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 Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 03/23/2018
From: Nick Taylor
NRC/RGN-IV/DRP/RPB-B
To: Heflin A
Wolf Creek
Taylor N
References
IR 2018008
Download: ML18082A107 (12)


Text

March 23, 2018 Adam C. Heflin, President, Chief Executive Officer, and Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 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 2

(FLEX) Program

AP 21A-002 Diverse and Flexible Coping Mitigation Strategies 2

(FLEX) Program

EC LI-59/60 Operating Instruction: FLEX Spent Fuel Pool Level 0

Backup Power

EMG C-0 Loss of All AC Power 42

EMG C-0 Loss of All AC Power 42

EPP 06-012 Dose Assessment 14D

EPP 06-018 Maintenance of Emergency Facilities and 13

Communications Checks

FD510 FLEX 500 KW Generator #1, Operating Instruction 3

FD-FIP-001 Wolf Creek Generating Station Diverse and Flexible 2

Coping Mitigation Strategies Final Integrated Plan

FSG-03 Alt Low Pressure FW Source 1

FSG-04 ELAP [Extended Loss of AC Power] DC [Direct 2

Current] Load Shed/Management

FSG-05 Initial Assessment and FLEX Equipment Staging 2

FSG-06 Alt CST Makeup 1

FSG-07 Loss of Vital Instrumentation or Control Power 1

FSG-11 Alternate SFP Makeup Cooling 2

FSG-12 Alt Containment Cooling in Modes 5 and 6 1

OFN NB-034 Loss of All AC Power - Shutdown Condition 30

OFN SG-048 Flash Flood Warning 5

PFD610 FLEX RCS Pump #1 Operating Instruction 3

SATCOM Satellite Phone System Operating Instruction 0

SYS FD-001 Operations Monthly FLEX Tasks 2

SYS FD-002 Operations Annual FLEX Tasks 0

SYS OPS-008 Cold Weather Operations 5

WCCH-06 Running EDCP When the Computer Network is 03

Unavailable

Preventative Maintenance Activities

Number Title Revision

16-411046-019 Perform a functional test and inspection PM of FLEX 11/17/2016

Portable 6000W Generator Diesel Engine Driven,

FD100A.

16-415695-001 Functional Test and Inspection - FLEX Spent Fuel 8/28/2016

Pool Pump #1 (90 day)

