IR 05000482/2020004
| ML21040A411 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/09/2021 |
| From: | O'Keefe C NRC/RGN-IV/DNMS/NMSB-B |
| To: | Reasoner C Wolf Creek |
| References | |
| IR 2020004 | |
| Download: ML21040A411 (14) | |
Text
February 9, 2021
SUBJECT:
WOLF CREEK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000482/2020004
Dear Mr. Reasoner:
On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Wolf Creek Generating Station. On January 6, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
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, Neil F. O'Keefe, Chief Reactor Projects Branch B Division of Reactor Projects
Docket No. 05000482 License No. NPF-42
Enclosure:
As stated
Inspection Report
Docket Number:
05000482
License Number:
Report Number:
Enterprise Identifier: I-2020-004-0008
Licensee:
Wolf Creek Nuclear Operating Corporation
Facility:
Wolf Creek Generating Station
Location:
Burlington, KS
Inspection Dates:
October 1, 2020, to December 31, 2020
Inspectors:
C. Henderson, Senior Resident Inspector
J. Vera, 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. 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
PLANT STATUS
Wolf Creek Generating Station began the inspection period at full power, except for the four occasions in the month of November when the licensee reduced power to 70 percent for flexible power operations (based on daily market demand) and returned to full power after each occasion. On December 11, 2020, the licensee reduced power to 70 percent to perform main turbine valve surveillance testing and data gathering for future flexible power operation cycles, the unit was returned to full power on December 12, 2020, where it remained for the rest of the reporting 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 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed onsite portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and onsite. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Emergency diesel generator A jacket water and intercooler system on October 22, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Auxiliary feedwater pump B room door 13271 breach authorization for maintenance, fire area A-13 on December 29, 2020
- (2) Auxiliary feedwater pump A room door 13261 breach authorization for degraded door gasket, fire area A-14 on December 29, 2020
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 operator performance during power changes as part of flexible power operations on November 14, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator simulator training activities on November 16, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Emergency diesel generator A placed in 10 CFR 50.65(a)(1) due to temperature control valve failures on October 22, 2020
- (2) Train B containment coolers due to essential service water outlet valve EFHV0046 failure to open on December 2, 2020.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Emergent work for shutdown bank C reactor control rods failing to insert during surveillance testing on December 18, 2020
- (2) Emergent work for reactor trip breaker A block switch for the automatic shunt trip failure during surveillance testing on December 21, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Emergency diesel generator A fuel oil transfer pump polarization index operability determination on November 2, 2020
- (2) Train B safety-related 480 volt bus NG02 exceeding 506 volts AC operability determination on December 18, 2020
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Change in time critical operator action to establish Class 1E room cooling air recirculation and shifting safety-related battery chargers following a failure of the safety-related air conditioning unit on November 17, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Emergency diesel generator A fuel oil pump replacement and fuel oil system maintenance on October 26, 2020
- (2) Emergency diesel generator B, 7-day technical specification maintenance outage on November 5, 2020
- (3) Emergency diesel generator A, 7-day technical specification maintenance outage on October 22, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Emergency diesel generator A monthly operability and lube oil inventory surveillance testing on October 27, 2020
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) Reactor coolant leakage surveillance testing on November 3, 2020
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) The inspectors observed emergency preparedness drills with no drill and exercise performance indication opportunity (DEP) and emergency preparedness table-tops with DEP on November 18,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07)===
- (1) October 1, 2019, through September 30, 2020
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) October 1, 2019, through September 30, 2020
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in human performance tool usage and control of evaluations that might be indicative of a more significant safety issue on December 17,
INSPECTION RESULTS
Observation: Semi-Annual Trend Review 71152 The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation available to help identify performance trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address the identified adverse trends. The inspectors did not review any cross-cutting themes because none existed at the site.
To verify that the licensee was taking corrective actions to address identified adverse trends that might indicate the existence of a more significant safety issue, the inspectors noted an apparent negative trend in work management that resulted human performance errors and reviewed the corrective action program documentation from April through December 2020.
Selected examples of these events that illustrate the performance included:
- Condition Report (CR) 141893: During the performance of Procedure SYS GK-201, Mitigating Actions for Inoperable SKG05 Train, Rev. 0, for an emergent refrigerant leak on the train B Class 1E electrical air conditioning unit (SGK05B), both safety-related batteries became inoperable when placing the swing battery chargers into services. Specifically, the licensee lowered the output voltage of both normally aligned safety-related chargers concurrently causing both trains of safety-related batteries to become inoperable. This issue was documented in NRC Inspection Report 05000482/2020002 (Adams ML20224A354) as NCV 05000482/2020002-01.
- CR 143812: The licensees failure to implement Procedure AI 16C-005, Toolpouch and Minor Maintenance Preparation and Implementation, Revision 0. Specifically, the licensee failed to inform operations personnel of safety injection pump A oil leakage during post maintenance testing per Procedure AI 16C-005 to determine whether the safety-related function of the system or component would be affected prior to attempting to repair the leakage. This was evaluated as a minor issue because it was identified and corrected during maintenance in progress.
