IR 05000482/2011008

NRC Temporary Instruction 2515/183 Inspection Report 05000482/2011008

ML11133A354
Person / Time
Site:	Wolf Creek
Issue date:	05/13/2011
From:	Geoffrey Miller NRC/RGN-IV/DRP/RPB-B
To:	Matthew Sunseri Wolf Creek
References
TI 2515/183 IR-11-008
Download: ML11133A354 (20)

Text

UNIT ED STAT ES NU C LE AR RE G UL AT O RY C O M M I S S I O N May 13, 2011

SUBJECT:

WOLF CREEK GENERATING STATION - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000482/2011008

Dear Mr. Sunseri:

On April 28, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Wolf Creek Generating Station, using Temporary Instruction 2515/183, "Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event." The enclosed inspection report documents the inspection results which were discussed on April 28, 2011, with yourself and other members of your staff.

The objective of this inspection was to assess the adequacy of actions taken at Wolf Creek Generating Station in response to the Fukushima Daiichi Nuclear Station fuel damage event.

The results from this inspection, along with the results from similar inspections at other operating commercial nuclear plants in the United States, will be used to evaluate the United States nuclear industrys readiness to respond to a similar event. These results will also help the NRC to determine if additional regulatory actions are warranted.

All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to respond to this letter.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Wolf Creek Nuclear Operating Corporation -2-

Sincerely,

/RA/

Geoffrey B. Miller, Chief Project Branch B Division of Reactor Projects Docket: 50-482 License: NPF-42

Enclosure:

Inspection Report 05000482/2011008 w/attachment: Supplemental Information

REGION IV==

Docket: 05000482 License: NPF-42 Report: 05000482/2011008 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane NE Burlington, KS 66839 Dates: March 23 through April 28, 2011 Inspectors: C. Long, Senior Resident Inspector C. Peabody, Resident Inspector D. Reinert, Acting Resident Inspector Approved by: Geoffrey B. Miller, Chief, Project Branch B Division of Reactor Projects-1- Enclosure

SUMMARY OF FINDINGS

IR 05000482/2011008, 03/23/2011 - 04/29/2011; Wolf Creek Generating Station, Temporary

Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.

This report covers an announced temporary instruction inspection. The inspection was conducted by resident and Region IV inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the temporary instruction is to be a high-level look at the industrys preparedness for events that may exceed the design basis for a plant. The focus of the temporary instruction was on

(1) assessing the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats;

(2) assessing the licensees capability to mitigate station blackout conditions;

(3) assessing the licensees capability to mitigate internal and external flooding events required by station design; and

(4) assessing the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. If necessary, a more specific followup inspection will be performed at a later date.

INSPECTION RESULTS

The following table documents the NRC inspection at Wolf Creek Generating Station performed in accordance with Temporary Instruction 2515/183. The numbering system in the table corresponds to the inspection items in the temporary instruction.

03.01 Assess the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 CFR 50.54(hh). Use Inspection Procedure 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. If Inspection Procedure 71111.05T was recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe what the licensee did to test or inspect equipment.

a. Verify through test or The licensee conducted an inventory and inspection of fire brigade equipment and self contained inspection that breathing apparatus units. The licensee conducted an inventory and inspection of B.5.b equipment is available equipment stored on their fire truck. The licensee conducted an inventory of B.5.b prestaged and functional. Active equipment storage boxes and reviewed the most recent annual performance test of the portable equipment shall be B.5.b pump.

tested and passive equipment shall be walked down and Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, reviewed inspected. It is not test results, discussed actions, reviewed records, etc.).

expected that permanently installed equipment that is tested The inspectors reviewed the results of the licensees equipment inventory and inspections. The under an existing inspectors independently walked down applicable fire protection and prestaged B.5.b equipment regulatory testing and verified that the equipment was in accordance with station procedures. The inspectors program be retested.

reviewed procedures and training materials for applicable fire protection and prestaged B.5.b equipment and reviewed the portable B.5.b pump performance testing results.

This review should be done for a reasonable sample of mitigating Discuss general results including corrective actions by licensee.

strategies/equipment.

The inspectors verified equipment was available in specified locations and that current test histories provided reasonable assurance of functionality. The inspectors concluded that the licensee adequately incorporated B.5.b requirements into station procedures and adequately

staged, inventoried, tested, and maintained the equipment necessary to implement the strategies.

Licensee Action Describe the licensees actions to verify that procedures are in place and can be executed (e.g.,

walkdowns, demonstrations, tests, etc.)

b. Verify through The licensee performed tabletop exercises and field walkdowns for associated extensive damage walkdowns or mitigation guidelines, severe accident mitigation guidelines, emergency management guidelines, demonstration that and selected off-normal and emergency planning procedures.

procedures to implement the strategies associated Describe inspector actions and the sample strategies reviewed. Assess whether procedures with B.5.b and were in place and could be used as intended.

