IR 05000482/2018001: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
(14 intermediate revisions by the same user not shown)
Line 2: Line 2:
| number = ML18131A017
| number = ML18131A017
| issue date = 05/14/2018
| issue date = 05/14/2018
| title = Wolf Creek Generating Station - NRC Integrated Inspection Report 05000482/2018001
| title = NRC Integrated Inspection Report 05000482/2018001
| author name = Taylor N H
| author name = Taylor N
| author affiliation = NRC/RGN-IV/DRP/RPB-B
| author affiliation = NRC/RGN-IV/DRP/RPB-B
| addressee name = Heflin A C
| addressee name = Heflin A
| addressee affiliation = Wolf Creek Nuclear Operating Corp
| addressee affiliation = Wolf Creek Nuclear Operating Corp
| docket = 05000482
| docket = 05000482
| license number = NPF-042
| license number = NPF-042
| contact person = Taylor N H
| contact person = Taylor N
| document report number = IR 2018001
| document report number = IR 2018001
| document type = Inspection Report, Letter
| document type = Inspection Report, Letter
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:May 14, 2018
[[Issue date::May 14, 2018]]


Mr. Adam C. Heflin, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839
==SUBJECT:==
WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000482/2018001


SUBJECT: WOLF CREEK GENERATING STATION
==Dear Mr. Heflin:==
- NRC INTEGRATED INSPECTION REPORT 05000482/2018 001
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Wolf Creek Generating Station. On April 25, 2018, the NRC inspectors discussed the results of this inspection with Mr. C. Reasoner, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
 
NRC inspectors documented one finding of very low safety significance (Green) in this report.
 
This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.
 
If you contest the violation or significance of this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Wolf Creek Generating Station.
 
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Wolf Creek Generating Station. 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/
 
Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects
 
Docket No. 50-482 License No. NPF-42
 
Enclosure:
Inspection Report 05000482/2018001 w/ Attachments:
1. Supplemental Information 2. Request for Information
 
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
 
==Inspection Report==
Docket Number:
05000482
 
License Number:
NPF-42
 
Report Number:
05000482/2018001
 
Enterprise Identifier: I-2018-001-0012
 
Licensee:
Wolf Creek Nuclear Operating Corporation
 
Facility:
Wolf Creek Generating Station
 
Location:
1550 Oxen Lane NE
 
Burlington, KS 66839
 
Inspection Dates:
January 1, 2018, to March 31, 2018
 
Inspectors:
D. Dodson, Senior Resident Inspector
 
F. Thomas, Resident Inspector
 
D. Bradley, Senior Resident Inspector, Callaway
 
Approved By:
N. Taylor, Chief, Project Branch B, Division of Reactor Projects
 
=SUMMARY=
The Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an Integrated Inspection at Wolf Creek Generating Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealed findings, violations, and additional items are summarized in the table below.
 
===List of Findings and Violations===
Inadequate Functionality Assessment Associated with the Emergency Excess Letdown Flowpath Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems
 
Green NCV 05000482/2018001-01 Closed
[H.14] - Human Performance,
Conservative Bias 71111.15 -
Operability Determinations and Functionality Assessments The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to adequately implement the operability determination and functionality assessment procedure.
 
Specifically, the licensee failed to document a functionality assessment of sufficient scope to address the capability of a safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and the excess letdown system to perform their specified safety functions, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional.
 
=PLANT STATUS=
 
Wolf Creek Generating Station began the inspection period at rated thermal power. On March 30, 2018, a plant shutdown was completed to begin Refueling Outage
 
==INSPECTION SCOPES==
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
 
==REACTOR SAFETY==
==71111.01 - Adverse Weather Protection==
===Impending Severe Weather (1 Sample)===
The inspectors evaluated readiness for impending adverse weather conditions for extreme low temperatures on January 2 and 3, 2018.
 
==71111.04 - Equipment Alignment==
===Partial Walkdown (2 Samples)===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
: (1) turbine-driven auxiliary feedwater train on February 6, 2018
: (2) residual heat removal pump B on March 21, 2018
 
===Complete Walkdown (1 Sample)===
The inspectors evaluated system configurations during a complete walkdown of the component cooling water system on February 23, 2018.
 
==71111.05AQ - Fire Protection Annual/Quarterly==
===Quarterly Inspection (5 Samples)===
The inspectors evaluated fire protection program implementation in the following selected areas:
: (1) fire area A-16, general area, elevation 2,026 feet on January 30, and March 28, 2018
: (2) fire area A-18, electrical penetration room (north), elevation 2,026 feet on January 30, 2018
: (3) fire area A-17, electrical penetration room (south), elevation 2,026 feet on March 28, 2018
: (4) fire area A-26, decontamination area for I&C shop, elevation 2,026 feet on March 28, 2018
: (5) fire area A-27, reactor trip switchgear, motor-generator sets, load centers, rod control and rod-drive power supply control cabinets 125 volt direct current panel on March 28, 2018.
 
==71111.06 - Flood Protection Measures==
===Internal Flooding (1 Sample)===
The inspectors evaluated internal flooding mitigation protections in rooms 1203 and 1203A, Pipe Space B on January 9, 2018.
 
==71111.07 - Heat Sink Performance==
===Heat Sink (1 Sample)===
The inspectors evaluated containment spray train A room cooler (SGL13A) performance on January 17, 2018.
 
==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance==
===Operator Requalification (1 Sample)===
The inspectors observed and evaluated licensed operator simulator requalification activities that included a loss of all alternating current power during shutdown scenario on February 22, 2018.
 
===Operator Performance (1 Sample)===
The inspectors observed and evaluated operator performance during end of life core moderator temperature coefficient measurement activities on February 5, 2018.
 
==71111.12 - Maintenance Effectiveness==
===Routine Maintenance Effectiveness (1 Sample)===
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
 
Auxiliary building heating ventilation and air conditioning (GL) system including safety-related pump and electrical penetration room coolers on January 29, 2018.
 
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
{{IP sample|IP=IP 71111.13|count=5}}
 
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
: (1) reactor partial trip alarm troubleshooting and main generator transformer B loss of two cooling groups on January 4, 2018
: (2) emergent maintenance on Class 1E electrical equipment air conditioning unit train A on January 24, 2018
: (3) planned maintenance on component cooling water train B on March 5, 2018
: (4) emergent maintenance associated with the failed control room envelope pressure test on March 6, 2018
: (5) emergent maintenance on Class 1E electrical equipment air conditioning unit train B on March 12, 2018.
 
==71111.15 - Operability Determinations and Functionality Assessments==
{{IP sample|IP=IP 71111.15|count=8}}
 
The inspectors evaluated the following operability determinations and functionality assessments:
: (1) auxiliary building elevation 1988 foot south pipe chase drain functionality with three clogged floor drains on January 10, 2018
: (2) 125 volt direct current to 120 volt alternating current NN15 inverter operability after a high voltage alarm would not clear on January 18, 2018
: (3) emergency diesel generator A lubrication oil leakage on January 31, 2018
: (4) Class 1E electrical equipment air conditioning unit train B operability following a step controller failure on February 12, 2018
: (5) reactor coolant pump A standpipe not filling on the expected frequency on February 25, 2018
: (6) Technical Specification 3.7.10 mitigating actions to ensure the control room envelope occupant radiological exposures would not exceed limits and control room envelope occupants are protected from chemical and smoke hazards while the control room envelope was inoperable on March 6, 2018
: (7) excess letdown heat exchanger outlet to pressurizer relief tank isolation valve functionality after failed stoke testing on March 12, 2018
: (8) station blackout diesel generator functionality after post maintenance testing on March 20, 2018.
 
==71111.19 - Post Maintenance Testing==
{{IP sample|IP=IP 71111.19|count=4}}
 
The inspectors evaluated the following post maintenance tests:
: (1) Class 1E electrical equipment air conditioning unit train A following planned maintenance on January 24, 2018
: (2) motor-driven auxiliary feedwater train B pump discharge to steam generators A and D auxiliary feed water flow regulating valve testing following planned maintenance on February 6, 2018
: (3) component cooling water pump A following planned maintenance on February 15, 2018
: (4) residual heat removal pump A following planned maintenance on March 21, 2018.
 
==71111.20 - Refueling and Other Outage Activities (Partial Sample)==
The inspectors evaluated Refueling Outage 22 activities from March 30 to 31, 2018. The inspectors completed inspection procedure Sections 03.01.a, 03.01.b, and 03.01.c.
 
==71111.22 - Surveillance Testing==
The inspectors evaluated the following surveillance tests:
 
===Routine===
{{IP sample|IP=IP 71111.22|count=5}}
: (1) STS IC-926B, Component Cooling Water System Automatic Valve Actuation Train B, Revision 6B, on January 4, 2018
: (2) STS IC-915B, Channel Operational Test Train B Component Cooling Water System Non-Nuclear Safety-Related Isolation, Revision 8A, on January 8, 2018
: (3) STS IC-926A, Component Cooling Water System Automatic Valve Actuation Train A, Revision 8A, on February 12, 2018
: (4) STS IC-217, [Reactor Coolant Pump] Loss of Voltage and Underfrequency [Trip Actuation Device Operational Testing], on March 5, 2018
: (5) STS PE-004, Auxiliary Building and Control Room Pressure Tests, Revision 16, on March 5 and March 12, 2018.
 
==71114.06 - Drill Evaluation==
===Emergency Planning Drill (1 Sample)===
The inspectors evaluated the emergency preparedness drill on February 27,
 
==OTHER ACTIVITIES - BASELINE==
===71151 - Performance Indicator Verification===
{{IP sample|IP=IP 71151|count=3}}
 
The inspectors verified licensee performance indicator submittals listed below:
: (1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017-12/31/2017)
: (2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017-12/31/2017)
: (3) IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017-12/31/2017).
 
==71152 - Problem Identification and Resolution==
===Annual Follow-up of Selected Issues (2 Samples)===
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
: (1) On February 8, 2018, the unit vent tornado damper failed to meet acceptance criteria for initial breakaway torque. This issue was documented in Condition Report 119330.
: (2) On May 11, 2017, Condition Report 112960 documented that pressurizer safety valve 88010As as-found lift setting was 3.2 percent below the nominal setpoint.
 
==INSPECTION RESULTS==
Inadequate Functionality Assessment Associated with the Emergency Excess Letdown Flowpath Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems
 
Green NCV 05000482/2018001-01 Closed
[H.14] - Human Performance, Conservative Bias
 
==71111.15 - Operability==
Determinations and Functionality Assessments The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to adequately implement the operability determination and functionality assessment procedure. Specifically, the licensee failed to document a functionality assessment of sufficient scope to address the capability of a safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and the excess letdown system to perform their specified safety functions, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional.
 
=====Description:=====
On March 12, 2018, the licensee was performing Procedure STN BB-201, Exercise of BB HV-8157A and BB HV-8157B, Revision 3, which tests and exercises the excess letdown heat exchanger to pressurizer relief tank isolation valves (BB HV-8157A and BB HV-8157B). The BB HV-8157B valve did not stroke fully closed as expected. Step 6.1.1 of Procedure STN BB-201 states, If the valve cannot be fully exercised, then valve shall be declared inoperable and corrective action initiated.
 
Condition Report 120287 was documented on March 12, 2018, reporting the valve failure. The immediate functionality assessment stated, The redundant path of excess letdown is still available. The system is functional but degraded. The system functionality is maintained by having a second redundant flow path for excess letdown. The inspectors noted that Section 6.4.7 of Procedure AP 26C-004, Operability Determination and Functionality Assessment, Revision 35, states, The scope of a functionality assessment must be sufficient to address the capability of SSCs to perform their specified functionsThe following things should be considered when performing functionality assessments: codes, standards and system requirements controlling the SSC.
 
The inspectors questioned the licensee concerning the immediate functionality determinations adequacy, and the licensee revised the functionality determination for the excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) and changed the determination to non-functional. The immediate functionality determination was updated to state:
 
The above screening gives an adequate justification for why the excess letdown po[r]tion of the [chemical and volume control system] remains functional but degraded. However, screening should be based on the component, not the system. Since BBHV8157B cannot be relied upon to go to the closed position using normal remote controls, the valve is considered nonfunctional. The system remains functional but degraded.
 
The inspectors also noted that Section 3.1.9, Boration Injection System - Operating, of the Technical Requirements Manual, requires two boration injection subsystems to be functional in MODES 1, 2, and 3. Section 3.1.9 of the Technical Requirements Manual Bases describes what is required for a boration injection subsystem to be considered functional. Specifically, both subsystems require the safety-related excess letdown flow path. Also, two independent boration injection subsystems are required to ensure single functional capability in the event an assumed failure renders one of the boration injection subsystems nonfunctional.
 
Updated Safety Analysis Report Section 7.4.3.3 describes the applicable single failure analysis. It states, The capability of the [residual heat removal system] to accommodate a single component failure and still perform a safety grade cooldown is demonstrated in the failure mode and effects analysis (FMEA) of the [residual heat removal] system for safety-related cold shutdown operations provided as Table 7.4-4. Table 7.4-4, Residual Heat Removal - Safety Related Cold Shutdown Operations - Failure Modes and Effects Analysis (FMEA), describes the function of the excess letdown to pressurizer relief tank isolation valves (8157A and 8157B), stating, Provides safety grade letdown flow path. Hence, in order for the safety-related excess letdown flowpath to the pressurizer relief tank to meet its safety function, either 8157A or 8157B must be functional and capable of opening.
 
The inspectors again questioned the updated immediate functionality determinations adequacy. Specifically, considering that 8157A and 8157B are parallel valves, that 8157B was non-functional, and assuming a design basis single failure (for example, assume 8157A fails to open or its power supply fails), the safety-related excess letdown flowpath would be non-functional, and both Technical Requirements Manual independent boration injection subsystems would be impacted. With the excess letdown heat exchanger to pressurizer relief tank isolation valve 8157B non-functional, current language in the Technical Requirements Manual would require one boration injection subsystem to be declared non-functional.
 
Corrective Actions: On March 20, 2018, the licensee changed the functionality assessment the excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) was determined to be non-functional. In response to the inspectors questions concerning system functionality and design basis information, the licensee initiated Condition Reports 120628 and 120822. The licensee restored the B train excess letdown heat exchanger to pressurizer relief tank isolation valve to service on April 9, 2018.
 
Corrective Action References: Condition Reports 120287, 120628, 120822 and 122411.
 
=====Performance Assessment:=====
Performance Deficiency: The licensee failed to document a functionality assessment of sufficient scope to address the capability of the safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and excess letdown system to perform their specified safety functions.
 
Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).
 
Specifically, the safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and excess letdown system were inappropriately determined to be functional but degraded and non-conforming, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional.
 
Significance: The inspectors assessed the significance of the finding using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter 0609, Appendix A, Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, and determined this finding is not a deficiency affecting the design or qualification of a mitigating SSC that maintained its operability or functionality; the finding does not represent a loss of system and/or function; the finding does not represent an actual loss of function of at least a single train for greater than its Technical Specification-allowed outage time; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as high safety-significant. Therefore, the inspectors determined the finding was of very low safety significance (Green).
 
Cross-cutting Aspect: The inspectors determined that the finding has a Human Performance cross-cutting aspect in the area of conservative bias in that individuals did not use decision making-practices that emphasize prudent choices over those that are simply allowable, and a proposed action was not determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, leaders did not take a conservative approach to decision making, particularly when information was incomplete or conditions were unusual when completing the functionality determination associated with the subject valve and system, which resulted in the valve and system being determined to be functional.
 
=====Enforcement:=====
Violation: Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances. Licensee Procedure AP 26C-004, Operability Determination and Functionality Assessment, Revision 35, an Appendix B quality related procedure, provides instructions for performing functionality assessments. Procedure AP 26C-004, Section 6.4.7, states, in part, that the scope of a functionality assessment must be sufficient to address the capability of SSCs to perform their specified functions, and codes, standards, and system requirements controlling the SSC should be considered when performing functionality assessments.
 
Contrary to the above, from March 12, 2018, until April 9, 2018, the scope of a functionality assessment was not sufficient to address the capability of SSCs to perform their specified functions, and codes, standards, and system requirements controlling the SSC were not considered when performing functionality assessments. Specifically, the functionality assessment associated with the excess letdown heat exchanger outlet to pressurizer relief tank isolation valve and excess letdown system was not adequate and did not adequately consider design basis information, which caused the licensee to fail to identify non-functionality of safety-related SSCs.
 
Disposition: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
 
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.
 
On April 25, 2018, the inspector presented the quarterly resident inspector inspection results to Mr. C. Reasoner, Site Vice President, and other members of the licensee staff.
 
=DOCUMENTS REVIEWED=
 
Section 1R01: Adverse Weather Protection
Procedures
Number
Title
Revision
SYS EF-205
ESW/Circ Water Cold Weather Operations
 
Miscellaneous
Number
Title
Date
96-0316
Performance Improvement Request
Initiated
February 5,
1996
2006-0006
Performance Improvement Request
Initiated
January 4,
2006
APF 15C-002-01 Procedure Cover Sheet - ESW/Circ Water Cold Weather
Operations - SYS EF-205
Completed
December 26,
2017
APF 15C-002-01 Procedure Cover Sheet - ESW/Circ Water Cold Weather
Operations - SYS EF-205
Completed
January 2,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Day Shift
January 19,
2018
APF 29B-003-01 Surveillance Test Routing Sheet - ESW Train B Warming
Line Verification - STN EF-020B
Completed
January 3,
2018
WM 96-0081
Docket No 50-482: Response to Enforcement Action
EA 96-124
July 31, 1996
Section 1R04: Equipment Alignment
Procedures
Number
Title
Revision
CKL Al-120
Auxiliary Feedwater Normal Lineup
CKL EG-120
Component Cooling Water System Valve, Switch and
Breaker Lineup
CKL EJ-120
RHR System Lineup
45B
 
Drawings
Number
Title
Revision
M-06EG07
Component Coolant Wtr. Sys. Aux. Bldg.
M-12AL01
Piping & Instrumentation Diagram Auxiliary Feedwater
System
M-12EG01
Piping & Instrumentation Diagram Component Cooling
Water System
M-12EG02
Piping & Instrumentation Diagram Component Cooling
Water System
M-12EG03
Piping & Instrumentation Diagram Component Cooling
Water System
M-12EJ01
Piping and Instrumentation Diagram Residual Heat
Removal System
M-12FC02
Piping & Instrumentation Diagram Auxiliary Feedwater
Pump Turbine
M-13EG07
Piping Isometric Component Cooling Water Sys. Aux. Bldg.
Common Header
M-15EG07
Hanger Location Drawing Component Cooling Water Sys
Aux. Bldg. Common Header
 
Condition Reports
119280
119401
20586
 
Section 1R05: Fire Protection
Procedures
Number
Title
Revision
AP 10-106
Fire Preplans
18A
CKL ZL-001
Auxiliary Building Reading Sheets
103
Condition Reports
119366
20782
20783
20784
 
Miscellaneous
Number
Title
Revision
E-1F9905
Fire Hazard Analysis
XX-X-004
Calculation Cover Sheet - Combustible Fire Loading For
Each Room In The Various Fire Areas at WCNOC
 
Section 1R06: Flood Protection Measures
Procedures
Number
Title
Revision
ALR 00-094F
Misc Sumps Lev Hi
 
Drawings
Number
Title
Revision
M-12EJ01
Piping and Instrumentation Diagram Residual Heat
Removal System
M-13LF02
Piping Isometric Sump Discharge Auxiliary Bldg.
 
Condition Reports
118576
118586
118587
118592
118593
Miscellaneous
Number
Title
Revision
FL-03
Flooding of Individual Auxiliary Building Rooms
 
Section 1R07: Heat Sink Performance
Procedures
Number
Title
Revision
AP 23L-002
Heat Exchanger Program
 
Work Orders
17-428729-000
17-428729-002
17-428729-003
17-428729-005
17-428737-000
Miscellaneous
Number
Title
Date
GL-05
Maintenance Rule Final Scope Evaluation
Printed
March 27,
2018
 
Section 1R11: Licensed Operator Requalification Program
Procedures
Number
Title
Revision
AP 21-001
Conduct of Operations
STS RE-006
EOL Core MTC Measurement
20B
STS SE-001
Power Range Adjustment to Calorimetric
 
Miscellaneous
Number
Title
Revision/Date
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Day Shift
February 2,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Day Shift
February 3,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
February 3,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
February 4,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
February 5,
2018
APF 29B-003-01 Surveillance Test Routing Sheet - EOL Core MTC
Measurement
Completed
February 5,
2018
EPF 06-007-01
Wolf Creek Generating Station Emergency Notification
(Drill)
February 22,
2018
LR5004005
Loss of All AC While Shutdown - Licensed Operator
Requal
 
Section 1R12: Maintenance Effectiveness
Drawings
Number
Title
Revision/Date
M-12GL01
Piping and Instrumentation Diagram Auxiliary Building
HVAC
M-612.00062
Carrier Air Handling Units and Room Coolers
Imaged May
2017
Condition Reports
10539
114660
117759


==Dear Mr. Heflin:==
Miscellaneous
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Wolf Creek Generating Station.
Number
Title
Date
GL Room Cooler PM Schedule


On April 25, 2018, the NRC inspectors discussed the results of this inspection with Mr. C. Reasoner, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
Maintenance Rule Expert Panel Meeting Agenda
November 1,
2017
114660
Functional Failure Determination Checklist
August 17,
2017
GL-01
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-02
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-03
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-04
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-05
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-06
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-07
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-08
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-09
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
Procedures
Number
Title
Revision
AP 22C-003
On-Line Nuclear Safety and Generation Risk Assessment


NRC inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements
Procedures
. The NRC is treating this violation as a non-cited violatio n consistent with Section 2.3.2 of the Enforcement Policy.
Number
Title
Revision
OFN AF-025
Unit Limitations
STS BB-201B
Cycle Test of PORV Block Valve BB HV-800B
STS IC-447
Channel Calibration Nuclear Instrumentation System Power
Range Incore-Excore
STS MT-024B
Functional Test of 480 and 120 Volt Molded Case Circuit
Breakers


If you contest the violation or significance of this non-cited violation
Drawings
, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Wolf Creek Generating Station.
Number
Title
Revision
M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout
W03
Condition Reports
118499
118938
118939
118940
118953
118958
118959
118963
118964


If you disagree with a cross
Work Orders
-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S.
17-422791-003
17-427320-000
18-434985-000
18-435758-000
18-435758-001
Miscellaneous
Number
Title
Date
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Day Shift
January 23,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
January 23,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Day Shift
January 24,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
January 24,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
January 25,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
January 26,
2018
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
18-0101
January 4,
2018


Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555
Miscellaneous
-0001; with copies to the Regional Administrator, Region IV; and t he NRC resident inspector at the Wolf Creek Generating Station
Number
. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading
Title
-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding.
Date
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
18-0111
March 13,
2018
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
2018-0110
February 15,
2018
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
2018-0104
January 10,
2018
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment -
2018-0122
February 14,
2018
APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-447
Completed
January 4,
2018
APF 29B-003-01 Surveillance Test Routing Sheet - STS PE-004 (Train B)
Completed
March 7,
2018
Section 1R15: Operability Evaluations
Procedures
Number
Title
Revision
AI 16C-006
Troubleshooting
AI 28B-005
Evidence and Action Matrix
AP 12-003
Foreign Material Exclusion
AP 26C-004
Operability Determination and Functionality Assessment
OFN BB-005
RCP Malfunctions
STN BB-201
Exercise of BB HV-8157A and BB HV-8157B
STS BG-001
Boron Injection Flow Path Verification
STS KJ-005A
Manual/Auto Start, Sync and Loading of EDG NE01
67A
STS PE-004
Auxiliary Building and Control Room Pressure Test
SYS GK-122
Manual CRVIS Line-Up
SYS OPS-001
Weekly Equipment Rotation and Readings
80A
Drawings
Number
Title
Revision
E-13GG01
Schematic Diagram Emergency Exhaust Fans
E-13GG03
Schematic Diagram Emergency Exhaust Heating Coils


"
Drawings
Number
Title
Revision
E-13GG15
Schematic Diagram Emergency Exhaust Cross Connection
Dampers
J-02GG14B (Q)
Fuel Building HVAC Spent Fuel Pool Normal/Emergency
Exhaust Radioactivity Sample Valve
M-12BB02
Piping & Instrumentation Diagram Reactor Coolant System
M-12BB03
Piping and Instrumentation Diagram Reactor Coolant System 15
M-12BG01
Piping & Instrumentation Diagram Chemical and Volume
Control System
M-12BL01
Piping & Instrumentation Diagram Reactor Make-Up Water
System
M-12GG01
Piping Instrumentation Diagram Fuel Building HVAC
M-12GT01
Piping & Instrumentation Diagram Containment Purge
Systems HVAC
M-12HB01
Piping and Instrumentation Diagram Liquid Radwaste
System
M-12LF01
Piping & Instrumentation Diagram Auxiliary Building Floor
and Equipment Drain System
M-12LF03
Piping & Instrumentation Diagram Auxiliary Building Floor
and Equipment Drain System
M-1H1531
Heating Ventilating and Air Cond. Auxiliary Building El. 2047-
Area-3
M-1H6311
Heating Ventilating & Air Cond. Fuel Building El. 2047-6 &
2065-0 Area 1
M-622.1A-00001 SGK05A & SGK05B Air Conditioner Refrigeration Schematic W12
M-622.1A-00002 SGK05A & SGK05B Air Conditioner Electrical Schematic
W13
M-622.1A-00003 SGK05A & SGK05B Air Conditioner Electrical Schematic
W09
M-622.1A-00257 Step Controllers
W01
M-712-00063
Reactor Coolant Pump Data Sheets
W04
M-OPIII
Embedded Drainage Systems (LF) Auxiliary Building EL.
1967-0 & 1974-0 Area I


Sincerely,/RA/ Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects Docket No. 50
Condition Reports
-482 License No. NPF-42
24199
90975
107789
110377
117283
118586
118587
118592
118827
118830


===Enclosure:===
Condition Reports
Inspection Report 05000482/2018001 w/ Attachment s: 1. Supplemental Information 2. Request for Information
118831
118910
118922
119069
119085
119330
119334
119442
119446
119487
119616
119822
119859
119860
119861
20053
20056
20071
20179
20181
20246
20287
20408
20409
20410
20411
20489
20535
20664
20722
Work Orders
16-411783-010
17-428518-000
18-436340-000
18-436340-002


1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 05000482 License Number: NPF-42 Report Number: 05000482/2018001 Enterprise Identifier:
Miscellaneous
I-2018-001-0012 Licensee:
Number
Wolf Creek Nuclear Operating Corporation Facility:
Title
Wolf Creek Generating Station Location:
Revision/Date
1550 Oxen Lane NE Burlington, KS 66839 Inspection Dates: January 1, 2018
107363
, to March 31, 2018 Inspectors:
Functional Failure Determination Checklist
D. Dodson, Senior Resident Inspector F. Thomas, Resident Inspector D. Bradley, Senior Resident Inspector, Callaway Approved By:
October 12,
N. Taylor, Chief, Project Branch B, Division of Reactor Projects
2016
118585
Function Failure Determination Checklist
January 28,
2018
AIF 10-001-02
SCBA Inspection
Completed
March 1, 2018
APF 05-002-05
Engineering Disposition - EDG Water, Lube Oil, and Fuel
Oil Leakage Guidance
APF 05C-004-01 Basic Engineering Disposition - Review of Regulatory and
License Basis Documents to evaluate the requirements of
Operability Determination when Safety Related or
Technical Specification Equipment is exposed to a hazard
APF 21-001-02
Control Room Turnover checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
March 14,
2018
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
2018-0112
February 14,
2018
APF30B-004-01
Wolf Creek Nuclear Operating Corporation Essential
Required Reading - SBO Power Equipment Center (PEC)
April 1, 2018
GG-01
Maintenance Rule Final Scope Evaluation
Printed
March 22,
2018
GG-02
Maintenance Rule Final Scope Evaluation
Printed
March 22,
2018


2 SUMMARY The Nuclear Regulatory Commission (
Miscellaneous
NRC) continued monitoring the licensee's performance by conducting an Integrated Inspection at Wolf Creek Generating Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC
Number
-identified and self-revealed findings, violations, and additional items are summarized in the table below.
Title
Revision/Date
GG-03
Maintenance Rule Final Scope Evaluation
Printed
March 22,
2018
GG-04
Maintenance Rule Final Scope Evaluation
Printed
March 22,
2018
Section 1R19: Post-Maintenance Testing
Procedures
Number
Title
Revision
STN AL-201
Auxiliary Feedwater System Valve Test
STN EG-205A
Component Cooling Water System Valve Test
STS EG-100A
Component Cooling Water Pumps A/C [Air Conditioning]
Inservice Pump Test
33A
STS EG-208A
EG TV-029 CCW [Component Cooling Water] HX [Heat
Exchanger] A Temperature Control Valve Inservice Valve
Test
STS EJ-100A
RHR [Residual Heat Removal] System Inservice Pump A
Test
STS IC-540A
Channel Calibration Auxiliary Feedwater System Steam
Generator A


List of Findings and Violations Inadequate Functionality Assessment Associated with the Emergency Excess Letdown Flowpath Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000482/2018001
Drawings
-01 Closed [H.14] - Human Performance, Conservative Bias 71111.15
Number
- Operability Determinations and Functionality Assessments The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," when the licensee failed to adequately implement the operability determination and functionality assessment procedure. Specifically, the licensee failed to document a functionality assessment of sufficient scope to address the capability of a safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and the excess letdown system to perform their specified safety functions, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional.
Title
Revision/Date
E-13GK13
Schematic Diagram Class 1E Electrical Equipment A/C [Air
Conditioning] Unit
M-12AL01
Piping & Instrumentation Diagram Auxiliary Feedwater
System
M-12AL01
Piping & Instrumentation Diagram Auxiliary Feedwater
System
M-622.1-00036
Electric Motor Data Sheet
March 3, 1977
M-622.1A-00002 SKG05A & SGK05B Air Conditioner Electrical Schematic
W13
M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout
W03


3 PLANT STATUS Wolf Creek Generating Station began the inspection period at rated thermal power. On March 30, 2018, a plant shutdown was completed to begin Refueling Outage 22.
Condition Reports
118881
118901
118920
118953
118958
118959
118963
118964
119289


INSPECTION SCOPE S Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading
Work Orders
-rm/doc-collections/insp
15-407137-000
-manual/inspection
-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, "Light
-Water Reactor Inspection Program - Operations Phase." The inspectors performed plant status activities described in IMC 2515 Appendix D, "Plant Status" and conducted routine reviews using IP 71152, "Problem Identification and Resolution
." The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.


