ML23244A214

IAEA Osart Report

ML23244A214
Person / Time
Site:	Wolf Creek
Issue date:	09/01/2023
From:	Greg Werner NRC/RGN-IV/DORS/PBB
To:
References
Download: ML23244A214 (1)

Text

REPORT OF THE OPERATIONAL SAFETY REVIEW TEAM (OSART)

MISSION TO THE WOLF CREEK NUCLEAR POWER PLANT UNITED STATES OF AMERICA 6 - 23 MARCH 2023 DIVISION OF NUCLEAR INSTALLATION SAFETY OPERATIONAL SAFETY REVIEW MISSION IAEA-NSNI/OSART/217/2023

PREAMBLE This report presents the results of the IAEA Operational Safety Review Team (OSART) review of Wolf Creek Nuclear Power Plant, United States of America. It includes recommendations and suggestions for improvements affecting operational safety for consideration by the responsible United States of America authorities and identifies good practices for consideration by other nuclear power plants. Each recommendation, suggestion, and good practice is identified by a unique number to facilitate communication and tracking.

Any use of or reference to this report that may be made by the competent United States of America organizations is solely their responsibility.

FOREWORD By the Director General The IAEA Operational Safety Review Team (OSART) programme assists Member States to enhance safe operation of nuclear power plants. Although good design, manufacture and construction are prerequisites, safety also depends on the ability of operating personnel and their conscientiousness in discharging their responsibilities. Through the OSART programme, the IAEA facilitates the exchange of knowledge and experience between team members who are drawn from different Member States, and plant personnel. It is intended that such advice and assistance should be used to enhance nuclear safety in all countries that operate nuclear power plants.

An OSART mission, carried out only at the request of the relevant Member State, is directed towards a review of items essential to operational safety. The mission can be tailored to the particular needs of a plant. A full scope review would cover ten operational areas: Leadership and Management for Safety; Training and Qualification; Operations; Maintenance; Technical Support; Operating Experience Feedback; Radiation Protection; Chemistry; Emergency Preparedness and Response, and Accident Management. Depending on individual needs, the OSART review can be directed to a few areas of special interest or cover the full range of review topics.

Essential features of the work of the OSART team members and their plant counterparts are the comparison of a plant's operational practices with best international practices and the joint search for ways in which operational safety can be enhanced. The IAEA Safety Series documents, including the Safety Standards and the Basic Safety Standards for Radiation Protection, and the expertise of the OSART team members form the bases for the evaluation. The OSART methods involve not only the examination of documents and the interviewing of staff but also reviewing the quality of performance.

It is recognized that different approaches are available to an operating organization for achieving its safety objectives. Proposals for further enhancement of operational safety may reflect good practices observed at other nuclear power plants.

An important aspect of the OSART review is the identification of areas that should be improved and the formulation of corresponding proposals. In developing its view, the OSART team discusses its findings with the operating organization and considers additional comments made by plant counterparts. Implementation of any recommendations or suggestions, after consideration by the operating organization and adaptation to particular conditions, is entirely discretionary.

An OSART mission is not a regulatory inspection to determine compliance with national safety requirements nor is it a substitute for an exhaustive assessment of a plant's overall safety status, a requirement normally placed on the respective power plant or utility by the regulatory body. Each review starts with the expectation that the plant meets the safety requirements of the country concerned. An OSART mission attempts neither to evaluate the overall safety of the plant nor to rank its safety performance against that of other plants reviewed. The review represents a `snapshot in time'; at any time after the completion of the mission care must be exercised when considering the conclusions drawn since programmes at nuclear power plants are constantly evolving and being enhanced. To infer judgements that were not intended would be a misinterpretation of this report.

The report that follows presents the conclusions of the OSART review, including good practices and proposals for enhanced operational safety, for consideration by the Member State and its competent authorities.

EXECUTIVE

SUMMARY

This report describes the results of the OSART mission conducted for Wolf Creek Nuclear Power Plant, United States of America from 6 to 23 March 2023.

The purpose of an OSART mission is to review the operational safety performance of a nuclear power plant against the IAEA safety standards, make recommendations and suggestions for further improvement and identify good practices that can be shared with NPPs around the world.

This OSART mission reviewed ten areas: Leadership and Management for Safety; Training and Qualification; Operations; Maintenance; Technical Support; Operating Experience Feedback; Radiation Protection; Chemistry; Emergency Preparedness & Response; and Accident Management.

The mission was coordinated by an IAEA Team Leader and Deputy Team Leader and the team was composed of experts from Argentina, Czech Republic, France, Germany, Slovak Republic, South Africa, Spain, Sweden, Switzerland, United Kingdom and one Observer from Netherlands.

The collective nuclear power experience of the team was 286 years.

The team identified nine issues, one recommendation, and eight suggestions. One area of good practice was also identified.

Several areas of good performance were noted:

The use of a spreadsheet calculator to predict and minimize lithium deviations from the chemistry specifications requirements during load-following activities.

The use of a chemistry software package to record chemistry analysis results, check violations and abnormalities and to automatically send an e-mail every morning to notify the Chemistry supervisors, Laboratory Supervisors and Quality personnel of any deviations.

The use of an indicator to clearly show to the plant management, the impact and potential vulnerabilities for the staffing of key positions within the emergency response organization.

The most significant issues identified were:

The plant should enhance the control and implementation of maintenance activities to ensure equipment reliability and personnel safety.

The plant should consider enhancing its arrangements for fire evacuation and training with all involved firefighting services to ensure a more effective fire response capability.

The plant should consider reinforcing its continuous improvement approach to take advantage of all learning opportunities to ensure sustainable safe plant operation and performance improvement.

Wolf Creek management expressed their commitment to address the issues identified and invited a follow up visit in about eighteen months to review the progress.

CONTENT INTRODUCTION AND MAIN CONCLUSIONS ................................................................... 1

1. LEADERSHIP AND MANAGEMENT FOR SAFETY................................................... 3

2. TRAINING AND QUALIFICATIONS ............................................................................ 8

3. OPERATIONS................................................................................................................. 12

4. MAINTENANCE ............................................................................................................ 19

5. TECHNICAL SUPPORT ................................................................................................ 25

6. OPERATING EXPERIENCE FEEDBAcK .................................................................... 30

7. RADIATION PROTECTION ......................................................................................... 32

8. CHEMISTRY .................................................................................................................. 34

9. EMERGENCY PREPAREDNESS AND RESPONSE ................................................... 37

10. ACCIDENT MANAGEMENT ................................................................................... 41

SUMMARY

OF RECOMMENDATIONS AND SUGGESTIONS and good practice .......... 44 DEFINITIONS......................................................................................................................... 45 REFERENCES ........................................................................................................................ 46 TEAM COMPOSITION .......................................................................................................... 48

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 INTRODUCTION AND MAIN CONCLUSIONS INTRODUCTION At the request of the government of United States of America, an IAEA Operational Safety Review Team (OSART) of international experts visited Wolf Creek Nuclear Power Plant from 6 to 23 March 2023. The purpose of the mission was to review operating practices in the areas of Leadership and Management for Safety, Training and Qualification, Operations, Maintenance, Technical Support, Operating Experience Feedback, Radiation Protection, Chemistry, Emergency Preparedness & Response and Accident Management. In addition, an exchange of technical experience and knowledge took place between the experts and their plant counterparts on how the common goal of excellence in operational safety could be further pursued.

The Wolf Creek Nuclear Power Plant is located near Burlington, Kansas, United States of America. The plant is jointly owned and operated by Evergy and Kansas Electric Power Cooperative. The Wolf Creek plant consists of a single unit Westinghouse four-loop pressurized light water reactor rated at 3565MWt with reference output of 1200 MWe gross. The Wolf Creek plant employs approximately 738 permanent staff.

The Wolf Creek OSART mission was the 217th in the programme, which began in 1982. The team was composed of experts from Argentina, Czech Republic, France, Germany, Slovak Republic, South Africa, Spain, Sweden, Switzerland, United Kingdom and one Observer from Netherlands and two IAEA staff members. The collective nuclear power experience of the team was 286 years.

Before visiting the plant, the team studied information provided by the IAEA and the Wolf Creek plant to familiarize themselves with the plant's main features and operating performance, staff organization and responsibilities, and important programmes and procedures. During the mission, the team reviewed many of the plant's programmes and procedures in depth, examined indicators of the plant's performance, observed work in progress, and held in-depth discussions with plant personnel.

Throughout the review, the exchange of information between the OSART experts and plant personnel was very open, professional and productive. Emphasis was placed on assessing the effectiveness of operational safety rather than simply the content of programmes. The conclusions of the OSART team were based on the plant's performance compared with international practices.

The following report is produced to summarize the findings in the review scope, according to the OSART Guidelines document. The text reflects only those areas where the team considers that a Recommendation, a Suggestion, an Encouragement, a Good Practice or a Good Performance is appropriate. In all other areas of the review scope, where the review did not reveal further safety conclusions at the time of the review, no text is included. This is reflected in the report by the omission of some paragraph numbers where no text is required.

Page 1 INTRODUCTION AND MAIN CONCLUSIONS

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 MAIN CONCLUSIONS The OSART team concluded that the managers of the Wolf Creek NPP are committed to improving the operational safety and reliability of their plant. The team found good areas of performance, including the following:

- The use of a spreadsheet tool to predict and prevent lithium deviations from the chemistry specifications requirements, during load-following activities.

- The use of a chemistry software package to record chemistry analysis results, check violations and abnormalities and to automatically send an e-mail every morning to notify the Chemistry supervisors, Laboratory Supervisors and Quality personnel of any deviations.

- The use of an indicator to clearly show to the plant management, the impact and potential vulnerabilities for the staffing of key positions within the emergency response organization.

A number of proposals for improvements in operational safety were offered by the team. The most significant proposals include the following:

- The plant should enhance the control and implementation of maintenance activities to ensure equipment reliability and personnel safety.

- The plant should consider enhancing its arrangements for fire evacuation and training with all involved firefighting services to ensure a more effective fire response capability.

- The plant should consider reinforcing its continuous improvement approach to take advantage of all learning opportunities to ensure sustainable safe plant operation and performance improvement.

Wolf Creek management expressed their commitment to address the issues identified and invited a follow up visit in about eighteen months to review the progress.

Page 2 INTRODUCTION AND MAIN CONCLUSIONS

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023

1. LEADERSHIP AND MANAGEMENT FOR SAFETY 1.1 LEADERSHIP FOR SAFETY Each division (department) at the plant performs a periodic self-assessment comparing its own performance against the set of values and behaviors that are deemed by the industry as being the enablers to establish a culture that achieves sustainable results (INPOs Staying on Top).

The team considered this practice a good performance.

1.4 MEASUREMENT, ASSESSMENT AND CONTINUOUS IMPROVEMENT The plant had an approach to continuous improvement based on establishing organizational principles and professional behaviours that supported the plants business plan. This approach was fostered and overseen by a set of committees and monitored through a group of key performance indicators based on an INPO document, as well as internal indicators at divisional level that provided more detailed information. However, the team noted some missed opportunities for organizational learning such as: coaching and task observations by leaders did not always take the opportunity to enhance plant and personnel performance, the safety impact of some organizational changes were not analyzed before implementation, and some processes did not have pre-established frequencies for their self-assessment. The team also identified some industry good practices, intended to minimize risk, which had not been implemented by the plant, for example, the labelling of single point vulnerabilities and the training of maintenance staff in the identification of counterfeit or suspect items. The team made a suggestion in this area.

