IR 05000482/2018007

NRC Problem Identification and Resolution Inspection Report 05000482/2018007

ML18218A265
Person / Time
Site:	Wolf Creek
Issue date:	08/08/2018
From:	Gerond George Division of Reactor Safety IV
To:	Heflin A Wolf Creek
References
IR 2018007
Download: ML18218A265 (20)

Text

ust 8, 2018

SUBJECT:

WOLF CREEK GENERATING STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000482/2018007

Dear Mr. Heflin:

On June 28, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution inspection at your Wolf Creek Generating Station. The NRC inspection team discussed the results of this inspection with Mr. J. H. McCoy, Vice President, Engineering, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program. The team assessed the programs effectiveness in identifying, prioritizing, evaluating, and correcting problems, and whether the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. However, the team found evidence of continued challenges to your organizations safety-conscious work environment in the maintenance support group, similar to those identified in NRC Integrated Inspection Report 05000482/2017003. (ADAMS Accession No. ML17311B223). In reviewing your corrective actions to address the 2017 maintenance support challenges, the team concluded that your actions appeared minimal. Your management stated that other actions had been taken, but were unable to provide any documentation of those actions or any evidence of whether they had been successful. Further, while your station had initiated corrective actions following the NRCs identification of a safety-conscious work environment cross-cutting theme in our 2017 assessment letter (ADAMS Accession No. ML18052A345), no actions were taken or planned to evaluate whether the work environment had improved following completion of the corrective actions taken.

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 of the Enforcement Policy.

If you contest the violation or significance of the 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; and the NRC resident inspector at the Wolf Creek Generating Station.

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

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Gerond A. George, Team Leader Inspection Programs and Assessment Team Division of Reactor Safety Docket No. 50-482 License No. NPF-42 Enclosure:

Inspection Report 05000482/2018007 w/ Attachment: Information Request

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000482 License Number: NPF-42 Report Number: 05000482/2018007 Enterprise Identifier: I-2018-007-0007 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: Burlington, Kansas Inspection Dates: June 11, 2018, to June 28, 2018 Inspectors: R. Azua, Senior Reactor Inspector, DRS (Team Lead)

E. Ruesch, Senior Reactor Inspector, DRS M. Stafford, Resident Inspector, Cooper Nuclear Station, DRP F. Thomas, Resident Inspector, Wolf Creek Generating Station, DRP Approved By: G. George, Team Leader Inspection Program and Assessment Team Division of Reactor Safety Enclosure

SUMMARY The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Problem Identification and Resolution inspection at the Wolf Creek Generating Station, Unit 1, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations Failure to Provide Adequate Work Instructions for Preventive Maintenance on Safety-Related Equipment Cornerstone Significance Cross-cutting Inspection Aspect Procedure Mitigating Green [P.2] Problem 71152 - Problem Systems NCV 05000482/2018007-01 Identification Identification and Closed and Resolution Resolution The team reviewed a Green, self-revealed non-cited violation of Technical Specification 5.4.1.a to establish, implement, and maintain written procedures recommended by Regulatory Guide 1.33, Appendix A, Revision 2. Specifically, work instructions for the preventive maintenance for the train B Class 1E electrical equipment A/C unit SGK05B, lacked adequate guidance for preventive maintenance and calibration of the associated thermostat. This resulted in the loss of cooling failure of the A/C unit SGK05B, on February 12, 2018.

OTHER ACTIVITIES - BASELINE 71152Problem Identification and Resolution Biennial Team Inspection (1 Sample)

The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety-conscious work environment. The assessment is documented below.

(1) Corrective Action Program Effectiveness: Problem Identification, Problem Prioritization and Evaluation, and Corrective Actions - The inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems. The team also evaluated the stations compliance with NRC regulations and licensee standards for corrective action programs. The sample included approximately 170 condition reports (CR) with associated root and apparent cause evaluations. This included an in-depth 5-year review of CRs associated with the licensees safety-related A/C units with a focus on the associated chillers.

