ML17311A518
| ML17311A518 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/01/2017 |
| From: | Nick Taylor NRC/RGN-IV/DRP/RPB-B |
| To: | Heflin A Wolf Creek |
| R ALEXANDER | |
| References | |
| IR 2018008 | |
| Download: ML17311A518 (7) | |
See also: IR 05000482/2018008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511
November 1, 2017
Adam C. Heflin, President,
Chief Executive Officer,
and Chief Nuclear Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, KS 66839
SUBJECT: WOLF CREEK GENERATING STATION - NOTIFICATION OF NRC
INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES
AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY
PREPAREDNESS COMMUNICATION/ STAFFING/MULTI-UNIT DOSE
ASSESSMENT PLANS (05000482/2018008) AND REQUEST FOR
INFORMATION
Dear Mr. Heflin:
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
staff will conduct a mitigation strategies for beyond-design-basis external events, spent fuel pool
instrumentation, and emergency preparedness enhancements inspection at the Wolf Creek
Generating Station, from January 22 - 26, 2018. The inspection will consist of three reactor
inspectors from the NRCs Region IV office, plus one of the assigned Resident Inspectors at the
Wolf Creek Generating Station for one week. The inspection will be conducted in accordance
with the NRCs Temporary Instruction 2515/191, Inspection of the Implementation of Mitigating
Strategies and Spent Fuel Pool Instrumentation Orders, and Emergency Preparedness
Communication/Staffing/Multi-Unit Dose Assessment Plans.
Experience has shown that this inspection is resource intensive both for the NRC inspectors
and licensee staff. In order to minimize the impact to your onsite resources and to ensure a
productive inspection, we have enclosed a request for documents needed for this inspection
activity. Please note that the documents are requested to be provided by January 5, 2018.
During the onsite inspection, inspectors will verify that plans for complying with NRC Orders
EA-12-049 and EA-12-051 are in place and are being implemented. Inspectors will also verify
the establishment of staffing and communications plans provided in response to the
March 12, 2012, request for information letter, and multi-unit dose assessment information
provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency
Preparedness for Japan Lessons Learned, dated March 27, 2013. These plans and information
were provided in the site specific submittals, which were subsequently reviewed by the NRC
staff for understanding and documented in the NRCs plant safety evaluations (SEs) and safety
assessments. Therefore, appropriate personnel knowledgeable of the stations FLEX
strategies, spent fuel pool instrumentation, and emergency preparedness enhancements should
be available to support the inspectors at the site during the inspection.
A. Heflin 2
We have discussed the schedule for this inspection activity with your staff and understand that
our regulatory contact for this inspection will be Nicole Good of your licensing organization. If
there are any questions about this inspection or the material requested, please contact the lead
inspector, Ryan D. Alexander, by telephone at (817) 200-1195 or by e-mail at
ryan.alexander@nrc.gov.
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. The NRC may not conduct or sponsor, and a person is not required to
respond to, a request for information or an information collection requirement unless the
requesting document displays a currently valid Office of Management and Budget control
number.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Nicholas H. Taylor, Chief
Project Branch B
Division of Reactor Projects
Docket: 50-482
License: NPF-42
Enclosure:
FLEX Strategies, Spent Fuel Pool
Instrumentation, & EP Enhancements
Inspection Request for Information
Request for Information
FLEX Strategies, Spent Fuel Pool Instrumentation, & EP Enhancements Inspection
Wolf Creek Generating Station
Inspection Report: 05000482/2018008
Inspection Dates: January 22 - 26, 2018
Inspection Procedure: Temporary Instruction 2515/191, Inspection of the
Implementation of Mitigating Strategies and Spent Fuel Pool
Instrumentation Orders, and Emergency Preparedness
Communication/Staffing/Multi-Unit Dose Assessment Plans
Inspectors: Ryan D. Alexander, Team Lead, Sr. Project Engineer, Region IV
Doug Dodson, Sr. Resident Inspector, Wolf Creek
Michael Stafford, Resident Inspector, Cooper Station
Inspector TBD, Region IV
Information Requested for the In-Office Preparation Week
The following information should be sent to the Region IV office in hard copy or electronic
format (use of the Certrec IMS information portal is preferred), to the attention of Ryan
Alexander, by January 5, 2017. The inspectors will select specific items from the information
requested below and then request from your staff additional documents needed during the
onsite inspection week. Also, we request that you categorize the documents in your response
with the numbered list below. Please provide requested documentation electronically if possible.
