IR 05000482/2005008

IR 05000482-05-008 on 10/24/2005 - 12/29/2005 for Wolf Creek Nuclear Operating Corporation; Wolf Creek Generating Station; Fire Protection (Triennial)

ML060330616
Person / Time
Site:	Wolf Creek
Issue date:	02/01/2006
From:	Smith L J Division of Reactor Safety IV
To:	Muench R A Wolf Creek
References
IR-05-008
Download: ML060330616 (32)

Text

February 1, 2006

Rick A. Muench, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation

P.O. Box 411 Burlington, KS 66839 Wolf Creek Nuclear Operating Corporation

SUBJECT: WOLF CREEK GENERATING STATION - INSPECTION REPORT 05000482/2005008

Dear Mr. Muench:

On December 29, 2005, the Nuclear Regulatory Commission (NRC) completed an inspection atthe Wolf Creek Generating Station. The enclosed report documents the inspection findings,which were discussed in a debrief meeting at the end of the onsite inspection on December 2, 2005, with you and other members of your staff and again in an exit meeting conducted via conference call on December 29, 2005.During this triennial fire protection inspection, the inspection team examined activitiesconducted under your license related to safety and compliance with the Commission's rules and regulations and the conditions of your license. The inspection consisted of selected examination of procedures and records, observations of activities and installed plant systems,and interviews with personnel.During the inspection, two apparent violations related to compliance with the requirements ofthe approved Fire Protection Program were identified. These findings involved analysis and procedure inadequacies related to fire damage induced spurious actuations of components.

These circuit vulnerabilities, could, under certain postulated fire scenarios, adversely affect theability to achieve and maintain safe shutdown of the facility. It is the NRC's understanding thatyou do not consider these vulnerabilities to be violations of NRC requirements. In order to allowthe industry to develop an acceptable approach to resolving this issue, that the NRC canendorse, the NRC will defer any enforcement action relative to these matters while the staffevaluates NEI's proposed resolution methodology for circuit vulnerabilities and you have time toimplement the resolution methodology, once approved, provided you take adequate compensatory measures for the identified vulnerabilities.Based on the results of this inspection, the NRC has also identified two findings that wereevaluated under the risk significance determination process as having very low safety significance (Green). The NRC has determined that these findings involve violations of NRCrequirements. These violations are being treated as noncited violations, consistent with Section VI.A of the Enforcement Policy. These noncited violations are described in the subject inspection report. If you contest the violations or their significance, you should provide a Wolf Creek Nuclear Operating Corporation-2-response within 30 days of the date of this inspection report, with the basis for your denial, tothe U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011; the Director, Office ofEnforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Wolf Creek facility.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response will be made available electronically for public inspection in theNRC Public Document Room or from the Publicly Available Records (PARS) com ponent ofNRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,//RA//

Linda Joy Smith, ChiefEngineering Branch 2 Division of Reactor SafetyDocket: 50-482License: NPF-42

Enclosure:

NRC Inspection Report 05000482/2005008

w/attachment:

Supplemental Informationcc w/enclosure:Vice President Operations/Plant Manager Wolf Creek Nuclear Operating Corp.

P.O. Box 411 Burlington, KS 66839Jay Silberg, Esq.Shaw Pittman, LLP 2300 N Street, NW Washington, DC 20037Supervisor LicensingWolf Creek Nuclear Operating Corp.

P.O. Box 411 Burlington, KS 66839 Wolf Creek Nuclear Operating Corporation-3-Chief EngineerUtilities Division Kansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027Office of the GovernorState of Kansas Topeka, KS 66612Attorney General120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597County ClerkCoffey County Courthouse 110 South 6th Street Burlington, KS 66839-1798Vick L. Cooper, Chief, Air Operating Permit and Compliance Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310Topeka, KS 66612-1366 Wolf Creek Nuclear Operating Corporation-4-Electronic distribution by RIV:Regional Administrator (BSM1)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (SDC)Resident Inspector (TBR2)SRI, Callaway (MSP)Branch Chief, DRP/B (WBJ)Senior Project Engineer, DRP/B (RAK1)Team Leader, DRP/TSS (RLN1)RITS Coordinator (KEG)DRS STA (DAP)J. Dixon-Herrity, OEDO RIV Coordinator (JLD)ROPreports WC Site Secretary (SLA2)SUNSI Review Completed: __Yes_ADAMS: Yes G No Initials: __LJS___ Publicly Available G Non-Publicly Available G Sensitive Non-SensitiveR:REACTORS\WC\2005\WC 2005-008RP-JMM.wpd RIV:DRS/EB2RIV:DRS/EB2RIV:DRS/EB2RIV:DRS/EB2JMMateychickDLLivermoreRMullikinBTindell/RA//RA//RA//RA/1/12 /061/12/061/12 /061/18/06RIV:DRS/EB2C:DRP/BC:DRS/PEBDHOverlandWBJonesLJSmith/RA//RA//RA/1/12/061/18/062/1/06OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax EnclosureU.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket:50-482 License:NPF-42 Report:05000482/2005008 Licensee:Wolf Creek Nuclear Operating Corporation Wolf Creek Generating StationLocation:1550 Oxen Lane NEBurlington, KansasDates:October 24 through December 29, 2005 Team LeaderJ. M. Mateychick, Senior Reactor Inspector, Engineering Branch 2 Inspectors:D. L. Livermore, Reactor Inspector, Engineering Branch 2D. H. Overland, Reactor Inspector, Engineering Branch 2 B. Tindell, Reactor Inspector, Engineering Branch 2AccompanyingPersonnel:R. Mullikin, ConsultantApproved By:Linda Joy Smith, ChiefEngineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 500482/2005008; 10/24/05 - 12/29/05; Wolf Creek Nuclear Operating Corporation; WolfCreek Generating Station; Fire Protection (Triennial)The NRC conducted an inspection with a team of four regional inspectors and one contractor. The inspection identified two apparent violations, two Green noncited violations (NCV) and two unresolved items (URI). The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using MC 0609 "Significance Determination Process" (SDP). Findings for which the significance determination process does not apply may be Green or may be assigned a severity level after NRC management review. The NRC describes its program for overseeingthe safe operation of commercial nuclear power reactors in NUREG-1649, "Reactor OversightProcess", Revision 3, dated July 2000.A.

Cornerstone: Mitigating Systems

Green.

The team identified a noncited violation (NCV) for failure to comply withTechnical Specification 5.4, "Procedures", in that a procedure required for post-fire safe shutdown was found to be inadequate. Procedure OFN RP-014, "Hot Standby to Cold Shutdown from Outside the Control Room", was inadequate because it did not provide a method to provide sufficiently borated water to the reactor coolant system so that coldshutdown could be achieved and maintained within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after a control room fire.

Procedure OFN RP-014 requires monitoring of the boron concentration in the reactor and, if necessary, starting the acid transfer pumps to draw borated water from the boric acid tanks. However, this procedure did not include sufficient instructions for refillingand borating the Refueling Water Storage Tank for a potential loss of offsite power or fire induced damage to circuits related to the pumps.This finding is greater than minor because it impacted the mitigati ng systemscornerstone objective to ensure the availability, reliability, and capability of systems thatrespond to external events (such as fire) to prevent undesirable consequences (i.e.,

core damage). The inspectors evaluated the finding using MC 0609, Appendix F, and determined that it screens as very low safety significance (Green) because it is related to the ability to achieve and maintain cold shutdown. (Section 1R05.1.b.(1))TBD. The team identified an Apparent Violation of Wolf Creek LicenseCondition 2.C.(5)(a) concerning an inadequate alternative shutdown analysis. The licensee's alternative shutdown analysis was inadequate in that it used an acceptancecriteria which was inconsistent with and less conservative than that required by the approved Fire Protection Program. The licensee developed Calculation Number AN-02-021, Revision 0, "OFN RP-017, 'Control Room Evacuation,'

Consequence Evaluation", to demonstrate alternative shutdown capability for WolfCreek in response to NRC-identified Noncited Violation 2002008-01, Inadequatealternative shutdown procedure. The calculation predicted that during an alternativeshutdown, the reactor coolant system subcooling margin would not be maintained,significant voiding would occur in the core, and a steam void would form in the reactor-2-Enclosurevessel head. The licensee found the results of the calculation to be acceptable since itdemonstrated that the void formation would be limited, natural circulation in the reactorcoolant system would be maintained, sufficient decay heat removal would bemaintained, and no fuel damage would occur. This is not consistent with the license condition to meet the technical requirements of 10 CFR Part 50, Appendix R.

