IR 05000285/2014003
| ML14239A654 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/27/2014 |
| From: | Hay M C NRC/RGN-IV/DRP |
| To: | Cortopassi L P Omaha Public Power District |
| Hay M | |
| References | |
| IR-2014-003 | |
| Download: ML14239A654 (44) | |
Text
27, 2014 Louis P. Cortopassi, Site Vice President Omaha Public Power District Fort Calhoun Station FC-2-4 P.O. Box 550 Fort Calhoun, NE 68023
-0550
SUBJECT: ERRATA FOR FORT CALHOUN STATION - NRC INTEGRATED INSPECTION REPORT 05000285/2014003
Dear Mr. Cortopassi
An administrative error was discovered in the Nuclear Regulatory Commission Inspection Report 05000285/2014003, dated July 29, 2014 (ML14211A602). It was identified that the completion of Temporary Instruction 182, "Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks" was not included in the report
. Please replace the inspection report with the enclosure to this lette
Sincerely,/RA/ Michael C. Hay, Chief Reactor Project Branch F Division of Reactor Projects Docket No.:
50-285 License No.: DPR-40
Enclosure:
ERRATA for NRC Inspection Report 05000285/201 4003 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E LAMAR BLVD ARLINGTON, TX 76011-4511
-1- Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000285 License: DPR-40 Report: 05000285/201400 3 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, NE 68008 Dates: April 1 through June 30 , 2014 Inspectors:
J. Kirkland, Senior Resident Inspector S. Schneider, Senior Resident Inspector J. Wingebach, Resident Inspector C. Alldredge, Health Physicist N. Greene, Ph.D., Health Physicist P. Hernandez, Health Physicist J. Larsen, Senior Physical Security Inspector
R. Latta, Senior Reactor Inspector C. Speer, Resident Inspector L. Willoughby, Senior Reactor Inspector J. Drake, Senior Reactor Inspector Approved By:
Michael C. Hay, Chief, Project Branch F Division of Reactor Projects
SUMMARY
IR 05000285/2014003; 04/01/2014 - 06/30/2014; Fort Calhoun Station;
Radiological Hazard Assessment and Exposure Control. The inspection activities described in this report were performed between April 1 and June 30, 2014, by the resident inspectors at the Fort Calhoun Station and inspectors from the Nuclear Regulatory Commission (NRC) Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red), and determined using Inspection Manual Chapter 0609, "Significance Determination Process" dated June 2, 2011. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310; "Components Within the Cross-Cutting Areas" dated December 19, 2013.
All violations of NRC requirements are dispositioned in accordance with the NRC
's Enforcement Policy dated July 9, 2013.
The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process" revision 5.
Cornerstone: Occupational Radiation Safety
- Green.
The inspectors reviewed a self-revealing, non-cited violation of Technical Specification 5.11.1.b, which resulted from an individual entering a high radiation area without being aware of the radiological conditions. Specifically, on July 19, 2013, an operator was performing valve lineup work in the reactor building. Although the operator was on a radiation work permit that allowed access to high radiation areas, access was only allowed with knowledge of the dose rates in the areas entered. As immediate corrective actions, the radiation protection supervisors coached the operator on properly informing Radiation Protection of his planned work areas; and coached the radiation protection technician on having a more intrusive questioning attitude during briefings so that radworkers are properly informed of all hazards and radiological conditions. This issue was documented in the licensee's corrective action program as Condition Report (CR) 2014-14693. The entry into a high radiation area without knowledge of the radiological conditions is a performance deficiency and is a violation of Technical Specification 5.11.1.b. The performance deficiency is more than minor because it is associated with the Occupational Radiation Safety cornerstone attribute of program and process (exposure control) and adversely affects the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation. Using Inspection Manual Chapter 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," dated August 19, 2008, the inspectors determined the violation has very low safety significance because: (1)it was not an as low as is reasonably achievable finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. This violation has a cross-cutting aspect in the human performance area, associated with teamwork, because the operator did not properly communicate his work locations to the radiation protection technician for briefing and the technician did not display a questioning attitude to understand the work locations for the operator to properly brief him and ensure nuclear safety was maintained [H.4]. (Section 2RS1)
PLANT STATUS
The unit began the inspection period at 100 percent power. On April 15, 2014, the unit commenced a plant shutdown in accordance with Technical Specification 2.0.1 due to two inoperable control room air conditioners. One air conditioner was restored to operable status on April 15, 2014, with reactor power at approximately 36 percent power and the shutdown was halted. The unit returned to 100 percent power on April 18, 2014. On April 20, 2014, reactor power was decreased to approximately 85 percent to perform condenser cleaning. The unit returned to 100 percent power on April 26, 2014. On May 14, 2014, reactor power was decreased to 90 percent power to repair leaking gaskets on the heater drain pump suction piping. The unit returned to 100 percent power on May 16, 2014. On Ju ne 20, 2014, due to rising Missouri river levels the station commenced a downpower to 30 percent. On June 23, 2014, high Missouri river levels were determined to not be an operational restraint and reactor power was raised to 100 percent where it remained for the rest of the inspection period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R 01 Adverse Weather Protection (71111.01)
.1 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
On May 12, 2014, the inspectors completed an inspection of the station's readiness for impending adverse weather conditions due to severe thunderstorms in the area. The inspectors reviewed plant design features, the licensee's procedures to respond to tornadoes and high winds, and the licensee's planned implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.
On June 1 6, 2014, the inspectors completed an inspection of the station's readiness for impending adverse weather conditions during a tornado watch. The inspectors reviewed plant design features, the licensee's procedures to respond to tornadoes and high winds, and the licensee's planned implementation of these procedures. The inspector's evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.
These activities constituted two samples of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
.2 Readiness to Cope with External Flooding
a. Inspection Scope
From June 17 through June 23, 2014, the inspectors completed an inspection of the station's readiness to cope with external flooding due to expected flooding on the Missouri River.
The inspectors reviewed plant design features and licensee procedures for coping with flooding. The inspectors walked down selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether credited operator actions could be successfully accomplished.
These activities constituted one sample of readiness to cope with external flooding, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R 04 Equipment Alignment (71111.04)
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walk
-downs of the following risk
-significant systems:
April 30, 2014, partial alignment of the diesel generator system while DG-1 was under a surveillance activity, May 28, 2014, partial system alignment of the spent fuel cooling system while spent fuel cooling pump AC-5A was out of service for maintenance, and June 18, 2014, partial system alignment of the intake cell level control system when the site anticipated river level would require their use.
The inspectors reviewed the licensee's 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 three partial system walk
-down samples as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R 05 Fire Protection (71111.05)
.1 Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensee's fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:
May 21 , 2014, Room 56E, East Switchgear Area, Fire Area 36A May 21 , 2014, Room 56W, West Switchgear Area, Fire Area 36B May 28, 2014, Room 59, Pipe Penetration Area, Fire Area June 19 , 2014, Intake Structure, Fire Area For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's 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 four quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R 06 Flood Protection Measures (71111.06)
a. Inspection Scope
On April 29, 2014, the inspectors completed an inspection of the station's ability to mitigate flooding due to internal causes. After reviewing the licensee's flooding analysis, the inspectors chose two plant areas containing risk
-significant structures, systems, and components that were susceptible to flooding:
Corridor 4, Basement and Personnel Corridor Area Room 21, Safety Injection and Containment Spray Pump Area I
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 constitute completion of one flood protection measures sample as defined in Inspection Procedure 71111.06.
b. Findings
No findings were identified.