1.6 NON-RADIATION-RELATED SAFETY PROGRAMME The plant had aligned its business plan, executive committees and communication strategies to achieve the internalization of industrial safety as a core value among its leaders and employees.

The team observed examples of positive reinforcement when workers reported and shared learning that improved the safety of the plant, as well as instances of prompt communications at all levels when lessons learnt from near misses were collected. Also, the plant had a dedicated Nuclear Safety Culture Coordinator that performed a daily screening of all condition reports and regularly met with the Safety Manager to discuss any concern that may affect industrial safety. This approach is considered by the team as a good performance.

1.8 CULTURE FOR SAFETY The team did not undertake a detailed safety culture assessment at the plant. However, the overall experience of the team was utilized to capture safety culture attributes, behaviours and practices which help to shape and define the safety culture at the plant. The team noted that the plant had carried out nuclear safety surveys, established a people first committee and had appointed a dedicated Nuclear Safety Culture Coordinator who carried out trending on events.

Also notable were the efforts to engage staff with the traits of a nuclear safety organisation by interpreting the wording of traits into messages that resonated with the staff at Wolf Creek.

With respect to observed strengths, the team noted that the strongest characteristic was Safety is integrated into all activities with many processes and individuals showing this attribute as part of normal business.

However, the team noted that some attributes could be strengthened to improve the overall safety culture and safety performance at the plant. The team observed that deviations from established and international standards contributed to a lack of questioning attitude.

Contributing to this were limited opportunities to carry out benchmarking against international Page 3 LEADERSHIP AND MANAGEMENT FOR SAFETY

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 best practices and some programmes and activities were not subjected to periodic self-assessment. This indicated that shortfalls exist in the following safety culture characteristic area: Safety is learning driven.

Page 4 LEADERSHIP AND MANAGEMENT FOR SAFETY

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 DETAILED LEADERSHIP AND MANAGEMENT FOR SAFETY FINDINGS 1.4 MEASUREMENT, ASSESSMENT, AND CONTINUOUS IMPROVEMENT 1.4 (1) Issue: The plants approach to continuous improvement does not always take advantage of all opportunities for organizational learning and performance improvement for sustainable safe plant operation.

During the review the team noted:

- Despite the average outage duration deviation of 6 days over the past 6 outages, no integrated analysis had been conducted to understand the causes of this pattern. When asked, senior leaders shared different opinions about the causes.

- The plant did not perform an analysis of some of its organizational changes before implementing them to identify any risk that could have implications for safety and to ensure that they were appropriately managed. Furthermore, once these changes had been implemented, there was no expectation to perform an effectiveness review of their outcome and results against predefined objectives.

- 96.9% of the behaviours assessed by leaders from the coaching and task observation programme in 2022 were deemed as meeting or exceeding expectations (38,612 out of 39,849). However, insufficient challenging of behaviours to improve individual performance while in the field, was a lost opportunity to improve human performance practices at the plant.

- Some activities, such as the leadership development programme and the coaching and observations programme, did not have pre-established frequencies for their self-assessment.

- Single Point Vulnerabilities (SPV) were not identified (labelled) in the field. However, there was guidance and good practices in the industry demonstrating that permanent tagging allowed SPVs to be visible to all personnel when in the field and thus minimized the risk of inadvertent impact or damage when working on nearby equipment. The plant had not implemented this good practice.

- Maintenance staff and supervisors had not received any training on how to identify counterfeit or suspect items, although individuals installing and testing components were the last barrier to identify parts that might differ from specifications.

- The plant did not require periodic reviews of all procedures to ensure that they were aligned with best practices and/or state-of-the-art. There were 50 administrative procedures that were last revised more than a decade ago. As an example, a procedure related to fuel integrity was from 2011 and included industry references from 1984, while there are more recent industry guidelines and good practices.

- As per the quarterly Organizational & Performance Improvement Reports, ten divisions had not reported any division clock reset (consequential events or minor events caused by human errors) during the year. For example, there have been no Division Clock Resets (DCR) in Design Engineering since December 2019, despite having a forced outage in June 2021 post refueling outage RF24. This was due to insufficient design validation related to the digital control system (7300) modification which resulted in inadequate steam generator water level control settings and a subsequent reactor trip on low steam generator water level.

- Despite electrical safety behaviours of staff being an area of concern for the plant due to not sharing electrical safety best practices, the team observed three electricians working Page 5 LEADERSHIP AND MANAGEMENT FOR SAFETY

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 in a 4160V cabinet (NB02 Bus) in short-sleeved shirts and wearing shoes without insulated soles. The workers involved in the work performed a Live-Dead verification and worked on the equipment without any electrical personal protective equipment (PPE). The plants standard allowed work to be performed on electrical equipment without electrical PPE once the equipment has been isolated and proved dead. However, there is operating experience in the industry of equipment being inadvertently re-energized and therefore the wearing of the electrical PPE is recommended throughout the testing period.

- The plant was in the third or fourth quartile ranking of USA plants in some of the key plant performance indicators affecting operational safety such as: High-Pressure Injection Unavailability, Heat Removal Unavailability and Emergency AC Unavailability.

- The indicator Unavailable Parts Needed To Support The Plant had been green for the past eight (8) months, although according to the indicators owner parts issues continually occur, and on occasions, work cannot be completed until the parts unavailability has been resolved.

- The plants 5-year As Low As Reasonably Achievable (ALARA) plan 2021 - 2026 had a list of collective radiation exposure mitigation initiatives. However, the plant did not rank the initiatives based on expected exposure saved or cost and did not track the progress of those initiatives.

- An Outage ALARA Report was required to be written by the plants ALARA Programme Procedure. The procedure specified the contents of the report, however not all the topics (for example an exposure summary table listing the major work performed and doses received, ALARA analysis for all major work with projected or actual exposures greater than or equal to certain value (i.e.,100 mSv, lessons learned, etc.) were covered by actual reports from last two outages. Although the reports contain radiological information from the outage, they did not consistently associate the information with the radiologically significant work. Furthermore, the report structure was different when comparing the last two outage ALARA reports.

Without leveraging all available opportunities for organizational learning and performance improvement, the sustainability of good nuclear safety performance could be challenged.

Suggestion: The plant should consider reinforcing its continuous improvement approach to take advantage of all learning opportunities to ensure sustainable safe plant operation and performance improvement.

IAEA Bases:

GSR Part 2 3.3. Managers at all levels in the organization:

(a) Shall encourage and support all individuals in achieving safety goals and performing their tasks safely; (b) Shall engage all individuals in enhancing safety performance 4.13. Provision shall be made in the management system to identify any changes (including organizational changes and the cumulative effects of minor changes) that could have significant implications for safety and to ensure that they are appropriately analyzed.

Page 6 LEADERSHIP AND MANAGEMENT FOR SAFETY

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 5.2. Senior managers and all other managers shall advocate and support the following: () e)

Measures to encourage a questioning and learning attitude at all levels in the organization and to discourage complacency with regard to safety.

6.4. Independent assessments and self-assessments of the management system shall be regularly conducted to evaluate its effectiveness and to identify opportunities for its improvement. Lessons and any resulting significant changes shall be analysed for their implications for safety.

6.6. Senior management shall conduct a review of the management system at planned intervals to confirm its suitability and effectiveness, and its ability to enable the objectives of the organization to be accomplished, with account taken of new requirements and changes in the organization.

6.8. Organizations shall make arrangements to learn from successes and from strengths for their organizational development and continuous improvement.

SSR-2/2 (Rev. 1) - Requirement 9 Monitoring and review of safety performance 4.33. An adequate audit and review system shall be established by the operating organization to ensure that the safety policy of the operating organization is being implemented effectively and that lessons are being learned from its own experience and from the experience of others to improve safety performance.

GS-G-3.5 2.29. The following are typical symptoms of a decline in safety culture: () (b)Procedures not being regularly reviewed and updated.

Appendix 1 (Safety Culture Attributes): Open reporting of deviations and errors is encouraged:

The organization should have a variety of established processes to allow and encourage individuals to report abnormal conditions, concerns and events, including near misses.

Recognition should be given to individuals and to teams who report abnormal conditions, concerns and events, including near misses.

Page 7 LEADERSHIP AND MANAGEMENT FOR SAFETY

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023

2. TRAINING AND QUALIFICATIONS 2.2. QUALIFICATION AND TRAINING OF PERSONNEL The plant had established a Training Request System, which could be used by employees to raise requests for both training (to close potential knowledge and skill gaps) and for the revision of training materials. All accredited and non-accredited training programmes used this system, and all training requests were stored within a database. The plant had set a clear expectation that all training requests were screened, analyzed and presented for approval to the relevant training committee within 30 days. However, it was identified that a total of 177 training requests had been raised but the Training Needs Analysis (TNA) had not been completed nor submitted to the relevant committee for approval. In the majority of cases, the training request had not been screened or assigned. Furthermore, only 38 of the aforementioned requests had been raised within the required 30 days, with the oldest training request being raised in 2018.

The team made a suggestion in this area.

Page 8 TRAINING AND QUALIFICATION

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 DETAILED TRAINING AND QUALIFICATION FINDINGS 2.2. QUALIFICATION AND TRAINING OF PERSONNEL 2.2 (1) Issue: The plants training request process is not always effective in responding to potential performance deficiencies in a timely manner to ensure the required knowledge and skills exists amongst its employees.

During the review the team noted:

- As of 14 March 2023, there were 104 training requests (some of which were the same request but for various programmes to consider) in an open state and awaiting assignment.

The oldest open and unassigned training request (2019-0268-3) regarding site medical emergencies, was raised in 2019 and had not been reviewed and assigned an owner by the Safety department/programme. There was a clear expectation from the Site Vice President that all training requests should be reviewed and assigned within 30 days. Other examples of open and not assigned training requests were as follows:

- TR 2021-0057-1

- Raised 10 March 2021

- Responsible department/programme: Leadership

- TR 2022-0122-8

- Raised 25 June 2022

- Responsible department/programme: Shift Manager/Shift Technical Advisor

- TR 2022-0155-5

- Raised 22 August 2022

- Responsible department/programme: Initial Licenced Operator

- As of 18 March 2023, there were 73 Training Requests that had been assigned an owner but were still awaiting the Training Needs Analysis (TNA) to be performed before the proposed solution to close the training request could be presented for approval to the relevant training committee (locally known as a Working Group) and for approval by the line management. The oldest Training Request 2018-0255-1, related to weakness in confined space awareness, was raised on 4 October 2018 and assigned to the Safety programme/department. The Training Needs Analysis (TNA) had not been completed and presented to the relevant training committee for approval. In addition, training request 2018-0311-18, regarding Professional to the core, was raised on 17 December 2018 and assigned to the Safety programme/department. The Training Needs Analysis (TNA) had not been completed and presented to the relevant training committee for approval.

