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05000285/FIN-2015010-0131 March 2015 23:59:59Fort CalhounNRC identifiedFailure to Provide Complete and Accurate Information on Licensed Operator ApplicationsTitle 10 of the Code of Federal Regulations (10 CFR) 50.9 requires, in part, that information provided to the Commission by an applicant for a license or by a licensee or information required by statue or by the Commissions regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects. Title 10 of the Code of Federal Regulations 55.21 requires, in part, that an applicant for a license shall have a medical examination by a physician and the licensee shall have a medical examination by a physician every two years. The physician shall determine that the applicant or licensee meets requirements of Section 55.33(a)(1). Title 10 of the Code of Federal Regulations 55.33(a)(1) requires, in part, that applicants' medical condition and general health will not adversely affect the performance of assigned operator job duties or cause operational errors endangering public health and safety. Title 10 of the Code of Federal Regulations 55.23 requires, in part, that to certify the medical fitness of the applicant, an authorized representative of the facility licensee shall complete and sign NRC Form 396, Certification of Medical Examination by Facility Licensee. Nuclear Regulatory Commission Form 396, when signed by an authorized representative of the facility licensee, certifies that a physician conducted a medical examination of the applicant and that the guidance contained in American National Standards Institute/American Nuclear Society (ANSI/ANS) Standard 3.4-1996, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants, was followed in conducting the examination and making the determination of medical qualification. American National Institute/American Nuclear Society Standard 3.4-1996, Section 5.3, provides specific minimum capacities required for medical qualifications. Section 5.3.1 requires, in part, ability to detect marker gases and products of combustion by provocation testing. Contrary to the above, prior to April 3, 2014, the facility licensee provided information to the NRC that was not complete and accurate in all material respects. Specifically, the facility licensee had not completed medical examinations of licensed operators in accordance with ANSI/ANS Standard 3.4-1996. The licensee submitted numerous NRC Forms 396 for renewal of senior reactor operator and reactor operator licenses, and for initial license applicants, that certified that the applicants met the medical requirements of ANSI/ANS Standard 3.4-1996 when, in fact, olfactory (combustion product odor) testing had not been conducted. This violation is a Severity Level IV violation.
05000285/FIN-2015008-0431 March 2015 23:59:59Fort CalhounNRC identifiedFailure to Make Required Licensee Event ReportThe team identified a Severity Level IV non-cited violation of 10 CFR 50.73(a)(2)(v)(B) for the failure to make a licensee event report to the NRC. Specifically, the licensee failed to include the loss of the auxiliary feedwater system as a safety system functional failure when reporting a condition prohibited by technical specifications on May 2, 2014. The licensee subsequently made a revision to and submitted a revised licensee event report to the NRC on January 29, 2015. The licensee entered the issue in its corrective action program as Condition Report CR 2015-010903. The failure to submit a required report within the time requirements specified in Part 50.73(a)(2)(v)(B) is a performance deficiency. The NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. Using Inspection Manual Chapter 0612, the team determined that this performance deficiency was not appropriate to evaluate using the NRCs Significance Determination Process due to the finding only affecting the NRCs ability to perform its regulatory oversight function. As a result, this performance deficiency was evaluated for traditional enforcement in accordance with the NRC Enforcement Policy. This performance deficiency was determined to be a Severity Level IV violation in accordance with Sections 6.9.d.9 and 6.9.d.10 of the NRC Enforcement Policy, dated July 9, 2013. The team determined that assigning a crosscutting aspect was not applicable to this performance deficiency due to the performance.
05000285/FIN-2014009-2430 September 2014 23:59:59Fort CalhounLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 50.73(a)(1) requires, in part, that licensees shall submit a licensee event report for any event of the type described in this paragraph within 60 days after the discovery of the event. Contrary to the above, on February 5, 2012, November 15, 2011, and February 19, 2013, the licensee failed to submit a licensee event report for an event meeting the requirements for reporting specified in 10 CFR 50.73. Specifically, the licensee submitted Licensee Event Reports 2012-013, 2012-015 and 2013-001 greater than 60 days following discovery of a reportable event. In accordance with Section 6.9 of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV, non-cited violation. The licensee entered this issue into their corrective action program as CR 2014-02792.
