IR 05000285/2016004: Difference between revisions
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{{#Wiki_filter: | {{#Wiki_filter:UNITED STATES ary 18, 2017 | ||
==SUBJECT:== | ==SUBJECT:== | ||
FORT CALHOUN STATION | FORT CALHOUN STATION - NRC INTEGRATED INSPECTION REPORT 05000285/2016004 | ||
- NRC INTEGRATED INSPECTION REPORT 05000285/2016004 | |||
==Dear Mr. Marik:== | ==Dear Mr. Marik:== | ||
On December 31, 2016 , the U.S. Nuclear | On December 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fort Calhoun Station. On January 11, 2017, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report. | ||
NRC inspectors documented one finding of very low safety significance (Green) in this report. | |||
This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. | |||
Further, inspectors documented three licensee-identified violations, which were determined to be of very low safety significance (Green) or Severity Level IV, in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. | Further, inspectors documented three licensee-identified violations, which were determined to be of very low safety significance (Green) or Severity Level IV, in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. | ||
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. | If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC inspector at the Fort Calhoun Station. | ||
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC inspector at the Fort Calhoun Station. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | |||
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 U.S. | |||
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC inspector at the Fort Calhoun Station. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, | |||
Sincerely, | Sincerely, | ||
/RA/ Geoffrey B. Miller, Branch Chief Project Branch D Division of Reactor Projects Docket No. 50-285 License No | /RA/ | ||
. DPR-40 | Geoffrey B. Miller, Branch Chief Project Branch D Division of Reactor Projects Docket No. 50-285 License No. DPR-40 | ||
===Enclosure:=== | ===Enclosure:=== | ||
Inspection Report | Inspection Report 05000285/2016004 w/ Attachment: | ||
1. Supplemental Information 2. O | 1. Supplemental Information 2. O | ||
REGION IV Docket: 50-285 License: DPR-40 Report: | REGION IV== | ||
S. Schneider, Senior Resident Inspector P. Voss, Senior Resident Inspector L. Brandt, Acting Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspector S. Hedger, Operations Engineer J. | Docket: 50-285 License: DPR-40 Report: 05000285/2016004 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, NE 68008 Dates: October 1 through December 31, 2016 Inspectors: S. Schneider, Senior Resident Inspector P. Voss, Senior Resident Inspector L. Brandt, Acting Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspector S. Hedger, Operations Engineer J. ODonnell, CHP, Health Physicist Approved Geoffrey B. Miller By: Chief, Project Branch D Division of Reactor Projects Enclosure | ||
=SUMMARY= | =SUMMARY= | ||
IR | IR 05000285/2016004; 10/01/2016 - 12/31/2016; Fort Calhoun Station; Maintenance of | ||
Emergency Preparedness. | |||
The NRC | The inspection activities described in this report were performed between October 1 and December 31, 2016, by the resident inspectors at Fort Calhoun Station, inspectors from the NRCs Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented in this report three licensee-identified violations of very low safety significance (Green) or Severity Level IV. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, | ||
-1649, | Significance Determination Process, dated April 29, 2015. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, dated July 2016. | ||
, | |||
===Cornerstone: Emergency Preparedness=== | ===Cornerstone: Emergency Preparedness=== | ||
: '''Green.''' | : '''Green.''' | ||
The inspector reviewed a self-revealed non-cited | The inspector reviewed a self-revealed non-cited violation associated with Fort Calhoun Stations failure to provide radiological emergency response training to those who may be called upon to assist in an emergency, as required by 10 CFR 50.47(b)(15). | ||
Specifically, in December 2014, 10 shift managers and 6 Technical Support Center and Emergency Operations Facility staff, responsible for making and reviewing protective action recommendations, were not trained on Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and flowchart EP-FC-111-AD-F-02, before they were implemented on December 23, 2014. As immediate corrective actions, the licensee issued a reading package covering the new protective action recommendation process to the 16 individuals who had not been trained. The issue was entered into the licensees corrective action program as Condition Report CR-2015-08951. | |||
The failure to provide radiological emergency response training to those who may be called upon to assist in an emergency is a performance deficiency within the licensees ability to foresee and correct. The performance deficiency was more than minor because it was associated with the procedure quality attribute of Emergency Prepardness Cornerstone and adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015, and was determined to be of very low safety significance (Green) because it was a failure to comply, was not a risk significant planning standard function, was not a loss of the planning standard function, and was a degraded planning standard function. This finding had a cross-cutting aspect in the area of human performance associated with change management because the emergency preparedness department failed to identify all of the emergency response organization staff who required training on revisions to the process for making protective action recommendations [H.3]. | |||
(Section 1EP5) | |||
===Licensee-Identified Violations=== | |||
Corrective actions taken or planned by the licensee have been entered into the | Violations of very low safety significance (Green) or Severity Level IV that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report. | ||
=PLANT STATUS= | |||
On October 1, 2016, the Fort Calhoun Station (FCS) was at 97.8 percent power following the commencement of a coastdown on September 29, 2016. On October 24, 2016, FCS completed a final shutdown of the plant to commence a defueling outage in support of the permanent decommissioning of the plant. On November 13, 2016, FCS issued the defueling certification letter to the NRC. | |||
REPORT DETAILS | |||
==REACTOR SAFETY== | ==REACTOR SAFETY== | ||
Cornerstones: | Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity {{a|1R01}} | ||
==1R01 Adverse Weather Protection== | |||
{{IP sample|IP=IP 71111.01}} | |||
Readiness for Seasonal Extreme Weather Conditions | Readiness for Seasonal Extreme Weather Conditions | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
On November 3, 2016, the inspectors completed an inspection of the | On November 3, 2016, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for cold weather operations and evaluated the licensees implementation of these procedures. The inspectors verified that prior to the onset of cold weather, the licensee had corrected weather-related equipment deficiencies identified during the previous winter. | ||
These activities | The inspectors selected three risk-significant systems that were required to be protected from cold weather: | ||
* Intake Structure | |||
* Raw Water | |||
* Control Room Air Conditioning The inspectors reviewed the licensees procedures and design information to ensure the systems would remain functional when challenged by cold weather. The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the cold weather protection features. | |||
These activities constituted one sample of readiness for seasonal adverse weather, as defined in Inspection Procedure 71111.01. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R04}} | ||
==1R04 Equipment Alignment== | |||
{{IP sample|IP=IP 71111.04}} | |||
Partial Walk-Down | |||
====a. Inspection Scope==== | |||
The inspectors performed partial system walk-downs of the following risk-significant systems: | |||
- | * October 21, 2016, control room air conditioning and ventilation system | ||
* October 23, 2016, raw water system following raw water pump AC-10B in-service test | |||
* October 28, 2016, shutdown cooling system | |||
* November 18, 2016, component cooling water system following maintenance on component cooling water pump AC-3C | |||
* December 2, 2016, spent fuel pool cooling system The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration. | |||
These activities constituted five partial system walk-down samples, as defined in Inspection Procedure 71111.04. | |||
-down samples , as defined | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R05}} | ||
==1R05 Fire Protection== | |||
{{IP sample|IP=IP 71111.05}} | |||
Quarterly Inspection | Quarterly Inspection | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors evaluated the | The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on five plant areas important to safety: | ||
* October 9, 2016, control room, fire area 42 | |||
* October 9, 2016, cable spreading room, fire area 41 | |||
* November 1, 2016, containment, fire area 30 | |||
* November 15, 2016, room 69 ventilation area, fire area 20-7 | |||
* November 15, 2016, upper electrical penetration room, fire area 34B-1 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions. | |||
These activities | These activities constituted five quarterly inspection samples, as defined in Inspection Procedure 71111.05. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R11}} | ||
==1R11 Licensed Operator Requalification Program and Licensed Operator Performance== | |||
{{IP sample|IP=IP 71111.11}} | |||
===.1 Review of Licensed Operator Requalification=== | ===.1 Review of Licensed Operator Requalification=== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
On October 18, 2016, the inspectors observed simulator training for an operating crew preparing for the upcoming plant shutdown. The crew performed the planned down power evolution leading into the shutdown while addressing abnormal conditions included by the evaluation staff. Specifically, the crew was evaluated addressing a malfunction with the chemical volume and control system during a boration, as well as a stuck turbine control valve on the main turbine. The inspectors assessed the performance of the operators and the evaluators | On October 18, 2016, the inspectors observed simulator training for an operating crew preparing for the upcoming plant shutdown. The crew performed the planned down power evolution leading into the shutdown while addressing abnormal conditions included by the evaluation staff. Specifically, the crew was evaluated addressing a malfunction with the chemical volume and control system during a boration, as well as a stuck turbine control valve on the main turbine. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during training. | ||
These activities | These activities constituted completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11. | ||
====b. Findings==== | ====b. Findings==== | ||
Line 149: | Line 139: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors observed the performance of on | The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity or risk. The inspectors observed the operators performance of the following activities: | ||
-shift licensed operators in the | * October 19, 2016, operators preparing for quarterly in-service test of raw water pump AC-10B | ||
. The inspectors observed the operators | * October 20, 2016, operators completing containment wide range pressure instrument channel and core reactivity surveillance testing and adjusting nitrogen blanket pressure in the component cooling water expansion tank | ||
October 19, 2016, operators preparing for quarterly in | * October 21, 2016, operators responding to a smoke detector alarm and reports of an acrid odor in one of the plant areas | ||
-service test of raw water pump AC-10B | * October 24, 2016, downpower maneuvers, manual trip, and post trip actions | ||
-up brief In addition, the inspectors assessed the operators | * October 26, 2016, power operated relief valve low temperature low pressure surveillance test | ||
* November 2, 2016, reactor coolant system drain down to lowered inventory | |||
* November 4, 2016, reactor coolant system flood-up brief In addition, the inspectors assessed the operators adherence to plant procedures and other operations department policies. | |||
These activities | These activities constituted completion of seven quarterly licensed operator performance samples, as defined in Inspection Procedure 71111.11. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R13}} | ||
==1R13 Maintenance Risk Assessments and Emergent Work Control== | |||
{{IP sample|IP=IP 71111.13}} | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed three risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk: | The inspectors reviewed three risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk: | ||
October 12, 2016, planned yellow risk during emergency diesel generator 1 testing | * October 12, 2016, planned yellow risk during emergency diesel generator 1 testing | ||
* October 26, 2016, planned yellow risk for power operated relief valve low temperature low pressure surveillance test | |||
* November 4, 2016, planned yellow risk for heavy load lift over the reactor vessel The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments. | |||
These activities | These activities constituted completion of three maintenance risk assessment inspection samples, as defined in Inspection Procedure 71111.13. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R15}} | ||
==1R15 Operability Determinations and Functionality Assessments== | |||
{{IP sample|IP=IP 71111.15}} | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed three operability | The inspectors reviewed three operability determinations and functionality assessments that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs): | ||
October 4, 2016, operability determination of MasterPact breaker fail to close technical bulletin and impact on Fort Calhoun Station breakers November 22, 2016 , functionality assessment of Allen-Bradley 700 RTC relay susceptibility to electromagnetic interference and radio frequency interference December 2, 2016, functionality assessment of component cooling water surge tank pressure and level control in manual versus automatic The inspectors reviewed the timeliness and technical adequacy of the licensee | * October 4, 2016, operability determination of MasterPact breaker fail to close technical bulletin and impact on Fort Calhoun Station breakers | ||
* November 22, 2016, functionality assessment of Allen-Bradley 700 RTC relay susceptibility to electromagnetic interference and radio frequency interference | |||
* December 2, 2016, functionality assessment of component cooling water surge tank pressure and level control in manual versus automatic The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC. | |||
