ML12132A395
| ML12132A395 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/11/2012 |
| From: | Clark J NRC/RGN-IV/DRP |
| To: | Bannister D Omaha Public Power District |
| References | |
| EA-12-095 IR-12-002 | |
| Download: ML12132A395 (48) | |
See also: IR 05000285/2012002
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I V
1600 EAST LAMAR BLVD
ARLINGTON, TEXAS 76011-4511
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
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 Commissions 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
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
[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
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
-1- 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.
-2- 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 licensees 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 licensees 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
-3- 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 licensees 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 licensees corrective action program. This violation and
associated corrective action tracking numbers are listed in Section 4OA7 of this report.
-4- 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.
-5- 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
-6- 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
-7- 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,
-8- 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 licensees
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.
-9- Enclosure
Analysis. The inspectors determined that the licensees 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 Semiannual Complete System Walkdown
a. 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
licensees 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
- 10 - 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 System Walkdown Associated With Temporary Instruction (TI) 2515/177, Managing Gas
Accumulation In Emergency Core Cooling, Decay Heat Removal, And Containment
Spray Systems.
a. Inspection Scope
The inspectors conducted a walkdown of the high-pressure safety injection system in
sufficient detail to reasonably assure the acceptability of the licensees walkdowns
(TI 2515/177, Section 04.02.d). The inspectors also verified that the information
obtained during the licensees walkdown was consistent with the items identified during
the inspectors independent walkdown (TI 2515/177, Section 04.02.c.3).
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.
- 11 - 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. Findings
No findings of significance were identified.
1R05 Fire Protection (71111.05)
.1 Quarterly Fire Inspection Tours
a. Inspection Scope
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:
- 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 licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk
as documented in the plants 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 plants 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
- 12 - 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 licensees 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. Findings
No findings of significance were identified.
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.
- 13 - Enclosure
b. Findings
No findings of significance were identified.
.2 Quarterly Review of Licensed Operator Requalification Program
a. Inspection Scope
On March 26, 2012, the inspectors observed a crew of licensed operators in the plants
simulator during requalification training. The inspectors assessed the following areas:
- 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. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP1 Exercise Evaluation (71114.01)
a. Inspection Scope
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 licenses 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.
The inspectors observed the emergency plan exercise conducted March 27, 2012, to
determine if the exercise tested major elements of the licensees 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 personnels capability to implement their emergency
plan. The scenario simulated the following:
- 14 - 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
licensees 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. Findings
No findings of significance were identified.
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
a. Inspection Scope
- 15 - 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. Inspection Scope
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.
These activities constitute completion of one sample as defined in Inspection
Procedure 71114.05-05.
b. Findings
Introduction. A Green non-cited violation was identified for the licensees failure to
follow the site emergency plan on February 23, 2012, as required by 10 CFR
50.54(q)(2).
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.
- 16 - 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 licensees 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
licensees 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
- 17 - 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 licensees 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 licensees 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. Inspection Scope
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 crews
- 18 - 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. Findings
No findings of significance were identified.
4. OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
4OA1 Performance Indicator Verification (71151)
.1 Drill/Exercise Performance (EP01)
a. Inspection Scope
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 licensees 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.
These activities constitute completion of the drill/exercise performance sample as
defined in Inspection Procedure 71151-05.
b. Findings
(1) Failure to follow the licensee emergency plan during the June 7, 2011, Alert
declaration
Introduction. A Green non-cited violation was identified for the licensees 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
- 19 - 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 licensees 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 licensees failure did not affect the ability of
offsite authorities to implement appropriate protective measures for the public.
This failure has been entered into the licensees 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
- 20 - 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 licensees 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. Inspection Scope
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 licensees
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 licensees corrective action program
because of the inspectors observations are included in the attached list of documents
reviewed.
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
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No findings of significance were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
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 licensees corrective action program. The inspectors
accomplished this through review of the stations daily corrective action documents.
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. Findings
No findings of significance were identified.
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
- 22 - 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.
- 23 - 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
- 24 - 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 stations leadership
oversight effort has not been effective in the areas of use of the stations 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 stations 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
- 25 - 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
a. Inspection Scope
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.
b. Inspection Documentation
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.
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.
