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NRC Integrated Inspection Report 05000482/2018001
	ML18131A017
Person / Time
Site:	Wolf Creek
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

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 05000482/2018 00 1

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 violatio n 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 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.

"

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/ Attachment s: 1. Supplemental Information 2. Request for Information

1 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

2

SUMMARY

The 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

-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

-0 1 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.

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

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

-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

Main article: IP 71111.01

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

Main article: IP 71111.04

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

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection

Main article: IP 71111.05AQ

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

Main article: IP 71111.06

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

Main article: IP 71111.07

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

.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification

Main article: IP 71111.11

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

Main article: IP 71111.12

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

===

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 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.

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 71111.13

(1) STS IC-926B, Component Cooling Water System Automatic Valve A c tuation 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

Main article: IP 71114.06

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

-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 Issue s (2 Sample s) 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

-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

-0 1 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 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

-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 functions-The 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 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.

The system remains functional but degraded.

9 The inspectors also noted that Section 3.1.9, "Boration Injection System

- 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.

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 describe s 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 determination's 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.

Correctiv e 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 Report s 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 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

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 n on-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETING S 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.

1

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 28 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 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

- 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 1R0

7: 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 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

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

Procedures

Number Title Revision OFN AF-025 Unit Limitations

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

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 3 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 24 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 0 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

M-12BG01 Piping & Instrumentation Diagram Chemical and Volume Control System

M-12BL01 Piping & Instrumentation Diagram Reactor Make

-Up Water System 15 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 15 M-12LF01 Piping & Instrumentation Diagram Auxiliary Building Floor and Equipment Drain System

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

W 12 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 5 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 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

- 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

0 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 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

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 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

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 90 SYS AE-320 Turbine Driven Main Feedwater Pump Shutdown

28A SYS AF-121 Heater Drain Pump Operation

Section 1R

2: 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

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 3 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 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

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-S A-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 5 Condition Reports

90975 110377 112960 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 N

O. 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 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.

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 PR

A.

20. In so far as there are recent or pending changesProperty "Contact" (as page type) with input value "A.20. In so far as there are recent or pending changes" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., 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 05000482/2018

1 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 violatio

n 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 CommissionProperty "Contact" (as page type) with input value "U.S.Nuclear Regulatory Commission" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., ATTN: Document Control Desk, Washington, DC 20555

-0001; with copies to the Regional Administrator, Region IV; and t

he NRC resident inspector at the

Wolf Creek Generating Station

.

A. Heflin 2 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/ Attachment

s: 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 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

-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

-0 1 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 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

-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

DProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 2515 AppendixD" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., "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

(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:

(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

o n 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 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.

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 A c tuation 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

.

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 Issue s (2 Sample s) 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

-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

-0 1 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 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

-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 functions-The

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

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.

The system remains functional but degraded.

The inspectors also noted that Section 3.1.9, "Boration

Injection System

- 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.

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 describe

s 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 determination's 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.

Correctiv e 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 Report

s 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

20287 , 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

n on-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETING S 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.