010-1,014 feet mean sea level as identified in Updated Safety Analysis Report,

Section 9.8, Raw Water System. Specifically, the design basis states that water

level inside the intake cells can be controlled during a design basis flood by

positioning the exterior sluice gates to restrict the inflow into the cells. This finding,

and its corrective actions, will be managed by the Manual Chapter 0350 Oversight

Panel.

This finding was more than minor because it adversely impacted the equipment

performance and protection against external events attributes of the Mitigating

Systems Cornerstone objective of ensuring the availability, reliability and capability of

systems that respond to initiating events to prevent undesirable consequences. The

significance of this finding is bounded by the significance of a related Yellow finding

regarding the ability to mitigate an external flooding event (Inspection Report 05000285/2010008). This finding has a cross-cutting aspect in the area of problem

identification and resolution, corrective action program, for failure to thoroughly

evaluate problems such that the resolutions address causes and extent of conditions

P.1(c). (Section 1R01)

Cornerstone: Emergency Preparedness

• Green. The inspector identified a non-cited violation of 10 CFR 50.54(q)(2) for

failure to follow the licensees emergency plan. Specifically, the licensee did not

follow the Radiological Emergency Response Plan, Section E, Notification Methods

and Procedures, Revision 26, which requires offsite warning sirens be activated by

radio signal. The licensee did not respond to indications of siren system failure for

approximately six hours and did not inform offsite authorities of the need for

alternative means to notify the public for three additional hours. This failure has been

entered into the licensees corrective action system as Condition Reports 2012-

01435 and 2012-01489.

This finding is more than minor because it affected the facilities and equipment

cornerstone attribute (availability of the alert and notification system) and impacted

the cornerstone objective of implementing adequate measures to protect public

-3- Enclosure

health and safety. This finding was evaluated using the Emergency Preparedness

Significance Determination Process and was determined to be of very low safety

significance because the planning standard function was not lost or degraded. The

function was not degraded because some sirens remained functional in the 0-5 and

5-10 mile areas of the emergency planning zone, and offsite officials could have

promptly recognized failed sirens. The finding had a cross-cutting aspect in the work

control component of the human performance area because the communications

department and control room personnel did not communicate and coordinate as

necessary with offsite organizations H3.b]. (Section 1EP5)

• Green. The inspectors identified a non-cited violation of 10 CFR 50.54(q) for failure

to follow an emergency plan requirement during a declared alert. Specifically, the

licensee did not notify the states of Nebraska and Iowa of the emergency within 15

minutes of event declaration as required by Section E, paragraph 2.4, of their

emergency plan. This failure has been entered into the licensees corrective action

system as Condition Report 2011-8529.

This finding is more than minor because it affects safety and impacts the cornerstone

attributes of emergency response organization performance and actual event

response. The finding had a credible impact on the Emergency Preparedness

Cornerstone objective because untimely notification to offsite authorities degrades

their ability to implement adequate measures to protect the health and safety of the

public. The finding is of very low safety significance because it was a problem with

implementation of the site emergency plan during an event that did not affect the

ability of offsite authorities to respond to the emergency. The finding had a cross-

cutting aspect in the work practices (management oversight) component of the

human performance area because licensee management did not set performance

expectations for event notifications and monitor performance to ensure compliance

with emergency plan requirements H4.c] (Section 4OA1).

B. Licensee-Identified Violations

A violation of very low safety significance (Green) identified by the licensee has been

reviewed by the inspectors. Corrective actions taken or planned by the licensee have

been entered into the licensees corrective action program. This violation and

associated corrective action tracking numbers are listed in Section 4OA7 of this report.

-4- Enclosure

REPORT DETAILS

Summary of Plant Status

The station remained in refueling shutdown conditons with the fuel in the reactor vessel for the

entire inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

.1 Readiness to Cope with External Flooding

a. Inspection Scope

The inspectors performed a walk down of flood protection barriers and equipment used

to prepare for a flooding event. The inspectors performed a review of procedures used

to prepare for, and cope with, an external flooding event with emphasis on a design

basis flood (1,014 feet mean sea level).

During the inspection, the inspectors performed a review of the Updated Safety Analysis

Report and related flood analysis documents

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one readiness to cope with external flooding as

defined in Inspection Procedure 71111.01-04.

b. Findings

(1) Inadequate Procedures to Mitigate a Design Basis Flood Event

Introduction. The inspectors identified four examples of a violation of Technical

Specification 5.8.1.a, Procedures, for failure to establish and maintain

procedures to mitigate an external flooding event. The inspectors determined

that the procedural guidance of Abnormal Operating Procedure 1, Acts of

Nature, Section - I, Flooding, and other supporting procedures, were inadequate

to mitigate the consequences of external flooding. As a result, the

licensee initiated an 8-hour report to the NRC Operations Center in accordance

with 10 CFR 50.72(b)(3)(ii)(B), unanalyzed condition that significantly degraded

plant safety, on February 10, 2012.

Description. Four examples describing the inadequacies in Abnormal Operating

Procedure 1 were identified by the inspectors.

-5- Enclosure

(a) Abnormal Operating Procedure 1 failed to provide operators with

sufficient information to ensure a transfer of power from offsite to an

onsite emergency diesel generator prior to a loss of offsite power. The

procedure directed operators to transfer one class-1E 4160 volt AC bus to

emergency diesel power if river level was expected to exceed 1,006 feet

mean sea level and the switchyard had not been protected. However, the

procedure did not define what constituted protection of the switchyard.

In addition, had the operators chosen to continue in the procedure and

not direct transfer of power to an emergency diesel, the procedure did not

provide information to the operators as to when offsite power must be

transferred prior to loss of the switchyard. The procedure strategy was to

construct barriers to flood waters around the switchyard on an as-needed

basis to maintain offsite sources available for as long as possible to

conserve diesel fuel oil. The barriers, however, were not intended to

protect the switchyard against a design basis flood of 1,014 feet mean

sea level, thus a transfer of offsite power would need to occur at some

point during procedure implementation.

(b) Abnormal Operating Procedure 1 failed to identify that the

class-1E powered motor operators of the six intake structure sluice gates

were located at an elevation of 1,010 feet mean sea level. Since the

design basis flood was to a river level of 1,014 feet mean sea level,

control of the sluice gates could have been lost when river level exceeded

1,010 feet mean sea level because the electric motors could have

become submerged and were not qualified to operate under water.

(c) Abnormal Operating Procedure 1 did not identify that three of the six

sluice gate motor operators would be de-energized when offsite power

was transferred from offsite to one onsite emergency diesel generator.

Only one emergency diesel generator would have been started in an

effort to maintain an adequate diesel fuel oil supply. In addition, Abnormal

Operating Procedure 1 did not provide direction to the operators to

ensure the one of six sluice gates selected to control intake structure cell

water level would have remained energized when power was transferred

to the emergency diesel generator. As part of the strategy for intake

structure flood mitigation, five of the six sluice gates would have been

closed and level would have been controlled by repositioning the

remaining sluice gate as required.

(d) Abnormal Operating Procedure 1 did not adequately ensure the fuel

transfer hose to emergency diesel generator day tanks was staged prior

to river level exceeding 1,004 feet mean sea level. Abnormal Operating

Procedure 1, Step 1, directed implementation of Attachment D, Flood

Protective Actions. Step 2 of Attachment D only directed Emergency

Planning to review EPIP-TSC-2 for expected flood level and did not

have explicit directions to perform any actions. Step 7.9 of EPIP-TSC-2

-6- Enclosure

directed installation or staging of plant flood barriers per procedure PE-

RR-AE-1001, Flood Barrier and Sandbag Staging and Installation.

Attachment 23 of PE-RR-AE-1001 was for staging the fuel transfer hose.

Inspectors concluded that the implementing procedures were not

adequate to ensure staging the transfer hose was performed.

Analysis. The inspectors determined that failure of the licensee to establish and

maintain adequate procedures to mitigate an external flooding event was a

performance deficiency. This finding was more than minor because it adversely

impacted the procedure quality, human performance and protection against

external events attributes of the Mitigating Systems Cornerstone objective of

ensuring the availability, reliability, and capability of systems that respond to

initiating events to prevent undesirable consequences. The significance of this

finding is bounded by the significance of a related Yellow finding regarding the

ability to mitigate an external flooding event (Inspection Report 05000285/2010008). This finding has a cross-cutting aspect in the area of

problem identification and resolution, corrective action program, for failure to

thoroughly evaluate problems such that the resolutions address causes and

extent of conditions. This also includes, for significant problems, conducting

effectiveness reviews of corrective actions to ensure that the problems are

resolved P.1(c).

Enforcement. Technical Specification 5.8.1.a, Procedures, states, Written

procedures and administrative policies shall be established, implemented, and

maintained covering the following activities: (a) The applicable procedures

recommended in Regulatory Guide 1.33, Revision 2, Appendix A, 1978. NRC

Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation),

Appendix A, Typical Procedures for Pressurized Water Reactors and Boiling

Water Reactors, Section 6, recommends procedures for combating emergencies

and other significant events. Abnormal Operating Procedure 1, Acts of Nature,

Section - I, Flooding, and its supporting procedures, prescribe station actions to

mitigate the consequences of external flooding. Contrary to the above, since

1978, the licensee failed to have adequate procedures for combating

emergencies. Specifically, Abnormal Operating Procedure 1, Acts of Nature,

Section - I, Flooding, and its supporting procedures, were inadequate to

mitigate the consequences of external flooding by (1) failing to provide operators

with sufficient information to ensure a transfer of power from offsite to an onsite

emergency diesel geneator prior to a loss of offsite power, (2) failing to identify

that the class-1E powered motor operators of the six intake structure sluice gates

were located at an elevation of 1,010 feet mean sea level, (3) failing to identify

that three of the six sluice gate motor operators would be de-energized when

offsite power was transferred from offsite to one onsite emergency diesel

generator, and (4) not adequately ensuring the fuel transfer hose to emergency

diesel generator day tanks were staged prior to river level exceeding 1,004 feet

mean sea level. This violation is considered as a related violation to the Yellow

finding issued in October 2010, that, in general, dealt with issues related to

mitigating a significant external flooding event. A separate citiation will not be

-7- Enclosure

issued as this finding, and its corrective actions, will be managed by the Manual

Chapter 0350 Oversight Panel. VIO 05000285/2012002-01, Inadequate

Procedures to Mitigate a Design Basis Flood Event.