05000285/FIN-2014009-1330 September 2014 23:59:59Fort CalhounNRC identifiedFailure to Perform Evaluation for Design ChangeA cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, was identified involving the failure to evaluate if a change to the facility as described in the Updated Safety Analysis Report would require prior NRC review and approval. Specifically, the licensee did not evaluate a change that would permanently substitute a manual action for an automatic action to add water and nitrogen gas to the component cooling water surge tank. The licensee entered this issue into its corrective action program as Condition Report 2014-09080 and initiated action to evaluate the change to the component cooling water system. The NRC determined that the licensees failure to perform an evaluation prior to implementing a proposed change described in the Updated Safety Analysis Report was a violation of 10 CFR 50.59. Because this performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, the NRC evaluated the performance deficiency using traditional enforcement. In accordance with Section 2.1.3.E.6 of the NRC Enforcement Manual, the team evaluated this finding using the significance determination process to assess its significance. The NRC performed an initial screening of the finding in accordance with NRC Manual Chapter IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated July 1, 2012, the finding was of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program. Therefore, in accordance with Section 6.1.d.2 of the NRC Enforcement Policy this performance deficiency is being characterized as a Severity Level IV violation. The team determined that a cross-cutting aspect was not applicable to this finding because the issue was strictly associated with a traditional enforcement violation.
05000285/FIN-2014009-0830 September 2014 23:59:59Fort CalhounNRC identifiedFailure to Report Loss of Environmental Qualification of Safety Related Limit Switches within Required Time LimitsA non-cited violation of 10 CFR 50.73(a)(1), Licensee Event Report System, was identified involving the failure to submit a required licensee event report. Specifically, the licensee failed to report within 60 days the discovery that NamcoTM Type EA 180 limit switches were not environmentally qualified as required due to inadequate maintenance procedures, a condition that resulted in operation prohibited by the plants technical specifications. The licensee restored compliance by submitting Licensee Event Report 05000285/2014-004 on June 20, 2014. The licensee entered this issue into its corrective action program as Condition Report 2014-08454. The NRC determined that the failure to submit a licensee event report within the time limits specified in regulations was a violation of 10 CFR 50.73. This violation was evaluated using Section 2.2.4 of the NRC Enforcement Policy, because the failure to submit a required licensee event report may impact the ability of the NRC to perform its regulatory oversight function. As a result, this violation was evaluated using traditional enforcement. In accordance with Section 6.9 of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV, non-cited violation. The NRC determined that a cross-cutting aspect was not applicable because the issue was strictly associated with a traditional enforcement violation.
05000285/FIN-2014009-0430 September 2014 23:59:59Fort CalhounNRC identifiedFailure to Perform an Evaluation for a New Operator Manual Action to Refill Component Cooling Water System During Post- Accident ConditionsA non-cited violation of 10 CFR 50.59, Changes, Test, and Experiments, was identified involving the failure to evaluate if a change to the facility as described in the Updated Safety Analysis Report would require prior NRC review and approval. Specifically, the licensee failed to evaluate if a change implemented under Engineering Change 59252 that credited the non-safety related demineralized water system as a make-up source to the component cooling water system during post-accident conditions represented an adverse change to the Updated Safety Analysis Report described design function. The licensee entered this deficiency into its corrective action program for resolution as Condition Report 2014-09151 and established action items to update Engineering Change 59252. The NRC determined that the licensees failure to perform an evaluation prior to implementing a proposed change described in the Updated Safety Analysis Report was a violation of 10 CFR 50.59. Because this violation had the potential to impact the NRCs ability to perform its regulatory function, the NRC evaluated the violation using traditional enforcement. In accordance with Section 2.1.3.E.6 of the NRC Enforcement Manual, the NRC evaluated this finding using the significance determination process to assess its significance. The NRC performed an initial screening of the finding in accordance with NRC Manual Chapter IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated July 1, 2012, the finding was of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program. Therefore, in accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this performance deficiency is characterized as a Severity Level IV violation. The team determined that a cross-cutting aspect was not applicable because the issue involving the failure to perform an adequate 10 CFR 50.59 evaluation was strictly associated with a traditional enforcement violation.
