IR 05000482/2018008

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Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans - Inspection Report 05000482/2018008
ML18082A107
Person / Time
Site: Wolf Creek 
Issue date: 03/23/2018
From: Nick Taylor
NRC/RGN-IV/DRP/RPB-B
To: Heflin A
Wolf Creek
Taylor N
References
IR 2018008
Preceding documents:
Download: ML18082A107 (12)


Text

March 23, 2018

SUBJECT:

WOLF CREEK GENERATING STATION - INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS -

INSPECTION REPORT 05000482/2018008

Dear Mr. Heflin:

On January 25, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of this inspection at your Wolf Creek Generating Station. On March 7, 2018, the NRC inspectors discussed the results of this inspection with Mr. J. McCoy, Vice President, Engineering, and other members of your staff. The results of this inspection are documented in the enclosed report.

The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication, Staffing, and Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.

The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

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

Docket: 50-482 License: NPF-42

Enclosure:

Inspection Report 05000482/2018008

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number(s):

05000482

License Number(s):

NPF-42

Report Number(s):

05000482/2017009

Enterprise Identifier: I-2018-008-0003

Licensee:

Wolf Creek Nuclear Operating Corporation

Facility:

Wolf Creek Generating Station

Location:

Burlington, KS

Inspection Dates:

January 22, 2018 to March 7, 2018

Inspectors:

R. Alexander, Sr. Project Engineer (Team Leader)

M. Stafford, Resident Inspector - Cooper

F. Thomas, Resident Inspector - Wolf Creek

M. Tobin, Resident Inspector - Arkansas Nuclear One

Approved By:

Nicholas H. Taylor

Chief, Project Branch B

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting a Temporary Instruction 2515/191, Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/

Staffing/Multi-Unit Dose Assessment Plans at Wolf Creek Generating Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations

No findings were identified.

INSPECTION SCOPES

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

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans

Inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Agencywide Documents Access and Management System (ADAMS) Accession No.

ML12056A045) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS No. ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ADAMS No. ML12053A340) and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS No.

ML12339A262).

(1) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals [including the Final Integrated Plan (ADAMS Accession No. ML17026A194)] and the associated safety evaluation (ADAMS No. ML17144A009) and determined that the licensee is in compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. The inspectors verified the licensee satisfactorily:

a) developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events; b) integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures; c) protected FLEX equipment from site-specific hazards; d) developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; e) trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and f) developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.

(2) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals [including the Final Integrated Plan (ADAMS Accession No.

ML17026A194)] and the associated safety evaluation (ADAMS No. ML17144A009) and determined that the licensee is in compliance with NRC Order NRC Order EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation.

The inspectors verified the licensee satisfactorily :

a) installed the spent fuel pool (SFP) instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation; b) installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; c) trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and d) developed and issued procedures for maintenance, testing and use of the reliable SFP instrumentation.

(3) The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter (ADAMS No. ML12053A340), and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 in response to a large scale natural emergency event that results in an extended loss of all ac power to all site units and impedes access to the site The inspectors verified the following:

a) the licensee satisfactorily implemented required staffing changes to support an extend loss of all AC power (ELAP)/loss of ultimate heat sink (LUHS) scenario; b) EP communications equipment and facilities are sufficient for dealing with an ELAP/LUHS scenario; and c) the licensee implemented multi-unit/-source dose assessment capabilities (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.

The inspectors verified that non-compliances with requirements and standards identified during the inspection were entered into the licensee's corrective action program as appropriate.

EXIT MEETINGS AND DEBRIEFS

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

  • On January 25, 2018, the inspection team presented the on-site inspection results in a management debrief to Mr. J. McCoy, Vice President, Engineering, and other members of the site staff.
  • On March 7, 2018, the inspection team leader presented the final inspection results in a telephonic exit meeting to Mr. J. McCoy, Vice President, Engineering, and other members of the site staff.

