ML091340061

IR 05000482-09-002, on 1/01 - 3/31/2009; Wolf Creek Generating Plant, Integrated Resident and Regional Report; Adverse Weather, Fire Protection, Maintenance Effectiveness, Surveillance Testing, Problem Identification and Resolution, Other A

ML091340061
Person / Time
Site:	Wolf Creek
Issue date:	05/13/2009
From:	Vincent Gaddy NRC/RGN-IV/DRP/RPB-B
To:	Muench R Wolf Creek
References
EA-09-110 IR-09-002
Download: ML091340061 (46)

See also: IR 05000482/2009002

Text

UNITED STATES

NUC LE AR RE G UL AT O RY C O M M I S S I O N

R E GI ON I V

612 EAST LAMAR BLVD , SU I TE 400

AR LI N GTON , TEXAS 76011-4125

May 13, 2009

EA-09-110

Rick A. Muench, President and

Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

SUBJECT: WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION

REPORT AND NOTICE OF VIOLATION 05000482/2009002

Dear Mr. Muench:

On March 31, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Wolf Creek Generating Station. The enclosed integrated inspection report documents

the inspection findings, which were discussed on April 7, 2009, with Mr. Matt Sunseri,

Vice President of Operations and Plant Manager, and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

Based on the results of this inspection, one violation is cited in the enclosed Notice of Violation

(Notice) and the circumstances surrounding this violation are described in detail in the enclosed

report. The violation involved failure to implement corrective actions to address the repetitive

incorrect closure of valves that provide cooling to the reactor coolant pump seals (EA-09-110).

Although determined to be of very low safety significance (Green), this violation is being cited

because one of the criteria specified in Section VI.A.1 of the NRC Enforcement Policy for a cited

violation was satisfied. Specifically, Wolf Creek Nuclear Operating Corporation failed to restore

compliance within a reasonable time after the violation was last identified in NRC Inspection

Report 05000482/2007003-003. Please note that you are required to respond to this letter and

should follow the instructions specified in the enclosed Notice when preparing your response.

The NRC will use your response, in part, to determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

This report also documents six NRC identified findings of very low safety significance (Green).

Five of these findings were determined to involve violations of NRC requirements. However,

because of the very low safety significance and because they are entered into your corrective

action program, the NRC is treating these findings as noncited violations, consistent with

Section VI.A.1 of the NRC Enforcement Policy. If you contest the violations or the significance

of the noncited violations, 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,

Wolf Creek Nuclear Operating Corporation - 2 -

EA-09-110

ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional

Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd, Suite 400,

Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory

Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the Wolf Creek

Generating Station. In addition, if you disagree with the characterization of any finding 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 Regional Administrator, Region IV, and the NRC

Resident Inspector at the Wolf Creek Generating Station. The information you provide will be

considered in accordance with Inspection Manual Chapter 0305.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its

enclosure, will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA/

Vincent G. Gaddy, Chief

Project Branch B

Division of Reactor Projects

Docket No. 50-482

License No. NPF-42

Enclosures: Notice of Violation and

NRC Inspection Report 05000482/2009002

w/attachment: Supplemental Information

cc w/enclosure:

Vice President Operations/Plant Manager

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

Jay Silberg, Esq.

Pillsbury Winthrop Shaw Pittman LLP

2300 N Street, NW

Washington, DC 20037

Supervisor Licensing

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

Wolf Creek Nuclear Operating Corporation - 3 -

EA-09-110

Chief Engineer

Utilities Division

Kansas Corporation Commission

1500 SW Arrowhead Road

Topeka, KS 66604-4027

Office of the Governor

State of Kansas

Topeka, KS 66612-1590

Attorney General

120 S.W. 10th Avenue, 2nd Floor

Topeka, KS 66612-1597

County Clerk

Coffey County Courthouse

110 South 6th Street

Burlington, KS 66839

Chief, Radiation and Asbestos

Control Section

Bureau of Air and Radiation

Kansas Department of Health and

Environment

1000 SW Jackson, Suite 310

Topeka, KS 66612-1366

Chief, Technological Hazards Branch

REMA Region VII

9221 Ward Parkway

Suite 300

Kansas City, MO 64114-3372

Wolf Creek Nuclear Operating Corporation - 4 -

EA-09-110

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.gov)

DRS Director (Roy.Caniano@nrc.gov)

DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (Chris.Long@nrc.gov)

Site Secretary (Shirley.Allen@nrc.gov)

Branch Chief, DRP/B (Vincent.Gaddy@nrc.gov)

Senior Project Engineer, DRP/B (Rick,Deese@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional State Liaison Officer (Bill.Maier@nrc.gov)

NSIR/DPR/EP (Steve.LaVie@nrc.gov)

Senior Enforcement Specialist (Mark.Haire@nrc.gov)

Only inspection reports to the following:

DRS STA (Dale.Powers@nrc.gov)

OEDO RIV Coordinator, (John.Adams@nrc.gov)

ROPreports

R:\_REACTORS\_WC\2009\WC 2009-002 RP CML-vgg ADAMS.doc ADAMS ML091340061

SUNSI Rev Compl. : Yes No ADAMS  : Yes No Reviewer Initials VGG

Publicly Avail  : Yes No Sensitive Yes : No Sens. Type Initials VGG

SRI:DRP/B SPE:DRP/B C:DRS/EB1 C:DRS/EB2 C:DRS/OB

CMLong RDeese TFarnholtz NOkeefe RELantz

/RA/ /RA/ /RA/ /RA/ /RA/

4/27/09 5/4/09 5/5/09 5/5/09 5/5/09

C:DRS/PSB C:DRS/BC ACES C/DRP/B

MPShannon GWerner MHaire VGGaddy

/RA/ /RA/ /RA/ /RA/

5/7/09 5/7/09 4/28/09 5/13/09

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

NOTICE OF VIOLATION

Wolf Creek Nuclear Operating Corporation Docket: 50-482

Wolf Creek Plant Generating Station License: NPF-42

EA-09-110

During an NRC inspection conducted December 10, 2008, through March 31, 2009, a violation

of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the

violation is listed below:

Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part,

that measures shall be established to assure that conditions adverse to quality, such as

failures, malfunctions, deficiencies, deviations, defective material and equipment, and

nonconformances are promptly identified and corrected.

Contrary to the above, from 2001 through March 31, 2009, the licensee failed to

establish measures to assure that conditions adverse to quality are promptly identified

and corrected. Specifically, the licensee failed to identify the adverse condition of and to

take corrective action for the repetitive, inappropriate closure of the reactor coolant pump

thermal barrier heat exchanger valves, inappropriate closure of the downstream

component cooling water containment isolation valves, and inappropriate circuit

breakers opening associated with the above thermal barrier valves.

This violation is associated with a Green Significance Determination Process finding.

Pursuant to the provisions of 10 CFR 2.201, Wolf Creek Nuclear Operating Corporation is

hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the

Regional Administrator, Region IV, and a copy to the NRC Senior Resident Inspector at the

facility that is the subject of this Notice of Violation (Notice), within 30 days of the date of the

letter transmitting this Notice. This reply should be clearly marked as a "Reply to Notice of

Violation EA-09-110," and should include: (1) the reason for the violation, or, if contested, the

basis for disputing the violation or severity level, (2) the corrective steps that have been taken

and the results achieved, (3) the corrective steps that will be taken to avoid further violations,

and (4) the date when full compliance will be achieved. Your response may reference or include

previous docketed correspondence, if the correspondence adequately addresses the required

response. If an adequate reply is not received within the time specified in this Notice, an Order

or a Demand for Information may be issued as to why the license should not be modified,

suspended, or revoked, or why such other action as may be proper should not be taken. Where

good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with the

basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory

Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not

include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. If personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

-1- Enclosure

response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. If you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in

detail the bases for your claim of withholding (e.g., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required by

10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information. If safeguards information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21.

Dated this __13th__ day of May 2009

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-482

License: NPF-42

Report: 05000482/2009002

Licensee: Wolf Creek Nuclear Operating Corporation

Facility: Wolf Creek Generating Station

Location: 1550 Oxen Lane SE

Burlington, Kansas

Dates: January 1 through March 31, 2009

Inspectors: C. Long, Senior Resident Inspector

B. Tindell, Resident Inspector, Comanche Peak

P. Elkmann, Senior Emergency Preparedness Specialist

P. Jayroe, Project Engineer

M. Hayes, Reactor Inspector, Project Engineer

Approved By: V. G. Gaddy, Chief, Project Branch B

Division of Reactor Projects

-1- Enclosure

SUMMARY OF FINDINGS

IR 05000482/2009002; 1/01 - 3/31/2009; Wolf Creek Generating Plant, Integrated Resident and

Regional Report; Adverse Weather, Fire Protection, Maintenance Effectiveness, Surveillance

Testing, Problem Identification and Resolution, Other Activities.

The report covered a 3-month period of inspection by resident inspectors and an announced

baseline inspection and by regional based inspectors. Five Green noncited violations, one

Green finding, and one Green cited violation were identified. The significance of most findings

is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609,

Significance Determination Process. Findings for which the significance determination

process does not apply may be Green or be assigned a severity level after NRC management

review. The NRC's program for overseeing the safe operation of commercial nuclear power

reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated

December 2006.

A. NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Initiating Events

• Green. The inspectors identified a cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Conditions Adverse to Quality, involving Wolf Creeks failure to

correct the cause of the reactor coolant pump thermal barrier component cooling

water heat exchanger outlet valves stroking closed on high flow. Specifically,

between 2001 and 2009, Wolf Creek experienced repeated cases of the reactor

coolant pump thermal barrier component cooling water heat exchanger outlet

valves stroking closed during component cooling water pump swaps and during

isolations of the radioactive waste evaporators. Wolf Creek reinitiated evaluation

of the issue after the inspectors questions but did not review the impact on the

operators ability to open the valves given the valves circuit breakers opening.

Repeated throttle valve adjustments have not been successful in stopping the

valve closures. Wolf Creek has corrective action pending to modify valve

circuitry but it has not been implemented. This issue is being tracked by the

licensee as Condition Report 2009-02074.

