IR 05000482/2018007
| ML18218A265 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/08/2018 |
| From: | Gerond George Division of Reactor Safety IV |
| To: | Heflin A Wolf Creek |
| References | |
| IR 2018007 | |
| Download: ML18218A265 (20) | |
Text
August 8, 2018
SUBJECT:
WOLF CREEK GENERATING STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000482/2018007
Dear Mr. Heflin:
On June 28, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution inspection at your Wolf Creek Generating Station. The NRC inspection team discussed the results of this inspection with Mr. J. H. McCoy, Vice President, Engineering, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program. The team assessed the programs effectiveness in identifying, prioritizing, evaluating, and correcting problems, and whether the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. However, the team found evidence of continued challenges to your organizations safety-conscious work environment in the maintenance support group, similar to those identified in NRC Integrated Inspection Report 05000482/2017003. (ADAMS Accession No. ML17311B223). In reviewing your corrective actions to address the 2017 maintenance support challenges, the team concluded that your actions appeared minimal. Your management stated that other actions had been taken, but were unable to provide any documentation of those actions or any evidence of whether they had been successful. Further, while your station had initiated corrective actions following the NRCs identification of a safety-conscious work environment cross-cutting theme in our 2017 assessment letter (ADAMS Accession No. ML18052A345), no actions were taken or planned to evaluate whether the work environment had improved following completion of the corrective actions taken.
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 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 the cross-cutting aspect 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Gerond A. George, Team Leader Inspection Programs and Assessment Team Division of Reactor Safety
Docket No. 50-482 License No. NPF-42
Enclosure:
Inspection Report 05000482/2018007 w/ Attachment: Information Request
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000482
License Number:
Report Number:
Enterprise Identifier: I-2018-007-0007
Licensee:
Wolf Creek Nuclear Operating Corporation
Facility:
Wolf Creek Generating Station
Location:
Burlington, Kansas
Inspection Dates:
June 11, 2018, to June 28, 2018
Inspectors:
R. Azua, Senior Reactor Inspector, DRS (Team Lead)
E. Ruesch, Senior Reactor Inspector, DRS
M. Stafford, Resident Inspector, Cooper Nuclear Station, DRP
F. Thomas, Resident Inspector, Wolf Creek Generating Station, DRP
Approved By:
G. George, Team Leader
Inspection Program and Assessment Team
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting a Problem Identification and Resolution inspection at the Wolf Creek
Generating Station, Unit 1, in accordance with the Reactor Oversight Process. The Reactor
Oversight Process is the NRCs program for overseeing the safe operation of commercial
nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more
information. NRC and self-revealed findings, violations, and additional items are summarized in
the table below.
List of Findings and Violations
Failure to Provide Adequate Work Instructions for Preventive Maintenance on Safety-Related
Equipment
Cornerstone
Significance
Cross-cutting
Aspect
Inspection
Procedure
Mitigating
Systems
Green
Closed
[P.2] Problem
Identification
and Resolution
71152 - Problem
Identification and
Resolution
The team reviewed a Green, self-revealed non-cited violation of Technical Specification 5.4.1.a
to establish, implement, and maintain written procedures recommended by Regulatory Guide 1.33, Appendix A, Revision 2. Specifically, work instructions for the preventive maintenance
for the train B Class 1E electrical equipment A/C unit SGK05B, lacked adequate guidance for
preventive maintenance and calibration of the associated thermostat. This resulted in the loss
of cooling failure of the A/C unit SGK05B, on February 12, 2018.
OTHER ACTIVITIES - BASELINE
71152Problem Identification and Resolution
Biennial Team Inspection (1 Sample)
The inspectors performed a biennial assessment of the licensees corrective action program,
use of operating experience, self-assessments and audits, and safety-conscious work
environment. The assessment is documented below.
(1) Corrective Action Program Effectiveness: Problem Identification, Problem Prioritization and
Evaluation, and Corrective Actions - The inspection team reviewed the stations corrective
action program and the stations implementation of the program to evaluate its effectiveness
in identifying, prioritizing, evaluating, and correcting problems. The team also evaluated the
stations compliance with NRC regulations and licensee standards for corrective action
programs. The sample included approximately 170 condition reports (CR) with associated
root and apparent cause evaluations. This included an in-depth 5-year review of CRs
associated with the licensees safety-related A/C units with a focus on the associated
chillers.
