Text

IR 05000285-13-013 and Notice of Violation, July 8, 2013 Through February 18, 2014, Fort Calhoun Station
	ML14094A052
Person / Time
Site:	Fort Calhoun
Issue date:	04/03/2014
From:	Hay M; NRC/RGN-IV/DRP
To:	Cortopassi L; Omaha Public Power District
References
	EA-13-201 IR-13-013
	Download: ML14094A052 (122)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E LAMAR BLVD

ARLINGTON, TX 76011-4511

April 3, 2014

EA-13-201

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: FORT CALHOUN - MANUAL CHAPTER 0350 TEAM INSPECTION REPORT

NO. 05000285/2013013 AND NOTICE OF VIOLATION

Dear Mr. Cortopassi:

On February 18, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a team

inspection at the Fort Calhoun Station (FCS). The purpose of this inspection was to evaluate

the readiness of plant hardware, plant staff, plant processes, and management programs that

supported safe restart and continued operation of the FCS. The team focused on those issues

described in the Restart Checklist, enclosed in the Confirmatory Action Letter issued to the FCS

on June 11, 2012 (ML12163A287), and updated on February 26, 2013 (ML13057A287), which

were ready for NRC inspection. The enclosed report documents the inspection results which

were discussed on February 18, 2014, with you and other members of your staff.

During this inspection, the NRC staff examined activities conducted under your license as they

relate to safety and compliance with the Commissions rules and regulations and with the

conditions of your license. The team reviewed selected procedures and records, observed

activities, and interviewed personnel.

Twenty one findings of very low safety significance (Green) are documented in this report. All of

these findings involved violations of NRC requirements. Three of these violations were

determined to be Severity Level IV under the traditional enforcement process. One of the SLIV

violations is being cited in the enclosed Notice of Violation (Notice) as discussed below.

The NRC determined that a Severity Level IV violation of NRC requirements occurred. The

circumstances of the violation involved incomplete and inaccurate information submitted by FCS

in a response to a Request for Additional Information (RAI) concerning the exemption request

from the requirements of 10 CFR Part 50, Appendix R, Section III.G.1.b for Fire Area 31 at the

Fort Calhoun Station. The details of the violation are described in the enclosed report. The

violation was evaluated in accordance with the NRC Enforcement Policy. The current

Enforcement Policy is included on the NRC's web site at

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. In accordance with

Section 6.9.c.1 of the Enforcement Policy, this violation would normally be assessed as Severity

L. Cortopassi -2-

Level III. However, in accordance with the Enforcement Policy, and considering the very low

safety significance (Green) of the associated finding, the NRC concluded this violation is more

appropriately assessed as Severity Level IV with a response required.

You are required to respond to this letter and should follow the instructions specified in the

enclosed notice when preparing your response. If you have additional information that you

believe the NRC should consider, you may provide it in your response to the notice. The NRCs

review of your response to the notice will also determine whether further enforcement action is

necessary to ensure your compliance with regulatory requirements.

If you contest these violations or significance of these NCVs, you should provide a response

within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United

States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident

Inspector at the Fort Calhoun Station.

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

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

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

FCS.

In accordance with 10 CFR 2.390 of the NRC's Rules of Practice and Procedure, a copy of this

letter, its enclosure, and your response (if any) will be available electronically for public

inspection in the NRC Public Document Room or from the Publicly Available Records (PARS)

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

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

Public Electronic Reading Room).

Sincerely,

/RA/

Michael Hay, Chief

Project Branch F

Division of Reactor Projects

Docket No.: 50-285

License No.: DPR-40

Enclosure:

1. Notice of Violation

2. NRC Inspection Report 05000285/2013017

w/Attachments:

Attachment 1: Supplemental Information

L. Cortopassi -3-

Electronic Distribution by RIV:

Regional Administrator (Marc.Dapas@nrc.gov)

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

MC0350 Chairman (Anton.Vegal@nrc.gov)

MC0350 Vice Chairman (Louise.Lund@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

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

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

Acting DRS Deputy Director (Geoffrey.Miller@nrc.gov)

