IR 05000482/2024010

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Biennial Problem Identification and Resolution Inspection Report 05000482/2024010 (Public)
ML24254A437
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 09/10/2024
From: Ami Agrawal
NRC/RGN-IV/DORS
To: Reasoner C
Wolf Creek
References
IR 2024010
Preceding documents:
Download: ML24254A437 (21)
v • d • e


Text

September 10, 2024

SUBJECT:

WOLF CREEK GENERATING STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000482/2024010

Dear Cleve Reasoner:

On July 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Wolf Creek Generating Station and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations problem identification and resolution program to confirm that the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight Process can continue to be implemented.

The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and the stations use of industry and NRC operating experience information. The results of these evaluations are in the enclosures.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

One finding of very low safety significance (Green) is documented in this report (Enclosure 2).

Enclosure 2 transmitted herewith contains SUNSI. When separated from Enclosure 2, this transmittal document and Enclosure 1 are decontrolled. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Wolf Creek Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Wolf Creek Generating Station.

This letter, Enclosure 1, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding. Enclosure 2 contains Security-Related Information, so Enclosure 2 will not be made publicly available in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390(d)(1). If you choose to provide a response that contains Security-Related Information, please mark your entire response, Security-Related Information-Withhold from public disclosure under 10 CFR 2.390, in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). The NRC is waiving the affidavit requirements for your response in accordance with 10 CFR 2.390(b)(1)(ii).

Sincerely, Proulx, David signing on behalf of Agrawal, Ami on 09/10/24 Ami N. Agrawal, Team Leader Inspection Programs & Assessment Team Division of Operating Reactor Safety

Docket No. 05000482 License No. NPF-42

Enclosures:

As stated

Inspection Report

Docket Number: 05000482

License Number: NPF-42

Report Number: 05000482/2024010

Enterprise Identifier: I-2024-010-0006

Licensee: Wolf Creek Nuclear Operating Corp.

Facility: Wolf Creek Generating Station

Location: Burlington, KS

Inspection Dates: July 22, 2024, to July 30, 2024

Inspectors: D. Dodson, Senior Reactor Inspector J. Drake, Senior Reactor Inspector C. Henderson, Senior Resident Inspector S. Obadina, Reactor Operations Engineer

Approved By: Ami N. Agrawal, Team Leader Inspection Programs & Assessment Team Division of Operating Reactor Safety

Enclosure 2 transmitted herewith contains SUNSI. When separated from Enclosure 2, the transmittal document and Enclosure 1 are decontrolled.

Enclosure 1

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Wolf Creek Generating Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Use the Site Corrective Action Program to Correct Failures and Deficiencies in the Physical Protection Program Cornerstone Significance Cross-Cutting Report Aspect Section Security Green[P.2] - 71152B NCV 05000482/2024010-01 Evaluation Open/Closed The NRC identified a Green non-cited violation of 10 CFR 73.55(b)(10) for the licensees failure to take effective corrective actions to prevent recurrence of failures and deficiencies in the physical protection program. This non-cited violation is described in of this report.

Additional Tracking Items

None.

2

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)

Main article: IP 71152
(1) The inspectors performed a biennial assessment of the effectiveness of the licensees problem identification and resolution program, use of operating experience, audits and self-assessments, and safety-conscious work environment.
  • Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
  • Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
  • Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Corrective Action Program Effectiveness

Based on the samples reviewed, the inspectors determined that the licensee's corrective action program was adequate and supported nuclear safety during the assessed timeframe.

However, the inspectors noted one weakness in the area of effectiveness of corrective actions; additionally, the inspectors noted recent performance challenges in the areas of problem identification, prioritization and evaluation of issues, use of self-assessments and audits, and operating experience.

Problem Identification

The inspectors found that the licensee was generally identifying and documenting problems at an appropriately low threshold that supported nuclear safety. During the prior 24 months, the licensee entered approximately 5,700 condition reports into the corrective action program as conditions adverse to quality and initiated about 16,800 total condition reports. However, the inspectors noted some current performance challenges associated with identification of issues and entering issues into the corrective action program. Specifically, this report documents one minor performance deficiency with eight examples associated with identification of conditions adverse to quality during the screening process and an observation associated with identifying nuclear safety culture assessment trends as conditions adverse to quality.

Problem Prioritization and Evaluation

The inspectors found that the licensee was adequately prioritizing and evaluating problems such that nuclear safety was supported. However, the inspectors noted some current performance challenges associated with evaluation of issues. Specifically, this report documents two observations associated with extent of condition reviews and evaluation documentation quality.

