IR 05000482/2016001
| ML16116A413 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/25/2016 |
| From: | Nick Taylor NRC/RGN-IV/DRP/RPB-B |
| To: | Heflin A Wolf Creek |
| Taylor N | |
| References | |
| IR 2016001 | |
| Download: ML16116A413 (34) | |
Text
UNITED STATES ril 25, 2016
SUBJECT:
WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000482/2016001
Dear Mr. Heflin:
On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Wolf Creek Generating Station. On April 13, 2016, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violation or significance of this NCV, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; 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 Regional Administrator, Region IV; and the NRC resident inspector at the Wolf Creek Generating Station.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management 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/
Nicholas H. Taylor, Branch Chief Project Branch B Division of Reactor Projects Docket No. 50-0482 License No. NPF-42
Enclosure:
Inspection Report 05000482/2016001 w/ Attachment: Supplemental Information
REGION IV==
Docket: 05000482 License: NPF-42 Report: 05000482/2016001 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane NE Burlington, KS 66839 Dates: January 1 through March 31, 2016 Inspectors: D. Dodson, Senior Resident Inspector F. Thomas, Resident Inspector S. Alferink, Reactor Inspector V. Gaddy, Chief, Operations Branch Approved Nicholas H. Taylor By: Chief, Project Branch B Division of Reactor Projects-1- Enclosure 1
SUMMARY
IR 05000482/2016001; 01/01/2016 - 03/31/2016; Wolf Creek Generating Station; Problem
Identification and Resolution The inspection activities described in this report were performed between January 1 and March 31, 2016, by the resident inspectors at Wolf Creek Generating Station and inspectors from the NRCs Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red),
which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310,
Aspects within the Cross-Cutting Areas, issued December 4, 2014. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green non-cited violation of Technical Specification 5.4.1.a for the licensees failure to adequately develop and adjust preventive maintenance activities in accordance with Procedure AP 16B-003, Planning and Scheduling Preventive Maintenance, Revision 5. Specifically, the licensee did not adequately develop a preventive maintenance replacement task and schedule for control room air conditioning unit SGK04A refrigerant sensing lines and fittings. The licensees immediate actions included securing and declaring the SGK04A system inoperable, completing corrective maintenance to eliminate the refrigerant leak, and confirming that the impacted preventive maintenance frequency was adequately established. The licensee entered this condition into the corrective action program as Condition Reports 101862 and 101867.
This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors utilized Inspection Manual Chapter 0609, Appendix A, Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012. The inspectors determined this finding is not a deficiency affecting the design or qualification of a mitigating structures, systems, and components (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 it 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). The finding has a cross-cutting aspect in the area of human performance, resources, because leaders did not ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. Specifically, leaders did not ensure procedures and other resource materials were available to support successful work performance when setting preventive maintenance activity base dates, which resulted in the licensee failing to adequately develop and adjust preventive maintenance activities associated with control room air conditioning unit SGK04A refrigerant sensing lines and fittings [H.1]. (Section 4OA2)
PLANT STATUS
Wolf Creek Generating Station began the inspection period operating at full power. On February 26, 2016, operators reduced power to approximately 84 percent to support main turbine valve cycle testing. Later that day operators reduced power to approximately 70 percent to support 345 KV switchyard insulator repairs. Plant power was restored to full power later on February 26, 2016, and the plant operated at or near full power for the rest of the period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Summer Readiness for Offsite and Alternate-Alternating Current Power Systems
a. Inspection Scope
On February 26, 2016, the inspectors completed an inspection of the stations off-site and alternate-alternating current power systems. The inspectors inspected the material condition of these systems, including transformers and other switchyard equipment to verify that plant features and procedures were appropriate for operation and continued availability of off-site and alternate-alternating current power systems. The inspectors reviewed outstanding work orders and open condition reports for these systems. The inspectors walked down the switchyard to observe the material condition of equipment providing off-site power sources. The inspectors assessed corrective actions for identified degraded conditions and verified that the licensee had considered the degraded conditions in its risk evaluations and had established appropriate compensatory measures.
