Text

IR 05000482-09-004, 7/1/2009 - 9/30/2009; Wolf Creek Generating Station, Integrated Resident and Regional Report; Operability Evaluations; Post Maintenance Testing; Plant Modifications; Maintenance Risk Assessments and Emergent Work Control
	ML093140803
Person / Time
Site:	Wolf Creek
Issue date:	11/10/2009
From:	Geoffrey Miller; Division of Nuclear Materials Safety IV
To:	Muench R; Wolf Creek
References
	IR-09-004
	Download: ML093140803 (61)
	v • d • e

November 10, 2009

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 05000482/2009004

Dear Mr. Muench:

On September 30, 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 October 14, 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.

This report documents eight NRC identified findings of very low safety significance (Green). All

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,

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 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).

UNITED STATES

NUCLEAR REGULATORY COMMISSION

R E GI ON I V

612 EAST LAMAR BLVD, SUITE 400

ARLINGTON, TEXAS 76011-4125

Wolf Creek Nuclear Operating Corporation - 2 -

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

Public Electronic Reading Room).

Sincerely,

/RA/

Geoffrey B. Miller, Chief

Project Branch B

Division of Reactor Projects

Docket No. 50-482

License No. NPF-42

Enclosure

Inspection Report 05000482/2009004

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

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

Wolf Creek Nuclear Operating Corporation - 3 -

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

FEMA, Region VII

9221 Ward Parkway

Suite 300

Kansas City, MO 64114-3372

Wolf Creek Nuclear Operating Corporation - 4 -

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)

Resident Inspector (Charles.Peabody@nrc.gov)

Site Secretary (Shirley.Allen@nrc.gov)

Branch Chief, DRP/B (Geoffrey.Miller@nrc.gov)

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

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

Technical Support Branch (Chuck.Paulk@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

OEMail Resource

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

NSIR/DRP/EP (Robert.Kahler@nrc.gov)

DRS STA (Dale.Powers@nrc.gov)

OEDO RIV Coordinator (Leigh.Trocine@nrc.gov)

ROPreports

File located: R:\\_REACTORS\\_WC\\2009\\WC 2009-004RP-CML.doc ADAMS ML093140803

SUNSI Rev Compl.

7Yes No

ADAMS

7Yes No

Reviewer Initials

GM

Publicly Avail

7Yes No

Sensitive

Yes 7 No

Sens. Type Initials

GM

RI:DRP/

SRI:DRP/

SPE:DRP/

C:DRS/EB1

C:DRS/EB2

CAPeabody

CMLong

PJayroe

RLKellar

NFOKeefe

/RA - E/

/RA/

/RA WSifre for/

/RA/

10/20/2009

11/10/2009

11/05/2009

C:DRS/OB

C:DRS/PSB1

C:DRS/PSB2

C:DRP/

SGarchow

MPShannon

GEWerner

GBMiller

/RA/

/RA Johnson for/

/RA/

11/05/2009

11/06/2009

11/10/2009

OFFICIAL RECORD COPY

T=Telephone E=E-mail F=Fax

- 1 -

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket:

50-482

License:

NPF-42

Report:

05000482/2009004

Licensee:

Wolf Creek Operating Corporation

Facility:

Wolf Creek Generating Station

Location:

1550 Oxen Lane SE

Burlington, Kansas

Dates:

July 1 through September 30, 2009

Inspectors:

C. M. Long, Senior Resident Inspector

C. A. Peabody, Resident Inspector

P. A. Jayroe, Project Engineer, Project Branch B

G. W. Apger, Operations Engineer

S. M. Alferink, Reactor Inspector, Engineering Branch 2

J. P. Adams, Reactor Inspector, Engineering Branch 1, DRS

C. M. Ryan, Reactor Inspector, Engineering Branch 1, DRS

G. P. Tutak, Reactor Inspector, Engineering Branch 2, DRS

Approved By:

G. B. Miller, Chief, Project Branch B

Division of Reactor Projects

- 2 -

Enclosure

SUMMARY OF FINDINGS

IR 05000482/2009004, 7/1/2009 - 9/30/2009; Wolf Creek Generating Station, Integrated

Resident and Regional Report; Operability Evaluations; Post Maintenance Testing; Plant

Modifications; Maintenance Risk Assessments and Emergent Work Control; Fire Protection;

Event Followup.

