IR 05000482/2021001

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Integrated Inspection Report 05000482/2021001
ML21120A162
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 05/05/2021
From: O'Keefe C
NRC/RGN-IV/DRP
To: Reasoner C
Wolf Creek
References
IR 2021001
Download: ML21120A162 (36)


Text

May 5, 2021

SUBJECT:

WOLF CREEK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000482/2021001

Dear Mr. Reasoner:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Wolf Creek Generating Station. On April 7, 2021, the NRC inspectors discussed the results of this inspection with Mr. J. McCoy, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Both of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the 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 Wolf Creek Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Wolf Creek Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, 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:

NPF-42

Report Number:

05000482/2021001

Enterprise Identifier: I-2021-001-0093

Licensee:

Wolf Creek Nuclear Operating Corp.

Facility:

Wolf Creek Generating Station

Location:

Burlington, KS

Inspection Dates:

January 1, 2021 to March 31, 2021

Inspectors:

C. Henderson, Senior Resident Inspector

J. Vera, Resident Inspector

J. Melfi, Project Engineer

C. Alldredge, Health Physicist

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. A licensee-identified non-cited violation is documented in report Section 7115

List of Findings and Violations

Failure to Ensure Proper Functioning of Fire and Halon Boundary Door Self-Closing Mechanism Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000482/2021001-01 Open/Closed

[H.13] -

Consistent Process 71111.13 The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1.d, for the licensees failure to implement the fire protection program.

Specifically, the licensee failed to recognize that the fire and halon boundary door self-closing mechanism was required to maintain door functionality and failed to implement appropriate fire compensatory measures during planned maintenance activities that caused the door in question to be held open by ventilation airflow.

Failure to Operate the Correct Breaker During Testing Restoration Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000482/2021001-02 Open/Closed

[H.12] - Avoid Complacency 71111.22 The inspectors reviewed a self-revealed Green finding and associated non-citied violation of Technical Specification 5.4.1.a, for the licensees failure to properly pre-plan and perform maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to implement Procedure SYS GK-121, Control Building HVAC Operation,

Revision 35, when restoring from train A control room isolation ventilation system testing causing train A control room exhaust ventilation system to become inoperable when an operator opened the wrong breaker.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000482/2021-001-00 Entry into Mode 4 with Excessive Containment Valve Leakage Resulted in a Condition Prohibited by Technical Specifications 71153 Closed LER 05000482/2021-001-01 Re-Entry into Mode 4 with Excessive Containment Valve Leakage Resulted in a 71153 Closed

Condition Prohibited by Technical Specifications

PLANT STATUS

Wolf Creek Generating Station began the inspection period at full power. On March 25, 2021, the unit was shut down to begin Refueling Outage

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 Disease 2019 (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

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of extreme seasonal cold temperatures for the following systems:

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from an issued wind advisory for winds 25 to 35 mph with gusts of 40 to 50 mph on January 14, 2021.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (5 Samples)

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

(1) Auxiliary building and control building heating, ventilation and air conditioning (HVAC)lineup on January 8, 2020
(2) Train B Class 1E air conditioning system during scheduled maintenance for train A on January 21, 2021
(3) Train B essential service water system to auxiliary feedwater system on February 2, 2021
(4) Train A Class 1E control room air conditioning system during scheduled maintenance for train B on February 2, 2021
(5) Emergency diesel generator alignment to restore emergency operation when in parallel with offsite power on March 10, 2021

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

(1) The inspectors evaluated system configurations during a complete walkdown of the auxiliary feedwater system on February 3, 2021.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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) Turbine-driven auxiliary feedwater pump room, fire area A-15, on January 6, 2021
(2) Auxiliary building general area, elevation 1,974 feet, fire area A-1, on January 12, 2021
(3) Auxiliary feedwater pipe chase room, fire area A-33, on January 14, 2021
(4) Engineered safety feature switchgear rooms and associated electrical cable case rooms, fire areas C-9, C-10, and C-12 on February 5, 2021
(5) Emergency diesel generator rooms, fire areas C-9 and C-10, on February 5, 2021

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Auxiliary feedwater system turbine-driven pump and pipe chase rooms on February 4, 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 licensed operator performance in the Control Room during shutdown for Refueling Outage 24 on March 25, 2021.

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

(1) The inspectors observed and evaluated simulator training for a loss of all AC power and a loss-of-coolant accident in Mode 4 on January 12, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Auxiliary feedwater system on February 3, 2021.

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Auxiliary feedwater water motor operated valves on February 1, 2021.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 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) Diesel and electric fire pumps unavailable due to circulating bay C planned maintenance activities on January 14, 2021
(2) Emergent work for swing safety-related inverter NK25 failed potentiometer and impacts on train A Class 1E air conditioning system on January 20, 2021
(3) Train B essential service water system and emergency diesel generator planned maintenance outage on January 27, 2021
(4) Train B emergency exhaust system isolation damper for main steam enclosure building not fully closing emergent work on January 29, 2021
(5) Train A component cooling water system planned maintenance outage on February 10, 2021
(6) Emergency diesel generator A emergent work for overspeed trip degraded conduit repair on February 18, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Train B emergency exhaust system compensatory measures during maintenance activities operability determination on January 6, 2021
(2) Auxiliary feedwater system motor and pump allowed oil leakage operability determination on January 14, 2021
(3) Train B emergency exhaust system pressure test incorrect damper alignment and main steam enclosure building isolation damper failure to close operability determination on February 8, 2021
(4) Train B switchgear NK04 past operability determination for the as-found condition of Door 34041 being nonfunctional on February 22, 2021
(5) Train B safety injection pump motor inboard bearing oil leak operability determination on February 23, 2021
(6) Emergency diesel generator A degraded governor conduit past operability determination on March 25, 2021

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) Temporary modification for residual heat removal for shutdown cooling bypass valve control system for 7300 ovation upgrade on March 18, 2021

Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the severe accident guidelines update on February 24, 2021

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Safety-related swing inverter NK25 failed potentiometer replacement on January 21, 2021.
(2) Train B essential service water system maintenance window on January 26, 2021
(3) Train B emergency exhaust system main steam enclosure isolation damper failure to full close repair on January 29, 2021
(4) Safety-related DC switchgear room 4 Door 34041 self-closing mechanism corrective maintenance on February 2, 2021.
(5) Emergency diesel generator A governor switch replacement due to degrading conduit on February 18, 2021
(6) Train A component cooling water pump C misting oil due to misaligned oiler corrective maintenance on February 24, 2021
(7) Train A component cooling water system pump room belt replacement and damper maintenance on February 24, 2021

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)

(1)

(Partial)

The inspectors evaluated Refueling Outage 24 activities from March 25-31, 2021.

