ML12132A395

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

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

See also: IR 05000285/2012002

Text

May 11, 2012 EA-2012-095

David J. Bannister, Vice President and Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station FC-2-4 P.O. Box 550 Fort Calhoun, NE 68023-0550

Subject: FORT CALHOUN - NRC INTEGRATED INSPECTION REPORT NUMBER 05000285/2012002

Dear Mr. Bannister:

On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fort Calhoun Station. The enclosed inspection report documents the inspection results which were discussed on April 11, 2012, with you and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Two NRC identified findings of very low safety significance (Green) were identified during this inspection. Both of these findings were determined to involve violations of NRC requirements. Further, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating these violations as non-cited violations consistent with Section 2.3.2 of the Enforcement Policy. Additionally, three other violations of NRC requirements were identified. These findings were determined to be violations related to a previously issued Yellow finding regarding the ability to mitigate an external flooding event (Inspection Reports 05000285/2010007 and 05000285/2010008; ML101970547 and ML102800342, respectively). The significance of these findings was bounded by the Yellow finding and therefore were not characterized by color

significance. All three of these findings were determined to involve violations of NRC requirements. Separate citiations will not be issued as these items associated with flood mitigation are being evaluated by the NRC under the Manual Chapter 0350, "Oversight of Reactor Facilities in a Shutdown Condition Due to Significant Performance and/or Operational Concerns," process (EA-2012-095). If you contest these violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV1600 EAST LAMAR BLVDARLINGTON, TEXAS 76011-4511

D. Bannister - 2 - Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Fort Calhoun Station. If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC Resident Inspector at Fort Calhoun Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /RA/ Jeffrey A. Clark, P.E. Chief, Project Branch F Division of Reactor Projects Docket: 50-285 License: DPR-40 Enclosure: NRC Inspection Report 05000285/2012002 w/Attachment: Supplemental Information cc w/encl: Electronic Distribution

D. Bannister - 3 - DISTRIBUTION: Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) Deputy Regional Administrator (Art.Howell@nrc.gov) DRP Director (Kriss.Kennedy@nrc.gov) DRP Deputy Director (Troy.Pruett@nrc.gov) Acting DRS Director (Tom.Blount@nrc.gov) Acting DRS Deputy Director (Patrick.Louden@nrc.gov) Senior Resident Inspector (John.Kirkland@nrc.gov) Resident Inspector (Jacob.Wingebach@nrc.gov) Branch Chief, DRP/F (Jeff.Clark@nrc.gov) Senior Project Engineer, DRP/F (Rick.Deese@nrc.gov) Project Engineer, DRP/F (Chris.Smith@nrc.gov) FCS Administrative Assistant (Berni.Madison@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Public Affairs Officer (Lara.Uselding@nrc.gov) Acting Branch Chief, DRS/TSB (Dale.Powers@nrc.gov) Project Manager (Lynnea.Wilkins@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov) Regional Counsel (Karla.Fuller@nrc.gov) Congressional Affairs Officer (Jenny.Weil@nrc.gov) OEMail Resource ROPreports RIV/ETA: OEDO (Michael.McCoppin@nrc.gov) DRS/TSB STA (Dale.Powers@nrc.gov) MC 0350 Panel Vice-Chairman (John.Lubinski@nrc.gov) MC 0350 Panel Member (Michael.Markley@nrc.gov) MC 0350 Panel Non-voting Member (Michael.Balazik@nrc.gov) ADAMS ACCESSION NUMBER: [Accession Number] SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials RWD Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials RWD SRI:DRP/F RI:DRP/F SPE:DRP/F C:DRS/EB1 C:DRS/EB2 C:DRS/OB JCKirkland JFWingebach RWDeese TRFarnholtz GBMiller MSHaire /RWDeese via E/ /RWDeese via E/ /RA/ /RA/ /RA/ /COsterholtz for/ 5/11/12 5/11/12 5/4/12 5/2/12 5/3/12 5/4/12 C:DRS/PSB1 C:DRS/PSB2 C:DRS/TSB C:ORA/ACES BC:DRP/F MCHay GEWerner DAPowers HGepford JAClark /RA/ /RA/ /RAlexander for/ /RA/ /RA/ 5/2/12 5/3/12 5/3/12 5/11/12 5/11/12 OFFICIAL RECORD COPY T=Telephone E=Email F=Fax

- 1 - Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000285 License: DPR-40 Report: 05000285/2012002 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, NE 68008 Dates: January 1 through March 31, 2012 Inspectors: J. Kirkland, Senior Resident Inspector J. Wingebach, Resident Inspector K. Clayton, Senior Operations Engineer R. Kopriva, Senior Reactor Inspector, B. Larson, Senior Operations Engineer G. Apger, Operations Engineer P. Elkmann, Senior Emergency Preparedness Inspector G. Guerra, CHP, Emergency Preparedness Inspector D. Strickland, Operations Engineer C. Henderson, Resident Inspector J. Laughlin, Emergency Preparedness Inspector, NSIR Approved By: Jeffrey Clark, P.E., Chief, Project Branch F Division of Reactor Projects

- 2 - Enclosure SUMMARY OF FINDINGS IR 05000285/2012002; 01/01/2012 - 03/31/2012; Fort Calhoun Station, Integrated Resident and Regional Report; Adverse Weather Protection, Emergency Plan Biennial Exercise, MC 0350 The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region-based inspectors. Two violations were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Additionally, three violations were identified, and were determined to be violations related to and bounded by a previously issued Yellow finding regarding the ability to combat an external flooding event

(Inspection Report 05000285/2010008) and therefore were not characterized by color significance. The cross-cutting aspect is determined using Inspection Manual Chapter 0310, "Components Within the Cross Cutting Areas." Findings for which the significance

determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006. A. NRC-Identified Findings and Self-Revealing Findings Cornerstone: Mitigating Systems N/A. The inspectors identified four examples of a violation of Technical Specification 5.8.1.a, "Procedures," for failure to establish and maintain procedures to mitigate an external flooding event. The procedural guidance for flooding was inadequate to mitigate the consequences of external flooding. This finding, and its corrective actions, will be managed by the Manual Chapter 0350 Oversight Panel. This finding was more than minor because it adversely impacted the procedure quality, human performance and protection against external events attributes of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of this finding is bounded by the significance of a related Yellow finding regarding the ability to mitigate an external flooding event (Inspection Report 05000285/2010008). This finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, for failure to thoroughly evaluate problems such that the resolutions address causes and extent of conditions. This also includes, for significant problems, conducting effectiveness reviews of corrective actions to ensure that the problems are resolved P.1(c). (Section 1R01) N/A. The inspectors identified a violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for failure of the licensee to classify the six intake structure exterior sluice gates and their motor operators as Safety Class III. This finding, and its corrective actions, will be managed by the Manual Chapter 0350 Oversight Panel.

- 3 - Enclosure This finding was more than minor because it adversely impacted the protection against external events attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of this finding is bounded by the significance of a related Yellow finding regarding the ability to mitigate an external flooding event (Inspection Report 05000285/2010008). This finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, for failure to thoroughly evaluate problems such that the resolutions address causes and extent of conditions. This also includes, for significant problems, conducting effectiveness reviews of corrective actions to ensure that the problems are resolved P.1(c). (Section 1R01) N/A. The inspectors identified a violation of 10 CFR 50, Appendix B, Criterion III, "Design Control," for failure to meet design basis requirements for protection of the

safety related raw water system during a design basis flood for flood levels between 1,010-1,014 feet mean sea level as identified in Updated Safety Analysis Report, Section 9.8, "Raw Water System." Specifically, the design basis states that water level inside the intake cells can be controlled during a design basis flood by positioning the exterior sluice gates to restrict the inflow into the cells. This finding, and its corrective actions, will be managed by the Manual Chapter 0350 Oversight Panel. This finding was more than minor because it adversely impacted the equipment performance and protection against external events attributes of the Mitigating

Systems Cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of this finding is bounded by the significance of a related Yellow finding regarding the ability to mitigate an external flooding event (Inspection Report 05000285/2010008). This finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, for failure to thoroughly evaluate problems such that the resolutions address causes and extent of conditions P.1(c). (Section 1R01) Cornerstone: Emergency Preparedness Green. The inspector identified a non-cited violation of 10 CFR 50.54(q)(2) for failure to follow the licensee's emergency plan. Specifically, the licensee did not follow the Radiological Emergency Response Plan, Section E, "Notification Methods and Procedures," Revision 26, which requires offsite warning sirens be activated by radio signal. The licensee did not respond to indications of siren system failure for approximately six hours and did not inform offsite authorities of the need for alternative means to notify the public for three additional hours. This failure has been entered into the licensee's corrective action system as Condition Reports 2012-

01435 and 2012-01489. This finding is more than minor because it affected the facilities and equipment

cornerstone attribute (availability of the alert and notification system) and impacted the cornerstone objective of implementing adequate measures to protect public

- 4 - Enclosure health and safety. This finding was evaluated using the Emergency Preparedness Significance Determination Process and was determined to be of very low safety significance because the planning standard function was not lost or degraded. The function was not degraded because some sirens remained functional in the 0-5 and 5-10 mile areas of the emergency planning zone, and offsite officials could have promptly recognized failed sirens. The finding had a cross-cutting aspect in the work control component of the human performance area because the communications department and control room personnel did not communicate and coordinate as necessary with offsite organizations H3.b]. (Section 1EP5) Green. The inspectors identified a non-cited violation of 10 CFR 50.54(q) for failure to follow an emergency plan requirement during a declared alert. Specifically, the licensee did not notify the states of Nebraska and Iowa of the emergency within 15

minutes of event declaration as required by Section E, paragraph 2.4, of their emergency plan. This failure has been entered into the licensee's corrective action system as Condition Report 2011-8529. This finding is more than minor because it affects safety and impacts the cornerstone attributes of emergency response organization performance and actual event response. The finding had a credible impact on the Emergency Preparedness Cornerstone objective because untimely notification to offsite authorities degrades their ability to implement adequate measures to protect the health and safety of the public. The finding is of very low safety significance because it was a problem with implementation of the site emergency plan during an event that did not affect the

ability of offsite authorities to respond to the emergency. The finding had a cross-cutting aspect in the work practices (management oversight) component of the human performance area because licensee management did not set performance expectations for event notifications and monitor performance to ensure compliance with emergency plan requirements H4.c] (Section 4OA1). B. Licensee-Identified Violations A violation of very low safety significance (Green) identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

- 5 - Enclosure REPORT DETAILS Summary of Plant Status The station remained in refueling shutdown conditons with the fuel in the reactor vessel for the entire inspection period. 1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111.01) .1 Readiness to Cope with External Flooding a. Inspection Scope The inspectors performed a walk down of flood protection barriers and equipment used

to prepare for a flooding event. The inspectors performed a review of procedures used to prepare for, and cope with, an external flooding event with emphasis on a design basis flood (1,014 feet mean sea level). During the inspection, the inspectors performed a review of the Updated Safety Analysis Report and related flood analysis documents

Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of one readiness to cope with external flooding as defined in Inspection Procedure 71111.01-04. b. Findings (1) Inadequate Procedures to Mitigate a Design Basis Flood Event Introduction. The inspectors identified four examples of a violation of Technical Specification 5.8.1.a, "Procedures," for failure to establish and maintain procedures to mitigate an external flooding event. The inspectors determined that the procedural guidance of Abnormal Operating Procedure 1, "Acts of Nature, Section - I, Flooding," and other supporting procedures, were inadequate to mitigate the consequences of external flooding. As a result, the licensee initiated an 8-hour report to the NRC Operations Center in accordance with 10 CFR 50.72(b)(3)(ii)(B), unanalyzed condition that significantly degraded plant safety, on February 10, 2012. Description. Four examples describing the inadequacies in Abnormal Operating Procedure 1 were identified by the inspectors.