REACTOR SAFETY 71111.01 - Adverse Weather Protection Impending Severe Weather (1 Sample) The inspectors evaluated readiness for impending adverse weather conditions for extreme low temperatures on January 2 and 3, 2018. 71111.04 - Equipment Alignment Partial Walkdown (2 Samples) The inspectors evaluated system configuration s during partial walkdowns of the following systems/trains
Miscellaneous
: (1) turbine-driven auxiliary feedwater train on February 6, 2018 (2) residual heat removal pump B on March 21, 2018 Complete Walkdown (1 Sample) The inspectors evaluated system configuration s during a complete walkdown of the component cooling water system on February 23, 2018. 71111.05AQ
Number
- Fire Protection Annual/Quarterly Quarterly Inspection (5 Samples) The inspectors evaluated fire protection program implementation in the following selected areas:
Title
4 (1) fire area A
Revision/Date
-16, general area, elevation 2,026 feet on January 30
WCGS Standing Order 1 - Valve Setup and Operation
, and March 28, 2018 (2) fire area A-18, electrical penetration room (north), elevation 2,026 feet on January 30, 2018 (3) fire area A-17, electrical penetration room (south), elevation 2,026 feet on March 28, 2018 (4) fire area A
36121
-26, decontamination area for I&C shop, elevation 2,026 feet on March 28, 2018 (5) fire area A
Preventative Maintenance Work Instruction
-27, reactor trip switchgear, motor
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment
-generator sets, load centers, rod control and rod-drive power supply control cabinets 125 volt direct current panel on March 28, 2018. 71111.06 - Flood Protection Measures Internal Flooding (1 Sample) The inspectors evaluated internal flooding mitigation protections in rooms 1203 and 1203A, Pipe Space B on January 9, 2018
January 23,
. 71111.07 - Heat Sink Performance Heat Sink (1 Sample)
2018
The inspectors evaluated containment spray train A room cooler (SGL13A)
APF 29B-003-01 Surveillance Test Routing Sheet - Auxiliary Feedwater
performance on January 17, 2018
System Valve Test
. 71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification (1 Sample) The inspectors observed and evaluated licensed operator simulator requalification activities that included a loss of all alternating current power during shutdown scenario on February 22, 2018. Operator Performance (1 Sample) The inspectors observed and evaluated operator performance during end of life core moderator temperature coefficient measurement activities on February 5, 2018
Completed
. 71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness (1 Sample) The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions
February 6,
: Auxiliary building heating ventilation and air conditioning (
2018
GL) system including safety
Section 1R20: Refueling and Other Outage Activities
-
Procedures
5 related pump and electrical penetration room coolers on January 29, 2018
Number
. 71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples) The inspectors evaluated the risk assessments for the following planned and emergent work activities
Title
: (1) reactor partial trip alarm troubleshooting and main generator transformer B loss of two cooling groups on January 4, 2018 (2) emergent maintenance on Class 1E electrical equipment air conditioning unit train A on January 24, 2018 (3) planned maintenance on component cooling water train B on March 5, 2018 (4) emergent maintenance associated with the failed control room envelope pressure test on March 6, 2018 (5) emergent maintenance on Class 1E electrical equipment air conditioning unit train B on March 12, 2018. 71111.15 - Operability Determinations and Functionality Assessments (8 Samples) The inspectors evaluated the following operability determinations and functionality assessments:
Revision
(1) auxiliary building elevation 1988 f oot south pipe chase drain functionality with three clogged floor drains on January 10, 2018 (2) 125 volt direct current to 120 volt alternating current NN15 inverter operability after a high voltage alarm would not clear on January 1 8, 2018 (3) emergency diesel generator A lubrication oil leakage on January 31, 2018 (4) Class 1E electrical equipment air conditioning unit train B operability following a step controller failure on February 12, 2018 (5) reactor coolant pump A standpipe not filling on the expected frequency on February 25, 2018 (6) Technical Specification 3.7.10 mitigating actions to ensure the control room envelope occupant radiological exposures would not exceed limits and control room envelope occupants are protected from chemical and smoke hazards while the control room envelope was inoperable on March 6, 2018 (7) excess letdown heat exchanger outlet to pressurizer relief tank isolation valve functionality after failed stoke testing on March 12, 2018 (8) station blackout diesel generator functionality after post maintenance testing on March 20, 2018.
GEN 00-004
Power Operation
GEN 00-005
Minimum Load To Hot Standby
SYS AE-320
Turbine Driven Main Feedwater Pump Shutdown
28A
SYS AF-121
Heater Drain Pump Operation


6 71111.19 - Post Maintenance Testing (4 Samples) The inspectors evaluated the following post maintenance tests: (1) Class 1E electrical equipment air conditioning unit train A following planned maintenance on January 24, 2018 (2) motor-driven auxiliary feedwater train B pump discharge to steam generators A and D auxiliary feed water flow regulating valve testing following planned maintenance on February 6, 2018 (3) component cooling water pump A following planned maintenance on February 15, 2018 (4) residual heat removal pump A following planned maintenance on March 21, 2018
Section 1R22: Surveillance Testing
. 71111.20 - Refueling and Other Outage Activities (Partial Sample) The inspectors evaluated Refueling Outage 22 activities from March 30 to 31, 2018. The inspectors completed inspection procedure Sections 03.01.a, 03.01.b, and 03.01.c. 71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:
Procedures
Routine (5 Samples) (1) STS IC-926B, Component Cooling Water System Automatic Valve Actuation Train B, Revision 6B, on January 4, 2018 (2) STS IC-915B, Channel Operational Test Train B Component Cooling Water System Non-Nuclear Safety
Number
-Related Isolation, Revision 8A, on January 8, 2018 (3) STS IC-926A, Component Cooling Water System Automatic Valve Actuation Train A, Revision 8A, on February 12, 2018 (4) STS IC-217, [Reactor Coolant Pump] Loss of Voltage and Underfrequency [Trip Actuation Device Operational Testing], on March 5, 2018 (5) STS PE-004, Auxiliary Building and Control Room Pressure Test s, Revision 16
Title
, on March 5 and March 12, 2018
Revision
. 71114.06 - Drill Evaluation Emergency Planning Drill (1 Sample) The inspectors evaluated the emergency preparedness drill on February 27, 2018
AP 23-009
.
Control Room Envelope Habitability Program
7 OTHER ACTIVITIES
STS EG-100B
- BASELINE 71151 - Performance Indicator Verification (3 Samples
Component Cooling Water Pumps B/D Inservice Pump Test 29
) The inspectors verified licensee performance indicator submittals listed below: (1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017
STS IC-217
-12/31/2017
RCP Loss of Voltage and Underfrequency TADOT
) (2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017
15C
-12/31/2017
STS IC-915B
) (3) IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017
Channel Operational Test Train B Component Cooling
-12/31/2017). 71152 - Problem Identification and Resolution Annual Follow
Water System Non-Nuclear Safety-Related Isolation
-up of Selected Issues (2 Samples) The inspectors reviewed the licensee's implementation of its corrective action program related to the following issues:
8A
(1) On February 8, 2018, the unit vent tornado damper failed to meet acceptance criteria for initial breakaway torque. This issue was documented in Condition Report 119330.
STS IC-926A
Component Cooling Water System Automatic Valve
Actuation Train A
8A  


(2) On May 11, 2017, Condition Report 112960 documented that pressurizer safety valve 88010A's as
Procedures
-found lift setting was 3.2 percent below the nominal setpoint.
Number
Title
Revision
STS IC-926B
Component Cooling Water System Automatic Valve
Actuation Train B
6B
STS PE-004
Auxiliary Building and Control Room Pressure Test


8 INSPECTION RESULTS Inadequate Functionality Assessment Associated with the Emergency Excess Letdown Flowpath Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000482/2018001
Drawings
-01 Closed [H.14] - Human Performance, Conservative Bias 71111.15
Number
- Operability Determinations and Functionality Assessments The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," when the licensee failed to adequately implement the operability determination and functionality assessment procedure. Specifically, the licensee failed to document a functionality assessment of sufficient scope to address the capability of a safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and the excess letdown system to perform their specified safety functions, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional
Title
. Description
Revision
: On March 12, 2018, the licensee was performing Procedure STN BB
E-13EG01D
-201, "Exercise of BB HV
Schematic Diagram Component Cooling Water Pump D
-8157A and BB HV
E-13EG08A
-8157B," Revision 3, which tests and exercises the excess letdown heat exchanger to pressurizer relief tank isolation valves (BB HV
Schematic Diagram Component Cooling Water Supply
-8157A and BB HV-8157B). The BB HV-8157B valve did not stroke fully closed as expected. Step 6.1.1 of Procedure STN BB
Return From Radwaste Building
-201 states, "If the valve cannot be fully exercised, then valve shall be declared inoperable and corrective action initiated."
E-13EG11
Schematic Diagram Annunciation and Instrumentation
E-13EG20
Schematic Diagram Pass CCW Isolation Valves
M-12EG01
Piping & Instrumentation Diagram Component Cooling
Water System
M-12EG02
Piping & Instrumentation Diagram Component Cooling
Water System
M-12EG03
Piping & Instrumentation Diagram Component Cooling
Water System


Condition Report 120287 was documented on March 12, 2018, reporting the valve failure. The immediat e functionality assessment stated, "The redundant path of excess letdown is still available. The system is functional but degraded. The system functionality is maintained by having a second redundant flow path for excess letdown." The inspectors noted that Section 6.4.7 of Procedure AP 26C
Condition Reports
-004, "Operability Determination and Functionality Assessment," Revision 35, states,
118493
"The scope of a functionality assessment must be sufficient to address the capability of SSCs to perform their specified functions-The following things should be considered when performing functionality assessments: codes, standards and system requirements controlling the SSC."
118551
118552
119412
20061
20064
20148
20151
20408
20409
20410
20411


The inspectors questioned the licensee concerning the immediate functionality determination's adequacy, and the licensee revised the functionality determination for the excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) and changed the determination to non-functional. The immediate functionality determination was updated to state: The above screening gives an adequate justification for why the excess letdown po[r]tion of the [chemical and volume control system] remains functional but degraded. However, screening should be based on the component, not the system. Since BBHV8157B cannot be relied upon to go to the closed position using normal remote controls, the valve is considered nonfunctional.
Work Orders
17-431050-000
17-431170-000
17-431759-000
17-432247-000


The system remains functional but degraded.
Miscellaneous
Number
Title
Date
APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-217
Completed
March 5,
2018
APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-926B
Completed
January 4,
2018


9 The inspectors also noted that Section 3.1.9, "Boration Injection System
Miscellaneous
- Operating," of t he Technical Requirements Manual, requires two boration injection subsystems to be functional in MODES 1, 2, and 3. Section 3.1.9 of the Technical Requirements Manual Bases describes what is required for a boration injection subsystem to be considered functional. Specifically, both subsystems require the safety-related excess letdown flow path.
Number
Title
Date
APF 30B-004-01 Wolf Creek Nuclear Operating Corporation Essential
Required Reading: 18-0010 Accuracy of WCRE-35
March 7,
2018
Section 1EP6: Drill Evaluation
Procedures
Number
Title
Revision
EPP 06-006
Protective Action Recommendations
9A
Condition Reports
119869
119870
119871
119872
119874
119877
119878
119879
119883
119885
119886
119887
119888
119889
119897
119901
119903
119904
119906
119911
119941
20017
20227
20323


Also, two independent boration injection subsystems are required to ensure single functional capability in the event an assumed failure renders one of the boration injection subsystems nonfunctional.
Miscellaneous
Number
Title
Revision/Date
18-SA-01
Wolf Creek Generating Station - Emergency Planning Drill
February 27,
2018
APF 06-002-01
Emergency Action Levels
17A
CR-001
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018
EOF-001
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018
EOF-002
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018
EOF-003
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018
EOF-004
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018
TSC-001
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018


Updated Safety Analysis Report Section 7.4.3.3 describe s the applicable single failure analysis. It states
Section 4OA1: Performance Indicator Verification
, "The capability of the [residual heat removal system] to accommodate a single component failure and still perform a safety grade cooldown is demonstrated in the failure mode and effects analysis (FMEA) of the [residual heat removal
Miscellaneous
] system for safety
Number
-related cold shutdown operations provided as Table 7.4
Title
-4." Table 7.4
Revision
-4, "Residual Heat Removal - Safety Related Cold Shutdown Operations
NEI 99-02
- Failure Modes and Effects Analysis (FMEA)," describes the function of the excess letdown to pressurizer relief tank isolation valves (8157A and 8157B
Regulatory Assessment Performance Indicator Guideline
), stating,
"Provides safety grade letdown flow path."


Hence, in order for the safety
Section 4OA2: Identification and Resolution of Problems
-related excess letdown flowpath to the pressurizer relief tank to meet its safety function, either 8157A or 8157B must be functional and capable of opening. The inspectors again questioned the updated immediate functionality determination's adequacy. Specifically, considering that 8157A and 8157B are parallel valves
Procedures
, that 8157B was non-functional
Number
, and assuming a design basis single failure (for example, assume 8157A fails to open or its power supply fails), the safety-related excess letdown flowpath would be non-functional
Title
, and both Technical Requirements Manual independent boration injection subsystems would be impacted. With the excess letdown heat exchanger to pressurizer relief tank isolation valve 8157B non
Revision
-functional, current language in the Technical Requirements Manual would require one boration injection subsystem to be declared non
STS MT-005
-functional.
Pressurizer Code Safety Valve Operability


Correctiv e Actions: On March 20, 2018, the licensee changed the functionality assessment
Drawings
-the excess letdown heat exchanger to pressurizer relief tank isolation valve (
Number
8157B) was determined to be non
Title
-functional. In response to the inspectors' questions concerning system functionality and design basis information, the licensee initiated Condition Report s 120628 and 120822
Revision
. The licensee restored the B train excess letdown heat exchanger to pressurizer relief tank isolation valve to service on April 9, 2018.
M-1H1531
Heating Ventilating and Air Cond. Auxiliary Building El.
2047-6 Area-3


Corrective Action References:
Condition Reports
Condition Reports 120287, 120628, 120822 and 122411
90975
. Performance Assessment
110377
: Performance Deficiency: The licensee failed to document a functionality assessment of sufficient scope to address the capability of the safety
2960
-related excess letdown heat exchanger to pressurizer relief tank isolation valve and excess letdown system to perform their specified safety functions
118910
. Screening:
119330
The inspectors determined the performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the safety
Work Orders
-related excess letdown heat exchanger to pressurizer relief tank isolation valve and excess letdown system were inappropriately determined to be functional but degraded and non
17-428518-001
-conforming, which resulted in the licensee failing to recognize that two 10 independent Technical Requirements Manual required boration injection subsystems were not functional
. Significance
: The inspectors assessed the significance of the finding using Exhibit 2, "Mitigating Systems Screening Questions," of Inspection Manual Chapter 0609, Appendix A, "Significance Determination Process (SDP) for Findings At
-Power," issued June 19, 2012, and determined this finding is not a deficiency affecting the design or qualification of a mitigating SSC that maintained its operability or functionality; the finding does not represent a loss of system and/or function; the finding does not represent an actual loss of function of at least a single train for greater than its Technical Specification
-allowed outage time; and the finding does not represent an actual loss of function of one or more non
-Technical Specification trains of equipment designated as high safety
-significant. Therefore, the inspectors determined the finding was of very low safety significance (Green).


Cross-cutting Aspect
Miscellaneous
: The inspectors determined that the finding has a Human Performance cross-cutting aspect in the area of conservative bias in that individuals did not use decision making-practices that emphasize prudent choices over those that are simply allowable, and a proposed action was not determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, leaders did not take a conservative approach to decision making, particularly when information was incomplete or conditions were unusual when completing the functionality determination associated with the subject valve and system, which resulted in the valve and system being determined to be functional.
Number
Title
Date
Email from NWS
Technologies to
Wolf Creek
<EXTERNAL> RE: Wolf Creek PSV failure - Questions
from our NRC Resident Inspector
November
30, 2017
P.O. # 692145
SR
Valve Serial Number N60446-00-0001; Traveler 14-381
Testing
Completed
January 2015
PO # 779245
Valve Serial Number N60446-00-0001; Traveler 17-41
Testing
Completed
August 2017
NRC Letter to
Otto L. Maynard
Wolf Creek Generating Station - Issuance of Amendment
RE: Pressurizer Safety Valves (TAC NO. MA6969)
March 23,
2000
White Paper
Pressurizer Safety Valve NRC Follow-up Questions and
Answers


Enforcement
White Paper
: Violation: Title 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
Why PZR Safety Valve Failure is NOT a Part 21 Issue
requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances. Licensee Procedure AP 26C-004, "Operability Determination and Functionality Assessment," Revision 35, an Appendix B quality related procedure, provides instructions for performing functionality assessments. Procedure AP 26C
-004, Section 6.4.7
, states, in part, that the scope of a functionality assessment must be sufficient to address the capability of SSCs to perform their specified functions, and codes, standards, and system requirements controlling the SSC should be considered when performing functionality assessments.


Contrary to the above, from March 12, 2018, until April 9, 2018, the scope of a functionality assessment was not sufficient to address the capability of SSCs to perform their specified functions, and codes, standards, and system requirements controlling the SSC were not considered when performing functionality assessments. Specifically, the functionality assessment associated with the excess letdown heat exchanger outlet to pressurizer relief tank isolation valve and excess letdown system was not adequate and did not adequately consider design basis information, which caused the licensee to fail to identify non
Initial Request for Information
-functionality of safety
Integrated Inspection
-related SSCs.
Wolf Creek Nuclear Generating Station


Disposition:
Inspection Report: 05000482/2018001
This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.


11 EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report
Inspection Dates: January 1 - March 31, 2018  
. On April 25, 2018, the inspector presented the quarterly resident inspector inspection results to Mr. C. Reasoner, Site Vice President, and other members of the licensee staff.


Attachment 1 DOCUMENTS REVIEWED Section 1R01: Adverse Weather Protection Procedures Number Title Revision SYS EF-205 ESW/Circ Water Cold Weather Operations 40 Miscellaneous Number Title Date 96-0316 Performance Improvement Request Initiated February 5, 1996 2006-0006 Performance Improvement Request Initiated January 4, 2006 APF 15C-002-01 Procedure Cover Sheet
Inspection Procedure: Integrated Inspection Procedures  
- ESW/Circ Water Cold Weather Operations
- SYS EF-205 Completed December 26, 2017 APF 15C-002-01 Procedure Cover Sheet
- ESW/Circ Water Cold Weather Operations
- SYS EF-205 Completed January 2, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Day Shift January 19, 2018 APF 29B-003-01 Surveillance Test Routing Sheet
- ESW Train B Warming Line Verification
- STN EF-020B Completed January 3, 2018 WM 96-0081 Docket No 50
-482: Response to Enforcement Action EA 96-124 July 31, 1996 Section 1R04: Equipment Alignment Procedures Number Title Revision CKL Al-120 Auxiliary Feedwater Normal Lineup 42 CKL EG-120 Component Cooling Water System Valve, Switch and Breaker Lineup 49 CKL EJ-120 RHR System Lineup 45B A1-2 Drawings Number Title Revision M-06EG07 Component Coolant Wtr. Sys. Aux. Bldg.


4 M-12AL01 Piping & Instrumentation Diagram Auxiliary Feedwater System 28 M-12EG01 Piping & Instrumentation Diagram Component Cooling Water System 24 M-12EG02 Piping & Instrumentation Diagram Component Cooling Water System 27 M-12EG03 Piping & Instrumentation Diagram Component Cooling Water System 19 M-12EJ01 Piping and Instrumentation Diagram Residual Heat Removal System 53 M-12FC02 Piping & Instrumentation Diagram Auxiliary Feedwater Pump Turbine 25 M-13EG07 Piping Isometric Component Cooling Water Sys. Aux. Bldg. Common Header 3 M-15EG07 Hanger Location Drawing Component Cooling Water Sys Aux. Bldg. Common Header 14 Condition Reports 119280 119401 120586 Section 1R05: Fire Protection Procedures Number Title Revision AP 10-106 Fire Preplans 18A CKL ZL-001 Auxiliary Building Reading Sheets 103 Condition Reports 119366 120782 120783 120784 Miscellaneous Number Title Revision E-1F9905 Fire Hazard Analysis 8 XX-X-004 Calculation Cover Sheet
Lead Inspector: Douglas Dodson, Senior Resident Inspector
- Combustible Fire Loading For Each Room In The Various Fire Areas at WCNOC 4
A1-3 Section 1R06: Flood Protection Measures Procedures Number Title Revision ALR 00-094F Misc Sumps Lev Hi 5 Drawings Number Title Revision M-12EJ01 Piping and Instrumentation Diagram Residual Heat Removal System 53 M-13LF02 Piping Isometric Sump Discharge Auxiliary Bldg.