The inspectors completed inspection procedure sections 03.01.a, 03.01.b, 03.01.c.1 through 8.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Control room ventilation isolation signal response time testing on January 15, 2021
(2) Train B essential service water system on February 2, 2021
(3) Turbine-driven auxiliary feedwater water pump and motor-driven auxiliary feedwater pump A and B low suction pressure transfer to essential service water monthly surveillance testing on February 3, 2021.
(4) Train B emergency exhaust system pressure test damper incorrect testing alignment on February 5, 2021
(5) Auxiliary feedwater system check valve inservice surveillance and steam generator full flow testing on February 16, 2021

Inservice Testing (IP Section 03.01) (2 Samples)

(1) Motor-driven auxiliary feedwater pump B inservice surveillance testing on February 11, 2021
(2) Train A component cooling water system pumps A and C inservice testing surveillance on February 8, 2021

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Evaluated reactor coolant system unidentified leak rate and containment radiation monitor spikes on March 18, 2021

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) Emergency preparedness drill involving a faulted and ruptured steam generator with a loss of train A essential service water and loss of offsite power on March 2,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01)===

(1) January 1, 2020, through December 31, 2020

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02) (1 Sample)

(1) January 1, 2020, through December 31, 2020

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (1 Sample)

(1) January 1, 2020, through December 31, 2020

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Train B emergency exhaust system pressure test incorrect testing alignment and extent of condition on February 15, 2021
(2) Train A component cooling water pump C outboard bearing oiler misalignment on March 11, 2021

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 05000482/2021-001-00 and 01, Entry into Mode 4 with Excessive Containment Valve Leakage Resulted in a Condition Prohibited by Technical Specifications, (ADAMS Accession Numbers: ML21055A872 and ML21077A135)

The inspectors concluded that one licensee-identified violation of NRC requirements occurred.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

92723 - Follow-Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month period

During the 12-month time period beginning April 1, 2018 through March 31, 2019, the NRC issued three SL IV traditional enforcement violations, and subsequently issued three additional SL IV traditional enforcement violations in the area of impeding the regulatory process, as follows:

(1) NCV 05000482/2018002-01, Announcement of an NRC Inspectors Presence by Station Personnel
(2) NCV 05000482/2018003-02, Failure to Submit a Licensee Event Report for a Condition Prohibited by Technical Specifications
(3) NCV 05000482/2019001-01, Failure to Provide Unfettered Access to an NRC Resident Inspector
(4) NCV 05000482/2019002-01, Failure to Submit a Revision to Section 9.1.4.3 of the Wolf Creek Updated Final Safety Analysis Report
(5) Licensee Identified Non-Cited Violation documented in Inspection Report 05000482/2019002 for failure to submit a revision to Section 13.2.2 of the Wolf Creek Updated Final Safety Analysis Report
(6) Licensee Identified Non-Cited Violation documented in Inspection Report 05000482/2020002 for failure to submit a report containing a description of each security plan change within 2 months after the change was made

The inspectors reviewed the licensees cause evaluation and corrective actions associated with these violations and concluded that the licensees actions met the Inspection Procedure 92723 inspection objectives to provide assurance that:

(1) the cause(s) of the violations are understood by the licensee;
(2) the extent of condition and extent of cause of the violations are identified; and
(3) licensee corrective actions for the violations are sufficient to address the cause(s).

INSPECTION RESULTS

Failure to Ensure Proper Functioning of Fire and Halon Boundary Door Self-Closing Mechanism Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000482/2021001-01 Open/Closed

[H.13] -

Consistent Process 71111.13 The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1.d, for the licensee failure to implement the fire protection program.

Specifically, the licensee failed to recognize the fire and halon boundary door self-closing mechanism was required to maintain door functionality and failed to implement appropriate fire compensatory measures during planned maintenance activities that caused the door in question to be held open by ventilation airflow.

Description:

On January 20, 2021, the inspectors were performing walkdowns for scheduled train A Class 1E electrical equipment air conditioning system (SKG05A) maintenance activities to verify the licensee implemented their planned risk-management measures. Specifically, the licensee places the train B Class 1E electrical equipment air conditioning system (SKG05B) in recirculation mode as required by Technical Specification 3.7.20, Class 1E Electrical Equipment Air-Conditioning (A/C) System in order to use the B train equipment to cool the equipment in both trains. During this walkdown, the inspectors identified safety-related DC switchgear room 4 (Room 3404), double door (Door 34041), was not fully closed and latched. The doors self-closing mechanism was not working with the increased differential pressure caused by this infrequent ventilation lineup. Door 34041 was credited as a fire door, a halon system boundary, and a flood barrier door as documented in Procedure WCRE-35, Boundary Matrix, Revision 8. The inspectors informed the licensee of the condition of Door 34041. The licensee established the required hourly fire watch per BAP-21-0019, initiated Condition Report (CR) 10000899, and repaired the door under Work Order (WO) 20457742000.

The condition identified by the inspectors was previously evaluated in two additional condition reports (CR 140012 and 140042) initiated in January 2020. These CRs were closed to planned WO 20-457742-000, which was intended to modify Door 34041s inactive leaf from automatic to manual release. This change prevents the inactive leaf from opening when the active leaf is opened during increased differential pressure from the hallway when SKG05B is in recirculation mode. In WO 20-457742-000, it is stated the reason Door 34041 would not automatically fully close and latch was that upon opening the active leaf from the outside, the differential pressure from the hallway to the inside of Room 3404 was large enough when SKG05B was in recirculation mode that the inactive leaf was held open preventing the door from properly securing. This condition was also described in CRs 140012 and 140042, but no breach authorization permit was identified following the identification of the degraded condition of door 34041. The operability screening in CR 10000899, CR 140012, WO 20-457742-000, and multiple condition reports prior to 2020, stated the following:

  • Door 34041 functions as a fire barrier and a flood barrier. The door will latch and stay closed if closed properly and challenged properly. Wolf Creek has an expectation that personnel challenge doors after closing them to ensure that they are closed properly when within the power block. Door 34041 was operable/functional but degraded.

The inspectors determined that the licensee did not establish a breach authorization permit in accordance with Procedure AP 10-104, Breach Authorization, Revision 39, step 5.5.1, or implement a fire compensatory measure of an hourly fire watch for a nonfunctional halon system as required by Procedure AP 10-103, Fire Protection Impairment Control, Revision36. Additionally, the inspectors noted that the Updated Final Safety Analysis Report (USAR) Appendix 9.5E, Table 9.5E-1, Wolf Creek Generation Station Fire Protection Comparison to 10CFR50 Appendix R, stated that fire doors shall be self-closing and doors for areas protected by halon systems shall have self-closing mechanisms or be electrically supervised to ensure they are maintained closed. Also, Procedure AP 10-103, step 5.6.1, states, All personnel shall maintain the operability/functionality of all required barriers. Note: Fire doors with automatic closers that do not close and latch on their own require a breach authorization permit. For Door 34041, the self-closing mechanism is used to meet the requirement of USAR Table 9.5E-1 and Procedure AP 10-103, step 5.6.1, but it appeared to not be working, and the door was not electrically supervised.