(2) Failure to Classify Intake Structure Sluice Gates as Safety Class III

Introduction. The inspectors identified a violation of 10 CFR Part 50, Appendix B,

Criterion III, Design Control, for failure of the licensee to classify the six intake

structure exterior sluice gates and their motor operators as Safety Class III as

defined in the Updated Safety Analysis Report, Appendix N.

Description. The inspectors discovered that this finding had been originally

identified by licensee personnel in February 2011, as Action Item No. 34 to

Condition Report 2010-2387. However, this action item was closed in August

2011, without action taken to classify the sluice gates as safety related. In

preparation for the NRC flooding inspection, licensee personnel conducted a

review of Condition Report 2010-2387 Action Item No. 34 that revealed the

quality classification of each penetration/flood barrier had not been verified.

Condition Report 2011-10302 was issued in December 2011, to identify that the

quality classification of the intake structure cell level control and level monitoring

equipment may be incorrect. Because of the failure of the corrective action

program to resolve the issue after initially being identified, and the significant

value added by further inspection effort, the finding is documented as

NRC-identified.

Analysis. The inspectors determined that failure to classify the intake structure

exterior sluice gates and their motor operators as Safety Class III is a

performance deficiency. This finding was more than minor because it adversely

impacted the protection against external events attribute of the Mitigating

Systems Cornerstone objective of ensuring the availability, reliability and

capability of systems that respond to initiating events to prevent undesirable

consequences. The significance of this finding is bounded by the significance of

a related Yellow finding regarding the ability to mitigate an external flooding event

(Inspection Report 05000285/2010008). This finding has a cross-cutting aspect

in the area of problem identification and resolution, corrective action program, for

failure to thoroughly evaluate problems such that the resolutions address causes

and extent of conditions. This also includes, for significant problems, conducting

effectiveness reviews of corrective actions to ensure that the problems are

resolved P.1(c).

Enforcement. 10 CFR 50, Appendix B, Criterion III, Design Control, states in

part that measures shall be established to assure that applicable regulatory

requirements and the design basis for those structures, systems, and

components are correctly translated into specifications, drawings, procedures,

and instructions. Contrary to this, before February 6, 2012, the licensee failed to

establish measures to assure applicable regulatory requirements and the design

basis for those components were correctly translated into specifications,

-8- Enclosure

drawings, procedures, and instructions. Specifically, the licensee failed to

classify the six intake structure exterior sluice gates and their motor operators as

Safety Class III as defined in the Updated Safety Analysis Report, Appendix N.

This violation is not being treated as a new violation. Instead, it is considered as

a related violation to the Yellow finding issued in October 2010, that, in general,

dealt with issues related to mitigating a significant external flooding event. A

separate citiation will not be issued as this finding, and its corrective actions, will

be managed by the Manual Chapter 0350 Oversight Panel: VIO

05000285/2012002-02, Failure to Classify Intake Structure Sluice Gates as

Safety Class III (EA-2012-095).

(3) Failure to Meet Design Basis Requirements for Design Basis Flood Event

Introduction. The inspectors identified a violation of 10 CFR 50, Appendix B,

Criterion III, Design Control, for failure to meet design basis requirements for

protection of the safety related raw water system during a design basis flood for

flood levels between 1,010-1,014 feet mean sea level as identified in Updated

Safety Analysis Report, Section 9.8, Raw Water System. Specifically, the

design basis states that water level inside the intake cells can be controlled

during a design basis flood by positioning the exterior sluice gates to restrict the

inflow into the cells.

Description. The electric motor operators that position the six exterior sluice

gates on the intake structure are located at an elevation of 1,010 feet mean sea

level outside the east wall of the intake structure. At the design basis flooding

elevation of 1,014 feet mean sea level, they would be completely submerged.

Therefore, the motors that position the exterior sluice gates may not function

when river water level rises above the 1,010 feet mean sea level. The licensees

flooding mitigation strategy involves closing five of the six exterior sluice gates

and positioning the remaining gate such that a balance between inflow and raw

water pump discharge are balanced (approximately one-inch open) prior to water

level rising to 1,010 feet mean sea level.

The inspectors identified that changing river conditions above 1,010 feet mean

sea level, could interrupt the pre-established flow balance and jeopardize the

control of intake cell water level without the ability to reposition any of the

external sluice gates. Should silting or sanding occur that blocks the one slightly

open sluice gate, a lowering of cell water level could occur to a level below raw

water pump minimum submergence requirements, resulting in loss of the raw

water system - the ultimate heat sink. Similarly, should a water-born hazard

(floating tree or other large river debris) strike any of the sluice gates, or their

motor operators, or their connecting rods such that inflow or leakage is increased

to greater than the capacity of two raw water pumps, a raising of cell water level

could occur to a level that results in flooding of the raw water pump vaults

(1,007.5 feet mean sea level), resulting in a loss of the raw water system.

-9- Enclosure

Analysis. The inspectors determined that the licensees failure to meet design

basis requirements in the Updated Safety Analysis Report was a performance

deficiency. This finding was more than minor because it adversely impacted the

equipment performance and protection against external events attributes of the

Mitigating Systems Cornerstone objective of ensuring the availability, reliability

and capability of systems that respond to initiating events to prevent undesirable

consequences. The significance of this finding is bounded by the significance of

a related Yellow finding regarding the ability to mitigate an external flooding event

(Inspection Report 05000285/2010008). This finding has a cross-cutting aspect

in the area of problem identification and resolution, corrective action program, for

failure to thoroughly evaluate problems such that the resolutions address causes

and extent of conditions P.1(c).

Enforcement. 10 CFR 50, Design Control, Appendix B, Criterion III, states in

part that measures shall be established to assure that applicable regulatory

requirements and the design basis for those structures, systems, and

components are correctly translated into specifications, drawings, procedures,

and instructions. Contrary to the above, the licensee failed to establish

measures to assure that applicable regulatory requirements and the design basis

for those components were correctly translated into specifications, drawings,

procedures, and instructions. Specifically, the licensee failed to translate design

basis requirements for protection of the safety related raw water system during a

design basis flood for flood levels between 1,010-1,014 feet mean sea level as

identified in Updated Safety Analysis Report, Section 9.8, Raw Water System.

Specifically, the design basis states that water level inside the intake cells can be

controlled during a design basis flood by positioning the exterior sluice gates to

restrict the inflow into the cells and this operation was not assured under all

design basis conditions. This violation is not being treated as a new violation.

Instead, it is considered as a related violation to the Yellow finding issued in

October 2010, that, in general, dealt with issues related to mitigating a significant

external flooding event. A separate citiation will not be issued as this finding, and

its corrective actions, will be managed by the Manual Chapter 0350 Oversight

Panel. VIO 05000285/2012002-03, Failure to Meet Design Basis Requirements

for Design Basis Flood Event.

1R04 Equipment Alignment (71111.04)

.1 Semiannual Complete System Walkdown

a. Inspection Scope

The inspectors performed a complete system alignment inspection of the high-pressure

safety injection system to verify the functional capability of the system. This system was

selected because it was considered both safety significant and risk significant in the

licensees probabilistic risk assessment. The inspectors walked down the system to

review mechanical and electrical equipment line ups, electrical power availability, system

pressure and temperature indications, as appropriate, component labeling, component

- 10 - Enclosure

lubrication, component and equipment cooling, hangers and supports, operability of

support systems, and to ensure that ancillary equipment or debris did not interfere with

equipment operation. A review of a sample of past and outstanding work orders was

performed to determine whether any deficiencies significantly affected the system

function. In addition, the inspectors reviewed the corrective action program database to

ensure that system equipment alignment problems were being identified and

appropriately resolved. Documents reviewed are listed in the attachment.

In addition, additional activities were performed during the system walkdown that were

associated with Temporary Instruction 2515/177, Managing gas accumulation in

emergency core cooling, decay heat removal, and containment spray systems. These

activities are described in Section 1R04.2.

These activities constituted one complete system walkdown sample as defined in

Inspection Procedure 71111.04-05.

b. Findings

No findings of significance were identified.

.2 System Walkdown Associated With Temporary Instruction (TI) 2515/177, Managing Gas

Accumulation In Emergency Core Cooling, Decay Heat Removal, And Containment

Spray Systems.

a. Inspection Scope

The inspectors conducted a walkdown of the high-pressure safety injection system in

sufficient detail to reasonably assure the acceptability of the licensees walkdowns

(TI 2515/177, Section 04.02.d). The inspectors also verified that the information

obtained during the licensees walkdown was consistent with the items identified during

the inspectors independent walkdown (TI 2515/177, Section 04.02.c.3).

In addition, the inspectors verified that the licensee had isometric drawings that

described the high-pressure safety injection system configurations and had acceptably

confirmed the accuracy of the drawings (TI 2515/177, Section 04.02.a). The inspectors

verified the following related to the isometric drawings:

• High point vents were identified

• High points that do not have vents were acceptably recognizable

Other areas where gas can accumulate and potentially impact subject system

operability, such as at orifices in horizontal pipes, isolated branch lines, heat

exchangers, improperly sloped piping, and under closed valves, were acceptably

described in the drawings or in referenced documentation.

• Horizontal pipe centerline elevation deviations and pipe slopes in nominally

horizontal lines that exceed specified criteria were identified.

- 11 - Enclosure

• All pipes and fittings were clearly shown.

• The drawings were up-to-date with respect to recent hardware changes and that

any discrepancies between as-built configurations and the drawings were

documented and entered into the corrective action program for resolution.

The inspectors verified that Piping and Instrumentation Diagrams (P&IDs) accurately

described the subject systems, that they were up-to-date with respect to recent

hardware changes, and any discrepancies between as-built configurations, the isometric

drawings, and the P&IDs were documented and entered into the corrective action

program for resolution (TI 2515/177, Section 04.02.b).

Documents reviewed are listed in the attachment to this report.