1 Condition Reports 118576 118586 118587 118592 118593 Miscellaneous Number Title Revision FL-03 Flooding of Individual Auxiliary Building Rooms 2 Section 1R0 7: Heat Sink Performance Procedures Number Title Revision AP 23L-002 Heat Exchanger Program 5 Work Orders 17-428729-000 17-428729-002 17-428729-003 17-428729-005 17-428737-000 Miscellaneous Number Title Date GL-05 Maintenance Rule Final Scope Evaluation Printed March 27, 2018 A1-4 Section 1R11: Licensed Operator Requalification Program Procedures Number Title Revision AP 21-001 Conduct of Operations 81 STS RE-006 EOL Core MTC Measurement 20B STS SE-001 Power Range Adjustment to Calorimetric 35 Miscellaneous Number Title Revision/Date APF 21-001-02 Control Room Turnover Checklist
I.
- On-Coming CRS/WC SRO/RO/BOP Review
Information Requested Prior to December 22, 2017  
- Day Shift February 2, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Day Shift February 3, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift February 3, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift February 4, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift February 5, 2018 APF 29B-003-01 Surveillance Test Routing Sheet
- EOL Core MTC Measurement Completed February 5, 2018 EPF 06-007-01 Wolf Creek Generating Station Emergency Notification (Drill) February 22, 2018 LR5004005 Loss of All AC While Shutdown
- Licensed Operator Requal 12 Section 1R12: Maintenance Effectiveness Drawings Number Title Revision/Date M-12GL01 Piping and Instrumentation Diagram Auxiliary Building HVAC 13 M-612.00062 Carrier Air Handling Units and Room Coolers Imaged May 2017 Condition Reports 10539 114660 117759 A1-5 Miscellaneous Number Title Date GL Room Cooler PM Schedule Maintenance Rule Expert Panel Meeting Agenda November 1, 2017 114660 Functional Failure Determination Checklist August 17, 2017 GL-01 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-02 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-03 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-04 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-05 Maintenance Rule Final Scope Evaluati on Printed January 29, 2018 GL-06 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-07 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-08 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-09 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 Section 1R13: Maintenance Risk Assessment and Emergent Work Controls Procedures Number Title Revision AP 22C-003 On-Line Nuclear Safety and Generation Risk Assessment 22 A1-6 Procedures Number Title Revision OFN AF-025 Unit Limitations 52 STS BB-201B Cycle Test of PORV Block Valve BB HV
-800B 4 STS IC-447 Channel Calibration Nuclear Instrumentation System Power Range Incore
-Excore 46 STS MT-024B Functional Test of 480 and 120 Volt Molded Case Circuit Breakers 17 Drawings Number Title Revision M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout W03 Condition Reports 118499 118938 118939 118940 118953 118958 118959 118963 118964 Work Orders 17-422791-003 17-427320-000 18-434985-000 18-435758-000 18-435758-001 Miscellaneous Number Title Date APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Day Shift January 23, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review - Night Shift January 23, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Day Shift January 24, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift January 24, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift January 25, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift January 26, 2018 APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
18-0101 January 4, 2018 A1-7 Miscellaneous Number Title Date APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
18-0111 March 13, 2018 APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
2018-0110 February 15, 2018 APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
2018-0104 January 10, 2018 APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment
-2018-0122 February 14, 2018 APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-447 Completed January 4, 2018 APF 29B-003-01 Surveillance Test Routing Sheet
- STS PE-004 (Train B)
Completed March 7, 2018 Section 1R15: Operability Evaluations Procedures Number Title Revision AI 16C-006 Troubleshooting 9 AI 28B-005 Evidence and Action Matrix 4 AP 12-003 Foreign Material Exclusion 16 AP 26C-004 Operability Determination and Functionality Assessment 35 OFN BB-005 RCP Malfunctions 27 STN BB-201 Exercise of BB HV
-8157A and BB HV
-8157B 3 STS BG-001 Boron Injection Flow Path Verification 20 STS KJ-005A Manual/Auto Start, Sync and Loading of EDG NE01 67A STS PE-004 Auxiliary Building and Control Room Pressure Test 16 SYS GK-122 Manual CRVIS Line
-Up 24 SYS OPS-001 Weekly Equipment Rotation and Readings 80A Drawings Number Title Revision E-13GG01 Schematic Diagram Emergency Exhaust Fans 6 E-13GG03 Schematic Diagram Emergency Exhaust Heating Coils 1
A1-8 Drawings Number Title Revision E-13GG15 Schematic Diagram Emergency Exhaust Cross Connection Dampers 0 J-02GG14B (Q)
Fuel Building HVAC Spent Fuel Pool Normal/Emergency Exhaust Radioactivity Sample Valve 0 M-12BB02 Piping & Instrumentation Diagram Reactor Coolant System 27 M-12BB03 Piping and Instrumentation Diagram Reactor Coolant System 15 M-12BG01 Piping & Instrumentation Diagram Chemical and Volume Control System 19 M-12BL01 Piping & Instrumentation Diagram Reactor Make
-Up Water System 15 M-12GG01 Piping Instrumentation Diagram Fuel Building HVAC 8 M-12GT01 Piping & Instrumentation Diagram Containment Purge Systems HVAC 24 M-12HB01 Piping and Instrumentation Diagram Liquid Radwaste System 15 M-12LF01 Piping & Instrumentation Diagram Auxiliary Building Floor and Equipment Drain System 3 M-12LF03 Piping & Instrumentation Diagram Auxiliary Building Floor and Equipment Drain System 6 M-1H1531 Heating Ventilating and Air Cond. Auxiliary Building El. 2047'
-6" Area-3 5 M-1H6311 Heating Ventilating & Air Cond. Fuel Building El. 2047'
-6" & 2065'-0" Area 1 2 M-622.1A-00001 SGK05A & SGK05B Air Conditioner Refrigeration Schematic W12 M-622.1A-00002 SGK05A & SGK05B Air Conditioner Electrical Schematic W13 M-622.1A-00003 SGK05A & SGK05B Air Conditioner Electrical Schematic W09 M-622.1A-00257 Step Controllers W01 M-712-00063 Reactor Coolant Pump Data Sheets W04 M-OPIII Embedded Drainage Systems (LF) Auxiliary Building EL.


1967'-0" & 1974'
The following information should be provided in electronic format (Certrec IMS
-0" Area I 5 Condition Reports 24199 90975 107789 110377 117283 118586 118587 118592 118827 118830 A1-9 Condition Reports 118831 118910 118922 119069 119085 119330 119334 119442 119446 119487 119616 119822 119859 119860 119861 120053 120056 120071 120179 120181 120246 120287 120408 120409 120410 120411 120489 120535 120664 120722 Work Orders 16-411783-010 17-428518-000 18-436340-000 18-436340-002 Miscellaneous Number Title Revision/Date 107363 Functional Failure Determination Checklist October 12, 2016 118585 Function Failure Determination Checklist January 28, 2018 AIF 10-001-02 SCBA Inspection Completed March 1, 2018 APF 05-002-05 Engineering Disposition
preferred), to the attention of Douglas Dodson by December 22, 2017, to facilitate the
- EDG Water, Lube Oil, and Fuel Oil Leakage Guidance 00 APF 05C-004-01 Basic Engineering Disposition
reduction in the items to be selected for a final list during inspection preparation. The
- Review of Regulatory and License Basis Documents to evaluate the requirements of Operability Determination when Safety Related or Technical Specification Equipment is exposed to a hazard 00 APF 21-001-02 Control Room Turnover checklist
inspection team will finalize its sample selections and will provide an additional
- On-Coming CRS/WC SRO/RO/BOP Review
information request with specific items. This information shall be made available by
- Night Shift March 14, 2018 APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
December 22, 2017. The specific items selected from the lists shall be available and
2018-0112 February 14, 2018 APF30B-004-01 Wolf Creek Nuclear Operating Corporation Essential Required Reading
ready for review on the day indicated in this request. *Please provide requested
- SBO Power Equipment Center (PEC)
documentation electronically in pdf files, Excel, or other searchable formats, if possible.
April 1, 2018 GG-01 Maintenance Rule Final Scope Evaluation Printed March 22, 2018 GG-02 Maintenance Rule Final Scope Evaluation Printed March 22, 2018 A1-10 Miscellaneous Number Title Revision/Date GG-03 Maintenance Rule Final Scope Evaluation Printed March 22, 2018 GG-04 Maintenance Rule Final Scope Evaluation Printed March 22, 2018 Section 1R19: Post
The information should contain descriptive names, and be indexed and hyperlinked to
-Maintenance Testing Procedures Number Title Revision STN AL-201 Auxiliary Feedwater System Valve Test 8 STN EG-205A Component Cooling Water System Valve Test 2 STS EG-100A Component Cooling Water Pumps A/C [Air Conditioning] Inservice Pump Test 33A STS EG-208A EG TV-029 CCW [Component Cooling Water] HX [Heat Exchanger] A Temperature Control Valve Inservice Valve Test 1 STS EJ-100A RHR [Residual Heat Removal] System Inservice Pump A Test 55 STS IC-540A Channel Calibration Auxiliary Feedwater System Steam Generator A 9 Drawings Number Title Revision/Date E-13GK13 Schematic Diagram Class 1E Electrical Equipment A/C [Air Conditioning] Unit 6 M-12AL01 Piping & Instrumentation Diagram Auxiliary Feedwater System 23 M-12AL01 Piping & Instrumentation Diagram Auxiliary Feedwater System 28 M-622.1-00036 Electric Motor Data Sheet March 3, 1977 M-622.1A-00002 SKG05A & SGK05B Air Conditioner Electrical Schematic W13 M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout W03 A1-11 Condition Reports 118881 118901 118920 118953 118958 118959 118963 118964 119289 Work Orders 15-407137-000 Miscellaneous Number Title Revision/Date WCGS Standing Order 1
facilitate ease of use. Information in lists should contain enough information to be
- Valve Setup and Operation 45 36121 Preventative Maintenance Work Instruction APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment January 23, 2018 APF 29B-003-01 Surveillance Test Routing Sheet
easily understood by someone who has knowledge of pressurized water reactor
- Auxiliary Feedwater System Valve Test Completed February 6, 2018 Section 1R20
technology. If requested documents are large and/or only hard copy formats are
: Refueling and Other Outage Activities Procedures Number Title Revision GEN 00-004 Power Operation 89 GEN 00-005 Minimum Load To Hot Standby 90 SYS AE-320 Turbine Driven Main Feedwater Pump Shutdown 28A SYS AF-121 Heater Drain Pump Operation 24 Section 1R 22: Surveillance Testing Procedures Number Title Revision AP 23-009 Control Room Envelope Habitability Program 2 STS EG-100B Component Cooling Water Pumps B/D Inservice Pump Test 29 STS IC-217 RCP Loss of Voltage and Underfrequency TADOT 15C STS IC-915B Channel Operational Test Train B Component Cooling Water System Non
available, please inform the inspector(s), and provide subject documentation.  
-Nuclear Safety
-Related Isolation 8A STS IC-926A Component Cooling Water System Automatic Valve Actuation Train A 8A A1-12 Procedures Number Title Revision STS IC-926B Component Cooling Water System Automatic Valve Actuation Train B 6B STS PE-004 Auxiliary Building and Control Room Pressure Test 16 Drawings Number Title Revision E-13EG01D Schematic Diagram Component Cooling Water Pump D 5 E-13EG08A Schematic Diagram Component Cooling Water Supply Return From Radwaste Building 3 E-13EG11 Schematic Diagram Annunciation and Instrumentation 4 E-13EG20 Schematic Diagram Pass CCW Isolation Valves 3 M-12EG01 Piping & Instrumentation Diagram Component Cooling Water System 24 M-12EG02 Piping & Instrumentation Diagram Component Cooling Water System 27 M-12EG03 Piping & Instrumentation Diagram Component Cooling Water System 19 Condition Reports 118493 118551 118552 119412 120061 120064 120148 120151 120408 120409 120410 120411 Work Orders 17-431050-000 17-431170-000 17-431759-000 17-432247-000 Miscellaneous Number Title Date APF 29B-003-01 Surveillance Test Routing Sheet
- STS IC-217 Completed March 5, 2018 APF 29B-003-01 Surveillance Test Routing Sheet
- STS IC-926B Completed January 4, 2018 A1-13 Miscellaneous Number Title Date APF 30B-004-01 Wolf Creek Nuclear Operating Corporation Essential Required Reading: 18
-0010 Accuracy of WCRE
-35 March 7, 2018 Section 1EP6: Drill Evaluation Procedures Number Title Revision EPP 06-006 Protective Action Recommendations 9A Condition Reports 119869 119870 119871 119872 119874 119877 119878 119879 119883 119885 119886 119887 119888 119889 119897 119901 119903 119904 119906 119911 119941 120017 120227 120323 Miscellaneous Number Title Revision/Date 18-SA-01 Wolf Creek Generating Station
- Emergency Planning Drill February 27, 2018 APF 06-002-01 Emergency Action Levels 17A CR-001 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 EOF-001 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 EOF-002 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 EOF-003 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 EOF-004 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 TSC-001 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 A1-14 Section 4OA1: Performance Indicator Verification Miscellaneous Number Title Revision NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7 Section 4OA2: Identification and Resolution of Problems Procedures Number Title Revision STS MT-005 Pressurizer Code Safety Valve Operability 20 Drawings Number Title Revision M-1H1531 Heating Ventilating and Air Cond. Auxiliary Building El.


2047'-6" Area-3 5 Condition Reports 90975 110377 112960 118910 119330 Work Orders 17-428518-001 Miscellaneous Number Title Date Email from NWS Technologies to Wolf Creek
1. Any pre-existing evaluation or list of component cooling water system components
<EXTERNAL> RE: Wolf Creek PSV failure
and associated calculations with low design margins.
- Questions from our NRC Resident Inspector November 30, 2017 P.O. # 692145 SR Valve Serial Number N60446
-00-0001; Traveler 14
-381 Testing Completed January 2015 PO # 779245 Valve Serial Number N60446
-00-0001; Traveler 17
-41 Testing Completed August 2017 NRC Letter to Otto L. Maynard Wolf Creek Generating Station
- Issuance of Amendment RE: Pressurizer Safety Valves (TAC NO. MA6969) March 23, 2000 White Paper Pressurizer Safety Valve NRC Follow
-up Questions and Answers A1-15 White Paper Why PZR Safety Valve Failure is NOT a Part 21 Issue


Attachment 2 Initial Request for Information Integrated Inspection Wolf Creek Nuclear Generating Station Inspection Report:  05000482/2018001 Inspection Dates:  January 1
2. A list of high risk component cooling water system maintenance rule components
- March 31, 2018 Inspection Procedure: Integrated Inspection Procedures Lead Inspector:  Douglas Dodson, Senior Resident Inspector I. Information Requested Prior to December 22, 2017 The following information should be provided in electronic format (Certrec IMS preferred), to the attention of Douglas Dodson by December 22, 2017, to facilitate the reduction in the items to be selected for a final list during inspection preparation. The inspection team will finalize its sample selections and will provide an additional information request with specific items. This information shall be made available by December 22, 2017. The specific items selected from the lists shall be available and ready for review on the day indicated in this request. *Please provide requested documentation electronically in "pdf" files, Excel, or other searchable formats, if possible. The information should contain descriptive names, and be indexed and hyperlinked to facilitate ease of use. Information in "lists" should contain enough information to be easily understood by someone who has knowledge of pressurized water reactor technology. If requested documents are large and/or only hard copy formats are available, please inform the inspector(s), and provide subject documentatio n. 1. Any pre-existing evaluation or list of component cooling water system components and associated calculations with low design margins.
and functions based on engineering or expert panel judgment.  


2. A list of high risk component cooling water system maintenance rule components and functions based on engineering or expert panel judgment.
3. A list of component cooling water system related operating experience evaluations
for the last 3 years.  


3. A list of component cooling water system related operating experience evaluations for the last 3 years.
4. A list of all component cooling water system time-critical operator actions in
procedures.  


4. A list of all component cooling water system time
5. A list of permanent and temporary modifications related to component cooling water
-critical operator actions in procedures.
system sorted by component.  


5. A list of permanent and temporary modifications related to component cooling water system sorted by component.
6. A list of current component cooling water system related operator work
arounds/burdens.  


6. A list of current component cooling water system related "operator work arounds/burdens."
7. A list of the component cooling water system design calculations, which provide the
design margin information for components.  


7. A list of the component cooling water system design calculations, which provide the design margin information for components.
8. List of component cooling water system root cause evaluations associated with


8. List of component cooling water system root cause evaluations associated with A2-2 component failures or design issues initiated/completed in the last 5 years.
component failures or design issues initiated/completed in the last 5 years.  


9. A list of any component cooling water system common
9. A list of any component cooling water system common-cause failures of
-cause failures of components in the last 3 years.
components in the last 3 years.  


10. An electronic copy of the component cooling water system design bases documents and any open, pending, or recently completed changes. Although not an exhaustive list, please include any open, pending, or recently completed (last 3 years) changes to temporary modifications, permanent modifications, engineering change packages, and/or procedure change packages. Specifically, please include any open, pending, or recently completed changes to emergency operating, abnormal operating, normal operating, alarm response, system alignment, surveillance, or other procedure.
10. An electronic copy of the component cooling water system design bases documents
and any open, pending, or recently completed changes. Although not an exhaustive
list, please include any open, pending, or recently completed (last 3 years) changes
to temporary modifications, permanent modifications, engineering change
packages, and/or procedure change packages. Specifically, please include any
open, pending, or recently completed changes to emergency operating, abnormal
operating, normal operating, alarm response, system alignment, surveillance, or
other procedure.  


11. An electronic copy of the component cooling water system System Health notebook.
11. An electronic copy of the component cooling water system System Health notebook.  


12. A copy of component cooling water system related audits completed in the last 2 years. 13. A list of component cooling water system motor operated valves (MOVs) in the program, design margin and risk ranking.
2. A copy of component cooling water system related audits completed in the last 2
years.  


14. A list of component cooling water system air operated valves (AOVs) in the valve program, design margin and risk ranking. 15. Component cooling water system structure, system, and components' maintenance rule category, scoping, unavailability data, unreliability data, functional failure evaluations, (a)(1) determinations, (a)(1) goals, and any supporting basis documentation. 16. A list of component cooling water system licensee contacts for the inspection team with pager or phone numbers.
13. A list of component cooling water system motor operated valves (MOVs) in the
program, design margin and risk ranking.  


17. An excel spreadsheet of component cooling water system related PRA human action basic events or risk ranking of operator actions from your site specific PSA sorted by RAW and FV. Provide copies of your human reliability worksheets for these items.
14. A list of component cooling water system air operated valves (AOVs) in the valve
program, design margin and risk ranking.
15. Component cooling water system structure, system, and components maintenance
rule category, scoping, unavailability data, unreliability data, functional failure
evaluations, (a)(1) determinations, (a)(1) goals, and any supporting basis
documentation.  


18. In so far as there are recent or pending changes, please provide an Excel spreadsheet of component cooling water system related equipment basic events (with definitions) including importance measures sorted by risk achievement worth (RAW) and Fussell
16. A list of component cooling water system licensee contacts for the inspection team
- Vesely (FV) from your internal events probabilistic risk assessment (PRA). Include basic events with RAW value of 1.3 or greater.
with pager or phone numbers.  


19. In so far as there are recent or pending changes, please provide a list of the top 50 cut-sets from your PRA.
17. An excel spreadsheet of component cooling water system related PRA human
action basic events or risk ranking of operator actions from your site specific PSA
sorted by RAW and FV. Provide copies of your human reliability worksheets for
these items.  


20. In so far as there are recent or pending changes, please provide copies of PRA "system notebooks," and the latest PRA summary document.
18. In so far as there are recent or pending changes, please provide an Excel
spreadsheet of component cooling water system related equipment basic events
(with definitions) including importance measures sorted by risk achievement worth
(RAW) and Fussell-Vesely (FV) from your internal events probabilistic risk
assessment (PRA). Include basic events with RAW value of 1.3 or greater.  


21. In so far as there are recent or pending changes, and if you have an external events A2-3 or fire PSA model, provide the information requested in items 17
19. In so far as there are recent or pending changes, please provide a list of the top 50
-19 for external events and fire, as it relates to the component cooling water system.
cut-sets from your PRA.  


22. In so far as there are recent or pending changes, please provide a copy of the Wolf Creek Nuclear Generating Station IPEEE changes, if available electronically.
20. In so far as there are recent or pending changes, please provide copies of PRA
system notebooks, and the latest PRA summary document.  


ML18131A017 SUNSI Review:
21. In so far as there are recent or pending changes, and if you have an external events
ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: NHT/rdr Yes No Publicly Available Sensitive NRC-002 OFFICE SRI:DRP/B RI:DRP/B C:DRS/OB C:DRS/PSB2 C:DRS/EB1 C:DRS/EB2 NAME DDodson FThomas VGaddy HGepford TFarnholtz JDrake SIGNATURE
/RA/ /RA/ /RA/ /RA/ /RA/ /RA/ DATE 5/9/2018 5/10/18 5/3/18 5/3/18 5/3/2018 5/9/18 OFFICE TL:DRS/IPAT SRI/DRP/B BC:DRP/B NAME GGeorge DBradley NTaylor SIGNATURE
/RA - HFreeman for
/ /RA/ /RA/ DATE 5/10/18 5/7/18 5/14/18 May 14, 2018 Mr. Adam C. Heflin, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839


SUBJECT: WOLF CREEK GENERATING STATION
or fire PSA model, provide the information requested in items 17-19 for external
- NRC INTEGRATED INSPECTION REPORT 05000482/2018 001
events and fire, as it relates to the component cooling water system.


==Dear Mr. Heflin:==
2. In so far as there are recent or pending changes, please provide a copy of the Wolf
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Wolf Creek Generating Station.
Creek Nuclear Generating Station IPEEE changes, if available electronically.  


On April 25, 2018, the NRC inspectors discussed the results of this inspection with Mr. C. Reasoner, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
ML18131A017
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: NHT/rdr
Yes No
Publicly Available
Sensitive
NRC-002
OFFICE
SRI:DRP/B
RI:DRP/B
C:DRS/OB
C:DRS/PSB2
C:DRS/EB1
C:DRS/EB2
NAME
DDodson
FThomas
VGaddy
HGepford
TFarnholtz
JDrake
SIGNATURE
/RA/
/RA/
/RA/
/RA/
/RA/
/RA/
DATE
5/9/2018
5/10/18
5/3/18
5/3/18
5/3/2018
5/9/18
OFFICE
TL:DRS/IPAT
SRI/DRP/B
BC:DRP/B


NRC inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements
NAME
. The NRC is treating this violation as a non-cited violatio n consistent with Section 2.3.2 of the Enforcement Policy.
GGeorge
DBradley
NTaylor


If you contest the violation or significance of this non-cited violation
SIGNATURE
, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Wolf Creek Generating Station.
/RA -
HFreeman for/
/RA/
/RA/


If you disagree with a cross
DATE
-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S.
5/10/18
5/7/18
5/14/18


Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555
May 14, 2018
-0001; with copies to the Regional Administrator, Region IV; and t he NRC resident inspector at the Wolf Creek Generating Station
. 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.


"
Mr. Adam
: [[contact::C. Heflin]], President
and Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, KS 66839
SUBJECT:
WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION
REPORT 05000482/2018001
Dear Mr. Heflin:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Wolf Creek Generating Station. On April 25, 2018, the NRC inspectors discussed the
results of this inspection with Mr.
: [[contact::C. Reasoner]], Site Vice President, and other members of your
staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. The NRC is treating this violation as a
non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or significance of this non-cited violation, you should provide a
response within 30 days of the date of this inspection report, with the basis for your denial, to
the
: [[contact::U.S. Nuclear Regulatory Commission]], ATTN: Document Control Desk, Washington, DC
20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of
Enforcement; and the NRC resident inspector at the Wolf Creek Generating Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the
: [[contact::U.S. Nuclear Regulatory Commission]], ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the
NRC resident inspector at the Wolf Creek Generating Station.


Sincerely,/RA/ Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects Docket No. 50
A. Heflin
-482 License No. NPF-42


===Enclosure:===
This letter, its enclosure, and your response (if any) will be made available for public inspection
Inspection Report 05000482/2018001 w/ Attachment s: 1. Supplemental Information 2. Request for Information
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,


1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 05000482 License Number: NPF-42 Report Number: 05000482/2018001 Enterprise Identifier:
/RA/
I-2018-001-0012 Licensee:
Nicholas
Wolf Creek Nuclear Operating Corporation Facility:
: [[contact::H. Taylor]], Chief
Wolf Creek Generating Station Location:
Project Branch B
1550 Oxen Lane NE Burlington, KS 66839 Inspection Dates: January 1, 2018
Division of Reactor Projects
, to March 31, 2018 Inspectors:
Docket No. 50-482
D. Dodson, Senior Resident Inspector F. Thomas, Resident Inspector D. Bradley, Senior Resident Inspector, Callaway Approved By:
License No. NPF-42
N. Taylor, Chief, Project Branch B, Division of Reactor Projects
Enclosure:
Inspection Report 05000482/2018001
w/ Attachments:
1. Supplemental Information
2. Request for Information


2 SUMMARY The Nuclear Regulatory Commission (
U.S. NUCLEAR REGULATORY COMMISSION
NRC) continued monitoring the licensee's performance by conducting an Integrated Inspection at Wolf Creek Generating Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC
Inspection Report
-identified and self-revealed findings, violations, and additional items are summarized in the table below.


List of Findings and Violations Inadequate Functionality Assessment Associated with the Emergency Excess Letdown Flowpath Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000482/2018001
Docket Number:
-01 Closed [H.14] - Human Performance, Conservative Bias 71111.15
05000482  
- Operability Determinations and Functionality Assessments The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," when the licensee failed to adequately implement the operability determination and functionality assessment procedure. Specifically, the licensee failed to document a functionality assessment of sufficient scope to address the capability of a safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and the excess letdown system to perform their specified safety functions, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional.


3 PLANT STATUS Wolf Creek Generating Station began the inspection period at rated thermal power. On March 30, 2018, a plant shutdown was completed to begin Refueling Outage 22.
License Number:
NPF-42


INSPECTION SCOPE S Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading
Report Number:
-rm/doc-collections/insp
05000482/2018001
-manual/inspection
-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, "Light
-Water Reactor Inspection Program - Operations Phase." The inspectors performed plant status activities described in IMC 2515 Appendix D, "Plant Status" and conducted routine reviews using IP 71152, "Problem Identification and Resolution
." The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.


REACTOR SAFETY 71111.01 - Adverse Weather Protection Impending Severe Weather (1 Sample) The inspectors evaluated readiness for impending adverse weather conditions for extreme low temperatures on January 2 and 3, 2018. 71111.04 - Equipment Alignment Partial Walkdown (2 Samples) The inspectors evaluated system configuration s during partial walkdowns of the following systems/trains
Enterprise Identifier: I-2018-001-0012
: (1) turbine-driven auxiliary feedwater train on February 6, 2018 (2) residual heat removal pump B on March 21, 2018 Complete Walkdown (1 Sample) The inspectors evaluated system configuration s during a complete walkdown of the component cooling water system on February 23, 2018. 71111.05AQ
- Fire Protection Annual/Quarterly Quarterly Inspection (5 Samples) The inspectors evaluated fire protection program implementation in the following selected areas:
4 (1) fire area A
-16, general area, elevation 2,026 feet on January 30
, and March 28, 2018 (2) fire area A-18, electrical penetration room (north), elevation 2,026 feet on January 30, 2018 (3) fire area A-17, electrical penetration room (south), elevation 2,026 feet on March 28, 2018 (4) fire area A
-26, decontamination area for I&C shop, elevation 2,026 feet on March 28, 2018 (5) fire area A
-27, reactor trip switchgear, motor
-generator sets, load centers, rod control and rod-drive power supply control cabinets 125 volt direct current panel on March 28, 2018. 71111.06 - Flood Protection Measures Internal Flooding (1 Sample) The inspectors evaluated internal flooding mitigation protections in rooms 1203 and 1203A, Pipe Space B on January 9, 2018
. 71111.07 - Heat Sink Performance Heat Sink (1 Sample)
The inspectors evaluated containment spray train A room cooler (SGL13A)
performance on January 17, 2018
. 71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification (1 Sample) The inspectors observed and evaluated licensed operator simulator requalification activities that included a loss of all alternating current power during shutdown scenario on February 22, 2018. Operator Performance (1 Sample) The inspectors observed and evaluated operator performance during end of life core moderator temperature coefficient measurement activities on February 5, 2018
. 71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness (1 Sample) The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions
: Auxiliary building heating ventilation and air conditioning (
GL) system including safety
-
5 related pump and electrical penetration room coolers on January 29, 2018
. 71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples) The inspectors evaluated the risk assessments for the following planned and emergent work activities
: (1) reactor partial trip alarm troubleshooting and main generator transformer B loss of two cooling groups on January 4, 2018 (2) emergent maintenance on Class 1E electrical equipment air conditioning unit train A on January 24, 2018 (3) planned maintenance on component cooling water train B on March 5, 2018 (4) emergent maintenance associated with the failed control room envelope pressure test on March 6, 2018 (5) emergent maintenance on Class 1E electrical equipment air conditioning unit train B on March 12, 2018. 71111.15 - Operability Determinations and Functionality Assessments (8 Samples) The inspectors evaluated the following operability determinations and functionality assessments:
(1) auxiliary building elevation 1988 f oot south pipe chase drain functionality with three clogged floor drains on January 10, 2018 (2) 125 volt direct current to 120 volt alternating current NN15 inverter operability after a high voltage alarm would not clear on January 1 8, 2018 (3) emergency diesel generator A lubrication oil leakage on January 31, 2018 (4) Class 1E electrical equipment air conditioning unit train B operability following a step controller failure on February 12, 2018 (5) reactor coolant pump A standpipe not filling on the expected frequency on February 25, 2018 (6) Technical Specification 3.7.10 mitigating actions to ensure the control room envelope occupant radiological exposures would not exceed limits and control room envelope occupants are protected from chemical and smoke hazards while the control room envelope was inoperable on March 6, 2018 (7) excess letdown heat exchanger outlet to pressurizer relief tank isolation valve functionality after failed stoke testing on March 12, 2018 (8) station blackout diesel generator functionality after post maintenance testing on March 20, 2018.


