IR 05000285/2016003

NRC Integrated Inspection Report Number 05000285/2016003

ML16315A180
Person / Time
Site:	Fort Calhoun
Issue date:	11/08/2016
From:	Geoffrey Miller NRC/RGN-IV/DRP/RPB-D
To:	Marik S Omaha Public Power District
GEOFF MILLER
References
IR 2016003
Download: ML16315A180 (66)

Text

November 8, 2016

SUBJECT:

FORT CALHOUN STATION - NRC INTEGRATED INSPECTION REPORT NUMBER 05000285/2016003

Dear Mr. Marik:

On September 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fort Calhoun Station. On October 12, 2016, the NRC inspectors discussed the results of this inspection with Michael J. Prospero, Acting Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any findings or violations of more than minor significance.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Geoffrey B. Miller, Branch Chief Project Branch D Division of Reactor Projects

Docket No. 50-285 License No. DPR-40

Enclosure:

Inspection Report 05000285/2016003 w/ Attachment:

1. Supplemental Information 2. Request for Information for the O

REGION IV==

Docket:

05000285 License:

DPR-40 Report:

05000285/2016003 Licensee:

Omaha Public Power District Facility:

Fort Calhoun Station Location:

9610 Power Lane Blair, NE 68008 Dates:

July 1 through September 30, 2016 Inspectors: S. Schneider, Senior Resident Inspector S. Money, Acting Resident Inspector T. Sullivan, Acting Resident Inspector L. Brandt, Acting Resident Inspector L. Carson II, Sr. Health Physicist N. Greene, PhD, Health Physicist P. Hernandez, Health Physicist J. Kirkland, Senior Operations Engineer J. ODonnell, CHP, Health Physicist C. Cowdrey, Operations Engineer

Approved By:

Geoffrey B. Miller Chief, Project Branch D Division of Reactor Projects

- 2 -

SUMMARY

IR 05000285/2016003; 07/01/2016 - 09/30/2016; Fort Calhoun Station; Integrated Inspection

Report.

The inspection activities described in this report were performed between July 1 and September 30, 2016, by the resident inspectors at Fort Calhoun Station and inspectors from the NRCs Region IV office. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

No findings were identified.

PLANT STATUS

The unit began the inspection period at approximately 98 percent power following start-up from an unplanned automatic reactor trip and returned to 100 percent power on July 1, 2016. On September 29, 2016, the licensee commenced a power coastdown, and Fort Calhoun operated at approximately 98.5 percent power at the end of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On September 6, 2016, the inspectors completed an inspection of the stations readiness for impending adverse weather conditions. The inspectors reviewed plant design features, the licensees procedures to respond to impending storms, and the licensees compensatory actions to protect safety-related equipment. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant and conducted a plant walk-down.

These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walk-Down

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

• July 13, 2016, emergency diesel generator 2 during testing on emergency diesel generator 1

• July 18, 2016, steam driven auxiliary feedwater pump FW-10 prior to motor driven auxiliary feedwater pump FW-6 operability test

• September 20, 2016, auxiliary feedwater system prior to steam driven auxillary feedwater pump FW-10 operability test

• September 26, 2016, component cooling water system with component cooling water pump AC-3B out of service for maintenance

The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.

These activities constituted four partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walk-Down

a. Inspection Scope

On August 19, 2016, the inspectors performed a complete system walk-down inspection of the spent fuel pool cooling system. The inspectors reviewed the licensees procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors also reviewed open condition reports, in-process design changes, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on five plant areas important to safety:

• July 21, 2016, emergency diesel generator room 1, fire area 35A

• August 10, 2016, auxiliary building, fire area 33

• August 10, 2016, auxiliary building, fire area 43

• August 11, 2016, auxiliary building, fire areas 35A and 35B

• August 12, 2016, auxiliary building, fire area 10

For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted five quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

On August 9, 2016, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose one plant area containing risk-significant structures, systems, and components that were susceptible to flooding:

• Room 22, safety injection pump room

The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

These activities constituted completion of one flood protection measures sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

On August 15, 2016, the inspectors completed an inspection of the readiness and availability of a risk-significant heat exchanger. The inspectors reviewed the data from the performance of spent fuel pool cooling heat exchanger AC-8 disassembly, cleaning, visual inspection, and reassembly activities.