This inspection effort counts towards the completion of Temporary Instruction 2515/177,

which was closed in Section 4OA5.2 of this report.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05)

.1 Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability,

accessibility, and the condition of firefighting equipment in the following risk-significant

plant areas:

• February 26, 2012, Fire Area 36B (West Switchgear Room), Room 56W

• February 26, 2012, Fire Area 36A (East Switchgear Room), Room 56E

• March 28, 2012, Fire Area 41 (Cable Spreading Room), Room 70

• March 28, 2012, Fire Areas 37 & 38 (Battery Rooms 1 and 2), Rooms 54 & 55

The inspectors reviewed areas to assess if licensee personnel had implemented a fire

protection program that adequately controlled combustibles and ignition sources within

the plant; effectively maintained fire detection and suppression capability; maintained

passive fire protection features in good material condition; and had implemented

adequate compensatory measures for out of service, degraded or inoperable fire

protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk

as documented in the plants Individual Plant Examination of External Events with later

additional insights, their potential to affect equipment that could initiate or mitigate a

plant transient, or their impact on the plants ability to respond to a security event. Using

the documents listed in the attachment, the inspectors verified that fire hoses and

extinguishers were in their designated locations and available for immediate use; that

- 12 - Enclosure

fire detectors and sprinklers were unobstructed; that transient material loading was

within the analyzed limits; and fire doors, dampers, and penetration seals appeared to

be in satisfactory condition. The inspectors also verified that minor issues identified

during the inspection were entered into the licensees corrective action program.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four quarterly fire-protection inspection samples

as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11)

The licensed operator requalification program involves two training cycles that are

conducted over a 2-year period. In the first cycle, the annual cycle, the operators are

administered an operating test consisting of job performance measures and simulator

scenarios. In the second part of the training cycle, the biennial cycle, operators are

administered an operating test and a comprehensive written examination. For this

annual inspection requirement, the licensee was in the first part of the training cycle.

.1 Annual Inspection

a. Inspection Scope

The inspectors reviewed the results of the examinations and operating tests in order to

satisfy the annual inspection requirements.

On January 4, 2011, the licensee informed the inspectors of the following results:

• 8 of 10 crews passed the simulator portion of the operating test

• 40 of 45 licensed operators passed the simulator portion of the operating test

• 45 of 45 licensed operators passed the job performance measure portion of the

examination

The individuals that failed the simulator scenario portions of the operating test were

remediated, retested, and passed their retake operating tests.

These activities constitute completion of one annual licensed operator requalification

program sample as defined in Inspection Procedure 71111.11.

- 13 - Enclosure

b. Findings

No findings of significance were identified.

.2 Quarterly Review of Licensed Operator Requalification Program

a. Inspection Scope

On March 26, 2012, the inspectors observed a crew of licensed operators in the plants

simulator during requalification training. The inspectors assessed the following areas:

• Licensed operator performance

• The ability of the licensee to administer the evaluations [and/or the quality of the

training provided]

• The quality of post-scenario critiques

These activities constitute completion of one quarterly licensed operator requalification

program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

1EP1 Exercise Evaluation (71114.01)

a. Inspection Scope

The licensee submitted the proposed scenario and evaluation objectives for the 2012

emergency plan exercise on January 27, 2012, as required by Appendix E to Part 50,

IV.F.2.b. This exercise was postponed from October 2011, as approved by the NRC in

an exemption, dated October 2, 2011 (ADAMS Accession Number ML112640400). The

inspectors performed an in-office review of the scenario and objectives to determine if

the proposed exercise acceptably tested major elements of the licenses emergency

plan, allowed for demonstration of key emergency preparedness skills, provided a

challenging drill environment, avoided the preconditioning of participant responses, and

supported the exercise evaluation objectives.

The inspectors observed the emergency plan exercise conducted March 27, 2012, to

determine if the exercise tested major elements of the licensees emergency plan,

allowed for demonstration of key emergency preparedness skills, and avoided

preconditioning participant responses. The scenario events were designed to escalate

through the emergency classifications from a Notification of Unusual Event to a General

Emergency to demonstrate licensee personnels capability to implement their emergency

plan. The scenario simulated the following:

- 14 - Enclosure

• a reactor coolant system leak inside containment;

• a loss of normal feed water to steam generators;

• a loss of auxiliary feed water to steam generators;

• a reactor protection system failure resulting in an anticipated transient without

reactor scram;

• reactor vessel water level lowering to below the top of active fuel;

• a hydrogen explosion inside containment; and

• failure of a containment penetration, resulting in a radiological release.

The inspectors observed licensee performance in the Control Room Simulator, Technical

Support Center, Operations Support Center, and Emergency Operations Facility. The

inspectors evaluated exercise performance by focusing on the risk-significant activities

of event classification, offsite notification, assessment of radiological consequences, and

the development of protective action recommendations.

The inspectors also assessed recognition of, and response to, abnormal and emergency

plant conditions, the transfer of decision-making authority and emergency function

responsibilities between facilities, onsite and offsite communications, protection of

emergency workers, the prioritization and conduct of emergency repairs, and the overall

implementation of the emergency plan to protect public health and safety and the

environment. The inspectors reviewed the current revision of the facility emergency

plan, emergency plan implementing procedures associated with operation of the

licensees emergency response facilities, and procedures for the performance of

associated emergency functions.

The inspectors compared the observed exercise performance with the requirements in

the facility emergency plan, 10 CFR 50.47(b), 10 CFR Part 50, Appendix E, with the

guidance in the emergency plan implementing procedures, and other federal guidance.

The inspectors attended the post-exercise critiques in each emergency response facility

to evaluate the initial licensee self-assessment of exercise performance. The inspectors

also attended a subsequent formal presentation of critique items to plant management.

The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.01-05.

b. Findings

No findings of significance were identified.

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)

a. Inspection Scope

- 15 - Enclosure

The NSIR headquarters staff performed an in-office review of the latest revisions of

various Emergency Plan Implementing Procedures located under ADAMS accession

numbers ML12009A076 and ML12023A008, as listed in the attachment.

The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in

these revisions resulted in no reduction in the effectiveness of the Plan, and that the

revised procedures continued to meet the requirements of 10 CFR 50.47(b) and

Appendix E to 10 CFR Part 50. This review was not documented in a safety evaluation

report and did not constitute approval of licensee-generated changes; therefore, this

revision is subject to future inspection. The specific documents reviewed during this

inspection are listed in the attachment.

b. Findings

No findings of significance were identified

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies (71114.05)

a. Inspection Scope

The inspector reviewed the licensee=s response to failures in the emergency alert and

notification siren system that occurred February 23, 2012, and March 6, 2012, as

documented in NRC Event Notifications 47696 and 47721. The inspector reviewed

event timelines, control room logs, and licensee Condition Reports 2012-01435,

2012-01489, 2012-01490, 2012-01501, and 2012-01742. The inspector also reviewed

the Fort Calhoun Station Radiological Emergency Response Plan, Section E,

Notification Methods and Procedures, Revision 26, and Appendix A, Letters of

Agreement, Revision 21.

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.05-05.

b. Findings

Introduction. A Green non-cited violation was identified for the licensees failure to

follow the site emergency plan on February 23, 2012, as required by 10 CFR

50.54(q)(2).

Description. The NRC identified that between 6:09 p.m. on February 23 and 3:04 a.m.

on February 24, 2012, the licensee failed to follow an emergency plan requirement that

offsite warning signals be activated by radio signal. Consequently, notification to some

members of the public of an emergency would have been delayed because offsite

authorities would have had to respond to unanticipated failures of emergency sirens.

Specifically, twenty-one outdoor warning sirens in Pottawattamie and Harrison Counties,

Iowa, could not be activated by radio signals, and alternative means for notification were

not established because the siren system status was not communicated to offsite

authorities.

- 16 - Enclosure

The outdoor emergency warning system in the Fort Calhoun Station emergency

planning zone consists of 72 sirens in four counties. A failure occurred in the primary

radio system used to activate offsite sirens at 6:09 p.m., February 23, 2012, causing a

reboot of the siren system server. Twenty-one sirens in Pottawattamie and Harrison

Counties, Iowa, failed to reestablish communications with the server following the

reboot. A series of automatic pages to Communications Department technicians

reported the loss and restoration of siren communication, one pager signal per siren per

change in status. Siren technicians did not immediately investigate the siren system

status because they were troubleshooting with high priority unrelated failures in

communications data servers leased by offsite authorities and the messages displayed

on pagers did not indicate siren system problems. It was not readily apparent that

communications to all sirens in the system was not restored because of data display

limitations in the pagers.

Communications Department technicians acknowledged siren system alarms at

11:17 p.m. on February 23 and became aware of communications problems to some

sirens. The technicians began to troubleshoot the siren system, but did not

communicate the failure to the Communications Department or the Fort Calhoun Station

Control Room until approximately 2:00 a.m. on February 24. A list of affected sirens was

provided the Control Room at 2:24 a.m.

The Control Room informed Sheriff Department dispatchers in Pottawattamie and

Harrison Counties, Iowa, of the siren system communications failure at 3:04 a.m. on

February 24. The licensee requested that alternative means (route alerting) be

employed should notification to the public of an emergency be required.

The inspector identified Section E, Part 4.0, Alert Notification System, of the licensee

emergency plan requires that offsite emergency warning sirens are activated by radio

signal. The inspector also identified that Letters of Agreement with Pottawattamie and

Harrison Counties, Iowa, included the provision of early notification to the public of a

radiological emergency. The inspector verified the provision of notification to the public

included alternate means of notification when necessary.

The inspector concluded the licensee could not have known of the inability to activate

offsite sirens until after 6:09 p.m., February 23, 2012. The inspector also concluded that

between 6:09 p.m. on February 23 and 3:04 a.m. on February 24, 2012, the licensee

failed to follow Section E, Part 4.0, Alert Notification System, of the licensee

emergency plan and failed to inform offsite authorities. The lack of communication to

offsite authorities affected the ability of Pottawattamie and Harrison Counties, Iowa, to

carry out their responsibilities under their Letters of Agreement.

Analysis. The inspector determined the licensees failure to promptly respond to

indications of siren system failure and the subsequent failure to promptly inform offsite

authorities of a siren control system failure are performance deficiencies within the

licensees control. This finding is more than minor because it had the potential to affect

safety and affected the facilities and equipment cornerstone attribute (availability of the

alert and notification system). The finding impacted the emergency preparedness

- 17 - Enclosure

cornerstone objective because the ability to implement adequate measures to protect

the public health and safety is affected when the means to notify some members of the

public of an emergency are degraded. The finding was associated with a violation of

NRC requirements. This finding was evaluated using Attachment 2, Failure to Comply

Significance Logic, to Manual Chapter 0609, Appendix B, Emergency Preparedness

Significance Determination Process. The finding was determined to be of very low

safety significance (Green) because the risk-significant planning standard function was

not lost or degraded. The planning standard function was not degraded because some

sirens remained functional in the 0-5 and 5-10 mile areas of the emergency planning

zone and offsite officials could have promptly recognized the failed sirens and

implemented alternative means of notification. The need to recognize and respond to

multiple unanticipated siren failures would have delayed the implementation of alternate

means to notify the public. This failure has been entered into the licensees corrective

action system as Condition Reports 2012-01435 and 2012-01489. This finding was

assigned a Cross-Cutting Aspect of Work Coordination because the Communications

Department and Control Room did not communicate and coordinate as necessary to

ensure plant and human performance, and to maintain interfaces with offsite

organizations H3.b].