- As of 18 March 2023, there were 187 Training Requests that had been approved by the relevant training committee (Working Group), but training had not been conducted. For example, of the oldest Training Requests that had been approved and awaiting training to be delivered:

- Training request 2019-0056-1, regarding Instructor Training, was raised on 11 March 2019, with a delivery due date of 1 of June 2020. This training request was recorded as Open - Approved / No Training Conducted, hence the training needs analysis had been approved but was still open with no evidence that training had been delivered. Upon further investigation with the Educational Specialist, this training had been postponed until a later date due to prioritisation.

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OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023

- Training request 2019-0138-1, regarding Vision Training for Instructors, was raised in 2019. This training request was recorded as Open - Approved / No Training Conducted, hence the training needs analysis had been approved but was still open with no evidence that training had been delivered.

- Training request 2018-0288-1, regarding Maintenance of Power Diodes (used for emergency diesel generators), was raised on the 6 November 2018. This training had recently been conducted in quarter 1 2023, over four years since the original request was made. In addition, an effectiveness evaluation was still required to confirm the identified performance deficiency had been resolved.

Ineffective response to training requests could lead to staff performance deficiencies not being closed in a timely manner.

Suggestion: The plant should consider enhancing its arrangements for the timely administration of training requests, thus ensuring the required knowledge and skills exists amongst its employees to avoid potential performance deficiencies.

IAEA Bases:

SSR-2/2 (Rev.1) - Requirement 7: Qualification and training of personnel.

4.16. The operating organization shall clearly define the requirements for qualification and competence to ensure that personnel performing safety related functions are capable of safely performing their duties. Certain operating positions may require formal authorisation or a licence.

4.21. The training programmes shall be assessed and improved by means of periodic review.

In addition, a system shall be put in place for the timely modification and updating of the training facilities, computer models, simulators and materials to ensure that they adequately reflect current plant conditions and operating policy, and that any differences are justified.

NS-G-28 4.14. A systematic approach to training should include the following phases:

Analysis. This should comprise the identification of training needs and of the competences required to perform a particular job.

Design. In this phase, competences should be converted into training objectives. These objectives should be organized into a training plan.

Development. In this phase, training materials should be prepared so that the training objectives can be achieved.

Implementation. In this phase, training should be conducted by using the training materials developed.

Evaluation. In this phase, all aspects of the training programmes should be evaluated on the basis of data collected in each of the other phases. This should be followed by feedback leading to improvements in the training programmes and to plant improvements.

GS-G-3.1 4.20. Training should be designed to ensure that the training content addresses the specific needs of individuals and the overall organization. This means that training should be planned and carried out using a systematic approach, with established measurable objectives and with Page 10 TRAINING AND QUALIFICATION

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 a means of evaluating its effectiveness. Qualified instructors who are competent in the area of expertise and in the necessary instructional techniques should be involved in the analysis, design, development, implementation and evaluation of training. Training is crucial to the continuing development of personnel. Senior management should therefore also allocate technically competent experts in the subject matter to develop the training curricula necessary for the achievement of the organizations objectives and to enhance the development of personnel. Line managers should participate personally in the analysis of training needs, in the review and approval of training programmes and plans (as well as in the delivery of some parts of the training), and in the evaluation of the effectiveness of the training.

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OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023

3. OPERATIONS 3.4 CONDUCT OF OPERATIONS The team observed that field operators conducted regular plant tours to ensure that the status of equipment was evaluated and that abnormal conditions were identified and reported. The Field Operator tours were aided by the use of a small mobile programmable plant tour device.

This tool guided the Operator to areas which required local readings and was programmed with clear action trigger points. However, during plant tours and observations, the team found several deficiencies not identified by field operators. These deficiencies included material condition, incorrect storage of equipment and housekeeping. Therefore, the team made a suggestion in this area.

3.6 FIRE PREVENTION AND PROTECTION PROGRAMME The plant had a fully qualified on-shift fire brigade made up of the field operators which included the brigade leader and fire responders. An agreement with the local district fire department guaranteed a minimum off-site fire response. The plant had procedures, initial and refresher training programmes as well as regular fire drills, including the annual joint fire drill with all involved firefighting services. However, there was a low and variable attendance of the off-site fire responders in the annual joint drills and no practical training of the off-site firefighters had taken place inside the radiologically controlled area. In addition, there were no fixed muster locations for each building in case of a fire alarm and there were no drill reports with a description of the trained scenario, lessons learned, areas for improvement or strengths, related to the effective coordination and cooperation with all firefighting responders. The team made a suggestion in this area.

Page 12 OPERATIONS

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 DETAILED OPERATIONS FINDINGS 3.4 CONDUCT OF OPERATIONS 3.4 (1) Issue: The field operations are not always carried out with the level of rigor to ensure that material conditions and housekeeping deficiencies are identified and reported.

During the review the team noted:

Material Condition:

- Not all deviations were identified and reported during a field operator walkdown in the auxiliary building. For example, minor damage to insulation on the Essential Service Water (ESW) system (EF V41 - safety related), broken plant label on the industrial air system KA V072 (not safety related) had not been identified.

- A field operator did not report that the bottom 5cm of gas bottle KC-PCV0087 with 4%

hydrogen was corroded.

- There was degraded floor coating under the seal water cooler outlet drain from condenser vacuum pump 1C which was not reported by the field operator.

- Overall lighting inside the plant and in the Emergency Diesel Generator-B room was not always sufficient to enable field operators to clearly see plant indications. For example, when starting the Emergency Diesel locally after troubleshooting, the Field Operators had to use their flashlights to ensure labels were clearly read on the local cabinet.

- The caps from the drain valves (needed for post firefighting activities) from the emergency exhaust filter absorbers in the spent fuel building were difficult to remove due to their proximity to the floor. The same situation was observed in the auxiliary/fuel normal exhaust filter unit in the auxiliary building. These were not identified by the field operator.

- During the routine field operator rounds, the fuel oil temperature was recorded for the station blackout diesel generators. The instrument was located near the floor making it difficult to read.

- In the Spent Fuel Building (SFP 2047 elevation) two fire extinguishers were mounted on the wall above a flexible coupling for the instrumentation cabling of one of the FLEX SFP level measurement instruments. The extinguishers were secured to the wall with the vendor supplied hoop which was not seismically secured.

- Out of 6 reviewed Manager in Field Observation cards (executed by the Shift Managers),

performed between 05 January and 12 March 2023, the section Field Operators Perform Detailed Rounds was rated as meet expectations in three observations and marked exceeds expectations in three. This is not in alignment with the findings during the plant tour performed by the OSART team, where several deviations were found in the field without any Condition Report being raised.

- During the OSART team walkdown the following defects had not been reported during field operator rounds:

- AC-HIS-269A and 269B lightbulbs in Reheater Second Stage Blanketing Steam System Panel (used when system is out of service) were not illuminating.

- AF-V201 and AF-V227 (valves in the heater drain tank recirculation line) had traces of oxidation on the valve bodies.

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OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023

- Valve AF-V228 with traces of oil leaks on the thermal insulation (non-active).

- Safety injection pump room cooler floor mesh had missing fixing bolts.

- There was a vibrating pipe from the main turbine component, ACHV025, which was rubbing against structural steel without any damper to protect the pipe.

- The floor coating next to steam generator blowdown regenerator heat exchanger Cond Inlet ISO BM-V184, was degraded.

- Between ball valve test connection KD-V236 and ball valve test connection KD-V239 (Potable water system) there was surface rust on the flange connections and the coating was degraded.

- In the radiologically controlled areas (RCA), 2000 elevation, there was a scaffold storage area right across a narrow passageway near to a FLEX electrical panel.

The ladders and the kick-plates on the upper racks were not tied or secured to prevent accidental movement during a seismic event.

Cleanliness/Housekeeping:

- The life buoys and throw ropes at the spent fuel pool were lying on the floor and not in designated storage locations. This had not been reported by field operators.

- The floor in the Circulating Water Screen House had lime stains and the coating was degraded. Contributing to this condition was the service water pump packing was leaking and the pipe to collect the leakage was not routed to a drain.

- The contents of the Operations storage cabinet in the auxiliary building next to door 11171 were stored in a disorganized manner. The same condition existed in the operations storage cabinet on the first floor of the turbine building.

- There was a discarded sign and incorrectly stored scaffolding foot behind the welding staging area adjacent to valve KA-V759 in the auxiliary building.

- A ladder was incorrectly stored against wall adjacent to crane bay, in the auxiliary building.

- The floor coating under the seal water cooler outlet drain from condenser vac pump 1C was degraded.

- During a Field Operator (FO) walkdown in the auxiliary building, the FO could not describe what was allowed to be put in the marked temporary storage areas.

Consequently, it was difficult for him to challenge whether the area was in the correct condition or not.

Without adequate attention to anomalies in the field, the condition of structures, systems and components could gradually deteriorate.

Suggestion: The plant should consider enhancing the level of rigor to ensure that field operations identify and report material condition and housekeeping deficiencies.

IAEA Bases:

SSR-2/2 (Rev.1) - Requirement 28: Material conditions and housekeeping 7.10. Administrative controls shall be established to ensure that operational premises and equipment are maintained, well-lit and accessible, and that temporary storage is controlled and limited. Equipment that is degraded (owing to leaks, corrosion spots, loose parts or damaged Page 14 OPERATIONS

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 thermal insulation, for example) shall be identified and reported and deficiencies shall be corrected in a timely manner.

NS-G-2.14 4.39. To ensure best practice for identifying and reporting deviations, specific training should be provided to the shift personnel. In addition, supervisors should coach operations crews and individual operators in achieving a consistent standard in identifying and reporting plant deficiencies.

Page 15 OPERATIONS

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 3.6. FIRE PREVENTION AND PROTECTION PROGRAMME 3.6. (1) Issue: The plant arrangements for fire evacuation and joint training with firefighting services are not comprehensive to ensure an optimum fire response capability.

During the review the team noted:

Joint training with all involved firefighting services:

- According to the plant procedures, one drill with off-site fire responders was to be performed per year. As the on-site fire brigade consists of 6-crews, not all the on-site fire teams have the opportunity to exercise with the off-site fire responders.

- The off-site fire responders receive training on radiation protection, which included a presentation and a simulation of radiation-controlled area conditions on the plant.

However, there had not been a common fire drill with the off-site fire responders in the radiologically controlled areas (RCA) to allow hands-on training and familiarization with actual RCA conditions.

- Only the attendance of the off-site fire responders at the on-site fire drills was documented. There were no reports with a description of the scenarios used, lessons learned, areas for improvement or strengths.

- The plant had an agreement for the local district fire department to provide additional fire, disaster and management assistance. However, the attendance of the off-site fire responders varied: 16 attended in 2022, four in 2021, no drill in 2020, 15 in 2019, 19 in 2018, nine in 2017. In addition, the drill in 2021 (during the pandemic) did not meet the agreement number of members with only one team leader and two, two-man-hose teams.

- The annual off-site fire drill was not performed in 2020 due to the COVID-pandemic and an additional drill was not performed in 2021.