- 6 - Enclosure (a) Abnormal Operating Procedure 1 failed to provide operators with sufficient information to ensure a transfer of power from offsite to an onsite emergency diesel generator prior to a loss of offsite power. The procedure directed operators to transfer one class-1E 4160 volt AC bus to emergency diesel power if river level was expected to exceed 1,006 feet mean sea level and the switchyard had not been protected. However, the procedure did not define what constituted protection of the switchyard. In addition, had the operators chosen to continue in the procedure and

not direct transfer of power to an emergency diesel, the procedure did not provide information to the operators as to when offsite power must be transferred prior to loss of the switchyard. The procedure strategy was to construct barriers to flood waters around the switchyard on an as-needed basis to maintain offsite sources available for as long as possible to conserve diesel fuel oil. The barriers, however, were not intended to protect the switchyard against a design basis flood of 1,014 feet mean sea level, thus a transfer of offsite power would need to occur at some point during procedure implementation. (b) Abnormal Operating Procedure 1 failed to identify that the class-1E powered motor operators of the six intake structure sluice gates were located at an elevation of 1,010 feet mean sea level. Since the design basis flood was to a river level of 1,014 feet mean sea level, control of the sluice gates could have been lost when river level exceeded 1,010 feet mean sea level because the electric motors could have become submerged and were not qualified to operate under water. (c) Abnormal Operating Procedure 1 did not identify that three of the six sluice gate motor operators would be de-energized when offsite power was transferred from offsite to one onsite emergency diesel generator.

Only one emergency diesel generator would have been started in an effort to maintain an adequate diesel fuel oil supply. In addition, Abnormal Operating Procedure 1 did not provide direction to the operators to ensure the one of six sluice gates selected to control intake structure cell water level would have remained energized when power was transferred to the emergency diesel generator. As part of the strategy for intake structure flood mitigation, five of the six sluice gates would have been closed and level would have been controlled by repositioning the remaining sluice gate as required. (d) Abnormal Operating Procedure 1 did not adequately ensure the fuel transfer hose to emergency diesel generator day tanks was staged prior to river level exceeding 1,004 feet mean sea level. Abnormal Operating Procedure 1, Step 1, directed implementation of Attachment D, "Flood Protective Actions." Step 2 of Attachment D only directed Emergency Planning to "review" EPIP-TSC-2 for expected flood level and did not have explicit directions to perform any actions. Step 7.9 of EPIP-TSC-2

- 7 - Enclosure directed installation or staging of plant flood barriers per procedure PE-RR-AE-1001, Flood Barrier and Sandbag Staging and Installation. Attachment 23 of PE-RR-AE-1001 was for staging the fuel transfer hose. Inspectors concluded that the implementing procedures were not adequate to ensure staging the transfer hose was performed. Analysis. The inspectors determined that failure of the licensee to establish and maintain adequate procedures to mitigate an external flooding event was a performance deficiency. This finding was more than minor because it adversely impacted the procedure quality, human performance and protection against external events attributes of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of this finding is bounded by the significance of a related Yellow finding regarding the ability to mitigate an external flooding event (Inspection Report 05000285/2010008). This finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, for failure to thoroughly evaluate problems such that the resolutions address causes and extent of conditions. This also includes, for significant problems, conducting effectiveness reviews of corrective actions to ensure that the problems are resolved P.1(c). Enforcement. Technical Specification 5.8.1.a, "Procedures," states, "Written procedures and administrative policies shall be established, implemented, and maintained covering the following activities: (a) The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, 1978." NRC Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)," Appendix A, "Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors," Section 6, recommends procedures for combating emergencies and other significant events. Abnormal Operating Procedure 1, "Acts of Nature, Section - I, Flooding," and its supporting procedures, prescribe station actions to mitigate the consequences of external flooding. Contrary to the above, since 1978, the licensee failed to have adequate procedures for combating emergencies. Specifically, Abnormal Operating Procedure 1, "Acts of Nature, Section - I, Flooding," and its supporting procedures, were inadequate to mitigate the consequences of external flooding by (1) failing to provide operators with sufficient information to ensure a transfer of power from offsite to an onsite emergency diesel geneator prior to a loss of offsite power, (2) failing to identify that the class-1E powered motor operators of the six intake structure sluice gates were located at an elevation of 1,010 feet mean sea level, (3) failing to identify

that three of the six sluice gate motor operators would be de-energized when offsite power was transferred from offsite to one onsite emergency diesel

generator, and (4) not adequately ensuring the fuel transfer hose to emergency diesel generator day tanks were staged prior to river level exceeding 1,004 feet mean sea level. This violation is considered as a related violation to the Yellow finding issued in October 2010, that, in general, dealt with issues related to mitigating a significant external flooding event. A separate citiation will not be

- 8 - Enclosure issued as this finding, and its corrective actions, will be managed by the Manual Chapter 0350 Oversight Panel. VIO 05000285/2012002-01, Inadequate Procedures to Mitigate a Design Basis Flood Event. (2) Failure to Classify Intake Structure Sluice Gates as Safety Class III Introduction. The inspectors identified a violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for failure of the licensee to classify the six intake structure exterior sluice gates and their motor operators as Safety Class III as defined in the Updated Safety Analysis Report, Appendix N. Description. The inspectors discovered that this finding had been originally identified by licensee personnel in February 2011, as Action Item No. 34 to Condition Report 2010-2387. However, this action item was closed in August 2011, without action taken to classify the sluice gates as safety related. In preparation for the NRC flooding inspection, licensee personnel conducted a review of Condition Report 2010-2387 Action Item No. 34 that revealed the quality classification of each penetration/flood barrier had not been verified. Condition Report 2011-10302 was issued in December 2011, to identify that the quality classification of the intake structure cell level control and level monitoring

equipment may be incorrect. Because of the failure of the corrective action program to resolve the issue after initially being identified, and the significant value added by further inspection effort, the finding is documented as NRC-identified. Analysis. The inspectors determined that failure to classify the intake structure exterior sluice gates and their motor operators as Safety Class III is a performance deficiency. This finding was more than minor because it adversely impacted the protection against external events attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable

consequences. The significance of this finding is bounded by the significance of a related Yellow finding regarding the ability to mitigate an external flooding event (Inspection Report 05000285/2010008). This finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, for failure to thoroughly evaluate problems such that the resolutions address causes and extent of conditions. This also includes, for significant problems, conducting

effectiveness reviews of corrective actions to ensure that the problems are resolved P.1(c). Enforcement. 10 CFR 50, Appendix B, Criterion III, "Design Control," states in part that measures shall be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components are correctly translated into specifications, drawings, procedures, and instructions. Contrary to this, before February 6, 2012, the licensee failed to establish measures to assure applicable regulatory requirements and the design basis for those components were correctly translated into specifications,

- 9 - Enclosure drawings, procedures, and instructions. Specifically, the licensee failed to classify the six intake structure exterior sluice gates and their motor operators as Safety Class III as defined in the Updated Safety Analysis Report, Appendix N. This violation is not being treated as a new violation. Instead, it is considered as a related violation to the Yellow finding issued in October 2010, that, in general, dealt with issues related to mitigating a significant external flooding event. A separate citiation will not be issued as this finding, and its corrective actions, will be managed by the Manual Chapter 0350 Oversight Panel: VIO 05000285/2012002-02, Failure to Classify Intake Structure Sluice Gates as Safety Class III (EA-2012-095). (3) Failure to Meet Design Basis Requirements for Design Basis Flood Event Introduction. The inspectors identified a violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for failure to meet design basis requirements for protection of the safety related raw water system during a design basis flood for flood levels between 1,010-1,014 feet mean sea level as identified in Updated Safety Analysis Report, Section 9.8, "Raw Water System." Specifically, the

design basis states that water level inside the intake cells can be controlled during a design basis flood by positioning the exterior sluice gates to restrict the

inflow into the cells. Description. The electric motor operators that position the six exterior sluice gates on the intake structure are located at an elevation of 1,010 feet mean sea level outside the east wall of the intake structure. At the design basis flooding elevation of 1,014 feet mean sea level, they would be completely submerged. Therefore, the motors that position the exterior sluice gates may not function when river water level rises above the 1,010 feet mean sea level. The licensee's flooding mitigation strategy involves closing five of the six exterior sluice gates and positioning the remaining gate such that a balance between inflow and raw water pump discharge are balanced (approximately one-inch open) prior to water level rising to 1,010 feet mean sea level. The inspectors identified that changing river conditions above 1,010 feet mean sea level, could interrupt the pre-established flow balance and jeopardize the control of intake cell water level without the ability to reposition any of the

external sluice gates. Should silting or sanding occur that blocks the one slightly open sluice gate, a lowering of cell water level could occur to a level below raw water pump minimum submergence requirements, resulting in loss of the raw water system - the ultimate heat sink. Similarly, should a water-born hazard (floating tree or other large river debris) strike any of the sluice gates, or their motor operators, or their connecting rods such that inflow or leakage is increased to greater than the capacity of two raw water pumps, a raising of cell water level could occur to a level that results in flooding of the raw water pump vaults (1,007.5 feet mean sea level), resulting in a loss of the raw water system.