Enforcement. Title 10 CFR, 50.54(q)(2), states, in part, that a holder of a license under

this part shall follow and maintain the effectiveness of an emergency plan that meets the

requirements of Appendix E to Part 50, and the planning standards of 50.47(b). Fort

Calhoun Station Radiological Emergency Response Plan Section E, Notification

Methods and Procedures, Revision 26, Section 4.0, requires in part that outdoor

emergency warning sirens are activated by radio signal. Contrary to the above, on

February 23, 2012, outdoor emergency warning sirens could not be activated by radio

signal. Specifically between 6:09 p.m. on February 23 and 3:04 a.m. on February 24,

2012, twenty-one outdoor warning sirens could not be activated by radio signals and

alternate means to notify the public were not established. Because this failure is of very

low safety significance and has been entered into the licensees corrective action system

(Condition Reports 2012-01435 and 2012-01489), this violation is being treated as an

NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 50-

285/2012002-04, [Failure to Promptly Recognize and Communicate Siren System

Failures].

1EP6 Drill Evaluation (71114.06)

.1 Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on

March 27, 2012, which required emergency plan implementation by a licensee

operations crew. This evolution was planned to be evaluated and included in

performance indicator data regarding drill and exercise performance. The inspectors

observed event classification and notification activities performed by the crew. The

inspectors also attended the post-evolution critique for the scenario. The focus of the

inspectors activities was to note any weaknesses and deficiencies in the crews

- 18 - Enclosure

performance and ensure that the licensee evaluators noted the same issues and entered

them into the corrective action program. As part of the inspection, the inspectors

reviewed the scenario package and other documents listed in the attachment.

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.06-05.

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Physical Protection

4OA1 Performance Indicator Verification (71151)

.1 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill and Exercise Performance,

performance indicator for the period from April 2010 through September 2011. To

determine the accuracy of the performance indicator data reported during those periods,

performance indicator definitions and guidance contained in Nuclear Energy Institute

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6,

was used. The inspectors reviewed the licensees records associated with the

performance indicator to verify that the licensee accurately reported the indicator in

accordance with relevant procedures and the Nuclear Energy Institute guidance.

Specifically, the inspectors reviewed licensee records and processes including

procedural guidance on assessing opportunities for the performance indicator;

assessments of performance indicator opportunities during predesignated control room

simulator training sessions, and performance during other drills. The specific documents

reviewed are described in the attachment to this report.

These activities constitute completion of the drill/exercise performance sample as

defined in Inspection Procedure 71151-05.

b. Findings

(1) Failure to follow the licensee emergency plan during the June 7, 2011, Alert

declaration

Introduction. A Green non-cited violation was identified for the licensees failure

to follow the Fort Calhoun Radiological Emergency Response Plan during an

emergency on June 7, 2011, as required by 10 CFR 50.54(q). Specifically, the

- 19 - Enclosure

licensee failed to notify offsite authorities within 15 minutes of an emergency

declaration as required by Fort Calhoun Radiological Emergency Response Plan,

Section E, part 2.4.

Description. The Fort Calhoun Radiological Emergency Response Plan,

Section E, part 2.4, requires notification to the states of Nebraska and Iowa

within 15 minutes of an emergency declaration. Inspectors determined the

notification to responsible state and local governmental agencies following the

June 7, 2011, alert emergency classification was completed 18 minutes 41

seconds after declaring the emergency.

The licensee declared an alert emergency classification at 9:40 a.m.,

June 7, 2011. The offsite contact time recorded for this event on Form FC-1188,

Fort Calhoun Station - Emergency Notification Form, Revision 25, dated

June 7, 2011, was 9:56 a.m., 16 minutes following event classification. On

October 20, 2011, the licensee reviewed a recording of the June 7, 2011, event

notification call, and determined notification was completed at 9:58:41 a.m.;

notification consisted of the emergency classification, the applicable emergency

action level, and that no protective actions were required for the public. On

February 3, 2012, the licensee reviewed the notification call recording and

determined the call was initiated from the Fort Calhoun Station Control Room at

approximately 9:55 a.m., 15 minutes after event classification.

The inspectors concluded that an actual notification time of 18 minutes,

41 seconds after event declaration did not comply with the Fort Calhoun

Radiological Emergency Response Plan requirement to notify offsite authorities

within 15 minutes of an emergency declaration.

Analysis. The inspectors determined the failure to comply with requirements of

the Fort Calhoun Radiological Emergency Response Plan is a performance

deficiency within the licensees control. This finding is more than minor because

it affects safety and impacts the cornerstone attributes of emergency response

organization performance and actual event response. The finding had a credible

impact on the Emergency Preparedness Cornerstone objective because untimely

notification to offsite authorities degrades their ability to implement adequate

measures to protect the health and safety of the public. The finding was

associated with a violation of NRC requirements. This finding was evaluated

using Attachment 1, Actual Event Significance Logic, to Manual Chapter 0609,

Appendix B, Emergency Preparedness Significance Determination Process.

The finding was determined to be of very low safety significance (Green)

because it was a failure to implement the emergency plan during an event, the

event was a declared alert, and the licensees failure did not affect the ability of

offsite authorities to implement appropriate protective measures for the public.

This failure has been entered into the licensees corrective action system as

Condition Report 2011-8529. This finding has been assigned a cross-cutting

aspect of work practices (management oversight) because licensee management

did not set performance expectations for event notifications and monitor

- 20 - Enclosure

performance to ensure compliance with emergency plan requirements.

Specifically, licensee management did not ensure that notification completion

times were evaluated and trended, and did not monitor the notification function to

ensure processes, training, and equipment supported the emergency plan

requirement that offsite notification be performed in a timely manner. H4.c].

Enforcement. Title 10 CFR 50.54(q)(2) states, in part, that a holder of a license

under this part shall follow and maintain the effectiveness of an emergency plan

that meets the planning standards of 50.47(b). The Fort Calhoun Radiological

Emergency Response Plan, Section E, part 2.4, requires notification to the states

of Nebraska and Iowa within 15 minutes of an emergency declaration. Contrary

to the above, on June 7, 2011, the licensee failed to notify the states of Nebraska

and Iowa within 15 minutes of an emergency declaration. Specifically, Fort

Calhoun Station notified the states of Nebraska and Iowa 18 minutes 41 seconds

after declaring the emergency. Because this failure is of very low safety

significance and has been entered into the licensees corrective action system

(Condition Report 2011-8529), this violation is being treated as an NCV,

consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000285/2012002-05, Failure to comply with an emergency plan requirement

to notify offsite authorities within 15 minutes of an emergency.

4OA2 Problem Identification and Resolution (71152)

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of

this report, the inspectors routinely reviewed issues during baseline inspection activities

and plant status reviews to verify that they were being entered into the licensees

corrective action program at an appropriate threshold, that adequate attention was being

given to timely corrective actions, and that adverse trends were identified and

addressed. The inspectors reviewed attributes that included the complete and accurate

identification of the problem; the timely correction, commensurate with the safety

significance; the evaluation and disposition of performance issues, generic implications,

common causes, contributing factors, root causes, extent of condition reviews, and

previous occurrences reviews; and the classification, prioritization, focus, and timeliness

of corrective actions. Minor issues entered into the licensees corrective action program

because of the inspectors observations are included in the attached list of documents

reviewed.

These routine reviews for the identification and resolution of problems did not constitute

any additional inspection samples. Instead, by procedure, they were considered an

integral part of the inspections performed during the quarter and documented in

Section 1 of this report.

b. Findings

- 21 - Enclosure

No findings of significance were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific

human performance issues for follow-up, the inspectors performed a daily screening of

items entered into the licensees corrective action program. The inspectors

accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status

monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings of significance were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion (71153)

.1 (Closed) Licensee Event Report 05000285/2010-001-01: Containment Integrity Violated

During Refueling Leak Test Due to Inadequate Training

Containment integrity was violated on November 1, 2009. This was a result of opening

manual containment isolation valve SI-410 (Safety injection Tanks Fill/Drain Valve) when

containment integrity was required and inadequate administrative controls were

implemented. In preparation for performing a leak check of the safety injection tanks

leakoff piping, a procedural step in the surveillance test opened manual containment

isolation valve. SI-410, as well as re-aligning other valves. The procedure prerequisites

require the reactor coolant system to be pressurized above 600 psig, which results in the

reactor coolant system being greater than 210 degrees Fahrenheit; thus, containment

integrity is required.

Prior to the performance of the surveillance test on November 1, 2009, it was recognized

that the opening of valve SI-410 needed to be administratively controlled. The

surveillance test procedure was revised to require administrative controls be in place

prior to opening containment isolation valve SI-410.

A root cause analysis determined that training on containment integrity to specifically

meet the intent of Technical Specifciation 2.6(1)a, as defined in the Technical

Specification basis section, is insufficient to ensure complete understanding of the

requirements.

This licensee event report was reviewed by inspectors. A licensee identified violation is

documented in Section 4OA7 of this report. This licensee event report is closed.

.2 (Closed) Licensee Event Report 05000285/2010-006-01: Reactor Trip Due to Erroneous

Moisture Separator Trip Signal

- 22 - Enclosure

Fort Calhoun Station was operating at full power (nominal 100 percent). The station was

preparing a scaffolding for an upcoming outage when on December 23, 2010, at 1050

Central Standard Time, a reactor trip occurred. The operators entered Emergency

Operating Procedure 00, Standard Post Trip Actions. The main steam and feedwater

systems operated normally. All control rods inserted fully.

The apparent cause of the turbine and subsequent reactor trip was the inadvertent

actuation, caused by bumping, and sticking of one of four turbine moisture separator

high water level turbine trip switches while reactor power was above 15 percent. The

root cause was insufficient performance monitoring of the moisture separator high level

trip mercury switches which resulted in degraded performance and increased risk for

susceptibility to binding.

Following the initial determination of the erroneous moisture separator high level trip

signal, immediate actions included: halting all work near the moisture separator sensing

lines and level switches, posting the affected areas as Protected Equipment, and

initiating a stop work action for all ongoing scaffold work within the turbine building. The

moisture separator level switches and logic will be replaced during the 2011 refueling

outage.

This licensee event report was reviewed by inspectors. It appears that the direct cause

for an erroneous actuation of the moisture separator trip signal is due to on-going work

near the vicinity of the moisture separator level switches. Personnel involved in scaffold

construction work had been observed working near moisture separator level sensing

lines prior to and immediately after the turbine trip. A green non-cited violation related to

scaffold procedures was documented in Inspection Report 05000285/2011003. This

licensee event report is closed.

