IR 05000482/2017001

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NRC Integrated Inspection Report 05000482/2017001
ML17132A257
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 05/12/2017
From: John Dixon
NRC/RGN-IV/DRP/RPB-B
To: Heflin A
Wolf Creek
JOHN DIXON
References
IR 2017001
Download: ML17132A257 (37)


Text

UNITED STATES May 12, 2017

SUBJECT:

WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000482/2017001

Dear Mr. Heflin:

On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Wolf Creek Generating Station. On May 2, 2017, the NRC inspectors discussed the results of this inspection with Mr. Stephen Smith, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the NCV, 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; and the NRC resident inspector at the Wolf Creek Generating Station.

If you disagree with a 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Wolf Creek Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

John L. Dixon, Branch Chief Project Branch B Division of Reactor Projects Docket No.: 50-482 License No.: NPF-42 Enclosure:

Inspection Report 05000482/2017001 w/ Attachment: Supplemental Information

SUNSI Review ADAMS Non-Sensitive Publicly Available By: JDixon Yes No Sensitive Non-Publicly Available OFFICE SRI/DRP/B ASRI/DRP/B RI/DRP/B C:DRS/EB1 C:DRS/EB2 C:DRS/OB NAME DDodson MLangelier FThomas TFarnholtz GWerner VGaddy SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 5/3/2017 5/8/2017 05/03/2017 05/04/2017 05/04/2017 5/3/2017 OFFICE C:DRS/PSB2 TL:DRS/IPAT SRI/DRP/C SPE:DRP/B BC:DRP/B NAME HGepford THipschman PVoss DProulx JDixon SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/

DATE 05/04/2017 5/4/2017 5/9/2017 5/4/2017 5/12/2017

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000482 License: NPF-42 Report: 05000482/2017001 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane NE Burlington, KS 66839 Dates: January 1, 2017, through March 31, 2017 Inspectors: D. Dodson, Senior Resident Inspector M. Langelier, P.E., Acting Senior Resident Inspector F. Thomas, Resident Inspector J. Drake, Senior Reactor Engineer P. Elkmann, Senior Emergency Preparedness Inspector D. Proulx, Senior Project Engineer P. Voss, Senior Resident Inspector, Cooper Approved John L. Dixon By: Chief, Project Branch B Division of Reactor Projects Enclosure

SUMMARY

IR 05000482/2017001; 01/01/2017 - 03/31/2017; Wolf Creek Generating Station; Maintenance

Effectiveness The inspection activities described in this report were performed between January 1 and March 31, 2017, by the resident inspectors at Wolf Creek Generating Station and inspectors from the NRCs Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (i.e., Green, greater than Green,

White, Yellow, or Red), determined using Inspection Manual Chapter 0609, Significance Determination Process, dated April 29, 2015. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, dated July 2016.

Cornerstone: Mitigating Systems

Green.

The inspectors reviewed a Green, self-revealed non-cited violation of Technical Specification 5.4.1.a and Regulatory Guide 1.33 for the licensees failure to provide adequate work instructions for preventive maintenance on safety-related equipment.

Specifically, work instructions to inspect and clean the condensate drain lines on the class 1E air conditioner air handling units lacked guidance for adequately cleaning the drain line.

This caused the unit to become non-functional. The licensee took the immediate corrective action to clear the clogged condensate drain line on SGK05B, and entered the issue in the corrective action program as Condition Report 106416.

The failure to provide adequate work instructions for preventive maintenance on safety-related equipment is a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the procedure quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). In accordance with NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined this finding screened to

Green.

The inspectors determined that the finding has a problem identification and resolution cross-cutting aspect of resolution because the organization did not take effective corrective actions to address issues in a timely manner commensurate with their safety significance. This issue is indicative of current performance because neither the preventive maintenance change process was substantively changed nor were human performance errors associated with the preventive maintenance change corrected, and the same resolution inadequacies that resulted in the inadequate preventive maintenance instructions would be expected to occur

[P.3]. (Section 1R12)

PLANT STATUS

Wolf Creek Generating Station began the inspection period operating at full power. On February 9, 2017, operators reduced power to approximately 82 percent to complete planned main turbine valve cycle testing. Plant power was restored to approximately full power on February 10, 2017, and the plant operated at, or near, full power for the rest of the period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Summer Readiness for Offsite and Alternate AC Power Systems

a. Inspection Scope

On March 10, 2017, the inspectors completed an inspection of the stations off-site and alternate-alternating current (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 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

.1 Partial Walk-Down

a. Inspection Scope

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

  • January 24, 2017, safety injection pump B
  • February 22, 2017, emergency diesel generator B 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 trains were correctly aligned for the existing plant configuration.

