IR 05000482/2019002

Integrated Inspection Report 05000482/2019002

ML19225D316
Person / Time
Site:	Wolf Creek
Issue date:	08/13/2019
From:	O'Keefe N NRC Region 4
To:	Heflin A Wolf Creek
References
IR 2019002
Download: ML19225D316 (26)

Text

August 13, 2019

SUBJECT:

WOLF CREEK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000482/2019002

Dear Mr. Heflin:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Wolf Creek Generating Station. On July 11, 2019, the NRC inspectors discussed the results of this inspection with Mr. C. Reasoner, Senior Vice President and Chief Nuclear Officer, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

Further, inspectors documented one licensee-identified violation, which was determined to be Severity Level IV in this report. The NRC is treating this violation as an NCV consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations, or significance or severity of the violations, documented in this inspection report, 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. 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/

Neil F. O'Keefe, Chief Reactor Projects Branch B

Docket No. 50-482 License No. NPF-42

Enclosure:

Inspection Report 05000482/2019002

Inspection Report

Docket Number:

05000482

License Number:

NPF-42

Report Number:

05000482/2019002

Licensee:

Wolf Creek Nuclear Operating Corp.

Facility:

Wolf Creek Generating Station

Location:

Burlington, Kansas

Inspection Dates:

April 1, 2019, to June 30, 2019

Inspectors:

R. Azua, Senior Reactor Inspector

W. Cullum, Reactor Inspector

D. Dodson, Senior Resident Inspector

P. Elkmann, Senior Emergency Preparedness Inspector

G. George, Senior Reactor Inspector

S. Makor, Reactor Inspector

J. Melfi, Acting Resident Inspector

B. Tharakan, Senior Project Engineer

F. Thomas, Acting Senior Resident Inspector

Approved By:

Neil F. O'Keefe, Chief

Reactor Projects Branch B

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Wolf Creek Generating Station in accordance with the Reactor Oversight Process (ROP). 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.

List of Findings and Violations

Failure to Submit a Revision to Section 9.1.4.3 of the Wolf Creek Updated Final Safety Analysis Report Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable NCV 05000482/2019002-01 Open/Closed Not Applicable 71111.17T The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71(e)(4) for the licensees failure to revise Updated Final Safety Analysis Report, Section 9.1.4.3, to reflect changes to the reactor head load drop analysis.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000482/2018-002-00 Modification Activities Affected Control Room Envelope Boundary Causing a Condition Prohibited by Technical Specifications 71153 Closed

PLANT STATUS

Wolf Creek Generating Station began the inspection period operating at full power. On May 24, 2019, licensee conducted an unplanned power reduction to approximately 96 percent power following the loss of the start-up transformer, due to an external fault between cable terminations. After that event, the plant operated at or near full power for the rest of the period.

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 performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Residual heat removal train A on April 9, 2019

(2) Component cooling water train A on June 25, 2019

(3) Safety injection train B on June 25, 2019

(4) Offsite circuit train B on June 28, 2019

71111.04S - Equipment Alignment

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the essential service water system on June 6, 2019.

71111.05A - Fire Protection (Annual)

Annual Inspection (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated fire brigade performance on April 12, 2019.

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01) (4 Samples)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Essential service water pump house A and B, elevation 2,000 feet, fire areas ESW-1 and ESW-2, on June 6, 2019

(2) Auxiliary building, elevation 2,026 feet, fire areas A-27 and A-28, on June 26, 2019

(3) Control building, elevation 2,073 feet, fire area C-22, on June 26, 2019

(4) Fuel building, elevation 2,026 feet, fire areas F-4 and F-5, on June 26, 2019

71111.06 - Flood Protection Measures

Inspection Activities - Underground Cables (IP Section 02.02c.) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Essential service water manhole MHE2B

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during a planned power reduction to approximately 85 percent followed by planned turbine valve testing by under instruction reactor operators on April 25, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated crew performance evaluation activities on April 22, 2019.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness Inspection (IP Section 02.01) (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Train A control room air condition unit SGK04A was declared inoperable due to cylinder head temperature increase on September 11, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Planned maintenance outages for the train B control room air conditioning unit and pressurizer backup heaters on April 3, 2019

(2) Start-up transformer unplanned cable connection repair on May 24, 2019

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02) (2 Samples)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Component cooling water pump A surge tank level decrease on May 6, 2019

(2) Heavy forklift entered heavy load exclusion zone driving over buried trains A and B essential service water supply and return piping on May 23, 2019

71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)

From April 29 to May 2, 2019, the inspectors reviewed the 10 CFR 50.59 safety evaluations, screenings, and/or applicability determinations associated with following changes:

(1) Procedure ALR 00-089B, Diesel Generator Fuel Tank A Level LO, Revision 16 (Applicability Determination)

(2) Calculation JE-J-002, Estimation of Emergency Fuel Oil Storage Tank Level Indication Loop, Revision 0 (Screen)

(3) Design Change Package DCP 14811, Install Piping Support on Pipe KC079KBF-6 to Seismically Qualify Piping, Revision 2 (Screen)

(4) Design Change Package DCP 14780, Replace EDG Crankcase Pressure Transmitter With Gauge, Revision 0 (Screen)

(5) Procedure STS EJ-100B, RHR System Inservice Pump B Test, Revision 46 (Screen)

(6) Minor Change Package MCP 14870, SJHV0137 High Temp Wire, Revision 0 (Screen)