05000285/FIN-2014002-0531 March 2014 23:59:59Fort CalhounNRC identifiedUntimely Submittal of Required Licensee Event ReportsTwo examples of a cited Severity Level IV violation of 10 CFR 50.73, Immediate Notification Requirements for Operating Nuclear Power Reactors, were identified involving the failure to submit a required licensee event report (LER) within 60 days following discovery of an event requiring a report. In the first example, LER 2013-010-0 was submitted on July 2, 2013, seventy-nine days after the flow imbalance was observed by the licensees staff. In the second example, LER 2013-017-0 was submitted to the NRC on December 27, 2013, 62 days after the event date on the licensees reportability evaluation and sixty-six days after a condition report documented the reportable condition. The licensee initiated CR 2014-01358 on January 29, 2014 to document this repetitive violation. The violation was evaluated using Section 2.2.4 of the NRC Enforcement Policy, because the failure to submit a required LER may impact the ability of the NRC to perform its regulatory oversight function. As a result, this violation was evaluated using traditional enforcement. In accordance with Section 6.9(d)(9) of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV violation. The inspetors determined that a cross-cutting aspect was not applicable to this performance deficiency because the failure to make a required report was strictly associated with a traditional enforcement violation.
05000285/FIN-2013017-0531 March 2014 23:59:59Fort CalhounNRC identifiedFailure to Obtain Prior NRC Approval for a Change in Method of EvaluationThe team identified three examples of a non-cited violation of 10 CFR 50.59, Changes, Test, and Experiments, associated with the licensees failure to adequately evaluate changes to determine if prior NRC approval is required. Specifically, from April 19, 2011, through August 17, 2012, the licensee failed to obtain a license amendment pursuant to Section 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would result in a departure from a method of evaluation described in the Updated Safety Analysis Report. The licensee addressed these issues by submitting a license amendment which was reviewed and approved by the NRC. This issue has been entered into the licensees corrective action program as Condition Reports CR 2013-03839, 2013-04266, 2013-05210, 2013-14363, and 2013-14665. The licensees failure to implement the requirements of 10 CFR 50.59 and adequately evaluate changes to requirements for tornado missile protection described in the Updated Safety Analysis Report was a performance deficiency. Because this performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, the team evaluated the performance deficiency using traditional enforcement. In accordance with Section 2.1.3.E.6 of the NRC Enforcement Manual, the team evaluated this finding using the significance determination process to assess its significance. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather event. Therefore, in accordance with Section 6.1.d.2 of the NRC Enforcement Policy, the team characterized this performance deficiency as a Severity Level IV violation. The team determined that a cross-cutting aspect was not applicable to this performance deficiency because the failure to adequately evaluate changes in accordance with 10 CFR 50.59 was strictly associated with a traditional enforcement violation.
05000285/FIN-2013013-0431 March 2014 23:59:59Fort CalhounNRC identifiedFailure to Submit Licensee Event ReportThe team identified three examples of a Severity Level IV non-cited violation of 10 CFR 50.73, Immediate Notification Requirements for Operating Nuclear Power Reactors, associated with the licensees failure to submit a Licensee Event Report within 60 days following a discovery of an event were to submit the licensee event reports. The licensee entered this deficiency into their corrective action program for resolution as CRs 2013-12863 and 2012-03796. The team determined that the failure to make a required Licensee Event Report is a violation of 10 CFR 50.73. The violation was evaluated using Section 2.2.4 of the NRC Enforcement Policy because the failure to submit a required licensee event report may impact the ability of the NRC to perform its regulatory oversight function. As a result, this violation was evaluated using traditional enforcement. In accordance with Section 6.9 of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV non-cited violation. The team determined that a cross-cutting aspect was not applicable to this performance deficiency because the failure to make a required report was strictly associated with a traditional enforcement violation.
05000285/FIN-2014407-0131 December 2013 23:59:59Fort CalhounNRC identifiedSecurity
05000285/FIN-2013005-0530 June 2013 23:59:59Fort CalhounLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR Part 50.72, paragraph(b)(3)(ii)(B), states, in part, the licensee shall notify the NRC as soon as practical and in all cases within eight hours of the occurrence of any of the following event or condition that results in the nuclear power plant being in an unanalyzed condition that significantly degrades plant safety. Contrary to 10 CFR 50.72 (b)(3), from December 13, 2011, to July 23, 2012, the licensee failed to make a notification within eight hours of identifying a condition that resulted in the nuclear power plant being in an unanalyzed condition that significantly degraded plant safety when the licensee determined that various electrical components inside containment were not analyzed for harsh environment conditions caused by a postulated main steam line break. The licensee entered this condition into the corrective action program as CR 2012-03718. Consistent with the NRC Enforcement Policy, this violation is considered a Severity Level IV violation.