These activities constituted two partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walk-Down

a. Inspection Scope

On January 24, 2017, the inspectors performed a complete system walk-down inspection of the residual heat removal pump B. The inspectors reviewed the licensees procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors also reviewed outstanding, open condition reports, temporary modifications, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

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 seven plant areas important to safety:

  • January 23, 2017, fire areas A-21 and A-22, control room air-conditioning and filtration units, elevation 2,047 feet
  • February 24, 2017, fire areas ESWA and ESWB, essential service water pump house, elevation 2,000 feet
  • February 28, 2017, fire area A-33, auxiliary feedwater piping, valves, and instrumentation room, elevation 1,989 feet
  • March 6, 2017, circulating water screen house floor area, elevation 2,000 feet
  • March 9, 2017, station blackout diesel generator enclosure floor area, elevation 2,000 feet
  • March 15, 2017, fire areas A-17 and A-18, electrical penetration rooms A and B, elevation 2,026 feet
  • March 29, 2017, fire area A-23, main steam and feedwater valve compartment, elevation 2,047 feet 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 seven quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

On January 25, 2017, and February 22, 2017, respectively, the inspectors completed an inspection of the readiness and availability of risk-significant heat exchangers. The inspectors observed performance tests, reviewed the data from the performance tests, verified the licensee used the industry standard periodic maintenance method outlined in EPRI NP-7552, and verified the material condition for the train A spent fuel pool pump room cooler and train A emergency diesel generator jacket water heat exchanger.

The inspectors also verified that both the train A spent fuel pool pump room cooler and train A emergency diesel generator jacket water heat exchangers were correctly categorized under the Maintenance Rule and were receiving the required maintenance.

These activities constituted completion of two heat sink performance annual review samples, as defined in Inspection Procedure 71111.07.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On March 1, 2017, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the evaluated simulator scenario.

These activities constituted completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

On March 20, 2017, the inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened risk due to chemical and volume control system inservice check valve testing and associated reactivity manipulations.

In addition, the inspectors assessed the operators adherence to plant procedures, including AP 21-001, Conduct of Operations, Revision 79, and other operations department policies.

These activities constituted completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Routine Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of safety-significant structures, systems, and components (SSCs):

  • January 30, 2017, NF039B load shedding and emergency load sequencing cabinet, undervoltage power supplies found out of tolerance on ripple voltage checks
  • February 1, 2017, containment cooler fan D motor control circuit, failed contactor The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

b. Findings

Introduction.

The inspectors reviewed a Green, self-revealed non-cited violation of Technical Specification 5.4.1.a and Regulatory Guide 1.33 for the licensees failure to provide adequate work instructions for preventive maintenance on safety-related equipment. Specifically, work instructions to inspect and clean the condensate drain line on the train B class 1E air conditioner air handling unit lacked adequate guidance to clean the drain line. This resulted in the train B class 1E air conditioning unit becoming non-functional.

Description.

On August 15, 2016, at 4:33 a.m., the train B class 1E air conditioning unit (SGK05B) was declared non-functional when an operator discovered water on the floor near the air handling unit where one would not normally expect such a condition. This water was determined to be from condensate that had accumulated within the air handling unit and was leaking out of an access door seal. The condensate within the air handling unit had accumulated enough to wet the bottom of the fan motor within the unit.

The direct cause of the accumulation of condensation in this air handling unit was determined to be a clogged condensate drain line. This line was cleared using pressurized water, the station started the unit for post maintenance testing on August 15, 2016, at 10:59 p.m., and the unit was declared functional at 11:35 a.m., on August 16, 2016.