6 71111.19 - Post Maintenance Testing (4 Samples) The inspectors evaluated the following post maintenance tests: (1) Class 1E electrical equipment air conditioning unit train A following planned maintenance on January 24, 2018 (2) motor-driven auxiliary feedwater train B pump discharge to steam generators A and D auxiliary feed water flow regulating valve testing following planned maintenance on February 6, 2018 (3) component cooling water pump A following planned maintenance on February 15, 2018 (4) residual heat removal pump A following planned maintenance on March 21, 2018
Licensee:
. 71111.20 - Refueling and Other Outage Activities (Partial Sample) The inspectors evaluated Refueling Outage 22 activities from March 30 to 31, 2018. The inspectors completed inspection procedure Sections 03.01.a, 03.01.b, and 03.01.c. 71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:
Wolf Creek Nuclear Operating Corporation
Routine (5 Samples) (1) STS IC-926B, Component Cooling Water System Automatic Valve Actuation Train B, Revision 6B, on January 4, 2018 (2) STS IC-915B, Channel Operational Test Train B Component Cooling Water System Non-Nuclear Safety
-Related Isolation, Revision 8A, on January 8, 2018 (3) STS IC-926A, Component Cooling Water System Automatic Valve Actuation Train A, Revision 8A, on February 12, 2018 (4) STS IC-217, [Reactor Coolant Pump] Loss of Voltage and Underfrequency [Trip Actuation Device Operational Testing], on March 5, 2018 (5) STS PE-004, Auxiliary Building and Control Room Pressure Test s, Revision 16
, on March 5 and March 12, 2018
. 71114.06 - Drill Evaluation Emergency Planning Drill (1 Sample) The inspectors evaluated the emergency preparedness drill on February 27, 2018
.
7 OTHER ACTIVITIES
- BASELINE 71151 - Performance Indicator Verification (3 Samples
) The inspectors verified licensee performance indicator submittals listed below: (1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017
-12/31/2017
) (2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017
-12/31/2017
) (3) IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017
-12/31/2017). 71152 - Problem Identification and Resolution Annual Follow
-up of Selected Issues (2 Samples) The inspectors reviewed the licensee's implementation of its corrective action program related to the following issues:
(1) On February 8, 2018, the unit vent tornado damper failed to meet acceptance criteria for initial breakaway torque. This issue was documented in Condition Report 119330.


(2) On May 11, 2017, Condition Report 112960 documented that pressurizer safety valve 88010A's as
Facility:
-found lift setting was 3.2 percent below the nominal setpoint.
Wolf Creek Generating Station


8 INSPECTION RESULTS Inadequate Functionality Assessment Associated with the Emergency Excess Letdown Flowpath Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000482/2018001
Location:
-01 Closed [H.14] - Human Performance, Conservative Bias 71111.15
1550 Oxen Lane NE
- Operability Determinations and Functionality Assessments The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," when the licensee failed to adequately implement the operability determination and functionality assessment procedure. Specifically, the licensee failed to document a functionality assessment of sufficient scope to address the capability of a safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and the excess letdown system to perform their specified safety functions, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional
. Description
: On March 12, 2018, the licensee was performing Procedure STN BB
-201, "Exercise of BB HV
-8157A and BB HV
-8157B," Revision 3, which tests and exercises the excess letdown heat exchanger to pressurizer relief tank isolation valves (BB HV
-8157A and BB HV-8157B). The BB HV-8157B valve did not stroke fully closed as expected. Step 6.1.1 of Procedure STN BB
-201 states, "If the valve cannot be fully exercised, then valve shall be declared inoperable and corrective action initiated."


Condition Report 120287 was documented on March 12, 2018, reporting the valve failure. The immediat e functionality assessment stated, "The redundant path of excess letdown is still available. The system is functional but degraded. The system functionality is maintained by having a second redundant flow path for excess letdown." The inspectors noted that Section 6.4.7 of Procedure AP 26C
Burlington, KS 66839
-004, "Operability Determination and Functionality Assessment," Revision 35, states,  
Inspection Dates:
"The scope of a functionality assessment must be sufficient to address the capability of SSCs to perform their specified functions-The following things should be considered when performing functionality assessments: codes, standards and system requirements controlling the SSC."
January 1, 2018, to March 31, 2018


The inspectors questioned the licensee concerning the immediate functionality determination's adequacy, and the licensee revised the functionality determination for the excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) and changed the determination to non-functional. The immediate functionality determination was updated to state: The above screening gives an adequate justification for why the excess letdown po[r]tion of the [chemical and volume control system] remains functional but degraded. However, screening should be based on the component, not the system. Since BBHV8157B cannot be relied upon to go to the closed position using normal remote controls, the valve is considered nonfunctional.
Inspectors:
: [[contact::D. Dodson]], Senior Resident Inspector
: [[contact::F. Thomas]], Resident Inspector
: [[contact::D. Bradley]], Senior Resident Inspector, Callaway
Approved By:
: [[contact::N. Taylor]], Chief, Project Branch B, Division of Reactor Projects


The system remains functional but degraded.
SUMMARY
The Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance
by conducting an Integrated Inspection at Wolf Creek Generating Station in accordance with the
Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and
self-revealed findings, violations, and additional items are summarized in the table below.
List of Findings and Violations


9 The inspectors also noted that Section 3.1.9, "Boration Injection System
Inadequate Functionality Assessment Associated with the Emergency Excess Letdown
- Operating," of t he Technical Requirements Manual, requires two boration injection subsystems to be functional in MODES 1, 2, and 3. Section 3.1.9 of the Technical Requirements Manual Bases describes what is required for a boration injection subsystem to be considered functional. Specifically, both subsystems require the safety-related excess letdown flow path.
Flowpath
Cornerstone
Significance
Cross-cutting Aspect Report Section
Mitigating
Systems
Green
NCV 05000482/2018001-01
Closed
[H.14] - Human
Performance,
Conservative Bias
71111.15 -
Operability
Determinations
and Functionality
Assessments
The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to
adequately implement the operability determination and functionality assessment procedure.
Specifically, the licensee failed to document a functionality assessment of sufficient scope to
address the capability of a safety-related excess letdown heat exchanger to pressurizer relief
tank isolation valve and the excess letdown system to perform their specified safety functions,
which resulted in the licensee failing to recognize that two independent Technical
Requirements Manual required boration injection subsystems were not functional.  


Also, two independent boration injection subsystems are required to ensure single functional capability in the event an assumed failure renders one of the boration injection subsystems nonfunctional.
PLANT STATUS
Wolf Creek Generating Station began the inspection period at rated thermal power. On
March 30, 2018, a plant shutdown was completed to begin Refueling Outage 22.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed plant status activities described in
IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem
Identification and Resolution. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather (1 Sample)
The inspectors evaluated readiness for impending adverse weather conditions for extreme
low temperatures on January 2 and 3, 2018.
71111.04 - Equipment Alignment
Partial Walkdown (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) turbine-driven auxiliary feedwater train on February 6, 2018
(2) residual heat removal pump B on March 21, 2018
Complete Walkdown (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of the
component cooling water system on February 23, 2018.
71111.05AQ - Fire Protection Annual/Quarterly
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:


Updated Safety Analysis Report Section 7.4.3.3 describe s the applicable single failure analysis. It states
(1) fire area A-16, general area, elevation 2,026 feet on January 30, and March 28, 2018
, "The capability of the [residual heat removal system] to accommodate a single component failure and still perform a safety grade cooldown is demonstrated in the failure mode and effects analysis (FMEA) of the [residual heat removal
(2) fire area A-18, electrical penetration room (north), elevation 2,026 feet on January 30,
] system for safety
2018
-related cold shutdown operations provided as Table 7.4
(3) fire area A-17, electrical penetration room (south), elevation 2,026 feet on March 28,
-4." Table 7.4
2018
-4, "Residual Heat Removal - Safety Related Cold Shutdown Operations
(4) fire area A-26, decontamination area for I&C shop, elevation 2,026 feet on March 28,
- Failure Modes and Effects Analysis (FMEA)," describes the function of the excess letdown to pressurizer relief tank isolation valves (8157A and 8157B
2018
), stating,
(5) fire area A-27, reactor trip switchgear, motor-generator sets, load centers, rod control
"Provides safety grade letdown flow path."
and rod-drive power supply control cabinets 125 volt direct current panel on March 28,
2018.
71111.06 - Flood Protection Measures
Internal Flooding (1 Sample)
The inspectors evaluated internal flooding mitigation protections in rooms 1203 and 1203A,
Pipe Space B on January 9, 2018.
71111.07 - Heat Sink Performance
Heat Sink (1 Sample)
The inspectors evaluated containment spray train A room cooler (SGL13A) performance on
January 17, 2018.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated licensed operator simulator requalification activities
that included a loss of all alternating current power during shutdown scenario on February 22,
2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated operator performance during end of life core moderator
temperature coefficient measurement activities on February 5, 2018.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness (1 Sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated
with the following equipment and/or safety significant functions:
Auxiliary building heating ventilation and air conditioning (GL) system including safety-


Hence, in order for the safety
related pump and electrical penetration room coolers on January 29, 2018.
-related excess letdown flowpath to the pressurizer relief tank to meet its safety function, either 8157A or 8157B must be functional and capable of opening. The inspectors again questioned the updated immediate functionality determination's adequacy. Specifically, considering that 8157A and 8157B are parallel valves
71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples)
, that 8157B was non-functional
The inspectors evaluated the risk assessments for the following planned and emergent
, and assuming a design basis single failure (for example, assume 8157A fails to open or its power supply fails), the safety-related excess letdown flowpath would be non-functional
work activities:
, and both Technical Requirements Manual independent boration injection subsystems would be impacted. With the excess letdown heat exchanger to pressurizer relief tank isolation valve 8157B non
(1) reactor partial trip alarm troubleshooting and main generator transformer B loss of two
-functional, current language in the Technical Requirements Manual would require one boration injection subsystem to be declared non
cooling groups on January 4, 2018
-functional.
(2) emergent maintenance on Class 1E electrical equipment air conditioning unit train A on
January 24, 2018
(3) planned maintenance on component cooling water train B on March 5, 2018
(4) emergent maintenance associated with the failed control room envelope pressure test
on March 6, 2018
(5) emergent maintenance on Class 1E electrical equipment air conditioning unit train B on
March 12, 2018.
71111.15 - Operability Determinations and Functionality Assessments (8 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) auxiliary building elevation 1988 foot south pipe chase drain functionality with three
clogged floor drains on January 10, 2018
(2) 125 volt direct current to 120 volt alternating current NN15 inverter operability after a
high voltage alarm would not clear on January 18, 2018
(3) emergency diesel generator A lubrication oil leakage on January 31, 2018
(4) Class 1E electrical equipment air conditioning unit train B operability following a step
controller failure on February 12, 2018
(5) reactor coolant pump A standpipe not filling on the expected frequency on February 25,
2018
(6) Technical Specification 3.7.10 mitigating actions to ensure the control room envelope
occupant radiological exposures would not exceed limits and control room envelope
occupants are protected from chemical and smoke hazards while the control room
envelope was inoperable on March 6, 2018
(7) excess letdown heat exchanger outlet to pressurizer relief tank isolation valve
functionality after failed stoke testing on March 12, 2018
(8) station blackout diesel generator functionality after post maintenance testing on
March 20, 2018.  


Correctiv e Actions: On March 20, 2018, the licensee changed the functionality assessment
71111.19 - Post Maintenance Testing (4 Samples)
-the excess letdown heat exchanger to pressurizer relief tank isolation valve (
The inspectors evaluated the following post maintenance tests:  
8157B) was determined to be non
(1) Class 1E electrical equipment air conditioning unit train A following planned maintenance
-functional. In response to the inspectors' questions concerning system functionality and design basis information, the licensee initiated Condition Report s 120628 and 120822
on January 24, 2018
. The licensee restored the B train excess letdown heat exchanger to pressurizer relief tank isolation valve to service on April 9, 2018.
(2) motor-driven auxiliary feedwater train B pump discharge to steam generators A and D
auxiliary feed water flow regulating valve testing following planned maintenance on
February 6, 2018
(3) component cooling water pump A following planned maintenance on February 15, 2018
(4) residual heat removal pump A following planned maintenance on March 21, 2018.
71111.20 - Refueling and Other Outage Activities (Partial Sample)
The inspectors evaluated Refueling Outage 22 activities from March 30 to 31, 2018. The
inspectors completed inspection procedure Sections 03.01.a, 03.01.b, and 03.01.c.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (5 Samples)
(1) STS IC-926B, Component Cooling Water System Automatic Valve Actuation Train B,
Revision 6B, on January 4, 2018
(2) STS IC-915B, Channel Operational Test Train B Component Cooling Water System
Non-Nuclear Safety-Related Isolation, Revision 8A, on January 8, 2018
(3) STS IC-926A, Component Cooling Water System Automatic Valve Actuation Train A,
Revision 8A, on February 12, 2018
(4) STS IC-217, [Reactor Coolant Pump] Loss of Voltage and Underfrequency [Trip
Actuation Device Operational Testing], on March 5, 2018
(5) STS PE-004, Auxiliary Building and Control Room Pressure Tests, Revision 16, on
March 5 and March 12, 2018.
71114.06 - Drill Evaluation
Emergency Planning Drill (1 Sample)
The inspectors evaluated the emergency preparedness drill on February 27, 2018.  


Corrective Action References:
OTHER ACTIVITIES - BASELINE
Condition Reports 120287, 120628, 120822 and 122411
71151 - Performance Indicator Verification (3 Samples)
. Performance Assessment
The inspectors verified licensee performance indicator submittals listed below:
: Performance Deficiency: The licensee failed to document a functionality assessment of sufficient scope to address the capability of the safety
(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017-12/31/2017)
-related excess letdown heat exchanger to pressurizer relief tank isolation valve and excess letdown system to perform their specified safety functions
(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017-
. Screening:
2/31/2017)
The inspectors determined the performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the safety
(3) IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017-12/31/2017).
-related excess letdown heat exchanger to pressurizer relief tank isolation valve and excess letdown system were inappropriately determined to be functional but degraded and non
71152 - Problem Identification and Resolution
-conforming, which resulted in the licensee failing to recognize that two 10 independent Technical Requirements Manual required boration injection subsystems were not functional
Annual Follow-up of Selected Issues (2 Samples)
. Significance
The inspectors reviewed the licensees implementation of its corrective action program
: The inspectors assessed the significance of the finding using Exhibit 2, "Mitigating Systems Screening Questions," of Inspection Manual Chapter 0609, Appendix A, "Significance Determination Process (SDP) for Findings At
related to the following issues:
-Power," issued June 19, 2012, and determined this finding is not a deficiency affecting the design or qualification of a mitigating SSC that maintained its operability or functionality; the finding does not represent a loss of system and/or function; the finding does not represent an actual loss of function of at least a single train for greater than its Technical Specification
(1) On February 8, 2018, the unit vent tornado damper failed to meet acceptance criteria for
-allowed outage time; and the finding does not represent an actual loss of function of one or more non
initial breakaway torque. This issue was documented in Condition Report 119330.
-Technical Specification trains of equipment designated as high safety
(2) On May 11, 2017, Condition Report 112960 documented that pressurizer safety valve
-significant. Therefore, the inspectors determined the finding was of very low safety significance (Green).
88010As as-found lift setting was 3.2 percent below the nominal setpoint.  


INSPECTION RESULTS
Inadequate Functionality Assessment Associated with the Emergency Excess Letdown
Flowpath
Cornerstone
Significance
Cross-cutting Aspect
Cross-cutting Aspect
: The inspectors determined that the finding has a Human Performance cross-cutting aspect in the area of conservative bias in that individuals did not use decision making-practices that emphasize prudent choices over those that are simply allowable, and a proposed action was not determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, leaders did not take a conservative approach to decision making, particularly when information was incomplete or conditions were unusual when completing the functionality determination associated with the subject valve and system, which resulted in the valve and system being determined to be functional.
Report Section
Mitigating
Systems
Green
NCV 05000482/2018001-01
Closed
[H.14] - Human
Performance,
Conservative Bias
71111.15 -
Operability
Determinations
and Functionality
Assessments
The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part
50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee
failed to adequately implement the operability determination and functionality assessment
procedure. Specifically, the licensee failed to document a functionality assessment of
sufficient scope to address the capability of a safety-related excess letdown heat exchanger
to pressurizer relief tank isolation valve and the excess letdown system to perform their
specified safety functions, which resulted in the licensee failing to recognize that two
independent Technical Requirements Manual required boration injection subsystems were
not functional.
Description: On March 12, 2018, the licensee was performing Procedure STN BB-201,
Exercise of BB HV-8157A and BB HV-8157B, Revision 3, which tests and exercises the
excess letdown heat exchanger to pressurizer relief tank isolation valves (BB HV-8157A and
BB HV-8157B). The BB HV-8157B valve did not stroke fully closed as expected. Step 6.1.1
of Procedure STN BB-201 states, If the valve cannot be fully exercised, then valve shall be
declared inoperable and corrective action initiated.
Condition Report 120287 was documented on March 12, 2018, reporting the valve
failure. The immediate functionality assessment stated, The redundant path of
excess letdown is still available. The system is functional but degraded. The system
functionality is maintained by having a second redundant flow path for excess
letdown. The inspectors noted that Section 6.4.7 of Procedure AP 26C-004,
Operability Determination and Functionality Assessment, Revision 35, states, The
scope of a functionality assessment must be sufficient to address the capability of
SSCs to perform their specified functionsThe following things should be considered
when performing functionality assessments: codes, standards and system
requirements controlling the SSC.
The inspectors questioned the licensee concerning the immediate functionality
determinations adequacy, and the licensee revised the functionality determination for the
excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) and changed
the determination to non-functional. The immediate functionality determination was updated
to state:
The above screening gives an adequate justification for why the excess
letdown po[r]tion of the [chemical and volume control system] remains
functional but degraded. However, screening should be based on the
component, not the system. Since BBHV8157B cannot be relied upon to go to
the closed position using normal remote controls, the valve is considered
nonfunctional. The system remains functional but degraded.
 
The inspectors also noted that Section 3.1.9, Boration Injection System - Operating, of the
Technical Requirements Manual, requires two boration injection subsystems to be functional
in MODES 1, 2, and 3. Section 3.1.9 of the Technical Requirements Manual Bases describes
what is required for a boration injection subsystem to be considered functional. Specifically,
both subsystems require the safety-related excess letdown flow path. Also, two independent
boration injection subsystems are required to ensure single functional capability in the event
an assumed failure renders one of the boration injection subsystems nonfunctional.
Updated Safety Analysis Report Section 7.4.3.3 describes the applicable single failure
analysis. It states, The capability of the [residual heat removal system] to accommodate a
single component failure and still perform a safety grade cooldown is demonstrated in the
failure mode and effects analysis (FMEA) of the [residual heat removal] system for safety-
related cold shutdown operations provided as Table 7.4-4. Table 7.4-4, Residual Heat
Removal - Safety Related Cold Shutdown Operations - Failure Modes and Effects Analysis
(FMEA), describes the function of the excess letdown to pressurizer relief tank isolation
valves (8157A and 8157B), stating, Provides safety grade letdown flow path. Hence, in
order for the safety-related excess letdown flowpath to the pressurizer relief tank to meet its
safety function, either 8157A or 8157B must be functional and capable of opening.
The inspectors again questioned the updated immediate functionality determinations
adequacy. Specifically, considering that 8157A and 8157B are parallel valves, that 8157B
was non-functional, and assuming a design basis single failure (for example, assume 8157A
fails to open or its power supply fails), the safety-related excess letdown flowpath would be
non-functional, and both Technical Requirements Manual independent boration injection
subsystems would be impacted. With the excess letdown heat exchanger to pressurizer relief
tank isolation valve 8157B non-functional, current language in the Technical Requirements
Manual would require one boration injection subsystem to be declared non-functional.
Corrective Actions: On March 20, 2018, the licensee changed the functionality assessment
the excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) was
determined to be non-functional. In response to the inspectors questions concerning system
functionality and design basis information, the licensee initiated Condition Reports 120628
and 120822. The licensee restored the B train excess letdown heat exchanger to pressurizer
relief tank isolation valve to service on April 9, 2018.
Corrective Action References: Condition Reports 120287, 120628, 120822 and 122411.
Performance Assessment:
Performance Deficiency: The licensee failed to document a functionality assessment of
sufficient scope to address the capability of the safety-related excess letdown heat exchanger
to pressurizer relief tank isolation valve and excess letdown system to perform their specified
safety functions.
Screening: The inspectors determined the performance deficiency was more than minor
because it adversely affected the equipment performance attribute of the Mitigating Systems
Cornerstone objective to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences (i.e., core damage).
Specifically, the safety-related excess letdown heat exchanger to pressurizer relief tank
isolation valve and excess letdown system were inappropriately determined to be functional
but degraded and non-conforming, which resulted in the licensee failing to recognize that two
 
independent Technical Requirements Manual required boration injection subsystems were
not functional.
Significance: The inspectors assessed the significance of the finding using Exhibit 2,
Mitigating Systems Screening Questions, of Inspection Manual Chapter 0609, Appendix A,
Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012,
and determined this finding is not a deficiency affecting the design or qualification of a
mitigating SSC that maintained its operability or functionality; the finding does not represent a
loss of system and/or function; the finding does not represent an actual loss of function of at
least a single train for greater than its Technical Specification-allowed outage time; and the
finding does not represent an actual loss of function of one or more non-Technical
Specification trains of equipment designated as high safety-significant. Therefore, the
inspectors determined the finding was of very low safety significance (Green).
Cross-cutting Aspect: The inspectors determined that the finding has a Human Performance
cross-cutting aspect in the area of conservative bias in that individuals did not use decision
making-practices that emphasize prudent choices over those that are simply allowable, and a
proposed action was not determined to be safe in order to proceed, rather than unsafe in
order to stop. Specifically, leaders did not take a conservative approach to decision making,
particularly when information was incomplete or conditions were unusual when completing
the functionality determination associated with the subject valve and system, which resulted
in the valve and system being determined to be functional.
Enforcement:
Violation: Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings, requires, in part, that activities affecting quality shall be accomplished in
accordance with documented instructions, procedures, or drawings of a type appropriate to
the circumstances. Licensee Procedure AP 26C-004, Operability Determination and
Functionality Assessment, Revision 35, an Appendix B quality related procedure, provides
instructions for performing functionality assessments. Procedure AP 26C-004, Section 6.4.7,
states, in part, that the scope of a functionality assessment must be sufficient to address the
capability of SSCs to perform their specified functions, and codes, standards, and system
requirements controlling the SSC should be considered when performing functionality
assessments.
Contrary to the above, from March 12, 2018, until April 9, 2018, the scope of a functionality
assessment was not sufficient to address the capability of SSCs to perform their specified
functions, and codes, standards, and system requirements controlling the SSC were not
considered when performing functionality assessments. Specifically, the functionality
assessment associated with the excess letdown heat exchanger outlet to pressurizer relief
tank isolation valve and excess letdown system was not adequate and did not adequately
consider design basis information, which caused the licensee to fail to identify non-
functionality of safety-related SSCs.
Disposition: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
 
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 25, 2018, the inspector presented the quarterly resident inspector inspection results to
Mr.
: [[contact::C. Reasoner]], Site Vice President, and other members of the licensee staff.
 
DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Procedures
Number
Title
Revision
SYS EF-205
ESW/Circ Water Cold Weather Operations
 
Miscellaneous
Number
Title
Date
96-0316
Performance Improvement Request
Initiated
February 5,
1996
2006-0006
Performance Improvement Request
Initiated
January 4,
2006
APF 15C-002-01 Procedure Cover Sheet - ESW/Circ Water Cold Weather
Operations - SYS EF-205
Completed
December 26,
2017
APF 15C-002-01 Procedure Cover Sheet - ESW/Circ Water Cold Weather
Operations - SYS EF-205
Completed
January 2,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Day Shift
January 19,
2018
APF 29B-003-01 Surveillance Test Routing Sheet - ESW Train B Warming
Line Verification - STN EF-020B
Completed
January 3,
2018
WM 96-0081
Docket No 50-482: Response to Enforcement Action
EA 96-124
July 31, 1996
Section 1R04: Equipment Alignment
Procedures
Number
Title
Revision
CKL Al-120
Auxiliary Feedwater Normal Lineup
CKL EG-120
Component Cooling Water System Valve, Switch and
Breaker Lineup
CKL EJ-120
RHR System Lineup
45B
 
Drawings
Number
Title
Revision
M-06EG07
Component Coolant Wtr. Sys. Aux. Bldg.
M-12AL01
Piping & Instrumentation Diagram Auxiliary Feedwater
System
M-12EG01
Piping & Instrumentation Diagram Component Cooling
Water System
M-12EG02
Piping & Instrumentation Diagram Component Cooling
Water System
M-12EG03
Piping & Instrumentation Diagram Component Cooling
Water System
M-12EJ01
Piping and Instrumentation Diagram Residual Heat
Removal System
M-12FC02
Piping & Instrumentation Diagram Auxiliary Feedwater
Pump Turbine
M-13EG07
Piping Isometric Component Cooling Water Sys. Aux. Bldg.
Common Header
M-15EG07
Hanger Location Drawing Component Cooling Water Sys
Aux. Bldg. Common Header
 
Condition Reports
119280
119401
20586
 
Section 1R05: Fire Protection
Procedures
Number
Title
Revision
AP 10-106
Fire Preplans
18A
CKL ZL-001
Auxiliary Building Reading Sheets
103
Condition Reports
119366
20782
20783
20784
 
Miscellaneous
Number
Title
Revision
E-1F9905
Fire Hazard Analysis
XX-X-004
Calculation Cover Sheet - Combustible Fire Loading For
Each Room In The Various Fire Areas at WCNOC
 
Section 1R06: Flood Protection Measures
Procedures
Number
Title
Revision
ALR 00-094F
Misc Sumps Lev Hi
 
Drawings
Number
Title
Revision
M-12EJ01
Piping and Instrumentation Diagram Residual Heat
Removal System
M-13LF02
Piping Isometric Sump Discharge Auxiliary Bldg.
 
