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Current Status of U.S. Nuclear Regulatory Commission Inspection Manual Chapter 0350 Panel Fort Calhoun Station Restart Checklist and Basis Documents
	ML13319B251
Person / Time
Site:	Fort Calhoun
Issue date:	11/15/2013
From:	Dapas M; Region 4 Administrator
To:	Cortopassi L; Omaha Public Power District
References
	EA-13-020
	Download: ML13319B251 (68)
	v • d • e

UNITE D S TATE S NUC LEAR RE GULATOR Y C OMMI S SI ON RE G IO N I V 1600 EAST LAMAR BLVD AR L INGTON , TEXAS 7 60 1 1 - 4511 November 15, 2013 EA-13-020 Mr. Louis P. Cortopassi, Vice President and Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station FC-2-4 P.O. Box 550 Fort Calhoun, NE 68023-0550

SUBJECT:

CURRENT STATUS OF U.S. NUCLEAR REGULATORY COMMISSION INSPECTION MANUAL CHAPTER 0350 PANEL FORT CALHOUN STATION RESTART CHECKLIST AND BASIS DOCUMENTS

Dear Mr. Cortopassi:

The purpose of this letter is to provide the current status of the U.S. Nuclear Regulatory Commission (NRC) actions regarding the items contained in the Restart Checklist, dated February 26, 2013, and the Restart Checklist Basis Document, dated March 7, 2013.

The Restart Checklist describes those actions Omaha Public Power District (OPPD) committed to take prior to the restart of Fort Calhoun Station to address post flood recovery actions, following the Missouri River flood during the summer of 2011, and to address performance issues at the station. The Restart Checklist Basis Document provides details and clarification for the scope and breadth of the Restart Checklist items and the minimum actions that the NRC plans to take to verify that Fort Calhoun Station has adequately addressed the specific items.

An updated version of both the Restart Checklist and the Restart Checklist Basis Document are enclosed with this letter, and highlights the current status of NRC reviews for the items. The Basis Document includes references to the relevant inspection reports that document our closure of specific items. Closure of the Restart Checklist areas indicates that all inspections related to the area have been satisfactorily completed and the results reviewed by the Inspection Manual Chapter 0350 Panel as acceptable for closure. The remaining items associated with the Restart Checklist are currently under NRC review, with the exception of those items which OPPD is in the process of addressing. Pending the completion of these items, the NRC will perform an independent assessment of the adequacy of OPPD actions.

L. Cortopassi Please direct any questions or comments regarding the enclosures to Michael Hay, Chief, Division of Reactor Projects, Project Branch F at (817) 200-1147.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosures will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS),

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

Sincerely

/RA/

Marc L. Dapas Regional Administrator Docket No.: 50-285 License No.: DPR-40

Enclosures:

1. Updated Fort Calhoun Station Restart Checklist

2. Updated Restart Checklist Basis Document cc w/ encl: Electronic Distribution for Fort Calhoun Station

L. Cortopassi Electronic Distribution by RIV:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Steven.Reynolds@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

DRP Deputy Director (Troy.Pruett@nrc.gov)

DRS Director (Tom.Blount@nrc.gov)

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

MC 0350 Chairman (Anton.Vegel@nrc.gov)

MC 0350 Co-Chair (Louise.Lund@nrc.gov)

MC 0350 Panel Member (Michael.Balazik@nrc.gov)

MC 0350 Panel Member (Joseph.Sebrosky@nrc.gov)

MC 0350 Panel Member (Michael.Markley@nrc.gov)

DPR Deputy Director, NSIR (Scott.Morris@nrc.gov)

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

Resident Inspector (Jacob.Wingebach@nrc.gov)

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

Special Assistant, DRP/F (Jamnes.Cameron@nrc.gov)

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

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

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

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

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

Project Manager (Lynnea.Wilkins@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

RIV RSLO (Bill.Maier@nrc.gov)

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

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

RIV/ETA: OEDO (Brett.Rini@nrc.gov)

RidsOEMailCenter.Resource NRREnforcement.Resource ROPreports DOCUMENT NAME:R:_REACTORS\_FCS2013NovemberCALstatus.mch SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials MCH Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials MCH C:DRP/RPBF DD:DORL D:ACES D:DRP D:DRS D:DNMS RIV:RA MCHay LLund HGepford KMKennedy TBlount AVegel MDapas

/RA/ /RA/ /RBrowder for/ /RA/ /RA/ /RA/ /RA/

11/14/13 11/14/13 11/14/13 11/14/13 11/14/13 11/14/13 11/14/13 OFFICIAL RECORD COPY

U.S. Nuclear Regulatory Commission Inspection Manual Chapter 0350 Panel Fort Calhoun Station Restart Checklist Item Number Description Status 1 Causes of Significant Performance Deficiencies and Assessment of Organizational Effectiveness 1.a Flooding Issue - Yellow finding Reviews Completed Area Closed 1.b Reactor Protection System contact failure - White finding Reviews Completed Area Closed 1.c Electrical bus modification and maintenance - Red Reviews Near finding Completion 1.d Security - Greater than Green findings Reviews Completed Area Closed 1.e Third-Party Safety Culture Assessment Reviews Completed Area Closed 1.f Integrated Organizational Effectiveness Assessment Reviews Completed Area Closed 1.g Safety System Functional Failures White Performance Reviews Near Indicator Completion 2 Flood Restoration and Adequacy of Structures, Systems, and Components 2.a Flood Recovery Plan actions associated with facility and Reviews system restoration Completed Area Closed 2.b System readiness for restart following extended plant Reviews Near shutdown Completion 2.c Qualification of containment electrical penetrations Reviews in Progress Enclosure 1

2.d Containment internal structure Reviews Completed Area Closed 3 Adequacy of Significant Programs and Processes 3.a Corrective Action Program Reviews Completed Area Closed 3.b Equipment design qualifications Reviews Pending Completion of Actions by OPPD 3.c Design changes and modifications Reviews Pending Completion of Actions by OPPD 3.d Maintenance programs Reviews Completed Area Closed 3.e Operability process Reviews Near Completion 3.f Quality assurance Reviews Completed Area Closed 4 Review of Integrated Performance Improvement Plan Reviews in progress 5 Assessments of NRC Inspection Procedure 95003 Key Attributes 5.a Design Reviews Pending Completion of Actions by OPPD 5.b Human performance Reviews Completed Area Closed 5.c Procedure quality Reviews Completed Area Closed 5.d Equipment performance Reviews Near Completion 5.e Configuration control Reviews Near Completion 5.f Emergency response Reviews Completed Area Closed 5.g Occupational radiation safety Reviews Completed Area Closed 5.h Public radiation safety Reviews Completed Area Closed 5.i Security Reviews Completed Area Closed 6 Licensing Issue Resolution 6.a Review of necessary licensing amendments or actions Reviews in progress 6.b Review of licensing commitments necessary for restart Reviews Completed Area Closed 7 Readiness for Restart 7.a Operations organization ready for restart Reviews Completed Area Closed 7.b Systems ready for restart and Mode restraints properly Reviews in addressed progress 7.c Final review of corrective actions program for restart Reviews in items progress 8 Confirmatory Action Letter Resolution 8.a Verification that all restart-related Confirmatory Action Reviews in Letter items are appropriately resolved progress 8.b Conduct public meeting regarding plant readiness for November 21, restart 2013 9 Final Recommendation for Restart 9.a Inspection Manual Chapter 0350 Panel recommends Future Action restart to Region IV Administrator. Region IV Administrator obtains concurrence for restart from the Deputy Executive Director for Reactor and Preparedness Programs and the Director of the Office of Nuclear Reactor Regulation (NRR).

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

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

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

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

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

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

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

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

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

Enclosure 2

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

Section 1: Causes of Significant Performance Deficiencies and Assessment of Organizational Effectiveness Section 1 of the Restart Checklist contains those items necessary to develop a comprehensive understanding of the root causes of the performance deficiencies identified at Fort Calhoun Station for all greater than Green findings. In addition, Section 1 includes the independent safety culture assessment with the associated root causes and findings. The integration of the assessments under Item 1.f will identify the fundamental aspects of organizational performance in the areas of organizational structure and engagement, values, standards, culture, and human behaviors that have resulted in the protracted performance decline and are critical for sustained performance improvement. Section 1 reviews will also include an assessment against appropriate NRC Inspection Procedure 95003 key attributes as described in Section 5.

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

Item 1.a Flooding Issue - Yellow Finding Item 1.a is included in the restart checklist for the failure of Fort Calhoun Station to maintain procedures and equipment that protects the plant from the effects of a design basis flood.

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

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

Action Actions to be Verified Prior to Restart Status Item Number 4.2.1.1 Review/observe all external flood barrier configurations Closed and verify that they have not been altered during flood IR 2013-008 response or outage activities ML13197A261 4.2.1.2 Issue SO-G-124, Flood Barrier Impairment program Closed IR 2013-008 ML13197A261 4.2.1.3 Document external flood barrier impairments as Closed applicable in accordance with SO-G-124 IR 2013-008 ML13197A261 4.2.1.6 Identify flood barriers which will not have adequate Closed qualification basis before leaving Cold Shutdown. IR 2013-008 ML13197A261 The following NRC open items are specifically related to the Yellow finding and therefore need to be evaluated prior to restart of the facility. For these specific items, the NRC will verify that the licensee has performed adequate root cause and extent of condition evaluations related to the associated deficiencies that protect the plant from the effects of a design basis flood. In addition, the NRC will verify that adequate corrective actions were identified associated with the licensees root and contributing causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status LER 2012-001 Inadequate Flooding Protection Procedure Closed Inspections completed Future report LER 2012-019 Traveling Screen Sluice Gates Found with Dual Closed Indication Inspections completed Future report LER 2011-003 Inadequate Flooding Protection Due to Closed Ineffective Oversight Inspections completed Future report LER 2011-001 Inadequate Flooding Protection Due to Closed Ineffective Oversight IR 2013-008 ML13197A261 VIO 2012002-01 Inadequate Procedures to Mitigate a Design Closed Basis Flood Event Inspections completed Future report VIO 2012002-02 Failure to Classify Intake Structure Sluice Gates Closed as Safety Class III Inspections completed Future report VIO 2012002-03 Failure to Meet Design Basis Requirements for Closed Design Basis Flood Event Inspections completed Future report VIO 2010007-01 Failure to Maintain External Flood Procedures Closed Inspections completed Future report Although not a specific plant restart action, the NRC will review the following long-term actions planned to be implemented by the licensee.