05000285/FIN-2013008-4330 June 2013 23:59:59Fort CalhounNRC identifiedRepetitive Issues Involving Untimely Submittal of Required Licensee Event ReportsThe team identified nine examples of a non-cited violation of 10 CFR 50.73, Immediate Notification Requirements for Operating Nuclear Power Reactors, for the licensees failure to make required licensee event reports within 60 days following discovery of an event requiring a report. Specifically, on nine occurrences between May 9, 2011, and August 30, 2012, the licensee failed to submit a licensee event report for an event meeting the requirements for reporting specified in 10 CFR 50.73. This issue has been entered into the corrective action program as Condition Report CR 2012-03796. The violation was evaluated using Section 2.2.4 of the NRC Enforcement Policy, because the failure to submit a required licensee event report may impact the ability of the NRC to perform its regulatory oversight function. As a result, this violation was evaluated using traditional enforcement. In accordance with Section 6.9 of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV non-cited violation. The team determined that a cross-cutting aspect was not applicable to this performance deficiency because the failure to make a required report was strictly associated with a traditional enforcement violation
05000285/FIN-2013008-4230 June 2013 23:59:59Fort CalhounNRC identifiedFailure to Make Timely Event Notifications for Unanalyzed ConditionsThe team identified four examples of a non-cited violation of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, for the licensees failure to make required event notifications within 8 hours following discovery of an event requiring a report. Specifically, on April 12, 2012, February 7, 2013, February 25, 2013, and February 27, 2013, the licensee failed to notify the NRC within 8 hours of the occurrence an event or condition that resulted in the nuclear power plant being in an unanalyzed condition that significantly degraded plant safety. This issue has been entered into the corrective action program as Condition Report CR 2013-05070. The violation was evaluated using Section 2.2.4 of the NRC Enforcement Policy, because the failure to required event report may impact the ability of the NRC to perform its regulatory oversight function. As a result, this violation was evaluated using traditional enforcement. In accordance with Section 6.9 of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV non-cited violation. The team determined that a cross-cutting aspect was not applicable to this performance deficiency because the failure to make a required report was strictly associated with a traditional enforcement violation
05000285/FIN-2012005-0130 September 2012 23:59:59Fort CalhounNRC identifiedFailure to Update the Safety Analysis Report Solid WasteThe inspectors identified a cited violation of 10 CFR 50.71(e), Maintenance of Records, Making of Reports, for the failure to update the Updated Safety Analysis Report with a detailed description of the Original Steam Generator Storage Facility. Specifically, since December 2006, the licensee stored a significant source of radioactivity in the Original Steam Generator Storage Facility, but failed to describe the volume of waste, the principal sources of radioactivity, the total quantity of radioactivity, and the estimated dose rate at the site boundary per curie of radioactivity in the Updated Safety Analysis Report. The licensee has entered this violation into their corrective action program as Condition Report 2012-05725. This issue was evaluated using traditional enforcement because it has the potential to impact the NRCs ability to perform its regulatory function. This issue is being characterized as a Severity Level IV violation in accordance with Section 6.1.d.3 of the NRC Enforcement Policy. Cross-cutting aspects are not assigned to traditional enforcement violations. NOV summary: The inspectors identified a cited violation of 10 CFR 50.71(e), Maintenance of Records, Making of Reports, for the failure to update the Updated Safety Analysis Report with a detailed description of the Original Steam Generator Storage Facility. Specifically, since December 2006, the licensee stored a significant source of radioactivity in the Original Steam Generator Storage Facility, but failed to describe the volume of waste, the principal sources of radioactivity, the total quantity of radioactivity, and the estimated dose rate at the site boundary per curie of radioactivity in the Updated Safety Analysis Report. The licensee has entered this violation into their corrective action program as Condition Report 2012-05725. This issue was evaluated using traditional enforcement because it has the potential to impact the NRCs ability to perform its regulatory function. This issue is being characterized as a Severity Level IV violation in accordance with Section 6.1.d.3 of the NRC Enforcement Policy. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000285/FIN-2012004-0130 September 2012 23:59:59Fort CalhounNRC identifiedFailure to report an event to the NRC within 60 days for an operation prohibited by Technical SpecificationsThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73(a) for the failure to submit a Licensee Event Report within 60 days after the discovery of performing an operation prohibited by technical specifications. The licensee failed to report to the NRC that they moved fuel while the Spent Fuel Pool Area Charcoal Filtration System, VA-66, was not in operation, contrary to Technical Specification 2.8.3(4). The licensee discovered in September 2011 that the fuel movement in December 2009 was inappropriate based on technical specifications, but failed to submit Licensee Event Report, 2012-008-0 until July 27, 2012. This issue was entered into the licensees corrective action program and evaluated with an Apparent Cause Analysis under Condition Report, 2012-08521 and 2012-08386 The failure to make an official report to the NRC regarding an operation prohibited by the Technical Specifications is a performance deficiency. The issue was dispositioned using traditional enforcement because failing to submit the Licensee Event Report had the potential to adversely impact the NRCs ability to perform its regulatory function. The issue is characterized as a Severity Level IV violation in accordance with the NRC Enforcement Policy, Section 6.9.d.9. Since this issue was dispositioned using traditional enforcement, there is no cross-cutting aspect.