From the information provided above, the inspectors concluded the licensee did not recognize the requirement to maintain a functional self-closing mechanism to ensure Door 34041 remain closed to perform its function as a fire and halon boundary door, and relied on the site expectation that all doors are challenged by station personnel to ensure they remained latched and closed. This resulted in the licensees failure to establish a breach authorization permit and an hourly fire watch for Door 34041 during SKG05A planned maintenance activity and assigning a low work priority of enhancement to WO 20-457742-000.

Corrective Actions: The licensee implemented Breach Authorization Permit BAP-21-019, established an hourly fire watch, and changed Door 34041s inactive leaf from automatic to manually locked condition in accordance with WO 20-457742-000.

Corrective Action References: Conditions Reports 10000899 and 10000916

Performance Assessment:

Performance Deficiency: The licensees failure to recognize that a fire and halon boundary door self-closing mechanism was required to maintain door functionality was a performance deficiency. As a result, the licensee failed to implement compensatory actions required by the fire protection program when the door in question was not reliably self-closing.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Hazards (i.e., fires) attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure of Door 34041 self-closing mechanism to close and latch the door degraded the fire barrier function and prevented the door from retaining a halon release and flood waters and required a fire compensatory measure of stationing an hourly fire watch for the halon protected safety-related switchgear room 4 during planned train A Class 1E air conditioning system maintenance activities.

Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection Significance Determination Process. The inspectors assigned the finding a fire finding Category 1.4.1 and 1.4.4 using Inspection Manual Chapter 0609, Appendix F, 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018, because the finding involved fire prevention and administrative controls and fire confinement. The inspectors determined that the finding had very low safety significance (Green) because the finding:

(1) did not increase the likelihood of a fire, delay detection of a fire, or resulted in a more significant fire than previously analyzed such that credited safe shutdown strategy could be adversely impacted; and
(2) the degraded fire confinement element continued to provide adequate fire endurance to prevent fire propagation through the fire confinement element given the combustible loading and location of equipment important to safe shutdown in the fire area of concern. Specifically, there was no combustible material or safety equipment that constituted a fire target in the hallway adjoining the degraded door.

Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. Specifically, the licensee failed to properly use the breach authorization and door fire protection impairments process and failed to use a decision-making process consistently when evaluating Door 34041s self-closing mechanism functionality.

Enforcement:

Violation: Technical Specification 5.4.1.d requires that written procedures shall be established, implemented, and maintained covering fire protection program implementation. The licensee established Procedures AP 10-103, Fire Protection Impairment Control, Revision 36, and AP 10-104, Breach Authorization, Revision 39, for impairments of the fire protection system and instructions to maintain required barriers for fire protection.

Procedure AP 10-104, Step 5.5.1, stated, fire protection [personnel] shall specify the compensatory measures required when a fire barrier is breached, degraded, or determined inoperable/non-functional.

Procedure AP 10-103, Attachment E, Required Action C.1, required the establishment of an hourly fire watch patrol for any other halon system nonfunctional.

Contrary to the above, on January 20, 2021, the licensee failed to implement fire protection program Procedures AP 10-104 and AP 10-103 to specify the necessary compensatory measures when required. Specifically, when door 34041 self-closing mechanism failed to close and latch the door when it was opened with SGK05B in recirculation mode to support SGK05A maintenance activities, the fire barrier was degraded but the licensee failed to establishment of an hourly fire watch patrol for the halon system being nonfunctional.

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

Failure to Operate the Correct Breaker During Testing Restoration Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000482/2021001-02 Open/Closed

[H.12] - Avoid Complacency 71111.22 The inspectors reviewed a self-revealed Green finding and non-citied violation of Technical Specification 5.4.1.a, for the licensees failure to properly pre-plan and perform maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to implement Procedure SYS GK-121, Control Building HVAC Operation, Revision 35, when restoring from train A control room ventilation isolation ventilation signal (CRIVS) testing causing train A control room emergency ventilation system (CREVS) to become inoperable when an operator opened the wrong breaker.

Description:

On January 15, 2021, the licensee failed to implement Procedure SYS GK-121, Control Building HVAC Operation, Revision 35, when restoring from train A CRIVS response time testing. Specifically, the licensee failed to open the adsorber unit heater breaker A in accordance with Procedure SYS GK-121. Instead, the licensee opened the control room pressurization fan A breaker and caused train A CREVS to become inoperable for 12 minutes. The licensee entered this issue into their corrective action program and performed a performance assessment worksheet (PAW) and an equipment performance evaluation (EPE).

The inspectors reviewed the PAW and EPE and concluded the licensee failed to use error reduction tools to ensure the correct breaker was operated. Prior to the breaker operation the licensee performed a self-check, obtained a peer-check, and placed a pink status control magnet on the breaker cubicle of the breaker to be operated. However, the individual took their eyes off the breaker to don a flash hood and failed to perform a self-check or obtain a peer-check prior to operating the breaker.

Corrective Actions: Restored train A CREVS to operable by closing the control room pressurization fan A's breaker.

Corrective Action References: Condition Report 10000801

Performance Assessment:

Performance Deficiency: The licensees failure to open the adsorber unit heater breaker A, and instead opened the pressurization fan A breaker, which caused inoperability of train A CREVS was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee's failure to open the correct breaker during restoration from train A CRIVS testing resulted in train A CREVS being inoperable for 12 minutes.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 3, Section D, because the finding affected the barrier function of the control room, the inspectors determined the finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room, and it did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee failed to effectively implement appropriate error reduction tools to ensure the correct breaker was opened.

Enforcement:

Violation: Technical Specification 5.4.1.a, requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures in Appendix A to Regulatory Guide 1.33. Appendix A, Section 9.a, states, in part, that maintenance that can affect performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established Procedure SYS GK-121 to restore CRIVS from testing.

Contrary to above, on January 15, 2021, the licensee failed to properly pre-plan and perform maintenance that can affect performance of safety-related equipment in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Specifically, the licensee failed to implement Procedure SYS GK-121 and opened the incorrect breaker rendering safety-related train A CREVS inoperable.

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 71153 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: Technical Specification (TS) 3.0.4 requires, in part, that when a limiting condition for operation (LCO) is not met, entry into a mode or other specified condition in the applicability shall only be made when the associated actions to be entered permit continued operation in the mode or other specified condition in the applicability for an unlimited period of time, after performance of a risk assessment addressing inoperable systems and components, or when an allowance is stated.

Contrary to the above, on May 15, 2018 and November 2, 2019, with LCO 3.6.1 not met, the station entered into a mode and specified condition in the applicability when the associated actions to be entered did not permit continued operation in the mode and specified condition in the applicability for an unlimited period of time; without performance of a risk assessment addressing inoperable systems and components; and without a stated allowance.

Specifically, the licensee transitioned Wolf Creek Generating Station from Mode 5 into Mode 4 with Containment Purge Valve Penetration 161 being inoperable due to not meeting the maximum allowable leakage rate for the penetration. The licensee was able to isolate the penetration in accordance with TS 3.6.3.

