ML14223B221

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IR 05000482-14-003, on 03/29/2014 & 06/27/2014, Wolf Creek Generating Station, Integrated Resident and Regional Report; Maintenance Risk Assessments and Emergent Work Control
ML14223B221
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 08/11/2014
From: O'Keefe N
NRC/RGN-IV/DRP/RPB-B
To: Heflin A
Wolf Creek
C. Peabody
References
IR-14-003
Download: ML14223B221 (46)


See also: IR 05000482/2014003

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

August 11, 2014

Adam C. Heflin, 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 05000482/2014003

Dear Mr. Heflin:

On June 27, 2014, the U.S. Nuclear Regulatory Commission completed an inspection at the

Wolf Creek Generating Station. On July 8, 2014, the Nuclear Regulatory Commission

inspectors discussed the results of this inspection with you and other members of your staff.

Inspectors documented the results of this inspection in the enclosed inspection report.

The Nuclear Regulatory Commission inspectors documented one finding of very low safety

significance (Green) in this report. This finding involved a violation of Nuclear Regulatory

Commission requirements. The Nuclear Regulatory Commission is treating this violation as

non-cited violation consistent with Section 2.3.2.a of the Nuclear Regulatory Commission

Enforcement Policy.

If you contest the violation or significance of the non-cited violation, you should provide a

response within 30 days of the date of this inspection report, with the basis for your denial, to

the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC

20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of

Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the

Nuclear Regulatory Commission resident inspector at the Wolf Creek Generating Station.

If you disagree with the cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the Regional Administrator, Region IV; and the Nuclear Regulatory

Commission resident inspector at the Wolf Creek Generating Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your

response (if any) will be available electronically for public inspection in the NRCs Public

A. Heflin -2-

Document Room or from the Publicly Available Records component of the Nuclear Regulatory

Commission Agencywide Documents Access and Management System. Agencywide

Documents Access and Management System is accessible from the Nuclear Regulatory

Commission Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic

Reading Room).

Sincerely,

/RA/

Neil OKeefe, Chief

Project Branch B

Division of Reactor Projects

Docket Nos.: 50-482

License Nos: NPF-42

Enclosure:

Inspection Report 05000482/2014003

w/Attachments

1. Supplemental Information

2. Public Radiation Safety Inspection Request

cc w/encl: Electronic Distribution to

Wolf Creek Nuclear Operating Corporation

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000482

License: NPF-42

Report: 05000482/2014003

Licensee: Wolf Creek Nuclear Operating Corporation

Facility: Wolf Creek Generating Station

Location: 1550 Oxen Lane NE

Burlington, Kansas

Dates: March 29 through June 27, 2014

Inspectors: C. Peabody, Senior Resident Inspector

R. Stroble, Resident Inspector

L. Carson II, Senior Health Physicist

N. Greene, PhD, Health Physicist

P. Hernandez, Health Physicist

J. ODonnell, Health Physicist

D. Proulx, Senior Project Engineer

Approved Neil OKeefe

By: Chief, Project Branch B

Division of Reactor Projects

Enclosure

SUMMARY

IR 05000482/2014003; 03/29/2014 - 06/27/2014; Wolf Creek Generating Station, Integrated

Resident and Regional Report; Maintenance Risk Assessments and Emergent Work Control.

The inspection activities described in this report were performed between March 29 and

June 27, 2014, by the resident inspectors at Wolf Creek Generating Station and inspectors from

the Nuclear Regulatory Commission Region IV office. One finding of very low safety

significance (Green) is documented in this report. This finding involved a violation of Nuclear

Regulatory Commission requirements. The significance of inspection findings is indicated by

their color (Green, White, Yellow, or Red), which is determined using Inspection Manual

Chapter 0609, Significance Determination Process. Their cross-cutting aspects are

determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting

Areas. Violations of NRC requirements are dispositioned in accordance with the Nuclear

Regulatory Commission Enforcement Policy. The NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG 1649, Reactor

Oversight Process.

Findings

No findings were identified.

Licensee Identified Findings

No findings were identified.

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PLANT STATUS

Wolf Creek began the inspection period with the unit in Mode 5 (cold shutdown) for a planned

mid-cycle outage. On May 8, 2014, the reactor was restarted then promptly shut down due to a

leaking steam generator bowl drain valve inside containment. On May 10, 2014, the reactor

was again restarted and promptly shut down due to a reactor coolant pump oil leak inside

containment. On May 13, 2014, the reactor was restarted successfully, reached 100 percent

power on May 15, 2014, and remained at that power level for the remainder of the inspection

period.

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

Summer Readiness for Offsite and Alternate AC Power Systems

a. Inspection Scope

On May 2, 2014, the inspectors completed an inspection of the stations off-site and

alternate-ac power systems. The inspectors inspected the material condition of these

systems, including transformers and other switchyard equipment to verify that plant

features and procedures were appropriate for operation and continued availability of off-

site and alternate-ac power systems. The inspectors reviewed outstanding work orders

and open condition reports for these systems. The inspectors walked down the

switchyard to observe the material condition of equipment providing off-site power

sources. The inspectors verified that the licensees procedures included appropriate

measures to monitor and maintain availability and reliability of the off-site and alternate-

ac power systems.

These activities constituted one sample of summer readiness of off-site and alternate-ac

power systems, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment (71111.04)

Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant

systems:

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  • April 7, 2014, control room air conditioning system and control room emergency

ventilation system train B

  • June 17, 2014, safety injection system train A

The inspectors reviewed the licensees procedures and system design information to

determine the correct lineup for the systems. They visually verified that critical portions

of the systems or trains were correctly aligned for the existing plant configuration.

These activities constituted three partial system walk-down samples as defined in

Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection (71111.05)

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status

and material condition. The inspectors focused their inspection on four plant areas

important to safety:

  • May 1, 2014, radiological controlled area and health physics office space
  • May 1, 2014, lower cable spreading room
  • May 7, 2014, upper cable spreading room

For each area, the inspectors evaluated the fire plan against defined hazards and

defense-in-depth features in the licensees fire protection program. The inspectors

evaluated control of transient combustibles and ignition sources, fire detection and

suppression systems, manual firefighting equipment and capability, passive fire

protection features, and compensatory measures for degraded conditions.

These activities constituted four quarterly inspection samples, as defined in Inspection

Procedure 71111.05.

b. Findings

No findings were identified.

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.2 Annual Inspection

a. Inspection Scope

On June 27, 2014, the inspectors completed their annual evaluation of the licensees fire

brigade performance. This evaluation included observation of an unannounced fire drill

for 2016, control building non-vital switchgear room B on June 27, 2014.

During this drill, the inspectors evaluated the capability of the fire brigade members, the

leadership ability of the brigade leader, the brigades use of turnout gear and fire-fighting

equipment, and the effectiveness of the fire brigades team operation. The inspectors

also reviewed whether the licensees fire brigade met NRC requirements for training,

dedicated size and membership, and equipment.

These activities constituted one annual inspection sample, as defined in Inspection

Procedure 71111.05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11)

Review of Licensed Operator Requalification

a. Inspection Scope

On June 18, 2014, the inspectors evaluated a simulator scenario performed by an

operating crew. The inspectors assessed the performance of the operators and the

evaluators critique of their performance.

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.

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

a. Inspection Scope

The inspectors reviewed two risk assessments performed by the licensee prior to

changes in plant configuration and the risk management actions taken by the licensee in

response to elevated risk:

planned maintenance outage

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  • June 16-22, 2014, train B safety injection planned maintenance outage and train

B containment spray planned maintenance outage

The inspectors verified that these risk assessments were performed timely and in

accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant

procedures. The inspectors reviewed the accuracy and completeness of the licensees

risk assessments and verified that the licensee implemented appropriate risk

management actions based on the result of the assessments.