The failure to correct a condition adverse to quality of ensuring reactor coolant

pump seal cooling as described in the Updated Safety Analysis Report is a

performance deficiency. The finding is more than minor because it is associated

with the equipment performance attribute for the Initiating Events Cornerstone;

and, it affected the cornerstone objective to limit the likelihood of those events

that upset plant stability and challenge critical safety functions during shutdown

as well as power operations. The finding was determined to be of very low safety

significance because the finding would not result in exceeding the Technical

Specification limit for identified reactor coolant system leakage and would not

have affected other mitigation systems resulting in a total loss of the seal cooling

safety function. This finding is being cited because the licensee failed to

establish measures to assure this condition adverse to quality was promptly

identified and corrected. This finding has a crosscutting aspect in the area of

human performance associated with the decision making component because,

even though numerous instances of valve closures occurred since the first

-1- Enclosure

noncited violation, Wolf Creek downgraded the condition report. Using

nonconservative assumptions, the licensee consistently viewed this issue as not

having a risk impact because seal injection was not simultaneously lost [H.1 ( b)]

(Section 4OA2).

Cornerstone: Mitigating Systems

• Green. The inspectors identified a finding for allowing low room temperature to

cause a boric acid flow path to be inoperable. The inspectors reviewed a

Performance Improvement Request from 2005, which identified that boric acid

could decrease below its limits if the room cooler was started while lake

temperature was low which would render the system inoperable. The inspectors

reviewed operator logs of safety injection Room A temperature data and found an

instance where room temperature had decreased below the solubility limit for

boric acid which had not been noted by operators. The licensee entered this

issue into their corrective action programs as Condition Reports 2009-00516 and

2009-0145.

The failure to implement the heat tracing corrective action within 3 years to

maintain the boric acid injection piping operable during the winter is a

performance deficiency. The inspectors determined that this finding was more

than minor because this issue aligned with Inspection Manual Chapter 0612,

Appendix E, example 2.f because the heat tracing was required by Condition

Reports 2005-3461 and 2007-2472 but was not installed and the room

temperature dropped below the boron solubility limit. The inspectors evaluated

the significance of this finding using Phase 1 of Inspection Manual Chapter 0609,

Appendix G, Attachment 1, Checklist 3, and determined that the finding was of

very low safety significance because Wolf Creek maintained shutdown margin in

compliance with its Technical Specifications. No violation of regulatory

requirements occurred. The inspectors determined that this finding has a cross

cutting aspect in the area of human performance associated with the resources

component because Wolf Creek did not maintain long term plant safety by not

correcting this long term (3 years) equipment issue and its compensatory

measure with the boric acid system H.1.a] (Section 1R01).

• Green. The inspectors identified a noncited violation of License

Condition 2.C(5)(a) for a degraded fire seal that separated redundant safe

shutdown equipment. Specifically, a silicone foam seal and ceramic fiber board

separating redundant motor-driven auxiliary feedwater trains was degraded so

that it no longer provided a 3-hour rated fire barrier. The licensee entered the

finding into their corrective action program as Condition Report 2009-001087.

The finding was more than minor because it was similar to example 2.e. of NRC

Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, in

that, the performance deficiency impacted the ability of the seal to perform its

function. In addition, the performance deficiency was associated with the

Mitigating Systems cornerstone attribute of Protection Against External Events,

and affected the cornerstone objective to ensure the reliability of systems that

respond to Initiating Events to prevent undesirable consequences. Under NRC

Inspection Manual Chapter 0609, Appendix F, Attachment 2, Degradation

Rating Guidance Specific to Various Fire Protection Program Elements the

-2- Enclosure

finding was associated with a Moderate B degradation due to the seal not being

in a tested or evaluated condition. Using Appendix F, Supplemental Screening

for Fire Confinement Findings, the finding screens as Green due to exposing fire

Area A33 featuring an automatic full area water-based suppression system. The

inspectors determined that this finding has a crosscutting aspect in the area of

problem identification and resolution associated with the corrective action

program component because Wolf Creek failed to identify the degraded seal and

missing ceramic board during previous post waterhammer walkdowns P.1.a]

(Section 1R05).

• Green. On February 6, 2009, the inspectors identified a noncited violation of 10

CFR 50 Appendix B, Criterion XI, Test Control for a procedure that allowed

unacceptable preconditioning of the control rods prior to Technical Specification

Surveillance 3.1.4.2. Wolf Creek did not perform any preconditioning

acceptability review when adopting operating experience and revising Procedure

STS SF-001. The licensee entered this issue into their corrective action

programs as Condition Report 2009-00598.

Unacceptable preconditioning of the control rods is a performance deficiency.

The finding was more than minor because it was associated with the equipment

performance attribute of the mitigating systems cornerstone, and it affected the

cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences.

The inspectors evaluated the significance of this finding under the mitigating

systems cornerstone using Phase 1 of Inspection Manual Chapter 0609.04,

Phase 1 - Initial Screening and Characterization of Findings, and determined

that the finding was of very low safety significance (Green) because, it did not

represent an actual loss of safety function and did not screen as potentially risk

significant due to a seismic, flooding, or severe weather initiating event. This

finding was determined to have a crosscutting aspect in the area of problem

identification and resolution associated with the corrective action program

because the condition report that adopted the operating experience failed to

evaluate NRC guidance regarding preconditioning during surveillance testing

which should have disallowed the procedure change. Therefore, the applicable

procedures were not complete and accurate P.1(c) (Section 1R22).

• Green. A self-revealing noncited violation of Technical Specification 5.4.1(a) was

identified when an on-duty operations shift manager was observed to be

inattentive on multiple occasions in 2004 and 2005. This limited his ability to

monitor the safe operation of the plant, assist the control room supervisor with

the control room command function, and respond in the event of an accident.

The licensee entered this issue into the corrective action program as Condition

Report 2008-000572.

The failure of the shift manager to remain attentive is considered a performance

deficiency. This finding is more than minor because it adversely impacts the

Human Performance attribute of the Mitigating Systems cornerstone, and if left

uncorrected this performance deficiency has the potential to lead to a more

significant safety concern because the shift manager plays an important role in

the oversight of post-accident response by all licensed operators on shift. This

issue was reviewed by NRC management using Inspection Manual Chapter 609,

-3- Enclosure

Appendix M, Significance Determination Process Using Qualitative Criteria. NRC

management reviewed the qualitative factors involved with this finding and

determined that this finding is Green. No crosscutting aspect was identified

because the shift manager has not stood watch for several years, and therefore

this issue was not considered current performance (Section 4OA5).

Cornerstone: Barrier Integrity

• Green. The inspectors identified a noncited violation of Technical Specification 5.4.1.a, Procedures, for failure to follow Procedure AP 12-003, Foreign Material

Exclusion. On January 17, 2009, inspectors conducted a walkdown of the spent

fuel pool area and found numerous untracked tools and other equipment inside

the fuel pool area. Inspectors also found duct tape attached to various fueling

and control rod tools such that duct tape was above and below the water.

Condition Report 2009-001388 was initiated identifying a loss of spent fuel pool

foreign material control. Subsequently, Wolf Creek began re-inventorying all

materials in the spent fuel pool area.

The inspectors determined that the failure to implement multiple steps of

Procedure AP 12-003 was a performance deficiency. This finding is more than

minor because it impacted the Barrier Integrity cornerstone attribute of

configuration control and affected the cornerstone objective to maintain

functionality of the spent fuel pool system. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, this

finding was determined be of very low safety significance because the finding -

only affected the barrier function of the spent fuel pool. This finding has a

crosscutting aspect in the area of human performance associated with the work

practices component because even though personnel had been made aware of

Wolf Creeks policy on procedure use and adherence through site-wide

communications, personnel still failed to follow numerous parts of the procedure,

such that Wolf Creek was not using the procedure H.4.b] (Section 1R05).

• Green. On February 25, 2009, the inspectors identified a noncited violation of

10 CFR 50.65 a(2), the Maintenance Rule, for failure to demonstrate that the

performance of a containment isolation valve was effectively controlled through

the performance of preventive maintenance such that the valve remained

capable of performing its intended function. An inadequate Maintenance Rule

evaluation was performed after a containment isolation valve (SJHV0005)

exceeded its Maintenance Rule a(2) performance criteria, and as a result goal

setting and monitoring were not performed as required by paragraph a(1) of the

Maintenance Rule. This issue was entered into the licensees corrective action

program as Condition Report 2009-001667.

The failure to follow 10 CFR 50.65 a(2) and properly evaluate the failed valve,

establish performance goals, and monitor its performance is considered a

performance deficiency. Per Inspection Manual Chapter 0612, Appendix E,

Section 7, this finding is more than minor because failure to demonstrate

effective control of performance or condition and not putting the affected

structures, systems, and components in (a)(1) necessarily involves degraded

structures, systems, or components performance or condition. Under NRC

Inspection Manual Chapter 0609.04, the Phase I Significance Screening

-4- Enclosure

Process, it was found that the finding is of very low safety significance because it

does not represent an actual open pathway in the physical integrity of the reactor

containment. This finding was determined to have a crosscutting aspect in the

area of problem identification and resolution associated with the corrective action

program because the licensee failed to properly classify, prioritize, and evaluate

a condition adverse to quality P.1.c] (Section 1R12).

-5- Enclosure

REPORT DETAILS

Summary of Plant Status

The plant started the inspection period at 100 percent rated thermal power and remained there

until March 27, 2009, when two of three 345 kV power lines were lost. Reactor power was

subsequently reduced to 80 percent. Wolf Creek returned to full power on March 30, 2009,

when two of the 345 kV lines were restored and breaker 345-110 could be isolated for repairs.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and

Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of the licensees adverse weather procedures for

seasonal extremes (e.g., extreme high temperatures, extreme low temperatures, or

hurricane season preparations). The inspectors verified that weather-related equipment

deficiencies identified during the previous year were corrected prior to the onset of

seasonal extremes; and evaluated the implementation of the adverse weather

preparation procedures and compensatory measures for the affected conditions before

the onset of, and during, the adverse weather conditions

During the inspection, the inspectors focused on plant-specific design features and the

licensees procedures used to mitigate or respond to adverse weather conditions.