These activities constituted completion of three operability and functionality review samples, as defined in Inspection Procedure 71111.15. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R19}} | ||
==1R19 Post-Maintenance Testing== | |||
{{IP sample|IP=IP 71111.19}} | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed four post-maintenance testing activities that affected risk | The inspectors reviewed four post-maintenance testing activities that affected risk-significant SSCs: | ||
-significant SSCs: | * October 7, 2016, penetration M-45 Type C local leak rate post-maintenance test | ||
October 7, 2016, penetration M | * October 20, 2016, control room air conditioning and air filtration system post-maintenance test | ||
-45 Type C local leak rate post-maintenance test | * November 17, 2016, component cooling water pump AC-3C post-maintenance test | ||
-3C post-maintenance test | * December 14, 2016, raw water system strainer AC-12B post-maintenance test The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests or reviewed the results to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs. | ||
-12B post-maintenance test The inspectors reviewed licensing- and design | |||
-basis documents for the SSCs and the maintenance and post-maintenance test procedures. | |||
These activities constituted completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19. | |||
These activities | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R20}} | ||
==1R20 Refueling and Other Outage Activities== | |||
{{IP sample|IP=IP 71111.20}} | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
During the | During the stations defueling outage that concluded on November 11, 2016, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following: | ||
Review of the | * Review of the licensees outage plan prior to the outage | ||
-in-depth during outage activities Observation and review of reduced | * Review and verification of the licensees fatigue management activities | ||
-inventory activities Observation and review of fuel handling activities | * Monitoring of shutdown and cooldown activities | ||
* Verification that the licensee maintained defense-in-depth during outage activities | |||
These activities | * Observation and review of reduced-inventory activities | ||
* Observation and review of fuel handling activities These activities constituted completion of one defueling outage sample, as defined in Inspection Procedure 71111.20. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R22}} | ||
==1R22 Surveillance Testing== | |||
{{IP sample|IP=IP 71111.22}} | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors observed seven risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions: | The inspectors observed seven risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions: | ||
In-service | In-service tests: | ||
-service test | * October 13, 2016, raw water system Category C valve in-service test | ||
-10B in-service test Other surveillance tests: | * October 25, 2016, raw water pump AC-10B in-service test Other surveillance tests: | ||
October 13, 2016, reactor coolant system flow rate determination by heat balance October 14, 2016, auxiliary feedwater pump FW | * October 13, 2016, reactor coolant system flow rate determination by heat balance | ||
-6 surveillance test | * October 14, 2016, auxiliary feedwater pump FW-6 surveillance test | ||
-ring seal surveillance test | * October 20, 2016, emergency diesel generator 2 surveillance test | ||
* October 26, 2016, power operated relief valve low temperature low pressure surveillance test | |||
* November 3, 2016, personnel access lock o-ring seal surveillance test The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing. | |||
These activities | These activities constituted completion of seven surveillance testing inspection samples, as defined in Inspection Procedure 71111.22. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
===Cornerstone: | ===Cornerstone: Emergency Preparedness=== | ||
{{a|1EP2}} | |||
==1EP2 Alert and Notification System Testing== | |||
{{IP sample|IP=IP 71114.02}} | |||
1 | ====a. Inspection Scope==== | ||
The inspector verified the adequacy of the licensees methods for testing the primary and backup alert and notification system (ANS). The inspector interviewed licensee personnel responsible for the maintenance of the primary and backup ANS and reviewed a sample of corrective action system reports written for ANS problems. The inspector compared the licensees alert and notification system testing program with criteria in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1; FEMA Report REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants; and the licensees current FEMA-approved alert and notification system design report, Updated Design Report to FEMA for the Outdoor Public Warning System and Backup Alert and Notification, as approved in a letter from Mr. R. McCabe, Chief, Technological Hazards Branch, FEMA Region VII, dated December 17, 2012. | |||
These activities constituted completion of one alert and notification system evaluation sample, as defined in Inspection Procedure 71114.02. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1EP3}} | ||
==1EP3 Emergency Response Organization Staffing and Augmentation System== | |||
{{IP sample|IP=IP 71114.03}} | |||
====a. Inspection Scope==== | |||
The inspector verified that the licensees emergency response organization on-shift and augmentation staffing levels were in accordance with the licensees emergency plan commitments. The inspector reviewed documentation and discussed with licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to verify the adequacy of the licensees methods for staffing emergency response facilities, including the licensees ability to staff pre-planned alternate facilities. | |||
The inspector also reviewed records of emergency response organization augmentation tests and events to determine whether the licensee had maintained a capability to staff emergency response facilities within emergency plan timeliness commitments. | |||
These activities | These activities constituted completion of one emergency response organization staffing and augmentation testing sample, as defined in Inspection Procedure 71114.03. | ||
, as defined in Inspection Procedure 71114.03. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1EP4}} | ||
==1EP4 Emergency Action Level and Emergency Plan Changes== | |||
{{IP sample|IP=IP 71114.04}} | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspector performed an on | The inspector performed an on-site review of the Fort Calhoun Radiological Emergency Response Plan, Sections A, B, F, G, H, J, K, and O, and Appendix A, Revision 0; Procedure EP-FC-110-200, Dose Assessment, Revision 0; and EP-FC-1001, Addendum 3, Emergency Action Levels, Revision 2. These revisions: | ||
-site review of the Fort Calhoun Radiological Emergency Response Plan, Sections A, B, F, G, H, J, K, and O, and Appendix A, Revision 0; Procedure EP-FC-110-200, | * Removed references to the security department staffing the fire brigade | ||
Removed references to the security department staffing the fire brigade | * Removed references to the Blair Industrial Park Co-op phone | ||
-op phone | * Replaced references to Stone and Webster Engineering Corporation with Tierney-Blair LLC | ||
; to the criteria of NUREG-0654, | * Replaced references to the Fremont fire department with references to the Elkhorn Decontamination Center | ||
-generated changes; therefore, these revisions are subject to future inspection. | * Added making initial notifications to the NRC to the shift technical advisors duties | ||
* Added satellite phones as required communication systems | |||
* Reassigned the maintenance and replacement of radiation protection equipment inventories from emergency planning to the radiation protection department | |||
* Revised the frequency of CPR training | |||
* Implemented the utility revision of the Radiological Assessment System for Consequence Analysis (RASCAL) dose assessment program | |||
* Revised external radiation levels in emergency action level E-HU1 | |||
* Revised procedure titles and procedure numbers throughout the document These revisions were compared to their previous revisions; to the criteria of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1; to NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6, dated November 2012; and to the standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that the revisions did not decrease the effectiveness of the emergency plan. This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection. | |||
These activities | These activities constituted completion of three emergency action level and emergency plan changes samples, as defined in Inspection Procedure 71114.04. | ||
, as defined in Inspection Procedure 71114.04. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1EP5}} | ||
==1EP5 Maintenance of Emergency Preparedness== | |||
{{IP sample|IP=IP 71114.05}} | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspector reviewed the following for the period November 2014 through November 2016: | The inspector reviewed the following for the period November 2014 through November 2016: | ||
* After-action reports for emergency classifications | |||
* After-action evaluation reports for licensee drills and exercises | |||
* Independent audits and surveillances of the licensees emergency preparedness program | |||
* Self-assessments of the emergency preparedness program conducted by the licensee | |||
* Licensee evaluations of changes made to the Emergency Plan and Emergency Plan Implementing Procedures | |||
* Drill and exercise performance issues entered into the licensees corrective action program | |||
* Emergency preparedness program issues entered into the licensees corrective action program | |||
* Maintenance records for equipment supporting the emergency preparedness program | |||
* Emergency response organization and emergency planner training records The inspector reviewed summaries of 356 corrective action program reports associated with emergency preparedness and selected 15 to review against program requirements, to determine the licensees ability to identify, evaluate, and correct problems in accordance with the requirements of planning standard 10 CFR 50.47(b)(14) and 10 CFR Part 50, Appendix E, Section IV.F. The inspector verified that the licensee accurately and appropriately identified and corrected emergency preparedness weaknesses during critiques and assessments. | |||
The inspector reviewed summaries of 30 licensee evaluations of the impact of changes to the emergency plan and implementing procedures, and selected five to review against program requirements to determine the | The inspector reviewed summaries of 30 licensee evaluations of the impact of changes to the emergency plan and implementing procedures, and selected five to review against program requirements to determine the licensees ability to identify reductions in the effectiveness of the emergency plan, in accordance with the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that evaluations of proposed changes to the licensee emergency plan appropriately identified the impact of the changes prior to being implemented. | ||
, in accordance with the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that evaluations of proposed changes to the licensee emergency plan appropriately identified the impact of the changes prior to being implemented. | |||
These activities | These activities constituted completion of one sample of the maintenance of the licensees emergency preparedness program, as defined in Inspection Procedure 71114.05. | ||
, as defined in Inspection Procedure 71114.05. | |||
====b. Findings==== | ====b. Findings==== | ||
=====Introduction.===== | =====Introduction.===== | ||
The inspector reviewed a self | The inspector reviewed a self-revealed, Green, non-cited violation associated with Fort Calhoun Stations failure to provide radiological emergency response training to those who may be called upon to assist in an emergency, as required by 10 CFR 50.47(b)(15). Specifically, in December 2014, 10 shift managers and 6 Technical Support Center and Emergency Operations Facility staff members, responsible for making and reviewing protective action recommendations, were not trained on Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and flowchart EP-FC-111-AD-F-02, before they were implemented on December 23, 2014. | ||
-revealed , Green, non | |||
-cited violation associated with Fort Calhoun | |||
, were not trained on Procedure EPIP-EOF-7, | |||
-FC-111-AD-F-02 , before they were implemented on December 23, 2014. | |||
=====Description.===== | =====Description.===== | ||
Fort Calhoun Station implemented Procedure EPIP-EOF-7, | Fort Calhoun Station implemented Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and associated flowchart EP-FC-111-AD-F-02 on December 23, 2014 (ML15023A126). The emergency preparedness department had previously determined that training on the procedure revision was required for emergency response organization personnel responsible for making or reviewing protective action recommendations made to offsite authorities for protecting the health and safety of the public. Emergency preparedness staff conducted two classroom training sessions for Technical Support Center and Emergency Operations Facility staff prior to implementing the procedure change, training 23 persons. The emergency preparedness department did not verify that all required individuals attended the training. | ||
-FC-111-AD-F-02 on December 23, 2014 (ML15023A126). The emergency preparedness department had previously determined that training on the procedure revision was required for emergency response organization personnel responsible for making or reviewing protective action recommendations made to offsite authorities for protecting the health and safety of the public. Emergency preparedness staff conducted two classroom training sessions for Technical Support Center and Emergency Operations Facility staff prior to implementing the procedure change, training 23 persons. The emergency preparedness department did not verify that all required individuals attended the training. | |||
