ML111290768
| ML111290768 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/09/2011 |
| From: | Geoffrey Miller NRC/RGN-IV/DRP/RPB-B |
| To: | Matthew Sunseri Wolf Creek |
| References | |
| IR-11-002 | |
| Download: ML111290768 (73) | |
See also: IR 05000482/2011002
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I V
1600 EAST LAMAR BLVD
ARLINGTON, TEXAS 76011-4125
May 9, 2011
Matthew Sunseri, 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 05000482/2011002
Dear Mr. Sunseri:
On March 31, 2011, 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, 2011, with you 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, the NRC has identified 11 issues that were evaluated
under the risk significance determination process as having very low safety significance
(Green). The NRC has determined that violations are associated with all of these issues.
However, because of the very low safety significance and because they were entered into your
corrective action program, the NRC is treating these findings as noncited violations, consistent
with Section 2.3.2 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 facility. In addition, if you disagree with the crosscutting aspect
assigned to 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 facility.
Wolf Creek Nuclear Operating Corporation -2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response, if you choose to provide one for cases where a response is not
required, will be made available electronically for public inspection in the NRC Public Document
Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not
include any personal privacy or proprietary, information so that it can be made available to the
Public without redaction.
Sincerely,
/RA/
Geoffrey B. Miller
Chief, Project Branch B
Division of Reactor Projects
Docket No. 50-482
License No. NPF-42
Enclosure:
NRC Inspection Report 05000482/2011002
w/Attachment: Supplemental Information
Distribution via Listserv
Wolf Creek Nuclear Operating Corporation -3-
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Art.Howell@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
DRP Deputy Director (Troy.Pruett@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
Senior Resident Inspector (Chris.Long@nrc.gov)
Resident Inspector (Charles.Peabody@nrc.gov)
Resident Inspector (Brian.Tindell@nrc.gov)
Resident Inspector (Dustin.Reinert@nrc.gov)
WC Administrative Assistant (Shirley.Allen@nrc.gov)
Branch Chief, DRP/B (Geoffrey.Miller@nrc.gov)
Senior Project Engineer, DRP/B (Rick.Deese@nrc.gov)
Project Engineer, DRP/B (Greg.Tutak@nrc.gov)
Project Engineer, DRP/B (Nestor.Makris@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Randy.Hall@nrc.gov)
Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
Executive Technical Assistant (Stephanie.Bush-Goddard@nrc.gov)
OEMail Resource
ROPreports
DRS/TSB STA (Dale.Powers@nrc.gov)
RSLO (Bill.Maier@nrc.gov)
NSIR (Robert.Kahler@nrc.gov)
NSIR/DPR/EP (Eric.Schrader@nrc.gov)
R:\_REACTORS\_WC\2011\WC2011002-CML.docx
ADAMS: No Yes SUNSI Review Complete Reviewer Initials: GM
Publicly Available Non-Sensitive
Non-Publicly Available Sensitive
SRI:DRP/B RI:DRP/B SRI:DRP/B RI:DRP/B
CLong CPeabody BTindell DReinert
/E-Mail for / /E-Mail for/ /E-Mail for / /E-Mail for /
5/9/2011 5/9/2011 5/9/2011 5/9/2011
C:DRS/EB1 C:DRS/EB2 C:DRS/PSB C:DRS/OB
TFarnholtz NOKeefe MShannon MHaire
/RA/ /RA/ /EByre for/ /RA/
5/6/2011 5/6/2011 5/6/2011 5/6/2011
DRS/PSB2 C:DRP/B
GWerner GMiller
/RA/ /RA/
5/6/2011 5/9/2011
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000482
License: NPF-42
Report: 05000482/2011002
Licensee: Wolf Creek Nuclear Operating Corporation
Facility: Wolf Creek Generating Station
Location: 1550 Oxen Lane NE
Burlington, Kansas
Dates: January 1 to March 31, 2011
Inspectors: C. Long, Senior Resident Inspector
B. Tindell, Acting Senior Resident Inspector
J. Drake, Senior Reactor Inspector
C. Peabody, Resident Inspector
D. Reinert, Acting Resident Inspector
C. Smith, Reactor Inspector
A. Fairbanks, Reactor Inspector
G. Guerra, CHP, Emergency Preparedness Inspector
L. Carson II, Senior Health Physicist
C. Alldredge, Health Physicist
Approved By: G. Miller, Chief, Project Branch B
Division of Reactor Projects
-1- Enclosure
SUMMARY OF FINDINGS
IR 05000482/2011002, 1/1/2011 - 3/31/2011; Wolf Creek Generating Station, Integrated
Resident and Regional Report; Equipment Alignment, Maintenance Effectiveness, Operability
Determinations and Functionality Assessments, Postmaintenance Testing, Refueling and Other
Outage Activities, Surveillance Testing, and Radiological Hazard Assessment and Exposure
Controls.
The report covered a 3-month period of inspection by resident inspectors and announced
baseline inspections by region-based inspectors. Eleven Green 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. The crosscutting aspect is determined using Inspection Manual Chapter 0310,
Components Within the Cross Cutting Areas. 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 reviewed a self-revealing noncited violation of Technical
Specification 5.4.1.a, Procedures, involving the failure to follow the requirements of
Procedure AP 21E-001, Clearance Orders. This procedure violation resulted in an
inadequate tagout for the Train A solid state protection system resulting in an unplanned
swap of the volume control tank charging pump suction to the reactor water storage tank
and an unplanned entry into Technical Specification 3.4.12 due to the de-energization of
power operated relief valve A low temperature overpressure protection relays.
Operators took manual actions to restore the pump suction, and power was restored
after approximately four hours. This finding has been entered into the licensees
corrective action program as Condition Reports 35288 and 35318.
The failure to follow procedures to complete clearance orders with adequate boundaries
is a performance deficiency. The performance deficiency was more than minor because
it impacted the Initiating Events Cornerstone objective of configuration control to limit the
likelihood of those events that upset plant stability and challenge critical safety functions
during shutdown as well as power operations. The significance of the finding was
determined using Inspection Manual Chapter 0609, Significance Determination Process,
Appendix G, Checklist 2, and determined to be of very low safety significance, because
it did not cause the loss of mitigating capability of core heat removal, inventory control,
power availability, containment control, or reactivity control. Additionally, the cause of
the finding is related to the human performance crosscutting component of work control.
Specifically, the licensee did not appropriately plan for the maintenance work scope by
-2- Enclosure
ensuring work groups and an offsite organization communicate the necessary electrical
boundaries to assure plant and human performance H.3(b) (Section 1R20).
Cornerstone: Mitigating Systems
Green. The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B,
Criterion III, for the failure to assure that applicable regulatory requirements and the
design basis were met. Specifically, the licensee failed to ensure that the fuel oil storage
tank fill system minimized turbulence, as required by the Updated Safety Analysis
Report, such that the emergency diesel generators can be refueled while running
uninterrupted. The licensee entered this issue in the corrective action program and will
develop corrective actions as part of Condition Report 34730.
The failure to establish measures to assure that applicable regulatory requirements and
the design basis are met was a performance deficiency. The performance deficiency
was more than minor because it impacted the Mitigating Systems Cornerstone attribute
of design control and affects the associated cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. Using Inspection Manual Chapter 0609.04,
"Phase 1 - Initial Screening and Characterization of Findings," the inspectors
determined that the finding had very low safety significance because it did not result in 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, or screen as potentially risk
significant due to a seismic, flooding, or severe weather initiating event. This finding has
a crosscutting aspect in the area of human performance associated with the decision
making component because the licensee failed to use conservative assumptions in
decision making and adopt a requirement to demonstrate the proposed action is safe in
order to proceed rather than a requirement to demonstrate that it is unsafe in order to
disapprove the action H.1(b) (Section 1R04).
Green. The inspectors reviewed a self-revealing noncited violation of Technical Specification 5.4.1.a involving the failure to properly implement the clearance order
procedure resulting in a failure to provide adequate cooling to inservice safety-related
equipment. Operators restored cooling water flow after approximately one hour. The
licensee entered the finding into their corrective action program as Condition
Report 33357.
The inspectors determined that the failure to ensure that plant conditions could support
establishing the clearance order boundaries, which resulted in a component cooling
water heatup and trip of the inservice control room air conditioner, was a performance
deficiency. The inspectors determined that this finding was more than minor because it
is associated with the configuration control 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. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening
and Characterization of Findings, the finding was determined to have very low safety
significance because it was confirmed not to result in loss of operability of control room
-3- Enclosure
air conditioning Train B for greater than its technical specification allowed outage time
and it did not result in the loss of the normal service water function for greater than 24
hours. This finding has a crosscutting aspect in the area of human performance
associated with work control because the licensee failed to plan the work activity by
incorporating the impact on the plant H.3(a) (Section 1R04).
Green. The inspectors identified a noncited violation of 10 CFR 50.65(a)(1) with three
examples involving the failure to monitor the performance of stand by nonsafety-related
systems and components that exceeded performance criteria against goals. First, the
inspectors identified that the licensee failed to monitor the turbine-driven main feedwater
pumps against their standby restart function to fill the steam generators in emergency
operating procedures. Failures of the two turbine-driven main feedwater pumps
occurred which could have prevented fulfillment of this function. Second, the inspectors
identified that the licensee failed to evaluate reactor trips caused by the main feedwater
system against the systems plant level monitoring criteria. Third, the inspectors
identified that the licensee failed to monitor the instrument air compressor system
against its emergency operating procedure function to restart and provide compressed
air. Several instrument air compressor trips have occurred in the last 18 months which
could have prevented fulfillment of this function. The licensee entered this issue in the
corrective action program and will develop corrective actions as part of Condition Report
36600.
The failure to establish performance monitoring goals commensurate with the mitigating
safety function specified in the emergency operating procedures and the plant level
criteria is a performance deficiency. The performance deficiency is more than minor, and
therefore a finding, because it impacts equipment performance attribute of the Mitigating
Systems Cornerstone objective to ensure the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences (i.e., core
damage). Using the NRC Inspection Manual Chapter 0609, Attachment 0609.04,
Phase 1 - Initial Screening and Characterization of Findings, the finding screened to a
Phase 2 significance determination because it involved a potential loss of safety function
of the main feedwater system and failure of the instrument air system. A Region IV
senior reactor analyst performed a Phase 2 significance determination and using the
pre-solved worksheet from the Risk Informed Inspection Notebook for the Wolf Creek,
Revision 2.01a; however, the presolved worksheet did not include the simultaneous
failure of multiple components in different systems. Therefore, the senior reactor analyst
performed a bounding Phase 3 significance determination using Appendix M of
Inspection Manual Chapter 0609, Significance Determination Process Using Qualitative
Criteria, Section 4.1.2. The analyst determined that the finding was of very low safety
significance (Green). The bounding change to the core damage frequency was
approximately 8 E-7/year. The relatively low risk worth of the instrument air system at
Wolf Creek helped to mitigate the significance. To evaluate the change to the large early
release frequency (LERF), the analyst used Inspection Manual Chapter 0609,
Appendix H, Containment Integrity Significance Determination Process. The finding
screened as having very low safety significance for LERF because it did not affect the
intersystem loss of coolant accident or steam generator tube rupture categories. The
inspectors determined that the finding had a crosscutting aspect in the area of problem
-4- Enclosure
identification and resolution. Specifically, when Wolf Creek evaluated exceeding the
plant level monitoring criteria for reactor trips, their analysis did not identify that failures
within the main feedwater system were the cause of four of the six reactor trips, and did
not place the affected system function in a(1) monitoring P.1(c) (Section 1R12).
Green. The inspectors identified a noncited violation of 10 CFR 50.65 a(2), involving the
failure to demonstrate that the performance of main control board annunciator power
supplies was effectively controlled through preventive maintenance such that the
annunciators remained capable of performing their intended function. The licensee
entered this issue into the corrective action program and will develop corrective actions
as part of Condition Report 34681.
The failure to properly evaluate the failed main control board annunciator power
supplies, establish performance goals, and monitor their performance is considered a
performance deficiency. This finding is more than minor because it is associated with
the Mitigating Systems Cornerstone attribute of equipment performance and it adversely
affects the cornerstone objective ensuring the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences. Using
the Inspection Manual Chapter 0609, Significance Determination Process, Phase 1
Worksheets, the finding is determined to have very low safety significance since it did
not result in 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, or 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
licensee failed to properly classify, prioritize, and evaluate a condition adverse to quality
P.1(c) (Section 1R12).
Green. The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B,
Criterion III, involving an inadequate calculation supporting vital switchgear room
temperatures with only one vital switchgear cooler operable. The licensee entered this
issue in the corrective action program and will develop corrective actions as part of
Condition Reports 27276, 28252, and 31452.
The inspectors considered the inadequate heat loads and assumptions used in
calculation GK-06-W to be a performance deficiency. The performance deficiency is
more than minor, and therefore a finding, because it impacted 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. Using Inspection Manual Chapter 0609.04, Phase 1 -
Initial Screening and Characterization of Findings, the inspectors screened the finding
to Green because the additional temperatures would not have caused the loss of
functionality of vital switchgear or batteries, and it did not screen as potentially risk
significant due to a seismic, flooding, or severe weather initiating event. No crosscutting
aspects were identified because the supporting documentation was prepared in the late
1990s and was not representative of current licensee performance (Section 1R15).
-5- Enclosure
Green. The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B,
Criterion V, involving the failure to follow plant procedures. Specifically, the licensee
failed to follow procedure and perform an operability determination when a
nonconforming or degraded condition was identified in the Train B emergency diesel
generator fuel oil storage tank, as required by Procedure AP 26C-004, Operability
Determination and Functionality Assessment, Revision 21. The licensee subsequently
performed an operability determination and concluded the fuel oil storage tank was
operable but degraded. The licensee entered this issue in the corrective action program
as Condition Reports 33355 and 34068.
The failure to follow Procedure AP 26C-004, Operability Determination and
Functionality Assessment, Revision 21, when a nonconforming or degraded condition
was identified was a performance deficiency. This performance deficiency was more
than minor because it could become a more significant safety concern if left uncorrected.
Using Inspection Manual Chapter 0609.04, "Phase 1 - Initial Screening and
Characterization of Findings," the inspectors determined that the finding had very low
safety significance (Green) because it did not result in 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, or screen as potentially risk significant due to a
seismic, flooding, or severe weather initiating event. This finding has a crosscutting
aspect in the area of problem identification and resolution associated with the corrective
action program component because the licensee failed to thoroughly evaluate problems,
including evaluating for operability, such that the resolution addressed the cause P.1(c)
(Section 1R15).
Green. The inspectors identified a noncited violation of 10 CFR Part 50 Appendix B,
Criterion III, involving a failure to perform periodic testing to verify that ultimate heat sink
sedimentation remained within design basis limits. The licensee subsequently verified
the ultimate heat sink depth remained acceptable using SONAR. The licensee entered
this issue in the corrective action program as Condition Report 27144.
Wolf Creeks failure to perform periodic testing to verify that ultimate heat sink
sedimentation remained within design basis limits is a performance deficiency. The
issue is more than minor, and therefore a finding, because if left uncorrected the issue
has the potential to become a more significant safety concern. The inspectors
concluded that the issue screened to Green under the significance determination
process using Inspection Manual Chapter 0609.04, Phase 1-Initial Screening and
Characterization of Findings, because the finding was a design deficiency that was later
confirmed not to result in the loss of operability or functionality of the ultimate heat sink.
The inspectors concluded that this findings cause has a crosscutting aspect in the area
of human performance associated with the work control component because Wolf Creek
did not appropriately coordinate work activities by incorporating actions to address the
impact of changes to the work scope or activity on the plant and human performance.
Specifically, when Wolf Creek performed and planned dredging preventive maintenance
on the ultimate heat sink, they did not consider the need to confirm as-found and as-left
sediment depth to verify that their design basis was met H.3(b) (Section 1R19).