Condition Reports
118576
118586
118587
118592
118593
Miscellaneous
Number
Title
Revision
FL-03
Flooding of Individual Auxiliary Building Rooms
 
Section 1R07: Heat Sink Performance
Procedures
Number
Title
Revision
AP 23L-002
Heat Exchanger Program
 
Work Orders
17-428729-000
17-428729-002
17-428729-003
17-428729-005
17-428737-000
Miscellaneous
Number
Title
Date
GL-05
Maintenance Rule Final Scope Evaluation
Printed
March 27,
2018
 
Section 1R11: Licensed Operator Requalification Program
Procedures
Number
Title
Revision
AP 21-001
Conduct of Operations
STS RE-006
EOL Core MTC Measurement
20B
STS SE-001
Power Range Adjustment to Calorimetric
 
Miscellaneous
Number
Title
Revision/Date
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Day Shift
February 2,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Day Shift
February 3,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
February 3,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
February 4,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
February 5,
2018
APF 29B-003-01 Surveillance Test Routing Sheet - EOL Core MTC
Measurement
Completed
February 5,
2018
EPF 06-007-01
Wolf Creek Generating Station Emergency Notification
(Drill)
February 22,
2018
LR5004005
Loss of All AC While Shutdown - Licensed Operator
Requal
 
Section 1R12: Maintenance Effectiveness
Drawings
Number
Title
Revision/Date
M-12GL01
Piping and Instrumentation Diagram Auxiliary Building
HVAC
M-612.00062
Carrier Air Handling Units and Room Coolers
Imaged May
2017
Condition Reports
10539
114660
117759
 
Miscellaneous
Number
Title
Date
GL Room Cooler PM Schedule
 
Maintenance Rule Expert Panel Meeting Agenda
November 1,
2017
114660
Functional Failure Determination Checklist
August 17,
2017
GL-01
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-02
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-03
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-04
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-05
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-06
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-07
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-08
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
GL-09
Maintenance Rule Final Scope Evaluation
Printed
January 29,
2018
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
Procedures
Number
Title
Revision
AP 22C-003
On-Line Nuclear Safety and Generation Risk Assessment
 
Procedures
Number
Title
Revision
OFN AF-025
Unit Limitations
STS BB-201B
Cycle Test of PORV Block Valve BB HV-800B
STS IC-447
Channel Calibration Nuclear Instrumentation System Power
Range Incore-Excore
STS MT-024B
Functional Test of 480 and 120 Volt Molded Case Circuit
Breakers
 
Drawings
Number
Title
Revision
M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout
W03
Condition Reports
118499
118938
118939
118940
118953
118958
118959
118963
118964
 
Work Orders
17-422791-003
17-427320-000
18-434985-000
18-435758-000
18-435758-001
Miscellaneous
Number
Title
Date
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Day Shift
January 23,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
January 23,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Day Shift
January 24,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
January 24,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
January 25,
2018
APF 21-001-02
Control Room Turnover Checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
January 26,
2018
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
18-0101
January 4,
2018
 
Miscellaneous
Number
Title
Date
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
18-0111
March 13,
2018
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
2018-0110
February 15,
2018
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
2018-0104
January 10,
2018
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment -
2018-0122
February 14,
2018
APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-447
Completed
January 4,
2018
APF 29B-003-01 Surveillance Test Routing Sheet - STS PE-004 (Train B)
Completed
March 7,
2018
Section 1R15: Operability Evaluations
Procedures
Number
Title
Revision
AI 16C-006
Troubleshooting
AI 28B-005
Evidence and Action Matrix
AP 12-003
Foreign Material Exclusion
AP 26C-004
Operability Determination and Functionality Assessment
OFN BB-005
RCP Malfunctions
STN BB-201
Exercise of BB HV-8157A and BB HV-8157B
STS BG-001
Boron Injection Flow Path Verification
STS KJ-005A
Manual/Auto Start, Sync and Loading of EDG NE01
67A
STS PE-004
Auxiliary Building and Control Room Pressure Test
SYS GK-122
Manual CRVIS Line-Up
SYS OPS-001
Weekly Equipment Rotation and Readings
80A
Drawings
Number
Title
Revision
E-13GG01
Schematic Diagram Emergency Exhaust Fans
E-13GG03
Schematic Diagram Emergency Exhaust Heating Coils
 
Drawings
Number
Title
Revision
E-13GG15
Schematic Diagram Emergency Exhaust Cross Connection
Dampers
J-02GG14B (Q)
Fuel Building HVAC Spent Fuel Pool Normal/Emergency
Exhaust Radioactivity Sample Valve
M-12BB02
Piping & Instrumentation Diagram Reactor Coolant System
M-12BB03
Piping and Instrumentation Diagram Reactor Coolant System 15
M-12BG01
Piping & Instrumentation Diagram Chemical and Volume
Control System
M-12BL01
Piping & Instrumentation Diagram Reactor Make-Up Water
System
M-12GG01
Piping Instrumentation Diagram Fuel Building HVAC
M-12GT01
Piping & Instrumentation Diagram Containment Purge
Systems HVAC
M-12HB01
Piping and Instrumentation Diagram Liquid Radwaste
System
M-12LF01
Piping & Instrumentation Diagram Auxiliary Building Floor
and Equipment Drain System
M-12LF03
Piping & Instrumentation Diagram Auxiliary Building Floor
and Equipment Drain System
M-1H1531
Heating Ventilating and Air Cond. Auxiliary Building El. 2047-
Area-3
M-1H6311
Heating Ventilating & Air Cond. Fuel Building El. 2047-6 &
2065-0 Area 1
M-622.1A-00001 SGK05A & SGK05B Air Conditioner Refrigeration Schematic W12
M-622.1A-00002 SGK05A & SGK05B Air Conditioner Electrical Schematic
W13
M-622.1A-00003 SGK05A & SGK05B Air Conditioner Electrical Schematic
W09
M-622.1A-00257 Step Controllers
W01
M-712-00063
Reactor Coolant Pump Data Sheets
W04
M-OPIII
Embedded Drainage Systems (LF) Auxiliary Building EL.
1967-0 & 1974-0 Area I
 
Condition Reports
24199
90975
107789
110377
117283
118586
118587
118592
118827
118830
 
Condition Reports
118831
118910
118922
119069
119085
119330
119334
119442
119446
119487
119616
119822
119859
119860
119861
20053
20056
20071
20179
20181
20246
20287
20408
20409
20410
20411
20489
20535
20664
20722
Work Orders
16-411783-010
17-428518-000
18-436340-000
18-436340-002
 
Miscellaneous
Number
Title
Revision/Date
107363
Functional Failure Determination Checklist
October 12,
2016
118585
Function Failure Determination Checklist
January 28,
2018
AIF 10-001-02
SCBA Inspection
Completed
March 1, 2018
APF 05-002-05
Engineering Disposition - EDG Water, Lube Oil, and Fuel
Oil Leakage Guidance
APF 05C-004-01 Basic Engineering Disposition - Review of Regulatory and
License Basis Documents to evaluate the requirements of
Operability Determination when Safety Related or
Technical Specification Equipment is exposed to a hazard
APF 21-001-02
Control Room Turnover checklist - On-Coming CRS/WC
SRO/RO/BOP Review - Night Shift
March 14,
2018
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
2018-0112
February 14,
2018
APF30B-004-01
Wolf Creek Nuclear Operating Corporation Essential
Required Reading - SBO Power Equipment Center (PEC)
April 1, 2018
GG-01
Maintenance Rule Final Scope Evaluation
Printed
March 22,
2018
GG-02
Maintenance Rule Final Scope Evaluation
Printed
March 22,
2018
 
Miscellaneous
Number
Title
Revision/Date
GG-03
Maintenance Rule Final Scope Evaluation
Printed
March 22,
2018
GG-04
Maintenance Rule Final Scope Evaluation
Printed
March 22,
2018
Section 1R19: Post-Maintenance Testing
Procedures
Number
Title
Revision
STN AL-201
Auxiliary Feedwater System Valve Test
STN EG-205A
Component Cooling Water System Valve Test
STS EG-100A
Component Cooling Water Pumps A/C [Air Conditioning]
Inservice Pump Test
33A
STS EG-208A
EG TV-029 CCW [Component Cooling Water] HX [Heat
Exchanger] A Temperature Control Valve Inservice Valve
Test
STS EJ-100A
RHR [Residual Heat Removal] System Inservice Pump A
Test
STS IC-540A
Channel Calibration Auxiliary Feedwater System Steam
Generator A
 
Drawings
Number
Title
Revision/Date
E-13GK13
Schematic Diagram Class 1E Electrical Equipment A/C [Air
Conditioning] Unit
M-12AL01
Piping & Instrumentation Diagram Auxiliary Feedwater
System
M-12AL01
Piping & Instrumentation Diagram Auxiliary Feedwater
System
M-622.1-00036
Electric Motor Data Sheet
March 3, 1977
M-622.1A-00002 SKG05A & SGK05B Air Conditioner Electrical Schematic
W13
M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout
W03
 
Condition Reports
118881
118901
118920
118953
118958
118959
118963
118964
119289
 
Work Orders
15-407137-000
 
Miscellaneous
Number
Title
Revision/Date
WCGS Standing Order 1 - Valve Setup and Operation
36121
Preventative Maintenance Work Instruction
APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment
January 23,
2018
APF 29B-003-01 Surveillance Test Routing Sheet - Auxiliary Feedwater
System Valve Test
Completed
February 6,
2018
Section 1R20: Refueling and Other Outage Activities
Procedures
Number
Title
Revision
GEN 00-004
Power Operation
GEN 00-005
Minimum Load To Hot Standby
SYS AE-320
Turbine Driven Main Feedwater Pump Shutdown
28A
SYS AF-121
Heater Drain Pump Operation
 
Section 1R22: Surveillance Testing
Procedures
Number
Title
Revision
AP 23-009
Control Room Envelope Habitability Program
STS EG-100B
Component Cooling Water Pumps B/D Inservice Pump Test 29
STS IC-217
RCP Loss of Voltage and Underfrequency TADOT
15C
STS IC-915B
Channel Operational Test Train B Component Cooling
Water System Non-Nuclear Safety-Related Isolation
8A
STS IC-926A
Component Cooling Water System Automatic Valve
Actuation Train A
8A
 
Procedures
Number
Title
Revision
STS IC-926B
Component Cooling Water System Automatic Valve
Actuation Train B
6B
STS PE-004
Auxiliary Building and Control Room Pressure Test
 
Drawings
Number
Title
Revision
E-13EG01D
Schematic Diagram Component Cooling Water Pump D
E-13EG08A
Schematic Diagram Component Cooling Water Supply
Return From Radwaste Building
E-13EG11
Schematic Diagram Annunciation and Instrumentation
E-13EG20
Schematic Diagram Pass CCW Isolation Valves
M-12EG01
Piping & Instrumentation Diagram Component Cooling
Water System
M-12EG02
Piping & Instrumentation Diagram Component Cooling
Water System
M-12EG03
Piping & Instrumentation Diagram Component Cooling
Water System
 
Condition Reports
118493
118551
118552
119412
20061
20064
20148
20151
20408
20409
20410
20411
 
Work Orders
17-431050-000
17-431170-000
17-431759-000
17-432247-000
 
Miscellaneous
Number
Title
Date
APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-217
Completed
March 5,
2018
APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-926B
Completed
January 4,
2018
 
Miscellaneous
Number
Title
Date
APF 30B-004-01 Wolf Creek Nuclear Operating Corporation Essential
Required Reading: 18-0010 Accuracy of WCRE-35
March 7,
2018
Section 1EP6: Drill Evaluation
Procedures
Number
Title
Revision
EPP 06-006
Protective Action Recommendations
9A
Condition Reports
119869
119870
119871
119872
119874
119877
119878
119879
119883
119885
119886
119887
119888
119889
119897
119901
119903
119904
119906
119911
119941
20017
20227
20323
 
Miscellaneous
Number
Title
Revision/Date
18-SA-01
Wolf Creek Generating Station - Emergency Planning Drill
February 27,
2018
APF 06-002-01
Emergency Action Levels
17A
CR-001
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018
EOF-001
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018
EOF-002
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018
EOF-003
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018
EOF-004
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018
TSC-001
Wolf Creek Generating Station Emergency Notification
(Drill)
February 27,
2018
 
Section 4OA1: Performance Indicator Verification
Miscellaneous
Number
Title
Revision
NEI 99-02
Regulatory Assessment Performance Indicator Guideline
 
Section 4OA2: Identification and Resolution of Problems
Procedures
Number
Title
Revision
STS MT-005
Pressurizer Code Safety Valve Operability
 
Drawings
Number
Title
Revision
M-1H1531
Heating Ventilating and Air Cond. Auxiliary Building El.
2047-6 Area-3
 
Condition Reports
90975
110377
2960
118910
119330
Work Orders
17-428518-001
 
Miscellaneous
Number
Title
Date
Email from NWS
Technologies to
Wolf Creek
<EXTERNAL> RE: Wolf Creek PSV failure - Questions
from our NRC Resident Inspector
November
30, 2017
P.O. # 692145
SR
Valve Serial Number N60446-00-0001; Traveler 14-381
Testing
Completed
January 2015
PO # 779245
Valve Serial Number N60446-00-0001; Traveler 17-41
Testing
Completed
August 2017
NRC Letter to
Otto L. Maynard
Wolf Creek Generating Station - Issuance of Amendment
RE: Pressurizer Safety Valves (TAC NO. MA6969)
March 23,
2000
White Paper
Pressurizer Safety Valve NRC Follow-up Questions and
Answers
 
White Paper
Why PZR Safety Valve Failure is NOT a Part 21 Issue
 
Initial Request for Information
Integrated Inspection
Wolf Creek Nuclear Generating Station
 
Inspection Report: 05000482/2018001
 
Inspection Dates: January 1 - March 31, 2018
 
Inspection Procedure: Integrated Inspection Procedures
 
Lead Inspector: Douglas Dodson, Senior Resident Inspector


Enforcement
I.
: Violation: Title 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
Information Requested Prior to December 22, 2017
requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances. Licensee Procedure AP 26C-004, "Operability Determination and Functionality Assessment," Revision 35, an Appendix B quality related procedure, provides instructions for performing functionality assessments. Procedure AP 26C
-004, Section 6.4.7
, states, in part, that the scope of a functionality assessment must be sufficient to address the capability of SSCs to perform their specified functions, and codes, standards, and system requirements controlling the SSC should be considered when performing functionality assessments.


Contrary to the above, from March 12, 2018, until April 9, 2018, the scope of a functionality assessment was not sufficient to address the capability of SSCs to perform their specified functions, and codes, standards, and system requirements controlling the SSC were not considered when performing functionality assessments. Specifically, the functionality assessment associated with the excess letdown heat exchanger outlet to pressurizer relief tank isolation valve and excess letdown system was not adequate and did not adequately consider design basis information, which caused the licensee to fail to identify non
The following information should be provided in electronic format (Certrec IMS
-functionality of safety
preferred), to the attention of Douglas Dodson by December 22, 2017, to facilitate the
-related SSCs.
reduction in the items to be selected for a final list during inspection preparation. The
inspection team will finalize its sample selections and will provide an additional
information request with specific items. This information shall be made available by
December 22, 2017. The specific items selected from the lists shall be available and
ready for review on the day indicated in this request. *Please provide requested
documentation electronically in pdf files, Excel, or other searchable formats, if possible.
The information should contain descriptive names, and be indexed and hyperlinked to
facilitate ease of use. Information in lists should contain enough information to be
easily understood by someone who has knowledge of pressurized water reactor
technology. If requested documents are large and/or only hard copy formats are
available, please inform the inspector(s), and provide subject documentation.  


Disposition:
1. Any pre-existing evaluation or list of component cooling water system components
This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
and associated calculations with low design margins.  


11 EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report
2. A list of high risk component cooling water system maintenance rule components
. On April 25, 2018, the inspector presented the quarterly resident inspector inspection results to Mr. C. Reasoner, Site Vice President, and other members of the licensee staff.
and functions based on engineering or expert panel judgment.  


Attachment 1 DOCUMENTS REVIEWED Section 1R01: Adverse Weather Protection Procedures Number Title Revision SYS EF-205 ESW/Circ Water Cold Weather Operations 40 Miscellaneous Number Title Date 96-0316 Performance Improvement Request Initiated February 5, 1996 2006-0006 Performance Improvement Request Initiated January 4, 2006 APF 15C-002-01 Procedure Cover Sheet
3. A list of component cooling water system related operating experience evaluations
- ESW/Circ Water Cold Weather Operations
for the last 3 years.  
- SYS EF-205 Completed December 26, 2017 APF 15C-002-01 Procedure Cover Sheet
- ESW/Circ Water Cold Weather Operations
- SYS EF-205 Completed January 2, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Day Shift January 19, 2018 APF 29B-003-01 Surveillance Test Routing Sheet
- ESW Train B Warming Line Verification
- STN EF-020B Completed January 3, 2018 WM 96-0081 Docket No 50
-482: Response to Enforcement Action EA 96-124 July 31, 1996 Section 1R04: Equipment Alignment Procedures Number Title Revision CKL Al-120 Auxiliary Feedwater Normal Lineup 42 CKL EG-120 Component Cooling Water System Valve, Switch and Breaker Lineup 49 CKL EJ-120 RHR System Lineup 45B A1-2 Drawings Number Title Revision M-06EG07 Component Coolant Wtr. Sys. Aux. Bldg.


4 M-12AL01 Piping & Instrumentation Diagram Auxiliary Feedwater System 28 M-12EG01 Piping & Instrumentation Diagram Component Cooling Water System 24 M-12EG02 Piping & Instrumentation Diagram Component Cooling Water System 27 M-12EG03 Piping & Instrumentation Diagram Component Cooling Water System 19 M-12EJ01 Piping and Instrumentation Diagram Residual Heat Removal System 53 M-12FC02 Piping & Instrumentation Diagram Auxiliary Feedwater Pump Turbine 25 M-13EG07 Piping Isometric Component Cooling Water Sys. Aux. Bldg. Common Header 3 M-15EG07 Hanger Location Drawing Component Cooling Water Sys Aux. Bldg. Common Header 14 Condition Reports 119280 119401 120586 Section 1R05: Fire Protection Procedures Number Title Revision AP 10-106 Fire Preplans 18A CKL ZL-001 Auxiliary Building Reading Sheets 103 Condition Reports 119366 120782 120783 120784 Miscellaneous Number Title Revision E-1F9905 Fire Hazard Analysis 8 XX-X-004 Calculation Cover Sheet
4. A list of all component cooling water system time-critical operator actions in
- Combustible Fire Loading For Each Room In The Various Fire Areas at WCNOC 4
procedures.  
A1-3 Section 1R06: Flood Protection Measures Procedures Number Title Revision ALR 00-094F Misc Sumps Lev Hi 5 Drawings Number Title Revision M-12EJ01 Piping and Instrumentation Diagram Residual Heat Removal System 53 M-13LF02 Piping Isometric Sump Discharge Auxiliary Bldg.


1 Condition Reports 118576 118586 118587 118592 118593 Miscellaneous Number Title Revision FL-03 Flooding of Individual Auxiliary Building Rooms 2 Section 1R0 7: Heat Sink Performance Procedures Number Title Revision AP 23L-002 Heat Exchanger Program 5 Work Orders 17-428729-000 17-428729-002 17-428729-003 17-428729-005 17-428737-000 Miscellaneous Number Title Date GL-05 Maintenance Rule Final Scope Evaluation Printed March 27, 2018 A1-4 Section 1R11: Licensed Operator Requalification Program Procedures Number Title Revision AP 21-001 Conduct of Operations 81 STS RE-006 EOL Core MTC Measurement 20B STS SE-001 Power Range Adjustment to Calorimetric 35 Miscellaneous Number Title Revision/Date APF 21-001-02 Control Room Turnover Checklist
5. A list of permanent and temporary modifications related to component cooling water
- On-Coming CRS/WC SRO/RO/BOP Review
system sorted by component.  
- Day Shift February 2, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Day Shift February 3, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift February 3, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift February 4, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift February 5, 2018 APF 29B-003-01 Surveillance Test Routing Sheet
- EOL Core MTC Measurement Completed February 5, 2018 EPF 06-007-01 Wolf Creek Generating Station Emergency Notification (Drill) February 22, 2018 LR5004005 Loss of All AC While Shutdown
- Licensed Operator Requal 12 Section 1R12: Maintenance Effectiveness Drawings Number Title Revision/Date M-12GL01 Piping and Instrumentation Diagram Auxiliary Building HVAC 13 M-612.00062 Carrier Air Handling Units and Room Coolers Imaged May 2017 Condition Reports 10539 114660 117759 A1-5 Miscellaneous Number Title Date GL Room Cooler PM Schedule Maintenance Rule Expert Panel Meeting Agenda November 1, 2017 114660 Functional Failure Determination Checklist August 17, 2017 GL-01 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-02 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-03 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-04 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-05 Maintenance Rule Final Scope Evaluati on Printed January 29, 2018 GL-06 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-07 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-08 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 GL-09 Maintenance Rule Final Scope Evaluation Printed January 29, 2018 Section 1R13: Maintenance Risk Assessment and Emergent Work Controls Procedures Number Title Revision AP 22C-003 On-Line Nuclear Safety and Generation Risk Assessment 22 A1-6 Procedures Number Title Revision OFN AF-025 Unit Limitations 52 STS BB-201B Cycle Test of PORV Block Valve BB HV
-800B 4 STS IC-447 Channel Calibration Nuclear Instrumentation System Power Range Incore
-Excore 46 STS MT-024B Functional Test of 480 and 120 Volt Molded Case Circuit Breakers 17 Drawings Number Title Revision M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout W03 Condition Reports 118499 118938 118939 118940 118953 118958 118959 118963 118964 Work Orders 17-422791-003 17-427320-000 18-434985-000 18-435758-000 18-435758-001 Miscellaneous Number Title Date APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Day Shift January 23, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review - Night Shift January 23, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Day Shift January 24, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift January 24, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift January 25, 2018 APF 21-001-02 Control Room Turnover Checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift January 26, 2018 APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
18-0101 January 4, 2018 A1-7 Miscellaneous Number Title Date APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
18-0111 March 13, 2018 APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
2018-0110 February 15, 2018 APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
2018-0104 January 10, 2018 APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment
-2018-0122 February 14, 2018 APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-447 Completed January 4, 2018 APF 29B-003-01 Surveillance Test Routing Sheet
- STS PE-004 (Train B)
Completed March 7, 2018 Section 1R15: Operability Evaluations Procedures Number Title Revision AI 16C-006 Troubleshooting 9 AI 28B-005 Evidence and Action Matrix 4 AP 12-003 Foreign Material Exclusion 16 AP 26C-004 Operability Determination and Functionality Assessment 35 OFN BB-005 RCP Malfunctions 27 STN BB-201 Exercise of BB HV
-8157A and BB HV
-8157B 3 STS BG-001 Boron Injection Flow Path Verification 20 STS KJ-005A Manual/Auto Start, Sync and Loading of EDG NE01 67A STS PE-004 Auxiliary Building and Control Room Pressure Test 16 SYS GK-122 Manual CRVIS Line
-Up 24 SYS OPS-001 Weekly Equipment Rotation and Readings 80A Drawings Number Title Revision E-13GG01 Schematic Diagram Emergency Exhaust Fans 6 E-13GG03 Schematic Diagram Emergency Exhaust Heating Coils 1
A1-8 Drawings Number Title Revision E-13GG15 Schematic Diagram Emergency Exhaust Cross Connection Dampers 0 J-02GG14B (Q)
Fuel Building HVAC Spent Fuel Pool Normal/Emergency Exhaust Radioactivity Sample Valve 0 M-12BB02 Piping & Instrumentation Diagram Reactor Coolant System 27 M-12BB03 Piping and Instrumentation Diagram Reactor Coolant System 15 M-12BG01 Piping & Instrumentation Diagram Chemical and Volume Control System 19 M-12BL01 Piping & Instrumentation Diagram Reactor Make
-Up Water System 15 M-12GG01 Piping Instrumentation Diagram Fuel Building HVAC 8 M-12GT01 Piping & Instrumentation Diagram Containment Purge Systems HVAC 24 M-12HB01 Piping and Instrumentation Diagram Liquid Radwaste System 15 M-12LF01 Piping & Instrumentation Diagram Auxiliary Building Floor and Equipment Drain System 3 M-12LF03 Piping & Instrumentation Diagram Auxiliary Building Floor and Equipment Drain System 6 M-1H1531 Heating Ventilating and Air Cond. Auxiliary Building El. 2047'
-6" Area-3 5 M-1H6311 Heating Ventilating & Air Cond. Fuel Building El. 2047'
-6" & 2065'-0" Area 1 2 M-622.1A-00001 SGK05A & SGK05B Air Conditioner Refrigeration Schematic W12 M-622.1A-00002 SGK05A & SGK05B Air Conditioner Electrical Schematic W13 M-622.1A-00003 SGK05A & SGK05B Air Conditioner Electrical Schematic W09 M-622.1A-00257 Step Controllers W01 M-712-00063 Reactor Coolant Pump Data Sheets W04 M-OPIII Embedded Drainage Systems (LF) Auxiliary Building EL.