Additionally, the inspectors reviewed the Updated Safety Analysis Report and

performance requirements for systems selected for inspection, and verified that operator

actions were appropriate as specified by plant-specific procedures. Specific documents

reviewed during this inspection are listed in the attachment. The inspectors also

reviewed corrective action program items to verify that the licensee was identifying

adverse weather issues at an appropriate threshold and entering them into their

corrective action program in accordance with station corrective action procedures. The

inspectors reviews focused specifically on the following plant systems:

• February 2, 2009, insufficient essential service water warming line temperature,

and February 3, 2009, boric acid system piping temperature

These activities constitute completion of one readiness for seasonal adverse weather

sample as defined in IP 71111.01-05.

b. Findings

Introduction. On January 27, 2009, the inspectors identified a Green finding for allowing

low room temperature to challenge the boric acid flow path due to an uninstalled

temporary modification.

-6- Enclosure

Description. On January 27, 2009, the inspectors walked down the safety injection

pump Room A and noted a temporary modification of heat tracing partially installed on

boric acid piping. The inspectors reviewed the temporary modification documentation

and found that Wolf Creek had written Performance Improvement Request 2005-3461 in

December 2005, which identified that if the safety injection pump and the room coolers

were started while lake temperature was low, the room temperature may decrease below

the boric acid solubility limit and that compensatory actions may be needed. The boric

acid system provided reactivity control for emergency boration and boration to hot and

cold shutdown conditions. On February 3, 2009, the inspectors questioned the ability to

accomplish boration during cold weather with incomplete heat tracing. The inspectors

reviewed several years of operator logs of safety injection Room A room temperature

data and found that on March 26, 2008, room temperature decreased to 59.5°F, which is

below the solubility limit for boric acid. On March 24 and 26, 2008, boric acid

concentration determinations were completed for boric acid Tanks A and B and found

that their concentrations were 7530 parts per million and 7680 parts per million,

respectively. The inspectors also reviewed Procedure SYS BG-206, Boric Acid System

Operation, and found that the solubility limit for a 7680 parts per million boric acid

solution was 63°F. Logs taken on March 27, 2008 recorded temperature at 67°F.

Control room operators did not note any deficiencies in STS CR 002, Shift Log Modes

4, 5, and 6, for March 26 or 27, 2008. The inspectors reviewed logs, condition reports,

and risk assessments but could not locate any deficiencies or corrective actions for the

several hours that the boric acid system was inoperable. However, the inspectors found

that during March 26, 2008, the refueling water storage tank was operable and could

have performed the reactivity control function. Wolf Creek was in Mode 6 for Refueling

Outage 16 at this time.

The inspectors reviewed the corrective action history for heat tracing temporary

Modification 07-012-BG. The inspectors reviewed Condition Report 2005-3461 and

found that it was continued under Condition Report 2007-2472. Condition

Report 2007-2472 created Corrective Action 4222 which was to plan and install this

temporary modification. The temporary modification installation work order began on

October 29, 2008. The inspectors found the modification partially installed on

January 27, 2009, and completed on February 9, 2009. Condition Report 2007-2472

also had corrective action to issue guidance to operators taking temperature readings in

the safety injection pump Room A. This guidance was implemented on December 19,

2008, and it instructed operators that the boric acid piping may become inoperable due

to precipitation, if room temperature drops below 67 degrees Fahrenheit.

Analysis. The failure to implement the heat tracing corrective action within 3 years to

maintain the boric acid injection piping operable during the winter is a performance

deficiency. Traditional enforcement does not apply since there were no actual safety

consequences or potential for impacting the NRCs regulatory function, and the finding

was not the result of any willful violation of NRC requirements or Wolf Creek procedures.

The inspectors determined that this finding was more than minor because this issue

aligned with Inspection Manual Chapter 0612, Appendix E, example 2.f because the

heat tracing was required by Condition Report 2007-2472 but it was not installed and the

room temperature dropped below the boron solubility limit on March 26, 2008. The

inspectors evaluated the significance of this finding using Phase 1 of Inspection Manual

Chapter 0609, Appendix G, Attachment 1, Checklist 3, and determined that the finding

was of very low safety significance because Wolf Creek maintained shutdown margin in

compliance with its Technical Specifications. The inspectors determined that this finding

-7- Enclosure

has a cross cutting aspect in the area of human performance associated with the

resources component because Wolf Creek did not maintain long-term plant safety by not

correcting this long-term (3 years) equipment issue and its compensatory measure with

the boric acid system H.1.a].

Enforcement. No violation of regulatory requirements occurred because Wolf Creek still

had one boron injection subsystem available and complied with its Technical

Specifications on March 26, 2008. This finding was of very low safety significance and

the issue was addressed in Wolf Creeks corrective action program as Condition

Reports 2009-000516 and 2009-001495. FIN 05000482/2009002-01, untimely

corrective actions result in room temperature below boric acid solubility limit.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

Since thunderstorms with potential tornados and high winds were forecast in the vicinity

of the facility for March 23, 2009, the inspectors reviewed the licensees overall

preparations and protection for the expected weather conditions. On March 23, 2009,

the inspectors walked down the emergency diesel generators and the transformer yard

because their safety-related functions could be affected or required as a result of high

winds or tornado-generated missiles or the loss of offsite power. The inspectors

evaluated the licensee staffs preparations against the sites procedures and determined

that the staffs actions were adequate. During the inspection, the inspectors focused on

plant-specific design features and the licensees procedures used to respond to

specified adverse weather conditions. The inspectors also toured the plant grounds to

look for any loose debris that could become missiles during a tornado. The inspectors

evaluated operator staffing and accessibility of controls and indications for those

systems required to control the plant. Additionally, the inspectors reviewed the Updated

Safety Analysis Report and performance requirements for systems selected for

inspection, and verified that operator actions were appropriate as specified by plant-

specific procedures. The inspectors also reviewed a sample of corrective action

program items to verify that the licensee identified adverse weather issues at an

appropriate threshold and dispositioned them through the corrective action program in

accordance with station corrective action procedures. Specific documents reviewed

during this inspection are listed in the attachment.

These activities constitute completion of one readiness for impending adverse weather

condition sample as defined in IP 71111.01-05.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignments (71111.04)

.1 Partial Walk downs

a. Inspection Scope

The inspectors performed partial equipment walkdowns of the following risk significant

systems:

-8- Enclosure

• January 7, 2009, Auxiliary Feedwater Train B while Train A auxiliary feedwater

out of service for preventive maintenance

• January 27, 2009, Safety Injection Train A while Train B safety injection out of

service for preventive maintenance

• March 11, 2009, Emergency Diesel Generator B auxiliaries while Emergency

Diesel Generator A out of service for preventive maintenance

The inspectors selected these systems based on their risk significance relative to the

Reactor Safety cornerstones at the time they were inspected. The inspectors attempted

to identify any discrepancies that could affect the function of the system, and, therefore,

potentially increase risk. The inspectors reviewed applicable operating procedures,

system diagrams, Updated Safety Analysis Report, Technical Specification requirements,

administrative Technical Specifications, outstanding work orders, condition reports, and

the impact of ongoing work activities on redundant trains of equipment in order to identify

conditions that could have rendered the systems incapable of performing their intended

functions. The inspectors also walked down accessible portions of the systems to verify

system components and support equipment were aligned correctly and operable. The

inspectors examined the material condition of the components and observed operating

parameters of equipment to verify that there were no obvious deficiencies. The

inspectors also verified that the licensee had properly identified and resolved equipment

alignment problems that could cause Initiating Events or impact the capability of

Mitigating Systems or Barriers and entered them into the corrective action program with

the appropriate significance characterization. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of three partial system walk down samples as

defined in IP 71111.04-05.

b. Findings

No findings of significance were identified.

.2 Semi-Annual Complete System Walk down

a. Inspection Scope

On February 25, 2009, the inspectors performed a complete system alignment

inspection of the auxiliary feedwater system to verify the functional capability of the

system. The inspectors selected this system because it was considered both safety

significant and risk significant in the licensees probabilistic risk assessment. The

inspectors walked down the system to review mechanical and electrical equipment

lineups, electrical power availability, system pressure and temperature indications, as

appropriate, component labeling, component lubrication, component and equipment

cooling, hangers and supports, operability of support systems, and to ensure that

ancillary equipment or debris did not interfere with equipment operation. The inspectors

reviewed a sample of past and outstanding work orders to determine whether any

deficiencies significantly affected the system function. In addition, the inspectors

reviewed the corrective action program database to ensure that system equipment

alignment problems were being identified and appropriately resolved. Specific

documents reviewed during this inspection are listed in the attachment.

-9- Enclosure

These activities constitute completion of one complete system walk down sample as

defined by IP 71111.04-05.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05)

.1 Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability,

accessibility, and the condition of firefighting equipment in the following risk significant

plant areas:

• January 16, 2009, motor-driven auxiliary Feedwater B and 1989 pipe chase

• March 31, 2009, central alarm station cable penetrations, Area C29

• March 31, 2009, lower cable spreading room, Area C21

• January 16, 2009, spent fuel pool area 2047

The inspectors reviewed areas to assess if licensee personnel had implemented a fire

protection program that adequately controlled combustibles and ignition sources within

the plant; effectively maintained fire detection and suppression capability; maintained

passive fire protection features in good material condition; and had implemented

adequate compensatory measures for out of service, degraded or inoperable fire

protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk

as documented in the plants Individual Plant Examination of External Events with later

additional insights, their potential to affect equipment that could initiate or mitigate a plant

transient, or their impact on the plants ability to respond to a security event. Using the

documents listed in the attachment, the inspectors verified that fire hoses and

extinguishers were in their designated locations and available for immediate use; that

fire detectors and sprinklers were unobstructed; that transient material loading was

within the analyzed limits; and fire doors, dampers, and penetration seals appeared to

be in satisfactory condition. The inspectors also verified that minor issues identified

during the inspection were entered into the licensees corrective action program.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four quarterly fire protection inspection samples

as defined in IP 71111.05-05.

b. Findings

.1 Introduction. The inspectors identified a Green noncited violation of License

Condition 2.C(5)(a) for a degraded fire seal that separated redundant safe shutdown

equipment.

Description. On January 17, 2009, while touring Fire Area A13, the inspectors observed

a degraded silicone fire seal for a mechanical penetration in the motor-driven auxiliary

feedwater Pump B floor. Specifically, a silicone foam and ceramic fiber board seal

-10- Enclosure

separating redundant motor-driven auxiliary feedwater trains was degraded so that it no

longer provided a 3-hour rated fire barrier. The seal separated the pump room from fire

Area A33 below, which contained motor-driven auxiliary feedwater Train A equipment.