In addition to these issues identified by the team, the inspectors noted three other performance challenges documented in recent NRC inspection reports. Specifically, relevant issues included NCV 05000482/2022050-04, NCV 05000482/2022402-02, and NCV 05000482/2022404-02. In each case, the performance deficiency or underlying causes related to inadequate evaluation of a condition adverse to quality or a finding that was assigned a P.2, Evaluation, cross-cutting aspect.

Effectiveness of Corrective Actions

The inspectors concluded that the station is adequately developing effective corrective actions and timely implementing those actions for the problems evaluated in the corrective action program, commensurate with their safety significance. However, the inspectors concluded that the station has a weakness associated with effectiveness of corrective actions based on a review of recently documented performance issues and additional concerns identified during the inspection. Specifically, this report includes one reoccurring NCV associated with effectiveness of corrective actions (NCV 05000482/2024010-01, which is included in Enclosure 2), one minor violation with three examples associated with failures to implement corrective actions that fully address the causes identified, and an observation associated with the licensee missing two opportunities to take more robust actions that might have prevented a July 2022 reactor trip. Additionally, the inspectors noted two other performance challenges associated with effectiveness of corrective actions, which were documented in recent NRC inspection reports. These included NCV 05000482/2022001-01 and NCV 05000482/2022401-03. In each case, the performance deficiency or underlying causes related to effectiveness of corrective actions and the NCVs were assigned a P.3, Resolution, cross-cutting aspect.

Assessment 71152B Operating Experience, Self-Assessments, and Audits

The inspectors reviewed a variety of sources of operating experience including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups. The inspectors also reviewed a sample of the station's self-assessments and audits to assess whether performance trends were regularly identified and effectively addressed. Additionally, the inspectors reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the inspectors concluded that the licensee is adequately screening and addressing issues identified through operational experience that applies to the station, and this information is being evaluated in a timely manner once it is being received. The inspectors also concluded that the licensee had an adequate self-assessment and audit process. However, the inspectors did note some recent performance challenges in these areas that were documented in other recent NRC inspection reports. These issues included NCV 05000482/2022001-02, which was assigned a P.5, Operating Experience, cross-cutting aspect, and NCV 05000482/2022050-01, which was assigned a P.6, Self-Assessment, cross-cutting aspect.

Assessment 71152B Safety-Conscious Work Environment

The inspectors conducted safety-conscious work environment focus group interviews with approximately 49 individuals from various departments and organizations across the site, including: non-licensed and licensed operators; and mechanical, electrical, and instrumentation and control maintenance; engineering; security; radiation protection; and chemistry personnel. The inspectors also observed interactions between employees during routine meetings; interviewed the Employee Concerns Program lead; and reviewed the results of the latest safety culture surveys and case files that relate to safety-conscious work environment. Based upon all these interviews, observations, and document reviews, the inspectors concluded that the station has an adequate safety-conscious work environment where individuals feel free to raise safety concerns without fear of retaliation.

While the inspectors determined that the station has an adequate conscious work environment where individuals feel free to raise safety concerns without fear of retaliation, the inspectors noted a few observations from our interactions with security and engineering personnel and other observations discussed in this report that have potential to impact safety-conscious work environment if not monitored and addressed appropriately.

Specifically, some individuals indicated that concerns important to security are often the last to get addressed. Personnel indicated that some of these concerns ranged from heating and cooling issues in isolated workspaces to other equipment concerns. Similarly, some engineering personnel noted that condition reports documenting necessary temporary or permanent equipment to complete work are sometimes not addressed until a third or fourth condition report is written for the same concern. Multiple groups also expressed that there is little to no feedback provided to some personnel on how condition reports are resolved.

Reflecting on this feedback, some questioned how the organization views their importance and wondered why they would bother to write condition reports for something that never gets fixed. While these statements do not indicate issues with maintaining a safety-conscious work environment, the inspectors noted that individuals losing confidence in the corrective action program or management's response to their concerns could degrade individuals' willingness to raise safety concerns.

Minor Performance Deficiency 71152B Failures to Screen Condition Reports in Accordance with Corrective Action Program Procedures

Minor Performance Deficiency: The inspectors identified eight examples of failures to screen condition reports in accordance with corrective action program procedures to ensure that conditions adverse to quality are evaluated and corrected in accordance with their safety significance.