1R 07 Heat Sink Performance (71111.07)
a. Inspection Scope
The inspectors reviewed licensee programs to verify heat exchanger performance and operability for the following heat exchangers:
Raw Water/Component Cooling Water Heat Exchanger - AC-1B Shutdown Cooling Heat Exchanger - AC-4A Spent Fuel Pool Heat Exchanger - AC-8 The inspectors verified whether testing, inspection, maintenance, and chemistry control programs were adequate to ensure proper heat transfer. The inspectors verified that the periodic testing and monitoring methods, as outlined in commitments to NRC Generic Letter 89-13, utilized appropriate industry heat exchanger guidance. Additionally, the inspectors verified that the licensee's chemistry program ensured that biological fouling was properly controlled between tests. The inspectors reviewed previous maintenance records of the heat exchangers to verify that the licensee's heat exchanger inspections adequately addressed structural integrity and cleanliness of their tubes. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of three triennial heat sink inspection samples as defined in Inspection Procedure 71111.07-05.
b. Findings
No findings were identified.
1R 11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11)
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On April 17 , 2014, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators' critique of their performance.
These activities constitute 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 plant's main control room. At the time of the observations, the plant was in a period of heightened activity. The inspectors also assessed the operators' adherence to plant procedures, including conduct of operations procedure and other operations department policies. The inspectors observed the operators' performance of the following activities:
April 15, 2014, Technical Specification required shutdown due to inoperable control room air conditioning units May 12, 2014, Plant downpower to 90 percent power due to leaking gaskets in heater drain pump suction piping Reactor Plant power maneuvers to support power ascension on June 22 and 23, 2014 These activities constitute completion of three quarterly licensed operator performance sample s, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1R 12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
The inspectors reviewed two instances of degraded performance or condition of safety
-related structures, systems, and components (SSCs):
April 15, 2014, failure of control r oom air conditioning Unit VA
-46A May 2, 2014, charging Pump CH-1A packing failure
The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensee's corrective actions. The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensee's 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 two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
1R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
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:
April 3, 2014, risk management actions asso ciated with the turbine driven auxiliary feedwater Pump FW
-10 being out of service for maintenance April 29, 2014, risk management actions associated with the performance of OP-ST-ESF-009 , Channel "A" Safety Injection, Containment Spray and Recirculation Actuation Signal Test 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 licensee's risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.
In addition, on April 5, 2014, the inspectors also observed portions of one emergent work activities that had the potential to affect the functional capability of the Chemical and Volume Control System. Specifically, the inspectors observed portions of the emergent rebuild of the A Charging Pump, CH-1 A.
The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components (SSCs).
These activities constitute completion of three maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R 15 Operability Determinations and Functionality Assessments (71111.15)
a. Inspection Scope
The inspectors reviewed four operability determinations that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs):
April 15, 2014, operability determination of control room air conditioning Unit VA-46A after installation of a modification to bypass the low lube oil pressure switch April 23, 2014, operability determination of charging Pump CH
-1B May 2, 2014, operability determination of reactor coolant system Loop 1A charging line stop Valve HCV-238 June 4, 2014, operability determination of the auxiliary building while allowing access down the main access gate while under a tornado warning The inspectors reviewed the timeliness and technical adequacy of the licensee's evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensee's 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.
These activities constitute completion of four operability review samples, as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1R 19 Post-Maintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed five post
-maintenance testing activities that affected risk
-significant structures, systems, or components (SSCs):
May 23, 2014, post-maintenance testing following maintenance on Emergency Diesel Generator 1 (EDG
-1) June 2, 2014, post-maintenance testing following maintenance on the diesel driven auxiliary feedwater Pump, FW
-54 April 17, 2014, post-maintenance testing following maintenance on control room Air Conditioner VA-46A May 1, 2014, post-maintenance testing following maintenance on raw water piping June 6, 2014, post-maintenance testing following maintenance on raw water Strainer AC-12B 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 constitute completion of five post
-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R 22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors observed four 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:
May 1, 2014, Safety Injection System Category A and B Valve Exercise Test, OP-ST-3001 Other surveillance tests:
April 4, 2014, Component Cooling Water Pump Base Line Curve Procedure, SE-ST-CCW-3002 April 22, 2014, Quarterly Functional Test of Steam Generator Low Water Level Trip Units, IC
-ST-RPS-0014 April 10 , 2014, Channel Functional Test of Containment Pressure High Signal (CPHS) Switches 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 test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing. These activities constitute completion of four surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone:
1
EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed an emergency preparedness drill on May 13, 2014, to verify the adequacy and capability of the licensee's assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the technical support center, operations support center, simulator, emergency operations facility, and attended the post-drill critique. The inspectors verified that the licensee's emergency classifications, off
-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post
-drill critique and entered into the corrective action program for resolution.
These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone:
2 RS1 Radiological Hazard Assessment and Exposure Controls (71124.01)
a. Inspection Scope
The inspectors assessed the licensee's performance in assessing the radiological hazards in the workplace associated with licensed activities.
The inspectors assessed the licensee's implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. The inspectors walked down various portions of the plant and performed independent radiation dose rate measurements. The inspectors interviewed the Radiation Protection (RP) manager, RP supervisors, and radiation workers. The inspectors reviewed licensee performance in the following areas:
The hazard assessment program, including a review of the licensee's evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability Radiological hazards control and work coverage, including the adequacy of surveys, RP job coverage, and contamination controls, the use of electronic dosimeters in high noise areas, dosimetry placement, airborne radioactivity monitoring, controls for highly activated or contaminated materials (non
-fuel) stored within spent fuel and other storage pools, and posting and physica l
controls for high radiation areas and very high radiation areas Radiation worker and RP technician performance with respect to RP work requirements Audits, self
-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection These activities constitute completion of one sample of radiological hazard assessment and exposure controls as defined in Inspection Procedure 71124.01.
b. Findings
Introduction.
The inspectors reviewed a self-revealing, Green, non
-cited violation of Technical Specification 5.11.1.b, which resulted from the licensee's failure to control entry into a high radiation area (HRA) when an operator entered a posted HRA without knowledge of the dose rates. As a result, the operator received a high dose rate alarm upon entry into an area with greater than anticipated dose rates.
Description.
On July 19, 2013, an operator entered a posted HRA without adequate knowledge of the radiological conditions (dose rates) in the area. As a result, the electronic alarming dosimeter (EAD) worn by the operator alarmed due to a high dose rate. This unanticipated dose rate alarm was received while performing valve lineups on the 1013 foot elevation of the reactor building, 'B' steam generator (S/G) bay area. This work was performed while signed onto Radiation Work Permit (RWP) 11
-0020, Task 2, "OPS support (STs, walkdowns etc.)," with alarm setpoints of 35 millirem for dos e and 375 millirem per hour for dose rate. However, the inspectors determined that the operator should have been signed onto Task 1, "Valve Line
-Up and Tag Outs," to perform the specific duties of valve lineup; the Task 1 alarm setpoints were 30 millirem for dose and 150 millirem per hour for dose rate. Both tasks of RWP 11-0020 allowed access to an HRA, but only after being made knowledgeable of the dose rates in the areas to be entered.