Subsequent to implementing Procedure EPIP-EOF-7, Revision 26, a senior reactor operator failed to correctly make a protective action recommendation during routine licensed operator training in the control room simulator. Following the | Subsequent to implementing Procedure EPIP-EOF-7, Revision 26, a senior reactor operator failed to correctly make a protective action recommendation during routine licensed operator training in the control room simulator. Following the operators failure to correctly recommend protective actions, the licensee determined that six Technical Support Center and Emergency Operations Facility staff failed to attend the training on Procedure EPIP-EOF-7, and therefore, lacked training before the procedure was implemented. In addition, the licensee determined the emergency preparedness staff relied on the routine licensed operator training program to train the shift managers on the revised procedure. As a result, none of the licensees 10 shift managers (on-shift emergency coordinators) received the training. The licensee entered this issue into their corrective action program as Condition Report CR-2015-08951. As immediate corrective action, the licensee issued a reading package covering the new protective action recommendation process to the 16 individuals who had not been trained. | ||
, lacked training before the procedure was implemented. In addition, the licensee determined the emergency preparedness staff relied on the routine licensed operator training program to train the shift managers on the revised procedure. As a result, none of the | |||
-shift emergency coordinators) received the training. The licensee entered this issue into | |||
=====Analysis.===== | =====Analysis.===== | ||
The failure to provide radiological emergency response training to those who may be called upon to assist in an emergency is a performance deficiency within the | The failure to provide radiological emergency response training to those who may be called upon to assist in an emergency is a performance deficiency within the licensees ability to foresee and correct. The performance deficiency was more than minor because it was associated with the procedure quality attribute of Emergency Prepardness Cornerstone and adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, personnel unfamiliar with procedures for making protective action recommendations may not make accurate or timely recommendations to protect the health and safety of the public. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015, and was determined to be of very low safety significance (Green) because it was a failure to comply, was not a risk significant planning standard function, was not a loss of the planning standard function, and was a degraded planning standard function. The planning standard function was degraded because training was only provided to 23 of 39 individuals requiring training. This finding had a cross-cutting aspect in the area of human performance associated with change management because the emergency preparedness department failed to do a thorough analysis of the emergency response organization staff who were required to be trained on revisions to the process for making protective action recommendations to offsite authorities [H.3]. | ||
. Specifically, personnel unfamiliar with procedures for making protective action recommendations may not make accurate or timely recommendations to protect the health and safety of the public. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, | |||
=====Enforcement.===== | |||
Title 10 CFR 50.47(b)(15), requires that radiological emergency response training is provided to those who may be called upon to assist in an emergency. | |||
-FC-111-AD-F-02. The licensee restored compliance by issuing a reading package covering the new protective action recommendation process to the 16 persons who had not been trained in December 2014 and verified that each person reviewed the package. Because this violation is of very low safety significance (Green) and was entered into the | |||
Contrary to above, on December 23, 2014, Fort Calhoun Station failed to provide radiological emergency response training to those who may be called upon to assist in an emergency. Specifically, the licensee failed to provide training to 16 emergency response organization staff on Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and associated flowchart EP-FC-111-AD-F-02. The licensee restored compliance by issuing a reading package covering the new protective action recommendation process to the 16 persons who had not been trained in December 2014 and verified that each person reviewed the package. Because this violation is of very low safety significance (Green) and was entered into the licensees corrective action program as Condition Report CR-2015-08951, this violation is being treated as a non-cited violation in accordance with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000285/2016004-01, Failure to Provide Training on Changes to Protective Action Recommendation Procedures) | |||
==RADIATION SAFETY== | ==RADIATION SAFETY== | ||
Cornerstones: | Cornerstones: Public Radiation Safety and Occupational Radiation Safety {{a|2RS2}} | ||
Public Radiation Safety and Occupational Radiation Safety | ==2RS2 Occupational ALARA Planning and Controls== | ||
{{IP sample|IP=IP 71124.02}} | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspector assessed licensee performance with respect to maintaining individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspector performed this portion of the attachment during the defueling outage in order to directly observe the | The inspector assessed licensee performance with respect to maintaining individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspector performed this portion of the attachment during the defueling outage in order to directly observe the licensees ALARA process activities, including planning, implementation of radiological work controls, execution of work activities, and ALARA review of work-in-progress. During the inspection, the inspector interviewed licensee personnel, reviewed licensee documents, and evaluated licensee performance in the following areas: | ||
, including planning, implementation of radiological work controls, execution of work activities, and ALARA review of work | * Implementation of ALARA and radiological work controls. The inspector observed pre-job briefings, reviewed planned radiological administrative, operational, and engineering controls, and compared the planned controls to field activities. | ||
-in-progress. During the inspection, the inspector interviewed licensee personnel, reviewed licensee documents, and evaluated licensee performance in the following areas: | * Radiation worker and radiation protection technician performance during work activities performed in radiation areas, airborne radioactivity areas, or high radiation areas. | ||
Implementation of ALARA and radiological work controls. The inspector observed pre | * Problem identification and resolution for ALARA and radiological work controls. | ||
-job briefings, reviewed planned radiological administrative, operational, and engineering controls, and compared the planned controls to field activities. | |||
Radiation worker and radiation protection technician performance during work activities performed in radiation areas, airborne radioactivity areas, or high radiation areas. | |||
The inspector reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution. | |||
-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution. | |||
These activities constituted completion of two of the five required samples of the occupational ALARA planning and controls program, as defined in Inspection Procedure 71124.02. | These activities constituted completion of two of the five required samples of the occupational ALARA planning and controls program, as defined in Inspection Procedure 71124.02. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|2RS3}} | ||
==2RS3 In-Plant Airborne Radioactivity Control and Mitigation== | |||
{{IP sample|IP=IP 71124.03}} | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspector evaluated whether the licensee controlled in-plant airborne radioactivity concentrations consistent with ALARA principles and that the use of respiratory protection devices did not pose an undue risk to the wearer. During the inspection, the inspector interviewed licensee personnel, walked down various areas in the plant, and reviewed licensee performance in the following areas: | The inspector evaluated whether the licensee controlled in-plant airborne radioactivity concentrations consistent with ALARA principles and that the use of respiratory protection devices did not pose an undue risk to the wearer. During the inspection, the inspector interviewed licensee personnel, walked down various areas in the plant, and reviewed licensee performance in the following areas: | ||
Engineering controls, including the use of permanent ventilation systems to control airborne radioactivity. The inspector evaluated installed ventilation systems, including review of procedural guidance , verified the systems were used during high | * Engineering controls, including the use of permanent ventilation systems to control airborne radioactivity. The inspector evaluated installed ventilation systems, including review of procedural guidance, verified the systems were used during high-risk activities, and verified airflow capacity, flow path, and filter/charcoal unit efficiencies. Additionally, the inspector evaluated the licensees airborne monitoring protocols, including verification that alarms and set points were appropriate. | ||
-risk activities , and verified airflow capacity , flow path, and filter/charcoal unit efficiencies. Additionally, the inspector evaluated the | * Use of respiratory protection devices, including an evaluation of the licensees respiratory protection program for use, storage, maintenance, and quality assurance of National Institute for Occupational Safety and Health (NIOSH)certified equipment, air quality and quantity for supplied-air devices and self-contained breathing apparatus (SCBA) bottles, qualification and training of personnel, and user performance. | ||
* Self-contained breathing apparatus for emergency use, including the licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, hydrostatic testing of SCBA bottles, status of SCBA staged and ready for use in the plant including vision correction, mask sizes, etc., SCBA surveillance and maintenance records, and personnel qualification, training, and readiness. | |||
Use of respiratory protection devices, including an evaluation of the | * Problem identification and resolution for airborne radioactivity control and mitigation. The inspector reviewed audits, self-assessments, and corrective action documents to verify problems were being identified and properly addressed for resolution. | ||
, including the | |||
Problem identification and resolution for airborne radioactivity control and mitigation. The inspector reviewed audits, self | |||
-assessments, and corrective action documents to verify problems were being identified and properly addressed for resolution. | |||
These activities constituted completion of the four required samples of the in-plant airborne radioactivity control and mitigation program, as defined in Inspection Procedure 71124.03. | These activities constituted completion of the four required samples of the in-plant airborne radioactivity control and mitigation program, as defined in Inspection Procedure 71124.03. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|2RS4}} | ||
==2RS4 Occupational Dose Assessment== | |||
{{IP sample|IP=IP 71124.04}} | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspector evaluated the accuracy and operability of the | The inspector evaluated the accuracy and operability of the licensees personnel monitoring equipment, verified the accuracy and effectiveness of the licensees methods for determining total effective dose equivalent, and verified that the licensee was appropriately monitoring occupational dose. The inspector interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas: | ||
* Source term characterization, including characterization of radiation types and energies, hard-to-detect isotopes, and scaling factors. | |||
* External dosimetry including National Voluntary Laboratory Accreditation Program (NVLAP) accreditation, storage, issue, use, and processing of active and passive dosimeters. | |||
* Internal dosimetry, including the licensees use of whole body counting and dose assessments based on airborne monitoring. | |||
* Special dosimetry situations, including declared pregnant workers, dosimeter placement, and neutron dose assessment. | |||
* Problem identification and resolution for occupational dose assessment. The inspector reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution. | |||
These activities constituted completion of the five required samples of the occupational dose assessment program, as defined in Inspection Procedure 71124.04. | |||
These activities | |||
====b. Findings==== | ====b. Findings==== | ||
Line 373: | Line 355: | ||
==OTHER ACTIVITIES== | ==OTHER ACTIVITIES== | ||
Cornerstones: | Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security | ||
{{a|4OA1}} | |||
===.1 Mitigating Systems Performance Index: | ==4OA1 Performance Indicator Verification== | ||
{{IP sample|IP=IP 71151}} | |||
Emergency AC Power | ===.1 Mitigating Systems Performance Index: Emergency AC Power Systems (MS06)=== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the | The inspectors reviewed the licensees mitigating system performance index data for the period of October 1, 2015 through September 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. | ||
These activities constituted verification of the mitigating system performance index for emergency ac power systems, as defined in Inspection Procedure 71151. | These activities constituted verification of the mitigating system performance index for emergency ac power systems, as defined in Inspection Procedure 71151. | ||
Line 387: | Line 369: | ||
No findings were identified. | No findings were identified. | ||
===.2 Mitigating Systems Performance Index | ===.2 Mitigating Systems Performance Index: Residual Heat Removal Systems (MS09)=== | ||
: | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the | The inspectors reviewed the licensees mitigating system performance index data for the period of October 1, 2015 through September 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. | ||
These activities constituted verification of the mitigating system performance index for residual heat removal systems, as defined in Inspection Procedure 71151. | These activities constituted verification of the mitigating system performance index for residual heat removal systems, as defined in Inspection Procedure 71151. | ||
Line 401: | Line 382: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the | The inspectors reviewed the licensees reactor coolant system chemistry sample analyses for the period of October 1, 2015 through September 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. | ||
These activities constituted verification of the reactor coolant system specific activity performance indicator, as defined in Inspection Procedure 71151. | These activities constituted verification of the reactor coolant system specific activity performance indicator, as defined in Inspection Procedure 71151. | ||
