IR 05000285/2013016

IR 05000285-13-016; 10/01/2013 - 11/15/2013; Fort Calhoun Station; Integrated Resident and Regional Report

ML13345B304
Person / Time
Site:	Fort Calhoun
Issue date:	12/11/2013
From:	Hay M NRC/RGN-IV/DRP
To:	Cortopassi L Omaha Public Power District
References
IR-13-016
Download: ML13345B304 (27)

Text

December 11, 2013

Louis P. Cortopassi, Site Vice President Omaha Public Power District

Fort Calhoun Station FC-2-4 P.O. Box 550

Fort Calhoun, NE 68023-0550

Subject: FORT CALHOUN - NRC INTEGRATED INSPECTION REPORT NUMBER 05000285/2013016

Dear Mr. Cortopassi:

On November 15, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fort Calhoun Station. On December 4, 2013, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report. The NRC inspectors did not identify any findings or violations of more than minor significance.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronicall y for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Michael Hay, Chief

Project Branch F Division of Reactor Projects

Docket: 50-285 License: DPR-40

Enclosure:

NRC Inspection Report 05000285/2013016 w/Attachment: Supplemental Information

REGION IV1600 EAST LAMAR BLVDARLINGTON, TEXAS 76011-4511

ML13345B304 SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials MCH Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials MCH SRI:DRP/F RI:DRP/F BC:DRP/F JKirkland JWingebach MHay /RA/ E /RA/ E /RA/ 12/9/13 12/9/13 12/11/13

- 1 - Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000285 License: DPR-40

Report: 05000285/2013016 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, NE 68008 Dates: October 1 through November 15, 2013 Inspectors: J. Kirkland, Senior Resident Inspector J. Wingebach, Resident Inspector R. Smith, Senior Resident Inspector, Grand Gulf Station A. Sanchez, Senior Resident Inspector, South Texas Project R. Baldwin, Senior Operations Engineer, Region II Approved By: Michael Hay, Chief, Project Branch F Division of Reactor Projects

- 2 -

SUMMARY

IR 05000285/2013016; 10/01/2013 - 11/15/2013; Fort Calhoun Station; Integrated Resident and

Regional Report

The inspection activities described in this report were performed between October 1, 2013, and November 15, 2013, by the resident inspectors at Fort Calhoun Station and three inspectors from the NRC's Region IV Office and other NRC offices. No findings were identified.

PLANT STATUS

The station began the inspection period in mode 5 with all fuel in the reactor vessel. On October 31, 2013, the plant entered mode 3 to perform plant testing at hot conditions. On November 5 the plant exited mode 3 and remained in mode 5 for the remainder of the inspection period.

REPORT DETAILS

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensee's corrective action program and periodically attended the licensee's condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensee's problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

.1 (Closed) Licensee Event Report 05000285/2012-009-00

Inoperable Equipment Due to Lack of Environmental Qualifications "During the review of the current analysis of record for Main Steam Line Break (MSLB)inside containment, no analysis or evaluation could be found to address why the original Electrical Environmental Qualification (EEQ) evaluation of peak MSLB conditions remain valid. The current analysis of record establishes that containment temperatures remain above the Loss of Coolant Accident (LOCA) peak temperature for substantially longer (220 seconds versus 60 seconds), but at a lower temperature (347.9 degrees Fahrenheit vs. 401 degrees Fahrenheit). The longer dwell times could result in a more adverse impact on environmentally qualified equipment.

"A cause analysis is being processed and the results will be reported in a supplement to this

LER." "Fort Calhoun Station will perform thermal lag analyses for the Electrical Equipment Qualification Program equipment located within containment prior to plant startup. The LER will be supplemented with the information from the EEQ and cause analysis."

The licensee event report is closed. Revision 1 of this licensee event report was submitted on October 31, 2013.