If requested documents are large and only hard copy formats are available, please inform the
lead inspector, and provide subject documentation during the first day of the onsite inspection.
If you have any questions regarding this information request, please call the lead inspector as
soon as possible.
TI 2515/191 - Appendix A
A. Provide current revision of the FLEX Final Integrated Plan (i.e., current FLEX Program
Document), including any revisions since January 2017 submission to the NRC.
B. Provide the FLEX Strategy Basis Document.
C. Provide each operating, off-normal, abnormal, and/or emergency procedures where entry
into one or more FLEX Support Guideline(s) are initiated.
D. Provide a list and copies of every FLEX Support Guidelines (FSGs) or equivalent
procedures which you developed or revised to implement your mitigating strategies.
E. Provide a list of key pieces of equipment that directly perform a FLEX mitigation strategy for
core cooling (RCS and Steam Generators), containment, and/or spent fuel pool cooling.
F. Provide a listing/summaries of plant modifications completed related to the FLEX program.
G. Provide a listing of calculations, evaluations, and 50.59 reviews related to the FLEX program
and modifications.
1 Enclosure
H. Applicable site specific hazards for the Wolf Creek Generating Station:
1) Provide documents which show the locations and configuration of structure(s) which
store FLEX equipment.
2) Seismic
(a) Provide the travel route(s) for FLEX equipment from storage location(s) to their
location(s) of use, AND evaluation(s) which demonstrate that for the potential for soil
liquefaction is not of a concern for these travel route(s).
(b) Seismic concerns for water source(s)
(1) If the FLEX water sources are seismically robust, then provide the assessment
that shows that they are.
(2) If the FLEX water sources are not seismically robust, then provide:
(a) an assessment of alternate water sources, and
(b) the procedure(s) which describe when and how to access those sources.
3) External Flooding
(a) Provide description of where FLEX equipment is stored relative to protection from
flood waters in accordance with site flood analysis.
(1) If any FLEX equipment is stored below flood level, then (i) on an event timeline,
show when that equipment will be needed; and (ii) provide the procedure(s) used
to retrieve and deploy that equipment.
(b) Provide your plans/procedures to support successful FLEX equipment deployment
for flooding/ponding from localized intense precipitation (which persist over a long
time period).
(c) If credited in the strategy, provide plans/procedures for storage and deployment of
temporary flood barriers, including timeline of deployment strategy.
4) Severe storms with high winds
(a) Provide evaluation/evidence as to how FLEX equipment is stored relative to
protection from severe storms with high winds (including tornadic):
(1) In a structure that meets the plants design basis for high wind hazards (e.g.,
existing safety-related structure); OR
(2) In a structure that meets the design requirements as described in ASCE 7-10,
Minimum Design Loads for Buildings and Other Structures, given the limiting
tornado wind speeds from Regulatory Guide 1.76, and/or design-basis hurricane
wind speeds.
(b) Provide pathways via which you plan to move FLEX equipment from onsite storage
areas to final deployment locations.
(1) Show how you designated and evaluated those pathways for post-storm
accessibility for staging and connecting FLEX equipment.
5) Snow, Ice, and Extreme Cold
For each key piece of equipment described in Item E (above) that directly performs or
implements a FLEX mitigation strategy:
2
(a) Provide procedures/documents demonstrating that the FLEX equipment is
maintained at a temperature within a range to ensure that it will function when called
upon.
(b) Provide procedures/documents demonstrating how the FLEX equipment can be
moved from the storage location to its deployment location during extreme snowfall
and ice storms.
6) Extreme high temperatures
For each key piece of equipment described in Item E (above) that directly performs or
implements a FLEX mitigation strategy:
(a) Provide procedures/documents which describes the high-temperature limit of the
range within which the equipment will function.
(b) Provide procedures/documents which describe how the equipment is maintained
below that limit in its storage location.