Line 411: | Line 392: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspector reviewed selected drill, exercise, and training sessions conducted between April 2015 and September 2016 to verify the accuracy of the | The inspector reviewed selected drill, exercise, and training sessions conducted between April 2015 and September 2016 to verify the accuracy of the licensees data for classification, notification, and protective action recommendation opportunities. The inspectors reviewed a sample of the licensees completed classifications, notifications, and protective action recommendations to verify their timeliness and accuracy. The inspector used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report. | ||
These activities constituted verification of the drill/exercise performance indicator | These activities constituted verification of the drill/exercise performance indicator, as defined in Inspection Procedure 71151. | ||
, as defined in Inspection Procedure 71151. | |||
====b. Findings==== | ====b. Findings==== | ||
Line 422: | Line 402: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspector reviewed licensee records for participation in drill, exercise, and training sessions conducted between April 2015 and September 2016 to verify the accuracy of the | The inspector reviewed licensee records for participation in drill, exercise, and training sessions conducted between April 2015 and September 2016 to verify the accuracy of the licensees data for drill participation opportunities. The inspector verified that all members of the licensees emergency response organization (ERO) in the identified key positions had been counted in the reported performance indicator data. The inspector reviewed the licensees basis for reporting the percentage of ERO members who participated in a drill. The inspector reviewed drill attendance records and verified a sample of those reported as participating. The inspector used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report. | ||
These activities constituted verification of the emergency response organization drill participation performance indicator | These activities constituted verification of the emergency response organization drill participation performance indicator, as defined in Inspection Procedure 71151. | ||
, as defined in Inspection Procedure 71151. | |||
====b. Findings==== | ====b. Findings==== | ||
Line 433: | Line 412: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspector reviewed the | The inspector reviewed the licensees records of alert and notification system tests conducted between April 2015 and September 2016 to verify the accuracy of the licensees data for siren system testing opportunities. The inspector reviewed procedural guidance on assessing alert and notification system opportunities and the results of periodic alert and notification system operability tests. The inspector used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report. | ||
These activities constituted verification of the alert and notification system reliability performance indicator | These activities constituted verification of the alert and notification system reliability performance indicator, as defined in Inspection Procedure 71151. | ||
, as defined in Inspection Procedure 71151. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|4OA2}} | ||
==4OA2 Problem Identification and Resolution== | |||
{{IP sample|IP=IP 71152}} | |||
===.1 Routine Review=== | ===.1 Routine Review=== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
Throughout the inspection period, the inspectors performed daily reviews of items entered into the | Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report. | ||
The inspectors also reviewed the | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
===.2 | ===.2 Semiannual Trend Review=== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the | The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends. | ||
These activities | These activities constituted completion of one semiannual trend review sample, as defined in Inspection Procedure 71152. | ||
, and operator burdens. Examples of equipment reliability issues during 2016 included a chemical and volume control system leak in January, a component cooling water pump motor failure in February, and a high pressure safety injection pump suction valve weld failure in March. In 2016, the licensee continued to reduce backlogs in open operability determinations and temporary configuration changes. In addition, the | |||
b. Observations and Assessments In NRC Inspection Report 05000285/2016002, the inspectors documented a continuing adverse trend in equipment reliability at Fort Calhoun Station. The inspectors reviewed equipment reliability challenges in 2016 through the fourth quarter. These challenges resulted in equipment unavailability, unplanned technical specification entries, and operator burdens. Examples of equipment reliability issues during 2016 included a chemical and volume control system leak in January, a component cooling water pump motor failure in February, and a high pressure safety injection pump suction valve weld failure in March. In 2016, the licensee continued to reduce backlogs in open operability determinations and temporary configuration changes. In addition, the licensees plant health committee continued to focus on their Top 10 equipment list to resolve critical items. The inspectors have determined that the licensees progress in improving equipment reliability at the Fort Calhoun Station is sufficient to warrant closure of this trend. | |||
====c. Findings==== | ====c. Findings==== | ||
No findings were identified. | No findings were identified. {{a|4OA3}} | ||
==4OA3 Follow-up of Events and Notices of Enforcement Discretion== | |||
{{IP sample|IP=IP 71153}} | |||
===.1 (Closed) Licensee Event Report 05000285/2016-002-00, Unanalyzed Condition=== | |||
Shutdown Heat Exchanger Isolations | |||
===. | ====a. Inspection Scope==== | ||
On May 10, 2016, the licensee discovered an unanalyzed condition during scheduled maintenance on the shutdown cooling heat exchanger valves. As part of the maintenance, HCV-484, Shutdown Heat Exchanger AC-4A Component Cooling Water Outlet Valve, and HCV-481, Shutdown Cooling Heat Exchanger AC-4B Component Cooling Water Inlet Valve, were failed open which rendered both valves inoperable. | |||
Under these conditions, with the assumed single failure loss of DC control power during a loss of coolant accident (LOCA), component cooling water (CCW) would be allowed to flow through both shutdown cooling heat exchangers, effectively reducing CCW system flow to the containment air cooling units. These conditions are not assumed under plant design basis calculations and placed the plant in an unanalyzed condition. It has not been demonstrated that the CCW system would adequately perform its design function of providing a cooling medium for the containment atmosphere under LOCA conditions with CCW flow diverted through both shutdown cooling heat exchangers. With two containment air cooling units inoperable, Technical Specification 2.4, Containment Cooling, does not provide an associated action; therefore, Technical Specification 2.0.1 applies, which requires the unit to be shut down within 6 hours. Upon completion of the maintenance activity, both valves were returned to service which eliminated the condition. The licensee conducted an extent of condition review and identified that they had created this unanalyzed condition six times within the last 3 years and had exceeded the Technical Specification 2.0.1 6-hour shutdown action statement on March 8, 2016, April 21, 2016, and May 10, 2016. | |||
The NRC inspectors reviewed the details of this condition including corrective action documents, apparent cause analyses, system descriptions and drawings, and procedures. Based on a review of the condition, the inspectors determined that during the maintenance periods, the licensee was in violation of Technical Specification 2.0.1, which requires the unit to be shut down within 6 hours in the event a limiting condition for operation and/or associated action requirement cannot be satisfied because of circumstances in excess of those addressed in the specification. On March 8, 2016, April 21, 2016, and May 10, 2016, the licensee operated in the unanalyzed condition for longer than 6 hours and did not shut down the unit. | |||
This LER is closed. | This LER is closed. | ||
====b. Findings==== | ====b. Findings==== | ||
This violation was identified by the licensee and is discussed in further detail in Section | This violation was identified by the licensee and is discussed in further detail in Section 4OA7 of this report. | ||
===.2 (Closed) Licensee Event Report 05000285/2016=== | ===.2 (Closed) Licensee Event Report 05000285/2016-002-01, Unanalyzed Condition=== | ||
Shutdown Heat Exchanger Isolations | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
This licensee event report (LER) described additional, amplifying information to that contained in LER 2016-002-00, issued on July 7, 2016. The original LER described an unanalyzed condition that was discovered as a result of maintenance on two shutdown cooling heat exchanger valves. The inspectors identified that the licensee failed to include all applicable reporting codes per 10 CFR 50.73 when the licensee submitted the original LER. Specifically, when the original LER was submitted, the | This licensee event report (LER) described additional, amplifying information to that contained in LER 2016-002-00, issued on July 7, 2016. The original LER described an unanalyzed condition that was discovered as a result of maintenance on two shutdown cooling heat exchanger valves. The inspectors identified that the licensee failed to include all applicable reporting codes per 10 CFR 50.73 when the licensee submitted the original LER. Specifically, when the original LER was submitted, the 10 CFR 50.73(a)(2)(i)(B) reporting criterion was not checked to indicate that the unanalyzed condition was also a condition prohibited by the plants technical specifications. Although this issue should be corrected, it constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section 2 of the Enforcement Policy. This violation was placed into the licensees corrective action program as CR 2016-07637. This revision to the original LER restores compliance with 10 CFR 50.73 and also provides clarification on the safety significance of the unanalyzed condition. | ||
10 CFR 50.73(a)(2)(i)(B) reporting criterion was not checked to indicate that the unanalyzed condition was also a condition prohibited by the | |||
This LER is closed. | This LER is closed. | ||
Line 502: | Line 469: | ||
No findings were identified. | No findings were identified. | ||
===.3 (Closed) Licensee Event Report 05000285/2016=== | ===.3 (Closed) Licensee Event Report 05000285/2016-003-00, Unplanned Turbine Trip during=== | ||
DCS Modification due to Failure to Identify and Disable the Transmitter Deviation Based Trip | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
On June 22, 2016, the licensee | On June 22, 2016, the licensee experienced an automatic turbine trip which resulted in an automatic reactor protective system (RPS) actuation and reactor trip. During follow-up of the event, the licensee discovered that the trip occurred during post-modification testing activities on a turbine emergency trip system pressure loop trip. The licensee initiated a root cause evaluation to evaluate the cause of the event. The licensee determined that a modification activity that was intended to eliminate a single point vulnerability in the emergency trip system pressure loop had been inappropriately implemented and had not undergone necessary reviews and validation during the modification planning process. As a result, engineering and operations personnel had failed to identify and disable a transmitter deviation-based trip during post-maintenance testing activities. The testing configuration triggered the two transmitters-in-deviation trip for the emergency trip system loop and initiated the turbine trip. The licensees evaluation concluded that the root cause was associated with organizational weaknesses with the maintenance, implementation, and challenging of the emergent work process. Specifically, shift management failed to set and enforce standards related to the emergent work process. Corrective actions included creation of improved standards for engineering and operations personnel during work on emergent work packages and technical engineering products. | ||
-up of the event, the licensee discovered that the trip occurred during post-modification testing activities on a turbine emergency trip system pressure loop trip. | |||
The licensee initiated a root cause evaluation to evaluate the cause of the event. The licensee determined that a modification activity that was intended to eliminate a single point vulnerability in the emergency trip system pressure loop had been inappropriately implemented and had not undergone necessary reviews and validation during the modification planning process. | |||
As a result, engineering and operations personnel had failed to identify and disable a transmitter deviation | |||
-based trip during post | |||
-maintenance testing activities. | |||
-in-deviation trip for the emergency trip system loop and initiated the turbine trip. The | |||
Corrective actions included creation of improved standards for engineering and operations personnel during work on emergent work packages and technical engineering products | |||
The inspectors reviewed the root cause evaluation, the corrective actions, and the LER for the event to determine whether the causal analysis was thorough, the corrective actions appropriately | The licensee reported this issue at the time of the event under 10 CFR 50.72(b)(2)(iv)(B)as a 4-hour report for an RPS actuation while the reactor was critical, and under 50.72(b)(3)(iv)(A) as an 8-hour report for a valid specified system actuation (RPS). In addition, on August 22, 2016, the licensee reported the event under 10 CFR 50.73(a)(2)(iv)(A), as a licensee event report (LER) for a valid specified system actuation (RPS). The inspectors reviewed the root cause evaluation, the corrective actions, and the LER for the event to determine whether the causal analysis was thorough, the corrective actions appropriately addressed the condition and causes, and the appropriate NRC reporting requirements were met. | ||
This LER is closed. | This LER is closed. | ||
====b. Findings==== | ====b. Findings==== | ||
One finding associated with this event was previously documented in the second quarter resident inspector NRC Integrated Inspection Report ( | One finding associated with this event was previously documented in the second quarter resident inspector NRC Integrated Inspection Report (05000285/2016002-02, Failure to Develop Adequate Procedures for Post-Modification Testing). No additional findings were identified. | ||
-02, | |||