Significance/Severity: Green. The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix G, Shutdown Safety SDP. The inspectors determined the finding degraded the physical integrity of the reactor containment due a degraded containment isolation valve and required screening in accordance with Inspection Manual Chapter 0609 Appendix H, Containment Integrity Significance Determination Process. The finding was determined to be of very low safety significance (Green) at step 2.2 in Table 7.2 because it belongs to the late time window, after the refueling operation and greater than 8 days of the outage.

Corrective Action References: Condition Reports 10000201 and 10001583

Assessment: Problem Identification for Traditional Enforcement Violation Trend 92723 Determine that the licensees evaluation identifies who and under what conditions the issue(s) was identified.

The inspectors determined that the licensees evaluation of these violations clearly identified how the issue was identified. Specifically, the NRC identified each of the four violations issued to the licensee. The licensee identified two of the violations.

Determine that the evaluation documents how long the issue existed, and prior opportunities for identification.

The inspectors determined that the evaluation properly considered how long the issues existed and prior opportunities for identification. Specifics regarding each of the evaluated violations are as follows.

NCV 05000482/2018002-01, Announcement of an NRC Inspectors Presence by Station Personnel

Because of the nature of the issue, it did not represent an existing issue but rather one of sporadic occurrence. The licensees similar-same extent of condition evaluation identified that there was one prior event on February 27, 2018 where an individual announced the presence of the NRC during an emergency plan drill, but there was a missed opportunity to potentially prevent the issue from occurring if corrective actions had been taken on this previous instance. No other instances of announcing NRC inspector presence were identified.

NCV 05000482/2018003-02, Failure to Submit a Licensee Event Report for a Condition Prohibited by Technical Specifications

The evaluation identified that once executive management made the decision that the event did not need to be reported, there wouldnt have been an opportunity to identify this issue without any new information.

NCV 05000482/2019001-01, Failure to Provide Unfettered Access to an NRC Resident Inspector

The licensees evaluation identified previous issues and corrective actions for the processes which could potentially affect unfettered access to NRC inspectors. However, no opportunities to prevent occurrence of the violation were identified because no previous access issues occurred that would drive them to identify such opportunities.

NCV 05000482/2019002-01, Failure to Submit a Revision to Section 9.1.4.3 of the Wolf Creek Updated Final Safety Analysis Report

The evaluation identified that the calculation change which required a USAR update was completed on November 7, 2017. To be timely, the March 2019 USAR revision should have incorporated this change. However, there was condition report action that was tracking the need for a USAR change, but no change request had been generated.

Assessment: Cause, Extent of Condition and Extent of Cause Evaluations for Traditional Enforcement Violation Trend 92723 Determine that the group of Severity Level IV violations received an evaluation at an appropriate level of detail using a systematic method(s) to identify cause(s).

The inspectors determined that the violations received an evaluation at an appropriate level of detail using systematic root cause evaluation methods to identify the causes. In addition to the details provided below for each individual violation, the licensee conducted a common cause evaluation to evaluate the cause of receiving six (including two licensee-identified)violations for impeding the regulatory process. The common cause identified was that station leadership did not effectively reinforce the importance of decisions with a potential NRC regulatory impact by ensuring adequate procedures are available and followed. The contributing cause was that specific process procedures were inadequate to assure that the regulatory process was not impeded.

NCV 05000482/2018002-01, Announcement of an NRC Inspectors Presence by Station Personnel

The violation was evaluated via a Barrier Analysis, an Organizational and Programmatic Investigation, and a Safety Culture Assessment. These methods identified the probable cause as a lack of a documented process that includes initial and continuing training to ensure that the arrival and presence of an NRC inspector is not announced. The contributing cause was identified as error in judgment by the technician who made the announcement.

NCV 05000482/2018003-02, Failure to Submit a Licensee Event Report for a Condition Prohibited by Technical Specifications

The violation was evaluated via a Barrier Analysis, an Organizational and Programmatic Investigation, and a Safety Culture Assessment. These methods identified that the probable cause was that leadership exhibited incorrect behaviors for conservative bias in decision making and procedural compliance. The contributing cause was that procedures implementing decision making for reportability and resolving Differing Professional Opinion (DPO) were inadequate and allowed management to choose not to report the licensee event report (LER).

NCV 05000482/2019001-01, Failure to Provide Unfettered Access to an NRC Resident Inspector

The violation was evaluated via a Barrier Analysis, an Organizational and Programmatic Investigation, and a Why Tree

Analysis.

These methods identified the probable cause as inadequate change management and leadership oversight, inadequate guidance, and the lack of training for Security leadership on NRC unfettered access. The contributing cause was identified as the removal of the NRC inspectors from the Mis-Match Report by the badging subject matter expert, which left Security with no way to know, other than direct communication, when to update training data in the system which affects badging, and therefore access.

NCV 05000482/2019002-01, Failure to Submit a Revision to Section 9.1.4.3 of the Wolf Creek Updated Final Safety Analysis Report

The violation was evaluated via a Barrier Analysis, and a Why Tree

Analysis.

These methods identified that the probable cause was the lack of guidance in Wolf Creek procedures for processing USAR changes for calculation changes made outside the modifications process. The contributing cause was engineering organizations lack of knowledge for timeliness requirements for USAR changes.

Determine that the evaluation included a consideration of how prior occurrences in the same traditional enforcement area (willfulness, regulatory process or consequences)were addressed by the licensee.

The inspectors determined that the evaluation appropriately included prior occurrences of similar problems.

Determine that the evaluation addresses the extent of condition and the extent of cause of the problem.

The inspectors determined that the licensee performed an adequate evaluation of the extent of condition and the extent of causes. In addition to the details provided below for each individual violation, the licensee addressed the extent of condition in the common cause evaluation. The evaluation reviewed information from each of the individual violations extent of condition reviews and concluded that there was a common theme of not taking action as required by NRC regulations.

NCV 05000482/2018002-01, Announcement of an NRC Inspectors Presence by Station Personnel

The licensees similar-same extent of condition evaluation identified that there was one instance prior to this event where an individual announced the presence of the NRC during an emergency plan drill. This announcement took place between a Wolf Creek employee and a State employee. The licensee identified that there was a missed opportunity to potentially prevent the issue from occurring if corrective actions had been taken on this previous instance. No other instances of announcing NRC inspector presence were identified.

NCV 05000482/2018003-02, Failure to Submit a Licensee Event Report for a Condition Prohibited by Technical Specifications

The licensees extent of cause identified nine instances from 2015 through November 2019 for late or missing NRC reports outside of the LER reporting requirements. These events occurred due to the lack of an action to track the submittal of the LER. There were no instances caused by executive level decision making.

NCV 05000482/2019001-01, Failure to Provide Unfettered Access to an NRC Resident Inspector

The licensees extent of condition evaluation identified three additional examples of badging and access level issues which interrupted immediate unfettered access of NRC inspectors.