Specifically, procedure AP 28A-100, "Corrective Action Program," step 6.2.1, states,

"[Screening Review Team] completes the screening process by assigning a [condition report]

owner, Category, and associated Assignment Types in accordance with procedure AI 28A-010, "Screening Condition Reports." Procedure AI 28A-010, "Screening Condition Reports," step 6.3.6, states, "The following attachments are tools provided to the [Screening Review Team] to assist with their determinations...Attachment A, Category and Levels." Step 6.3.7 also states, "Assess each issue based on the risk and vulnerability of the described issueby performing the following: Determine the issues category, level, and risk. Reference A, Category and Levels." Contrary to this standard, the licensee categorized seven condition reports as non-conditions adverse to quality even though the conditions were sufficiently similar to or the same as condition adverse to quality examples provided in procedure AI 28A-010, "Screening Condition Reports." The seven examples include the following:

  • Condition report 10012518, associated with an incorrect protective action recommendation during a drill/training scenario, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 36 condition adverse to quality example A.6.3.d, which includes, A condition adversely affecting performance in the [emergency preparedness] program. This includes issues involving drill or exercise implementation issues, including scenarios and critiques.
  • Condition report 10012584, associated with incorrect maintenance rule scoping of the NK025 swing charger, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 36 condition adverse to quality example A.13.3.1, which includes, "A condition that could lead or has led to an NRC minor violation or fatigue rule violations (Regulatory)."
  • Condition report 10019184, associated with safety-related essential service water piping in containment being coated with non-containment qualified coatings impacting coating margin calculations that ensure the containment sump is not adversely impacted by a design basis event, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 37 condition adverse to quality example A.7.3.4, which includes, "Items that impact safety related programs or require programmatic controls for tracking."
  • Condition report 10022543, associated with a human performance error impacting surveillance testing and manipulation of AL HV-12, steam generator C turbine driven auxiliary feedwater regulating control valve, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 38 condition adverse to quality example A.16.2.c, which includes, "Improper technical specification surveillance testing or maintenance."
  • Condition report 10028635, documented AL HK-0006A, steam generator D turbine driven auxiliary feedwater regulating valve controller (a functional importance determination 2 safety-related component) indication issues and the valve failing to meet its maximum allowed time to close, which required corrective maintenance.

Procedure AI 28A-010, Revision 38, states, "Functional Importance Determination (FID) 1, 2, or safety related (SR) equipment issues should be [conditions adverse to quality] or higher."

  • Condition report 10031043, associated with component cooling water room cooler calculation non-conservative single failure assumptions, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 38 condition adverse to quality example A.7.2.3, which includes, "A condition that has the potential to inhibit, or has inhibited, a safety-related or [Integrated Technical Specifications] structure, system or component from satisfactory performance of a safety-related or [Integrated Technical Specifications] function.
  • Condition report 10035173, associated with an NRC-identified emergency diesel generator fuel oil line vibration and indication of rubbing, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 39 condition adverse to quality example A.15.3.1, "Equipment non-conformances, deficiencies, etc., that do not pose a near-term challenge to equipment functionality or operability."

Similarly, condition report 10025950, associated with extent of condition actions to evaluate safety-related push buttons related to a DSGL13B containment spray pump room cooler auto-start circuit push button failure (documented in condition report 10025470, a condition adverse to quality), was categorized by the licensee as a non-condition adverse to quality condition report and closed to another non-condition adverse to quality condition report contrary to procedure AI 28A-100, "Condition Report Resolution," Revisions 23, 24, and 25, Step 6.1.3.1, which states, "A [condition report] may be closed to another [condition report] of equal or higher category and/or evaluation level."

The licensee documented these issues in their corrective action program as condition report 10035392.

Screening: The inspectors determined the performance deficiency was minor. The inspectors determined the examples of the performance deficiency did not adversely affect a cornerstone objective, would not lead to a more significant safety concern if left uncorrected, and could not reasonably be viewed as a precursor to a significant event.

Minor Violation 71152B Failure to Take Adequate Corrective Actions to Fully Address Causes

Minor Violation: The inspectors identified three examples of the licensee failing to fully correct conditions adverse to quality. Specifically, 10 CFR 50, Appendix B, Criterion XVI, requires, in part, that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

(1) Contrary to the above, from October 25, 2022, until August 1, 2024, the licensee did not ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances were promptly identified and corrected. Specifically, the licensee's failure to periodically calibrate radiation monitors as required (as documented in NCV 05000482/2023002-01), a condition adverse to quality, was not fully corrected.