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

baseline inspections by regional based inspectors. Seven Green and one Severity Level IV

noncited violations of significance 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: Mitigating Systems

Green. On June 30, 2009, the inspectors identified a noncited violation of Technical

Specification 3.8.1 for failure to perform an adequate common cause evaluation within

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to demonstrate no common cause failure mechanism existed between the

emergency diesel generators after a through-wall leak was discovered on the essential

service water piping. Wolf Creek did not start the opposite train emergency diesel

generator and declared that the through-wall flaw was not a common cause failure

without any evaluation or supporting statements. Nondestructive testing had not been

started at this time. Subsequent evaluation of the flaw per American Society of

Mechanical Engineers (ASME) Code Case N513.2 restored operability to the essential

service water piping. The licensee entered this issue in their corrective action program

as Condition Report 18347.

The inspectors determined that the failure to demonstrate, per Technical

Specifications 3.8.1 Required Actions B.3.1 or B.3.2, that no common cause failure

existed for the emergency diesel generators was a performance deficiency. The

inspectors determined that this finding was more than minor because it is associated

with the equipment performance attribute for the Mitigating Systems Cornerstone and

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 using Phase 1 of Inspection Manual

Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings

for At Power Situations," and determined that the finding was of very low safety

significance (Green) because the issue was not a design or qualification deficiency

confirmed to result in loss of operability or functionality, did not represent a loss of

system safety function, an actual loss of safety function of a single train for greater than

its technical specification allowed outage time, an actual loss of safety function of a

nontechnical specification risk-significant equipment train, and did not screen as

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

- 3 -

Enclosure

The cause of the finding has a problem identification and resolution crosscutting aspect

in the area associated with the corrective action program because Wolf Creek failed to

thoroughly evaluate the failure mechanism such that the resolutions address the causes

and extent of conditions, as necessary. Specifically Wolf Creek did not properly

consider the possibility of common-cause pitting failures which could have impacted the

essential service water piping Train A structural integrity thereby affecting its cooling

loads, including the Emergency Diesel Generator A P.1(c) (Section 1R15).

Green. The inspectors identified a noncited violation of Technical Specification 3.8.1,

Required Action B.4.2.2 on March 24, 2009 when the licensee performed elective

maintenance on safety bus relays and removed equipment from service that was

required by the technical specification and the NRC Safety Evaluation Report (SER)

while in an extended diesel generator outage. The maintenance had the potential to

open the normal offsite feeder breaker. This issue has been entered into the corrective

action program as Condition Report 15727.

The inspectors determined that the failure to implement requirements of Technical

Specification 3.8.1 and the associated NRC safety evaluation was a performance

deficiency. The finding was more than minor because it is associated with the

equipment performance attribute for the Mitigating Systems Cornerstone and affected

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

that respond to initiating events to prevent undesirable consequences (i.e., core

damage). The finding was determined to be of very low safety significance because the

issue did not result in the Train B offsite power being inoperable for greater than

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and did not involve external events such as flooding. Additionally, the cause of

the finding has a problem identification and resolution crosscutting aspect in the area

associated with the corrective action program. Specifically, Wolf Creek did an extent of

condition review in response to a previous violation which included

Procedure STS IC-208B, but still failed to prohibit performance of STS IC-208B during

the 7-day diesel outages P.1(c) (Section 1R19).

Green. On August 22, 2009, the inspectors identified a noncited violation of Technical

Specification 3.0.3 in which both trains of Technical Specification 3.3.2 engineered safety

features actuation system interlock function 8.a were bypassed with jumper wires in

accordance with a plant procedure. Function 8.a is the interlock for reactor trip signal

coincident with lo Tave signal. Wolf Creek blocked the signal from the feedwater valves

with jumper wires during control rod drive motor-generator testing in Mode 3. The

inspectors and the NRR technical specification branch found this to be contrary to the

Updated Safety Analysis Report, the technical specifications, the technical specification

bases, and the NRC safety evaluations supporting the technical specifications. The

licensee entered this issue in their corrective action program as Condition Report 19318.