Prior to this occurrence, on August 7, 2016, at 3:52 a.m., the train A control room air conditioning unit (SGK04A) was declared inoperable due to the discovery of condensation accumulating inside the air handling unit for this air conditioner. This issue was initially found by the operator on rounds when the operator noted the absence of water dripping from the condensate drain line as it normally does during operation. The condensation within the air handling unit had accumulated enough to wet the bottom of the fan motor. The direct cause of the accumulation of condensate within the air handling unit was determined to be a partially clogged condensate drain line. During operation, a small vacuum is created within the air handling unit and this vacuum, coincident with a partially clogged drain line, prevented condensate from draining from the unit. This line was partially cleared using pressurized water and the unit was declared operable at 5:50 p.m. on August 7, 2016. Inspectors challenged the licensee on their assessment that the unit was operable and not degraded due to only partially clearing the drain line. The licensee agreed, and revised their operability determination to operable but degraded.

As part of a basic cause evaluation completed in September 2016, the licensee determined that the condensate drain lines had clogged on these units several times in the past and had also occurred on the train B control room air conditioning unit (SGK04B). A total of twelve incidents since 1998 were reported. Initial corrective actions in 1998, implemented a preventive maintenance strategy for the control room air conditioning units and the class 1E air conditioning units for their condensate drain lines.

This preventive maintenance activity did not initially provide guidance to check the drain lines for obstructions. In July 2000, after the train A control room air conditioning unit experienced a clogged condensate drain line, the preventive maintenance instructions were updated to request maintenance personnel to pour one gallon of water down the drain line to verify adequate drainage flow. However, these instructions did not include guidance on what was an acceptable flow rate.

In 2008, after continuing to have issues with clogging condensate drain lines, the preventive maintenance instructions were updated to require disassembly of the drain lines by maintenance personnel to inspect and thoroughly clean the drain lines. The ability to disassemble the condensate drain line was only possible on SGK05A due to a threaded union being present in the drain line. The other three units; SGK05B, SGK04A, and SGK04B, did not have a threaded union in the drain line. Because of this, a recommendation was made in 2012 to change the preventive maintenance instructions. The preventive maintenance instructions for the other three units were subsequently essentially reverted to the previous instructions that utilized the flushing water technique and did not require the lines to always be cleaned, even though the preventive maintenance tasks had previously been changed in 2008 to resolve ongoing issues. The licensees basic cause evaluation determined that the most probable cause of the collection of debris in the condensate drain lines was lack of guidance in the preventive maintenance work instructions to adequately clean the drain lines to determine if blockages exist and to remove them.

The inspectors questioned whether any substantive changes to the preventive maintenance change process had occurred subsequent to 2012 or if any new actions were planned, and the inspectors questioned whether any corrective actions had been taken or were planned related to any human performance issues associated with the inadequate preventive maintenance change in 2012. The licensee confirmed that neither previous nor planned actions addressed the programmatic or human performance issues that resulted in inadequate resolution of the inadequate preventive maintenance task issue. As a result, the issue is indicative of current performance, and the licensee documented Condition Report 112754 to address the inspectors concerns.

The licensee entered this issue into its corrective action program as Condition Reports 106262,106416, and 112754. Condition Report 106416 documented completion of actions to improve the preventive maintenance work instructions to require the use of pressure (air and/or water) to clean/purge the condensate drain lines.

Analysis.

The failure to provide adequate work instructions for preventive maintenance on safety-related equipment is a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the procedure quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).

Specifically, work instructions for preventive maintenance on the condensate drain line for SGK05B were inadequate, and as a result, SGK05B condensate drain lines became clogged and SGK05B was declared non-functional.

The inspectors evaluated the finding using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter 0609, Appendix A, Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, and determined this finding is not a deficiency affecting the design or qualification of a mitigating SSC that maintained its operability or functionality; the finding does not represent a loss of system and/or function; the finding does not represent an actual loss of function of at least a single train for greater than its technical specification-allowed outage time; and the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Therefore, the inspectors determined the finding was of very low safety significance (Green).

The inspectors determined that the finding has a problem identification and resolution cross-cutting aspect in the area of resolution because the organization did not take effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, in 2012 the preventive maintenance instructions for the SGK05B, SGK04A, and SGK04B units, which were created in 2008 to address continuing condensate drain line clogging issues, were essentially reverted back to the previous inadequate instructions. This issue is indicative of current performance because neither the preventive maintenance change process was substantively changed nor were human performance errors associated with the preventive maintenance change corrected, and the same resolution inadequacies that resulted in the inadequate preventive maintenance instructions would be expected to occur [P.3].

Enforcement.