Additionally, the inspectors walked down spent fuel pool cooling heat exchanger AC-8 to observe its performance and material condition and verified that the heat exchanger was correctly categorized under the Maintenance Rule and was receiving the required maintenance.

These activities constituted completion of one heat sink performance annual review sample, as defined in Inspection Procedure 71111.07.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On July 26, 2016, the inspectors observed an Emergency Plan drill for an operating crew in the simulator. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the requalification activities.

These activities constituted completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants main control room. The inspectors observed the operators performance of the following activities:

• July 5, 2016, operators responded to an automatic isolation of steam generator B blowdown

• August 10, 2016, entry into abnormal operating procedure AOP-31 due to 161 kV grid disturbances

• August 29, 2016, entry into abnormal operating procedure AOP-12 due to loss of containment integrity

• September 13, 2016, operators performed an emergency diesel generator 1 surveillance test while conducting fuel moves in the spent fuel pool and diluting the reactor coolant system

• September 15, 2016, operators responded to the failed Loop 2 Thot resistance temperature detector from the B reactor protective system instrument channel In addition, the inspectors assessed the operators adherence to plant procedures and other operations department policies.

These activities constituted completion of five quarterly licensed operator performance samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Biennial Review of Requalification Program

a. Inspection Scope

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.

To assess the performance effectiveness of the licensed operator requalification program, the inspectors reviewed both the written examination and operating test quality and observed licensee administration of an annual requalification test while onsite. The operating tests observed included five job performance measures and two scenarios that were used in the current biennial requalification cycle. These observations allowed the inspectors to assess the licensee's effectiveness in conducting the operating test to ensure operator mastery of the training program content and to determine if feedback of performance analyses into the requalification training program was being accomplished.

On September 16, 2016, the licensee informed the inspectors of the completed cycle results for Fort Calhoun Station for both the written examinations and the operating tests:

• 8 of 8 crews passed the simulator portion of the operating test

• 35 of 38 licensed operators passed the simulator portion of the operating test

• 36 of 38 licensed operators passed the job performance measure portion of the operating test

• 34 of 38 licensed operators passed the written examination Two licensed operators did not take any portion of the operating test or written examination. They were unavailable for medical reasons and will be meeting the requalification exam requirements prior to the end of the current biennial cycle ending December 31, 2016.

The individual that failed the simulator scenario portion of the operating test was remediated, retested, and passed their retake test.

Two individuals failed the written examinations. One individual was remediated, retested, and passed their retake examination. The other individual was remediated, retested, and failed their retake examination. On September 26, 2016, the licensee requested that this individuals license be terminated.

The inspectors observed examination security measures in place during administration of the examinations (including controls and content overlap) and reviewed any remedial training and re-examinations, if necessary. The inspectors also reviewed medical records of five licensed operators for conformance to license conditions and the licensees system for tracking qualifications and records of license reactivation for one operator.

The inspectors reviewed simulator performance for fidelity with the actual plant and the overall simulator program of maintenance, testing, and discrepancy correction.

The inspectors completed one inspection sample of the biennial licensed operator requalification program.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed one instance of degraded performance or condition of safety-related structures, systems, and components (SSCs):

• July 28, 2016, spent fuel pool bridge failure

The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of one maintenance effectiveness sample, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

• July 8, 2016, planned yellow risk during emergency diesel generator 2 maintenance

• August 17, 2016, planned yellow risk during emergency diesel generator 1 testing The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

These activities constituted completion of two maintenance risk assessment inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed six operability determinations that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs):

• July 15, 2016, operability determination of the primary and secondary control element assemblies following discovery of a degraded condition

• August 23, 2016, operability determination of the reactor coolant pump RC-3A motor lower oil reservoir level anomolies

• August 29, 2016, operability determination of the flooding impact to the raw water pumps not adequately evaluated for the most limiting impact from tornado missile hazards

• September 2, 2016, operability determination of the raw water pump seal water piping supports not appearing to be seismically qualified

• September 28, 2016, operability determination of the boric acid leak on a reactor coolant system sampling line outside containment but inside the reactor coolant system containment isolation valve which affected containment integrity

• September 29, 2016, assessment of operator work-arounds The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded SSC.

The inspectors reviewed operator actions taken or planned to compensate for degraded or nonconforming conditions. The inspectors verified that the licensee effectively managed these operator work-arounds to prevent adverse effects on the function of mitigating systems and to minimize their impact on the operators ability to implement abnormal and emergency operating procedures.