- 10 - Enclosure Analysis. The inspectors determined that the licensee's failure to meet design basis requirements in the Updated Safety Analysis Report was a performance deficiency. This finding was more than minor because it adversely impacted the equipment performance and protection against external events attributes of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of this finding is bounded by the significance of a related Yellow finding regarding the ability to mitigate an external flooding event (Inspection Report 05000285/2010008). This finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, for failure to thoroughly evaluate problems such that the resolutions address causes

and extent of conditions P.1(c). Enforcement. 10 CFR 50, "Design Control," Appendix B, Criterion III, states in part that measures shall be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, the licensee failed to establish measures to assure that applicable regulatory requirements and the design basis

for those components were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to translate design basis requirements for protection of the safety related raw water system during a design basis flood for flood levels between 1,010-1,014 feet mean sea level as identified in Updated Safety Analysis Report, Section 9.8, "Raw Water System." Specifically, the design basis states that water level inside the intake cells can be controlled during a design basis flood by positioning the exterior sluice gates to restrict the inflow into the cells and this operation was not assured under all design basis conditions. This violation is not being treated as a new violation. Instead, it is considered as a related violation to the Yellow finding issued in October 2010, that, in general, dealt with issues related to mitigating a significant external flooding event. A separate citiation will not be issued as this finding, and its corrective actions, will be managed by the Manual Chapter 0350 Oversight Panel. VIO 05000285/2012002-03, Failure to Meet Design Basis Requirements for Design Basis Flood Event. 1R04 Equipment Alignment (71111.04) .1 a. Semiannual Complete System Walkdown Inspection Scope The inspectors performed a complete system alignment inspection of the high-pressure safety injection system to verify the functional capability of the system. This system was selected because it was considered both safety significant and risk significant in the licensee's probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment line ups, electrical power availability, system

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

- 11 - Enclosure lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding work orders was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to

ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the attachment. In addition, additional activities were performed during the system walkdown that were associated with Temporary Instruction 2515/177, "Managing gas accumulation in

emergency core cooling, decay heat removal, and containment spray systems." These activities are described in Section 1R04.2. These activities constituted one complete system walkdown sample as defined in

Inspection Procedure 71111.04-05. b. Findings No findings of significance were identified. .2 a. System Walkdown Associated With Temporary Instruction (TI) 2515/177, "Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal, And Containment Spray Systems." The inspectors conducted a walkdown of the high-pressure safety injection system in sufficient detail to reasonably assure the acceptability of the licensee's walkdowns (TI 2515/177, Section 04.02.d). The inspectors also verified that the information obtained during the licensee's walkdown was consistent with the items identified during the inspectors' independent walkdown (TI 2515/177, Section 04.02.c.3). Inspection Scope In addition, the inspectors verified that the licensee had isometric drawings that described the high-pressure safety injection system configurations and had acceptably confirmed the accuracy of the drawings (TI 2515/177, Section 04.02.a). The inspectors

verified the following related to the isometric drawings: High point vents were identified High points that do not have vents were acceptably recognizable Other areas where gas can accumulate and potentially impact subject system operability, such as at orifices in horizontal pipes, isolated branch lines, heat

exchangers, improperly sloped piping, and under closed valves, were acceptably described in the drawings or in referenced documentation. Horizontal pipe centerline elevation deviations and pipe slopes in nominally horizontal lines that exceed specified criteria were identified.

- 12 - Enclosure All pipes and fittings were clearly shown. The drawings were up-to-date with respect to recent hardware changes and that any discrepancies between as-built configurations and the drawings were documented and entered into the corrective action program for resolution. The inspectors verified that Piping and Instrumentation Diagrams (P&IDs) accurately described the subject systems, that they were up-to-date with respect to recent hardware changes, and any discrepancies between as-built configurations, the isometric drawings, and the P&IDs were documented and entered into the corrective action program for resolution (TI 2515/177, Section 04.02.b). Documents reviewed are listed in the attachment to this report. This inspection effort counts towards the completion of Temporary Instruction 2515/177, which was closed in Section 4OA5.2 of this report. b. No findings of significance were identified. Findings 1R05 Fire Protection (71111.05) .1 Quarterly Fire Inspection Tours a. The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas: Inspection Scope February 26, 2012, Fire Area 36B (West Switchgear Room), Room 56W February 26, 2012, Fire Area 36A (East Switchgear Room), Room 56E March 28, 2012, Fire Area 41 (Cable Spreading Room), Room 70 March 28, 2012, Fire Areas 37 & 38 (Battery Rooms 1 and 2), Rooms 54 & 55

The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented

adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that

- 13 - Enclosure fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of four quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05. b. No findings of significance were identified. Findings 1R11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11) The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination. For this annual inspection requirement, the licensee was in the first part of the training cycle. .1 Annual Inspection a. Inspection Scope The inspectors reviewed the results of the examinations and operating tests in order to satisfy the annual inspection requirements. On January 4, 2011, the licensee informed the inspectors of the following results: 8 of 10 crews passed the simulator portion of the operating test 40 of 45 licensed operators passed the simulator portion of the operating test 45 of 45 licensed operators passed the job performance measure portion of the examination The individuals that failed the simulator scenario portions of the operating test were remediated, retested, and passed their retake operating tests.

These activities constitute completion of one annual licensed operator requalification program sample as defined in Inspection Procedure 71111.11.

- 14 - Enclosure b. Findings No findings of significance were identified. .2 a. Quarterly Review of Licensed Operator Requalification Program On March 26, 2012, the inspectors observed a crew of licensed operators in the plant's simulator during requalification training. The inspectors assessed the following areas: Inspection Scope Licensed operator performance The ability of the licensee to administer the evaluations [and/or the quality of the training provided] The quality of post-scenario critiques These activities constitute completion of one quarterly licensed operator requalification program sample as defined in Inspection Procedure 71111.11. b. No findings of significance were identified. Findings

Cornerstone: Emergency Preparedness 1EP1 Exercise Evaluation (71114.01) a. The licensee submitted the proposed scenario and evaluation objectives for the 2012 emergency plan exercise on January 27, 2012, as required by Appendix E to Part 50, IV.F.2.b. This exercise was postponed from October 2011, as approved by the NRC in an exemption, dated October 2, 2011 (ADAMS Accession Number ML112640400). The inspectors performed an in-office review of the scenario and objectives to determine if the proposed exercise acceptably tested major elements of the license's emergency plan, allowed for demonstration of key emergency preparedness skills, provided a challenging drill environment, avoided the preconditioning of participant responses, and supported the exercise evaluation objectives. Inspection Scope The inspectors observed the emergency plan exercise conducted March 27, 2012, to determine if the exercise tested major elements of the licensee's emergency plan, allowed for demonstration of key emergency preparedness skills, and avoided

preconditioning participant responses. The scenario events were designed to escalate through the emergency classifications from a Notification of Unusual Event to a General Emergency to demonstrate licensee personnel's capability to implement their emergency plan. The scenario simulated the following:

- 15 - Enclosure a reactor coolant system leak inside containment; a loss of normal feed water to steam generators; a loss of auxiliary feed water to steam generators; a reactor protection system failure resulting in an anticipated transient without reactor scram; reactor vessel water level lowering to below the top of active fuel; a hydrogen explosion inside containment; and failure of a containment penetration, resulting in a radiological release. The inspectors observed licensee performance in the Control Room Simulator, Technical

Support Center, Operations Support Center, and Emergency Operations Facility. The inspectors evaluated exercise performance by focusing on the risk-significant activities of event classification, offsite notification, assessment of radiological consequences, and

the development of protective action recommendations. The inspectors also assessed recognition of, and response to, abnormal and emergency plant conditions, the transfer of decision-making authority and emergency function responsibilities between facilities, onsite and offsite communications, protection of emergency workers, the prioritization and conduct of emergency repairs, and the overall implementation of the emergency plan to protect public health and safety and the environment. The inspectors reviewed the current revision of the facility emergency plan, emergency plan implementing procedures associated with operation of the licensee's emergency response facilities, and procedures for the performance of

associated emergency functions. The inspectors compared the observed exercise performance with the requirements in the facility emergency plan, 10 CFR 50.47(b), 10 CFR Part 50, Appendix E, with the guidance in the emergency plan implementing procedures, and other federal guidance. The inspectors attended the post-exercise critiques in each emergency response facility to evaluate the initial licensee self-assessment of exercise performance. The inspectors also attended a subsequent formal presentation of critique items to plant management. The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.01-05. b. No findings of significance were identified. Findings 1EP4 Emergency Action Level and Emergency Plan Changes (71114.04) a. Inspection Scope

- 16 - Enclosure The NSIR headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures located under ADAMS accession numbers ML12009A076 and ML12023A008, as listed in the attachment. The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in these revisions resulted in no reduction in the effectiveness of the Plan, and that the revised procedures continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the attachment. b. Findings No findings of significance were identified 1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies (71114.05) a. The inspector reviewed the licensee=s response to failures in the emergency alert and notification siren system that occurred February 23, 2012, and March 6, 2012, as documented in NRC Event Notifications 47696 and 47721. The inspector reviewed event timelines, control room logs, and licensee Condition Reports 2012-01435, 2012-01489, 2012-01490, 2012-01501, and 2012-01742. The inspector also reviewed the Fort Calhoun Station Radiological Emergency Response Plan, Section E, "Notification Methods and Procedures," Revision 26, and Appendix A, "Letters of Agreement," Revision 21. Inspection Scope

These activities constitute completion of one sample as defined in Inspection Procedure 71114.05-05.

b. Introduction. A Green non-cited violation was identified for the licensee's failure to follow the site emergency plan on February 23, 2012, as required by 10 CFR

50.54(q)(2). Findings Description. The NRC identified that between 6:09 p.m. on February 23 and 3:04 a.m. on February 24, 2012, the licensee failed to follow an emergency plan requirement that offsite warning signals be activated by radio signal. Consequently, notification to some

members of the public of an emergency would have been delayed because offsite authorities would have had to respond to unanticipated failures of emergency sirens. Specifically, twenty-one outdoor warning sirens in Pottawattamie and Harrison Counties, Iowa, could not be activated by radio signals, and alternative means for notification were not established because the siren system status was not communicated to offsite authorities.