Action Description Status Item Number 4.4.3.1 Gather flood response lessons learned through the Post restart item Condition Report (CR) reviews to determine if procedure or strategy changes should be implemented 4.4.3.2 Review flood design basis and determine if the 2011 Post restart item flood event provides additional information that should drive design basis changes 4.4.3.3 Implement procedure and strategy changes as indicated Post restart item by the lessons learned review conducted Item 1.b Reactor Protection System Contactor Failure - White Finding Item 1.b is included in the restart checklist for the failure of Fort Calhoun Station to correct a degraded contactor, which subsequently failed, in the reactor protection system (RPS). This deficiency resulted in a White (low to moderate safety significance) finding as documented in NRC Inspection Report 05000285/2011007 (ML112000064). With respect to this finding the NRC will verify that the licensee adequately identifies the root and contributing causes of the risk-significant issue; verify that the extent of condition and extent of causes of the risk-significant issue are identified, and verify that the corrective actions adequately address the causes to preclude repetition. The following licensee actions will be reviewed by the NRC:

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

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

Item Actions to be Verified Prior to Restart Status 1.c.1 Electrical Fire Red Finding root and contributing cause Closed evaluation IR 2013-013 To be issued 1.c.2 Electrical Fire Red Finding extent of condition and cause Closed evaluation IR 2013-013 To be issued 1.c.3 Electrical Fire Red Finding corrective actions addressing Closed root and contributing causes IR 2013-013 To be issued In addition, the NRC will verify that the actions related to the Red Finding being implemented by the licensee are adequate to support plant restart. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Description Status Item Number 1.3.1.1 Rebuild the 1B4A load center Closed IR 2013-013 To be issued 1.3.1.2 Provide documentation for the dedication of the rebuilt Closed load center in accordance with Contract 163495 IR 2013-013 To be issued 1.3.1.3 Complete Engineering Change 53257 and obtain Plant Closed Review Committee (PRC) approval to authorize the use IR 2013-013 of the rebuilt load center, 1B4A To be issued 1.3.1.4 Test all cables that terminate in 1B4A load center Closed IR 2013-015 ML13312A876 1.3.1.5 Repair or replace defective cables terminating in 1B4A Closed load center IR 2013-015 ML13312A876 1.3.1.6 Perform testing on the insulation of the cables that were Closed potentially impacted by the fire located in the cable tray IR 2013-015 above 1B4A load center using Electric Power Research ML13312A876 Institute (EPRI) technology 1.3.1.7 Complete Engineering Change 53517 that details the Closed repair to the cable jackets for cables located in the cable IR 2013-013 tray above 1B4A load center To be issued 1.3.1.8 Repair or replace the cables located in the cable tray Closed above load center 1B4A that have had jacket damage IR 2013-013 To be issued 1.3.1.9 Witness Factory Acceptance Testing of the new Square Closed D circuit breakers that will be used in the 1B4A load IR 2013-002 center to replace the existing AK-25 breakers and the two ML13092A286 Square D input and bus tie breakers 1.3.1.10 Calibration of the internal relays and protection Closed equipment for Bus1B4A IR 2013-013 To be issued 1.3.1.11 Install new 4160 to 480 volt transformer T1B4A Closed IR 2013-002 ML13092A286 1.3.1.12 Calibrate new Square D circuit breakers Closed IR 2013-013 To be issued 1.3.1.14 Clean equipment in the switchgear room that has been Closed coated with by-products from the fire IR 2013-015 ML13312A876 1.3.1.15 Provide any required Engineering Change for the non- Closed segregated bus between 1B4A and 1B3A-4A IR 2013-015 ML13312A876 1.3.1.16 Repair 1B4A to 1B3A-4A non-segregated bus section Closed IR 2013-015 ML13312A876 1.3.1.17 Perform testing of all circuits associated with 1B4A load Closed center IR 2013-013 To be issued 1.3.1.18 Perform testing of all circuits associated with cabling not Closed associated with the 1B4A load center (i.e. cables located IR 2013-015 in the cable tray above the load center) ML13312A876 1.3.1.19 Submit, track, and seek approval of procedures that are Closed changed as the result of EC 53257 and are required to be IR 2013-013 issued before the System Acceptance Process. To be issued 1.3.1.21 Declare bus 1B4A Operable Reviews near completion 1.3.1.22 Temporary Modification restoration Closed IR 2013-002 ML13092A286 1.3.1.23 Extent of Condition repair requirements. Provide repair Reviews near requirements for extent of condition. completion 1.3.1.24 Implement the requirements supplied by System Closed Engineering regarding the extent of condition. IR 2013-013 To be issued The following NRC open items are specifically related to the Red finding and therefore need to be evaluated prior to restart of the facility. For these specific items the NRC will verify that the licensee has performed adequate root cause and extent of condition evaluations related to the failure of the 1B4A breaker and associated electrical fire in the vital switchgear. In addition, the NRC will verify that adequate corrective actions were identified associated with the licensees root and contributing causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

NRC Item Description Status VIO 2012010-01 Failure to Ensure that the 480 VAC Electrical Reviews near Power Distribution System Design Requirements completion were Implemented and Maintained VIO 2012007-01 Failure to Provide Adequate Post-Fire Safe Closed Shutdown Actions in the Switchgear Rooms IR 2013-015 ML13312A876 VIO 2012007-02 Failure to Maintain Command and Control Closed Function During Fire Fighting Activities in the Inspections completed Protected Future report Area (PA)

VIO 2012004-04 Failure to Ensure Breaker Coordination of 480 Reviews near VAC Electrical Power Distribution System Was completion Maintained URI 2011014-02 Failure to Perform Adequate 10 CFR 50.59 Closed Review IR 2013-008 ML13197A261 URI 2011014-03 Cause of Breaker 1B3A Trip Not Understood Closed IR 2012-004 ML12276A456 LER 2011-010 Fire Causes a Circuit Breaker to Open Outside Closed Design Assumptions IR 2013-013 To be issued Item 1.d Security - Greater than Green Findings Item 1.d is included in the restart checklist because of greater than Green findings that adversely affected the security cornerstone. Information about these findings is located in NRC Inspection Reports 05000285/2011404 (ML111460688) and 05000285/2011406 (ML12108A186).

With respect to these findings, the NRC will verify that the licensee adequately identifies the root and contributing causes of the risk-significant issues; verify that the extent of condition and extent of causes of the risk-significant issues are identified, and verify that the corrective actions adequately address the causes to preclude repetition.

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

All the security-related items were closed in two inspection reports, 05000285/2013-405 (ML13115A095) and 05000285/2013-407 (ML13213A497).

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

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

Item Actions to be Verified Prior to Restart Status 1.e.1 Verification of comprehensiveness of licensee third party Closed safety culture assessment IR 2013-008 ML13197A261 1.e.2 Methods used by the third-party assessment team to Closed collect and analyze the data were adequate and IR 2013-008 appropriate ML13197A261 1.e.3 Verification that licensees assessment team members Closed were independent and qualified IR 2013-008 ML13197A261 1.e.4 Licensees activities to communicate results of the Closed assessment to various levels of management and staff IR 2013-008 ML13197A261 1.e.5 Licensees corrective actions to the assessment results Closed IR 2013-008 ML13197A261 If substantial weaknesses are identified with the licensees third-party safety culture assessment or the NRC has low confidence in the validity of the licensees results, the NRC will conduct an independent safety culture assessment in order to gain accurate insights on the contribution of weaknesses in safety culture components to licensee performance.

The site performed an integrated assessment and identified 15 Fundamental Performance Deficiencies (FPDs) that resulted in the overall performance decline at the station. Nuclear Safety Culture and Safety Conscience Work Environment were identified as areas for improvement. With respect to these Fundamental Performance Deficiencies, the NRC will assess the following:

Item Actions to Be Verified Prior to Restart Status 1.e.6 Licensee Assessment of the Fundamental Closed Performance Deficiency associated with Nuclear IR 2013-008 Safety Culture ML13197A261 1.e.7 Adequacy of extent of condition and extent of causes Closed IR 2013-008 ML13197A261 1.e.8 Adequacy of corrective actions Closed IR 2013-008 ML13197A261 1.e.9 Licensee Assessment of the Fundamental Closed Performance Deficiency associated with Safety IR 2013-008 Conscience Work Environment ML13197A261 1.e.10 Adequacy of extent of condition and extent of causes Closed IR 2013-008 ML13197A261 1.e.11 Adequacy of corrective actions Closed IR 2013-008 ML13197A261 Item 1.f Integrated Organizational Effectiveness Assessment Item 1.f is included on the restart checklist because organizational effectiveness was identified as a potential key contributor to the overall station performance. Organizational effectiveness can impact multiple activities and programs across multiple functional areas at the facility.

At the completion of the assessments performed under Restart Checklist Items 1.a through 1.e, Fort Calhoun Station will integrate the outcomes of each of those assessments to determine what aspects of its organization and human performance need additional focus and improvement. The integration of the root cause and safety culture assessments under Item 1.f will identify those fundamental aspects of organizational performance in the areas of organizational structure and engagement, values, standards, culture and human behaviors that have resulted in the protracted performance decline, and are critical for sustained performance improvement. The licensee will perform this assessment using qualified individuals with independent oversight.

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

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

Item Actions to be Verified Prior to Restart Status 1.f.1 Verification of comprehensiveness of licensee Integrated Closed Organizational Effectiveness assessment IR 2013-008 ML13197A261 1.f.2 Methods used by assessment team to collect and Closed analyze the data were adequate and appropriate IR 2013-008 ML13197A261 1.f.3 Verification that licensees assessment team members Closed were independent and qualified IR 2013-008 ML13197A261 1.f.4 Licensees activities to communicate results of the Closed assessment to various levels of management and staff IR 2013-008 ML13197A261 1.f.5 Licensees corrective actions to the assessment results Closed IR 2013-008 ML13197A261 The site performed an integrated assessment and identified 15 FPDs that resulted in the overall performance decline at the station. These deficiencies included Leadership/Organizational Effectiveness, Nuclear Safety Culture, Safety Conscious Work Environment, Corrective Action Program, Site Operational Focus, Resource Management, Processes for Meeting Regulatory Requirements, Equipment Reliability/Work Management, Engineering Design/Configuration Control, Performance Improvement, Procedure Quality/Procedure Management, Nuclear Oversight, Emergency Response Organization, and Security.

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

Item Actions to Be Verified Prior to Restart Status 1.f.6 Licensee Assessment of Leadership/Organizational Closed Effectiveness Fundamental Performance Deficiency IR 2013-008 ML13197A261 1.f.7 Adequacy of extent of condition and extent of causes Closed IR 2013-008 ML13197A261 1.f.8 Adequacy of corrective actions Closed IR 2013-008 ML13197A261 Item 1.g Safety System Functional Failures White Performance Indicator The Safety System Functional Failure Performance Indicator for the 3rd quarter of 2012 moved into the White region based on a number of events being identified, mainly during the licensees discovery efforts to improve overall safety at the facility. This indicator reflects the number of events or conditions that alone prevented, or could have prevented, the fulfillment of the safety function of structures or systems in the previous four quarters. In the past four quarters, nine functional failures were identified and reported by the licensee.