Section III.L of 10 CFR Part 50, Appendix R, "Alternative and dedicated shutdowncapability", that states in part, "During the postfire shutdown, the reactor processvariables shall be maintained within those predicted for a loss of normal a.c. power."This finding is greater than minor because it impacted the mitigati ng systemscornerstone objective to ensure the availability, reliability, and capability of systems thatrespond to external events (such as fire) to prevent undesirable consequences (i.e.,

core damage). It is the NRC's understanding that the licensee does not consider thesecircuit vulnerabilities to be violations of NRC requirements. The licensee considers thespurious operation of multiple components to be outside of the plant licensing basis for the Fire Protection Program. Specifically, in this case, both pressurizer power-operated relief valves are assumed to spuriously open because of fire induced circuit damage.

The NRC staff and the industry are currently working on developing a resolutionmethodology to address these types of potential fire induced circuit failures. The team concluded that this violation meets the criteria of the NRC Enforcement M anualSection 8.1.7.1 for deferring enforcement actions for postulated fire induced circuit failures. (Section 1R05.1.b.(2))Green. The team identified a noncited violation of License Condition 2.C.(5), FireProtection (Section 9.5.1, SER; Section 9.5.1.8, SSER #5), for failure to ensure thatredundant trains of safe shutdown systems in the same fire area were free of firedamage. The licensee credited manual actions to mitigate the effects of fire damage in lieu of providing the physical protection required by 10 CFR Part 50, Appendix R,

Section III.G.2.SNUPPS FSAR Appendix 9.5E provided the design comparison between the plant's fireprotection program and 10 CFR Part 50, Appendix R. The comparison to Section III.G,Fire Protection of Safe Shutdown Capability, states, "Redundant trains of systemsrequired to achieve and maintain hot standby are separated by 3-hour-rated firebarriers, or the equivalent provided by III.G.2, or else a diverse means of providing thesafe shutdown capability exists that is unaffected by the fire." Wolf Creek hasinterpreted "diverse means" as by any reasonable means including local valve andbreaker operations as long as they are within the scope of normal operator duties. The team disagrees with this interpretation. The NRC staff does not recognize the use ofmanual actions as meeting the technical requirements of Appendix R,Section III.G.2. The components being operated are identified as required for operation of safe shutdown systems or are subject to potential spurious operation impacting theshutdown. The local manual actions are being performed because of fire damage to electrical cables related to those components and are meant to compensate for damage or maloperation of safe shutdown equipment caused by fire.

-3-EnclosureThis finding is greater than minor because it impacted the mitigati ng systemscornerstone objective to ensure the availability, reliability, and capability of systems thatrespond to external events (such as fire) to prevent undesirable consequences (i.e.,

core damage). The team found that the manual operator actions implemented to mitigate the effects of fire damage were reasonable (as defined in of NRC Inspection Procedure 71111.05T, "Fire Protection (Triennial)"), and could be performedwithin the analyzed time limits. Therefore, in accordance with of NRC Inspection Procedure 71111.05T, the finding was determined to be of very lowsafety significance (Green), and the significance determination process was not entered. (Section 1R05.2) TBD. The team identified an Apparent Violation of Technical Specification 5.4,Procedures, due to an inadequate alternative shutdown procedure that is required for implementation of the Fire Protection Program. The team found that some time critical actions required to safely shutdown the plant following a control room fire could not be accomplished within the required time periods. Specifically, the team found that the recommendations by Westinghouse Owners Group for assuring reactor coolant pump seal reliability and avoiding component cooling water thermal barrier waterhammer concerns would not be met if the operators had to respond to multiple spurious operations. The procedure was developed and verified based on a time line assuming operators only have to respond to one spurious operation from the fire induced damage during the scenario. The team disagrees with this limitation of potential spurious operations.This finding is greater than minor because it impacted the mitigati ng systemscornerstone objective to ensure the availability, reliability, and capability of systems thatrespond to external events (such as fire) to prevent undesirable consequences (i.e.,

core damage). It is the NRC's understanding that the licensee does not consider thesecircuit vulnerabilities to be violations of NRC requirements. The licensee considers thespurious operation of multiple components to be outside of the plant licensing basis for the Fire Protection Program. The NRC staff and the industry are currently working ondeveloping a resolution methodology to address these types of potential fire induced circuit failures. The team concluded that this violation meets the criteria of the NRCEnforcement Manual Section 8.1.7.1 for deferring enforcement actions for postulated fire induced circuit failures. (Section 1R05.6.b.(2))

B.Licensee-Identified Violations

None Enclosure

REPORT DETAILS

1REACTOR SAFETY1R05Fire ProtectionThe purpose of this inspection was to review the Wolf Creek Generating Station's fireprotection program for selected risk-significant fire areas. Emphasis was placed on verification of the post-fire safe shutdown capability. The inspection was performed inaccordance with the NRC regulatory oversight process using a risk-informed approachfor selecting the fire areas and attributes to be inspected. The team used the Individual Plant Examination for External Events for the Wolf Creek Generating Stationto choose risk-significant areas for detailed inspection and review. Inspection Procedure 71111.05T, "Fire Protection (Triennial)," requires selecting three to five fire areas for review. The four areas reviewed during this inspection were:Fire Area A-8:Auxiliary Building - 2000' Elevation, General AreaFire Area A-18:Auxiliary Building - 2026' Elevation, Electrical Penetration Room(North)Fire Area A-27:Auxiliary Building - 2026' Elevation, Reactor Trip SwitchgearRoomFire Area C-9:Control Building Elevation - 2000', ESF Switchgear Room (North)

For each of these fire areas, the inspection focused on fire protection features, systemsand equipment necessary to achieve and maintain safe shutdown conditions, and licensing basis commitments. Documents reviewed by the team are listed in the attachment..1Shutdown From Outside Main Control Room

a. Inspection Scope

The team reviewed the functional requirements identified by the licensee as necessaryfor achieving and maintaining hot shutdown conditions to ensure that at least one post-fire safe shutdown success path was available in the event of fire in each of the selected areas and alternative shutdown for the case of control room evacuation. The team reviewed piping and instrumentation diagrams of systems credited inaccomplishing safe shutdown functions to independently verify whether the shutdown methodology had properly identified the required components. The team focused on the following functions that must be available to achieve and maintain safe shutdown conditions:Reactivity control capable of achieving and maintaining cold shutdown reactivityconditions; Reactor coolant makeup capable of maintaining the reactor coolant inventory;Reactor heat removal capable of achieving and maintaining decay heat removal; Supporting systems capable of providing other services necessary to permit extendedoperation of equipment necessary to achieve and maintain hot shutdown conditions; andVerification that a safe shutdown can be achieved and maintained with and withoutoff-site power.A review was also conducted to ensure that all required components in the selectedsystems were included in the safe shutdown analysis. The team identified t he systemsrequired for each of the primary safety functions necessary to achieve and maintain shutdown conditions. These systems were then evaluated to identify the systems thatinterfaced with the selected fire areas and were the most risk significant systemsrequired for reaching hot shutdown conditions.

b. Findings

(1) Failure to Provide Adequate Post-Fire Shutdown Procedures

Introduction.

The team identified a Green noncited violation (NCV) for failure to complywith Technical Specification 5.4, Procedures. Procedure OFN RP-014, "Hot Standby to Cold Shutdown from Outside the Control Room," was inadequate because it did not provide a method to provide sufficiently borated water to the reactor coolant system sothat cold shutdown could be achieved and maintained within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after a control room fire.