DOCUMENTS REVIEWED

Other Activities - TI 2515/191

Procedures/Instructions

Number

Title

Revision

AP 16B-003

Planning and Scheduling Preventative Maintenance

8A

AP 21A-002

Diverse and Flexible Coping Mitigation Strategies

(FLEX) Program

AP 21A-002

Diverse and Flexible Coping Mitigation Strategies

(FLEX) Program

EC LI-59/60

Operating Instruction: FLEX Spent Fuel Pool Level

Backup Power

EMG C-0

Loss of All AC Power

EMG C-0

Loss of All AC Power

EPP 06-012

Dose Assessment

14D

EPP 06-018

Maintenance of Emergency Facilities and

Communications Checks

FD510

FLEX 500 KW Generator #1, Operating Instruction

FD-FIP-001

Wolf Creek Generating Station Diverse and Flexible

Coping Mitigation Strategies Final Integrated Plan

FSG-03

Alt Low Pressure FW Source

FSG-04

ELAP [Extended Loss of AC Power] DC [Direct

Current] Load Shed/Management

FSG-05

Initial Assessment and FLEX Equipment Staging

FSG-06

Alt CST Makeup

FSG-07

Loss of Vital Instrumentation or Control Power

FSG-11

Alternate SFP Makeup Cooling

FSG-12

Alt Containment Cooling in Modes 5 and 6

OFN NB-034

Loss of All AC Power - Shutdown Condition

OFN SG-048

Flash Flood Warning

PFD610

FLEX RCS Pump #1 Operating Instruction

SATCOM

Satellite Phone System Operating Instruction

SYS FD-001

Operations Monthly FLEX Tasks

SYS FD-002

Operations Annual FLEX Tasks

SYS OPS-008

Cold Weather Operations

WCCH-06

Running EDCP When the Computer Network is

Unavailable

Preventative Maintenance Activities

Number

Title

Revision

16-411046-019

Perform a functional test and inspection PM of FLEX

Portable 6000W Generator Diesel Engine Driven,

FD100A.

11/17/2016

16-415695-001

Functional Test and Inspection - FLEX Spent Fuel

Pool Pump #1 (90 day)

8/28/2016

Number

Title

Revision

16-416987-000

FLEX CAT 924K Wheel Loader Warranty Service

8/25/2016

17-421260-001

PFD611 - (1092 day) Performance Test of the FLEX

RCS Pump #2

{None}

17-421376-000

CFD620 - (1092 day) Perform Oil and Filter

Replacement and Maintenance of the FLEX Electric

Driven Air Compressor #1

{None}

17-421387-000

FD510 - (1092 day) Perform Inspection, Battery

Replacement, and Unloaded Run of the FLEX 500KW

Generator #1

1/17/2018

17-422130-001

Annual Operational Testing for Spent Fuel Pool Pump

  1. 2

9/7/2017

17-422144-001

Annual Coolant Testing for Spent Fuel Pool Pump #2

7/22/2017

17-422146-000

PFD6010 - (364 day) Component Operational

Inspection of the FLEX RCS Pump #1

8/16/2017

17-422192-001

Quarterly Functional Testing for Spent Fuel Pool Pump

  1. 2

9/15/2017

17-423378-000

CFD620 - (364 day) Functional Test and Inspection of

the FLEX Electric Driven Air Compressor #1

11/9/2017

17-423378-004

CFD621 - (364 day) Functional Test and Inspection of

the FLEX Electric Driven Air Compressor #2

11/9/2017

17-423385-001

PFD611 - (91 day) Manual Shaft Rotation and

Lubrication of the FLEX RCS Pump #2

9/21/2017

17-424464-000

CFD630 - (364 day) Perform Oil and Filter

Replacement and Maintenance of the FLEX Diesel

Driven Air Compressor #1

10/20/2017

17-424466-001

CFD631 - (364 day) Perform Oil and Filter

Replacement and Maintenance of the FLEX Diesel

Driven Air Compressor #2

11/3/2017

17-424534-000

Perform Normal PM (Two Point) Calibration of

ECLPL0059 per CWI INC EC-0059

11/21/2017

17-424534-001

Perform Normal PM (Two Point) Calibration of

ECLPL0060 per CWI INC EC-0060

11/21/2017

17-424658-000

Troubleshoot EC LI-60

3/27/2017

17-424713-000

PFD611 - (As Required) Perform the Return to

Standby Maintenance for the FLEX RCS Pump #2

{None}

17-425351-000

FD102A - (364 day) Perform Functional Test and

Inspection of the FLEX Generator, Gasoline Engine

Driven w/Light Kit

2/14/2017

17-425352-001

SFD701 - (364 day) Perform Trailer and Axle

Inspection of the FLEX 480V Cable Trailer #2.