With respect to these functional failures, the NRC will verify that the licensee adequately identifies the root and contributing causes; verify that the extent of condition and extent of causes are identified, and verify that the corrective actions adequately address the causes.

This item remains open pending completion of NRC review of the licensees revised root cause and corrective actions for the trend in safety system functional failures.

These events are already captured in this basis document as items that will be reviewed by the NRC. The following table provides a reference to the section in this document where these items are addressed:

Item Description Section LER 2012-017 Containment Valve Actuators Design Temperature 3.b.2 Ratings Below those Required for Design Basis Accidents LER 2012-015 Electrical Equipment Impacted by High Energy Line 3.b.2 Break Outside Containment LER 2012-014 Containment Beam 22 Loading Conditions Outside of the 2.d Allowable Limits LER 2012-011 Emergency Diesel Inoperability Due to Bus Loads During 3.a a Loss of Offsite Power (LOOP)

LER 2012-009 Inoperable Equipment Due to Lack of Environmental 3.b.2 Qualifications LER 2012-005 Technical Specification Violation Due to Inadequate 5.d Testing of Emergency Diesel Fuel Pumps LER 2012-004 Inadequate Analysis of Drift Affects Safety Related 3.a Equipment LER 2012-001 Inadequate Flooding Protection Procedure 1.a LER 2011-010 Fire Causes a Circuit Breaker to Open Outside Design 1.c Assumptions Section 2: Flood Restoration and Adequacy of Structures, Systems, and Components Section 2 of the Restart Checklist contains those items necessary to ensure that important structures, systems and components affected by the flood and safety significant structures, systems and components at Fort Calhoun Station are in appropriate condition to support safe restart and continued safe plant operation.

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

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

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

Action Actions to be Verified Prior to Restart Status Item Number 1.2.1.1 Determine if equipment in the intake structure and cells Closed has been damaged IR 2013-003 ML13130A050 1.2.1.4 Return B.5.b materials to proper location Closed IR 2012-005 ML12318A341 1.4.1.2 Inspect 13.8kV underground pad mount transmission Closed and distribution (T&D) switch SW1062 IR 2012-003 ML12226A630 1.4.1.3 Inspect and/or test T&D 13.8 kV transformer T1B-3C-1 Closed (T&D 13TN43G) IR 2012-003 ML12226A630 1.4.1.4 Inspect manholes and ducts for MH01 through MH04 Closed from T&D switch SW1062 to transformer T1B-3C-1 to IR 2012-003 facilitate pulling new 1/0 cable ML12226A630 1.4.1.5 Inspect ducts associated with manholes MH1 through Closed MH4 between T&D switch SW1062 to T&D transformer IR 2012-003 13TN43G and repair as necessary ML12226A630 1.4.1.6 Inspect and/or test Circuit 231 from T&D switch Closed SW1062 to T&D transformer 13TN43G and repair as IR 2012-003 necessary ML12226A630 2.1.1.2 Repair any damaged or non-functional fire hydrants Closed located inside the protected area or connected to the IR 2012-012 main fire protection header ring ML13045B055 2.1.1.3 Flush fire protection system piping connected to the fire Closed protection header ring which flowed river water during IR 2012-005 flood mitigation actions ML12318A341 2.1.1.4 Inspect all SO-G-103 fire barriers in plant buildings Closed affected by flood waters. Includes Pyrocrete barriers in IR 2012-003 Intake Structure ML12226A630 2.1.1.6 Restore the exterior fire hose houses impacted by Closed flooding to functional condition IR 2012-012 ML13045B055 2.1.1.7 Verify proper functioning of flood affected fire hose Closed houses IR 2012-012 ML13045B055 2.1.1.8 Complete Fire Protection (FP) System preventive Closed maintenance (PM) and surveillance test (ST) on flood IR 2013-003 impacted equipment which was not accessible for ML13130A050 inspection and testing 2.1.1.9 Complete full flow testing of fire pumps Closed IR 2012-005 ML12318A341 2.1.1.10 Remove the plugs that were installed in the transformer Closed pits for drainage from the rocks IR 2012-003 ML12226A630 2.3.1.1 Assess whether wetted motors are to be tested for Closed possible use, refurbished or replaced. Motors that were IR 2012-005 wetted for a short timeframe will be Tested for Possible ML12318A341 Use. Motors that were wetted for an extended period of time will be Refurbished or Replaced.

2.3.1.2 Take oil sample from bearing housings of wetted motors Closed IR 2012-005 ML12318A341 2.3.1.3 Evaluate if water has gotten in contact with bearings. Closed IR 2012-005 ML12318A341 2.3.1.4 Refurbish motor if water contamination is present in oil. Closed Replace motor in whole is an additional option IR 2013-004 ML13164A359 2.3.1.5 Perform visual and boroscope inspection of wetted Closed motor internals (to included termination box) looking for IR 2012-005 silt, pools of water, corrosion, etc. ML12318A341 2.3.1.6 Evaluate visual inspection results for possible actions Closed (removal of moisture, cleaning, refurbishment of motor) IR 2012-005 ML12318A341 2.3.1.7 If bearing are in good condition and wetted motor is Closed visibly in good condition, static test motor IR 2013-014 ML13266A225 2.3.1.8 If static test results are SAT, motor can be started. Closed Maintenance oversight of initial run. Vibration data to IR 2013-015 be taken during initial run ML13312A876 2.3.1.9 Remove wetted motor and prepare for shipment to Closed vendor IR 2012-003 ML12226A630 2.3.1.10 Refurbish wetted motor Closed IR 2012-003 ML12226A630 2.3.1.11 Install refurbished motor Closed IR 2012-003 ML12226A630 2.3.1.12 Post-maintenance testing of motor Closed IR 2012-003 ML12226A630 2.3.1.13 Ensure spare motor is available or order new motor Closed IR 2012-004 ML12276A456 2.3.1.14 Remove degraded motor Closed IR 2012-004 ML12276A456 2.3.1.15 Install new motor Closed IR 2012-004 ML12276A456 2.3.1.16 Post maintenance testing of motor Closed IR 2012-004 ML12276A456 3.1.1.1 Document review of all Engineering Programs Closed IR 2013-015 ML13312A876 3.2.1.1 Test Maintenance Rule Medium Voltage Power Cables Closed subjected to wetting/ submergence IR 2013-004 ML13164A359 3.2.1.2 Test Maintenance Rule Low Voltage Power Cables Closed subjected to wetting/ submergence IR 2012-005 ML12318A341 3.2.1.3 Test Maintenance Rule Low Voltage Control and Closed Instrumentation Cables subjected to wetting/ IR 2012-005 submergence ML12318A341 3.2.2.1 Test or replace 13.8kV medium voltage cable for Closed emergency power feed and met tower feed IR 2013-002 ML13092A286 3.2.2.2 Inspect manholes and vaults for damage and integrity of Closed water seals at penetrations IR 2013-014 ML13266A225 3.2.2.3 Contingency cable replacement (if identified defective Closed cable during testing) IR 2013-002 ML13092A286 3.2.2.4 Testing of contingency cables installed after Closed replacement (if needed) IR 2013-002 ML13092A286 3.3.1.2 Assess results of ground penetrating radar (GPR) Closed IR 2013-005 ML13221A584 4.2.1.4 Perform walkdown of all flood mitigation devices (i.e., Closed berms, sandbags, HESCO barriers, to determine if each IR 2013-003 device is to be removed or is to remain ML13130A050 4.2.1.5 Initiate actions to remove flood mitigation devices which Closed have been determined to not be permanent fixtures IR 2013-003 ML13130A050 4.2.2.1 Identify degraded flood barriers Closed IR 2013-004 ML13164A359 4.2.2.2 Repair flood barriers as required Closed IR 2013-004 ML13164A359 4.2.2.4 Prepare SO-G-124 documentation for all flood barriers Closed which do not have adequate qualification IR 2013-004 ML13164A359 4.2.2.5 Review restoration plans for each impaired flood barrier Closed per SO-G-124 form FC-1411 IR 2013-004 ML13164A359 4.2.2.6 Review impaired flood barriers as identified in Closed accordance with SO-G-124 form FC-1411 IR 2013-004 ML13164A359 4.2.2.7 Removal of all flood mitigation devices which have been Closed determined to not be permanent fixtures IR 2013-016 To be issued 4.3.2.1 Completion of all ECs/restoration required for plant Closed start-up IR 2013-016 To be issued The NRC will verify that the licensee adequately addresses systems that were potentially affected by the flood of 2011. These activities will verify the capability of selected systems to fulfill their intended functions. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number 2.2.1.1 Assess the effects of the flood on the Auxiliary Cooling Closed System (ACS) and identify actions to restore the system. IR 2013-004 ML13164A359 2.2.1.2 Assess the effects of the flood on the Auxiliary Feedwater Closed System (AFW) and identify actions to restore the system IR 2012-011 ML12366A158 2.2.1.3 Assess the effects of the flood on the Auxiliary Closed Instrumentation System (AIS) and identify actions to IR 2012-011 restore the system ML12366A158 2.2.1.4 Assess the effects of the flood on the Control Rod Drive Closed System (CRD) and identify actions to restore the system IR 2012-011 ML12366A158 2.2.1.5 Assess the effects of the flood on the Chemical and Closed Volume Control System (CVC) and identify actions to IR 2012-011 restore the system ML12366A158 2.2.1.6 Assess the effects of the flood on the Circulating Water Closed System (CWS) and identify actions to restore the system IR 2013-004 ML13164A359 2.2.1.7 Assess the effects of the flood on the Emergency Core Closed Cooling System (ECC) and identify actions to restore the IR 2012-011 system ML12366A158 2.2.1.8 Assess the effects of the flood on the Emergency Diesel Closed Generator System (EDG) and identify actions to restore IR 2012-011 the system. ML12366A158 2.2.1.9 Assess the effects of the flood on the Electrical Closed Distribution System (EDS) and identify actions to restore IR 2013-003 the system ML13130A050 2.2.1.10 Assess the effects of the flood on the Engineered Safety Closed Features System (ESF) and identify actions to restore the IR 2012-011 system ML12366A158 2.2.1.11 Assess the effects of the flood on the Fuel Handling Closed System (FHS) and identify actions to restore the system IR 2012-011 ML12366A158 2.2.1.12 Assess the effects of the flood on the Fire Protection Closed System (FPS) and identify actions to restore the system IR 2013-003 ML13130A050 2.2.1.13 Assess the effects of the flood on the Hoisting Equipment Closed System (HES) and identify actions to restore the system IR 2012-011 ML12366A158 2.2.1.14 Assess the effects of the flood on the Instrument Air Closed System (IAS) and identify actions to restore the system IR 2012-011 ML12366A158 2.2.1.15 Assess the effects of the flood on the Main Feedwater Closed System (MFW) and identify actions to restore the system IR 2012-011 ML12366A158 2.2.1.16 Assess the effects of the flood on the Reactor Coolant Closed System (RCS) and identify actions to restore the system IR 2012-012 ML13045B055 2.2.1.17 Assess the effects of the flood on the Radiation Closed Monitoring System (RMS) and identify actions to restore IR 2012-011 the system ML12366A158 2.2.1.18 Assess the effects of the flood on the Reactor Protection Closed System (RPS) and identify actions to restore the system IR 2012-012 ML13045B055 2.2.1.19 Assess the effects of the flood on the Spent Fuel Pool Closed System (SFP) and identify actions to restore the system IR 2012-012 ML13045B055 2.2.1.20 Assess the effects of the flood on the Steam Generator Closed System (SGS) and identify actions to restore the system IR 2012-012 ML13045B055 2.2.1.21 Assess the effects of the flood on the Sampling System Closed (SLS) and identify actions to restore the system IR 2012-012 ML13045B055 2.2.1.22 Assess the effects of the flood on the Structures Closed System (STR) and identify actions to restore the system IR 2013-016 To be issued 2.2.1.23 Assess the effects of the flood on the Turbine Generator Closed System (TGS) and identify actions to restore the system IR 2012-012 ML13045B055 2.2.1.24 Assess the effects of the flood on the Turbine Plant Closed Cooling System (TPC) and identify actions to restore the IR 2012-012 system ML13045B055 2.2.1.25 Assess the effects of the flood on the Ventilating Air Closed Conditioning System (VAC) and identify actions to restore IR 2013-003 the system. ML13130A050 2.2.1.26 Assess the effects of the flood on the Waste Disposal Closed System (WDS) and identify actions to restore the system. IR 2012-012 ML13045B055 2.2.1.27 Assess the effects of the flood on the Demineralized Closed Water/ Potable Water System (DW/PW) and identify IR 2012-012 actions to restore the system. ML13045B055 2.2.1.28 Assess the effects of the flood on the Vents and Drains Closed System (VDS) and identify actions to restore the system. IR 2013-004 This will include Sanitary and Storm Drains. ML13164A359 2.2.1.29 Assess the effects of the flood on the Auxiliary Steam Closed System (AUS) and identify actions to restore the system. IR 2013-004 This will include the Auxiliary Boiler. ML13164A359 2.2.1.30 Assess the effects of the flood on the Meteorological Closed Monitoring System (MMS) and identify actions to restore IR 2012-012 the system. ML13045B055 2.2.1.31 Assess the effects of the flood on the Plant Security Closed Systems (SEC) and identify actions to restore the IR 2013-407 system. ML13213A497 2.2.1.32 Assess the effects of the flood on the Communications Closed Systems (COM) and identify actions to restore the IR 2012-005 system. ML12318A341 Although not a specific plant restart action, the NRC will review the following long term actions planned to be implemented by the licensee.