Description.

Wolf Creek utilizes Procedure OFN RP-014, "Hot Standby to ColdShutdown from Outside the Control Room", to satisfy the fire protection program requirement to achieve and maintain cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after a control room fire. Following the fire, borated water must be injected into the reactor coolant system to make up for reactor coolant pump seal leakage, control reactor cool ant system inventoryduring the cooldown and maintain cold shutdown reactivity conditions.Procedure OFN RP-017, "Control Room Evacuation", provides instructions forperforming an alternative shutdown from outside of the control room to establish stablehot shutdown conditions. Procedure OFN RP-017 includes steps to mitigate potential spurious actuations that could divert required inventory of borated water from the Reactor Water Storage Tank. For example, operation of the containment spray systemwould divert water to the containment until the spuriously operating pump was secured.The team identified that in this case the Reactor Water Storage Tank would not containenough borated water to maintain reactivity less than 0.99 for the required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> assuming that the containment spray system spuriously operates along with theassumed loss of offsite power during a control room fire. Procedure OFN RP-014 requires monitoring of the boron concentration in the reactor and, if necessary, starting the boric acid transfer pumps to draw borated water from the boric acid tanks. However,this procedure did not include any instructions under the "Response Not Obtained" column should the operation not be accomplished because of a loss of offsite power or fire induced damage to circuits related to the pumps.Analysis. The inspectors referred to the guidance of MC 0612 and determined that thefinding is greater than minor in that it affected the ability to makeup borated water to thereactor coolant system following a control room fire and a spurious operation of thecontainment spray system. This finding is associated with the Mitigating Systems cornerstone and the respective attribute of procedure quality. This finding impacted the mitigating systems cornerstone objective to ensure the availability, reliability, andcapability of systems that respond to external events (such as fire) to preventundesirable consequences. The inspectors evaluated the finding using MC 0609, Appendix F, and determined that it screens as very low safety significance (Green)because it is related to the ability to achieve and maintain cold shutdown. The licenseedocumented the team's concern in PIR 2005-3033. The licensee has revised Procedure OFN RP-014 to include steps to use the diesel driven fire pump to refill theReactor Water Storage Tank as needed and detailed instructions how to isolate boric transfer pump circuits from the control room and restore operability. The licensee hasalso pre-staged the required electrical jumpers and fuses.Enforcement. Wolf Creek Technical Specifications, Section 5.4.1 states, in part,"Written Procedures shall be established, implemented, and maintained covering the following activities:.... d. Fire Protection Program implementation." LicenseCondition 2.C.(5)(a) states, "The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek siteaddendum through Revision 15, and as approved in the SER through Supplement 5, subject to provisions b & c below." Safety Evaluation Report, Section 9.5.1.7, "Appendix R Statement," states, "The staff will condition the operating license to requirethe applicant to meet the technical requirements of Appendix R to 10 CFR Part 50, or provide equivalent protection." Section III.L.3 of Appendix R states, "The shutdowncapability for specific fire areas may be unique for each such area, or it may be oneunique combination of systems for all such areas. In either case, the alternativeshutdown capability shall be independent of the specific fire area(s) and shallaccommodate postfire conditions where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Procedures shall be in effect to implement this capability."Contrary to the above, Procedure OFN RP-014 did not contain adequate instructions toassure an adequate supply of borated water. Because this finding is of very low safety significance and the licensee has already completed corrective actions, this violation is being treated as a noncited violation, consistent with Section VI.A of the NRCEnforcement Policy: NCV 05000482/2005008-01, Failure to Provide Adequate Post-Fire Shutdown Procedures.

(2) Failure to Maintain Reactor Coolant System Subcooling During the Alternative ShutdownIntroduction. The team identified an Apparent Violation of License Condition 2.C.(5)(a)concerning an inadequate alternative shutdown analysis. The alternative shutdown analysis was inadequate in that it used acceptance criteria which was inconsistent with and less conservative than that required by the approved Fire Protection Program.Description. The licensee developed Calculation Number AN-02-021, Revision 0,"OFN RP-017, 'Control Room Evacuation,' Consequence Evaluation," to demonstratealternative shutdown capability for Wolf Creek in response to NRC-identified NoncitedViolation 2002008-01, Inadequate alternative shutdown procedure. The original basisfor the time critical actions in Procedure OFN RP-017 was the phased procedural approach outlined in Licensee Letter SLNRC 84-0109, dated August 23, 1984. Thisalternative shutdown methodology was found acceptable by the NRC as documented inSupplemental Safety Evaluation Report 5. No detailed thermal-hydraulic analysis of the plant response during the alternative shutdown had been performed at that time. Indeveloping Calculation Number AN-02-021, the licensee used no fuel damage as an acceptance criteria. The calculation predicted that during an alternative shutdown, thereactor coolant system subcooling margin would not be maintained, significant voidingwould occur in the core, and a steam void would form in the reactor vessel head. The licensee found the results of the calculation to be acceptable since it demonstrated thatthe void formation would be limited, natural circulation in the reactor coolant system would be maintained, sufficient decay heat removal would be maintained, and no fuel damage would occur.The team's review of the approved Fire Protection Program noted that the plant mustmeet the technical requirements of 10 CFR Part 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979." Section III.Lof 10 CFR Part 50 Appendix R, "Alternative and dedicated shutdown capability," statesin part, "During the postfire shutdown, the reactor process variables shall be maintained within those predicted for a loss of normal a.c. power." The predicted plant response documented in Wolf Creek UFSAR, Chapter 15, Section 15.2.6, "Loss of non-emergency AC power to the station auxiliaries (blackout)," maintains reactor coolantsystem subcooling margin and no void formation in the reactor vessel head occurs. Therefore, the team considered the acceptance criteria used in Calculation NumberAN-02-021 to not be in compliance with the approved Fire Protection Program.Analysis. The inspectors referred to the guidance of MC 0612 and determined that thefinding is greater than minor in that it affected the ability to achieve and maintain hotshutdown following a control room fire. This finding is associated with the Mitigating Systems cornerstone and the respective attribute of protection against external factors (e.g., fire). This finding impacted the mitigating systems cornerstone objective to ensurethe availability, reliability, and capability of systems that respond to external events (suchas fire) to prevent undesirable consequences.During the inspection, the licensee contended that the evaluation was overlyconservative in that it assumed multiple fire induced spurious operations, while their licensing basis only required one worst case spurious operation for the design ofalternative shutdown capability. Calculation Number AN-02-021 assumed the spuriousoperation of both pressurizer power-operated relief valves. However, the licensee initiated compensatory measures consisting of stationing additional fire watch personnel in the control room to increase surveillance for potential fire hazards and fires in the incipient stage. The team did not enter the Significance Determination Process at thistime because the enforcement is being deferred as discussed below and the licensee has established adequate compensatory measures. Therefore, the significance will bedetermined after the NRC endorses a path to resolution for fire induced circuit failures.Enforcement. License Condition 2.C.(5)(a) states, "The Operating Corporation shallmaintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the WolfCreek site addendum through Revision 15, and as approved in the SER through Supplement 5, subject to provisions b & c below." The Safety Evaluation Report, Section 9.5.1.7, "Appendix R Statement," states, "The staff will condition the operatinglicense to require the applicant to meet the technical requirements fo Appendix R to 10 CFR 50, or provide equivalent protection." Wolf Creek SER, Supplement 3 states, "Based on our review, the staff concludes that the alternative shutdown capability for thecontrol room meets the requirements of Appendix R,Section III.L, and is thereforeacceptable." Title 10 CFR Part 50, Appendix R, Section III.L. 1 specifies, in part, thatduring alternative post-fire shutdown, "the reactor coolant system process variables shall be maintained within those predicted for a loss of normal a.c. power."Contrary to the above, the alternative shutdown methodology in Procedure OFN RP-017as evaluated in Calculation Number AN-02-021 fails to maintain reactor coolant process variables (e.g., pressure, temperature, and subcooling margin) within those predicted for a normal loss of AC power. It is the NRC's understanding that the licensee does notconsider these vulnerabilities to be violations of NRC requirements. The licenseeconsiders the spurious operation of multiple components to be outside of the plant licensing basis for the Fire Protection Program. Specifically, in this case, both pressurizer power-operated relief valves are assumed to spuriously open because of fire induced circuit damage. The NRC staff and the industry are currently working ondeveloping a resolution methodology to address these types of potential fire circuit failures. The team's review concluded that this violation meets the criteria of the NRCEnforcement Manual Section 8.1.7.1 for deferring enforcement actions for postulated fire induced circuit failures. This violation is being treated as an apparent violation:

AV 05000482/2005008-02, Failure to Maintain Reactor Coolant System Subcooling During the Alternative Shutdown.