The inspectors could feel air moving through the seal, indicating that the seal had

separated from the pipe for the entire depth of the seal. Further walkdowns revealed a

portion of the ceramic fiber damming board was missing from the bottom of the

penetration. When notified by the inspectors, the licensee initiated Work

Order 09-313747-000, Breach Permit No. 2009-018, Condition Report 2009-001087,

and compensatory actions for the degraded seal.

Procedure M-663-00017, Penetration Seal Typical Details, Revision W20, provides

design information for installation and inspection of the seals. Detail drawing and limiting

parameters for a M-1 seal specified a one inch thick damming board and an air tight seal

in the required 3-hour rated configuration. Therefore, the inspectors concluded that the

seal would fail to provide the required 3-hour protection from a fire.

The inspectors determined that the degradation was not typical due to a walkdown of

similar seals and by reviewing the licensees seal inspection documentation. The pipe in

the penetration, part of the essential service water system, experienced a water hammer

event on April 7, 2008, which was considered to be the most likely cause of the damage

to the seal. The licensee performed a walkdown of the system following the event and

failed to identify this damage.

Analysis. The failure of the fire seal to have been in the required configuration, which

resulted in a degradation of the 3-hour fire barrier between redundant motor-driven

auxiliary feedwater trains, was a performance deficiency. The finding was more than

minor because it was similar to Not minor if section of example 2.e. of NRC Inspection

Manual Chapter 0612, Appendix E, Examples of Minor Issues, in that, the performance

deficiency impacted the ability of the seal to perform its function. In addition, the

performance deficiency was associated with the Mitigating Systems cornerstone

attribute of Protection Against External Events, and affected the cornerstone objective to

ensure the reliability of systems that respond to Initiating Events to prevent undesirable

consequences. Using NRC Inspection Manual Chapter 0609, Appendix F,

Attachment 2, Degradation Rating Guidance Specific to Various Fire Protection

Program Elements, under Fire Barrier Degradation, Table A2.2, the finding was

associated with a Moderate B degradation due to the seal not being in a tested or

evaluated condition. Using NRC Inspection Manual Chapter 0609, Appendix F, Fire

Protection Significance Determination Process, in supplemental screening for fire

confinement findings, the finding screens as Green due to exposing Fire Area A33

featuring an automatic full area water-based suppression system. The inspectors

determined that this finding has a crosscutting aspect in the area of problem

identification and resolution associated with the corrective action program component

because Wolf Creek failed to identify the degraded seal and missing ceramic board

during previous post waterhammer walkdowns. P.1.a]

Enforcement. Wolf Creek License Condition 2.C.(5)(a) requires, in part, that the licensee

maintain in effect all provisions of the approved fire protection program. The Wolf Creek

Fire Protection Program, as documented, in part, by the Updated Safety Analysis

Report, Revision 22, Table 9.5A-1, Section D.1.(j), states that where fire barriers are

provided to separate redundant safe shutdown trains, piping penetrations are sealed to

provide a fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Contrary to the above, floor penetration

-11- Enclosure

Seal OP135S0214, which separates redundant safe shutdown trains of motor-driven

auxiliary feedwater, was degraded such that it would not provide a fire resistance rating

of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> on January 17, 2009. Since the violation was of very low safety significance

and was documented in the licensees corrective action program as Condition

Report 2009-001087, it is being treated as a noncited violation, consistent with Section

VI.A of the NRC Enforcement Policy: NCV 05000482/2009002-02, degraded fire barrier

for auxiliary feedwater.

.2 Introduction. On January 17, 2009, inspectors identified a Green noncited violation of

Technical Specification 5.4.1.a, Procedures, for failure to follow AP 12-003, Foreign

Material Exclusion. Wolf Creek failed to follow multiple sections of this procedure.

Description. On January 17, 2009, inspectors conducted a walkdown of the spent fuel

pool area and found numerous tools and equipment inside the fuel pool area. Inspectors

found duct tape, air hoses running across the boundaries, plastic sheeting, ropes, tools,

a toolbox, cameras, and extension cords. Inspectors also found duct tape attached to

various fueling and control rod tools such that duct tape was above and below the water.

Inspectors questioned Wolf Creek regarding the spent fuel pool area material tracking

practices. Inspectors reviewed Procedure AP 12-003, Foreign Material Exclusion,

Revision 6. The area surrounding the spent fuel pool is posted as a foreign material

exclusion area, a contaminated area, and a hot particle area. Procedure AP 12-003

requires the highest level of foreign material accountability or Level 1 for the spent fuel

pool. Level 1 requires several actions: all materials in the area to be described; all

materials are logged in and out; logs specify how material was removed; logs identify the

person writing on the log itself; and track the pages of the log itself.

Inspectors reviewed the spent fuel pool area logs and found that the logs were

inadequate because Wolf Creek failed to log material in, log material out, state who

logged material out, state how the material was removed, and track the log sheets

themselves. Numerous pieces of duct tape, including that on fueling and control rod

manipulation tools, were not on the logs. Wolf Creek subsequently initiated Condition

Report 2009-000319 which identified the issue as housekeeping problems associated

with the spent fuel pool area. Wolf Creek began cleaning the area and reconciling the

material inside the area with the material logs during the week of January 26, 2009. On

January 30, 2009, Wolf Creek initiated Condition Report 2009-000485 which stated that

foreign material tracking was an ongoing problem. On March 19, 2009, based on

questions from the inspectors, Condition Report 2009-001388 was initiated identifying a

loss of spent fuel pool foreign material control. Using the requirements in Procedure AP

12-003, the inspectors found that Wolf Creek did not have a foreign material exclusion

area Level 1 plan and had not initiated actions for a loss of foreign material exclusion

area control due to the numerous log deficiencies. Subsequently, Wolf Creek again

began re-inventorying all materials in the spent fuel pool area. Inspectors did not identify

a sufficient amount of material to challenge the evaluated combustible loading

calculation.

Analysis. The inspectors determined that the failure to implement multiple steps of

Procedure AP 12-003 was a performance deficiency. Traditional enforcement does not

apply since there were no actual safety consequences or potential for impacting the

NRC's regulatory function, and the finding was not the result of any willful violation of

NRC requirements or Wolf Creek procedures. This finding is more than minor because it

impacted the barrier integrity cornerstone attribute of configuration control and affected

-12- Enclosure

the cornerstone objective to maintain functionality of the spent fuel pool system. Using

Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings,

this finding was determined be of very low safety significance because the finding only

affected the barrier function of the spent fuel pool. The inspectors determined that this

finding has a crosscutting aspect in the area of human performance associated with the

work practices component because even though personnel had been made aware of

Wolf Creeks policy on procedure use and adherence through site-wide communications,

personnel still failed to follow numerous parts of the procedure, such that Wolf Creek

was not using the procedure. H.4.b]

Enforcement. Technical Specification 5.4.1.a requires the implementation of written

procedures described in Regulatory Guide 1.33, Revision 2, Appendix A, including

procedures for performing maintenance that can affect the performance of safety-related

equipment. Procedure AP 12-003, Foreign Material Exclusion, Revision 6, requires

that spent fuel pool work comply with theses requirements. Contrary to the above, prior

to March 19, 2009, the licensee failed to adequately implement Procedure AP 12-003 for

spent fuel pool work activities. Specifically, Procedure AP 12-003, was not implemented

and resulted in failure to account for foreign material in the spent fuel pool and the spent

fuel pool exclusion area. Because this violation was determined to be of very low safety

significance and was placed in the corrective action program as Condition

Reports 2009-000319, 2009-000485, and 2009-001388, this violation is being treated as

a noncited violation in accordance with Section VI.A.1 of the Enforcement Policy:

NCV 05000482/2009002-03, failure to implement foreign material exclusion control

procedure for spent fuel pool.

1R11 Licensed Operator Requalification Program (71111.11)

a. Inspection Scope

On March 27, 2009, the inspectors observed a crew of licensed operators in the plants

simulator during licensed operator requalification examinations to verify that operator

performance was adequate, evaluators were identifying and documenting crew

performance problems, and training was being conducted in accordance with licensee

procedures. The inspectors evaluated the following areas:

• Licensed operator performance

• Crews clarity and formality of communications

• Crews ability to take timely actions in the conservative direction

• Crews prioritization, interpretation, and verification of annunciator alarms

• Crews correct use and implementation of abnormal and emergency procedures

• Control board manipulations

• Oversight and direction from supervisors

• Crews ability to identify and implement appropriate Technical Specification

actions and emergency plan actions and notifications

-13- Enclosure

The inspectors compared the crews performance in these areas to pre-established

operator action expectations and successful critical task completion requirements.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one quarterly licensed-operator requalification

program sample as defined in IP 71111.11.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk

significant systems:

• SJ nuclear sampling system

The inspectors reviewed events such as where ineffective equipment maintenance has

resulted in valid or invalid automatic actuations of engineered safeguards systems and

independently verified the licensee's actions to address system performance or condition

problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

• Scoping of systems in accordance with 10 CFR 50.65(b)

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

• Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or (a)(2)

• Verifying appropriate performance criteria for structures, systems, and

components classified as having an adequate demonstration of performance

through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as

requiring the establishment of appropriate and adequate goals and corrective

actions for systems classified as not having adequate performance, as described

in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability,

and condition monitoring of the system. In addition, the inspectors verified maintenance

effectiveness issues were entered into the corrective action program with the appropriate

significance characterization. Specific documents reviewed during this inspection are

listed in the attachment.

-14- Enclosure

These activities constitute completion of one quarterly maintenance effectiveness

sample as defined in IP 71111.12-05.

b. Findings

Introduction. The inspectors identified a Green noncited violation of 10 CFR 50.65

(Maintenance Rule) for failure to demonstrate that the performance of a containment

isolation valve was effectively controlled through the performance of preventive

maintenance such that the valve remained capable of performing its intended function.

Description. An inadequate Maintenance Rule evaluation was performed after a

containment isolation valve (SJHV0005) exceeded its Maintenance Rule a(2)

performance criteria, and as a result, goal setting and monitoring were not performed as

required by paragraph a(1) of the Maintenance Rule. The reactor coolant system liquid

sampling inner containment isolation valve, SJHV-0005, failed a valve stroke test on

May 18, 2008, and again on August 17, 2008. The Maintenance Rule a(2) criteria for

this containment isolation valve is one functional failure per cycle under Function CI-01,

containment isolation. The licensees Maintenance Rule expert panel evaluated the

second failure on August 18, 2008, and kept the valve in a(2) without any evidence that

preventive maintenance was maintaining the valves ability to function properly. The

inspectors found the August 18, 2009, Maintenance Rule expert panel evaluation to be

inadequate because a run-to-failure analysis was not performed, preventive

maintenance was not being performed, and repair work on the valve was not expedited

despite a known cause. The functional failure evaluations stated that the valves could

not be proven closed. The failed valve is a direct acting Valcor solenoid valve.