The inspectors verified that the licensees procedures included appropriate measures to monitor and maintain availability and reliability of the off-site and alternate-alternating current power systems.
These activities constituted one sample of summer readiness of off-site and alternate-alternating current power systems, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- January 11, 2016, train A emergency diesel generator
- January 28, 2016, train A spent fuel pool cooling
- February 8, 2016, station black out diesel generators
- February 25, 2016, train B essential service water The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.
These activities constituted four partial system walkdown samples as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
.2 Complete Walkdown
a. Inspection Scope
On March 29, 2016, the inspectors completed a complete system walkdown inspection of the train A motor driven auxiliary feedwater system. The inspectors reviewed the licensees procedures and system design information to determine the correct A motor driven auxiliary feedwater system lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.
These activities constituted one complete system walkdown sample, as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R05 Fire Protection
Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:
- February 8, 2016, fire area SBO, station blackout diesel generator enclosure, elevation 2000 feet
- February 9, 2016, fire area A-14, auxiliary feedwater pump room 1326, elevation 2000 feet
- February 25, 2016, fire area ESW-2, essential service water pump house B train
- March 29, 2016, fire area A-28, auxiliary shutdown panel room For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
On March 21 and 22, 2016, the inspectors completed an inspection of underground bunkers susceptible to flooding. The inspectors selected two underground vaults that contained risk-significant or multiple-train cables whose failure could disable risk-significant equipment:
- Train A essential service water system manhole MHE2A
- Train A essential service water system manhole MHE3A The inspectors observed the material condition of the cables and splices contained in the vaults and looked for evidence of cable degradation due to water intrusion. The inspectors verified that the cables and vaults met design requirements.
These activities constituted completion of one flood protection measures sample, which consisted of two bunker/manhole inspections, as defined in Inspection Procedure 71111.06.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On February 29, 2016, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the requalification activities.
These activities constituted completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
a. Inspection Scope
The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened risk. The inspectors observed the operators performance of the following activities:
- January 28, 2016, control and shutdown rod operability testing in accordance with STS SF-001, Control and Shutdown Rod Operability Verification, Revision 28, including the pre-job brief
- February 10, 2016, operator immediate response to a partial reactor trip alarm in accordance with ALR 00-083C, Rx Partial Trip, Revision 5A
- February 26, 2016, reduction in power to approximately 84 percent to support main turbine valve cycle testing, and later operators reduced power to approximately 70 percent to support 345 KV switchyard insulator repairs, including the pre-job brief In addition, the inspectors assessed the operators adherence to plant procedures, including AP 21-001, Conduct of Operations, Revision 75, and other operations department policies.
These activities constituted completion of one quarterly licensed operator performance sample as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
On March 22, 2016, the inspectors reviewed one instance of degraded performance or condition of safety-related SSC - Train A spent fuel pool cooling pump surveillance testing issues.
The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.
These activities constituted completion of one maintenance effectiveness sample, as defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed three risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:
- January 11, 2016, B emergency diesel generator planned maintenance
- March 9, 2016, A service water pump discharge check valve planned maintenance
- March 23, 2016, A centrifugal charging pump planned maintenance The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.
The inspectors also observed portions of three emergent work activities that had the potential to affect the functional capability of mitigating systems or to impact barrier integrity:
- January 21, 2016, unplanned A emergency diesel generator voltage regulator handswitch replacement
- March 17, 2016, unplanned B containment spray discharge isolation valve troubleshooting
- March 24, 2016, unplanned control building air conditioning unit SGK04B refrigerant leak corrective maintenance and control room emergency ventilation radiation monitor test failure The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.