(2) Operating Experience, Self-Assessments, and Audits - The team evaluated the stations
processes for use of industry and NRC operating experience. The team also evaluated the
effectiveness of the stations audits and self-assessments program. The sample included
industry operating experience communications including Part 21 notifications and other
vendor correspondence, NRC generic communications, and publications from various
industry groups including Institute of Nuclear Power Operations (INPO) and Electric Power
Research Institute, plus associated site evaluations.
(3) Safety-Conscious Work Environment - The team evaluated the stations safety-conscious
work environment. The team interviewed approximately fifty individuals in eight group
interviews. The purpose of these interviews was: (1) to evaluate the willingness of the
licensee staff to raise nuclear safety issues, either by initiating a CR or by another method;
(2) to evaluate the perceived effectiveness of the corrective action program at resolving
identified problems; and (3) to evaluate their safety-conscious work environment. The focus
group participants included personnel from the mechanical and electrical maintenance,
instrumentation and controls, engineering, and maintenance support. The team also
interviewed the employee concerns program manager, reviewed employee concerns files,
and reviewed the results of the most recent safety culture survey. The team reviewed the
licensees actions taken in response to the significant work environment challenges
identified by the NRC in a June 2017 inspection, which were documented in Inspection
Report 2017003 (ADAMS Accession No. ML17311B223), and the safety-conscious work
environment cross-cutting theme identified in the NRCs 2017 Annual Assessment Letter
(ADAMS Accession No. ML18052A345).
INSPECTION RESULTS
Corrective Action Program Assessment
71152Problem Identification and
Resolution
Corrective Action Program: Based on the samples reviewed, the team determined that your
staffs performance in each of these areas adequately supported nuclear safety.
Effectiveness of Problem Identification: Overall, the team found that the licensees
identification and documentation of problems were adequate to support nuclear safety.
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the
licensees prioritization and evaluation of issues were adequate to support nuclear safety.
Effectiveness of Corrective Actions: Overall, the team concluded that the licensees corrective
actions generally supported nuclear safety.
Operating Experience, Self-Assessments, and Audits
Assessment
71152Problem Identification and
Resolution
Operating Experience, Self-Assessments and Audits: Based on the samples reviewed, the
team determined that the licensees performance in each of these areas adequately
supported nuclear safety. In the area of operating experience, the team found that
information was being appropriately used at the Wolf Creek Generating Station to ensure
potential issues were promptly identified and corrected. Having said that, the team noted
some indications that screening of operating experience information could be improved. One
example was identified where the licensee failed to promptly identify and correct a condition
adverse to quality in the area of operating experience. This issue is further documented in
this report as a minor violation.
Safety-Conscious Work Environment Assessment
71152Problem Identification and
Resolution
Safety-Conscious Work Environment: In most work groups, the team found no evidence of
challenges to the safety-conscious work environment. Individuals in these groups expressed
a willingness to raise nuclear safety concerns and other issues through at least one of the
several means available.
However, the team found continued work environment challenges in the maintenance support
group, similar to those identified during the June 2017 inspection. In reviewing corrective
actions taken by the licensee following the previous inspection activities, the team noted other
than a personnel move, the licensee had not documented any actions taken to correct the
work environment challenges. Further, the licensee had taken no action to evaluate whether
the work environment had improved as a result of the personnel move or of any
undocumented actions taken. Neither had the licensee documented the identified issues in
the corrective action program or any other formal action tracking process. Following
identification by the team, the employee concerns program coordinator briefed the stations
nuclear safety culture monitoring panel and conducted a pulse survey that confirmed the
teams conclusions that the work environment challenges had not been corrected. The team
determined that presently, the maintenance support group would raise nuclear safety
concerns; however, concern arises if the work environment challenges are allowed to
continue. The licensee documented the issue in CR 124460.