The inspectors also observed portions of one emergent work activities that had the

potential to affect the functional capability of mitigating systems:

replacement

The inspectors verified that the licensee appropriately developed and followed a work

plan for these activities. The inspectors verified that the licensee took precautions to

minimize the impact of the work activities on unaffected structures, systems, and

components (SSCs).

Additionally, the inspectors reviewed the risk assessments associated with two planned

maintenance activities performed during a time in the outage when the primary plant was

in a water-solid condition that resulted in unplanned pressure transients.

valve testing

These activities constitute completion of four maintenance risk assessments and

emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

(Note: The March 14, 2014, sample was counted in Inspection Report 2014002).

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed four operability determinations that the licensee performed for

degraded or nonconforming SSCs:

heating, ventilation, and air conditioning inlet damper hydramotor oil analysis

condition

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failure

governor hydraulic actuator SKJ09B

The inspectors reviewed the timeliness and technical adequacy of the licensees

evaluations. Where the licensee determined the degraded SSC to be operable, the

inspectors verified that the licensees compensatory measures were appropriate to

provide reasonable assurance of operability. The inspectors verified that the licensee

had considered the effect of other degraded conditions on the operability of the

degraded SSC.

In the case of the containment cooler issues, the inspectors obtained the assistance of

specialist inspectors from the Region IV office and experts from the Office of Nuclear

Reactor Regulation. The NRC conducted several calls with licensee technical and

management personnel. Based on NRC concerns, the licensee decided to perform

hydrostatic testing of the remaining coolers to provide provide test data to support

continued operabililty with continuing pitting corrosion. The inspectors observed one of

the pressure tests and reviewed the revised operability determination.

These activities constitute completion of four operability review samples, as defined in

Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected risk-

significant SSCs:

The inspectors reviewed licensing and design basis documents for the SSCs and the

maintenance and post-maintenance test procedures. The inspectors observed the

performance of the post-maintenance tests to verify that the licensee performed the tests

in accordance with approved procedures, satisfied the established acceptance criteria,

and restored the operability of the affected SSCs.

These activities constitute completion of four post-maintenance testing inspection

samples, as defined in Inspection Procedure 71111.19.

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b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities (71111.20)

a. Inspection Scope

During the stations mid-cycle outage that concluded on May 13, 2014, the inspectors

evaluated the licensees outage activities. The inspectors verified that the licensee

considered risk in developing and implementing the outage plan, appropriately managed

personnel fatigue, and developed mitigation strategies for losses of key safety functions.

This verification included the following:

  • Review of the licensees outage plan prior to the outage
  • Monitoring of shut-down and cool-down activities
  • Verification that the licensee maintained defense-in-depth during outage activities
  • Monitoring of heat-up and startup activities

These activities constitute completion of one planned outage sample outage activities

sample, as defined in Inspection Procedure 71111.20.

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors observed six risk-significant surveillance tests and reviewed test results

to verify that these tests adequately demonstrated that the SSCs were capable of

performing their safety functions:

In-service tests:

Reactor Coolant System Leak Detection:

Other surveillance tests:

  • March 28-29, 2014, train A engineered safety features actuating safety testing
  • April 25-28, 2014, station blackout diesel functional testing
  • May 6, 2014, containment closeout walkdown

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The inspectors verified that these tests met technical specification requirements, that the

licensee performed the tests in accordance with their procedures, and that the results of

the test satisfied appropriate acceptance criteria.

These activities constitute completion of six surveillance testing inspection samples, as

defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on June 18, 2014, to verify

the adequacy and capability of the licensees assessment of drill performance. The

inspectors reviewed the drill scenario, observed the drill from the simulator and

emergency operations facility, and attended the post-drill critique. The inspectors

verified that the licensees emergency classifications, off-site notifications, and protective

action recommendations were appropriate and timely. The inspectors verified that any

emergency preparedness weaknesses were appropriately identified by the licensee in

the post-drill critique and entered into the corrective action program for resolution.

These activities constitute completion of one emergency preparedness drill observation

sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

2 RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation (71124.05)

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring

equipment used by the licensee (1) to monitor areas, materials, and workers to ensure a

radiologically safe work environment, and (2) to detect and quantify radioactive process

streams and effluent releases. The inspectors interviewed licensee personnel, walked

down various portions of the plant, and reviewed licensee performance in the following

areas:

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  • Selected plant configurations and alignments of process, post-accident, and

effluent monitors with descriptions in the Final Safety Analysis Report and the

offsite dose calculation manual

  • Select instrumentation, including effluent monitoring instrument, portable survey

instruments, area radiation monitors, continuous air monitors, personnel

contamination monitors, portal monitors, and small article monitors to examine

their configurations and source checks

  • Calibration and testing of process and effluent monitors, laboratory

instrumentation, whole body counters, post-accident monitoring instrumentation,

portal monitors, personnel contamination monitors, small article monitors,

portable survey instruments, area radiation monitors, electronic dosimetry, air

samplers, and continuous air monitors

  • Audits, self-assessments, and corrective action documents related to radiation

monitoring instrumentation since the last inspection

These activities constitute completion of one sample of radiation monitoring

instrumentation as defined in Inspection Procedure 71124.05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

a. Inspection Scope

The inspectors evaluated whether the licensee maintained gaseous and liquid effluent

processing systems and properly mitigated, monitored, and evaluated radiological

discharges with respect to public exposure. The inspectors verified that abnormal

radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors

are out-of-service, were controlled in accordance with the applicable regulatory

requirements and licensee procedures. The inspectors verified that the licensees

quality control program ensured radioactive effluent sampling and analysis adequately

quantified and evaluated discharges of radioactive materials. The inspectors verified the

adequacy of public dose projections resulting from radioactive effluent discharges. The

inspectors interviewed licensee personnel and reviewed or observed the following items:

  • Radiological effluent release reports since the previous inspection and reports

related to the effluent program issued since the previous inspection

  • Effluent program implementing procedures, including sampling, monitor setpoint

determinations, and dose calculations

  • Equipment configuration and flow paths of selected gaseous and liquid discharge

system components, filtered ventilation system material condition, and significant

changes to their effluent release points, if any, and associated 10 CFR 50.59

reviews

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  • Selected portions of the routine processing and discharge of radioactive gaseous

and liquid effluents (including sample collection and analysis)

  • Controls used to ensure representative sampling and appropriate compensatory

sampling

  • Results of the inter-laboratory comparison program
  • Effluent stack flow rates
  • Surveillance test results of technical specification-required ventilation effluent

discharge systems since the previous inspection

  • Significant changes in reported dose values
  • A selection of radioactive liquid and gaseous waste discharge permits
  • Part 61 analyses and methods used to determine which isotopes are included in

the source term

  • Meteorological dispersion and deposition factors
  • Latest land use census
  • Records of abnormal gaseous or liquid tank discharges
  • Groundwater monitoring results
  • Changes to the licensees written program for identifying and controlling

contaminated spills/leaks to groundwater

if any, and associated evaluations of the extent of the contamination and the

radiological source term

  • Offsite notifications and reports of events associated with spills, leaks, or

groundwater monitoring results

  • Audits, self-assessments, reports, and corrective action documents related to

radioactive gaseous and liquid effluent treatment since the last inspection

These activities constitute completion of one sample of radioactive gaseous and liquid

effluent treatment, as defined in Inspection Procedure 71124.06.

b. Findings

No findings were identified.