While the licensee took some actions to update procedures, the corrective actions did not adequately address causes and ensure that the appropriate and responsible organizations were appropriately involved in preventive maintenance change decision making.

(2) Contrary to the above, from July 11, 2023, until August 1, 2024, the licensee did not ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances were promptly identified and corrected. Specifically, the licensee's failure to maintain fire protection compensatory measures during control room ventilation isolation signal actuation (as documented in NCV 05000482/2023002-01), a condition adverse to quality, was not fully corrected. While the licensee took actions to update procedures and other actions, the corrective actions did not adequately address causes and ensure that knowledge gaps were adequately corrected.
(3) Contrary to the above, from October 26, 2023, until August 1, 2024, the licensee did not ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances were promptly identified and corrected. Specifically, the licensee's failure to properly pre-plan and perform maintenance on 4160-volt Siemens breaker components (as documented in NCV 05000482/2023003-01), a condition adverse to quality, was not fully corrected. While the licensee took some actions to update procedures, the corrective actions did not adequately address causes and ensure adequate procedure changes to address loose connections.

The licensee documented these issues in their corrective action program as condition report 10035392.

Screening: The inspectors determined the performance deficiency was minor. The inspectors determined the examples of the performance deficiency did not adversely affect a cornerstone objective, would not lead to a more significant safety concern if left uncorrected, and could not reasonably be viewed as a precursor to a significant event.

Enforcement:

These failures to comply with 10 CFR Part 50, Appendix B, Criterion XVI, constitute minor violations that are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Nuclear Safety Culture Assessment Trending 71152B The inspectors reviewed Nuclear Safety Culture Assessments completed in 2019, 2021, and 2023. The licensee documented condition report 10027781 in response to the 2023 safety culture survey self-assessment and repetitive survey indications associated with work environment. The inspectors noted the station categorized condition report 10027781 as a non-condition adverse to quality. The inspectors also noted that procedure AI 28A-010, "Screening Condition Reports," Revision 38 included condition adverse to quality examples A.9.3.1.b, "Work environment concerns with line of site to the core," and A.9.3.6, "Adverse trend impacting safety or reliability or a large number of similar performance problems that could result in more significant future problems," that the licensee did not invoke. Additionally, the inspectors noted that screening and management review procedures provide flexibility to elevate condition reports based on frequency of similar events, severity, potential risk, and judgment. However, the station did not exercise its flexibility and elevate the condition report to be a condition adverse to quality and perform more than a very informal and minimally documented evaluation.

Considering the importance of individuals feeling comfortable to share differing opinions and being willing to approach station leadership, considering the importance of work environment and its similarities with and potential impact on maintaining a safety-conscious work environment where individuals feel free to raise safety concerns without fear of retaliation, and considering the screening and management review procedure flexibility, the inspectors concluded that the licensee's response to 10027781 was a missed opportunity for the station to demonstrate conservative decision making and sensitivity to safety-conscious work environment adjacent concerns.

The station captured the inspector's observation as condition report 10035397.

Observation: Opportunities to Identify Degradation Mechanisms 71152B The inspectors reviewed the licensees actions associated with multiple stem failures and issues associated with the B steam generator main feedwater regulating valve (MFRV)

(AEFCV0520), and the inspectors noted that there were at least two opportunities for the licensee to have more thoroughly evaluated failures and conditions prior to the July 18, 2022, B steam generator MFRV failure and plant trip. These opportunities for more thorough evaluation and effective actions, which included performance of a root cause evaluation for a similar 2021 failure and abnormal operation of the same AEFCV0520 component in May 2022, could have led to identification of the failure mechanism earlier.

Specifically, the inspectors noted that on July 18, 2022, the B steam generator MFRV (AEFCV0520) stem failed causing the valve to go closed. This caused a sudden reduction in feedwater flow to the B steam generator and resulted in an automatic reactor trip. The licensee entered this issue into the stations corrective action program as condition report 10016103, classified it as a significant condition adverse to quality, performed a root cause evaluation, and submitted Licensee Event Report 05000482/2022-001-00, Low Steam Generator Level due to Main Feedwater Valve Failure Caused Reactor Trip, Revision 0. The licensee ultimately determined that the cause of the valve stem failure was stress corrosion cracking starting in the region where the valve stem entered the packing area of the valve, which resulted from using the anti-seize lubricant along with high temperatures and the use of susceptible material. The NRC documented FIN 05000482/2022003-05, Failure to Properly Evaluate the Use of Anti-Seize Lubricant and Have Adequate Work Instructions, related to the issues.