-6- Enclosure
Green. The inspectors reviewed a self-revealing noncited violation of Technical Specification 5.4.1.a, Procedures, involving the failure to perform an adequate fill and
vent of the component cooling water system which resulted in voiding of the system.
The licensee entered the finding into their corrective action program and will develop
corrective actions as part of Condition Report 33925.
The inspectors determined that the failure to perform an adequate fill and vent of
component cooling water that resulted in system voiding was a performance deficiency.
The inspectors determined that this finding was more than minor because it is
associated with the human 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. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening
and Characterization of Findings, the finding was determined to have very low safety
significance (Green) because it did not result in 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, or screen as potentially risk significant due to a seismic, flooding,
or severe weather initiating event. This finding has a crosscutting aspect in the area of
problem identification and resolution associated with the corrective action program
because the licensee failed to take appropriate corrective actions from previous voiding
events P.1(d) (Section 1R19).
Green. The inspectors identified a noncited violation of Technical Specification 5.4.1.a,
Procedures, involving the failure to follow Procedure AP 21-001, Conduct of
Operations. Specifically, the licensee failed to enter into technical specification limiting
condition of operation 3.7.5.B.1 for one auxiliary feedwater pump inoperable during
performance of 92-day check valve surveillance tests. Wolf Creek took prompt
corrective action to amend the procedures to include instructions for maintaining the
pumps operable with manual actions. This occurred prior to the next check valve test.
This issue is captured in Condition Report 34469.
The failure to enter technical specification action statements in accordance with
Procedure AP 21-001 was a performance deficiency. The performance deficiency was
more than minor, and therefore a finding, because it impacted with the human
performance attribute of the Mitigating Systems Cornerstone and its objective to ensure
the availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. Using Inspection Manual Chapter 0609.04,
Phase 1 - Initial Screening and Characterization of Findings, the finding was
determined to be of very low safety significance (Green) because the issue did not result
in a loss of operability for a time period greater than the action statement, and did it not
screen as potentially risk significant due to a seismic, flooding, or severe weather
initiating event. The inspectors determined that the finding has a crosscutting aspect in
the area of human performance associated with decision making. Specifically, informally
maintained pre-job briefing sheets were being relied upon to determine technical
specification applicability instead of the licensees decision making process of operator
review on a case by case basis H.1.a. (Section 1R22).
-7- Enclosure
Cornerstone: Occupational Radiation Safety
Green. The inspectors identified a noncited violation of Technical Specification 5.4.1.a,
Procedures, involving the failure to follow procedure requirements related to adding
work to existing radiation work permits. Specifically, welding was performed in a locked
high radiation area on radiation work permit 110039, which did not cover that type of
activity. The licensee placed the finding into the corrective action program as Condition
Report 35522 and acknowledged that the radiation work permit used was inappropriate
for the work completed.
The failure to follow a procedure was a performance deficiency. The finding was more
than minor because it negatively impacted the Occupational Radiation Safety
Cornerstones attribute of program and process, in that the inappropriate use of a
radiation work permit led to workers unplanned and unintended dose. Using Inspection
Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance
Determination Process, the finding was determined to be of very low safety significance
because: (1) it was not associated with ALARA planning or work controls, (2) there was
no overexposure, (3) there was no substantial potential for an overexposure, and (4) the
ability to assess dose was not compromised. This deficiency had a crosscutting aspect
in the area of human performance related to work controls. Specifically, there was
inappropriate coordination and communication of work activities between work groups
H.3.b] (2RS01).
B. Licensee-Identified Violations
Violations of very low safety significance, which were identified by the licensee, have
been reviewed by the inspectors. Corrective actions taken or planned by the licensee
have been entered into the licensees corrective action program. These violations and
condition report numbers are listed in Section 4OA7.
-8- Enclosure
REPORT DETAILS
Summary of Plant Status
Wolf Creek began the inspection period at 100 percent power. On January 6, 2011, Wolf Creek
decreased reactor power to 97 percent to perform testing on the auxiliary feedwater pump Train
A. Wolf Creek resumed operation at 100 percent power the same day. Wolf Creek commenced
an orderly shutdown for a scheduled refueling outage on March 18, 2011. The reactor
shutdown was completed March 19, 2011, and Wolf Creek ended the inspection period in a
refueling outage.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R04 Equipment Alignments (71111.04)
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk significant
systems:
- January 5, 2011, Chemical and volume control system during tagout for vent
valve leakage
- January 20, 2011, Emergency diesel generator A while emergency diesel
generator B was inoperable
- February 3, 2011, Emergency diesel generator fuel oil system
- February 28, 2011, Essential service water Train A after essential service water
Train B was inadvertently isolated
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 inspected accessible portions
of the systems to verify system components and support equipment were aligned
-9- Enclosure
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 samples as
defined in Inspection Procedure 71111.04-05.
a. Findings
.1 Introduction. The inspectors identified a Green noncited violation of 10 CFR Part 50,
Appendix B, Criterion III, for the failure to assure that applicable regulatory requirements
and the design basis were met. Specifically, the licensee failed to ensure that the fuel oil
storage tank fill system minimized turbulence, as required by the Updated Safety
Analysis Report, such that the emergency diesel generators can be refueled while
running uninterrupted.
Description. The Wolf Creek USAR requires, in part, that the addition of fuel oil to the
fuel oil storage tanks be done in a way that minimizes the creation of turbulence such
that the emergency diesel generators can be refueled while running uninterrupted,
consistent with Regulatory Guide 1.137. Turbulence has the potential to stir up
sediment which could cause the overall quality of fuel oil in the storage tank to become
unacceptable and clog engine fuel oil filters.
The NRC examined this issue during plant licensing. NRC question 430.14, as stated in
the USAR, proposed two alternatives for minimizing turbulence:
1. Design a fuel oil storage tank fill system that will minimize turbulence in the tank.
2. Cross connect the fuel oil storage tank of each diesel in a manner that will permit
supply of fuel oil to either engine from either tank. In this manner, one tank could
be filled while the other tank supplies fuel to the operating diesel generator. After
filling the tank, fuel would not be drawn from the tank for a period of time to
permit settling of sediment.
From the period of initial operation to 2001, Wolf Creek utilized the cross-connect lines
to allow for the settling of sediment when filling the diesel storage tanks (alternative 2)
which would not interrupt operation of either engine. Originally, the cross-connect lines
were tested by technical specification surveillance requirement 4.8.1.1.2g.10. Wolf
Creek converted from Westinghouse standard technical specifications to improved
technical specifications in 1999, at which point this surveillance requirement was moved
to the licensee controlled USAR.
After the conversion to improved technical specifications, USAR Section 9.5.4.4 stated,
A verification that the fuel oil transfer pump is capable of transferring fuel oil from each
- 10 - Enclosure
fuel oil storage tank to the day tank of the opposite train via the installed cross-connect
line is performed every 18 months during a refueling outage. However, a series of
performance improvement requests (PIR), were written to address the fact that there
were no operating procedures for cross tying the fuel oil storage tanks. PIR 2001-1104
provided the justification for the deletion of surveillance Procedure STN JE-002,
Emergency Fuel Oil System Crosstie Flow Test, and the applicable portion of USAR
Section 9.5.4.4. PIR 2001-1104 stated the fuel oil storage tank was, in fact, designed to
minimize turbulence during filling operations (alternative 1 of NRC question 430.14).
The inspectors questioned how the licensee was in compliance with Regulatory
Guide 1.137, as endorsed by the USAR, with the deletion of requirements for cross tying
the fuel oil storage tanks when no other physical changes or analyses were performed.
PIR 2001-1104 identified that another plant modified its fuel oil fill lines to minimize
turbulence consistent with Regulatory Guide 1.137; however, Wolf Creek did not adopt
similar changes.
On March 7, 2011, the licensee generated engineering disposition Condition
Report 30468 which stated that Wolf Creek, Does not have a calculation to evaluate the
hydraulic effects of the fuel oil filling the tank. However, the churning and buouyancy
[sic] effects on the sediment of 2 gallons per second falling less than 15 feet into 6,694
gallons (initially) of fuel oil is judged to be minimal. The inspectors determined that the
qualitative statements provided inadequate justification for asserting the design of the fill
system minimizes turbulence. The inspectors further identified USAR Section 9.5.4.2.1
states, System operation provides flow to motivate water toward sump, tank
replenishment provides similar motive force. The inspectors concluded that the fill
system was not designed to minimize turbulence, and the licensees justification that the
design prevented turbulence lacked an adequate technical basis. The licensee initiated
Condition Report 34730 which will restore compliance with the USAR and Regulatory
Guide 1.137.
Analysis. The failure to establish measures to assure that applicable regulatory
requirements and the design basis are met was a performance deficiency. The
performance deficiency was more than minor because it impacted the Mitigating
Systems Cornerstone attribute of design control and affects the associated cornerstone
objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Using Inspection Manual
Chapter 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," the
inspectors determined that the finding had very low safety significance because it did not
result in 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, or screen as potentially
risk significant due to a seismic, flooding, or severe weather initiating event. This finding
has a crosscutting aspect in the area of human performance associated with the
decision making component because the licensee failed to use conservative
assumptions in decision making and adopt a requirement to demonstrate the proposed
action is safe in order to proceed rather than a requirement to demonstrate that it is
unsafe in order to disapprove the action H.1(b).
- 11 - Enclosure
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires,
in part, that measures shall be established to assure that applicable regulatory
requirements and the design basis are correctly translated into specifications, drawings,
procedures, and instructions. Contrary to the above, from 2001 until 2011, the
measures established by the licensee failed to assure that applicable regulatory
requirements and the design basis were correctly translated into specifications,
drawings, procedures, and instructions. Specifically, the licensee failed to ensure the fill
system for the fuel oil storage tanks minimized the creation of turbulence to ensure that
emergency diesels run without interruption, as required by the USAR, consistent with
Regulatory Guide 1.137. Because this violation was of very low safety significance and
was entered into the licensee's corrective action program (Condition Report 34730), this
violation is being treated as a noncited violation, consistent with Section 2.3.2 of the
NRC Enforcement Policy: NCV 05000485/2011002-01, Inadequate Design Control of
the Fuel Oil Storage Tank Fill System.
.2 Introduction. The inspectors reviewed a Green self-revealing noncited violation of
Technical Specification 5.4.1.a involving the failure to properly implement the clearance
order procedure resulting in a failure to provide adequate cooling to inservice safety-
related equipment.
Description. On February 10, 2011, operations personnel isolated Train B essential
service water return to the ultimate heat sink in preparations for motor-operated valve
testing in accordance with clearance order D-EF-B-021. Approximately 10 minutes after
the return line was isolated, operations personnel in the control room noted that the
temperature of some components was unexpectedly increasing. Operations personnel
then determined that all service water cooling to Train B had been lost due to the
isolation of the ultimate heat sink return line and restored cooling water flow. The
licensee initiated Condition Report 33357 to document the error.
Licensee personnel who had planned the work and prepared and authorized the ultimate
heat sink return line isolation failed to consider that the normal service water system
uses the ultimate heat sink return line to return water to the lake during the winter. As a
result, when the return line was isolated, flow through various Train B heat exchangers
was isolated for approximately one hour. Equipment that lost cooling included inservice
Train B mitigation equipment, such as component cooling water, all Train B pump room
coolers, containment air coolers, the vital switchgear air conditioner, and the control
room air conditioner.
Analysis. The inspectors determined that the failure to ensure that plant conditions
could support establishing the clearance order boundaries, which resulted in a
component cooling water heatup and trip of the inservice control room air conditioner,
was a performance deficiency. The inspectors determined that this finding was more
than minor because it is associated with the configuration control 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. Using Inspection Manual Chapter 0609.04, Phase
1 - Initial Screening and Characterization of Findings, the finding was determined to
have very low safety significance because it was confirmed not to result in loss of
- 12 - Enclosure
operability of control room air conditioning Train B for greater than its technical
specification allowed outage time and it did not result in the loss of the normal service
water function for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This finding has a crosscutting aspect in the
area of human performance associated with work control because the licensee failed to
plan the work activity by incorporating the impact on the plant H.3(a).
Enforcement. Technical Specification 5.4.1.a, Procedures, requires that written
procedures be established and implemented covering activities specified in Appendix A,
Typical Procedures for Pressurized Water Reactors, of Regulatory Guide 1.33, Quality
Assurance Program Requirements (Operation), February 1978. Regulatory Guide 1.33,
Appendix A, Section 1, requires, in part, that the licensee control equipment (e.g. locking
and tagging) in accordance with written instructions. Wolf Creek
Procedure AP 21E-001, Clearance Orders, Revision 26, is used for equipment control.
Step 5.11.2 of Procedure AP 21E-001, requires, in part, ensuring that plant conditions
support establishing the clearance order boundaries. Contrary to the above, on
February 10, 2011, the licensee implemented clearance order D-EF-B-021 without
ensuring that plant conditions supported establishing the clearance order boundaries.
Specifically, the clearance order boundary inadvertently isolated cooling water to
inservice safety-related equipment. Because of the very low safety significance of this
finding and because the licensee entered this issue into the corrective action program as
Condition Report 33357, this violation is being treated as a noncited violation in
accordance with Section 2.3.2 of the NRC Enforcement Policy:
NCV 05000482/2011002-02, Inadequate Clearance Order Isolated Cooling to Inservice
Train B Safety-Related Equipment.
.2 Complete Walkdown
a. Inspection Scope
On March 28, 2011, the inspectors performed a complete system alignment inspection of
the spent fuel pool cooling 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 inspected
the system to review mechanical and electrical equipment line ups, 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 Inspection Procedure 71111.04-05.
- 13 - Enclosure
b. Findings
No findings were identified.
1R05 Fire Protection (71111.05)
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 27, 2011, Fire Area A2
- January 27, 2011, Fire Area A4
- February 7, 2011, Fire Area F15
- February 7, 2011, Fire Area F17
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 Inspection Procedure 71111.05-05.
b. Findings
No findings were identified.
- 14 - Enclosure
1R06 Flood Protection Measures (71111.06)
a. Inspection Scope
On February 18, 2011, the inspectors observed essential service water Train B cable
vaults to verify the cables were not submerged. In addition, the inspectors observed the
material condition of the cable supports. The inspectors reviewed the licensees efforts
to maintain the cables in a qualified environment. The inspectors reviewed the
corrective action program to determine if licensee personnel identified and corrected
flooding problems.
These activities constitute completion of one bunker/manhole sample as defined in
Inspection Procedure 71111.06-05.
b. Findings
No findings were identified.
1R07 Heat Sink Performance (71111.07)
a. Inspection Scope
The inspectors reviewed licensee programs, verified performance against industry
standards, and reviewed critical operating parameters and maintenance records for the
component cooling water heat exchangers. The inspectors verified that performance
tests were satisfactorily conducted for heat exchangers/heat sinks and reviewed for
problems or errors; the licensee utilized the periodic maintenance method outlined in
EPRI Report NP 7552, Heat Exchanger Performance Monitoring Guidelines; the
licensee properly utilized biofouling controls; the licensees heat exchanger inspections
adequately assessed the state of cleanliness of their tubes; and the heat exchanger was
correctly categorized under 10 CFR 50.65, Requirements for Monitoring the
Effectiveness of Maintenance at Nuclear Power Plants. Specific documents reviewed
during this inspection are listed in the attachment.
These activities constitute completion of one heat sink inspection sample as defined in
Inspection Procedure 71111.07-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program (71111.11)
a. Inspection Scope
On February 10, 2011, the inspectors observed a crew of licensed operators perform a
shutdown to Mode 5 in the plants simulator to verify that operator performance was
adequate, evaluators were identifying and documenting crew performance problems and
- 15 - Enclosure
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 Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk
significant systems:
- February16, 2011, NF-01, Load shedding and emergency load sequencer
- March 3, 2011, AE-01, Main feedwater pump supply to steam generators
- March 8, 2011, AD-04, Condensate pump discharge to main feed suction
- March 9, 2011, KA-01, Instrument air compressors
- March 21, 2011, RK-01, Main control board annunciators and power supplies
The inspectors reviewed events such as where ineffective equipment maintenance has
resulted in valid or invalid automatic actuations of engineered safeguards systems and
- 16 - Enclosure
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
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.