Engineering has postulated that these failures are potentially an indication failure caused

by the valves reed switches. A historical review of this type of valve installed in Wolf

Creek systems shows that a solution to the reed switch indication problem has been

available from the vendor for several years.

Analysis. The failure to follow 10 CFR 50.65 a(2) and properly evaluate the failed valve,

establish performance goals, and monitor its performance is considered a performance

deficiency. Traditional enforcement does not apply since there were no actual safety

consequences or potential for impacting the NRCs regulatory function, and the finding

was not the result of any willful violation of NRC requirements or Wolf Creek procedures.

Per Inspection Manual Chapter 0612, Appendix E, Section 7, this finding is more than

minor because failure to demonstrate effective control of performance or condition and

not putting the affected structure, system, and component in (a)(1) necessarily involves

degraded structure, system, and component performance or condition. During the

Phase I Significance Screening Process, it was found that the finding is of very low

safety significance because it does not represent an actual open pathway in the physical

integrity of the reactor containment. This finding was determined to have a crosscutting

aspect in the area of problem identification and resolution associated with the corrective

action program because the licensee failed to properly classify, prioritize, and evaluate a

condition adverse to quality. P.1.c]

Enforcement. Title 10 CFR 50.65 paragraph a(2) states, that, Monitoring as specified in

Paragraph a(1) of this section is not required where it has been demonstrated that the

performance or condition of a structure, system, or component is being effectively

controlled through the performance of appropriate preventive maintenance, such that the

structure, system, or component remains capable of performing its intended function.

-15- Enclosure

Contrary to the above, on August 18, 2008, the licensee failed to properly evaluate a

component that had exceeded its functional failure criteria and had not demonstrated

that its ability to perform its intended function was being controlled through the

performance of preventive maintenance. Because the finding is of very low safety

significance and has been entered into the licensees corrective action program as

Condition Report 2009-001667, this violation is being treated as a noncited violation,

consistent with Section VI.A of the NRC Enforcement Policy:

NCV 05000482/2009002-04, failure to follow 10 CFR 50.65a(2) for containment isolation

valve failures.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk

for the maintenance and emergent work activities affecting risk-significant and safety-

related equipment listed below to verify that the appropriate risk assessments were

performed prior to removing equipment for work:

• January 7 to 9, 2009, control power fuse verification in 4160V switchgear

• January 9, 2009, reactor trip Breaker B charging spring motor did not stop

running

• January 24, 2009, reactor trip breaker auxiliary contact wiring insulation losses of

greater than 10 percent acceptance criteria

• February 5, 2009, risk assessment of battery Charger PK23 during planned

maintenance

• March 17, 2009, risk assessment for missed Technical Specification Surveillance

Requirement 3.6.1.1

The inspectors selected these activities based on potential risk significance relative to

the reactor safety cornerstones. As applicable for each activity, the inspectors verified

that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)

and that the assessments were accurate and complete. When licensee personnel

performed emergent work, the inspectors verified that the licensee personnel promptly

assessed and managed plant risk. The inspectors reviewed the scope of maintenance

work, discussed the results of the assessment with the licensee's probabilistic risk

analyst or shift technical advisor, and verified plant conditions were consistent with the

risk assessment. The inspectors also reviewed the Technical Specification requirements

and inspected portions of redundant safety systems, when applicable, to verify risk

analysis assumptions were valid and applicable requirements were met. Specific

documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five maintenance risk assessments and

emergent work control inspection samples as defined in IP 71111.13 05.

b. Findings

No findings of significance were identified.

-16- Enclosure

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors reviewed the following issues:

• February 9, 2009, spent fuel pool low level transmitter missing silicone fluid

• January 19, 2009, component cooling water heat exchanger leakage

• February 11, 2009, component cooling water pump coupling bolts loose

• January 4, 2009, Emergency Diesel Generator A overspeed limit switch bracket

missing one screw and remaining screw loose

• Emergency diesel generator cotter pins on threaded fuel rack not installed with

sufficient bend

The inspectors selected these potential operability issues based on the risk significance

of the associated components and systems. The inspectors evaluated the technical

adequacy of the evaluations to ensure that Technical Specification operability was

properly justified and the subject component or system remained available such that no

unrecognized increase in risk occurred. The inspectors compared the operability and

design criteria in the appropriate sections of the Technical Specifications and Updated

Safety Analysis Report to the licensees evaluations, to determine whether the

components or systems were operable. Where compensatory measures were required

to maintain operability, the inspectors determined whether the measures inplace would

function as intended and were properly controlled. The inspectors determined, where

appropriate, compliance with bounding limitations associated with the evaluations.

Additionally, the inspectors also reviewed a sampling of corrective action documents to

verify that the licensee was identifying and correcting any deficiencies associated with

operability evaluations. Specific documents reviewed during this inspection are listed in

the attachment.

These activities constitute completion of five operability evaluations inspection samples

as defined in IP 71111.15-05

b. Findings

An unresolved item was identified when Wolf Creek entered Technical Specification 3.8.1

on January 4, 2009, when an operator identified one missing and one loose screw in the

Emergency Diesel Generator A overspeed limit switch. A reportability determination

dated February 19, 2009, determined that the condition was not reportable, although

Wolf Creek stated that the configuration was not seismically qualified and inoperable.

Wolf Creek concluded per NUREG 1022 that because there was not firm evidence that

screws did not fall out of the limit switch bracket immediately before discovery by an

operator, that the issue was not reportable under 10 CFR 50.73(a)(2)(i)(B). The

inspectors questioned this reportability evaluation and requested support from the Office

of Nuclear Reactor Regulations Division of Operating Reactor Oversight and Licensing.

The inspectors found that the last time that maintenance was performed on this limit

switch was 2002. At the completion of the inspection period, there were still unresolved

questions about the assumptions and results associated with the evaluation of the limit

-17- Enclosure

switch, its impact of failure on Emergency Diesel Generator A, operator response

actions, and this issues reportability. These concerns require additional inspection and,

when completed, the inspection results will require significance determination. This

issue is considered unresolved pending additional NRC review of Wolf Creek operability

determination calculations: URI 05000482/2009002-05, seismic operability of

Emergency Diesel Generator A due to overspeed limit switch degradation.

1R19 Postmaintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that

procedures and test activities were adequate to ensure system operability and functional

capability:

• January 7, 2009, Auxiliary Feedwater Pump A after circuit breaker preventive

maintenance

• February 12, 2009, Emergency Diesel Generator B jacketwater keepwarm pump

current draw and vibrations after replacement

• March 6, 2009, Emergency Diesel Generator A after 18-month preventive

maintenance

• January 15, 2009, personnel air lock test after foreign material removal

The inspectors selected these activities based upon the structure, system, or

component's ability to affect risk. The inspectors evaluated these activities for the

following (as applicable):

• The effect of testing on the plant had been adequately addressed; testing was

adequate for the maintenance performed

• Acceptance criteria were clear and demonstrated operational readiness; test

instrumentation was appropriate

The inspectors evaluated the activities against the Technical Specifications, the Updated

Safety Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and various

NRC generic communications to ensure that the test results adequately ensured that the

equipment met the licensing basis and design requirements. In addition, the inspectors

reviewed corrective action documents associated with postmaintenance tests to

determine whether the licensee was identifying problems and entering them in the

corrective action program and that the problems were being corrected commensurate

with their importance to safety. Specific documents reviewed during this inspection are

listed in the attachment.

These activities constitute completion of four post-maintenance testing inspection

sample(s) as defined in IP 71111.19 05.

b. Findings

No findings of significance were identified.

-18- Enclosure

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors reviewed the Updated Safety Analysis Report, procedure requirements,

and Technical Specifications to ensure that the three surveillance activities listed below

demonstrated that the systems, structures, and/or components tested were capable of

performing their intended safety functions. The inspectors either witnessed or reviewed

test data to verify that the significant surveillance test attributes were adequate to

address the following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

• Engineering evaluations, root causes, and bases for returning tested systems,

structures, and components not meeting the test acceptance criteria were correct

• Reference setting data

• Annunciators and alarms setpoints.

The inspectors also verified that licensee personnel identified and implemented any

needed corrective actions associated with the surveillance testing.

• March 18, 2009, Emergency Diesel Generator B

• February 6, 2009, control and shutdown rod operability exercises

• Emergency Diesel Generator A and B hot restart on July 2, 2008, reviewed on

March 5, 2009

-19- Enclosure

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three surveillance testing inspection sample(s)

as defined in IP 71111.22-05.

b. Findings

Introduction. On February 6, 2009, the inspectors identified a Green noncited violation

of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for a procedure that allowed

unacceptable preconditioning of the control rods prior to Technical Specification

Surveillance 3.1.4.2.

Description. On February 6, 2009, the inspectors questioned the practice of stepping

each control rod group two steps in and two steps out, and repeated two more

repetitions. Procedure STS SF-001, Control and Shutdown Rod Operability

Verification, Revision 24 contained this guidance which is followed by the Technical

Specification Surveillance Requirement 3.1.4.2. Technical Specification Surveillance

Requirement 3.1.4.2 requires the control rod groups be inserted 10 steps and the rods

can then be withdrawn to the desired number of steps. The inspectors reviewed

operating experience from Westinghouse regarding control rod exercises to reduce crud

buildup at the gripper latches and reduce the frequency of slipped or dropped control

rods. Although the operating experience identifies that a gripper latch has never been

found to be unable to release a control rod, the inspector judged this practice is

unacceptable. Wolf Creek did not perform any preconditioning acceptability review

when adopting this operating experience and revising Procedure STS SF-001. The

inspectors did not find any data or test history that indicates that the Technical

Specification surveillance test would have failed with out the preconditioning, and

therefore, did not challenge the operability of the control rods. The inspectors reviewed

the regulatory positions and guidance on the subject of preconditioning that are

contained in NRC Information Notice (IN) 97-16, Preconditioning of Plant Structures,

Systems, and Components Before ASME Code Inservice Testing or Technical

Specification Surveillance Testing; NRC Inspection Manual Part 9900: Technical

Guidance, Maintenance - Preconditioning of Structures, Systems, and Components

Before Determining Operability; and NUREG-1482, Guidelines for Inservice Testing at

Nuclear Power Plants. The preventive maintenance routinely performed just before the

testing and preventive maintenance was performed for scheduling convenience. The

inspectors consulted with the regional senior technical advisor and determined that the

activity was a preventative maintenance activity that procedurally and routinely preceded

control rod testing. The inspector also determined that the practice could mask an as

found condition if crud accumulation was much more substantial, although this has not

been observed per the vendor. Wolf Creek did not utilize specialty testing equipment to

show the decay current for the gripper coils are showing a slow release of the control

rod.