The inspectors also noted that on August 18, 2021, the subject MFRVs valve stem had previously failed and resulted in a plant trip. After the failure on August 18, 2021, the licensee performed a root cause evaluation and determined that a fatigue crack propagated through the valve stem of the MFRV, causing the stem to fracture and subsequent plant trip. The NRC did not identify any performance deficiencies associated with this instance and documented this conclusion in NRC inspection report 05000482/2021004 (ML22012A444).

The licensees evaluation for the August 2021 failure did not identify that the stem was susceptible to stress corrosion cracking and that the mechanism was already occurringthis was later identified when the licensee performed a hardware failure analysis on the stem that failed in July 2022 and retroactively looked at the stem that failed in August 2021.

Additionally, the inspectors noted that on May 1, 2022, while at 60 percent reactor power, the licensee observed B steam generator level oscillating up to 2.5 percent on narrow range indications as a result of the subject MFRV cycling; at the same time, the other three steam generators were steady at approximately 50 percent steam generator level. The licensee documented condition report 10014005 but chose to continue with power ascension activities without fully understanding the causes behind the level oscillations. Per licensee engineering evaluation, the most likely cause of the steam generator level swings was increased packing friction, causing a higher hysteresis in the valve stroke and slight overshoot when the valve stroked, which set up the level swings that were seen. The licensee neither adjusted the valves packing prior to nor immediately following initiation of condition report 10014005. Less than 2 months later, the MFRV valve stem failed.

A new violation is not being documented here because FIN 05000482/2022003-05 documented the more-than-minor failure to properly evaluate the use of anti-seize lubricant and have adequate work instructions. However, this valve stems failure in August 2021 and the oscillations of the same valve in May 2022 represented opportunities for the licensee to identifyprior to the July 2022 failurethe failure mechanism that was identified as the cause of the July 2022 failure. Had more conservative decisions been made to conduct a more thorough evaluation of the August 2021 and May 2022 issues as they occurred, the licensee might have identified the degradation mechanism and taken action to prevent the July 2022 failure.

Observation: Reactor Trip Breaker Evaluation and Extent of Condition 71152B The inspectors reviewed NCV 05000482/2024001-02, "Failure to Perform Post-Maintenance Testing Following Maintenance and Installation of the Bypass Reactor Trip Breaker," and associated evaluations and noted that the extent of condition identified by the licensee focused narrowly on the reactor trip breakers. The licensee determined the failure to perform post-maintenance testing resulted from shifting the reactor trip breaker replacements from outage work to online work. However, the licensee's extent of condition did not focus on maintenance that was moved from outage work to online work. Additionally, this narrow extent of condition was not identified by the site's corrective action review board. The inspectors communicated this observation to the licensee, and the licensee documented condition reports 10035095 and 10035111.

Observation: Documentation and Evaluation 71152B The inspectors noted examples of evaluation and action documentation not capturing all the actions being taken or planned. For example, following a safety-related room cooler stop push button failing, the licensee planned corrective actions to replace the push button and extent of condition push buttons, including safety-related push buttons. However, the licensee's evaluation did not consider the probability of the equipment failing and determine a risk ranking for prioritizing replacements. The licensee later recognized the need to prioritize the push button repairs when they learned that there were obsolete parts involved. The licensee's plan was not thoroughly communicated throughout the organization and lacked documentation tied to the corrective action program documents necessary for correcting the conditions.

Similarly, a root cause evaluation associated with NCV 05000482/2022050-01, an issue impacting the Security cornerstone and associated with modifying equipment and introducing deficiencies, included an extent of cause evaluation and actions to addresses potential concerns in other areas of the plant. The licensee indicated that a review of locked high radiation areas was completed to partially address the extent of cause, but these actions were not documented.

The licensee documented condition reports 10035336 and 10035403 related to these observations.