Fire evacuation & Response:

- There were no evacuation plans installed in buildings or evacuation escape route signs on the floor in the radiologically controlled areas (RCA).

- There were no fixed muster locations for each building in case of a fire alarm.

- The plant performed annual fire evacuation drills for buildings of high occupancy but not for the whole plant.

- In 2022, six announced and six unannounced fire drills for the on-site fire responders were performed. However, the six unannounced fire drills were all outside the RCA.

Furthermore, the on-site fire responders for crews C and F were the only crews who performed a fire drill inside the RCA which was an announced drill.

- According to off normal fire response procedure (OFN KC-016), a valid fire condition is defined as a fire reported by personnel, fire alarm verified by inspection or multiple fire alarms received. In these circumstances the fire response team would be assembled immediately. In the case of a single alarm, one individual for the on-site fire responder team would be dispatched to verify conditions in the field and the remainder of the fire response team would only be assembled after the individual had reported if there is an actual fire which delays the fire response.

- Field Operators, who are part of the on-site fire brigade response team, undertook walkdowns of the Essential Service Water System (ESW) twice a day. During this walkdown they were inside another security area and this can cause a delay in the on-site Page 16 OPERATIONS

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 fire response. Furthermore, the plant has not performed a time response study to assess the impact of such a delay.

- The plant used the plant announcement (PA) system as the primary means of contacting the on-site fire responders in the event of a fire outbreak. Radios were the alternative method of communication but were not always carried by the fire responders. However, there were areas of the plant where the PA system was difficult to hear. Furthermore, when interviewing three field operators who were members of the on-site fire responders, they stated that there were examples when they were required to respond to a fire drill, but their response was delayed as they did not hear the announcement via the plant PA system.

- The plant did not have a pre-arranged schedule to provide additional on-site fire responders in order to strengthen the on-site fire brigade in the event of severe fire outbreaks.

- All qualified fire watch and brigade members were provided with hands-on extinguisher training. All other plant employees were only provided with computer-based training on fire extinguisher use.

Without adequate arrangements for fire prevention, protection and response programmes, the plant fire response could be compromised which could lead to delays in extinguishing potential fires as well as in the evacuation of personnel.

Suggestion: The plant should consider enhancing its arrangements for fire evacuation and joint training with the firefighting services to ensure a more effective fire response capability.

IAEA Bases:

SSR-2/2 (Rev. 1) - Requirement 22: Fire safety 5.23 In the arrangements for firefighting, special attention shall be paid to cases for which there is a risk of release of radioactive material in a fire. Appropriate measures shall be established for the radiation protection of firefighting personnel and the management of releases to the environment.

5.24 The operating organization shall be responsible for ensuring that appropriate procedures, equipment and staff are in place for effectively coordinating and cooperating with all firefighting services involved. Periodic joint fire drills and exercises shall be conducted to assess the effectiveness of the fire response capability.

NS-G-2.1:

8.4. Where full or partial reliance for manual firefighting capability is placed on off-site resources, there should be proper co-ordination between the plant personnel and the off-site response group in order to ensure that the latter is familiar with the hazards of the plant. The responsibilities and lines of authority for manual firefighting personnel should be documented in a fire fighting plan.

9.1. All plant staff and contractors personnel temporarily assigned to the plant should receive training in plant fire safety, including their responsibilities in fire incidents, before starting work at the plant. This training should include the following topics:

fire safety policy at the plant; awareness of specific fire hazards, including limitations on area fire loading and, where necessary, associated radiological concerns; Page 17 OPERATIONS

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 the significance of the control of combustible materials and ignition sources and its potential impact on the permissible fire loading in an area; means of reporting fires and actions to be taken; recognition of audible and visual fire alarm signals; means of exit and emergency evacuation routes in the event of fire; the different types of fire extinguishing equipment provided and their use in extinguishing fires in the initial stage.

NS-G-2.8:

4.34. Training should be provided for all staff members who have assignments under the emergency plan. The training for emergencies should include the periodic performance of emergency drills and exercises. Training should also include conventional safety, in particular in firefighting and medical first aid. Periodic drills and exercises should be held to reinforce training and to assess the effectiveness of the emergency response capability. There should be full scale exercises involving external organizations such as the police, fire services, ambulance teams, rescue teams and other emergency services.

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OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023

4. MAINTENANCE 4.5 CONDUCT OF MAINTENANCE WORK The team observed deficiencies in mechanical standards when assembling and disassembling equipment and in the bolting arrangements for some plant equipment. In addition, electrical work was not always conducted with work practices and behaviours to support personal safety.

In addition, the plant FME standards were not always implemented. The team made a recommendation in this area.

4.7 WORK CONTROL The plant had a comprehensive programme for planning and scheduling maintenance tasks.

The plant had implemented a 13-week scheduling process with defined milestones. The work management organization was the owner of the planning and scheduling process and worked with all maintenance sections to adapt the schedule to the available skills and resources.

However, the team noted that planning and scheduling of maintenance activities were not adequately implemented. The team observed that deviations in scheduling and planning led to delays in the completion of maintenance tasks on safety related equipment. Preparation of maintenance tasks was not always adequate, leading to additional technical specification entry and extended safety related equipment deficiency. The maintenance backlog included tasks open since 2020, yet during the OSART mission, the maintenance team were not performing any maintenance activities for more than three days (cumulated on two weeks) due to insufficient work planning. The team made a suggestion in this area.

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OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 DETAILED MAINTENANCE FINDINGS 4.5. CONDUCT OF MAINTENANCE WORK 4.5.(1) Issue: The plant maintenance activities are not always controlled and implemented in a manner to ensure equipment reliability and personnel safety.

During the review, the team noted:

During the disassembly of the locking nut of the steam generator start-up feed pump PAE02, the maintenance workers used a hammer (ballpeen) and brass drift punch to remove the locking nut. There was visible damage to the locking nut from previous attempts to remove the locking nut using inappropriate tools. The supervisor who was present during the activity did not correct the workers.

During the assembly of the steam generator start-up feed pump PAE02, maintenance workers mistakenly inverted one of the pump brass slinger rings which then required the pump to be disassembled. To enable the pump to be disassembled, the pump bearing had to be removed for a second time, which involves the cold extraction of the bearing along the pump shaft. The use of the cold extraction of bearings technique should be minimized in order to reduce the probability of damage to the pump shaft. Workers took a photo of the pump prior to the start of the work but had not used it for reference during the re-assembly of the pump.

During maintenance of the steam generator start-up feed pump, PAE02 maintenance workers were not able to install the bearing housing on two occasions and they did not stop to request help from engineering or review the manufacturers information. During their attempts to assemble the bearing on the pump body, they used the fixing threads of the pump body with threaded rods to make the bearing fit the pump body which put additional strain on the pump body threads.

There were examples where the bolting requirements for flanges and equipment were not in compliance with the plant standard which was to have the nut and bolt level.

However, international standards require the bolt threads exceed the nut by at least two threads. Examples were found on emergency diesel generators and on emergency cooling pump. These conditions had not been identified by maintenance personnel.

During maintenance observations, two valve stems on the feedwater heater extract and drains system, (AFFV73A/B) were identified as damaged by the use of clamps during a previous maintenance activity. The damage was 1mm marking around the stem upper part. This was not identified by plant personnel.

During the startup of the safety related component cooling water pump, (4.16 kV CCW), the maintenance workers did not step away from the electrical cabinets (TADOT NB01 BUS - SEP GRP1) as required, when control room announcement requested them to do so because they did not hear the message clearly.

During the injection of 9400V to the motor startup feed water pump from the low/medium voltage system electrical cabinet (PBO4), a permanent guard was stationed at the working place to avoid workers inadvertently approaching the motor.

However, the maintenance team carrying out the work complied with the plant standard, but this required them to work at less than one meter from the motor with no exclusion area or dedicated barriers in place to protect them from electric shock in the event of an accidental short circuit.

Page 20 MAINTENANCE

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 During the assembly of air compressor (CKAO1B), workers assembled two bolts out of five with the FME cover removed even though there was a clear risk of bolts falling inside the compressor. This was pointed out by the lead technician only after two bolts were assembled and his colleague coached them on the FME risk.

During the pre-job briefing (PJB) of I&C (Instrumentation & Controls) maintenance on reactor control cabinet identified as sensitive (DO1265T), the supervisor and workers did not discuss the FME requirements. Furthermore, they did not carry out initial or final FME checks of the work area. This was contrary to plant expectations.

During preventive maintenance of the safety related 4kVA system utilizing procedure Loss of Voltage and Degraded Voltage TADOT NB01 BUS - SEP GRP1, a worker mixed two steps. He mixed the step of activation 8.11.7 and the step of de-activation 8.11.10 of the indicating lamps. The worker found out his mistake and stopped the test.

After discussion with the supervisor, the test resumed, and step 8.11.7 was performed again. Workers used three-way communication only on the step references and did not use three-way communication on the indicator references which contributed to the mistake. The procedure was identified as a continuous use procedure.

I&C workers made two mistakes when performing the preventive maintenance of the safety related reactor protection system cabinet. On one occasion, a worker had not configured his equipment for current injection and was not able to proceed with the task. He stopped the task but was not able to find his mistake. On the second occasion, the test required surveillance on the system computer near the electrical cabinet, but the worker was sent to the control room. On both occasions, the I&C manager performing field observation corrected the two workers and allowed the task to continue.

Improper maintenance practices and the use of improper maintenance tools may result in degradation of structures, systems, and components (SSC) important to safety, emergent corrective maintenance, rework, and injury to personnel.

Recommendation: The plant should enhance the control and implementation of maintenance activities to ensure equipment reliability and personnel safety.

IAEA Bases:

SSR-2/2 (Rev.1) - Requirement 28: Material conditions and housekeeping 7.11 An exclusion programme for foreign objects shall be implemented and monitored.

SSR-2/2 (Rev.1) - Requirement 31: Maintenance, testing, surveillance and inspection programmes 8.8 A comprehensive work planning and control system shall be implemented to ensure that work for purposes of maintenance, testing, surveillance and inspection is properly authorized, is carried out safely and is documented in accordance with established procedures.

8.9. An adequate work control system shall be established for the protection and safety of personnel and for the protection of equipment during maintenance, testing, surveillance and inspection.

NS-G-2.6:

5.14. A comprehensive work planning and control system applying the defence in depth principle should be implemented so that work activities can be properly authorized, scheduled Page 21 MAINTENANCE

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 and carried out by either plant personnel or contractors, in accordance with appropriate procedures, and can be completed in timely manner.

6.7. Once an activity for MS&I has been completed, the results should be reviewed by a competent person other than person who performed the activity. The review should establish whether the activity was appropriate and was properly completed and should provide assurance that all results satisfy the acceptance criteria.

GS-G-3.1 2.21 All work that is done should be planned and authorized before it is commenced. Work should be accomplished under suitably controlled conditions by technically competent individuals using technical standards, instructions, procedures, or other appropriate documents.

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OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 4.7. WORK CONTROL 4.7(1) Issue: The plant work control arrangements are not always effective in planning, scheduling, and work package preparation, to ensure timely repair of system, structures, and components.