(7) Design Change Package DCP 14520, Replacement for obsolete fisher 7810 valve and 656 actuator, Revision 0 (Screen)

(8) Design Change Package DCP 14788, Containment air cooler coil replacement for SGN01B, Revision 2 (Screen)

(9) Design Change Package DCP 14917, Manual valve installation on SI test header, Revision 0 (Screen)

(10) Design Change Package DCP 20161, Removal of interlock to motor-driven feedwater pump motor start, Revision 0 (Screen)

(11) Procedure SYS EM-121, ECCS Check Valve Leak Check, Revision 0 (Screen)

(12) Procedure SYS EM-200, Safety Injection Operation to Seat Accumulator Line Check Valves, Revision 0 (Screen)

(13) Procedure SYS KJ-300, Removal of EDG support systems, Revision 0 (Screen)

(14) Design Change Package DCP 15081, New RHR Pressure Transmitter EJPT0027 and NPIS Point, Revision 0 (Screen)

(15) Change Package CCP 013192, Replacement Speed Switch and Added Power Supply for Emergency Diesel Generator, Revision 0 (Screen)

(16) Field Change Notice FCN 14209, Square D Masterpact Breaker (GE AKR Replacement) & DCGM01A/B Repowering from NG Load Centers, Revision 7 (Screen)

(17) Design Change Package DCP 14598, Replacement Transformer for XSL2G, Revision 0 (Screen)

(18) Design Change Package DCP 14800, Installation of Digital Out-of-Step Relays, Revision 0 (Screen)

(19) Minor Change Package MCP 15036, Siemens Circuit Breaker Type 5-3AH-GER-350-1200-78 Equivalency for Existing Type 5-3AF-GER-350-1200-78 Breaker, Revision 0 (Screen)

(20) Procedure OFN NB-042, Loss of Offsite Power to NB01 (NB02) with EDG Paralleled, Revision 11 (Screen)

(21) Procedure OFN SB-008, Instrument Malfunctions, Revision 44 (Screen)

(22) Procedure SYS KJ-123, Post Maintenance Run of Emergency Diesel Generator A, Revision 62 (Screen)

(23) Procedure EMG ES-32, Post-SGTR Cooldown Using Blowdown, Revision 19 (Screen)

(24) Procedure EMG CS-02, Loss of All AC Power Recovery with SI Required, Revision 24 (Screen)

(25) Procedure OFN SG-003, Natural Events, Revision 36 (Screen)

(26) Evaluation No. 59 2016-0002, Dedicated Operator to Support Maintenance Activity on GKD0081, Revision 0 (Evaluation)

(27) Evaluation No. 59 2017-0001, Install Open Phase Detection (OPD) on Startup Transformer and OPD Trip Function for No. 7 Transformer, Revision 0 (Evaluation)

(28) Evaluation No. 59 2018-0001, Radiological Consequences of a Fuel Handling Accident in the Fuel Handling Building during Can Sipping, Revision 0 (Evaluation)

(29) Evaluation No. 59 2017-0002, Wolf Creek Generating Station Simplified Head Assembly Drop Analysis Revision, Revision 1 (Evaluation)

(30) Evaluation No. 59 2018-0002, Change SR Detector Actuation from Automatic to Manual, Revision 0 (Evaluation)

(31) Evaluation No. 59 2018-0003, Operation of Class 1E Compensatory Cooling during Post-Modification Testing, Revision 1 (Evaluation)

(32) Evaluation No. 59 2017-0003, Temporarily Secure Cavity Cooling Fans to Support NI-31 Degraded Cooling Issue, Revision 0 (Evaluation)

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Design Equivalent Change Package 020280 to approve use "as is" for terminal lug on start-up transformer low voltage bushing

(2) Temporary Modification TMO-19-002-BG, "Leak Sealant Injection for Internal Leakage Through BGV0214," associated with the regenerative heat exchanger

71111.19 - Post-Maintenance Testing

Post Maintenance Test Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Pressurizer backup heater group B testing following planned maintenance on April 3, 2019

(2) Residual heat removal pump suction from the refueling water storage tank valve (BNHV8812A/B) testing following emergent maintenance on April 9, 2019

(3) Start-up transformer XMR01 testing following emergent maintenance on May 27, 2019

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

FLEX Testing (IP Section 03.02)

(1) FLEX equipment testing - 150 KW and 500 KW diesel generator loaded test runs on June 11, 2019

Inservice Testing (IP Section 03.01) (2 Samples)

(1) STS EJ-201B, "Train B [Residual Heat Removal] System Inservice Valve Test," on Aril 8, 2019

(2) STS AL-210D, "[Auxiliary Feedwater] Inservice Check Valve Test," on June 5, 2019

Surveillance Tests (other) (IP Section 03.01) (4 Samples)

(1) STS IC-260, "Channel Operation Test Auxiliary Feedwater Pump Suction Pressure Low Transfer to [Essential Service Water]," on April 1, 2019

(2) STS GG-001A,"Emergency Exhaust Filtration System Train A Operability Test," on April 18, 2019

(3) STS IC-805B, "Channel Calibration of NB02 Grid Degraded Voltage, Time Delay Trip," on May 7, 2019

(4) STS IC-615B, "Slave Relay Test K615 Train B Safety Injection," on June 3, 2019

71114.08 - Exercise Evaluation Scenario Review

Inspection Review (IP Section 02.01 - 02.04) (1 Sample)

The inspectors reviewed the licensee's preliminary exercise scenario which was submitted to the NRC on March 28, 2019. The inspectors discussed the preliminary scenario with Mr. M. Dekat, Superintendent, Emergency Planning, on April 29, 2019. The inspectors' review does not constitute NRC approval of the scenario.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS07: High Pressure Injection Systems (IP Section 02.06)===

(1) July 1, 2018, through June 30, 2019

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) July 1, 2018, through June 30, 2019

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (2 Samples)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in the area of safety conscious work environment (SCWE) and mitigating system performance indicator accounting and reporting that might be indicative of more significant safety issues.