The inspectors found that the failure to implement Technical Specification 3.3.2 interlock,

function 8.a was a performance deficiency. The inspectors determined that this finding

was more than minor because it is associated with the design control attribute of the

Mitigating Systems Cornerstone and it affected the cornerstone objective to ensure the

availability, reliability, and capability of mitigating systems that respond to initiating

events to prevent undesirable consequences (i.e., core damage). The inspectors

evaluated the significance of this finding using Inspection Manual Chapter 0609.04,

- 4 -

Enclosure

Phase 1 - Initial Screening and Characterization of Findings, and screened the finding

to Phase 2 because the finding represents a loss of a systems function. The inspectors

used Inspection Manual Chapter 0609, Appendix A and screened the finding to the NRC

senior reactor analyst for review because there was not an acceptable equipment

deficiency in the pre-solved worksheet. The senior reactor analyst determined that the

finding is Green because he solved Table 3.10 of the Risk-Informed Inspection

Notebook for Wolf Creek Generating Station, Revision 2.1a and found that the loss of

feedwater isolation signal for less than 3 days resulted in a 1E-7 (Green) outcome. The

inspectors also determined that the cause of the finding has a crosscutting aspect in the

human performance area associated with decision making because Wolf Creek failed to

make a risk significant decision using a systematic process. This issue was evaluated

more than once and those evaluations sought to justify bypassing the interlock rather

than seek the full regulatory basis for the interlock H.1.a] (1R15).

Green. The inspectors identified a noncited violation of 10 CFR 50 Appendix B,

Criterion III, Design Control, for failing to translate the boric acid design basis into

procedures that ensure time sensitive operator actions are completed to achieve the

core shutdown margin specified in the core operating limits report. Performance

Improvement Request 2005-3461 identified that if the room coolers were started while

lake temperature was low, the boric acid solution temperature may decrease below the

solubility limit. Corrective actions for heat tracing and room temperature logging took

approximately 3 years to implement and stopped short of addressing boric acid system

operation when nonsafety power is lost to the heat tracing and the plant must be taken

to cold shutdown in accordance with technical specifications. The licensee entered this

issue in their corrective action program as Condition Report 20717.

The failure to translate the design bases into procedures that ensure the function of the

safety-related boric acid system upon loss of nonsafety-related heat tracing 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 pipe temperature was required to stay above the boric acid

solubility limit and the loss of the heat tracing and or room temperature decrease will

block the boric acid system. This issue was associated with the equipment performance

attribute of the mitigating systems cornerstone and affected the cornerstone objective to

ensure the availability, reliability, and capability of systems that respond to initiating

events. The inspectors evaluated the significance of this finding using Phase 1 of

Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor

Inspection Findings for At Power Situations," and determined that the finding screened to

phase 2 because the issue was a design or qualification deficiency confirmed to result in

loss of operability or functionality The inspectors evaluated the significance of this

finding using Phase 2 of Inspection Manual Chapter 0609, Risk Informed Inspection

Notebook for Wolf Creek Generating Station, and determined that the finding was of very

low safety significance because loss of the boric acid system in Table 3.9 for one year

resulted in a 1E-7 CDF when giving recovery credit for the refueling water storage tank.

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 did not take appropriate corrective actions to resolve

known deficiencies in the design and operation of the boric acid system for

- 5 -

Enclosure

approximately 4 years. The issue was re-evaluated in 2009, and the licensee failed to

correct the deficiencies identified in 2005. P.1.d] (Section 1R18).

Green. The inspector identified a noncited violation of 10 CFR 50.65(a)(4) for failure to

adequately assess and manage the increase in risk during fuse inspection of component

cooling water valves supplying cooling loads inside containment. On March 18, 2009,

component cooling water Valves EG HV-16 and EG HV-54 were out of service for fuse

inspections to verify wiring for fire protection analyses. The inspectors observed that the

evolution was not included in the weekly risk assessment and that operations and

maintenance personnel did not have guidance or briefings for restoration of the valves.

Review of the risk assessment revealed that the impact of de-energizing the valves in

the closed position was neglected and that restoration actions credited by the risk

analyst were unknown to the control room and craft workers. The issue was entered into

the corrective action program as Condition Report 15318.