Technical Specification 5.4.1.a requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix A to Regulatory Guide 1.33, Revision 2, requires, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established Procedure AP 16B-003, Planning and Scheduling Preventive Maintenance, which provides direction for implementing the preventive maintenance program to meet the Regulatory Guide 1.33 requirement. Section 6.2 of Procedure AP 16B-003 requires, in part, that preventive maintenance activities be developed by considering, in part, equipment history, operating experience, and component functional importance. Contrary to the above, until December 15, 2016, preventive maintenance activities were not developed by adequately considering equipment history, operating experience, and component functional importance. Specifically, preventive maintenance activity 28380 for cleaning and inspecting the drain line on SGK05B, an activity affecting quality, was not appropriate to the circumstances. As a result, the train B class 1E air conditioning unit (SGK05B) was declared non-functional on August 15, 2016. The licensee took the immediate corrective action to clear the clogged condensate drain line on SGK05B and has completed corrective actions to improve the preventive maintenance instructions.

The licensee entered this issue into the corrective action program as Condition Reports 106262, 106416, and 112754. This violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000482/2017001-01, Failure to Provide Adequate Work Instructions for Preventive Maintenance.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed three 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:

  • January 23, 2017, planned maintenance for train A control room air-conditioning unit and train A safety injection pump
  • February 21 and 22, 2017, planned 7-day maintenance window for train A emergency diesel generator 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.

Additionally, on January 17, 2017, the inspectors also observed portions of steam generator atmospheric relief valve A controller replacement emergent work activities that had the potential to affect the functional capability of mitigating systems. 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 SSCs.

These activities constituted completion of four maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed five operability determinations and evaluations that the licensee performed for degraded or nonconforming SSCs:

  • December 22, 2016, evaluation of train A hydrogen analyzer containment isolation valves in an abnormal line-up
  • January 11, 2017, evaluation of unit vent planned maintenance
  • March 14, 2017, operability determination of postulated tornado generated missile impact on A and B train emergency diesel generator truck connections 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.

These activities constituted completion of five operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed six post-maintenance testing activities that affected risk-significant SSCs:

  • January 23, 2017, train A control room air conditioning unit planned maintenance
  • February 2, 2017, train B containment cooler fan D motor contactor replacement
  • March 28, 2017, train A motor-driven auxiliary feedwater pump and valve planned maintenance 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 constituted completion of six post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed seven 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:

  • January 19, 2017, STS MT-079, A [Essential Service Water] Vacuum Breaker Valve Inservice Test, Revision 1
  • February 16, 2017, STS EF-100A, [Essential Service Water] System Inservice Pump A & [Essential Service Water] A Check Valve Test, Revision 46B
  • March 27, 2017, STS EN-101A, Containment Spray Pump A Comprehensive Pump Test, Revision 14 Other surveillance tests:
  • February 15, 2017, STS IC-530D, Wide Range Temperature and Wide Range Pressure Instrumentation Protection Set 1 Channel Calibration, Revision 28
  • March 16, 2017, STS EN-101B, Containment Spray Pump B Comprehensive Pump Test, Revision 14 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. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constituted completion of seven surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The inspector performed an in-office review of AP-06-002, Radiological Emergency Response Plan, Revision 18A, implemented November 29, 2016. This revision:

  • Revised the definitions and descriptions of radiation dosimetry throughout the Plan
  • Corrected minor typographical and administrative errors This revision was compared to its previous revision, to the criteria of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, and to the standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that the revision did not decrease the effectiveness of the emergency plan. This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection.

These activities constitute completion of one emergency action level and emergency plan changes sample as defined in Inspection Procedure 71114.04.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Training Evolution Observation

a. Inspection Scope

On March 1 and 9, 2017, the inspectors observed simulator-based licensed operator requalification training that included implementation of the licensees emergency plan.

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 evaluators and entered into the corrective action program for resolution.

These activities constituted completion of one training observation sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 Unplanned Scrams per 7000 Critical Hours (IE01)

a. Inspection Scope

The inspectors reviewed licensee event reports (LERs) for the period of January 1, 2016, through December 31, 2016, to determine the number of scrams that occurred.

The inspectors compared the number of scrams reported in these LERs to the number reported for the performance indicator. Additionally, the inspectors sampled operating logs to verify the number of critical hours during the period. 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 data reported.