(2) The inspectors reviewed the licensees corrective action program for trends in human performance and equipment reliability that might be indicative of more significant safety issues.

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000482/2018-002-00, "Modification Activities Affected Control Room Envelope Boundary Causing a Condition Prohibited by Technical Specifications" (ADAMS Accession: ML19065A049). The circumstances and performance deficiency surrounding this LER are documented in Section

71152 - Problem Identification and

Resolution of Inspection Report 05000482/2018003.

INSPECTION RESULTS

Observation: Semiannual Trend Review 71152 The inspectors reviewed the licensees corrective action program for trends in the area of SCWE.

SCWE

The NRC conducted several inspections during the assessment period to assess the corrective actions taken to address the existing SCWE cross-cutting theme, including observations made in a Problem Identification and Resolution Inspection (Inspection Report 05000482/2018007 (ADAMS ML18218A265)) and a quarterly Integrated Inspection (Report 05000482/2018004 (ADAMS ML19042A089)). Based on these inspections and review of the licensees actions taken and planned, as well as the issuance of the violation of 10 CFR 50.7, the NRC determined that a theme in the SCWE area continued to exist.

Consistent with NRC guidance, the licensees progress on addressing the SCWE theme will be reviewed on a semiannual basis. During the current inspection, the inspectors review included consideration of previous NRC reviews of the licensees progress in addressing the SCWE theme, recent actions that Wolf Creek has completed or planned to address the cross-cutting theme in the SCWE area, and consideration of recent enforcement actions taken by the NRC.

The inspectors reviewed approximately 60 condition reports during this effort that were directly or potentially related to SCWE. The number of condition reports from June 2018 to December 2018 were compared against the number of SCWE condition reports that were written between January 2019 to June 2019, the specific content of the SCWE condition reports was evaluated, and the number of anonymous SCWE condition reports was assessed.

Assessment

With regard to actions taken to address the cross-cutting theme in the SCWE area, it appears that the licensee is applying the corrective actions as described in their identified plan. Many of the corrective actions taken include senior management presentations to the staff (referred to as Blitzes), group training for managers, group training for employees, and procedural changes. These activities (Blitzes, training and procedural changes) are not yet complete, and the licensee has not yet evaluated the effectiveness of these actions. The inspectors reviewed the licensees actions and did not identify any significant concerns.

Regarding the trend of SCWE-related condition reports, there did appear to be an increase in number compared to previous time periods. Upon review, the inspectors determined that the increase in number of SCWE-related condition reports coincided with the scheduled management presentations on SCWE (Blitzes), indicating that the topic was gaining more attention across the site. A closer review of these condition reports identified a number that would fall into the Non-Condition Adverse to Quality (NCAQ) category. The inspectors concluded that the increase in SCWE-related condition reports was not unusual and did not represent a degradation in the licensees SCWE. However, the inspectors noted that the number of anonymous condition reports did not appear to decrease, indicating that there are still employees who do not feel comfortable bringing their concerns directly to their management.

Observation: Semiannual Trend Review 71152 The inspectors reviewed the licensees corrective action program for trends in human performance and equipment reliability that might be indicative of more significant safety issues.

Human Performance

During this past quarter, the licensee experienced multiple human performance issues associated with procedure implementation. The following condition reports were written for events that have occurred in the quarter:

• CR 132789 and CR 132791 - On May 29, 2019, during maintenance work to replace batteries associated with an uninterruptable power supply for security related facilities, the site experienced a loss of power to the main security building. Human error was determined to be the cause. Specifically, while implementing maintenance procedures to align equipment for battery replacement, technicians accidentally disconnected power to the main security building.

• CR 132303: On May 9, 2019, while performing chemical and volume control system diaphragm valve torqueing and post maintenance tests for the boron thermal regeneration system (BTRS) in preparation for the outage, operators identified that letdown flow unexpectedly went to 0 gallons per minute during a valve stroke. Logs indicate that operators returned the subject valve to the closed position, which restored letdown flow to the initial value. Further investigation revealed that the procedure did not direct operators to place the subject valve in manual. The cause was determined to be lack of adequate rigor during the procedure change process.

• CR 132451: On May 8, 2019, maintenance technicians completed a clean and inspect work order in the wrong cabinet on the BTRS. The technicians were signed on to the appropriate clearance order for the work order they were using. However, the labeling for the two cabinets was unclear, and the technicians did not stop to resolve which was the correct cabinet, which led to the technicians performing work in the wrong cabinet.

• CR 131452: On April 10, 2019, while performing a post-maintenance test on the B instrument air compressor, a control room operator failed to verify that the train B essential service water supply valve to the B instrument air compressor was open. The compressor had been filled and vented, but there was no cooling water flow through the compressor. Thus, when the compressor was started and loaded, it tripped on high temperature.