These activities constituted completion of six maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed five operability determinations that the licensee performed for degraded or nonconforming SSCs:
- February 10 and 11, 2016, operability determination of the B motor-driven auxiliary feedwater pump with elevated piping vibrations
- February 11, 2016, operability determination and extent of condition for essential service water vacuum breaker valve EFV0484 after failing its as-found stroke test
- March 3, 2016, operability determination of the turbine-driven auxiliary feedwater pump with high particulate count in oil samples for both the inboard and outboard pump bearings
- March 18, 2016, operability determination of the leaking by B containment spray pump discharge valve
- March 21, 2016, operability determination of the turbine-driven auxiliary feedwater pump with the steam trap bypass valve cycling The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded SSC.
These activities constituted completion of five operability and functionality review samples, as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed five post-maintenance testing activities that affected risk-significant SSCs:
- January 6, 2016, B centrifugal charging pump following planned maintenance
- January 11, 2016, B emergency diesel generator following planned maintenance
- February 9, 2016, diesel fire pump following planned maintenance
- February 9 through 10, 2016, B motor driven auxiliary feedwater pump following planned maintenance
- February 18, 2016, A containment cooler fan motor following planned maintenance The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.
These activities constituted completion of five post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed five risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:
In-service tests:
- February 12, 2016, STS AB-201D, Atmospheric Relief Valve Inservice Valve Test, Revision 27A
- February 17, 2016, STS EM-100A, Safety Injection Pump A Inservice Pump Test, Revision 39 Other surveillance tests:
- January 4, 2016, STS IC-208B, 4KV Loss of Voltage & Degraded Voltage TADOT NB02 - SEP GRP 4, Revision 4E
- February 26, 2016, STS AC-001, Main Turbine Valve Cycle Test, Revision 51 The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the tests satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.
These activities constituted completion of five surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed an emergency preparedness drill on February 17, 2016, to verify the adequacy and capability of the licensees assessment of drill performance.
The inspectors reviewed the drill scenario, observed the drill from the Technical Support Center and Emergency Operations Facility, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.
These activities constituted completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Unplanned Scrams per 7000 Critical Hours (IE01)
a. Inspection Scope
The inspectors reviewed licensee event reports (LERs) for the period of January 1, 2015, through December 31, 2015, to determine the number of scrams that occurred.
The inspectors compared the number of scrams reported in these LERs to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.
These activities constituted verification of the unplanned scrams per 7000 critical hours performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Unplanned Power Changes per 7000 Critical Hours (IE03)
a. Inspection Scope
The inspectors reviewed LERs, and reactor power trend logs for the period of January 1, 2015, through December 31, 2015, to determine the number of unplanned power changes that occurred. The inspectors compared the number of unplanned power changes documented to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.
These activities constituted verification of the unplanned power outages per 7000 critical hours performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Unplanned Scrams with Complications (IE04)
a. Inspection Scope
The inspectors reviewed the licensees basis for including or excluding in this performance indicator for each scram that occurred between January 1, 2015, and December 31, 2015. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.
These activities constituted verification of the unplanned scrams with complications performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
b. Findings
No findings were identified.
.2 Annual Follow-up of Selected Issues
a. Inspection Scope
The inspectors selected two issues for an in-depth follow-up:
- On December 29, 2015, the licensee recognized that inservice testing had not been performed for one of the vacuum breaker valves (EFV0478) that had been recently installed on the train A essential service water water hammer mitigation loop. Additionally, an inservice testing procedure had not been developed or approved.
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition as described in Condition Report 101760.
- On January 5, 2016, the control room air conditioning unit (SGK04A) was identified with low refrigerant levels, and a refrigerant leak was discovered that resulted in the SGK04A unit being declared inoperable and unavailable for maintenance.
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition as described in Condition Report 101862.
These activities constitute completion of two annual follow-up samples as defined in Inspection Procedure 71152.
b. Findings
Introduction.