-Modification Testing | |||
===.4 (Closed) Licensee Event Report 05000285/2016=== | ===.4 (Closed) Licensee Event Report 05000285/2016-004-00, Unanalyzed Condition for=== | ||
Potential Tornado-Borne Missile Impact to the Raw Water System | |||
-Borne Missile Impact to the Raw Water System | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
On August 25, 2016, the licensee identified that a tornado missile strike on diesel | On August 25, 2016, the licensee identified that a tornado missile strike on diesel-driven fire water pump FP-1B or associated piping had not been addressed during the 2013 tornado missile project. As such, a missile strike affecting pump FP-1B or its associated piping could cause a larger volume of water to enter the raw water pump vault than had previously been analyzed. An operability evaluation was conducted and compensatory measures were implemented to disable pump FP-1B and isolate associated piping upon entering a severe thunderstorm or tornado watch per their Abnormal Operating Procedure AOP-01, Acts of Nature. | ||
-driven fire water pump FP | |||
-1B or associated piping had not been addressed during the 2013 tornado missile project. As such, a missile strike affecting pump FP-1B or its associated piping could cause a larger volume of water to enter the raw water pump vault than had previously been analyzed. An operability evaluation was conducted and compensatory measures were implemented to disable pump FP-1B and isolate associated piping upon entering a severe thunderstorm or tornado watch per their Abnormal Operating Procedure AOP-01, | |||
The NRC inspectors reviewed the details of this condition including corrective actions and compensatory measures implemented to maintain operability. Based on review of the condition, the inspectors determined that the licensee was previously ineffective in implementing corrective actions to address all missile hazards that could impact safety-related equipment when this was originally identified as a concern in 2013. | |||
Specifically, the vulnerability to a missile strike upon pump FP-1B and associated piping was discussed during the 2013 tornado missile project. However, the postulated tornado missile strike on the intake structure which impacts the pump and associated piping was not addressed nor were corrective actions taken to protect the raw water pump vault at that time. | |||
This LER is closed. | |||
====b. Findings==== | ====b. Findings==== | ||
This violation was identified by the licensee and is discussed in further detail in Section | This violation was identified by the licensee and is discussed in further detail in Section 4OA7 of this report. | ||
These activities constituted completion of four event follow-up samples, as defined in Inspection Procedure 71153. | |||
{{a|4OA6}} | |||
==4OA6 Meetings, Including Exit== | |||
===Exit Meeting Summary=== | ===Exit Meeting Summary=== | ||
On November 10, 2016 , the inspector presented the radiation safety inspection results to Mr. T. Tierney, Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspector had been returned or destroyed. | On November 10, 2016, the inspector presented the radiation safety inspection results to Mr. T. Tierney, Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspector had been returned or destroyed. | ||
On December 2, 2016, the inspector presented the results of the onsite inspection of the | On December 2, 2016, the inspector presented the results of the onsite inspection of the licensees emergency preparedness program to Mr. S. Marik, Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed. | ||
S. Marik, Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed. | On January 11, 2017, the inspectors presented the inspection results to Mr. S. Marik, Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed. | ||
{{a|4OA7}} | |||
==4OA7 Licensee-Identified Violations== | |||
The following licensee-identified violations of NRC requirements were determined to be of very low safety significance (Green) or Severity Level IV and meet the NRC Enforcement Policy criteria for being dispositioned as non-cited violations: | |||
-identified violations of NRC requirements were determined to be of very low safety significance (Green) or Severity Level IV and meet the NRC Enforcement Policy criteria for being dispositioned as non-cited violations: | * Technical Specification 2.0.1 requires the unit to be shut down within 6 hours in the event a limiting condition for operation and/or associated action requirement cannot be satisfied because of circumstances in excess of those addressed in the specification. | ||
Technical Specification 2.0.1 requires the unit to be shut down within 6 hours in the event a limiting condition for operation and/or associated action requirement cannot be satisfied because of circumstances in excess of those addressed in the specification | |||
Contrary to the above, the licensee failed to enter Technical Specification 2.0.1 and take the prescribed actions on several occasions when shutdown cooling heat exchanger valves were opened which impacted component cooling water (CCW) flow to the containment air cooling units under certain accident conditions. | |||
On May 10, 2016, an unanalyzed condition was discovered during scheduled maintenance on the shutdown cooling heat exchanger valves. As part of the maintenance, HCV-484, Shutdown Heat Exchanger AC-4A Component Cooling Water Outlet Valve, and HCV-481, Shutdown Cooling Heat Exchanger AC-4B Component Cooling Water Inlet Valve, were failed open which rendered both valves inoperable. | |||
Under these conditions, with the assumed single failure loss of DC control power during a loss of coolant accident (LOCA), CCW would be allowed to flow through both shutdown cooling heat exchangers, effectively reducing CCW system flow to the containment air cooling units. These conditions are not assumed under plant design basis calculations and placed the plant in an unanalyzed condition. It has not been demonstrated that the CCW system would adequately perform its design function of providing a cooling medium for the containment atmosphere under LOCA conditions with CCW flow diverted through the shutdown cooling heat exchangers. With two containment air cooling units inoperable, Technical Specification 2.4, does not provide an associated action; therefore, Technical Specification 2.0.1 applies. Upon completion of the maintenance activity, both valves were returned to service which eliminated the condition. The licensee conducted an extent of condition review and identified that they had created this unanalyzed condition six times within the last 3 years and had exceeded the Technical Specification 2.0.1 6-hour shutdown action statement on March 8, 2016; April 21, 2016; and May 10, 2016. In addition, the licensee determined this condition was first identified on February 3, 2015, in Condition Report 2015-01388. | |||
- | |||
Procedure TDB-VIII, Equipment Applicability Guidance, Revision 64, incorrectly stated the valves had a required safety function in the open direction. The licensee initiated procedure change EC-68088 on September 26, 2015, to correct the procedure; however, the proposed change did not accurately reflect the safety function of the valves to remain closed for all LOCA conditions. This procedure change was still under review on May 10, 2016. The failure to promptly correct Procedure TDB-VIII was a contributing cause of the violation. | |||
. This was | |||
The violation is more than minor because it is associated with the configuration control attribute of the Mitigating Systems Cornerstone. On March 8, 2016; April 21, 2016; and May 10, 2016, the plant was placed in a condition prohibited by technical specifications and exceeded the Technical Specification 2.0.1, 6-hour shutdown action statement. | |||
Title 10 of the Code of Federal Regulations, Part 50.9(a), requires that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on December 26 , 2014, Fort Calhoun Station provided information to the Commission which was not complete and accurate in all material respects. Specifically, a license amendment request (ML14365A123) to adopt a scheme of emergency action levels based on Nuclear Energy Institute Document 99-02, Revision 6, contained inaccurate information about the characteristics of the cask used in the | This adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. A senior reactor analyst qualitatively determined that this finding was of very low safety significance (Green) for increases in core damage frequency and large early release frequency because of the short exposure time of less than 3 days and because of the low frequency of events where a LOCA with an independent and coincidental loss of DC control power would occur. Therefore, this finding screens to Green. The licensee entered the issue into their corrective action program as Condition Reports 2016-05340 and 2016-04468. | ||
, as a result | * Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, though the licensee identified a potential vulnerability to raw water pumps from a missile hazard striking diesel driven fire pump FP-1B or associated piping during review of missile hazards during the 2013 tornado missile project, the licensee failed to evaluate this condition or specify a modification to the plant to protect the raw water pumps at that time. This was discovered on August 25, 2016, by the licensee during a design review. This finding is of very low safety significance (Green) considering compensatory measures that were put in place to disable pump FP-1B and isolate associated piping when severe weather is forecast and the very low probability of the postulated event. This issue was entered into the licensees corrective action program as CR 2016-06972. | ||
, incorrect external radiation levels were incorporated into emergency action level E-HU1 | * Title 10 of the Code of Federal Regulations, Part 50.9(a), requires that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on December 26, 2014, Fort Calhoun Station provided information to the Commission which was not complete and accurate in all material respects. Specifically, a license amendment request (ML14365A123) to adopt a scheme of emergency action levels based on Nuclear Energy Institute Document 99-02, Revision 6, contained inaccurate information about the characteristics of the cask used in the licensees Independent Spent Fuel Storage Installation and, as a result, incorrect external radiation levels were incorporated into emergency action level E-HU1. | ||
The issue was determined to be a Severity Level IV violation of NRC requirements, in accordance with Section 6.9 of the Enforcement Policy, dated November 1, 2016, because the inaccurate information would not have caused the NRC to reconsider a regulatory position or undertake substantial further inquiry. The issue was documented in the | Subsequently, while preparing another emergency action level submittal, the emergency preparedness staff discovered the incorrect information that had previously been submitted. The issue was determined to be a Severity Level IV violation of NRC requirements, in accordance with Section 6.9 of the Enforcement Policy, dated November 1, 2016, because the inaccurate information would not have caused the NRC to reconsider a regulatory position or undertake substantial further inquiry. The issue was documented in the licensees corrective action program as Condition Report CR-2016-08400. Because the Severity Level IV violation has been entered into the licensees corrective action program, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy. | ||
=SUPPLEMENTAL INFORMATION= | =SUPPLEMENTAL INFORMATION= | ||
Line 623: | Line 572: | ||
===Opened and Closed=== | ===Opened and Closed=== | ||
Failure to Provide Training on Changes to Protective Action | |||
: 05000285/2016004-01 NCV Recommendation Procedures (Section 1EP5) | |||
===Closed=== | ===Closed=== | ||
Unanalyzed Condition Shutdown Heat Exchanger Isolations | |||
: 05000285/2016002-00 LER (Section 4OA3) | |||
: 05000285/2016002 | Unanalyzed Condition Shutdown Heat Exchanger Isolations | ||
- | : 05000285/2016002-01 LER (Section 4OA3) | ||
Unplanned Turbine Trip during DCS Modification due to Failure | |||
: 05000285/2016003-00 LER to Identify and Disable the Transmitter Deviation Based Trip (Section 4OA3) | |||
Unanalyzed Condition for Potential Tornado-Borne Missile | |||
: 05000285/2016004-00 LER Impact to the Raw Water System (Section 4OA3) | |||
-Borne Missile Impact to the Raw Water System | |||
==LIST OF DOCUMENTS REVIEWED== | ==LIST OF DOCUMENTS REVIEWED== | ||
}} | }} |
Latest revision as of 17:25, 19 December 2019
ML17018A386 | |
Person / Time | |
---|---|
Site: | Fort Calhoun |
Issue date: | 01/18/2017 |
From: | Geoffrey Miller NRC/RGN-IV/DRP/RPB-D |
To: | Marik S Omaha Public Power District |
Geoffrey Miller | |
References | |
IR 2016004 | |
Download: ML17018A386 (56) | |
Text
UNITED STATES ary 18, 2017
SUBJECT:
FORT CALHOUN STATION - NRC INTEGRATED INSPECTION REPORT 05000285/2016004
Dear Mr. Marik:
On December 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fort Calhoun Station. On January 11, 2017, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
Further, inspectors documented three licensee-identified violations, which were determined to be of very low safety significance (Green) or Severity Level IV, in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC inspector at the Fort Calhoun Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC inspector at the Fort Calhoun Station. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Geoffrey B. Miller, Branch Chief Project Branch D Division of Reactor Projects Docket No. 50-285 License No. DPR-40
Enclosure:
Inspection Report 05000285/2016004 w/ Attachment:
1. Supplemental Information 2. O
REGION IV==
Docket: 50-285 License: DPR-40 Report: 05000285/2016004 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, NE 68008 Dates: October 1 through December 31, 2016 Inspectors: S. Schneider, Senior Resident Inspector P. Voss, Senior Resident Inspector L. Brandt, Acting Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspector S. Hedger, Operations Engineer J. ODonnell, CHP, Health Physicist Approved Geoffrey B. Miller By: Chief, Project Branch D Division of Reactor Projects Enclosure
SUMMARY
IR 05000285/2016004; 10/01/2016 - 12/31/2016; Fort Calhoun Station; Maintenance of
The inspection activities described in this report were performed between October 1 and December 31, 2016, by the resident inspectors at Fort Calhoun Station, inspectors from the NRCs Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented in this report three licensee-identified violations of very low safety significance (Green) or Severity Level IV. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609,
Significance Determination Process, dated April 29, 2015. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, dated July 2016.
Cornerstone: Emergency Preparedness
- Green.