- 17 - Enclosure The outdoor emergency warning system in the Fort Calhoun Station emergency planning zone consists of 72 sirens in four counties. A failure occurred in the primary radio system used to activate offsite sirens at 6:09 p.m., February 23, 2012, causing a reboot of the siren system server. Twenty-one sirens in Pottawattamie and Harrison Counties, Iowa, failed to reestablish communications with the server following the reboot. A series of automatic pages to Communications Department technicians reported the loss and restoration of siren communication, one pager signal per siren per change in status. Siren technicians did not immediately investigate the siren system status because they were troubleshooting with high priority unrelated failures in communications data servers leased by offsite authorities and the messages displayed on pagers did not indicate siren system problems. It was not readily apparent that communications to all sirens in the system was not restored because of data display limitations in the pagers. Communications Department technicians acknowledged siren system alarms at 11:17 p.m. on February 23 and became aware of communications problems to some sirens. The technicians began to troubleshoot the siren system, but did not communicate the failure to the Communications Department or the Fort Calhoun Station Control Room until approximately 2:00 a.m. on February 24. A list of affected sirens was

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

The Control Room informed Sheriff Department dispatchers in Pottawattamie and Harrison Counties, Iowa, of the siren system communications failure at 3:04 a.m. on February 24. The licensee requested that alternative means (route alerting) be employed should notification to the public of an emergency be required. The inspector identified Section E, Part 4.0, "Alert Notification System," of the licensee emergency plan requires that offsite emergency warning sirens are activated by radio signal. The inspector also identified that Letters of Agreement with Pottawattamie and Harrison Counties, Iowa, included the provision of early notification to the public of a radiological emergency. The inspector verified the provision of notification to the public included alternate means of notification when necessary. The inspector concluded the licensee could not have known of the inability to activate offsite sirens until after 6:09 p.m., February 23, 2012. The inspector also concluded that between 6:09 p.m. on February 23 and 3:04 a.m. on February 24, 2012, the licensee failed to follow Section E, Part 4.0, "Alert Notification System," of the licensee emergency plan and failed to inform offsite authorities. The lack of communication to offsite authorities affected the ability of Pottawattamie and Harrison Counties, Iowa, to carry out their responsibilities under their Letters of Agreement. Analysis. The inspector determined the licensee's failure to promptly respond to indications of siren system failure and the subsequent failure to promptly inform offsite authorities of a siren control system failure are performance deficiencies within the licensee's control. This finding is more than minor because it had the potential to affect safety and affected the facilities and equipment cornerstone attribute (availability of the alert and notification system). The finding impacted the emergency preparedness

- 18 - Enclosure cornerstone objective because the ability to implement adequate measures to protect the public health and safety is affected when the means to notify some members of the public of an emergency are degraded. The finding was associated with a violation of NRC requirements. This finding was evaluated using Attachment 2, "Failure to Comply Significance Logic," to Manual Chapter 0609, Appendix B, "Emergency Preparedness Significance Determination Process." The finding was determined to be of very low safety significance (Green) because the risk-significant planning standard function was not lost or degraded. The planning standard function was not degraded because some

sirens remained functional in the 0-5 and 5-10 mile areas of the emergency planning zone and offsite officials could have promptly recognized the failed sirens and

implemented alternative means of notification. The need to recognize and respond to multiple unanticipated siren failures would have delayed the implementation of alternate means to notify the public. This failure has been entered into the licensee's corrective action system as Condition Reports 2012-01435 and 2012-01489. This finding was assigned a Cross-Cutting Aspect of Work Coordination because the Communications Department and Control Room did not communicate and coordinate as necessary to ensure plant and human performance, and to maintain interfaces with offsite organizations H3.b]. Enforcement. Title 10 CFR, 50.54(q)(2), states, in part, that a holder of a license under this part shall follow and maintain the effectiveness of an emergency plan that meets the requirements of Appendix E to Part 50, and the planning standards of 50.47(b). Fort Calhoun Station Radiological Emergency Response Plan Section E, "Notification Methods and Procedures," Revision 26, Section 4.0, requires in part that outdoor emergency warning sirens are activated by radio signal. Contrary to the above, on February 23, 2012, outdoor emergency warning sirens could not be activated by radio signal. Specifically between 6:09 p.m. on February 23 and 3:04 a.m. on February 24, 2012, twenty-one outdoor warning sirens could not be activated by radio signals and alternate means to notify the public were not established. Because this failure is of very low safety significance and has been entered into the licensee's corrective action system (Condition Reports 2012-01435 and 2012-01489), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 50-285/2012002-04, [Failure to Promptly Recognize and Communicate Siren System Failures]. 1EP6 Drill Evaluation (71114.06) .1 Training Observations a. The inspectors observed a simulator training evolution for licensed operators on March 27, 2012, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors' activities was to note any weaknesses and deficiencies in the crew's Inspection Scope

- 19 - Enclosure performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment. These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05. b. No findings of significance were identified. Findings 4. OTHER ACTIVITIES Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection 4OA1 Performance Indicator Verification (71151) .1 Drill/Exercise Performance (EP01) a. The inspectors sampled licensee submittals for the Drill and Exercise Performance, performance indicator for the period from April 2010 through September 2011. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, was used. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in

accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator; assessments of performance indicator opportunities during predesignated control room simulator training sessions, and performance during other drills. The specific documents reviewed are described in the attachment to this report. Inspection Scope These activities constitute completion of the drill/exercise performance sample as defined in Inspection Procedure 71151-05. b. (1) Failure to follow the licensee emergency plan during the June 7, 2011, Alert declaration Findings Introduction. A Green non-cited violation was identified for the licensee's failure to follow the Fort Calhoun Radiological Emergency Response Plan during an

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

- 20 - Enclosure licensee failed to notify offsite authorities within 15 minutes of an emergency declaration as required by Fort Calhoun Radiological Emergency Response Plan, Section E, part 2.4. Description. The Fort Calhoun Radiological Emergency Response Plan, Section E, part 2.4, requires notification to the states of Nebraska and Iowa within 15 minutes of an emergency declaration. Inspectors determined the notification to responsible state and local governmental agencies following the June 7, 2011, alert emergency classification was completed 18 minutes 41 seconds after declaring the emergency. The licensee declared an alert emergency classification at 9:40 a.m., June 7, 2011. The offsite contact time recorded for this event on Form FC-1188, "Fort Calhoun Station - Emergency Notification Form," Revision 25, dated June 7, 2011, was 9:56 a.m., 16 minutes following event classification. On October 20, 2011, the licensee reviewed a recording of the June 7, 2011, event notification call, and determined notification was completed at 9:58:41 a.m.; notification consisted of the emergency classification, the applicable emergency action level, and that no protective actions were required for the public. On February 3, 2012, the licensee reviewed the notification call recording and determined the call was initiated from the Fort Calhoun Station Control Room at approximately 9:55 a.m., 15 minutes after event classification. The inspectors concluded that an actual notification time of 18 minutes, 41 seconds after event declaration did not comply with the Fort Calhoun Radiological Emergency Response Plan requirement to notify offsite authorities within 15 minutes of an emergency declaration. Analysis. The inspectors determined the failure to comply with requirements of the Fort Calhoun Radiological Emergency Response Plan is a performance deficiency within the licensee's control. This finding is more than minor because it affects safety and impacts the cornerstone attributes of emergency response organization performance and actual event response. The finding had a credible

impact on the Emergency Preparedness Cornerstone objective because untimely notification to offsite authorities degrades their ability to implement adequate measures to protect the health and safety of the public. The finding was associated with a violation of NRC requirements. This finding was evaluated using Attachment 1, "Actual Event Significance Logic," to Manual Chapter 0609, Appendix B, "Emergency Preparedness Significance Determination Process." The finding was determined to be of very low safety significance (Green) because it was a failure to implement the emergency plan during an event, the

event was a declared alert, and the licensee's failure did not affect the ability of offsite authorities to implement appropriate protective measures for the public.

This failure has been entered into the licensee's corrective action system as Condition Report 2011-8529. This finding has been assigned a cross-cutting aspect of work practices (management oversight) because licensee management did not set performance expectations for event notifications and monitor

- 21 - Enclosure performance to ensure compliance with emergency plan requirements. Specifically, licensee management did not ensure that notification completion times were evaluated and trended, and did not monitor the notification function to ensure processes, training, and equipment supported the emergency plan requirement that offsite notification be performed in a timely manner. H4.c]. Enforcement. Title 10 CFR 50.54(q)(2) states, in part, that a holder of a license under this part shall follow and maintain the effectiveness of an emergency plan that meets the planning standards of 50.47(b). The Fort Calhoun Radiological Emergency Response Plan, Section E, part 2.4, requires notification to the states of Nebraska and Iowa within 15 minutes of an emergency declaration. Contrary to the above, on June 7, 2011, the licensee failed to notify the states of Nebraska and Iowa within 15 minutes of an emergency declaration. Specifically, Fort Calhoun Station notified the states of Nebraska and Iowa 18 minutes 41 seconds after declaring the emergency. Because this failure is of very low safety significance and has been entered into the licensee's corrective action system (Condition Report 2011-8529), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000285/2012002-05, "Failure to comply with an emergency plan requirement to notify offsite authorities within 15 minutes of an emergency." 4OA2 Problem Identification and Resolution (71152) .1 Routine Review of Identification and Resolution of Problems a. As part of the various baseline inspection procedures discussed in previous sections of

this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents

reviewed. Inspection Scope These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in

Section 1 of this report. b. Findings

- 22 - Enclosure No findings of significance were identified. .2 Daily Corrective Action Program Reviews a. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. The inspectors accomplished this through review of the station's daily corrective action documents. Inspection Scope The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples. b. No findings of significance were identified. Findings 4OA3 Followup of Events and Notices of Enforcement Discretion (71153) .1 (Closed) Licensee Event Report 05000285/2010-001-01: Containment Integrity Violated During Refueling Leak Test Due to Inadequate Training Containment integrity was violated on November 1, 2009. This was a result of opening manual containment isolation valve SI-410 (Safety injection Tanks Fill/Drain Valve) when containment integrity was required and inadequate administrative controls were implemented. In preparation for performing a leak check of the safety injection tanks leakoff piping, a procedural step in the surveillance test opened manual containment isolation valve. SI-410, as well as re-aligning other valves. The procedure prerequisites require the reactor coolant system to be pressurized above 600 psig, which results in the reactor coolant system being greater than 210 degrees Fahrenheit; thus, containment integrity is required.

Prior to the performance of the surveillance test on November 1, 2009, it was recognized that the opening of valve SI-410 needed to be administratively controlled. The surveillance test procedure was revised to require administrative controls be in place prior to opening containment isolation valve SI-410. A root cause analysis determined that training on containment integrity to specifically meet the intent of Technical Specifciation 2.6(1)a, as defined in the Technical Specification basis section, is insufficient to ensure complete understanding of the requirements. This licensee event report was reviewed by inspectors. A licensee identified violation is documented in Section 4OA7 of this report. This licensee event report is closed. .2 (Closed) Licensee Event Report 05000285/2010-006-01: Reactor Trip Due to Erroneous Moisture Separator Trip Signal

- 23 - Enclosure Fort Calhoun Station was operating at full power (nominal 100 percent). The station was preparing a scaffolding for an upcoming outage when on December 23, 2010, at 1050 Central Standard Time, a reactor trip occurred. The operators entered Emergency Operating Procedure 00, "Standard Post Trip Actions." The main steam and feedwater systems operated normally. All control rods inserted fully. The apparent cause of the turbine and subsequent reactor trip was the inadvertent actuation, caused by bumping, and sticking of one of four turbine moisture separator high water level turbine trip switches while reactor power was above 15 percent. The root cause was insufficient performance monitoring of the moisture separator high level trip mercury switches which resulted in degraded performance and increased risk for susceptibility to binding.