These activities constituted completion of six operability review samples, which included one operator work-around sample, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed two temporary plant modifications that affected risk-significant structures, systems, and components (SSCs):

• August 24, 2016, tornado protection for raw water system cable pull boxes

• September 23, 2016, removal of a failed Loop 2 Thot resistance temperature detector from the B reactor protective system instrument channel The inspectors verified that the licensee had installed these temporary modifications in accordance with technically adequate design documents. The inspectors verified that these modifications did not adversely impact the operability or availability of affected SSCs. The inspectors reviewed design documentation and plant procedures affected by the modifications to verify the licensee maintained configuration control.

These activities constituted completion of two samples of temporary modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed five post-maintenance testing activities that affected risk-significant structures, systems, or components (SSCs):

• August 17, 2016, raw water pump AC-10 post-maintenance test

• September 8, 2016, replace battery charger 3 float potentiometer

• September 19, 2016, replace time delay agastat relay for component cooling water pump AC-3B from DC sequencer S2-1

• September 20, 2016, refurbishment of compressed air CA-1B air compressor

• September 26, 2016, removal of a failed Loop 2 Thot resistance temperature detector from the B reactor protective system instrument channel The inspectors reviewed licensing-and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constituted completion of five post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed nine risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components (SSCs) were capable of performing their safety functions:

In-service tests:

• August 19, 2016, component cooling water pump AC-3A in-service test

• September 9, 2016, safety injection/containment spray pumps in-service and valve exercise test

• September 30, 2016, raw water pump AC-10D in-service test Containment isolation valve surveillance tests:

• July 20, 2016, containment cooler inlet and outlet valves surveillance test

Reactor coolant system leak detection tests:

• September 28, 2016, reactor coolant system leak detection test

Other surveillance tests:

• July 15, 2016, emergency diesel generator 1 S1-2 automatic load sequencer surveillance test

• August 4, 2016, chemical and volume control system boric acid pump CH-4B surveillance test

• August 19, 2016, ventilating air system Category A valve exercise surveillance test

• September 20, 2016, diesel driven auxillary feedwater pump FW-54 full flow operability verification test The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the tests satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constituted completion of nine surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on July 26, 2016, to verify the adequacy and capability of the licensees assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the simulator, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any recommendations were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.

These activities constituted completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

The inspectors evaluated the licensees performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensees implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. During the inspection, the inspectors interviewed licensee personnel, walked down various areas in the plant, performed independent radiation dose rate measurements, and observed postings and physical controls. The inspectors reviewed licensee performance in the following areas:

• Radiological hazard assessment, including a review of the plants radiological source terms and associated radiological hazards. The inspectors also reviewed the licensees radiological survey program to determine whether radiological hazards were properly identified for routine and non-routine activities and assessed for changes in plant operations.

• Instructions to workers including radiation work permit requirements and restrictions, actions for electronic dosimeter alarms, changing radiological condition, and radioactive material container labeling.

• Contamination and radioactive material control, including release of potentially contaminated material from the radiologically controlled area, radiological survey performance, radiation instrument sensitivities, material control and release criteria, and control and accountability of sealed radioactive sources.

• Radiological hazards control and work coverage. During walk-downs of the facility and job performance observations, the inspectors evaluated ambient radiological conditions, radiological postings, adequacy of radiological controls, radiation protection job coverage, and contamination controls. The inspectors also evaluated dosimetry selection and placement as well as the use of dosimetry in areas with significant dose rate gradients. The inspectors examined the licensees controls for items stored in the spent fuel pool and evaluated airborne radioactivity controls and monitoring.

• High radiation area and very high radiation area controls. During plant walk-downs, the inspectors verified the adequacy of posting and physical controls, including areas of the plant with the potential to become risk-significant high radiation areas.

• Radiation worker performance and radiation protection technician proficiency with respect to radiation protection work requirements. The inspectors determined if workers were aware of significant radiological conditions in their workplace, radiation work permit controls/limits in place, and electronic dosimeter dose and dose rate set points. The inspectors observed radiation protection technician job performance, including the performance of radiation surveys.

• Problem identification and resolution for radiological hazard assessment and exposure controls. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constituted completion of the seven required samples of radiological hazard assessment and exposure control program, as defined in Inspection Procedure 71124.01.