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2RS7 Radiological Environmental Monitoring Program (71124.07)

a. Inspection Scope

The inspectors evaluated whether the licensees radiological environmental monitoring

program quantified the impact of radioactive effluent releases to the environment and

sufficiently validated the integrity of the radioactive gaseous and liquid effluent release

program. The inspectors verified that the radiological environmental monitoring program

was implemented consistent with the licensees technical specifications and offsite dose

calculation manual, and that the radioactive effluent release program met the design

objective in Appendix I to 10 CFR Part 50. The inspectors verified that the licensees

radiological environmental monitoring program monitored non-effluent exposure

pathways, was based on sound principles and assumptions, and validated that doses to

members of the public were within regulatory dose limits. The inspectors reviewed or

observed the following items:

  • Selected air sampling and dosimeter monitoring stations
  • Collection and preparation of environmental samples
  • Operability, calibration, and maintenance of meteorological instruments
  • Selected events documented in the annual environmental monitoring report

which involved a missed sample, inoperable sampler, lost dosimeter, or

anomalous measurement

  • Selected structures, systems, or components that may contain licensed material

and has a credible mechanism for licensed material to reach ground water

as the result of changes to the land census or sampler station modifications since

the last inspection

  • Calibration and maintenance records for selected air samplers, composite water

samplers, and environmental sample radiation measurement instrumentation

  • Inter-laboratory comparison program results
  • Audits, self-assessments, reports, and corrective action documents related to the

radiological environmental monitoring program since the last inspection

These activities constitute completion of one sample of the radiological environmental

monitoring program as defined in Inspection Procedure 71124.07.

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b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensees programs for processing,

handling, storage, and transportation of radioactive material. The inspectors interviewed

licensee personnel and reviewed the following items:

scope of the licensees audit program

  • Control of radioactive waste storage areas including container labeling/marking

and monitoring containers for deformation or signs of waste decomposition

  • Changes to the liquid and solid waste processing system configuration including

a review of waste processing equipment that is not operational or abandoned in

place

  • Radio-chemical sample analysis results for radioactive waste streams and use of

scaling factors and calculations to account for difficult-to-measure radionuclides

  • Processes for waste classification including use of scaling factors and

10 CFR Part 61 analysis

  • Shipment, packaging, surveying, labeling, marking, placarding, vehicle checking,

driver instructing, and preparation of the disposal manifest

  • Audits, self-assessments, reports, and corrective action reports on radioactive

solid waste processing and radioactive material handling, storage,

and transportation performed since the last inspection

These activities constitute completion of one sample of radioactive solid waste

processing, and radioactive material handling, storage, and transportation as defined in

Inspection Procedure 71124.08.

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

Security

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4OA1 Performance Indicator Verification (71151)

.1 Reactor Coolant System Specific Activity (BI01)

a. Inspection Scope

The inspectors reviewed the licensees reactor coolant system chemistry sample

analyses for the period of April 1, 2013, through March 31, 2014, to verify the accuracy

and completeness of the reported data. The inspectors reviewed the surveillance

paperwork for the reactor coolant system sample taken on May 19, 2014. The

inspectors used definitions and guidance contained in Nuclear Energy Institute

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,

to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system specific activity

performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Reactor Coolant System Identified Leakage (BI02)

a. Inspection Scope

The inspectors reviewed the licensees records of reactor coolant system identified

leakage for the period of April 1, 2013 through March 31, 2014 to verify the accuracy and

completeness of the reported data. The inspectors reviewed the performance

of STS BB-006 RCS Water Inventory Balance on May 31, 2014. The inspectors used

definitions and guidance contained in Nuclear Energy Institute Document 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the

accuracy of the reported data.

These activities constituted verification of the reactor coolant system leakage

performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152)

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items

entered into the licensees corrective action program and periodically attended the

licensees condition report screening meetings. The inspectors verified that licensee

personnel were identifying problems at an appropriate threshold and entering these

problems into the corrective action program for resolution. The inspectors verified that

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the licensee developed and implemented corrective actions commensurate with the

significance of the problems identified. The inspectors also reviewed the licensees

problem identification and resolution activities during the performance of the other

inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

To verify that the licensee was taking corrective actions to address identified adverse

trends that might indicate the existence of a more significant safety issue, the inspectors

reviewed corrective action program documentation associated with the following

licensee-identified trends:

  • High backlogs in the design implementation and configuration control process

area

Also, the inspectors identified the following trends that might indicate the existence of a

more significant safety issue, and reviewed the licensees response to them:

  • Inadequate technical verification and validation of temporary and permanent

plant modifications

  • The licensees corrective action program group is not trending data at a station-

wide level (i.e., above the department level), nor are they prioritizing

departmental issues and trends which are significantly affecting overall station

performance

The NRC identified a theme in NRC inspection findings with cross-cutting aspects in

maintaining design margins [H.6] during the 2013 End Of Cycle Assessment. The

inspectors reviewed the licensees response to that trend to verify that the licensee was

taking appropriate actions to address it.

These activities constitute completion of one semiannual trend review sample, as

defined in Inspection Procedure 71152.

b. Observations and Assessments

The inspectors review of the trends identified above produced the following observations

and assessments:

  • Design Control Backlogs. In July of 2013, an industry group assessment of

station performance noted an unusually high number of open design change

packages. The backlog included approximately 1700 change packages, some

open since the early 1990s, including some SSCs with multiple open design

changes. Some change packages had targeted completion dates that were

- 15 -

beyond the expiration date of the plant operating license. Historically, the station

has had challenges with design control, as noted in NRC inspection reports.

The licensee performed an apparent cause evaluation under Condition

Reports 72164, 72166, and 72167 to identify the organizational causes. Among

the licensees conclusions, management oversight of configuration control was

lacking, there was not an awareness of the vulnerability created by incomplete

configuration changes, and there was no single owner of design change products

to ensure configuration management documents are kept up to date. The

licensee took corrective actions to develop a configuration management health

plan to improve the design control program as well as developing a

comprehensive backlog reduction strategy. The inspectors also noted that the

licensee performed an aggregate risk assessment of the backlog to ensure that

items with more significant safety impacts were addressed more quickly. The

inspectors also noted that the backlog reduction program has reduced the

number of open change packages to 400 at the end of June 2014, with a goal of

less than 200 planned by January 2015.

  • Findings with Design Margins Cross Cutting Aspect [H6]. A theme in findings

with cross-cutting aspects in the area of maintaining design margins was

identified during the NRCs 2013 End of Cycle Assessment for Wolf Creek. The

licensee performed an apparent cause evaluation under Condition

Reports 74508 and 78794. The inspectors noted that this trend was related to

the larger problem of backlog management. Because this trend is related to

other improvement efforts, the inspectors noted that the licensee has evaluated

and taken actions related to this theme in the areas of corrective action,

preventive maintenance, and procedure revision backlog reductions under

Condition Reports 62394, 68194, and 78708. Most of the backlog improvement

efforts were making a notable reduction. The inspectors observed that most

backlog reduction efforts remained on target through the mid-cycle 20 outage in

March and April of 2014. Overall outage management and scope control

performance improvement was observed, and as a result, the corrective action

and work order backlogs did not see the growth observed during previous

outages. The licensee has taken corrective actions to establish and validate new

internal performance indicators for the engineering and maintenance

departments. Furthermore the licensee has scheduled actions to track these

new indicators and backlogs to specific goals based on industry standards in the

future.