Following the initial determination of the erroneous moisture separator high level trip signal, immediate actions included: halting all work near the moisture separator sensing lines and level switches, posting the affected areas as "Protected Equipment," and initiating a stop work action for all ongoing scaffold work within the turbine building. The moisture separator level switches and logic will be replaced during the 2011 refueling outage.

This licensee event report was reviewed by inspectors. It appears that the direct cause for an erroneous actuation of the moisture separator trip signal is due to on-going work near the vicinity of the moisture separator level switches. Personnel involved in scaffold construction work had been observed working near moisture separator level sensing lines prior to and immediately after the turbine trip. A green non-cited violation related to scaffold procedures was documented in Inspection Report 05000285/2011003. This licensee event report is closed. .3 (Closed) Licensee Event Report 05000285/2011-001-00: Inadequate Flooding Protection Due To Ineffective Oversight During identification and evaluation of flood barriers, unsealed through wall conduit

penetrations in the outside wall of the intake structure were identified that are below the licensing basis flood elevation.

A summary of the root causes included: a weak procedure revision process; insufficient oversight of work activities associated with external flood matters; ineffective

identification, evaluation and resolution of performance deficiencies related to external flooding; and "safe as is" mindsets relative to external flooding events. The penetrations were temporarily sealed and a configuration change was developed and implemented whereby permanent seals were installed. Comprehensive corrective actions to address the root and contributing causes are being addressed through the corrective action program.

- 24 - Enclosure This licensee event report was reviewed by inspectors. The licensee cancelled this licensee event report, determining that the issues on flooding should be reported in a single licensee event report. The issues were incorporated into Licensee Event Report 2011-003-03. This licensee event report is closed. .4 (Closed) Licensee Event Report 05000285/2011-005-00: Failure to Correctly Enter Technical Specifications Limiting Condition for Operation for the Reactor Protective System On June 14, 2010, the reactor protective system M2 contactor (similar to the reactor

protective system breakers) failed to open during periodic surveillance testing. Operations declared the reactor protective system M2 contactor inoperable and entered Technical Specification Limiting Condition for Operation Action 2.15(1) because the reactor protective system M2 contactor did not have a specifically defined limiting condition for operation. Subsequent reviews determined that the station continued to operate in a condition not allowed by technical specifications on June 14 and 15, 2010, for a period of approximately 20.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Technical Specification 2.0.1, which specifies measures to be employed for conditions not covered by Limiting Conditions for Operation, should have been invoked.

The root cause for this error was determined to be the failure to implement an interim technical specification strategy when funding for standard improved technical specifications was deferred. The operations staff has been directed to enter Technical Specification 2.0.1 for any failures of these contactors. The licensee planned to conduct a formal review of other components which do not have specific technical specification limiting condition for operation action statements and station actions that could be non-conservative with regard to entering Technical Specification 2.0.1. The review will identify those items that need administrative controls and place them in the appropriate station procedures. This licensee event report was reviewed by inspectors. A White violation related to to failures involving the reactor protective system M2 contactor was documented in Inspection Report 05000285/2011007. This licensee event report is closed. .5 (Closed) Licensee Event Report 05000285/2011-006-00: Inoperability of Both Trains of Containment Coolers Due to a Mispositioned Valve On March 22, 2011, during the performance of a test on containment cooler valves, a technician discovered that NGHCV-400A-A3, "CCW Inlet Valve HCV-400A Nitrogen Supply Isolation Valve," was in the closed position. This is not the correct position. He

informed the control room of the condition. At the time of discovery, containment cooler VA-3B was inoperable to support the performance of a surveillance test. Operations declared VA-3A inoperable as the backup nitrogen supply to HCV-400A for containment cooler VA-3A cooling coil was unavailable. Operations entered Technical Specification 2.0.1 since both VA-3A and VA-3B were simultaneously inoperable. An equipment operator was dispatched to open NG-HCV-400A-A3. After NG-HCV-400A-A3

- 25 - Enclosure was opened, VA-3A was declared operable. Technical Specification 2.0.1 was then exited. The root cause analysis determined the cause of this event was the station's leadership oversight effort has not been effective in the areas of use of the station's corrective action program, human performance tools and safe work practices in reducing the potential for mispositioning events. The immediate corrective action of opening the affected valve restored VA-3A to an operable condition. Additional corrective actions to address the root and generic

implications of this event will be addressed by the station's corrective action process. This licensee event report was reviewed by inspectors. The licensee cancelled this licensee event report, determining that the valve would open during design basis conditions allowing the containment cooler to perform its intended safety function. This licensee event report is closed. .6 (Closed) Licensee Event Report 05000285/2011-009-00: Manual Start of a Safety System On June 26, 2011, at approximately 1:25 a.m. Central Daylight Time, the AquaDam, water-filled dam which was providing enhanced flood protection for Fort Calhoun Station, failed after being struck by a skid loader. As a precautionary measure, plant operators used the abnormal operating procedures to align necessary plant equipment to alternate (emergency) power supplies. Emergency Diesel Generator 2 was manually started to remove bus 1A4 from offsite power. Emergency Diesel Generator 1 was manually started to remove bus 1A3 from offsite power as well. Both emergency diesel generators loaded on their respective busses as designed. Offsite power remained available throughout the event. No safety-related equipment was impacted by the water intrusion. Plant equipment was realigned to the off-site power operating configuration and the emergency diesel generators were secured.

This licensee event report was reviewed by inspectors. The inspectors determined that there was no violation of regulatory requirements, as the licensee was taking action associated with a sequence of events. This licensee event report is closed. 4OA5 Other Activities .1 Confirmatory Action Letter Activities On August 30, 2011, Fort Calhoun Station issued Revision 1 to the "Fort Calhoun Station Post-Flooding Recovery Action Plan," that provided for extensive reviews of plant systems, structures, and components to assess the impact of the flood waters. On September 2, 2011, the NRC issued Confirmatory Action Letter 4-11-003, listing 235 items described in the Fort Calhoun Station Post-Flooding Recovery Action Plan that the licensee committed to complete. The areas to be inspected were identified in that

- 26 - Enclosure confirmatory action letter and many of these items were reviewed during this report period. With the emergence of more performance issues since issuance of Confirmatory Action Letter 4-11-003, a new confirmatory action letter which subsumes Confirmatory Action Letter 4-11-003 was under development during this report period by the Manual Chapter 0350 Oversight team. The new confirmatory action letter will be designed to cover all items in Confirmatory Action Letter 4-11-003, along with the more recently discovered performance issues. .2 (Closed) NRC Temporary Instruction 2515/177, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter 2008-01)" a. The inspectors evaluated whether the licensee maintained documents, installed system hardware, and implemented actions that were consistent with the information provided in their response to NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems." Specifically, the inspectors verified that the licensee had implemented, or was in the process of implementing, the commitments, modifications, and programmatically controlled actions described in their response to Generic Letter 2008-01. The inspectors conducted their review in accordance with Temporary Instruction 2515/177 and

considered the site-specific supplemental information provided by the Office of Nuclear Reactor Regulation to the inspectors. Inspection Scope b. The inspectors reviewed the licensing basis, design, testing, and corrective actions as specified in the temporary instruction. The specific items reviewed and any resulting observations are documented below. Inspection Documentation Licensing Basis. The inspectors reviewed selected portions of licensing basis documents to verify that they were consistent with the Office of Nuclear Reactor Regulation assessment report, and that the licensee properly processed any required changes. The inspectors reviewed selected portions of technical specifications, technical specification bases, and the Updated Safety Analysis Report. The inspectors also verified that applicable documents that described the plant and plant operation, such as calculations, piping and instrumentation diagrams, procedures, and corrective action program documents addressed the areas of concern and were changed, if needed, following plant changes. The inspectors confirmed that the licensee performed surveillance tests at the frequency required by the technical specifications. The inspectors verified that the licensee tracked their commitment to evaluate and implement any changes that would be contained in the technical specification task force traveler.

- 27 - Enclosure Design The inspectors verified that the licensee had identified the applicable gas intrusion mechanisms for their plant. . The inspectors reviewed selected design documents, performed system walkdowns, and interviewed plant personnel to verify that the licensee addressed design and operating characteristics. Specifically: The inspectors verified that the licensee had established void acceptance criteria consistent with the void acceptance criteria identified by the Office of Nuclear Reactor Regulation. The inspectors also confirmed that the range of flow

conditions evaluated by the licensee was consistent with the full range of design basis and expected flow rates for various break sizes and locations. The inspectors selectively reviewed applicable documents, including calculations, and engineering evaluations with respect to gas accumulation in the emergency core cooling systems and decay heat removal systems. Specifically, the inspectors verified that these documents addressed venting requirements, aspects where pipes were normally voided, void control during maintenance

activities, and the potential for vortex effects that could ingest gas into the systems during design basis events. The inspectors verified that piping and instrumentation diagrams and isometric drawings describe up-to-date configurations of the emergency core cooling systems and decay heat removal systems. The review of the selected portions of

isometric drawings considered the following: (1) High point vents were identified (2) High points without vents were recognizable (3) Other areas where gas could accumulate and potentially impact operability, such as orifices in horizontal pipes, isolated branch lines, heat exchangers, improperly sloped piping, and under closed valves, were described in the drawings or in referenced documentation (4) Horizontal pipe centerline elevation deviations and pipe slopes in nominally horizontal lines that exceeded specified criteria were identified (5) All pipes and fittings were clearly shown. (6) The drawings were up-to-date with respect to recent hardware changes, and that any discrepancies between as-built configurations and the drawings were documented and entered into the corrective action program for resolution The inspectors verified that the licensee had completed their walkdowns and selectively verified that the licensee identified discrepant conditions in their

- 28 - Enclosure corrective action program and appropriately modified affected procedures and training documents. Testing. The inspectors reviewed selected surveillances, post-modification tests, and post-maintenance test procedures and results, conducted during power and shutdown operations, to verify that the licensee was using procedures that appropriately addressed gas accumulation and/or intrusion into the subject systems. This review included the verification of procedures used for conducting surveillances and for the determination of void volumes to ensure that void criteria were satisfied and would continue to be satisfied until the next scheduled void surveillances. In addition, the inspectors reviewed procedures used for filling and venting following conditions that could introduce voids into the subject systems to verify that the procedures adequately tested for such voids and provided adequate instructions for their reduction or elimination. Corrective ActionsBased on this review, the inspectors concluded that there is reasonable assurance that the licensee will complete all outstanding items and incorporate this information into the design basis and operational practices. This temporary instruction is closed for