The inspectors identified a Green non-cited violation of Technical Specification 5.4.1.a for the licensees failure to adequately develop and adjust preventive maintenance activities in accordance with Procedure AP 16B-003, Planning and Scheduling Preventive Maintenance, Revision 5. Specifically, the licensee did not adequately develop a preventive maintenance replacement task and schedule for control room air conditioning unit SGK04A refrigerant sensing lines and fittings; as a result, a large scale leak was identified that resulted in the SGK04A unit being declared inoperable and unavailable, required corrective maintenance, and resulted in unplanned entries into Condition A of Technical Specifications 3.7.10 and 3.7.11.
Description.
On January 5, 2016, Condition Report 101862, documented that control room air conditioning unit SGK04A refrigerant level was found low. The control room air conditioning system is designed to maintain the control room temperature for 30 days of continuous occupancy. In response to Condition Report 101862 Wolf Creek personnel completed refrigerant leak checks in accordance with Work Order 16 410207-000 and identified a large scale leak where the water regulating valve (GKV0765) capillary sensing line attaches to a Swagelok bulkhead fitting at isolation valve number 7this condition was documented in Condition Report 101867. A large scale leak is defined by Procedure MPE GK-003, Control Room and Class 1E A/C Units Preventive Maintenance Activity, Revision 6, as any leak greater than 5 ounces per year.
The SGK04A system was immediately secured and declared inoperable on January 5, 2016, due to the location and size of the leak. As a result, at 6:58 p.m. on January 5, 2016, the station entered Technical Specification 3.7.11, Condition A, for one control room air conditioning system train inoperable. At 12:13 a.m. on January 6, 2016, the station entered Technical Specification 3.7.10, Condition A, for one control room emergency ventilation system train inoperable while the sensing line and fitting were replaced. Following completion of corrective maintenance, the SGK04A unit was restored to service and applicable Technical Specification conditions were exited at 4:50 a.m. on January 6, 2015, following successful testing.
In response to Condition Report 101867 the licensee completed a Basic Cause Evaluation. The evaluation states, The probable cause of this failure was determined to be a missed opportunity to replace the sensing line in a timely manner which resulted in a large scale refrigerant leak on the water regulating valve sensing line Swagelok fitting/nut.
An incorrect base date for a corrective action from CR [(condition report)] 76409 to implement a time directed replacement PM for the sensing lines to eliminate failure due to aging and vibration was established, resulting in a missed opportunity to replace the sensing line in a timely manner.
The cause evaluation discussed Table 6-2, Degradation Mechanisms, of Electric Power Research Institute report 1015075, Plant Support Engineering: Life Cycle Management Planning Sourcebooks - Chillers, December 2007, which notes that refrigerant operated control valve capillary lines are expected to be failure-free for 10 years.
Evaluation determined that the preventive maintenance activity base date had been incorrectly set because the station utilized the last replacement date of the suction sensing line coming from the suction of the compressorthe licensee determined that the replacement date of the water regulating valve sensing line and fittings should have been used instead. The water regulating valve sensing line associated with the SGK04A unit had been in place since installation of the SGK04A skid in 2004, approximately 12 years prior to the components failure.
The inspectors noted that Procedure AP 16B-003, Planning and Scheduling Preventive Maintenance, Revision 5, provides direction for implementing the preventive maintenance program. Section 6.2.2 states, PM [(preventive maintenance)]
frequencies are established and adjusted in accordance with AI 16B-002, Updating the PM Activity Module and the following considerationsThe age of the installed equipment. The inspectors determined that the preventive maintenance frequency for replacement of the SGK04A water regulating valve sensing line and fittings was not adequately established and the age of installed equipment adequately considered.