(2) Operating Experience, Self-Assessments, and Audits - The team evaluated the stations processes for use of industry and NRC operating experience. The team also evaluated the effectiveness of the stations audits and self-assessments program. The sample included industry operating experience communications including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including Institute of Nuclear Power Operations (INPO) and Electric Power Research Institute, plus associated site evaluations.

(3) Safety-Conscious Work Environment - The team evaluated the stations safety-conscious work environment. The team interviewed approximately fifty individuals in eight group interviews. The purpose of these interviews was: (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a CR or by another method; (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems; and (3) to evaluate their safety-conscious work environment. The focus group participants included personnel from the mechanical and electrical maintenance, instrumentation and controls, engineering, and maintenance support. The team also interviewed the employee concerns program manager, reviewed employee concerns files, and reviewed the results of the most recent safety culture survey. The team reviewed the licensees actions taken in response to the significant work environment challenges identified by the NRC in a June 2017 inspection, which were documented in Inspection Report 2017003 (ADAMS Accession No. ML17311B223), and the safety-conscious work environment cross-cutting theme identified in the NRCs 2017 Annual Assessment Letter (ADAMS Accession No. ML18052A345).

INSPECTION RESULTS Corrective Action Program Assessment 71152Problem Identification and Resolution Corrective Action Program: Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Effectiveness of Problem Identification: Overall, the team found that the licensees identification and documentation of problems were adequate to support nuclear safety.

Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensees prioritization and evaluation of issues were adequate to support nuclear safety.

Effectiveness of Corrective Actions: Overall, the team concluded that the licensees corrective actions generally supported nuclear safety.

Operating Experience, Self-Assessments, and Audits 71152Problem Identification and Assessment Resolution Operating Experience, Self-Assessments and Audits: Based on the samples reviewed, the team determined that the licensees performance in each of these areas adequately supported nuclear safety. In the area of operating experience, the team found that information was being appropriately used at the Wolf Creek Generating Station to ensure potential issues were promptly identified and corrected. Having said that, the team noted some indications that screening of operating experience information could be improved. One example was identified where the licensee failed to promptly identify and correct a condition adverse to quality in the area of operating experience. This issue is further documented in this report as a minor violation.

Safety-Conscious Work Environment Assessment 71152Problem Identification and Resolution Safety-Conscious Work Environment: In most work groups, the team found no evidence of challenges to the safety-conscious work environment. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available.

However, the team found continued work environment challenges in the maintenance support group, similar to those identified during the June 2017 inspection. In reviewing corrective actions taken by the licensee following the previous inspection activities, the team noted other than a personnel move, the licensee had not documented any actions taken to correct the work environment challenges. Further, the licensee had taken no action to evaluate whether the work environment had improved as a result of the personnel move or of any undocumented actions taken. Neither had the licensee documented the identified issues in the corrective action program or any other formal action tracking process. Following identification by the team, the employee concerns program coordinator briefed the stations nuclear safety culture monitoring panel and conducted a pulse survey that confirmed the teams conclusions that the work environment challenges had not been corrected. The team determined that presently, the maintenance support group would raise nuclear safety

concerns; however, concern arises if the work environment challenges are allowed to continue. The licensee documented the issue in CR 124460.

Following receipt of the NRCs 2017 annual assessment letter, the licensee performed an apparent cause evaluation to evaluate circumstances that led to the safety-conscious work environment cross-cutting issue and to develop actions to correct any adverse conditions and their causes (CR 119954). These planned actions include benchmarking, process changes, and leadership training. The licensee also developed an action to evaluate the effectiveness of these actions approximately 6 months after they are complete. This planned effectiveness review includes surveys of and interviews with station leadership, validation of corrective action program process outputs, and review of the results of a planned third-party assessment. The team reviewed the licensees actions and determined that the success criteria, which were approved by Corrective Action Review Board on June 20, 2018, do not include validation through interviews or surveys with individual contributors to verify that any underlying safety-conscious work environment challenges have been corrected. The team noted that the licensees effectiveness measures may validate that the planned actions have been accomplished, but not whether they have been successful at correcting the deficiency they are intended to correct. The licensee documented this observation in CR 124660.