These activities constitute completion of five quarterly maintenance effectiveness
samples as defined in Inspection Procedure 71111.12-05.
b. Findings
.1 Introduction. The inspectors identified a Green noncited violation of 10 CFR 50.65(a)(1)
with three examples involving the failure to monitor the performance of standby
nonsafety-related systems and components that exceeded performance criteria against
goals. First, the inspectors identified that the licensee failed to monitor the turbine-driven
main feedwater pumps against their standby restart function to fill the steam generators
in emergency operating procedures. Failures of the two turbine-driven main feedwater
pumps occurred which could have prevented fulfillment of this function. Second, the
inspectors identified that the licensee failed to evaluate reactor trips caused by the main
feedwater system against the systems plant level monitoring criteria. Third, the
inspectors identified that the licensee failed to monitor the instrument air compressor
system against its emergency operating procedure function to restart and provide
- 17 - Enclosure
compressed air. Several instrument air compressor trips have occurred in the last 18
months which could have prevented fulfillment of this function.
Description. Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at
Nuclear Power Plants, provides industry guidance for compliance with 10 CFR 50.65,
The Maintenance Rule. This regulatory guide endorses NUMARC 93-01, Industry
Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,
Revision 2, with some exceptions as specified in the regulatory guide. The scope of
10 CFR 50.65 includes nonsafety-related components that are utilized in emergency
operating procedures.
The inspectors reviewed the main feedwater system maintenance rule functions and
scoping. Function AE-01 requires feedwater to the steam generators using only
turbine-driven main feedwater pumps. This function monitors nonsafety equipment
which could cause a plant trip or actuation of safety-related systems, as well as for a
nonsafety-related function which is used in the emergency operating procedures to
provide accident mitigation. Function AE-01 monitored the steam-driven pumps at the
plant level and was in a(2) status. The inspectors identified that the steam-driven main
feed pumps were not monitored for their emergency operating procedure function, per
the AE-01 scoping. The licensee had concluded that the emergency operating
procedure function for the steam-driven main feedwater pumps was not subject to
monitoring under the maintenance rule because it did not perform a significant fraction of
the mitigating function (i.e., it was not risk significant) in accordance with Section 1.1.2 of
Regulatory Guide 1.160. The inspectors reviewed the regulatory guide and determined
that Wolf Creek had improperly applied the guidance. Section 1.1.2 of Regulatory Guide 1.160 requires that all equipment that is explicitly addressed in the emergency operating
procedures be monitored for maintenance effectiveness. Regulatory Guide 1.160
specifies that only equipment that is not explicitly addressed, but the use of which is
implied, may be excluded on the basis of risk. The inspectors concluded that the
exclusion of the turbine-driven main feedwater pumps based on risk consideration was
not appropriate since the pumps are explicitly identified to mitigate an accident in
emergency operating Procedure FR-H1, step 14.
The inspectors performed additional inspection samples of Wolf Creek maintenance rule
functions and identified that additional standby mitigating components explicitly
referenced in the emergency operating procedures were not being monitored for the
following systems:
- Condensate pumps - function AD-04
- Instrument air compressors - function KA-01
- Non-IE electrical - functions PA-01, PB-01, PG-01, PK-01, and SL-01
The inspectors reviewed the equipment history over the past 3 years for these systems
and found that the instrument air compressors had a history of component failures due
to maintenance practices, most notably repetitive lube oil pressures and levels being out
of specification, leading to subsequent failures. The inspectors identified seven
compressor demand failures between November 18, 2008, and March 1, 2011, but no
- 18 - Enclosure
maintenance rule functional failure evaluations were performed. The inspectors
concluded the licensee had failed to appropriately monitor the performance of the
instrument air compressors standby emergency restart function
Regulatory Guide 1.160, Section 1.7.1, Plant Level Cause Determinations, states, in
part, for all structures, systems or components that are being monitored using plant level
performance criteria, a cause determination is required whenever any of these
performance criteria are exceeded in order to determine which structure, system or
component caused the criterion to be exceeded or whether the failure was a repetitive
maintenance preventable functional failure. As part of the cause determination, it would
also be necessary to determine whether the structure, system or component was within
the scope of the maintenance rule and, if so, whether corrective action and monitoring
(tracking, trending, and goal setting) under 10 CFR 50.65(a)(1) should be performed.
Wolf Creek plant level criteria has been in a(1) status for reactor trips since May 13,
2010. Over the past 3-year monitoring period, Wolf Creek has experienced the following
- March 17, 2008, XPB03 13.8kV transformer failure
- April 28, 2009, Main feed regulating valve closure due to fuse failure
- August 19, 2009, Loss of offsite power
- March 2, 2010, Main feed pump A trip due to PN09 bus failure
- March 8, 2010, Main feed pump A trip due to servo malfunction
- October 17, 2010, Main feedwater isolation due to high steam generator .level
oscillations caused by feed regulating bypass valve control
The inspectors identified that four plant trips were related to the main feedwater system.
Furthermore, all of the main feedwater events were maintenance related. The PN09 bus
and servo failures were direct results of maintenance activities and the fuse failure was
caused by a lack of preventive maintenance. However, the licensee evaluation did not
attribute any of the failures to the feedwater system. Since the main feedwater system
and function is a dominant contributor to the plant level monitoring function for reactor
trips it should have also been placed in a(1) and appropriate corrective actions to restore
to a(2) status established. This issue is captured in Condition Report 27144.
Analysis: The failure to establish performance monitoring goals commensurate with the
mitigating safety function specified in the emergency operating procedures and the plant
level criteria is a performance deficiency. The performance deficiency is more than
minor, and therefore a finding, because it impacts equipment performance attribute of
the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable
consequences (i.e., core damage). Using the NRC Inspection Manual Chapter 0609,
Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the
finding screened to a Phase 2 significance determination because it involved a potential
loss of safety function of the main feedwater system and failure of the instrument air
system. A Region IV senior reactor analyst performed a Phase 2 significance
determination and using the pre-solved worksheet from the Risk Informed Inspection
Notebook for the Wolf Creek, Revision 2.01a; however, the pre-solved worksheet did
- 19 - Enclosure
not include the simultaneous failure of multiple components in different systems.
Therefore, the senior reactor analyst performed a bounding Phase 3 significance
determination using Appendix M of Inspection Manual Chapter 0609, Significance
Determination Process Using Qualitative Criteria, Section 4.1.2. The analyst
determined that the finding was of very low safety significance (Green). The bounding
change to the core damage frequency was approximately 8 E-7/year. The dominant
core damage sequences involved a loss of component cooling water, failure of operators
to recover component cooling water, the failure of operators to start a charging pump
and a reactor coolant pump seal loss of coolant accident. The relatively low risk worth of
the instrument air system at Wolf Creek helped to mitigate the significance. To evaluate
the change to the large early release frequency (LERF), the analyst used Inspection
Manual Chapter 0609, Appendix H, Containment Integrity Significance Determination
Process. Wolf Creek has a large dry containment. The finding screened as having very
low safety significance for LERF because it did not affect the intersystem loss of coolant
accident or steam generator tube rupture categories. The inspectors determined that
the finding had a crosscutting aspect in the area of problem identification and resolution.
Specifically, when Wolf Creek evaluated exceeding the plant level monitoring criteria for
reactor trips, their analysis did not identify that failures within the main feedwater system
were the cause of four of the six reactor trips, and did not place the affected system
function in a(1) monitoring P.1(c).
Enforcement: Title 10 CFR 50.65(a)(1) requires, in part, that each holder of an operating
license for a nuclear power plant shall monitor the performance or condition of
structures, systems, or components, against licensee-established goals, in a manner
sufficient to provide reasonable assurance that these structures, systems, and
components, as defined in paragraph (b) of this section, are capable of fulfilling their
intended functions. These goals shall be established commensurate with safety and,
where practical, take into account industry-wide operating experience. The scope of
paragraph (b) includes, in part, nonsafety-related structures, systems, and components
that are used in emergency operating procedures. Title 10 CFR 50.65(a)(2) states in
part, that monitoring as specified in paragraph (a)(1) 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 preventive maintenance such
that the structure, system or component remains capable of performing its intended
function.
Contrary to the above, from January 1, 2008, to March 3, 2011, the licensee did not
establish goals sufficient to provide reasonable assurance that structures, systems, and
components, as defined in paragraph (b) of 10 CFR 50.65, were capable of fulfilling their
intended functions. Specifically, (1) Wolf Creek did not establish appropriate goals to
monitor the performance of the turbine-driven main feedwater system functions under
operating conditions. This function was not fulfilled when failures in the main feedwater
system caused reactor trips on April 28, 2009, March 2 and 8, and October 17, 2010.
(2) Wolf Creek did not establish appropriate goals to monitor the performance of the
turbine-driven main feedwater system standby restart function, as specified in
emergency operating procedures. This function was not fulfilled when the pumps failed
to restart during the recovery from the reactor trips of April 28 and August 19, 2009, and
- 20 - Enclosure
the failures were not evaluated against any goals or criteria. (3) Wolf Creek did not
establish appropriate goals to monitor the performance of the instrument air
compressors standby emergency restart function. Specifically, seven compressor
demand failures occurred on November 18 and December 18, 2008; January 7,
February 6, and May 14, 2009; March 10, 2010; and March 1, 2011. No monitoring
goals were set and no evaluation of these failures was performed, leaving insufficient
basis for the function to remain in 10 CFR 50.65(a)(2) status.
Because this violation is of very low safety significance (Green) and has been entered
into the licensees corrective action program as Condition Report 36600, this violation is
being treated as a noncited violation consistent with Section 2.3.2 of the NRC
Enforcement Policy: NCV 05000482/2011002-03, Failure to Monitor the Performance
of Nonsafety-Related Systems and Components Used in the Plant Emergency
Operating Procedures under 10 CFR 50.65 Programs.
.2 Introduction. The inspectors identified a Green noncited violation of 10 CFR 50.65 a(2),
involving the failure to demonstrate that the performance of main control board
annunciator power supplies was effectively controlled through preventive maintenance
such that the annunciators remained capable of performing their intended function.
Description. The maintenance rule a(2) reliability criteria for function RK-01, to provide
the control room operator a visual and audible plant status condition, is less than two
functional failures per 18 months. A functional failure is defined as an unplanned loss of
more than six percent of the total annunciators. Performance of this function is
monitored by tracking power supply failures since any power supply failure will result in a
loss of more than six percent of the total annunciators. On October 13, 2009, 23 percent
of main control board annunciators were lost due to independent failures of two power
supplies, RK045E1PS2 and RK045E3PS1. Power supply E3PS1 fed 10.7 percent of
the annunciators and power supply E1PS2 fed 12.1 percent of the annunciators. The
two power supplies that failed are physically located in two separate plant annunciator
system cabinets that are about six feet apart and are electrically separated with different
125Vdc power supply sources. Additionally, there are no common loads shared
between the two power supplies.
The licensee classified the loss of the power supplies on October 13, 2009, as a single
functional failure because greater than six percent of main control board annunciators
had been lost and the power supplies had failed at nearly the same time. However, the
licensee found no causal link between their failures. The inspectors concluded the
licensees evaluation lacked a technical basis to consider the failures as a single
functional failure of the RK-01 function, and the failure of power supplies RK045E1PS2
and RK045E3PS1 represented two functional failures of the RK-01 function. As a result
of the inadequate maintenance rule evaluation, the licensee did not recognize that the
plant annunciator system exceeded its maintenance rule a(2) performance criteria.
Because the power supply failures had not been correctly counted, goal setting, and
monitoring were not performed as required by paragraph a(1) of the maintenance rule.
Analysis. The failure to properly evaluate the failed main control board annunciator
power supplies, establish performance goals, and monitor their performance is
- 21 - Enclosure
considered a performance deficiency. This finding is more than minor because it is
associated with the Mitigating Systems Cornerstone attribute of equipment performance
and it adversely affects the cornerstone objective ensuring the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable
consequences. Using the Inspection Manual Chapter 0609, Significance Determination
Process, Phase 1 Worksheets, the finding is determined to have very low safety
significance since it did not result in 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, or 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 licensee failed to properly classify, prioritize, and evaluate a
condition adverse to quality P.1(c).
Enforcement. Title 10 CFR 50.65(a)(1) requires, in part, that the licensee monitor the
performance or condition of structures, systems, or components, against licensee-
established goals, in a manner sufficient to provide reasonable assurance that such
structures, systems, or components are capable of fulfilling their intended functions.
Title 10 CFR 50.65 paragraph (a)(2) states, 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. Contrary to the above,
on December 10, 2009, Wolf Creek failed to demonstrate that performance of the main
control board annunciator power supplies was being effectively controlled through the
performance of appropriate preventive maintenance such that the system remained
capable of performing its intended function and did not establish goals in a manner
sufficient to provide reasonable assurance that the system was capable of fulfilling its
intended functions. Specifically, the licensee did not identify that the main control board
annunciator power supplies had exceeded their functional failure reliability criteria and
did not establish performance monitoring goals for the system. Because the finding is of
very low safety significance and has been entered into the licensees corrective action
program as Condition Report 34681, this violation is being treated as a noncited
violation, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000482/2011002-04, Failure to Follow 10 CFR 50.65 a(2) for Main Control Board
Annunciator Power Supply 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 8 to 13, 2011, Main generator exciter overvoltage
- 22 - Enclosure
- February 14, 2011, Missed surveillance risk assessment- auxiliary feedwater and
emergency core cooling systems swap over response time
- March 1, 2011, Refueling Outage 18 scheduled March 19 to May 7, 2011
- March 22, 2011, Low temperature overpressure protection control power
emergent work
- March 28, 2011, Residual heat removal and spent fuel pool cooling 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 five maintenance risk assessments and
emergent work control inspection samples as defined in Inspection
Procedure 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Evaluations (71111.15)
a. Inspection Scope
The inspectors reviewed the following issues
- January 26, 2010, Essential service water snubbers posttransient walkdown
- March 3, 2010, Vital switchgear rooms temperature
- July 3 and 4, 2010, Residual heat removal snubbers posttransient walkdown
- February 10, 2011, Missing emergency diesel generator fuel oil tank coatings
- 23 - Enclosure
- February 15, 2011, Emergency diesel generator jacket water Smith-Blair
compression coupling failure
- February 25, 2011, Component cooling water B voiding
- March 7, 2011 , Refueling water storage tank boron concentration
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 licensee personnels 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 seven operability evaluations inspection
samples as defined in Inspection Procedure 71111.15-04
b. Findings
.1 Introduction. The inspectors identified a Green noncited violation of 10 CFR Part 50,
Appendix B, Criterion III, involving an inadequate calculation supporting vital switchgear
room temperatures with only one vital switchgear cooler operable.
Description. Wolf Creek is designed with two vital switchgear air conditioning units.
Each air conditioning unit cools one vital 4160V switchgear room, two sets of vital dc
battery rooms, and two sets of vital dc switchgear. On August 3, 2010, Wolf Creek
experienced a trip of the Train A vital switchgear air conditioning unit. Wolf Creek
entered technical requirements manual (formerly USAR, Chapter 16) limiting condition of
operation 3.7.23. Technical requirements manual 3.7.23 allows one vital air conditioning
unit to be out of service for 7 days provided compensatory measures are taken. After
7 days, the technical specifications must be entered. Compensatory measures are
stated in Procedure GK-200 and the inspectors found they were implemented in
accordance with the procedure. The procedure opens all doors between the vital ac and
dc switchgear rooms, places box fans between rooms, and posts continuous fire
watches. The use of one air conditioning unit to cool all switchgear is based on
configuration change package 07905. The inspectors reviewed the heat transfer
calculations supporting change package 07905. The principle calculation is GK-06-W,
- 24 - Enclosure
SGK05A/B Class IE Electrical Equipment Rooms A/C Units, Single Unit Operation
Capability.
