05000285/LER-2012-001, Regarding Inadequate Flooding Protection Procedure

Regarding Inadequate Flooding Protection Procedure

ML12102A096
Person / Time
Site:	Fort Calhoun
Issue date:	04/10/2012
From:	Bannister D Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LlC-12-0039 LER 12-001-00
Download: ML12102A096 (6)

LER-2012-001, Regarding Inadequate Flooding Protection Procedure

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2852012001R00 - NRC Website

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Omaha Public Power Ois/rief 444 South /6 111 Street Mall Omaha. NE 68102-2247 LlC-12-0039 April 10,2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 References: 1. Docket No. 50-285

2. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk) dated March 1,2012 (LlC-12-0022)

Subject:

Licensee Event Report 2012-001, Revision 0, for the Fort Calhoun Station Please find attached Licensee Event Report 2012-001, Revision 0, dated April 10, 2012.

This report is being submitted pursuant to 10 CFR 50.73(a)(2)(v)(B) and (D). No commitments are being made in this letter.

If you should have any questions, please contact me.

Sincerely,

~~

D. J. Bannister Vice President and CNO DJB /epm Attachment c:

E. E. Colliins, Jr., NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector INPO Records Center Employment with Equal Opportunity

NRC FORM 366 (10-2010)

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (10-2010)

LICENSEE EVENT REPORT (LER)

(See reverse for required number of digits/characters for each block)

APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013

, the NRC may not conduct or sp onsor, and a person is not required to respond to, th e

information collection.

1. FACILITY NAME Fort Calhoun Station

2. DOCKET NUMBER 05000285

3. PAGE 1 OF 3

4. TITLE Inadequate Flooding Protection Procedure

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL NUMBER REV NO.

MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 05000 2

10 2012 2012 - 001 -

0 4

10 2012 FACILITY NAME DOCKET NUMBER 05000

9. OPERATING MODE 5

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 20.2201(b) 20.2203(a)(3)(i) 50.73(a)(2)(i)(C) 50.73(a)(2)(vii) 20.2201(d) 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 20.2203(a)(1) 20.2203(a)(4) 50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B) 20.2203(a)(2)(i) 50.36(c)(1)(i)(A) 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A) 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(x) 20.2203(a)(2)(iii) 50.36(c)(2) 50.73(a)(2)(v)(A) 73.71(a)(4) 20.2203(a)(2)(iv) 50.46(a)(3)(ii) 50.73(a)(2)(v)(B) 73.71(a)(5) 20.2203(a)(2)(v) 50.73(a)(2)(i)(A) 50.73(a)(2)(v)(C)

OTHER 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B) 50.73(a)(2)(v)(D)

Specify in Abstract below or in LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

EVENT DESCRIPTION

During an inspection of flood preparations by the NRC in response to NRC findings previously noted, it was determined that the guidance is not adequate to mitigate a design basis flood event (1014 feet mean sea level (msl)). As a result of the procedural inadequacies, the intake structure was vulnerable to water inflow during an extreme flooding event. This inflow had the potential to affect the operability of both trains of safety related raw water pumps (ultimate heat sink). As a result the station implemented the actions listed in the corrective actions below.

On February 10, 2012, an eight (8) hour report was made under 10 CFR 50.72 (b)(3)(ii)(B) to the NRC Headquarters Operation Office (HOO) at 1754 CST (Event Number47658). After further evaluation this report is being made per 10 CFR 50.73(a)(2)(v)(B) and (D).

CONCLUSION A root cause determination is in progress. The results of the evaluation will be published in a revision to this LER.

CORRECTIVE ACTIONS

Compensatory actions have been identified and were implemented.

1. The station revised AOP-01, Acts of Nature,Section I - Flood, and Attachment D, Flooding Protective Actions, and the Floating Step Monitoring Index. Corrections were made to add steps to provide alternate filling capability for maintaining Intake cell level.

2. Changes were also made to Operating Instruction OI-CW-1, Circulating Water System Normal Operation, to address deficiencies in controlling the circulating water system during design basis conditions.

Additional corrective actions will be made following completion of the cause evaluation.

SAFETY SIGNIFICANCE

The Fort Calhoun Station is required to be protected from flooding within the stations licensing basis.

The safety related equipment required to mitigate the consequences of an accident were affected by these findings. The openings could have jeopardized the ability of the safety related equipment to perform their design basis function during an accident. Other methods of removing decay heat and mitigating the consequences of a flooding event were available. Therefore, this external flooding concern has substantial importance to safety as indicated by the Yellow Finding issued for this event.

SAFETY SYSTEM FUNCTIONAL FAILURE This event does result in a safety system functional failure in accordance with NEI-99-02.

PREVIOUS EVENTS LER 2011-003

FORT CALHOUN STATION NOD-QP-9.2 QUALITY PROCEDURE FORM R0 LICENSING CORRESPONDENCE REVIEW FORM LIC-12-0039 Date Issued: 4/2/12 Requested Return Date:____4/4/12______

Review/Approval Information Dave Bannister Lynn Smith Susan Baughn Woody Goodell J. Herman Brad Blome S. Miller Mike Cooper K. Hyde C. Cameron Subject___ Inadequate Flooding Protection Procedure Please review and approve the attached draft correspondenc e (referenced above). In order to document your review for our records, please sign this form and return it to the Licensing Coordinator. If n o notification is received by the requested return date, your concurrence with no comment will be assumed.

E. Matzke 6855____

Technical Coordinator (Ext.) Licensing Coordinator (Ext.)

[ ] Approved with no comment. [ ] Approved pending resolution of comments as noted.

Comments:_______________________________________________________________________________

Reviewer's Signature Date

FORT CALHOUN STATION NOD-QP-9.2 QUALITY PROCEDURE FORM R0 LICENSING CORRESPONDENCE REVIEW FORM SUMMARY LIC-12-0039 Date Issued: 4/2/12 Requested Return Date: 4/4/12 Name Date Comments Received No Comments1 Comments - How Resolved2 Dave Bannister 4/2/12 See sheet.

Susan Baughn J. Herman S. Miller 4/3/12 See email string Mike Cooper Woody Goodell K. Hyde 4/2/12 X

C. Cameron 4/*4/12 See sheet.

Lynn Smith Subject: Inadequate Flooding Protection Procedure NOTE - This submittal does ____ does not __X__ include documents/files on CD-ROM.3 NL Comment Coordinator Signature E. Matzke Date 04/10/12 Responsible Dept. Manager (if required)

Date Review by Nuclear Licensing Supervisor Date 1 Attach only signed Licensing Correspondence Review Form.

2 Attach necessary documentation.

3 Ensure that the CD-ROM files are formatted properly for electronic information exchange (EIE) to the NRC. (Reference NL-17)