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

Resident Inspector (Jacob.Wingebach@nrc.gov)

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

Regional State Liaison Office (William.Maier@nrc.gov)

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

RidsOeMailCenter Resource

OE, Director (Roy.Zimmerman@nrc.gov)

OE/EB, Branch Chief (Nick.Hilton@nrc.gov)

OE/CRB, Enforcement Specialist (Nicole.Coleman@nrc.gov)

OE/EGB Sr. Enforcement Specialist (John.Wray@nrc.gov)

NRR/DIRS/IPAB/IAET Allegations Specialist (Carleen.Sanders@nrc.gov)

NRREnforcement Resource

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

RIV/ETA: OEDO (Joseph.Nick@nrc.gov)

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

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

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

ROP reports

File located: R:\_REACTORS\_FCS\2014 ADAMS: ML14094A052

SUNSI Rev Yes No ADAMS Yes No Reviewer MCH

Compl. Initials

Publicly Avail Yes No Sensitive Yes No

SRI:DRP/C SRI:DRS/EB2 RI:DRS/EB2 BC:DRS/EB2 ORA/ACES

JJosey SGraves JWatkins JDixon RBrowder

/RA/ /RA/ /RA/ /RA/ /RA/

4/3/14 3/26/14 4/2/14 4/2/14 4/1/14

BC:DRP/F

MHay

4/3/14

/RA/

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

NOTICE OF VIOLATION

Omaha Public Power District (OPPD) Docket No. 50-285

Fort Calhoun Station License No. DPR-40

EA-2013-201

During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted from July 8 through

December 16, 2013, a violation of NRC requirements was identified. In accordance with the

NRC Enforcement Policy, the violation is listed below:

10 CFR 50.9(a), Completeness and Accuracy of Information, requires in part that,

information provided to the Commission by a licensee shall be complete and accurate in

all material respects.

Contrary to the above, on October 13, 2008, the licensee provided to the Commission

documentation which contained information that was not complete and accurate in all

material respects. Specifically, the licensee submitted a letter dated October 13, 2008,

which stated that the pyrocrete enclosure remained in place to protect the cables

associated with AC-10A and AC-10B from a fire in the intake structure. When in fact,

the motor lead cables associated with raw water pump AC-10A were not protected by

the pyrocrete enclosure. In a letter, dated February 6, 2009, the NRC granted an

exemption from the specific requirements of Section III.G.1.b of 10 CFR Part 50,

Appendix R, for the Fort Calhoun Station based in part, upon the NRCs review and

evaluation of information provided by the licensee in its letter dated October 13, 2008.

Therefore, this information was considered material to the NRC.

This is a Severity Level IV Violation (Section 6.9).

Pursuant to the provisions of 10 CFR 2.201, Omaha Public Power District (OPPD) is hereby

required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the

Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the Fort

Calhoun facility, within 30 days of the date of the letter transmitting this Notice of Violation

(Notice). This reply should be clearly marked as a Reply to a Notice of Violation; EA-13-201

and should include for the violation: (1) the reason for the violation, or, if contested, the basis

for disputing the violation or severity level; (2) the corrective steps that have been taken and the

results achieved; (3) the corrective steps that will be taken; and (4) the date when full

compliance will be achieved. Your response may reference or include previous docketed

correspondence, if the correspondence adequately addresses the required response. If an

adequate reply is not received within the time specified in this Notice, an Order or a Demand for

Information may be issued as to why the license should not be modified, suspended, or

revoked, or why such other action, as may be proper, should not be taken. Where good cause

is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington DC 20555-0001.

-1- Enclosure 1

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs Agencywide Documents Access and Management

System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html, to the extent possible, it should not include any personal privacy or proprietary

information so that it can be made available to the public without redaction. If personal privacy

or proprietary information is necessary to provide an acceptable response, then please provide

a bracketed copy of your response that identifies the information that should be protected and a

redacted copy of your response that deletes such information. If you request withholding of

such material, you must specifically identify the portions of your response that you seek to have

withheld and provide in detail the bases for your claim of withholding (e.g., explain why the

disclosure of information will create an unwarranted invasion of personal privacy or provide the

information required by 10 CFR 2.390(b) to support a request for withholding confidential

commercial or financial information).