Following receipt of the NRCs 2017 annual assessment letter, the licensee performed an
apparent cause evaluation to evaluate circumstances that led to the safety-conscious work
environment cross-cutting issue and to develop actions to correct any adverse conditions and
their causes (CR 119954). These planned actions include benchmarking, process changes,
and leadership training. The licensee also developed an action to evaluate the effectiveness
of these actions approximately 6 months after they are complete. This planned effectiveness
review includes surveys of and interviews with station leadership, validation of corrective
action program process outputs, and review of the results of a planned third-party
assessment. The team reviewed the licensees actions and determined that the success
criteria, which were approved by Corrective Action Review Board on June 20, 2018, do not
include validation through interviews or surveys with individual contributors to verify that any
underlying safety-conscious work environment challenges have been corrected. The team
noted that the licensees effectiveness measures may validate that the planned actions have
been accomplished, but not whether they have been successful at correcting the deficiency
they are intended to correct. The licensee documented this observation in CR 124660.
Overall, the team concluded that most work groups at the Wolf Creek Generating Station
maintained a healthy safety-conscious work environment. However, the lack of tracking
mechanisms or effectiveness reviews for actions taken to improve the work environment, in
those groups with challenges, appears to have hindered timely resolution of those challenges.
INSPECTION RESULTS - ISSUES/FINDINGS
Minor Violation
71152Problem Identification and
Resolution
Performance Deficiency: Failure to promptly identify and correct known-defective switches in
inservice safety-related breakers, or to control nonconforming breakers accepted into
warehouse stores, as required by 10 CFR 50 Appendix B Criteria XV and XVI.
In February 2008, the licensee received a notification from GE Hitachi of reduced reliability of
some safety-related circuit breakers due to defective cutoff switches internal to the breakers.
The licensee incorrectly screened this information as not applicable to the Wolf Creek
Generating Station. In August 2011, after licensee engineers received the information again
from industry peers, the licensee screened the information as applicable. The licensee then
added steps to its overhaul and pre-install test procedures to check for the defective
subcomponent. These steps were performed during subsequent regularly scheduled
overhaul or pre-install tests, with the last affected switches being replaced in June 2014 and
the last potentially susceptible safety-related breaker being inspected in March 2015. The
team determined that because the station had information on the defect in February 2008, but
did not correct the condition until 2014 and did not confirm that it was corrected until 2015, the
licensee had failed to promptly identify and correct a condition adverse to quality. Further, the
licensee failed to inspect or place administrative controls on potentially affected spare
breakers that had been accepted into warehouse stores, though the added steps in the pre-
install procedure likely would have prevented a defective component from being installed.
However, by failing to segregate the potentially affected components until they were
inspected, the licensee failed to comply with quality assurance requirements for control of
nonconforming components. On June 26, 2018, the licensee put a hold on four potentially
affected breakers that were in warehouse stores. The licensee documented this performance
deficiency in CR 124693.
Screening: The performance deficiency was minor because the licensee did not experience
an inservice failure as a result of the defect during the 6 years they remained in service and
had a procedure in place that would likely have prevented a defective spare from being
issued for installation. Therefore, there was no adverse effect on the mitigating systems
cornerstone objective and there was no potential to create a more significant safety concern.
Enforcement: This failure to comply with 10 CFR 50 Appendix B Criteria XV and XVI
constitutes a minor violation that is not subject to enforcement action in accordance with the
NRCs Enforcement Policy.
Failure to Provide Adequate Work Instructions for Preventive Maintenance on Safety-Related
Equipment
Cornerstone
Significance
Cross-cutting
Aspect
Inspection Procedure
Mitigating
Systems
Green
Closed
[P.2] - Problem
Identification
and Resolution
71152Problem
Identification and
Resolution
The inspectors reviewed a Green, self-revealed non-cited violation of Technical Specification 5.4.1.a to establish, implement, and maintain written procedures recommended
by Regulatory Guide 1.33, Appendix A, Revision 2. Specifically, work instructions for the
preventive maintenance for the train B Class 1E electrical equipment A/C unit SGK05B,
lacked adequate guidance for preventive maintenance and calibration of the associated
thermostat. This resulted in the loss of cooling failure of the A/C unit SGK05B, on February
12, 2018.
Description:
On February 12, 2018, the licensee made an unplanned entry into action statements
associated with Technical Specifications 3.0.3, Limiting Condition for Operation Applicability,
(which requires initiation of actions within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, to be in Mode 3 within
7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />); 3.8.9, Conditions C and D, Electrical Power Systems - Distribution Systems;
3.8.7, Condition A, Electrical Power Systems - Inverters - Operating; and 3.8.4, Condition A,
Electrical Power Systems - DC Sources. This unplanned entry was made as a result of the
train B Class 1E electrical equipment A/C unit SGK05B not operating in accordance with
design requirements.