1967'-0" & 1974'
6. A list of current component cooling water system related operator work
-0" Area I 5 Condition Reports 24199 90975 107789 110377 117283 118586 118587 118592 118827 118830 A1-9 Condition Reports 118831 118910 118922 119069 119085 119330 119334 119442 119446 119487 119616 119822 119859 119860 119861 120053 120056 120071 120179 120181 120246 120287 120408 120409 120410 120411 120489 120535 120664 120722 Work Orders 16-411783-010 17-428518-000 18-436340-000 18-436340-002 Miscellaneous Number Title Revision/Date 107363 Functional Failure Determination Checklist October 12, 2016 118585 Function Failure Determination Checklist January 28, 2018 AIF 10-001-02 SCBA Inspection Completed March 1, 2018 APF 05-002-05 Engineering Disposition
arounds/burdens.  
- EDG Water, Lube Oil, and Fuel Oil Leakage Guidance 00 APF 05C-004-01 Basic Engineering Disposition
- Review of Regulatory and License Basis Documents to evaluate the requirements of Operability Determination when Safety Related or Technical Specification Equipment is exposed to a hazard 00 APF 21-001-02 Control Room Turnover checklist
- On-Coming CRS/WC SRO/RO/BOP Review
- Night Shift March 14, 2018 APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:
2018-0112 February 14, 2018 APF30B-004-01 Wolf Creek Nuclear Operating Corporation Essential Required Reading
- SBO Power Equipment Center (PEC)
April 1, 2018 GG-01 Maintenance Rule Final Scope Evaluation Printed March 22, 2018 GG-02 Maintenance Rule Final Scope Evaluation Printed March 22, 2018 A1-10 Miscellaneous Number Title Revision/Date GG-03 Maintenance Rule Final Scope Evaluation Printed March 22, 2018 GG-04 Maintenance Rule Final Scope Evaluation Printed March 22, 2018 Section 1R19: Post
-Maintenance Testing Procedures Number Title Revision STN AL-201 Auxiliary Feedwater System Valve Test 8 STN EG-205A Component Cooling Water System Valve Test 2 STS EG-100A Component Cooling Water Pumps A/C [Air Conditioning] Inservice Pump Test 33A STS EG-208A EG TV-029 CCW [Component Cooling Water] HX [Heat Exchanger] A Temperature Control Valve Inservice Valve Test 1 STS EJ-100A RHR [Residual Heat Removal] System Inservice Pump A Test 55 STS IC-540A Channel Calibration Auxiliary Feedwater System Steam Generator A 9 Drawings Number Title Revision/Date E-13GK13 Schematic Diagram Class 1E Electrical Equipment A/C [Air Conditioning] Unit 6 M-12AL01 Piping & Instrumentation Diagram Auxiliary Feedwater System 23 M-12AL01 Piping & Instrumentation Diagram Auxiliary Feedwater System 28 M-622.1-00036 Electric Motor Data Sheet March 3, 1977 M-622.1A-00002 SKG05A & SGK05B Air Conditioner Electrical Schematic W13 M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout W03 A1-11 Condition Reports 118881 118901 118920 118953 118958 118959 118963 118964 119289 Work Orders 15-407137-000 Miscellaneous Number Title Revision/Date WCGS Standing Order 1
- Valve Setup and Operation 45 36121 Preventative Maintenance Work Instruction APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment January 23, 2018 APF 29B-003-01 Surveillance Test Routing Sheet
- Auxiliary Feedwater System Valve Test Completed February 6, 2018 Section 1R20
: Refueling and Other Outage Activities Procedures Number Title Revision GEN 00-004 Power Operation 89 GEN 00-005 Minimum Load To Hot Standby 90 SYS AE-320 Turbine Driven Main Feedwater Pump Shutdown 28A SYS AF-121 Heater Drain Pump Operation 24 Section 1R 22: Surveillance Testing Procedures Number Title Revision AP 23-009 Control Room Envelope Habitability Program 2 STS EG-100B Component Cooling Water Pumps B/D Inservice Pump Test 29 STS IC-217 RCP Loss of Voltage and Underfrequency TADOT 15C STS IC-915B Channel Operational Test Train B Component Cooling Water System Non
-Nuclear Safety
-Related Isolation 8A STS IC-926A Component Cooling Water System Automatic Valve Actuation Train A 8A A1-12 Procedures Number Title Revision STS IC-926B Component Cooling Water System Automatic Valve Actuation Train B 6B STS PE-004 Auxiliary Building and Control Room Pressure Test 16 Drawings Number Title Revision E-13EG01D Schematic Diagram Component Cooling Water Pump D 5 E-13EG08A Schematic Diagram Component Cooling Water Supply Return From Radwaste Building 3 E-13EG11 Schematic Diagram Annunciation and Instrumentation 4 E-13EG20 Schematic Diagram Pass CCW Isolation Valves 3 M-12EG01 Piping & Instrumentation Diagram Component Cooling Water System 24 M-12EG02 Piping & Instrumentation Diagram Component Cooling Water System 27 M-12EG03 Piping & Instrumentation Diagram Component Cooling Water System 19 Condition Reports 118493 118551 118552 119412 120061 120064 120148 120151 120408 120409 120410 120411 Work Orders 17-431050-000 17-431170-000 17-431759-000 17-432247-000 Miscellaneous Number Title Date APF 29B-003-01 Surveillance Test Routing Sheet
- STS IC-217 Completed March 5, 2018 APF 29B-003-01 Surveillance Test Routing Sheet
- STS IC-926B Completed January 4, 2018 A1-13 Miscellaneous Number Title Date APF 30B-004-01 Wolf Creek Nuclear Operating Corporation Essential Required Reading: 18
-0010 Accuracy of WCRE
-35 March 7, 2018 Section 1EP6: Drill Evaluation Procedures Number Title Revision EPP 06-006 Protective Action Recommendations 9A Condition Reports 119869 119870 119871 119872 119874 119877 119878 119879 119883 119885 119886 119887 119888 119889 119897 119901 119903 119904 119906 119911 119941 120017 120227 120323 Miscellaneous Number Title Revision/Date 18-SA-01 Wolf Creek Generating Station
- Emergency Planning Drill February 27, 2018 APF 06-002-01 Emergency Action Levels 17A CR-001 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 EOF-001 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 EOF-002 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 EOF-003 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 EOF-004 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 TSC-001 Wolf Creek Generating Station Emergency Notification (Drill) February 27, 2018 A1-14 Section 4OA1: Performance Indicator Verification Miscellaneous Number Title Revision NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7 Section 4OA2: Identification and Resolution of Problems Procedures Number Title Revision STS MT-005 Pressurizer Code Safety Valve Operability 20 Drawings Number Title Revision M-1H1531 Heating Ventilating and Air Cond. Auxiliary Building El.


2047'-6" Area-3 5 Condition Reports 90975 110377 112960 118910 119330 Work Orders 17-428518-001 Miscellaneous Number Title Date Email from NWS Technologies to Wolf Creek
7. A list of the component cooling water system design calculations, which provide the
<EXTERNAL> RE: Wolf Creek PSV failure
design margin information for components.
- Questions from our NRC Resident Inspector November 30, 2017 P.O. # 692145 SR Valve Serial Number N60446
-00-0001; Traveler 14
-381 Testing Completed January 2015 PO # 779245 Valve Serial Number N60446
-00-0001; Traveler 17
-41 Testing Completed August 2017 NRC Letter to Otto L. Maynard Wolf Creek Generating Station
- Issuance of Amendment RE: Pressurizer Safety Valves (TAC NO. MA6969) March 23, 2000 White Paper Pressurizer Safety Valve NRC Follow
-up Questions and Answers A1-15 White Paper Why PZR Safety Valve Failure is NOT a Part 21 Issue


Attachment 2 Initial Request for Information Integrated Inspection Wolf Creek Nuclear Generating Station Inspection Report:  05000482/2018001 Inspection Dates:  January 1
8. List of component cooling water system root cause evaluations associated with  
- March 31, 2018 Inspection Procedure: Integrated Inspection Procedures Lead Inspector:  Douglas Dodson, Senior Resident Inspector I. Information Requested Prior to December 22, 2017 The following information should be provided in electronic format (Certrec IMS preferred), to the attention of Douglas Dodson by December 22, 2017, to facilitate the reduction in the items to be selected for a final list during inspection preparation. The inspection team will finalize its sample selections and will provide an additional information request with specific items. This information shall be made available by December 22, 2017. The specific items selected from the lists shall be available and ready for review on the day indicated in this request. *Please provide requested documentation electronically in "pdf" files, Excel, or other searchable formats, if possible. The information should contain descriptive names, and be indexed and hyperlinked to facilitate ease of use. Information in "lists" should contain enough information to be easily understood by someone who has knowledge of pressurized water reactor technology. If requested documents are large and/or only hard copy formats are available, please inform the inspector(s), and provide subject documentatio n. 1. Any pre-existing evaluation or list of component cooling water system components and associated calculations with low design margins.


2. A list of high risk component cooling water system maintenance rule components and functions based on engineering or expert panel judgment.
component failures or design issues initiated/completed in the last 5 years.  


3. A list of component cooling water system related operating experience evaluations for the last 3 years.
9. A list of any component cooling water system common-cause failures of
components in the last 3 years.  


4. A list of all component cooling water system time
10. An electronic copy of the component cooling water system design bases documents
-critical operator actions in procedures.
and any open, pending, or recently completed changes. Although not an exhaustive
list, please include any open, pending, or recently completed (last 3 years) changes
to temporary modifications, permanent modifications, engineering change
packages, and/or procedure change packages. Specifically, please include any
open, pending, or recently completed changes to emergency operating, abnormal
operating, normal operating, alarm response, system alignment, surveillance, or
other procedure.  


5. A list of permanent and temporary modifications related to component cooling water system sorted by component.
11. An electronic copy of the component cooling water system System Health notebook.  


6. A list of current component cooling water system related "operator work arounds/burdens."
2. A copy of component cooling water system related audits completed in the last 2
years.  


7. A list of the component cooling water system design calculations, which provide the design margin information for components.
13. A list of component cooling water system motor operated valves (MOVs) in the
program, design margin and risk ranking.  


8. List of component cooling water system root cause evaluations associated with A2-2 component failures or design issues initiated/completed in the last 5 years.
14. A list of component cooling water system air operated valves (AOVs) in the valve
program, design margin and risk ranking.
15. Component cooling water system structure, system, and components maintenance
rule category, scoping, unavailability data, unreliability data, functional failure
evaluations, (a)(1) determinations, (a)(1) goals, and any supporting basis
documentation.  


9. A list of any component cooling water system common
16. A list of component cooling water system licensee contacts for the inspection team
-cause failures of components in the last 3 years.
with pager or phone numbers.  


10. An electronic copy of the component cooling water system design bases documents and any open, pending, or recently completed changes. Although not an exhaustive list, please include any open, pending, or recently completed (last 3 years) changes to temporary modifications, permanent modifications, engineering change packages, and/or procedure change packages. Specifically, please include any open, pending, or recently completed changes to emergency operating, abnormal operating, normal operating, alarm response, system alignment, surveillance, or other procedure.
17. An excel spreadsheet of component cooling water system related PRA human
action basic events or risk ranking of operator actions from your site specific PSA
sorted by RAW and FV. Provide copies of your human reliability worksheets for
these items.  


11. An electronic copy of the component cooling water system System Health notebook.
18. In so far as there are recent or pending changes, please provide an Excel
spreadsheet of component cooling water system related equipment basic events
(with definitions) including importance measures sorted by risk achievement worth
(RAW) and Fussell-Vesely (FV) from your internal events probabilistic risk
assessment (PRA). Include basic events with RAW value of 1.3 or greater.  


12. A copy of component cooling water system related audits completed in the last 2 years. 13. A list of component cooling water system motor operated valves (MOVs) in the program, design margin and risk ranking.
19. In so far as there are recent or pending changes, please provide a list of the top 50
cut-sets from your PRA.  


14. A list of component cooling water system air operated valves (AOVs) in the valve program, design margin and risk ranking. 15. Component cooling water system structure, system, and components' maintenance rule category, scoping, unavailability data, unreliability data, functional failure evaluations, (a)(1) determinations, (a)(1) goals, and any supporting basis documentation. 16. A list of component cooling water system licensee contacts for the inspection team with pager or phone numbers.
20. In so far as there are recent or pending changes, please provide copies of PRA
system notebooks, and the latest PRA summary document.  


17. An excel spreadsheet of component cooling water system related PRA human action basic events or risk ranking of operator actions from your site specific PSA sorted by RAW and FV. Provide copies of your human reliability worksheets for these items.
21. In so far as there are recent or pending changes, and if you have an external events


18. In so far as there are recent or pending changes, please provide an Excel spreadsheet of component cooling water system related equipment basic events (with definitions) including importance measures sorted by risk achievement worth (RAW) and Fussell
or fire PSA model, provide the information requested in items 17-19 for external
- Vesely (FV) from your internal events probabilistic risk assessment (PRA). Include basic events with RAW value of 1.3 or greater.
events and fire, as it relates to the component cooling water system.  


19. In so far as there are recent or pending changes, please provide a list of the top 50 cut-sets from your PRA.
2. In so far as there are recent or pending changes, please provide a copy of the Wolf
Creek Nuclear Generating Station IPEEE changes, if available electronically.  


20. In so far as there are recent or pending changes, please provide copies of PRA "system notebooks," and the latest PRA summary document.
ML18131A017
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: NHT/rdr
Yes No
Publicly Available
Sensitive
NRC-002
OFFICE
SRI:DRP/B
RI:DRP/B
C:DRS/OB
C:DRS/PSB2
C:DRS/EB1
C:DRS/EB2
NAME
DDodson
FThomas
VGaddy
HGepford
TFarnholtz
JDrake
SIGNATURE
/RA/
/RA/
/RA/
/RA/
/RA/
/RA/
DATE
5/9/2018
5/10/18
5/3/18
5/3/18
5/3/2018
5/9/18
OFFICE
TL:DRS/IPAT
SRI/DRP/B
BC:DRP/B


21. In so far as there are recent or pending changes, and if you have an external events A2-3 or fire PSA model, provide the information requested in items 17
NAME
-19 for external events and fire, as it relates to the component cooling water system.
GGeorge
DBradley
NTaylor


22. In so far as there are recent or pending changes, please provide a copy of the Wolf Creek Nuclear Generating Station IPEEE changes, if available electronically.
SIGNATURE
/RA -
HFreeman for/
/RA/
/RA/


ML18131A017 SUNSI Review:
DATE
ADAMS: Non-Publicly Available Non-Sensitive Keyword:
5/10/18
By: NHT/rdr Yes No Publicly Available Sensitive NRC-002 OFFICE SRI:DRP/B RI:DRP/B C:DRS/OB C:DRS/PSB2 C:DRS/EB1 C:DRS/EB2 NAME DDodson FThomas VGaddy HGepford TFarnholtz JDrake SIGNATURE
5/7/18
/RA/ /RA/ /RA/ /RA/ /RA/ /RA/ DATE 5/9/2018 5/10/18 5/3/18 5/3/18 5/3/2018 5/9/18 OFFICE TL:DRS/IPAT SRI/DRP/B BC:DRP/B NAME GGeorge DBradley NTaylor SIGNATURE
5/14/18
/RA - HFreeman for
/ /RA/ /RA/ DATE 5/10/18 5/7/18 5/14/18
}}
}}

Latest revision as of 22:04, 5 January 2025

NRC Integrated Inspection Report 05000482/2018001
ML18131A017
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 05/14/2018
From: Nick Taylor
NRC/RGN-IV/DRP/RPB-B
To: Heflin A
Wolf Creek
Taylor N
References
IR 2018001
Download: ML18131A017 (32)
v • d • e


Text

May 14, 2018

SUBJECT:

WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000482/2018001

Dear Mr. Heflin:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Wolf Creek Generating Station. On April 25, 2018, the NRC inspectors discussed the results of this inspection with Mr. C. Reasoner, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance of this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Wolf Creek Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Wolf Creek Generating Station. 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/

Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects

Docket No. 50-482 License No. NPF-42

Enclosure:

Inspection Report 05000482/2018001 w/ Attachments:

1. Supplemental Information 2. Request for Information

Enclosure U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number:

05000482

License Number:

NPF-42

Report Number:

05000482/2018001

Enterprise Identifier: I-2018-001-0012

Licensee:

Wolf Creek Nuclear Operating Corporation

Facility:

Wolf Creek Generating Station

Location:

1550 Oxen Lane NE

Burlington, KS 66839

Inspection Dates:

January 1, 2018, to March 31, 2018

Inspectors:

D. Dodson, Senior Resident Inspector

F. Thomas, Resident Inspector

D. Bradley, Senior Resident Inspector, Callaway

Approved By:

N. Taylor, Chief, Project Branch B, Division of Reactor Projects

SUMMARY

The Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an Integrated Inspection at Wolf Creek Generating Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations

Inadequate Functionality Assessment Associated with the Emergency Excess Letdown Flowpath Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems

Green NCV 05000482/2018001-01 Closed

[H.14] - Human Performance,

Conservative Bias 71111.15 -

Operability Determinations and Functionality Assessments The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to adequately implement the operability determination and functionality assessment procedure.

Specifically, the licensee failed to document a functionality assessment of sufficient scope to address the capability of a safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and the excess letdown system to perform their specified safety functions, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional.

PLANT STATUS

Wolf Creek Generating Station began the inspection period at rated thermal power. On March 30, 2018, a plant shutdown was completed to begin Refueling Outage

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for extreme low temperatures on January 2 and 3, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) turbine-driven auxiliary feedwater train on February 6, 2018
(2) residual heat removal pump B on March 21, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the component cooling water system on February 23, 2018.

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) fire area A-16, general area, elevation 2,026 feet on January 30, and March 28, 2018
(2) fire area A-18, electrical penetration room (north), elevation 2,026 feet on January 30, 2018
(3) fire area A-17, electrical penetration room (south), elevation 2,026 feet on March 28, 2018
(4) fire area A-26, decontamination area for I&C shop, elevation 2,026 feet on March 28, 2018
(5) fire area A-27, reactor trip switchgear, motor-generator sets, load centers, rod control and rod-drive power supply control cabinets 125 volt direct current panel on March 28, 2018.

71111.06 - Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protections in rooms 1203 and 1203A, Pipe Space B on January 9, 2018.

71111.07 - Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated containment spray train A room cooler (SGL13A) performance on January 17, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated licensed operator simulator requalification activities that included a loss of all alternating current power during shutdown scenario on February 22, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated operator performance during end of life core moderator temperature coefficient measurement activities on February 5, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

Auxiliary building heating ventilation and air conditioning (GL) system including safety-related pump and electrical penetration room coolers on January 29, 2018.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) reactor partial trip alarm troubleshooting and main generator transformer B loss of two cooling groups on January 4, 2018
(2) emergent maintenance on Class 1E electrical equipment air conditioning unit train A on January 24, 2018
(3) planned maintenance on component cooling water train B on March 5, 2018
(4) emergent maintenance associated with the failed control room envelope pressure test on March 6, 2018
(5) emergent maintenance on Class 1E electrical equipment air conditioning unit train B on March 12, 2018.

71111.15 - Operability Determinations and Functionality Assessments

Main article: IP 71111.15

The inspectors evaluated the following operability determinations and functionality assessments:

(1) auxiliary building elevation 1988 foot south pipe chase drain functionality with three clogged floor drains on January 10, 2018
(2) 125 volt direct current to 120 volt alternating current NN15 inverter operability after a high voltage alarm would not clear on January 18, 2018
(3) emergency diesel generator A lubrication oil leakage on January 31, 2018
(4) Class 1E electrical equipment air conditioning unit train B operability following a step controller failure on February 12, 2018
(5) reactor coolant pump A standpipe not filling on the expected frequency on February 25, 2018
(6) Technical Specification 3.7.10 mitigating actions to ensure the control room envelope occupant radiological exposures would not exceed limits and control room envelope occupants are protected from chemical and smoke hazards while the control room envelope was inoperable on March 6, 2018
(7) excess letdown heat exchanger outlet to pressurizer relief tank isolation valve functionality after failed stoke testing on March 12, 2018
(8) station blackout diesel generator functionality after post maintenance testing on March 20, 2018.

71111.19 - Post Maintenance Testing

Main article: IP 71111.19

The inspectors evaluated the following post maintenance tests:

(1) Class 1E electrical equipment air conditioning unit train A following planned maintenance on January 24, 2018
(2) motor-driven auxiliary feedwater train B pump discharge to steam generators A and D auxiliary feed water flow regulating valve testing following planned maintenance on February 6, 2018
(3) component cooling water pump A following planned maintenance on February 15, 2018
(4) residual heat removal pump A following planned maintenance on March 21, 2018.

71111.20 - Refueling and Other Outage Activities (Partial Sample)

The inspectors evaluated Refueling Outage 22 activities from March 30 to 31, 2018. The inspectors completed inspection procedure Sections 03.01.a, 03.01.b, and 03.01.c.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine

Main article: IP 71111.22
(1) STS IC-926B, Component Cooling Water System Automatic Valve Actuation Train B, Revision 6B, on January 4, 2018
(2) STS IC-915B, Channel Operational Test Train B Component Cooling Water System Non-Nuclear Safety-Related Isolation, Revision 8A, on January 8, 2018
(3) STS IC-926A, Component Cooling Water System Automatic Valve Actuation Train A, Revision 8A, on February 12, 2018
(4) STS IC-217, [Reactor Coolant Pump] Loss of Voltage and Underfrequency [Trip Actuation Device Operational Testing], on March 5, 2018
(5) STS PE-004, Auxiliary Building and Control Room Pressure Tests, Revision 16, on March 5 and March 12, 2018.

71114.06 - Drill Evaluation

Emergency Planning Drill (1 Sample)

The inspectors evaluated the emergency preparedness drill on February 27,

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

Main article: IP 71151

The inspectors verified licensee performance indicator submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017-12/31/2017)
(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017-12/31/2017)
(3) IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017-12/31/2017).

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) On February 8, 2018, the unit vent tornado damper failed to meet acceptance criteria for initial breakaway torque. This issue was documented in Condition Report 119330.
(2) On May 11, 2017, Condition Report 112960 documented that pressurizer safety valve 88010As as-found lift setting was 3.2 percent below the nominal setpoint.

INSPECTION RESULTS

Inadequate Functionality Assessment Associated with the Emergency Excess Letdown Flowpath Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems

Green NCV 05000482/2018001-01 Closed

[H.14] - Human Performance, Conservative Bias

71111.15 - Operability

Determinations and Functionality Assessments The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to adequately implement the operability determination and functionality assessment procedure. Specifically, the licensee failed to document a functionality assessment of sufficient scope to address the capability of a safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and the excess letdown system to perform their specified safety functions, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional.

Description:

On March 12, 2018, the licensee was performing Procedure STN BB-201, Exercise of BB HV-8157A and BB HV-8157B, Revision 3, which tests and exercises the excess letdown heat exchanger to pressurizer relief tank isolation valves (BB HV-8157A and BB HV-8157B). The BB HV-8157B valve did not stroke fully closed as expected. Step 6.1.1 of Procedure STN BB-201 states, If the valve cannot be fully exercised, then valve shall be declared inoperable and corrective action initiated.

Condition Report 120287 was documented on March 12, 2018, reporting the valve failure. The immediate functionality assessment stated, The redundant path of excess letdown is still available. The system is functional but degraded. The system functionality is maintained by having a second redundant flow path for excess letdown. The inspectors noted that Section 6.4.7 of Procedure AP 26C-004, Operability Determination and Functionality Assessment, Revision 35, states, The scope of a functionality assessment must be sufficient to address the capability of SSCs to perform their specified functionsThe following things should be considered when performing functionality assessments: codes, standards and system requirements controlling the SSC.

The inspectors questioned the licensee concerning the immediate functionality determinations adequacy, and the licensee revised the functionality determination for the excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) and changed the determination to non-functional. The immediate functionality determination was updated to state:

The above screening gives an adequate justification for why the excess letdown po[r]tion of the [chemical and volume control system] remains functional but degraded. However, screening should be based on the component, not the system. Since BBHV8157B cannot be relied upon to go to the closed position using normal remote controls, the valve is considered nonfunctional. The system remains functional but degraded.

The inspectors also noted that Section 3.1.9, Boration Injection System - Operating, of the Technical Requirements Manual, requires two boration injection subsystems to be functional in MODES 1, 2, and 3. Section 3.1.9 of the Technical Requirements Manual Bases describes what is required for a boration injection subsystem to be considered functional. Specifically, both subsystems require the safety-related excess letdown flow path. Also, two independent boration injection subsystems are required to ensure single functional capability in the event an assumed failure renders one of the boration injection subsystems nonfunctional.

Updated Safety Analysis Report Section 7.4.3.3 describes the applicable single failure analysis. It states, The capability of the [residual heat removal system] to accommodate a single component failure and still perform a safety grade cooldown is demonstrated in the failure mode and effects analysis (FMEA) of the [residual heat removal] system for safety-related cold shutdown operations provided as Table 7.4-4. Table 7.4-4, Residual Heat Removal - Safety Related Cold Shutdown Operations - Failure Modes and Effects Analysis (FMEA), describes the function of the excess letdown to pressurizer relief tank isolation valves (8157A and 8157B), stating, Provides safety grade letdown flow path. Hence, in order for the safety-related excess letdown flowpath to the pressurizer relief tank to meet its safety function, either 8157A or 8157B must be functional and capable of opening.

The inspectors again questioned the updated immediate functionality determinations adequacy. Specifically, considering that 8157A and 8157B are parallel valves, that 8157B was non-functional, and assuming a design basis single failure (for example, assume 8157A fails to open or its power supply fails), the safety-related excess letdown flowpath would be non-functional, and both Technical Requirements Manual independent boration injection subsystems would be impacted. With the excess letdown heat exchanger to pressurizer relief tank isolation valve 8157B non-functional, current language in the Technical Requirements Manual would require one boration injection subsystem to be declared non-functional.

Corrective Actions: On March 20, 2018, the licensee changed the functionality assessment the excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) was determined to be non-functional. In response to the inspectors questions concerning system functionality and design basis information, the licensee initiated Condition Reports 120628 and 120822. The licensee restored the B train excess letdown heat exchanger to pressurizer relief tank isolation valve to service on April 9, 2018.

Corrective Action References: Condition Reports 120287, 120628, 120822 and 122411.

Performance Assessment:

Performance Deficiency: The licensee failed to document a functionality assessment of sufficient scope to address the capability of the safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and excess letdown system to perform their specified safety functions.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).

Specifically, the safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and excess letdown system were inappropriately determined to be functional but degraded and non-conforming, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional.

Significance: The inspectors assessed the significance of the finding using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter 0609, Appendix A, Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, and determined this finding is not a deficiency affecting the design or qualification of a mitigating SSC that maintained its operability or functionality; the finding does not represent a loss of system and/or function; the finding does not represent an actual loss of function of at least a single train for greater than its Technical Specification-allowed outage time; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as high safety-significant. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-cutting Aspect: The inspectors determined that the finding has a Human Performance cross-cutting aspect in the area of conservative bias in that individuals did not use decision making-practices that emphasize prudent choices over those that are simply allowable, and a proposed action was not determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, leaders did not take a conservative approach to decision making, particularly when information was incomplete or conditions were unusual when completing the functionality determination associated with the subject valve and system, which resulted in the valve and system being determined to be functional.

Enforcement:

Violation: Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances. Licensee Procedure AP 26C-004, Operability Determination and Functionality Assessment, Revision 35, an Appendix B quality related procedure, provides instructions for performing functionality assessments. Procedure AP 26C-004, Section 6.4.7, states, in part, that the scope of a functionality assessment must be sufficient to address the capability of SSCs to perform their specified functions, and codes, standards, and system requirements controlling the SSC should be considered when performing functionality assessments.

Contrary to the above, from March 12, 2018, until April 9, 2018, the scope of a functionality assessment was not sufficient to address the capability of SSCs to perform their specified functions, and codes, standards, and system requirements controlling the SSC were not considered when performing functionality assessments. Specifically, the functionality assessment associated with the excess letdown heat exchanger outlet to pressurizer relief tank isolation valve and excess letdown system was not adequate and did not adequately consider design basis information, which caused the licensee to fail to identify non-functionality of safety-related SSCs.

Disposition: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On April 25, 2018, the inspector presented the quarterly resident inspector inspection results to Mr. C. Reasoner, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

Number

Title

Revision

SYS EF-205

ESW/Circ Water Cold Weather Operations

Miscellaneous

Number

Title

Date

96-0316

Performance Improvement Request

Initiated

February 5,

1996

2006-0006

Performance Improvement Request

Initiated

January 4,

2006

APF 15C-002-01 Procedure Cover Sheet - ESW/Circ Water Cold Weather

Operations - SYS EF-205

Completed

December 26,

2017

APF 15C-002-01 Procedure Cover Sheet - ESW/Circ Water Cold Weather

Operations - SYS EF-205

Completed

January 2,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Day Shift

January 19,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - ESW Train B Warming

Line Verification - STN EF-020B

Completed

January 3,

2018

WM 96-0081

Docket No 50-482: Response to Enforcement Action

EA 96-124

July 31, 1996

Section 1R04: Equipment Alignment

Procedures

Number

Title

Revision

CKL Al-120

Auxiliary Feedwater Normal Lineup

CKL EG-120

Component Cooling Water System Valve, Switch and

Breaker Lineup

CKL EJ-120

RHR System Lineup

45B

Drawings

Number

Title

Revision

M-06EG07

Component Coolant Wtr. Sys. Aux. Bldg.