Also, while completing this trend review, the inspectors identified the following trends

that the licensee had not previously identified. The inspectors also reviewed the

licensees response to these trends:

  • Quality of Plant Modifications. Over the past 2 years, Wolf Creek has been

implementing a large number of modifications. Additional non-safety related

diesel generators and an auxiliary feed water pump were added to improve plant

safety. The plant has also been addressing long standing corrosion and water

hammer issues in the essential service water system by replacing piping above

and below ground. Obsolete analog controllers have been replaced with digital

control systems. However, the inspectors have observed a number of plant

events and equipment failures associated with inadequate technical validation

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and verification associated with these modifications.

On May 2, 2013, an unplanned and uncontrolled 11 percent power

increase occurred as a result of operator training deficiencies while

swapping from the full arc to partial arc steam admission shortly after

installing the new Westinghouse Ovation digital turbine controls. It was

subsequently determined that additional functions and flexibilities of the

new digital control system allowed operators to manipulate the plant in

configurations prohibited by the old analog system, and that system

response varied with power level, but this was not recognized and

incorporated into procedures and training. Condition Report 68711,

Non-Cited Violation NCV 05000482/2013003-05.

On May 28, 2013, and again on September 5, 2013, the turbine driven

auxiliary feed water pump control system failed unexpectedly, rendering

the pump incapable of operation. The digital control system positioner

locked up and required replacement. It was later determined that an

additional unused input to the positioner was experiencing noise, and if

the noise came in at a certain point in the digital computer programs

subroutine, the control software would crash. The problem was fixed by

jumpering out the unused input connection and a vendor technical bulletin

was issued to correct vulnerabilities at other nuclear power plants utilizing

the same control system. Condition Reports 69721, 69754, and 73624.

On April 25, 2014, during station blackout diesel generator testing, the

licensee was unable to connect the train A Class 1E 4kV distribution bus

to the station blackout diesel generators due to a protective relay

actuating to lock out the bus. The diesels had been declared functional

and were credited in performance indicators and probabilistic risk

assessment models since October 2013, when construction was

completed but testing had not been fully completed. Troubleshooting as a

result of the failed test found incorrect wiring of a protective relay to be

the cause. Extent of condition inspections found that the train B bus

connection was also wired incorrectly, and neither safety related bus

would have been able to have been powered from the station blackout

diesel generators. The licensee had intended to perform testing during

the previous refueling outage, but construction delays caused work to

extend beyond the outage. Plant conditions for this test necessitated the

plant be shut down. The inspectors had engaged the licensee concerning

their testing plan when construction was complete, but the licensee

concluded that their quality checks were adequate to have a high

confidence that testing to connect the generators to the safety buses

would be adequate until plant conditions for the testing were available.

The inspectors concluded that those quality checks were inadequate,

although this did not constitute a violation because the diesel generators

and protective relaying were non-safety equipment and were not credited

to meet any regulatory requirements. Condition Report 83379.

- 17 -

Not all of the validation and verification oversights resulted in plant events or

failures. Some of the items were caught very late in the planning process,

but still impacted regulatory commitments.

In February of 2014 the licensee commitment to correct long standing

water hammer conditions in the essential service water system was

delayed. The 2010 and 2012 Problem Identification and Resolution

inspections have assessed cited violations regarding long-standing

essential service water corrosion and water hammer issues not being

addressed in a timely manner. Wolf Creek responded on the docket and

committed to fixing the essential service water corrosion and water

hammer issues by the spring 2014 mid-cycle outage. However, after

over 3 years of planning, shortly before a modification was to be installed

to correct the water hammer, it was discovered that the mitigating strategy

would invalidate the essential service water design basis safety function

to provide a source of auxiliary feed water during a design basis external

event that compromises the condensate storage tank. This was

documented in Condition Reports 53443 and 79619. The licensee

concluded that there was inadequate contractor oversight during the

modification development process. A revised modification was tentatively

rescheduled for the next refueling outage.

On March 30, 2014, a containment cooler tube bundle failed (small tube

leaks) as a result of water hammer during the engineered safety features

actuation system testing. A similar failure occurred when the opposite

train was tested a few weeks later. While reviewing the cause evaluation,

the inspectors noted the failure mechanism was due to a combination of

pitting corrosion and sudden pressure spike during the essential service

water system water hammer. The ispectors determined that corrective

actions to address corrosion in carbon steel essential service water piping

had not addressed the copper-nickel containment cooler tubes. The

inspectors reviewed the history of containment cooler degradation and

noted that all 48 of the tube bundles had already been replaced due to

widespread degradation in the late 1990s, and now the 2nd generation

like-for-like replacements were beginning to fail. The problem was further

complicated because non-destructive testing to monitor corrosion was not

possible because the cooler design and complex cooler geometry

prevented this. The licensee plans to correct the condition by replacing

all coolers dueing the next outage, then replacing the original design with

stainless steel cooler tubes that will allow for eddy current testing.

Condition Reports 81809 and 82904.

On November 18, 2011, an NRC Component Design Basis Inspection

assessed NCV 05000482/2010007-01 for the failure to properly analyze

the isolation between the safety-related and non-safety related portions of

the component cooling water system. Portions of the non-safety piping

leading to the rad waste building are non-seismically qualified, and should

they fail, could result in a loss of inventory greater than can be

accommodated by the component cooling water surge tanks. The

inspector noted that the licensee promptly manually isolated this piping

and has been working on installing a combination of check valves and

- 18 -

orifices, for the past four years. The planned modification to correct this

violation has been delayed a number of times since 2012 because the

licensee has found problems with the design. Condition Reports 28237

and 85328.

The inspectors determined that the licensee was aware of these issues

individually, but had not identified the collective trend. The licensee wrote

Condition Report 85907 to evaluate and address this trend.

  • Lack Trending and Prioritization above the Department Level. In reviewing the

station roll-up reports that record corrective action program activities at the

station and departmental levels, the inspectors noted that the analytical trending

ends at the departmental summaries. The station corrective action staff was not

summarizing analytical trends across divisions, nor were they giving additional

priority to departmental trends which were having a significant impact on station

performance. (e.g. design control, procedure quality, etc.)

The inspectors reviewed additional documentation associated with station

improvement initiatives and determined that at a station level, senior leadership

was performing some station level trend analysis and setting station priorities

based on the available data, but this was being done outside the corrective

action program, and was not proceduralized and therefore would not continue

when the improvement initiatives were completed. The licensee has written

Condition Report 85905 to evaluate and address this issue.

The inspectors assessment noted improved corrective action trending at the

department level. The operations department continues to be a station leader in

this area. The maintenance and engineering departments have made notable

advancements in the past year to improve the quality of their corrective action

program work products. The inspectors have also witnessed a significant

improving trend in the quality, detail, and technical rigor, of apparent cause

evaluations and root cause analyses performed by station personnel.

c. Findings

No findings were identified.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected one issues for an in-depth follow-up:

  • On May 1, 2014, below ground essential service water piping replacement to

correct long standing corrosion issues.

The inspectors assessed the licensees problem identification threshold, cause

analyses, extent of condition reviews and compensatory actions. The inspectors

reviewed modifications paperwork and observed pipe fitting and welding activities

in the field. The inspectors verified that the licensee appropriately prioritized the

- 19 -

planned corrective actions and that these actions were adequate to correct the

condition.

These activities constitute completion of one annual follow-up sample as defined in

Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On June 5, 2014, the inspectors presented the results of the radiation safety inspection to

Mr. C. Reasoner, Engineering, Vice President, and other members of the licensee staff. The

licensee acknowledged the issues presented. The licensee confirmed that any proprietary

information reviewed by the inspectors had been returned or destroyed.

On July 8, 2014, the inspectors presented the inspection results to Mr. A. Heflin, Chief Executive

Officer, and other members of the licensee staff. The licensee acknowledged the issues

presented. The licensee confirmed that any proprietary information reviewed by the inspectors

had been returned or destroyed.