The safety-related function of the A/C unit SGK05B is to provide suitable environment for
Class 1E electrical equipment during normal and accident conditions. By not cooling
properly, the A/C unit SGK05B would not be able to meet the required room temperatures
needed to support train B engineering safety feature equipment. The failure was identified as
a result of a security officer performing rounds having noticed an increase in temperature on
the 2016 foot elevation in the Control Building. According to the operations logs, the highest
affected room temperature was recorded at approximately 80 degrees Fahrenheit.
According to Condition Report (CR) 119446, initial troubleshooting performed by the fix-it now
team led the licensee to suspect that the step controller associated with the A/C unit was not
functioning properly due to a potentially loose set screw on the micro-switch. The CR also
indicated that this set screw coming loose had been an issue in the past. The step controller
and thermostat were replaced on February 13, 2018, as a part of further troubleshooting
efforts. Past maintenance records indicate that the A/C unit SGK05B step controller,
according to Work Order 15-402910-004, had last been replaced on October 1, 2016. Before
then, it had been replaced on March 28, 2014, per Work Order 14-385255-001. The
thermostat had not been replaced until February 13, 2018.
As indicated in the basic cause evaluation, the licensee determined that this failure
constituted a maintenance preventable functional failure. In accordance with the
Maintenance Rule Database Function GK-01, the function of A/C unit SGK05B is to provide a
suitable environment for Class 1E electrical equipment during normal and accident conditions.
Any equipment failure that results in the system being incapable of maintaining room
temperature below a temperature of 90 degrees F is considered a high safety significant
functional failure. Demand failures that do not result in the room temperature reaching 90
degrees F are considered functional failures, but are not considered high safety significant
functional failures. The A/C unit SGK05B would not have performed its function to provide a
suitable environment for Class 1E electrical equipment due to the failure of the thermostat.
The licensees basic cause evaluation identified the probable cause of the failure as having
been the failure of the GKTC0005B thermostat for the A/C unit SGK05B, resulting in
anomalous operation of the associated controller and subsequent lack of temperature control
for supported equipment rooms. The conclusion in the basic cause evaluation indicated that
the failure of the thermostat resulted in the inability of the A/C unit SGK05B to cool supported
equipment rooms. This was based on the results of a hardware failure analysis performed by
a third party, which showed signs of erratic and unexpected operation from the thermostat.
Furthermore, the basic cause evaluation indicated that the lack of available calibration,
preventive maintenance, or replacement records on the thermostat contributed to the failure.
Furthermore, the basic cause evaluation for the February 12, 2018, event stated that a review
of the stock transaction for the Honeywell thermostat showed four prior replacements of the
component between the four air conditioning units which utilize it. The units which utilize
these components are the train A and B Control Room A/C units (SGK04A and SGK04B),
and the train A and B Class 1E electrical equipment A/C units (SGK05A and SGK05B). None
of the replacements were on the A/C unit SGK05B. The basic cause evaluation also stated
that a review of the IQ Review database showed that the calibration template task had been
disregarded during the 2014 preventive maintenance optimization effort based on it being
considered, determined by driving asset or program. The basic cause analysis also
indicated, that without preventive maintenance in place to periodically check their condition, it
is likely only a self-revealing failure would be identified within the corrective action program.
Several months before, at 5:24 AM, on November 7, 2017, the licensee had taken the train B
Class 1E electrical equipment A/C unit SGK05B out of service for a planned maintenance
outage. At 4:50 AM, on November 8, 2017, an operations log entry was made by the night-
shift manager indicating that the A/C unit SGK05B was not responding to adjustments on the
thermostat assembly during post-maintenance testing activities. Condition Report CR 117283
was initiated for troubleshooting. The troubleshooting activities were implemented under
Work Order 17-423314-007. As a part of their troubleshooting activities, the electricians took
voltage readings at the step controller and adjusted the thermostat setting to approximately
50 degrees F. The step controller did not move. Electricians then took voltage readings at
the terminal board on the step controller and it started to operate. While observing the
movement of internal step controller components, the technician notes indicated that a small
arc was seen on the potentiometer. Also, at some point during the troubleshooting, the
electricians lightly tapped on the step controller assembly until the balance relay contacts
inside of the step controller changed state and drove the controller to energize liquid line
solenoids. These solenoids regulate the flow of refrigerant into the air-handling unit for air
cooling. The fix-it now team electricians concluded that the problem was with the feedback
potentiometer. According to technician notes in the aforementioned work order, the contacts
for the feedback potentiometer were burnished and the associated disc assembly was
cleaned. The electricians also adjusted the contact tension on the feedback potentiometer.