An RP technician briefed the operator on the general area radiological conditions of the walk path for the job, but failed to provide detailed information on the work areas surrounding the walk path. Per discussion with the licensee, the operator informed the RP technician that he was performing valve lineup work in the 'B' S/G bay area, but he did not specify that he would veer from the walk path for which he was briefed. The RP technician briefed the operator of the radiological conditions using Survey M-20130625-5, dated June 25, 2013. The survey showed a maximum general area dose rate of 20 millirem per hour on the walk path of the 'B' S/G bay area. The operator veered from this path to access a valve atop the reactor coolant pump volute area, which was located a few feet away from the walk path below the shroud level of the pump. Upon entry to this area, he received a high dose rate alarm of 476 millirem per hour. As required, the operator stopped work and immediately exited the radiation controlled area (RCA) to inform RP of the alarming dosimeter. A follow-up survey, M-20130719-2, dated July 2013, was completed and showed a maximum of 1,000 millirem per hour on contact and 450 millirem per hour at 30 cm in this specific location.
The licensee determined in their investigation of the event that if better communication had occurred between the operator and RP technician performing the briefing, this issue could have been avoided. There are procedural requirements, developed and maintained for the purpose of radiological protection of personnel, which also could have also prevented this event. Section 7.12.3.A of Procedure RP
-204, "Radiological Area Controls," Revision 66, states, in part, that a briefing shall be conducted PRIOR to initial entry: (1) with the most recent survey data available, BRIEF workers on current radiological conditions in the work area and travel path; (2) INFORM the workers of areas to avoid; (3) BRIEF on EAD alarm settings and ENSURE they are adequate for the work area; and (4) ENSURE workers are aware of entry only to briefed HRAs. In addition, Section 4.5.3.B.1 of Procedure SO-G-101, "Radiation Worker Practices," Revision 39, states, in part, that entry into HRAs with an alarming dosimeter shall be made only after the dose rate level(s) in the area have been established and personnel have been made knowledgeable of the radiological conditions. These steps were not followed by either the RP technician or the operator. Records show that the radworker received a total of 9.9 millirem dose during the radiological controlled area (RCA) entry.
As immediate corrective actions, the RP supervisors coached the operator on properly informing RP of his planned work areas and coached the RP technician on having a more intrusive questioning attitude during briefings so that radworkers, in general, are properly informed of all hazards and radiological conditions. In addition to these immediate corrective actions, per discussion with the NRC inspectors, the licensee also planned to post more detailed surveys at the entrance to large areas posted as HRAs to better inform radworkers of the radiological conditions which they may encounter. This issue was documented in the licensee's corrective action program as Condition Report (CR) 2014-14693.
Analysis.
The entry into a HRA without knowledge of the radiological conditions is a performance deficiency and is a violation of Technical Specification 5.11.1.b. The performance deficiency is more than minor because it is associated with the Occupational Radiation Safety cornerstone attribute of program and process (exposure control) and adversely affects the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation. Additionally, this issue resembles IMC 0612, Appendix E, Example 6(h). Using Inspection Manual Chapter 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," dated August 19, 2008, the inspectors determined the violation has very low safety significance because: (1) it was not an as low as is reasonably achievable (ALARA) finding; (2) there was no overexposure; (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. This violation has a cross
-cutting aspect in the human performance area, associated with teamwork, because the operator did not properly communicate his work locations to the RP technician for briefing and the RP technician did not display a questioning attitude to understand the work locations for the operator to properly brief him and ensure nuclear safety was maintained (H.4).
Enforcement.
Technical Specification (TS)5.11.1.b states, in part, that any individual or group of individuals permitted to enter a HRA shall be provided with a radiation monitoring device which continuously integrates the radiation dose rates in the area and alarms when a preset integrated dose is received and that entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them. Contrary to the requirement of TS 5.11.1.b, on July 19, 2013, an operator entered a HRA with a radiation monitoring device (electronic alarming dosimeter), but was not knowledgeable of the dose rate levels in the area. Specifically, the operator veered from the walk path, on which he was briefed for a maximum dose rate level of 20 millirem per hour, and entered a HRA with dose rates of 450 millirem per hour at 30 cm. As a result, the operator received a high dose rate alarm of 476 millirem per hour on his EAD.
Because this violation is of very low safety significance and was entered into the licensee's corrective action program as CR 2014-14693 , this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy:
NCV 05000285/2014003-01: "Failure to Control an Entry to a High Radiation Area Resulting in a Dose Rate Alarm." 2 RS2 Occupational ALARA Planning and Controls (71124.02)
a. Inspection Scope
The inspectors assessed licensee performance with respect to maintaining occupationa l individual and collective radiation exposures as low as is reasonably achievable (ALARA). During the inspection, the inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:
Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site
-specific trends in collective exposures, and source-term measurements ALARA work activity evaluations/post-job reviews, exposure estimates, and exposure mitigation requirements The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man
-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry Radiation worker and RP technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas Audits, self
-assessments, and corrective action documents related to ALARA planning and controls since the last inspection
These activities constitute completion of one sample of occupational ALARA planning and controls as defined in Inspection Procedure 71124.02.
b. Findings
No findings were identified.
2 RS4 Occupational Dose Assessment (71124.04)
a. Inspection Scope
The inspectors evaluated the accuracy and operability of the licensee's personnel monitoring equipment, verified the accuracy and effectiveness of the licensee's methods for determining total effective dose equivalent, and verified that the licensee was appropriately monitoring occupational dose. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:
External dosimetry accreditation, storage, issue, use, and processing of active and passive dosimeters The technical competency and adequacy of the licensee's internal dosimetry program Adequacy of the dosimetry program for special dosimetry situations, such as declared pregnant workers, multiple dosimetry placement, and neutron dose assessment Audits, se lf-assessments, and corrective action documents related to dose assessment since the last inspection
These activities constitute completion of one sample of occupational dose assessment as defined in Inspection Procedure 71124.04.
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 Reactor Coolant System Specific Activity (BI01)
a. Inspection Scope
The inspectors reviewed the licensee's reactor coolant system chemistry sample analyses for the period of December 1, 2013, through March 31, 2014, 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 reactor coolant system specific activity performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Reactor Coolant System Total Leakage (BI02)
a. Inspection Scope
The inspectors reviewed the licensee's records of reactor coolant system total leakage for the period of December 1, 2013, through March 31, 2014, to verify the accuracy and completeness of the reported data. The inspectors observed the performance of OP-ST-RC-3001, Reactor Coolant System (RCS) Leak Rate Test on February 4, 2014. 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 reactor coolant system leakage performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Occupational Exposure Control Effectiveness (OR
01)
a. Inspection Scope
The inspectors verified 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, 2013, to March 31, 2014. 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.
.4 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, 2013, and March 31, 2014, 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 licensee's corrective action program and periodically attended the licensee's 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 licensee's 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 March 13, 2014, the inspectors assessed the licensee's operator work
-arounds to determine if the mitigating system function is affected or the operator's ability to implement abnormal and emergency operating procedures were affected. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate.
These activities constitute completion of one annual follow
-up sample, which included one operator work
-around sample, as defined in Inspection Procedure 71152.
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
.1 (Opened) Licensee Event Report
05000285/2014 00: Reactor Trip Due to Stator Water Cooling Leak During Maintenance On March 17, 2014, at 12:02 Central Daylight Time (C DT), a turbine trip, and subsequent reactor trip occurred while operating at nominal 100 percent power.