- 20 -

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

L. Aiken, Health Physicist II

D. Campbell, Superintendent, Electrical Maintenance

C. Carman, Supervisor, Chemistry

S. Carpenter, Technician, Instruments and Controls

B. Crow, System Engineering

D. Dees, Superintendent, Operations Support

D. Erbe, Manager, Security

R. Flannigan, Manager, Nuclear Engineering

K. Fredrickson, Engineer, Licensing

J. Freeman, Supervisor, Operations

C. Garcia, Supervisor, Engineering

D. Gibson, Technician, Radiation Protection

M. Guyer, Training

R. Hammond, Supervisor, Regulatory Support

A. Heflin, President and Chief Executive Officer

S. Henry, Manager, Integrated Plant Scheduling

P. Herrman, Manager, Programs Engineering

R. Hobby, Licensing Engineer

S. Hossain, Engineer, System Engineering

B. Kiley, Technician III, Chemistry

S. Koenig, Manager, Regulatory Affairs

R. Lane, Superintendent, Operations

M. McMullen, Design Engineer, Engineering

C. Medenciy, Supervisor, Radiation Protection

K. Miller, Technician Level III, Instruments and Controls

K. Mitchell, Master Chemistry Technician

W. Muilenburg, Supervisor, Licensing

T. Rice, Manager, Environmental Management

D. Scrogum, Systems Engineer, Engineering

M. Skiles, Acting Manager, Radiation Protection

R. Smith, Site Vice President

S. Smith, Plant Manager

T. Smith, Manager, Project Construction Engineering

J. Truelove, Supervisor, Chemistry

L. Upson, Manager, Strategic Initiatives

B. Vickery, Manager, Financial Services

J. Yunk, Manager, Corrective Actions

Attachment 1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000482-2014003- NCV Failure to Assess and Manage Risk of Planned Outage

01 Maintenance Activities During Solid Plant Operations

(Section 1R13)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

Number Title Revision

STS NB-005 Breaker Alignment Verification 26

Section 1R04: Equipment Alignment

Procedures

Number Title Date

CKL EM-120 Safety Injection System Lineup Checklist September

17, 2014

Section 1R05: Fire Protection

Procedures

Number Title Revision

AP 10-106 Fire Preplans 13

Section 1R11: Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number Title Revision

BD-EMG C-0 Loss of All AC Power 20

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

Number Title Revision/Date

AI 22C-013 Protected Equipment Program 11

A1-2

Procedures

Number Title Revision/Date

AP 22B-001 Outage Risk Management 17

AP 21D-002 Evaluation for Potential Energy/Fluid Transfer Paths 11A

APF 22B-001-10 Shutdown Safety Function Status and Risk Assessment March 14,

Summary 2014 Night

Shift

APF 22B-001-10 Shutdown Safety Function Status and Risk Assessment April 1, 2014

Summary Day Shift

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment, May 28, 2014

Schedule Week 2014-0211

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment June 11,

Schedule Week 2014-0212 2014

SYS PG-204 Energizing PG19 or PG20 from Alternate Power Source 21

TMP 14-002 CCW Train B Operations with Heat Exchanger Bypassed 0

Condition Reports

80870 81981

Work Order

12-359936-000 12-359637-000

Miscellaneous

Number Title Revision/Date

ODM 2014-05 Operations Decision Making Documentation Form: Wolf 0

Creek will maintain solid pressurizer conditions with reduced

temperature and pressure control bands.