.3 (Closed) Licensee Event Report 05000285/2011-001-00: Inadequate Flooding Protection

Due To Ineffective Oversight

During identification and evaluation of flood barriers, unsealed through wall conduit

penetrations in the outside wall of the intake structure were identified that are below the

licensing basis flood elevation.

A summary of the root causes included: a weak procedure revision process; insufficient

oversight of work activities associated with external flood matters; ineffective

identification, evaluation and resolution of performance deficiencies related to external

flooding; and "safe as is" mindsets relative to external flooding events.

The penetrations were temporarily sealed and a configuration change was developed

and implemented whereby permanent seals were installed. Comprehensive corrective

actions to address the root and contributing causes are being addressed through the

corrective action program.

- 23 - Enclosure

This licensee event report was reviewed by inspectors. The licensee cancelled this

licensee event report, determining that the issues on flooding should be reported in a

single licensee event report. The issues were incorporated into Licensee Event

Report 2011-003-03. This licensee event report is closed.

.4 (Closed) Licensee Event Report 05000285/2011-005-00: Failure to Correctly Enter

Technical Specifications Limiting Condition for Operation for the Reactor Protective

System

On June 14, 2010, the reactor protective system M2 contactor (similar to the reactor

protective system breakers) failed to open during periodic surveillance testing.

Operations declared the reactor protective system M2 contactor inoperable and entered

Technical Specification Limiting Condition for Operation Action 2.15(1) because the

reactor protective system M2 contactor did not have a specifically defined limiting

condition for operation. Subsequent reviews determined that the station continued to

operate in a condition not allowed by technical specifications on June 14 and 15, 2010,

for a period of approximately 20.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Technical Specification 2.0.1, which specifies

measures to be employed for conditions not covered by Limiting Conditions for

Operation, should have been invoked.

The root cause for this error was determined to be the failure to implement an interim

technical specification strategy when funding for standard improved technical

specifications was deferred.

The operations staff has been directed to enter Technical Specification 2.0.1 for any

failures of these contactors. The licensee planned to conduct a formal review of other

components which do not have specific technical specification limiting condition for

operation action statements and station actions that could be non-conservative with

regard to entering Technical Specification 2.0.1. The review will identify those items that

need administrative controls and place them in the appropriate station procedures.

This licensee event report was reviewed by inspectors. A White violation related to to

failures involving the reactor protective system M2 contactor was documented in

Inspection Report 05000285/2011007. This licensee event report is closed.

.5 (Closed) Licensee Event Report 05000285/2011-006-00: Inoperability of Both Trains of

Containment Coolers Due to a Mispositioned Valve

On March 22, 2011, during the performance of a test on containment cooler valves, a

technician discovered that NGHCV-400A-A3, CCW Inlet Valve HCV-400A Nitrogen

Supply Isolation Valve, was in the closed position. This is not the correct position. He

informed the control room of the condition. At the time of discovery, containment cooler

VA-3B was inoperable to support the performance of a surveillance test. Operations

declared VA-3A inoperable as the backup nitrogen supply to HCV-400A for containment

cooler VA-3A cooling coil was unavailable. Operations entered Technical

Specification 2.0.1 since both VA-3A and VA-3B were simultaneously inoperable. An

equipment operator was dispatched to open NG-HCV-400A-A3. After NG-HCV-400A-A3

- 24 - Enclosure

was opened, VA-3A was declared operable. Technical Specification 2.0.1 was then

exited.

The root cause analysis determined the cause of this event was the stations leadership

oversight effort has not been effective in the areas of use of the stations corrective

action program, human performance tools and safe work practices in reducing the

potential for mispositioning events.

The immediate corrective action of opening the affected valve restored VA-3A to an

operable condition. Additional corrective actions to address the root and generic

implications of this event will be addressed by the stations corrective action process.

This licensee event report was reviewed by inspectors. The licensee cancelled this

licensee event report, determining that the valve would open during design basis

conditions allowing the containment cooler to perform its intended safety function. This

licensee event report is closed.

.6 (Closed) Licensee Event Report 05000285/2011-009-00: Manual Start of a Safety

System

On June 26, 2011, at approximately 1:25 a.m. Central Daylight Time, the AquaDam,

water-filled dam which was providing enhanced flood protection for Fort Calhoun Station,

failed after being struck by a skid loader. As a precautionary measure, plant operators

used the abnormal operating procedures to align necessary plant equipment to alternate

(emergency) power supplies. Emergency Diesel Generator 2 was manually started to

remove bus 1A4 from offsite power. Emergency Diesel Generator 1 was manually

started to remove bus 1A3 from offsite power as well. Both emergency diesel generators

loaded on their respective busses as designed. Offsite power remained available

throughout the event. No safety-related equipment was impacted by the water intrusion.

Plant equipment was realigned to the off-site power operating configuration and the

emergency diesel generators were secured.

This licensee event report was reviewed by inspectors. The inspectors determined that

there was no violation of regulatory requirements, as the licensee was taking action

associated with a sequence of events. This licensee event report is closed.

4OA5 Other Activities

.1 Confirmatory Action Letter Activities

On August 30, 2011, Fort Calhoun Station issued Revision 1 to the Fort Calhoun Station

Post-Flooding Recovery Action Plan, that provided for extensive reviews of plant

systems, structures, and components to assess the impact of the flood waters. On

September 2, 2011, the NRC issued Confirmatory Action Letter 4-11-003, listing 235

items described in the Fort Calhoun Station Post-Flooding Recovery Action Plan that

the licensee committed to complete. The areas to be inspected were identified in that

- 25 - Enclosure

confirmatory action letter and many of these items were reviewed during this report

period.

With the emergence of more performance issues since issuance of Confirmatory Action

Letter 4-11-003, a new confirmatory action letter which subsumes Confirmatory Action

Letter 4-11-003 was under development during this report period by the Manual Chapter

0350 Oversight team. The new confirmatory action letter will be designed to cover all

items in Confirmatory Action Letter 4-11-003, along with the more recently discovered

performance issues.

.2 (Closed) NRC Temporary Instruction 2515/177, Managing Gas Accumulation in

Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems

(NRC Generic Letter 2008-01)

a. Inspection Scope

The inspectors evaluated whether the licensee maintained documents, installed system

hardware, and implemented actions that were consistent with the information provided in

their response to NRC Generic Letter 2008-01, Managing Gas Accumulation in

Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems.

Specifically, the inspectors verified that the licensee had implemented, or was in the

process of implementing, the commitments, modifications, and programmatically

controlled actions described in their response to Generic Letter 2008-01. The inspectors

conducted their review in accordance with Temporary Instruction 2515/177 and

considered the site-specific supplemental information provided by the Office of Nuclear

Reactor Regulation to the inspectors.

b. Inspection Documentation

The inspectors reviewed the licensing basis, design, testing, and corrective actions as

specified in the temporary instruction. The specific items reviewed and any resulting

observations are documented below.

Licensing Basis. The inspectors reviewed selected portions of licensing basis

documents to verify that they were consistent with the Office of Nuclear Reactor

Regulation assessment report, and that the licensee properly processed any required

changes. The inspectors reviewed selected portions of technical specifications,

technical specification bases, and the Updated Safety Analysis Report. The inspectors

also verified that applicable documents that described the plant and plant operation,

such as calculations, piping and instrumentation diagrams, procedures, and corrective

action program documents addressed the areas of concern and were changed, if

needed, following plant changes. The inspectors confirmed that the licensee performed

surveillance tests at the frequency required by the technical specifications. The

inspectors verified that the licensee tracked their commitment to evaluate and implement

any changes that would be contained in the technical specification task force traveler.

- 26 - Enclosure

Design. The inspectors reviewed selected design documents, performed system

walkdowns, and interviewed plant personnel to verify that the licensee addressed design

and operating characteristics. Specifically:

• The inspectors verified that the licensee had identified the applicable gas

intrusion mechanisms for their plant.

• The inspectors verified that the licensee had established void acceptance criteria

consistent with the void acceptance criteria identified by the Office of Nuclear

Reactor Regulation. The inspectors also confirmed that the range of flow

conditions evaluated by the licensee was consistent with the full range of design

basis and expected flow rates for various break sizes and locations.

• The inspectors selectively reviewed applicable documents, including calculations,

and engineering evaluations with respect to gas accumulation in the emergency

core cooling systems and decay heat removal systems. Specifically, the

inspectors verified that these documents addressed venting requirements,

aspects where pipes were normally voided, void control during maintenance

activities, and the potential for vortex effects that could ingest gas into the

systems during design basis events.

• The inspectors verified that piping and instrumentation diagrams and isometric

drawings describe up-to-date configurations of the emergency core cooling

systems and decay heat removal systems. The review of the selected portions of

isometric drawings considered the following:

(1) High point vents were identified

(2) High points without vents were recognizable

(3) Other areas where gas could accumulate and potentially impact

operability, such as orifices in horizontal pipes, isolated branch lines, heat

exchangers, improperly sloped piping, and under closed valves, were

described in the drawings or in referenced documentation

(4) Horizontal pipe centerline elevation deviations and pipe slopes in

nominally horizontal lines that exceeded specified criteria were identified

(5) All pipes and fittings were clearly shown.

(6) The drawings were up-to-date with respect to recent hardware changes,

and that any discrepancies between as-built configurations and the

drawings were documented and entered into the corrective action

program for resolution

• The inspectors verified that the licensee had completed their walkdowns and

selectively verified that the licensee identified discrepant conditions in their

- 27 - Enclosure

corrective action program and appropriately modified affected procedures and

training documents.

Testing. The inspectors reviewed selected surveillances, post-modification tests, and

post-maintenance test procedures and results, conducted during power and shutdown

operations, to verify that the licensee was using procedures that appropriately addressed

gas accumulation and/or intrusion into the subject systems. This review included the

verification of procedures used for conducting surveillances and for the determination of

void volumes to ensure that void criteria were satisfied and would continue to be

satisfied until the next scheduled void surveillances. In addition, the inspectors reviewed

procedures used for filling and venting following conditions that could introduce voids

into the subject systems to verify that the procedures adequately tested for such voids

and provided adequate instructions for their reduction or elimination.

Corrective Actions. The inspectors reviewed selected corrective action program

documents to assess how effectively the licensee addressed the issues associated with

Generic Letter 2008-01 in their corrective action program. In addition, the inspectors

verified that the licensee implemented appropriate corrective actions for issues identified

in the nine-month and supplemental responses. The inspectors determined that the

licensee had effectively implemented the actions required by Generic Letter 2008-01.