.2 (Opened) Licensee Event Report 05000285/2012-009-01

Inoperable Equipment due to Lack of Environmental Qualifications

"On December 13, 2011, it was identified that the current analysis of record for the Main Steam Line Break (MSLB) inside containment identified a peak temperature of 358.6 degrees Fahrenheit (F) and the Electrical Environmental Equipment Qualification (EEQ) evaluation assumed a maximum temperature of 401 degrees F. It was also identified that the MSLB temperature has a longer exposure time than the EEQ temperature of approximately 160 seconds. However, no evaluation or analysis could be found to address why the original EEQ assumptions remained valid as the longer exposure time of the MSLB analysis could result in an adverse impact on environmentally qualified equipment. This condition was identified when Fort Calhoun Station was shut down and defueled."

"FCS performed a thermal lag analysis to determine the impact of the longer exposure time. The results show that the additional exposure time of the lower MSLB temperature did not adversely affect the EEQ analysis as origi nally assumed in Event Notification No. 47900 ( 10 CFR 50.72(b)(3)(ii)(B)). The results of the thermal lag analysis are being documented in the updated program basis documentation. The EEQ Harsh Files for the affected

equipment have been revised."

"The original condition no longer represents a safety system functional failure and this condition is being submitted as a voluntary report."

.3 (Closed) Licensee Event Report 05000285/2013-004-00:

Electrical Equipment Impacted by High Energy Line Break Outside of Containment "On February 22, 2013, while performing testing of the diesel generators in accordance with

OP-STESF-0002, the Ametek inverters "A" and "C," instrument bus "A" and "C" Low Voltage/Ground alarms came in and cleared repeatedly. A slight smell of smoke was detected by several personnel in the Control Room in the vicinity of Al-40A. The following equipment had failed and/or was damaged: LIC-2802, PIC-2802, A/PIA-102X, C-VOPT, and possibly one or more of the CCW HX/RW temperature meters."

"Fort Calhoun had replaced the original Elgar inverters with new Ametek SCI inverters during the 2008 refueling outage. After installation, continuing intermittent inverter trouble alarms and instrument bus low voltage/ground alarms occurred when loads are placed on or removed from various a-c buses. A design change completed in April of 2011 removed a ground connection between two capacitors in the inverters. However, testing of the modification was not completed before the 2011 flood and the station did not operate with the modification installed. A causal analysis is in progress and the results of the analysis will be published in a supplement to this LER."

Based on the final causal analysis, the voltage swings experienced during the event were caused by the removal of a ground wire internal to the (Ametek) vital instrument bus inverters during the 2011 refueling outage. This ground has been replaced and the inverters were tested satisfactorily. The station vital instrument bus inverters are not required below temperatures of 300 degrees Fahrenheit. The grounds were removed while the plant was not in a condition requiring the inverters to be operable, and the condition was identified and corrected prior to restoring the inverters to an operable status.

The licensee withdrew this licensee event report based on the results of the final causal analysis (ML13280A295). The inspectors reviewed the causal analysis and concluded that the withdrawal of the licensee event report was appropriate.

This licensee event report is included in Section 3.b of the restart checklist basis document. This licensee event report and the corresponding line item in the restart checklist basis document are closed.

.4 (Closed) Licensee Event Report 05000285/2013-010-00: HPSI Pump Flow Imbalance

"On May 03, 2013, at approximately 1759 CST, it was identified that the high pressure injection pump injection flows to the reactor coolant system are not balanced in accordance with the Fort Calhoun Station (FCS) Updated Safety Analysis Report Section 14.15.5.2.

FCS is currently shutdown with fuel removed from the vessel."

"A causal analysis is in progress. The results of the analysis will be published in a supplement to this LER."

The licensee event report is closed. Revision 1 of this licensee event report was submitted on October 23, 2013.

.5 (Opened) Licensee Event Report 05000285/2013-010-01:

HPSI Pump Flow Imbalance "On May 03, 2013, at approximately 1759 CST, station personnel identified that the high pressure safety injection (HPSI) pump injection flows to the reactor coolant system were not balanced in accordance with the Fort Calhoun Station (FCS) Updated Safety Analysis Report. When discovered, FCS was shutdown with fuel removed from the vessel."