According to work order information, the electricians were eventually able to adjust the
thermostat, and observe expected pick-up and drop-out load response from A/C unit
SGK05B. The unit was returned to service at 9:19 PM, on November 8, 2017. The
troubleshooting work order did not contain or indicate that any calibration or resistance
checks were performed specifically on the thermostat.
On September 29, 2015, troubleshooting work was performed on the train A
control room A/C unit SGK04A during a planned maintenance outage (under Work
Order 14-396140-000), due to excessive cycling having been observed on the unit on
December 14, 2014. According to the work order, electrical maintenance personnel
recommended that the Honeywell T991A thermostat be calibrated during the next
maintenance outage, in accordance with Procedure INC C-1000, Calibration of
Miscellaneous Components. According to the work order, the as-found condition notes
indicated that the resistance measurements for the thermostat were not balanced.
Maintenance technicians adjusted the thermostat calibration accordingly and the unit was
later returned to service on October 30, 2015.
The licensee wrote CR 117283 for issues observed during the November 7, 2017,
maintenance outage. In CR 117283 it indicated that the defect in the A/C unit SGK05B was a
lack of control of the A/C unit with varying thermostatic input, because the unit was not
responding to changing thermostatic inputs and cycled off multiple times following restoration
from preventive maintenance activities. The cause of the failure identified in the basic cause
evaluation was the loss of contact or high resistance at the feedback potentiometer, which
resulted in the step controller stalling at a singular position which resulted in a lack of
response from the A/C unit SGK05B.
Considering troubleshooting work performed on the A/C unit SGK04A back on September 29,
2015, where the same model Honeywell T991A thermostat is used and specific steps were
taken to troubleshoot the thermostat, it is possible that the same troubleshooting steps should
have been performed on the A/C unit SGK05B thermostat during the November 7 - 8, 2017,
planned maintenance outage. While there was no documented loss of cooling or equipment
failure on the A/C unit SGK04A between December 14, 2014, and September 30, 2015, there
was an indication of a degraded condition on the Honeywell T991A thermostat. Thus, there
was an opportunity to have identified a degraded condition on the Honeywell T991A
thermostat on the A/C unit SGK05B during the November 7 - 8, 2017, planned maintenance
outage.
Corrective Actions: The licensee took the immediate corrective actions to: (1) implement
compensatory measures for having one of two Class 1E electrical equipment A/C units out of
service, as described in Procedure SYS GK-200, Non-Functional Class 1E A/C Unit;
(2) perform troubleshooting as required by Work Order 18436340-002; and (3) replace both
the step controller and thermostats.
Performance Assessment:
Performance Deficiency: The failure to provide adequate work instructions for preventive
maintenance on safety-related equipment is a performance deficiency.
Screening: The performance deficiency is more than minor, and therefore a finding, because
it is associated with the equipment performance 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 train B Class 1E electrical equipment A/C unit SGK05B, lacked preventive
maintenance and calibration instruction for the A/C unit thermostat, which led to the failure of
the A/C unit thermostat, resulting in the loss of cooling failure of the A/C unit SKG05B, on
February 12, 2018.
Significance: 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 structure,
system, or component 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. Therefore,
the inspectors determined the finding was of very low safety significance (Green).
Cross-cutting Aspect: The inspectors determined that the finding has a cross-cutting aspect
in the area of Problem Identification and Resolution associated with evaluation, because the
organization did not take effective corrective actions to thoroughly evaluate issues to ensure
that resolutions address cause and extent of conditions commensurate with their safety
significance. Specifically, the licensee failed to ensure that issues with the A/C unit SGK05B
were thoroughly investigated according to their safety significance [P.2].
Enforcement:
Violation: Technical Specification 5.4.1.a, requires, in part, that procedures shall be
established, implemented, and maintained covering the applicable procedures recommended
by Regulatory Guide 1.33, Appendix A, Revision 2. Section 9.a of Appendix A of Regulatory
Guide 1.33, Revision 2, states, 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 and component functional importance.