.2 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the piping and instrumentation diagrams, safe shutdown equipmentlist, safe shutdown design basis documents, and the post-fire safe shutdown analysis to verify whether the shutdown methodology had properly identified the components andsystems necessary to achieve and maintain safe shutdown conditions for equipment inthe fire areas selected for review. The team also reviewed and observed walkdowns of the procedures for achieving and maintaining safe shutdown in the event of a fire to verify that the safe shutdown analysis provisions were properly implemented. The teamfocused on the following functions that must be ensured to achieve and maintain post-fire safe shutdown conditions:

(1) reactivity control capable of achieving and maintaining cold shutdown reactivity conditions,

(2) reactor coolant makeup capable of maintaining the reactor coolant level within the level indication in the pressurizer,

(3) reactor heat removal capable of achieving and maintaining decay heat removal,

(4) supporting systems capable of providing all other services necessary to permitextended operation of equipment necessary to achieving and maintaining hot shutdown conditions, and

(5) process monitoring capable of providing direct readings to perform and control the above functions.The team reviewed the separation of safe shutdown cables, equipment, andcomponents within the same fire areas, and reviewed the methodology for meeting the requirements of 10 CFR 50.48, Appendix A to Branch Technical Position 9.5-1 and 10 CFR Part 50, Appendix R, Section III.G. Specifically, this was to determine whetherat least one post-fire safe shutdown success path was free of fire damage in the event of a fire in the selected areas. The evaluation focused on the cabling of selected components for the chemical and volume control system, high pressure safety injectionsystem, and the auxiliary feedwater system. A sample of components was selectedwhose inadvertent operation could significantly affect the shutdown capability credited inthe safe shutdown analysis. The specific components selected are listed in the attachment. In addition, the team reviewed license documentation, such as NRC safetyevaluation reports, the Wolf Creek Updated Final Safety Analysis Report, submittals made to the NRC by the licensee in support of the NRC's review of their fire protectionprogram, and deviations from NRC regulations to verify that the licensee met licensecommitments.

b. Findings

Introduction.

The team identified a noncited violation of License Condition 2.C.(5), FireProtection (Section 9.5.1, SER; Section 9.5.1.8, SSER #5), for failure to ensure thatredundant trains of safe shutdown systems in the same fire area were free of firedamage. The licensee credited manual actions to mitigate the effects of fire damage in lieu of providing the physical protection required by 10 CFR Part 50, Appendix R, Section III.G.2. The team determined that the violation was of very low safety significance (Green).

Description.

License Condition 2.C.(5)(a) states, "The Operating Corporation shallmaintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the WolfCreek site addendum through Revision 15, and as approved in the SER through Supplement 5, subject to provisions b & c below." SER Section 9.5.1.7, Appendix R Statement, states, "The staff will condition the operating license to require the applicantto meet the technical requirements fo Appendix R to 10 CFR 50, or provide equivalent protection." Section III.G.2 of 10 CFR Part 50, Appendix R, describes three acceptable methods for protecting at least one safe shutdown train when redundant trains are located in the same fire area. The Section III.G.2 requirements are based on the combination of physical barriers, spacial separation, fire detection and automatic suppression systems.SNUPPS FSAR Appendix 9.5E provided the design comparison between the plant's fireprotection program and 10 CFR Part 50, Appendix R. The comparison to Section III.G,Fire Protection of Safe Shutdown Capability, states, "Redundant trains of systemsrequired to achieve and maintain hot standby are separated by 3-hour-rated firebarriers, or the equivalent provided by III.G.2, or else a diverse means of providing thesafe shutdown capability exists that is unaffected by the fire." Wolf Creek hasinterpreted "diverse means" to mean by any reasonable means including local valve andbreaker operations as long as they are within the scope of normal operator duties. The team disagrees with this interpretation. The NRC staff does not recognize the use ofmanual actions as meeting the technical requirements of Appendix R. The components being operated are identified as required for operation of safe shutdown systems or aresubject to potential spurious operation impacting the shutdown. The local manual actions are being performed because of fire damage to electrical cables related to those components and are meant to compensate for damage or maloperation of safe shutdown equipment caused by fire. Manual actions are not a method of satisfying Appendix R,Section III.G.2 requirements. Plant specific manual actions may beacceptable based on detailed specific exemptions or deviations for each case identified.Analysis. This finding is of greater than minor safety significance because it impactedthe mitigating systems cornerstone objective to ensure the availability, reliability, andcapability of systems that respond to external events (such as fire) to preventundesirable consequences. The team reviewed Procedure OFN KC-016, "Fire Response," and stepped through the manual actions directed in the procedure with licensee operations personnel. The team found that the manual operator actions were reasonable (as defined in Enclosure 2 of Inspection Procedure 71111.05T), and could be performed within the analyzed time limits. Since the manual operator actions were considered reasonable, the significance determination process was not entered. Theteam determined that this finding is of very low safety significance (Green) in accordance with the guidance in Enclosure 2 to Inspection Procedure 71111.05T.Enforcement. The Fire Hazard Analysis states that it will comply with the technicalrequirements of Appendix R or utilize a diverse means to do so. Appendix R,Section III.G.2 to 10 CFR Part 50 requires that cables whose fire damage could prevent the operation or cause maloperation of safe shutdown functions be physically protected from fire damage. Contrary to this requirement, the licensee implemented amethodology that utilized manual operator actions as a diverse means to mitigate theeffects of fire damage in lieu of providing physical protection from fire damage. This is a violation of License Condition 2.C.(5)(a) for failing to meet the technical requirements of10 CFR Part 50, Appendix R, as required by SER Section 9.5.1.7. Because this finding is of very low safety significance, this violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy:

NCV 05000482/2005008-03, Failure to Ensure Redundant Safe Shutdown Systems Located In the Same Fire Area Are Free of Fire Damage..3Passive Fire Protection

a. Inspection Scope

For the selected fire areas, the team evaluated the adequacy of fire area barriers,penetration seals, fire doors, electrical raceway fire barriers and fire rated electrical cables. The team observed the material condition and configuration of the installed barriers, seals, doors, and cables. The team compared the as-installed configurations to the approved construction details and supporting fire tests. In addition, the team reviewed license documentation, such as NRC safety evaluation reports, and deviationsfrom NRC regulations and the National Fire Protection Association code to verify thatfire protection features met license commitments.

b. Findings

No findings of significance were identified.

.4 Active Fire Protection

a. Inspection Scope

For the selected fire areas, the team evaluated the adequacy of fire suppression anddetection systems. The team observed the material condition and configuration of theinstalled fire detection and suppression systems. The team reviewed design documentsand supporting calculations. In addition, the team reviewed license basis documentation, such as NRC safety evaluation reports, and deviations from NRCregulations and the National Fire Protection Association codes to verify that fire suppression and detection systems met license commitments.The team also observed an announced site fire brigade dr ill and the subsequent drillcritique using the guidance in Inspection Procedure 71111.05AQ. Team members observed the fire brigade simulate fire fighting activities in plant Fire Area T-4 (Lube Oil Storage Room). The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the dr ill debrief, and took appropriatecorrective actions. Specific attributes evaluated were:

(1) proper wearing of turnout gear and self-contained breathing apparatus;

(2) proper use and layout of fire hoses; (3)employment of appropriate fire fighting techniques;

(4) sufficient fire fighting equipment brought to the scene;

(5) effectiveness of fire brigade leader communications,command, and control;

(6) search for victims and propagation of the fire into other plant areas;

(7) smoke removal operations;

(8) utilization of pre-planned strategies;

(9) adherence to the pre-planned dr ill scenario; and

(10) drill objectives.

b. Findings

No findings of significance were identified.