The failure to adequately assess and manage risk in accordance with AP 22C-003 and

the preplanned risk assessment for the use of local actions to ensure component cooling

water cooling to loads inside containment was a performance deficiency. The finding is

more than minor because the licensee failed to effectively manage prescribed significant

compensatory measures for maintenance activities that could increase the likelihood of

initiating events. The finding was of very low safety significance because the magnitude

of the calculated risk deficit was less than IE-6 even though risk management actions

were not in place. The inspectors also determined that the finding has a human

performance crosscutting aspect in the area associated with work control because the

risk assessment procedure and clearance order procedure assumed local actions could

be accomplished but there was no communication regarding this during the work

planning stages H.3(b) (Section 1R13).

Severity Level IV. The inspectors identified a Severity Level IV noncited violation of

License Condition 2.C.(5), Fire Protection, for making changes to the approved fire

protection program without the required prior Commission approval. Specifically, the

licensee made a change to the Updated Safety Analysis Report that allowed the

licensee to violate the requirements of 10 CFR Part 50, Appendix R, Section III.L.

Specifically, when the licensee recognized that fire damage could cause a pressurizer

power operated relief valve to open long enough to create a void in the reactor vessel,

this was documented as acceptable when it was not in compliance with this regulatory

requirement. The licensee entered this issue into their corrective action program as

Performance Improvement Request 2008-004869.

This finding was assessed using traditional enforcement since it had the potential for

impacting the NRCs ability to perform its regulatory function. This finding is more than

minor since the change required prior staff review and approval prior to implementation

and it did not receive the required approval. A senior reactor analyst performed a

Phase 3 evaluation and determined this performance deficiency was of very low risk

significance. In accordance with the guidance in Supplement I of the Enforcement

Policy, this issue is considered a Severity Level IV noncited violation because it is of

very low risk significance. This finding had a crosscutting aspect in the area of human

performance associated with resources because the licensee failed to maintain

long-term plant safety by maintaining design margins. Specifically, the licensees choice

- 6 -

Enclosure

to allow reactor vessel head voiding during an alternative shutdown in lieu of restoring

the plant to compliance with the requirements of 10 CFR Part 50, Appendix R,

Section III.L constituted a reduction in safety margin H.2(a) (Section 40A5.3).

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 August 12, 2009, the inspectors conducted a walkdown of the spent fuel pool area

and found duct tape attached to various fueling and control rod tools such that duct tape

was below the water. This duct tape was not in the foreign material exclusion logs.

Spent fuel pool foreign material control is required under Procedure AP 12-003. The

licensee entered this issue in their corrective action program as Condition Report 20338.

The inspectors determined that the failure to log material in accordance with

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 to 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

problem identification and resolution associated with the corrective action program

component because although Wolf Creek performed a root cause and extent of

condition evaluation for untracked foreign material, the evaluation still failed to find the

duct tape in the pool itself. This allowed the tape to continue to be untracked P.1.c]

(Section 1R05).

Cornerstone: Miscellaneous

Severity Level IV. The inspectors identified a Severity Level IV noncited violation of

10 CFR 50.73, Licensee Event Report System, with three examples in which the

licensee failed to submit licensee event reports within 60 days following discovery of an

event meeting the reportability criteria. First, on April 10, 2008, Wolf Creek submitted

Licensee Event Report 2008-002-00 under 10 CFR 50.73(a)(2)(i)(B) which is operation

prohibited by technical specifications but failed to make a report for a loss of safety

function per 10 CFR 50.73(a)(2)(v) for the same event in which both trains of the

emergency core cooling system were inoperable on February 13-14, 2008. Second,

Wolf Creek filed Licensee Event Report 2008-004-00 on June 6, 2008 under

50.73(a)(2)(iv)(A) for an event that caused automatic start of an emergency diesel during

a loss of offsite power on April 16, 2008. No report was made under 50.73(a)(2)(v) for

an event or condition that could have prevented a safety function due to the loss of

offsite power. Third, on April 10, 2008, Wolf Creek filed Event Notification 44131

under 10 CFR 50.72(b)(3)(ii)(B) based on a possible trip of all four containment coolers.

The notification was later retracted. The inspectors found insufficient evidence to show

that the containment coolers would not trip and concluded the event should have been

reported under 10 CFR 50.73(a)(2)(v). All three issues are collectively captured in

Condition Report 15318.