M-12AL01

Piping & Instrumentation Diagram Auxiliary Feedwater

System

M-12EG01

Piping & Instrumentation Diagram Component Cooling

Water System

M-12EG02

Piping & Instrumentation Diagram Component Cooling

Water System

M-12EG03

Piping & Instrumentation Diagram Component Cooling

Water System

M-12EJ01

Piping and Instrumentation Diagram Residual Heat

Removal System

M-12FC02

Piping & Instrumentation Diagram Auxiliary Feedwater

Pump Turbine

M-13EG07

Piping Isometric Component Cooling Water Sys. Aux. Bldg.

Common Header

M-15EG07

Hanger Location Drawing Component Cooling Water Sys

Aux. Bldg. Common Header

Condition Reports

119280

119401

20586

Section 1R05: Fire Protection

Procedures

Number

Title

Revision

AP 10-106

Fire Preplans

18A

CKL ZL-001

Auxiliary Building Reading Sheets

103

Condition Reports

119366

20782

20783

20784

Miscellaneous

Number

Title

Revision

E-1F9905

Fire Hazard Analysis

XX-X-004

Calculation Cover Sheet - Combustible Fire Loading For

Each Room In The Various Fire Areas at WCNOC

Section 1R06: Flood Protection Measures

Procedures

Number

Title

Revision

ALR 00-094F

Misc Sumps Lev Hi

Drawings

Number

Title

Revision

M-12EJ01

Piping and Instrumentation Diagram Residual Heat

Removal System

M-13LF02

Piping Isometric Sump Discharge Auxiliary Bldg.

Condition Reports

118576

118586

118587

118592

118593

Miscellaneous

Number

Title

Revision

FL-03

Flooding of Individual Auxiliary Building Rooms

Section 1R07: Heat Sink Performance

Procedures

Number

Title

Revision

AP 23L-002

Heat Exchanger Program

Work Orders

17-428729-000

17-428729-002

17-428729-003

17-428729-005

17-428737-000

Miscellaneous

Number

Title

Date

GL-05

Maintenance Rule Final Scope Evaluation

Printed

March 27,

2018

Section 1R11: Licensed Operator Requalification Program

Procedures

Number

Title

Revision

AP 21-001

Conduct of Operations

STS RE-006

EOL Core MTC Measurement

20B

STS SE-001

Power Range Adjustment to Calorimetric

Miscellaneous

Number

Title

Revision/Date

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Day Shift

February 2,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Day Shift

February 3,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

February 3,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

February 4,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

February 5,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - EOL Core MTC

Measurement

Completed

February 5,

2018

EPF 06-007-01

Wolf Creek Generating Station Emergency Notification

(Drill)

February 22,

2018

LR5004005

Loss of All AC While Shutdown - Licensed Operator

Requal

Section 1R12: Maintenance Effectiveness

Drawings

Number

Title

Revision/Date

M-12GL01

Piping and Instrumentation Diagram Auxiliary Building

HVAC

M-612.00062

Carrier Air Handling Units and Room Coolers

Imaged May

2017

Condition Reports

10539

114660

117759

Miscellaneous

Number

Title

Date

GL Room Cooler PM Schedule

Maintenance Rule Expert Panel Meeting Agenda

November 1,

2017

114660

Functional Failure Determination Checklist

August 17,

2017

GL-01

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-02

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-03

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-04

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-05

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-06

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-07

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-08

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-09

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

Procedures

Number

Title

Revision

AP 22C-003

On-Line Nuclear Safety and Generation Risk Assessment

Procedures

Number

Title

Revision

OFN AF-025

Unit Limitations

STS BB-201B

Cycle Test of PORV Block Valve BB HV-800B

STS IC-447

Channel Calibration Nuclear Instrumentation System Power

Range Incore-Excore

STS MT-024B

Functional Test of 480 and 120 Volt Molded Case Circuit

Breakers

Drawings

Number

Title

Revision

M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout

W03

Condition Reports

118499

118938

118939

118940

118953

118958

118959

118963

118964

Work Orders

17-422791-003

17-427320-000

18-434985-000

18-435758-000

18-435758-001

Miscellaneous

Number

Title

Date

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Day Shift

January 23,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

January 23,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Day Shift

January 24,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

January 24,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

January 25,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

January 26,

2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:

18-0101

January 4,

2018

Miscellaneous

Number

Title

Date

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:

18-0111

March 13,

2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:

2018-0110

February 15,

2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:

2018-0104

January 10,

2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment -

2018-0122

February 14,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-447

Completed

January 4,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - STS PE-004 (Train B)

Completed

March 7,

2018

Section 1R15: Operability Evaluations

Procedures

Number

Title

Revision

AI 16C-006

Troubleshooting

AI 28B-005

Evidence and Action Matrix

AP 12-003

Foreign Material Exclusion

AP 26C-004

Operability Determination and Functionality Assessment

OFN BB-005

RCP Malfunctions

STN BB-201

Exercise of BB HV-8157A and BB HV-8157B

STS BG-001

Boron Injection Flow Path Verification

STS KJ-005A

Manual/Auto Start, Sync and Loading of EDG NE01

67A

STS PE-004

Auxiliary Building and Control Room Pressure Test

SYS GK-122

Manual CRVIS Line-Up

SYS OPS-001

Weekly Equipment Rotation and Readings

80A

Drawings

Number

Title

Revision

E-13GG01

Schematic Diagram Emergency Exhaust Fans

E-13GG03

Schematic Diagram Emergency Exhaust Heating Coils

Drawings

Number

Title

Revision

E-13GG15

Schematic Diagram Emergency Exhaust Cross Connection

Dampers

J-02GG14B (Q)

Fuel Building HVAC Spent Fuel Pool Normal/Emergency

Exhaust Radioactivity Sample Valve

M-12BB02

Piping & Instrumentation Diagram Reactor Coolant System

M-12BB03

Piping and Instrumentation Diagram Reactor Coolant System 15

M-12BG01

Piping & Instrumentation Diagram Chemical and Volume

Control System

M-12BL01

Piping & Instrumentation Diagram Reactor Make-Up Water

System

M-12GG01

Piping Instrumentation Diagram Fuel Building HVAC

M-12GT01

Piping & Instrumentation Diagram Containment Purge

Systems HVAC

M-12HB01

Piping and Instrumentation Diagram Liquid Radwaste

System

M-12LF01

Piping & Instrumentation Diagram Auxiliary Building Floor

and Equipment Drain System

M-12LF03

Piping & Instrumentation Diagram Auxiliary Building Floor

and Equipment Drain System

M-1H1531

Heating Ventilating and Air Cond. Auxiliary Building El. 2047-

Area-3

M-1H6311

Heating Ventilating & Air Cond. Fuel Building El. 2047-6 &

2065-0 Area 1

M-622.1A-00001 SGK05A & SGK05B Air Conditioner Refrigeration Schematic W12

M-622.1A-00002 SGK05A & SGK05B Air Conditioner Electrical Schematic

W13

M-622.1A-00003 SGK05A & SGK05B Air Conditioner Electrical Schematic

W09

M-622.1A-00257 Step Controllers

W01

M-712-00063

Reactor Coolant Pump Data Sheets

W04

M-OPIII

Embedded Drainage Systems (LF) Auxiliary Building EL.

1967-0 & 1974-0 Area I

Condition Reports

24199

90975

107789

110377

117283

118586

118587

118592

118827

118830

Condition Reports

118831

118910

118922

119069

119085

119330

119334

119442

119446

119487

119616

119822

119859

119860

119861

20053

20056

20071

20179

20181

20246

20287

20408

20409

20410

20411

20489

20535

20664

20722

Work Orders

16-411783-010

17-428518-000

18-436340-000

18-436340-002

Miscellaneous

Number

Title

Revision/Date

107363

Functional Failure Determination Checklist

October 12,

2016

118585

Function Failure Determination Checklist

January 28,

2018

AIF 10-001-02

SCBA Inspection

Completed

March 1, 2018

APF 05-002-05

Engineering Disposition - EDG Water, Lube Oil, and Fuel

Oil Leakage Guidance

APF 05C-004-01 Basic Engineering Disposition - Review of Regulatory and

License Basis Documents to evaluate the requirements of

Operability Determination when Safety Related or

Technical Specification Equipment is exposed to a hazard

APF 21-001-02

Control Room Turnover checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

March 14,

2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:

2018-0112

February 14,

2018

APF30B-004-01

Wolf Creek Nuclear Operating Corporation Essential

Required Reading - SBO Power Equipment Center (PEC)

April 1, 2018

GG-01

Maintenance Rule Final Scope Evaluation

Printed

March 22,

2018

GG-02

Maintenance Rule Final Scope Evaluation

Printed

March 22,

2018

Miscellaneous

Number

Title

Revision/Date

GG-03

Maintenance Rule Final Scope Evaluation

Printed

March 22,

2018

GG-04

Maintenance Rule Final Scope Evaluation

Printed

March 22,

2018

Section 1R19: Post-Maintenance Testing

Procedures

Number

Title

Revision

STN AL-201

Auxiliary Feedwater System Valve Test

STN EG-205A

Component Cooling Water System Valve Test

STS EG-100A

Component Cooling Water Pumps A/C [Air Conditioning]

Inservice Pump Test

33A

STS EG-208A

EG TV-029 CCW [Component Cooling Water] HX [Heat

Exchanger] A Temperature Control Valve Inservice Valve

Test

STS EJ-100A

RHR [Residual Heat Removal] System Inservice Pump A

Test

STS IC-540A

Channel Calibration Auxiliary Feedwater System Steam

Generator A

Drawings

Number

Title

Revision/Date

E-13GK13

Schematic Diagram Class 1E Electrical Equipment A/C [Air

Conditioning] Unit

M-12AL01

Piping & Instrumentation Diagram Auxiliary Feedwater

System

M-12AL01

Piping & Instrumentation Diagram Auxiliary Feedwater

System

M-622.1-00036

Electric Motor Data Sheet

March 3, 1977

M-622.1A-00002 SKG05A & SGK05B Air Conditioner Electrical Schematic

W13

M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout

W03

Condition Reports

118881

118901

118920

118953

118958

118959

118963

118964

119289

Work Orders

15-407137-000

Miscellaneous

Number

Title

Revision/Date

WCGS Standing Order 1 - Valve Setup and Operation

36121

Preventative Maintenance Work Instruction

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment

January 23,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - Auxiliary Feedwater

System Valve Test

Completed

February 6,

2018

Section 1R20: Refueling and Other Outage Activities

Procedures

Number

Title

Revision

GEN 00-004

Power Operation

GEN 00-005

Minimum Load To Hot Standby

SYS AE-320

Turbine Driven Main Feedwater Pump Shutdown

28A

SYS AF-121

Heater Drain Pump Operation

Section 1R22: Surveillance Testing

Procedures

Number

Title

Revision

AP 23-009

Control Room Envelope Habitability Program

STS EG-100B

Component Cooling Water Pumps B/D Inservice Pump Test 29

STS IC-217

RCP Loss of Voltage and Underfrequency TADOT

15C

STS IC-915B

Channel Operational Test Train B Component Cooling

Water System Non-Nuclear Safety-Related Isolation

8A

STS IC-926A

Component Cooling Water System Automatic Valve

Actuation Train A

8A

Procedures

Number

Title

Revision

STS IC-926B

Component Cooling Water System Automatic Valve

Actuation Train B

6B

STS PE-004

Auxiliary Building and Control Room Pressure Test

Drawings

Number

Title

Revision

E-13EG01D

Schematic Diagram Component Cooling Water Pump D

E-13EG08A

Schematic Diagram Component Cooling Water Supply

Return From Radwaste Building

E-13EG11

Schematic Diagram Annunciation and Instrumentation

E-13EG20

Schematic Diagram Pass CCW Isolation Valves

M-12EG01

Piping & Instrumentation Diagram Component Cooling

Water System

M-12EG02

Piping & Instrumentation Diagram Component Cooling

Water System

M-12EG03

Piping & Instrumentation Diagram Component Cooling

Water System

Condition Reports

118493

118551

118552

119412

20061

20064

20148

20151

20408

20409

20410

20411

Work Orders

17-431050-000

17-431170-000

17-431759-000

17-432247-000

Miscellaneous

Number

Title

Date

APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-217

Completed

March 5,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-926B

Completed

January 4,

2018

Miscellaneous

Number

Title

Date

APF 30B-004-01 Wolf Creek Nuclear Operating Corporation Essential

Required Reading: 18-0010 Accuracy of WCRE-35

March 7,

2018

Section 1EP6: Drill Evaluation

Procedures

Number

Title

Revision

EPP 06-006

Protective Action Recommendations

9A

Condition Reports

119869

119870

119871

119872

119874

119877

119878

119879

119883

119885

119886

119887

119888

119889

119897

119901

119903

119904

119906

119911

119941

20017

20227

20323

Miscellaneous

Number

Title

Revision/Date

18-SA-01

Wolf Creek Generating Station - Emergency Planning Drill

February 27,

2018

APF 06-002-01

Emergency Action Levels

17A

CR-001

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

EOF-001

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

EOF-002

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

EOF-003

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

EOF-004

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

TSC-001

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

Section 4OA1: Performance Indicator Verification

Miscellaneous

Number

Title

Revision

NEI 99-02

Regulatory Assessment Performance Indicator Guideline

Section 4OA2: Identification and Resolution of Problems

Procedures

Number

Title

Revision

STS MT-005

Pressurizer Code Safety Valve Operability

Drawings

Number

Title

Revision

M-1H1531

Heating Ventilating and Air Cond. Auxiliary Building El.

2047-6 Area-3

Condition Reports

90975

110377

2960

118910

119330

Work Orders

17-428518-001

Miscellaneous

Number

Title

Date

Email from NWS

Technologies to

Wolf Creek

<EXTERNAL> RE: Wolf Creek PSV failure - Questions

from our NRC Resident Inspector

November

30, 2017

P.O. # 692145

SR

Valve Serial Number N60446-00-0001; Traveler 14-381

Testing

Completed

January 2015

PO # 779245

Valve Serial Number N60446-00-0001; Traveler 17-41

Testing

Completed

August 2017

NRC Letter to

Otto L. Maynard

Wolf Creek Generating Station - Issuance of Amendment

RE: Pressurizer Safety Valves (TAC NO. MA6969)

March 23,

2000

White Paper

Pressurizer Safety Valve NRC Follow-up Questions and

Answers

White Paper

Why PZR Safety Valve Failure is NOT a Part 21 Issue

Initial Request for Information

Integrated Inspection

Wolf Creek Nuclear Generating Station

Inspection Report: 05000482/2018001

Inspection Dates: January 1 - March 31, 2018

Inspection Procedure: Integrated Inspection Procedures

Lead Inspector: Douglas Dodson, Senior Resident Inspector

I.

Information Requested Prior to December 22, 2017

The following information should be provided in electronic format (Certrec IMS

preferred), to the attention of Douglas Dodson by December 22, 2017, to facilitate the

reduction in the items to be selected for a final list during inspection preparation. The

inspection team will finalize its sample selections and will provide an additional

information request with specific items. This information shall be made available by

December 22, 2017. The specific items selected from the lists shall be available and

ready for review on the day indicated in this request. *Please provide requested

documentation electronically in pdf files, Excel, or other searchable formats, if possible.

The information should contain descriptive names, and be indexed and hyperlinked to

facilitate ease of use. Information in lists should contain enough information to be

easily understood by someone who has knowledge of pressurized water reactor

technology. If requested documents are large and/or only hard copy formats are

available, please inform the inspector(s), and provide subject documentation.

1. Any pre-existing evaluation or list of component cooling water system components

and associated calculations with low design margins.

2. A list of high risk component cooling water system maintenance rule components

and functions based on engineering or expert panel judgment.

3. A list of component cooling water system related operating experience evaluations

for the last 3 years.

4. A list of all component cooling water system time-critical operator actions in

procedures.

5. A list of permanent and temporary modifications related to component cooling water

system sorted by component.

6. A list of current component cooling water system related operator work

arounds/burdens.

7. A list of the component cooling water system design calculations, which provide the

design margin information for components.

8. List of component cooling water system root cause evaluations associated with

component failures or design issues initiated/completed in the last 5 years.

9. A list of any component cooling water system common-cause failures of

components in the last 3 years.

10. An electronic copy of the component cooling water system design bases documents

and any open, pending, or recently completed changes. Although not an exhaustive

list, please include any open, pending, or recently completed (last 3 years) changes

to temporary modifications, permanent modifications, engineering change

packages, and/or procedure change packages. Specifically, please include any

open, pending, or recently completed changes to emergency operating, abnormal

operating, normal operating, alarm response, system alignment, surveillance, or

other procedure.

11. An electronic copy of the component cooling water system System Health notebook.

2. A copy of component cooling water system related audits completed in the last 2

years.

13. A list of component cooling water system motor operated valves (MOVs) in the

program, design margin and risk ranking.

14. A list of component cooling water system air operated valves (AOVs) in the valve

program, design margin and risk ranking.

15. Component cooling water system structure, system, and components maintenance

rule category, scoping, unavailability data, unreliability data, functional failure

evaluations, (a)(1) determinations, (a)(1) goals, and any supporting basis

documentation.

16. A list of component cooling water system licensee contacts for the inspection team

with pager or phone numbers.

17. An excel spreadsheet of component cooling water system related PRA human

action basic events or risk ranking of operator actions from your site specific PSA

sorted by RAW and FV. Provide copies of your human reliability worksheets for

these items.

18. In so far as there are recent or pending changes, please provide an Excel

spreadsheet of component cooling water system related equipment basic events

(with definitions) including importance measures sorted by risk achievement worth

(RAW) and Fussell-Vesely (FV) from your internal events probabilistic risk

assessment (PRA). Include basic events with RAW value of 1.3 or greater.

19. In so far as there are recent or pending changes, please provide a list of the top 50

cut-sets from your PRA.

20. In so far as there are recent or pending changes, please provide copies of PRA

system notebooks, and the latest PRA summary document.

21. In so far as there are recent or pending changes, and if you have an external events

or fire PSA model, provide the information requested in items 17-19 for external

events and fire, as it relates to the component cooling water system.

2. In so far as there are recent or pending changes, please provide a copy of the Wolf

Creek Nuclear Generating Station IPEEE changes, if available electronically.

ML18131A017

SUNSI Review:

ADAMS:

Non-Publicly Available

Non-Sensitive

Keyword:

By: NHT/rdr

Yes No

Publicly Available

Sensitive

NRC-002

OFFICE

SRI:DRP/B

RI:DRP/B

C:DRS/OB

C:DRS/PSB2

C:DRS/EB1

C:DRS/EB2

NAME

DDodson

FThomas

VGaddy

HGepford

TFarnholtz

JDrake

SIGNATURE

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

DATE

5/9/2018

5/10/18

5/3/18

5/3/18

5/3/2018

5/9/18

OFFICE

TL:DRS/IPAT

SRI/DRP/B

BC:DRP/B

NAME

GGeorge

DBradley

NTaylor

SIGNATURE

/RA -

HFreeman for/

/RA/

/RA/

DATE

5/10/18

5/7/18

5/14/18

May 14, 2018

Mr. Adam

C. Heflin, President

and Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION

REPORT 05000482/2018001

Dear Mr. Heflin:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Wolf Creek Generating Station. On April 25, 2018, the NRC inspectors discussed the

results of this inspection with Mr.

C. Reasoner, Site Vice President, and other members of your

staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a

non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance of this non-cited violation, you should provide a

response within 30 days of the date of this inspection report, with the basis for your denial, to

the

U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC

20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of

Enforcement; and the NRC resident inspector at the Wolf Creek Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the

U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the

NRC resident inspector at the Wolf Creek Generating Station.

A. Heflin

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/

Nicholas

H. Taylor, Chief

Project Branch B

Division of Reactor Projects

Docket No. 50-482

License No. NPF-42

Enclosure:

Inspection Report 05000482/2018001

w/ Attachments:

1. Supplemental Information

2. Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number:

05000482

License Number:

NPF-42

Report Number:

05000482/2018001

Enterprise Identifier: I-2018-001-0012

Licensee:

Wolf Creek Nuclear Operating Corporation

Facility:

Wolf Creek Generating Station

Location:

1550 Oxen Lane NE

Burlington, KS 66839

Inspection Dates:

January 1, 2018, to March 31, 2018

Inspectors:

D. Dodson, Senior Resident Inspector
F. Thomas, Resident Inspector
D. Bradley, Senior Resident Inspector, Callaway

Approved By:

N. Taylor, Chief, Project Branch B, Division of Reactor Projects

SUMMARY

The Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance

by conducting an Integrated Inspection at Wolf Creek Generating Station in accordance with the

Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for

overseeing the safe operation of commercial nuclear power reactors. Refer to

https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and

self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations

Inadequate Functionality Assessment Associated with the Emergency Excess Letdown

Flowpath

Cornerstone

Significance

Cross-cutting Aspect Report Section

Mitigating

Systems

Green

NCV 05000482/2018001-01

Closed

[H.14] - Human

Performance,

Conservative Bias

71111.15 -

Operability

Determinations

and Functionality

Assessments

The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to

adequately implement the operability determination and functionality assessment procedure.

Specifically, the licensee failed to document a functionality assessment of sufficient scope to

address the capability of a safety-related excess letdown heat exchanger to pressurizer relief

tank isolation valve and the excess letdown system to perform their specified safety functions,

which resulted in the licensee failing to recognize that two independent Technical

Requirements Manual required boration injection subsystems were not functional.

PLANT STATUS

Wolf Creek Generating Station began the inspection period at rated thermal power. On

March 30, 2018, a plant shutdown was completed to begin Refueling Outage 22.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors performed plant status activities described in

IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem

Identification and Resolution. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for extreme

low temperatures on January 2 and 3, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) turbine-driven auxiliary feedwater train on February 6, 2018

(2) residual heat removal pump B on March 21, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the

component cooling water system on February 23, 2018.

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) fire area A-16, general area, elevation 2,026 feet on January 30, and March 28, 2018

(2) fire area A-18, electrical penetration room (north), elevation 2,026 feet on January 30,

2018

(3) fire area A-17, electrical penetration room (south), elevation 2,026 feet on March 28,

2018

(4) fire area A-26, decontamination area for I&C shop, elevation 2,026 feet on March 28,

2018

(5) fire area A-27, reactor trip switchgear, motor-generator sets, load centers, rod control

and rod-drive power supply control cabinets 125 volt direct current panel on March 28,

2018.

71111.06 - Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protections in rooms 1203 and 1203A,

Pipe Space B on January 9, 2018.

71111.07 - Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated containment spray train A room cooler (SGL13A) performance on

January 17, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated licensed operator simulator requalification activities

that included a loss of all alternating current power during shutdown scenario on February 22,

2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated operator performance during end of life core moderator

temperature coefficient measurement activities on February 5, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

Auxiliary building heating ventilation and air conditioning (GL) system including safety-

related pump and electrical penetration room coolers on January 29, 2018.

71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) reactor partial trip alarm troubleshooting and main generator transformer B loss of two

cooling groups on January 4, 2018

(2) emergent maintenance on Class 1E electrical equipment air conditioning unit train A on

January 24, 2018

(3) planned maintenance on component cooling water train B on March 5, 2018

(4) emergent maintenance associated with the failed control room envelope pressure test

on March 6, 2018

(5) emergent maintenance on Class 1E electrical equipment air conditioning unit train B on

March 12, 2018.

71111.15 - Operability Determinations and Functionality Assessments (8 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) auxiliary building elevation 1988 foot south pipe chase drain functionality with three

clogged floor drains on January 10, 2018

(2) 125 volt direct current to 120 volt alternating current NN15 inverter operability after a

high voltage alarm would not clear on January 18, 2018

(3) emergency diesel generator A lubrication oil leakage on January 31, 2018

(4) Class 1E electrical equipment air conditioning unit train B operability following a step

controller failure on February 12, 2018

(5) reactor coolant pump A standpipe not filling on the expected frequency on February 25,

2018

(6) Technical Specification 3.7.10 mitigating actions to ensure the control room envelope

occupant radiological exposures would not exceed limits and control room envelope

occupants are protected from chemical and smoke hazards while the control room

envelope was inoperable on March 6, 2018

(7) excess letdown heat exchanger outlet to pressurizer relief tank isolation valve

functionality after failed stoke testing on March 12, 2018

(8) station blackout diesel generator functionality after post maintenance testing on

March 20, 2018.

71111.19 - Post Maintenance Testing (4 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Class 1E electrical equipment air conditioning unit train A following planned maintenance

on January 24, 2018

(2) motor-driven auxiliary feedwater train B pump discharge to steam generators A and D

auxiliary feed water flow regulating valve testing following planned maintenance on

February 6, 2018

(3) component cooling water pump A following planned maintenance on February 15, 2018

(4) residual heat removal pump A following planned maintenance on March 21, 2018.

71111.20 - Refueling and Other Outage Activities (Partial Sample)

The inspectors evaluated Refueling Outage 22 activities from March 30 to 31, 2018. The

inspectors completed inspection procedure Sections 03.01.a, 03.01.b, and 03.01.c.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (5 Samples)

(1) STS IC-926B, Component Cooling Water System Automatic Valve Actuation Train B,

Revision 6B, on January 4, 2018

(2) STS IC-915B, Channel Operational Test Train B Component Cooling Water System

Non-Nuclear Safety-Related Isolation, Revision 8A, on January 8, 2018

(3) STS IC-926A, Component Cooling Water System Automatic Valve Actuation Train A,

Revision 8A, on February 12, 2018

(4) STS IC-217, [Reactor Coolant Pump] Loss of Voltage and Underfrequency [Trip

Actuation Device Operational Testing], on March 5, 2018

(5) STS PE-004, Auxiliary Building and Control Room Pressure Tests, Revision 16, on

March 5 and March 12, 2018.

71114.06 - Drill Evaluation

Emergency Planning Drill (1 Sample)

The inspectors evaluated the emergency preparedness drill on February 27, 2018.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification (3 Samples)

The inspectors verified licensee performance indicator submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017-12/31/2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017-

2/31/2017)

(3) IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017-12/31/2017).

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1) On February 8, 2018, the unit vent tornado damper failed to meet acceptance criteria for

initial breakaway torque. This issue was documented in Condition Report 119330.

(2) On May 11, 2017, Condition Report 112960 documented that pressurizer safety valve

88010As as-found lift setting was 3.2 percent below the nominal setpoint.

INSPECTION RESULTS

Inadequate Functionality Assessment Associated with the Emergency Excess Letdown

Flowpath

Cornerstone

Significance

Cross-cutting Aspect

Report Section

Mitigating

Systems

Green

NCV 05000482/2018001-01

Closed

[H.14] - Human

Performance,

Conservative Bias

71111.15 -

Operability

Determinations

and Functionality

Assessments

The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee

failed to adequately implement the operability determination and functionality assessment

procedure. Specifically, the licensee failed to document a functionality assessment of

sufficient scope to address the capability of a safety-related excess letdown heat exchanger

to pressurizer relief tank isolation valve and the excess letdown system to perform their

specified safety functions, which resulted in the licensee failing to recognize that two

independent Technical Requirements Manual required boration injection subsystems were

not functional.