"The cause of the event was determined to be the emergency core cooling system pre-operational testing (1972) to balance HPSI system flow and record loop injection valve positions was not adequately translated into design documents. This resulted in the periodic flow balance requirements not being sustained. It was also identified that engineers had limited understanding of HPSI system flow balance design and unclear or incomplete HPSI design basis documents inhibited understanding of the reason for HPSI flow balance."

"HPSI flow to the reactor coolant loops has been balanced and a testing procedure will be developed to periodically verify that HPSI injection flow into the four reactor coolant loops remains balanced."

.6 (Opened) Licensee Event Report 05000285/2013-015-00:

Unqualified Coating used as a Water Tight Barrier in Rooms 81 and 82 "On September 13, 2013, it was identified that the floor coatings in Rooms 81 and 82 may not maintain its integrity during a high energy line break environment allowing water to migrate into the rooms below which contain the diesel generators and safety-related switchgear. This was reported on September 23, 2013, under 10 CFR 50.72(b)(3)(ii)(8),

Unanalyzed Condition (Event Notification 49378). Fort Calhoun Station was shutdown in MODE 5 when the condition was identified and entered into the station's corrective action

program as Condition Report 2013-17605."

"Engineering is reviewing this condition and the evaluation performed in 2009 for a previous condition. The completed results of this review will be used to update this report."

These activities constitute completion of one event follow-up sample, as defined in Inspection Procedure 71153.

4OA4 IMC 0350 Inspection Activities

Inspectors continued implementing IMC 0350 inspection activities, which include follow-up on the restart checklist items contained in the Confirmatory Action Letter (CAL) issued February 26, 2013 (EA-13-020, ML13057A287). The purpose of these inspection activities is to assess the licensee's performance and progress in addressing its implementation and effectiveness of FCS's Integrated Performance Improvement Plan (IPIP), significant performance issues, weaknesses in programs and processes, and flood restoration activities.

Inspectors used the criteria described in baseline and supplemental inspection procedures, various programmatic NRC inspection procedures, and IMC 0350 to assess the licensee's performance and progress in implementing its performance improvement initiatives. Inspectors performed on-site and in-office activities, which are described in more detail in the following sections of this report. This report covers inspection activities from October 1 through November 15, 2013. Specific documents reviewed during this inspection are listed in the

attachment.

The following inspection scope, assessments, observations, and findings are documented by CAL restart checklist item number.

.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 FCS are in appropriate condition to support safe restart and continued safe plant operation. Section 2 reviews will also include an assessment of how the licensee appropriately addressed the NRC Inspection Procedure 95003 key attributes as described in Section 6.

.a Flood Recovery Plan Actions Associated With Facility and System Restoration

Item 2.a is the NRC's independent evaluation of FCS's 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 areas to be inspected are identified in the CAL. Inspection items are considered complete when the licensee has submitted a closure package that has been

satisfactorily reviewed by the inspectors.

(1) CAL Action Item 2.2.1.22

i. Inspection Scope

The purpose of Action Item 2.2.1.22 was to assess the effects of the flood on the Structures System and identify actions to restore the system. This item was required to be completed prior to exceeding 210°F in the reactor coolant system.

The inspectors independently reviewed the system to identify if there were any temporary modifications in place as a result of the flood, if there were any outstanding preventive maintenance activities that had been deferred due to the flood, and reviewed condition reports to determine if there were any deficiencies noted due to the flood. The inspectors queued condition reports that were related to flooding, written between April 1, 2011, and December 31, 2011. The inspectors also conducted a complete system walkdown to identify any adverse conditions related to flooding. The inspectors compared the results of their independent assessment to those contained in the licensee's Flooding Recovery Startup System Health Assessment report.

The inspectors identified no temporary modifications and no preventive or corrective maintenance activities which were deferred because of the flooding.

The inspectors reviewed all condition reports affecting the Structures System written related to the flood. The majority of these involved leaks identified during the flood. The inspectors reviewed the corrective actions associated with these condition reports and determined that there were no outstanding issues associated with the electrical distribution system.