The inspector reviewed a self-revealed non-cited violation associated with Fort Calhoun Stations failure to provide radiological emergency response training to those who may be called upon to assist in an emergency, as required by 10 CFR 50.47(b)(15).
Specifically, in December 2014, 10 shift managers and 6 Technical Support Center and Emergency Operations Facility staff, responsible for making and reviewing protective action recommendations, were not trained on Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and flowchart EP-FC-111-AD-F-02, before they were implemented on December 23, 2014. As immediate corrective actions, the licensee issued a reading package covering the new protective action recommendation process to the 16 individuals who had not been trained. The issue was entered into the licensees corrective action program as Condition Report CR-2015-08951.
The failure to provide radiological emergency response training to those who may be called upon to assist in an emergency is a performance deficiency within the licensees ability to foresee and correct. The performance deficiency was more than minor because it was associated with the procedure quality attribute of Emergency Prepardness Cornerstone and adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015, and was determined to be of very low safety significance (Green) because it was a failure to comply, was not a risk significant planning standard function, was not a loss of the planning standard function, and was a degraded planning standard function. This finding had a cross-cutting aspect in the area of human performance associated with change management because the emergency preparedness department failed to identify all of the emergency response organization staff who required training on revisions to the process for making protective action recommendations [H.3].
(Section 1EP5)
Licensee-Identified Violations
Violations of very low safety significance (Green) or Severity Level IV that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report.
PLANT STATUS
On October 1, 2016, the Fort Calhoun Station (FCS) was at 97.8 percent power following the commencement of a coastdown on September 29, 2016. On October 24, 2016, FCS completed a final shutdown of the plant to commence a defueling outage in support of the permanent decommissioning of the plant. On November 13, 2016, FCS issued the defueling certification letter to the NRC.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
On November 3, 2016, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for cold weather operations and evaluated the licensees implementation of these procedures. The inspectors verified that prior to the onset of cold weather, the licensee had corrected weather-related equipment deficiencies identified during the previous winter.
The inspectors selected three risk-significant systems that were required to be protected from cold weather:
- Intake Structure
- Raw Water
- Control Room Air Conditioning The inspectors reviewed the licensees procedures and design information to ensure the systems would remain functional when challenged by cold weather. The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the cold weather protection features.
These activities constituted one sample of readiness for seasonal adverse weather, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial Walk-Down
a. Inspection Scope
The inspectors performed partial system walk-downs of the following risk-significant systems:
- October 21, 2016, control room air conditioning and ventilation system
- October 23, 2016, raw water system following raw water pump AC-10B in-service test
- October 28, 2016, shutdown cooling system
- November 18, 2016, component cooling water system following maintenance on component cooling water pump AC-3C
- December 2, 2016, spent fuel pool cooling system The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.
These activities constituted five partial system walk-down samples, as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R05 Fire Protection
Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on five plant areas important to safety:
- October 9, 2016, control room, fire area 42
- October 9, 2016, cable spreading room, fire area 41
- November 1, 2016, containment, fire area 30
- November 15, 2016, room 69 ventilation area, fire area 20-7
- November 15, 2016, upper electrical penetration room, fire area 34B-1 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constituted five quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On October 18, 2016, the inspectors observed simulator training for an operating crew preparing for the upcoming plant shutdown. The crew performed the planned down power evolution leading into the shutdown while addressing abnormal conditions included by the evaluation staff. Specifically, the crew was evaluated addressing a malfunction with the chemical volume and control system during a boration, as well as a stuck turbine control valve on the main turbine. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during training.
These activities constituted completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
a. Inspection Scope
The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity or risk. The inspectors observed the operators performance of the following activities:
- October 19, 2016, operators preparing for quarterly in-service test of raw water pump AC-10B
- October 20, 2016, operators completing containment wide range pressure instrument channel and core reactivity surveillance testing and adjusting nitrogen blanket pressure in the component cooling water expansion tank
- October 21, 2016, operators responding to a smoke detector alarm and reports of an acrid odor in one of the plant areas
- October 24, 2016, downpower maneuvers, manual trip, and post trip actions
- October 26, 2016, power operated relief valve low temperature low pressure surveillance test
- November 2, 2016, reactor coolant system drain down to lowered inventory
- November 4, 2016, reactor coolant system flood-up brief In addition, the inspectors assessed the operators adherence to plant procedures and other operations department policies.
These activities constituted completion of seven quarterly licensed operator performance samples, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed three risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:
- October 12, 2016, planned yellow risk during emergency diesel generator 1 testing
- October 26, 2016, planned yellow risk for power operated relief valve low temperature low pressure surveillance test
- November 4, 2016, planned yellow risk for heavy load lift over the reactor vessel The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.
These activities constituted completion of three maintenance risk assessment inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed three operability determinations and functionality assessments that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs):
- October 4, 2016, operability determination of MasterPact breaker fail to close technical bulletin and impact on Fort Calhoun Station breakers
- November 22, 2016, functionality assessment of Allen-Bradley 700 RTC relay susceptibility to electromagnetic interference and radio frequency interference
- December 2, 2016, functionality assessment of component cooling water surge tank pressure and level control in manual versus automatic The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC.
These activities constituted completion of three operability and functionality review samples, as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed four post-maintenance testing activities that affected risk-significant SSCs:
- October 7, 2016, penetration M-45 Type C local leak rate post-maintenance test
- October 20, 2016, control room air conditioning and air filtration system post-maintenance test
- November 17, 2016, component cooling water pump AC-3C post-maintenance test
- December 14, 2016, raw water system strainer AC-12B post-maintenance test The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests or reviewed the results to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.
These activities constituted completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
During the stations defueling outage that concluded on November 11, 2016, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following:
- Review of the licensees outage plan prior to the outage
- Review and verification of the licensees fatigue management activities
- Monitoring of shutdown and cooldown activities
- Verification that the licensee maintained defense-in-depth during outage activities
- Observation and review of reduced-inventory activities
- Observation and review of fuel handling activities These activities constituted completion of one defueling outage sample, as defined in Inspection Procedure 71111.20.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed seven risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:
In-service tests:
- October 13, 2016, raw water system Category C valve in-service test
- October 25, 2016, raw water pump AC-10B in-service test Other surveillance tests:
- October 13, 2016, reactor coolant system flow rate determination by heat balance
- October 14, 2016, auxiliary feedwater pump FW-6 surveillance test
- October 20, 2016, emergency diesel generator 2 surveillance test
- October 26, 2016, power operated relief valve low temperature low pressure surveillance test
- November 3, 2016, personnel access lock o-ring seal surveillance test The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.
These activities constituted completion of seven surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Testing
a. Inspection Scope
The inspector verified the adequacy of the licensees methods for testing the primary and backup alert and notification system (ANS). The inspector interviewed licensee personnel responsible for the maintenance of the primary and backup ANS and reviewed a sample of corrective action system reports written for ANS problems. The inspector compared the licensees alert and notification system testing program with criteria in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1; FEMA Report REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants; and the licensees current FEMA-approved alert and notification system design report, Updated Design Report to FEMA for the Outdoor Public Warning System and Backup Alert and Notification, as approved in a letter from Mr. R. McCabe, Chief, Technological Hazards Branch, FEMA Region VII, dated December 17, 2012.
These activities constituted completion of one alert and notification system evaluation sample, as defined in Inspection Procedure 71114.02.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System
a. Inspection Scope
The inspector verified that the licensees emergency response organization on-shift and augmentation staffing levels were in accordance with the licensees emergency plan commitments. The inspector reviewed documentation and discussed with licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to verify the adequacy of the licensees methods for staffing emergency response facilities, including the licensees ability to staff pre-planned alternate facilities.
The inspector also reviewed records of emergency response organization augmentation tests and events to determine whether the licensee had maintained a capability to staff emergency response facilities within emergency plan timeliness commitments.
These activities constituted completion of one emergency response organization staffing and augmentation testing sample, as defined in Inspection Procedure 71114.03.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The inspector performed an on-site review of the Fort Calhoun Radiological Emergency Response Plan, Sections A, B, F, G, H, J, K, and O, and Appendix A, Revision 0; Procedure EP-FC-110-200, Dose Assessment, Revision 0; and EP-FC-1001, Addendum 3, Emergency Action Levels, Revision 2. These revisions:
- Removed references to the security department staffing the fire brigade
- Removed references to the Blair Industrial Park Co-op phone
- Replaced references to Stone and Webster Engineering Corporation with Tierney-Blair LLC
- Replaced references to the Fremont fire department with references to the Elkhorn Decontamination Center
- Added making initial notifications to the NRC to the shift technical advisors duties
- Added satellite phones as required communication systems
- Reassigned the maintenance and replacement of radiation protection equipment inventories from emergency planning to the radiation protection department
- Revised the frequency of CPR training
- Implemented the utility revision of the Radiological Assessment System for Consequence Analysis (RASCAL) dose assessment program
- Revised external radiation levels in emergency action level E-HU1
- Revised procedure titles and procedure numbers throughout the document These revisions were compared to their previous revisions; to the criteria of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1; to NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6, dated November 2012; and to the standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that the revisions did not decrease the effectiveness of the emergency plan. This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection.
These activities constituted completion of three emergency action level and emergency plan changes samples, as defined in Inspection Procedure 71114.04.
b. Findings
No findings were identified.
1EP5 Maintenance of Emergency Preparedness
a. Inspection Scope
The inspector reviewed the following for the period November 2014 through November 2016:
- After-action reports for emergency classifications
- After-action evaluation reports for licensee drills and exercises
- Independent audits and surveillances of the licensees emergency preparedness program
- Self-assessments of the emergency preparedness program conducted by the licensee
- Licensee evaluations of changes made to the Emergency Plan and Emergency Plan Implementing Procedures
- Drill and exercise performance issues entered into the licensees corrective action program
- Emergency preparedness program issues entered into the licensees corrective action program
- Maintenance records for equipment supporting the emergency preparedness program
- Emergency response organization and emergency planner training records The inspector reviewed summaries of 356 corrective action program reports associated with emergency preparedness and selected 15 to review against program requirements, to determine the licensees ability to identify, evaluate, and correct problems in accordance with the requirements of planning standard 10 CFR 50.47(b)(14) and 10 CFR Part 50, Appendix E, Section IV.F. The inspector verified that the licensee accurately and appropriately identified and corrected emergency preparedness weaknesses during critiques and assessments.
The inspector reviewed summaries of 30 licensee evaluations of the impact of changes to the emergency plan and implementing procedures, and selected five to review against program requirements to determine the licensees ability to identify reductions in the effectiveness of the emergency plan, in accordance with the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that evaluations of proposed changes to the licensee emergency plan appropriately identified the impact of the changes prior to being implemented.
These activities constituted completion of one sample of the maintenance of the licensees emergency preparedness program, as defined in Inspection Procedure 71114.05.
b. Findings
Introduction.
The inspector reviewed a self-revealed, Green, non-cited violation associated with Fort Calhoun Stations failure to provide radiological emergency response training to those who may be called upon to assist in an emergency, as required by 10 CFR 50.47(b)(15). Specifically, in December 2014, 10 shift managers and 6 Technical Support Center and Emergency Operations Facility staff members, responsible for making and reviewing protective action recommendations, were not trained on Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and flowchart EP-FC-111-AD-F-02, before they were implemented on December 23, 2014.
Description.
Fort Calhoun Station implemented Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and associated flowchart EP-FC-111-AD-F-02 on December 23, 2014 (ML15023A126). The emergency preparedness department had previously determined that training on the procedure revision was required for emergency response organization personnel responsible for making or reviewing protective action recommendations made to offsite authorities for protecting the health and safety of the public. Emergency preparedness staff conducted two classroom training sessions for Technical Support Center and Emergency Operations Facility staff prior to implementing the procedure change, training 23 persons. The emergency preparedness department did not verify that all required individuals attended the training.