- CR 144243: During the restoration of steam generator blowdown from planned maintenance activities in accordance with Procedure SYS BM-127, Blow Down Flow Adjustments, Revision 15, the steam generator blowdown system unexpectedly automatically isolated due to a high flash tank level. This event occurred because the licensee failed to ensure all individuals involved were in place and ready to perform the evolution. Specifically, an operator was assigned to throttle radiation monitor flow and perform an independent verification for hanging a clearance order. The control room and the other assigned local operator did not verify that the individual was in place to throttle radiation monitor flow, resulting in the isolation of steam generator blow down. This was evaluated as a minor issue because it did not result in a plant transient.
- CR 144908: The licensee released approximately 180 gallons from the A train secondary liquid waste tank (THF04A), however the release permit was for discharging the contents of THF04B. Prior to the release, one of the on-shift field operators unexpectedly had to leave the site. The replacement watch-stander failed to review the liquid release permit to ensure the correct THF04 was aligned for release. This was evaluated as a minor issue because it did not result in a release greater than the release approved in the permit for THF04B.
The inspectors performed an independent assessment of the adverse trend that resulted in human performance issues at the station and concluded there was a potential adverse trend associated with Work Management. Specifically, the inspectors identified that the licensee did not implement the following aspects of the Work Management Process in the following instances:
- Effectively plan and execute work by incorporating risk insights, job site conditions and for coordination with different groups or job activities (CR 144243)
- Consider the impact of changes to the work scope and the need to keep personnel apprised of work status (CR 143812)
- Ensure individuals are aware of plant status, the nuclear safety risks associated with work in the field, and other parallel station activities (CR 144908)
- Coordinate work activities to address conflicting or changing priorities across the whole spectrum of activities contributing to nuclear safety, which includes emergent work activities (CR 141893)
Additionally, the inspectors identified the licensee also noted declining human performance, which resulted in the licensee performing a self-assessment, Gap to Excellence in Human Performance, (CR 144353) and a common cause evaluation, Organizational Performance Review of Site Events. (CR 142240). The licensee concluded the most probable cause was leaders and workers have not consistently implemented their roles and responsibilities as identified in the Human Performance program. Specifically, the licensee did not implement effective communications, there were gaps in procedure use and adherence, and failures to stop when unsure. The licensee implemented corrective actions for each of the gaps identified in the implementation of the Human Performance program. The corrective actions included re-enforcing the roles and responsibilities of the Human Performance program for leaders and workers and a Human Performance action plan focusing on error prevention tools (i.e., effective communication, procedure use and adherence, and self-checks). The inspectors concluded the licensee self-assessment and common cause evaluation did not identify the potential adverse trend in terms of work management, but the inspectors noted the licensees Nuclear Safety Culture subcommittee initiated CR 146284 identifying 12 examples associated with work management with respect to scheduling of maintenance activities. In response, the licensee assigned a corrective action to complete a formal trend analysis, scheduled to be completed in January 2021, to implement an appropriate corrective action plan.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 6, 2021, the inspectors presented the integrated inspection results to Mr. C. Reasoner, Chief Executive Officer and Chief Nuclear Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
XX-M-052
Wolf Creek Tank Document Verifications
Corrective Action
Documents
Condition Reports 024199
Corrective Action
Documents
Resulting from
Inspection
Condition Reports 145756, 145854, 145853
Drawings
M-12KJ01
Piping and Instrumentation Diagram Standby Diesel
Generator A Cooling Water System
M-13KJ03
Small Piping Isometric Standby Diesel System Lube Oil and
Jacket Water
Miscellaneous
WCRE-01
WCNOC Total Plant Setpoint Document
WCRE-03
Tank Document
WCRE-34
Fourth 10-year Interval Inservice Testing Program
Procedures
ALR 00-020D
DG NE01 Trouble
ALR 00-095B
ALR 501
Standby Diesel Engine System Control Panel KJ-121