Calculation GK-06-W determined that the final rooms temperature with one air
conditioning unit would be 94°F and 100°F for normal operations and 94°F for all rooms
during loss of coolant accident operation. However, USAR 3.11(B).2.3.2 states that the
vital switchgear rooms will not exceed 90°F, and the Wolf Creek technical requirements
manual specifies a maximum temperature limit of 87°F. Calculation GK-06-W
assumption 14 acknowledges that the calculation results contradict the USAR and
provides justification stating that 104°F is acceptable due to design of the equipment
without providing specifics other than stating that battery capacity increases with
temperature. The justification further states that 104°F may only be reached once or
twice over plant life, and is therefore acceptable. No environmental qualification
references are provided.
The inspectors reviewed Calculation GK-06-W and identified several discrepancies.
Several heat loads were missing from the calculation, including normal operating loads
such as pressurizer heater breakers that are always closed, diesel generator output
breaker that is closed for testing, and one running centrifugal charging pump breaker
that is closed for chemical and volume control duties. Loads missing during accident
operations included nearly all 4160V breakers closed by the load sequencer.
Additionally, Calculation GK-06-W assumed an 85°F room temperature for the health
physics area under the 4160V switchgear room. This area is cooled by nonvital air
conditioning units SGK02 and SGK03. These nonvital coolers are not protected under
Procedure AP GK-200 or the maintenance rule risk assessment program. Using such a
temperature effectively made the floor of rooms a plate-type heat exchanger which
removed a significant amount of heat. The inspectors concluded the 85°F room
temperature assumption was nonconservative since the nonvital coolers are not ensured
to be running and are not protected equipment.
Also, the surface area of the ceiling of the 2016 foot elevation rooms used in the
calculation was much less than the architectural drawings showed. The added surface
area increased the heat transmitted to the dc switchgear rooms. The inspectors
repeated the calculation with additional heat loads and found that room temperatures
could be as high as 100°F for the lower ac switchgear rooms and 110°F for the upper dc
switchgear rooms using the heat removal capacity stated in Calculation GK-06-W. The
inspectors identified additional margin in performance tests of an SGK05 unit, and, in
discussion with Wolf Creek engineering, estimated that the cooling coil was capable of
removing an additional 22,000 Btu/hr based on instrumented performance testing of the
cooling coil. The inspectors repeated the calculation with the cooling coils additional
capacity and found to be capable of cooling the rooms to about 97°F and 106°F,
respectively. Given the acceptance criteria at 90°F per the USAR, the inspectors
concluded that the calculations inputs and justification of its results were inadequate.
Wolf Creek initiated three Condition Reports 27276, 28252, and 31452 on this issue and
will address the rooms heat balance prior to the summer 2011.
- 25 - Enclosure
Analysis. The inspectors considered the inadequate heat loads and assumptions used
in calculation GK-06-W to be a performance deficiency. The performance deficiency is
more than minor, and therefore a finding, because it impacted 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. Using Inspection Manual Chapter 0609.04, Phase 1 -
Initial Screening and Characterization of Findings, the inspectors screened the finding
to Green because the additional temperatures would not have caused the loss of
functionality of vital switchgear or batteries, and it did not screen as potentially risk
significant due to a seismic, flooding, or severe weather initiating event. No crosscutting
aspects were identified because the supporting documentation was prepared in the late
1990s and was not representative of current licensee performance.
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, required
that Wolf Creek establish measures to assure that applicable regulatory requirements
and design bases be correctly translated into specifications, and that design control
measures be provided for verifying or checking the adequacy of design such as by the
performance of design reviews, the use of alternate or simplified calculation methods, or
the performance of a suitable testing program. Contrary to the above, on April 22, 1999,
the measures established by the licensee failed to properly verify or check the adequacy
of design through the use of calculation methods. Specifically, Wolf Creek approved
Calculation GK-06-W which failed to adequately verify or check vital switch gear air
conditioning unit design in that the heat balance calculation did not ensure that the
cooling coil could remove sufficient heat from both trains of switchgear to maintain
temperature in accordance with the USAR. Because this issue was determined to be of
very low safety significance (Green) and was entered into the licensees corrective
action program as Condition Reports 27276, 28252, and 31452, this violation is being
treated as a noncited violation in accordance with Section 2.3.2 of the NRC Enforcement
Policy: NCV 05000482/2011002-05, Inadequate Calculation for Vital Switchgear
Cooling.
.2 Introduction. The inspectors identified a Green, noncited violation of 10 CFR Part 50,
Appendix B, Criterion V, involving the failure to follow plant procedures. Specifically, the
licensee failed to follow procedure and perform an operability determination when a
nonconforming or degraded condition was identified in the Train B emergency diesel
generator fuel oil storage tank, as required by Procedure AP 26C-004, Operability
Determination and Functionality Assessment, Revision 21.
Description. On April 10 to 14, 2002, Wolf Creek personnel performed surveillance
requirement STN MT-002, Standby Diesel Fuel Oil Storage Tanks Drain and Clean,
Revision 1, on diesel fuel oil storage tank TJE01B. During the cleaning of the storage
tank, the licensee discovered approximately 40 percent of the protective interior coating
was damaged or missing from the inside tank wall. Regulatory Guide 1.137, as
endorsed by the licensees USAR, requires this coating to protect against corrosion of
the tank.
On April 13, 2002, shortly after discovery of the degraded coating, Wolf Creek personnel
prepared and issued engineering disposition CCP 10153, Missing Coating on TJE01B,
- 26 - Enclosure
Revision 1. The conclusion of CCP 10153, Revision 0, was to replace the coating during
the next outage. This engineering disposition was subsequently revised to allow use of
the tank with the coating missing.
During the week of January 19, 2011, a Wolf Creek engineering standards team
performed a self-assessment and review of engineering disposition CCP 10153. The
licensee determined that the conclusions of CCP 10153, use the fuel oil storage tank
with a missing interior coating was inadequate and generated Condition Report 32348
documenting the degraded condition in the Train B fuel oil storage tank.
Procedure AP 26C-004, Operability Determination and Functionality Assessment,
Revision 21, requires that plant personnel perform an immediate operability
determination when a nonconforming or degraded condition is identified. Specifically,
Section 4.6 states, An immediate determination of technical specification structures,
systems, or components operability is completed after confirming that a degraded or
nonconforming condition exists that could impact the capability of structures, systems, or
components to perform their specified safety function(s). The immediate operability
determination is made without delay and in a controlled manner using the best available
information.
On February 9, 2011, the inspectors questioned the current operability of the Train B fuel
oil storage tank given the determination by the engineering review team that the missing
coating was a degraded or nonconforming condition. However, the licensee had not
performed an operability determination immediately after identifying this degraded or
nonconforming condition, as required by procedure. The licensee subsequently
performed an operability determination and determined the fuel oil storage tank to be
operable, but degraded.
Analysis. The failure to follow Procedure AP 26C-004, Operability Determination and
Functionality Assessment, Revision 21, when a nonconforming or degraded condition
was identified was a performance deficiency. This performance deficiency was more
than minor because it could become a more significant safety concern if left uncorrected.
Using Inspection Manual Chapter 0609.04, "Phase 1 - Initial Screening and
Characterization of Findings," the inspectors determined that the finding had very low
safety significance (Green) because it did not result in 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, or screen as potentially risk significant due to a
seismic, flooding, or severe weather initiating event. This finding has a crosscutting
aspect in the area of problem identification and resolution associated with the corrective
action program component because the licensee failed to thoroughly evaluate problems,
including evaluating for operability, such that the resolution addressed the cause
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,
and Drawings, requires, in part, that activities affecting quality shall be prescribed by
documented instructions, procedures, or drawings, of a type appropriate to the
circumstances and shall be accomplished in accordance with these instructions,
procedures, or drawings. Contrary to this requirement, on January 14, 2011, the
- 27 - Enclosure
licensee failed to accomplish an activity affecting quality in accordance with prescribed
procedures. Specifically, the licensee failed to follow procedure and perform an
immediate operability determination after identifying a degraded or nonconforming
condition, as required by Procedure AP 26C-004, Operability Determination and
Functionality Assessment, Revision 21. The licensee subsequently performed an
operability determination on February 9, 2011, and determined the fuel oil storage tank
to be operable, but degraded. Because this violation was of very low safety significance
and was entered into the licensee's corrective action program as Condition
Reports 33355 and 34068, this violation is being treated as a noncited violation,
consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000485/2011002-
06, Failure to Perform an Operability Determination for Degradation of the Fuel Oil
Storage Tank.
1R19 Postmaintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed the following postmaintenance activities to verify that
procedures and test activities were adequate to ensure system operability and functional
capability:
- October 6, 2004, and August 20, 2010, Ultimate heat sink dredging
- January 7, 2011, Auxiliary feedwater pump A full flow test after discharge check
valve replacement.
- January 24, 2011, Diesel generator A jacket water temperature low after start
- February 23, 2011, Ultrasonic testing of component cooling water Train B after fill
and vent
- March 1, 2011, Service water to essential service water valve diagnostic testing
after packing and electrical maintenance
- March 10, 2011, Diesel fire pump run after jacket water hose replacement
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
- 28 - Enclosure
The inspectors evaluated the activities against the technical specifications, the USAR,
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 six postmaintenance testing inspection samples
as defined in Inspection Procedure 71111.19-05.
b. Findings
.1 Introduction. The inspectors identified a Green noncited violation of 10 CFR Part 50
Appendix B, Criterion III, involving a failure to perform periodic testing to verify that
ultimate heat sink sedimentation remained within design basis limits.
Description. In April 1982, the NRC issued NUREG-0881, Safety Evaluation Report
Related to the Operation of Wolf Creek Generating Station, Unit 1. In Section 2.4.4.4,
Sedimentation in the Ultimate Heat Sink, the NRC approved annual visual inspections
as a means of ensuring that design basis sedimentation limits, and by extension the
safety-related function of the ultimate heat sink, were maintained and verified throughout
the period of licensed plant operation. The NRC staff considered the annual visual
inspection surveillance to be part of Wolf Creeks licensing bases for meeting the
requirements of 10 CFR Part 50, Appendix A, General Design Criterion 44, Cooling
Water. The ultimate heat sink safety design basis is described in USAR
Sections 9.2.5.1.1 and includes:
- Safety Design Basis One - The ultimate heat sink provides a reliable source of
cooling water to dissipate the heat of an accident safely and to achieve and
maintain safe shutdown of one nominal 1,214 MWe unit following a design bases
accident.
- Safety Design Basis Two - The ultimate heat sink supplies emergency makeup
water to the fuel storage pool and component cooling water systems, and is the
backup water supply for the auxiliary feedwater system.
- Safety Design Basis Five - The ultimate heat sink was designed to withstand
postulated site-related events, such as loss of the main cooling lake.
The system functions are met using acceptance criteria for temperature, water level, and
sedimentation level. USAR Section 9.2.5.3.1 states: Dredging of the ultimate heat sink
will be performed whenever necessary to maintain a minimum capacity and adequate
flow to the essential service water pumps, and Section 9.2.5.4 states: The ultimate
heat sink is inspected periodically to determine degree of siltation. NUREG-0881 stated
- 29 - Enclosure
NRC approval was based, in part, on annual measurements to ensure that
sedimentation levels remained within predefined limits to keep the ultimate heat sink
capable of performing its safety-related functions. This ensured the required volume of
water in the ultimate heat sink to meet the input assumption design requirement.
The licensee took annual sediment measurements as required between January 1985,
and September 2002. On August 8, 2003, Wolf Creek developed USAR change 04-027,
which was implemented as Revision 18 to the USAR on March 11, 2005. This revision
removed the annual sediment depth surveillance of the ultimate heat and replaced it with
a periodic dredging preventive maintenance activity to be performed every five years.
The inspectors reviewed the justification for replacing the annual visual surveillance with
the five-year dredging activity. The inspectors concluded the basis for periodicity of
dredging was nonconservative since it relied upon an average sedimentation rate over a
17-year period rather than a maximum sedimentation rate. The inspectors also
reviewed the dredging work orders and data and determined that the dredging activity
did not verify as-found or as-left ultimate heat sink depth to assure conformance to the
ultimate heat sink design. The 5-year frequency was also not carried out between 2004
and 2010, but was extended under an administrative 25 percent grace period. The
inspectors concluded that the 5-year preventive maintenance activity was not adequate
to ensure that a sufficient volume of water would be maintained in the ultimate heat sink
to meet the design basis requirements .The licensee subsequently measured the
ultimate heat sink depth with SONAR on August 13 and 14, 2010, and determined that
the actual sediment depth supported ultimate heat sink operability and conformance with
the USAR design basis requirements.
Analysis. The failure to perform periodic testing to verify that ultimate heat sink
sedimentation remained within design basis limits is a performance deficiency. The
issue is more than minor, and therefore a finding, because if left uncorrected the issue
has the potential to become a more significant safety concern. Using Inspection Manual
Chapter 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," the
inspectors determined that the finding had very low safety significance (Green) because
it did not result in 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, or screen as
potentially risk significant due to a seismic, flooding, or severe weather initiating event.
The inspectors concluded that this findings cause has a crosscutting aspect in the area
of human performance associated with the work control component because Wolf Creek
did not appropriately coordinate work activities by incorporating actions to address the
impact of changes to the work scope or activity on the plant and human performance.
Specifically, when Wolf Creek performed and planned dredging preventive maintenance
on the ultimate heat sink, they did not consider the need to confirm as-found and as-left
sedimentation data, to verify that their design basis was met H.3(b).
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states in
part that, measures shall be established to assure that applicable regulatory
requirements and the design basis are correctly translated into specifications, drawings,
procedures, and instructions. The design control measures shall provide for verifying or
checking the adequacy of design, such as by the performance of design reviews, by the
- 30 - Enclosure
use of alternate or simplified calculation methods, or by the performance of a suitable
testing program. Contrary to the above, from March 11, 2005, until August 27, 2010, the
measures established by the licensee failed to assure that applicable regulatory
requirements and the design basis of the ultimate heat sink were correctly translated into
specifications, drawings, procedures, and instructions through the performance of design
reviews, by the use of alternate or simplified calculation methods, or by the performance
of a suitable testing program. Specifically, Wolf Creek discontinued periodic verification
of sedimentation levels in the ultimate heat sink without verification that the heat sink
design would continue to be met for the effects of sediment accumulation. Because this
finding is of very low safety significance and was entered into the corrective action
program as Condition Report 27144, this violation is being treated as a noncited violation
in accordance with Section 2.3.2 of the NRC Enforcement Policy:
NCV 05000482/2011002-07, Failure to Verify Ultimate Heat Sink Sedimentation Levels
within Design Bases.
.2 Introduction. The inspectors reviewed a Green self-revealing noncited violation of
Technical Specification 5.4.1.a, Procedures, involving the failure to perform an
adequate fill and vent of the component cooling water system which resulted in voiding
of the system.
Description. On February 16, 2011, the licensee isolated and drained pump D of
component cooling water Train B for planned maintenance. The licensee intended to
maintain Train B operable with pump B available. After maintenance, the licensee filled
and vented the isolated portion of Train B. On February 23, 2011, the licensee started
pump D for postmaintenance testing. When pump D started, pump B automatically
started due to sensed low discharge pressure of pump D. In addition, the Train B
component cooling water surge tank inventory reduced approximately 23 cubic feet.
The licensee recognized these indications as symptoms of voiding in the system and
declared Train B inoperable. After extensive flushing and ultrasonic inspections for
voiding, Train B was declared operable on February 25, 2011.