- 7 -

Enclosure

The inspectors reviewed this issue in accordance with Inspection Manual Chapter 0612

and the NRC Enforcement Manual. Through this review, the inspectors determined that

traditional enforcement was applicable to this issue because the NRC's regulatory ability

was affected. Specifically, the NRC relies on the licensee to identify and report

conditions or events meeting the criteria specified in regulations in order to perform its

regulatory function, and when this is not done, the regulatory function is impacted. The

inspectors determined that this finding was not suitable for evaluation using the

significance determination process, and as such, was evaluated in accordance with the

NRC Enforcement Policy. The finding was reviewed by NRC management, and because

the violation was determined to be of very low safety significance, was not repetitive or

willful, and was entered into the corrective action program, this violation is being treated

as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy.

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

identification and resolution associated with the corrective action program in that the

licensee failed to appropriately and thoroughly evaluate for reportability aspects all

factors and time frames associated with the inoperability of the emergency core cooling

system, the offsite power system, and the containment heat removal system P.1(c)

(Section 4OA3).

- 8 -

Enclosure

REPORT DETAILS

Summary of Plant Status

The plant started the inspection period at 100 percent rated thermal power. On August 19,

2009, Wolf Creek experienced and automatic reactor trip from 100 percent power when a

lightning strike caused a loss of offsite power. Wolf Creek restarted on August 24, 2009. On

August 28, 2009, Wolf Creek reduced power to 99 percent for the end of core life moderator

temperature coefficient surveillance test. On September 30, 2009, Wolf Creek decreased to

97 percent power for heater drain pump repair.

1.

REACTOR SAFETY

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

Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

.1

Summer Readiness for Offsite and Alternate ac Power

a.

Inspection Scope

On August 10, 2009, the inspectors performed a review of the licensees preparations for

summer weather for selected systems, including conditions that could lead to loss-of-

offsite power and conditions that could result from high temperatures. The inspectors

reviewed the licensees procedures affecting these areas and the communications

protocols between the transmission system operator and the plant to verify that the

appropriate information was being exchanged when issues arose that could affect the

offsite power system. Examples of aspects considered in the inspectors review

included:

The coordination between the transmission system operator and the plant during

offnormal or emergency events

The explanations for the events

The estimates of when the offsite power system would be returned to a normal

state

The notifications from the transmission system operator to the plant when the

offsite power system was returned to normal

These activities constitute completion of one readiness for summer weather affect on

offsite and alternate ac power sample as defined in Inspection

Procedure (IP) 71111.01-05.

b.

Findings

No findings of significance were identified.

- 9 -

Enclosure

1R04 Equipment Alignments (71111.04)

.1

Partial Walkdown

a.

Inspection Scope

The inspectors performed partial walkdown of the following risk-significant systems:

Motor-Driven auxiliary feedwater Train B, July 7, 2009

Turbine-Driven auxiliary feedwater, July 7, 2009

Essential service water Train A, August 9, 2009

Centrifugal charging pump Train A, September 22, 2009

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 (USAR), 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 four partial system walkdown sample as defined

in IP 71111.04-05.

b.

Findings

No findings of significance were identified.

.2

Complete Walkdown

a.

Inspection Scope

On September 18, 2009, the inspectors performed a complete system alignment

inspection of the main steam 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 line ups,

- 10 -

Enclosure

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.

These activities constitute completion of one complete system walkdown sample as

defined in 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:

4kV Switchgear rooms, control building 2000 elevation, July 9, 2009

Diesel generator rooms, diesel building 2000 elevation, July 9, 2009

Turbine-Driven auxiliary feedwater room, August 11, 2009

Spent fuel pool 2047 elevation, August 12, 2009

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.

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Enclosure

These activities constitute completion of four quarterly fire protection inspection samples

as defined by IP 71111.05-05.

b.

Findings

.2

Introduction. On August 12, 2009, the inspectors identified a Green noncited violation of

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

Material Exclusion, after a root cause assessment on foreign material exclusion.

Description. On August 12, 2009, the inspectors conducted a walkdown of the spent fuel

pool area and found duct tape below the water. Numerous pieces of duct tape, including

that on fueling and control rod manipulation tools, were not in the logs. The inspectors

reviewed Procedure AP 12-003, Foreign Material Exclusion, Revision 7. 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 are 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 the pages of the log itself are tracked. The inspectors

reviewed the spent fuel pool area logs and concluded the logs were inadequate.