.5 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

For the sample areas, the team verified that redundant trains of systems required for hotshutdown were not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems including the effects offlooding.

b. Findings

No findings of significance were identified.

.6 Alternative Shutdown Capabilitya.Inspection ScopeThe team reviewed the alternative shutdown methodology to determine if the licenseeproperly identified the components, systems, and instrumentation necessary to achieveand maintain safe shutdown conditions from the auxiliary shutdown panel andalternative shutdown locations.

The team focused on the adequacy of t he systemsselected for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring and support system functions. The team verified that hot and cold shutdownfrom outside the control room could be achieved and maintained with offsite power available or not available. The team verified that the transfer of control from the controlroom to the alternative locations was not affected by fire induced circuit faults by reviewing the provision of separate fuses for alternative shutdown control circuits.The team also reviewed the operational implementation of the alternative shutdownmethodology. Team members observed a walk-through of the control room evacuation procedures with that days watchstanders consisting of both licensed reactor and senior reactor operators. The team observed operators simulate performing the steps of Procedure OFN RP-017 that provided instructions for performing an alternative shutdown from the auxiliary shutdown panel and for manipulating equipment in theplant. The team verified that the minimum number of available operators, exclusive of those required for the fire brigade, could reasonably be expected to perform the procedural actions within the applicable plant shutdown time requirements and that equipment labeling was consistent with the procedure. Also, the team verified that procedures, tools, dosimetry, keys, lighting, and communications equipment wereavailable and adequate to support successfully performing the procedure as intended.

The team also reviewed records for operator training conducted on this procedure.

b. Findings

(1) Lack of Evaluations of Changes to The Approved Fire Protection ProgramIntroduction. The team identified an unresolved item related to unanalyzed changes toapproved Wolf Creek Generating Station fire protection program. Specifically, the teamidentified that the licensee had revised Procedure OFN RP-017 without documentationdemonstrating that the changes would not adversely affect the ability to achieve andmaintain safe shutdown in the event of a fire. This will be treated as an unresolved item pending further evaluation by the license. NRC inspection of the results of the license'sevaluations and determination of safety significance.Description. In Letter SLNRC 84-0109, the licensee made time commitments forspecific items required to achieve and maintain hot shutdown conditions from outside the control room that would be completed in six "phases." Phase A items would be completed in 5 minutes. Phase B items would be completed in 10 minutes. Phase C items would be completed in 20 minutes. Phase D items would be completed in 30 minutes. Phase E items would be completed in 60 minutes. Phase F items would be completed in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. These phased time commitments were approved by the NRC staffin SER Supplement 5.Future revisions to OFN RP-017 consolidated the approved number of phases from sixto four. Phases B and C were consolidated into a new Phase B with an item completion time of 20 minutes. Phases D and E were consolidated into a new Phase C with an item completion time of 60 minutes. Review of the procedure revisions identified changes that resulted in actions having allowable completion times longer that the approved time commitments per SLNRC 84-0109. The changes of concern allowed:a.An item with a 5 minute commitment per Letter SLNRC 84-0109 to become a10 minute action. The step to verify EDG running (Step C10) was initially a Phase A item, which per Letter SLNRC 84-0109, allowed 5 minutes forcompletion. Step C10 is now a Phase B item, which per the current revision of the procedure, allows 20 minutes for completion. The actual step was performed in 7 minutes and 25 seconds when the response not obtained column was invoked. b.Six items that were initially Phase B items, which per Letter SLNRC 84-0109,allowed 10 minutes for completion, are now allowed longer completion times.

Steps B10, C18, C21, and C22 are all currently Phase B items, which per the current revision of the procedure, allows 20 minutes for completion. Timed walkthroughs of the procedure confirmed that completion of these steps would require more than 10 minutes. Step B10 to isolate RHR Pump A was completedat time 10:45. Step C18 to ensure room cooling for EDG room was completed at time 11:18. Step C21 to ensure room cooling for ESW room was completed attime 12:24. Step C22 to isolate 'B' RHR pump was completed at time 12:40.

Steps C30 and D10 are currently Phase C items, which per the current revision of the procedure, allows 60 minutes for completion. Step C30 to ensure 'A' containment spray pump stopped was completed at time 18:46. Step D10 toensure room cooling for the electrical penetration room was completed at time 22:15.Analysis. This finding is unresolved pending the completion of further inspection andcompletion of a significance determination. The license must complete a records search for any documentation evaluating the changes to Procedure OFN RP-017 described above. The license must perform evaluations for changes where no previous evaluations can be identified. The NRC will review the results of the license's efforts. This finding is of greater than minor safety significance because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, andcapability of systems that respond to external events (such as fire) to preventundesirable consequences. Specifically, the license did not evaluate all changes to the approved fire protection program to assure that the changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.Enforcement. License Condition 2.C(5)(b) states, "The licensee may make changes tothe approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safeshutdown in the event of a fire." However, the team could not identify evaluationsshowing that changes to OFN RP-017 would not adversely affect the ability to achieveand maintain safe shutdown in the event of a fire. Pending completion of further inspection of the impact of these changes and a significance determination, this finding is identified as URI 05000482/2005008-04, Lack of Evaluations of Changes to The Approved Fire Protection Program.

(2) Inadequate Alternative Shutdown ProcedureIntroduction. The team identified an Apparent Violation of Technical Specification 5.4,Procedures, because of an inadequate alternative shutdown procedure which is required for implementation of the Fire Protection Program. The team found that sometime critical actions required to safely shutdown the plant following a control room fire could not be accomplished within the planned time periods.Description. Wolf Creek utilized Procedure OFN RP-017 to satisfy the fire protectionprogram requirement to be able to achieve and maintain hot standby in the case of a control room fire. During the procedure, the operators must respond to a loss of reactor coolant pump seal injection, and a loss of component cooling water thermal barrier cooling. The Westinghouse Owners Group released the "Assessment of RCP Operation DuringLoss of Seal Cooling" for members in February 2000. The assessment states that if reactor coolant pump seal injection is lost and then restored, it should be restored in a short period of time. If seal injection is restored after the seals have heated, there is apossibility that the seals will leak reactor coolant excessively. Also, the letter states a concern that when flow is stopped to the component cooling water thermal barrier in the reactor coolant pump, that voiding may occur in the component cooling water system,and if flow is re-established, then it could cause a water hammer leading to systemdamage.The licensee timed a practice run of the control room evacuation and concluded thatthey met the recommendations by Westinghouse for assuring reactor coolant pump seal reliability and avoiding component cooling water thermal barrier water hammerconcerns. However, the team found that the methodology assumed only one spuriousoperation from the fire during the scenario. This method minimized the number of spurious operations the operators had to respond to and correspondingly minimized the procedure completion time.The team performed an independent timed walkthrough of the control room evacuationprocedure during the inspection. The team asked the operators to mitigate almost all of the spurious operations that might be caused by the fire, including manually openingmotor operated valves and starting the emergency diesel generator. This lengthened the operator's response times significantly, such that the Westinghouse recommendations were no longer being met for the steps in the procedure addressing the reactor coolant pump seals and the thermal barrier.Analysis. The inspectors referred to MC 0612 and determined that the finding is greaterthan minor in that it affected the ability to achieve and maintain hot shutdown following acontrol room fire. This finding is associated with the Mitigating Systems cornerstone and the respective attribute of protection against external factors (e.g., fire). This finding impacted the mitigating systems cornerstone objective to ensure the availability,reliability, and capability of systems that respond to external events (such as fire) toprevent undesirable consequences.The licensee recognized that the assumption of multiple spurious actuations wouldaffect the validity of their previous timing results. However, the licensee's position is that their licensing basis only requires one spurious operation to be assumed during a control room fire. However, the licensee did initiate compensatory measures consisting of stationing additional fire watch personnel in the control room to increase surveillancefor potential fire hazards and fires in the incipient stage. The team did not enter theSignificance Determination Process at this time because the enforcement is being deferred as discussed below and the licensee has established adequate compensatory measures. Therefore, the significance will be determined after the NRC endorses apath to resolution for fire induced circuit failures.Enforcement. Technical Specification 5.4.1 states, in part, "Written Procedures shall beestablished, implemented, and maintained covering the following activities:.... d. Fire Protection Program implementation." License Condition 2.C.(5)(a) states "The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, and asapproved in the SER through Supplement 5, subject to provisions b & c below." Safety Evaluation Report, Section 9.5.1.7, "Appendix R Statement," states "The staff willcondition the operating license to require the applicant to meet the technical requirements fo Appendix R to 10 CFR Part 50, or provide equivalent protection."