During filling and venting of pump D on February 22, 2011, licensee personnel opened
the suction isolation valve while venting from the pump casing. Since the suction
isolation valve is physically higher than the pump casing, air in the suction piping rose
into the common suction line of pumps B and D of Train B instead of being vented
through the pump casing. Clearance order D-EF-B-010A restoration instructions
required ultrasonic testing of the discharge piping, but did not direct testing on the pump
suction piping. The inspectors concluded that after introducing air into the system during
maintenance, the licensee performed an inadequate fill and vent by failing to vent from
the high point of the system. The inspectors also concluded the clearance order
restoration instructions were inadequate in that they failed to require ultrasonic testing of
the high point of the system. The inspectors determined the introduction of air to the
suction side of both component cooling water Train B pumps reduced the reliability of
the system; however, the system continued to be able to perform its safety function.
The inspectors determined the cause of the inadequate clearance restoration order was
a mistaken belief that any air on the suction side of the pumps would self-vent back to
the surge tank. This misconception was one of the root causes for previous component
- 31 - Enclosure
cooling water voiding events documented in NRC Inspection Report 05000482/2010008.
Therefore, the inspectors concluded that corrective actions from previous component
cooling water voiding events had not been fully effective.
Analysis. The inspectors determined that the failure to perform an adequate fill and
vent of component cooling water that resulted in system voiding was a performance
deficiency. The inspectors determined that this finding was more than minor because it
is associated with the human 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. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening
and Characterization of Findings, the finding was determined to have very low safety
significance (Green) because it did not result in 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, or screen as potentially risk significant due to a seismic, flooding,
or severe weather initiating event. This finding has a crosscutting aspect in the area of
problem identification and resolution associated with the corrective action program
because the licensee failed to take appropriate corrective actions from previous voiding
events P.1(d).
Enforcement. Technical Specification 5.4.1.a, Procedures, requires that written
procedures be established and implemented covering activities specified in Appendix A
of Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation),
February 1978. Regulatory Guide 1.33, Appendix A, Section 9, requires, in part, that
maintenance that can affect the performance of safety-related equipment be performed
in accordance with written instructions appropriate to the circumstances. Contrary to the
above, on February 22, 2011, the license failed to perform maintenance that affected the
performance of safety-related equipment with written instructions appropriate to the
circumstances. Specifically, clearance order D-EF-B-010A restoration instructions were
not appropriate to the circumstances in that the instructions resulted in inadequate filling
and venting resulting in gas introduction to the system. Because of the very low safety
significance of this finding and because the licensee entered this issue into the
corrective action program as Condition Report 33925, this violation is being treated as a
noncited violation in accordance with Section 2.3.2.a of the NRC Enforcement Policy:
NCV 05000482/2011002-08, Inadequate Fill and Vent of Component Cooling Water.
1R20 Refueling and Other Outage Activities (71111.20)
a. Inspection Scope
The inspectors reviewed the outage safety plan and contingency plans for the refueling
outage, starting on March 19, 2011, to confirm that licensee personnel had appropriately
considered risk, industry experience, and previous site-specific problems in developing
and implementing a plan that assured maintenance of defense in depth. During the
refueling outage, the inspectors observed portions of the shutdown and cooldown
processes and monitored licensee controls over the outage activities listed below.
- 32 - Enclosure
- Configuration management, including maintenance of defense in depth, is
commensurate with the outage safety plan for key safety functions and
compliance with the applicable technical specifications when taking equipment
out of service.
- Clearance activities, including confirmation that tags were properly hung and
equipment appropriately configured to safely support the work or testing.
- Status and configuration of electrical systems to ensure that technical
specifications and outage safety-plan requirements were met, and controls over
switchyard activities.
- Monitoring of decay heat removal processes, systems, and components.
- Verification that outage work was not impacting the ability of the operators to
operate the spent fuel pool cooling system.
- Reactor water inventory controls, including flow paths, configurations, and
alternative means for inventory addition, and controls to prevent inventory loss.
- Controls over activities that could affect reactivity.
- Licensee identification and resolution of problems related to refueling outage
activities.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one refueling outage and other outage
inspection sample as defined in Inspection Procedure 71111.20-05.
b. Findings
Introduction. The inspectors reviewed a self-revealing Green noncited violation of
Technical Specification 5.4.1.a, Procedures, involving the failure to follow the
requirements of Procedure AP 21E-001, Clearance Orders. This procedure violation
resulted in an inadequate tagout for the Train A solid state protection system resulting in
an unplanned swap of the volume control tank charging pump suction to the reactor
water storage tank and an unplanned entry into Technical Specification 3.4.12 due to the
de-energization of power operated relief valve A low temperature overpressure
protection relays.
Description. On March 22, 2011, control room operators received an annunciator alarm
indicating realignment of the charging pump suction from the volume control tank to the
reactor water storage tank. The volume control tank level increased from 95 to
100 percent and tank pressure increased from 18 to 40 psi. Control room operators
re-aligned the volume control tank suction back to the charging flow path, and the
volume control tank level and pressure returned to their normal operating levels.
- 33 - Enclosure
The licensee subsequently determined that a clearance order had de-energized the
Train A solid state protection system, de-energizing both the Train A reactor water
storage tank swap over and power operated relief valve low temperature overpressure
protection relays. The Train A reactor water storage tank swap over required manual
operator action to address the increase in volume control tank level and the de-
energization of the power operated relief valve low temperature overpressure protection
relay placed the plant in Technical Specification 3.4.12, Condition F, which has a
requirement to restore the power operated relief valve to operable status within 24
hours. The low temperature overpressure protection system controls reactor coolant
system pressure at low temperatures so the integrity of the reactor coolant pressure
boundary is not compromised. Upon recognizing that the inadequate clearance order
was the cause of the reactor water storage tank swap over and de-energization of the
power operated relief valve, operators removed the clearance order and restored all
equipment to its normal operating condition approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after receiving the
initial control room alarm.
Clearance order R-SB-A-004 was generated in preparation for a vendor to perform logic
testing of the Train A solid state protection system circuit boards consistent with industry
operating experience. The clearance order worksheet contained very limited details
describing the vendors work scope. The clearance order instructions, provided only a
few days prior to the scheduled start date, simply requested to de-energize the Train A
solid state protection system cabinet. No licensee personnel were completely cognizant
of the vendors planned scope of work. The licensee recognized that there are
numerous power sources supplying the solid state protection system cabinets, and
decided to expand the clearance order scope to include the instrument ac power,
125Vdc power, and reactor protection breakers that supply the Train A solid state
protection system cabinet. The reactor water storage tank swap over and de-
energization of the power operated relief valve was caused by a failure to recognize that
opening instrument ac power breaker NN00112 would de-energize the Train A solid
state protection system slave relay power supply.
Analysis. The failure to follow procedures to complete clearance orders with adequate
boundaries is a performance deficiency. The performance deficiency was more than
minor because it impacted the Initiating Events Cornerstone objective of configuration
control to limit the likelihood of those events that upset plant stability and challenge
critical safety functions during shutdown as well as power operations. The significance
of the finding was determined using Inspection Manual Chapter 0609, Significance
Determination Process, Appendix G, Checklist 2, and determined to be of very low
safety significance, because it did not cause the loss of mitigating capability of core heat
removal, inventory control, power availability, containment control, or reactivity control.
Additionally, the cause of the finding is related to the human performance crosscutting
component of work control. Specifically, the licensee did not appropriately plan for the
maintenance work scope by ensuring work groups and an offsite organization
communicate the necessary electrical boundaries to assure plant and human
performance H.3(b).
Enforcement. Technical Specification 5.4.1.a, Procedures, requires, in part, that
written procedures shall be established, implemented and maintained for the activities
- 34 - Enclosure
recommended in Regulatory Guide 1.33, Quality Assurance Program Requirements
(Operation), Revision 2, Appendix A, February 1978. Section 1.c of Regulatory Guide
1.33, Revision 2, Appendix A, recommends procedures for equipment control (e.g.,
locking and tagging). Wolf Creek Procedure AP 21E-001, Clearance Orders, Revision
27, step 5.7.1, requires the licensee to develop clearance order instructions, based on
the work scope, so adequate tagging boundaries can be developed. Contrary to this
requirement, on March 19, 2011, the licensee failed to provide clearance order
instructions, based on the work scope, so adequate tagging boundaries could be
developed in the tagout boundary for clearance order R-SB-A-004. Because the finding
is of very low safety significance and has been entered into the licensees corrective
action program as Condition Report 35318, this violation is being treated as a noncited
violation consistent with Section 2.3.2 of the NRC Enforcement Policy:
NCV 05000482/2011002-09, Inadequate Clearance Order Disables Power Operated
Relief Valve Low temperature Overpressure Protection Train.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors reviewed the USAR, procedure requirements, and technical
specifications to ensure that the 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
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- 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.
- December 6, 2010, 25 year containment tendon surveillance
- December 16, 2010, Turbine-Driven auxiliary feedwater pump inservice test
- January 10, 2011, Incore-Excore axial flux difference comparison
- January 10, 2011, Heat flux hot channel factor
- January 24, 2011, KJ-005A Jacket water temperature control valve
- February 15, 2011, Over-Temperature Delta-Temperature and Over-Power Delta-
Temperature trip setpoint
- February 18, 2011, Diesel generator fuel oil storage tank cloud point
- February 28, 2011, Safety injection pump A inservice test
- March 7, 2011, Turbine-Drivine auxiliary feedwater check valve inservice test
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of nine surveillance testing inspection samples as
defined in Inspection Procedure 71111.22-05.
b. Findings
Introduction. The inspectors identified a Green noncited violation of Technical
Specification 5.4.1.a, Procedures, involving the failure to follow Procedure AP 21-001,
Conduct of Operations. Specifically, the licensee failed to enter into technical
specification limiting condition of operation 3.7.5.B.1 for one auxiliary feedwater pump
inoperable during performance of 92-day check valve surveillance tests.
Description. On March 7, 2011, the inspectors identified that technical
specification 3.7.5 limiting condition of operation action statement B.1 was not logged
- 36 - Enclosure
during turbine-driven auxiliary feedwater check valve testing. The check valve testing
involved opening one-inch drain lines on the upstream and downstream sides of the
suction check valves. A torque wrench is then applied to the valve disc pin, and the
valve is checked for the correct opening torque. During this time, the open drain lines
create the potential to divert suction flow from the pump. This condition affected suction
check valves from the condensate storage tank or the essential service water pumps.
The inspectors concluded this condition impacted the operability of the auxiliary
feedwater pumps since the open drain lines could result in water spray in the room,
additional flooding volume, a decrease in pump net positive suction head, lost
condensate storage tank inventory and lost ultimate heat sink inventory.
Wolf Creek initiated Condition Report 34469 to evaluate the condition. Wolf Creek
concluded that the auxiliary feedwater pumps were inoperable during each of their
respective check valve testing procedures. Wolf Creek changed all the auxiliary
feedwater check valve testing procedures to add steps to declare the pump inoperable
or take appropriate manual actions to ensure operability. The added steps provide the
option of entering the action statement or posting a nonlicensed operator with
continuous communications to the control room to shut the vent valves, if needed. The
inspectors determined that Wolf Creek had failed to recognize that Technical Specification 3.7.5.B.1 applied and did not log entry into the action statement for
Procedure STS AL-210C (turbine-driven pump) on March 12, June 10, July 29, and
December 10, 2010, and March 6, 2011; for Procedure STS AL-210A (Train A pump) on
June 1, August 31, November 27, 2010, and March 4, 2011; and Procedure STS AL-
210B (Train B pump) on June 16, August 17, September 16, and December 15, 2010.
Procedure AP 21-001, Conduct of Operations, required the licensee to review each
evolution for technical specification applicability per step 6.8.4. The inspectors
interviewed licensee personnel on procedures that do not direct entry into technical
specification action statements and determined the licensee relied on informally
maintained pre-job briefing sheets to meet this requirement. The inspectors reviewed
the pre-job briefing sheets for the suction check valve testing and concluded that the
sheets contained good guidance on error traps, expected equipment responses, internal
operating experience and acceptance criteria, but did not contain instructions on manual
actions to maintain operability or instructions to enter technical specification action
statements sufficient to address technical specification applicability.
Analysis. The failure to enter technical specification action statements in accordance
with Procedure AP 21-001 was a performance deficiency. The performance deficiency
was more than minor, and therefore a finding, because it impacted with the human
performance attribute of the Mitigating Systems Cornerstone and its objective to ensure
the availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. Using Inspection Manual Chapter 0609.04, Phase
1 - Initial Screening and Characterization of Findings, the finding was determined to be
of very low safety significance (Green) because the issue did not result in a loss of
operability for a time period greater than the action statement, and did it not screen as
potentially risk significant due to a seismic, flooding, or severe weather initiating event.
The inspectors determined that the finding has a crosscutting aspect in the area of
human performance associated with decision making. Specifically, informally
- 37 - Enclosure
maintained pre-job briefing sheets were being relied upon to determine technical
specification applicability instead of the licensees decision making process of operator
review on a case by case basis H.1.a..
Enforcement. Technical Specification 5.4.1.a, Procedures, requires that written
procedures be established, implemented, and maintained covering activities related to
procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, 1978.
Regulatory Guide 1.33, Section 1(h), Administrative Procedures, requires log entries.
Procedure AP 21-001, Conduct of Operations, Revision 50, step 6.8.4, requires, in
part, plant log entries of technical specification action statements and that operations
shall review technical specification requirements for each evolution. Contrary to the
above, on March 7 and 12, June 1, 10, and 16, July 29, August 17 and 31,
September 16, November 27, and December 10 and 15, 2010, and March 4, 2011, Wolf
Creek failed to review technical specification requirements and log technical
specification action statement 3.7.5.B.1 when any of the three auxiliary feedwater pumps
were out of service for check valve testing which rendered the pumps inoperable.
Because this issue was determined to be of very low safety significance (Green) and
was entered into the licensees corrective action program as Condition Report 34469,
this violation is being treated as a noncited violation in accordance with Section 2.3.2 of
the NRC Enforcement Policy: NCV 05000482/2011002-10, Repetitive Failure to Enter
Technical Specifications for Auxiliary Feedwater Suction Valve 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 the Wolf Creek Emergency Plan;
Document APF 06-002-01, Emergency Action Levels, Revision 15. This revision
changed the bases 1-RER5 of EAL-1, Radioactive Effluent Release, for
Radiation Monitor 0-SD-RE-41 from 23,500 millirem per hour (the times 1000 value) to
10,000 millirem per hour (the upper detection limit of the monitor). Also,
Procedure OFN RP-014, Hot Standby to Cold Shutdown from Outside the Control
Room, was deleted from bases 9-LPC/SC5 of EAL-9, Loss of Plant Control/Security
Compromise, since this procedure can only be entered through other procedures
already listed.
This revision was compared to its previous revision, to the criteria of NUREG-0654,
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants, Revision 1, 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 the SER and did not constitute
approval of licensee-generated changes; therefore, this revision is subject to future
inspection.
These activities constitute completion of one sample as defined in Inspection
Procedure 71114.04-05.
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b. Findings
No findings were identified.
1EP6 Drill Evaluation (71114.06)
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine licensee emergency drill on
January 11, 2011, to identify any weaknesses and deficiencies in classification,
notification, and protective action recommendation development activities. The
inspectors observed emergency response operations in the turbine failure and resulting
Alert 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 Inspection
Procedure 71114.06-05.
b. Findings
No findings were identified.
2. RADIATION SAFETY
Cornerstones: Occupational and Public Radiation Safety
2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01)
a. Inspection Scope
This area was inspected to: (1) review and assess licensees performance in assessing
the radiological hazards in the workplace associated with licensed activities and the
implementation of appropriate radiation monitoring and exposure control measures for
both individual and collective exposures, (2) verify the licensee is properly identifying
and reporting Occupational Radiation Safety Cornerstone performance indicators, and
(3) identify those performance deficiencies that were reportable as a performance
indicator and which may have represented a substantial potential for overexposure of
the worker.