EXIT MEETINGS AND DEBRIEFS

On July 30, 2024, the inspectors presented the biennial problem identification and resolution inspection results to Cleve Reasoner, Chief Executive Officer and Chief Nuclear Officer, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

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DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Calculations EC 20791 Alternative Start and Stop Pushbutton for Motor Control 0

Center Breaker Cubicles

71152B Corrective Action Action 19509240; 19509242; 19509244; 19509247; 19509249;

Documents 19562046; 19574193; 19574195; 19574197; 19574199;

19574201; 19574203; 19639799

71152B Corrective Action CR- 00011637; 00099349; 00142922; 00116831; 00136802;

Documents 00142179; 00143672; 01001806; 10000916; 10001080;

10003704; 10005735; 10005736; 10005736; 10005953;

10005991; 10005992; 10005994; 10007252; 10007386;

10007567; 10008876; 10009753; 10010478; 10011538;

10011637; 10011639; 10011645; 10011703; 10011896;

10011967; 10012135; 10012220; 10012238; 10012254;

10012478; 10012518; 10012584; 10012628; 10012707;

10013298; 10013554; 10014417; 10015098; 10015100;

10015102; 10015559; 10015736; 10016097; 10016103;

10016103; 10016194; 10016195; 10016196; 10016222;

10016223; 10015414; 10016681; 10016849; 10017247;

10017506; 10017950; 10017952; 10018051; 10018064;

10018065; 10018255; 10018470; 10019184; 10019265;

10019281; 10019914; 10020002; 10020043; 10020045;

10020786; 10021267; 10021273; 10021276; 10021277;

10021278; 10021309; 10021310; 10021482; 10021663;

10021746; 10021110; 10021866; 10022150; 10022543;

10022990; 10022993; 10023133; 10023402; 10024766;

10025080; 10025351; 10025392; 10025453; 10025615;

10025950; 10025987; 10025990; 10026429; 10027042;

10027781; 10027814; 10027996; 10028128; 10028305;

10028635; 10028646; 10028662; 10028663; 10028664;

10029005; 10029110; 10029246; 10029488; 10029579;

10029701; 10031043; 10031432; 10031684; 10031879;

10031968; 10032414; 10032572; 10033341; 10033341;

10034299; 10034299; 10035111; 10035173

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Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action CR-10035095; 10035111; 10035147; 10035173; 10035251;

Documents 10035259; 10035260; 10035265; 10035266; 10035267;

Resulting from 10035281; 10035287; 10035336; 10035347; 10035365;

Inspection 10035385; 10035392; 10035395; 10035396; 10035397;

10035403; 10035409

71152B Drawings J-301-00065 Type Test Report for Pressure Transmitters Rosemount 2

Model 1153 Series B

71152B Drawings J-301-00173 Certified Installation Drawing for Rosemount Model 1154 W02

Series H Pressure Transmitter

71152B Drawings J-301-00181 Qualification Report for Pressure Transmitter Model 1154 W02

Rosemount Report

71152B Drawings J-301-00191 Rosemount 1153 Series B Alphaline Nuclear Pressure W01

Transmitter

71152B Drawings M-12AL Piping and Instrumentation Diagram Auxiliary Feedwater 33

System

71152B Engineering 013324 Steam Generator Level Control, 7300system

Changes

71152B Engineering 21-003-RP-000 Remove Thermocouple BBT/C00S0 (R-10) from scan for the 0

Changes Thermocouple Core Cooling Monitor

71152B Engineering 21-003-RP-000 Remove Thermocouple BBT/C00S0 (R-10) from scan for the 0

Changes Thermocouple Core Cooling Monitor

71152B Engineering 23-003-MR-00 Cable Tray for startup transformer 0

Changes

71152B Engineering 23-003-MR-00 Cable Tray for startup transformer 0

Changes

71152B Engineering 23-005-EF-00 Hi Side Pressure, Alternate Supply 0

Changes EFPDT0043

71152B Engineering 23-005-EF-00 Hi Side Pressure, Alternate Supply 0

Changes EFPDT0043

71152B Engineering CCP 13531 MFRV (Main Feedwater Regulating Valve) Valve Stem 0

Changes Refurbishment

71152B Engineering CCP 13531 MFRV Valve Stem Refurbishment 0

Changes

2)),&,$/86(21/<+/-6(&85,7< 5(/$7(',1)250$7,21

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Miscellaneous Gore PTFE Facts 08/2021

71152B Miscellaneous Siemens Type 3AF-GER Vertical Lift Direct Replacement B

Vacuum Circuit Breakers

71152B Miscellaneous Siemens Vacuum Circuit Breakers (Vehicle) Type GER 5kV B

to 15kV

71152B Miscellaneous Mechanical-Packing-Safety-Data-Sheet-AP-STYLE-5000

71152B Miscellaneous 05-2024 Monthly CAP Report

71152B Miscellaneous 22-01-RP/PC QA Audit Plan 22-01-RP/PC Radiological Protection & 12/15/2021