Contrary to the above requirement, on November 8, 2018, the licensee failed to implement
written procedures recommended by Regulatory Guide 1.33, Appendix A, Revision 2.
Specifically, preventive maintenance activities were developed without adequately
considering equipment history and component functional importance in accordance with
Procedure AP 16B-003. Preventive maintenance Work Orders 17-428613-000 and17-
423314-007 did not require preventive maintenance and calibration testing of the thermostat
associated with A/C unit SGK05B.
Disposition: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
On June 28, 2018, the inspectors presented the Problem Identification and Resolution
inspection results to Mr. J. H. McCoy, Vice President, Engineering, and other members of the
licensee staff. The inspectors verified no proprietary information was retained or documented in
this report.
DOCUMENTS REVIEWED
71152Problem Identification and Resolution
Condition Reports
42461
46173
53586
70482
73241
73863
75337
78108
80172
81711
84848
86032
90162
90879
92274
95378
96307
96397
100328
100902
101706
101867
102322
103395
104266
105186
105558
105559
105771
105865
105901
105929
106016
106064
106165
106183
106289
106292
106328
106417
106668
106725
106867
107732
107743
108163
108416
108493
108529
108553
108699
108800
108996
110399
111210
111751
111818
111939
111941
112136
112244
112339
112363
112436
112497
112503
112588
112689
112964
113061
113304
113485
113913
114245
114437
114850
114885
114886
114887
114933
114947
115001
115103
115127
115326
115471
115642
115667
116175
116176
116178
116179
116180
116181
116489
116786
116792
116831
116852
116893
117124
117238
117283
117389
117408
118665
118885
118894
118994
119173
119275
119297
119298
119446
119487
119593
119954
119981
120045
120056
120064
120091
120112
120125
120151
120287
120331
120484
120519
120628
120674
120780
120822
121443
121762
122076
122359
122375
122411
122598
123038
123276
123708
123900
124153
124187
124238
124242
124288
124373
124380
124381
124382
124383
124386
124460
124490
124520
124661
124662
124667
124669
Work Orders
05-273192-000
14-107802-000
14-385255-001
14-392578-001
14-396140-000
15-402910-002
15-402910-004
15-406675-022
16-412247-000
16-418672-001
16-418672-002
16-418672-003
17-122291-000
17-423314-005
17-423314-007
17-423314-008
17-423325-000
17-428613-000
18-436340-003
18-439562-000
Procedures
Number
Title
Revision
AI 23O-001
Functional Importance Determination
AI 28A-010
Screening Condition Reports
AI 28A-010
Screening Condition Reports
29A
AI 28A-017
Effectiveness Follow-up
AI 28A-018
Corrective Action Review Board
AI 28A-023
Evaluation of Maintenance Rule Functional Failure
Condition Reports
Procedures
Number
Title
Revision
AI 28A-100
Condition Report Resolution
AI 28A-101
Non-Condition Adverse to Quality
AI 28B-005
Evidence and Action Matrix
AI 36-001
Nuclear Safety Culture Panel
Scaffold Construction and Use
Planning and Scheduling Preventive Maintenance
8A
MPAC [Maintenance Planning and Controls] Work
Request/Work Order Process Controls
Conduct of Performance Assessment
AP 21-001
Conduct of Operations
WCGS [Wolf Creek Generating Station] Maintenance Rule
Program
Warehouse Material Storage, Handling, Packaging,
Shipping, and Maintenance
Operability Determination and Functionality Assessment
AP 28-011
Resolving Degraded or Nonconforming Conditions
Impacting Structures, Systems, and Components
Corrective Action Program
AP 36-001
Nuclear Safety Culture
INC C-1000
Calibration of Miscellaneous Components
7A
MGE TL-001
Wiring Termination and Lug/Connector Installation
MPE E017Q-04
Circuit Breaker Test for AKR 50 and AKR 30 Breakers
Drawing
Number
Title
Revision
M-650A-00054
Control Building Electrical Chases - Wet Pipe
System El. 1974-0 through 2073-6
W05
Miscellaneous
Documents
Number
Title
Revision
BG-16-006
Operability Evaluation
CKL ZL-004
Turbine Building Reading Sheets
161
CKL ZL-005A
An Emergency Diesel Generator (EDG) Operation Log
FL-08
Control Building Flooding (Calculation)
OE EF-16-002
Operability Evaluation
Operability Evaluation
OE GM-17-001
Operability Evaluation
OE KJ-16-005
Operability Evaluation
OE NB-16-004
Operability Evaluation
OE NE-17-002
Operability Evaluation
Operability Evaluation
Specification
10466-A-086
Technical Specification for Rolling Doors for the
Standardized Nuclear Unit Power Plant System (SNUPPS)