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring equipment used by the licensee to monitor areas, materials, and workers to ensure a radiologically safe work environment. This evaluation included equipment used to monitor radiological conditions related to normal plant operations, anticipated operational occurrences, and conditions resulting from postulated accidents. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance associated with radiation monitoring instrumentation, as described below:

• The inspectors performed walk-downs and observations of selected plant radiation monitoring equipment and instrumentation, including portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors. The inspectors assessed material condition and operability, evaluated positioning of instruments relative to the radiation sources or areas they were intended to monitor, and verified performance of source checks and calibrations.

• The inspectors evaluated the calibration and testing program, including laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors.

• The inspectors assessed problem identification and resolution for radiation monitoring instrumentation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constituted completion of the three required samples of radiation monitoring instrumentation, as defined in Inspection Procedure 71124.05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

The inspectors evaluated whether the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensees quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

• During walk-downs and observations of selected portions of the radioactive gaseous and liquid effluent equipment, the inspectors evaluated routine processing and discharge of effluents, including sample collection and analysis.

The inspectors observed equipment configuration and flow paths of selected gaseous and liquid discharge system components, effluent monitoring systems, filtered ventilation system material condition, and significant changes to effluent release points.

• Calibration and testing program for process and effluent monitors, including National Institute of Standards and Technology (NIST) traceability of sources, primary and secondary calibration data, channel calibrations, set-point determination bases, and surveillance test results.

• Sampling and analysis controls used to ensure representative sampling and appropriate compensatory sampling. Reviews included results of the inter-laboratory comparison program.

• Instrumentation and equipment, including effluent flow measuring instruments, air cleaning systems, and post-accident effluent monitoring instruments.

• Dose calculations for effluent releases. The inspectors reviewed a selection of radioactive liquid and gaseous waste discharge permits and abnormal gaseous or liquid tank discharges, and verified the projected doses were accurate. The inspectors also reviewed 10 CFR Part 61 analyses and methods used to determine which isotopes were included in the source term. The inspectors reviewed land use census results, offsite dose calculation manual changes, and significant changes in reported dose values from previous years.

• Problem identification and resolution for radioactive gaseous and liquid effluent treatment. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constituted completion of the six required samples of radioactive gaseous and liquid effluent treatment program, as defined in Inspection Procedure 71124.06.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items:

• Radioactive material storage, including waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition.

• Radioactive waste system, including walk-downs of the accessible portions of the radioactive waste processing systems and handling equipment. The inspectors also reviewed or observed changes made to the radioactive waste processing systems, methods for dewatering and waste stabilization, waste stream mixing methodology, and waste processing equipment that was not operational or abandoned in place.

• Waste characterization and classification, including radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides, and processes for waste classification including use of scaling factors and 10 CFR Part 61 analyses.

• Shipment preparation, including packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifests.

• Shipping records for LSA I, II, III, SCO I, II, Type A, or Type B radioactive material or radioactive waste shipments.

• Problem identification and resolution for radioactive solid waste processing and radioactive material handling, storage, and transportation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constituted completion of the six required samples of radioactive solid waste processing and radioactive material handling, storage, and transportation program, as defined in Inspection Procedure 71124.08.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index: High Pressure Injection Systems (MS07)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of July 1, 2015, through June 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for high pressure injection systems, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index: Heat Removal Systems (MS08)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of July 1, 2015, through June 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for heat removal systems, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index: Cooling Water Support Systems (MS10)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of July 1, 2015, through June 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for cooling water support systems, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors verified that there were no unplanned exposures or losses of radiological control over locked high radiation areas and very high radiation areas during the period of April 1, 2015, to June 30, 2016. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than 100 millirem. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the occupational exposure control effectiveness performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.5 Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual

(ODCM) Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed corrective action program records for liquid or gaseous effluent releases that occurred between April 1, 2015, and June 30, 2016, and were reported to the NRC to verify the performance indicator data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the radiological effluent technical specifications (RETS)/offsite dose calculation manual (ODCM) radiological effluent occurrences performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected one issue for an in-depth follow-up:

• On September 30, 2016, in leakage into safety injection tank 6A.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

These activities constituted completion of one annual follow-up sample as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

.1 Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems as applicable. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in Inspection Manual Chapter 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that the licensee made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR 50.72 and 50.73. The inspectors reviewed the licensees follow-up actions related to the event to assure that the licensee implemented appropriate corrective actions commensurate with their safety significance.