- 26 - Enclosure
Design. 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 identified the applicable gas
intrusion mechanisms for their plant.
- 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
- 27 - 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 Actions. 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.
Based 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.
c. Findings
No findings of significance were identified.
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
licensees staff. The inspectors presented the results of the October 2011, onsite
inspection of emergency preparedness performance indicators. The licensee
- 28 - 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 licensees 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 licensees 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 licensees 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.
- 29 - Enclosure
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
Inadequate Procedures to Mitigate a Design Basis Flood
Event (Section 1R01)
Failure to Classify Intake Structure Sluice Gates as Safety
Class III (Section 1R01)
Failure to Meet Design Basis Requirements for Design Basis05000285/2012002-03 VIO
Flood Event (Section 1R01)
Opened and Closed
Failure to Promptly Recognize and Communicate Siren
System Failures (Section 1EP5)
A-1 Attachment
Failure To Comply With An Emergency Plan Requirement To
05000285/2012002-05 NCV 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)
Containment Integrity Violated During Refueling Leak Test
05000285/2010-001-01 LER
Due to Inadequate Training (Section 4OA3.1)
Reactor Trip Due to Erroneous Moisture Separator Trip
05000285/2010-006-01 LER
Signal(Section 4OA3.2)
Report: Inadequate Flooding Protection Due To Ineffective
05000285/2011-001-00 LER
Oversight (Section 4OA3.3)
Failure to Correctly Enter Technical Specifications Limiting
05000285/2011-005-00 LER Condition for Operation for the Reactor Protective System
(Section 4OA3.4)
Inoperability of Both Trains of Containment Coolers Due to a
05000285/2011-006-00 LER
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 10
A187, Switchgear Ventilation
EPIP-TSC-2 Catastrophic Flooding Preparations 14
FCSG-20 Abnormal Operating Procedure and Emergency Operating 9
Procedure Writers Guide
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-2
PROCEDURES
NUMBER TITLE REVISION
OI-FO-1 Fuel Receipt (FO-1, FO-10, FO-27, FO-32, FO-43A, and 31
FO-43B)
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 April 21, 2011
During Flooding Conditions at the Ft. Calhoun Plant
CN-SEE-II-11-2 Intake Cell Level Control - Flood Alternate Flow Path April 5, 2011
Evaluation for Fort Calhoun Station
FC08030 Intake Structure Cell Level Control Using the Intake April 25, 2011
Structure Sluice Gates
FC08070 Validation of Backup Fuel Oil Transfer During Flooding
Conditions
CONDITION REPORTS
2011-6062 2011-5489 2011-10512 2011-10302 2011-10300
A-3
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 25
Requirements
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-4
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-5
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 2
Levels/Radiological Effluent
TBD-EPIP-OSC-1C Recognition Category C- Cold Shutdown/Refueling 2
System Malfunction
TBD-EPIP-OSC-1F Recognition Category F - Fission Product Barrier 1
Degradation
TBD-EPIP-OSC-1H Recognition Category H - Hazards and Other Conditions 1
Affecting Plant Safety
TBD-EPIP-OSC-1S Recognition Category S - System Malfunction 2
CONDITION REPORTS
2011-6117 2011-8529 2011-8530 2011-8531
PROCEDURES
A-6
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 0
Delivered to the ECCS Pumps in the Fort Calhoun Design (Vendor
Calc. No.: FA1108-89)
FC07258 Fort Calhoun Transient, Investigating the Potential for Vortex 0
Formation in the SlRWT Suction Flow
FC07487 Response to the Fort Calhoun HPSl Piping High Points to Gas-Water 0
Waterhammer
FC07500 Evaluation of Allowable Suction Piping Gas Void Volumes for Fort 2
Calhoun to Address GL 2008-01 (Vendor Calc. No.: CN-SEE-III-08-40)
FC07501 Evaluation of the Potential for Waterhammer in the Containment Spray 0
System for Fort Calhoun
FC07502 Evaluation of the Potential for Waterhammer During Cold Leg Injection 0
for Fort Calhoun
FC07503 Allowable Gas Void Accumulation for the Fort Calhoun High Pressure 1
Safety Injection Discharge Piping
FC07504 Gas-Water Waterhammer Evaluations for the Fort Calhoun 1
Containment Spray Piping
FC07505 Evaluation of the Potential for Gas-Water, Waterhammer in Fort 0
Calhoun During Hot Leg Injection
FC07532 Subsystem Si-164C (4 Inch HPSI Header) Stress Analysis For Void- 0
Induced Water-Hammer Event
FC07532 Subsystem SI-164C (4 Inch HPSI Header) Stress Analysis For Void- 0
Induced Water-Hammer Event
FC07548 Evaluation of the Gas Intrusion to the HPSI 2B Vendor Calc. No.: 0
FAI/09-177 Pump Suction.