Based on this review, the inspectors concluded that there is reasonable assurance that

the licensee will complete all outstanding items and incorporate this information into the

design basis and operational practices. This temporary instruction is closed for

Fort Calhoun Station.

c. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On January 4, 2012, the inspectors obtained the final annual examination results and

telephonically exited regarding the annual licensed operator requalification inspection

with Mr. T. Giebelhausen, Operations Training Manager. The inspectors did not review

any proprietary information during this inspection.

On February 16, 2012, the inspectors presented the inspection results regarding

Temporary Instruction 177 to Mr. M. Prospero, Plant Manager, and other members of the

licensee staff. The licensee acknowledged the issues presented. The inspectors

confirmed that none of the potential report input discussed was considered proprietary.

On February 23, 2012, the inspectors conducted a telephonic exit meeting with

Mr. D. Bannister, Vice President and Chief Nuclear Officer, and other members of the

licensees staff. The inspectors presented the results of the October 2011, onsite

inspection of emergency preparedness performance indicators. The licensee

- 28 - Enclosure

acknowledged the issues presented. The inspectors asked the licensee whether any

materials examined during the inspection should be considered proprietary. No

proprietary information was identified.

On March 22, 2012, the inspection team conducted a telephonic exit meeting with

Mr. D. Bannister, Site Vice President and Chief Nuclear Officer, and other members of

the licensees staff to discuss the results of the readiness to cope with external flooding

inspection. The licensee acknowledged the findings presented. While limited

proprietary information was reviewed during the inspection, no proprietary information

was included in this report.

On March 30, 2012, the inspectors presented the results of the onsite inspection of the

March 27, 2012, emergency preparedness exercise, onsite review of the February 23-24

and March 6, 2012, losses of siren system functionality, and the in-office and onsite

inspections of Flood Recovery Plan items to Mr. D. Bannister, Vice President and Chief

Nuclear Officer, and other members of the licensees staff. The licensee acknowledged

the issues presented. The inspectors asked the licensee whether any materials

examined during the inspection should be considered proprietary. No proprietary

information was identified.

On April 11, 2012, the inspectors presented the quarterly inspection results to

Mr. D. Banniser, Site Vice Presient and Chief Nuclear Officer, and other members of the

licensee staff. The licensee acknowledged the issues presented. The inspectors asked

the licensee whether any materials examined during the inspection should be

considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the

licensee and is a violation of NRC requirements which meets the criteria of the NRC

Enforcement Policy for being dispositioned as a non-cited violation.

Fort Calhoun Station Technical Specification 5.8.1, requires, in part, that the licensee

establish and implement written procedures recommended in Regulatory Guide 1.33,

Revision 2, Appendix A, dated February 1978, including procedures for equipment

control (e.g., locking and tagging). Contrary to this, containment integrigity was violated

on November 1, 2009, when an inadequate procedural step in a surveillance test

procedure required by Regulatory Guide 1.33 allowed opening of a locked closed

containment isolation valve, thus violating containment integrity. The finding was

determined to be of very low safety significance (Green) as it did not result in an actual

release of radioactive material. Because this violation was of very low safety

significance and it was entered into the licensees corrective action program as

Condition Report 2010-1664, this violation is being treated as a non-cited violation

consistent with Section 2.3.2.a of the NRC Enforcement Policy.

- 29 - Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Acker, Licensing Engineer

S. Baughn, Manager, Nuclear Licensing

A. Berck, Supervisor, Emergency Planning

B. Blome, Manager, Quality Assurance

N. Bretey, Reliability Engineer,

C. Cameron, Supervisor Regulatory Compliance

E. Dean, System Engineer

T. Dendinger, Mechanical Engineer, Design Engineering Nuclear

K. Erdman, Supervisor, Programs

M. Fern, Manager, SPII

M. Frans, Manager, Engineering Programs

S. Gebers, Manager, Emergency Planning and Health Physics

W. Goodell, Division Manager, NPIS

W. Hansher, Supervisor, Nuclear Licensing

R. Haug, Manager, Training

J. Herman, Division Manager, Nuclear Engineering

K. Kingston, Manager, Chemistry

T. Maine, Manager, Radiation Protection

E. Matzke, Senior Licensing Engineer

S. Miller, Manager, Design Engineering

D. Molzer, AOV Program Engineer

K. Naser, Manager, System Engineering

A. Pallas, Manager, Shift Operations

M. Prospero, Division Manager, Plant Operations

M. Smith, Manager, Operations

T. Uehling, Manager, Maintenance

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

Inadequate Procedures to Mitigate a Design Basis Flood

05000285/2012002-01 VIO

Event (Section 1R01)

Failure to Classify Intake Structure Sluice Gates as Safety

05000285/2012002-02 VIO

Class III (Section 1R01)

Failure to Meet Design Basis Requirements for Design Basis05000285/2012002-03 VIO

Flood Event (Section 1R01)

Opened and Closed

Failure to Promptly Recognize and Communicate Siren

05000285/2012002-04 NCV

System Failures (Section 1EP5)

A-1 Attachment

Failure To Comply With An Emergency Plan Requirement To

05000285/2012002-05 NCV Notify Offsite Authorities Within 15 Minutes Of An Emergency

(Section 4OA1)

Closed

2515/177 TI Managing Gas Accumulation in Emergency Core Cooling,

Decay Heat Removal, and Containment Spray Systems

(NRC Generic Letter 2008-01) (Section 4OA5.2)

Containment Integrity Violated During Refueling Leak Test

05000285/2010-001-01 LER

Due to Inadequate Training (Section 4OA3.1)

Reactor Trip Due to Erroneous Moisture Separator Trip

05000285/2010-006-01 LER

Signal(Section 4OA3.2)

Report: Inadequate Flooding Protection Due To Ineffective

05000285/2011-001-00 LER

Oversight (Section 4OA3.3)

Failure to Correctly Enter Technical Specifications Limiting

05000285/2011-005-00 LER Condition for Operation for the Reactor Protective System

(Section 4OA3.4)

Inoperability of Both Trains of Containment Coolers Due to a

05000285/2011-006-00 LER

Mispositioned Valve (Section 4OA3.5)

05000285/2011-009-00 LER Manual Start of a Safety System (Section 4OA3.6)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Conditions

PROCEDURES

NUMBER TITLE REVISION

AOP-01 Acts of Nature,Section I - Flood 28 and 29

ARP-AI-187/A187 Annunciator Response Procedure A187 Local Annunciator 10

A187, Switchgear Ventilation

EPIP-TSC-2 Catastrophic Flooding Preparations 14

FCSG-20 Abnormal Operating Procedure and Emergency Operating 9

Procedure Writers Guide

FCSG-64 External Flooding of Site 1

M8145WD Flood Control Walk-down Exercise 1

OI-CW-1 Circulating Water System Normal Operation 65 and 66

A-2

PROCEDURES

NUMBER TITLE REVISION

OI-FO-1 Fuel Receipt (FO-1, FO-10, FO-27, FO-32, FO-43A, and 31

FO-43B)

OI-PGP-1 Operation of Portable Gas Powered Pumps 0

OPD-4-09 EOP/AOP Users Guidelines 15

PE-RR-AE-1000 Flood Barrier Inspection and Repair 9

PE-RR-AE-1001 Flood Barrier and Sandbag Staging and Installation 12, 13 14,15

PE-RR-AE-1002 Installation of Portable Steam Generator Makeup Pumps 4

QAM-5 NSRG Charter 5

SAP-29 Severe Weather and Flooding 13

SARC-0 Safety Audit and Review Committee (SARC) Charter 42

SARC-2 Safety Audit and Review Committee (SARC) Reviews 34

SARC-3 Safety Audit and Review Committee (SARC) Auditing 25

SHB: M8145 Flood Control (Mechanical Maintenance) Student Handbook 11

SO-G-124 Flood Barrier Impairment 1

SO-G-5 Fort Calhoun Station Plant Review Committee 160

TBD-AOP-01 Acts of Nature, Section 1 - Flood 28 and 29

CALCULATIONS

NUMBER TITLE DATE

61563 Burns & McDonnell, Flood Barrier Qualification August 10, 2011

CN-OA-11-7 Intake Cell Level Control Using the Intake Sluice Gate April 21, 2011

During Flooding Conditions at the Ft. Calhoun Plant

CN-SEE-II-11-2 Intake Cell Level Control - Flood Alternate Flow Path April 5, 2011

Evaluation for Fort Calhoun Station

FC08030 Intake Structure Cell Level Control Using the Intake April 25, 2011

Structure Sluice Gates

FC08070 Validation of Backup Fuel Oil Transfer During Flooding

Conditions

CONDITION REPORTS

2011-6062 2011-5489 2011-10512 2011-10302 2011-10300

A-3

CONDITION REPORTS

2012-00307 2012-00600 2012-00871 2012-00875 2012-00882

2012-00882 2012-00899 2012-00901 2012-00906 2012-00929

2012-00945 2012-00949 2012-00965 2012-00967 2012-00980

2012-00986 2012-00996 2012-00998 2012-01000 2012-01003

2012-01010 2012-01012 2012-01021 2012-01330 2012-02142

MISCELLANEOUS DOCUMENTS

TITLE REVISION

Technical Specification 2.16, River Level

Updated Safety Assessment Report - 2.7, Hydrology 11

Updated Safety Assessment Report - 9.8, Raw Water System 29

Section 1R04: Equipment Alignment

Documents reviewed for Section 1R04 are included in section 4OA5

Section 1RO5: Fire Protection

PROCEDURES

NUMBER TITLE REVISION

SO-G-28 Standing Order, Station Fire Plan 82

SO-G-58 Standing Order, Control of Fire Protection System Impairments 37

SO-G-91 Standing Order, Control and Transportation of Combustible Materials 27

SO-G-102 Standing Order, Fire Protection Program Plan 11

SO-G-103 Standing Order, Fire Protection Operability Criteria and Surveillance 25