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The inspectors used the requirements in 10 CFR Part 20, the technical specifications,
and the licensees procedures required by technical specifications as criteria for
determining compliance. During the inspection, the inspectors interviewed the radiation
protection manager, radiation protection supervisors, and radiation workers. The
inspectors performed walkdowns of various portions of the plant, performed independent
radiation dose rate measurements and reviewed the following items:
- Performance indicator events and associated documentation reported by the
licensee in the Occupational Radiation Safety Cornerstone
- The hazard assessment program, including a review of the licensees evaluations
of changes in plant operations and radiological surveys to detect dose rates,
airborne radioactivity, and surface contamination levels
- Instructions and notices to workers, including labeling or marking containers of
radioactive material, radiation work permits, actions for electronic dosimeter
alarms, and changes to radiological conditions
- Programs and processes for control of sealed sources and release of potentially
contaminated material from the radiologically controlled area, including survey
performance, instrument sensitivity, release criteria, procedural guidance, and
sealed source accountability
- Radiological hazards control and work coverage, including the adequacy of
surveys, radiation protection job coverage, and contamination controls; the use of
electronic dosimeters in high noise areas; dosimetry placement; airborne
radioactivity monitoring; controls for highly activated or contaminated materials
(nonfuel) stored within spent fuel and other storage pools; and posting and
physical controls for high radiation areas and very high radiation areas
- Radiation worker and radiation protection technician performance with respect to
radiation protection work requirements
- Audits, self-assessments, and corrective action documents related to radiological
hazard assessment and exposure controls since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one required sample as defined in Inspection
Procedure 71124.01-05.
b. Findings
Introduction. Inspectors identified a Green noncited violation of Technical
Specification 5.4.1.a, Procedures, involving the failure to follow procedure
requirements for increased work scope on an existing radiation work permit.
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Specifically, welding was performed in a locked high radiation area on a radiation work
permit that did not cover that type of activity.
Description. On January 4, 2011, work was performed under maintenance work
order 11-336634-000 in a locked high radiation area on the 1988 elevation of the
auxiliary building. The radiological aspects of the work were covered using radiation
work permit 110039. The radiation work permit stated that this permit was not intended
to be used for major contamination breaches. During the work, welders cut into and
welded a contaminated pipe. This type of activity was not covered by the radiation work
permit.
Wolf Creek Procedure RPP 02-105, RWP, states that if the exposure estimate to
complete the work is greater than 100 mrem it is appropriate to consider creating a new
radiation work permit. As described in the licensee identified violation in Section 4OA7
of this report, the licensee performed an inadequate hazard assessment of the work by
performing a dose estimate for the job using the incorrect location and by
underestimating the number of workers who would be required for the work. Due to the
inadequate hazard assessment, the dose estimate did not reach the 100 mrem
threshold. This caused a missed opportunity to recognize the potential benefits of
creating a separate radiation work permit or revising radiation work permit 110039 for
this work activity.
Instead, the licensee removed a special instruction specifying that grinding and welding
activities were not allowed on radiation work permit 110039. In addition, health physics
staff changed the alarm settings on the workers electronic dosimeters to support the
new work scope. This change was contrary to Procedure RPP 02-105 which states that
health physics may assign work to an existing radiation work permit when it:
- Appropriately covers the type of work
- Has proper stop points
- Meets the radiation work permit risk assessment
- Meets the respiratory protection evaluation
- Meets the additional dosimetry worksheet
- Will not change the exposure goal or estimate.
The licensee did not evaluate that the above conditions were met before using radiation
work permit 110039 for the increased work scope. The change in work scope resulted in
the exposure estimate being increased from 90 mrem to 300 mrem. The licensee
placed the finding into the corrective action program as Condition Report 00035522 and
acknowledged that the radiation work permit used was inappropriate for the work
completed.
Analysis. The failure to follow a procedure was a performance deficiency. The finding
was more than minor because it negatively impacted the Occupational Radiation Safety
Cornerstones attribute of program and process, in that the use of an inadequate
radiation work permit led to workers unplanned, unintended dose. Using Inspection
Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance
Determination Process, the finding was determined to be of very low safety significance
- 41 - Enclosure
because: (1) it was not associated with as low as is reasonably achievable (ALARA)
planning or work controls, (2) there was no overexposure, (3) there was no substantial
potential for an overexposure, and (4) the ability to assess dose was not compromised.
In addition, this finding has a crosscutting aspect in the area of Human Performance
related to work controls. Specifically, there was inappropriate coordination and
communication of work activities between work groups H.3.b].
Enforcement. Technical Specification 5.4.1.a requires that procedures be established,
implemented and maintained as recommended in Regulatory Guide 1.33, Quality
Assurance Program Requirements (Operation), Revision 2, February 1978, Appendix A.
Section 7.e of Appendix A covers exposure controls, including a radiation work permit
system. Wolf Creek Procedure RPP 02-105 RWP, Section 9.2, Assigning work to an
existing radiation work permit number, states in part, that Health Physics may assign
work to an existing radiation work permit number when: the radiation work permit
appropriately covers this type of work and the work will not change the current radiation
work permit exposure goal or estimate. Contrary to the above, on January 4, 2011,
Wolf Creek inappropriately allowed maintenance work to be performed under radiation
work permit 110039 that did not appropriately cover the type of work and significantly
changed the exposure estimate. Specifically, the maintenance work order included
cutting into a contaminated system, which contradicted the radiation work permit
statement that it was not meant for major contamination breaches. Also, the added work
did change the radiation work permit exposure goal, in that it increased the exposure
estimate to 300 mrem from the original estimate of 90 mrem. Since this violation was of
very low safety significance and was documented in the licensees corrective action
program as Condition Report 35522, it is being treated as a noncited violation,
consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000482/2011002-
11, Failure to Follow Radiation Work Permit Instructions.
2RS02 Occupational ALARA Planning and Controls (71124.02)
a. Inspection Scope
This area was inspected to assess performance with respect to maintaining occupational
individual and collective radiation exposures ALARA. The inspectors used the
requirements in 10 CFR Part 20, the technical specifications, and the licensees
procedures required by technical specifications as criteria for determining compliance.
During the inspection, the inspectors interviewed licensee personnel and reviewed the
following items:
- Site-specific ALARA procedures and collective exposure history, including the
current 3-year rolling average, site-specific trends in collective exposures, and
source-term measurements
- ALARA work activity evaluations/postjob reviews, exposure estimates, and
exposure mitigation requirements
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- The methodology for estimating work activity exposures, the intended dose
outcome, the accuracy of dose rate and man-hour estimates, and intended
versus actual work activity doses and the reasons for any inconsistencies
- Records detailing the historical trends and current status of tracked plant source
terms and contingency plans for expected changes in the source term due to
changes in plant fuel performance issues or changes in plant primary chemistry
- Radiation worker and radiation protection technician performance during work
activities in radiation areas, airborne radioactivity areas, or high radiation areas
- Audits, self-assessments, and corrective action documents related to ALARA
planning and controls since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one required sample as defined in Inspection
Procedure 71124.02-05.
b. Findings
No findings were identified.
2RS03 In-plant Airborne Radioactivity Control and Mitigation (71124.03)
a. Inspection Scope
This area was inspected to verify in-plant airborne concentrations are being controlled
consistent with ALARA principles and the use of respiratory protection devices onsite
does not pose an undue risk to the wearer. The inspectors used the requirements in
10 CFR Part 20, the technical specifications, and the licensees procedures required by
technical specifications as criteria for determining compliance. During the inspection,
the inspectors interviewed licensee personnel, performed walkdowns of various portions
of the plant, and reviewed the following items:
- The licensees use, when applicable, of ventilation systems as part of its
engineering controls
- The licensees respiratory protection program for use, storage, maintenance, and
quality assurance of NIOSH certified equipment, qualification and training of
personnel, and user performance
- The licensees capability for refilling and transporting SCBA air bottles to and
from the control room and operations support center during emergency
conditions, status of SCBA staged and ready for use in the plant and associated
surveillance records, and personnel qualification and training
- 43 - Enclosure
- Audits, self-assessments, and corrective action documents related to in-plant
airborne radioactivity control and mitigation since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one sample as defined in Inspection
Procedure 71124.03-05.
b. Findings
No findings were identified.
4. OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
4OA1 Performance Indicator Verification (71151)
.1 Data Submission Issue
a. Inspection Scope
The inspectors performed a review of the performance indicator data submitted by the
licensee for the 4th Quarter 2010 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 were identified.
.2 Unplanned Scrams per 7000 Critical Hours (IE01)
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 2010 through the
fourth quarter 2010. To determine the accuracy of the performance indicator data
reported during those periods, the inspectors used definitions and guidance contained in
NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
Revision 6. The inspectors reviewed the licensees operator narrative logs, issue
reports, event reports, and NRC integrated inspection reports for the period of January
1, 2010, through December 31, 2010, to validate the accuracy of the submittals. The
- 44 - Enclosure
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 one unplanned scrams per 7000 critical hours
sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.3 Unplanned Scrams with Complications (IE04)
a. Inspection Scope
The inspectors sampled licensee submittals for the unplanned scrams with
complications performance indicator for the period from the first quarter 2010 through
the fourth quarter 2010. To determine the accuracy of the performance indicator data
reported during those periods, the inspectors used definitions and guidance contained in
NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
Revision 6. The inspectors reviewed the licensees operator narrative logs, issue
reports, event reports, and NRC integrated inspection reports for the period of January
1, 2010, through December 31, 2010, 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 one unplanned scrams with complications
sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.4 Unplanned Power Changes per 7000 Critical Hours (IE03)
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 2010 through the
fourth quarter 2010. To determine the accuracy of the performance indicator data
reported during those periods, the inspectors used definitions and guidance contained in
NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
Revision 6. 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, 2010, through December 31, 2010, to validate the accuracy
- 45 - Enclosure
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 one unplanned transients per 7000 critical
hours sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.5 Occupational Exposure Control Effectiveness (OR01)
a. Inspection Scope
The inspectors reviewed performance indicator data for the fourth quarter 2010 through
the first quarter 2011. The objective of the inspection was to determine the accuracy and
completeness of the performance indicator data reported during these periods. The
inspectors used the definitions and clarifying notes contained in NEI Document 99-02,
Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for
determining whether the licensee was in compliance.
The inspectors reviewed corrective action program records associated with high
radiation area and very high radiation area nonconformances. The inspectors reviewed
radiological controlled area exit transactions greater than 100 mrem. The inspectors
also conducted walkdowns of high radiation areas and very high radiation area
entrances to determine the adequacy of the controls of these areas.
These activities constitute completion of the occupational exposure control effectiveness
sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
Radiological Effluent Occurrences (PR01)
a. Inspection Scope
The inspectors reviewed performance indicator data for the fourth quarter 2010 through
the first quarter 2011. The objective of the inspection was to determine the accuracy and
completeness of the performance indicator data reported during these periods. The
inspectors used the definitions and clarifying notes contained in NEI Document 99-02,
Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for
determining whether the licensee was in compliance.
- 46 - Enclosure
The inspectors reviewed the licensees corrective action program records and selected
individual annual or special reports to identify potential occurrences such as
unmonitored, uncontrolled, or improperly calculated effluent releases that may have
impacted offsite dose.
These activities constitute completion of the radiological effluent technical
specifications/offsite dose calculation manual radiological effluent occurrences sample
as defined in Inspection Procedure 71151-05.
b. Findings
No findings 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
.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.
b. Findings
No findings were identified.
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.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 follow up, 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 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 selected a corrective action item documenting the missed risk assessment of
the extended motor-driven main feedwater pump maintenance from November 5 to 18,
2010, for detailed followup.
These activities constitute completion of one in-depth problem identification and
resolution sample as defined in Inspection Procedure 71152-05.
b. Findings and Observations
No findings were identified. The licensees evaluation identified that Wolf Creek failed to
follow its procedure for turnover of maintenance that takes longer than scheduled. The
inspectors observed that the evaluation missed an opportunity to re-assess the risk
significance of the three main feedwater pumps to be consistent with the scrams and
scrams with complications root cause evaluations, which identified that Wolf Creek was
not maintaining the main feedwater system, in part, because the system was incorrectly
regarded as a low risk significance system. Elevating the risk significance would aid
Wolf Creek in assessing the risk associated with working on more than one main
feedwater pump at the same time. Wolf Creek initiated Condition Report 30245 to
evaluate this observation.
4OA3 Event Follow-up (71153)
.1 (Closed) LER 2009-007-00, Removal of Equipment from Service Required by Technical
Specifications and NRC Safety Evaluation - RETRACTED
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This event was reviewed by Region IV and Headquarters staff and determined not to be
reportable. Reference enforcement action EA-09-326 under ADAMS accession number
ML100630900 for further information. This licensee event report (LER) is closed.
.2 (Closed) LER 2009-008-00, Potential of Containment Coolers to Have not Automatically
Started in Slow Speed - RETRACTED.
The licensee received operating experience that indicated that thermal overloads for
containment fan coolers were set too low for fan operation in a postaccident
environment. There was insufficient evidence to show that the containment coolers
could accomplish their safety function, so the licensee reported the condition on
January 11, 2010. Subsequent to the report, the licensee evaluated the thermal
overload settings and determined that the settings were adequate. Therefore, the
licensee retracted the report on March 30, 2010. The inspectors reviewed the basis for
the retraction. No violations were identified during the inspectors review. This LER is
closed.
.3 (Closed) LER 2009-009-00; -01, Defeating Feedwater Isolation on Low Tavg Coincident
with P-4 Function Results in Missed Mode Change
On October 22, 2009, the inspectors identified a failure to report a condition prohibited
by technical specification for defeating both trains of the P-4 interlock. LER 2009-009-00
reported this condition per 50.73(a)(2)(i)(B), but the licensee did not report the event
under reporting criteria 50.73(a)(2)(v) as a safety system functional failure. The NRC
documented this failure as a Severity Level IV noncited violation,
NCV 05000482/2009005-15, Failure to Report a Condition that Could Have Prevented
Fulfillment of a Safety Function. Subsequently, Wolf Creek submitted LER 2009-009-01
which correctly reported the issue under 50.73(a)(2)(v). No additional violations were
identified during the inspectors review. These LERs are closed.
.4 (Closed) LER 2009-010-00; -01, Failure to Meet Limiting Condition for Operation 3.0.4b
During Transition from Mode 4 to Mode 3
On November 17, 2009, heat up activities were in progress to return the plant to service
following a refueling outage with the plant ready to transition from Mode 4 to Mode 3 with
the exception of completing some work activities and postmaintenance testing to restore
the turbine-driven auxiliary feedwater pump to a functional status. A risk assessment
was completed as required by limiting condition for operation 3.0.4b and required that
protected train signs be posted on the motor driven auxiliary feedwater pump rooms. On
November 18, 2009, at 12:24 a.m., the plant transitioned from Mode 4 to Mode 3 under
the provisions of limiting condition for operation 3.0.4b for the turbine-driven auxiliary
feedwater pump with no protected equipment signs posted for the motor-driven auxiliary
feedwater pump rooms. The inspectors identified the condition later that morning and
upon notification of the control room operators, the protected train signs were hung at
10:00 a.m., satisfying all actions required by limiting condition for operation 3.0.4b.
The inspectors reviewed apparent cause evaluation 22483, the hazard-barrier-target
analysis, and new and revised station procedures associated with this event. The
- 49 - Enclosure
inspectors concluded that Wolf Creeks corrective actions were adequate to ensure
compliance during future mode changes made under Technical Specification 3.0.4b. A
violation associated with this event is described in NRC Inspection
Report 05000482/2009005 as NCV 05000482/2009005-05, Mode Change under
Technical Specification 3.0.4.b Without Required Risk Management Actions. The
inspectors concluded that Wolf Creek satisfied the applicable Regulatory Commitment
associated with this LER documented in a letter from Mr. S. Hedges to the NRC dated
July 13, 2010. These LERs are closed.