Subsequent to implementing Procedure EPIP-EOF-7, Revision 26, a senior reactor operator failed to correctly make a protective action recommendation during routine licensed operator training in the control room simulator. Following the operators failure to correctly recommend protective actions, the licensee determined that six Technical Support Center and Emergency Operations Facility staff failed to attend the training on Procedure EPIP-EOF-7, and therefore, lacked training before the procedure was implemented. In addition, the licensee determined the emergency preparedness staff relied on the routine licensed operator training program to train the shift managers on the revised procedure. As a result, none of the licensees 10 shift managers (on-shift emergency coordinators) received the training. The licensee entered this issue into their corrective action program as Condition Report CR-2015-08951. As immediate corrective action, the licensee issued a reading package covering the new protective action recommendation process to the 16 individuals who had not been trained.
Analysis.
The failure to provide radiological emergency response training to those who may be called upon to assist in an emergency is a performance deficiency within the licensees ability to foresee and correct. The performance deficiency was more than minor because it was associated with the procedure quality attribute of Emergency Prepardness Cornerstone and adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, personnel unfamiliar with procedures for making protective action recommendations may not make accurate or timely recommendations to protect the health and safety of the public. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015, and was determined to be of very low safety significance (Green) because it was a failure to comply, was not a risk significant planning standard function, was not a loss of the planning standard function, and was a degraded planning standard function. The planning standard function was degraded because training was only provided to 23 of 39 individuals requiring training. This finding had a cross-cutting aspect in the area of human performance associated with change management because the emergency preparedness department failed to do a thorough analysis of the emergency response organization staff who were required to be trained on revisions to the process for making protective action recommendations to offsite authorities [H.3].
Enforcement.
Title 10 CFR 50.47(b)(15), requires that radiological emergency response training is provided to those who may be called upon to assist in an emergency.
Contrary to above, on December 23, 2014, Fort Calhoun Station failed to provide radiological emergency response training to those who may be called upon to assist in an emergency. Specifically, the licensee failed to provide training to 16 emergency response organization staff on Procedure EPIP-EOF-7, Protective Action Recommendations, Revision 26, and associated flowchart EP-FC-111-AD-F-02. The licensee restored compliance by issuing a reading package covering the new protective action recommendation process to the 16 persons who had not been trained in December 2014 and verified that each person reviewed the package. Because this violation is of very low safety significance (Green) and was entered into the licensees corrective action program as Condition Report CR-2015-08951, this violation is being treated as a non-cited violation in accordance with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000285/2016004-01, Failure to Provide Training on Changes to Protective Action Recommendation Procedures)
RADIATION SAFETY
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
The inspector assessed licensee performance with respect to maintaining individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspector performed this portion of the attachment during the defueling outage in order to directly observe the licensees ALARA process activities, including planning, implementation of radiological work controls, execution of work activities, and ALARA review of work-in-progress. During the inspection, the inspector interviewed licensee personnel, reviewed licensee documents, and evaluated licensee performance in the following areas:
- Implementation of ALARA and radiological work controls. The inspector observed pre-job briefings, reviewed planned radiological administrative, operational, and engineering controls, and compared the planned controls to field activities.
- Radiation worker and radiation protection technician performance during work activities performed in radiation areas, airborne radioactivity areas, or high radiation areas.
- Problem identification and resolution for ALARA and radiological work controls.
The inspector reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.
These activities constituted completion of two of the five required samples of the occupational ALARA planning and controls program, as defined in Inspection Procedure 71124.02.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspector evaluated whether the licensee controlled in-plant airborne radioactivity concentrations consistent with ALARA principles and that the use of respiratory protection devices did not pose an undue risk to the wearer. During the inspection, the inspector interviewed licensee personnel, walked down various areas in the plant, and reviewed licensee performance in the following areas:
- Engineering controls, including the use of permanent ventilation systems to control airborne radioactivity. The inspector evaluated installed ventilation systems, including review of procedural guidance, verified the systems were used during high-risk activities, and verified airflow capacity, flow path, and filter/charcoal unit efficiencies. Additionally, the inspector evaluated the licensees airborne monitoring protocols, including verification that alarms and set points were appropriate.
- Use of respiratory protection devices, including an evaluation of the licensees respiratory protection program for use, storage, maintenance, and quality assurance of National Institute for Occupational Safety and Health (NIOSH)certified equipment, air quality and quantity for supplied-air devices and self-contained breathing apparatus (SCBA) bottles, qualification and training of personnel, and user performance.
- Self-contained breathing apparatus for emergency use, including the licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, hydrostatic testing of SCBA bottles, status of SCBA staged and ready for use in the plant including vision correction, mask sizes, etc., SCBA surveillance and maintenance records, and personnel qualification, training, and readiness.
- Problem identification and resolution for airborne radioactivity control and mitigation. The inspector reviewed audits, self-assessments, and corrective action documents to verify problems were being identified and properly addressed for resolution.
These activities constituted completion of the four required samples of the in-plant airborne radioactivity control and mitigation program, as defined in Inspection Procedure 71124.03.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspector evaluated the accuracy and operability of the licensees personnel monitoring equipment, verified the accuracy and effectiveness of the licensees methods for determining total effective dose equivalent, and verified that the licensee was appropriately monitoring occupational dose. The inspector interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:
- Source term characterization, including characterization of radiation types and energies, hard-to-detect isotopes, and scaling factors.
- External dosimetry including National Voluntary Laboratory Accreditation Program (NVLAP) accreditation, storage, issue, use, and processing of active and passive dosimeters.
- Internal dosimetry, including the licensees use of whole body counting and dose assessments based on airborne monitoring.
- Special dosimetry situations, including declared pregnant workers, dosimeter placement, and neutron dose assessment.
- Problem identification and resolution for occupational dose assessment. The inspector reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.
These activities constituted completion of the five required samples of the occupational dose assessment program, as defined in Inspection Procedure 71124.04.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Mitigating Systems Performance Index: Emergency AC Power Systems (MS06)
a. Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the period of October 1, 2015 through September 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the mitigating system performance index for emergency ac power systems, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index: Residual Heat Removal Systems (MS09)
a. Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the period of October 1, 2015 through September 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the mitigating system performance index for residual heat removal systems, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Reactor Coolant System Specific Activity (BI01)
a. Inspection Scope
The inspectors reviewed the licensees reactor coolant system chemistry sample analyses for the period of October 1, 2015 through September 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the reactor coolant system specific activity performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.4 Drill/Exercise Performance (EP01)
a. Inspection Scope
The inspector reviewed selected drill, exercise, and training sessions conducted between April 2015 and September 2016 to verify the accuracy of the licensees data for classification, notification, and protective action recommendation opportunities. The inspectors reviewed a sample of the licensees completed classifications, notifications, and protective action recommendations to verify their timeliness and accuracy. The inspector used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.
These activities constituted verification of the drill/exercise performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.5 Emergency Response Organization Drill Participation (EP02)
a. Inspection Scope
The inspector reviewed licensee records for participation in drill, exercise, and training sessions conducted between April 2015 and September 2016 to verify the accuracy of the licensees data for drill participation opportunities. The inspector verified that all members of the licensees emergency response organization (ERO) in the identified key positions had been counted in the reported performance indicator data. The inspector reviewed the licensees basis for reporting the percentage of ERO members who participated in a drill. The inspector reviewed drill attendance records and verified a sample of those reported as participating. The inspector used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.
These activities constituted verification of the emergency response organization drill participation performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.6 Alert and Notification System Reliability (EP03)
a. Inspection Scope
The inspector reviewed the licensees records of alert and notification system tests conducted between April 2015 and September 2016 to verify the accuracy of the licensees data for siren system testing opportunities. The inspector reviewed procedural guidance on assessing alert and notification system opportunities and the results of periodic alert and notification system operability tests. The inspector used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.
These activities constituted verification of the alert and notification system reliability performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
b. Findings
No findings were identified.
.2 Semiannual Trend Review
a. Inspection Scope
The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends.
These activities constituted completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.
b. Observations and Assessments In NRC Inspection Report 05000285/2016002, the inspectors documented a continuing adverse trend in equipment reliability at Fort Calhoun Station. The inspectors reviewed equipment reliability challenges in 2016 through the fourth quarter. These challenges resulted in equipment unavailability, unplanned technical specification entries, and operator burdens. Examples of equipment reliability issues during 2016 included a chemical and volume control system leak in January, a component cooling water pump motor failure in February, and a high pressure safety injection pump suction valve weld failure in March. In 2016, the licensee continued to reduce backlogs in open operability determinations and temporary configuration changes. In addition, the licensees plant health committee continued to focus on their Top 10 equipment list to resolve critical items. The inspectors have determined that the licensees progress in improving equipment reliability at the Fort Calhoun Station is sufficient to warrant closure of this trend.
c. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
.1 (Closed) Licensee Event Report 05000285/2016-002-00, Unanalyzed Condition
Shutdown Heat Exchanger Isolations
a. Inspection Scope
On May 10, 2016, the licensee discovered an unanalyzed condition during scheduled maintenance on the shutdown cooling heat exchanger valves. As part of the maintenance, HCV-484, Shutdown Heat Exchanger AC-4A Component Cooling Water Outlet Valve, and HCV-481, Shutdown Cooling Heat Exchanger AC-4B Component Cooling Water Inlet Valve, were failed open which rendered both valves inoperable.
Under these conditions, with the assumed single failure loss of DC control power during a loss of coolant accident (LOCA), component cooling water (CCW) would be allowed to flow through both shutdown cooling heat exchangers, effectively reducing CCW system flow to the containment air cooling units. These conditions are not assumed under plant design basis calculations and placed the plant in an unanalyzed condition. It has not been demonstrated that the CCW system would adequately perform its design function of providing a cooling medium for the containment atmosphere under LOCA conditions with CCW flow diverted through both shutdown cooling heat exchangers. With two containment air cooling units inoperable, Technical Specification 2.4, Containment Cooling, does not provide an associated action; therefore, Technical Specification 2.0.1 applies, which requires the unit to be shut down within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Upon completion of the maintenance activity, both valves were returned to service which eliminated the condition. The licensee conducted an extent of condition review and identified that they had created this unanalyzed condition six times within the last 3 years and had exceeded the Technical Specification 2.0.1 6-hour shutdown action statement on March 8, 2016, April 21, 2016, and May 10, 2016.
The NRC inspectors reviewed the details of this condition including corrective action documents, apparent cause analyses, system descriptions and drawings, and procedures. Based on a review of the condition, the inspectors determined that during the maintenance periods, the licensee was in violation of Technical Specification 2.0.1, which requires the unit to be shut down within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in the event a limiting condition for operation and/or associated action requirement cannot be satisfied because of circumstances in excess of those addressed in the specification. On March 8, 2016, April 21, 2016, and May 10, 2016, the licensee operated in the unanalyzed condition for longer than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and did not shut down the unit.
This LER is closed.
b. Findings
This violation was identified by the licensee and is discussed in further detail in Section 4OA7 of this report.