Process Control

71152B Miscellaneous 22-04-OPS Quality Assurance Audit Report Operations 06/02/2022

71152B Miscellaneous 22-10-CHM Quality Assurance Audit Report Chemistry 10/26/2022

71152B Miscellaneous 24-01-RP/PC Quality Assurance Audit Report Radiological Protection &

Process Control Programs

71152B Miscellaneous 24-02-CAP Quality Assurance Audit Report CAP Audit 03/30/2024

71152B Miscellaneous 3002008059 Valve Packing Maintenance and Program Practices _ Update 1

to__3002005353

71152B Miscellaneous 3002023768 Cross-Linked Polytetrafluoroethylene Research for Fluid 07/2022

Sealing Applications_ Final Report

71152B Miscellaneous AMS 2460 Aerospace Material Specification Plating, Chromium 07/2007

71152B Miscellaneous APF 26A-011-02 10 CFR 21 Evaluation 0

71152B Miscellaneous COG-02-4065 Qualification Of Lattygraf 6940 EF And 6940 Braided 03/2003

Graphite Valve Packing AT 20.7 MPA Gland Stress

71152B Miscellaneous ECP Files 2022-005; 2022-007; 2022-010; 2022-012; 2022-015; 2022-

016; 2022-017; 2022-018; 2022-020; 2022-024; 2022-025;22-028; 2022-029; 2023-001; 2023-005; 2023-014; 2023-

018; 2023-019; 2023-020; 2023-021; 2023-025; 2024-001;24-003; 2024-005; 2024-017; 2024-019; 2024-024

71152B Miscellaneous EQSC-I Equipment Qualification Design Basis Document Equipment 20

Qualification

71152B Miscellaneous GNP-30839-AP Style 5000 Valve Packing 0

REPT-001

71152B Miscellaneous M-10GL System Description for Auxiliary Building Ventilation System 7

71152B Miscellaneous M-250 Valve Packing Standard 09

2)),&,$/86(21/<+/-6(&85,7< 5(/$7(',1)250$7,21

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Miscellaneous MEC-046 18" Containment Isolation Purge Valves

71152B Miscellaneous MEC-047 36" Containment Isolation Purge Valves

71152B Miscellaneous MEC-048 6" Hydrogen Purge CTMT ISO

71152B Miscellaneous Monthly CAP 1 to 12

Report 2023

71152B Miscellaneous Monthly CAP 1 to 6

Report 2024

71152B Miscellaneous PQE-J-301-P02 Rosemount Pressure and Differential Transmitter Models 4

1154 Series H

71152B Miscellaneous PQE-J-301-P05 Rosemount Pressure and Differential Transmitter Models 4

1154 Series H

71152B Miscellaneous QA-2023-0593 Screening Review Team (SRT) of Corrective Action Program 09/21/2023

(CAP) Surveillance

71152B Miscellaneous WCNOC-163 Mitigating System Performance Index (MSPI) Basis 14

Document

71152B Miscellaneous WCRE-34 Fourth 10-Year Interval Inservice Testing Basis Document 13

71152B Miscellaneous WCRE-35 Boundary Matrix 11

71152B Miscellaneous Weekly CAP 3-7-2022 to 12-12-2022

Reports 2022

71152B Procedures AI 01A-002 Fitness for Duty Screening 24

71152B Procedures AI 20-001 WCGS Quality Oversight Report 10

71152B Procedures AI 23M-007 Structures Monitoring Program 10

71152B Procedures AI 28A-010 Screening Condition Reports 36

71152B Procedures AI 28A-010 Screening Condition Reports 37

71152B Procedures AI 28A-010 Screening Condition Reports 38

71152B Procedures AI 28A-010 Screening Condition Reports 39

71152B Procedures AI 28A-100 Condition Report Resolution 25

71152B Procedures AI 28A-102 Root Cause Analysis 4

71152B Procedures AI 36-002 Nuclear Safety Culture Assessment 2

71152B Procedures ALR KC-888 Fire Protection Panel KC-008 Alarm Response 35

71152B Procedures AP 06-002 Radiological Emergency Response Plan (RERP) 24

71152B Procedures AP 10-103 Fire Protection Impairment Control 41

71152B Procedures AP 14B-001 Chemical Control Program 18

2)),&,$/86(21/<+/-6(&85,7< 5(/$7(',1)250$7,21

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Procedures AP 20B-001 Plant Safety Review Committee 20B