In addition, the licensees second effectiveness follow-up identified one additional instance of a badging issue which resulted in a five-minute wait for access for an NRC inspector at the Main Access Facility. The underlying causes for all these instances were enveloped by the causes identified in the licensees evaluation.

NCV 05000482/2019002-01, Failure to Submit a Revision to Section 9.1.4.3 of the Wolf Creek Updated Final Safety Analysis Report

The licensees extent of condition identified two additional examples of calculations which required a USAR change, in which the calculation package was finalized without a USAR update. The review also identified an adverse trend in timely USAR updates, which was included within the scope of the common cause evaluation. The extent of condition review concluded that there was a weakness in issuing USAR change requests for calculations not associated with change packages.

Assessment: Corrective Actions for Traditional Enforcement Violation Trend 92723 Determine that appropriate corrective action(s) are specified for each cause identified for the group of violations or that there is an evaluation indicating that no actions are necessary.

The inspectors determined that appropriate corrective actions were specified for each cause identified for each of the violations reviewed, including methods for long term sustainability for the corrective actions. The inspectors did not identify any deficiencies with the corrective actions. The common cause evaluation provided numerous corrective actions which focused on training licensee personnel on rules and regulations that affect their work and providing personnel with processes and procedures which provide staff with the appropriate level of guidance for the work activities they are conducting.

NCV 05000482/2018002-01, Announcement of an NRC Inspectors Presence by Station Personnel

To address the probable cause, the licensee issued a news article to the station regarding the requirement for not announcing NRC inspectors, revised their procedure for supplemental personnel on-boarding as well as the on-boarding lesson plan to provide guidance for interaction with the NRC, and planned to develop a periodic refresher training on the applicable requirements. To address the contributing cause, the licensee issued a news article to the station, conducted a stand down with contractor employees and conducted briefs during Radiation Protection shift turnover meetings to explain the regulatory requirements.

NCV 05000482/2018003-02, Failure to Submit a Licensee Event Report for a Condition Prohibited by Technical Specifications

To address the probable cause, the plant manager had discussions with management about conservative decision making, and final approval of LERs resides with the director of Nuclear and Regulatory Affairs. To address the contributing cause, the licensee updated procedures implementing decision making for reportability and the DPO process. Updates included licensing management review of Reportability Evaluation Requests and adding a requirement that the DPO process be entered as soon as there is disagreement on the need to submit an LER, and if the disagreement is not resolved before the due date, an LER must be submitted.

NCV 05000482/2019001-01, Failure to Provide Unfettered Access to an NRC Resident Inspector

To address the probable cause, the licensee developed a Desktop Instruction to delineate the requirements and responsibilities associated with maintaining plant access data for NRC personnel. The licensee revised the personnel access procedure to provide appropriate guidance on NRC access. In addition, the licensee provided training to Security leadership on unfettered access requirements. To address the contributing cause, the licensee added back the NRC badged personnel training expiration dates to the daily Security/SSIS Badge Expiration Date Mis-Match Report to ensure Security is notified when NRC training dates need to be updated to maintain NRC badge access.

NCV 05000482/2019002-01, Failure to Submit a Revision to Section 9.1.4.3 of the Wolf Creek Updated Final Safety Analysis Report

To address the probable cause, 10 CFR 50.59 screeners were trained, and procedures were updated to include guidance for processing USAR changes required for calculations outside the modifications process. To address the contributing cause and extent of condition, training was implemented that explained the connections between the design basis documents and the licensing basis documents.

Determine that the corrective actions have been prioritized with consideration of the regulatory compliance.

The inspectors determined that the corrective actions for each of the violations reviewed have been prioritized with consideration of the regulatory compliance. The inspectors did not identify any deficiencies with the licensees corrective action prioritization involved in the common cause evaluation or any of the individual violations. Many of the corrective actions associated with the common cause evaluation were completed prior to the inspection. The majority of those that are not complete are associated with continued communication and training, tracking resolution of identified issues, and effectiveness follow-up reviews. The open actions are scheduled to be completed by the end of 2021.

Determine that a schedule has been established for implementing and completing the corrective actions.

The inspectors reviewed the licensees schedule for implementing and completing the remaining corrective actions for each of the violations reviewed. The inspectors did not identify any deficiencies with the schedule for implementation of the corrective actions involved in the common cause evaluation or any of the individual violations. The majority of the corrective actions that were not completed by the time of this inspection were associated with continued communication and training, tracking resolution of identified issues, and effectiveness follow-up reviews. The open actions are scheduled to be completed by the end of 2021.

Determine that measures of success have been developed for determining the effectiveness of the corrective actions to prevent recurrence.

The inspectors reviewed the licensees completed and planned effectiveness reviews and determined that the licensee had established adequate measures of success to determine whether the corrective actions related to this violation would be effective to preclude repetition. The first planned effectiveness review associated with the common cause evaluation is complete, and the second planned effectiveness review was in progress. However, based on the totality of the actions taken to date and the results of completed effectiveness reviews involved in the common cause evaluation or any of the individual violations, the inspectors determined that the remaining open effectiveness reviews were appropriate to identify and correct any weaknesses in the corrective actions to preclude repetition.

Conclusions

The inspectors reviewed the licensees cause evaluation and corrective actions associated with these violations and concluded that the licensees actions met the inspection objectives in Inspection Procedure 92723 to provide assurance that:

(1) the cause(s) of the violations are understood by the licensee;
(2) the extent of condition and extent of cause of the violations are identified; and
(3) licensee corrective actions for the violations are sufficient to address the cause(s).

EXIT MEETINGS AND DEBRIEFS

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

  • On March 5, 2021, the inspectors presented the IP 92723 inspection results to Mr. C. Reasoner, Chief Executive Officer and Chief Nuclear Officer, and other members of the licensee staff.
  • On April 7, 2021, the inspectors presented the integrated inspection results to Mr. J. McCoy, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Calculations