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 {None}

RCS Pump #2

17-421376-000 CFD620 - (1092 day) Perform Oil and Filter {None}

Replacement and Maintenance of the FLEX Electric

Driven Air Compressor #1

17-421387-000 FD510 - (1092 day) Perform Inspection, Battery 1/17/2018

Replacement, and Unloaded Run of the FLEX 500KW

Generator #1

17-422130-001 Annual Operational Testing for Spent Fuel Pool Pump 9/7/2017

  1. 2

17-422144-001 Annual Coolant Testing for Spent Fuel Pool Pump #2 7/22/2017

17-422146-000 PFD6010 - (364 day) Component Operational 8/16/2017

Inspection of the FLEX RCS Pump #1

17-422192-001 Quarterly Functional Testing for Spent Fuel Pool Pump 9/15/2017

  1. 2

17-423378-000 CFD620 - (364 day) Functional Test and Inspection of 11/9/2017

the FLEX Electric Driven Air Compressor #1

17-423378-004 CFD621 - (364 day) Functional Test and Inspection of 11/9/2017

the FLEX Electric Driven Air Compressor #2

17-423385-001 PFD611 - (91 day) Manual Shaft Rotation and 9/21/2017

Lubrication of the FLEX RCS Pump #2

17-424464-000 CFD630 - (364 day) Perform Oil and Filter 10/20/2017

Replacement and Maintenance of the FLEX Diesel

Driven Air Compressor #1

17-424466-001 CFD631 - (364 day) Perform Oil and Filter 11/3/2017

Replacement and Maintenance of the FLEX Diesel

Driven Air Compressor #2

17-424534-000 Perform Normal PM (Two Point) Calibration of 11/21/2017

ECLPL0059 per CWI INC EC-0059

17-424534-001 Perform Normal PM (Two Point) Calibration of 11/21/2017

ECLPL0060 per CWI INC EC-0060

17-424658-000 Troubleshoot EC LI-60 3/27/2017

17-424713-000 PFD611 - (As Required) Perform the Return to {None}

Standby Maintenance for the FLEX RCS Pump #2

17-425351-000 FD102A - (364 day) Perform Functional Test and 12/14/2017

Inspection of the FLEX Generator, Gasoline Engine

Driven w/Light Kit

17-425352-001 SFD701 - (364 day) Perform Trailer and Axle 11/30/2017

Inspection of the FLEX 480V Cable Trailer #2.

17-426699-000 QF020, QF021, QF022 - Electrical PM for E-Plan 12/12/2017

Satellite Telephone Power Supplies and battery

replacement

17-428359-000 Spent Fuel Pool Level Instrumentation System UPS 12/19/2017

Backup Battery Replacement (ECLQY0059) Work with

17-424505-000

Number Title Revision

17-431110-001 Replace existing "short" cable with new 150' cable, in 12/21/2017

support of resolution to CR #00114670

17-433235-000 FD510 - (91 day) Perform Functional Test and 11/6/2017

Inspection of the FLEX 500KW GENERATOR #1

17-433728-000 Troubleshoot FLEX Spent Fuel Pool Level UPS 12/19/2017

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 37

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 4/21/2016

Coping Mitigation Strategies (FLEX) Program

MI1203301 I&C Training - Guided Wave Radar (Spent Fuel Level 7/28/2015

Indication System)

MJ8310501 Mechanical Training - FLEX 12/15/2016

OP1352001 Operations Training - FLEX Project Overview 7/11/2016

OP8352002 Operations Training - Alternate Instrument Monitoring 5/19/2016

and Control - FLEX

OP8352003 Operations Training - FLEX Overview Seminar 9/7/2017

Other Documents/Reports

Number Title Revision

Hampel Oil - Standby Fuel Letter 12/20/2017

Study of the Adequacy of the FLEX Buildings 5/19/2016

Separation Considering Severe Storms and High Wind

Conditions

FLEX Support Guideline Validation Process - Revision 3/13/2017

FLEX On-Shift Staffing Assessment - Revision1 1/3/2018

FLEX Support Guideline (FSG) Validation Process 1

SAFER Response Plan for Wolf Creek Generating 2

Station

14864 CST Valve House Missile Protection and Seismic 02

Upgrade

Basic Battery Room Ventilation Strategy Post-ELAP in 9/29/2016

Engineering Extreme Winter Conditions

Disposition

Evaluation FD- Structural Design for FLEX Storage Buildings 0

17-009

FD-FIP-001 Wolf Creek Generating Station (WCGS) Diverse and 2

Flexible Coping Mitigation Strategies (FLEX) Final

Integrated Plan

Number Title Revision

WCNOC-183 Operations and Maintenance Manual - RCS Pump Cat WO1

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

1650 Psig

WCNOC-185 Beyond Design Basis FLEX Equipment, Operation and 6/9/2016

Maintenance Manual - 500KW Generator, C15 Model

WCNOC-189 Operations and Maintenance Manual - Atlas Copco WO1

Portable Diesel Air Compressor Model XAS 90 KD7

WCNOC-193 Operations and Maintenance Manual - 2015 Polaris WO2

Ranger XP900

WCNOC-194 Operations and Maintenance Manual - Terex RL4 WO1

Light Tower Kubota Diesel Engine

WM 12-0041 Wolf Creek Nuclear Operating Corporation, Subject: 10/31/2012

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

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

91772 102734 103481 103964

104464 105070 105172 105334

105630 109447 109449 110066

111003 111336 112524 112863

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* 120160* PCR 67735* PCR 67731*

PCR 67729* PCR 67725* PCR 67722*

  • - Initiated as a result of this inspection

ML18082A107

SUNSI Review Non-Sensitive Publicly Available Keyword:

By: RAlexander/dll/rdr Sensitive Non-Publicly Available 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