On May 16, 2019, CR132471 was initiated by the licensee to document an adverse trend in maintenance performance. Condition Reports 132451 and 132791 were added to CR 132471 as examples for the trend analysis. This condition report concluded that the maintenance organization demonstrated less than adequate performance due to inattention to detail and mis-judgement. It also concluded that individuals rationalized proceeding in the face of uncertainty instead of stopping when unsure. Furthermore, on April 11, 2019, CR 131489 was initiated to document a site trend for failure to use effective human performance error reduction tools. All of the above mentioned human performance issues have a commonality of a lack of attention to detail in implementing procedures.

Overall, inspectors determined that the licensee has adequately captured the above issues in their corrective action program. Also, the licensee has taken timely action to identify a low-level trend in human performance and implement corrective actions.

Equipment Reliability - Communications Issues with Radiation Monitors

In May and June 2019 the licensee experienced several instances of system communications failures that led to the inoperability of safety-related radiation monitors. These issues were documented in the following condition reports, that were written within one month:

• CR 132680: On May 23, 2019, the train A fuel building exhaust radiation monitor (GGRE0027) was declared inoperable due to having lost communications from field computer point (RM-80) to the control and display panel in the control room (RM-23).

• CR 133199: On June 13, 2019, operators declared the train B fuel building exhaust radiation monitor (GGRE0028) inoperable due to communications failure experienced while performing channel operational testing on GGRE0028.

• CR 133212: On June 17, 2019, the licensee declared the train A control building supply air radiation monitor (GKRE0005) inoperable due to a communications failure. Technical Specification 3.3.7, Condition A required operators to place one train of Control room emergency ventilation system in control room ventilation isolation mode.

• CR 133314: On June 19, 2019, the licensee identified that five radiation monitors had exceeded their established Maintenance Rule performance criteria for cumulative unavailability. The three-aforementioned safety-related radiation monitors were included in the five radiation monitors reviewed in this condition report.

The above-mentioned issues with the GGRE0027, GGRE0028, and GKRE0005 radiation monitors, have a commonality of communications failure. These failures indicate a low-level trend for decreasing radiation monitor reliability combined with a trend of increased unavailability time for radiation monitors. The inspectors noted that these trends appeared to indicate a lack of priority for radiation monitor repair.

Failure to Submit a Revision to Section 9.1.4.3 of the Wolf Creek Updated Final Safety Analysis Report Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000482/2019002-01 Open/Closed Not Applicable 71111.17T The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71(e)(4) for the licensees failure to file a revision of Section 9.1.4.3, Safety Evaluation, of the Wolf Creek Final Safety Analysis Report, which reflected changes to the reactor head load drop analysis.

Description:

Section 9.1.4.3 of the Wolf Creek Updated Final Safety Analysis Report contains the safety evaluation for various fuel handling system accidents. One of the fuel handling accidents postulated is a fuel handling accident caused by a drop of the reactor vessel head caused by failure of the polar crane. Updated Final Safety Analysis Report (UFSAR),page 9.1-53 to page 9.1-70, contain the analysis methodology, accident cases, input assumptions such as weight and dissipation factors, and results for the postulated drop of the reactor vessel head assembly.

In November 2017 the licensee approved Calculation 0720517.01-C-001, Wolf Creek Generating Station (WCGS) Simplified Head Assembly (SHA) Drop Analysis, Revision 1. This calculation updated the previous reactor vessel head drop analysis to include an increased reactor vessel head assembly weight due to insulation changes and addition of canopy seal clamp assemblies. Additionally, inputs for the reactor vessel weight, reactor vessel nozzle stiffness, support stiffness, and energy dissipation factors were changed to produce more conservative results. These analyses were performed with two new accident cases at drop heights of 28.5 feet and 32 feet above the vessel flange, respectively. The change to design inputs resulted in the calculation results being more conservative than the results reflected in the UFSAR Section 9.1.4.3 for bending stress, vessel nozzle displacement, and support displacement. To support the calculation changes, the licensee completed a 10 CFR 50.59 safety evaluation (approved in December 2017) to determine that the change in design inputs and results would not require a license amendment from the NRC.

Step 6.2.1 of Procedure AP 26A-003, 10 CFR 50.59 Reviews, directs the licensee to initiate a change to the UFSAR if the proposed change causes the existing information in the UFSAR is no longer correct. However, during the May 2019 NRC inspection, the inspectors identified that the action to update the UFSAR was still open and no revision to UFSAR, Section 9.1.4.3, was being actively pursued.

Since the change to the reactor vessel head drop analysis in the UFSAR was approved, the licensee has submitted two annual revisions of the UFSAR to the NRC, in March 2018 and on March 11, 2019. Title 10 CFR 50.71(e) requires annual updates to the UFSAR which reflect all changes up to a maximum 6 months prior to the date of filing. In this case, the licensee failed to submit a revision of UFSAR, Section 9.1.4.3, in their March 11, 2019, submittal (ADAMS Accession No. ML19092A099).

Corrective Actions: The licensee entered the issue into the corrective action program to generate a Final Safety Analysis Report change request.

Corrective Action References: Condition Report 132010

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency. The licensees failure to meet Procedure AP 26A-003, 10 CFR 50.59 Reviews, Revision 14, Step 6.2.1 to initiate a change to the UFSAR when a change makes the existing UFSAR information no longer correct was a performance deficiency.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.

Severity: Because this performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, it is necessary to address this violation using traditional enforcement to adequately deter non-compliance. Using the NRC Enforcement Policy, dated May 15, 2018, the violation was determined to be a Severity Level IV violation in accordance with Section 6.1.d.3, because the lack of up-to-date information in the UFSAR had not resulted in any unacceptable changes to the facility or procedures.