The inspectors reviewed the Basic Cause Evaluation associated with Condition Report 101867 and noted the actions taken. Specifically, Wolf Creek took immediate actions to replace the impacted sensing line and Swagelok nut associated with SGK04A and returned the unit to service. The station also verified that the base date was adequately set to ensure that future SGK04A water regulating valve sensing line replacements would occur within five years (April 23, 2018) of the most recent sensing line and Swagelok nut replacement (January 6, 2016). The Actions Planned section stated, No further actions are required to minimize recurrence of the failure based on the probable cause. The inspectors questioned whether any corrective actions had been taken or documented to address the probable causeAn incorrect base date for a corrective action from CR [(condition report)] 76409and the inspectors determined that no actions had been taken to understand or correct why the base date was incorrectly set.
The inspectors determined through interviews and document reviews that procedure guidance associated with setting preventive maintenance base dates lacked sufficient detail to ensure that preventive maintenance activities associated with safety-related equipment are completed commensurate with their safety significance. The licensee initiated Condition Report 103694 in response to the inspectors questions and is evaluating what additional corrective actions are needed.
Analysis.
The inspectors determined that the licensees failure to adequately develop and adjust preventive maintenance activities associated with control room air conditioning unit SGK04A refrigerant sensing lines and fittings was a performance deficiency. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Attachment 0609.04, "Initial Characterization of Findings,"
worksheet to Inspection Manual Chapter (IMC) 0609, Significance Determination Process, issued June 19, 2012. The attachment instructs the inspectors to utilize IMC 0609, Appendix A, Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012. The inspectors 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 it 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).
The inspectors determined that in accordance with Inspection Manual Chapter 0310 Aspects Within The Cross-Cutting Areas, issued December 4, 2014, the finding has a cross-cutting aspect in the area of human performance, resources, because leaders did not ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. Specifically, leaders did not ensure procedures and other resource materials were available to support successful work performance when setting preventive maintenance activity base dates, which resulted in the licensee failing to adequately develop and adjust preventive maintenance activities associated with control room air conditioning unit SGK04A refrigerant sensing lines and fittings
[H.1].
Enforcement.
Technical Specification 5.4.1.a, requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 9.b of Appendix A to Regulatory Guide 1.33, Revision 2, requires that preventive maintenance schedules be developed to specifyinspection or replacement of parts that have a specific lifetime. The licensee established Procedure AP 16B-003, Planning and Scheduling Preventive Maintenance, Revision 5, which provides direction for implementing the preventive maintenance program to meet the Regulatory Guide 1.33 requirement. Section 6.2.2 of Procedure AP 16B-003 requires that preventive maintenance activities are established and adjusted in accordance with the age of the installed equipment. Contrary to the above, until January 6, 2016, the licensee did not ensure that preventive maintenance frequencies were established and adjusted in accordance with the age of installed equipment. Specifically, the licensee did not ensure that adequate preventive maintenance activities were developed for control room air conditioning unit SGK04A refrigerant sensing lines and fittings. As a result, a large refrigerant leak was identified that resulted in the SGK04A unit being declared inoperable and unavailable, required corrective maintenance, and resulted in unplanned entries into Condition A of Technical Specifications 3.7.10 and 3.7.11. The licensee entered this condition into its corrective action program as Condition Reports 101862 and 101867. The licensees immediate actions included securing and declaring the SGK04A system inoperable, completing corrective maintenance to eliminate the refrigerant leak, and confirming that the impacted preventive maintenance frequency was adequately established. Because this violation was of very low safety significance and this issue was entered into the licensees corrective action program, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. (NCV 05000482/2016001-01, Failure to Adequately Establish and Adjust Preventive Maintenance Activities for Control Room Air Conditioning Unit SGK04A Sensing Lines and Fittings)
4OA3 Follow-up of Events and Notices of Enforcement Discretion
(Closed) LER 05000482/2014-006-00: Post-Fire Safe Shutdown Latent Issue May Impact Ability to Achieve Safe Shutdown On November 19, 2014, the licensee determined that a control room fire scenario could result in the shutdown of the train B emergency diesel generator due to high jacket water temperature prior to establishing essential service water cooling to the emergency diesel generator. This condition would preclude the emergency diesel generator from providing the necessary electrical power to safely shutdown the plant during specific control room fire scenarios. This issue was dispositioned as non-cited violation 05000482/2014008-01 in the NRC Triennial Fire Protection Inspection Report 05000482/2014008 (ADAMS Accession Number ML14352A342).
