IR 05000482/2021001
ML21120A162 | |
Person / Time | |
---|---|
Site: | Wolf Creek ![]() |
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:
Report Number:
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:
- Refueling water storage tank, condensate storage tank, essential service water system, fire protection system, and circulating water system on February 16, 2021
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
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
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
20-460744-000, 20-460808-000
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
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 SWGR BKR Trip
ALR 00-018B
NB01 Bus UV
ALR 00-020B
8A
ALR 00-023B
9A
ALR 00-127B
ALR 00-127C
8B
ALR 00-127D
CST Lev LOLO2
ALR 00-127E
CST Lev LOLO1
10A
CFR 50.59 Reviews
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
19-451842-000, 19-451842-002, 19-451842-001
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
Calculations
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
ALR 00-09C
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
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
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
Motor Operated Valve Program
AP 16-003
Master Lubrication List and Control of Lubricants
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
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
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
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
20-457462-000, 20-457742-000, 20-463309-002,
20-464923-000, 21-468880-000
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
Screening, Prioritization and Pre-Approval
Operability Determination and Functionality Assessment
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
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
17-433919-002, 17-433919-008, 17-433919-013, 17-
433919-014, 17-433919-025, 17-433919-030, 17-433919-
038
Corrective Action
Documents
Condition Reports 10000509, 10000839, 10001063, 10001064, 10001190,
10001662
Procedures
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
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
Corrective Action
Documents
Condition Reports 10000235, 10000761, 10001193, 10001277, 10001279,
10001335, 10001558, 10002673
Corrective Action
Documents
Resulting from
Inspection
Condition Report
10002965
Miscellaneous
Refueling 24 Risk Assessment Team Report
01/25/2021
Procedures
Outage Risk Management
SYS BB-215
RCS Drain Down with Fuel in Reactor
SYS NB-201
Transferring NB01 Power Sources
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
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
17-432442-009, 18-442286-000, 20-464315-000, 20-
460905-000
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
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
Operability Determination and Functionality Assessment
MPM OS-001
Preventative Maintenance Lubricant Sampling and
Replenishment
Work Orders
21-468416-000, 20-465135-000, 19-456395-000, 20-
464090-000, 20-461060-000
Corrective Action
Documents
Condition Reports 10000201, 10001583
Procedures
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
Calculations
Calculations
2