I. Provide the station-specific FLEX strategies time validation study(ies).
J. Provide the relevant station procedure(s)/guideline(s) which describe the testing and
maintenance program for FLEX equipment. As applicable, provide a listing of the model
work orders established to conduct period testing and maintenance activities for FLEX
equipment.
NOTE - A sample of records for completed maintenance/testing activities will be
requested for review during the onsite inspection week.
K. Provide documents/procedures which describe the programmatic controls in place to ensure
that if equipment and applicable connections are unavailable (e.g., due to maintenance,
non-functionality), then compensatory measures are implemented in accordance with
guidance outlined NEI 12-06.
L. Provide the station-specific National SAFER Center Playbook
M. Relative to personnel training on FLEX strategies, provide:
1) FLEX training bases document(s)
2) Lesson plans/training documents for site emergency response leaders responsible for
the implementation of FLEX strategies. [Records for staff completing this training may be
requested for review during the onsite inspection week.]
3) Lesson plans/training documents for site personnel responsible for the execution of
mitigating strategies for BDBEEs (i.e., operators, craft personnel, security, radiation
protection, etc.).
NOTE - Records for staff completing these training activities may be requested for review
during the onsite inspection week.
N. A current copy of administrative procedure(s) for the CAP, modification program, operations
procedure writing and implementation, and top-level documents for the work control and
work scheduling programs. (If FLEX related procedures such as FSGs or the FIP are
maintained under a different process, please include copies of those procedures.)
O. A current copy of the U/FSAR, Technical Specifications, and Technical Specification Bases
documents.
P. Listing of corrective action program document summaries generated related to FLEX
equipment, strategies, procedures, and/or training.
3
NOTE - Complete corrective action program documents for a selection of those included in
the summary will be requested for review during the onsite inspection week.
Q. A copy of any audits/self-assessments related to your preparation for this inspection, as well
as any related to the implementation or maintenance of the FLEX program.
TI 2515/191 - Appendix B
R. Provide the procedures implemented for maintenance, testing, calibration, and use of the
primary and backup Spent Fuel Pool (SFP) instrumentation channels.
S. Provide lesson plans/training documents which describe the training program that address
the use, maintenance, calibration, surveillance, and the use of alternate power to the
primary and backup SFP instrument channels.
TI 2515/191 - Appendix C
T. Communications:
1) Provide documents which show that the communications system(s), technologies,
equipment and power supplies would be available from the beginning of the event and
operate during an ELAP.
2) Provide the procedures and/or guidance used to implement the communication
capabilities.
3) Provide documents which show that you have added any new communications
equipment, portable power supplies and/or systems have been added to ongoing testing
and preventative maintenance programs.
U. Staffing:
1) Provide documents which show that onsite and augmented staff will be available to
implement the strategies in response to a large scale natural event that results an ELAP
and impedes access to the site, and that functions/tasks have been appropriately
staffed.
2) Provide documents which show that the site access methods (e.g., roadways, navigable
bodies of water and dockage, airlift, etc.) expected to be available following the event
and available to the Emergency Response Organization (ERO) [as described in the
Phase 1 and 2 staffing assessments and NRC safety assessment].
3) Provide documents which show the testing, training, and drills/exercises performed by
the station to demonstrate the EROs ability to utilize the communications systems
and/or equipment.
V. Provide documents and procedures which show that your dose assessment
process/program is capable of analyzing concurrent radiological releases from all on-site
significant sources, including releases from spent fuel pools (i.e., multi-unit/multi-source
dose assessment capability).
Lead Inspector Contact Information:
Ryan D. Alexander, Sr. Project Engineer Mailing Address:
817-200-1195 U.S. NRC, Region IV
Ryan.Alexander@nrc.gov Attn: Ryan Alexander, DRP
1600 East Lamar Blvd.
Arlington, TX 76011-4511
4
SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword
By: RDA/dll Yes No Non-Sensitive Publicly Available NRC-002
OFFICE DRP/RPBA C:DRP/RPBB
NAME RAlexander NTaylor
SIGNATURE /RA/-E /RA/
DATE 11/01/2017 11/1/2017