This licensee event report is closed.
These activities constitute completion of one event follow-up sample, as defined in Inspection Procedure 71153.
4OA5 Other Activities
(Closed) IP 92722 - Follow-up Inspection for Any Severity Level I or II Traditional Enforcement Violation or For Two or More Severity Level III Traditional Enforcement Violations in a 12-Month Period On January 27, 2016, the NRC issued to Wolf Creek Nuclear Operating Corporation two Notices of Violation that represented a Severity III problem. Details are discussed in NRC Inspection Reports 05000482/2015010 and 05000482/2015011. The violations were associated with licensed reactor operator medical examinations and related NRC reporting requirements. In Inspection Report 05000482/2015010, the NRC concluded that information regarding: 1) the reasons for the violations, 2) the actions planned or already taken to correct the violations and prevent recurrence, and 3) the dates when full compliance was achieved were already adequately addressed on the docket and no response was required. Specifically, inspectors confirmed that the Wolf Creek Nuclear Operating Corporation: 1) requested the NRC amend the operators licenses to include a restriction for the use of prescribed medication (on July 15, 2015, the NRC issued the amended license with the new restriction), 2) initiated a causal analysis that included an extent of condition review for all operators to determine if there were any further unknown medical conditions, and 3) trained appropriate personnel on NRC medical restriction requirements. Based on these facts, the NRC considers this item to be closed and no follow-up inspection activity for these two Notices of Violation is planned. This item is closed.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On April 13, 2016, the inspectors presented the inspection results to Adam Heflin, President and Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- T. Baban, Manager, System Engineering
- W. Brown, Superintendent, Security Operations
- A. Broyles, Manager, Information Services
- D. Campbell, Superintendent, Maintenance
- T. East, Superintendent, Emergency Planning
- J. Edwards, Manager, Operations
- D. Erbe, Manager, Security
- R. Flannigan, Manager, Nuclear Engineering
- J. Fritton, Oversight
- B. Gagnon, Superintendent, Security
- C. Hafenstine, Manager, Regulatory Affairs
- A. Heflin, President and Chief Executive Officer
- S. Henry, Manager, Integrated Plant Scheduling
- R. Hobby, Licensing Engineer
- J. Isch, Operations Work Controls
- B. Lee, Supervising Instructor
- D. Mand, Manager, Design Engineering
- J. McCoy, Vice President, Engineering
- W. Muilenburg, Supervisor, Licensing
- L. Ratzlaff, Manager, Maintenance
- C. Reasoner, Site Vice President
- M. Skiles, Manager, Radiation Protection
- T. Slenker, Supervisor, Operations Support
- S. Smith, Plant Manager
- M. Storts, Engineer
- A. Stueve, Engineer
- A. Stull, Vice President and Chief Operations Administrative Officer
- M. Tate, Superintendent, Security
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000482/2016001-01 NCV Failure to Adequately Establish and Adjust Preventive Maintenance Activities for Control Room Air Conditioning Unit SGK04A Sensing lines and Fittings (Section 4OA2)
Attachment 1
Closed
- 05000482/2014006-00 LER Post-Fire Safe Shutdown Latent Issue May Impact Ability to Achieve Safe Shutdown (Section 4OA3)
- 05000482/2015010-01 NOV Incomplete and Inaccurate Medical Information Resulted in Issuance of a Renewed Operator License Without a Required Medical Restriction
- 05000482/2015010-02 NOV Failure to Report a Permanent Change in a Licensed Operators Medical Status and Request a Condition be Placed on the Operators License