Action Actions to Be Reviewed Status Item Number 1.2.3.21 Inspect tank and equipment on DI tank for damage Post restart item 1.2.3.58 Repair, replace and test B.5.b equipment as necessary Closed IR 2012-012 ML13045B055 1.2.3.82 Perform Independent Spent Fuel Storage Installation Post restart item (ISFSI) route load test Item 2.b System Readiness from Extended Shutdown Systems that have been shut down for prolonged periods may be subject to different environments than those experienced during power operations. The NRC will evaluate the effects of the extended shutdown, and verify that the structures, systems, and components are ready for plant restart and they conform to the licensing and design bases requirements.

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

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

Item Actions to Be Verified Prior to Restart Status 2.b.1.1 Auxiliary Cooling System Closed IR 2013-016 To be issued 2.b.1.2 Auxiliary Feedwater System Closed IR 2013-016 To be issued 2.b.1.3 Spent Fuel Pool System Closed IR 2013-014 ML13266A225 2.b.1.4 Sampling System Closed IR 2013-014 ML13266A225 2.b.1.5 Chemical and Volume Control System Closed IR 2013-016 To be issued 2.b.1.6 Emergency Core Cooling System Closed IR 2013-016 To be issued 2.b.1.7 Hoisting Equipment System Closed IR 2013-014 ML13266A225 2.b.1.8 Waste Disposal System Closed IR 2013-014 ML13266A225 2.b.1.9 Control Rod Drive System Closed IR 2013-016 To be issued 2.b.1.10 Reactor Coolant System Closed IR 2013-014 ML13266A225 2.b.1.11 Demineralized and Potable Water Systems Closed IR 2013-005 ML13221A584 2.b.1.12 Circulating Water System Closed IR 2013-005 ML13221A584 2.b.1.13 Emergency Diesel Generator Closed IR 2013-016 To be issued 2.b.1.14 Ventilation, Heating and Air Conditioning System Closed IR 2013-016 To be issued 2.b.1.15 Main Feedwater System Closed IR 2013-016 To be issued 2.b.1.16 Structures Closed IR 2013-016 To be issued 2.b.1.17 Steam Generator System Closed IR 2013-016 To be issued 2.b.1.18 Steam Generator Blowdown Turbine Plant Cooling Closed IR 2013-014 ML13266A225 2.b.1.19 Instrument Air System Closed IR 2013-014 ML13266A225 2.b.1.20 Turbine Generator and Support Systems Closed IR 2013-014 ML13266A225 2.b.1.21 Auxiliary Instrumentation System Closed IR 2013-014 ML13266A225 2.b.1.22 Electrical Distribution System Closed IR 2013-016 To be issued 2.b.1.23 Engineered Safeguards System Closed IR 2013-016 To be issued 2.b.1.24 Radiation Monitoring System Closed IR 2013-016 To be issued 2.b.1.25 Fuel Handling System Closed IR 2013-014 ML13266A225 2.b.1.26 Reactor Protective System Closed IR 2013-016 To be issued 2.b.1.27 Fire Protection System Closed IR 2013-005 ML13221A584 Item 2.b.2 Detailed Review of Alternating and Direct Current Electrical Distribution, High Pressure Safety Injection System, Emergency Diesel Generator System, and Reactor Protection System Fort Calhoun Station will perform a comprehensive review to evaluate and verify the capability of selected systems to fulfill their intended safety functions as defined by the licensing and design basis and identify broad-based safety, organizational, and performance issues. The review is structured consistent with NRC Inspection Procedure 95003 (Sections 02.03 and 03.03), and is accomplished by review in the six key attributes.

The selected systems for detailed review (vertical slice) as part of the Reactor Safety Strategic Performance Area were based on its high risk significance, input from system health reports, performance indicators, condition reports, and licensee event reports. Teams of Omaha Public Power District and independent external experts will perform the Reactor Safety Strategic Performance Area reviews.

Systems selected are:

AC and DC Electrical Distribution Systems. These systems include the 4160V breakers, 480V breakers, batteries, and battery chargers. Electrical distribution systems at Fort Calhoun Station provide necessary power for Mitigating Systems. The AC and DC systems provide power to key pumps, motors, valves, and instruments required to monitor and respond to plant conditions. From the plants probabilistic assessment, the AC and DC electrical systems account for a substantial portion of plant risk. The electrical distribution system was selected for self-assessment by the licensee based on both identified issues and their importance to safety.

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

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

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

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

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

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

condition of subsurface soil; and

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

Action Item Actions to be Verified Prior to Restart Status Number 1.2.1.3 Repair any structural damage identified in the intake Closed structure IR 2013-005 ML13221A584 2.1.1.1 Ensure underground FP piping is intact and no Closed unacceptable voids are present near FP piping IR 2013-005 ML13221A584 2.1.1.5 Verify soil compaction and moisture content in areas of Closed underground fire protection main header ring and IR 2013-005 attached piping is per NFPA requirements ML13221A584 3.3.1.1 Inspect underground Raw Water, EDG Fuel Oil and Fire Closed Protection piping and tanks using GPR (Ground IR 2013-005 Penetrating Radar) ML13221A584 3.3.1.3 Resolve any deficiencies affecting operability or Closed functionality (if needed) IR 2013-016 To be issued 4.1.1.12 Review structure design features to assess potential for Closed damage due to flooding IR 2013-005 ML13221A584 4.1.1.14 Assess post-inundation condition of structures Closed IR 2013-005 ML13221A584 4.1.1.15 Prepare remediation alternatives (if appropriate) Closed IR 2013-005 ML13221A584 4.1.1.16 Create report of findings Closed IR 2013-005 ML13221A584 4.1.1.17 Review findings and recommendations with FCS and Closed document results IR 2013-005 ML13221A584 4.1.1.20 Inspect Non-Class 1 Priority 1 Structures Closed IR 2013-005 ML13221A584 4.1.1.21 Assess post-inundation condition of structures Closed IR 2013-005 ML13221A584 4.1.1.22 Prepare remediation alternatives (if appropriate) Closed IR 2013-005 ML13221A584 4.1.1.23 Create report of findings Closed IR 2013-005 ML13221A584 4.1.1.24 Review findings and recommendations with FCS and Closed document results IR 2013-005 ML13221A584 4.1.1.25 Post-Flood River Channel Evaluation Closed IR 2013-016 To be issued 4.1.1.30 Verify no geotechnical or structural impact to Turbine Closed Building and Auxiliary Building/Containment as a result IR 2013-016 of the 2011 flood To be issued 4.1.1.32 Remediation of the Turbine Building and Class 1 Closed structure void IR 2013-016 To be issued 4.1.2.2 Verify no geotechnical or structural impact to site Closed structures IR 2013-005 ML13221A584 4.1.3.10 Remediation of the loose soils area under the Turbine Closed Building and Class 1 structures if required IR 2013-016 To be issued Although not a specific plant restart action, the NRC will review the following long term actions planned to be implemented by the licensee.

Action Actions to be Reviewed Status Item Number 1.2.3.57 Repair ISFSI as necessary (structural) Closed IR 2013-005 ML13221A584 1.2.3.79 Repair the ISFSI haul route as necessary Closed IR 2013-005 ML13221A584 Item 2.c Qualification of Containment Electrical Penetrations During the course of discovery activities, Fort Calhoun Station staff identified that certain containment electrical penetrations contain materials that could degrade under the post-accident radiation profile inside containment. This issue was entered into the licensees Corrective Action Program.

With respect to this issue, the NRC will verify that the licensee adequately identifies the root and contributing causes of the issue; verify that the extent of condition and extent of causes of the issue are identified, and verify that the corrective actions adequately address the problem.

The following licensee actions will be reviewed by the NRC:

Item Actions to be Verified Prior to Restart Status 2.c.1 Containment electrical penetrations root and contributing Closed cause evaluation IR 2013-013 To be issued 2.c.2 Containment electrical penetrations extent of condition and Reviews near cause evaluation completion 2.c.3 Containment electrical penetrations corrective actions Reviews near completion LER 2012-002 Inadequate Qualifications for Containment Penetrations Closed Renders Containment Inoperable IR 2013-013 To be issued Item 2.d Containment Internal Structure During the course of discovery activities, Fort Calhoun Station staff identified that certain containment internal structural members do not fully meet design specifications described in the licensing basis. The structural design of the containment internal structures is being re-analyzed by the licensee to assess the extent of condition and determine the scope of corrective actions.