Operability Determination and Functionality Assessment
STS KJ-005A
Manual/Auto Start, Sync, and Loading of EDG NE01
69A
Corrective Action
Documents
Condition Reports 10000367, 10000161, 10000097
Miscellaneous
Breach
Authorization
Permit
BAP 20-0300, BAP 20-0294
E-1F9905
Fire Hazard Analysis
WCRE-35
Boundary Matrix
Procedures
AP 10-103
Fire Protection Impairment Control
AP 10-104
Breach Authorization
AP 10-106
Fire Preplans
Work Orders
20-463920-002
71111.11Q Procedures
AI 21-300
Flexible Power Operations
AP 21-001
Conduct of Operations
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
BD-EMG C-0
Loss of All AC Power
EMG C-0
Loss of All AC Power
EMG E-0
Reactor Trip or Safety Injection
GEN 00-004
Power Operation
Corrective Action
Documents
Condition Reports 134814, 135452, 138206, 137244, 137247, 002671, 135086,
145497, 145845
Drawings
M-12KJ01
Piping & Instrumentation Diagram Standby Diesel Generator
A Cooling Water System
Miscellaneous
E-025-00005
Instruction Manual for Limitorque Actuator Instructions and
Maintenance
W06
SCA-91-0084
SCA-92-0143
WCRE-34
Fourth 10-Year Interval Inservice Testing Basis Document
Procedures
AP 23-006
System Engineering Program
27A
Operability Determination and Functionality Assessment
MGE LT-008
Routine Electrical Limitorque Operator Maintenance
8A
MGE LT-100
Limitorque Valve Operator General Notes and Details
MPM KJ-004
Robertshaw Model 1285 Temperature Control Valve
MPM LT-001
Limitorque Operator Minor Maintenance, Lubrication, and
Inspection
SYS KJ-130
Removal and Restoration of EDG Support Systems
Work Orders
15-406452-000, 17-430103-000, 18-441495-000, 19-
455530-004, 19-454101-000, 19-450841-000, 19-450840-
000
Corrective Action
Documents
Condition Reports 10000223, 10000247
Procedures
OFN SF-011
Realignment of Dropped, Misaligned Rod(s), and Rod
Control Malfunctions
STN SF-001
Control Rod Parking
21A
Corrective Action
Documents
Condition Reports 145356, 145358, 145667
Drawings
E-11013
Installation, Inspection and Testing Details for Electrical
Equipment and Cables
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
MGE EOOP-05
Insulation Resistance Testing
Work Orders
19-456424-000
Corrective Action
Documents
Condition Reports 141893
Procedures
Implementation and Revision of TS Bases, TRM, PTLR
2A
CFR 50.59 Reviews
Revisions to the Operating License and/or Technical
Specifications
GK-M-016
Wolf Creek Control Building Loss of Class 1E A/C GOTHIC
Room Heat Up Analysis with Installed Crosstie Fans and
SYS GK-201
Mitigating Actions for Inoperable SGK05 Train
Corrective Action
Documents
Condition Reports 145678, 145639, 145662, 145668, 145634, 145633, 145632,
145708, 145703, 145912, 145940, 145962, 145963, 145964,
145969, 145903
Corrective Action
Documents
Resulting from
Inspection
Condition Reports 145715
Miscellaneous
M-018-00309
Instruction Manual for Emergency Diesel Generator System
W139
Procedures
Emergency Diesel Generator Reliability Program
CKL ZL-005A
A EDG Operating Log
6A
MEC-038
Emergency Diesel Engine Injection Pump Replacement
MPM M018Q-01
Standby Diesel Generator Inspection
26A
STS KJ-005A
Manual/Auto Start, Sync, and Loading of EDG NE01
69A
SYS KJ-123
Post Maintenance Run of Emergency Diesel Generator A
67A
SYS KJ-130
Removal and Restoration of EDG Support Systems
Work Orders
19-450868-001, 20-463519001-001, 19-452880006-001, 14-
396122-001, 14-396122-005, 20-466446-003, 19-454576-
000, 20-461902-000
Corrective Action
Documents
Condition Reports 144501, 145273, 145433, 145419, 024199, 145832, 146222
Corrective Action
Documents
Condition Reports 145714, 145713, 146110, 10000593, 10000594, 10000598
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
Procedures
Operability Determination and Functionality Assessment
RCS Unidentified Leak Rate Monitoring Program
OFN NB-042
Loss of Offsite Power to NB01 (NB02) with EDG Paralleled
STS BB-004
RCS Water Inventory Balance
51A
STS BB-006
RCS Water Inventory Balance Using the NPIS Computer
STS KJ-005A
Manual/Auto Start, Sync, and Loading of EDG NE01
69A
STS KJ-005B
Manual/Auto Start, Sync, and Loading of EDG NE02
65A
STS KJ-013A
Hot Restart of EDG NE01
Work Orders
20-458467-000
71151
Corrective Action
Documents
Condition Reports 145401
Miscellaneous
WCNOC-163
Mitigating System Performance Index (MSPI) Basis
Document
Corrective Action
Documents
Condition Reports 133793, 141893, 144257, 141893, 136241, 144908, 144243,
144353, 144362, 142240, 146052, 146284
Corrective Action
Documents
Resulting from
Inspection
Condition Reports 145507, 10000597
Drawings
M-12EF02
Piping Instrumentation Diagram Essential Service Water
System
Procedures
AI 28A-010
Screening Condition Reports
AI 28E-007
Corrective Action Coding and Trend Analysis
Corrective Action Program
AP 34-001
Human Performance
16A
SYS BM-127
Blowdown Flow Adjustments
SYS EF-300B
ESW/Service Water Macrofoul Treatment for Train B
0A