These activities constituted verification of the unplanned scrams per 7000 critical hours performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. Inspection Scope

The inspectors reviewed operating logs and corrective action program records for the period of January 1, 2016, through December 31, 2016, to determine the number of unplanned power changes that occurred. The inspectors compared the number of unplanned power changes documented to the number reported for the performance indicator. Additionally, the inspectors sampled operating logs to verify the number of critical hours during the period. 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 data reported.

These activities constituted verification of the unplanned power changes per 7000 critical hours performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Unplanned Scrams with Complications (IE04)

a. Inspection Scope

The inspectors reviewed the licensees basis for including or excluding in this performance indicator each scram that occurred between January 1, 2016, through December 31, 2016. 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 data reported.

These activities constituted verification of the unplanned scrams with complications performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

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 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.

4OA5 Other Activities

Temporary Instruction 2515/192, Inspection of the Licensees Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems.

a. Inspection Scope

The objective of this performance based Temporary Instruction was to verify implementation of interim compensatory measures associated with an open phase condition design vulnerability in electric power systems for operating reactors. The inspectors conducted an inspection to determine if the licensee implemented the following interim compensatory measures. These compensatory measures are to remain in place until permanent automatic detection and protection schemes are installed and declared operable for the open phase condition design vulnerability. The inspectors verified the following:

  • The licensee identified and discussed with plant staff the lessons-learned from the open phase condition events at the U.S. operating plants including the Byron Station open phase condition and its consequences. This included conducting operator training for promptly diagnosing, recognizing consequences, and responding to an open phase condition.
  • The licensee updated plant operating procedures to help operators promptly diagnose and respond to open phase conditions on off-site power sources credited for safe shutdown of the plant.
  • The licensee established and implemented periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the off-site power circuits to detect a visible open phase condition.
  • The licensee ensured that routine maintenance and testing activities on switchyard components have been implemented and maintained. As part of the maintenance and testing activities, the licensee assessed and managed plant risk in accordance with 10 CFR 50.65(a)(4) requirements.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On March 22, 2017, the inspector conducted a telephonic exit meeting to present the results of the in-office inspection of changes to the licensees emergency plan to Mr. T. East, Superintendent, Emergency Planning, and other members of the licensee staff. The licensee acknowledged the issues presented.

On March 23, 2017, the inspectors presented the final inspection results to Mr. C. Reasoner, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. No proprietary information was identified.

On May 2, 2017, the inspectors presented the inspection results to Mr. S. Smith, Plant Manager, 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.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Ashley, Supervisor, System Engineering
R. Audano, Superintendent, Maintenance
R. Ayers, Supervisor, Radiation Protection
T. Baban, Manager, System Engineering
W. Brandt, Shift Manager
J. Cuffe, Supervisor, Radiation Protection
T. East, Superintendent, Emergency Planning
J. Edwards, Manager, Operations
R. Fincher, Manager, Quality
R. French, Supervisor, Radiation Protection
J. Fritton, Oversight
G. Fugate, Director, Plant Support
N. Good, Licensing Engineer
C. Gross, Manager, Chemistry
C. Hafenstine, Manager, Regulatory Affairs
D. Hall, Manager, Strategic Projects
A. Heflin, President and Chief Executive Officer
P. Herrman, Manager, Design Engineering
R. Hobby, Licensing Engineer
J. Isch, Superintendent, Operations Work Controls
J. Knust, Licensing Engineer
R. Lane, Manager, Corrective Action Program
B. Lee, Licensed Supervising Instructor
D. Mand, Manager, System Engineering
J. McCoy, Vice President, Engineering
W. Muilenburg, Supervisor Licensing
L. Ratzlaff, Manager, Maintenance
C. Reasoner, Site Vice President
M. Skiles, Manager, Security
T. Slenker, Supervisor, Operations Support
S. Smith, Plant Manager
L. Stone, Licensing Engineer
A. Stull, Vice President and Chief Administrative Officer
J. Suter, Supervisor, Fire Protection
M. Tate, Superintendent, Security Operations
J. Yunk, Manager, Training

NRC Personnel

D. Loveless, Senior Reactor Analyst
C. Smith, Reactor Inspector, Engineering Branch 1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

Failure to Provide Adequate Work Instructions for Preventive

05000482/2017001-01 NCV Maintenance (Section 1R12)

Closed

Inspection of the Licensees Interim Compensatory Measures 2515/192 TI Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems (Section 4OA5)

LIST OF DOCUMENTS REVIEWED