Although Wolf Creek logged some duct tape, numerous pieces of duct tape on fuel and

control rod tools were not logged.

The inspectors reviewed the spent fuel pool area material tracking practices since the

completion of a root cause evaluation and extent of condition review in response to

previous NRC finding 05000482/2009002-03. The inspectors found that Wolf Creek

performed an extent of condition review to examine the bottom of the cask pit and the

spent fuel racks, but failed to identify the duct tape on the tools. The inspectors did not

find any documentation stating that the tape was acceptable for use underwater in an

acidic environment. Although the tape markings are used for refueling operations, the

inspectors found no documentation that would lead Wolf Creek to identify the missing

tape. On August 12, 2009, Wolf Creek initiated Condition Report 19110, but this report

only asked how to handle the submerged tape and did not identify the failure to log the

material. The issue was appropriately captured in the corrective action program with

Condition Report 20338.

Analysis. The inspectors determined that the failure to track foreign material in

accordance with 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 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 to be of very low safety

significance because the finding only affected the barrier function of the spent fuel pool

and did not result in actual clogging of the 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 although Wolf Creek

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Enclosure

performed a root cause and extent of condition evaluation for untracked foreign material,

the evaluation still failed to find the duct tape in the pool itself. This allowed the tape to

continue to be untracked P.1.c].

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

foreign material accountability for the spent fuel pool. Contrary to the above, prior to

August 12, 2009, the licensee failed account for foreign material in the spent fuel pool.

Because this violation was determined to be of very low safety significance and was

placed in the corrective action program as Condition Report 20338, this violation is being

treated as a noncited violation in accordance with Section VI.A.1 of the Enforcement

Policy: NCV 05000482/2009004-01, Failure to Log Foreign Material in Spent Fuel Pool

after Extent of Condition Evaluation.

1R06 Flood Protection Measures (71111.06)

a.

Inspection Scope

The inspectors reviewed the USAR, the flooding analysis, and plant procedures to

assess seasonal susceptibilities involving internal flooding; reviewed the USAR and

corrective action program to determine if licensee personnel identified and corrected

flooding problems; inspected underground bunkers/manholes to verify the adequacy of

sump pumps, level alarm circuits, cable splices subject to submergence, and drainage

for bunkers/manholes; verified that operator actions for coping with flooding can

reasonably achieve the desired outcomes; and walked down the one area listed below to

verify the adequacy of equipment seals located below the flood line, floor and wall

penetration seals, watertight door seals, common drain lines and sumps, sump pumps,

level alarms, and control circuits, and temporary or removable flood barriers. Specific

documents reviewed during this inspection are listed in the attachment.

September 17, 2009, Essential service water Manhole MHE-2B for cable splice

inspections.

These activities constitute completion of one flood protection measures inspection

sample as defined by IP 71111.06-05.

b.

Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.11)

.1

Quarterly Inspection

a.

Inspection Scope

On September 14, 2009, the inspectors observed a crew of licensed operators in the

plants simulator to verify that operator performance was adequate, evaluators were

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Enclosure

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

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.

.2

Annual Inspection (71111.11B)

The licensed operator prequalification program involves two training cycles that are

conducted over a 2-year period. In the first cycle, the annual cycle, the operators are

administered an operating test consisting of job performance measures and simulator

scenarios. In the second part of the training cycle, the biennial cycle, operators are

administered an operating test and a comprehensive written examination.

a.

Inspection Scope

The inspector conducted an in office review of the annual prequalification training

program operating test results for 2009. The licensee examined fifty operators (twenty-

one reactor operators and twenty-nine senior reactor operators) during this

prequalification cycle. In addition, nine operating crews were examined on the facility's

simulator. All of the operating crews passed the simulator scenarios and all operators

passed the operating tests.

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Enclosure

b.

Findings

No findings of significance were identified.

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:

Performance of Procedure TMP 09-014, July 15, 2009

Failure of flow indicator BBFI-425, July 16, 2009

Component cooling water valves fuse inspections, March 16, 2009

Week of August 24, 2009, planned work risk assessment

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 four maintenance risk assessments and

emergent work control inspection samples as defined by IP 71111.13-05.

b.

Findings

Introduction. The inspector identified a noncited violation of 10 CFR 50.65(a)(4) for

failure to adequately assess and manage the increase in risk during fuse inspection of

component cooling water valves supplying cooling loads inside containment.