The independent walkdown performed by the inspectors identified no current adverse conditions to the electrical distribution system and its individual components as a result of the flood.

In addition, this report documents closure of the impact of sub-surface water on soils and structures; Section 2.b below. This section included the impact on structures below grade.

This activity constitutes completion of Action Item 2.2.1.22 as described in CAL EA-13-020.

ii. Findings No findings were identified.

(2) CAL Action Items 4.2.2.7 and 4.3.2.1

i. Inspection Scope

The purpose of Action Items 4.2.2.7 and 4.3.2.1 were to remove all flood mitigation devices which have been determined to not be permanent fixtures, and to complete all ECs/restoration required for plant start-up. These items were required to be completed prior to the reactor achieving criticality.

These items are duplicated in the review the inspectors completed for CAL Action Item 4.3.1.4, which is documented in Inspection Report 05000285/2012002, ML13045B055. Action Item 4.3.1.4 was to remove non-permanent configuration changes, which include all flood mitigation devices and restoration.

Due to the duplication of these action items, this constitutes completion of Action Items 4.2.2.7 and 4.3.2.1 as described in CAL EA-13-020.

ii. Findings No findings were identified.

.b System Readiness for Restart Following Extended Plant 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 ensure that the structures, systems, and components are ready for plant restart and they conform to the appropriate licensing and

design basis requirements.

i. System Health Reviews The purpose of this item is to validate structures, systems, and components conform to the licensing and design basis. The NRC will evaluate 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.).

(1) Inspection Scope

The inspectors assessed the startup readiness of the below listed systems.

These assessments consisted of reviews of open work orders, condition reports, temporary modifications and operator challenges, and a review of the maintenance rule status of those components scoped in the maintenance rule. The review of open work orders and condition reports did not include those items that were related to equipment service life (ESL), which is being evaluated in Section 3.d.2 of the Restart Checklist Basis Document. The inspectors also conducted system walkdowns using the guidance contained in Inspection

Procedure 71111.04, Equipment Alignment.

2.b.1.1 Auxiliary Cooling System 2.b.1.2 Auxiliary Feedwater System 2.b.1.3 Spent Fuel Pool System 2.b.1.4 Sampling System 2.b.1.5 Chemical and Volume Control System 2.b.1.6 Emergency Core Cooling System 2.b.1.7 Hoisting Equipment System 2.b.1.8 Waste Disposal System 2.b.1.9 Control Rod Drive System 2.b.1.10 Reactor Coolant System 2.b.1.11 Demineralized and Potable Water Systems 2.b.1.12 Circulating Water System 2.b.1.13 Emergency Diesel Generator 2.b.1.14 Ventilation, Heating and Air Conditioning System 2.b.1.15 Main Feedwater System 2.b.1.16 Structures 2.b.1.17 Steam Generator System 2.b.1.18 Steam Generator Blowdown Turbine Plant Cooling 2.b.1.19 Instrument Air System 2.b.1.20 Turbine Generator and Support Systems 2.b.1.21 Auxiliary Instrumentation System 2.b.1.22 Electrical Distribution System 2.b.1.23 Engineered Safeguards System 2.b.1.24 Radiation Monitoring System 2.b.1.25 Fuel Handling System 2.b.1.26 Reactor Protective System 2.b.1.27 Fire Protection System The inspectors reviewed all open work orders that require completion prior to reactor startup. The inspectors verified that the open work orders are scheduled to be complete and are included on the outage schedule. The inspectors will continue to track these work orders to completion.

The inspectors performed a review of all open condition reports for the Reactor Coolant System. The inspectors verified that work orders have been prepared for the open condition reports, and that the work is scheduled prior to restart.

For the system walkdowns, the inspectors reviewed plant procedures, including abnormal and emergency, drawings, USAR and vendor manuals to determine the correct lineup and visually inspected the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. The system walkdowns occurred both during hot and cold plant conditions.