With respect to this issue, the NRC will verify that the licensee adequately identifies the root and contributing causes of the issue; verify that the extent of condition and extent of causes of the issue are identified, and verify that the corrective actions adequately address the problem.

The following licensee actions will be reviewed by the NRC:

Item Actions to be Verified Prior to Restart Status 2.d.1 Containment internal structure root and contributing Closed cause evaluation Inspections completed Future report 2.d.2 Containment internal structure extent of condition and Closed cause evaluation Inspections completed Future report 2.d.3 Containment internal structure corrective actions Closed Inspections completed Future report LER 2012- Containment Beam 22 Loading Conditions Outside of Closed 014 the Allowable Limits Inspections completed Future report Section 3: Adequacy of Significant Programs and Processes Section 3 of the Restart Checklist addresses major programs and processes in place at Fort Calhoun Station. Section 3 reviews will also include an assessment of the adequacy of licensee reviews in context of NRC Inspection Procedure 95003 key attributes as described in Section 5.

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

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

Item Actions to Be Verified Prior to Restart Status 3.a.1 Licensee Assessment of Corrective Action Program Closed Inspections completed Future report 3.a.2 Adequacy of extent of condition and extent of causes Closed Inspections completed Future report 3.a.3 Adequacy of corrective actions Closed Inspections completed Future report 3.a.4 Adequacy of effectiveness measures to monitor Closed program improvements Inspections completed Future report The site performed an integrated assessment and identified 15 Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. The Corrective Action Program was identified as one of these areas for improvement. Examples identified by the licensee included problems not being thoroughly evaluated to determine the causes; corrective actions lack clarity or do not correlate to the root and contributing causes, condition reports are assigned incorrect significance levels, and corrective actions are not completed in a timely manner. With respect to this FPD, the NRC will assess the following:

Item Actions to Be Verified Prior to Restart Status 3.a.5 Licensee Assessment of the Fundamental Closed Performance Deficiency associated with the Inspections completed Corrective Action Program Future report 3.a.6 Adequacy of extent of condition and extent of causes Closed Inspections completed Future report 3.a.7 Adequacy of corrective actions Closed Inspections completed Future report Licensee evaluations identified that the site Operating Experience Program is not effectively implemented to enhance the performance of the Station. The practice of learning from internal and external industry events has not been internalized. The screening process is not being consistently applied to preclude events. There are weaknesses in the training and qualification of individuals assigned to administer and implement the program. Program expectations are unclear and there is a lack of management oversight to ensure adequate implementation. To assess the licensees actions in regards to these deficiencies the NRC will review the following:

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

Item Description Status NCV 2012004-01 Failure to report an event to the NRC within 60 Closed days for an operation prohibited by Technical IR 2013-008 Specifications ML13197A261 VIO 2011006-02 Inadequate Corrective Actions to Ensure Closed Reliability of Raw Water Pump Power Inspections completed Future report NCV 2011006-06 Failure to Implement an Adequate Trending Closed Program Inspections completed Future report NCV 2011004-01 Failure to Incorporate Design Information into Closed Procedures IR 2013-008 ML13197A261 NCV 2011002-02 Failure to Determine the Cause of the Out Of Closed Tolerance Condition Regarding Reactor IR 2013-008 Protection System Channel A Trip Unit 6 ML13197A261 NCV 2011002-03 Failure to Submit a Timely Licensee Event Closed Report IR 2013-008 ML13197A261 NCV 2011002-04 Failure to Verify Design Adequacy of Refueling Closed Water Tank Vortex Eliminator IR 2013-008 ML13197A261 NCV 2010002-01 Inadequate Reportability Guidance Closed IR 2013-008 ML13197A261 NCV 2010003-01 Failure to Provide Adequate Limiting Condition Closed for Operation for High River Level Inspections completed Future report NCV 2010003-05 Failure to Submit a Required Licensee Event Closed Report IR 2013-008 ML13197A261 NCV 2010004-02 Failure to Submit a Required Licensee Event Closed Report IR 2013-008 ML13197A261 NCV 2010004-04 Failure to Translate Calculation into Calibration Closed Procedure IR 2013-008 ML13197A261 Specific independent inspections will include assessing the Corrective Actions Program effectiveness in resolving the issues submitted in the following Licensee Event Reports.

Item Description Status LER 2012-011 Emergency Diesel Inoperability Due to Bus Loads Closed During a LOOP IR 2013-005 ML13221A584 LER 2012-010 Seismic Qualification of Instrument Racks Reviews near completion LER 2012-007 Failure of Pressurizer Heater Sheath Closed Inspections completed Future report LER 2012-006 Operation of Component Cooling Pumps Outside Reviews near Manufacturers Recommendation completion LER 2012-004 Inadequate Analysis of Drift Affects Safety Closed Related Equipment Inspections completed Future report LER 2012-003 Non-Conservative Error in Calculation for Closed Alternate Hot Leg Injection Results in Hot Leg IR 2013-08 Injection Results in Unanalyzed Condition ML13197A261 Because the overall health of a licensees corrective action program is key to sustaining operational safety the NRC will not only be performing routine inspections of this program, but will also perform a Team inspection following the guidance in NRC Inspection Procedure 71152, Problem Identification and Resolution. This inspection will focus on ensuring that the corrective action program is effectively being implemented and addressing those items related to design, human performance, procedure quality, equipment performance, configuration control, emergency response, occupational radiation safety, and public radiation safety. These items are defined as Key Attributes in NRC Inspection Procedure 95003. Additionally, the NRC will assess on the resolution of specific equipment issues that are known to exist.

Item Description Status 3.a.12 Perform NRC Team Problem Identification and Closed Resolution inspection Inspections completed Future report 3.a.13 Raw Water Pump C high vibrations Closed IR 2013-015 ML13312A876 3.a.14 Reactor cavity leakage Closed IR 2013-015 ML13312A876 3.a.15 Effects on equipment impacted by reactor cavity Closed leakage IR 2013-015 ML13312A876 Item 3.b Equipment Design Qualifications This item of the Restart Checklist verifies that plant components are maintained within their licensing and design basis. Additionally, this item provides monitoring of the capability of the selected components and operator actions to perform their functions. As plants age, modifications may alter or disable important design features making the design bases difficult to determine or obsolete. The plant risk assessment model assumes the capability of safety systems and components to perform their intended safety function successfully.

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

Action Actions to be Verified Prior to Restart Status Item Number 4.6.1.1 Address concerns identified with the Reactor Coolant Closed Pump oil collection system IR 2013-014 ML13266A225 4.6.1.2 Address non-conservative 161 kV minimum voltage to Closed support operation of a main feedwater pump in a Safety IR 2013-015 Injection Actuation Signal (SIAS)-only scenario ML13312A876 (CR 2011-6725) 4.6.1.3 Provide analysis of Steam Generator accident ring Reviews Pending (CR 2011-6825) Completion of Actions by OPPD The following NRC items are specifically related to maintaining systems, structures, and components within their licensing and design basis. For these specific items, the NRC will verify that the licensee has performed adequate casual analysis and extent of condition evaluations related to the issues. The NRC will verify that adequate corrective actions were identified associated with the licensees casual analysis and extent of condition evaluations and that implementation of corrective actions are either implemented or appropriately scheduled for implementation. These assessments will provide the NRC insights regarding the licensees ability to effectively resolve equipment design qualification problems.

Item Description Status LER 2012-020 Raw Water Pump Anchors Closed IR 2013-012 ML13144A772 LER 2012-016 Unanalyzed Charging System Socket Welds to Reviews in progress the Reactor Coolant System LER 2012-013 Inadequate Calculation of Uncertainty Results in Reviews in progress a Technical Specification Violation NCV 2011003 Failure to Adequately Design a Reactor Coolant Closed Pump Lube Oil Collection System IR 2013-014 ML13266A225 LER 2013-003 Unanalyzed Condition Due to Possible Run-Out Reviews Pending of High Pressure Safety Injection Pump Completion of Actions by OPPD LER 2013-004 Inverters Potentially Inoperable During Reviews near Emergency Diesel Generator Operation completion LER 2013-001 Relay Backing Plate Fasteners Discovered to be Reviews Pending at Less than Specified Torque Completion of Actions by OPPD LER 2013-006 Low Pressure Safety Injection and Containment Reviews in progress Spray Pumps Mechanical Seals Item 3.b.1 Safety Related Parts Program A number of instances have been identified where non-safety-related parts have been installed into safety-related applications. Fort Calhoun Station will perform reviews to identify conditions where a non-safety-related component or subcomponent were improperly used in a safety-related application.

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

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

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

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

Action Actions to be Verified Prior to Restart Status Item Number 3.b.2.1 Licensee assessment of high energy line break program Reviews Pending and equipment qualifications Completion of Actions by OPPD 3.b.2.2 Adequacy of extent of condition and extent of causes Reviews Pending Completion of Actions by OPPD 3.b.2.3 Adequacy of corrective actions Reviews Pending Completion of Actions by OPPD 4.5.1.8 Complete Equipment Environmental Qualification (EEQ) Reviews Pending Harsh Environment analysis for Room 13 crack in Steam Completion of Actions Generator Blowdown system by OPPD 4.5.1.9 Develop plan to address Room 13 EEQ harsh Reviews Pending environment qualification of electrical equipment Completion of Actions by OPPD 4.5.1.10 Initiate actions to resolve Room 13 EEQ harsh Reviews Pending environment qualification of equipment which must be Completion of Actions addressed prior to leaving cold shutdown by OPPD 4.5.1.11 Resolve Room 13 EEQ harsh environment qualification of Reviews Pending equipment which must be addressed prior to leaving cold Completion of Actions shutdown by OPPD 4.5.1.12 Perform analysis to address HCV-1385/1386 Main Steam Reviews Pending Line Break/Feedwater isolation concern (CR 2011-6757) Completion of Actions by OPPD 4.5.1.13 Implement resolution of HCV-1385/1386 Main Steam Line Reviews Pending Break/Feedwater isolation concern Completion of Actions by OPPD 4.5.1.14 Perform High Energy Line Break (HELB) analysis of Reviews Pending Auxiliary Steam piping in the auxiliary building Completion of Actions by OPPD 4.5.1.15 Implement resolution of Auxiliary Steam piping in the Reviews Pending auxiliary building Completion of Actions by OPPD The following NRC open items are specifically related to high energy line break and equipment qualification concerns. For these specific items, the NRC will verify that the licensee has performed adequate root cause and extent of condition evaluations related to the failures resulting in the event. In addition, the NRC will verify that adequate corrective actions were identified associated with the licensees root and contributing causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status LER 2012-017 Containment Valve Actuators Design Reviews Pending Temperature Ratings Below those Required for Completion of Actions Design Basis Accidents by OPPD LER 2012-015 Electrical Equipment Impacted by High Energy Reviews Pending Line Break Outside Containment Completion of Actions by OPPD LER 2012-009 Inoperable Equipment Due to Lack of Closed Environmental Qualifications IR 2013-005 ML13221A584 Item 3.c Design Changes and Modifications Modifications to risk-significant structures, systems, and components can adversely affect its availability, reliability, or functional capability. Modifications to one system may also affect the design bases and functioning of interfacing systems. Similar modifications to several systems could introduce potential for common cause failures that affect plant risk. A temporary modification may result in a departure from the design basis and system success criteria.