71152B Procedures AP 20E-001 Industry Operating Experience Program 32

71152B Procedures AP 20G-001 Control Of Inspection Planning and Inspection Activities 17B

71152B Procedures AP 21I-001 Temporary Configuration Changes Responsible Organization 16B

71152B Procedures AP 23M-001 WCGS Maintenance Rule Program 14

71152B Procedures AP 24C-001 Quality Review of Procurement Documents 6D

71152B Procedures AP 24C-008 Supplier Audits and Commercial Grade Surveys 18

71152B Procedures AP 24F-001 Certification Of ASME Material 4A

71152B Procedures AP 24H-003 Commodity Discrepancies 6A

71152B Procedures AP 25A-200 Access to Locked High or Very High Radiation Areas 29A

71152B Procedures AP 26A-001 Reportable Events - Evaluation and Documentation 27

71152B Procedures AP 26A-011 10 CFR Part 21 Review Process 0

71152B Procedures AP 28-011 Resolving Degraded or Nonconforming Conditions Impacting 8

SSCs

71152B Procedures AP 28A-100 Corrective Action Program 27

71152B Procedures AP 29E-001 Program Plan for Containment Leakage Measurement 17A

71152B Procedures EPP 06-009 Drill and Exercise Requirements 12

71152B Procedures EPP 06-009 Drill and Exercise Requirements 13

71152B Procedures MPE E009Q-03 Inspection And Testing of Siemens Vacuum Circuit Breakers 11

71152B Procedures MPE E009Q-03 Inspection And Testing of Siemens Vacuum Circuit Breakers 12

71152B Procedures OFN KC-016 Fire Response 54

71152B Self-Assessments ASMNT 2021-Pre-PI&R Self-Assessment 2021

205, SA-2021-

0167

71152B Self-Assessments ASMNT 2021-2021 STARS Round Robin PI-HU Assessment E 102

255, SA-2021-

0169

71152B Self-Assessments ASMNT 2021-NRC Triennial Heat Exchanger/Sink Performance Self- 03/10/2022

24, SA-2021-Assessment

0172

71152B Self-Assessments ASMNT 2022-Self-assessment - Prep for January 2023 INPO Corporate 09/07/2022

0072, SA-2022-Evaluation

2)),&,$/86(21/<+/-6(&85,7< 5(/$7(',1)250$7,21

Inspection Type Designation Description or Title Revision or

Procedure Date

0173

71152B Self-Assessments ASMNT 2022-Wolf Creek Employee Concerns Program Self-Assessment T 81

0073, SA-2022-

0174

71152B Self-Assessments ASMNT 2022-2022 Mid-Cycle Assessment 10/19/2022

0131, SA-2022-

0177

71152B Self-Assessments ASMNT 2022-Reactivity Management Self-Assessment

0149, SA-2022-

0178

71152B Self-Assessments ASMNT 2022-Confirmatory Order, Item P (CR 134185-01-18) - Perform an

242, SA-2022-Annual Effectiveness Review of the Corrective Actions

0179 Associated with NRC CO

71152B Self-Assessments SA-2019-0147

71152B Self-Assessments SA-2021-0166

71152B Self-Assessments SA-2023-0181

71152B Work Orders 08-305719-000

71152B Work Orders 09-313843-000

71152B Work Orders 12047

71152B Work Orders 19214

71152B Work Orders 19244

71152B Work Orders 19703

71152B Work Orders 19718

71152B Work Orders 21-473455-002 TS3 Troubleshoot Risk Level 3

71152B Work Orders 22-280609-000

71152B Work Orders 22-480608-000

71152B Work Orders 22-481103-000

71152B Work Orders 22-482865-000

71152B Work Orders 26959

71152B Work Orders 26961

71152B Work Orders 26962

71152B Work Orders 26964

71152B Work Orders 26967

2)),&,$/86(21/<+/-6(&85,7< 5(/$7(',1)250$7,21

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Work 26969

Orders

71152B Work Orders 26971

71152B Work Orders 32367

71152B Work Orders WO 22-480583 AEFCV0520, B Feedwater Control Valve Stem Replacement 07/22/2022

And Repacking

18

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