Overall, the team concluded that most work groups at the Wolf Creek Generating Station maintained a healthy safety-conscious work environment. However, the lack of tracking mechanisms or effectiveness reviews for actions taken to improve the work environment, in those groups with challenges, appears to have hindered timely resolution of those challenges.

INSPECTION RESULTS - ISSUES/FINDINGS Minor Violation 71152Problem Identification and Resolution Performance Deficiency: Failure to promptly identify and correct known-defective switches in inservice safety-related breakers, or to control nonconforming breakers accepted into warehouse stores, as required by 10 CFR 50 Appendix B Criteria XV and XVI.

In February 2008, the licensee received a notification from GE Hitachi of reduced reliability of some safety-related circuit breakers due to defective cutoff switches internal to the breakers.

The licensee incorrectly screened this information as not applicable to the Wolf Creek Generating Station. In August 2011, after licensee engineers received the information again from industry peers, the licensee screened the information as applicable. The licensee then added steps to its overhaul and pre-install test procedures to check for the defective subcomponent. These steps were performed during subsequent regularly scheduled overhaul or pre-install tests, with the last affected switches being replaced in June 2014 and the last potentially susceptible safety-related breaker being inspected in March 2015. The team determined that because the station had information on the defect in February 2008, but did not correct the condition until 2014 and did not confirm that it was corrected until 2015, the licensee had failed to promptly identify and correct a condition adverse to quality. Further, the licensee failed to inspect or place administrative controls on potentially affected spare breakers that had been accepted into warehouse stores, though the added steps in the pre-install procedure likely would have prevented a defective component from being installed.

However, by failing to segregate the potentially affected components until they were inspected, the licensee failed to comply with quality assurance requirements for control of nonconforming components. On June 26, 2018, the licensee put a hold on four potentially

affected breakers that were in warehouse stores. The licensee documented this performance deficiency in CR 124693.

Screening: The performance deficiency was minor because the licensee did not experience an inservice failure as a result of the defect during the 6 years they remained in service and had a procedure in place that would likely have prevented a defective spare from being issued for installation. Therefore, there was no adverse effect on the mitigating systems cornerstone objective and there was no potential to create a more significant safety concern.

Enforcement: This failure to comply with 10 CFR 50 Appendix B Criteria XV and XVI constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Failure to Provide Adequate Work Instructions for Preventive Maintenance on Safety-Related Equipment Cornerstone Significance Cross-cutting Inspection Procedure Aspect Mitigating Green [P.2] - Problem 71152Problem Systems NCV 05000482/2018007-01 Identification Identification and Closed and Resolution Resolution The inspectors reviewed a Green, self-revealed non-cited violation of Technical Specification 5.4.1.a to establish, implement, and maintain written procedures recommended by Regulatory Guide 1.33, Appendix A, Revision 2. Specifically, work instructions for the preventive maintenance for the train B Class 1E electrical equipment A/C unit SGK05B, lacked adequate guidance for preventive maintenance and calibration of the associated thermostat. This resulted in the loss of cooling failure of the A/C unit SGK05B, on February 12, 2018.

Description:

On February 12, 2018, the licensee made an unplanned entry into action statements associated with Technical Specifications 3.0.3, Limiting Condition for Operation Applicability, (which requires initiation of actions within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, to be in Mode 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />); 3.8.9, Conditions C and D, Electrical Power Systems - Distribution Systems; 3.8.7, Condition A, Electrical Power Systems - Inverters - Operating; and 3.8.4, Condition A, Electrical Power Systems - DC Sources. This unplanned entry was made as a result of the train B Class 1E electrical equipment A/C unit SGK05B not operating in accordance with design requirements.

The safety-related function of the A/C unit SGK05B is to provide suitable environment for Class 1E electrical equipment during normal and accident conditions. By not cooling properly, the A/C unit SGK05B would not be able to meet the required room temperatures needed to support train B engineering safety feature equipment. The failure was identified as a result of a security officer performing rounds having noticed an increase in temperature on the 2016 foot elevation in the Control Building. According to the operations logs, the highest affected room temperature was recorded at approximately 80 degrees Fahrenheit.