Violation: Title 10 CFR Part 50.71(e) requires, in part, each person licensed to operate a nuclear power reactor under the provisions of § 50.21 or § 50.22, and each applicant for a combined license under Part 52 of this chapter, shall update periodically, as provided in paragraphs (e)(3) and

(4) of this section, the Final Safety Analysis Report (FSAR) originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the applicant or licensee or prepared by the applicant or licensee pursuant to Commission requirement since the submittal of the original FSAR, or as appropriate, the last update to the FSAR under this section. The submittal shall include the effects of all changes made in the facility or procedures as described in the FSAR; all safety analyses and evaluations performed by the applicant or licensee either in support of approved license amendments or in support of conclusions that changes did not require a license amendment in accordance with § 50.59(c)(2) or, in the case of a license that references a certified design, in accordance with § 52.98(c) of this chapter; and all analyses of new safety issues performed by or on behalf of the applicant or licensee at Commission request.

Title 10 CFR Part 50.71(e)(4) requires, in part, subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months. The revisions must reflect all changes up to a maximum of 6 months prior to the date of filing.

Contrary to the above, on March 11, 2019, the licensee made a subsequent revision to the UFSAR and failed to include all changes up to a maximum of 6 months prior to the date of filing. Specifically, on March 11, 2019, the licensee failed to update FSAR Section 9.1.4.3 to reflect the effects of a December 2017, § 50.59 safety evaluation which concluded that changes to the safety analysis for the postulated drop of the reactor vessel head during refueling activities would not require a license amendment.

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

Licensee Identified Non-Cited Violation 71152 Problem Identification and Resolution This violation of very low safety-significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Title 10 CFR Part 50.71

(e) requires, in part, that each person licensed to operate a nuclear power reactor under the provisions of § 50.21 or § 50.22, and each applicant for a combined license under part 52 of this chapter, shall update periodically, as provided in paragraphs (e)

(3) and

(4) of this section, the Final Safety Analysis Report (FSAR) originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the applicant or licensee or prepared by the applicant or licensee pursuant to Commission requirement since the submittal of the original FSAR, or as appropriate, the last update to the FSAR under this section. The submittal shall include the effects of all changes made in the facility or procedures as described in the FSAR; all safety analyses and evaluations performed by the applicant or licensee either in support of approved license amendments or in support of conclusions that changes did not require a license amendment in accordance with § 50.59(c)(2) or, in the case of a license that references a certified design, in accordance with § 52.98(c) of this chapter; and all analyses of new safety issues performed by or on behalf of the applicant or licensee at Commission request.

Title 10 CFR Part 50.71(e)(4) requires that subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months. The revisions must reflect all changes up to a maximum of 6 months prior to the date of filling.

Contrary to the above, between March 11, 2017 and March 11, 2019, the licensee made two subsequent revisions to the UFSAR and the changes did not reflect all changes up to a maximum of 6 months prior to the date of filing. Specifically, the licensee failed to update FSAR Section 13.2.2 to reflect the removal of requirements for six preplanned lecture series during a two-year training cycle for Nuclear Station Operators (NSOs) and two preplanned lecture series during a two-year training cycle for Treatment Systems Operators (TSOs).

Significance/Severity Level: Using the NRC Enforcement Policy, dated May 15, 2018, the violation was determined to be a Severity Level IV violation in accordance with Section 6.1.d.3, because the lack of up-to-date information in the UFSAR had not resulted in any unacceptable changes to the facility or procedures.

Corrective Action Reference(s): Condition Reports 127609, 133798, and

EXIT MEETINGS AND DEBRIEFS

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

• On May 2, 2019, the inspectors presented the Inspection Procedure 71111.17T, Evaluations of Changes, Tests, or Experiments, results to Mr. J. McCoy, Site Vice President, and other members of the licensee staff.

• On July 11, 2019, the inspectors presented the integrated inspection results to Mr. C. Reasoner, Sr. Vice President and Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Corrective Action