.2 (Closed) Licensee Event Report 05000285/2016-002-01, Unanalyzed Condition
Shutdown Heat Exchanger Isolations
a. Inspection Scope
This licensee event report (LER) described additional, amplifying information to that contained in LER 2016-002-00, issued on July 7, 2016. The original LER described an unanalyzed condition that was discovered as a result of maintenance on two shutdown cooling heat exchanger valves. The inspectors identified that the licensee failed to include all applicable reporting codes per 10 CFR 50.73 when the licensee submitted the original LER. Specifically, when the original LER was submitted, the 10 CFR 50.73(a)(2)(i)(B) reporting criterion was not checked to indicate that the unanalyzed condition was also a condition prohibited by the plants technical specifications. Although this issue should be corrected, it constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section 2 of the Enforcement Policy. This violation was placed into the licensees corrective action program as CR 2016-07637. This revision to the original LER restores compliance with 10 CFR 50.73 and also provides clarification on the safety significance of the unanalyzed condition.
This LER is closed.
b. Findings
No findings were identified.
.3 (Closed) Licensee Event Report 05000285/2016-003-00, Unplanned Turbine Trip during
DCS Modification due to Failure to Identify and Disable the Transmitter Deviation Based Trip
a. Inspection Scope
On June 22, 2016, the licensee experienced an automatic turbine trip which resulted in an automatic reactor protective system (RPS) actuation and reactor trip. During follow-up of the event, the licensee discovered that the trip occurred during post-modification testing activities on a turbine emergency trip system pressure loop trip. The licensee initiated a root cause evaluation to evaluate the cause of the event. The licensee determined that a modification activity that was intended to eliminate a single point vulnerability in the emergency trip system pressure loop had been inappropriately implemented and had not undergone necessary reviews and validation during the modification planning process. As a result, engineering and operations personnel had failed to identify and disable a transmitter deviation-based trip during post-maintenance testing activities. The testing configuration triggered the two transmitters-in-deviation trip for the emergency trip system loop and initiated the turbine trip. The licensees evaluation concluded that the root cause was associated with organizational weaknesses with the maintenance, implementation, and challenging of the emergent work process. Specifically, shift management failed to set and enforce standards related to the emergent work process. Corrective actions included creation of improved standards for engineering and operations personnel during work on emergent work packages and technical engineering products.
The licensee reported this issue at the time of the event under 10 CFR 50.72(b)(2)(iv)(B)as a 4-hour report for an RPS actuation while the reactor was critical, and under 50.72(b)(3)(iv)(A) as an 8-hour report for a valid specified system actuation (RPS). In addition, on August 22, 2016, the licensee reported the event under 10 CFR 50.73(a)(2)(iv)(A), as a licensee event report (LER) for a valid specified system actuation (RPS). The inspectors reviewed the root cause evaluation, the corrective actions, and the LER for the event to determine whether the causal analysis was thorough, the corrective actions appropriately addressed the condition and causes, and the appropriate NRC reporting requirements were met.
This LER is closed.
b. Findings
One finding associated with this event was previously documented in the second quarter resident inspector NRC Integrated Inspection Report (05000285/2016002-02, Failure to Develop Adequate Procedures for Post-Modification Testing). No additional findings were identified.
.4 (Closed) Licensee Event Report 05000285/2016-004-00, Unanalyzed Condition for
Potential Tornado-Borne Missile Impact to the Raw Water System
a. Inspection Scope
On August 25, 2016, the licensee identified that a tornado missile strike on diesel-driven fire water pump FP-1B or associated piping had not been addressed during the 2013 tornado missile project. As such, a missile strike affecting pump FP-1B or its associated piping could cause a larger volume of water to enter the raw water pump vault than had previously been analyzed. An operability evaluation was conducted and compensatory measures were implemented to disable pump FP-1B and isolate associated piping upon entering a severe thunderstorm or tornado watch per their Abnormal Operating Procedure AOP-01, Acts of Nature.
The NRC inspectors reviewed the details of this condition including corrective actions and compensatory measures implemented to maintain operability. Based on review of the condition, the inspectors determined that the licensee was previously ineffective in implementing corrective actions to address all missile hazards that could impact safety-related equipment when this was originally identified as a concern in 2013.
Specifically, the vulnerability to a missile strike upon pump FP-1B and associated piping was discussed during the 2013 tornado missile project. However, the postulated tornado missile strike on the intake structure which impacts the pump and associated piping was not addressed nor were corrective actions taken to protect the raw water pump vault at that time.
This LER is closed.
b. Findings
This violation was identified by the licensee and is discussed in further detail in Section 4OA7 of this report.
These activities constituted completion of four event follow-up samples, as defined in Inspection Procedure 71153.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On November 10, 2016, the inspector presented the radiation safety inspection results to Mr. T. Tierney, Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspector had been returned or destroyed.
On December 2, 2016, the inspector presented the results of the onsite inspection of the licensees emergency preparedness program to Mr. S. Marik, Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On January 11, 2017, the inspectors presented the inspection results to Mr. S. Marik, Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
4OA7 Licensee-Identified Violations
The following licensee-identified violations of NRC requirements were determined to be of very low safety significance (Green) or Severity Level IV and meet the NRC Enforcement Policy criteria for being dispositioned as non-cited violations:
- Technical Specification 2.0.1 requires the unit to be shut down within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in the event a limiting condition for operation and/or associated action requirement cannot be satisfied because of circumstances in excess of those addressed in the specification.
Contrary to the above, the licensee failed to enter Technical Specification 2.0.1 and take the prescribed actions on several occasions when shutdown cooling heat exchanger valves were opened which impacted component cooling water (CCW) flow to the containment air cooling units under certain accident conditions.
On May 10, 2016, an unanalyzed condition was discovered during scheduled maintenance on the shutdown cooling heat exchanger valves. As part of the maintenance, HCV-484, Shutdown Heat Exchanger AC-4A Component Cooling Water Outlet Valve, and HCV-481, Shutdown Cooling Heat Exchanger AC-4B Component Cooling Water Inlet Valve, were failed open which rendered both valves inoperable.
Under these conditions, with the assumed single failure loss of DC control power during a loss of coolant accident (LOCA), CCW would be allowed to flow through both shutdown cooling heat exchangers, effectively reducing CCW system flow to the containment air cooling units. These conditions are not assumed under plant design basis calculations and placed the plant in an unanalyzed condition. It has not been demonstrated that the CCW system would adequately perform its design function of providing a cooling medium for the containment atmosphere under LOCA conditions with CCW flow diverted through the shutdown cooling heat exchangers. With two containment air cooling units inoperable, Technical Specification 2.4, does not provide an associated action; therefore, Technical Specification 2.0.1 applies. Upon completion of the maintenance activity, both valves were returned to service which eliminated the condition. The licensee conducted an extent of condition review and identified that they had created this unanalyzed condition six times within the last 3 years and had exceeded the Technical Specification 2.0.1 6-hour shutdown action statement on March 8, 2016; April 21, 2016; and May 10, 2016. In addition, the licensee determined this condition was first identified on February 3, 2015, in Condition Report 2015-01388.
Procedure TDB-VIII, Equipment Applicability Guidance, Revision 64, incorrectly stated the valves had a required safety function in the open direction. The licensee initiated procedure change EC-68088 on September 26, 2015, to correct the procedure; however, the proposed change did not accurately reflect the safety function of the valves to remain closed for all LOCA conditions. This procedure change was still under review on May 10, 2016. The failure to promptly correct Procedure TDB-VIII was a contributing cause of the violation.
The violation is more than minor because it is associated with the configuration control attribute of the Mitigating Systems Cornerstone. On March 8, 2016; April 21, 2016; and May 10, 2016, the plant was placed in a condition prohibited by technical specifications and exceeded the Technical Specification 2.0.1, 6-hour shutdown action statement.
This adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. A senior reactor analyst qualitatively determined that this finding was of very low safety significance (Green) for increases in core damage frequency and large early release frequency because of the short exposure time of less than 3 days and because of the low frequency of events where a LOCA with an independent and coincidental loss of DC control power would occur. Therefore, this finding screens to Green. The licensee entered the issue into their corrective action program as Condition Reports 2016-05340 and 2016-04468.
- Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, though the licensee identified a potential vulnerability to raw water pumps from a missile hazard striking diesel driven fire pump FP-1B or associated piping during review of missile hazards during the 2013 tornado missile project, the licensee failed to evaluate this condition or specify a modification to the plant to protect the raw water pumps at that time. This was discovered on August 25, 2016, by the licensee during a design review. This finding is of very low safety significance (Green) considering compensatory measures that were put in place to disable pump FP-1B and isolate associated piping when severe weather is forecast and the very low probability of the postulated event. This issue was entered into the licensees corrective action program as CR 2016-06972.
- Title 10 of the Code of Federal Regulations, Part 50.9(a), requires that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on December 26, 2014, Fort Calhoun Station provided information to the Commission which was not complete and accurate in all material respects. Specifically, a license amendment request (ML14365A123) to adopt a scheme of emergency action levels based on Nuclear Energy Institute Document 99-02, Revision 6, contained inaccurate information about the characteristics of the cask used in the licensees Independent Spent Fuel Storage Installation and, as a result, incorrect external radiation levels were incorporated into emergency action level E-HU1.
Subsequently, while preparing another emergency action level submittal, the emergency preparedness staff discovered the incorrect information that had previously been submitted. The issue was determined to be a Severity Level IV violation of NRC requirements, in accordance with Section 6.9 of the Enforcement Policy, dated November 1, 2016, because the inaccurate information would not have caused the NRC to reconsider a regulatory position or undertake substantial further inquiry. The issue was documented in the licensees corrective action program as Condition Report CR-2016-08400. Because the Severity Level IV violation has been entered into the licensees corrective action program, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- C. Beck, Director, Training, (Acting)
- R. Beck, Manager Chemistry, Environmental, and Radwaste
- B. Blome, Manager, Regulatory Assurance
- E. Breault, Supervisor, Radiation Protection
- D. Brehm, Supervisor, Radiation Protection
- C. Cameron, Principal Regulatory Specialist, Licensing
- J. Cate, Manager, Engineering Projects
- H. Childs, Manager, Security
- B. Currier, Director, Site Engineering
- S. Dixon, Respiratory Specialist, Radiation Protection
- A. Hansen, Licensing Engineer
- R. Hugenroth, Manager, Nuclear Oversight
- T. Leaf, Director, Operations
- D. Little, Dosimetry Specialist, Radiation Protection
- S. Marik, Vice President and Chief Nuclear Officer
- E. Matzke, Senior Licensing Engineer
- J. Mise, Engineer, Systems Engineering
- J. Musser, Superintendent, Operations
- B. Pearson, Supervisor, Radiation Protection
- E. Plautz, Manager, Emergency Planning
- J. Shuck, Manager, Systems Engineering
- N. Thompson, Engineer, System Engineering
- T. Tierney, Plant Manager
- T. Uehling, Plant Manager, Decommissioning
- C. Verdoni, Operation Training
- B. Ward, Nuclear Engineer, Rapid Response
- D. Weaver, Director, Work Management
- D. Whisler, Manager, Radiation Protection
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
Failure to Provide Training on Changes to Protective Action
- 05000285/2016004-01 NCV Recommendation Procedures (Section 1EP5)
Closed
Unanalyzed Condition Shutdown Heat Exchanger Isolations
- 05000285/2016002-00 LER (Section 4OA3)
Unanalyzed Condition Shutdown Heat Exchanger Isolations
- 05000285/2016002-01 LER (Section 4OA3)
Unplanned Turbine Trip during DCS Modification due to Failure
- 05000285/2016003-00 LER to Identify and Disable the Transmitter Deviation Based Trip (Section 4OA3)
Unanalyzed Condition for Potential Tornado-Borne Missile
- 05000285/2016004-00 LER Impact to the Raw Water System (Section 4OA3)