10CFR 50.54(hh) are in place and are executable.

The inspectors reviewed the results of the licensees tabletop and field walkdown exercises, and Licensees may performed an independent review of the procedures associated with the licensee actions. The choose not to inspectors walked down extensive damage mitigation guidelines actions with qualified nuclear connect or operate station operators to ensure that the operators knew where the equipment was located and how to permanently installed operate the equipment. The inspectors reviewed hydraulic calculations for the extensive damage equipment during this mitigation guidelines strategies.

verification.

This review should be Discuss general results including corrective actions by licensee.

done for a reasonable sample of mitigating Extensive damage mitigation guidelines procedures specify that if the control room staff and field strategies/equipment. operators are compromised, then the shift security commander becomes the incident coordinator until an operator can be found. Inspectors identified that shift security commanders are not extensively trained on reactor technology and mitigating systems, therefore it is not reasonable to assume they would have a sufficient knowledge base or decision making ability to effectively direct technical response to an extensive damage situation. The licensee entered the issue into their corrective action program and is in the process of conducting additional procedural and technical training for security commanders.

The licensee identified that extensive damage mitigation guidelines procedures to refill the refueling water storage tank are not viable because the specified connection point is not readily accessible. The licensee entered this issue into their corrective action program and is evaluating potential design changes to remedy this concern.

The licensee identified that extensive damage mitigation guideline procedures require additional precautionary guidance to prevent excessive reactor coolant system depressurization which could compromise natural circulation core cooling. The licensee entered this issue into their corrective action program and is evaluating procedural enhancements to remedy this concern.

The licensee identified that alternate power sources specified by extensive damage mitigation guidelines procedures are not properly staged in advance, and additional technical guidance on the configuration and use of these sources needs to be added to the extensive damage mitigation guidelines procedures. The licensee entered this issue into their corrective action program and is evaluating alternative equipment and procedural enhancements to remedy this concern.

The inspectors concluded that the licensee had completed or begun implementation of adequate corrective actions in this area. The inspectors plan to conduct further inspection on the above items; the results of this inspection will be documented in Inspection Report 2011003.

Licensee Action Describe the licensees actions and conclusions regarding training and qualifications of operators and support staff.

c. Verify the training and The licensee reviewed training materials administered to licensed and nonlicensed operators, qualifications of security officers, and members of the fire brigade to implement procedures and work instructions operators and the for activities related to B.5.b. The licensee also reviewed lists of qualified personnel at the above support staff needed to positions who had maintained current qualification on those training activities.

implement the procedures and work instructions are current for activities related to B.5.b and severe accident management guidelines as required by 10 CFR 0.54 (hh).

Describe inspector actions and the sample strategies reviewed to assess training and qualifications of operators and support staff.

The inspectors reviewed training materials administered to licensed and nonlicensed operators, security officers, and members of the fire brigade to implement procedures and work instructions for activities related to B.5.b. The inspectors also reviewed lists of qualified personnel at the above positions who had maintained current qualification on those training activities.

Discuss general results including corrective actions by licensee.

The inspectors observed that the licensee has conducted adequate training in relation to B.5.b implementation, and, where necessary, has completed or begun implementation of adequate corrective actions in this area.

Licensee Action Describe the licensees actions and conclusions regarding applicable agreements and contracts are in place.

d. Verify that any The licensee reviewed applicable medical, governmental, law enforcement, fire protection, and applicable agreements industry organization support agreements and contracts to verify their adequacy.

and contracts are in place and are capable of meeting the For a sample of mitigating strategies involving contracts or agreements with offsite entities, conditions needed to describe inspector actions to confirm agreements and contracts are in place and current mitigate the (e.g., confirm that offsite fire assistance agreement is in place and current).

consequences of these events.

The inspectors reviewed applicable medical, governmental, law enforcement, fire protection, and This review should be industry organization support agreements and contracts and verified that they were current.

done for a reasonable Discuss general results including corrective actions by licensee.

sample of mitigating strategies/equipment.

The inspectors observed that applicable agreements and contracts were in place and provide reasonable assurance to meet the conditions prescribed. The inspectors verified, where necessary, that the licensee had completed or begun implementation of adequate corrective actions.