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

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

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

Action Actions to be Verified Prior to Restart Status Item Number 4.5.1.1 Review of EC 53202; FW-10 Steam Line HELB Reviews Pending Modification Completion of Actions by OPPD 4.5.1.2 Final Station Modification Acceptance Review Team Reviews Pending (SMART) Review of EC 53202; FW-10 Steam Line Completion of HELB Modification Actions by OPPD 4.5.1.3 Plant Review Committee review of EC 53202; FW-10 Reviews Pending Steam Line HELB Modification Completion of Actions by OPPD 4.5.1.4 Develop Construction Work Orders for EC 53202; Reviews Pending FW-10 Steam Line HELB Modification Completion of Actions by OPPD 4.5.1.5 Complete installation of EC 53202; FW-10 Steam Line Reviews Pending HELB Modification Completion of Actions by OPPD 4.5.1.6 Prepare EC 52662; Add a new Pipe Support on the Reviews Pending SGBD vertical line above FW-1020 Completion of Actions by OPPD 4.5.1.7 Install EC 52662; Add a new Pipe Support on the SGBD Reviews Pending vertical line above FW-1020 Completion of Actions by OPPD Item 3.c.1 Vendor Modification Control The NRC inspections and licensee evaluations have identified that vendor modification packages do not consistently ensure critical characteristics are identified and properly addressed. Additionally, examples exist that demonstrate an engineering overreliance on vendor knowledge and skill and the failure to provide the appropriate level of oversight for vendor related activities.

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

Item Actions to Be Verified Prior to Restart Status 3.c.1.1 Licensee assessment of vendor modification control Closed processes IR 2013-015 ML13312A876 3.c.1.2 Adequacy of extent of condition and extent of causes Closed IR 2013-015 ML13312A876 3.c.1.3 Adequacy of corrective actions Closed IR 2013-015 ML13312A876 Item 3.c.2 10 CFR 50.59 Screening and Safety Evaluations The NRC inspections indicated that several changes to the facility were not properly screened or evaluated per the requirements 10 CFR 50.59. Plant and procedure modifications will be reviewed to determine if modifications required a 10 CFR 50.59 review. The licensee also determined that the 50.59 Program is not being effectively implemented consistently and is performing a root cause analysis. The NRC will evaluate the adequacy of the licensees assessment, the thoroughness of their extent of condition and causal analysis, and the adequacy of identified corrective actions to ensure proper treatment of changes to the facility.

Item Actions to Be Verified Prior to Restart Status 3.c.2.1 Licensee Assessment of the 50.59 process Closed IR 2013-008 ML13197A261 3.c.2.2 Adequacy of extent of condition and extent of causes Closed Inspections completed Future report 3.c.2.3 Adequacy of corrective actions Closed Inspections completed Future report The following NRC items are specifically related to 10 CFR 50.59 concerns. For these specific items the NRC will verify that the licensee has performed adequate root cause and extent of condition evaluations related to the event. In addition, the NRC will verify that adequate corrective actions were identified associated with the licensees root and contributing causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status URI 2011014-02 Failure to Perform Adequate 10 CFR 50.59 Closed Review IR 2013-008 ML13197A261 NCV 2010004-05 Failure to Perform a 10 CFR 50.59 Evaluation Closed IR 2013-008 ML13197A261 Item 3.d Maintenance Programs Inadequate maintenance activities that are not detected prior to returning the equipment to service can result in a significant increase in unidentified risk for the subject system.

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

The site performed an integrated assessment and identified 15 Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. Equipment Reliability/Work Management was identified as one of the areas for improvement. Examples identified by the licensee included intolerance to equipment failures has not been established; engineering and maintenance strategies are not focused on critical components; long term strategies have not been developed for age related degradation; the maintenance rule function to monitor the performance of plant equipment has not been effectively implemented. With respect to this FPD, the NRC will assess the following:

Item Actions to Be Verified Prior to Restart Status 3.d.1 Licensee Assessment of the Fundamental Closed Performance Deficiency associated with Equipment Inspections completed Reliability/Work Management Future report 3.d.2 Adequacy of extent of condition and extent of Closed causes Inspections completed Future report 3.d.3 Adequacy of corrective actions Closed Inspections completed Future report Item 3.d.1 Vendor Manuals and Vendor Informational Control Programs The NRC inspections and licensee evaluations identified that vendor manuals and information have not been adequately maintained, which resulted in adverse conditions at Fort Calhoun Station. The licensee will perform a review to identify and incorporate updates to vendor manual technical documentation. This review applies to all equipment and components classified as a Critical Quality Element (safety-related).

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

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

Item Actions to Be Verified Prior to Restart Status 3.d.1.1 Licensee Assessment of Vendor Informational Control Closed Program IR 2013-008 ML13197A261 3.d.1.2 Adequacy of extent of condition and extent of causes Closed IR 2013-008 ML13197A261 3.d.1.3 Adequacy of corrective actions Closed IR 2013-008 ML13197A261 The following NRC item is specifically related to vendor manual and vendor information control concerns. For this specific item the NRC will verify that the licensee has performed adequate casual analysis and extent of condition evaluations related to the issue. In addition, the NRC will verify that adequate corrective actions were identified associated with the causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status NCV 2011006-05 Failure to Establish Adequate Measures to Closed Maintain Vendor Manual Design Control IR 2013-008 Information ML13197A261 Item 3.d.2 Equipment Service Life NRC inspections determined that the licensee opted to keep some plant equipment in service beyond the vendor recommended service life or standard industry guidelines. Operating equipment past the recommended replacement timeline has resulted in age-related failures at Fort Calhoun Station. In response, the licensee will perform an assessment to evaluate the service life of safety-related plant equipment and the effectiveness of programs used to implement service life requirements. The NRC will inspect and assess the adequacy of this evaluation and the associated corrective actions.

Item Actions to Be Verified Prior to Restart Status 3.d.2.1 Licensee Assessment of equipment service life program Closed IR 2013-013 To be issued 3.d.2.2 Adequacy of extent of condition and extent of causes Closed IR 2013-013 To be issued 3.d.2.3 Adequacy of corrective actions Closed IR 2013-013 To be issued The NRC will verify that the following actions being implemented by the licensee adequately address equipment service life issues at the facility. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number 3.4.1.1 Replace Non-RPS CQE (reactor protection system critical Closed quality equipment) power supplies that will be beyond their IR 2013-013 recommended service life To be issued 3.4.2.1 Establish High Impact Team with a Charter Closed IR 2013-002 ML13092A286 3.4.2.2 Identify all CQE power supplies; priority will be on RPS Closed CQE power supplies and then non-RPS CQE power IR 2013-013 supplies To be issued 3.4.2.3 Determine the installation date for FCS CQE power Closed supplies; these dates will be used to define those CQE IR 2013-013 power supplies that are beyond their service life To be issued 3.4.2.4 Conduct an industry and FCS specific analysis of historical Closed performance for CQE power supplies; determine the IR 2013-013 effectiveness of the current Equipment Reliability (ER) To be issued Strategies at the FCS component level 3.4.2.5 Conduct an analysis of the current FCS ER Strategy for Closed power supplies; contact vendors, review industry IR 2013-013 documentation, benchmark other plants To be issued 3.4.2.6 Determine the recommended service life for CQE power Closed supplies based on analyses performed earlier in this action IR 2013-013 plan. To be issued These service lives will be based on: (1) manufacturer and model; (2) qualified life testing; (3) vendor recommendations and communication with vendors; (4) remnant life based on stress testing of removed power supplies; (5) industry and FCS specific historical performance; and (6) actual duty cycle and service condition where these power supplies are installed 3.4.2.7 Conduct a failure modes and effects analysis on each Closed power supply to ensure the impact of failures is IR 2013-013 understood To be issued 3.4.2.8 Document the time based replacement strategy and basis Closed for CQE and RPS power supplies. IR 2013-013 This strategy and basis will provide the tasks to be To be issued performed and the basis for the scope and frequency of those tasks. This action is being completed before start up to ensure each power supply has been analyzed and a recommended service life defined 3.4.2.9 Define those power supplies that are beyond their service Closed life. This will include power supplies that will be beyond IR 2013-013 their service life before the next planned refueling outage To be issued 3.4.2.10 Replace RPS CQE power supplies beyond their service Closed life IR 2013-013 To be issued 3.4.2.11 Replace Non-RPS CQE power supplies that will be Closed beyond their recommended service life IR 2013-013 To be issued The following NRC open item is specifically related equipment service life concerns and therefore will be reviewed by the NRC prior to restart of the facility. For this specific item the NRC will verify that the licensee has performed adequate casual analysis and extent of condition evaluations related to the failures. In addition, the NRC will verify that adequate corrective actions were identified associated with the causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status NCV 2011003-04 Failure to Provide Procedural Guidance to Closed Replace or Evaluate Age Degraded Components IR 2013-013 To be issued Although not a specific plant restart action, the NRC will review the following long-term actions planned to be implemented by the licensee.

Action Description Status Item Number 3.4.3.1 Complete the development of the ER strategy for CQE Closed power supplies. This action will include all tasks to be IR 2013-013 performed and basis for those tasks and PM (Preventative To be issued Maintenance) Change Requests for any PM change 3.4.3.2 Implement PM Change Requests by changing PMs in Closed Asset Suite. Validate PM changes in Asset Suit to be IR 2013-013 correct To be issued 3.4.3.3 Schedule new and revised PMs Closed IR 2013-013 To be issued Item 3.e Operability Process Improper evaluations of degraded and/or non-conforming conditions may result in continued operation with a structure, system, or component that is not capable of performing its design function.

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

The site performed an integrated assessment and identified 15 Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of the deficiencies identified was Processes to Meet Regulatory Requirements. Examples in this area included the site does not consistently recognize degraded-nonconforming conditions; and operability determinations and functional assessments are not sufficiently rigorous.

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

Item Actions to Be Verified Prior to Restart Status 3.e.1 Licensee Assessment of the Fundamental Reviews near Performance Deficiency associated with Processes to completion Meet Regulatory Requirements specifically related to the Operability Determination Process 3.e.2 Adequacy of extent of condition and extent of causes Reviews near completion 3.e.3 Adequacy of corrective actions Reviews near completion Item 3.f Quality Assurance Quality Assurance is an important program at nuclear power plants. It is designed to be an independent group that assesses plant workers in the performance of a broad range of safety-related work or evaluations. Through quality assurance assessments or audits, problems and trends can be identified before they become significant plant problems.