05000285/FIN-2012301-0230 June 2012 23:59:59Fort CalhounNRC identifiedFailure to Periodically Update the Final Safety Analysis Report for the Emergency Diesel GeneratorsThe team identified a Severity Level IV non-cited violation of Title 10 CFR Part 50.71(e), for failure to periodically update the final safety analysis report originally submitted as part of the application for the license to assure that the information included in the report contains the latest information developed. Specifically, the licensee failed to update the final safety analysis report to include the required continuous hour rating used for emergency diesel generator testing as referenced by Technical Specification Surveillance Requirement 3.7(1)(a)(ii). After identification, the licensee entered this issue in the corrective action program as Condition Report 2011- 06612. The failure to update the final safety analysis report to include information that is specifically referenced by the technical specifications is a performance deficiency. The inspectors considered this issue to be within the traditional enforcement process because it has the potential to impede or impact the NRC\'s ability to perform its regulatory function. The inspectors used the NRC Enforcement Policy to evaluate the significance of this violation. The violation is more than minor because the omitted final safety analysis report update information had a potential impact on safety and licensed activities in that the licensee did not have the required reference for a surveillance test. Consistent with the guidance in Section 2.2.2 and Section 6.1.d.3 of the NRC Enforcement Policy, the inspectors concluded that the violation is a Severity Level IV because the omitted information did not result in an unacceptable change to the facility or procedures.
05000285/FIN-2011002-0331 March 2011 23:59:59Fort CalhounNRC identifiedFailure to Submit a Timely Licensee Event ReportThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73 (a)(2)(i)(B) for the licensees failure to submit a licensee event report within 60 days of discovery. On November 29, 2010, the licensee had the available information to determine reactor protection system channel A trip unit 6 had been inoperable from November 8 until November 29, 2010. Per the licensees technical specifications, reactor protection system channel A trip unit 6 should have been in the tripped condition within 48 hours from time of discovering loss of operability. This is a reportable condition required by 10 CFR 50.73 (a)(2)(i)(B) as a condition prohibited by technical specifications. This was entered into the licensees corrective action program as Condition Report 2011-2006. The inspectors determined that the licensees failure to submit a licensee event report within the required time was a performance deficiency. The licensee had the appropriate licensing basis information as well as the inspectors specific concerns regarding inadequate troubleshooting, potential preconditioning, inadequate maintenance, and operability concern; therefore the performance deficiency was within their ability to foresee and correct. The inspectors reviewed this issue in accordance with Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was potentially affected. Specifically, the NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done the regulatory function is impacted, and is therefore a finding. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated for traditional enforcement only, in accordance with the NRC Enforcement Policy. This is a Severity Level IV noncited violation consistent with Sections 2.3.2 and 6.9.d of the NRC Enforcement Policy.
05000285/FIN-2010004-0530 September 2010 23:59:59Fort CalhounNRC identifiedFailure to Perform a 10 CFR 50.59 EvaluationThe inspectors identified a Severity Level IV violation of 10 CFR 50.59 after the licensee failed to perform an adequate evaluation to demonstrate that prior NRC approval was not required before making changes to the facility as described in the Updated Safety Analysis Report. On April 9, 2010, the licensee changed the facility as described in the Updated Safety Analysis Report to install a cable splice in a safety related cable without determining if prior NRC approval was required. The licensee took actions to make the modification temporary until a permanent repair could be made and entered the issue into the corrective action program as Condition Report 2010-4466. Fort Calhoun Station utilizes NEI 96-07 as their process to meet 10 CFR 50.59 requirements. Their failure to perform a 10 CFR 50.59 evaluation, in accordance with NEI 96 07, prior to changing the facility as described in the Updated Safety Analysis Report is a performance deficiency. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was potentially affected. Specifically, the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done the regulatory function is impacted, and is therefore more than minor. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated for Traditional Enforcement only in accordance with the NRC Enforcement Policy. The inspectors concluded that the 10 CFR 50.59 evaluation would have likely identified that prior NRC approval would have been required, unless the change to the facility was for a short duration of time. This was due to the introduction of additional potential failure mechanisms of the splices that are age-dependent. Since the licensee subsequently classified the cable splice as a temporary modification, and scheduled to be removed during the next refueling outage, the aging mechanisms would no longer be applicable. Therefore, this is a Severity Level IV violation as defined in Section 2.2.1.c of the NRC Enforcement Policy (Section 1R20).