Requirements

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION

EA-FC-97-001 Fire hazards Analysis Manual 16

FC05814 UFHA Combustible Loading Calculation 11

USAR 9.11 Updated Safety Analysis Report, Fire Protection Systems 23

A-4

Section 1R11: Licensed Operator Requalification Program

PROCEDURES

NUMBER TITLE REVISION

LOR TPMP Licensed Operator Requal Training Program Master Plan 54

SO-G-26 Training and Qualification Programs Standing Orders 59

OPD-3-11 Licensed Activation and Watch station Maintenance 18

Section 1EP1: Exercise Evaluation

PROCEDURES

NUMBER TITLE REVISION

Radiological Emergency Response Plan

EPIP-OSC-1 Emergency Classification 46

EPIP-OSC-2 Command and Control Position Actions-Notifications 54-56

EPIP-OSC-9 Emergency Team Briefings 14

EPIP-OSC-16 Communicator Actions 27

EPIP-OSC-21 Activation of the Operations Support Center 20

EPIP-TSC-1 Activation of the Technical Support Center 32

EPIP-EOF-1 Activation of the Emergency Operations Facility 18

EPIP-EOF-3 Offsite Monitoring 23

EPIP-EOF-6 Dose Assessment 43

EPIP-EOF-7 Protective Action Guidelines 21

EPIP-EOF-21 Potassium Iodide Issuance 8

EPIP-EOF-11 Dosimetry Record, Exposure Extensions and Habitability 26

EPIP-RR-1 Technical Support Center Director Actions 17

EPIP-RR-21 Operations Support Center Director Actions 17

A-5

CONDITION REPORTS (CR)

2012-01435 2012-01489 2012-01490 2012-01501 2012-01742 2012-02131

2012-02250 2012-02374 2012-02376 2012-02377 2012-02379 2012-02381

2012-02400 2012-02475

Section 1EP4: Emergency Action Level and Emergency Plan Changes

PROCEDURES

NUMBER TITLE REVISION

EPIP-EOF-3 Offsite Monitoring 24, 25

EPIP-EOF-7 Protective Action Guidelines 21, 22

EPIP-RR-21A Maintenance Coordinator Actions 6, 7

EPIP-RR-72 Field Team Specialist Actions 10, 20

EPIP-RR-90 EOF/TSC CHP Communicator Actions 5, 6

Section 1EP6: Drill Evaluation

PROCEDURES

NUMBER TITLE REVISION

TBD-EPIP-OSC-1A Recognition Category A - Abnormal Rad 2

Levels/Radiological Effluent

TBD-EPIP-OSC-1C Recognition Category C- Cold Shutdown/Refueling 2

System Malfunction

TBD-EPIP-OSC-1F Recognition Category F - Fission Product Barrier 1

Degradation

TBD-EPIP-OSC-1H Recognition Category H - Hazards and Other Conditions 1

Affecting Plant Safety

TBD-EPIP-OSC-1S Recognition Category S - System Malfunction 2

CONDITION REPORTS

2011-6117 2011-8529 2011-8530 2011-8531

PROCEDURES

A-6

NUMBER TITLE REVISION

EOF-7 Protective Action Guidelines 20, 21

EPDM-14 Emergency Preparedness Performance Indicator Program 12

Section 4OA5: Other Activities

CALCULATIONS

NUMBER TITLE REVISION

FC06689 Susceptibility of HPSl / LPSl, System to Water Hammer 2

FC06941 LPSI System Critical Void Size and Operator Action Time 1

FC07124 Evaluation of the Maximum Gas, Void Fractions That Could be 0

Delivered to the ECCS Pumps in the Fort Calhoun Design (Vendor

Calc. No.: FA1108-89)

FC07258 Fort Calhoun Transient, Investigating the Potential for Vortex 0

Formation in the SlRWT Suction Flow

FC07487 Response to the Fort Calhoun HPSl Piping High Points to Gas-Water 0

Waterhammer

FC07500 Evaluation of Allowable Suction Piping Gas Void Volumes for Fort 2

Calhoun to Address GL 2008-01 (Vendor Calc. No.: CN-SEE-III-08-40)

FC07501 Evaluation of the Potential for Waterhammer in the Containment Spray 0

System for Fort Calhoun

FC07502 Evaluation of the Potential for Waterhammer During Cold Leg Injection 0

for Fort Calhoun

FC07503 Allowable Gas Void Accumulation for the Fort Calhoun High Pressure 1

Safety Injection Discharge Piping

FC07504 Gas-Water Waterhammer Evaluations for the Fort Calhoun 1

Containment Spray Piping

FC07505 Evaluation of the Potential for Gas-Water, Waterhammer in Fort 0

Calhoun During Hot Leg Injection

FC07532 Subsystem Si-164C (4 Inch HPSI Header) Stress Analysis For Void- 0

Induced Water-Hammer Event

FC07532 Subsystem SI-164C (4 Inch HPSI Header) Stress Analysis For Void- 0

Induced Water-Hammer Event

FC07548 Evaluation of the Gas Intrusion to the HPSI 2B Vendor Calc. No.: 0

FAI/09-177 Pump Suction.