Maintenance was in progress on the main generator stator cooling system when system inventory was lost resulting in an automatic turbine trip due to low system pressure. Immediate response by operations personnel included implementing procedure emergency operating procedure (EOP)-00, Standard Post Trip Actions, and subsequent entry into Procedure EOP
-01, Reactor Trip Recovery. Based on plant system response this is considered an uncomplicated trip.
The station determined that the root cause of the plant trip was that operational risk was not effectively identified or mitigated by individuals throughout the organization.
The leak was isolated shortly after the trip by fully removing the probe and closing the isolation valve. Fort Calhoun Station will be implementing the Exelon Risk Management Procedure, WC
-AA-104, Integrated Risk Management. This procedure provides direction consistent with industry best practices, and requires individual review of each category of risk identification and mitigation.
.2 Operator Response During Unplanned Events
For the plant event listed below, the inspectors reviewed and observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant event to appropriate regional personnel.
The inspectors verified that Fort Calhoun made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Fort Calhoun's follow-up actions related to the event to assure that Fort Calhoun implemented appropriate corrective actions commensurate with their safety significance.
Operator conduct of a plant downpower to approximately 30 percent power to prepare for a potential plant shutdown due to rising Missouri river water level on June 20, 2014, and Fort Calhoun actions to ready the plant to mitigate the consequences of a significant flooding event from June 17 through June 22, 2014. These activities constitute completion of two event follow
-up sample s, as defined in Inspection Procedure 71153.
4OA4 IMC 0350 Inspection Activities
On December 17, 2013, the Nuclear Regulatory Commission issued a Confirmatory Action Letter to Fort Calhoun Station (ML13351A395). The Confirmatory Action Letter confirms the commitments in the December 2, 2013, Omaha Public Power District (OPPD), "Integrated Report to Support Restart of Fort Calhoun Station and Post
-Restart Commitments for Sustained Improvement." In the report, OPPD committed to take actions following restart of the Fort Calhoun Station to ensure the improvements realized during the extended outage remain in place and performance continues to improve at the facility. Included in the commitments are completing actions detailed in the Flooding Recovery Action Plan.
Flood Recovery Action Item Plan 1.2.3.21, Inspect tank and equipment on demineralized water tank for damage
a. Inspection scope
A water filled barrier was installed prior to the 2011 flood to protect the Deionized (DI) Water Storage Tank and its associated utility building. Due to excessive stress on the barrier in the tight installation configuration, the barrier failed and the tank was exposed to flood water for several months.
A structural assessment of the DI Water Tank was conducted. The inspectors reviewed the structural assessment, and performed visual inspection of the tank and concluded that there was no damage to the tank or associated utility building.
The inspectors previously performed a review of the Demineralized and Potable Water Systems. The scope of these reviews determined that the only equipment affected were to the Reverse Osmosis Unit Water Storage Tank Inlet and Outlet Pumps, DW
-69, and DW-70. These pump motors were damaged after being submerged in flood waters. These pump motors were replaced in accordance with Flood Recovery Action Plan items 2.3.1.13, 2.3.1.14, 2.3.1.15, and 2.3.1.16, and documented in Inspection Report 05000285/2012004 (ML 12276 A 456).
This activity constitutes completion of action item 1.2.3.21 as described in the Flood Recovery Action Plan and the December 17, 2013 Confirmatory Action Letter.
b. Findings
No findings were identified.
4OA5 Other Activities
1. Temporary Instruction 2515/182 - Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks
a. Inspection scope
Leakage from buried and underground pipes has resulted in groundwater contamination incidents with associated heightened NRC and public interest. The industry issued a guidance document, NEI 09
-14, "Guideline for the Management of Buried Piping Integrity," (ML1030901420) to describe the goals and required actions (commitments made by the licensee) resulting from this underground piping and tank initiative.
On December 31, 2010, NEI issued Revision 1 to NEI 09 14, "Guidance for the Management of Underground Piping and Tank Integrity," (ML110700122) with an expanded scope of components which included underground piping that was not in direct contact with the soil and underground tanks. On November 17, 2011, the NRC issued Temporary Instruction 2515/182, "Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks," to gather information related to the industry's implementation of this initiative.
b. Observations The licensee's buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.a of the Temporary Instruction and it was confirmed that activities which correspond to completion dates specified in the program which have passed since the Phase 1 inspection was conducted, have been completed.
Additionally, the licensee's buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.b of the Temporary instruction and responses to specific questions were submitted to the NRC headquarters staff. Based upon the scope of the review described above, Phase II of TI
-2515/182 was completed.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On April 24, 2014, the inspectors presented the radiation safety inspection results to Mr. M. Prospero, Plant Manager, 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. One document, which remained in the possession of an NRC inspector, was identified as proprietary after we left site. The NRC inspector informed the licensee that this document was later identified as proprietary and the licensee informed the NRC inspector to shred the document. Thus, the proprietary document was shredded in an official security waste bin at the NRC office.
On May 6, 2014, t he inspec tor presen t ed t he re sults o f Temporary Inspection 2515/182, "Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks
," to Mr. M. Prospero, and othe r members of your staff. T he li censee ack nowl ed g ed t he issues presented. T he insp ector ask ed t he licensee w he t her any materials exami ned duri ng t he inspecti on shou l d be cons i de r ed proprietary. The proprietary info rmati on i dentified was deleted from the NRC computer.
On June 12, 2014, the inspectors presented the final inspection results Mr. E. Dean, Plant Manager and other members of the licensee's staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
On July 16, 2014, the inspectors presented the inspection results for the Heat Sink Performance Inspection to Mr. E. Dean, Plant Manager, 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
- S. Anderson, Manager, Design Engineering
- D. Bakalar, Manager, Security
- J. Bousum, Manager, Emergency Planning and Administration
- D. Brehm, Engineer, Radiation Protection
- C. Cameron, Supervisor Regulatory Compliance
- L. Cherko, Health Physicist
- L. Cortopassi, Site Vice President
- S. Coufal, Health Physicist
- E. Dean, Plant Manager
- E. Durboraw, Health Physicist, Radiation Protection
- M. Ferm, Manager, System Engineering
- H. Goodman, Site Engineering Director
- P. Gunderson, Supervisor, Radiological Operations
- S. Hamm, Unit Supervisor
- R. Hugenroth, Supervisor Nuclear Oversight
- K. Ihnen, Manager, Site Nuclear Oversight
- P. Kellogg, Supervisor, ALARA
- J. Lindsey, Director, Training
- D. Little, Rad Health Specialist
- K. Maassen, Program Engineer, GL 89
-13
- T. Maine, Manager, Radiation Protection
- E. Matzke, Senior Licensing Engineer
- W. McCall, Health Physicist, Radiation Protection
- J. McManis, Manager Engineering Programs
- B. Obermeyer, Manager, Corrective Action Program
- T. Orth, Director, Site Work Management
- D. Pier, Shift Manager
- M. Prospero, Plant Manager
- S. Shea, Supervisor, Operations Training
- T. Simpkin, Manager, Site Regulatory Assurance
- M. Stewart, Sr. Radiation Protection Technician
- S. Swanson, Director, Operations
- D. Whisler, Supervisor, ALARA
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
-003-00 LER Reactor Trip Due to Stator Water Cooling Leak During Maintenance
(Section 4 OA 3) Closed 2515/182 TI Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks
Opened and Closed
-01 NCV Failure to Control an Entry to a High Radiation Area Resulting in a Dose Rate Alarm
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Procedures
- Number Title Revision
- AOP-1 Acts of Nature
- NOD-PP-M-4 Severe Weather Procedure
- O P-AA-108-111-1001 Severe Weather and Natural Disaster Guidelines
- EPIP-TSC-2 Catastrophic Flooding Preparations
- SY-AA-101-146 Severe Weather Preparation and Response
- SY-FC-101-146-AD-WEA Severe Weather Preparation and Response (FCS Specific) 0 T
- BD-EPIP-OSC-1 H Recognition Category H
- Hazards and Other Conditions Affecting Plant Safety
- PE-RR-AE-1003 Preparation of Station Non
-Vital Assets for External Flooding 0
- PE-RR-AE-1001 Flood Barrier and Sandbag Staging and Installation
Condition Reports
- 2014-07489
Section 1R04: Equipment Alignment
Procedures
- Number Title Revision
- AOP-1 Acts of Nature
- OI-DG-2 Diesel Generator No.