Description. On March 18, 2008, component cooling water Valves EG HV-16 and EG

HV-54 were out of service for fuse inspections to verify wiring for fire protection

analyses. The inspectors observed that the evolution was not included in the weekly risk

assessment. The inspectors noted that operations and maintenance personnel did not

have guidance or briefings for restoration of the valves. Review of the risk assessment

by Wolf Creek after inspector questioning revealed that the impact of de-energizing the

valves in the close position was neglected and that restoration actions credited by the

risk analyst were unknown to the control room and craft workers. Specifically, Condition

Report 0015318 states that loss of reactor coolant pump thermal barriers was possible,

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Enclosure

but it did not state that it was possible to also lose the reactor coolant pump seal water

cooling heat exchanger, reactor coolant pump radial bearing cooling, reactor coolant

pump motor cooling, the letdown heat exchanger, and the excess letdown heat

exchanger. Due to these additional loads, this would also be a reactor trip initiator

initiating event.

A local clearance order was assumed to provide local control and restoration instructions

but Wolf Creek later found that these actions were not possible because the clearance

order contained no restoration instructions. Inspectors reviewed the work package for

the fuse inspections and found that the pre-job briefing did not contain any instructions to

craftsmen for rapid restoration. Procedure AP 22C-003, Revision 13 Attachment A

required risk management actions due to the potential for a trip initiator and the potential

to interrupt the thermal barrier heat exchangers for the reactor coolant pump seals. The

control room and maintenance personnel were not aware of the restoration actions

assumed in the risk assessment. Only the risk engineers were aware of the restoration

actions. Wolf Creeks evaluation of the issue found that the maintenance planning

group, the risk assessment engineers, and operations were not procedurally required to

discuss the restoration actions when changes were made during maintenance planning

in the prior weeks.

Analysis. The failure to adequately assess and manage risk in accordance with

AP 22C-003 and the preplanned risk assessment for the use of local actions to ensure

component cooling water cooling to loads inside containment 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.

The finding is more than minor because the licensee failed to effectively manage

prescribed significant compensatory measures for maintenance activities that could

increase the likelihood of initiating events. The finding was of very low safety significance

because the magnitude of the calculated risk deficit was less than 1 x 10-6 even though

risk management actions were not in place. The inspectors also determined that the

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

control because the risk assessment procedure and clearance order procedure assumed

local actions could be accomplished but there was no communication regarding this

during the work planning stages H.3(b)

Enforcement. 10 CFR 50(a)(4), requires, in part, that before performing maintenance

activities (including but not limited to surveillance, post maintenance testing, and

corrective and preventive maintenance), the licensee shall assess and manage the

increase in risk that may result from the proposed maintenance activities.

Procedure AP 22C-003, Revision 13, and the resulting weekly risk assessment

implement this regulation. Contrary to the above, on March 18, 2009, the licensee did

not effectively manage the increase in risk resulting from a maintenance activity.

Specifically, on March 18, 2009, during fuse inspections of component cooling water

Valves EG HV-16 and EG HV-54, the licensee failed to adequately assess and manage

the increase in risk that resulted from the maintenance activity. Restoration actions

credited in Wolf Creeks weekly risk assessment were determined to be not possible to

implement. The licensee entered this issue into their corrective action program as

Condition Report 15318. Because the licensee has entered the issue into their corrective

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Enclosure

action program and the finding is of very low safety significance, this violation is being

treated as a NCV, consistent with Section VI.A of the NRC Enforcement Policy:

NCV 5000482/2009004-02, Inability to perform manual actions for risk assessment.

1R15 Operability Evaluations (71111.15)

a.

Inspection Scope

The inspectors reviewed the following issues:

Essential service water piping through wall leakage, separate occurrences on

June 30, July 28, and August 19, 2009

Diesel generator common cause failure evaluation on June 30, 2009

Performance of procedure SYS SB-122 on August 22, 2009

Nonconservative core flux technical specification on August 5, 2009

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 USAR 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 in place 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 four operability evaluations inspection samples

as defined in IP-1111.15-05

b.

Findings

.1

Introduction. The inspectors identified a Green noncited violation of Technical

Specification 3.8.1 for failure to perform an adequate common cause evaluation within

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to demonstrate no common cause failure mechanism existed between the

operable and inoperable emergency diesel generators.