Licensee Action Document the corrective action report number and briefly summarize problems noted by the licensee that have significant potential to prevent the success of any existing mitigating strategy.

e. Review any open Overall, the inspectors reviewed 30 condition reports that the licensee initiated related to response corrective action and followup of the Fukushima Daiichi Nuclear Station events. The inspectors found that the documents to assess licensee had a low threshold for identifying problems. The inspectors verified, where necessary, problems with mitigating that the licensee had completed or begun implementation of adequate corrective actions. The strategy implementation inspectors assessed the impact of these corrective action items as challenges that could identified by the complicate but not prevent the response capability of the operators during a B.5.b, station licensee. Assess the blackout, or 10 CFR 50.54(hh) event.

impact of the problem The following are specific corrective action document numbers and descriptions of items entered on the mitigating into the licensees corrective action program which inspectors considered to be the most capability and the significant for improving implementation capability.

remaining capability that is not impacted.

Condition Report 27743 identified an enhancement to Procedure EDMG T-01 calling for the staging of ladders or scaffolds to top of the refueling water storage tank to open the manway for refilling the tank. Condition Report 33256 suggested using a Genie Lift, a modification to the ground level manway, or adding a spool piece to the manway on the top of the tank. Inspectors found this activity likely to be accomplished but under time pressure with the needed gathering of unstaged equipment in various other locations. Use of the Genie lift is not feasible during severe weather. Also, the lift was not pre-staged in a seismic or tornado qualified location.

Condition Report 37371 identified that the fire truck was not protected from a seismic or severe weather events as it is parked in a non-seismic sheet metal building. Wolf Creek is evaluating what corrective actions to take.

Condition Report 37374 identified numerous equipment needs for staging, the most important of which Wolf Creek identified was needed improvement in portable generators for AC and DC power and equipment to connect gas cylinders to air operated valves. Inspectors found that these actions would improve the stations ability to cope with an extended station blackout.

03.02 Assess the licensees capability to mitigate station blackout conditions, as required by 10 CFR 50.63, "Loss of All Alternating Current Power," and station design, is functional and valid. Refer to Temporary Instruction 2515/120, "Inspection of Implementation of Station Blackout Rule Multi-Plant Action Item A-22," as a guideline. It is not intended that Temporary Instruction 2515/120 be completely reinspected. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe the licensees actions to verify the adequacy of equipment needed to mitigate a station blackout event.

a. Verify through The licensee performed an inventory and test of materials and equipment required for a station walkdowns and blackout event.

inspection that all required materials are adequate and properly Describe inspector actions to verify equipment is available and useable.

staged, tested, and maintained.

The inspectors walked down the location of staged materials and equipment required for a station blackout event.

Discuss general results including corrective actions by licensee.

The inspectors observed that required materials and equipment were properly staged, tested, and maintained in working order, and, where necessary, the licensee had completed or begun implementation of adequate corrective actions in this area.

Licensee Action Describe the licensees actions to verify the capability to mitigate a station blackout event.

b. Demonstrate through The licensee performed tabletop reviews and walkdowns to verify that procedures for station walkdowns that blackout are executable.

procedures for response to a station blackout are Describe inspector actions to assess whether procedures were in place and could be used as executable.

intended.

The inspectors reviewed the results of the licensees tabletop exercises and field walkdowns. The inspectors conducted a walkdown of EMG C-0, "Loss of All AC Power," with a licensed control room operator and a nuclear station operator. The operators would be expected to implement local actions in this procedure.

Discuss general results including corrective actions by licensee.

Nuclear station operators failed to promptly locate certain emergency operating procedure components in the field. The inspectors determined that this was due to inadequate training, lack of specific procedural guidance, and over-reliance on a computer database of equipment locations. The computer database would be unavailable during an actual station blackout. The licensee agreed with this characterization and entered this issue into their corrective action program as Condition Report 37810.

The corrective actions associated with this condition report consisted of performing extent of condition walkdowns with additional operations' watch standers. The licensee observed similar weaknesses in emergency operating procedure component identification. As an interim action, the licensee issued field copies of documentation of all emergency operating procedure component field locations to all station watch standers. Inspectors verified that the component location guides were in the required equipment lockers. In the longer term, the licensee plans to review and enhance, as necessary, the level of component identification detail in all emergency operating procedures and off normal procedures. The licensee will also conduct additional training in the classroom and in the field to improve the equipment identification reliability among all qualified nuclear station operators.

The inspectors concluded that the licensee had completed or begun implementation of adequate corrective actions in this area. The inspectors plan to conduct further inspection on this item; the results of this inspection will be documented in Inspection Report 2011003.

03.03 Assess the licensees capability to mitigate internal and external flooding events required by station design. Refer to Inspection Procedure 71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding," as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.