.5 (Closed) LER 2010-001-00, Automatic Start of Motor-Driven Auxiliary Feedwater Pumps
Inoperable During Startup in Mode 1
On February 4, 2010, licensee personnel reviewed industry operating experience and
identified that the anticipatory actuation of the auxiliary feedwater pumps on a trip of both
main feedwater pumps would not function under certain conditions. Specifically, the
logic would not actuate on trip of a single operating main feedwater pump if the second
main feedwater pump was secured and reset. Two channels of auxiliary feedwater
actuation logic are required to be operable in Modes 1 and 2 as specified by Technical
Specification Table 3.3.2-1, function 6.g. There is no specified required action for two
inoperable channels, so limiting condition for operation 3.0.3 would be applicable
requiring action to be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit in Mode 3 in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. A
review by the licensee discovered occurrences where the required channels were both
inoperable and the technical specification required action was not completed. The
licensee determined that the occurrences constituted a condition prohibited by technical
specifications, a common-cause inoperability of independent channels and a
safety-system functional failure. The inspectors reviewed the licensees submittal and
determined that the report adequately documented the summary of the event, the
potential safety consequences, and the corrective actions required to address the
performance deficiency. The enforcement aspects of this violation were discussed in
NRC inspection report 05000482/2010002 in noncited violation
NCV 05000482/2010002-05, Failure to Follow Procedure for a Main Feed Pump Trip.
No additional violations were identified during the inspectors review. This LER is
closed.
.6 (Closed) LER 2010-002-00, Turbine Trip Function of Reactor Trip, P-4 Interlock
Defeated During Entry Into and in Mode 3
As part of the extent of condition review for NCV 05000482/2009005-15, Failure to
Report a Condition that Could Have Prevented Fulfillment of a Safety Function, Wolf
Creek identified that the P-4 interlock for turbine trip was being defeated in Mode 3. The
issue was reported as a condition prohibited by technical specification for defeating both
trains of the P-4 interlock. This included the reporting criteria under 50.73(a)(2)(i)(B) and
50.73(a)(2)(v). A licensee identified violation involving this issue is included in
Section 4OA7 of this report. No additional violations were identified during the
inspectors review. This LER is closed.
- 50 - Enclosure
.7 (Closed) LER 2010-014-00, Technical Specification Required Shutdown Due to
Inadequate Planning Resulting in Extended Emergency Diesel Generator Inoperability
On November 29, 2010, the licensee removed Train A emergency diesel generator from
service for a scheduled 7-day technical specification equipment outage in accordance
with Technical Specification 3.8.1, Condition B. During the outage, a number of delays
occurred and a high number of emergent work activities impacted the schedule. On
December 6, 2010, during the final surveillance run for declaring the emergency diesel
generator operable, the licensee identified that the peak firing pressure for cylinder 12
was almost 500 psig less than expected. The licensee determined that the condition
could not be fixed within the remaining time in the technical specification equipment
outage and commenced a shutdown of the reactor in compliance with technical
specifications.
The license determined that the retaining bolt for the fuel injector pump timing
adjustment lock plate on cylinder 12 had backed out due to a loose/deformed keeper
plate. This affected the timing of the injector pump and caused the reduction in the
cylinder pressure. The remaining cylinders were inspected and no other problems were
found. Work on the emergency diesel generator Train A was completed and the
emergency diesel generator was returned to operable status on December 7, 2010, and
Wolf Creek returned to Mode 1 on December 8, 2010.
The inspectors reviewed the root cause analysis and associated actions taken for this
event documented in Condition Report 30918. Wolf Creek determined that the root
cause of the unplanned shutdown was weaknesses in coordination of emergent work
into the work scheduling and work control processes. The inspectors concluded that no
violations of NRC requirements occurred during this event and that the cause evaluation
and corrective actions were appropriate. This LER is closed.
4OA6 Meetings
Exit Meeting Summary
On March 15, 2011, the inspectors discussed the results of the in-office inspection of changes to
the licensees emergency plan with Mr. T. East, superintendent emergency planning, and other
members of the licensees staff. The licensee acknowledged the issues presented. The
inspectors asked the licensee whether any materials examined during the inspection should be
considered proprietary. No proprietary information was identified.
On March 25, 2011, the inspectors presented the results of the radiation safety inspection to
Mr. M. Sunseri, President and Chief Executive Officer, and other members of the licensee staff.
The licensee acknowledged the issues presented. The inspectors asked the licensee whether
any materials examined during the inspection should be considered proprietary. No proprietary
information was identified.
On April 7, 2011, the inspectors presented the inspection results to Mr. M, Sunseri, President
and Chief Executive Officer, and other members of the licensee staff. The licensee
acknowledged the issues presented. The inspectors asked the licensee whether any materials
- 51 - Enclosure
examined during the inspection should be considered proprietary. No proprietary information
was identified.
4OA7 Licensee-Identified Violations
The following violations of very low safety significance (Green) were identified by the licensee
and are violations of NRC requirements which meet the criteria of Section 2.3.2 of the NRC
Enforcement Policy, NUREG-1600, for being dispositioned as noncited violations.
- Technical Specification 3.3.2, Table 1, Engineered Safety Feature Actuation System
Instrumentation, function 6.g., requires, in part, two operable channels of auxiliary
feedwater actuation upon trip of all main feedwater pumps in modes 1 and 2. There is
no specified required action for two inoperable channels, so limiting condition for
operation 3.0.3 is applicable. Limiting condition for operation 3.0.3 requires action to be
initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the plant in mode 3 in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. Contrary to the above, on
January 20, 2010, Wolf Creek identified that at various times, the actuation logic function
6.g. for auxiliary feedwater had been inoperable and that the licensee had failed to
initiate action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit in mode 3 in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. Specifically, the
actuation logic could not be made up with one main feedwater pump operating and the
second main feedwater pump secured and reset. This condition occurred during unit
startups and shutdowns. This finding was entered in the licensees corrective action
program as Condition Report 23008. Using Inspection Manual Chapter 0609.04,
Phase 1 - Initial Screening and Characterization of Findings, the issue screened to a
Phase 2 significance determination because it involved an actual loss of safety function.
A Phase 2 significance determination using the pre-solved worksheet from the Risk
Informed Inspection Notebook for Wolf Creek Generating Station, determined the
finding was of very low safety significance (Green) because this feature was not credited
in the plants safety analysis and the auxiliary feedwater safety function was still
available.
- Title 10 CFR 20.1501(a) states: Each licensee shall make or cause to be made,
surveys that (1) may be necessary for the licensee to comply with the regulations in this
part; and (2) are reasonable under the circumstances to evaluate (i) the magnitude and
extent of radiation levels; (ii) concentrations or quantities of radiological materials; and
(iii) the potential radiological hazards. On January 4, 2011, a dose estimate was created
for welding activities in a locked high radiation area on the 1988 elevation of the
auxiliary building. The dose estimate provided was for the incorrect valve. The incorrect
radiation survey data was used for the dose estimate. Additionally, the licensee
underestimated the number of workers that would be required for the work.
Consequently, the actual dose received was 180 mrem, which was 123 mrem over the
dose estimate of 56 mrem. Also, as stated in Section 2RS01, it caused the licensee to
fail to recognize that a revised or separate radiation work permit was required for this
work activity. Incorrectly evaluating the radiological hazard caused workers unintended
and unplanned dose. The inspectors determined this finding to be of very low safety
significance because it was not associated with ALARA planning or work controls, there
was no overexposure, there was no substantial potential for an overexposure, and the
- 52 - Enclosure
ability to assess dose was not compromised. This issue was documented in the
licensees corrective action program as Condition Report 00031818.
- Technical Specification Table 3.3.2.1, function 8.a, requires two trains of the P-4
interlock to be operable in Modes 1, 2, and 3. Function 8.a does not provide a required
action for both trains of engineered safety features actuation system interlocks
inoperable. Wolf Creek Technical Specification 3.0.3 requires the plant to be in Mode 4
within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> when there is no required action specified for a limiting condition of
operation that cannot be met. Contrary to the above, with both channels of the P-4 input
to the Turbine Trip function defeated in Mode 3, Wolf Creek did not take action to place
the unit in Mode 4 on November 6-8, 2006, May 10, 2008, April 30, 2009, and November
18, 2009. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and
Characterization of Findings, the issue screened to a Phase 2 significance
determination because it involved an actual loss of safety function. A Phase 2
significance determination could not be performed using the Risk Informed Inspection
Notebook for Wolf Creek Generating Station since the pre-solved worksheet did not
address the P-4 interlock. Using a Phase 3 analysis, a senior reactor analyst calculated
the core damage probability to be less than 1E-7 per year, or of very low safety
significance (Green). This issue was entered in the licensees corrective action program
as Condition Report 23108.
- 53 - Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
P. Bedgood, Manager, Radiation Protection
R. Evenson, Requalification Program Supervisor
S. Hedges, Site Vice President
S. Henry, Operations Manager
R. Hobby, Licensing Engineer
D. Hooper, Supervisor, Regulatory Affairs
T. Just, Senior Technician, Chemistry
J. Keim, Support Engineering Supervisor
M. McMullen, Technician, Engineering
C. Medency, Supervisor, Radiation Protection
W. Muilenburg, Licensing Engineer
R. Murray, Simulator Supervisor
B. Norton, Manage, Integrated Plant Scheduling
J. Pankaskie, Engineering Supervisor
G. Pendergrass, Director of Engineering
L. Rockers, Licensing Engineer
G. Sen, Regulatory Affairs Manager
R. Smith, Plant Manager
M. Sunseri, President and Chief Executive Officer
J. Truelove, Supervisor, Chemistry
J. Weeks, System Engineer
M. Westman, Training Manager
NRC Personnel
C. Long, Senior Resident Inspector
C. Peabody, Resident Inspector
D. Reinert, Acting Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000482/2011002-01 NCV Inadequate Design Control of the Fuel Oil Storage Tank Fill
System (Section 1RO4)05000482/2011002-02 NCV Inadequate Clearance Order Isolated Cooling to Inservice
Safety-Related Equipment (Section 1R04)05000482/2011002-03 NCV Failure to Monitor the Performance of Nonsafety-Related
Systems and Components Used in the Plant Emergency
Operating Procedures under 10 CFR 50.65 Programs
(Section 1R12)05000482/2011002-04, NCV Failure to Follow 10 CFR 50.65 a(2) for Main Control Board
Annunciator Power Supply Failures (Section 1R12)
A-1 Attachment
Opened and Closed
05000482/2011002-05 NCV Inadequate Calculation for Vital Switchgear Cooling
(Section 1R15)05000485/2011002-06 NCV Failure to Perform an Operability Determination for Degradation
of the Fuel Oil Storage Tank (Section 1R15)05000482/2011002-07 NCV Failure to Verify Ultimate Heat Sink Sedimentation Levels within
Design Bases (Section 1R19)05000482/2011002-08 NCV Inadequate Fill and Vent of Component Cooling Water
(Section 1R19)05000482/2011002-09 NCV Inadequate Clearance Order Disables Power Operated Relief
Valve Low temperature Overpressure Function (Section 1R20)05000482/2011002-10 NCV Repetitive Failure to Enter Technical Specifications for Auxiliary
Feedwater Suction Valve Testing (Section 1R22)05000482/2011002-11 NCV Failure to Follow Radiation Work Permit Instructions
(Section 2RS01)
Closed
050002009-007-00 LER Removal of Equipment from Service Required by Technical
Specification and NRC Safety Evaluation (Section 4OA3)
050002009-008-00 LER Potential of Containment Coolers to Have Not Automatically
Started in Slow Speed (Section 4OA3)
050002009-009-00, 01 LER Defeating Feedwater Isolation on Low Tavg Coincident with P-4
Function Results in Missed Mode Change. (Section 4OA3)
050002009-010-00, 01 LER Failure to meet LCO 3.4B during transition from Mode 4 to
Mode 3. (Section 4OA3)
050002009-011-00 LER Intermediate Range Detector NI 36 Inoperable (Section 4OA3)
050002010-001-00 LER Automatic Start of Motor-Driven Feedwater Pumps Inoperable
During Startup in Mode 1 (Section 4OA3)
050002010-002-00 LER Turbine Trip Function of Reactor Trip, P-4 Interlock Defeated
During Entry Into and in Mode 3 (Section 4OA3)
A-2 Attachment
LIST OF DOCUMENTS REVIEWED
Section 1RO4: Equipment Alignment
PROCEDURES
NUMBER TITLE REVISION
CKL JE-120 Emergency Fuel Oil System Lineup 19
AP 21G-001 Control of Locked Component Status 53B
STN MT-002 Standby Diesel Fuel Oil Storage Tanks Drain and Clean 4
Surveillance TJE01B 0
STS PE-021E Train A Emergency Fuel Oil Transfer System 0
STS PE-021E Pressure Test 0
DRAWINGS
M-12EC01 Piping and Instrumentation Diagram Fuel Pool Cooling and 19
Cleanup System
M-12EC02 Piping and Instrumentation Diagram Fuel Pool Cooling and 7
Cleanup System
M-109 Emergency Fuel Oil Stg. Tk. SNUPPS 6
WCRE-03 Tank Emergency Fuel Oil Storage Tank THE 01 A&B 22
Documents
M-13JE02 Piping Isometric Emer. Fuel Oil Sys. - Train A Diesel 7
Generator Building
M-13JE01 Piping Orthographic Emergency Fuel Oil System (Below 4
Grade)
USAR Figure P&ID Emergency Fuel Oil System 19
9.5.4-1-00
MISCELLANEOUS
NUMBER TITLE REVISION
SY1406400 Lesson Plan: Fuel Oil Purpose, Power Supplies, Layout 8
Control Room IOD: B EDG FUEL OIL 0
Logs
USAR Chapter 9.5.4