According to Condition Report (CR) 119446, initial troubleshooting performed by the fix-it now team led the licensee to suspect that the step controller associated with the A/C unit was not functioning properly due to a potentially loose set screw on the micro-switch. The CR also indicated that this set screw coming loose had been an issue in the past. The step controller

and thermostat were replaced on February 13, 2018, as a part of further troubleshooting efforts. Past maintenance records indicate that the A/C unit SGK05B step controller, according to Work Order 15-402910-004, had last been replaced on October 1, 2016. Before then, it had been replaced on March 28, 2014, per Work Order 14-385255-001. The thermostat had not been replaced until February 13, 2018.

As indicated in the basic cause evaluation, the licensee determined that this failure constituted a maintenance preventable functional failure. In accordance with the Maintenance Rule Database Function GK-01, the function of A/C unit SGK05B is to provide a suitable environment for Class 1E electrical equipment during normal and accident conditions.

Any equipment failure that results in the system being incapable of maintaining room temperature below a temperature of 90 degrees F is considered a high safety significant functional failure. Demand failures that do not result in the room temperature reaching 90 degrees F are considered functional failures, but are not considered high safety significant functional failures. The A/C unit SGK05B would not have performed its function to provide a suitable environment for Class 1E electrical equipment due to the failure of the thermostat.

The licensees basic cause evaluation identified the probable cause of the failure as having been the failure of the GKTC0005B thermostat for the A/C unit SGK05B, resulting in anomalous operation of the associated controller and subsequent lack of temperature control for supported equipment rooms. The conclusion in the basic cause evaluation indicated that the failure of the thermostat resulted in the inability of the A/C unit SGK05B to cool supported equipment rooms. This was based on the results of a hardware failure analysis performed by a third party, which showed signs of erratic and unexpected operation from the thermostat.

Furthermore, the basic cause evaluation indicated that the lack of available calibration, preventive maintenance, or replacement records on the thermostat contributed to the failure.

Furthermore, the basic cause evaluation for the February 12, 2018, event stated that a review of the stock transaction for the Honeywell thermostat showed four prior replacements of the component between the four air conditioning units which utilize it. The units which utilize these components are the train A and B Control Room A/C units (SGK04A and SGK04B),

and the train A and B Class 1E electrical equipment A/C units (SGK05A and SGK05B). None of the replacements were on the A/C unit SGK05B. The basic cause evaluation also stated that a review of the IQ Review database showed that the calibration template task had been disregarded during the 2014 preventive maintenance optimization effort based on it being considered, determined by driving asset or program. The basic cause analysis also indicated, that without preventive maintenance in place to periodically check their condition, it is likely only a self-revealing failure would be identified within the corrective action program.

Several months before, at 5:24 AM, on November 7, 2017, the licensee had taken the train B Class 1E electrical equipment A/C unit SGK05B out of service for a planned maintenance outage. At 4:50 AM, on November 8, 2017, an operations log entry was made by the night-shift manager indicating that the A/C unit SGK05B was not responding to adjustments on the thermostat assembly during post-maintenance testing activities. Condition Report CR 117283 was initiated for troubleshooting. The troubleshooting activities were implemented under Work Order 17-423314-007. As a part of their troubleshooting activities, the electricians took voltage readings at the step controller and adjusted the thermostat setting to approximately 50 degrees F. The step controller did not move. Electricians then took voltage readings at the terminal board on the step controller and it started to operate. While observing the movement of internal step controller components, the technician notes indicated that a small

arc was seen on the potentiometer. Also, at some point during the troubleshooting, the electricians lightly tapped on the step controller assembly until the balance relay contacts inside of the step controller changed state and drove the controller to energize liquid line solenoids. These solenoids regulate the flow of refrigerant into the air-handling unit for air cooling. The fix-it now team electricians concluded that the problem was with the feedback potentiometer. According to technician notes in the aforementioned work order, the contacts for the feedback potentiometer were burnished and the associated disc assembly was cleaned. The electricians also adjusted the contact tension on the feedback potentiometer.