Appendix R,Section III.L.7, states "The safe shutdown equipment and systems for eachfire area shall be known to be isolated from associated non-safety circuits in the fire area so that hot shorts, open circuits, or shorts to ground in the associated circuits willnot prevent operation of the safe shutdown equipment. The separation and barriersbetween trays and conduits containing associated circuits of one safe shutdown division and trays and conduits containing associated circuits or safe shutdown cables from the redundant division, or the isolation of these associated circuits from the safe shutdownequipment, shall be such that a postulated fire involving associated circuits will notprevent safe shutdown."Contrary to the above, the licensee could not perform some time critical actions requiredfor safe shutdown following a control room fire within the required time periods using Procedure OFN RP-017. The licensee considers the spurious operation of multiple components to be outside of the plant licensing basis for the Fire Protection Program.

The licensee's position is that the original procedure timing method with one spurious operation is valid and the team's assumption of multiple spurious operations is overly conservative and an increase in regulatory requirements. The NRC staff and theindustry are currently working on developing a resolution methodology to address these types of potential fire induced circuit failures. The team's review concluded that this violation met the criteria of the NRC Enforcement Manual Section 8.1.7.1 for deferringenforcement actions for postulated fire induced circuit failures. This violation is being treated as an apparent violation: AV 05000482/2005008-05, Inadequate AlternativeShutdown Procedure..7Circuit Analyses

a. Inspection Scope

The team reviewed the post-fire safe shutdown analysis to verify that the licensee hadidentified circuits that may impact safe shutdown. On a sample basis, the team verified those cables for equipment required to achieve and maintain hot shutdown conditions in the event of fire in selected fire zones had been properly identified. The evaluation focused on the cabling of selected components for the chemical and volume control system, high pressure safety injection system , and the auxiliary feedwater system. Included in this evaluation were a sample of components whose inadvertent operation could significantly affect the shutdown capability credited in the safe shutdown analysis. In addition, the team verified that these cables had either been adequately protectedfrom the potentially adverse effects of fire damage, mitigated with approved manual operator actions, or analyzed to show that fire induced faults (e.g., hot shorts, open circuits, and shorts to ground) would not prevent safe shutdown. In order to accomplish this, the team reviewed electrical schematics and cable routing data for power and control cables associated with each of the selected components.

In addition, the team verified, on a sample basis, that circuit breaker coordination andfuse protection have been analyzed, and are acceptable as means of protecting the power source of the designated redundant or alternative safe shutdown component. For the selected fire areas, the team also reviewed the location and installation ofdiagnostic instrumentation that was necessary for achieving and maintaining safe shutdown conditions to ensure that in the event of a fire, this instrumentation wouldremain functional.

b. Findings

No findings of significance were identified..8Communications

a. Inspection Scope

The team reviewed the adequacy of the communicati on system to support plantpersonnel in the performance of alternative safe shutdown functions and fire brigade duties. The team verified that phones were available for use and maintained in working order. The team reviewed that the electrical power supplies and cable routing for the

phone system would allow them to remain functional following a fire in the control roomfire area.

b. Findings

No findings of significance were identified..9Emergency Lighting

a. Inspection Scope

The team reviewed the emergency lighting system required to support plant personnelin the performance of alternative safe shutdown functions to verify it was adequate to support the performance of manual actions required to achieve and maintain hot shutdown conditions, and for illuminating access and egress routes to the areas wheremanual actions are required. The locations and positioning of emergency lights were observed during a walkthrough of the control room evacuation procedure.

b. Findings

No findings of significance were identified.

.10 Cold Shutdown Repairs

a. Inspection Scope

The team reviewed Procedure OFN RP-014 to determine whether repairs were requiredto achieve cold shutdown. The team also verified that the repair material was available on the site.

b. Findings

No findings of significance were identified..11Compensatory Measuresa.Inspection ScopeThe team reviewed the program with respect to compensatory measures in place forout-of-service, degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems or features.The team reviewed AP 10-103, "Fire Protection Impairment Control," Revision 19 todetermine whether the procedures adequately controlled compensatory measures forfire protection systems, equipment and features (e.g., detection and suppressionsystems and equipment, and passive fire barriers). The team also walked downcompensatory measures in effect at the time of the inspection.

b. Findings

No findings of significance were identified.4OA2Problem Identification and Resolution

a. Inspection Scope

The team reviewed a sample of Problem Identification Reports to verify that the licenseewas identifying fire protection-related issues at an appropriate threshold and entering those issues into the corrective action program. A listing of Problem Identification Reports reviewed is provided in the attachment to this report.

b. Findings

Introduction.

The team identified an unresolved item related to the evaluation ofconditions adverse to fire protection, which is a provision of the Wolf Creek Generating Station fire protection program. This will be treated as an unresolved item pendingfurther inspection of the extent of condition and determination of safety significance.

Description.

The NRC issued Information Notice 92-18, "Potential for Loss of RemoteShutdown Capability During a Control Room Fire," on February 28, 1992, to all holdersof operating licenses. This notice was issued to alert licensees to conditions found at several reactors that could result in the loss of capability to maintain the reactor in a safeshutdown condition because of a control room fire that caused operators to evacuatethe control room. A fire in the control room could cause hot short circuits between control wiring and power sources, for certain motor-operated valves needed for safe shutdown. If a fire in the control room forces operators to leave the control room, thesemotor-operated valves can be operated from the remote/alternative shutdown panel.

However, hot short circuits combined with the absence of thermal overload, torque switch and limit switch protection, could cause valve damage before the operator shifted control of the valves to the remote/alternative shutdown panel. The licensee evaluated Information Notice 92-18 via Industry Technical InformationProgram (ITIP)1906 on April 15, 1992, and determined that the notice was notapplicable to Wolf Creek. The disposition and closure of ITIP 1906 relied upon evaluations performed during initial licensing as discussed in documents from 1984 and 1985. The documents referenced in the ITIP are Letter SLNRC 84-0108,dated August 24 1985; Letter SLNRC 84-0109, dated August 10, 1984; and SafetyEvaluation Report, NUREG 0881, Supplement 5. Based upon the NRC's acceptance ofthe response plan to spurious actuations resulting from control room fires, as discussed in the referenced documents, the licensee deemed the information contained in Information Notice 92-18 as having previously been evaluated. The licensee subsequently reevaluated their position in regard to InformationNotice 92-18 in 1999 based upon questions raised by the NRC during an inspection atthe Callaway Plant. The licensee initiated Performance Improvement Request 99-1245 on April 4, 1999, to validate their position as described in ITIP 1906. The performance improvement request stated that engineering had compiled a list of motor-operated valves which are susceptible to inadvertent failure because of a control room fire, and could potentially jeopardize plant safe shutdown. It also stated that further evaluationand investigation was being done to narrow down the list of valves requiring modifications. Performance Improvement Request 99-1245 was closed based on an NRC/industry initiative in place at the time to address dealing with multiple hot shorts inassociated circuits resulting in spurious actuations. The NRC temporarily sus pendedthe associated circuit portion of the triennial fire protection inspection in November 2000, but restarted the inspections in January 2005. At the time of the inspection, the licensee had not determined which motor-operatedvalves could be susceptible to mechanistic damage because of having the torque and limit switches, and the thermal overloads bypassed because of fire induced short circuits. The inspectors reviewed a sample of valves and determined that they could have their protection bypassed. Four motor operated valves was selected from control room evacuation Procedure OFN RP-017 for review of Information Notice 92-18 applicability. The four valves, BN-LCV112E, EM-HV8803B, EM-HV8801A, andBN-HV8812A, were all found to be susceptible to having their torque and limit switch protection bypassed as a result of a control room fire. All four valves were also required by Procedure OFN RP-017 to be positioned after a control room fire. However, theinspectors could not determine whether damage could occur to the valves rendering them inoperable.