Documents

Condition Report

133555

Drawings

M-12EG01

Piping & Instrumentation Diagram Component Cooling

Water Storage System

M-12EJ01

Piping and Instrumentation Diagram Residual Heat Removal

System

M-12EM01

Piping & Instrumentation Diagram High Pressure Coolant

Injection System

Procedures

CKL EF-120

Component Cooling Water System Valve, Switch and

Breaker Lineup

CKL EJ-120

RHR System Lineup

CKL EM-120

Safety Injection System Valve, Switch and Breaker Lineup

71111.04S

CKL EF-120

Essential Service Water Valve, Breaker and Switch Lineup

71111.05A

Miscellaneous

APF 10-105-02

Fire Drill Scenario and Critique Report

04/12/2019

71111.05Q Corrective Action

Documents

Condition Report

131029

Miscellaneous

Fire Hazard Analysis

Procedures

AP 10-106

Fire Preplans

18A

71111.06

Work Orders

17-434627-003

71111.11Q Corrective Action

Documents

Condition Report

131888

Miscellaneous

A18-048

SMP Brief Description - 'A' MFRV Has Full Open Indication

in the Plant

07/12/2018

LR 4412801

Simulator Scenario

04/22/2019

Procedures

AP 21-001

Conduct of Operations

83A

STS AC-001

Main Turbine Valve Cycle Test

54A

71111.12

Miscellaneous

System Health Report: GK - Control Building HVAC

04/01/2016

to

06/30/2016

System Health Report: GK - Control Building HVAC

01/01/2018

to

06/30/2018

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

System Health Report: GK - Control Building HVAC

01/01/2017

to

06/30/2017

System Health Report: GK - Control Building HVAC

01/01/2016

to

03/31/2016

System Health Report: GK - Control Building HVAC

07/01/2016

to

2/31/2016

System Health Report: GK - Control Building HVAC

07/01/2017

to

2/31/2017

Maintenance Rule Final Scope Evaluation: System GK -

Control Building HVAC System, Function GK-01

07/22/2019

Maintenance Rule Final Scope Evaluation: System GK -

Control Building HVAC System, Function GK-03

07/22/2019

Maintenance Rule Final Scope Evaluation: System GK -

Control Building HVAC System, Function GK-04

07/22/2019

Maintenance Rule Final Scope Evaluation: System GK -

Control Building HVAC System, Function GK-05

07/22/2019

Maintenance Rule Final Scope Evaluation: System GK -

Control Building HVAC System, Function GK-02

07/22/2019

EDI 23M-050

Engineering Desktop Instruction Monitoring Performance to

Criteria and Goals: Justification for Considering a Functional

Failure not an MPFF - CR 126508

10/11/2018

Work Orders

15-400195-010, 18-444800-000, 18-444800-001, 18-

444800-002, 18-444800-003, 18-444800-004, 18-444800-

005, 18-444800-006, 18-444800-007, 18-444800-008, 18-

444800-009, 18-444800-011, 18-444800-012, 18-444800-

013

71111.13

Miscellaneous

APF 22C-003-01

On-Line Nuclear Safety and Generation Risk Assessment:

Schedule Week 19-0201

2/12/2019

Procedures

STS NB-005

Breaker Alignment Verification

34A

71111.15

Corrective Action

Condition Report

131981

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

Miscellaneous

Operations Archive Log

04/27/2019

to

05/07/2019

APF 30B-004-01

Essential Required Reading - Op Eval of EF-19-001

05/24/2019

WCRE-03

Wolf Creek Tank Document

71111.17T

Corrective Action

Documents

Condition Reports 91552, 106725, 132010, 132040

Drawings

E-13KJ01A

Schematic Diagram Diesel Generator KJ01A Engine Control

(Start/Stop Circuit)

E-13KJ01B

Schematic Diagram Diesel Generator KKJ01A Engine

Control (D/G Trips)

E-13KJ02

Schematic Diagram Diesel Generator KKJ01A Annunciator

and Miscellaneous Circuits

M-12EM01

Piping and Instrumentation Diagram High Pressure Coolant

Injection System

M-12KJ03

Piping and Instrumentation Diagram Standby Diesel

Generator "A" Lube Oil System

M-12KJ03

Piping and Instrumentation Diagram Standby Diesel

Generator "A" Lube System

M-627A-00108

Schedule for Q Listed Dampers

Miscellaneous

DCP 014520

Replacement for Obsolete Fisher 7810 Valve and Actuator

DCP 014788

Containment Air Cooler Replacement for SGN01B

DCP 014917

Manual Valve Installation on SI Test header

DCP 020060

Change SR Detector Actuation from Automatic to Manual

DCP 020161

Removal of Interlock to Motor Driven Feedwater Pump Motor

Start

DCP 13192

Replacement Speed Switch & Added Power Supply for

Emergency Diesel Generator

DCP 14209

Square D Masterpact Breaker (GE AKR Replacement) &

DCGM01A/B Repowering from NG Load Centers

DCP 14570

Install Open Phase Detection on Startup Transformer and

OPD Trip Function for No. 7

DCP 14598

Replacement Transformer for XSL2G

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

DCP 14800

Installation of Digital Out of Step Relays

DCP 15036

Siemens Circuit Breaker Type 5-3AH-GER-350-1200-78

Equivalency for Existing Type 5-3AF-GER-350-1200-78

Breaker

DCP 15081

New RHR Pressure Transmitter EJPIT0027 and NPIS Point

DCP 20060

Change SR Detector Actuation from Automatic to Manual

M-627A-00078

Instruction Manual for Dampers American Warming and

Ventilation

W08

QH-201901796

50.59 Pre-Inspection Self-Assessment

04/15/2019

SWO 12-350418-

24

Evaluation for Allowing Securing SGN01B when

Containment Temperature is Greater than 95°F

SWO 16-417067-

008

Required Function of GKD0081

08/30/2016

Procedures

AI 26A-003

Regulatory Evaluations (Other Than 10 CFR 50.59)

ALR 00-77E

SR HI VOLT FAIL

AP 26A-003

CFR 50.59 Reviews

CKL EM-120

Safety Injection System Lineup Checklists

GEN 00-002

Cold Shutdown to How Standby

2

GEN 00-003

Hot Standby to Minimum Load

101

GEN 00-005

Minimum Load to Hot Standby

OFN MA-038

Rapid Plant Shutdown

OFN NB-042

Loss of Offsite Power to Nb01 (Nb02) With EDG Paralleled

OFN SB-008

Instrument Malfunctions

STN AE-007

Startup Main Feedwater Pump Operational Test

2A

SYS DF-120

Rod Control System Operation

SYS EM-121

ECCS Check Valve Leak Check

SYS EM-200

Safety Injection Operation to Seat Accumulator Line Check

Valves

SYS GK-122

Manual CRVIS Line-Up

SYS KJ-123

Post Maintenance Run of Emergency Diesel Generator AV

SYS KJ-300

Removal of EDG Support Systems

71111.18

Corrective Action

Documents

Condition Report

133162

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Drawings

M-12BG01

Piping and Instrumentation Diagram - Chemical and Volume

Control System

M-12BG01

Piping & Instrumentation Diagram Chemical and Volume

Control System

M-12LF09

Piping and Instrumentation Diagram Reactor Bldg and Hot

Machine Shop Floor and Equipment Drain System

M-13BG26

Piping Isometric - CVCS Cation, Mixed Bed Demineralizers

"A" and "B" - Aux Bldg.