According to work order information, the electricians were eventually able to adjust the thermostat, and observe expected pick-up and drop-out load response from A/C unit SGK05B. The unit was returned to service at 9:19 PM, on November 8, 2017. The troubleshooting work order did not contain or indicate that any calibration or resistance checks were performed specifically on the thermostat.

On September 29, 2015, troubleshooting work was performed on the train A control room A/C unit SGK04A during a planned maintenance outage (under Work Order 14-396140-000), due to excessive cycling having been observed on the unit on December 14, 2014. According to the work order, electrical maintenance personnel recommended that the Honeywell T991A thermostat be calibrated during the next maintenance outage, in accordance with Procedure INC C-1000, Calibration of Miscellaneous Components. According to the work order, the as-found condition notes indicated that the resistance measurements for the thermostat were not balanced.

Maintenance technicians adjusted the thermostat calibration accordingly and the unit was later returned to service on October 30, 2015.

The licensee wrote CR 117283 for issues observed during the November 7, 2017, maintenance outage. In CR 117283 it indicated that the defect in the A/C unit SGK05B was a lack of control of the A/C unit with varying thermostatic input, because the unit was not responding to changing thermostatic inputs and cycled off multiple times following restoration from preventive maintenance activities. The cause of the failure identified in the basic cause evaluation was the loss of contact or high resistance at the feedback potentiometer, which resulted in the step controller stalling at a singular position which resulted in a lack of response from the A/C unit SGK05B.

Considering troubleshooting work performed on the A/C unit SGK04A back on September 29, 2015, where the same model Honeywell T991A thermostat is used and specific steps were taken to troubleshoot the thermostat, it is possible that the same troubleshooting steps should have been performed on the A/C unit SGK05B thermostat during the November 7 - 8, 2017, planned maintenance outage. While there was no documented loss of cooling or equipment failure on the A/C unit SGK04A between December 14, 2014, and September 30, 2015, there was an indication of a degraded condition on the Honeywell T991A thermostat. Thus, there was an opportunity to have identified a degraded condition on the Honeywell T991A thermostat on the A/C unit SGK05B during the November 7 - 8, 2017, planned maintenance outage.

Corrective Actions: The licensee took the immediate corrective actions to: (1) implement compensatory measures for having one of two Class 1E electrical equipment A/C units out of service, as described in Procedure SYS GK-200, Non-Functional Class 1E A/C Unit; (2) perform troubleshooting as required by Work Order 18436340-002; and (3) replace both the step controller and thermostats.

Performance Assessment:

Performance Deficiency: The failure to provide adequate work instructions for preventive maintenance on safety-related equipment is a performance deficiency.

Screening: The performance deficiency is more than minor, and therefore a finding, 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 (i.e., core damage). Specifically, work instructions for preventive maintenance on the train B Class 1E electrical equipment A/C unit SGK05B, lacked preventive maintenance and calibration instruction for the A/C unit thermostat, which led to the failure of the A/C unit thermostat, resulting in the loss of cooling failure of the A/C unit SKG05B, on February 12, 2018.

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

Cross-cutting Aspect: The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution associated with evaluation, because the organization did not take effective corrective actions to thoroughly evaluate issues to ensure that resolutions address cause and extent of conditions commensurate with their safety significance. Specifically, the licensee failed to ensure that issues with the A/C unit SGK05B were thoroughly investigated according to their safety significance [P.2].

Enforcement:

Violation: Technical Specification 5.4.1.a, requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended by Regulatory Guide 1.33, Appendix A, Revision 2. Section 9.a of Appendix A of Regulatory Guide 1.33, Revision 2, states, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

The licensee established Procedure AP 16B-003, Planning and Scheduling Preventive Maintenance, which provides direction for implementing the preventive maintenance program to meet the Regulatory Guide 1.33 requirement. Section 6.2 of Procedure AP 16B-003 requires, in part, that preventive maintenance activities be developed by considering, in part, equipment history and component functional importance.

Contrary to the above requirement, on November 8, 2018, the licensee failed to implement written procedures recommended by Regulatory Guide 1.33, Appendix A, Revision 2.