Analysis. The inspectors considered the unacceptable preconditioning of the control

rods per NRC guidance to be a performance deficiency. Traditional enforcement does

not apply since there were no actual safety consequences or potential for impacting the

NRCs regulatory function, and the finding was not the result of any willful violation of

NRC requirements or Wolf Creek procedures. The finding was more than minor

because it was associated with the equipment performance attribute of the mitigating

systems cornerstone, and it affected the cornerstone objective to ensure the availability,

-20- Enclosure

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences. The inspectors evaluated the significance of this finding

under the mitigating systems cornerstone using Phase 1 of Inspection Manual

Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and

determined that the finding was of very low safety significance (Green) because, it did

not represent an actual loss of safety function and did not screen as potentially risk

significant due to a seismic, flooding, or severe weather initiating event. This finding was

determined to have a crosscutting aspect in the area of problem identification and

resolution associated with the corrective action program because the condition report

that adopted the operating experience failed to evaluate NRC guidance regarding

preconditioning during surveillance testing which should have disallowed the procedure

change. Therefore, the applicable procedures were not complete and accurate. P.1(c)

Enforcement. 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in part,

that a test program be established to assure that all testing required to demonstrate that

structures, systems and components will perform satisfactorily in service is identified and

performed in accordance with written test procedures which incorporate the

requirements and acceptance limits contained in the applicable design documents.

Contrary to the above, on February 6, 2008, the licensee performed STS SF-001,

Control and Shutdown Rod Operability Verification, Revision 24, which failed to

adequately test all of the control rod groups prior to the Technical Specification

Surveillance Requirement 3.1.4.2. The licensee performed maintenance incorporated in

STS SF-001 on the control rods and as such, unacceptably preconditioned the control

rods. Because the finding is of very low safety significance and has been entered into

the licensees corrective action program as Condition Report 2009-000598, this violation

is being treated as a noncited violation, consistent with Section VI.A of the NRC

Enforcement Policy: NCV 05000482/2009002-06, unacceptable preconditioning of

control rods prior to surveillance testing.

Cornerstone: Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)

a. Inspection Scope

The inspector performed an in-office review of licensee changes to Emergency Plan

Implementing Procedure APF 06-002-01, AEmergency Action Levels,@ submitted

December 17, 2008. This revision added an automatic or manually-initiated safety

injection in progress as an entry condition to Emergency Action Level 3, Loss of Reactor

Coolant Boundary, and revised the bases of Emergency Action Level 4, Main Steam

Line Break, to provide additional criteria to determine when a steam generator is

faulted.

The revision was compared to its previous revision, to the criteria of NUREG-0654,

ACriteria for Preparation and Evaluation of Radiological Emergency Response Plans and

Preparedness in Support of Nuclear Power Plants,@ Revision 1, to the criteria of Nuclear

Energy Institute Report 99-01, AMethodology for Development of Emergency Action

Levels,@ Revision 2, and to the standards in 10 CFR 50.47(b) to determine if the revision

adequately implemented the requirements of 10 CFR 50.54(q). This review was not

documented in a Safety Evaluation Report and did not constitute an approval of the

licensees changes; therefore, these revisions are subject to future inspection.

-21- Enclosure

These activities constitute completion of one sample as defined in IP 71114.04-05.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation (71114.06)

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on

February 12, 2009, to identify any weaknesses and deficiencies in classification,

notification, and protective action recommendation development activities. The

inspectors observed emergency response operations in the simulator and technical

support center to determine whether the event classification, notifications, and protective

action recommendations were performed in accordance with procedures. The

inspectors also attended the licensee drill critique to compare any inspector-observed

weakness with those identified by the licensee staff in order to evaluate the critique and

to verify whether the licensee staff was properly identifying weaknesses and entering

them into the corrective action program. As part of the inspection, the inspectors

reviewed the drill package and other documents listed in the attachment.

These activities constitute completion of one sample as defined in IP 71114.06-05.

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the data submitted by the licensee for the fourth

quarter 2008 performance indicators for any obvious inconsistencies prior to its public

release in accordance with Inspection Manual Chapter 0608, Performance Indicator

Program.

This review was performed as part of the inspectors normal plant status activities and,

as such, did not constitute a separate inspection sample.

b. Findings

No findings of significance were identified.

-22- Enclosure

.2 Unplanned Scrams per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Scrams per 7000 Critical

Hours performance indicator for the period from the first quarter 2008 through the fourth

quarter 2008. To determine the accuracy of the performance indicator data reported

during those periods, performance indicator definitions and guidance contained in NEI

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5,

was used. The inspectors reviewed the licensees operator narrative logs, issue reports,

event reports, and NRC inspection reports for the period of January 1, 2008, through

December 31, 2008, to validate the accuracy of the submittals. The inspectors also

reviewed the licensees issue report database to determine if any problems had been

identified with the performance indicator data collected or transmitted for this indicator

and none were identified. Specific documents reviewed are described in the attachment

to this report.

These activities constitute completion of 1 unplanned scrams per 7000 critical hours

sample as defined in IP 71151-05.

b. Findings

No findings of significance were identified.

.3 Unplanned Scrams with Complications

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams with

complications performance indicator for the period from the second quarter 2008 through

the fourth quarter 2008. To determine the accuracy of the performance indicator data

reported during those periods, performance indicator definitions and guidance contained

in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 5, was used. The inspectors reviewed the licensees operator narrative logs,

issue reports, event reports, and NRC Integrated Inspection Reports for the period of

April 1, 2008, through December 31, 2008, to validate the accuracy of the submittals.

The inspectors also reviewed the licensees issue report database to determine if any

problems had been identified with the performance indicator data collected or

transmitted for this indicator and none were identified. Specific documents reviewed are

described in the attachment to this report.

These activities constitute completion of 1 unplanned scrams with complications sample

as defined in IP 71151-05.

b. Findings

No findings of significance were identified.

-23- Enclosure

.4 Unplanned Power Changes per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned power changes per 7000

critical hours performance indicator for the period from the first quarter 2008 through the

fourth quarter 2008. To determine the accuracy of the performance indicator data

reported during those periods, performance indicator definitions and guidance contained

in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 5, was used. The inspectors reviewed the licensees operator narrative logs,

issue reports, Maintenance Rule records, event reports and NRC Integrated Inspection

Reports for the period of January 1, 2008, through December 31, 2008, to validate the

accuracy of the submittals. The inspectors also reviewed the licensees issue report

database to determine if any problems had been identified with the performance

indicator data collected or transmitted for this indicator and none were identified.

Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of 1 unplanned power changes per 7000 critical

hours sample as defined in IP 71151-05.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152)

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical

Protection

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of

this report, the inspectors routinely reviewed issues during baseline inspection activities

and plant status reviews to verify that they were being entered into the licensees

corrective action program at an appropriate threshold, that adequate attention was being

given to timely corrective actions, and that adverse trends were identified and

addressed. The inspectors reviewed attributes that included: the complete and

accurate identification of the problem; the timely correction, commensurate with the

safety significance; the evaluation and disposition of performance issues, generic

implications, common causes, contributing factors, root causes, extent of condition

reviews, and previous occurrences reviews; and the classification, prioritization, focus,

and timeliness of corrective actions. Minor issues entered into the licensees corrective

action program because of the inspectors observations are included in the attached list

of documents reviewed.

These routine reviews for the identification and resolution of problems did not constitute

any additional inspection samples. Instead, by procedure, they were considered an

integral part of the inspections performed during the quarter and documented in

Section 1 of this report.

-24- Enclosure

b. Findings

No findings of significance were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific

Human Performance issues for followup, the inspectors performed a daily screening of

items entered into the licensees corrective action program. The inspectors

accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status

monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings of significance were identified.

.3 Selected Issue Follow-up Inspection

a. Inspection Scope

During a review of items entered in the licensees corrective action program, the

inspectors recognized a corrective action item documenting the reactor coolant pump

thermal barrier heat exchanger outlet valves and downstream containment isolation

valves. On January 31, 2009, downstream containment isolation Valve EG HV-62

closed when the radioactive waste evaporators were isolated. Valve EG HV-62 isolated

all four thermal barrier heat exchangers. On November 10, 19, 22, and 24, 2008, Wolf

Creek thermal barrier valves closed themselves without operator action during pump

swaps and isolations of radioactive waste evaporators.

These activities constitute completion of one in-depth problem identification and

resolution sample as defined in IP 71152-05.

c. Findings

Introduction. The inspectors identified a cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Conditions Adverse to Quality, for failure to correct a condition adverse to

quality with the component cooling water thermal barrier heat exchanger outlet valves to

ensure reactor coolant pump seal cooling. This issue was previously identified in NRC

Inspection Report 2007-03 as NCV 05000482/2007003-03.

Description. When the NRC issued NCV 05000482/2007003-03 on August 16, 2007, for

failing to identify the cause of component cooling valve closure, corrective actions were

tracked under Condition Reports 2007-002064 and 2007-002601. On December 10,

2007, Condition Report 2007-002064 was downgraded from a broke/fix type analysis to

an address management evaluation and the scope was changed to review component

cooling water operating experience and not to correct the issue. No subsequent action

was taken until October 27, 2008, when Wolf Creek realized that this condition report

was in response to NCV 05000482/2007003-03. The condition report was subsequently

-25- Enclosure

upgraded to an apparent cause evaluation on October 28, 2008, which was completed

on February 19, 2009. Wolf Creek found that the apparent cause was a lack of a time

delay in the valves motor circuit. This time delay would allow a high-flow condition to

decay prior to valve closure on high flow. This time delay would also prevent the motor

from reversing direction as soon as the valve was opened and prevent breaker trips. A

modification has yet to be implemented. No additional procedural guidance or

compensatory guidance was provided to operators to alert them to the incorrect closure

of these valves.