11/30/2017

17-426699-000

QF020, QF021, QF022 - Electrical PM for E-Plan

Satellite Telephone Power Supplies and battery

replacement

2/12/2017

17-428359-000

Spent Fuel Pool Level Instrumentation System UPS

Backup Battery Replacement (ECLQY0059) Work with

17-424505-000

2/19/2017

Number

Title

Revision

17-431110-001

Replace existing "short" cable with new 150' cable, in

support of resolution to CR #00114670

2/21/2017

17-433235-000

FD510 - (91 day) Perform Functional Test and

Inspection of the FLEX 500KW GENERATOR #1

11/6/2017

17-433728-000

Troubleshoot FLEX Spent Fuel Pool Level UPS

2/19/2017

Training Documents

Number

Title

Revision

Security FLEX Update

{None}

GE0035601

E-Plan Training - Generic Basic FLEX Cert

1/22/2014

GE0035602

E-Plan Training - Generic Advanced FLEX Cert

1/22/2014

GE1135662

2017 Table Top Series II - FLEX

GE1235626

E-Plan Training - Topics in E-Plan Communications

6/27/2017

GE5251601

E-Plan Training - Decision Making Under Stress

6/14/2017

LO1752001

Licensed Operator Training - Diverse and Flexible

Coping Mitigation Strategies (FLEX) Program

4/21/2016

MI1203301

I&C Training - Guided Wave Radar (Spent Fuel Level

Indication System)

7/28/2015

MJ8310501

Mechanical Training - FLEX

2/15/2016

OP1352001

Operations Training - FLEX Project Overview

7/11/2016

OP8352002

Operations Training - Alternate Instrument Monitoring

and Control - FLEX

5/19/2016

OP8352003

Operations Training - FLEX Overview Seminar

9/7/2017

Other Documents/Reports

Number

Title

Revision

Hampel Oil - Standby Fuel Letter

2/20/2017

Study of the Adequacy of the FLEX Buildings

Separation Considering Severe Storms and High Wind

Conditions

5/19/2016

FLEX Support Guideline Validation Process - Revision

3/13/2017

FLEX On-Shift Staffing Assessment - Revision1

1/3/2018

FLEX Support Guideline (FSG) Validation Process

SAFER Response Plan for Wolf Creek Generating

Station

14864

CST Valve House Missile Protection and Seismic

Upgrade

Basic

Engineering

Disposition

Battery Room Ventilation Strategy Post-ELAP in

Extreme Winter Conditions

9/29/2016

Evaluation FD-

17-009

Structural Design for FLEX Storage Buildings

FD-FIP-001

Wolf Creek Generating Station (WCGS) Diverse and

Flexible Coping Mitigation Strategies (FLEX) Final

Integrated Plan

Number

Title

Revision

WCNOC-183

Operations and Maintenance Manual - RCS Pump Cat

Triplex 353 1 HS.AIP Plunger Pump Rated 20 GPM @

1650 Psig

WO1

WCNOC-185

Beyond Design Basis FLEX Equipment, Operation and

Maintenance Manual - 500KW Generator, C15 Model

6/9/2016

WCNOC-189

Operations and Maintenance Manual - Atlas Copco

Portable Diesel Air Compressor Model XAS 90 KD7

WO1

WCNOC-193

Operations and Maintenance Manual - 2015 Polaris

Ranger XP900

WO2

WCNOC-194

Operations and Maintenance Manual - Terex RL4

Light Tower Kubota Diesel Engine

WO1

WM 12-0041

Wolf Creek Nuclear Operating Corporation, Subject:

Docket No. 50482: Wolf Creek Nuclear Operating

Corporation submittal of Emergency Preparedness

Communications Assessment Results in Response to

Request for Information Pursuant to Title 10 of the

Code of Federal Regulations 50.54(f) Regarding

Recommendation 9.3 of the Near-Term Task Force

Review of Insights from the Fukishima Dai-Ichi

Accident

10/31/2012

Corrective Action Program Documents (CRs & Procedure Change Requests [PCRs])

91772

2734

103481

103964

104464

105070

105172

105334

105630

109447

109449

110066

111003

111336

2524

2863

113820

114020

114669

114670

114897

114911

115026

115343

115706

116293

116581

117055

117056

117058

117059

117062

117241

117429

117945

117946

117992

117993

118066

118146

118223

118911

118912*

118913*

118950*

118979*

118980*

118981*

119011*

20160*

PCR 67735*

PCR 67731*

PCR 67729*

PCR 67725*

PCR 67722*

  • - Initiated as a result of this inspection

ML18082A107

SUNSI Review

By: RAlexander/dll/rdr

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available

Keyword:

NRC-002

OFFICE

SPE:DRP/A

RI:DRP/E/ANO

RI:DRP/C/CNS

RI:DRP/B/WC

BC:DRP/B

NAME

RAlexander

MTobin

MStafford

FThomas

NTaylor

SIGNATURE

/RA/

/RA-E/

/RA-E/

/RA-E/

/RA/

DATE

03/08/18

03/19/18

03/08/18

03/20/18

03/23/18