During the review, the team noted the following:

Planning & Scheduling In May 2022, condition reports, CR10014472 and CR10014489 were issued for problems with the excitation of A-train Emergency Diesel Generator. The prioritization of the work to be carried out under WO (Work Order) 22-479602-000 was 4 (low priority). There were several reasons why the work was still not finished and while the system was functional, there was an increased risk that the operational margins could be reduced if the emergency diesel was required to operate.

During the review of maintenance departments performance indicators, all indicators were green for the last quarter of 2022. This was not in line with non-critical preventive maintenance backlog which was in red for the work management department. The planning and scheduling of maintenance tasks was performed in collaboration between maintenance department and work management department. However during the OSART mission, for 4 days, maintenance personnel were available to carry out scheduled maintenance, but no maintenance work was planned by the work management department. For example, maintenance tasks such as 20-461655- 001-Replace motor belt sheave on SGL12A and 20-466450-000 Troubleshoot SGK05A low refrigerant level" were identified as priority 2 in the maintenance backlog. They were also identified in the online maintenance backlog, but the work was not scheduled and therefore not executed even though resources were available to do so. Furthermore, the preventive maintenance backlog for non-critical maintenance included more than 230 overdue tasks and the corrective maintenance backlog included more than 100 online corrective maintenance tasks.

Work Package Preparation

- During maintenance of a leaking seal valve, a maintenance worker discovered that the tagging performed by operations did not allow them to perform the task in a safe manner.

According to plant requirements, the maintenance clearance order holder must check that all the required isolations are in place and safe prior to starting work as this is the last barrier in the clearance order programme to guarantee workers safety. However, when the maintenance worker came to work on the system, they noticed that one of the required isolations was not in place.

The drawing used by the mechanics from the work package during work on the steam generator start-up feed pump PAE02 was inaccurate. The slinger ring installed on the steam generator start-up feed pump PAE02, was different from the one in the work package. The correct document was not initially included in the work package. Workers needed more details than the drawing provided in the work package and had to print the drawing from the vendor manual. The lack of this drawing in the work package contributed to the first slinger ring being wrongly assembled by the night shift maintenance team.

During the exchange of the room cooler motor (SGL11B) under technical specification condition (LCO), plant workers discovered that the new spare was not equivalent to the old Page 23 MAINTENANCE

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 one. After investigations, the supervisor discovered that this was due to a modification performed eight years ago that was not considered during work package preparation. The task was rescheduled and will incur an additional LCO entry.

Without an effective and efficient work control process, the planning, scheduling, and prioritization can result in untimely repair of important systems, structures and components and can compromise plant safety.

Suggestion: The plant should consider enhancing its work control arrangements for effective planning, scheduling, and work package preparation to ensure timely repair of systems, structures, and components.

IAEA Bases:

SSR-2/2 (Rev.1) - Requirement 31: maintenance, testing, surveillance and inspection programmes 8.8 A comprehensive work planning and control system shall be implemented to ensure that work for purposes of maintenance, testing, surveillance and inspection is properly authorized, is carried out safely and is documented in accordance with established procedures.

8.14. Corrective maintenance of structures, systems and components shall be performed as promptly as practicable and in compliance with operational limits and conditions. Priorities shall be established, with account taken first of the relative importance to safety of the defective structures, systems, and components.

NS-G-2.6 5.14. A comprehensive work planning and control system applying the defence in depth principle should be implemented so that work activities can be properly authorized, scheduled and carried out by either plant personnel or contractors, in accordance with appropriate procedures, and can be completed in a timely manner. The work planning system should maintain high availability and reliability of important plant SSCs (Systems, Structures or Components).

5.18. Management of the work should be recognized as a cross-functional process, not exclusive to any one work group but integrating the important activities of all work groups.

Consequently, for the work control process to be fully effective, all needs and concerns in relation to operations, maintenance, technical support, radiation protection, procurement and stores, contractors and other matters should be considered and should be accommodated wherever appropriate, consistent with the long-term operating strategy for the plant.

5.19. The effectiveness of the work control process should be monitored by appropriate indicators (such as repeated work orders, individual and collective radiation doses, the backlog of pending work orders, interference with operations) and by assessing whether corrective action is taken whenever required.

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OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023

5. TECHNICAL SUPPORT 5.4 AGEING MANAGEMENT The plant had an Ageing Management Programme based on Nuclear Regulatory Commission (NRC) requirements which included obsolescence. However, the team noted gaps in the implementation of corrective actions that derived from the different ageing management processes such as: ageing walkdowns, analysis of condition reports and data from work orders.

The team also identified through a review of plant documentation, condition reports, and events, that there were some shortfalls in the management of active components through the ageing management and obsolescence programmes. The team made a suggestion in this area.

5.7 PLANT MODIFICATION SYSTEM The plant had a Plant Modification Process to manage design modifications as per industry standard design process IP-ENG-001-F01. However, the team noted weaknesses in the process associated with the design modifications, in particular, deviations in the effectiveness of the independent review and assessment of safety related modifications. The plant had recognized this shortfall and had included within the 2023 business plan, actions to improve the safety assessment in the design modification process through cross-functional reviews and verifications of design changes. In addition, they were planning a review of previous modifications that may not have had suitable independent review prior to implementation on plant. The plant is encouraged to improve its plant modification process to ensure that personnel who are not involved in the design and implementation of the modification carry out a review of the scope and safety implications of proposed modifications.

Page 25 TECHNICAL SUPPORT

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 DETAILED TECHNICAL SUPPORT FINDINGS 5.4. AGEING MANAGEMENT 5.4(1) Issue: The Ageing Management and Obsolescence Management Programmes are not yet fully implemented at the plant to minimize the risk of unplanned failures of systems, structures and components (SSCs).

During the review the team noted:

The plant did not have an integrated aging management process which defined the status of ageing management for both passive and active components to demonstrate that the effects of aging and degradation mechanisms were being effectively managed.

The fan motor of the containment air cooler A, (SGN01A) stopped while shifting to fast speed, resulting in Containment Air Cooler 'A' being declared inoperable and an entry into Technical Specification 3.6.6 in 2018. Plant personnel performed troubleshooting, per WO 18-439264-000, and replaced a control power fuse, CRF relay, and the 42F contactor coil. After replacing these components, the starter was tested, and the Containment Cooling Motor operated in slow and fast speed as expected. The plant developed a set of actions to find alternatives for the obsolescent components, but they have still not been able to fix the obsolescence problem from 2018. This issue is part of the Maintenance Rule (a)(1) Issues (#53 GN-01 Fan Cooler Supply Breakers 42 Starter Relays 31/10/2018).

The plant had not implemented a technical solution to solve identified obsolescence issues on the emergency diesel generators regulators. A specific analysis was performed in 2016 and this proposed two solutions: reverse engineering or replacement with new technology. A solution had been presented and approved by the Plant Health Committee and was in the long-term plan. At the time of the mission, one of the two diesel generators had a backup power amplifier in an unusable state and the plant had not taken any actions in accordance with the long-term plan timeline. The proposed solution was expected to take one year to implement.

The plant engineering team used the System IQ software to record and display the system health status of tier one and tier two plant systems. At the time of the OSART mission, the Diesel Generator Systems showed the plant system to have a Green condition. Previous discussions had revealed that the diesel generator currently had a degraded voltage regulator circuit that was awaiting investigation and rectification, a problematic jacket water pump, due to obsolescence issues and was on the worry list of the regulator and the plant. The current approved system health report for the diesel generator system was dated 30 June 2022 and had the diesel generator score at 83 and in white, healthy condition.

The plant had an Obsolescence report with only 121 identified components.

The plant followed the process established by the Nuclear Regulatory Commission (NRC). In Annex A of the License Renewal Application (LRA) Safety Evaluation Report (NUREG 1915), 41 commitments were identified. However, all commitments were related to ageing management for the passive components. During the plant tour, ageing management defects were observed for both passive and active components:

Emergency Diesel train B: rusty bolts .

Page 26 TECHNICAL SUPPORT

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 Emergency Cooling System (EF): pipes and welds without paint and with rust, bolts with rust and rust in the penetration OP311W0841.

Component Cooling Water System: Spacer washers on the EG-V064, bolts with rust, wall with cracked and peeling paint (Outside the room 1968)

High-pressure coolant injection: Spacer washers degrading on EM-HV8802A.

Containment Spray room: Unidentified oil leak on component PEN0IB.

Fire Protection System: leaks on valves KC-V425 and KC-V440.

The plant had a Bolting Integrity Aging Management Programme, as part of the Ageing Management Programme. However, no activities were being developed regarding the management of corrosion, unless material wastage was identified.

The procedure AI 23-012 indicated the need to inspect insulated pipes during walkdowns. The requirement was to inspect a minimum of 20% of the pipe length of each (in scope) material every ten years. However, some components that had previously showed superficial corrosion were not inspected during subsequent outages.

The procedure AI 23-012 included the acceptance criteria for metallic components.

These must not show signs of loss of material, discoloration, corrosion or pitting during visual inspection. In the case of stainless steel, they must be clean and shiny, otherwise, a condition report (CR) must be generated for each identified case. However, plant walkdowns reports identify components with surface corrosion that did not have an associated CR, for example, during refueling outage RF25 in 2022, Emergency Cooling System: EFV0365, EFV0272, EFV0273, EFV0274, EFV286, EFV0195, Component Cooling Water: EG098HBD-12, EG102HBC-12, were reported as having surface corrosion but no CR was generated.

During the ageing management walkdowns, CRs are created to identify any relevant conditions regarding the components within the scope of the ageing management programme. A Work Order (WO) was required to be raised to implement an action arising from the CRs. However, the following WOs have not yet been executed:

- CR10004351 - reactor coolant (BB) system - areas of external rust locations on piping segment BB185CBC-3. The areas were at two locations with both located inside the bioshield. The degradation had occurred over a long period of time and there was a recommendation for a protective coating to be applied in refuelling outage RF25 in 2022 but no work was carried out.

- CR10004130 for the same pipe on the reactor coolant system, identified rust on the coupling below BBTE0011. Rust was light external corrosion with a recommendation for a protective coating to be applied in refuelling outage RF25 but this was not done (WO21-470210).

- CR10004263 for the same pipe on the reactor coolant system, identified rust on flow element BBFE0019 bolting and on the piping to the right of the flow element.

The degradation had occurred over a long period of time and there was a recommendation for a protective coating to be applied in refuelling outage RF25 in 2022 but no work was carried out (WO21-470219-000).

- CR10004252 for the reactor coolant system, identified rust on flow element flange BBFE0031. The degradation had occurred over a long period of time and there was a recommendation for a protective coating to be applied in refuelling outage RF25 in 2022 but no work was carried out.

The last available system health report for the Component Cooling Water (CCW) system for the period of 01 January- 30 June 2022 stated in the executive summary that Page 27 TECHNICAL SUPPORT

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 an upward trend in the chlorides, fluorides, and sulphates was detectable which could be indicative of an Essential Service Water (ESW) to CCW in-leak, but the leakage rate was below any administrative or action level. However, according to a system engineer, an administrative level for chloride at 7,000, triggers a bleed and feed to bring the level down, which was required to be undertaken during the last cycle, but this was not done.