FC07804 HPSI Pump Cooled Suction Piping Gas Intrusion, Gas Voiding 0
A-7
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 Safety Injection and Containment Spray System Flow 111
Sht. 1 Diagram
E-23866-210-130 Safety Injection and Containment Spray System Flow 24
Sht. 2A Diagram
E-23866-210-130 Safety Injection and Containment Spray System Flow 29
Sht. 3A Diagram
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-8
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 - June 6, 2008
Suction Header Overview
LRA-A-2 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-A-3 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-A-4 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-B-1 Safety Injection and Containment Spray Grade Map - June 6, 2008
Suction Header Overview
LRA-B-2 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-B-3 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-CGM-CS SI- Safety Injection and Containment Spray Grade Map - June 6, 2008
3A Composite Grade Map CS SI-3A
LRA-CGM-CS SI- Safety Injection and Containment Spray Grade Map - June 6, 2008
3B/3C Composite Grade Map CS SI-3B/3C
LRA-CGM-HPSI Safety Injection and Containment Spray Grade Map - June 6, 2008
SI-2A/2C Composite Grade Map HPSI SI-2A/2C
LRA-CGM-HPSI Safety Injection and Containment Spray Grade Map - June 6, 2008
SI-2B Composite Grade Map HPSI SI-2B
LRA-CGM-LPSI Safety Injection and Containment Spray Grade Map - June 6, 2008
SI-1A Composite Grade Map LPSI SI-1A
LRA-CGM-LPSI SI- Safety Injection and Containment Spray Grade Map - June 6, 2008
1B Composite Grade Map LPSI SI-1B
LRA-CS-1 Safety Injection and Containment Spray Grade Map - June 6, 2008
Overview
LRA-CS-10 Safety Injection and Containment Spray Grade Map - June 6, 2008
AC-4B RM 14, 15A, 56
LRA-CS-2 Safety Injection and Containment Spray Grade Map - June 6, 2008
SI-3A RM21
LRA-CS-3 Safety Injection and Containment Spray Grade Map - June 6, 2008
A-9
DRAWINGS
NUMBER TITLE REVISION / DATE
SO-3A RM 21, 22
LRA-CS-4 Safety Injection and Containment Spray Grade Map - June 6, 2008
SI-3B RM 22
LRA-CS-5 Safety Injection and Containment Spray Grade Map - June 6, 2008
SI-3C RM 22
LRA-CS-6 Safety Injection and Containment Spray Grade Map - June 6, 2008
SI-3A/3B/3C RM 22, 23, 12, 13
LRA-CS-7 Safety Injection and Containment Spray Grade Map - June 6, 2008
AC-4A RM 13, 14, 15A
LRA-CS-8 Safety Injection and Containment Spray Grade Map - June 6, 2008
AC-4A RM 14, 15, 56
LRA-CS-9 Safety Injection and Containment Spray Grade Map - June 6, 2008
AV-4B RM 15, 15A
LRA-CSUC-1 Safety Injection and Containment Spray Grade Map - June 6, 2008
Cooled Suction Overview
LRA-CSUC-2 Safety Injection and Containment Spray Grade Map - June 6, 2008
Cooled Suction to HPSI SI-2A/2C RM 13, 14, 15A
LRA-CSUC-3 Safety Injection and Containment Spray Grade Map - June 6, 2008
Cooled Suction to HPSI SI-2A/2C RM 13, 22, 23
LRA-CSUC-4 Safety Injection and Containment Spray Grade Map - June 6, 2008
Cooled Suction to HPSI SI-2A/2C RM 21, 22
LRA-CSUC-5 Safety Injection and Containment Spray Grade Map - June 6, 2008
Cooled Suction HPSI 2B RM 13, 14, 15
LRA-CSUC-6 Safety Injection and Containment Spray Grade Map - June 6, 2008
Cooled Suction HPSI 2B RM 13, 22, 23
LRA-CUSC-7 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-HP-1 Safety Injection and Containment Spray Grade Map - June 6, 2008
HPSI Overview
LRA-HP-10 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-HP-11 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-HP-12 Safety Injection and Containment Spray Grade Map - June 6, 2008