The site performed an integrated assessment and identified 15 Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of these deficiencies involved the effectiveness of Nuclear Oversight (NOS). Examples, included NOS, did not identify many of the substantive issues that have resulted in the decline in station performance; NOS has not performed critical and intrusive reviews focused on behaviors; NOS neither collected nor integrated performance data from line organizations; and issues identified by NOS are not communicated in a manner that compels site leaders to act.

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

Item Actions to Be Verified Prior to Restart Status 3.f.1 Licensee assessment of the Fundamental Closed Performance Deficiency associated with Nuclear IR 2013-008 Oversight effectiveness ML13197A261 3.f.2 Adequacy of extent of condition and extent of causes Closed IR 2013-008 ML13197A261 3.f.3 Adequacy of corrective actions Closed IR 2013-008 ML13197A261 3.f.4 Adequacy of recent Nuclear Oversight audits Closed IR 2013-008 ML13197A261 3.f.5 Effectiveness of Safety Audit and Review Committee Closed IR 2013-008 ML13197A261 Section 4: Review of Integrated Performance Improvement Plan Section 4 of the Restart Checklist is provided to assess Fort Calhoun Stations Integrated Performance Improvement Plan. OPPD has docketed the Integrated Performance Improvement Plan, which details the plans and actions needed to address the conditions that transitioned FCS to NRC oversight under IMC 0350.

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

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

Item Description Status 4.1 Review of Integrated Performance Improvement Plan Reviews in progress Section 5: Assessment of NRC Inspection Procedure 95003 Key Attributes Section 5 of the Restart Checklist is provided to assess the key attributes of NRC Inspection Procedure 95003. The key attributes are listed as separate subsections below. It is intended that the activities in these subsections be conducted in conjunction with reviews and inspections for Sections 1 - 4, rather than a stand-alone review. In addition, the NRC will review the effectiveness of licensee short term and long term corrective actions associated with these areas to ensure they are adequate to support sustained plant performance improvement.

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

assessment of effectiveness of corrective actions for deficiencies involving design;

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

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

evaluation of the interfaces between engineering, plant operations, maintenance, and plant support groups Item Description Status 5.a.1 Perform NRC design engineering team inspection of Reviews Pending the Auxiliary Feedwater System Completion of Actions by OPPD The site performed an integrated assessment and identified 15 Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of the deficiencies identified was Engineering Design/Configuration Control. Examples in this area included changes to plant configuration and design and licensing basis are not effectively analyzed, controlled, and implemented; incomplete documentation and poorly written justifications in modification packages; and evaluations of fit, form, and function have been inadequate.

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

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

Item Description Status NCV 2010006-01 Failure to Correct Repeated Tripping of the Closed Turbine-driven Auxiliary Feedwater Pump FW-10 IR 2013-013 To be issued NCV 2010006-02 Failure to Verify that the Turbine-driven Auxiliary Closed Feedwater Pump Exhaust Backpressure Trip IR 2013-008 Lever was Fully Latched ML13197A261 NCV 2010006-03 Failure to Vent Control Oil Following Closed Maintenance Results in Failure of the Turbine- IR 2013-008 driven Auxiliary Feedwater Pump to Start ML13197A261 NCV 2010006-04 Turbine-driven Auxiliary Feedwater Pump Trip Closed Due to Inadequate Design Margin IR 2013-008 ML13197A261 Item 5.b Human Performance By nature of the design of nuclear power plants and the role of plant personnel in maintenance, testing and operation, human performance plays an important part in normal, off-normal, and emergency operations. Human performance impacts each of the cornerstones and therefore should be considered across all inspections conducted at Fort Calhoun Station.

The site performed an integrated assessment and identified 15 Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of the deficiencies identified was Human Performance. Examples in this area included the station lacks an integrated approach to solving human performance issues; station leaders do not reinforce use of the tools that reduce human performance errors, human performance improvement tools are not consistently utilized; and weaknesses in the site observation program are contributing to ongoing human performance problems.

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

Item Description Status 5.b.1 Licensee Assessment of the Fundamental Performance Closed Deficiency of Human Performance IR 2013-008 ML13197A261 5.b.2 Adequacy of extent of condition and extent of causes Closed IR 2013-008 ML13197A261 5.b.3 Adequacy of corrective actions Closed IR 2013-008 ML13197A261 Item 5.c Procedure Quality Inadequate procedures can cause initiating events by inducing plant personnel to take inappropriate actions during plant operations, maintenance, calibration, testing, or event response. Adequate procedures also assure proper functioning of mitigating systems during operation, maintenance, and testing. Emergency and abnormal operating procedures are also essential for mitigating system performance and assuring appropriate actions will be taken to preserve reactor coolant system (RCS) and containment integrity.

The site performed an integrated assessment and identified 15 Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of the deficiencies identified was Procedure Quality/Procedure Management. Examples in this area included inaccurate or incomplete procedures have contributed to multiple significant events; some emergency and abnormal operating procedures are technically inaccurate; discrepancies occur within and between procedures; verification and validation of station procedures is not always rigorous; and the procedure maintenance group suffers from funding, training, personnel resources, and management support.

The NRC will evaluate the thoroughness of the licensees Procedure Quality/Procedure Management evaluation, adequacy of extent of condition and extent of causal analysis, and adequacy of associated corrective actions.

Item Description Status 5.c.1 Licensee Assessment of the Fundamental Closed Performance Deficiency of Procedure Inspections completed Quality/Procedure Management Future report 5.c.2 Adequacy of extent of condition and extent of Closed causes Inspections completed Future report 5.c.3 Adequacy of corrective actions Closed Inspections completed Future report The following NRC items are specifically related to procedural quality concerns and therefore will be evaluated by the NRC to assess the effectiveness of the licensees ability to resolve procedural issues. For these specific items the NRC will verify that the licensee has performed adequate casual analysis and extent of condition evaluations related to the deficient procedural guidance. In addition, the NRC will verify that adequate corrective actions were identified associated with the causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status NCV 2012301-01 Seven Examples of Inadequate Procedures Closed for the Mitigating Systems Cornerstone Inspections completed Future report NCV 2012301-04 Five Examples of Inadequate Procedures for Closed the Initiating Events Cornerstone Inspections completed Future report NCV 2012301-06 Inadequate Procedures with Four Examples Closed for the Barrier Integrity Cornerstone Inspections completed Future report NCV 2011002-01 Inadequate Operating Instruction Results in a Closed Loss of Auxiliary Feedwater Inspections completed Future report NCV 2010004-10 Inadequate Maintenance Procedure Results Closed in a Plant Shutdown Inspections completed Future report Item 5.d Equipment Performance Equipment failure or degradation can cause initiating events during power operation and losses of decay heat removal during shutdowns. To limit challenges to safety functions due to equipment problems, licensees should have programs to achieve a high degree of availability and reliability of equipment that can cause initiating events. The availability and reliability of equipment is also critical to mitigating the impact of initiating events on plant safety. Strong preventive and corrective maintenance programs are an integral part of assuring equipment availability and reliability.

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

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

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

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

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

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

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

Item Description Status LER 2012-018 Containment Air Cooling Units Operated Outside Closed of Technical Specification during Cycle 26 IR 2013-013 To be issued LER 2012-005 Technical Specification Violation Due to Closed Inadequate Testing of Emergency Diesel Fuel IR 2013-008 Pumps ML13197A261 NCV 2010004-09 Failure to perform vendor and industry Closed recommended testing on safety-related and risk- Inspections completed significant 4160 V and 480 V circuit breakers Future report Item 5.e Configuration Control The NRC will inspect and assess the licensees ability to maintain risk-significant systems and the principle fission product barriers in configurations which support their safety functions by completing the following inspection activities discussed in this basis document:

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

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

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

Review licensee actions regarding the identified Fundamental Performance Deficiency involving Engineering Design/Configuration Control.

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

Action Actions to be Verified Prior to Restart Status Item Number 4.3.1.1 Finalize identification of all configuration changes for Closed restoration IR 2012-012 ML13045B055 4.3.1.2 Finalize identification of configuration changes to be Closed made permanent IR 2012-012 ML13045B055 4.3.1.3 Establish Priority/Schedule for restoration Closed IR 2012-012 ML13045B055 4.3.1.4 Initiate actions to remove non-permanent configuration Closed changes IR 2012-012 ML13045B055 The following NRC items are specifically related to configuration control concerns and therefore will be reviewed by the NRC to assess the effectiveness of the licensees ability to resolve these issues. For these specific items the NRC will verify that the licensee has performed adequate root cause and extent of condition evaluations related to the failures. In addition, the NRC will verify that adequate corrective actions were identified associated with the licensees root and contributing causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status LER 2012-012 Multiple Safety Injection Tanks Rendered Reviews near Inoperable completion LER 2012-008 Technical Specification Violation for Fuel Closed Movement (VA-66) Inspections completed Future report Item 5.f Emergency Response Implementation of the Emergency Response Plan is dependent on the readiness of the emergency response organization to respond to an emergency. In this usage, readiness means the ability of the licensee to activate timely Emergency Response Organization augmentation of on-shift personnel as necessary to implement the emergency plan. Self-assessments of readiness during drills and activation tests are used to identify areas for improvement. Self-assessment and corrective action resolution is critical to Emergency Response Organization readiness. The NRC review includes the following inspection requirements:

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

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

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

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

Item Description Status 5.f.1 IP 71114.01, Exercise Evaluation Closed IR 2012-002 ML12132A395 5.f.2 IP 71114.02, Alert and Notification System Testing Closed IR 2012-012 ML13045B055 5.f.3 IP 71114.03, Emergency Preparedness Organization Closed Staffing and Augmentation System IR 2012-012 ML13045B055 5.f.4 IP 71114.04, Emergency Action Level and Emergency Closed Plan Changes IR 2012-002 ML12132A395 5.f.5 IP 71114.05, Maintenance of Emergency Closed Preparedness IR 2012-002 ML12132A395 5.f.6 IP 71114.06 Drill Evaluation Closed IR 2012-002 ML12132A395 The NRC will verify that the following licensee actions in the area of emergency response are adequately addressed. These items are listed in the Fort Calhoun Station Flooding and Recovery Action Plan, Revision 3, dated July 9, 2012, and consist of the following:

Action Actions to be Verified Prior to Restart Status Item Number 5.1.2.1 Procure 10 solar charging kits for nine affected sirens Closed IR 2013-002 ML13092A286 5.1.2.2 Perform fly over of flood affected sirens to determine status Closed and potential condition of the equipment IR 2013-002 ML13092A286 5.1.2.3 Based on siren inspection procure replacement siren Closed heads, poles, electronics, and power supplies IR 2012-004 ML12276A456 5.1.2.4 If siren damage and/or infrastructure is such that timely Closed repair of sirens is not possible, work with FEMA, state, and IR 2012-003 local governments for potential exemptions or long term ML12226A630 plan 5.1.2.5 Replace batteries in the affected sirens Closed IR 2012-004 ML12276A456 5.1.2.6 Install solar charging kits on the affected sirens Closed IR 2013-002 ML13092A286 5.1.2.7 Conduct siren inspections using the communications Closed developed check list IR 2012-004 ML12276A456 5.1.2.8 Conduct a full siren test after sirens have been restored to Closed functional status IR 2012-012 ML13045B055 5.1.3.1 Conduct Emergency Planning (EP) Test EP-37, Emergency Closed Sign Verification IR 2012-004 ML12276A456 5.2.1.1 Develop a field monitoring and environmental sampling plan Closed IR 2012-003 ML12226A630 5.2.2.1 Conduct a Protective Measure table top with the states of Closed Nebraska and Iowa IR 2012-003 ML12226A630 5.3.2.1 Perform Emergency Response Data System (ERDS) Closed testing IR 2012-003 ML12226A630 5.3.2.2 Perform normal communications testing Closed IR 2012-004 ML12276A456 5.3.2.3 Restore area radiation monitors Closed IR 2012-004 ML12276A456 5.3.2.4 Ensure effluent radiation monitors are functional Closed IR 2012-004 ML12276A456 5.3.2.5 Restore equipment used for emergency classification Closed IR 2012-004 ML12276A456 5.3.2.6 Perform normal facility inventories and assessments Closed IR 2013-002 ML13092A286 5.3.2.7 Conduct Meeting with FEMA, NRC, local Emergency Closed Manager, and State Emergency Managers IR 2012-003 ML12226A630 5.3.2.18 Obtain statement of Reasonable Assurance from FEMA Closed IR 2012-004 ML12276A456 5.4.2.1 Meteorological (MET) tower restoration Closed IR 2012-012 ML13045B055 5.4.2.2 MET tower building restoration Closed IR 2012-012 ML13045B055 5.4.2.3 Secondary Evacuation Route restoration Closed IR 2012-003 ML12226A630 5.4.2.4 Critique Flooding event Closed IR 2012-004 ML12276A456 The licensee performed an integrated assessment and identified 15 Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. One of the deficiencies identified was Emergency Response Organization (ERO). Examples in this area included important emergency response equipment are experiencing repeat failures; inadequate implementation and documentation of important ERO activities; and some emergency preparedness deficiencies are not effectively identified and corrected.

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

Item Description Status 5.f.7 Licensee Assessment of the Fundamental Performance Closed Deficiency of Emergency Response Organization IR 2013-010 ML13192A501 5.f.8 Adequacy of extent of condition and extent of causes Closed IR 2013-010 ML13192A501 5.f.9 Adequacy of corrective actions Closed IR 2013-010 ML13192A501 The following NRC items are specifically related to emergency response concerns and therefore will be reviewed by the NRC to assess the effectiveness of the licensees ability to resolve these issues. For these specific items the NRC will verify that the licensee has performed adequate root cause and extent of condition evaluations related to the failures. In addition, the NRC will verify that adequate corrective actions were identified associated with the licensees root and contributing causes and extent of condition evaluations and that implementation of these corrective actions are either implemented or appropriately scheduled for implementation.

Item Description Status NCV 2010003-02 Failure to conduct an adequate audit of Closed emergency preparedness interfaces with offsite IR 2013-002 authorities ML13092A286 NCV 2010003-03 Failure to Conduct Drills to Maintain Closed Environmental Monitoring Skills IR 2013-002 ML13092A286 NCV 2010003-04 Protective Action Recommendation processes Closed allow for the unnecessary evacuation of the IR 2013-002 public ML13092A286 Item 5.g Occupational Radiation Safety The goal for the Occupational Radiation Safety cornerstone is to ensure adequate protection of worker health and safety from exposure to radiation or radioactive material during routine civilian nuclear reactor operations. The facility is required to maintain fixed and portable radiation survey equipment (for airborne and external hazards), respiratory protection, communication equipment, temporary ventilation and shielding, and anti-contamination clothing to protect workers. This equipment is also needed to conduct adequate radiation monitoring and surveillance activities. Routine calibration and maintenance of this equipment ensures its continued operability. The NRC will inspect and assess the plant facilities, equipment, and instrumentation for occupational radiation safety.

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

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

The following NRC Inspection Procedures will be implemented:

Item Description Status 5.g.1 IP 71124.01, Radiological Hazard Assessment and Closed Exposure Controls IR 2012-011 ML12366A158 5.g.2 IP 71124.02, Occupational ALARA Planning and Closed Controls IR 2012-011 ML12366A158 Item 5.h Public Radiation Safety To prevent the inadvertent release of licensed radioactive material from the licensees control requires the use of sensitive radiation survey equipment that is properly setup and calibrated.

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

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

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

The following NRC Inspection Procedures will be implemented:

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

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

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

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

The security-related issues were closed in two Inspection Report Nos. 05000285/2013-405 (ML13115A095) and 05000285/2013-407 (ML13213A497).

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

Item 6.a Review of Necessary Licensing Amendments or Actions If licensing actions are identified they will be added to this item in the Restart Checklist.

Item Description Status 6.a.1 Revise Current Licensing Basis For Addressing Design- Closed Basis Tornado/Tornado Missile Impact ML13203A070 6.a.2 Revise Current Licensing Basis For Addressing High Closed Energy Line Breaks ML13296A584 Item 6.b Review of Licensing Commitments Necessary for Restart The NRC will conduct a commitment management audit, focusing on the implementation of regulatory commitments.

Item Description Status 6.b.1 Perform commitment management audit Closed IR 2013-008 ML13197A261 Section 7: Readiness for Restart Fort Calhoun Station has been shut down for a prolonged period of time (since April 2011). This section is provided to ensure final restart items are appropriately addressed to allow for power operation to recommence.

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

Item Description Status 7.a.1 Perform Operational Readiness Assessment Team Closed inspection Inspections completed Future report The site performed an integrated assessment and identified 15 Fundamental Performance Deficiencies that resulted in the overall performance decline at the station. Site Operational Focus was identified as one of these areas for improvement. Examples identified by the licensee included decisions do not demonstrate the use of a systematic process; station personnel lack understanding of the design and licensing basis of the plant in a manner that drives conservative, operational decision making; inconsistent recognition and evaluation of risk-significant conditions; and excessive backlogs in preventative maintenance, surveillances, procedure revisions, drawing changes, corrective maintenance, and low margin issues.

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

Item Description Status 7.a.2 Licensee Assessment of the Fundamental Closed Performance Deficiency associated with Site Inspections completed Operational Focus Future report 7.a.3 Adequacy of extent of condition and extent of causes Closed Inspections completed Future report 7.a.4 Adequacy of corrective actions Closed Inspections completed Future report Item 7.b Systems Ready for Restart and Mode Restraints Properly Addressed This item is a final review by the NRC of system lineups and preparations for restart. This will also include a specific review of how Fort Calhoun Station addressed, reviewed, and closed particular mode restraints.

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

Item Description Status 7.c.1 Final corrective action program review for restart Reviews in progress items prior to restart Section 8: Confirmatory Action Letter Resolution Item 8.a Verification that all Restart-Related Confirmatory Action Letter Items are Appropriately Resolved The NRC will inspect and independently verify that the required actions in the Confirmatory Action Letter are completed prior to restart.

Item Description Status 8.a.1 All Confirmatory Action Letter items addressed Reviews in progress Item 8.b Conduct Public Meeting Regarding Plant Readiness for Restart Item Description Status 8.b.1 Conduct public meeting to discuss plant readiness for November 21, 2013 restart Section 9: Final Recommendation for Restart Item 9.a Final Recommendation for Restart If warranted, the Inspection Manual Chapter 0350 Panel recommends restart to the Region IV Administrator. The Region IV Administrator obtains concurrence for restart from the Deputy Executive Director for Reactor and Preparedness Programs and the Director of the Office of Nuclear Reactor Regulation. Plant restart will be recommended when the NRC has determined that Fort Calhoun Station can operate safely and has completed the required sections of the Confirmatory Action Letter and Restart Checklist.

LIST OF ACRONYMS USED ACS Auxiliary Cooling System ADAMS Agencywide Documents Access and Management System AFW Auxiliary Feedwater System AIS Auxiliary Instrumentation System ALARA As Low As Reasonably Achievable AUS Auxiliary Steam System CFR Code of Federal Regulations COM Communications System CQE Critical Quality Equipment CR Condition Report CRD Control Rod Drive System CVC Chemical and Volume Control System CWS Circulating Water System DW/PW Demineralized Water/Potable Water System EC Engineering Change ECC Emergency Core Cooling System EDG Emergency Diesel Generator EDGS Emergency Diesel Generator System EDS Electrical Distribution System EEQ Equipment Environmental Qualification EP Emergency Planning EPRI Electric Power Research Institute ER Equipment Reliability ERDS Emergency Response Data System ERO Emergency Response Organization ESF Engineered Safety Features System FCS Fort Calhoun Station FEMA Federal Emergency Management Agency FHS Fuel Handling System FP Fire Protection FPD Fundamental Performance Deficiency FPS Fire Protection System GPR Ground Penetrating Radar HCV Hydraulic Control Valve HELB High Energy Line Break HES Hoisting Equipment System IAS Instrument Air System IMC Inspection Manual Chapter IP Inspection Procedure IPIP Integrated Performance Improvement Plan IR Inspection Report ISFSI Independent Spent Fuel Storage Installation LER Licensee Event Report LOOP Loss of Offsite Power MET Meteorological MFW Main Feedwater System MMS Meteorological Monitoring System NCV Noncited Violation NFPA National Fire Protection Association NOS Nuclear Oversight NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation OPPD Omaha Public Power District PA Protected Area PM Preventative Maintenance PRC Plant Review Committee RCS Reactor Coolant System RMS Radiation Monitoring System RPS Reactor Protection System SAT Satisfactory SEC Plant Security System SFP Spent Fuel Pool System SGBD Steam Generator Blowdown SGS Steam Generator System SIAS Safety Injection Actuation Signal SLS Sampling System SMART Station Modification Acceptance Review Team SSC Systems, Structures, and Components ST Surveillance Test STR Structures System T&D Transmission and Distribution TGS Turbine Generator System TPC Turbine Plant Cooling System URI Unresolved Item VAC Ventilating Air Conditioning System VDS Vents and Drains System VIO Violation WDS Waste Disposal System

ML13319B251: Difference between revisions

Latest revision as of 00:12, 6 February 2020

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Dear Mr. Cortopassi:

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ML13319B251: Difference between revisions

Latest revision as of 00:12, 6 February 2020

Text

SUBJECT:

Dear Mr. Cortopassi:

Enclosures:

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