Analysis.

This finding is unresolved pending the completion of further inspection of theextent of condition and completion of a significance determination. The licensee must evaluate the motor operated valves relied upon during a post-fire shutdown outside of the control room. The licensee must review control circuits to identify any valves which could spuriously operate because of fire damage with the normal protective devices bypassed. The licensee must determine if any such valves would be susceptible to damage which would prevent the planned electrical or manual operation of the valve during the shutdown from outside of the control room. This finding is of greater thanminor safety significance because it impacted the mitigating systems cornerstoneobjective to ensure the availability, reliability, and capability of systems that res pond toexternal events (such as fire) to prevent undesirable consequences. Specifically, the licensee did not perform a timely or technically adequate evaluation to determine if the Wolf Creek configurations were subject to the potential loss of capability to maintain thereactor in a safe shutdown condition following a control room fire described in NRC Information Notice 92-18.Enforcement. License Condition 2.c(5) of the Wolf Creek Generating Station OperatingLicense states that the Operating Corporation shall maintain in effect all provisions ofthe approved fire protection program as described in the SNUPPS Final Safety Analysis Report. The Wolf Creek Generating Station Updated Safety Analysis Report, Appendix 9.5A, Section 8, states that failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material and nonconformances which affect fire protection are promptly identified, reported, evaluated and corrected. However, the team found that the licensee failed to evaluate the potential for fireinduced damage to motor operated valves relied upon for safe shutdown following a control room evacuation as described in NRC Information Notice 92-18. The licenseeentered this finding in their corrective action program as Performance Improvement Request 2005-3314. Pending completion of further inspection for extent of condition and a significance determination, this finding is identified as URI 05000482/2005008-06, Failure to Adequately Evaluate Fire Protection Program Deficiencies4OA6 Management MeetingsDebrief Meeting SummaryThe team leader presented the inspection results to Mr. Rick A. Muench, President andChief Executive Officer, and other members of licensee management at the conclusion of the onsite inspection on December 2, 2005. During this meeting, the team leader confirmed to the licensee management thatmaterials considered to be proprietary had been examined during the inspection and had been returned to the licensee.

Exit Meeting SummaryThe team leader presented the inspection results to members of licensee managementat the conclusion of the inspection in a conference call on December 29, 2005.

A-1KEY POINTS OF CONTACTLicenseeT. M. Anselmi, Manager Design EngineeringW. Aregood, Fire Protection R. Badenhamer, Operations T. Card, Supervisor Support Engineering D. Dixon, Design Engineering - Electrical R. D. Flannigan, Manager Nuclear Engineering K. Fredrickson, Regulatory Affairs S. Hedges, VP Operations & Plant Manager S. A. Henry, Superintend of Operations P. Herrmann, Fire Protection D. M. Hooper, Regulatory Affairs W. Ketchum, Probabilistic Risk AnalysisT. Krause, Manager Quality J. B. Makar, Manager Systems Engineering K. J. Moles, Manager Regulatory Affairs R. A. Muench, President & CEO W. Muilenburg, Regulatory Affairs G. L. Pendergrass, Manager Support D. Phelps, Owner Company Representative L. Ratzlaff, Fire Protection E. A. Ray, Manager Operations W. Selbe, Design Engineering M.W.Sunseri, VP Oversite J. Suter, Fire Protection W. Wagner, Safety Analysis NRCS. Cochrum, Senior Resident Inspector A-2ITEMS OPENED AND CLOSED Opened05000482/2005008-02AVFailure to Maintain Reactor Coolant SystemSubcooling During the Alternative Shutdown (Section 1R05.1.b(2))05000482/2005008-04URILack of Evaluations of Changes to The Approved FireProtection Program (Section 1R05.6.b(1))05000482/2005008-05AVInadequate Alternative Shutdown Procedure (Section 1R05.6.b(2))05000482/2005008-06URIFailure to Adequately Evaluate Fire ProtectionProgram Deficiencies (Section 4OA2)Opened and Closed05000482/2005008-01NCVFailure to Provide Adequate Post-Fire ShutdownProcedures (Section 1R05.1.b(1))05000482/2005008-03NCVFailure to Ensure Redundant Safe Shutdown SystemsLocated In the Same Fire Area Are Free of Fire Damage (Section 1R05.2)ClosedNoneDiscussedNone A-3LIST OF

DOCUMENTS REVIEWED

The following documents were selected and reviewed by the team to accomplish the objectivesand scope of the inspection. COMPONENTS SELECTED FOR REVIEWComponentDescriptionALHV0030ALHV0031

ALHV0032

ALHV0033

ALHV0034

ALHV0035

ALHV0036Auxiliary Feedwater Pump Suction Isolation ValvesDPAL01AAuxiliary Feedwater Pump ADPAL01BAuxiliary Feedwater Pump BBGLCV112BBGLCV112CVolume Control Tank Outlet ValvesBGHV8110Centrifugal Charging Pump A Mini-Flow Isolation ValveBGHV8111Centrifugal Charging Pump B Mini-Flow Isolation Valve

BNHV8812ABNHV8812BRefueling Water Storage Tank To Residual Heat Removal SuctionIsolation ValvesDPBG05ACentrifugal Charging Pump A

DPBG05BCentrifugal Charging Pump B

DPEF01AEssential Service Water Pump A

DPEF01BEssential Service Water Pump B

EFHV0023EFHV0024

EFHV0025

EFHV0026Service Water To Essential Service Water Loop Isolation ValvesEGHV0058EGHV0071

EGHV0126

EGHV0127Component Cooling Water To Reactor Coolant Pump Isolation ValvesEJHV8701AEJHV8701BResidual Heat Removal Suction Isolation Valves

AttachmentA-4EJH8811AEJHV8811BContainment Sump Isolation ValvesCALCULATIONSNumberTitleRevisionAN-02-021OFN RP-017 "Control Room Evacuation" ConsequenceEvaluation

0E-H-8System NB Protective Relays 5FL-03Flooding of Individual Aux Bldg Rooms 0

FL-08Control Building Flooding0

LE-M-004Flooding In Class 1E Switchgear Rooms 3301 & 3302and Battery Room # 2 (3411) & Battery Room # 3

(3413)00XX-E-013Post-Fire Safe Shutdown (PFSSD) Analysis0DRAWINGSNumberTitleRevisionE-1F9910Post-Fire Safe Shutdown Fire Area Analysis0E-1R1441(Q)Raceway Plan - Auxiliary Building Area-4EL. 2026'-0" 6E-1R1443AExposed Conduit - Auxiliary Building Area-4EL. 2026'-6" 7E-1R1443BExposed Conduit - Auxiliary Building Area-4EL. 2026'-0" 11E-1R1443CExposed Conduit - Auxiliary Building Area-4 EL. 2026'-0" 9E-1R1444AExposed Conduit - Auxiliary Building Partial PlanArea-4 EL. 2026'-0" 4E-1R1444BExposed Conduit - Auxiliary Building Partial PlanArea-4 EL. 2026'-0" 7E-1R1444CExposed Conduit - Auxiliary Building Partial PlanArea-4 EL. 2026'-0" 12E-11NG01Low Voltage System Class IE 480 V. Single LineMeter & Relay Diagram