A-3 Attachment
07948 CCP Engineering Disposition: correct seismic class on M- 0
12JE01
10153 CCP Engineering Disposition 3
11-337160-001 Engineering Disposition: 3/4 Diameter Tubing from Main 0
Supply to a Header (KKJ01B)
Work Orders
10-323952-00 00-223036-000
Condition Reports
00032348 0033327 2008-004248
Section 1RO5: Fire Protection
PROCEDURES
NUMBER TITLE REVISION
AP 10-106 Fire Preplans 7
Section 1RO6: Flood Protection Measures
PROCEDURES
NUMBER TITLE REVISION
AP 21B-003 Control of Non-Plant Items Inside the Plant 8
AP 10-102 Control of Combustible Materials 15
MISCELLANEOUS
NUMBER TITLE REVISION /
DATE
09-005-XX-01 Temporary Modification Order February 19,
2011
E-029-00023 Scotch Super 33+ Vinyl electrical Tape Data Sheet W01
Condition Reports
A-4 Attachment
00033842 00033847 00033959
Work Order
08-311356-020
Section 1RO7: Heat Sink Performance
PROCEDURES
NUMBER TITLE DATE
STN PE-033 CCW Heat Exchanger Performance Test March 3,
2009
STN PE-033 CCW Heat Exchanger Performance Test October 8,
2009
Section 1R11: Licensed Operator Requalification Program
PROCEDURES
NUMBER TITLE REVISION
GEN-00-005 Generator Load to Hot Standby 67
GEN-00-006 Solid Pzr Ops
LR4132601 Simulator Lab Training Materials 000
Section 1R12: Maintenance Effectiveness
Condition Reports
00020665 00034681 00034650 00034529 00033909
00033896 00010657 00025817 00016581 00019447
00019390 00016504 00016467 00033465 00033594
00033562 00030432 00033823
PROCEDURES
NUMBER TITLE REVISION
EDI 23M-050 Engineering Desktop Instruction Monitoring Performance to 3
Criteria and Goals
STS KJ-005A Manual/Auto Start, Sync & Loading of EDG NE01 54
A-5 Attachment
PROCEDURES
NUMBER TITLE REVISION
MISCELLANEOUS
NUMBER TITLE
AD-04 Final Scope Evaluation for Condensate System Function to
Provide Water to the Suction of the Main Feedwater Pumps
AE-01 Final Scope Evaluation for Feedwater System Function to
Provide Feedwater and Controls to the Steam Generators
AE-04 Final Scope Evaluation for Feedwater System Function to
Provide Feedwater and Controls to the Steam Generators
(startup feed pump)
KA-01 Final Scope Evaluation for Compressed Air System Function
to Provide a Continuous Supply of Dry Oil-Free Air for
Pneumatic Instruments and Valves
NF-01 Final Scope Evaluation for Load Shedding and Emergency
Load Sequencing System Function to Shed and/or Sequence
Selected Loads from and/or to the Class 1E Buses
PA-01 Final Scope Evaluation for the Higher Medium Voltage
System 13,8kV Function to Distribute 13.8kV Power to
Various Loads Via Two Buses
PB-01 Final Scope Evaluation for the Lower Medium Voltage
System 4.16kV (Nonclass IE Power System) Function to
Provide Transformation of Power from 13.8kVac to 4.16kVac
and Distribute that 4.16kV Power to Supplied Loads
PG-01 Final Scope Evaluation for the Low Voltage System - 480V
(Nonclass IE Power System) Function to Provide
Transformation of Power from 13.8kVac to 480Vac and
Distribute that Power to Supplied Loads
PK-01 Final Scope Evaluation for 125Vdc System (Nonclass IE
Power System) Function to Provide 125Vdc Power to Various
Plant Loads for Control and Switching of Nonclass 1E
Electrical Systems
RK-01 Final Scope Evaluation for Plant Annunciator System
Function to Provide the Control Room Operator a Visual and
Audible Plant Status Condition
A-6 Attachment
PROCEDURES
NUMBER TITLE REVISION
SL-01 Final Scope Evaluation for Site Auxiliary Power System
Function to Provide ac Electrical Power to Service Water,
Circulating Water, and Fire Protection Systems
Work Orders
10-330047-000 10-330048-000 10-330049-000 10-331141-000 10-331148-000
10-331182-000 10-332898-000 10-332907-000 10-332894-000 09-316986-000
11-338443-000 11-338329-000 10-328341-000 10-328341-001 09-317354-000
09-317354-001 09-314014-000 08-312488-000 10-329847-001 09-320710-000
09-320710-001 09-318024-000 09-313998-000 09-313269-000 08-313088-000
08-313088-005 08-311453-000 10-336499-000 10-334406-000 10-328821-000
10-328821-001 10-326492-000 10-326377-000 08-310332-000 08-308271-003
08-304334-000 08-303649-000 08-303649-001 10-331046-000 10-325812-000
09-319777-000 09-318534-000 10-332636-000 10-332636-001 10-332636-002
10-328064-000 09-320189-000
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
MISCELLANEOUS
NUMBER TITLE REVISION
AP 22C-003 On-Line Nuclear Safety and Generation Risk Assessment 15A
ALR 00-131B Generator Field Overvoltage 8
ALR 00-131C Voltage Regulator Trip to Manual 6
ALR 00-131D Generator Voltage / Hertz Excess 10
STN AC-004 Quarterly Turbine Test 14A
SYS AC-120 Main Turbine Generator Startup 74
TSTF-IG-06-01 Implementation Guidance for TSTF-358, Missed Surveillance 6
Requirements
TSTF-358 Industry/TSTF Standard Technical Specification Change 6
Traveler
Technical Specification SR 3.3.2.10, Table B 3.3.2-2
Functional Unit 13
Technical Specification B 3.0-13, -14 34
Technical Specification 3.0-4 173
PSA-11-001 PSA Risk Evaluation of Incomplete Surveillances Tests STS 0
A-7 Attachment
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
MISCELLANEOUS
NUMBER TITLE REVISION
AL-005, STS IC-740A and STS IC-740B (CR 33352)
AP 26C-004 Operability Determination and Functionality Assessment 21
Calculation No. AN-02-006 0
M-724-00409 Instruction Manual for Gate and Check Valves W13
MGE LT-009 Limitorque Geared Limitswitch Adjustment 8A
DRAWINGS
E-13BN03A Refueling Water Storage Tank to RHR Pump MOV 8
E-13EJ06A Sump to No. 1 Residual Heat Removal Pump 7
E-13EJO6B Sump to No. 2 Residual Heat Removal Pump 9
EJHV8811A CTMT Recir Sump to RHR Pump A Suction ISO 0
EJHV8811B CTMT Recir Sump to RHR Pump B Suction ISO 0
BNHV8811A RWST to RHR PMP A Suction ISO W13
BNHV8812B RWST to RHR PMP B Suction ISO W13
44C308703 Alterrex Excitation System with S.C.R. Regulator 8
Condition Reports
00033352 00033717 00031929
Work Orders
08-310457-000 08-308676-001 08-308675-001 11-336846-001
Section 1R15: Operability Evaluations
NUMBER TITLE REVISION /
DATE
OFN-SG-003 Natural Events 20
BGV0192 to BGV0195 RWST Interface Piping 0
JE-M-003 Emergency Fuel Oil Storage Tanks Access Vaults Minimum 00
Temperature
STS CH-015 Emergency Diesel New Fuel 23
STS KJ-005A Manual/Auto Start, Sync & Loading of EDG NE01 54
A-8 Attachment
Section 1R15: Operability Evaluations
NUMBER TITLE REVISION /
DATE
STS MT-011 Snubber Visual Examination 18
SYS KJ-200 Inoperable Emergency Diesel 23A
CHS KJ-D01 Sampling Emergency Diesel A & B Fuel Oil System 1A
ASME B&PV Section XI - Subsection IWF Requirements for Class 1, 2, 3 1998
Code and MC Component Supports of Light Water Cooled Plants
MC8571 NRC Safety Evaluation, 3rd 10 Year Interval Inservice June 2, 2006
Examination Program for Snubbers Relief Request I3R-03
RER 2010-106 Broken Smith Blair Coupling Flange February 15,
2011
Work Order
10-331864-000
Condition Reports
00010832 00015385 00010833 00020515 00024818
00032420 0003718 00033730 00033953 00033486
00033653 00033758 00025988 00031020
Section 1R19: Postmaintenance Testing
CALCULATIONS
NUMBER TITLE REVISION /
DATE
Z065-C-001 Calculation Subject: Evaluation of Annual UHS 10
Sedimentation Measurements
CCP 011149 Revise Surveillance Frequency for SR Water Control 0
Structures and Reservoir (C-404)
MISCELLANEOUS
NUMBER TITLE REVISION /
DATE
C-302 Specification for Suction Dredging the Ultimate Heat Sink 2
C-302 Specification for Suction Dredging the Ultimate Heat Sink 3
A-9 Attachment
Section 1R19: Postmaintenance Testing
CALCULATIONS
NUMBER TITLE REVISION /
DATE
M-021-089-04 MDAFW A Pump Flow-Head Curve
OE AL-09-013 MDAFWP Total Discharge Flow Above 800gpm 0
PO: 750835/0 2010 Wolf Creek UHS Reservoir Hydrographic Survey August 20,
2010
PROCEDURES
NUMBER TITLE REVISION /
DATE
AP 10-103 Fire Protection Fire Impairment Control 23A
SYS FP-293 Fire Pumps Manual Operation 15
STN FP-211 Diesel Fire Pump1FP01PB Monthly Operation and Fuel 21A
Level Check
EF-M-021-000- Calculation Change Notice December 13,
CN001 2005
EFHV0039 30 Butterfly SMB-00-25
AP-16E-002 Post Maintenance Testing Development 9C
STN AE-007 Startup Main Feedwater Operational Test 0A
STS AL-101 MDAFW Pump A Inservice Pump Test (Completed) January 10,
2011
SYS AL-120 MDAFW or TDAFW Pump Operations (Completed) January 6,
2011
AP 29B-003 Surveillance Testing 11
MPM KJ-004 Robertshaw Model 1285 Temperature Control Valve 2
Condition Reports
00034331 00034806 00034500 00034434 00027080
00027220 00027243 00027144 00027196 00031876
00021559 00021630 00031853 00031848 00031820
00031819 00032573 00031863 00032582 00032584
00032586
A-10 Attachment
Work Orders
11-338679-000 11-338679-001 11-338679-002 11-338509-000 11-338509-001
10-331117-003 10-331117-001 10-332847-000 10-332847-002 09-322525-001
10-335457-001 04-262017-000 02-233644-000 09-322079-000 09-322079-001
09-322079-002 11-336729-000 09-322079-006 06-248742-000 06-289298-000
09-318482-000 10-325693-000 10-332582-000
Section 1R20: Refueling and Other Outage Activities
PROCEDURES
NUMBER TITLE REVISION
GEN 00-004 Power Operation 65
GEN 00-005 Minimum Load to Hot Standby 67
GEN 00-006 Hot Standby to Cold Shutdown 76
AP 21E-001 Clearance Orders 27
SYS-SB-120 Enabling/Disabling of SSPS 9
MISCELLANEOUS
NUMBER TITLE DATE
R-SB-A-004 Clearance Order March 22,
2011
10-328830-001 Clearance Order Worksheet Audit Report March 30,
2011
Condition Reports
00035318 00035288
Section 1R22: Surveillance Testing
PROCEDURES
NUMBER TITLE REVISION /
DATE
STS AL-103 Turbine Driven AFW Pump Inservice Test 45
STS EM-100A Safety Injection Pump A Inservice Pump Test 04A
STS RE-009 Heat Flux Hot Channel Factor Measurement (Completed) January 14,
2011
A-11 Attachment
Section 1R22: Surveillance Testing
PROCEDURES
NUMBER TITLE REVISION /
DATE
STS RE-013A Incore-Excore Detector Axial Flux Difference Comparison January 14,
(Completed) 2011
STN EM-100A Safety Injection Pump A Reference Pump Curve 3
Determination
STS PE-061 Control Room Control Building Habitability Test 0
STS IC-202A Channel Operational Test of Tavg, dT and Pressurizer 22A
Pressure Protection Set Two
MISCELLANEOUS
NUMBER TITLE REVISION /
DATE
CCP 013427 Broken Wires in Containment Tendons V7 and V65 00
WC-N1054-002 Wolf Creek Generating Station 7th Period - 25th Year June 22,
Containment Building Tendon Surveillance 2010
WC-N1054-500 Final Report for the Wolf Creek Nuclear Plant 25th Year December 6,
Containment Building Tendon Surveillance 2010
WCGS Special Administrative Requirements for Technical Specification 1
Order 26 Required Actions for Transient Relaxed Axial Offset Control
FQW(Z) Not Within Limits
Accelerated Atmospheric Tracer Depletion (ATD) February 28,
Testing for Unfiltered Air In-Leakage Determination at the 2011
Wolf Creek Nuclear Power Plant
DRAWINGS
NUMBER TITLE REVISION /
DATE
1000872.511 Wolf Creek B-Train M-15EF01 September 10,
2010
1000872.501 Wolf Creek A-Train M-15EF01 September 1,
2011
M-744-00042 Reactor Protection System Engineered Safety Features W11
Condition Reports
00033477 00033908 2006-002097
A-12 Attachment
Section 1EP6: Drill Evaluation
MISCELLANEOUS
NUMBER TITLE REVISION /
DATE
11-SA-01 Wolf Creek Emergency Planning Drill Scenario January 11,
2011
Section 2RS01: Radiological Hazard Assessment and Exposure Controls
PROCEDURES
NUMBER TITLE REVISION
AP 19B-001 Failed Fuel Action Program 7
AP 19D-100 Radioactive Source Program 4
AP 25A-001 Radiation Protection Manual 14
AP 25A-200 Access to Locked High or Very High Radiation Areas 24
AP 25A-700 Use of Temporary Lead Shielding or Locked High Radiation 12
Areas and Very High Radiation Area Barricades
AP 25B-100 Radiation Worker Guidelines 40
RPP 01-105 Health Physics Organization, Responsibilities, and Code of 13
Conduct
RPP 02-210 Radiation Survey Methods 37
RPP 02-215 Posting of Radiological Controlled Areas 26A
RPP 02-405 RCA Access Control 17
RPP 02-515 Release of Material from the RCA 26
RPP 02-605 Control and Inventory of Radioactive Sources 14
RPP 08-105 Underwater Dive Operations 8
STS HP-001 Sealed Source Contamination Surveillance Test 22
A-13 Attachment
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
NUMBER TITLE DATE
10-09-PC Quality Assurance Audit Report Process Control November 18, 2010
Program
10-03-RP Quality Assurance Audit Report Radiological Protection March 18, 2010
Program
SEL 2010-176 Self Assessment Report SEL 2010-176 HP June 24, 2010
Operations/Instrumentation
CONDITION REPORTS
00025491 00027545 00031818 00034013 00035289
00035392 00035396 00035408 00035500 00035519
RADIATION WORK PERMITS
NUMBER TITLE
110008 NRC Access to the RCA
110060 Underwater Vacuum Filter Removal from Spent Fuel Pool
111001 Operations Rover RWP for pre-RF-18 and RF-18 Activities
111101 Under RV Cavity Seal Ring Access for RF-18
111102 Incore Tunnel Inspections & Maintenance
112600 Routine Outage Access (No High Radiation Areas Access)
112601 Routine Outage Access (No Locked High Radiation Areas Access)
112602 Routine Outage Access (No Very High Radiation Areas Access)
113022 Eddy Current Testing of Incore Flux Thimble Tubes at Seal Table
113220 Primary Side Steam Generator Secondary Side Work
116020 RV Head Preparation
116031 RV Head Lift, Transfer, & Set
SURVEYS
1101-0028 1101-0040 1101-0041 1101-0052 1101-0055
1101-0197 1101-0198
A-14 Attachment
Section 2RS02: Occupational ALARA Planning and Controls
PROCEDURES
NUMBER TITLE REVISION
AI 02-005 Primary and Radwaste Guidelines for Plant Startup and 2
Shutdown
AP 25A-001 Radiation Protection Manual 14
CONDITION REPORTS
00025510 00025923 00026060 00030234 00031460
00033762 00034013
RADIATION WORK PERMITS
NUMBER TITLE
111000 Health Physics Rover Coverage RF-18
113220 Primary Side Steam Generator Secondary Side Work
114200 Steam Generator Secondary Side
114208 RCP Team Work Activities Reactor Vessel Head Lift Preparation and Post
Head Set Work Activities
114420 RV Head Lift, Transfer, & Set Scaffolding Erection/Removal
116020 RV Head Preparation
A-15 Attachment
MISCELLANEOUS DOCUMENTS
TITLE DATE
ALARA Report Refuel 17 August 30,2010
ALARA Committee Meeting November 16, 2010
ALARA Committee Meeting December 14, 2010
ALARA Committee Meeting February 08, 2011
ALARA Committee Meeting March 08, 2011
ALARA Long Range Source Term Reduction Plan 2010-2015 November 18, 2010
Section 2RS03: In-plant Airborne Radioactivity Control and Mitigation
PROCEDURES
NUMBER TITLE REVISION
AI 14-009 Industrial Respiratory Protection Program 5A
AP 25B-600 Respiratory Protection Program at Wolf Creek 7
AP 25A-800 Use of Vacuum Cleaners in the RCA 4A
RRP 05-205 Eberline AMS-4 Operation 8
RRP 05-920 RCA Vacuum Cleaner Maintenance 5
RRP 05-925 HEPA Portable Ventilation Unit Maintenance and Use 6
Section 4OA1: Performance Indicator Verification
PROCEDURES
NUMBER TITLE REVISION
APA 26A-2007 NRC Performance Indicators 8
OTHER DOCUMENTS
NUMBER TITLE DATE
SEL 2010-188 Self-Assessment Report November 18,
2010
CONDITION REPORTS
19369 19913 25817
Section 4OA3: Event Follow-Up
PROCEDURES
NUMBER TITLE REVISION
AP 26C-005 Technical Specification LCO 3.0.4 Mode Change Review 0
A-16 Attachment
MISCELLANEOUS
NUMBER TITLE DATE
EA-09-326 Response to Disputed Noncited Violations in NRC Inspection March 4,
Report 05000482/2009004 and Withdrawal of Noncited 2010
Violation
Condition Reports
00022483 00030918
A-17 Attachment