SA-2017-0128
FLEX Program Self-Assessment
STS KJ-011A
EDG NE01 24 Hour Run
QA-2016-0270
CR 84848 Problem Identification and Resolution Condition
Brought Up by NRC Inspector on Breach Procedure
QH-2017-1566
Engineering Life Cycle Management
QH-2017-1600
2018 Design Basis Assurance Inspection (DBAI) Self-
Assessment
QH-2018-1652
RF22 Steam Generator Readiness for NRC ISI Inspection
QH-2018-1653
RF22 ISI Inspection
QS-2016-1804
Review of Engineering CRs Non-LTCA Over 365 Days Old
for Escalation
WCRE-35
Boundary Matrix
Control Rod Parking Schedule, Cycle 23
Problem Identification (PI) Desktop Cause Evaluation Users
Guide
Wolf Creek Generating Station Cycle 23, Core Operating
Limits Report
Attachment
Information Request
Biennial Problem Identification and Resolution
Inspection Wolf Creek Generating Station
April 4, 2018
Inspection Report: 50-482/2018007
On-site Inspection Dates: June 11-15 & June 25-29, 2018
This inspection will cover the period from July 1, 2016, through June 29, 2018. All requested
information is limited to this period or to the date of this request unless otherwise specified.
To the extent possible, the requested information should be provided electronically in word-
searchable Adobe PDF (preferred) or Microsoft Office format. Any sensitive information
should be provided in hard copy during the teams first week on site; do not provide any
sensitive or proprietary information electronically.
Lists of documents (summary lists) should be provided in Microsoft Excel or a similar sortable
format. Please be prepared to provide any significant updates to this information during the
teams first week of on-site inspection. As used in this request, corrective action documents
refers to condition reports, notifications, action requests, cause evaluations, and/or other
similar documents, as applicable to the Wolf Creek Generating Station.
Please provide the following information no later than May 28, 2018:
1.
Document Lists
Note: For these summary lists, please include the document/reference number, the
document title, initiation date, current status, and long-text description of the issue.
a.
Summary list of all corrective action documents related to significant
conditions adverse to quality that were opened, closed, or evaluated during
the period
b.
Summary list of all corrective action documents related to conditions adverse
to quality that were opened or closed during the period
c.
Summary lists of all corrective action documents that were upgraded or
downgraded in priority/significance during the period (these may be limited
to those downgraded from, or upgraded to, apparent-cause level or higher)
d.
Summary list of all corrective action documents initiated during the period
that roll up multiple similar or related issues, or that identify a trend
e.
Summary lists of operator workarounds, operator burdens, temporary
modifications, and control room deficiencies (1) currently open and (2) that
were evaluated and/or closed during the period
f.
Summary list of safety system deficiencies that required prompt
operability determinations (or other engineering evaluations) to provide
reasonable assurance of operability
g.
Summary list of plant safety issues raised or addressed by the Employee
Concerns Program (or equivalent) (sensitive information should be made
A-2
available during the teams first week on sitedo not provide
electronically)
h.
Summary list of all Apparent Cause Evaluations completed during the
period
2. Full Documents with Attachments
a.
Root Cause Evaluations completed during the period; include a list of
any planned or in progress
b.
Quality Assurance audits performed during the period
c.
Audits/surveillances performed during the period on the Corrective
Action Program, of individual corrective actions, or of cause
evaluations
d.
Functional area self-assessments and non-NRC third-party assessments (e.g.,
peer assessments performed as part of routine or focused station self-and
independent assessment activities; do not include INPO assessments) that
were performed or completed during the period; include a list of those that are
currently in progress
e.
Any assessments of the safety-conscious work environment at the Wolf
Creek Generating Station
f.
Corrective action documents generated during the period associated with
the following:
i.