APF 22C-007 Shutdown Safety Contingency Planning Template: Decay 1

Heat Removal Defense in Depth

M-EJ-A-001 Clearance Order: RHR to CVCS Centrifugal Charging April 2, 2014

Pumps Isolation Valve

Work Week Manager Logs

Control Room Logs

Weekly Major Activity Summary Week 2014-208

Weekly Major Activity Summary Week 2014-211

Weekly Major Activity Summary Week 2014-212

A1-3

Miscellaneous

Number Title Revision/Date

Wolf Creek Shift Outage Update March 13,

2014 Day Shift

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

Number Title Revision

OE K-14-009 B-EDG Governor Hydraulic Actuator 0

STS IC-208A 4kV Loss of Voltage and Degraded Voltage TADOT NB01 5B

Bus - Separation Group 1

Condition Reports

85015 81809 82266 84318

Engineering Disposition

Title Revision

Containment Cooler Tube Pitting 1

Section 1R19: Post-Maintenance Testing

Procedures

Number Title Revision/Date

STN EF-220A ESW Train A Post-LOCA Flow Balance March 4, 2014

SYS BB-201 Reactor Coolant Pump Operation 58

SYS KJ-123-2 Post Maintenance Run of EDG A January 30,

2014

Work Orders

14-385808-006 11-347436-002 14-387407-002 14-386517-001

A1-4

Section 1R20: Refueling and Other Outage Activities

Procedures

Number Title Date

NE 14-0005 Mid-Cycle 20 Level 1 Schedule and Outage Risk February 6,

Assessment Report 2014

Section 1R22: Surveillance Testing

Procedures

Number Title Revision/Date

STS BB-006 RCS Water Inventory Balance Using the NPIS Computer 12

STS CH-024 Reactor Coolant Dose Equivalent Xe-133 Determination 6A

STS IC-208A 4kv Loss of Voltage and Degraded Voltage TADOT NB01 5B

Bus - Separation Group 1

STS KJ-001A Integrated D/G and Safeguards Actuation Text Train A March 14, 2014

STN KU-001A SBO DG NB01 Functional Test March 28, 2014

STN EJ-002 Containment Inspection 20

Section 2RS5: Radiation Monitoring Instrumentation

Procedures

Number Title Revision/Date

CHS AC-001 Accident Sampling 4A

WCIC-236 RMS Calibration Document November 13,

1995

STN SP-118 Channel Calibration Liquid Radwaste Discharge Radiation 8

Monitor HB RE-0018

STN CH-010 Calibration of Liquid Radiation Monitors 3B

STS CH-014 Calibration of Monitors GTRE21B and GHRE10B 12

STN CH-021 Calibration of the Particulate Detector for Radiation Monitors 4A

GTRE21A and GHRE10A

STN CH-022 Calibration of the Iodine Detector for Radiation Monitors 1B

GTRE21A and GHRE10B

AP 07B-003 Offsite Dose Calculation Model 8

RPP 01-405 HP Instrument Program 30

A1-5

Procedures

Number Title Revision/Date

RPP 03-407 Testing of Portal Monitors as Passive Whole Body Counters 1A

RPP 05-707 Operation of Whole Body Counters 8

RPP 06-101 Eberline RO-2 and RO-2A Calibration 6

RPP 06-105 Eberline RO-20 Calibration 5

RPP 06-306 PM12 Calibration 8A

STN SP-118 Channel Calibration Liquid Radwaste Discharge Radiation 8

Monitor HB RE-0018

STN CH-010 Calibration of Liquid Radiation Monitors 3B

Condition Reports

00081759 00084854 00084863 00084815 00084820

00084817 00083254 00082997 00080994 00079621

00078962 00078548 00074873 00074445 00074219

00072691 00072303 00068426 00068295 00068064

00051785 00054489 00065431 00067627 00062921

Calibration Records

Number Title Date

WO12360791000 Channel Calibration Digital High Range Area Monitor February 4,

GTRE-0059 Calibration Source Drop 2014

WO13381072000 Channel Calibration Digital High Range Area Radiation January 28,

Monitor GTRE60 2014

WO12360792000 Channel Calibration Digital High Range Area Radiation February 3,

Monitor GTRE60 Calibration Source Drop 2014

WO13381018000 Channel Calibration Digital High Range Area Radiation January 24,

Monitor GTRE59 2014

11428 AMS4 March 9, 2014

11748 AMS4 March 9, 2014

11429 AMS4 February 24,

2014

A1-6

11376 PCM-1B February 5,

2009

11379 PCM-1B February 5,

2009

11378 PCM-1B April 17, 2014

10240 PCM-1C April 9, 2009

11005 SAM 11 January 29,

2014

11006 SAM 11 June 19, 2013

92874 RTM 110 March 23,

2014

92877 RTM 110 April 28, 2014

10260 ASP-1 February 6,

2014

93330 PM12 August 15,

2013

93573 PM12 February 5,

2014

11511 HD-29A January 29,

2014

10242 PCM-2 December 9,

2013

10066 Whole Body Counter Calibration Certificate July 18, 2011

13027 Whole Body Counter Calibration Certificate September 15,

2008

Section 2RS6: Radioactive Gaseous and Liquid Effluent Treatment

Procedures

Number Title Revision

AI 07-007 Onsite Groundwater Protection Program Monitoring 14

AI 07B-001 Radioactive Releases 19

AI 07B-020 Instructions for Composite Preparation 19

AI 07B-036 Liquid Release Permits Using RADEAS 01

AI 07B-037 Unit and Radwaste Vent Permits Using RADEAS 01

AI 07B-038 Unit and Radwaste Vent Permits Using RADEAS 01

A1-7

Procedures

Number Title Revision

AP 07B-003 Offsite Dose Calculation Manual 08

CHA RC-004 Gamma Isotopic, Total Curie Content and Dose Equivalent 15

Iodine Determination

CHS RW-G02 Radwaste Vent Sampling and/or Exchange of Filters 3C

CHS SJ-144A SJ-144 Sampling Instructions 0C

CHS TB-L03 Turbine Building Local Sampling - Mid-Frequency 06

RPP 07-111 Handling Cartridge Filters 17

Condition Reports

00051966 00053930 00055466 00055535 00055538

00056233 00056574 00056887 00059243 00059832

00061757 00064627 00064667 00064798 00065779

00066655 00066920 00068803 00069832 00069959

00070420 00070826 00072303 00076226 00077621

00077802 00078707 00082909 00083740 00084346

10 CFR 50.75(g) Condition Reports

00084942

Gaseous and Liquid Release Permits

Permit No. System Release Type Date

U1LC2014-080/2013060 Turbine Building Drains Liquid June 11, 2013

U1GB2014-093/2013081 Containment Purge Unit Vent Gaseous July 17, 2013

U1GB2014-099/2013087 Containment Purge Unit Vent Gaseous July 27, 2013

U1LC2014-091/2013071 Steam Generator Blowdown Liquid August 30, 2013

U1LC2014-110/2013090 Lime Sludge Pond Liquid November 19, 2013

U1GB2014-017/2014017 Containment Purge Unit Vent Gaseous February 4, 2014

U1LC2014-005/2014005 Steam Generator Blowdown Liquid March 1, 2014

U1GB2014-162/2014162 Containment Purge Unit Vent Gaseous April 7, 2014

A1-8

In-Place Filter Testing Records

Work Order Test Date

STS PE-006 Charcoal Adsorber In-Place Leak Test Safety-Related Units December 10,

- FGK01B 2013

STS PE-005 HEPA Filter In-Place Leak Test Safety-Related Units - December 10,

FGK01B 2013

STS PE-002 Charcoal Adsorbent Sampling for Nuclear Safety-Related December 23,

Units - FGK01B 2013

STS PE-002 Charcoal Adsorbent Sampling for Nuclear Safety-Related December 23,

Units - FGG02B 2013

STS PE-006 Charcoal Adsorber In-Place Leak Test Safety-Related Units February 24,

- FGK01A 2014

STS PE-005 HEPA Filter In-Place Leak Test Safety-Related Units - February 24,

FGK01A 2014

Miscellaneous Documents

Number Title Revision/Date

11.1A-3 USAR Figure: Potential Gaseous Release 13

M-12HB01-5 WCNOC PID: Liquid Radwaste System 20

M-12EG01 WCNOC PID: Component Cooling Water System 24

System Health Report: Radiation Monitoring January 1 -

September

30, 2013

RA 13-0052 WCNOC 2013 Annual Radioactive Effluent Release

Report

RPF 02-210-05 50.75(g) Radiological Occurrence Worksheet for June 2, 2014

Decommissioning Record

2013-011-EG00 Temporary Modification Order: EG System (A/B Trains), August 19,

EGV0357 & EGV0310, EGV0324 & EGV0388 2013

RA 14-0043 WCNOC 2014 Annual Radioactive Effluent Release April 29, 2014

Report

WC Radiation Monitors Considered for Maintenance Rule June 2, 2014

Section 2RS7: Radiological Environmental Monitoring Program

Procedures

Number Title Revision

AI 07B-004 Reporting Requirements of the Radiological 13

Environmental Monitoring Program

A1-9

Procedures

Number Title Revision

AI 07B-005 Radiological Environmental Monitoring Program 20

Implementation

AI 07B-009 Collection, Preparation and Shipment of Sediment and 8

Soil Samples

AI 07B-011 Collection, Preparation and Shipment of Water Samples 15

AI 07B-012 Collection, Preparation and Shipment of Crop, 10

Vegetable, Fruit and Pasturage Samples

AI 07B-015 Land Use Census 11

AI 07B-034 Radiological Environmental Monitoring Program Air 11

Sampling

AI 07B-035 REMP Optically Stimulated Luminescence (OSL) 6

Dosimeters

AP 07B-003 Offsite Dose Calculation Manual 8

AP 07B-004 Offsite Dose Calculation Manual (Radiological 20

Environmental Monitoring Program)

AP 07B-005 Ground Water Protection Program 3

AP 07E-001 Validation of Meteorological Data 3

STN CH-024 Quarterly/Yearly Dose Projections 3

STS IC-890A Channel Calibration of Wind Speed Meteorological 17

Instrumentation

STS IC-890B Channel Calibration of Wind Direction/Deviation 17

Meteorological Instrumentation

STS IC-890C Channel Calibration of 10M/60M Ambient and 20

Differential Temperature Instrumentation

STS IC-890D Channel Calibration of Sonic Wind 2

Speed/Direction/Deviation Meteorological

Instrumentation

Audits, Self-Assessments, and Surveillances

Number Title Date

QH-2013-0654 NUPIC Audit Report of Landauer, Inc. December 16,

2013

11-2049 Evaluation Report of F&J Specialty Products, Inc. January 13,

2013

SQL 13-44 Evaluation Report of Landauer, Inc. - Glenwood, IL October 11,

2013

QH-2013-0660 Ground Water Protective Initiative 5-Year Follow-up December 16,

Assessment 2013

A1-10

Audits, Self-Assessments, and Surveillances

Number Title Date

Audit Report No: Quality Assurance Audit Report of Environmental April 17, 2014

14-03-ENV Management Plans

Condition Reports

00051888 00052766 00054626 00070866 00082043

00083302 00084016 00084879 00084901 00084915

00084919 00084920

Calibration And Maintenance Records

Number Title Date

WO 13-375743 Surveillance Test Routing Sheet: Channel Calibration of April 20, 2014

60m 10m Differential Temperature

WO 13-375744 Surveillance Test Routing Sheet: Channel Calibration of April 6, 2014

Wind Speed

WO 13-375741 Surveillance Test Routing Sheet: Channel Calibration of April10, 2014