05000285/FIN-2010004-0330 September 2010 23:59:59Fort CalhounNRC identifiedFailure to Update the Updated Safety Analysis Report Solid WasteThe inspectors identified a Severity Level IV, noncited violation of 10 CFR 50.71, Maintenance of Records, Making of Reports, paragraph (e) which states, in part, Each person licensed to operate a nuclear power reactor shall update periodically the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. Contrary to the above, the licensee failed to update periodically the Updated Safety Analysis Report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. Specifically, since December 2006, the licensee stored a significant source of radioactivity in the original steam generator storage facility but failed to describe the source, volume, and storage of radioactive equipment in the Updated Safety Analysis Report. The licensee has entered this violation into their corrective action program as Condition Report 2010-3636. The inspectors determined that the failure to update the Updated Safety Analysis Report as required by 10 CFR 50.71(e), Maintenance of Records, Making of Reports was a performance deficiency. This finding was evaluated using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The finding was more than minor because it had a material impact on licensed activities in that a radioactive solid waste storage facility was relocated from the plant radiological controlled area to the owner controlled area without being described in the Updated Safety Analysis Report. The finding was characterized as a Severity Level IV violation in accordance with Section 6.1.d.3 of the NRC Enforcement Policy (Section 1R17).
05000285/FIN-2010003-0530 June 2010 23:59:59Fort CalhounNRC identifiedFailure to Submit a Required Licensee Event ReportThe inspectors identified a noncited violation for the failure to submit a licensee event report within 60 days of discovery of an event as required by 10 CFR 50.73. Specifically, the turbine-driven auxiliary feedwater pump, FW-10, was inoperable from February 26 until April 6, 2009, which is a reportable condition required by 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by technical specifications. On March 11, 2009, the electric motor-driven auxiliary feedwater pump, FW-6, was inoperable for approximately four hours when diesel generator 1 was inoperable. With both auxiliary feedwater pumps simultaneously inoperable, this was a reportable condition required by 10 CFR 50.73(a)(2)(v) as an event that could have prevented fulfillment of a safety function. The licensee entered this violation into their corrective action program, completed a reportability evaluation and determined that a licensee event report was required to be submitted within 60 days of April 6, 2009, and had not been submitted. The licensee event report will be submitted prior to August 10, 2010. The inspectors determined that the licensee‟s failure to submit a Licensee Event Report was a performance deficiency. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was potentially affected. Specifically, the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done the regulatory function is impacted, and is therefore a finding. The inspectors determined that this finding was not suitable for evaluation using the significance determination process and, as such, was evaluated for traditional enforcement only in accordance with the NRC Enforcement Policy. This is a Severity Level IV noncited violation consistent with Section IV.A.3 and Supplement I, Paragraph D.4, of the NRC Enforcement Policy.