The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensee's corrective actions. The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

The inspectors reviewed one Tier 4 operator challenge involving sporadic alarms on Reactor Coolant Pump RC-3D seal leakage, and concluded that the operator challenge did not require resolution prior to start-up. The inspectors have concluded that the abov e listed systems are ready for plant startup pending resolution of the equipment service life issues, completion of those open work orders required prior to restart, and successful resolution of those condition reports required prior to restart. The inspectors also concluded that the licensee has an adequate method of ensuring that work orders and condition reports required for plant restart are adequately identified and tracked. The inspectors will have one final opportunity to ensure that all open items are completed, and that is Section 7.b of the Restart Checklist, "Final system readiness and mode restraint review." This activity constitutes completion of Action Items 2.b.1.1 through 2.b.1.27 as described in restart checklist basis document.

(2) Findings No findings were identified.

ii. Impact of Sub-Surface Water on Soils and Structures Fort Calhoun Station was subjected to flood waters for several months. The licensee will perform an assessment to evaluate:

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

• condition of subsurface soil

• floodwater impacts on subsurface SSCs.

The NRC will review, monitor, and inspect activities associated with the geo-technical surveys and assessments, and ensure proper actions were taken for the associated corrective actions and any identified safety concerns in this area.

(1) CAL Action Item 3.3.1.3

a) Inspection Scope The purpose of Action Item 3.3.1.3 was to resolve any deficiencies affecting operability or functionality (if needed). This item was required to be completed prior to RCS temperature >210°F. This action item was in place to correct any deficiencies identified during the licensee's investigation of the impact of sub-surface water on soils and structures. This inspection report, specifically items

(2) through

(6) below, completes the NRC's review of this section of the restart checklist basis document, and no outstanding deficiencies remain. Therefore, this item will be closed. This activity constitutes completion of Action Item 3.3.1.3 as described in Confirmatory Action Letter EA-13-020.

b) Findings No findings were identified.

(2) CAL Action Item 4.1.1.25 c) Inspection Scope The purpose of Action Item 4.1.1.25 was to complete a post-flood river channel evaluation. This item was required to be completed prior to RCS temperature >210°F. The licensee completed a technical memorandum on April 19, 2012, for the Missouri River Gage Analysis, followed by an internal assessment of the impacts to plant procedures and operations for accessing the Missouri River water through the intake structure for one-through cooling during low river flows. The inspectors reviewed the technical memorandum and the licensee's assessment of any possible impacts to the plant. This activity constitutes completion of Action Item 4.1.1.25 as described in Confirmatory Action Letter EA-13-020.

d) Findings No findings were identified.

(3) CAL Action Item 4.1.1.30

a) Inspection Scope The purpose of Action Item 4.1.1.30 was to verify no structural or geotechnical impact to Turbine Building and Auxiliary Building/Containment as a result of the 2011 flood (HDR Rev 1)

This item was required to be completed prior to Reactor Coolant System

temperature >210°F. The licensee performed visual inspection of the facilities as well as periodic building elevation surveys to verify no settlement of the structures. Soil boring testing, and static and dynamic cone penetration testing was completed to locate and characterize the extent of loose soils. Remediation efforts under the Turbine Building included relining of the broken sump lines.

A summary of these inspection efforts, testing, and remediation descriptions are documented in the Fort Calhoun Station Flood Recovery Action Plan 4.1 Plant and Facility Geotechnical and Structural Assessment, Revision 2, report completed by HDR and dated May 4, 2012.

There are no indications of negatively affected soils beneath the Auxiliary Building or Containment. Cone penetration testing of the space between these structures and the Turbine Building indicated the more densely compacted foundation beneath the Class 1 structures is intact and in accordance with original construction design records. Additionally, the licensee constructed a structural analysis to show that even under a severe, postulated scenario where subgrade soils were impacted, the building continues to respond in accordance with original design basis. This analysis was included in Stevenson & Associates Report 12Q4067-C-002, Revision 3, dated September 25, 2013.