M-13BG26

Small Piping Isometric Chemical and Volume Control

System Reactor Building

Miscellaneous

HVT Series Termination 5-35kV Class - High Voltage

Termination for Copper Tape, Wire Shield, Lead Sheath and

UniShield Cable

08/18/1998

20280

Design Equivalent Change Package: Damaged Terminal

Lug on Startup Transformer Low Voltage Bushing

APF 05C-004-01

Basic Engineering Disposition: XMR01 Startup Transformer

Testing Acceptance - CR132693

05/27/2019

APF 29B-003-01

Surveillance Test Routing Sheet (STRS): RCS Water

Inventory Balance Using the NPIS Computer

06/12/2019

APF 29B-003-01

Surveillance Test Routing Sheet (STRS): RCS Water

Inventory Balance Using the NPIS Computer

06/13/2019

APF 29B-003-01

Surveillance Test Routing Sheet (STRS): RCS Water

Inventory Balance Using the NPIS Computer

06/14/2019

E-003.3-00030

Instruction Manual for Power Transformers

W15

E-003.3-00054

Westinghouse Electric Corporation Instructions for Forced-

Air Cooling Equipment Unit Fan Assembly

W01

FSC-N-6B

Compound Information Sheet: Furmanite

IP-ENG-001

Standard Design Process

RPF 02-210-01

WCGS Radiological Survey Map - Survey M-20190612-9

06/12/2019

TMO 19-002-BG

Design Equivalent Change Package - Temporary

Modification Order (TMO) - Leak Sealant Injection (MPM LR-

001) For Internal Leakage Through BGV0214

TMO 19-002-BG

Design Equivalent Change Package: Leak Sealant Injection

(MPM LR-001) for Internal Leakage Through BGV0214

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

AP 21I-001

Temporary Configuration Changes

MPE MR-002

Start-Up Transformer Maintenance Activities

MPE XF-001

Transformer (COPS) Visual and Fan Test Run Inspection

MPM LR-001

Leak Sealant Injection

RM-3-010

Connecting 37pt. CT Junction Block

Work Orders

18-440283-002

18-440283-003

71111.19

Miscellaneous

Generic Letter 95-07, "Pressure Locking and Thermal

Binding of Safety-Related Power Operated Gate Valves" -

Wolf Creek Generating Station Unit 1 (TAC No. M93540)

09/02/1999

18-441116-001

Votes Infinity Valve Diagnostic System: Rising Stem Thrust

Evaluation

04/09/2019

96-48

Information Notice 96-48, Supplement 1: Motor-Operated

Valve Performance Issues

07/24/1998

98-00810

Technical Update 98-01 and Technical Update 98-01

Supplement #1

07/17/1998

APF 05-002-01

Engineering Screening: 09120

APF 05-002-05

Engineering Disposition: Margin Optimization for Motor

Operated Valves EJHV8804A & EJHV8804B

APF 05-002-05

Engineering Disposition: Margin Optimization for Motor

Operated Valves BNHV8812A & BNHV8812B

APF 05-002-05

Engineering Disposition: MOV Thrust/Torque Per Limitorque

Technical Update 98-01 & Supplement 1

APF 05-002-06

Change Package: Configuration Item Identification &

Reference Form

APF 05-002-07

Pre-implementation Planning Review: 09120

APF 05D-001-01

Calculation Cover Sheet: Thrust/Torque Calculation for

BNHV8812A and BNHV8812B

APF 05D-001-02

Calculation Change Notice No. BN-M-011-008-CN001

APF 26A-003-01

Regulatory Screening: CCP 09118

APF 26A-003-01

Regulatory Screening: CCP 09120

APF 26A-003-01

Regulatory Screening: DCP 07950

APF 26A-003-03

CFR 50.59 Unreviewed Safety Question Determination:

CCP 09118

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

APF 28A-001-01

Performance Improvement Request Initiation: PIR 962484

10/04/1996

PM File: 48523

Megger Test Group B - PG022 Backup Immersion Heaters

(Located in the Pressurizer)