05000285/FIN-2010002-0131 March 2010 23:59:59Fort CalhounNRC identifiedInadequate Reportability GuidanceThe inspectors identified a Severity Level IV noncited violation of Fort Calhoun Technical Specification 5.8.1 for inadequate corrective action documents. Specifically, the documents do not adequately address assigning reportability evaluations. As a result, the licensee failed to evaluate the reportability of a condition that was determined to be reportable until questioned by the inspectors. The inspectors determined that the licensees inadequate corrective action documents were a performance deficiency. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Policy. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was potentially affected. Specifically, the NRC relies on the licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done the regulatory function is impacted, and is therefore a finding. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and due in part to its repetitive nature the violation was determined to be of more than minor significance, however since it was not found to be willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy
05000285/FIN-2009006-0631 December 2009 23:59:59Fort CalhounNRC identifiedFailure to Update Intake Structure DesignThe team identified a Severity Level IV, noncited violation for failure to update the final (updated) safety analysis report in accordance with 10 CFR 50.71(e).Specifically, the licensee failed to update Section 9.8, Raw Water Systems, of the Fort Calhoun Station Updated Safety Analysis Report after constructing a sheet pile alignment wall alongside the intake structure in 1982. Furthermore, this modification removed the slope from the river bottom. Additionally, recent sounding records indicate the river bottom near the intake structure is approximately the same depth as the center of the channel, thus, invalidating the updated safety analysis report statement. The licensee entered this condition into the corrective action program as CR 2009-3927.The finding is more than minor because the finding is determined to have a material impact on safety. Specifically, with the new sheet pile alignment wall, it could lead to a barge strike that is different than described in the updated safety analysis report. Using Supplement I of the NRC Enforcement Policy, this finding will be treated as a Severity Level IV violation. This finding was not assigned a crosscutting aspect because the underlying cause was not indicative of current performance
05000285/FIN-2009006-0531 December 2009 23:59:59Fort CalhounNRC identifiedFailure to Maintain Quality Records of the Intake Structure DesignThe team identified a Severity Level IV, noncited violation of 10 CFR Part 50,Appendix B, Criterion XVII, Quality Assurance Records, for failure to maintain original records of the seismic and tornado analysis of the intake structure. Specifically, in 2005, the licensee could not retrieve the original design documentation of the seismic and tornado analysis of the intake structure. This condition was documented in CR 200504345. After the licensee determined the documentation was not retrievable, the licensee reconstituted the seismic and tornado analysis of the intake structure. These analyses were available during the teams inspection. This finding is assessed through traditional enforcement because the finding has the potential for impacting the NRCs ability to perform its regulatory function. Using Inspection Manual Chapter 0612, Appendix E, the finding is more than minor because the records were not retrievable. Using Supplement I of the NRC Enforcement Policy, this finding will be treated as a Severity Level IV violation. This finding was not assigned a crosscutting aspect because the underlying cause was not indicative of current performance
05000285/FIN-2009004-0230 September 2009 23:59:59Fort CalhounNRC identifiedFailure to Adopt Appropriate Procedures to Evaluate Deviations and Failures to Comply with 10 CFR Part 21The NRC identified a Severity Level IV noncited violation of 10 CFR Part 21.21(a), Notification of failure to comply or existence of a defect and its evaluation for the licensees failure to adopt appropriate procedures to evaluate deviations and failures to comply associated with substantial safety hazards. Specifically, the procedure fails to adequately assess the extent of deviations, which are discovered, and the potential impact on other components either installed in the plant or stored in the warehouse. Additionally, the procedure failed to adequately evaluate defects in components, which have never been installed or used in the nuclear plant. The inspectors determined that the failure to adopt appropriate procedures to evaluate deviations and failures to comply associated with substantial safety hazards was a performance deficiency. This finding was more than minor because if the procedure were left uncorrected it could become a more serious safety concern. Specifically, failure to notify the vendor upon discovery of a deviation does not allow for adequate evaluation of other components that could be subject to the deviation. Additionally, components with deviations could be located in the licensees warehouse and subsequently installed in the plant without the licensees knowledge, potentially creating a substantial safety hazard. Because this issue affected a potential reporting requirement and NRCs ability to perform its regulatory function, it was evaluated with the traditional enforcement process. Consistent with the guidance in Section IV.A.3 and Supplement VII paragraph D.4 of the NRC Enforcement Policy, this violation was categorized at Severity Level IV noncited violation. There is no crosscutting aspect associated with this finding because it is not indicative of current performance in that the procedure is many years old
05000285/FIN-2003009-0131 March 2003 23:59:59Fort CalhounNRC identifiedFailure to follow radiation protection procedural and RWP requirementsSeverity Level IV. Several examples of a violation of Technical Specification 5.8.1.a for the failure to follow radiation protection procedure requirements were identified. Fourteen different security officers deliberately violated applicable radiation protection procedural requirements on 62 occasions by not signing in on the required radiation work permit (RWP) 02-004 and not obtaining an electronic alarming dosimeter when assigned to the Alpha 1 security post during the period of April 27 through October 8, 2002. This violation is being treated as a Severity Level IV violation consistent with the NRC Enforcement Policy. This violation is in the licensee's corrective action program as CR- 200303574.