Fort Calhoun Station. . The inspectors reviewed selected corrective action program documents to assess how effectively the licensee addressed the issues associated with Generic Letter 2008-01 in their corrective action program. In addition, the inspectors verified that the licensee implemented appropriate corrective actions for issues identified in the nine-month and supplemental responses. The inspectors determined that the licensee had effectively implemented the actions required by Generic Letter 2008-01. c. No findings of significance were identified. Findings 4OA6 Meetings, Including Exit Exit Meeting Summary On January 4, 2012, the inspectors obtained the final annual examination results and telephonically exited regarding the annual licensed operator requalification inspection with Mr. T. Giebelhausen, Operations Training Manager. The inspectors did not review any proprietary information during this inspection. On February 16, 2012, the inspectors presented the inspection results regarding Temporary Instruction 177 to Mr. M. Prospero, Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. On February 23, 2012, the inspectors conducted a telephonic exit meeting with Mr. D. Bannister, Vice President and Chief Nuclear Officer, and other members of the licensee's staff. The inspectors presented the results of the October 2011, onsite inspection of emergency preparedness performance indicators. The licensee

- 29 - Enclosure acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified. On March 22, 2012, the inspection team conducted a telephonic exit meeting with Mr. D. Bannister, Site Vice President and Chief Nuclear Officer, and other members of the licensee's staff to discuss the results of the readiness to cope with external flooding

inspection. The licensee acknowledged the findings presented. While limited proprietary information was reviewed during the inspection, no proprietary information was included in this report. On March 30, 2012, the inspectors presented the results of the onsite inspection of the

March 27, 2012, emergency preparedness exercise, onsite review of the February 23-24 and March 6, 2012, losses of siren system functionality, and the in-office and onsite inspections of Flood Recovery Plan items to Mr. D. Bannister, Vice President and Chief Nuclear Officer, and other members of the licensee's staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials

examined during the inspection should be considered proprietary. No proprietary information was identified. On April 11, 2012, the inspectors presented the quarterly inspection results to Mr. D. Banniser, Site Vice Presient and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified. 4OA7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation. Fort Calhoun Station Technical Specification 5.8.1, requires, in part, that the licensee establish and implement written procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978, including procedures for equipment control (e.g., locking and tagging). Contrary to this, containment integrigity was violated on November 1, 2009, when an inadequate procedural step in a surveillance test procedure required by Regulatory Guide 1.33 allowed opening of a locked closed containment isolation valve, thus violating containment integrity. The finding was determined to be of very low safety significance (Green) as it did not result in an actual release of radioactive material. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program as Condition Report 2010-1664, this violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy.

A-1 Attachment SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel R. Acker, Licensing Engineer S. Baughn, Manager, Nuclear Licensing

A. Berck, Supervisor, Emergency Planning B. Blome, Manager, Quality Assurance N. Bretey, Reliability Engineer, C. Cameron, Supervisor Regulatory Compliance E. Dean, System Engineer T. Dendinger, Mechanical Engineer, Design Engineering Nuclear K. Erdman, Supervisor, Programs M. Fern, Manager, SPII M. Frans, Manager, Engineering Programs S. Gebers, Manager, Emergency Planning and Health Physics W. Goodell, Division Manager, NPIS W. Hansher, Supervisor, Nuclear Licensing R. Haug, Manager, Training J. Herman, Division Manager, Nuclear Engineering K. Kingston, Manager, Chemistry T. Maine, Manager, Radiation Protection E. Matzke, Senior Licensing Engineer S. Miller, Manager, Design Engineering D. Molzer, AOV Program Engineer K. Naser, Manager, System Engineering A. Pallas, Manager, Shift Operations M. Prospero, Division Manager, Plant Operations M. Smith, Manager, Operations T. Uehling, Manager, Maintenance LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 05000285/2012002-01 VIO Inadequate Procedures to Mitigate a Design Basis Flood Event (Section 1R01)05000285/2012002-02 VIO Failure to Classify Intake Structure Sluice Gates as Safety Class III (Section 1R01)05000285/2012002-03 VIO Failure to Meet Design Basis Requirements for Design Basis Flood Event (Section 1R01) Opened and Closed 05000285/2012002-04 NCV Failure to Promptly Recognize and Communicate Siren System Failures (Section 1EP5)

A-2 05000285/2012002-05 NCV Failure To Comply With An Emergency Plan Requirement To Notify Offsite Authorities Within 15 Minutes Of An Emergency (Section 4OA1) Closed 2515/177 TI Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter 2008-01) (Section 4OA5.2) 05000285/2010-001-01 LER Containment Integrity Violated During Refueling Leak Test Due to Inadequate Training (Section 4OA3.1) 05000285/2010-006-01 LER Reactor Trip Due to Erroneous Moisture Separator Trip Signal(Section 4OA3.2) 05000285/2011-001-00 LER Report: Inadequate Flooding Protection Due To Ineffective Oversight (Section 4OA3.3) 05000285/2011-005-00 LER Failure to Correctly Enter Technical Specifications Limiting Condition for Operation for the Reactor Protective System (Section 4OA3.4) 05000285/2011-006-00 LER Inoperability of Both Trains of Containment Coolers Due to a Mispositioned Valve (Section 4OA3.5) 05000285/2011-009-00 LER Manual Start of a Safety System (Section 4OA3.6) LIST OF DOCUMENTS REVIEWED Section 1R01: Adverse Weather Conditions PROCEDURES NUMBER TITLE REVISION AOP-01 Acts of Nature,Section I - Flood 28 and 29 ARP-AI-187/A187 Annunciator Response Procedure A187 Local Annunciator A187, Switchgear Ventilation 10 EPIP-TSC-2 Catastrophic Flooding Preparations 14 FCSG-20 Abnormal Operating Procedure and Emergency Operating Procedure Writer's Guide 9 FCSG-64 External Flooding of Site 1 M8145WD Flood Control Walk-down Exercise 1 OI-CW-1 Circulating Water System Normal Operation 65 and 66

A-3 PROCEDURES NUMBER TITLE REVISION OI-FO-1 Fuel Receipt (FO-1, FO-10, FO-27, FO-32, FO-43A, and FO-43B) 31 OI-PGP-1 Operation of Portable Gas Powered Pumps 0 OPD-4-09 EOP/AOP Users Guidelines 15 PE-RR-AE-1000 Flood Barrier Inspection and Repair 9 PE-RR-AE-1001 Flood Barrier and Sandbag Staging and Installation 12, 13 14,15 PE-RR-AE-1002 Installation of Portable Steam Generator Makeup Pumps 4 QAM-5 NSRG Charter 5 SAP-29 Severe Weather and Flooding 13 SARC-0 Safety Audit and Review Committee (SARC) Charter 42 SARC-2 Safety Audit and Review Committee (SARC) Reviews 34 SARC-3 Safety Audit and Review Committee (SARC) Auditing 25 SHB: M8145 Flood Control (Mechanical Maintenance) Student Handbook 11 SO-G-124 Flood Barrier Impairment 1 SO-G-5 Fort Calhoun Station Plant Review Committee 160 TBD-AOP-01 Acts of Nature, Section 1 - Flood 28 and 29 CALCULATIONS NUMBER TITLE DATE 61563 Burns & McDonnell, Flood Barrier Qualification August 10, 2011 CN-OA-11-7 Intake Cell Level Control Using the Intake Sluice Gate During Flooding Conditions at the Ft. Calhoun Plant April 21, 2011 CN-SEE-II-11-2 Intake Cell Level Control - Flood Alternate Flow Path Evaluation for Fort Calhoun Station April 5, 2011 FC08030 Intake Structure Cell Level Control Using the Intake Structure Sluice Gates April 25, 2011 FC08070 Validation of Backup Fuel Oil Transfer During Flooding Conditions CONDITION REPORTS 2011-6062 2011-5489 2011-10512 2011-10302 2011-10300

A-4 CONDITION REPORTS 2012-00307 2012-00600 2012-00871 2012-00875 2012-00882 2012-00882 2012-00899 2012-00901 2012-00906 2012-00929 2012-00945 2012-00949 2012-00965 2012-00967 2012-00980 2012-00986 2012-00996 2012-00998 2012-01000 2012-01003 2012-01010 2012-01012 2012-01021 2012-01330 2012-02142 MISCELLANEOUS DOCUMENTS TITLE REVISION Technical Specification 2.16, River Level Updated Safety Assessment Report - 2.7, Hydrology 11 Updated Safety Assessment Report - 9.8, Raw Water System 29 Section 1R04: Equipment Alignment Documents reviewed for Section 1R04 are included in section 4OA5 Section 1RO5: Fire Protection PROCEDURES NUMBER TITLE REVISION SO-G-28 Standing Order, Station Fire Plan 82 SO-G-58 Standing Order, Control of Fire Protection System Impairments 37 SO-G-91 Standing Order, Control and Transportation of Combustible Materials 27 SO-G-102 Standing Order, Fire Protection Program Plan 11 SO-G-103 Standing Order, Fire Protection Operability Criteria and Surveillance Requirements 25 MISCELLANEOUS DOCUMENTS NUMBER TITLE REVISION EA-FC-97-001 Fire hazards Analysis Manual 16 FC05814 UFHA Combustible Loading Calculation 11 USAR 9.11 Updated Safety Analysis Report, Fire Protection Systems 23

A-5 Section 1R11: Licensed Operator Requalification Program PROCEDURES NUMBER TITLE REVISION LOR TPMP Licensed Operator Requal Training Program Master Plan 54 SO-G-26 Training and Qualification Programs Standing Orders 59 OPD-3-11 Licensed Activation and Watch station Maintenance 18 Section 1EP1: Exercise Evaluation PROCEDURES NUMBER TITLE REVISION Radiological Emergency Response Plan EPIP-OSC-1 Emergency Classification 46 EPIP-OSC-2 Command and Control Position Actions-Notifications 54-56 EPIP-OSC-9 Emergency Team Briefings 14 EPIP-OSC-16 Communicator Actions 27 EPIP-OSC-21 Activation of the Operations Support Center 20 EPIP-TSC-1 Activation of the Technical Support Center 32 EPIP-EOF-1 Activation of the Emergency Operations Facility 18 EPIP-EOF-3 Offsite Monitoring 23 EPIP-EOF-6 Dose Assessment 43 EPIP-EOF-7 Protective Action Guidelines 21 EPIP-EOF-21 Potassium Iodide Issuance 8 EPIP-EOF-11 Dosimetry Record, Exposure Extensions and Habitability 26 EPIP-RR-1 Technical Support Center Director Actions 17 EPIP-RR-21 Operations Support Center Director Actions 17