Dated this 3rd day of April 2014.

-2-

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000285

License: DPR-40

Report: 05000285/2013013

Licensee: Omaha Public Power District

Facility: Fort Calhoun Station

Location: 9610 Power Lane

Blair, NE 68008

Dates: July 8, 2013 through February 18, 2014

Inspectors: H. Barrett, Senior Fire Protection Engineer, Headquarters

R. Deese, Senior Project Engineer, Region IV

G. George, Senior Reactor Inspector, Region IV

J. Hanna, Senior Reactor Analyst, Region II

R. Haskell, Reactor System Engineer, Headquarters

C. Henderson, Resident Inspector, Region IV

J. Jacobson, Senior Reactor Operations Engineer, Headquarters

J. Josey, Senior Resident Inspector, Region IV

S. Laur, Senior Reliability and Risk Analyst, Headquarters

T. Lightly, Project Engineer, Region II

D. Loveless, Senior Reactor Analyst, Region IV

S. Makor, Reactor Inspector, Region IV

J. Polickoski, Project Manager, Headquarters

F. Ramirez, Resident Inspector, Region III

J. Robles, Reactor System Engineer, Headquarters

C. Sanders, Allegations Specialist, Headquarters

A. Scarbeary, Resident Inspector, Region III

C. Smith, Project Engineer, Region IV

R. Telson, Reactor Operations Engineer, Headquarters

J. Watkins, Reactor Inspector, Region IV

J. Wingebach, Resident Inspector, Region IV

Accompanying C. Baron, Mechanical Contractor, Beckman and Associates

Personnel N. Patel, Electrical Contractor, Beckman and Associates

Approved By: Michael Hay, Chief

Project Branch F

Division of Reactor Projects

-1- Enclosure 2

SUMMARY OF FINDINGS

IR 05000285/2013013; 07/08/2013 - 2/18/2014; Fort Calhoun Station,

Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded

Cornerstones, Multiple Yellow Inputs or One Red Input.

The report covered a seven month period of inspection by an Inspection Manual Chapter 0350

inspection team. Eighteen Green non-cited violations were identified. Additionally, one cited

and two non-cited, Severity Level IV violations were identified. The significance of most findings

is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609,

Significance Determination Process. The cross-cutting aspect is determined using Inspection

Manual Chapter 0310, Components Within the Cross Cutting Areas. Findings for which the

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

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

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

Revision 4, dated December 2006.

A. NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green. The team identified a non-cited violation of 10 CFR Part 50 Appendix B,

Criterion XVI, Corrective Actions, for the licensees failure to promptly identify

and correct a condition adverse to quality. Specifically, the licensee failed to fully

implement a corrective action from a previous breaker issue, which was to

perform current injection testing for the 480 Vac 1B4A bus breakers without the

full function test kit. Testing with the full function test kit would not identify if zone

select interface jumpers were incorrectly installed. The licensee performed

current injection testing without the full functional test kit on the 480 Vac load

center main breaker 1B4A and the bus tie breaker BT-1B4A. The licensee

addressed this deficiency by performing the appropriate testing on the two

breakers. The licensee entered this deficiency into their corrective action

program for resolution as Condition Report (CR) 2013-13262.

The licensees failure to promptly identify and correct a condition adverse to

quality is a performance deficiency. This performance deficiency was more than

minor, and therefore a finding, because it was associated with the equipment

performance attribute of the Mitigating Systems Cornerstone and affected the

associated objective to ensure availability, reliability, and capability of systems

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

evaluated the finding using Inspection Manual Chapter 0609, Appendix G,

Shutdown Operations Significance Determination Process, Checklist 4, PWR

Refueling Operation: RCS level >23 or PWR Shutdown Operation with Time to

Boil > 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and Inventory in the Pressurizer, dated May 25, 2004, and

determined that the finding is of very low safety significance (Green) because the

finding did not require a quantitative risk assessment since adequate mitigating

equipment remained available. The finding has a cross-cutting aspect in the

area of human performance associated with the decision-making component

-2-

because the licensee did not ensure that the proposed action was safe in order

to proceed, rather than unsafe in order to disapprove the action

H.1(b)(Section 4OA4).

Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XVII, Quality Assurance Records, associated with the licensees

failure to furnish evidence of an activity affecting quality associated with the

480 Vac breakers. Specifically, the licensee failed to maintain design documents

that detailed the correct Digital Low Resistance Ohm (DLRO) values required for

ensuring proper connections between the Square D Masterpact NW

breaker/cradle assembly to the GE AKD-5, 480 Vac cubicle stabs. The licensee

re-generated acceptance criteria to address this issue. This issue was entered

into the licensees corrective action program as CR 2013-04032.

The licensees failure to furnish evidence that showed the required DLRO values

ensured proper connections between the Square D Masterpact NW

breaker/cradle assemble to the GE AKD-5, 480 V cubicle stabs is a performance

deficiency. The performance deficiency was determined to be more than minor,

and therefore a finding, because it affected the design control attribute of the

Mitigating Systems Cornerstone, and it directly affected the cornerstone objective

to ensure availability, reliability, and capability of systems that respond to

initiating events to prevent undesirable consequences. Using Inspection Manual

Chapter 0609, Appendix A, The Significance Determination Process (SDP) for

Findings At-Power, dated July 1, 2012, the finding was determined to have very

low safety significance (Green) because it: (1) was not a deficiency affecting the

design and qualification of a mitigating structure, system, or component, and did

not result in a loss of operability or functionality; (2) did not represent a loss of

system and/or function; (3) did not represent an actual loss of function of at least

a single train for longer than its allowed outage time or two separate safety

systems out-of-service for longer than their Technical Specification allowed

outage time; and (4) did not represent an actual loss of function of one or more

non-Technical Specification trains of equipment designated as high safety-

significance in accordance with the licensees maintenance rule program. This

finding had a cross-cutting aspect in the area of human performance, associated

with the resources component, because the licensee failed to maintain complete,

accurate, and up-to-date design documentation. Specifically, the licensee did not

maintain the engineering process for determining acceptable DLRO values

H.2(c)(Section 4OA4).

Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, for the licensees approval of Root Cause Analysis 2013-03424,

Revision 0 and Revision 1, MSPI Safety System Functional Failures Degrading

Trend, which did not assure corrective actions to prevent repetition of a

significant condition adverse to quality. The licensees addressed this issue by

revising the root cause analysis. The licensee entered this deficiency into their

corrective action program for resolution as CRs 2013-00584 and 2013-14614.

-3-

The licensees failure to establish measures to assure that the cause of the

degrading trend in MSPI safety system functional failures would be promptly

identified and action taken to preclude repetition in accordance with

10 CFR Part 50, Appendix B, Criterion XVI, was a performance deficiency. The

performance deficiency was more than minor, and therefore a finding, because

the failure to correct the cause and preclude the repetition of the cause would

have the potential to lead to a more significant safety concern. Specifically,

failure to identify the correct cause and preclude repetition could lead to a high

frequency of safety system functional failures. This finding was associated with

the mitigating systems cornerstone. Using Inspection Manual Chapter 0609,

Appendix A, The Significance Determination Process (SDP) for Findings At-

Power, dated July 1, 2012, the finding was determined to be of very low safety

significance (Green) because it: (1) was not a deficiency affecting the design

and qualification of a mitigating structure, system, or component, and did not

result in a loss of operability or functionality; (2) did not represent a loss of

system and/or function; (3) did not represent an actual loss of function of at least

a single train for longer than its allowed outage time, or two separate safety

systems out-of-service for longer than their Technical Specification allowed

outage time; and (4) did not represent an actual loss of function of one or more

non-Technical Specification trains of equipment designated as high safety-

significance in accordance with the licensees maintenance rule program. This

finding has a cross-cutting aspect in the area of in the area of problem

identification and resolution, associated with the corrective action program

component, because the licensee did not thoroughly evaluate the problem and,

consequently, the resolution did not identify the extent of cause as necessary

P.1(c)(Section 4OA4).