Specifically, preventive maintenance activities were developed without adequately considering equipment history and component functional importance in accordance with

Procedure AP 16B-003. Preventive maintenance Work Orders 17-428613-000 and17-423314-007 did not require preventive maintenance and calibration testing of the thermostat associated with A/C unit SGK05B.

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

EXIT MEETINGS AND DEBRIEFS On June 28, 2018, the inspectors presented the Problem Identification and Resolution inspection results to Mr. J. H. McCoy, Vice President, Engineering, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

DOCUMENTS REVIEWED 71152Problem Identification and Resolution Condition Reports 42461 46173 53586 70482 73241 73863 75337 78108 80172 81711 84848 86032 90162 90879 92274 95378 96307 96397 100328 100902 101706 101867 102322 103395 104266 105186 105558 105559 105771 105865 105901 105929 106016 106064 106165 106183 106289 106292 106328 106417 106668 106725 106867 107732 107743 108163 108416 108493 108529 108553 108699 108800 108996 110399 111210 111751 111818 111939 111941 112136 112244 112339 112363 112436 112497 112503 112588 112689 112964 113061 113304 113485 113913 114245 114437 114850 114885 114886 114887 114933 114947 115001 115103 115127 115326 115471 115642 115667 116175 116176 116178 116179 116180 116181 116489 116786 116792 116831 116852 116893 117124 117238 117283 117389 117408 118665 118885 118894 118994 119173 119275 119297 119298 119446 119487 119593 119954 119981 120045 120056 120064 120091 120112 120125 120151 120287 120331 120484 120519 120628 120674 120780 120822 121443 121762 122076 122359 122375 122411 122598 123038 123276 123708 123900 124153 124187 124238 124242 124288 124373 124380 124381 124382 124383 124386 124460 124490 124520 124661 124662 124667 124669 Work Orders 05-273192-000 14-107802-000 14-385255-001 14-392578-001 14-396140-000 15-402910-002 15-402910-004 15-406675-022 16-412247-000 16-418672-001 16-418672-002 16-418672-003 17-122291-000 17-423314-005 17-423314-007 17-423314-008 17-423325-000 17-428613-000 18-436340-003 18-439562-000 Procedures Number Title Revision AI 23O-001 Functional Importance Determination 7 AI 28A-010 Screening Condition Reports 28 AI 28A-010 Screening Condition Reports 29A AI 28A-017 Effectiveness Follow-up 4 AI 28A-018 Corrective Action Review Board 6 AI 28A-023 Evaluation of Maintenance Rule Functional Failure 4 Condition Reports

Procedures Number Title Revision AI 28A-100 Condition Report Resolution 13 AI 28A-101 Non-Condition Adverse to Quality 2 AI 28B-005 Evidence and Action Matrix 4 AI 36-001 Nuclear Safety Culture Panel 5 AP 14A-003 Scaffold Construction and Use 25 AP 16B-003 Planning and Scheduling Preventive Maintenance 8A AP 16C-006 MPAC [Maintenance Planning and Controls] Work 23 Request/Work Order Process Controls AP 20A-010 Conduct of Performance Assessment 4 AP 21-001 Conduct of Operations 81 AP 23M-001 WCGS [Wolf Creek Generating Station] Maintenance Rule 12 Program AP 24E-003 Warehouse Material Storage, Handling, Packaging, 11 Shipping, and Maintenance AP 26C-004 Operability Determination and Functionality Assessment 35 AP 28-011 Resolving Degraded or Nonconforming Conditions 7 Impacting Structures, Systems, and Components AP 28A-100 Corrective Action Program 23 AP 36-001 Nuclear Safety Culture 5 INC C-1000 Calibration of Miscellaneous Components 7A MGE TL-001 Wiring Termination and Lug/Connector Installation 25 MPE E017Q-04 Circuit Breaker Test for AKR 50 and AKR 30 Breakers 25 Drawing Number Title Revision M-650A-00054 Control Building Electrical Chases - Wet Pipe W05 System El. 1974-0 through 2073-6