Procedures

AI 23D-003

MOV Trending and Periodic Verification Program

AI 29B-003

Guidance to Prevent Unacceptable Preconditioning Prior to

Testing

STS MT-001B

PG22 Pressurizer Heater Verification

STS NB-005

Breaker Alignment Verification

34A

STS PE-007

Periodic Verification of Motor Operated Valves

5A

Work Orders

17-432997-000, 17-433510-026, 18-436910-000

71111.22

Corrective Action

Documents

Condition Reports 133126, 133131

Drawings

10466-J-110-

0357

Auxiliary Feedwater System Aux. Fw. Supply Pressure From

Condensate Storage Tank

M-12EJ01

Piping and Instrumentation Diagram Residual Heat Removal

System

Miscellaneous

Supplemental Brief Sheet - STS IC-615A/B

APF 05-013-01

E-1R8902 Physical Separation Exemptions

APF 15C-002-01

Procedure Cover Sheet: Fuel Building Emergency Exhaust

Operations

APF 29B-003-01

Surveillance Testing Routing Sheet (STRS): Slave Relay

Test K615 Train B Safety Injection

06/03/2019

APF 29B-003-01

Surveillance Test Routing Sheet (STRS): Manual/Auto Fast

Start, Sync & Loading of EDG NE02

06/03/2019

APF 29B-003-01

Surveillance Test Routing Sheet (STRS): Train B RHR

System Inservice Valve Test

04/08/2019

APF 29B-003-01

Surveillance Test Routing Sheet (STRS): Emergency

Exhaust Filter System Train A Operability Test

04/18/2019

ET 19-0002

Docket No. 50-482: License Amendment Request to Revise

Technical Specification 3.3.5, "Loss of Power (LOP) Diesel

Generator (DG) Start Instrumentation

03/18/2019

FD521

Flex 150KW Generator #2 Operating Instruction

Procedures

AI 16C-013

Work Order Planning Feedback Guidelines

AP 21A-002

Diverse and Flexible Coping Mitigation Strategies (FLEX)

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Program

FSG-05

Initial Assessment and Flex Equipment Staging

STS EJ-201B

Train B RHR System Inservice Valve Test

STS GG-001A

Emergency Exhaust Filtration System Train A Operability

Test

STS IC-260

Channel Operational Test Auxiliary Feedwater Pump Suction

Pressure Low Transfer to ESW

STS IC-615B

Slave Relay Test K615 Train B Safety Injection

STS IC-805B

Channel Calibration of NB02 Grid Degraded Voltage, Time

Delay Trip

STS KJ-015B

Manual/Auto Fast Start, Sync & Loading of EDG NE02

SYS GG-200

Fuel Building Emergency Exhaust Operations

Work Orders

18-441767-000, 18-444651-000, 18-446778-000, 18-

446778-001, 18-446779-000, 18-446779-001

71151

Miscellaneous

System Health Report: EF - Essential Service Water

07/01/2018

to

2/31/2018

MSPI Derivation Report - MSPI High Pressure Injection

System - Unreliability Index

03/2019

MSPI Derivation Report - MSPI High Pressure Injection

System - Unavailability Index

03/2019

MSPI Derivation Report - MSPI Cooling Water System -

Unavailability Index

03/2019

MSPI Derivation Report - MSPI Cooling Water System -

Unreliability Index

03/2019

NEI 99-02

Regulatory Assessment Performance Indicator Guideline

Procedures

AI 26A-008

NRC/INPO/WANO Performance Indicator and MOR

Reporting

AI 34-006

Performance Indicator Program Instructions

AP 26A-007

NRC Performance Indicators

71152

Corrective Action

Documents

Condition Reports 119954, 124341, 124460, 124584, 124605, 125504, 126229,

26252, 126332, 126458, 126591, 126799, 127044, 127187,

27236, 127701, 127960, 128024, 128024, 128099, 128099,

28111, 128111, 128143, 128144, 128248, 128253, 128340,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

28344, 128347, 128361, 128471, 128538, 128709, 128789,

28909, 129172, 129208, 129507, 129577, 130078, 130135,

130198, 130443, 131489, 131596, 131870, 132303, 132360,

2471, 132652, 132680, 132744, 132791, 133199, 133245,

133314

Miscellaneous

Senior Leadership Review Team Agenda

06/20/2019

Operating Manual Uninterruptible Power Supply - Digital

Energy SG Series

2008

AIF 13C-003-01

PARB Questionnaire

2A

AIF 13C-003-02

Work Environment Support Plan

AP 18A-001

Employee Concerns Program

AP 36-001

Nuclear Safety Culture

APF 21-001-01

Shift Manager Relief Checklist: On-Coming SM Review Prior

to Assuming Shift - Nights

06/18/2019

LO14 073 00

Process and Effluent Radiation Monitoring System - Lesson

Plan - GK RE 05

OP 01-02

Leadership Development Program

RCA 128909

Root Cause Analysis (RCA) 128909 - Level II Traditional

Enforcement Violation

Procedures

AI 13C-003

Personnel Action Review Board (PARB)

AI 28A-100

Condition Report Resolution

AP 06-004

Equipment Important to Emergency Response

9B

AP 18-001

Emerging Concerns

AP 28A-100

Correction Action Program

SYS BG-221

CVCS Diaphragm Valve Torquing and PMTS

Work Orders

18-444690-000

71153

Corrective Action

Documents

Condition Report

27691

ML19225D316

SUNSI Review

ADAMS:

Non-Publicly Available

Non-Sensitive

Keyword:

By: NOKeefe

Yes No

Publicly Available

Sensitive

NRC-002

OFFICE

ASRI:DRP/B

ARI:DRS/IPAT

SRI:DRS/IPAT

SRI:DRP/B

AC:DRS/EB1

C:DRS/EB2

NAME

FThomas

JMelfi

RAzua

DDodson

GGeorge

NTaylor

SIGNATURE

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

DATE

08/06/2019

08/05/2019

08/12/2019

08/02/2019

07/31/2019

08/01/2019

OFFICE

C:DRS/RCB

TL:DRS/IPAT

C:DRS/OB

C:DNMS/RIB

BC:DRP/B

NAME

MHaire

RKellar

GWerner

GWarnick

NOKeefe

SIGNATURE

/RA/

/RA/

/RA/ CCO for

/RA/

/RA/

DATE

07/31/2019

08/01/2019

08/01/2019

08/02/2019

08/12/2019