FC07804 HPSI Pump Cooled Suction Piping Gas Intrusion, Gas Voiding 0

A-7

CONDITION REPORTS

2008-2021 2009-2069 2009-4222 2010-1450

WORK ORDERS

350418 360590 362852 371018

379858 388762

DRAWINGS

NUMBER TITLE REVISION / DATE

E-23866-210-130 Safety Injection and Containment Spray System Flow 111

Sht. 1 Diagram

E-23866-210-130 Safety Injection and Containment Spray System Flow 24

Sht. 2A Diagram

E-23866-210-130 Safety Injection and Containment Spray System Flow 29

Sht. 3A Diagram

E-2520 IC-186 Safety Injection - Aux Building 9

E-2520 IC-187 Safety Injection - Aux Building 13

E-2520 IC-188 Safety Injection - Aux Building 8

E-2520 IC-194 Safety Injection - Aux Building 9

E-2520 IC-195 Safety Injection - Aux Building 9

E-2520 IC-196 Safety Injection - Aux Building 9

E-2520 IC-197 Safety Injection - Aux Building 8

E-2520 IC-198 Safety Injection - Aux Building 6

E-2520 IC-199 Safety Injection - Aux Building 8

E-2520 IC-201 Safety Injection - Aux Building 9

E-2520 IC-204 Safety Injection - Aux Building 9

E-2520 IC-205 Safety Injection - Aux Building 13

E-2520 IC-206 Safety Injection - Aux Building 13

E-2520 IC-209 Safety Injection - Aux Building 7

E-2520 IC-72 Safety Injection - Containment Building 14

E-2520 IC-78 Safety Injection - Containment Building 8

A-8

DRAWINGS

NUMBER TITLE REVISION / DATE

E-2520 IC-92 Aux Coolant (Return) in Containment 7

LRA-A-1 Safety Injection and Containment Spray Grade Map - June 6, 2008

Suction Header Overview

LRA-A-2 Safety Injection and Containment Spray Grade Map - June 6, 2008

Suction Header RM 21

LRA-A-3 Safety Injection and Containment Spray Grade Map - June 6, 2008

Suction Header RM 21, 22, 23

LRA-A-4 Safety Injection and Containment Spray Grade Map - June 6, 2008

Suction Header RM 23

LRA-B-1 Safety Injection and Containment Spray Grade Map - June 6, 2008

Suction Header Overview

LRA-B-2 Safety Injection and Containment Spray Grade Map - June 6, 2008

Suction Header RM 21, 22

LRA-B-3 Safety Injection and Containment Spray Grade Map - June 6, 2008

Suction Header RM 22, 23

LRA-CGM-CS SI- Safety Injection and Containment Spray Grade Map - June 6, 2008

3A Composite Grade Map CS SI-3A

LRA-CGM-CS SI- Safety Injection and Containment Spray Grade Map - June 6, 2008

3B/3C Composite Grade Map CS SI-3B/3C

LRA-CGM-HPSI Safety Injection and Containment Spray Grade Map - June 6, 2008

SI-2A/2C Composite Grade Map HPSI SI-2A/2C

LRA-CGM-HPSI Safety Injection and Containment Spray Grade Map - June 6, 2008

SI-2B Composite Grade Map HPSI SI-2B

LRA-CGM-LPSI Safety Injection and Containment Spray Grade Map - June 6, 2008

SI-1A Composite Grade Map LPSI SI-1A

LRA-CGM-LPSI SI- Safety Injection and Containment Spray Grade Map - June 6, 2008

1B Composite Grade Map LPSI SI-1B

LRA-CS-1 Safety Injection and Containment Spray Grade Map - June 6, 2008

Overview

LRA-CS-10 Safety Injection and Containment Spray Grade Map - June 6, 2008

AC-4B RM 14, 15A, 56

LRA-CS-2 Safety Injection and Containment Spray Grade Map - June 6, 2008

SI-3A RM21

LRA-CS-3 Safety Injection and Containment Spray Grade Map - June 6, 2008

A-9

DRAWINGS

NUMBER TITLE REVISION / DATE

SO-3A RM 21, 22

LRA-CS-4 Safety Injection and Containment Spray Grade Map - June 6, 2008

SI-3B RM 22

LRA-CS-5 Safety Injection and Containment Spray Grade Map - June 6, 2008

SI-3C RM 22

LRA-CS-6 Safety Injection and Containment Spray Grade Map - June 6, 2008

SI-3A/3B/3C RM 22, 23, 12, 13

LRA-CS-7 Safety Injection and Containment Spray Grade Map - June 6, 2008

AC-4A RM 13, 14, 15A

LRA-CS-8 Safety Injection and Containment Spray Grade Map - June 6, 2008

AC-4A RM 14, 15, 56

LRA-CS-9 Safety Injection and Containment Spray Grade Map - June 6, 2008

AV-4B RM 15, 15A

LRA-CSUC-1 Safety Injection and Containment Spray Grade Map - June 6, 2008

Cooled Suction Overview

LRA-CSUC-2 Safety Injection and Containment Spray Grade Map - June 6, 2008

Cooled Suction to HPSI SI-2A/2C RM 13, 14, 15A

LRA-CSUC-3 Safety Injection and Containment Spray Grade Map - June 6, 2008

Cooled Suction to HPSI SI-2A/2C RM 13, 22, 23

LRA-CSUC-4 Safety Injection and Containment Spray Grade Map - June 6, 2008

Cooled Suction to HPSI SI-2A/2C RM 21, 22

LRA-CSUC-5 Safety Injection and Containment Spray Grade Map - June 6, 2008

Cooled Suction HPSI 2B RM 13, 14, 15

LRA-CSUC-6 Safety Injection and Containment Spray Grade Map - June 6, 2008

Cooled Suction HPSI 2B RM 13, 22, 23

LRA-CUSC-7 Safety Injection and Containment Spray Grade Map - June 6, 2008

Cooled Suction HPSI 2B RM 22

LRA-HP-1 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI Overview

LRA-HP-10 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2B RM 22

LRA-HP-11 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2B RM 21, 22, 23

LRA-HP-12 Safety Injection and Containment Spray Grade Map - June 6, 2008

A-10

DRAWINGS

NUMBER TITLE REVISION / DATE

HPSI 2B RM 23, 13, Containment

LRA-HP-13 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2B Containment

LRA-HP-14 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2B Containment

LRA-HP-15 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2B Containment

LRA-HP-2 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2A RM 21

LRA-HP-3 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2C RM 21

LRA-HP-4 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2A/2C RM 23

LRA-HP-5 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2A/2C 23, 13

LRA-HP-6 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2A/2C Containment

LRA-HP-7 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2A/2C Containment

LRA-HP-8 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2A/2C Containment

LRA-HP-8 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2A/2C Containment

LRA-HP-9 Safety Injection and Containment Spray Grade Map - June 6, 2008

HPSI 2A/2C Containment

LRA-LP-1 Safety Injection and Containment Spray Grade Map - June 6, 2008

LPSI Overview

LRA-LP-2 Safety Injection and Containment Spray Grade Map - June 6, 2008

LPSI-1A RM 21-22

LRA-LP-3 Safety Injection and Containment Spray Grade Map - June 6, 2008

LPSI 1A/1B RM 22

LRA-LP-4 Safety Injection and Containment Spray Grade Map - June 6, 2008

LPSI-1A/1B RM 22, 23, 13

LRA-LP-5 Safety Injection and Containment Spray Grade Map - June 6, 2008

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DRAWINGS

NUMBER TITLE REVISION / DATE

LPSI-1A/1B RM 13, Containment

LRA-LP-6 Safety Injection and Containment Spray Grade Map - June 6, 2008

LPSI-1A/1B Containment

LRA-LP-7 Safety Injection and Containment Spray Grade Map - June 6, 2008

LPSI 1A/1B Containment

LRA-LP-8 Safety Injection and Containment Spray Grade Map - June 6, 2008

LPSI 1A/1B Containment

LRA-SD-1 Safety Injection and Containment Spray Grade Map - June 6, 2008

Shutdown Cooling Overview

LRA-SD-10 Safety Injection and Containment Spray Grade Map - June 6, 2008

Shutdown Cooling Heat Exchanger AC-4A RM 14,

15A

LRA-SD-11 Safety Injection and Containment Spray Grade Map - June 6, 2008

Shutdown Cooling From Heat Exchangers RM 13,

14, 15, 15A

LRA-SD-2 Safety Injection and Containment Spray Grade Map - June 6, 2008

Shutdown Cooling Hot Leg Return Containment, RM

13

LRA-SD-3 Safety Injection and Containment Spray Grade Map - June 6, 2008

Shutdown Cooling Hot Leg Return RM 13, 22, 23

LRA-SD-4 Safety Injection and Containment Spray Grade Map - June 6, 2008

Shutdown Cooling Hot Leg Return To SI-1A RM 21,

22

LRA-SD-5 Safety Injection and Containment Spray Grade Map - June 6, 2008

Shutdown Cooling Discharge from SI-1A RM 21, 22

LRA-SD-6 Safety Injection and Containment Spray Grade Map - June 6, 2008

Shutdown Cooling Hot Leg Return To SI-1B RM 22

LRA-SD-7 Safety Injection and Containment Spray Grade Map - June 6, 2008

Shutdown Cooling TO Heat Exchanger RM 12, 22, 23

LRA-SD-8 Safety Injection and Containment Spray Grade Map - June 6, 2008

Shutdown Cooling TO Heat Exchanger RM 12, 13,

14, 15

LRA-SD-9 Safety Injection and Containment Spray Grade Map - June 6, 2008

Shutdown Cooling Heat Exchanger AC-4B RM 15,

15A

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DRAWINGS

NUMBER TITLE REVISION / DATE

SI-2037 Sht. 2 Safety Injection - Containment Building 7

SI-2037-Sht. 1 Safety Injection - Containment Building 10

SI-2038-Sht. 1 Safety Injection - Containment Building 11

SI-2039-Sht. 1 Safety Injection - Containment Building 10

SI-2040-Sht. 1 Safety Injection - Containment Building 9

SI-2041-Sht. 1 Safety Injection - Containment Building 12

SI-2042-Sht. 1 Safety Injection - Containment Building 10

SI-2043-Sht. 1 Safety Injection - Containment Building 10

SI-2044-Sht. 1 Safety Injection - Containment Building 11

MODIFICATIONS

NUMBER TITLE REVISION

EC 27405 Installed LPSI Void Detectors

EC 43078 Installed 8 Vent Valves in 2008

EC 45266 Install Vent Valves upstream and downstream of Check 125

Valves SI-159 and SI-160 for filling, venting and temporary

bypassing of check valve due to gas voiding

EC 45266 OI-CO-5 OI-CO-5/ Containment Integrity 29

EC 45266 OI-CS-11 OI*CS-1 I Containment Spray - Normal Operation 38

EC 45266 OI-SFP-4 OI-SFP-4 / Alternate Spent Fuel Pool Cooling 5

EC 45266 OI-SI-1 OI-SI-1 / Safety Injection - Normal Operation 128

EC 45266 QC-ST- QC-ST-ECCS-0001, Quarterly ECCS Gas Accumulation 9

ECCCS-001 Detection

EC 45266 SE-EQT- SE-EQT-SI-0008, Test Preparation for HCV-383-3 and 3

SI-008 HCV-383-4 per Generic Letter 89-10

EC 45266 SE-ST-SI- SE-ST-SI-3005, Measurement of Post RAS Leakage Tests 22

3005 to the Safety Injection Refueling Water Tank (SIRWT)

EC 45266 SE-St-SI- SE-ST-SI-3027, RHR Headers "A" and "B" Refueling 16

3027 Hydrostatic and Leakage Test

EC 45428 Installed 17 Vent Valves in 2011

EC 47407 Installed 11 Vent Valves in 2009

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MODIFICATIONS

NUMBER TITLE REVISION

EC 48955 Installed 2 Vent Valves in 2011

EC: 48955 PED~EI- Install High Point Vent Valves on the Cooled HPSI Suction 9

35.1 Lines Downstream of HCV-349 & HCV-350

PROCEDURES

NUMBER TITLE REVISION / DATE

ARP-ERFCS Pg 36 Fort Calhoun Station Annunciator Response

Procedure - LPSI Void Alarm, Alarm Points Y351,

Y352, Y353, Y354

CH-AD-0060 Groundwater Sampling and Analysis Process 2

CH-SMP-RV-0014 Well Water Sampling 1

NOD-QP-42.1 Recovery Action Closure Verification Checklist 3

OI-CS-1 Operating Instruction Containment Spray - Normal September 22, 2011

Operation - EC 53486

OI-SC-1 Operating Instruction Shutdown Cooling Initiation September 27. 2011

- EC 53650, 53651, 53659

OI-SI-1 Operating Procedure - Safety Injection - Normal May 27, 2011

Operation - EC 38191

OP-1 Operating Procedure - Master Checklist For Plant September 13, 2011

Startup

OP-2A Operating Procedure - Plant Startup February 2, 2012

PBD-32 Managing Gas Accumulation in Safety Systems 3

QC-ST-ECCS-0001 Surveillance Test - Quarterly ECCS Gas February 18, 2011

Accumulation Detection

QC-ST-ECCS-0002 Refueling ECCS Gas Accumulation Detection 3

SDBD-SI-130 Shutdown Cooling 22

SDBD-SI-CS-131 Containment Spray 31

SDBD-SI-HP-132 High Pressure Safety Injection 27

SDBD-SI-LP-133 Low Pressure Safety Injection System 30

SO-G-118 Site Groundwater Protection Program 3

MISCELLANEOUS DOCUMENTS

A-14

NUMBER TITLE REVISION / DATE

Monitoring Well Sampling & Analysis Reports March 21, 2011

Monitoring Well Sampling & Analysis Reports March 21, 2011

Monitoring Well Sampling & Analysis Reports September 15, 2011

Monitoring Well Sampling & Analysis Reports September 16, 2011

Monitoring Well Sampling & Analysis Reports December 16, 2011

White Paper Acceptance Criteria for Void

Identification

EC 43078 HPSI High Point Vent Valves in Containment 2

EC 45266 Install Vent Valves Upstream and Downstream of 0

Check Valves SI-159 and SI-160 for Filling,

Venting and Temporary Bypassing of Check

Valve Due to Gas Voiding

EC 45428 Installation of ECCS High Point Vent Valves 0

EC 47407 Additional ECCS Vent Valves 0

EC 48955 Install High Point Vent Valves on the Cooled HPSI 0

Suction Lines Downstream of HCV-349 & HCV-

350

Letter from Todd L. Summary of work performed for the creation of August 7, 2008

Whitfield to Douglas isometric drawings on the emergency coolant

Molzer system piping at the Fort Calhoun Station Nuclear

power plant.

LIC-08-0106 Omaha Public Power District, Fort Calhoun October 14, 2008

Station (FCS), Response to NRC Generic Letter 2008-01

LIC-08-0106 Omaha Public Power District, Fort Calhoun October 14, 2008

Station (FCS), Response to NRC Generic Letter 2008-01

LIC-10-0062 Response to NRC Request for Status of August 10, 2010

Corrective Actions Contained in the Omaha

Public Power District (OPPD) Response to

Generic Letter 2008-01

LIC-10-0062 Response to NRC Request for Status of 3

Corrective Actions Contained in the Omaha

Public Power District (OPPD) Response to

Generic Letter 2008-01

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MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE

NRC 10-0062 Summary of Conference Call held on July 16, August 6, 2010

2010 between the U.S. Nuclear Regulatory

Commission and Omaha Public Power District

Concerning Generic Letter 2008-01 (TAC. NO.

MD7829)

QCP 334 Ultrasonic Examination for Liquid Level August 10, 2010

Measurement

RA 2009-0518 Self-Assessment Report and Corrective Actions December 15, 2011

TDB III-42 Technical Data Book - Requirements For ECCS December 23, 2008

and Containment Cooling Equipment Operation in

Mode 3, Transition Between Modes 3 and 4 and

Mode 4 and 5

TDB VIII Technical Data Book - Equipment Operability December 29, 2011

Guidance

Training - Power Generic Letter 2008-01, Managing Gas

Point Presentation Accumulation In Emergency Core Cooling, Decay

Heat Removal, And Containment Spray Systems

USAR 6.2 Engineered Safeguards - Safety Injection System 35

USAR 6.3 Engineered Safeguards - Containment Spray 17

System

USAR 6.3 Engineered Safeguards 17

Containment Spray System

USAR Appendix G Responses to 70 Criteria 18

Void Trending Excel Spread Sheets with Void Trending April 9, 2011

Information

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