BN-J-003

Calculation of Refueling Water Storage Tank Temperature

Indication and Low Temperature Alarm Loop Uncertainty

EF-M-029

Minimum ESW Temperature Rise

1, 1 CCN1, 1

CCN2

EF-M-030

Determine ESW Warming Line Flow

Corrective Action

Documents

Resulting from

Inspection

Condition Reports 10001336, 10001644

Drawings

M-12EF01

Piping Instrumentation Diagram Essential Service Water

System

M-12EF02

Piping Instrumentation Diagram Essential Service Water

System, Piping Instrumentation Diagram Essential Service

Water System

M-K2EF01

Piping and Instrumentation Diagram Essential Service Water

System

Procedures

AI 14-006

Severe Weather

ALR 00-047A

RWST Temp LO-LO

AP 21C-000

Wolf Creek Substation

OFN SG-003

Natural Events

STN EF-020A

ESW Train A Warming Line Verification

STN EF-020B

ESW Train B Warming Line Verification

SYS EF-205

ESW/Circ Water Cold Weather Operations

2A

SYS OPS-008

Cold Weather Operations

Work Orders

WO

20-460744-000, 20-460808-000

71111.04

Corrective Action

Documents

Condition Reports 132913, 135148, 102680, 146496, 145615, 144693, 2007-

000368, 2007-01786

Corrective Action

Documents

Resulting from

Inspection

Condition Reports 10001214, 10002516

Drawings

KD-7496

One Line Diagram

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

M-12AL01

Piping and Instrumentation Diagram Auxiliary Feedwater

System

M-12EF01

Piping and Instrumentation Diagram Essential Service Water

M-12EF02

Piping and Instrumentation Diagram Essential Service Water

M-12GF01

Piping and Instrumentation Diagram Miscellaneous Buildings

HVAC

M-1H1531

Heating Ventilating & Air Cond. Auxiliary Building

EL. 2047-6 Area-3

M-1H1541

Heating Ventilating & Air Cond. Auxiliary Building

EL. 2047-6 Area 4

M-223A-00012

Swing Check Valve with Lever

W12

Miscellaneous

APF 26A-003

OFN NB-042

E-1F9915

Design Basis Document for OFN RP-07, Control Rom

Evacuation

OE 23563

Diesel Generator Response While Connected to Electrical

Grid (River Bend)