In the past, Wolf Creek performed activities such as adding steps to procedures to

instruct operators to expect and accept the mal-operation of these valves, throttling flow

to other portions of the component cooling water system, and adjusting the flow switches

to these valves; however, none stopped the valves from closing. Several corrective

action documents, work orders and work requests have been initiated since 2001

documenting valve closure and corrective actions. A previous operability evaluation

stated that this issue is of low-safety significance because reactor coolant pump seal

injection is also available. The Wolf Creek plant safety analysis identifies providing

reactor coolant pump seal cooling in a timely manner as the most safety-significant

operator action. In some occurrences, inspectors found that during component cooling

water pump swap, the flow element on the down stream containment isolation valve was

also actuated and caused the associated valve to stroke closed. The inspectors found

that Wolf Creek has yet to correct this deficiency.

The inspectors found that these component cooling water valves are safety related as

specified in Updated Safety Analysis Report, Section 9.2.2.2.1. Section 5.1.1.2.2

describes thermal barrier heat exchangers and seal injection as diverse methods to

assure reactor coolant pump seal cooling. Lastly, the inspectors found in

Section 9.2.2.2.3 of the Updated Safety Analysis Report, the component cooling water

system is described as being able to provide cooling to the thermal barriers, to achieve

emergency cold safe shutdown with a single active component failure. The inadvertent,

automatic closure of these valves is contrary to these Updated Safety Analysis Report

sections.

Additionally, the inspectors and the licensee concluded it reasonable that the reactor

coolant pump component cooling water heat exchanger outlet valves will stroke closed

on a loss of offsite power and/or a safety injection signal due to the higher than normal

flow created by component cooling water pumps stop and start. Therefore, the

component cooling water thermal barriers may not be able to fulfill their function to

remain open for cooling of the reactor coolant pump seals during design basis accidents

and events because they will stroke closed on high flow when component cooling water

pumps stop and start and when the radioactive waste evaporator valves close. Reactor

coolant pump seal cooling is necessary to preclude a seal loss of coolant accident.

During NRC questioning of the apparent cause, Wolf Creek wrote Condition

Report 2009-001496 to consider adding emergency procedure steps to alert operators

that the thermal barrier valves need to be open. Although numerous flow balances have

been performed, Wolf Creek has no data on the actual flow balance in the system during

normal operations, during pump swaps, and during isolation of radioactive waste

evaporators. Wolf Creek stated that further flow balances would be performed when

control room annunciators are received in the control room for the component cooling

water valves that cool the reactor coolant pump heat loads.

-26- Enclosure

Analysis. The inspectors determined that the failure to correct the condition adverse to

quality of ensuring reactor coolant pump seal cooling as described in the Updated Safety

Analysis Report is a performance deficiency. Traditional enforcement does not apply

since there were no actual safety consequences or potential for impacting the NRC's

regulatory function, and the finding was not the result of any willful violation of NRC

requirements or Wolf Creek procedures. The inspectors determined that this finding was

more than minor because it is associated with the equipment performance attribute for

the Initiating Events cornerstone; and, it affected the cornerstone objective to limit the

likelihood of those events that upset plant stability and challenge critical safety functions

during shutdown as well as power operations. Specifically, this issue relates to the

reliability example of the equipment performance attribute because the valves have

demonstrated a history of inappropriately stroking closed and being difficult to re-open

when both trains of component cooling water pumps are started, which is similar to

design basis events and accidents. The inspectors evaluated the significance of this

finding using Phase 1 of Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial

Screening and Characterization of Findings, and determined that the finding was of very

low safety significance because assuming worst case degradation, the finding would not

result in exceeding the Technical Specification limit for identified reactor coolant system

leakage and would not have likely affected other Mitigation Systems resulting in a total

loss of their safety function because seal injection was available. This finding has a

crosscutting aspect in the area of human performance associated with the decision

making component because, even though numerous instances of valve closures

occurred since the first noncited violation, Wolf Creek downgraded the condition report.

Using nonconservative assumptions, the licensee consistently viewed this issue as not

having a risk impact because seal injection was not simultaneously lost. [H.1( b)]

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Conditions Adverse to

Quality, requires that conditions adverse to quality, such as failures, malfunctions,

deficiencies, deviations, defective material and equipment, and nonconformances are

promptly identified and corrected. Contrary to the above, from 2001 to 2009, Wolf Creek

did not correct the reactor coolant pump thermal barrier heat exchanger outlet valves

stroking closed on high flow which would be experienced during design basis accidents

and events. This issue and the corrective actions are being tracked by the licensee in

Condition Report 2007-002074. Because the violation was of very low safety

significance and the issue was captured in the licensee's corrective action program, but

the licensee failed to restore compliance, this violation is being treated as a cited

violation consistent with Section VI.A.1.a of the NRC Enforcement Policy:

NOV 05000482/2009002-07, failure to correct component cooling water valve closures.

EA-09-110

4OA3 Event Follow-up (71153)

.1 Plant down power due to loss of Benton and Rosehill 345 kV power lines.

a. Inspection Scope

On March 27, 2009, Wolf Creek experienced 180 MWe to 250 MWe load swings and

subsequently lost the 345 kV Benton power line. Emergency diesel generator B was out

of service for planned maintenance. Wolf Creek reduced turbine load to 90 percent

while diverting 10 percent to the steam dump valves. Reactor power was maintained at

-27- Enclosure

100 percent. The grid was determined to be stable early on March 28 and emergency

diesel generator B successfully passed it post maintenance test.

At 9:09 a.m., on March 28, the 345 kV Rosehill line breakers opened. One of these

breakers serves a dual purpose as the main generator output breaker. The other main

generator output breaker remained closed and within its operating limitations. At 10:03

a.m., operators reduced reactor power to match main generator output at approximately

80 percent, and the steam dumps were closed. At 11:11 a.m, the Rosehill line was

restored and sparks were observed from one LaCygne breaker in the switchyard. At

5:18 p.m., the shift manager discussed the grid state estimator calculation with the grid

operator. A standing order allowed splitting of the Wolf Creek 345 kV ring bus. The shift

manager decided that there was confidence in the remaining 345 kV LaCygne line to

provide sufficient voltage following a reactor trip and emergency equipment start in

response to a postulated loss of coolant accident. On March 29 at 6:17 a.m., the

Rosehill line breakers re-opened. One of the Rosehill breakers was determined to have

a bad fault-time-delay timer. Maintenance subsequently planned replacement of the

timer. At 5:05 p.m., one of two of the 345 kV Benton line breakers was closed. At 6:45

p.m, the second Benton line breaker was closed. At 7:20 p.m., the Rosehill breaker with

the bad fault-time-delay timer was successfully replaced. At 7:31 p.m. on March 29, the

Rosehill line was restored. At 7:39 p.m. on March 29, the LaCygne line breaker was

opened so that the breaker disconnects could be opened pending repair. At 8:50 p.m.,

reactor power increase was commenced. Early on March 30, the reactor was returned

to full power. Inspectors interviewed control room personnel, engineering personnel,

reviewed off-normal procedures, equipment limitations, Technical Specifications, and

control room logs.

These activities constitute completion of 1 event followup sample as defined in IP 71153-

05.

b. Findings

No findings of significance were identified.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors performed observations of security force

personnel and activities to ensure that the activities were consistent with Wolf Creeks

security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities

did not constitute any additional inspection samples. Rather, they were considered an

integral part of the inspectors normal plant status review and inspection activities.

b. Findings

No findings of significance were identified.

-28- Enclosure

.2 Inattentive Shift Manager

a. Inspection Scope

The NRC followed up to determine if a licensed senior operator had been inattentive in

the control room while assigned as shift manager.

b. Findings

Introduction. A Green self-revealing noncited violation of Technical

Specification 5.4.1(a) was identified when an on-duty operations shift manager was

observed to be inattentive on multiple occasions in 2004 and 2005.

Description. Numerous crewmembers indicated that they had observed a shift manager

inattentive to his duties on multiple occasions during 2004 and 2005. The

inattentiveness was of concern because the shift manager was not attentive to plant

conditions at all times. This limited his ability to monitor the safe operation of the plant,

assist the control room supervisor with the control room command function, and respond

in the event of an accident.

Analysis. The failure of the shift manager to remain attentive is considered a

performance deficiency. This finding is more than minor because it adversely impacts

the Human Performance attribute of the Mitigating Systems cornerstone, and if left

uncorrected this performance deficiency has the potential to lead to a more significant

safety concern because the shift manager plays an important role in the oversight of post

accident response by all licensed operators on shift. This issue was reviewed by NRC

management using Inspection Manual Chapter 0609, Appendix M, Significance

Determination Process Using Qualitative Criteria. NRC management reviewed the

qualitative factors involved with this finding and determined that this finding is Green.

The inspectors did not identify a cross cutting aspect because the shift manager has not

stood watch for several years, and therefore, the issue was not considered current

performance.

Enforcement. Wolf Creek Technical Specification 5.4.1(a) states that the applicable

procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated

February 1978, shall be established, implemented, and maintained. Wolf Creek

Procedure AP 21-001, Conduct of Operations, is one of those procedures. Section 6.5

of this procedure states that, no person shall assume a shift position unless he/she is

physically and mentally fit to competently discharge his/her responsibilities."

Furthermore, Section 6.8.4 of this procedure states that control room personnel are

responsible for inplant activities and must maintain control and cognizance of any

activities which have potential to impact plant conditions. Contrary to the above, the

shift manager in question assumed a shift position and subsequently was observed to be

inattentive on several occasions between 2004 and 2005, therefore, he was not

physically or mentally fit to assume the position nor could he have been completely

aware of plant activities. Because this finding is of very low safety significance and was

entered into the licensee's corrective action program as Condition Report 2008-000572,

this violation is being treated as a noncited violation, consistent with Section VI.A.1 of

the NRC Enforcement Policy, NCV 05000482/200902-08, inattentive on-duty senior

reactor operator.