Description: On March 12, 2018, the licensee was performing Procedure STN BB-201,

Exercise of BB HV-8157A and BB HV-8157B, Revision 3, which tests and exercises the

excess letdown heat exchanger to pressurizer relief tank isolation valves (BB HV-8157A and

BB HV-8157B). The BB HV-8157B valve did not stroke fully closed as expected. Step 6.1.1

of Procedure STN BB-201 states, If the valve cannot be fully exercised, then valve shall be

declared inoperable and corrective action initiated.

Condition Report 120287 was documented on March 12, 2018, reporting the valve

failure. The immediate functionality assessment stated, The redundant path of

excess letdown is still available. The system is functional but degraded. The system

functionality is maintained by having a second redundant flow path for excess

letdown. The inspectors noted that Section 6.4.7 of Procedure AP 26C-004,

Operability Determination and Functionality Assessment, Revision 35, states, The

scope of a functionality assessment must be sufficient to address the capability of

SSCs to perform their specified functionsThe following things should be considered

when performing functionality assessments: codes, standards and system

requirements controlling the SSC.

The inspectors questioned the licensee concerning the immediate functionality

determinations adequacy, and the licensee revised the functionality determination for the

excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) and changed

the determination to non-functional. The immediate functionality determination was updated

to state:

The above screening gives an adequate justification for why the excess

letdown po[r]tion of the [chemical and volume control system] remains

functional but degraded. However, screening should be based on the

component, not the system. Since BBHV8157B cannot be relied upon to go to

the closed position using normal remote controls, the valve is considered

nonfunctional. The system remains functional but degraded.

The inspectors also noted that Section 3.1.9, Boration Injection System - Operating, of the

Technical Requirements Manual, requires two boration injection subsystems to be functional

in MODES 1, 2, and 3. Section 3.1.9 of the Technical Requirements Manual Bases describes

what is required for a boration injection subsystem to be considered functional. Specifically,

both subsystems require the safety-related excess letdown flow path. Also, two independent

boration injection subsystems are required to ensure single functional capability in the event

an assumed failure renders one of the boration injection subsystems nonfunctional.

Updated Safety Analysis Report Section 7.4.3.3 describes the applicable single failure

analysis. It states, The capability of the [residual heat removal system] to accommodate a

single component failure and still perform a safety grade cooldown is demonstrated in the

failure mode and effects analysis (FMEA) of the [residual heat removal] system for safety-

related cold shutdown operations provided as Table 7.4-4. Table 7.4-4, Residual Heat

Removal - Safety Related Cold Shutdown Operations - Failure Modes and Effects Analysis

(FMEA), describes the function of the excess letdown to pressurizer relief tank isolation

valves (8157A and 8157B), stating, Provides safety grade letdown flow path. Hence, in

order for the safety-related excess letdown flowpath to the pressurizer relief tank to meet its

safety function, either 8157A or 8157B must be functional and capable of opening.

The inspectors again questioned the updated immediate functionality determinations

adequacy. Specifically, considering that 8157A and 8157B are parallel valves, that 8157B

was non-functional, and assuming a design basis single failure (for example, assume 8157A

fails to open or its power supply fails), the safety-related excess letdown flowpath would be

non-functional, and both Technical Requirements Manual independent boration injection

subsystems would be impacted. With the excess letdown heat exchanger to pressurizer relief

tank isolation valve 8157B non-functional, current language in the Technical Requirements

Manual would require one boration injection subsystem to be declared non-functional.

Corrective Actions: On March 20, 2018, the licensee changed the functionality assessment

the excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) was

determined to be non-functional. In response to the inspectors questions concerning system

functionality and design basis information, the licensee initiated Condition Reports 120628

and 120822. The licensee restored the B train excess letdown heat exchanger to pressurizer

relief tank isolation valve to service on April 9, 2018.

Corrective Action References: Condition Reports 120287, 120628, 120822 and 122411.

Performance Assessment:

Performance Deficiency: The licensee failed to document a functionality assessment of

sufficient scope to address the capability of the safety-related excess letdown heat exchanger

to pressurizer relief tank isolation valve and excess letdown system to perform their specified

safety functions.

Screening: The inspectors determined the performance deficiency was more than minor

because it adversely affected the equipment performance attribute of the Mitigating Systems

Cornerstone objective to ensure the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences (i.e., core damage).

Specifically, the safety-related excess letdown heat exchanger to pressurizer relief tank

isolation valve and excess letdown system were inappropriately determined to be functional

but degraded and non-conforming, which resulted in the licensee failing to recognize that two

independent Technical Requirements Manual required boration injection subsystems were

not functional.

Significance: The inspectors assessed the significance of the finding using Exhibit 2,

Mitigating Systems Screening Questions, of Inspection Manual Chapter 0609, Appendix A,

Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012,

and determined this finding is not a deficiency affecting the design or qualification of a

mitigating SSC that maintained its operability or functionality; the finding does not represent a

loss of system and/or function; the finding does not represent an actual loss of function of at

least a single train for greater than its Technical Specification-allowed outage time; and the

finding does not represent an actual loss of function of one or more non-Technical

Specification trains of equipment designated as high safety-significant. Therefore, the

inspectors determined the finding was of very low safety significance (Green).

Cross-cutting Aspect: The inspectors determined that the finding has a Human Performance

cross-cutting aspect in the area of conservative bias in that individuals did not use decision

making-practices that emphasize prudent choices over those that are simply allowable, and a

proposed action was not determined to be safe in order to proceed, rather than unsafe in

order to stop. Specifically, leaders did not take a conservative approach to decision making,

particularly when information was incomplete or conditions were unusual when completing

the functionality determination associated with the subject valve and system, which resulted

in the valve and system being determined to be functional.

Enforcement:

Violation: Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and

Drawings, requires, in part, that activities affecting quality shall be accomplished in

accordance with documented instructions, procedures, or drawings of a type appropriate to

the circumstances. Licensee Procedure AP 26C-004, Operability Determination and

Functionality Assessment, Revision 35, an Appendix B quality related procedure, provides

instructions for performing functionality assessments. Procedure AP 26C-004, Section 6.4.7,

states, in part, that the scope of a functionality assessment must be sufficient to address the

capability of SSCs to perform their specified functions, and codes, standards, and system

requirements controlling the SSC should be considered when performing functionality

assessments.

Contrary to the above, from March 12, 2018, until April 9, 2018, the scope of a functionality

assessment was not sufficient to address the capability of SSCs to perform their specified

functions, and codes, standards, and system requirements controlling the SSC were not

considered when performing functionality assessments. Specifically, the functionality

assessment associated with the excess letdown heat exchanger outlet to pressurizer relief

tank isolation valve and excess letdown system was not adequate and did not adequately

consider design basis information, which caused the licensee to fail to identify non-

functionality of safety-related SSCs.

Disposition: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On April 25, 2018, the inspector presented the quarterly resident inspector inspection results to

Mr.

C. Reasoner, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

Number

Title

Revision

SYS EF-205

ESW/Circ Water Cold Weather Operations

Miscellaneous

Number

Title

Date

96-0316

Performance Improvement Request

Initiated

February 5,

1996

2006-0006

Performance Improvement Request

Initiated

January 4,

2006

APF 15C-002-01 Procedure Cover Sheet - ESW/Circ Water Cold Weather

Operations - SYS EF-205

Completed

December 26,

2017

APF 15C-002-01 Procedure Cover Sheet - ESW/Circ Water Cold Weather

Operations - SYS EF-205

Completed

January 2,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Day Shift

January 19,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - ESW Train B Warming

Line Verification - STN EF-020B

Completed

January 3,

2018

WM 96-0081

Docket No 50-482: Response to Enforcement Action

EA 96-124

July 31, 1996

Section 1R04: Equipment Alignment

Procedures

Number

Title

Revision

CKL Al-120

Auxiliary Feedwater Normal Lineup

CKL EG-120

Component Cooling Water System Valve, Switch and

Breaker Lineup

CKL EJ-120

RHR System Lineup

45B

Drawings

Number

Title

Revision

M-06EG07

Component Coolant Wtr. Sys. Aux. Bldg.

M-12AL01

Piping & Instrumentation Diagram Auxiliary Feedwater

System

M-12EG01

Piping & Instrumentation Diagram Component Cooling

Water System

M-12EG02

Piping & Instrumentation Diagram Component Cooling

Water System

M-12EG03

Piping & Instrumentation Diagram Component Cooling

Water System

M-12EJ01

Piping and Instrumentation Diagram Residual Heat

Removal System

M-12FC02

Piping & Instrumentation Diagram Auxiliary Feedwater

Pump Turbine

M-13EG07

Piping Isometric Component Cooling Water Sys. Aux. Bldg.

Common Header

M-15EG07

Hanger Location Drawing Component Cooling Water Sys

Aux. Bldg. Common Header

Condition Reports

119280

119401

20586

Section 1R05: Fire Protection

Procedures

Number

Title

Revision

AP 10-106

Fire Preplans

18A

CKL ZL-001

Auxiliary Building Reading Sheets

103

Condition Reports

119366

20782

20783

20784

Miscellaneous

Number

Title

Revision

E-1F9905

Fire Hazard Analysis

XX-X-004

Calculation Cover Sheet - Combustible Fire Loading For

Each Room In The Various Fire Areas at WCNOC

Section 1R06: Flood Protection Measures

Procedures

Number

Title

Revision

ALR 00-094F

Misc Sumps Lev Hi

Drawings

Number

Title

Revision

M-12EJ01

Piping and Instrumentation Diagram Residual Heat

Removal System

M-13LF02

Piping Isometric Sump Discharge Auxiliary Bldg.

Condition Reports

118576

118586

118587

118592

118593

Miscellaneous

Number

Title

Revision

FL-03

Flooding of Individual Auxiliary Building Rooms

Section 1R07: Heat Sink Performance

Procedures

Number

Title

Revision

AP 23L-002

Heat Exchanger Program

Work Orders

17-428729-000

17-428729-002

17-428729-003

17-428729-005

17-428737-000

Miscellaneous

Number

Title

Date

GL-05

Maintenance Rule Final Scope Evaluation

Printed

March 27,

2018

Section 1R11: Licensed Operator Requalification Program

Procedures

Number

Title

Revision

AP 21-001

Conduct of Operations

STS RE-006

EOL Core MTC Measurement

20B

STS SE-001

Power Range Adjustment to Calorimetric

Miscellaneous

Number

Title

Revision/Date

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Day Shift

February 2,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Day Shift

February 3,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

February 3,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

February 4,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

February 5,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - EOL Core MTC

Measurement

Completed

February 5,

2018

EPF 06-007-01

Wolf Creek Generating Station Emergency Notification

(Drill)

February 22,

2018

LR5004005

Loss of All AC While Shutdown - Licensed Operator

Requal

Section 1R12: Maintenance Effectiveness

Drawings

Number

Title

Revision/Date

M-12GL01

Piping and Instrumentation Diagram Auxiliary Building

HVAC

M-612.00062

Carrier Air Handling Units and Room Coolers

Imaged May

2017

Condition Reports

10539

114660

117759

Miscellaneous

Number

Title

Date

GL Room Cooler PM Schedule

Maintenance Rule Expert Panel Meeting Agenda

November 1,

2017

114660

Functional Failure Determination Checklist

August 17,

2017

GL-01

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-02

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-03

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-04

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-05

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-06

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-07

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-08

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

GL-09

Maintenance Rule Final Scope Evaluation

Printed

January 29,

2018

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

Procedures

Number

Title

Revision

AP 22C-003

On-Line Nuclear Safety and Generation Risk Assessment

Procedures

Number

Title

Revision

OFN AF-025

Unit Limitations

STS BB-201B

Cycle Test of PORV Block Valve BB HV-800B

STS IC-447

Channel Calibration Nuclear Instrumentation System Power

Range Incore-Excore

STS MT-024B

Functional Test of 480 and 120 Volt Molded Case Circuit

Breakers

Drawings

Number

Title

Revision

M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout

W03

Condition Reports

118499

118938

118939

118940

118953

118958

118959

118963

118964

Work Orders

17-422791-003

17-427320-000

18-434985-000

18-435758-000

18-435758-001

Miscellaneous

Number

Title

Date

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Day Shift

January 23,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

January 23,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Day Shift

January 24,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

January 24,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

January 25,

2018

APF 21-001-02

Control Room Turnover Checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

January 26,

2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:

18-0101

January 4,

2018

Miscellaneous

Number

Title

Date

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:

18-0111

March 13,

2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:

2018-0110

February 15,

2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:

2018-0104

January 10,

2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment -

2018-0122

February 14,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-447

Completed

January 4,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - STS PE-004 (Train B)

Completed

March 7,

2018

Section 1R15: Operability Evaluations

Procedures

Number

Title

Revision

AI 16C-006

Troubleshooting

AI 28B-005

Evidence and Action Matrix

AP 12-003

Foreign Material Exclusion

AP 26C-004

Operability Determination and Functionality Assessment

OFN BB-005

RCP Malfunctions

STN BB-201

Exercise of BB HV-8157A and BB HV-8157B

STS BG-001

Boron Injection Flow Path Verification

STS KJ-005A

Manual/Auto Start, Sync and Loading of EDG NE01

67A

STS PE-004

Auxiliary Building and Control Room Pressure Test

SYS GK-122

Manual CRVIS Line-Up

SYS OPS-001

Weekly Equipment Rotation and Readings

80A

Drawings

Number

Title

Revision

E-13GG01

Schematic Diagram Emergency Exhaust Fans

E-13GG03

Schematic Diagram Emergency Exhaust Heating Coils

Drawings

Number

Title

Revision

E-13GG15

Schematic Diagram Emergency Exhaust Cross Connection

Dampers

J-02GG14B (Q)

Fuel Building HVAC Spent Fuel Pool Normal/Emergency

Exhaust Radioactivity Sample Valve

M-12BB02

Piping & Instrumentation Diagram Reactor Coolant System

M-12BB03

Piping and Instrumentation Diagram Reactor Coolant System 15

M-12BG01

Piping & Instrumentation Diagram Chemical and Volume

Control System

M-12BL01

Piping & Instrumentation Diagram Reactor Make-Up Water

System

M-12GG01

Piping Instrumentation Diagram Fuel Building HVAC

M-12GT01

Piping & Instrumentation Diagram Containment Purge

Systems HVAC

M-12HB01

Piping and Instrumentation Diagram Liquid Radwaste

System

M-12LF01

Piping & Instrumentation Diagram Auxiliary Building Floor

and Equipment Drain System

M-12LF03

Piping & Instrumentation Diagram Auxiliary Building Floor

and Equipment Drain System

M-1H1531

Heating Ventilating and Air Cond. Auxiliary Building El. 2047-

Area-3

M-1H6311

Heating Ventilating & Air Cond. Fuel Building El. 2047-6 &

2065-0 Area 1

M-622.1A-00001 SGK05A & SGK05B Air Conditioner Refrigeration Schematic W12

M-622.1A-00002 SGK05A & SGK05B Air Conditioner Electrical Schematic

W13

M-622.1A-00003 SGK05A & SGK05B Air Conditioner Electrical Schematic

W09

M-622.1A-00257 Step Controllers

W01

M-712-00063

Reactor Coolant Pump Data Sheets

W04

M-OPIII

Embedded Drainage Systems (LF) Auxiliary Building EL.

1967-0 & 1974-0 Area I

Condition Reports

24199

90975

107789

110377

117283

118586

118587

118592

118827

118830

Condition Reports

118831

118910

118922

119069

119085

119330

119334

119442

119446

119487

119616

119822

119859

119860

119861

20053

20056

20071

20179

20181

20246

20287

20408

20409

20410

20411

20489

20535

20664

20722

Work Orders

16-411783-010

17-428518-000

18-436340-000

18-436340-002

Miscellaneous

Number

Title

Revision/Date

107363

Functional Failure Determination Checklist

October 12,

2016

118585

Function Failure Determination Checklist

January 28,

2018

AIF 10-001-02

SCBA Inspection

Completed

March 1, 2018

APF 05-002-05

Engineering Disposition - EDG Water, Lube Oil, and Fuel

Oil Leakage Guidance

APF 05C-004-01 Basic Engineering Disposition - Review of Regulatory and

License Basis Documents to evaluate the requirements of

Operability Determination when Safety Related or

Technical Specification Equipment is exposed to a hazard

APF 21-001-02

Control Room Turnover checklist - On-Coming CRS/WC

SRO/RO/BOP Review - Night Shift

March 14,

2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment:

2018-0112

February 14,

2018

APF30B-004-01

Wolf Creek Nuclear Operating Corporation Essential

Required Reading - SBO Power Equipment Center (PEC)

April 1, 2018

GG-01

Maintenance Rule Final Scope Evaluation

Printed

March 22,

2018

GG-02

Maintenance Rule Final Scope Evaluation

Printed

March 22,

2018

Miscellaneous

Number

Title

Revision/Date

GG-03

Maintenance Rule Final Scope Evaluation

Printed

March 22,

2018

GG-04

Maintenance Rule Final Scope Evaluation

Printed

March 22,

2018

Section 1R19: Post-Maintenance Testing

Procedures

Number

Title

Revision

STN AL-201

Auxiliary Feedwater System Valve Test

STN EG-205A

Component Cooling Water System Valve Test

STS EG-100A

Component Cooling Water Pumps A/C [Air Conditioning]

Inservice Pump Test

33A

STS EG-208A

EG TV-029 CCW [Component Cooling Water] HX [Heat

Exchanger] A Temperature Control Valve Inservice Valve

Test

STS EJ-100A

RHR [Residual Heat Removal] System Inservice Pump A

Test

STS IC-540A

Channel Calibration Auxiliary Feedwater System Steam

Generator A

Drawings

Number

Title

Revision/Date

E-13GK13

Schematic Diagram Class 1E Electrical Equipment A/C [Air

Conditioning] Unit

M-12AL01

Piping & Instrumentation Diagram Auxiliary Feedwater

System

M-12AL01

Piping & Instrumentation Diagram Auxiliary Feedwater

System

M-622.1-00036

Electric Motor Data Sheet

March 3, 1977

M-622.1A-00002 SKG05A & SGK05B Air Conditioner Electrical Schematic

W13

M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout

W03

Condition Reports

118881

118901

118920

118953

118958

118959

118963

118964

119289

Work Orders

15-407137-000

Miscellaneous

Number

Title

Revision/Date

WCGS Standing Order 1 - Valve Setup and Operation

36121

Preventative Maintenance Work Instruction

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment

January 23,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - Auxiliary Feedwater

System Valve Test

Completed

February 6,

2018

Section 1R20: Refueling and Other Outage Activities

Procedures

Number

Title

Revision

GEN 00-004

Power Operation

GEN 00-005

Minimum Load To Hot Standby

SYS AE-320

Turbine Driven Main Feedwater Pump Shutdown

28A

SYS AF-121

Heater Drain Pump Operation

Section 1R22: Surveillance Testing

Procedures

Number

Title

Revision

AP 23-009

Control Room Envelope Habitability Program

STS EG-100B

Component Cooling Water Pumps B/D Inservice Pump Test 29

STS IC-217

RCP Loss of Voltage and Underfrequency TADOT

15C

STS IC-915B

Channel Operational Test Train B Component Cooling

Water System Non-Nuclear Safety-Related Isolation

8A

STS IC-926A

Component Cooling Water System Automatic Valve

Actuation Train A

8A

Procedures

Number

Title

Revision

STS IC-926B

Component Cooling Water System Automatic Valve

Actuation Train B

6B

STS PE-004

Auxiliary Building and Control Room Pressure Test

Drawings

Number

Title

Revision

E-13EG01D

Schematic Diagram Component Cooling Water Pump D

E-13EG08A

Schematic Diagram Component Cooling Water Supply

Return From Radwaste Building

E-13EG11

Schematic Diagram Annunciation and Instrumentation

E-13EG20

Schematic Diagram Pass CCW Isolation Valves

M-12EG01

Piping & Instrumentation Diagram Component Cooling

Water System

M-12EG02

Piping & Instrumentation Diagram Component Cooling

Water System

M-12EG03

Piping & Instrumentation Diagram Component Cooling

Water System

Condition Reports

118493

118551

118552

119412

20061

20064

20148

20151

20408

20409

20410

20411

Work Orders

17-431050-000

17-431170-000

17-431759-000

17-432247-000

Miscellaneous

Number

Title

Date

APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-217

Completed

March 5,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-926B

Completed

January 4,

2018

Miscellaneous

Number

Title

Date

APF 30B-004-01 Wolf Creek Nuclear Operating Corporation Essential

Required Reading: 18-0010 Accuracy of WCRE-35

March 7,

2018

Section 1EP6: Drill Evaluation

Procedures

Number

Title

Revision

EPP 06-006

Protective Action Recommendations

9A

Condition Reports

119869

119870

119871

119872

119874

119877

119878

119879

119883

119885

119886

119887

119888

119889

119897

119901

119903

119904

119906

119911

119941

20017

20227

20323

Miscellaneous

Number

Title

Revision/Date

18-SA-01

Wolf Creek Generating Station - Emergency Planning Drill

February 27,

2018

APF 06-002-01

Emergency Action Levels

17A

CR-001

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

EOF-001

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

EOF-002

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

EOF-003

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

EOF-004

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

TSC-001

Wolf Creek Generating Station Emergency Notification

(Drill)

February 27,

2018

Section 4OA1: Performance Indicator Verification

Miscellaneous

Number

Title

Revision

NEI 99-02

Regulatory Assessment Performance Indicator Guideline

Section 4OA2: Identification and Resolution of Problems

Procedures

Number

Title

Revision

STS MT-005

Pressurizer Code Safety Valve Operability

Drawings

Number

Title

Revision

M-1H1531

Heating Ventilating and Air Cond. Auxiliary Building El.

2047-6 Area-3

Condition Reports

90975

110377

2960

118910

119330

Work Orders

17-428518-001

Miscellaneous

Number

Title

Date

Email from NWS

Technologies to

Wolf Creek

<EXTERNAL> RE: Wolf Creek PSV failure - Questions

from our NRC Resident Inspector

November

30, 2017

P.O. # 692145

SR

Valve Serial Number N60446-00-0001; Traveler 14-381

Testing

Completed

January 2015

PO # 779245

Valve Serial Number N60446-00-0001; Traveler 17-41

Testing

Completed

August 2017

NRC Letter to

Otto L. Maynard

Wolf Creek Generating Station - Issuance of Amendment

RE: Pressurizer Safety Valves (TAC NO. MA6969)

March 23,

2000

White Paper

Pressurizer Safety Valve NRC Follow-up Questions and

Answers

White Paper

Why PZR Safety Valve Failure is NOT a Part 21 Issue

Initial Request for Information

Integrated Inspection

Wolf Creek Nuclear Generating Station

Inspection Report: 05000482/2018001

Inspection Dates: January 1 - March 31, 2018

Inspection Procedure: Integrated Inspection Procedures

Lead Inspector: Douglas Dodson, Senior Resident Inspector

I.

Information Requested Prior to December 22, 2017

The following information should be provided in electronic format (Certrec IMS

preferred), to the attention of Douglas Dodson by December 22, 2017, to facilitate the

reduction in the items to be selected for a final list during inspection preparation. The

inspection team will finalize its sample selections and will provide an additional

information request with specific items. This information shall be made available by

December 22, 2017. The specific items selected from the lists shall be available and

ready for review on the day indicated in this request. *Please provide requested

documentation electronically in pdf files, Excel, or other searchable formats, if possible.

The information should contain descriptive names, and be indexed and hyperlinked to

facilitate ease of use. Information in lists should contain enough information to be

easily understood by someone who has knowledge of pressurized water reactor

technology. If requested documents are large and/or only hard copy formats are

available, please inform the inspector(s), and provide subject documentation.

1. Any pre-existing evaluation or list of component cooling water system components

and associated calculations with low design margins.

2. A list of high risk component cooling water system maintenance rule components

and functions based on engineering or expert panel judgment.

3. A list of component cooling water system related operating experience evaluations

for the last 3 years.

4. A list of all component cooling water system time-critical operator actions in

procedures.

5. A list of permanent and temporary modifications related to component cooling water

system sorted by component.

6. A list of current component cooling water system related operator work

arounds/burdens.

7. A list of the component cooling water system design calculations, which provide the

design margin information for components.

8. List of component cooling water system root cause evaluations associated with

component failures or design issues initiated/completed in the last 5 years.

9. A list of any component cooling water system common-cause failures of

components in the last 3 years.

10. An electronic copy of the component cooling water system design bases documents

and any open, pending, or recently completed changes. Although not an exhaustive

list, please include any open, pending, or recently completed (last 3 years) changes

to temporary modifications, permanent modifications, engineering change

packages, and/or procedure change packages. Specifically, please include any

open, pending, or recently completed changes to emergency operating, abnormal

operating, normal operating, alarm response, system alignment, surveillance, or

other procedure.

11. An electronic copy of the component cooling water system System Health notebook.

2. A copy of component cooling water system related audits completed in the last 2

years.

13. A list of component cooling water system motor operated valves (MOVs) in the

program, design margin and risk ranking.

14. A list of component cooling water system air operated valves (AOVs) in the valve

program, design margin and risk ranking.

15. Component cooling water system structure, system, and components maintenance

rule category, scoping, unavailability data, unreliability data, functional failure

evaluations, (a)(1) determinations, (a)(1) goals, and any supporting basis

documentation.

16. A list of component cooling water system licensee contacts for the inspection team

with pager or phone numbers.

17. An excel spreadsheet of component cooling water system related PRA human

action basic events or risk ranking of operator actions from your site specific PSA

sorted by RAW and FV. Provide copies of your human reliability worksheets for

these items.

18. In so far as there are recent or pending changes, please provide an Excel

spreadsheet of component cooling water system related equipment basic events

(with definitions) including importance measures sorted by risk achievement worth

(RAW) and Fussell-Vesely (FV) from your internal events probabilistic risk

assessment (PRA). Include basic events with RAW value of 1.3 or greater.

19. In so far as there are recent or pending changes, please provide a list of the top 50

cut-sets from your PRA.

20. In so far as there are recent or pending changes, please provide copies of PRA

system notebooks, and the latest PRA summary document.

21. In so far as there are recent or pending changes, and if you have an external events

or fire PSA model, provide the information requested in items 17-19 for external

events and fire, as it relates to the component cooling water system.

2. In so far as there are recent or pending changes, please provide a copy of the Wolf

Creek Nuclear Generating Station IPEEE changes, if available electronically.

ML18131A017

SUNSI Review:

ADAMS:

Non-Publicly Available

Non-Sensitive

Keyword:

By: NHT/rdr

Yes No

Publicly Available

Sensitive

NRC-002

OFFICE

SRI:DRP/B

RI:DRP/B

C:DRS/OB

C:DRS/PSB2

C:DRS/EB1

C:DRS/EB2

NAME

DDodson

FThomas

VGaddy

HGepford

TFarnholtz

JDrake

SIGNATURE

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

DATE

5/9/2018

5/10/18

5/3/18

5/3/18

5/3/2018

5/9/18

OFFICE

TL:DRS/IPAT

SRI/DRP/B

BC:DRP/B

NAME

GGeorge

DBradley

NTaylor

SIGNATURE

/RA -

HFreeman for/

/RA/

/RA/

DATE

5/10/18

5/7/18

5/14/18

Retrieved from "https://kanterella.com/w/index.php?title=IR_05000482/2018001&oldid=4994485"