Miscellaneous Documents Number Title Revision BG-16-006 Operability Evaluation 0 CKL ZL-004 Turbine Building Reading Sheets 161 CKL ZL-005A An Emergency Diesel Generator (EDG) Operation Log 6 FL-08 Control Building Flooding (Calculation) 3 OE EF-16-002 Operability Evaluation 1 OE EP-16-007 Operability Evaluation 0 OE GM-17-001 Operability Evaluation 0 OE KJ-16-005 Operability Evaluation 0 OE NB-16-004 Operability Evaluation 0 OE NE-17-002 Operability Evaluation 0 OE SF-16-003 Operability Evaluation 1 Specification Technical Specification for Rolling Doors for the 6 10466-A-086 Standardized Nuclear Unit Power Plant System (SNUPPS)

SA-2017-0128 FLEX Program Self-Assessment STS KJ-011A EDG NE01 24 Hour Run 6 QA-2016-0270 CR 84848 Problem Identification and Resolution Condition 0 Brought Up by NRC Inspector on Breach Procedure QH-2017-1566 Engineering Life Cycle Management QH-2017-1600 2018 Design Basis Assurance Inspection (DBAI) Self-Assessment QH-2018-1652 RF22 Steam Generator Readiness for NRC ISI Inspection QH-2018-1653 RF22 ISI Inspection QS-2016-1804 Review of Engineering CRs Non-LTCA Over 365 Days Old for Escalation WCRE-35 Boundary Matrix 3 Control Rod Parking Schedule, Cycle 23 6 Problem Identification (PI) Desktop Cause Evaluation Users 0 Guide Wolf Creek Generating Station Cycle 23, Core Operating 0 Limits Report

Information Request Biennial Problem Identification and Resolution Inspection Wolf Creek Generating Station April 4, 2018 Inspection Report: 50-482/2018007 On-site Inspection Dates: June 11-15 & June 25-29, 2018 This inspection will cover the period from July 1, 2016, through June 29, 2018. All requested information is limited to this period or to the date of this request unless otherwise specified.

To the extent possible, the requested information should be provided electronically in word-searchable Adobe PDF (preferred) or Microsoft Office format. Any sensitive information should be provided in hard copy during the teams first week on site; do not provide any sensitive or proprietary information electronically.

Lists of documents (summary lists) should be provided in Microsoft Excel or a similar sortable format. Please be prepared to provide any significant updates to this information during the teams first week of on-site inspection. As used in this request, corrective action documents refers to condition reports, notifications, action requests, cause evaluations, and/or other similar documents, as applicable to the Wolf Creek Generating Station.

Please provide the following information no later than May 28, 2018:

1. Document Lists Note: For these summary lists, please include the document/reference number, the document title, initiation date, current status, and long-text description of the issue.

a. Summary list of all corrective action documents related to significant conditions adverse to quality that were opened, closed, or evaluated during the period b. Summary list of all corrective action documents related to conditions adverse to quality that were opened or closed during the period c. Summary lists of all corrective action documents that were upgraded or downgraded in priority/significance during the period (these may be limited to those downgraded from, or upgraded to, apparent-cause level or higher)

d. Summary list of all corrective action documents initiated during the period that roll up multiple similar or related issues, or that identify a trend e. Summary lists of operator workarounds, operator burdens, temporary modifications, and control room deficiencies (1) currently open and (2) that were evaluated and/or closed during the period f. Summary list of safety system deficiencies that required prompt operability determinations (or other engineering evaluations) to provide reasonable assurance of operability g. Summary list of plant safety issues raised or addressed by the Employee Concerns Program (or equivalent) (sensitive information should be made Attachment

available during the teams first week on sitedo not provide electronically)

h. Summary list of all Apparent Cause Evaluations completed during the period 2. Full Documents with Attachments a. Root Cause Evaluations completed during the period; include a list of any planned or in progress b. Quality Assurance audits performed during the period c. Audits/surveillances performed during the period on the Corrective Action Program, of individual corrective actions, or of cause evaluations d. Functional area self-assessments and non-NRC third-party assessments (e.g.,