A-6 CONDITION REPORTS (CR) 2012-01435 2012-01489 2012-01490 2012-01501 2012-01742 2012-02131 2012-02250 2012-02374 2012-02376 2012-02377 2012-02379 2012-02381 2012-02400 2012-02475 Section 1EP4: Emergency Action Level and Emergency Plan Changes PROCEDURES NUMBER TITLE REVISION EPIP-EOF-3 Offsite Monitoring 24, 25 EPIP-EOF-7 Protective Action Guidelines 21, 22 EPIP-RR-21A Maintenance Coordinator Actions 6, 7 EPIP-RR-72 Field Team Specialist Actions 10, 20 EPIP-RR-90 EOF/TSC CHP Communicator Actions 5, 6

Section 1EP6: Drill Evaluation PROCEDURES NUMBER TITLE REVISION TBD-EPIP-OSC-1A Recognition Category A - Abnormal Rad Levels/Radiological Effluent 2 TBD-EPIP-OSC-1C Recognition Category C- Cold Shutdown/Refueling System Malfunction 2 TBD-EPIP-OSC-1F Recognition Category F - Fission Product Barrier Degradation 1 TBD-EPIP-OSC-1H Recognition Category H - Hazards and Other Conditions Affecting Plant Safety 1 TBD-EPIP-OSC-1S Recognition Category S - System Malfunction 2 CONDITION REPORTS 2011-6117 2011-8529 2011-8530 2011-8531 PROCEDURES

A-7 NUMBER TITLE REVISION EOF-7 Protective Action Guidelines 20, 21 EPDM-14 Emergency Preparedness Performance Indicator Program 12 Section 4OA5: Other Activities CALCULATIONS NUMBER TITLE REVISION FC06689 Susceptibility of HPSl / LPSl, System to Water Hammer 2 FC06941 LPSI System Critical Void Size and Operator Action Time 1 FC07124 Evaluation of the Maximum Gas, Void Fractions That Could be Delivered to the ECCS Pumps in the Fort Calhoun Design (Vendor Calc. No.: FA1108-89) 0 FC07258 Fort Calhoun Transient, Investigating the Potential for Vortex Formation in the SlRWT Suction Flow 0 FC07487 Response to the Fort Calhoun HPSl Piping High Points to Gas-Water Waterhammer 0 FC07500 Evaluation of Allowable Suction Piping Gas Void Volumes for Fort Calhoun to Address GL 2008-01 (Vendor Calc. No.: CN-SEE-III-08-40) 2 FC07501 Evaluation of the Potential for Waterhammer in the Containment Spray System for Fort Calhoun 0 FC07502 Evaluation of the Potential for Waterhammer During Cold Leg Injection for Fort Calhoun 0 FC07503 Allowable Gas Void Accumulation for the Fort Calhoun High Pressure Safety Injection Discharge Piping 1 FC07504 Gas-Water Waterhammer Evaluations for the Fort Calhoun Containment Spray Piping 1 FC07505 Evaluation of the Potential for Gas-Water, Waterhammer in Fort Calhoun During Hot Leg Injection 0 FC07532 Subsystem Si-164C (4 Inch HPSI Header) Stress Analysis For Void-Induced Water-Hammer Event 0 FC07532 Subsystem SI-164C (4 Inch HPSI Header) Stress Analysis For Void-Induced Water-Hammer Event 0 FC07548 Evaluation of the Gas Intrusion to the HPSI 2B Vendor Calc. No.: FAI/09-177 Pump Suction. 0 FC07804 HPSI Pump Cooled Suction Piping Gas Intrusion, Gas Voiding 0

A-8 CONDITION REPORTS 2008-2021 2009-2069 2009-4222 2010-1450 WORK ORDERS 350418 360590 362852 371018 379858 388762 DRAWINGS NUMBER TITLE REVISION / DATE E-23866-210-130 Sht. 1 Safety Injection and Containment Spray System Flow Diagram 111 E-23866-210-130 Sht. 2A Safety Injection and Containment Spray System Flow Diagram 24 E-23866-210-130 Sht. 3A Safety Injection and Containment Spray System Flow Diagram 29 E-2520 IC-186 Safety Injection - Aux Building 9 E-2520 IC-187 Safety Injection - Aux Building 13 E-2520 IC-188 Safety Injection - Aux Building 8 E-2520 IC-194 Safety Injection - Aux Building 9 E-2520 IC-195 Safety Injection - Aux Building 9 E-2520 IC-196 Safety Injection - Aux Building 9 E-2520 IC-197 Safety Injection - Aux Building 8 E-2520 IC-198 Safety Injection - Aux Building 6 E-2520 IC-199 Safety Injection - Aux Building 8 E-2520 IC-201 Safety Injection - Aux Building 9 E-2520 IC-204 Safety Injection - Aux Building 9 E-2520 IC-205 Safety Injection - Aux Building 13 E-2520 IC-206 Safety Injection - Aux Building 13 E-2520 IC-209 Safety Injection - Aux Building 7 E-2520 IC-72 Safety Injection - Containment Building 14 E-2520 IC-78 Safety Injection - Containment Building 8

A-9 DRAWINGS NUMBER TITLE REVISION / DATE E-2520 IC-92 Aux Coolant (Return) in Containment 7 LRA-A-1 Safety Injection and Containment Spray Grade Map - Suction Header Overview June 6, 2008 LRA-A-2 Safety Injection and Containment Spray Grade Map - Suction Header RM 21 June 6, 2008 LRA-A-3 Safety Injection and Containment Spray Grade Map - Suction Header RM 21, 22, 23 June 6, 2008 LRA-A-4 Safety Injection and Containment Spray Grade Map - Suction Header RM 23 June 6, 2008 LRA-B-1 Safety Injection and Containment Spray Grade Map - Suction Header Overview June 6, 2008 LRA-B-2 Safety Injection and Containment Spray Grade Map - Suction Header RM 21, 22 June 6, 2008 LRA-B-3 Safety Injection and Containment Spray Grade Map - Suction Header RM 22, 23 June 6, 2008 LRA-CGM-CS SI-3A Safety Injection and Containment Spray Grade Map - Composite Grade Map CS SI-3A June 6, 2008 LRA-CGM-CS SI-3B/3C Safety Injection and Containment Spray Grade Map - Composite Grade Map CS SI-3B/3C June 6, 2008 LRA-CGM-HPSI SI-2A/2C Safety Injection and Containment Spray Grade Map - Composite Grade Map HPSI SI-2A/2C June 6, 2008 LRA-CGM-HPSI SI-2B Safety Injection and Containment Spray Grade Map - Composite Grade Map HPSI SI-2B June 6, 2008 LRA-CGM-LPSI SI-1A Safety Injection and Containment Spray Grade Map - Composite Grade Map LPSI SI-1A June 6, 2008 LRA-CGM-LPSI SI-1B Safety Injection and Containment Spray Grade Map - Composite Grade Map LPSI SI-1B June 6, 2008 LRA-CS-1 Safety Injection and Containment Spray Grade Map - Overview June 6, 2008 LRA-CS-10 Safety Injection and Containment Spray Grade Map - AC-4B RM 14, 15A, 56 June 6, 2008 LRA-CS-2 Safety Injection and Containment Spray Grade Map - SI-3A RM21 June 6, 2008 LRA-CS-3 Safety Injection and Containment Spray Grade Map - June 6, 2008

A-10 DRAWINGS NUMBER TITLE REVISION / DATE SO-3A RM 21, 22 LRA-CS-4 Safety Injection and Containment Spray Grade Map - SI-3B RM 22 June 6, 2008 LRA-CS-5 Safety Injection and Containment Spray Grade Map - SI-3C RM 22 June 6, 2008 LRA-CS-6 Safety Injection and Containment Spray Grade Map - SI-3A/3B/3C RM 22, 23, 12, 13 June 6, 2008 LRA-CS-7 Safety Injection and Containment Spray Grade Map - AC-4A RM 13, 14, 15A June 6, 2008 LRA-CS-8 Safety Injection and Containment Spray Grade Map - AC-4A RM 14, 15, 56 June 6, 2008 LRA-CS-9 Safety Injection and Containment Spray Grade Map - AV-4B RM 15, 15A June 6, 2008 LRA-CSUC-1 Safety Injection and Containment Spray Grade Map - Cooled Suction Overview June 6, 2008 LRA-CSUC-2 Safety Injection and Containment Spray Grade Map - Cooled Suction to HPSI SI-2A/2C RM 13, 14, 15A June 6, 2008 LRA-CSUC-3 Safety Injection and Containment Spray Grade Map - Cooled Suction to HPSI SI-2A/2C RM 13, 22, 23 June 6, 2008 LRA-CSUC-4 Safety Injection and Containment Spray Grade Map - Cooled Suction to HPSI SI-2A/2C RM 21, 22 June 6, 2008 LRA-CSUC-5 Safety Injection and Containment Spray Grade Map - Cooled Suction HPSI 2B RM 13, 14, 15 June 6, 2008 LRA-CSUC-6 Safety Injection and Containment Spray Grade Map - Cooled Suction HPSI 2B RM 13, 22, 23 June 6, 2008 LRA-CUSC-7 Safety Injection and Containment Spray Grade Map - Cooled Suction HPSI 2B RM 22 June 6, 2008 LRA-HP-1 Safety Injection and Containment Spray Grade Map - HPSI Overview June 6, 2008 LRA-HP-10 Safety Injection and Containment Spray Grade Map - HPSI 2B RM 22 June 6, 2008 LRA-HP-11 Safety Injection and Containment Spray Grade Map - HPSI 2B RM 21, 22, 23 June 6, 2008 LRA-HP-12 Safety Injection and Containment Spray Grade Map - June 6, 2008