Also, while an adverse condition monitoring template had been completed by operations which discussed risk, a risk level (low, medium, high) in accordance with AI 22C-016 had not been assigned.

The CCW-A heat exchanger had an in-leakage of circa. 500 l/day as of February 2023.

Action level for feed & bleed of CCW was based on chloride content. The water sampling was increased from quarterly to monthly. During RF24 (refueling outage) corrective maintenance did not detect the leak location. During RF25 outage, heat exchanger A could not be worked on. Thus, the leakage was still present in the current cycle. Since RF24, several CRs have also been raised on heat exchanger A & B issues, for example, quite a few tubes were blocked. No aggregate risk assessment was done on these issues. According to a system engineer, this was not an expectation and was usually not done.

In the first half of 2020, an evaluation of the aging of the CCW motor was submitted to the Plant Health Committee (PHC). The CCW pump motors date back to the start-up of the plant with each train at 2x100%. At that time Predictive Maintenance showed an increase in high frequency vibration levels in motors A and B. Such increases are an early indication of possible bearing failures. However, the increase had not reached any alert or action level. However, no risk assessment was provided, contrary to the requirements specified in procedure AI 22C-016 "Condition of the Unit and Residual Operational Risk".

According to the CCW system Life Cycle Management Plan (LCMP), there was an on-going long-standing issue with Low Oil Level of the CCW pumps. Related CRs had continued to be raised regularly over the last ten years. This issue was risk assessed in 2019 and remains open on the operations deficiency validation report. This issue was not listed in the latest CCW system health report.

Without comprehensive ageing management and obsolescence management programmes, the operability and reliability of safety related structures, systems and components could be jeopardized.

Suggestion: The plant should consider enhancing the implementation of the ageing management and obsolescence management programmes to ensure potential risk of unplanned failure of SSCs is minimized.

IAEA Bases:

SSR-2/2 (Rev. 1) - Requirement 14: Ageing management.

The operating organization shall ensure that an effective ageing management programme is implemented to ensure that required safety functions of systems, structures and components are fulfilled over the entire operating lifetime of the plant 4.50. The ageing management programme shall determine the consequences of ageing and the activities necessary to maintain the operability and reliability of structures, systems and components. The ageing management programme shall be coordinated with, and be consistent with, other relevant programmes, including the programme for periodic safety review. A systematic approach shall be taken to provide for the development, implementation and continuous improvement of ageing management programmes.

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OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 SSG 48 2.6 Effective ageing management throughout the lifetime of SSCs requires the use of a systematic approach to managing the effects of ageing that provides a framework for coordinating all activities relating to the understanding, prevention, detection, monitoring and mitigation of ageing effects on the plants structures and components.

2.8 To maintain plant safety, the effects of ageing on SSCs (i.e. net changes in characteristics) should be detected in a timely manner, so as to be able to take appropriate actions to ensure that the required safety functions of SSCs are fulfilled over the entire lifetime of the nuclear power plant.

2.11 Ageing management covers all activities that aim to prevent or control ageing effects, within acceptable limits, throughout the entire lifetime of the nuclear power plant (i.e. design; fabrication or construction; commissioning; operation, including long term operation; and decommissioning, including long term shutdown),

2.25 Nuclear power plant safety can be impaired if the obsolescence of SSCs is not identified in advance and corrective actions are not taken before the associated decrease in the reliability or availability of SSCs occurs.

2.26 Management of obsolescence is part of the general approach for enhancing nuclear power plant safety through ongoing improvements in both the performance of SSCs and safety management.

3.20 A systematic approach (see Fig. 1) should be applied to managing the ageing and obsolescence of SSCs to ensure that required intended functions are maintained at all times during the operation stage of the nuclear power plant.

5.22 An ageing management review for in-scope SSCs should be performed to ensure and demonstrate that ageing will be effectively managed.

6.1 Technological obsolescence of the SSCs in the plant should be managed through a dedicated plant programme with foresight and anticipation and should be resolved before any associated decrease in reliability and availability occur.

6.6. The technological obsolescence programme should include three basic steps (see Fig. 6):

(1) The operating organization should identify the installed SSCs important to safety that are technologically obsolete or will become obsolete in the upcoming years.

(2) The identified equipment should be prioritized on the basis of the safety and criticality significance of the obsolete equipment (i.e. its impact on the plant safety).

(3) The operating organization should develop and implement effective replacement solutions in a timely manner. Solutions to manage technological obsolescence are illustrated in Fig. 7 and are described in the IGALL technological obsolescence programme [5].

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6. OPERATING EXPERIENCE FEEDBACK 6.3 IDENTIFICATION AND REPORTING The team noted that over the last three years, an average of over 8,000 Condition Reports (CR) per year were raised in the operating experience programme (CAP - Corrective Action Programme), many of which were low-level events. However, some deficiencies in identification and reporting of low-level events in the operating experience programme were observed by the OSART team. Personnel from different organizational departments did not always report, potentially consequential, Foreign Material Exclusion (FME) deviations, chemical labelling, seismic, housekeeping, or radiological protection deficiencies. In some cases, this was because the deficiency was not identified as such. The team encourages the plant to continue to promote the identification and reporting of low-level events.

6.5 INVESTIGATION The team noted that the plant had an event cause evaluation process with different types of evaluations to be undertaken depending upon the event cause. The procedure Condition Report Resolution listed the minimal attribute requirements for the condition report evaluation, for example, for Level of Effort Evaluations (LEE), Common Cause Evaluations (CCE) Trend Analysis (TA), or for Equipment Performance Evaluations (EPE). In two out of three EPEs reviewed, some aspects of these minimal requirements were assessed as being too restrictive and thus prevented some meaningful information from being developed and flowing into the system health programme. The team encourages the plant to review the minimum attribute requirements for EPEs to enable more meaningful information to flow from the equipment performance evaluations process into the system health programme.

The team observed that after an event where an isolation had not been correctly put in place (CR 10022974). The plant assembled a multidisciplinary discovery team the following day to discuss the event evolution to ensure the timely capture of all important information and to decide on immediate actions. Technical as well as organizational and human performance factors were discussed in an open way without noticeable restrictions. A check list also provided good discussion guidance. The meeting provided a positive environment for comprehensive discussions into the causes of the event to be investigated. These activities were recognized as an area of good performance.

Page 30 OPERATING EXPERIENCE FEEDBACK

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 DETAILED OPERATING EXPERIENCE FINDINGS None Page 31 OPERATING EXPERIENCE FEEDBACK

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023

7. RADIATION PROTECTION 7.4. CONTROL OF OCCUPATIONAL EXPOSURE.

The team noted that the plants performance in the radiation protection area had improved in the last periods as shown by various Radiation Protection (RP) indicators. Also, the Collective Radiation Exposure for last outages were comparable to industry standards. However, the team observed that in some cases, the plant missed opportunities to reduce exposure by re-evaluating and changing the way work was carried out. There were also examples of discrepancies in radioactive material labelling, which can lead to a reduction in the significance of the radioactive warning labels perceived by the workers. The plant is encouraged to further search for opportunities to reduce personnel exposure, where reasonable, and to reinforce the expectations for radiological labelling.

Page 32 RADIATION PROTECTIION

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 DETAILED RADIATION PROTECTION FINDINGS None Page 33 RADIATION PROTECTIION

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023

8. CHEMISTRY 8.3 MANAGEMENT OF CHEMISTRY DATA Before the start of load changes, the plants Chemistry department worked closely with the Operations and Reactor Engineering departments to anticipate lithium adjustment with water and boron makeup to the reactor coolant system using a spreadsheet calculator. This practice minimized lithium deviations from the chemistry specifications requirements. The team recognizes this as a good performance.

8.4 CHEMISTRY SURVEILLANCE AND CONTROL PROGRAMME The plant utilized a software, connected to the plants computers, to perform a variety of chemistry activities. In particular, the software was used to automatically adjust sampling according to the chemistry surveillance programme and the plant mode. The software was also used to record analysis results, check violations and abnormalities and to automatically send an e-mail every morning to notify the chemistry supervisors, laboratory supervisors and quality check personnel, of any deviations. In addition, the plant used the software to trend chemistry performance and edit chemistry indicators and reports which could be sent directly to the appropriate personnel. The team recognizes this as a good performance.

The plant had not performed portable gamma scans to characterize the radionuclides deposited on pipes and equipment. Moreover, the plant did not inject zinc to the primary water to try and reduce dose rates. However, the plant was currently evaluating radiation protection techniques to characterize radionuclides during the next outage and would add zinc to the primary water prior to steam generator replacement, if required. The team encourages the plant to continue assessing the different options for source term reduction.

8.5 LABORATORIES AND MEASUREMENTS The plant had implemented the ORTEC Mbius Recycler as an innovative device to recycle the liquid nitrogen needed to cool the intrinsic germanium detectors used in the laboratories.

This practice allowed the plant to significantly reduce the quantity of liquid nitrogen being brought into the radiologically controlled area (RCA) and the associated risks regarding personnel injury during liquid nitrogen handling. The team recognizes this as a good practice.

The plant had arrangements for the storage and labelling of chemicals and filters. However, they were not always fully implemented which could result in personnel safety, analytical results performance and equipment safety concerns. For example, the team observed three bottles without any labels in the mechanical workshop and a bottle containing sodium was found upside-down in the chemical storage room. Moreover, in the hot laboratory, the chemists struggled to find the specific silver-zeolite filters which must be used in the Radwaste Ventilation in case of an accident, as they were not clearly identified. The team encourages the plant to improve its practices for storage and labelling of chemicals and filters.

Page 34 CHEMISTRY

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 DETAILED CHEMISTRY FINDINGS 8.5. LABORATORIES AND MEASUREMENTS 8.5(a) Good practice: The plant had implemented an innovative device to recycle the liquid nitrogen needed to cool the intrinsic germanium (IG) detectors used in the laboratories.

Purpose Liquid nitrogen (LN) was used to cool intrinsic germanium detector in radiochemistry monitoring equipment. LN was being recycled with the ORTEC Mbius Recycler to significantly reduce the quantity of liquid nitrogen being brought into the radiologically controlled areas (RCA) and the associated risks regarding personnel injury during liquid nitrogen handling.

Description The Mbius Recycler technology was composed of a cryocooler and a specially designed twenty-seven-litre liquid nitrogen dewar. The Mobius Recycler was installed directly under the radiochemistry monitoring equipment and recycles the liquid nitrogen used for the IG detector cooling.

Figure 1: Mobius Recycler Installed Underneath Intrinsic Germanium Detectors During a loss of input power, the Mobius Recycler would continue cooling the detector as if it was a standard dewar.

The LN monitor could be remotely mounted and indicated the liquid level, power consumption, and pressure levels allowing for proactive maintenance scheduling.