- 69
- OI-SFP-1 Spent Fuel Pool Cooling Normal Operation
- SDBD-AC-SFP-102 Spent Fuel Storage and Fuel Pool Cooling 24
Condition Reports
- 2011-10302
Drawings
- Number Title Revision 11405-M-11 Auxiliary Coolant Spent Fuel Pool Cooling System Flow Diagram P&ID
- 11405-M-257 Composite Flow Diagram Circulating Water P&ID
- Section 1 RO 5:
- Fire Protection
Procedures
- Number Title Revision
- OP-MW-201-0007 Fire Protection System Impairment Control
- SO-G-102 Fire Protection Program Plan
- SO-G-103 Fire Protection Operability Criteria and Surveillance Requirements
- SO-G-28 Station Fire Plan
- SO-G-91 Control and Transportation of Combustible Materials
Miscellaneous Documents
- Number Title Revision
- EA-FC-97-001 Fire Hazards Analysis Manual
- FC 05814 UFHA Combustible Loading Calculation
- USAR 9.11 Updated Safety Analysis Report, Fire Protection Systems 24
Section 1R06: Flood Protection Measures
Procedures
- Number Title Revision
- EA 08-010 Internal Flooding
Condition Reports
- 2007-2715 2007-3670 2008-3492
Section 1R07: Heat Sink Performance
Calculations
- Number Title Revision
- FC 05660 Check of CCW Flow Model Against Measured Data
- FC 05664 Determination of Raw Water Flows to CCW Heat Exchanger Performance
- FC 05693 Component Cooling Water System Design Heat Loads and Flows 1
- FC 05742 Acceptance Criteria for CCW Heat Exchanger Performance 0
- FC 05789 CCW System Design Basis Performance Criteria
- FC 05888 Raw Water Flows to CCW Heat Exchangers
Miscellaneous
- Number Title Date
- RA 2014-1214 Fort Calhoun Pre
-NRC Triennial Heat Sink Inspection June 6, 2014
- Certificate of Calibration Flow Meter No. MT
-22700 May 19, 2011
- Certificate of Calibration Flow Meter No. MT
-22701 November 30, 2011
- Certificate of Calibration Flow Meter No. MT
-22706 April 15, 2013
- Component Cooling Water System Health Report March 14, 2014
- Raw Water System Health Report March 14, 2014
- Service Water System Health Report March 14, 2014
- Vendor Documents Title Revision
- Instruction Manual for Component Cooling Heat Exchangers Instruction Manual for Shutdown Heat Exchangers Instruction Manual for Storage Pool Heat Exchangers
Procedures
- Number Title Revision/Date
- CH-AD-0035 Microbiologically Induced/Influenced Corrosion Monitoring Program
- 3
- CH-AD-0048 Environmental Inspection for Biofouling Organisms
- IC-CP-01-AI-96 Calibration of Component Cooling Water and Raw Water Outlet From Heat Exchanger AC
-1A/B/C/D 1
- NOD-OP-N-3 Strategic Water Plan
- OP-ST-RW-3001
- AC-10A Raw Water Pump Quarterly Inservice Test
- OP-ST-RW-3011
- AC-10B Raw Water Pump Quarterly Inservice Test
- OP-ST-R W-3021
- AC-10C Raw Water Pump Quarterly Inservice Test
- OP-ST-RW-3031
- AC-10D Raw Water Pump Quarterly Inservice Test
- PBD-17 Service Water Reliability
- PED-SEI-16 Evaluation of Heat Exchanger Performance
- PE-RR-CCW-0100 Disassembly, Cleaning, and Repair of Component Cooling Water Heat Exchanger
- Raw Water Side April 8, 2014
- PE-RR-CCW-0101 Removal and Reinstallation of Shutdown Cooling Heat Exchanger Heads
- SDBD-AC-CCW-100 Component Cooling Water
- SDBD-AC-RW-101 Raw Water 39
- SDBD-AC-SFP-1 02 Spent Fuel Storage and Fuel Pool Cooling
- SDBD-SI-130 Shutdown Cooling
- SE-PFT-CCW-0001 Component Cooling Water Heat Exchangers Performance Testing December 29, 2012
- USAR-9.3 Auxiliary Systems
- Shutdown Cooling System
- USAR-9.6 Auxiliary Systems - Spent Fuel Pool Cooling System
Procedures
- Number Title Revision/Date
- USAR-9.7 Auxiliary Systems
- Component Cooling Water System
- USAR-9.8 Auxiliary Systems
- Raw Water System
Condition Reports
- 2011-05215 2011-07340 2011-09401 2011-09401 2011-09477 2012-00735 2012-03097 20 12-05663 2012-06497 2012-08288 2012-08289 2012-09565 2012-09570 2012-11617 2012-12984 2012-13312 2012-18305 2013-04538 2013-04540 2013-04542
Work Orders
- 175833
- 175833
- 188897
- 188897
- 201320
- 201320
- 248454
- 248454
- 386035
- 396226
- 408766
- 449032
- 462250 47024 3
- 477978
- 495067
- 496412
- 496609
- 497665 498870
Section 1R11: Licensed Operator Requalification Program and Licensed Operator Performance
Procedures
- Number Title Revision
- EOP/AOP Floating Steps
a
- AOP-05 Emergency Shutdown
- AOP-22 Reactor Coolant Leak 34
- EOP-00 Standard Post Trip Actions
- EOP-04 Steam Generator Tube Rupture
- EOP-05 Uncontrolled Heat Extraction
- EPIP-OSC-1 Emergency Classifications
a
- EPIP-OSC-2 Command and Control Position Actions/Notifications
- OI-EE-1 Normal Operation of 4160 Volt System
a
- OP-3 A Plant Shutdown
- SO-G-105 Steam Generator Tube Leakage
a
- SO-O-1 Conduct of Operations
- 104
- SO-R-1 Reportability Determinations
Miscellaneous Documents
- Number Title Revision
- Cycle 2014-02 As Left Evaluation Simulator Fidelity 2014 Cycle 2
Section 1R12: Maintenance Effectiveness
Procedures
- Number Title Revision
- FCSG-69 Maintenance Rule Implementing Instructions (MRII)
- FCSG-69-5 Failure Identification and Reporting
- FCSG-69-6 Placement of SSCs into Category (a)(1), Goal Setting, and Return of SSCs to Category (a)(2) 0
- FCSG-69-7 Periodic Assessment
- PBD-16 Maintenance Rule Program Basis Document
a
- PED-SED-34 Maintenance Rule Program 9
- SDBD-VA-CR-140 Control Room Habitability
a
- USAR-9.10 Heating, Ventilating
, and Air Conditioning System
Condition Reports
- 2011-1316 2011-1452 2011-2259 2011-2261 2011-5466 2011-7616 2012-04590 2014-04797 2014-05004 2014-05577 2014-06387
Miscellaneous Documents
- Title Revision/Date Functional Scoping Data Sheet for Control Room Air Conditioning Status of Equipment in MR Category (a)(1) or (a)(1) review April 2 , 2014
Section 1R13: Maintenance Risk Assessments and Emergent Work
- Control
Procedures
- Number Title Revision
- FCSG-19 Performing Risk Assessments
- MM-RR-CH-0001 Inspection and Repair of Charging Pump Hydraulic Section
- OP-ST-ESF-009 Channel A Safety Injection, Containment Spray
, and Recirculation Actuation Signal Test 59 a
Procedures
- Number Title Revision
- SO-M-100 Conduct of Maintenance
b
- SO-M-101 Maintenance Work Control
- 103