A-10
DRAWINGS
NUMBER TITLE REVISION / DATE
HPSI 2B RM 23, 13, Containment
LRA-HP-13 Safety Injection and Containment Spray Grade Map - June 6, 2008
HPSI 2B Containment
LRA-HP-14 Safety Injection and Containment Spray Grade Map - June 6, 2008
HPSI 2B Containment
LRA-HP-15 Safety Injection and Containment Spray Grade Map - June 6, 2008
HPSI 2B Containment
LRA-HP-2 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-HP-3 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-HP-4 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-HP-5 Safety Injection and Containment Spray Grade Map - June 6, 2008
HPSI 2A/2C 23, 13
LRA-HP-6 Safety Injection and Containment Spray Grade Map - June 6, 2008
HPSI 2A/2C Containment
LRA-HP-7 Safety Injection and Containment Spray Grade Map - June 6, 2008
HPSI 2A/2C Containment
LRA-HP-8 Safety Injection and Containment Spray Grade Map - June 6, 2008
HPSI 2A/2C Containment
LRA-HP-8 Safety Injection and Containment Spray Grade Map - June 6, 2008
HPSI 2A/2C Containment
LRA-HP-9 Safety Injection and Containment Spray Grade Map - June 6, 2008
HPSI 2A/2C Containment
LRA-LP-1 Safety Injection and Containment Spray Grade Map - June 6, 2008
LPSI Overview
LRA-LP-2 Safety Injection and Containment Spray Grade Map - June 6, 2008
LPSI-1A RM 21-22
LRA-LP-3 Safety Injection and Containment Spray Grade Map - June 6, 2008
LRA-LP-4 Safety Injection and Containment Spray Grade Map - June 6, 2008
LPSI-1A/1B RM 22, 23, 13
LRA-LP-5 Safety Injection and Containment Spray Grade Map - June 6, 2008
A-11
DRAWINGS
NUMBER TITLE REVISION / DATE
LPSI-1A/1B RM 13, Containment
LRA-LP-6 Safety Injection and Containment Spray Grade Map - June 6, 2008
LPSI-1A/1B Containment
LRA-LP-7 Safety Injection and Containment Spray Grade Map - June 6, 2008
LPSI 1A/1B Containment
LRA-LP-8 Safety Injection and Containment Spray Grade Map - June 6, 2008
LPSI 1A/1B Containment
LRA-SD-1 Safety Injection and Containment Spray Grade Map - June 6, 2008
Shutdown Cooling Overview
LRA-SD-10 Safety Injection and Containment Spray Grade Map - June 6, 2008
Shutdown Cooling Heat Exchanger AC-4A RM 14,
15A
LRA-SD-11 Safety Injection and Containment Spray Grade Map - June 6, 2008
Shutdown Cooling From Heat Exchangers RM 13,
14, 15, 15A
LRA-SD-2 Safety Injection and Containment Spray Grade Map - June 6, 2008
Shutdown Cooling Hot Leg Return Containment, RM
13
LRA-SD-3 Safety Injection and Containment Spray Grade Map - June 6, 2008
Shutdown Cooling Hot Leg Return RM 13, 22, 23
LRA-SD-4 Safety Injection and Containment Spray Grade Map - June 6, 2008
Shutdown Cooling Hot Leg Return To SI-1A RM 21,
22
LRA-SD-5 Safety Injection and Containment Spray Grade Map - June 6, 2008
Shutdown Cooling Discharge from SI-1A RM 21, 22
LRA-SD-6 Safety Injection and Containment Spray Grade Map - June 6, 2008
Shutdown Cooling Hot Leg Return To SI-1B RM 22
LRA-SD-7 Safety Injection and Containment Spray Grade Map - June 6, 2008
Shutdown Cooling TO Heat Exchanger RM 12, 22, 23
LRA-SD-8 Safety Injection and Containment Spray Grade Map - June 6, 2008
Shutdown Cooling TO Heat Exchanger RM 12, 13,
14, 15
LRA-SD-9 Safety Injection and Containment Spray Grade Map - June 6, 2008
Shutdown Cooling Heat Exchanger AC-4B RM 15,
15A
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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 125
Valves SI-159 and SI-160 for filling, venting and temporary
bypassing of check valve due to gas voiding