Licensee Action Describe the licensees actions to verify the capability to mitigate existing design basis flooding events.

a. Verify through The licensee reviewed the site flooding analysis and performed walkdowns throughout the plant to walkdowns and identify any equipment susceptible to internal or external flooding.

inspection that all required materials are adequate and properly Describe inspector actions to verify equipment is available and useable. Assess whether staged, tested, and procedures were in place and could be used as intended.

maintained.

The inspectors reviewed the site flooding analysis and the results of the licensees walkdowns.

The inspectors performed walkdowns throughout the plant to identify any equipment susceptible to internal or external flooding.

Discuss general results including corrective actions by licensee.

The inspectors reviewed the Final Safety Analysis Report and related flood analysis documents to identify those areas that could reasonably be affected by external flooding. Due to the design and geographic location of Wolf Creek, the only credible external flooding event is one caused by heavy rains. The inspectors reviewed the design of structures, systems and components and their ability to cope with a maximum precipitation event. The review included a walkdown of building roofs to ensure that drain paths were available and that the drain system has adequate protection (screens/covers) to prevent debris from disabling the system.

Additionally, the inspectors noted that the licensee does not have materials prestaged for the mitigation of internal or external flooding because floor drains are designed to mitigate internal floods while site topography averts external flooding. The inspectors found internal flood doors, barriers, and penetration seals in good condition and, where necessary, the licensee had completed or begun implementation of adequate corrective actions in this area. The inspectors walked down all levels of the auxiliary building, fuel building, and control building for internal and external flood impacts. The inspectors also walked down the radiologicaly controlled and non-controlled yards as well as the intake structure. The licensee identified that the probable maximum precipitation could result in water levels up to the bottom of missile doors. The inspectors determined that the water height would not be sufficient to challenge equipment due to the capacity of the floor drain system, building internal curbs, and the condition of external missile door seals used for ventilation integrity.

03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. Assess the licensees development of any new mitigating strategies for identified vulnerabilities (e.g.,

entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use Inspection Procedure 71111.21, "Component Design Basis Inspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the licensees walkdowns and inspections.

Licensee Action Describe the licensees actions to assess the potential impact of seismic events on the availability of equipment used in fire and flooding mitigation strategies.

a. Verify through The licensee conducted walkdowns of plant areas which could be potentially susceptible to walkdowns that all seismic events, including all power block buildings and tanks, safety and nonsafety intake required materials are structures, security access points, and administrative site buildings.

adequate and properly staged, tested, and maintained.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors reviewed the results of the licensees seismic walkdowns. The inspectors conducted walkdowns of plant areas which could be potentially susceptible to seismic events, including the power block buildings and tanks, nonsafety intake structure, and selected administrative site buildings and determined procedures were in place and could be accomplished as written.

Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.

The licensee did not have additional materials prestaged for the mitigation of a beyond design basis earthquake, beyond that used for B.5.b and station blackout.

The licensee identified that some fire protection equipment is not stored in seismic or tornado qualified locations. The licensee identified that the water supply pumps and piping used for fire protection and extensive damage mitigation guideline actions is not seismic or tornado qualified.

The licensee also identified that equipment used to access underground diesel storage tanks is not seismic or tornado qualified; also the tanker truck used to refill the diesel-driven fire pump and fire truck is not parked in a seismic or tornado qualified building. The licensee entered these issues into their corrective action program. The inspectors found that Wolf Creek has contracts in place to deliver fuel oil to the site should the onsite truck become disabled. The inspectors found that Wolf Creek has agreements and measures to call in additional fire department assistance.

The inspectors identified that the condensate storage tank used in station blackout response and extensive damage mitigation guideline procedures is not seismic or tornado qualified. The licensee entered the issue into their corrective action program for enhancements. The inspectors found that the safety related source, from the essential service water system, would not be impacted.

The inspectors concluded that the licensee had completed or begun implementation of adequate corrective actions in this area. The inspectors plan to conduct further inspection on the above items; the results of this inspection will be documented in Inspection Report 2011003.

EXIT MEETING SUMMARY The inspectors presented the inspection results to Mr. M. Sunseri, President and CEO, and other members of Wolf Creek Nuclear Operating Corporation management at the conclusion of the inspection on April 28, 2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. The proprietary information was returned to the licensee or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Dees, Superintendant Operations

D. Garbe, Fire Protection Engineer

J. Glover, Nuclear Station Operator

J. Hinterwigger, Fire Protection Instructor

D. Hooper, Supervisor Licensing

M. Kewley, Senior Nuclear Station Operator

J. Mader, Senior Nuclear Station Operator

D. McClure, Senior Nuclear Station Operator

W.Muilenberg, Licensing Engineer

L. Rockers, Licensing Engineer

J. Suter, Supervisor Fire Protection Engineering

E. Winn, Reactor Operator

R. Zyduck, Manager Design Engineering