The inspectors reviewed the referenced reports as well as observed activities associated with the soil penetration testing, and reviewed documents associated with the new turbine building sump line repairs. There are no indications that the buildings have been negatively impacted by the flood of 2011.

This constitutes completion of Action Item 4.1.1.30 as described in Confirmatory Action Letter EA-13-020.

b) Findings No findings were identified.

(4) CAL Action Item 4.1.1.32

a) Inspection Scope The purpose of Action Item 4.1.1.32 was remediation of the Turbine Building and Class 1 structure voids. This item was required to be completed prior to Reactor Coolant System temperature >210°F.

Remediation efforts under the Turbine Building included relining of the broken sump lines, followed by performing video of the new lines to ensure successful installation. The inspectors reviewed work orders documenting the repairs, the video recordings, and visually inspected the new catch basins in May 2013. This activity constitutes completion of Action Item 4.1.1.32 as described in Confirmatory Action Letter EA-13-020.

b) Findings No findings were identified.

(5) CAL Action Item 4.1.2.2

i. Inspection Scope

The following action item is related to the impacts of flooding to verify that no geotechnical or structural impact to site structures occurred.

This item was required to be completed prior to reactor being critical.

The licensee performed visual inspection of the facilities as well as periodic building elevation surveys to verify no settlement of the structures. Soil boring testing and static and dynamic cone penetration testing were completed to locate and characterize the extent of loose soils. These inspections were documented in field reports and included in the Fort Calhoun Station Flood Recovery Action Plan 4.1 Plant and Facility Geotechnical and Structural Assessment, Revision 2, report completed by HDR and dated May 4, 2012. Final penetration testing in small annulus space between the Turbine Building and the Auxiliary Building indicates that the loose soils do not extend beyond the Turbine Building footprint into the more densely compacted, vibroflotated foundation of the Class 1 structures (Auxiliary Building and Containment). In lieu of core drilling the auxiliary building floor slab, a nuclear qualified consultant constructed an analysis to show even with a loss of some foundation soil, the seismic response of the Class 1 structures remains within the design basis criteria. To date, there are outstanding review comments by the NRC senior geotechnical engineer regarding this analysis that still need to be addressed.

The inspectors conducted visual walkdowns of the facility in September 2011 and again in May 2013. The field notes were reviewed, as well as comparison to prior plant records completed for the structures monitoring program. The inspectors verified that there are no indications of structural damage in site structure, however, the licensee's geotechnical and structural assessment reports contain open-ended statements requiring resolution of the turbine building sump piping and structural analysis beneath the Class I structures before closure.

This activity constitutes completion of Action Item 4.1.2.2 as described in Confirmatory Action Letter EA-13-020.

Findings No findings were identified.

(6) CAL Action Items 4.1.3.10

a) Inspection Scope The purpose of Action Item 4.1.3.10 was remediation of the loose soils area under the Turbine Building and Class 1 structures if required. This was a long-term action item.

The licensee completed relining of the subgrade pipes in the basement of the Turbine Building. Successful completion of this activity was verified by the licensee performing video of the pipes.

The inspectors observed the documents associated with the relining of the sump piping, as well as the isolation testing results the licensee conducted to verify that only equipment discharge was being seen in the piping, and no groundwater intrusion, even during elevated river levels.

This constitutes completion of Action Item 4.1.3.10 as described in

Confirmatory Action Letter EA-13-020.

b) Findings No findings were identified.

4OA5 Operational Readiness Assessment Team Inspections

The purpose of this inspection was to complete the evaluations asscociated with the Fort Calhoun Station plant operations staff readiness for restart. In April and May of 2013 the NRC performed a team inspection that eval uated the adequacy of operations procedures, self assessment program, Techncial Specification appraisal process, qualifications of key managers and operators, and training. Additiona lly, that inspection reviewed the licensee's evaluations and actions taken to address a licensee identified Fundamental Performance Deficiency associated with "Site Operational Focus." The results of this inspection are document in NRC Inspection Report 05000285/2 013010 dated July 11, 2013. The team concluded that there is notable improvement in that "Personnel at all levels understand and embrace the roles they play in maintaining an operationally focused team." Although procedures are in place, the majority of the changes have occurred since Exelon leadership was put into place in late 2012. It is therefore too early to tell if the changes are sustainable. Confirmatory Action Letter Items 7.a.2, 3 and 4 will be closed pending a sustainability review.