Benefits Prior to using the Mbius recycler, the plant had an average of eight liquid nitrogen dewar refills twice a week, involving the delivery of large dewars of about 300 kg. These large dewars presented a safety hazard when maneuvered and transferred into the laboratories, which included the use of an elevator. They also required the handling of a cryogenic liquid, to transfer the liquid nitrogen from the large dewars to the detectors smaller dewars. Radiation Protection and warehouse personnel were required to support the transfers of these dewars into and out of the RCA on a routine basis. During handling of these large dewars, the plant had two injuries (one broken leg and one back injury).

Page 35 CHEMISTRY

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 Now, with the use of the Mobius Recycler, liquid nitrogen refills were performed approximately once every other year under normal, continuous operating conditions. Hence, the ability to provide the liquid nitrogen without the requirement for frequent system refilling, enabled the plant to save time, money and to reduce hazardous material handling. The Mobius Recycler also allowed the plant to reduce the risk of personnel injury. The plant also estimated that the use of the Mobius Recycler saved approximately $9500 per year.

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OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023

9. EMERGENCY PREPAREDNESS AND RESPONSE 9.1. ORGANIZATION AND FUNCTIONS The Emergency Planning organization had implemented an Emergency Response Organization (ERO) Stability indicator that showed the impact and potential vulnerabilities in ERO staffing levels due to the turnover of key personnel. This performance indicator was used to highlight potential changes to staffing of ERO key positions to the plant management. The team recognized this as a good performance.

9.3. EMERGENCY PREPAREDNESS The plant had a detailed drill and exercise plan that incorporated an evaluation process. The plant performed different types of exercises annually (full scale, tabletop, medical, etc.). The Technical Support Center (TSC) and Emergency Operations Facility (EOF) were of adequate size and sufficiently equipped. However, emergency preparedness arrangements were not always supporting effective emergency response actions. The team observed that some of the arrangements did not effectively cover all potential situations. For example, there was no specific guidance provided to periodically verify the TSC Emergency Diesel Generator fuel level when running during emergency situations. The team made a suggestion in this area.

Page 37 EMERGENCY PREPAREDNESS AND RESPONSE

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 DETAILED EMERGENCY PREPAREDNESS AND RESPONSE FINDINGS 9.3. EMERGENCY PREPAREDNESS 9.3(1) Issue: The plants on-site emergency preparedness arrangements are not always sufficient to ensure optimal and effective emergency response actions are carried out.

During the review the team noted:

- The plant did not use electronic dosimeters with an alarm function for emergency intervention teams. Only pocket ion chamber dosimeters and Optically Stimulated Luminescence dosimeters (OSL) were utilised. Also, the Technical Support Center (TSC) was not equipped with electronic dosimeters with an alarm function, only pocket ion chamber dosimeters were available.

- In the case of a classifiable event (alert / site area emergency / general emergency), the power plant had two designated Areas Assembly Points for evacuation preparation.

Both areas could be utilised at the same time and Emergency Evacuation instructions were available in these areas. However:

- Specific individuals were not appointed in advance to carry out activities according to Emergency Evacuation instructions at the assembly points. The required activities were performed by the first incoming department manager or senior manager. In addition, no special refresher training was performed for this activity.

- The plant had made provisions for continuous radiation monitoring in Area Assembly Points (APP 06-013), although they had not been practiced during exercises.

- Neither assembly point had storage locations for iodine prophylaxis and other personal protective equipment (PPE). PPE and iodine prophylaxis for emergency workers was located in the TSC and at other designated locations, but not at the designated assembly points.

- The assembly point located in the Charles Curtis Development Center had two designated assembly rooms. However, one room was a break area with a kitchen and the other contained a large amount of gym equipment.

- The diesel generator (DG) in the TSC was not equipped with a local indication for the level of fuel in the fuel tank. The measurement was carried out as part of the monthly check using a mechanical stick. However, there was no specific guidance provided to periodically verify fuel level during an emergency.

- Radiation protection manual (AP 25A - 001) described activities such as respiratory protection in case of unexpected airborne contamination. However, in the emergency evacuation instruction, there was no information about the required protection to prevent inhalation of potentially radioactive particles during evacuation for non-emergency workers.

- The power plant had prepared good-quality procedures for initial briefings, status update briefings, and emergency manager event reminders. These documents were also included in the offsite emergency manager's folder. However, they were marked as not mandatory, and only utilised as an aid to supplement the implementing procedure guidance. In addition, these documents were not included in the event record management system.

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- The plant had developed a system for the preparation for the assignment to a new position in Emergency Response Organization (ERO). This specified exactly what training was required. However:

- there were no prerequisite criteria such as previous experience, required license, specific knowledge, etc., for personnel who were identified to fulfil ERO critical positions.

- there was no system to independently review and evaluate the preparation phase of new personnel by another responsible person (for example emergency director).

Additionally, there is no formal nomination, such as nomination certificate, for ERO positions.

- The power plant conducted emergency drills where staff simulate transporting an injured and contaminated worker to the hospital. The worker was escorted by one radiation safety worker. However:

- no signed written record detailing the contamination survey of the injured person was produced. The place where the contamination occurred on the injured person was marked directly on the skin of the injured person, in accordance with plant procedure AP 25A-001 (Radiation Protection Manual) and additional decontamination guidance at the plant was provided. However no written record of the full survey results of the contaminated person was produced.

- the transportation for only one contaminated worker had been practiced annually.

A more challenging drill with the contamination of more than one worker had only previously practiced once in 2021.

- In the Emergency Operations Facility (EOF), there were three different places designated for the placement of boards with the current event classification. During a Tabletop Drill, the event was reclassified (updated) from the ALERT to SITE AREA EMERGENCY. In one location, the event classification was correctly displayed, but this was not updated in the second location (alternative TSC), and in an additional place, it was not used at all.

- Position tags were located at the doors of the TSC and EOF (TSC personnel board, EOF personnel board). The card position and signature indicated that the position was manned and provided information on the staffing readiness of the centre. However, only four out of 20 position tags were used during the Tabletop Drill (three in TSC and one in EOF).

Without providing effective arrangements for emergency preparedness on site, emergency response actions may be delayed.

Suggestion: The plant should consider enhancing the arrangements for the on-site emergency preparedness, to ensure optimal and effective emergency response actions are carried out.

IAEA Bases:

GSR Part 7 5.37. Arrangements shall be made for actions to save human life or to prevent serious injury to be taken without any delay on the grounds of the possible presence of radioactive material (see paras unforeseen location with information on the precautions to take in giving first aid or in transporting an individual with possible contamination.

Page 39 EMERGENCY PREPAREDNESS AND RESPONSE

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 5.41. The operating organization of a facility in category I, II or III shall make arrangements to ensure protection and safety for all persons on the site in a nuclear or radiological emergency.

These shall include arrangements to do the following: (a) To notify all persons on the site of an emergency on the site; (b) For all persons on the site to take appropriate actions immediately upon notification of an emergency; (c) To account for those persons on the site and to locate and recover those persons unaccounted for; (d) To provide immediate first aid; (e) To take urgent protective actions.

5.42. Arrangements as stated in para. 5.41 shall also include ensuring the provision, for all persons present in the facility and on the site, of: (a) Suitable assembly points, provided with continuous radiation monitoring; (b) A sufficient number of suitable escape routes; (c) Suitable and reliable alarm systems and other means for warning and instructing all persons present under the full range of emergency conditions.

NS-G-2.8 4.34. Training should be provided for all staff members who have assignments under the emergency plan. The training for emergencies should include the periodic performance of emergency drills and exercises. Training should also include conventional safety, in particular in firefighting and medical first aid. Periodic drills and exercises should be held to reinforce training and to assess the effectiveness of the emergency response capability.

There should be full scale exercises involving external organizations such as the police, fire services, ambulance teams, rescue teams and other emergency services.

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10. ACCIDENT MANAGEMENT 10.1. ORGANIZATION AND FUNCTIONS The plant had well-developed guidance for beyond design basis accidents that included Severe Accident Management Guidelines (SAMGs), Extensive Damage Mitigation Guidelines (EDMGs) and FLEX Support Guidelines. The plants SAMGs were based on the PWR Owners Group generic package and included computer-based training for establishing the competency of the Technical Support Centre (TSC) staff. The team however noted that the Accident Management Programme guidance was not comprehensive and the proficiency of TSC staff in managing severe accidents in all plant states could be improved. A suggestion was made in this area.

10.4. DEVELOPMENT OF PROCEDURES AND GUIDELINES The team noted a few examples of minor deficiencies in the SAMG documentation. These were related to the Spent Fuel Pool (SFP) level trigger points and the inclusion of the Station Blackout diesel generators as potential alternative power sources. The plant is encouraged to address these minor deficiencies in the SAMG documentation.

10.5. PLANT EMERGENCY ARRANGEMENTS WITH RESPECT TO SAM The plant implemented several proactive and cost-effective measures to ensure that the availability and material condition of beyond design basis mobile equipment was maintained at a high level. For example, operators perform walkdowns of the FLEX equipment in the FLEX buildings every shift, and the FLEX programme owner identified that mobile equipment tyre valve stem replacements can effectively address a common cause of flat tires without requiring costly tyre replacements. The team recognizes this as a good performance.

Page 41 ACCIDENT MANAGEMENT

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 DETAILED ACCIDENT MANAGEMENT FINDINGS 10.1. ORGANIZATION AND FUNCTIONS 10.1(1) Issue: The Accident Management Programme does not comprehensively ensure that guidance is available and Technical Support Centre (TSC) staff are proficient in managing severe accidents in all plant states.

The team noted the following:

- The Severe Accident Management Guidelines (SAMGs) do not currently cover shutdown plant states with the reactor head removed and Core Exit Thermocouples unavailable. Thus, there are no transitions in the associated off-normal procedures into the SAMGs. The plant is currently in compliance with Revision 0 of the PWR Owners Group (PWROG) generic SAMGs and this is a known deficiency in the PWROG generic SAMGs. The PWROG is in the process of adding shutdown accident guidance to the next revision of the generic SAMGs with an expected completion date of 2025. The plant had committed to staying aligned with any future revisions to the PWROG generic SAMGs.

- The plants procedure for Technical Support Center Operations assigned roles and responsibilities to the individuals and groups in the TSC. This document however did not address organizational aspects for the use of the SAMGs by assigning specific responsibilities for different parts of the SAMGs to the various groups and individuals in the TSC.

- The plant used computer-based training (CBT) to establish the competency of individuals in the TSC with regards to severe accident management. CBT however does not establish proficiency in the organizational aspects and lines of communication between the different individuals and groups responsible for the implementation of the SAMGs.

- The plant performed validation exercises for the SAMGs in 2018 that involved table-top exercises with knowledgeable and experienced plant personnel. Few TSC team drills or exercises that involved a significant portion of the SAMGs have been performed since then.

The team noted that:

- table-top exercises were performed with reactor engineering individuals in 2021 for core damage assessment that reached the entry conditions for the SAMGs, but these exercises did not involve entry into the SAMGs.

- emergency plan drills in 2022 exercised the Extensive Damage Mitigation Guidelines (EDMGs) for scenarios involving respectively a Spent Fuel Pool accident and a loss of numerous safety and support systems. While there is significant overlap between accident management strategies in the EDMGs and SAMGs, the EDMG-focused exercises do not always ensure that the command-and-control transitions in the SAMGs are exercised.