- NUMARC-93-01 Industry Guidance for Monitoring the Effectiveness of Maintenance At Nuclear Power Plants
a Regulatory Guide 1.160 Monitoring the Effectiveness of Mainten ance at Nuclear Power Plants
Section 1R15: Operability Determinations and Functionality Assessments
Procedures
- Number Title Revision
- OP-FC-108-115 Operability Determinations
a
- SDBD-CH-108 Chemical and Volume Control Systems
- UAS-9.2 Chemical and Volume Control System
Condition Reports
- 2014-05026 2014-05501 2014-05577 2014-06093 2014-06785
Section 1R19:
- Post
-Maintenance Testing
Procedures
- Number Title Revision
- MM-PM-DG-0001 Diesel Generator DG
-1 Inspection
- OP-PM-AFW-0004 Third Auxiliary Feedwater Pump Operability Verification
Work Orders
- 345936
- 504052
- 509872
- 510831
- 517327 522553
Section 1R22: Surveillance Testing
Procedures
- Number Title Revision
- IC-ST-ESF-0004 Channel Functional Test of Containment Pressure High Signal (CPHS) Switches
a
Procedures
- Number Title Revision
- IC-ST-RPS-0014 Quarterly Functional Test of Steam Generator Low Water Level Trip Units
- OP-ST-SI-3001 Safety Injection System Category A and B Valve Exercise Test 37 a
- SE-ST-CCW-3002 CCW Pump Base Line Curve Procedure
Work Orders
- 498231 510757
Section 1EP6: Drill Evaluation
Procedures
- Number Title Revision
- AOP-6 Fire Emergency
a
- EPIP-EOF-7 Protective Action Guidelines
- EPIP-OSC-1 Emergency Classifications
a
- EPIP-OSC-2 Command and Control Position Actions/Notifications
- EPIP-OSC-9 Emergency Team Briefings
Miscellaneous Documents
- Title Date Scenario Manual Volume Training Drill May 13, 2014
Condition Reports
- 2014-5960 2014-5961 2014-5972 2014-5993 2014-5994 2014-6051 2014-6054
Section 2RS1: Radiological Hazard Assessment and Exposure Controls
Procedures
- Number Title Revision
- RP-202 Radiological Surveys
- 044
- RP-204 Radiological Area Controls
- 066
- RP-206 Radioactive Material Handling
- 2
Section 2RS1: Radiological Hazard Assessment and Exposure Controls
Procedures
- Number Title Revision
- RP-229 Changes in Radiological Conditions Due to Plant Evolutions
- 001
- RP-306 Hot Spot Identification and Tracking
- 21
- RP-307 Use and Control of Temporary Shielding
- 21
- RP-405 Radioactive Source Inventory Control
- 016
- RP-AD-200 Radiation Protection Surveillance Program
- 036
- Radiation Protection Plan
- 29
- RP-ST-RM-0002 Radioactive Material Sources Surveillance
- 008
- SO-G-01 Radiation Worker Practices
- 039
- SO-O-47 Spent Fuel Pool Inventory Control
- 009
- Audits, Self
-Assessments, and Surveillances Number Title Date
- RA-2013-2241 Radiation Protection Audit Report: Audit NOSA
-FCS-13-58 July 27 , 2013
- Radiological Surveys Number Title Date M-20130625-5 'B' S/G Walkway, Elevation
- 1013' June 25, 2013
- M-20130719-2 'B' S/G Walkway, Elevation
- 1013' Post Survey July 19, 2013
- M-20131119-5 Containment, Elevation
- 994' November 19, 2013
- M-20140307-2
- AUX 1007/Room 31, Source Storage March 7, 2014
- M-20140310-3 RW Building Room, Room
- 509 March 10, 2014
- M-20140416-6
- AUX 1025/Room 3, Spent Fuel Pool April 16 , 2014
Condition Reports
- 2012-0073 4 2013-02595 2013-12045 2013-13938 2013-13531 2013-14124 2013-14258 2013-14472 2013-14652 2013-14693 2013-15026 2013-15029 2013-16119 2013-16705 2013-17201 2013-17323 2013-20766 2013-21217 2014-01875 2014-05225
- Radiation Work Permits Number Title Revision Radiation Work Permits Number Title Revision 11-0020 Operations Support for the 2011
- RFO 00
- 14-0100 Minor Maintenance in Radiation Areas (no System Breaches)
- 02 14-2201 Waste Disposal Maintenance in Radiation Areas and High Radiation Areas
- 14-2203 SI/AC Maintenance in Radiation Areas and in High Radiation Areas
, and FP Maintenance in Radiation Areas and High Radiation Areas
- 14-2208 DTS Maintenance and Waste Processing
- 14-2209
- Post Outage Recovery
- 14-3304 Minor Maintenance in RHRAs of the Auxiliary/Radwaste Buildings
- 01 14-3307 Regulatory Inspections
Miscellaneous Documents
- Number Title Date 6080 2014 National Source Tracking System
- Annual Inventory Reconciliation
- January 14 , 2014
- FC-1217 Non-Fuel Material Spent Fuel Pool Inventory Ledger October 2013
- FC-RP-ST-RM-2 Radioactive Source Inventory and Leak Test November 12 , 2013
Section 2RS2: Occupational
- ALARA Planning and Controls
Procedures
- Number Title Revision
- RP-212 Diving Operations within Radiologically Controlled Areas
- RP-AA-400-2000 Department Dose Zealot
- RP-AD-300 ALARA Program
- 28a
- SO-G-116 Station ALARA Program
Condition Reports
- 2013-12805 2013-12891 2013-13277 2013-13394 2013-13401 2013-13531 2013-13544 2013-14124 2013-14125 2013-14666
- 2013-15805 2013-15854 2013-15961 2013-16020 2013-16354 2013-16378 2013-17135 2013-17150 2013-17489 2013-18601 2013-19791 2013-20016 2013-20121 2013-20419 2013-20592 2013-20858 2013-21334 2013-22928 2014-00486 2014-00872 2014-00918 2014-01528 2014-01692 2014-01875 2014-02366 2014-02525 2014-02526 2014-02527 2014-02891 2014-03355 2014-04982 2014-05055 2014-05056 2014-05057 2014-05058 2014-05062 2014-05208
- Radiation Work Permits Number Title Revision 12-2201 SI/AC System Maintenance in High Radiation Area
- 13-2552 Replace Union Attached to bottom of CH
- 208 and
- Associated Tasks
- 13-2565
- RC-3C Seal Piping Supports and Associated Tasks
- 13-3554 Upper Guide Structure Underwater Modifications and Associated Tasks
- 0 14-2201
- Waste Disposal Maintenance in Radiation Areas and High Radiation Areas
- 14-2201
- Waste Disposal Maintenance in Radiation Areas and High Radiation Areas
- 14-2201
- Waste Disposal Maintenance in Radiation Areas and High Radiation Areas
- 2 14-2202 CVCS Maintenance in Radiation Areas and High Radiation Areas
- 0 14-2202 CVCS Maintenance in Radiation Areas and High Radiation Areas
- 1 14-2202 CVCS Maintenance in Radiation Areas and High Radiation Areas
- 2 14-2203 SI/AC Maintenance in Radiation Areas and High Radiation Areas
- 0 14-2203 SI/AC Maintenance in Radiation Areas and High Radiation Areas
- 1 14-2208 DTS Maintenance and Waste Processing