11/06/2006

WCRE 34

Fourth 10-Year Interval Inservice Testing Basis Document

Procedures

ALR 00-013A

13-48 BKR Trip

ALR 00-013C

  1. 1 SWGR BKR Trip

ALR 00-018B

NB01 Bus UV

ALR 00-020B

DG NE01 UV or UF

8A

ALR 00-023B

DG NE02 UV or UF

9A

ALR 00-127B

ESW VLV to AFW Opening

ALR 00-127C

AFW Suct Switch to ESW

8B

ALR 00-127D

CST Lev LOLO2

ALR 00-127E

CST Lev LOLO1

10A

AP 26A-003

CFR 50.59 Reviews

AP 26C-004

Operability Determination and Functionality Assessment

CKL AL-120

Auxiliary Feedwater Normal Lineup

44A

CKL AL-120

Auxiliary Feedwater Normal Lineup

44A

CKL GF-120

Miscellaneous Building HVAC System Valve Breaker and

Switch Checklist

15B

CKL GK-121

Control Building HVAC Valve Checklist

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

EMG E-1

Loss of Reactor or Secondary Coolant

EMG E-2

Faulted Steam Generator Isolation

MEC-027

A/D Swing Check Valve with Lever Disassembly and

Assembly

OFN NB-042

Loss of Offsite Power to NB01 (NB02) with EDG Paralleled

OFN RP-017

Control Room Evacuation

OFN RP-13

Control Room not Habitable

OFN RP-17

Control Room Evacuation

OFN SG-003

Natural Events

STS AL-101

MDAFW Pump A Inservice Test

STS AL-102

MDAFW Pump B Inservice Pump Test

STS AL-103

TDAFW Pump Inservice Pump Test

SYS AL-120

Motor Driven or Turbine Driven AFW Pump Operations

55A

SYS NB-200

Transferring XNB01 Supply Between SL7 and #7

Transformer

Work Orders

WO

19-451842-000, 19-451842-002, 19-451842-001

71111.05

Corrective Action

Documents

Resulting from

Inspection

Condition Reports 10000792, 10001398

Miscellaneous

BAP 21-0041

Breach Authorization Permit

E-1F9900

Post-Fire Safe Shutdown Operator Manual Actions

E-1F9905

Fire Hazard Analysis

WCRE-35

Boundary Matrix

Procedures

ALR KC-888

Fire Protection Panel KC-008 Alarm Response

AP 10-106

Fire Preplans

OFN KC-016

Fire Response

STN FP-815C

Heat/Smoke Actuating Device Operational Test Bechtel

Zone 111

71111.06

Calculations

FC-03

Aux Feedwater Turbine Driven Pressurization Analysis

FL-13

Auxiliary Building Area 5 Flooding

LE-M-002

Flood Level in Auxiliary Building Rooms 1206 and 1207 due

to Pipe Break

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Corrective Action

Documents

Condition Reports 10000367

Drawings

M-12AN01

Piping and Instrumentation Diagram Demineralized Water

Storage and Transfer System

M-12AP01

Piping and Instrumentation Diagram Condensate Storage

and Transfer System

M-12LE01

Piping and Instrumentation Diagram Turbine Building and

Aux Feedwater Rooms Oily Waste System

Miscellaneous

BAP 20-0300

Breach Authorization Permit

SMP 21-004

Simulator Modification Package SMP 21-003

Procedures

ALR 00-095C

AFP RM Sump Lev HI

ALR 00-09C

AFP RM Sump Lev Hi

EMG E-2

Faulted Steam Generator Isolation

MPM-XX-002

Watertight Doors Preventive Maintenance Activity

OFN AB-041

Steamline or Feedline Leak

5A

STN PE-56

ESW Emergency Make-Up Piping Flow Test

WCRE-35

Boundary Matrix

Work Orders

WO

20-463920-002

71111.11Q Corrective Action

Documents

Condition Reports 10000731

Procedures

EMG E-0

Reactor Trip or Safety Injection

EMG ES-02

Reactor Trip Response

GEN 00-004

Power Operation

GEN 00-005

Minimum Load to Hot Standby

71111.12

Calculations

AL-MH-003

Engineering Assessment of Check Valves ALV002, 003

Corrective Action

Documents

Condition Reports 019284, 019314, 102275, 122009, 123140, 131106, 135130,

136346, 136347, 136369, 136388, 138072, 141555, 132913,

135148, 102680, 146496, 145615, 144693, 122009, 142821,

74686, 58238

Drawings

E-025-00007

Sheet 116

CST to TD Aux FW PMP ISO, ALHV0036

W15

E-13AL05A

Schematic Diagram Aux Feedwater Pumps, Discharge

Control Air Operated Valves

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

M-12AL01

Piping and Instrumentation Diagram Auxiliary Feedwater

System

Engineering

Changes

CCP-011927

Crompton MOV Longlife Grease Approval for Limitorque

Motor Operators

Miscellaneous

E-025-00003

Limitorque Design Information

W13

E-025-00005

Instruction Manual for Limitorque Actuator Instructions and

Maintenance

W6

SCA-92-0037

Grease for Limitorque Main Gear Box

WCRE-03

Tank Document

WCRE-34

Fourth 10-Year Interval Inservice Testing Basis Document

Procedures

23D-001

Motor Operated Valve Program

AP 16-003

Master Lubrication List and Control of Lubricants

AP 16E-002

Post Maintenance Testing Development

20A

BD-EMG C-0

Loss of All AC Power

EMG C-0

Loss of All AC Power

MGE LT-099

MOV Diagnostic Testing

MPM LT-001

Limitorque Operator Minor Maintenance, Lubrication, and

Inspection

STS AL-201A

MDAFW Pump A Inservice Check Valve Test

STS AL-201C

Turbine Driven Auxiliary Feedwater System Inservice Valve

Test

STS AL-212

MD AFP Comprehensive Pump Testing, Flow Path

Verification and CV Testing

STS CR-001

Shift Log for MODES 1, 2, and 3

111

Work Orders

WO

17-431852-000, 17-432441-015, 19-451842-000, 19-

451842-002, 19-451842-001, 19-456699-000, 19-456822-

000, 20-461287-000, 20-463564-000, 18-438701-000, 17-

431852-000, 18-438701-001, 19-448738-000, 19-453980-

000, 19-453980-002, 19-453980-004, 19-450030-000, 18-

439911-000, 20-461652-000

71111.13

Calculations

DCP 020024

Incorporate the Connection of a Temporary Fire Pump into

Design

Corrective Action

Documents

Condition Reports 136595, 136970, 137985, 140012, 140045, 10000509,

10000715, 10000718, 10000838, 10000839, 10001662

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Corrective Action

Documents

Resulting from

Inspection

Condition Reports 10000899, 10000916, 10000931

Drawings

M-0023

Sheet 7, P&ID Fire Protection System Temporary Fire Pump

Installation and Operation Requirement

Miscellaneous

BAP-21-0019

Breach Authorization Permit BAP-21-0019

M-10KC

System Description Fire Protection Systems

WCRE-35

Boundary Matrix

Procedures

AI 22C-013

Protected Equipment Program

AP 10-103

Fire Protection Impairment Control

AP 10-104

Breach Authorization

AP 22C-003

On-Line Nuclear Safety and Generation Risk Assessment

STN FP-209

Fire Pump Performance and Sequential Start Test

SYS FP-280

Temporary Diesel Fire Pump Installation and Removal

SYS FP-290

Temporary Diesel Fire Pump Operations

Work Orders

WO

20-457462-000, 20-457742-000, 20-463309-002,

20-464923-000, 21-468880-000

71111.15

Calculations

AL-30-WC

AFW System Setpoints: Pump Suction Pressure; Automatic

ESW Switchover; and CST Low Level

3, 3-CN003,

3-CN005

BN-20

RWST Volumes and Level Set Points

BN-M-013

Time Available for Injection, ECCS, and Containment Spray

Pumps Transfer and Evaluation of Air Entrainment at Empty

Alarm

2, 2-CN001

EF-M-046

UHS Analysis with Initial Lake Temperatures Up to 94

degrees F

FL-01

Flooding of the Auxiliary Building, 1974 Elevation

SA-15-004

Auxiliary Building Emergency Exhaust Signal Barrier Closure

Times to Support Licensing Basis Accident Analyses

Assumptions

Corrective Action

Documents

Condition Reports 118849, 130770, 136595, 136970, 137985, 138419, 140012,

140045, 00069789, 10000201, 10000509, 10000513,

10000899, 10000916, 10001679, 10001914, 10001922

Corrective Action

Condition Reports 10000724, 10000774, 10001662, 10001689

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

Resulting from

Inspection

Drawings

M-12EG03

Piping and Instrumentation Diagram Component Cooling

Water System

M-12LE02

Piping and Instrumentation Diagram Control and Diesel Gen

BLDG Oily Waste System

Engineering

Changes

DCP 07225

Emergency Makeup Water Requirement for AFW from

ESW/UHS

Miscellaneous

16577-M-658

Technical Specification for Contract for Furnishing, Installing,

and Testing Halgenated Agent Extinguishing System

BAP 21-002

Breach Authorization Permit BAP 21-002

BAP-19-0102

Breach Authorization Permit BAP-19-0102

BAP-21-0019

Breach Authorization Permit BAP-21-0019

CKL ZL-001

Auxiliary Building Reading Sheets

111

E-1F9905

Fire Hazard Analysis

WCRE-34

Fourth 10-Year Interval Inservice Testing Basis Document

WCRE-35

Boundary Matrix

WR 21-136847

Work Request

Procedures

AP 10-104

Breach Authorization

AP 22A-001

Screening, Prioritization and Pre-Approval

AP 26C-004

Operability Determination and Functionality Assessment

AP 29E-001

Program Plan for Containment Leakage Measurement

FL-08

Control Building Flooding

SYS GT-300