NumberTitleRevisionAttachmentA-5E-11NG02Low Voltage System Class IE 480 V. Single LineMeter & Relay Diagram

8E-11NG20Motor Control Center Summary234E-11NK01Class IE 125V DC System Meter & Relay Diagram9

E-11NK02Class IE 125V DC System Meter & Relay Diagram7

E-13AB01Schematic Diagram - Main Steam Supply Valve ToTurbine Driven Aux Feedwater Pump

2E-13AB18Schematic Diagram - Main Steam High PressureTrap Bypass Valves

0E-13AL03ASchematic Diagram - Auxiliary Feedwater Pumps,Discharge Control - Motor Operated Valves

4E-13AL04BSchematic Diagram - Supply From ESS ServiceWater System

8E-13AL05ASchematic Diagram - Auxiliary Feedwater Pumps,Discharge Control - Air Operated Valves

2E-13BB04Schematic Diagram - Seal Water Injection IsolationValves 3E-13BB12ASchematic Diagram - RHR Loop 1 Inlet IsolationValve 6E-13BB12BSchematic Diagram - RHR Loop 2 Inlet IsolationValve 4E-13BB30Schematic Diagram - RCS Head Vent Valves 2E-13BB39Schematic Diagram - Pressurizer Relief IsolationValves 8E-13BB40Schematic Diagram - Pressurizer Power ReliefValves 3E-13BG01Schematic Diagram - Centrifugal Charging Pump A3E-13BG01ASchematic Diagram - Centrifugal Charging Pump B1

E-13BG10Schematic Diagram - Letdown Line Isolation Valves3

E-13BG12Schematic Diagram - Volume Control Tank OutletIsolation Valve

3E-13BG12ASchematic Diagram - Volume Control Tank OutletIsolation Valve

NumberTitleRevisionAttachmentA-6E-13BG48Schematic Diagram - Excess Letdown Line IsolationValves 1E-13BN01Schematic Diagram - Refueling Water Storage TankTo Charging Pump MOV

3E-13BN03Schematic Diagram - Refueling Water Storage TankTo RHR Pump MOV

7E-13EG09Schematic Diagram - Component Cooling WaterContainment Isolation Valve

4E-13EG18Schematic Diagram - Component Cooling WaterContainment Isolation Valves

7E-13EJ05ASchematic Diagram - RHR Loop 1 Inlet isolationValve 4E-13EJ06ASchematic Diagram - Sump To No. 1 Residual HeatRemoval Pump

6E-13EJ06BSchematic Diagram - Sump To No. 2Residual HeatRemoval Pump

7KD-7496One Line Diagram27M-12AB01P&ID - Main Steam System10

M-12AB02P&ID - Main Steam System9

M-12AB03P&ID - Main Steam System18

M-12AL01P&ID - Auxiliary Feedwater System10M-12BB01P&ID - Reactor Coolant System24

M-12BB02P&ID - Reactor Coolant System14

M-12BB03P&ID - Reactor Coolant System9

M-12BB04P&ID - Reactor Coolant System10

M-12BG01P&ID - Chemical and Volume Control System12

M-12BG03P&ID - Chemical & Volume Control System36

M-12BN01P&ID - Borated Refueling Water Storage System12

M-12EF01P&ID - Essential Service Water System19

M-12EF02P&ID - Essential Service Water System22

M-12EG01P&ID - Component Cooling Water System14

NumberTitleRevisionAttachmentA-7M-12EG02P&ID - Component Cooling Water System17M-12EG03P&ID - Component Cooling Water System8

M-12EJ01P&ID - Residual Heat Removal System31

M-K2EF01P&ID - Essential Service Water System48PERFORMANCE IMPROVEMENT REQUESTS (PIRs)99-12452001004620053025*20053176*20053314*20053331*200036992001021020053033*20053209*20053317*20053333*

200100452005275720053054*20053305*20053319**PIR written as a result of inspection activitiesPROCEDURESNumberTitleRevisionAP 10-100Fire Protection Program9AP 10-103Fire Protection Impairment Control19

AP 10-105Fire Protection Training and Drills9AP 21-003Operations7A

OFN KC-016Fire Response13

OFN KJ-032Local Emergency Diesel Startup6

OFN RP-013Control Room Not Habitable10A

OFN RP-014Hot standby to Cold Shutdown From Outside theControl Room

8OFN RP-017Control Room Evacuation21STN GP-009Emergency Radio and Equipment Check and Inventory41

STN FP-206Spray and Sprinkler System Functional Testing9

STN FP-207Visual Inspection of Pipe Headers and Nozzle/SprinklerAreas 2STN FP-400BHalon Sys/North Pene Rm (KC-244)5STN FP-452Fire Barrier Penetration Seals Inspection4

AttachmentA-8STN FP-817FTrip Act. Device Oper. Test for Bechtel Zones 306, 307and 314-317

6MISCELLANEOUS DOCUMENTSNumberTitleRevisionAP 10-106Fire Preplans4APF 10-105-02Fire Drill Scenario and Critique Report1E-1F9905Fire Hazards Analysis0

E-1F9910Post-Fire Safe Shutdown Area Analysis0

ITIP No. 01906Industry Technical Information Program Report -NRC Information Notice 92-18: Potential For Loss Of

Remote Shutdown Capability During A Control Room

Fire 4/15/92LER 42146Potential Failure to Meet Required Response TimesFor Shutdown Outside Control Room

11/16/05License No. NPF-42Facility Operating License, Wolf Creek GeneratingStation, Unit No. 1AmendmentNo. 151M-663-00017Penetration Seal Typical DetailsW20

M-663-00017AFire Protection Evaluations For Unique or UnboundedFire Barrier ConfigurationsW01Self AssessmentSEL 01-027NFPA Code Compliance0SLNRC 84-0109SNUPPS Letter to H. R. Denton From N. A. Petrick -Subject: Fire Protection Review

8/23/1984Specification No.16577-M-658Technical Specification For Contract For Furnishing,Installing, and Testing Halogenated Agent

Extinguishing System for The Standardized Nuclear

Unit Power Plant System (SNUPPS) Wolf Creek Only

7NUREG 0881, Volume 1Safety Evaluation Report Related to the Operation ofWolf Creek Generating Station Unit No. 1April 1982NUREG 0881,Supplement No. 3Safety Evaluation Report Related to the Operation ofWolf Creek Generating Station Unit No. 1August 1983NUREG 0881,Supplement No. 5Safety Evaluation Report Related to the Operation ofWolf Creek Generating Station Unit No. 1March 1985PIR 1998-0600NFPA Code Deficiency Tracking Sheet09/21-2005

AttachmentA-9USAR - 7.4Updated Safety Analysis Report - Section 7.4 -Systems Required For Safe Shutdown

16USAR - 9.5.1Updated Safety Analysis Report - Section 9.5.1 - FireProtection System

16USAR - 15.2.6Updated Safety Analysis Report - Section 15.2.6 -Loss of Non-Emergency AC Power to the Station

Auxiliaries (Blackout)

16WCNOC-76Design Guide for Medium and Low Voltage AC andLow Voltage DC Overcurrent Protection Coordination

for Wolf Creek Generating Station

2Cable Routing Data for Various Components and FireAreasWCGS Approved Fuse List7

Wolf Creek Fire Protection Program RegulatoryBases 1Time - Current Curves for Various 480Vac and125Vdc ComponentsMODIFICATIONSNumberTitleRevisionDCP 011038Install Fire Wrap on Raceway in Fire Areas A-1 & A-184WORK ORDERS04-258679-00004-258728-00004-263755-00005-270020-000