Wind Direction

WO 13-375742 Surveillance Test Channel Calibration of Sonic Wind April 6, 2014

Speed/Direction/Deviation

Miscellaneous Documents

Number Title Date

SA-10-004 Relative Deposition per Unit Area (D/Q) 3 Year Update November 2,

(2007-2009) 2010

2012 Annual Radiological Environmental Operating Report April 27, 2013

2013 Annual Radiological Environmental Operating Report April 15, 2012

QH-2011-0016 REMP Review of 2010 Wind Direction August 31,

2011

QH-2012-0242 REMP Review of 2011 Wind Direction July 30, 2012

QH-2013-0016 REMP Review of 2012 Wind Direction August 14,

2011

A1-11

Section 2RS8: Radioactive Solid Waste Processing and Radioactive Material Handling,

Storage, and Transportation

Procedures

Number Title Revisions

AP 31A-100 Solid Radwaste Process Control Program 7 and 8

RPP 07-110 Solid Radwaste Packaging 9

RPP 07-111 Handling Filter Cartridges 17 and 18

RPP 07-112 Processing Cartridge Filters 5

RPP 07-131 Bead Resin/Activated Carbon Dewatering Procedures for 4

CNSI 14-215 or Smaller Liners

RPP 07-212 Requirements of Radioactive Materials Stored Outdoors 0

Audits and Self-Assessments

Number Title Date

QS-2014-0629 Quality Surveillance performed on the Radwaste Group by February 26,

WCNOC and Tech Specialist from Nine Mile Point 2014

Condition Reports

00051881 00056346 00056839 00062522 00066895

00066920 00073358 00079817 00081750 00081752

00084772 00084856 00084857 00084880 00084932

00084951

Radiation Work Permits

Number Title Revision

13-0121 ALARA Review Package 1

130121 Cartridge Filter Change-out 000

130121 Cartridge Filter Change-out 001

130121 Cartridge Filter Change-out 002

140029 Resin Transfer to Primary Spent Resin Storage Tank 000

(THC08)

A1-12

Radioactive Material Shipments

Number Title Revision

12R26 Radioactive Material LSA-I; UN 2912 1

13R30 Radioactive Material LSA-II; UN 3321 000

13R49 Radioactive Material LSA-II; UN 3321 001

14R18 Radioactive Material LSA-II; UN 3321 002

12R26 Radioactive Material LSA-I; UN 2912 000

Radioactive Waste Stream Characterization

Number Title Date

7 Primary Resin (CVCS, SFP) April 15, 2013

7 Primary Resin (CVCS, SFP) January 23,

2014

13 Dry Active Waste April 19, 2012

13 Dry Active Waste March 4, 2014

Miscellaneous Documents

Number Title Date

Access Control Shift Log (01:25 to 17:39) April 1, 2013

Filter Characterization Reports August 20,

(13F044, 13F046, 13F047, 13F048, 13F049, 13F051, 13F052, 2013

13F053, 13F055, 13F058, 13F059, 13F060, 13F061, 13F097)

13-063ES Characterization and Classification of Wolf Creek Excore May 31, 2013

Detectors

36 Annual Radioactive Effluent Release Report January 1,

2012 -

December 31,

2012

37 Annual Radioactive Effluent Release Report January 1,

2013 -

December 31,

2013

HW12158 Training Course Regulations and Requirements January 11,

01 2010

OTSC 13- On the Spot Change to RPP 07-111 Rev 17 April 3, 2013

0056

A1-13

Miscellaneous Documents

Number Title Date

RPF 07- Filter Information Log April 3, 2014

111-01

RPF 07- Radioactive Shipment Log 2012

123-01

RPF 07- Radioactive Shipment Log 2013

123-01

RPF 07- Radioactive Shipment Log 2014

123-01

Section 4OA2: Problem Identification and Resolution

Procedures

Number Title Revision

AP 05-005 Design, Implementation, and Configuration Control of 20

Modifications

AP 05-010 Design Drawings 9

AP 05F-001 Design Verification 3A

Condition Reports

79619 53443 82904 70384 70383

69721 69754 73624 71624 74508

78794 72166 72164 72167 68194

62394 78708

Miscellaneous

Number Title Revision/Date

WM 14-0011 Letter from Wolf Creek Nuclear Operating Corp. to U.S.NRC: May 8, 2014

Docket No. 50-482: Change to Essential Service Water System

Water Hammer Mitigation Commitment

WM 14-0013 Letter from Wolf Creek Nuclear Operating Corp. to U.S.NRC: May 8, 2014

Docket No. 50-482: Voluntary Commitment Regarding

Containment Coolers at Wolf Creek Generating Station

A1-14

Miscellaneous

Number Title Revision/Date

Wolf Creek Corrective Action Program Station Roll-Up March 6, 2014

Performance Results 4th Quarter 2013

Wolf Creek Corrective Action Program Station Roll-Up June 6, 2014

Performance Results 1st Quarter 2014

Wolf Creek Rebuilding Plan June 6, 2014

Engineering Excellence Plan - Product Quality Strategic Area 00

Wolf Creek Change Management Plan - Engineering Technical September 5,

Rigor Improvement 2013

A1-15

The following items are requested for the

Public Radiation Safety Inspection

Wolf Creek Generating Station

June 2 through June 6, 2014

Integrated Report 2014003

Inspection areas are listed in the attachments below.

Please provide the requested information on or before May 19, 2014.

Please submit this information using the same lettering system as below. For example,

all contacts and phone numbers for Inspection Procedure 71124.01 should be in a

file/folder titled 1- A, applicable organization charts in file/folder 1- B, updated final

safety analysis report

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Louis Carson at (817) 200-1221 or

Louis.Carson@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

Attachment 2

5. Radiation Monitoring Instrumentation (71124.05)

Date of Last Inspection: April 23, 2012

A. List of contacts and telephone numbers for the following areas:

1. Effluent monitor calibration

2. Radiation protection instrument calibration

3. Installed instrument calibrations

4. Count room and Laboratory instrument calibrations

B. Applicable organization charts

C. Copies of audits, self-assessments, vendor or Nuclear Procurement Issues Committee

(NUPIC) audits for contractor support and licensee event reports (LERs), written since

date of last inspection, related to:

1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey

instruments, electronic dosimeters, teledosimetry, personnel contamination monitors,

or whole body counters

2. Installed radiation monitors

D. Procedure index for:

1. Calibration, use and operation of continuous air monitors, criticality monitors,

portable survey instruments, temporary area radiation monitors, electronic

dosimeters, teledosimetry, personnel contamination monitors, and whole body

counters

2. Calibration of installed radiation monitors

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Calibration of portable radiation detection instruments (for portable ion chambers)

2. Whole body counter calibration

3. Laboratory instrumentation quality control

F. A summary list of corrective action documents (including corporate and subtiered

systems) written since date of last inspection, related to the following programs:

1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey

instruments, electronic dosimeters, teledosimetry, personnel contamination monitors,

whole body counters

2. Installed radiation monitors

3. Effluent radiation monitors

4. Count room radiation instruments

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that the

inspector can perform word searches.

G. Offsite dose calculation manual, technical requirements manual, or licensee controlled

specifications which lists the effluent monitors and calibration requirements

H. Current calibration data for the whole body counters

I. Primary to secondary source calibration correlation for effluent monitors

J. A list of the point of discharge effluent monitors with the two most recent calibration

dates and the work order numbers associated with the calibrations

K. Radiation Monitoring System health report for the previous 12 months

A2-2

6. Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

Date of Last Inspection: April 23, 2012

A. List of contacts and telephone numbers for the following areas:

1. Radiological effluent control

2. Engineered safety feature air cleaning systems

B. Applicable organization charts

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection, related to:

1. Radioactive effluents

2. Engineered Safety Feature Air cleaning systems

D. Procedure indexes for the following areas

1. Radioactive effluents

2. Engineered Safety Feature Air cleaning systems

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Sampling of radioactive effluents

2. Sample analysis

3. Generating radioactive effluent release permits

4. Laboratory instrumentation quality control

5. In-place testing of HEPA filters and charcoal adsorbers

6. New or applicable procedures for effluent programs (e.g., including ground water

monitoring programs)

F. List of corrective action documents (including corporate and subtiered systems) written

since date of last inspection, associated with:

1. Radioactive effluents

2. Effluent radiation monitors

3. Engineered Safety Feature Air cleaning systems

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that the

inspector can perform word searches.