-29- Enclosure

4OA6 Meetings, Including Exit

On January 15, 2009, the inspector conducted a telephonic exit meeting to present the

results of the in-office inspection of changes to the licensees emergency action levels to

Mr. T. East, Superintendent, Emergency Preparedness, who acknowledged the findings.

On April 7, 2009, the inspector presented the inspection results at an exit meeting to Mr.

Matt Sunseri, Vice President of Operations and Plant Manager, who acknowledged the

findings.

-30- Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. A. Muench, President and Chief Executive Officer

M. Sunseri, Vice President Operations and Plant Manager

S. E. Hedges, Vice President Oversight

K. Scherich, Director Engineering

T. East, Superintendent, Emergency Preparedness

P. Bedgood, Superintendent, Chemistry/Radiation Protection

G. Pendergrass, Manager, System Engineering

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

Seismic operability of Emergency Diesel Generator A due to

05000482/2009002-05 URI

overspeed limit switch degradation (Section 1R15)

Failure to correct component cooling water valve closures05000482/2009002-07 VIO

(Section 4OA2)

Opened and Closed

Untimely corrective actions result in room temperature

05000482/2009002-01 FIN

below boric acid solubility limit (Section 1RO1)05000482/2009002-02 NCV Degraded fire barrier for auxiliary feedwater (Section 1RO5)

Failure to implement foreign material exclusion control

05000482/2009002-03 NCV

procedure for spent fuel pool (Section 1RO5)

Unacceptable preconditioning of control rods prior to

05000482/2009002-06 NCV

surveillance testing (Section 1R22)

Failure to follow 10 CFR 50.65a(2) for containment isolation

05000482/2009002-04 NCV

valve failures (Section 1R12)05000482/2009002-08 NCV Inattentive on-duty senior reactor operator (Section 4OA5)

A-1 Attachment

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather

DOCUMENTS

NUMBER TITLE REVISION /

DATE

EGP 0077 CCW A & C Discharge Pressure

EFP 0007 ESW A Discharge Pressure

DNA History Plot

STN GP-001 Plant Winterization 39

SYS BG-206 Boric Acid System Operation 33

STS CH-022 Boric Acid Tank A Boron Concentration Determination 4

STS CH-023 Boric Acid Tank B Boron Concentration Determination 4

CKL ZL-1269 Record Safety Injection Pump A Room Temperature 73

Control Room Logs January 31 February 1, 2009

STN PE-036 Safety-Related Room Cooler Heat Transfer Verification and 13

Performance Trending

Updated Safety Analysis Report 9.4-33

Updated Safety Analysis Report 7.4.3.3, Cold Shutdown

Discussion

Freeze Protection/Heat Trace Systems

AFP 2B-001-02 Shutdown Safety Function Checklist 7

07-012-BG Temporary Modification Order R0

AP 22C-003 Operational Risk Assessment Program 22C

A-2 Attachment

Section 1R01: Adverse Weather

DOCUMENTS

NUMBER TITLE REVISION /

DATE

AI 14-006 Severe Weather 8

OFN SG-003 Natural Events 15

Condition Report

2009-000509 2009-000516 2009-000606 2009-001495

Work Order

07-301826-001 07-301826-002

Performance Improvement Request

96-002440 2001-0391 2005-3461

DOCUMENTS

NUMBER TITLE REVISION /

DATE

CKL AL-120 Auxiliary Feedwater Normal Lineup 34

SYS AL-120 Feeding Steam Generators with a Motor Driven or Turbine 33

Driven AFW Pump

SYS KJ-121 Diesel Generator Lineup for Auto Ops 39

ALR 00-128B TD AFW Start 8

CKL EM-120 Safety Injection Normal Lineup 24A

USAR, Table 3.2-4, Design Comparison to Regulatory Guide 1.26, Revision 3, Dated February

1976, Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste

Containing Components of Nuclear Power Plants

USAR, Table 3.2-1, Sheet 15, Classification of Structures, Components, and Systems

Design Specification for Standby Diesel Generators for the SNUPPS, Job No. 10466-M-018Q

A-3 Attachment

Section 1RO5: Fire Protection

DOCUMENTS

NUMBER TITLE REVISION /

DATE

AP 10-106 Fire Preplans 5

AP 10-106 Fire Preplans 6

E-1F9910 Post Fire Safe Shutdown Area Analysis 2

AP 10-106 Fire Protection Water Supply and Hydrant Locations 6

M-1Y004 Conduit Smoke and Gas Seal Typical Locations 00

M-663-00017 Penetration Seal Typical Details W20

Work Orders

06-290793-040 09-313747-000

Section 1R11: Licensed Operator Requalification

DOCUMENTS

NUMBER TITLE REVISION /

DATE

LR5002010 Loss of ESW (Complex Scenario) 006

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

DOCUMENTS

NUMBER TITLE REVISION /

DATE

Change Use As Is Reactor Trip Bypass Breaker Wiring 0

Package

013975

AP 22C-003 Operational Risk Assessment Program 22C

STS MT-044 Containment Tendon Inspection 7A

A-4 Attachment

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

DOCUMENTS

NUMBER TITLE REVISION /

DATE

012975 Use as is Reactor Trip Bypass Breaker Wiring 0

Work Request

09-071671 09-071887 09-313367-005 09-313367-008 09-313367-004

Work Order

09-313364-000 09-313367-004 08-310078-000

Condition Reports

2007-001482 2009-000113 2009-000354 2009-000355 2009-000357

2009-000506 2009-000354 2009-001392 2009-001302

Section 1R15: Operability Evaluations

NUMBER TITLE REVISION /

DATE

CR 200-111740 CCW Pump to Motor Coupling Bolts

STS EG 100B Component Cooling Wate Pumps B/D Inservice Pump Test Revision 20

WP 118089 Task 1 Rev 0

INC S-0503 Torquing & Sequencing Standards and Practices Rev 4

M-082-00069 Falk Corporation Instructions for installation and W01

maintenance sizes 10 thru 70 Gear Coupling Double

Engagement Horizontal Types G10 & 20 Vertical Types

GV10 & 20

M-082-00068 Falk Corporation Limited end Float Coupling Installation W01

Instructions Gear Couplings Double Engagement Horizontal

Types G10 & 20

Falk Lifelign Gear Couplings Manual

STS IC-615B Slave relay Test K615 Train B Safety Injection 20

M-1G023 Equipment Locations Reactor & Auxiliary Bldg Plan 9

EL 20260

A-5 Attachment

Section 1R15: Operability Evaluations

NUMBER TITLE REVISION /

DATE

SYS KJ-123 Post Maintenance Run of Emergency Diesel Generator A 41

STS KJ-015A Manual/Auto Fast Start, Sync & Loading of EDG NE01 25A

Condition Reports

2009-000259 2009-000262 2009-000666 2009-000310 2009-000643

2009-000733 2009-000666 AR 14667

Work Orders:

0-214187-000-001-003 08-313153-000 09-313686-000 05-279610-000

05-279610-003 05-279610-002 09-314853-000

0-214187-003 0-214187-001

Engineering Disposition:

ECLSL0058 J-Box Silicon Fluid

Drawing:

E-13EC01, Fuel Pool Cooling Pumps, Revision 1

Section 1R19: Postmaintenance Testing

DOCUMENTS

NUMBER TITLE REVISION /

DATE

STS PE-013 Personnel Airlock Seal Test 15

STS IC-615A Slave Relay Test K615 Train A Safety Injection 20

STS KJ-015A Manual/Auto Fast Start, Sync & Loading of EDG NE01 25A

Condition Report

2009-000187

Section 1R22: Surveillance Testing

PROCEDURES

NUMBER TITLE REVISION /

DATE

OE KJ-09-003 Emergency Diesel Generator B Crankcase Vapor Extractor 1 and 3

A-6 Attachment

Section 1R22: Surveillance Testing

PROCEDURES

NUMBER TITLE REVISION /

DATE

Material Safety Data Bulletin-Mobilgard 570

AP 15C-004 Preparation, Review and Approval of Procedures, 33

Instructions and Forms

AP 29B-001 IST Basis Document 3

AP 29B-002 ASME Code Testinig of Pumps and Valves 6

AP 29B-003 Surveillance Testing 9

STS SF-001 Control and Shutdown Rod Operability Verification 24

OSP-SF-00002 Control Bank 18

AP 29B-003 Surveillance Testing 10

Work Order

07-297977-000,

Condition Reports

2009-000598 2009-001357 2009-001391 2009-001401 2007-002911

Work Request

09-072564 09-072565 09-072566 09-072567 09-072568

Other Documents:

NRC Information Notice 97-16, Preconditioning of Plant Structures, Systems, and Components

before ASME Code Inservice Testing or Technical Specification Surveillance Testing

NRC Inforomation Notice 85-14, Failure of a Heavy Control Rod (B4C) Drive Assumbly to Insert

on a Trip Signal.

Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs

Action Plan:

1344, DRDM Transitory Misstepping Due to Crud

2708, Add Single Stepping of Rods to Rod Operability Surveillance.

A-7 Attachment

2709, CRDM Conditioning to Preclude Crud Buildup

Westinghouse Electric Company Technical Bulleting, CRDM Transitory Misstepping Due to

Crud, No. TB-06-17

Section 1EP6: Drill Evaluation

DOCUMENTS

NUMBER TITLE REVISION /

DATE

SA-01 Station Blackout Followed by Loss of Coolant Accident 00

Section 4OA1: Performance Indicator Verification

DOCUMENTS

NUMBER TITLE REVISION /

DATE

AP 26A-007 NRC Performance Indicators 5

Section 4OA2: Identification and Resolution of Problems

PROCEDURES

NUMBER TITLE REVISION /

DATE

SYS EG-205 CCW to RCP Flow Adjustment 5

012956 RCP Thermal Barrier Flow Loop Time Delay 0

M-12EG03 P&ID Component Cooling Water System 08

Condition Reports

2007-0178 2007-1125 2007-0597 2007-2064 2007-0643

2007-2601 2007-0717 2008-5241 2008-5688 2008-5691

Work Orders

02-246887-00 02-246887-01 01-224201-42 01-227685-00 08-31647-00

Work Requests

01-025637 02-29406 02-036118

A-8 Attachment

Performance Improvements Requests

2001-0866 2002-0734 2002-3039 2004-0298

Section 4OA3: Event Follow-Up

PROCEDURES

NUMBER TITLE REVISION /

DATE

OFN AF-025 Unit Limitations 25

A-9 Attachment