• August 10, 2016, operator response to 161 kV grid disturbances

• August 29, 2016, operator response to a loss of containment integrity

• September 3, 2016, operator response to a seismic event alarm

b. Findings

No findings were identified.

.2 (Closed) Licensee Event Report 05000285/2016-001-00, Technical Specification

Violation Due to Installation of an Unqualified Part in a Radiation Monitor

a. Inspection Scope

On February 10, 2016, the licensee became aware of a 10 CFR 21.21 nonconformance notification issued by Canberra Industries, Incorporated. Canberra identified that some components from purchase orders associated with radiation monitors had not fully met 10 CFR 50.49 electrical equipment qualification standards. It was determined that certain components (time delay, mass flow controller, and vacuum pump motor) in specific radiation monitors (RMs)-50, -51, and -52 may not be qualified for the potential worst case environmental conditions during an electromagnetic, high temperature or seismic event. By February 12, 2016, the licensee and Canberra located the components that should have been included in the electrical equipment qualification program. Eventually, the licensee determined that only RM-52 (auxiliary building vent stack monitor) had an unqualified part installed, a time delay relay.

The licensee did not have the nonconforming relay rededicated or requalified. As corrective action, the licensee replaced the relay with a new relay that had been properly qualified. The extent of condition evaluation revealed that when RM-52 was in the degraded condition with the unqualified time delay relay, it was relied on to backup the dedicated containment building radiation monitors RM-50, -51, and -62. These radiation monitors provide a containment radiation high signal during an event and are required to be operable per Technical Specification 2.15.1. The licensee corrected the deficiency immediately upon notification and no additional deficiencies were identified during the review of this licensee event report. Therefore, the inspector determined there was no performance deficiency. This licensee event report is closed.

b. Findings

No findings were identified.

.3 (Closed) Violation 05000285/2015010-01, Failure to Provide Complete and Accurate

Information on Licensed Operator Applications The NRC issued this cited violation of 10 CFR 50.9, Completeness and Accuracy of Information, for the Fort Calhoun Stations failure to perform combustion odor testing as required in American National Standards Institute Standard 3.4-1996 for physical examinations of licensed operators and as documented in NRC Form 396, Certification of Medical Examination by Facility Licensee. To address this violation, the licensee initiated Condition Report CR 2014-05108.

The inspectors reviewed the actions documented in Condition Report CR 2014-05108 and the subsequent condition reports. Those corrective actions included testing all licensed operators for combustion odor testing prior to taking their next scheduled watch, and revising Procedure OP-AA-105-101, Administrative Process for NRC License and Medical Requirements, to bring the Exelon fleet model to Fort Calhoun Station. The inspectors determined that through these actions, the licensee restored compliance to 10 CFR 55.23. This violation is closed.

These activities constituted completion of five event follow-up samples, as defined in Inspection Procedure 71153.

4OA5 Other Activities

Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period

a. Inspection Scope

The inspectors performed Inspection Procedure (IP) 92723, Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, based on the results of the NRCs mid-cycle assessment review of station performance as documented in the 2015 mid-cycle assessment letter dated September 1, 2015. From July 1, 2014 through June 30, 2015, the NRC issued eight Severity Level (SL) IV traditional enforcement violations in the area of impeding the regulatory process, four of which involved the implementation of the 10 CFR 50.59 process.

The inspectors reviewed the licensees cause evaluation and corrective actions associated with these issues in order to determine whether the licensees actions met the IP 92723 inspection objectives to provide assurance that:

(1) the cause(s) of the violations are understood by the licensee;

(2) the extent of condition and extent of cause of the violations are identified; and

(3) licensee corrective actions to the violations are sufficient to address the cause(s).

b. Observations and Findings

The licensee determined the cause was leadership had not provided adequate governance and oversight to influence behaviors and hold personnel accountable. The licensee also determined that the traditional enforcement issues were driven by human performance errors and were primarily associated with the implementation of the 10 CFR 50.59 process by engineering personnel. The licensee reviewed traditional enforcement violations from the previous 12-month time period and identified similar issues and drivers (e.g., several 10 CFR 50.59 process implementation issues). The inspectors determined the SLIV violations received an evaluation at an appropriate level of detail to identify the causes and included review of prior occurrences. The inspectors also concluded the evaluation of the traditional enforcement violations included an appropriate extent of condition and extent of cause of the issues.