Unit Ventilation Outage Fan Shutdown

16A

Work Orders

18-435355-000, 21-469341-000

71111.18

Corrective Action

Documents

Condition Reports 10000527, 10000528, 10000530

Drawings

M-12BB01

Piping and Instrumentation Diagram Reactor Coolant

System

M-12BN01

Piping and Instrumentation Diagram Borated Refueling

Water Storage System

M-12EJ01

Piping and Instrumentation Diagram Residual Heat Removal

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

System

Engineering

Changes

DCP 20008

7300 Control Upgrade - Temp Loop System

Miscellaneous

PWROG-15015-P PWROG Severe Accident Management Guidelines

WCRE-34

Fourth 10-Year Interval Inservice Testing Basis Document

Procedures

AFP 26A-003-01

Applicability Determination

BD-SAM SAG-01

Initial Response

BD-SAM SAG-08

Control Containment Pressure

DB-EMG ES-11

Post LOCA Cooldown and Depressurization

DB-SAM DPG

Diagnostic Process Guideline

EMG C-0

Loss of All AC Power

EMG FR-S1

Response to Nuclear Power Generation/ATWS

23B

GEN 00-006

Hot Standby to Cold Shutdown

103

OFN BB-31

Shutdown LOCA

OFN EC-046

Fuel Pool Cooling and Cleanup Malfunctions

SAM DPG

Diagnostic Process Guideline

SAM SAG-01

Initial Response

2A

SAM SAG-04

Depressurize RCS

SAM SAG-08

Control Containment Pressure

SYS BG-216

Reactor Make-Up Control System Alternate Operations

SYS EJ-120

Startup of a Residual Heat Removal Train

Work Orders

WO

17-433919-002, 17-433919-008, 17-433919-013, 17-

433919-014, 17-433919-025, 17-433919-030, 17-433919-

038

71111.19

Corrective Action

Documents

Condition Reports 10000509, 10000839, 10001063, 10001064, 10001190,

10001662

Procedures

AP 16E-002

Post Maintenance Testing Development

20A

MPE RC-001

Room Cooler Maintenance

STN FP-440

Fire Door Visual Inspection

SYS EG-120

Component Cooling Water System

Work Orders

WO

20-457742-000, 20-465069-001, 20-465069-002, 20-

465055-001, 20-465056-002, 20-465069-001, 20-465056-

001, 20-465056-003, 21-468416-000, 21-468880-000

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.20

Corrective Action

Documents

Condition Reports 10000235, 10000761, 10001193, 10001277, 10001279,

10001335, 10001558, 10002673

Corrective Action

Documents

Resulting from

Inspection

Condition Report

10002965

Miscellaneous

RA 21-0011

Refueling 24 Risk Assessment Team Report

01/25/2021

Procedures

AP 22B-001

Outage Risk Management

SYS BB-215

RCS Drain Down with Fuel in Reactor

SYS NB-201

Transferring NB01 Power Sources

71111.22

Calculations

AL-30-WC

AFW System Setpoints: Pump Suction Pressure; Automatic

ESW Switchover; and CST Low Level

3, 3 -

CN003, and

005

Corrective Action

Documents

Condition Reports 019284, 033352, 123140, 138445, 10000177, 10000336,

10000428, 10000434, 10000446, 10000509, 10000513,

10000590, 10000648, 10000649, 10000650, 10000692,

10000884, 10000885, 10001190, 10001214, 10001473,

10001887, 10001921

Corrective Action

Documents

Resulting from

Inspection

Condition Reports 10000611, 10002036

Drawings

M-12AL01

Piping and Instrument Diagram Auxiliary Feedwater System

M-12AP01

Piping and Instrumentation Diagram Condensate Storage

and Transfer System

Engineering

Changes

DCP 020085

Replace ALV0187 with Check Valve

Miscellaneous

SCA-13-0005

Safety Classification Analysis Isolation Valves ALV0186 and

ALV0188

0, 1

SCA-19-0007

Safety Classification Analysis Check Valve ALV0187

WCNOC-4

Report on Control of Heavy Loads

WCOP-02

Inservice Testing Program for Pumps, Valves, and Snubbers

WCOP-21

Response Time Test Summary

WCRE-34

Fourth 10-Year Interval Inservice Testing Basis Document

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

AP 29B-002

ASME Code Testing of Pumps and Valves

FHP 02-007A

Reactor Vessel Closure Head Removal

OFN BB-005

RCP Malfunctions

STN AP-101

NSAFP Recir Test

STN AP-102

NSAFP Full Flow Test

STS AL-005

ESW Pump Auto Start on AFAS with Low Suction Pressure

Actuation

STS AL-102

MDAFW Pump B Inservice Pump Test

STS AL-210D

AFW Inservice Check Valve Test

STS AL-211

TD AFP Comprehensive Pump Testing, Flow Path

Verification and CV Testing

STS AL-212

MD AFP Comprehensive Pump Testing, Flow Path

Verification and CV Testing

STS CR-001

Shift Log for MODES 1, 2, and 3

111

STS GK-005A

Control Room Ventilation Isolation Response Time Test -

Train A

STS IC-260

Channel Operational Test Auxiliary Feedwater Pump Suction

Pressure Low Transfer to ESW

STS IC-560

Auxiliary Feedwater Pump Low Suction Pressure (Transfer

to ESW) Channel Calibration

STS PE-004

Aux Building and Control Room Pressure Test

19, 20

SYS GK-121

Control Building HVAC Operations

SYS GK-123

Control Building A/C Units Startup and Shutdown

Work Orders

WO

17-432442-009, 18-442286-000, 20-464315-000, 20-

460905-000

71114.06

Corrective Action

Documents

Condition Reports 10001927, 10001928, 10001929, 10001930, 10001931,

10001934, 10001938, 10001939, 10001941, 10001943,

10001946, 10001948, 10001949, 10001950, 10001952,

10001953, 10001954, 10001955, 10001964, 10001981,

10001986, 10001989, 10001991, 10001992, 10001993,

10001994

Miscellaneous

21-SA-01

Emergency Planning Drill

01/27/2021

Procedures

AP 06-002

Radiological Emergency Response Plan

APF 06-002-02

Emergency Action Levels Technical Bases

0B

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

APF 06-002-03

EAL Classification Matrix

0B

EMG E-2

Faulted Steam Generator Isolation

EMG E-3

Steam Generator Tube Rupture

EPP 06-005

Emergency Classification

9A

71152

Corrective Action

Documents

Condition Reports 0069189, 10000513, 10001190, 105027, 104910, 145019,

143559, 143273

Miscellaneous

M-82-00039

Instruction Manual for Component Cooling Water Pumps

W15

Procedures

AP 26C-004

Operability Determination and Functionality Assessment

MPM OS-001

Preventative Maintenance Lubricant Sampling and

Replenishment

Work Orders

WO

21-468416-000, 20-465135-000, 19-456395-000, 20-

464090-000, 20-461060-000

71153

Corrective Action

Documents

Condition Reports 10000201, 10001583

Procedures

AP 29E-001

Program Plan for Containment Leakage Measurement

2723

Corrective Action

Documents

Condition Reports 127691, 131499, 132084, 133798, 138676, 142897,

1002002, 1002003, 1002004

Miscellaneous

Wolf Creek Generating Station Action Closure Document -

NRC Traditional Enforcement Severity Level IV Violation

Common Cause (Condition Report (CR) 131499) Common

Cause Training Actions

Wolf Creek Generating Station Action Closure Document -

NRC Traditional Enforcement Severity Level IV Violation

Common Cause (Condition Report (CR) 131499) Common

Cause Condition Report Station Procedure Actions (CCE

Package B - Actions 9 and 10)

Wolf Creek Generating Station Action Closure Document -

NRC Traditional Enforcement Severity Level IV Violation

Common Cause (Condition Report (CR) 131499) Common

Cause Leadership Training Actions (CCE Package C -

Actions 11, 14 and 20029324)

Wolf Creek Generating Station Action Closure Document -

NRC Traditional Enforcement Severity Level IV Violation

Common Cause (Condition Report (CR) 125106 and

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

138675) Announcing NRC Presence

Wolf Creek Generating Station Action Closure Document -

NRC Traditional Enforcement Severity Level IV Violation

Common Cause (Condition Report (CR) 130158, Revision 2,

and 138677) Unfettered Access

Wolf Creek Generating Station Action Closure Document -

NRC Traditional Enforcement Severity Level IV Violation

(Condition Report (CR) 143185, Revision 1) - Physical

Security Plan (PSP) Submittal not Timely

Wolf Creek Generating Station Action Closure Document -

NRC Traditional Enforcement Severity Level IV Violation -

Failed to Update USAR (CR 133798)

2/05/2021

Wolf Creek Generating Station Action Closure Document -

NRC Traditional Enforcement Severity Level IV Violation -

Failure to Update the Updated Safety Analysis Report

(USAR) (CR 132084, CR 138678)

2/05/2021

Wolf Creek Generating Station Action Closure Document -

Failure to Submit a Licensee Event Report (CR 127691

Revision 2,

CR 138676)

2/24/2021

Basic Cause Evaluation - NRC Sev Level IV Violation 3rd

Qtr Baseline Inspection '18 (CR 127691)

NRC Traditional Enforcement Violations Common Cause

Evaluation (CR 131499)

Procedures

AP 05D-001

Calculations

AP 05D-001

Calculations

2