Description. At 11:15 a.m., on June 30, 2009, Wolf Creek auxiliary building watch

discovered a through-wall leak in the essential service water Train B

Piping EF-138-HBC-30 just upstream of valve EF-HV-0038. The piping was leaking

through two adjacent pinholes at the bottom of the pipe spaced approximately 0.4 inch

apart. This condition was recognized as a limiting condition of operations per

Condition A of Technical Requirements Manual 3.4.17, Structural Integrity, which

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Enclosure

requires the structural integrity of all ASME Class I, II, and III piping to be maintained.

The required action directed operators to declare the essential service water Train B

inoperable. Thus Wolf Creek entered Condition A of Technical Specification 3.7.8

Essential Service Water, for one train of essential service water inoperable. This

condition has a required action of restoring the essential service water train to operable

status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , but it also requires simultaneous entry into Condition B of

Technical Specification 3.8.1, AC Sources Operating, for the emergency diesel

generator made inoperable by the essential service water system. There are four

required actions associated with Technical Specification 3.8.1, Condition B. First,

Required Action B.1, the control room operators are to verify correct breaker alignment

and indicated power availability for each offsite power circuit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and every

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. Second, Required Action B.2 requires that features supported by the

inoperable diesel generator be declared inoperable when its required redundant feature

is inoperable within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Third, Required Action B.3.1 requires Wolf Creek to

determine that the operable diesel generator is not inoperable due to a common cause

failure. Alternatively, Required Action B.3.2 directs Wolf Creek to verify the operable

diesel generator starts from standby conditions and achieves steady state voltage and

frequency, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Fourth, Required Action B.4.1 directs the restoration the

diesel generator to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Wolf Creek properly carried out

Required Actions B.1, B.2, and B.4.1 required by Technical Specification 3.8.1,

Condition B.

At 12:02 p.m., 47 minutes after the leak was discovered, the control room logs state that

Technical Specification 3.8.1, Action B.3.1, is being exited because Emergency Diesel

Generator B inoperable due to ESW being inoperable not a common cause failure. The

inspectors interviewed operations personnel on the adequacy of such a justification.

Operations provided the inspectors with a completed copy of Procedure SYS KJ-200,

Inoperable Emergency Diesel. Procedure Step 6.1.5 states: If the absence of any

potential common cause failure can be demonstrated . . . then document the evaluation

on the cover sheet. However, the cover sheet had only one sentence which matched

the log entry verbatim. At the time of this determination, ultrasonic testing to determine

flaw size and pipe wall thicknesses had yet to be performed. The results of that testing

were the basis for an ASME N513.2 code case which eventually restored operability.

During later interviews regarding the control room log entries, Wolf Creek stated that

nonlicensed operators did not find any other through wall leaks on essential service

water Train B, and therefore Train B was operable. The inspectors found that this type

of visual evaluation did not meet the reasonable assurance standard specified in RIS

2005-20. Visual examinations can not identify below minimum wall thickness piping or

piping flaws under insulation. The inspectors concluded the licensees evaluation lacked

a valid technical basis for determination that a common cause failure mechanism did not

exist on the opposite train emergency diesel generator.

The ASME N513.2 code case was issued and essential service water/emergency diesel

generator operability restored at 9:40 p.m. that night. The code case verified the

structural integrity of the piping despite the current through-wall flaw; however, it

specified that due to the potential common cause nature of pitting flaws, five additional

locations had to be ultrasonic tested to verify that minimum wall thickness was met.

Although none of the additional locations indicated any below minimum-wall flaws in the

essential service water piping, an expanded ultrasonic test of the leak area revealed two

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Enclosure

additional pits that were below the minimum wall thickness acceptance criteria.

Separate evaluations were performed for those flaws and all three were permanently

repaired per the ASME code on July 23, 2009.

Analysis: The inspectors determined that the failure to demonstrate operability of

Emergency Diesel Generator B per Technical Specification 3.8.1, Required Action B.3.1

or B.3.2 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. The inspectors determined that this finding was

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

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 (i.e., core damage). Specifically, this issue relates to

the availability and reliability examples of the equipment performance attribute because

a latent common mode failure mechanism was not correctly evaluated. The inspectors

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