- Minor deficiencies were found in the printed SAMG documentation available in the TSC that were not previously identified by TSC staff during exercises and drills:

several SAMG documents (SAG-3 to SAG-10) were meant to be printed in booklet format with supplemental information on the left-hand page and guidance steps on the right-hand page, but they were found to be printed one-sided.

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OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 two SAMG documents (DPG and TSG-5) were meant to be printed in colour to indicate the priority of certain SAMG actions but were found to be printed in black and white.

Without proficient TSC staff and comprehensive severe accident management guidance covering all plant states, the ability of the plant to effectively manage severe accidents may be compromised.

Suggestion: The plant should consider enhancing the Accident Management Programme to ensure that comprehensive guidance is available and TSC staff are proficient in managing severe accidents in all plant states.

IAEA Bases:

SSG-54 2.28. Accident management guidance should be robust:

(e) It should consider plant conditions in shutdown modes, particularly when the containment barrier is temporarily not available or when it is difficult to add water for decay heat removal.

2.89. A specialized team or group of teams (referred to in this Safety Guide as the technical support centre staff) should be available in an emergency to provide technical support to the operating personnel. The technical support centre staff should have the capability, based on their knowledge of the plant status, to recommend actions appropriate for the situation. Such recommendations should be made after an evaluation of the potential consequences of the recommended actions and the possibility and consequences of using erroneous information. If the technical support centre staff are composed of multiple teams, the role of each team should be specified.

2.107. Results from exercises and drills should be systematically evaluated to provide feedback for the improvement of the training programme and, if applicable, the procedures and guidelines, as well as the organizational aspects of accident management.

3.105. All significant sources of radioactive material in the plant, including the reactor core and spent fuel pools, and the occurrence of accidents in all relevant normal operating and shutdown states (including open reactor or open containment barriers) should be addressed.

3.115. Exercises and drills should be based on scenarios that require the application of a substantial portion of the overall severe accident management programme in conjunction with emergency response and should simulate realistic conditions characteristic of those that would be encountered in an emergency. Large scale exercises providing an opportunity to observe and evaluate all aspects of severe accident management should be undertaken.

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OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023

SUMMARY

OF RECOMMENDATIONS AND SUGGESTIONS AND GOOD PRACTICE AREAS RECOMMENDATIONS, SUGGESTIONS & GOOD PRACTICE LMS Suggestion: The plant should consider reinforcing its continuous improvement approach to take advantage of all learning opportunities to ensure sustainable safe plant operation and performance improvement.

TQ Suggestion: The plant should consider enhancing its arrangements for the timely administration of training requests, thus ensuring the required knowledge and skills exist amongst its employees to avoid potential performance deficiencies.

OPS Suggestion: The plant should consider enhancing the level of rigor to ensure that field operations identify and report material condition and housekeeping deficiencies.

Suggestion: The plant should enhance its arrangements for fire evacuation and training with the firefighting services to ensure a more effective fire response capability.

MA Recommendation: The plant should enhance the control and implementation of maintenance activities to ensure equipment reliability and personnel safety.

Suggestion: The plant should consider enhancing its work control arrangements for effective planning, scheduling, and work package preparation to ensure timely repair of system, structures, and components.

TS Suggestion: The plant should consider enhancing the implementation of the ageing management and obsolescence management programmes to ensure potential risk of unplanned failure of SSCs is minimized.

OEF None RP None CH 8.5(a) Good practice: The plant has implemented an innovative device to recycle the liquid nitrogen needed to cool the intrinsic germanium (IG) detectors used in the laboratories.

EPR Suggestion: The plant should consider enhancing the arrangements for the on-site emergency preparedness, to ensure optimal and effective emergency response actions are carried out.

AM Suggestion: The plant should consider enhancing the Accident Management Programme to ensure that comprehensive guidance is available and TSC staff are proficient in managing severe accidents in all plant states.

Page 44

SUMMARY

OF RECOMMENDATION AND SUGGESTIONS

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 DEFINITIONS Recommendation A recommendation is a proven non-fulfilment with at least one IAEA Safety Requirement. A recommendation is specific, realistic and aim to enable the operating organization to make a tangible safety improvement.

Suggestion A suggestion is a proven and partial non-fulfilment with one IAEA Safety Requirement or with some Safety Guides expectations. A suggestion is specific, realistic and primarily intended to improve a safety performance.

Good practice A good practice is a proven programme, activity or equipment in use that contributes to and sustains operational safety. A good practice is novel, has a proven benefit, is replicable, goes beyond an IAEA requirement, does not contradict an issue, and is worth considering by other nuclear installations.

Good performance A good performance is a superior objective that has been achieved or a good technique or programme that contributes directly or indirectly to operational safety and sustained good performance, that works well at the nuclear installation. However, it might not be necessary to recommend its adoption by other nuclear installations, because of financial considerations, differences in design or other reasons.

Self-identified issue A self-identified issue is documented by the OSART team in recognition of actions taken to address inadequate conformance with the IAEA safety standards identified in the self-assessment made by the host organization prior to the mission and reported to the OSART team by means of the Advance Information Package. Credit is given for the fact that actions have been taken, including root cause determination, which leads to a high level of confidence that the issue will be resolved within a reasonable time frame. These actions should include all the necessary provisions such as, for example, budget commitments, staffing, document preparation, increased or modified training, or equipment purchases, as necessary.

Encouragement If an item does not have sufficient safety significance to meet the criteria of a recommendation or suggestion, but the expert or the team feels that mentioning it is still desirable, the given topic may be described in the text of the report using the phrase encouragement (e.g. the team encouraged the host organization to).

Page 45 DEFINITIONS

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 REFERENCES Safety Fundamentals (SF)

SF-1 Fundamental Safety Principles (Safety Fundamentals)

General Safety Requirements (GSR)

GSR Part 1 Governmental, Legal and Regulatory Framework for Safety GSR Part 2 Leadership and Management for Safety GSR Part 3 Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards GSR Part 4 Rev.1 Safety Assessment for Facilities and Activities GSR Part 5 Predisposal Management of Radioactive Waste GSR Part 6 Decommissioning of Facilities GSR Part 7 Preparedness and Response for a Nuclear or Radiological Emergency Specific Safety Requirements (SSR)

SSR-2/1 Rev.1 Safety of Nuclear Power Plants: Design SSR-2/2 Rev.1 Safety of Nuclear Power Plants: Commissioning and Operation General Safety Guides (GSG)

GSG-2 Criteria for Use in Preparedness and Response for a Nuclear and Radiological Emergency GSG-7 Occupational Radiation Protection GSG-11 Arrangements for the Termination of a Nuclear Radiological Emergency Safety Guides (SG)

NS-G-2.1 Fire Safety in the Operation of Nuclear Power Plans NS-G-2.2 Operational Limits and Conditions and Operating Procedures for Nuclear Plants NS-G-2.3 Modifications to Nuclear Power Plants NS-G-2.4 The Operating Organization for Nuclear Power Plants NS-G-2.5 Core Management and Fuel Handling for Nuclear Power Plants NS-G-2.6 Maintenance, Testing, Surveillance and Inspection in Nuclear Power Plants NS-G-2.8 Recruitment, Qualification and Training of Personnel for Nuclear Power Plants NS-G-2.14 Conduct of Operations at Nuclear Power Plants NS-G-2.13 Evaluation of Seismic Safety for Existing Nuclear Installations GS-G-2.1 Arrangement for Preparedness for a Nuclear or Radiological Emergency GS-G-3.1 Application of the Management System for Facilities and Activities Page 46 REFERENCES

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 GS-G-3.5 The Management System for Nuclear Installations RS-G-1.8 Environmental and Source Monitoring for Purposes of Radiation Protection Specific Safety Guides (SSG)

SSG-2 Rev.1 Deterministic Safety Analysis for Nuclear Power Plants SSG-3 Development and Application of Level 1 Probabilistic Safety Assessment for Nuclear Power Plants SSG-4 Development and Application of Level 2 Probabilistic Safety Assessment for Nuclear Power Plants SSG-13 Chemistry Programme for Water Cooled Nuclear Power Plants SSG-25 Periodic Safety Review for Nuclear Power Plants SSG-28 Commissioning for Nuclear Power Plants SSG-38 Construction for Nuclear Installations SSG-39 Design of Instrumentation and Control Systems for Nuclear Power Plants SSG-40 Predisposal Management of Radioactive Waste from Nuclear Power Plants and Research Reactors SSG-47 Decommissioning of Nuclear Power Plants, Research Reactors and Other Nuclear Fuel Cycle Facilities SSG-48 Ageing Management and Development of a Programme for Long Term Operation of Nuclear Power Plants SSG-50 Operating Experience Feedback for Nuclear Installations SSG-54 Accident Management Programmes for Nuclear Power Plants SSG-61 Format and Content of the Safety Analysis report for Nuclear Power Plants International Labour Office publications on industrial safety Guidelines on occupational safety and health management systems, International Labour office (ILO), Geneva, ILO-OSH 2001 Safety and health in construction, International Labour office (ILO), Geneva, ISBN 92 107104-9 Safety in the use of chemicals at work, International Labour office (ILO), Geneva, ISBN 92-2-108006-4 Page 47 REFERENCES

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 TEAM COMPOSITION MORGAN Simon - United Kingdom Years of nuclear experience: 30 IAEA Team Leader DUGUID Johan - United Kingdom Years of nuclear experience: 39 IAEA Deputy Team Leader GALLES Quim - Spain Years of nuclear experience: 23 Company: ANAV Review area: Leadership and Management for Safety WILLIAMS Lewis - United Kingdom Years of nuclear experience: 21 Company: EDF Review area: Training and Qualification GRIMGARD Klas- Sweden Years of nuclear experience: 28 Company: Vattenfall AB Review area: Operations 1 KOENIG Evamaria - Germany Years of nuclear experience: 13 Company: PreussenElektra GmbH Review area: Operations 2 SASSI Anis - France Years of nuclear experience: 10 Company: Onano/WANO Review area: Maintenance PEDERNERA Patricia - Argentina Years of nuclear experience: 15 Company: Nucleoelectrica Argentina. S.A.

Review area: Technical Support KRAHENMANN Dominik - Switzerland Years of nuclear experience: 20 Company: Leibstadt NPP Review area: Operating Experience Feedback KVASNICKA - Ondrej - Czech Republic Years of nuclear experience: 17 Company: CEZ, a.s Review area: Radiation Protection VIRICEL Laure - France Years of nuclear experience: 25 Company: EdF Review area: Chemistry LUDL Otto - Slovak Republic Years of nuclear experience: 23 Company: Slovenské Elektrárne Review area: Emergency Preparedness & Response BOSMAN Herman - South Africa Years of nuclear experience: 15 Company: Tractebel south Africa Review area: Accident Management Page 48 TEAM COMPOSITION

OSART MISSION TO Wolf Creek NPP, 6 - 23 March 2023 WOLTERS Carlo - Netherlands Years of nuclear experience: 7 Company: Borssele NPP Review area: Observer Page 49 TEAM COMPOSITION