NRC findings and/or violations issued to the Wolf Creek Generating
Station
ii.
Licensee Event Reports issued by the Wolf Creek Generating Station
g.
Corrective action documents generated for the following, if they were
determined to be applicable to the Wolf Creek Generating Station (for those
that were evaluated but determined not to be applicable, provide a summary
list):
i.
NRC Information Notices, Bulletins, and Generic Letters
issued or evaluated during the period
ii.
Part 21 reports issued or evaluated during the period
iii.
Vendor safety information letters (or equivalent) issued or
evaluated during the period
iv.
Other external events and/or operating experience evaluated
for applicability during the period
h.
Corrective action documents generated for the following:
A-3
i.
Emergency planning drills and tabletop exercises performed during
the period
ii.
Maintenance preventable functional failures which occurred or
were evaluated during the period
iii.
Adverse trends in equipment, processes, procedures, or
programs that were evaluated during the period
iv.
Action items generated or addressed by offsite review committees
during the period
3. Logs and Reports
a.
Corrective action performance trending/tracking information generated during
the period and broken down by functional organization (if this information is
fully included in item 3.c, it need not be provided separately)
b.
Corrective action effectiveness review reports generated during the period
c.
Current system health reports, Management Review Meeting (MRM) package,
or similar information; provide past reports as necessary to include 12 months
of metric/trending data
d.
Radiation protection event logs during the period
e.
Security event logs and security incidents during the period (sensitive
information should be made available during the teams first week on sitedo
not provide electronically)
f.
Employee Concern Program (or equivalent) logs (sensitive information should
be made available during the teams first week on sitedo not provide
electronically)
g.
List of training deficiencies, requests for training improvements, and
simulator deficiencies for the period
Note: For items 3.d-3.g, if there is no log or report maintained separate from the
corrective action program, please provide a summary list of corrective action
program items for the category described.
4.
Procedures
Note: For these procedures, please include all revisions that were in effect at any time
during the period.
a.
Corrective action program procedures, to include initiation and evaluation
procedures, operability determination procedures, apparent and root cause
evaluation/determination procedures, and any other procedures that
implement the corrective action program at the Wolf Creek Generating
Station
A-4
b.
Quality Assurance program procedures (specific audit procedures are
not necessary)
c.
Employee Concerns Program (or equivalent) procedures
d.
Procedures which implement/maintain a safety-conscious work environment
5. Other
a.
List of risk-significant components and systems, ranked by risk worth
b.
Organization charts for plant staff and long-term/permanent contractors
c.
Electronic copies of the UFSAR (or equivalent), technical specifications,
and technical specification bases, if available
d.
Table showing the number of corrective action documents (or equivalent)
initiated during each month of the inspection period, by screened
significance
e.
For each day the team is on site,
i.
Planned work/maintenance schedule for the station
ii.
Schedule of management or corrective action review meetings (e.g.
operations focus meetings, condition report screening meetings,
Corrective Action Review Boards, MRMs, challenge meetings for
cause evaluations, etc.)
iii.
Agendas for these meetings
Note: The items listed in 5.d may be provided on a weekly or daily basis after
the team arrives on site.
All requested documents should be provided electronically where possible. Regardless of
whether they are uploaded to an internet-based file library (e.g., Certrecs IMS), please provide
copies on CD or DVD. One copy of the CD or DVD should be provided to the resident
inspector office at the Wolf Creek Generating Station; three additional copies should be
provided to the team lead, to arrive no later than May 28, 2018:
U.S. NRC Senior Reactor Inspector
Inspection Program and Assessment Team
Division of Reactor Safety, Region IV
1600 E. Lamar Blvd, Arlington, TX 76011
Office: (817) 200-1445
Cell: (817) 319-4376
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002
By: RVA Yes No
Publicly Available Sensitive
OFFICE
SRI:DRS/IPAT
SRI:DRS/IPAT
RI:DRP/PBC
RI:DRP/PBB
C:DRP/PBB
TL:DRS/IPAT
NAME
RAzua
ERuesch
MStafford
FThomas
NTaylor
GGeorge
SIGNATURE
/RA/
/RA/
/RA/
/RA/
/RA/
/RA/
DATE
07/19/2018
07/26/2018
07/25/2018
07/26/2018
08/02/2018
08/08/2018