This inspection report documents the results of the second operations focused inspection that focused on operator performance during a plant heat up to normal operating temperature and pressue using reactor coolant pumps. Based on the team's review, the team did not observe any activities that would make the team question the ability of the Fort Calhoun Station Operations Staff to safely operate the plant. The NRC performance of

a. Inspection Scope

The NRC team performed an Operational Readi ness Assessment Team inspection the week of October 27, 2013. The team performed approximately 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of continuous control room observations of activities while the licensee conducted a plant heat-up to normal operational temperature and pressure evolution. This inspection reviewed for closure the following Restart Checklist items:

• Item 7.a.1 - Perform Operational Readiness Assessment Team Inspection

• Item 7.a.2 - Licensee Assessment of the Fundamental Performance Deficiency associated with Site Operational Focus

• 7.a.3 - Adequacy of extent of condition and extent of causes

• 7.a.4 - Adequacy of corrective actions The team observed the following:

• pilot operated relief valve testing,

• reactor coolant pump starts,

• securing shutdown cooling operations,

• and other heat-up activities. The team evaluated the operators' performance in the following areas:

• shift turnover,

• control room documentation and operator logs,

• clarity and formality of communications,

• interdepartmental interactions,

• procedural adequacy and implementation,

• operator professionalism,

• group dynamics,

• annunciator response,

• control board manipulations,

• plant and equipment awareness,

• control and prioritization of support activities,

• pre-job briefings,

• and managerial oversight.

b. Observations and Findings

No findings were identified.

Team Observations

• Shift turnovers were conducted professional ly, clearly conveying status changes for important plant equipment, and addressing planned/ongoing evolutions.

• Operator logs and rounds were being performed appropriately.

• Three-way communication at times was inconsistent in that there were several missed three-way communications and one instance where an operator's announcement of an alarm was not acknowledged and the operator did not ensure receipt.

• Proper interdepartmental interactions were observed and adequate support was provided to operations from maintenance, engineering, and other support groups. The team observed:

o operational and organizational response to solving issues with a pilot operated relief valve that failed open during testing, o actions to resolve issues with stuck-open relief valves for closed cooling water that provided cooling to auxiliary coolers in the containment, o and an issue with pressurization of a crosstie line between the high pressure safety injection system and the charging system.

• The team attended the pre-job brief for the troubleshooting of the pilot operated relief valve and reviewed the troubleshooting work order. The team noted that the work order lacked adequate detail or standards for actions being taken during the troubleshooting process. The licensee entered this issue into their corrective action program.

• Procedures were adequately implemented by operations personnel. However, on one occasion the team identified two operators who were not using the procedure to operate pressurizer heaters to control reactor coolant system pressure. Operators were using personal knowledge to operate the heaters during plant heatup. This was brought to the attention of the operations staff, and the procedure was obtained and used for future manipulations. The procedure was a "continuous use" procedure. The licensee entered this issue into their corrective action program.

• Operators responded to annunciators and alarms in accordance with applicable standards and procedures.

• Operators usually monitored significant plant parameters and knew the status of plant equipment. The team noticed that on the plant computer the parameter that indicated containment spray flow was oscillating from 185 gallons per minute to approximately 224 gallons per minute for one of the loops. This was brought to the attention of the operations staff and they noted that this was not correct. This is an example that the crew members were/are not being as attentive as they should have been concerning plant parameters. This was entered into the licensee's corrective actions program. This indication is important because it has to be used to determine sufficient flow to containment when spraying the containment during an accident condition.