peer assessments performed as part of routine or focused station self- and independent assessment activities; do not include INPO assessments) that were performed or completed during the period; include a list of those that are currently in progress e. Any assessments of the safety-conscious work environment at the Wolf Creek Generating Station f. Corrective action documents generated during the period associated with the following:

i. NRC findings and/or violations issued to the Wolf Creek Generating Station ii. Licensee Event Reports issued by the Wolf Creek Generating Station g. Corrective action documents generated for the following, if they were determined to be applicable to the Wolf Creek Generating Station (for those that were evaluated but determined not to be applicable, provide a summary list):

i. NRC Information Notices, Bulletins, and Generic Letters issued or evaluated during the period ii. Part 21 reports issued or evaluated during the period iii. Vendor safety information letters (or equivalent) issued or evaluated during the period iv. Other external events and/or operating experience evaluated for applicability during the period h. Corrective action documents generated for the following:

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i. Emergency planning drills and tabletop exercises performed during the period ii. Maintenance preventable functional failures which occurred or were evaluated during the period iii. Adverse trends in equipment, processes, procedures, or programs that were evaluated during the period iv. Action items generated or addressed by offsite review committees during the period 3. Logs and Reports a. Corrective action performance trending/tracking information generated during the period and broken down by functional organization (if this information is fully included in item 3.c, it need not be provided separately)

b. Corrective action effectiveness review reports generated during the period c. Current system health reports, Management Review Meeting (MRM) package, or similar information; provide past reports as necessary to include 12 months of metric/trending data d. Radiation protection event logs during the period e. Security event logs and security incidents during the period (sensitive information should be made available during the teams first week on sitedo not provide electronically)

f. Employee Concern Program (or equivalent) logs (sensitive information should be made available during the teams first week on sitedo not provide electronically)

g. List of training deficiencies, requests for training improvements, and simulator deficiencies for the period Note: For items 3.d-3.g, if there is no log or report maintained separate from the corrective action program, please provide a summary list of corrective action program items for the category described.

4. Procedures Note: For these procedures, please include all revisions that were in effect at any time during the period.

a. Corrective action program procedures, to include initiation and evaluation procedures, operability determination procedures, apparent and root cause evaluation/determination procedures, and any other procedures that implement the corrective action program at the Wolf Creek Generating Station A-3

b. Quality Assurance program procedures (specific audit procedures are not necessary)

c. Employee Concerns Program (or equivalent) procedures d. Procedures which implement/maintain a safety-conscious work environment 5. Other a. List of risk-significant components and systems, ranked by risk worth b. Organization charts for plant staff and long-term/permanent contractors c. Electronic copies of the UFSAR (or equivalent), technical specifications, and technical specification bases, if available d. Table showing the number of corrective action documents (or equivalent)

initiated during each month of the inspection period, by screened significance e. For each day the team is on site, i. Planned work/maintenance schedule for the station ii. Schedule of management or corrective action review meetings (e.g.

operations focus meetings, condition report screening meetings, Corrective Action Review Boards, MRMs, challenge meetings for cause evaluations, etc.)

iii. Agendas for these meetings Note: The items listed in 5.d may be provided on a weekly or daily basis after the team arrives on site.

All requested documents should be provided electronically where possible. Regardless of whether they are uploaded to an internet-based file library (e.g., Certrecs IMS), please provide copies on CD or DVD. One copy of the CD or DVD should be provided to the resident inspector office at the Wolf Creek Generating Station; three additional copies should be provided to the team lead, to arrive no later than May 28, 2018:

Ray Azua U.S. NRC Senior Reactor Inspector Inspection Program and Assessment Team Division of Reactor Safety, Region IV 1600 E. Lamar Blvd, Arlington, TX 76011 Office: (817) 200-1445 Cell: (817) 319-4376 A-4

ML18218A265 SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002 By: RVA Yes No Publicly Available Sensitive OFFICE SRI:DRS/IPAT SRI:DRS/IPAT RI:DRP/PBC RI:DRP/PBB C:DRP/PBB TL:DRS/IPAT NAME RAzua ERuesch MStafford FThomas NTaylor GGeorge SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 07/19/2018 07/26/2018 07/25/2018 07/26/2018 08/02/2018 08/08/2018