A-11 DRAWINGS NUMBER TITLE REVISION / DATE HPSI 2B RM 23, 13, Containment LRA-HP-13 Safety Injection and Containment Spray Grade Map - HPSI 2B Containment June 6, 2008 LRA-HP-14 Safety Injection and Containment Spray Grade Map - HPSI 2B Containment June 6, 2008 LRA-HP-15 Safety Injection and Containment Spray Grade Map - HPSI 2B Containment June 6, 2008 LRA-HP-2 Safety Injection and Containment Spray Grade Map - HPSI 2A RM 21 June 6, 2008 LRA-HP-3 Safety Injection and Containment Spray Grade Map - HPSI 2C RM 21 June 6, 2008 LRA-HP-4 Safety Injection and Containment Spray Grade Map - HPSI 2A/2C RM 23 June 6, 2008 LRA-HP-5 Safety Injection and Containment Spray Grade Map - HPSI 2A/2C 23, 13 June 6, 2008 LRA-HP-6 Safety Injection and Containment Spray Grade Map - HPSI 2A/2C Containment June 6, 2008 LRA-HP-7 Safety Injection and Containment Spray Grade Map - HPSI 2A/2C Containment June 6, 2008 LRA-HP-8 Safety Injection and Containment Spray Grade Map - HPSI 2A/2C Containment June 6, 2008 LRA-HP-8 Safety Injection and Containment Spray Grade Map - HPSI 2A/2C Containment June 6, 2008 LRA-HP-9 Safety Injection and Containment Spray Grade Map - HPSI 2A/2C Containment June 6, 2008 LRA-LP-1 Safety Injection and Containment Spray Grade Map - LPSI Overview June 6, 2008 LRA-LP-2 Safety Injection and Containment Spray Grade Map - LPSI-1A RM 21-22 June 6, 2008 LRA-LP-3 Safety Injection and Containment Spray Grade Map - LPSI 1A/1B RM 22 June 6, 2008 LRA-LP-4 Safety Injection and Containment Spray Grade Map - LPSI-1A/1B RM 22, 23, 13 June 6, 2008 LRA-LP-5 Safety Injection and Containment Spray Grade Map - June 6, 2008

A-12 DRAWINGS NUMBER TITLE REVISION / DATE LPSI-1A/1B RM 13, Containment LRA-LP-6 Safety Injection and Containment Spray Grade Map - LPSI-1A/1B Containment June 6, 2008 LRA-LP-7 Safety Injection and Containment Spray Grade Map - LPSI 1A/1B Containment June 6, 2008 LRA-LP-8 Safety Injection and Containment Spray Grade Map - LPSI 1A/1B Containment June 6, 2008 LRA-SD-1 Safety Injection and Containment Spray Grade Map - Shutdown Cooling Overview June 6, 2008 LRA-SD-10 Safety Injection and Containment Spray Grade Map - Shutdown Cooling Heat Exchanger AC-4A RM 14, 15A June 6, 2008 LRA-SD-11 Safety Injection and Containment Spray Grade Map - Shutdown Cooling From Heat Exchangers RM 13, 14, 15, 15A June 6, 2008 LRA-SD-2 Safety Injection and Containment Spray Grade Map - Shutdown Cooling Hot Leg Return Containment, RM 13 June 6, 2008 LRA-SD-3 Safety Injection and Containment Spray Grade Map - Shutdown Cooling Hot Leg Return RM 13, 22, 23 June 6, 2008 LRA-SD-4 Safety Injection and Containment Spray Grade Map - Shutdown Cooling Hot Leg Return To SI-1A RM 21, 22 June 6, 2008 LRA-SD-5 Safety Injection and Containment Spray Grade Map - Shutdown Cooling Discharge from SI-1A RM 21, 22 June 6, 2008 LRA-SD-6 Safety Injection and Containment Spray Grade Map - Shutdown Cooling Hot Leg Return To SI-1B RM 22 June 6, 2008 LRA-SD-7 Safety Injection and Containment Spray Grade Map - Shutdown Cooling TO Heat Exchanger RM 12, 22, 23 June 6, 2008 LRA-SD-8 Safety Injection and Containment Spray Grade Map - Shutdown Cooling TO Heat Exchanger RM 12, 13, 14, 15 June 6, 2008 LRA-SD-9 Safety Injection and Containment Spray Grade Map - Shutdown Cooling Heat Exchanger AC-4B RM 15, 15A June 6, 2008

A-13 DRAWINGS NUMBER TITLE REVISION / DATE SI-2037 Sht. 2 Safety Injection - Containment Building 7 SI-2037-Sht. 1 Safety Injection - Containment Building 10 SI-2038-Sht. 1 Safety Injection - Containment Building 11 SI-2039-Sht. 1 Safety Injection - Containment Building 10 SI-2040-Sht. 1 Safety Injection - Containment Building 9 SI-2041-Sht. 1 Safety Injection - Containment Building 12 SI-2042-Sht. 1 Safety Injection - Containment Building 10 SI-2043-Sht. 1 Safety Injection - Containment Building 10 SI-2044-Sht. 1 Safety Injection - Containment Building 11 MODIFICATIONS NUMBER TITLE REVISION EC 27405 Installed LPSI Void Detectors EC 43078 Installed 8 Vent Valves in 2008 EC 45266 Install Vent Valves upstream and downstream of Check Valves SI-159 and SI-160 for filling, venting and temporary bypassing of check valve due to gas voiding 125 EC 45266 OI-CO-5 OI-CO-5/ Containment Integrity 29 EC 45266 OI-CS-11 OI*CS-1 I Containment Spray - Normal Operation 38 EC 45266 OI-SFP-4 OI-SFP-4 / Alternate Spent Fuel Pool Cooling 5 EC 45266 OI-SI-1 OI-SI-1 / Safety Injection - Normal Operation 128 EC 45266 QC-ST-ECCCS-001 QC-ST-ECCS-0001, Quarterly ECCS Gas Accumulation Detection 9 EC 45266 SE-EQT-SI-008 SE-EQT-SI-0008, Test Preparation for HCV-383-3 and HCV-383-4 per Generic Letter 89-10 3 EC 45266 SE-ST-SI-3005 SE-ST-SI-3005, Measurement of Post RAS Leakage Tests to the Safety Injection Refueling Water Tank (SIRWT) 22 EC 45266 SE-St-SI-3027 SE-ST-SI-3027, RHR Headers "A" and "B" Refueling Hydrostatic and Leakage Test 16 EC 45428 Installed 17 Vent Valves in 2011 EC 47407 Installed 11 Vent Valves in 2009

A-14 MODIFICATIONS NUMBER TITLE REVISION EC 48955 Installed 2 Vent Valves in 2011 EC: 48955 PED~EI-35.1 Install High Point Vent Valves on the Cooled HPSI Suction Lines Downstream of HCV-349 & HCV-350 9 PROCEDURES NUMBER TITLE REVISION / DATE ARP-ERFCS Pg 36 Fort Calhoun Station Annunciator Response Procedure - LPSI Void Alarm, Alarm Points Y351, Y352, Y353, Y354 CH-AD-0060 Groundwater Sampling and Analysis Process 2 CH-SMP-RV-0014 Well Water Sampling 1 NOD-QP-42.1 Recovery Action Closure Verification Checklist 3 OI-CS-1 Operating Instruction Containment Spray - Normal Operation - EC 53486 September 22, 2011 OI-SC-1 Operating Instruction Shutdown Cooling Initiation - EC 53650, 53651, 53659 September 27. 2011 OI-SI-1 Operating Procedure - Safety Injection - Normal Operation - EC 38191 May 27, 2011 OP-1 Operating Procedure - Master Checklist For Plant Startup September 13, 2011 OP-2A Operating Procedure - Plant Startup February 2, 2012 PBD-32 Managing Gas Accumulation in Safety Systems 3 QC-ST-ECCS-0001 Surveillance Test - Quarterly ECCS Gas Accumulation Detection February 18, 2011 QC-ST-ECCS-0002 Refueling ECCS Gas Accumulation Detection 3 SDBD-SI-130 Shutdown Cooling 22 SDBD-SI-CS-131 Containment Spray 31 SDBD-SI-HP-132 High Pressure Safety Injection 27 SDBD-SI-LP-133 Low Pressure Safety Injection System 30 SO-G-118 Site Groundwater Protection Program 3 MISCELLANEOUS DOCUMENTS

A-15 NUMBER TITLE REVISION / DATE Monitoring Well Sampling & Analysis Reports March 21, 2011 Monitoring Well Sampling & Analysis Reports March 21, 2011 Monitoring Well Sampling & Analysis Reports September 15, 2011 Monitoring Well Sampling & Analysis Reports September 16, 2011 Monitoring Well Sampling & Analysis Reports December 16, 2011 White Paper Acceptance Criteria for Void Identification EC 43078 HPSI High Point Vent Valves in Containment 2 EC 45266 Install Vent Valves Upstream and Downstream of Check Valves SI-159 and SI-160 for Filling, Venting and Temporary Bypassing of Check Valve Due to Gas Voiding 0 EC 45428 Installation of ECCS High Point Vent Valves 0 EC 47407 Additional ECCS Vent Valves 0 EC 48955 Install High Point Vent Valves on the Cooled HPSI Suction Lines Downstream of HCV-349 & HCV-350 0 Letter from Todd L. Whitfield to Douglas Molzer Summary of work performed for the creation of isometric drawings on the emergency coolant system piping at the Fort Calhoun Station Nuclear power plant. August 7, 2008 LIC-08-0106 Omaha Public Power District, Fort Calhoun Station (FCS), Response to NRC Generic Letter 2008-01 October 14, 2008 LIC-08-0106 Omaha Public Power District, Fort Calhoun Station (FCS), Response to NRC Generic Letter 2008-01 October 14, 2008 LIC-10-0062 Response to NRC Request for Status of Corrective Actions Contained in the Omaha

Public Power District (OPPD) Response to Generic Letter 2008-01 August 10, 2010 LIC-10-0062 Response to NRC Request for Status of Corrective Actions Contained in the Omaha Public Power District (OPPD) Response to Generic Letter 2008-01 3

A-16 MISCELLANEOUS DOCUMENTS NUMBER TITLE REVISION / DATE NRC 10-0062 Summary of Conference Call held on July 16, 2010 between the U.S. Nuclear Regulatory Commission and Omaha Public Power District Concerning Generic Letter 2008-01 (TAC. NO. MD7829) August 6, 2010 QCP 334 Ultrasonic Examination for Liquid Level Measurement August 10, 2010 RA 2009-0518 Self-Assessment Report and Corrective Actions December 15, 2011 TDB III-42 Technical Data Book - Requirements For ECCS and Containment Cooling Equipment Operation in Mode 3, Transition Between Modes 3 and 4 and Mode 4 and 5 December 23, 2008 TDB VIII Technical Data Book - Equipment Operability Guidance December 29, 2011 Training - Power Point Presentation Generic Letter 2008-01, "Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal, And Containment Spray Systems" USAR 6.2 Engineered Safeguards - Safety Injection System 35 USAR 6.3 Engineered Safeguards - Containment Spray System 17 USAR 6.3 Engineered Safeguards Containment Spray System 17 USAR Appendix G Responses to 70 Criteria 18 Void Trending Excel Spread Sheets with Void Trending Information April 9, 2011