• The team observed numerous pre-job briefings covering small and large issues. Most of the infrequently performed tests and evolution briefings conducted were done in a very professional manner. Everyone who attended was asked specifically if they had any issues and if they understood the task.

• Proper command and control by shift managem ent was observed in the control room.

• The licensee provided extra oversight for the plant heat-up activity. However, they did not establish a plan or exceptions of what specific activities to monitor during plant heatup. An example of oversight not being effective was on October 31, 2013, during the morning shift, activities in the main control room increased and the inspection team observed a decrease in rigor. The team addressed this with site management and a shift brief was performed to re-focus the team and an additional control room supervisor was brought to the control room to assist the on-shift crew.

• The team observed operators performing board actions and determined that peer checks were not consistent with industry standards, although no incorrect actions were performed. The team observed operators performing actions such as removing shutdown cooling from service, adjusting water level in the steam generators with auxiliary feedwater, and no peer checks were used during these evolutions.

• The team reviewed the licensee's "Manager Shift Operations Communications" book. This book appeared to be operation's management expectations or directions to the shift managers. The team noted that the collection of documents were required to be reviewed by shift managers and then signed off as being reviewed. Some documents were not signed by all shift managers.

In addition to control room observations, prior to the heat-up, the team reviewed the readiness of the site for changing operation mode to hot shutdown. The team performed a complete review of the site's custom technical specifications to ensure required surveillances were completed and up-to-date for this mode change. The team also reviewed various completed surveillances as inspection items to ensure there were no issues. The team determined through their reviews that the licensee was ready for mode change to hot shutdown. The team observed that the site's custom technical specifications are complicated, cumbersome, and not easy to use. It was a difficult and somewhat frustrating exercise in determining that technical specifications were met in order to change modes. The site is potentially vulnerable to not identifying inoperability of a system due to not having met all surveillance requirements. The team reviewed just-in-time training material that the licensee used to prepare their crews for the plant heat-up evolution. The team also reviewed the licensee's risk assessment for changing modes, and all outstanding issues involving safety equipment that were in a degraded non-conforming condition for acceptability for the mode change.

c. Conclusions

Based on the team's observations of control room operations, there was reasonable assurance that the operating staff could safely restart and operate the Fort Calhoun Station. Based on the results of these inspections Restart Checklist items 7.a.1, 7.a.2, 7.a.3, and 7.a.4 are closed.

4OA6 Meetings, Including Exit Exit Meeting Summary

On December 4, 2013, the inspectors presented the inspection results to Mr. L. Cortopassi, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

4OA7 Licensee-Identified Violations

None A-1 Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Bakalar, Manager, Security

J. Bousum, Manager, Emergency Planning and Administration

C. Cameron, Supervisor Regulatory Compliance

L. Cortopassi, Site Vice President

K. Ihnen, Manager, Site Nuclear Oversight

T. Leeper, Manager, Human Resource Services

T. Lindsey, Director, Training

E. Matzke, Senior Licensing Engineer, Regulatory Assurance

B. Obermeyer, Manager, Corrective Action Program

T. Orth, Director, Site Work Management

E. Plautz, Supervisor, Emergency Planning

R. Short, Assistant Director, Engineering

T. Simpkin, Manager, Site Regulatory Assurance

S. Swanson, Manager, Operations

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000285/2012-009-00 LER Inoperable Equipment Due to Lack of Environmental Qualifications (Section 4OA3.1)

05000285/2013-004-00 LER Electrical Equipment Impacted by High Energy Line Break

Outside of Containment (Section 4OA3.3)

05000285/2013-010-00 LER HPSI Pump Flow Imbalance (Section 4OA3.4)

Closed

05000285/2012-009-01 LER Inoperable Equipment Due to Lack of Environmental Qualifications (Section 4OA3.2)

05000285/2013-010-01 LER HPSI Pump Flow Imbalance (Section 4OA3.5)

05000285/2013-015-00 LER Unqualified Coating Used as a Water Tight Barrier in Rooms

and 82 (Section 4OA3.1)

Section 4OA2:

Problem Identification and Resolution (71152)