G. 2012 and 2013 Annual Radioactive Effluent Release Report, or the two most recent

reports.

H. Current Copy of the Offsite Dose Calculation Manual

I. Copy of the 2012 and 2013 interlaboratory comparison results for laboratory quality

control performance of effluent sample analysis, or the two most recent results.

J. Effluent sampling schedule for the week of the inspection

K. New entries into 10 CFR 50.75(g) files since date of last inspection

L. Operations department (or other responsible department) log records for effluent

monitors removed from service or out of service

M. Listing or log of liquid and gaseous release permits since date of last inspection

A2-3

N. A list of the technical specification-required air cleaning systems with the two most

recent surveillance test dates of in-place filter testing (of HEPA filters and charcoal

adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers

associated with the surveillances

O. System Health Report. Moreover, please provide a specific list of all effluent radiation

monitors that were considered inoperable for 7 days or more since November 2011.

If applicable, please provide the relative Special Report and condition report(s).

P. A list of all radiation monitors that are considered §50.65/Maintenance Rule equipment

Q. A list of all significant changes made to the Gaseous and Liquid Effluent Process

Monitoring System since the last inspection. If applicable, please provide the

corresponding updated final safety analysis report (UFSAR) section in which this change

was documented.

R. A list of any occurrences in which a non-radioactive system was contaminated by a

radioactive system. Please include any relative condition report(s).

A2-4

7. Radiological Environmental Monitoring Program (71124.07)

Date of Last Inspection: April 23, 2012

A. List of contacts and telephone numbers for the following areas:

1. Radiological environmental monitoring

2. Meteorological monitoring

B. Applicable organization charts

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection, related to:

1. Radiological environmental monitoring program (including contractor environmental

laboratory audits, if used to perform environmental program functions)

2. Environmental TLD processing facility

3. Meteorological monitoring program

D. Procedure index for the following areas:

1. Radiological environmental monitoring program

2. Meteorological monitoring program

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Environmental Program Description

2. Sampling, collection, and preparation of environmental samples

3. Sample analysis (if applicable)

4. Laboratory instrumentation quality control

5. Procedures associated with the Offsite Dose Calculation Manual

6. Appropriate QA Audit and program procedures, and/or sections of the stations

QA manual (which pertain to the REMP)

F. A summary list of corrective action documents (including corporate and subtiered

systems) written since date of last inspection, related to the following programs:

1. Radiological environmental monitoring

2. Meteorological monitoring

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that the

inspector can perform word searches.

G. Wind Rose data and evaluations used for establishing environmental sampling locations

H. Copies of the 2 most recent calibration packages for the meteorological tower

instruments

I. Copy of the 2012 and 2013 Annual Radiological Environmental Operating Report and

Land Use Census, and current revision of the Offsite Dose Calculation Manual, or the

two most recent reports.

J. Copy of the environmental laboratorys interlaboratory comparison program results for

2012 and 2013, or the two most recent results, if not included in the annual radiological

environmental operating report

K. Data from the environmental laboratory documenting the analytical detection sensitivities

for the various environmental sample media (i.e., air, water, soil, vegetation, and milk)

L. Quality Assurance audits (e.g., NUPIC) for contracted services

A2-5

M. Current NEI Groundwater Initiative Plan and status

N. Technical requirements manual or licensee controlled specifications which lists the

meteorological instruments calibration requirements

O. A list of Regulatory Guides and/or NUREGs that you are currently committed to relative

to the Radiological Environmental Monitoring Program. Please include the revision

and/or date for the committed item and where this can be located in your current

licensing basis/UFSAR.

P. If applicable, per NEI 07-07, provide any reports that document any spills/leaks to

groundwater since the last inspection.

A2-6

8. Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,

and Transportation (71124.08)

Date of Last Inspection: April 23, 2012

A. List of contacts and telephone numbers for the following areas:

1. Solid Radioactive waste processing

2. Transportation of radioactive material/waste

B. Applicable organization charts (and list of personnel involved in solid radwaste

processing, transferring, and transportation of radioactive waste/materials)

C. Copies of audits, department self-assessments, and LERs written since date of last

inspection related to:

1. Solid radioactive waste management

2. Radioactive material/waste transportation program

D. Procedure index for the following areas:

1. Solid radioactive waste management

2. Radioactive material/waste transportation

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Process control program

2. Solid and liquid radioactive waste processing

3. Radioactive material/waste shipping

4. Methodology used for waste concentration averaging, if applicable

5. Waste stream sampling and analysis

F. A summary list of corrective action documents (including corporate and subtiered

systems) written since date of last inspection related to:

1. Solid radioactive waste

2. Transportation of radioactive material/waste

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that the

inspector can perform word searches.

G. Copies of training lesson plans for 49CFR172, subpart H, for radwaste processing,

packaging, and shipping.

H. A summary of radioactive material and radioactive waste shipments made from date of

last inspection to present

I. Waste stream sample analyses results and resulting scaling factors for 2012 and 2013,

or the two most recent results.

J. Waste classification reports if performed by vendors (such as for irradiated hardware)

K. A listing of all onsite radwaste storage facilities. Please include a summary or listing of

the items stored in each facility, including the total amount of radioactivity and the

highest general area dose rate.

Although it is not necessary to compile the following information, the inspector will also review:

L. Training, and qualifications records of personnel responsible for the conduct of

radioactive waste processing, package preparation, and shipping

A2-7

ML14223B221

SUNSI Review ADAMS Yes Non-Sensitive Publicly Available Keyword

By: NFO No Sensitive Non-Publicly Available NRC-002

OFFICE SRI:DRP/B RI:DRP/B C:DRS/TSB C:DRS/EB1 C:DRS/EB2

NAME CPeabody/tk RStroble GMiller TFarnholtz JDixon

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/

DATE 7/23/14 8/11/14 8/8/14 8/6/14 8/6/14

OFFICE C:DRS/OB C:DRS/PSB1 C:DRS/PSB2 BC:DRP/B

NAME VGaddy MHaire HGepford NOKeeefe

SIGNATURE /RA/ /RA/ /RA/ /RA/

DATE 8/6/14 8/8/14 8/8/14 8/11/14

Letter to Adam Heflin from Neil OKeefe, dated August 11, 2014

SUBJECT: WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION

REPORT 05000482/2014003

DISTRIBUTION:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

Acting DRP Director (Troy.Pruett@nrc.gov)

Acting DRP Deputy Director (Michael.Hay@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Charles.Peabody@nrc.gov)

Resident Inspector (Raja.Stroble@nrc.gov)

WC Administrative Assistant (Carey.Spoon@nrc.gov)

Branch Chief, DRP/B (Neil.OKeefe@nrc.gov)

Senior Project Engineer, DRP/B (David.Proulx@nrc.gov)

Project Engineer, DRP/B (Fabian.Thomas@nrc.gov)

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

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Fred.Lyon@nrc.gov)

Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

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

RIV/ETA: OEDO (Anthony.Bowers@nrc.gov)

ROPreports