- ALARA Work Control Plans Number Title Date
- RWP 12-2201 SI/AC System Maintenance in High Radiation Areas November 10 , 2011
- 208 and Associated Tasks
- March 20 , 2013
- RWP 13-2565
- RC-3C Seal Piping Supports and Associated Tasks October 18 , 2013
- RWP 13-3554 Upper Guide Structure Underwater Modifications and Associated Tasks August 2 , 2013
- RWP 14-2201 Waste Disposal Maintenance in Radiation Areas and High Radiation Areas December 4 , 2013
- RWP 14-2201 Waste Disposal Maintenance in Radiation Areas and High Radiation Areas January 6 , 2014
- RWP 14-2201 Waste Disposal Maintenance in Radiation Areas and High Radiation Areas February 24 , 2014
- RWP 14-2201 Waste Disposal Maintenance in Radiation Areas and High Radiation Areas March 4 , 2014
- RWP 14-2202 CVCS Maintenance in Radiation Areas and High Radiation Areas
- December 4 , 2013
- RWP 14-2202 CVCS Maintenance in Radiation Areas and High Radiation Areas
- February 27 , 2014
- RWP 14-2203 SI/AC Maintenance in Radiation Areas and High Radiation Areas
- December 4 , 2013
- RWP 14-2203 SI/AC Maintenance in Radiation Areas and High Radiation Areas
- January 6 , 2014
- RWP 14-2208 DTS Maintenance and Waste Processing January 17 , 2014
- Work in Progress Reviews Number Title Date 1
- RWP 13-2552 Replace Ch
- 208 Union
- October 26 , 2013 2
- RWP 13-2552 Replace Ch 208 Union November 9 , 2013 1
- RWP 14-2202 CVCS Maintenance in Radiation Areas and High Radiation Areas April 9 , 2014
- ALARA Work Control Plans Number Title Date 1
- RWP 14-2201 Waste Disposal Maintenance February 20 , 2014 2
- RWP 14-2201 Waste Disposal Maintenance April 9 , 2014 1
- RWP 13-3554 Upper Guide Structure Underwater Modifications and Associated Tasks August 14 , 2013
- Radiological Surveys Number Title Date M-20130729-3 Lower cavity July 29, 2013
- M-20130730-2 Lower cavity July 30, 2013
- M-20130801-1 Lower cavity August 1, 2013
- M-20130801-2 Lower cavity
- August 1, 2013
- M-20130808-1 Upper cavity August 8, 2013
- M-20130808-2 Upper cavity August 8, 2013
Miscellaneous Documents
- Number Title Date
- Fort Calhoun Nuclear Station
- 2014-2018 Dose Excellence Plan
- 13-NOS-087 Radiation Protection Audit Report Audit NOSA
-FCS-13-58 July 27 , 2013
Section 2RS4: Occupational Dose Assessment
Procedures
- Number Title Revision/Date
- CH-ST-RV-0010 Environmental Monthly Progress Report Receipt
- FC-RP-605-1 Exposure Evaluation Report
- FCSG-24-1 Condition Report Initiating
- FCSG-24-3 Condition Report Screening
a
- IC-CP-02-0229 Calibration of MGP Telepole
- IC-CP-07-008 Calibration of Eberline PM
a
Procedures
- Number Title Revision/Date
- OP-ST-SI-3003 LP Safety Injection and Containment Spray System Pump and Check Valve Test
- June 14 , 2013
- RP-203 Air Sample Collection and Analysis
- RP-204 Radiological Area Controls
- RP-205
- DAC-Hour Tracking
- RP-602 Personnel Dosimetry Issuance and Changeout
- RP-605 TLD and Exposure Evaluation Reports
- RP-606 Special Dosimetry Issue, Control and Use
- RP-650 Internal Dosimetry Program
- RP-670 Declared Pregnancy/Anticipated Pregnancy Procedure
- RP-910 Radiological Risk Assessment
- RP-AD-200 Radiation Protection Surveillance Program
- RP-AD-600 Dosimetry Program 22
- RPG-037 Radiation Protection Outage Guideline
- RPG-071 Human Performance Tool for Investigating Dosimeter Alarms
- RPI-6 Alternate Access Control of Radiologically Controlled Area February 16 , 2006
- RPP Radiation Protection Plan
- RW-218 10CFR 61 Classification
- SO-G-101 Radiation Worker Practices
- TQG 19-27-17 Task Qualification Guide
- Radiation Contamination Guide
Condition Reports
- 2012-19508 2013-15026 2014-04927 2011-9947 2012-01086 2012-02171 2012-02483 2012-02950 2012-10913 2012-13074 2012-19142 2013-02498 2013-03542 2013-04833 2013-13416 2013-14121 2013-14651 2013-14661 2013-17225 2013-18776 2013-20292 2014-01126
Miscellaneous Documents
- Number Title Revision/Date National Voluntary Laboratory Accreditation Program
- 2014
- TLD Exposure Record Read Results
- 13-008 Personnel Contamination Report
- EA-FC-92-071 Engineering Analysis 10CFR20 Revision Bioassay Program Recommendations
- October 13 , 1992
- RA-12-002 Evaluation of Instrument Response to Measured Plant Radionuclide Mix
Section 4OA1: Performance Indicator Verification
Procedures
- Number Title Revision
- CH-ANL-RA-0018 Determination of Gamma Isotopic Activity Using Canberra APEX System
- CH-ST-RC-0003 Reactor Coolant DEI Activity
- NOD-QP-37 Performance Indicator Program
- NOD-QP-40 NRC Performance Indicator Program
- OP-ST-RC-3001 Reactor Coolant System (RCS) Leak Rate Test
Miscellaneous Documents
- Number Title Revision
- Control Room Logs from 12/1/13 through 3/31/14
- NEI 99-02 Regulatory Assessment Performance Indicator Guideline
Condition Reports
- 2014-05066
Section 4OA2: Problem Identification and Resolution
Procedures
- Number Title Revision
- FCSG-24-1 Condition Report Initiation
- FCSG-24-10 Corrective Action Program Trending 5
Procedures
- Number Title Revision
- FCSG-24-3 Condition Report Screening
- 2a
- FCSG-24-4 Condition Report and Cause Evaluation
- 8a
- FCSG-24-5 Cause Evaluation Manual
- 7a
- FCSG-24-6 Corrective Action Implementation and Condition Report Closure 12a
- SO-R-2 Condition Reporting and Corrective Action
- 53b
Section 4OA3:
- Follow
-up of Events and Notices of Enforcement Discretion
Procedures
- Number Title Revision
- FCSG-23 10
- CFR 50.59 Resource Manual
- EPIP-TSC-2 Catastrophic Flooding Preparations
- AOP-1 Acts of Nature
- IC-CP-01-50 43 Calibration of Stator Cooling Water System Conductivity Elements and Recorder
- NOD-QP-3 10
- CFR 50.59 and 10
- CFR 72.48 Reviews 37
- SO-R-1 Reportability Determinations
- TDB-EPIP-OSC-11 T Hazards and Other Conditions Affecting Plant Safety Emergency Levels 2
Condition Reports
- 2014-03381
Miscellaneous Documents
- Number Title Revision 50214 Reactor Plant Event Notification
- AOP-1 Technical Specification 2.16 River Level
- S ec ti on 4OA5:
- Other Activities
Miscellaneous
- D o c u m en t s N u mber T i t le Revision W.O.