Green. The team identified multiple examples of a non-cited violation of

10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees

failure to control deviations from design standards. Specifically, the licensee

failed to control deviations from the design basis requirements for structural

calculations related to the reactor coolant system. The licensee took action to

perform additional analysis to confirm the operability of the affected components

and to determine the scope of the problem. The licensee entered this deficiency

into their corrective action program for resolution as CRs 2013-19878,

2013-18361, 2013-20281, and 2013-14726.

The failure to control deviations from quality standards as required by

10 CFR Part 50, Appendix B, Criterion III, was a performance deficiency. This

performance deficiency is more than minor, and therefore a finding, because it is

associated with the design control attribute of the Mitigating Systems

Cornerstone, and affected the cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A,

The Significance Determination Process (SDP) for Findings At-Power, dated

July 1, 2012, the finding was determined to have very low safety significance

(Green) because it: (1) was not a deficiency affecting the design and

-4-

qualification of a mitigating structure, system, or component, and did not result in

a loss of operability or functionality; (2) did not represent a loss of system and/or

function; (3) did not represent an actual loss of function of at least a single train

for longer than its allowed outage time, or two separate safety systems out-of-

service for longer than their Technical Specification allowed outage time; and

(4) did not represent an actual loss of function of one or more non-Technical

Specification trains of equipment designated as high safety-significance in

accordance with the licensees maintenance rule program. There was no

cross-cutting aspect assigned to this finding because this issue does not reflect

present licensee performance (Section 4OA4).

Green. The team identified multiple examples of a non-cited violation of

10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and

Drawings. Specifically, the licensees failed to follow station procedures for

corrective actions, operability evaluations, and performance of calculations for

instances where the licensees interim operability procedure was invoked for

degraded conditions associated with piping and pipe supports. As a result, non-

conservative design inputs were used without entering the non-conformances

into the corrective action process or performing procedurally required operability

evaluations. The licensees corrective action was to capture the identified

instances in the corrective action program and discontinue the use of the interim

operability procedure. This issue was entered into the licensees corrective

action program as CR 2013-03598.

The failure to follow the interim operability procedure was a performance

deficiency. This performance deficiency is more than minor, and therefore a

finding, because it is associated with the human performance attribute of the

Mitigating Systems Cornerstone, and affected the cornerstone objective to

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

initiating events to prevent undesirable consequences. Using Inspection Manual

Chapter 0609, Appendix A, The Significance Determination Process (SDP) for

Findings At-Power, dated July 1, 2012, and guidance from the Office of Nuclear

Reactor Regulation, Division of Engineering technical staff for issues where the

inputs to calculations deviated from approved standards, the finding was

determined to have very low safety significance (Green) because: (1) the Office

of Nuclear Reactor Regulation technical staff determined the non-conformances

would not render the evaluated component as inoperable or unable to perform its

safety function; (2) it was not a deficiency affecting the design and qualification

of a mitigating structure, system, or component; and (3) it did not represent an

actual loss of function of one or more non-Technical Specification trains of

equipment designated as high safety-significance in accordance with the

licensees maintenance rule program. This finding has a cross-cutting aspect in

the area of human performance associated with work practices component

because the licensee failed to define and effectively communicate expectations

regarding compliance with station procedures H.4(b)(Section 4OA4).

-5-

Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, for the licensees failure to correct conditions

adverse to quality in safety-related equipment. The team identified multiple

examples where an interim operability criteria procedure was applied instead of

correcting the conditions adverse to quality in a timely manner. The licensees

corrective actions included performing an extent of condition review to identify

similar issues and ensure they are entered into the corrective action program for

appropriate resolution. This issue was entered into the licensees corrective

action program as CR 2013-22426.

The failure to correct conditions adverse to quality is a performance deficiency.

This performance deficiency was more than minor, and therefore a finding,

because it was associated with the equipment performance attribute of the