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- QC-ST-ECCS-0001, Quarterly ECCS Gas Accumulation 9
ECCCS-001 Detection
EC 45266 SE-EQT- SE-EQT-SI-0008, Test Preparation for HCV-383-3 and 3
SI-008 HCV-383-4 per Generic Letter 89-10
EC 45266 SE-ST-SI- SE-ST-SI-3005, Measurement of Post RAS Leakage Tests 22
3005 to the Safety Injection Refueling Water Tank (SIRWT)
EC 45266 SE-St-SI- SE-ST-SI-3027, RHR Headers "A" and "B" Refueling 16
3027 Hydrostatic and Leakage Test
EC 45428 Installed 17 Vent Valves in 2011
EC 47407 Installed 11 Vent Valves in 2009
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MODIFICATIONS
NUMBER TITLE REVISION
EC 48955 Installed 2 Vent Valves in 2011
EC: 48955 PED~EI- Install High Point Vent Valves on the Cooled HPSI Suction 9
35.1 Lines Downstream of HCV-349 & HCV-350
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 September 22, 2011
Operation - EC 53486
OI-SC-1 Operating Instruction Shutdown Cooling Initiation September 27. 2011
- EC 53650, 53651, 53659
OI-SI-1 Operating Procedure - Safety Injection - Normal May 27, 2011
Operation - EC 38191
OP-1 Operating Procedure - Master Checklist For Plant September 13, 2011
Startup
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 February 18, 2011
Accumulation Detection
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
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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 0
Check Valves SI-159 and SI-160 for Filling,
Venting and Temporary Bypassing of Check
Valve Due to Gas Voiding
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 0
Suction Lines Downstream of HCV-349 & HCV-
350
Letter from Todd L. Summary of work performed for the creation of August 7, 2008
Whitfield to Douglas isometric drawings on the emergency coolant
Molzer system piping at the Fort Calhoun Station Nuclear
power plant.
LIC-08-0106 Omaha Public Power District, Fort Calhoun October 14, 2008
Station (FCS), Response to NRC Generic Letter 2008-01
LIC-08-0106 Omaha Public Power District, Fort Calhoun October 14, 2008
Station (FCS), Response to NRC Generic Letter 2008-01
LIC-10-0062 Response to NRC Request for Status of August 10, 2010
Corrective Actions Contained in the Omaha
Public Power District (OPPD) Response to
LIC-10-0062 Response to NRC Request for Status of 3
Corrective Actions Contained in the Omaha
Public Power District (OPPD) Response to
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MISCELLANEOUS DOCUMENTS
NUMBER TITLE REVISION / DATE
NRC 10-0062 Summary of Conference Call held on July 16, August 6, 2010
2010 between the U.S. Nuclear Regulatory
Commission and Omaha Public Power District
Concerning Generic Letter 2008-01 (TAC. NO.
MD7829)
QCP 334 Ultrasonic Examination for Liquid Level August 10, 2010
Measurement
RA 2009-0518 Self-Assessment Report and Corrective Actions December 15, 2011
TDB III-42 Technical Data Book - Requirements For ECCS December 23, 2008
and Containment Cooling Equipment Operation in
Mode 3, Transition Between Modes 3 and 4 and
Mode 4 and 5
TDB VIII Technical Data Book - Equipment Operability December 29, 2011
Guidance
Training - Power Generic Letter 2008-01, Managing Gas
Point Presentation 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 17
System
USAR 6.3 Engineered Safeguards 17
Containment Spray System
USAR Appendix G Responses to 70 Criteria 18
Void Trending Excel Spread Sheets with Void Trending April 9, 2011
Information
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