The licensee credited several high level corrective actions previously implemented during their recovery while in the Inspection Manual Chapter 0350 process. These actions included; development of governance and oversight policies and transition to the Exelon Management model, implementation of a new engineering organizational structure, development and implementation of an Institute of Nuclear Power Operations (INPO) Human Performance Strategic Plan, and the development of an interim Engineering Assurance Group to review engineering product quality. In addition, actions were taken specifically to improve engineering performance and 10 CFR 50.59 process implementation. The actions included 10 CFR 50.59 training, limiting the number of personnel qualified to perform 10 CFR 50.59 evaluations and reviews, and the development of key performance indicators to trend the quality of these engineering products.

The inspectors determined these corrective actions were comprehensive and appropriate to improve overall site performance and specifically to improve 10 CFR 50.59 process and engineering department performance. The inspectors also determined that the corrective actions were prioritized and implemented on a schedule reflective of the organizational turn around necessary to improve site performance. The inspectors noted that although some actions had not appeared to have been in place long enough to effectively preclude the traditional enforcement violations that were identified in the 2014 to 2015 time period, overall site and specifically engineering performance has improved since this time.

The licensee identified several success measures to determine the effectiveness of the traditional enforcement corrective actions including: verification of the completion of engineering training classes, a Nuclear Oversight department audit of the design process (including the 10 CFR 50.59 process with no findings), a successful check-in self-assessment conducted in June 2016, and an overall reduction of traditional enforcement violations in the 12 months following the period of the review (two traditional enforcement violations issued, one of which involved the 10 CFR 50.59 process). The inspectors determined that the licensee developed measures of success which reasonably show improvement has occurred and that corrective actions were reasonably affective in preventing recurrence.

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On July 22, 2016, the inspectors presented the radiation safety inspection results to Mr. M. Prospero, Vice President, Site (Acting), and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On September 28, 2016, the inspectors briefed Mr. S. Marik, Vice President and Chief Nuclear Officer, and other members of the licensee's staff of the results of the licensed operator requalification program inspection. The licensee representatives acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On October 12, 2016, the inspectors presented the inspection results to Mr. M. Prospero, Acting Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

A. Barker, Supervisor, Radiation Protection

C. Beck, Director, Training, (Acting)

R. Beck, Manager Chemistry, Environmental, and Radwaste

A. Beebe, Supervisor, Chemistry

B. Blessie, Operations Training

B. Blome, Manager, Regulatory Assurance

B. Bonwell, Requalification Supervisor

E. Breault, Supervisor, Radiological Operations

D. Brehm, Supervisor, Radiation Protection Technical Support

C. Cameron, Principal Regulatory Specialist

J. Cate, Manager, Engineering Projects

H. Childs, Manager, Security

D. Conn, Shipper, Radiation Protection

B. Currier, Director, Site Engineering

E. Durboraw, Specialist, Radwaste

E. Engert, Senior Technician, Chemistry

J. Hoffman, Supervisor, Chemistry

R. Hugenroth, Manager, Nuclear Oversight

K. Kingston, Director Maintenance (Acting)

T. Leaf, Director, Operations

L. Maine, Senior Technician, Chemistry

S. Marik, Vice President and Chief Nuclear Officer

E. Matzke, Senior Licensing Engineer

T. Parent, Engineering

B. Pearson, Supervisor, Radiation Protection

E. Plautz, Manager, Emergency Planning

M. Prospero, Vice President, Site (Acting)

A. Ritton, Senior Technician, Chemistry

J. Shuck, Manager, Systems Engineering

J. St. Claire, Operations Training

J. Sunderman, Senior Radiation Protection Technician

T. Tierney, Plant Manager

T. Uehling, Manager, Training

C. Verdoni, Operation Training

D. Weaver, Director, Site Work Management (Acting)

D. Whisler, Manager, Radiation Protection

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

05000285/2016001-00 LER Technical Specification Violation Due to Installation of an Unqualified Part in a Radiation Monitor (Section 4OA3)

05000285/2015010-01 VIO Failure to Provide Complete and Accurate Information on Licensed Operator Applications (Section 4OA3)