- 00472098 Annual FCS Cathodic Protection Survey & Repair
- OP-ST-RW-3001 Ac-10a Raw Water Pump Quarterly lnservice Test
- OP-ST-RW-3021 Ac-10c Raw Water Pump Quarterly lnservice Test
- OP-ST-RW-3031 Ac-10 d Raw Water Pump Quarterly lnservice Test
- FCS Program Health Reports Buried Piping and Components
(Various)
- BP Works 2.0 Updated Buried Piping Database Results January 29, 2014
Condition Reports
- 2014-05665 2012-08509 2012-06064 2008-5517
- Pr ocedure s N u mber T i t le Rev i s io n P
- BD-28 Buried Piping and Components
- PBD-28 Attachment A
- G-Scan TM /B
-Scan Assessment of Various Piping Systems
- PBD-28 Attachment B
- Condition Assessment
- Water Service Pipeline
- OPPD038-FCS-BPI-001 Buried Pipe Program
- BPWORKSŽ Document
- PED-GEI-8 4 Buried Piping and Components External Inspection
- PED-GEI-84.1 Buried Piping and Components External Inspection
- T he fo llowi ng items are reques t ed for t he
- TI 2515-182 Phase 2 Inspection at Fort Calhoun Stati on
- Please provi de t he request ed informati on on or before January 31, 2014.
- Inspection Dates:
- To Be Determined
- Inspection Procedures:
- TI 2515-182, "Review of Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks"
- If y ou have any q uestions or c o mments, p lease c on tact
- Inspector:
- Peter Jayroe (817) 200
-1174, peter.jayroe@nrc.gov The following information should be sent to the Region IV office in hard copy or electronic format (ims.certrec.com preferred), in care of Peter Jayroe, by January 31, 2014, to facilitate the preparation for the inspection.
- Please provide requested documentation electronically if possible.
- If requested documents are large and only hard copy formats are available, please inform the inspector(s), and provide subject documentation during the first day of the onsite inspection.
- If you have any questions regarding this information request, please call the inspector as soon as possible.
- This le tter does not contain new or ame nded info rmati on co ll ecti on requirem ents subject to t he P aperwork R educ ti on A ct of 1995 (44 U.S.C. 3501 e t seq.).
- Existi ng information co ll ecti on requirem ents were approv ed by t he Office of M
anagement and B udget, Control number 3150-00 11.
- 1. Organization list of site individuals responsible for the site's underground piping and tanks program.
- 2. Copy of Site Underground Piping and Tanks program.
- 3. Please review the attached "Questions" list and provide the response and/or document requests.
- 4. Schedule for the completion of the following NEI 09
-14 Rev.1 attributes:
- Buried Piping
Procedures
and Oversight Risk Ranking Inspection Plan Plan Implementation Asset Management Plan
- Underground Piping and Tanks
Procedures
and Oversight Prioritization Condition Assessment Plan Plan Implementation Asset Management Plan
- 5. Location maps of buried & underground piping and tanks as requested by the inspector.
- 6. Self or third party assessments of the Underground Piping and Tanks Program (if any have been performed).
- 7. For any of the NEI 09
-14 Rev.1 attributes identified below which have been completed prior to the NRC's onsite inspection, provide written records that demonstrate that the program attribute is complete.
- Buried Piping
Procedures
and Oversigh
t
- Risk Ranking Inspection Plan Plan Implementation Asset Management Plan
- Underground Piping and Tanks
Procedures
and Oversight Prioritization Condition Assessment Plan Plan Implementation Asset Management Plan
- Q ues t i ons R esponse I n i ti a ti v e C ons i s t e n cy H as t he licensee t aken a ny de v i a t i ons t o eit her o f t he initiatives? Y es / N o
- I f so, w hat de v i a t i ons ha v e been t a ken and w hat is (are) t he basis for these deviations? P ro v i de documen t a ti on of de v i a ti ons and any associat ed corre c tive ac ti on report s. D oes t he licensee ha v e an ons i t e b u r ied pipi ng progr am m anager (ow ner) and, po t entia lly, a sta ff? Y es / N o
- H ow m any bu r i ed p i p i ng p r o g r a m o w ne r s have t here been since January 1, 2010? P ro v i de documen t a ti on i de n t i f y i ng i nd i v i dua l s responsible for t he s ite bur i ed pipi ng progr a m si nce January 1, 2010. H ow m any o t her s i t e p r o g r a m s a r e assig ned to t he buri ed pipi ng program o w ne r? L ist a l l s it e progr a ms t hat are under t he d irect responsibility of t he site's buri ed piping program
o w n e r. D oes t he li censee ha v e r e q u i r e m en t s t o capture program perfo rmance, such as syst em health r eports and performance i ndicators? Y es / N o
- P rovi de cop i es of most recent systems healt h repor t s i f ap p li ca b l e A r e t h e se r e q u i r e m e n t s pe r i od i c or e vent driv en? P e r i od i c / E v ent D r i v en / N one A r e t h e r e e x a m p l es w he r e these requirements have been successfu lly used to upgr ade pipi ng systems o r t o avert pipi ng or tank leaks?
- Y es / N o
- P rovi de documenta ti on relat ed to exampl es i f app li ca b l e D oes t he licensee ha v e a p r o g ram or procedure to confir
m t he as-bu ilt locati on of buri ed and undergrou nd pipi ng and tanks a t t he pl ant? Y es / N o
- H a s th e li c en s e e u s e d th i s p r o g r a m? Y es / N o
- W a s t he p r o g r a m e f f ec t i v e i n i den t i f y i ng Y es / N o
- SUNSI Review By: ADAMS:
- Yes
- No
- Sensitive
- Non-Sensitive
- Non-Publicly Available Publicly Available Keyword
- DRP F/C: NAME PJayroe HGepford
- MHay SIGNATURE /RA/ /RA/ /RA/ DATE 8/21/14 8/25/14
- 8/27/14
- Letter to Louis P. Cortopassi from Michael C. Hay dated, August
- 27, 2014
- SUBJECT: ERRATA FOR FORT CALHOUN STATION - NRC INTEGRATED INSPECTION REPORT 05000285/2014003