ML24295A379
| ML24295A379 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  (NPF-042) |
| Issue date: | 11/01/2024 |
| From: | Ami Agrawal NRC/RGN-IV/DORS/PBB |
| To: | Reasoner C Wolf Creek |
| References | |
| EA-24-091 IR 2024003 | |
| Download: ML24295A379 (1) | |
See also: IR 05000482/2024003
Text
November 01, 2024
Cleve Reasoner, Chief Executive Officer
and Chief Nuclear Officer
Wolf Creek Nuclear Operating Corp.
P.O. Box 411
Burlington, KS 66839
SUBJECT:
WOLF CREEK GENERATING STATION - INTEGRATED INSPECTION
REPORT 05000482/2024003
Dear Cleve Reasoner:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Wolf Creek Generating Station. On October 15, 2024, the NRC inspectors
discussed the results of this inspection with Robert Bayer, General Manager, Plant Operations,
and other members of your staff. The results of this inspection are documented in the enclosed
report.
One finding of very low safety significance (Green) is documented in this report. 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.
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
C. Reasoner
2
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
Ami N. Agrawal, Chief
Reactor Projects Branch B
Division of Operating Reactor Safety
Docket No. 05000482
License No. NPF-42
Enclosure:
Inspection Report 05000482/2024003
w/attachment: Request for Information
for the enforcement related order follow-up
cc w/ encl: Distribution via LISTSERV
Signed by Agrawal, Ami
on 11/01/24
x
SUNSI Review
By: MRB
x
Non-Sensitive
Sensitive
x
Publicly Available
Non-Publicly Available
OFFICE
SRI:DORS:B
RI:DORS:B
SPE:DORS:B
TL:DORS:B
D:DORS
NAME
CHenderson
CSigel
MBloodgood
AAgrawal
GMiller
SIGNATURE
/RA/
/RA/
/RA/
/RA/
/RA/
DATE
10/22/24
10/22/24
10/31/24
11/01/24
10/24/24
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket No:
05000482
License No:
Report No:
Enterprise Identifier:
I-2024-003-0004
Licensee:
Wolf Creek Nuclear Operating Corp.
Facility:
Wolf Creek Generating Station
Location:
Burlington, KS
Inspection Dates:
July 1 through September 30, 2024
Inspectors:
H. Anagnostopoulos, Senior Health Physicist
J. Drake, Senior Reactor Inspector
S. Hedger, Senior Emergency Preparedness Inspector
C. Henderson, Senior Resident Inspector
J. Melfi, Project Engineer
K. Murphy, Operations Engineer
J. O'Donnell, Senior Health Physicist
D. Proulx, Senior Project Engineer
C. Sigel, Resident Inspector
R. Williams, Operations Engineer
D. You, Operations Engineer
Approved By:
Ami N. Agrawal, Chief
Reactor Projects Branch B
Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated 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 Remove Motor-Operated Valve Thermal Overload Bypass Jumpers during
Surveillance Testing and System Maintenance
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
None (NPP)
The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part
50, Appendix B, Criterion III, Design Control, for the licensees failure to assure the
applicable design requirements associated with the licensees commitment to Regulatory
Guide 1.106, Thermal Overload Protection for Electric Motors on Motor-Operated Valves,
revision 1, was correctly translated into procedures and instructions. Specifically, the licensee
failed to translate that the thermal overloads be placed in force during stroking of
safety-related motor-operated valves for surveillance testing and routine maintenance into
procedures and instructions.
Additional Tracking Items
Type
Issue Number
Title
Report Section
Status
Failure to Perform Adequate
Audit of the Integrated Public
Alert Warning System
Open
Turbine-Driven Auxiliary
Feedwater Pump Turbine
Governor Valve Actuator
Failure (EA-24-091)
Open
Confirmatory Order, NRC
Inspection Report 05000482/2019010 and
NRC Investigation Report
4-2018-008 (EA-18-165)
92702 CONF
Closed
3
PLANT STATUS
Wolf Creek Generating Station began the inspection period at full power. On August 23, 2024,
the unit was shut down to Mode 4 in accordance with Technical Specification 3.7.5 for the
failure of the turbine-driven auxiliary feedwater pump to steam generator B air-operated isolation
valve, ALHV0010, and commenced forced outage 27-001 to repair ALHV0010. On August 26,
2024, the unit commenced reactor startup, and the reactor was made critical. The unit returned
to full power on August 28, 2024, and remained for the rest of the inspection period.
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 performed activities described in IMC 2515,
Appendix D, Plant Status, observed risk significant activities, and completed onsite portions of
IPs. 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.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1)
train B essential service water alignment for macrofoul treatment on July 30, 2024
(2)
train A centrifugal charging pump and motor coupling on September 11, 2024
(3)
ultimate heat sink supply and return for essential service water system on
September 17, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1)
diesel-driven fire pump failed to automatically start during surveillance testing and
unavailable for troubleshooting on July 31, 2024
(2)
emergency diesel generator room A, fire area D-1, on August 8, 2024
(3)
emergency diesel generator room B, fire area D-2, on August 8, 2024
(4)
fire protection piping through wall leak at circulating water screen house on August 8,
2024
4
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
(1)
The inspectors reviewed and evaluated the licensed operator examination failure
rates for the requalification annual operating exam administered and the biennial
written examinations completed on June 3 to July 26, 2024.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
(1)
Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification
written examination administered on June 4, 2024.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification
operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering
requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility
licensee is effectively evaluating their licensed operators for mastery of training
objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination
material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the
licensee, and reviewed the adequacy of re-examinations for licensed operators who
did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators
meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room
simulator in modeling the actual plant, and for meeting the requirements contained in
10 CFR 55.46.
5
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
(1)
The inspectors observed and evaluated licensed operator performance in the control
room during quarterly control rod surveillance testing and monthly rod parking on
July 18 and August 8, 2024, and technical specification required cooldown to Mode 4
on August 23, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated annual licensed operator requalification exam
on July 3, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1)
containment cooler motor thermal overload settings and maintenance on
September 12, 2024
(2)
safety-related batteries NK11, NK12, NK13, and NK14 maintenance effectiveness on
September 16, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1)
emergent work activities for troubleshooting steam generator A atmospheric relief
valve, ABPV0001, due to not stroking smoothly on July 17, 2024
(2)
emergent work activities for train A battery NK13 for three battery cells below
category A and B float voltage on July 26, 2024
(3)
turbine-driven auxiliary feedwater system terry turbine overspeed and discharge
header to steam generator B air-operated isolation valve, ALHV0010, emergent work
activities on August 23, 2024
(4)
train B DC switchgear, NK04, ground isolation emergent work activities on August 26,
2024
6
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
component cooling water room cooler calculation uses of non-conservative single
failure assumption on August 16, 2024
(2)
train A battery NK13 three cells (35, 47, and 56) below category A and B float voltage
operability determination on August 19, 2024
(3)
essential service water temperature assumptions for residual heat removal system
transition operability determination on August 20, 2024
(4)
technical specification offsite source operability requirements with an emergency
diesel generator in parallel operation on August 29, 2024
(5)
inadvertent actuation of control room ventilation isolation signal, fuel building isolation
signal, and containment purge isolation signal during surveillance testing operability
determination on September 16, 2024
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system
operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)
(1)
steam generator A atmospheric relief valve, ABPV0001, corrective maintenance
post-maintenance testing on August 14, 2024
(2)
train B swing inverter, NN016, preventive maintenance post-maintenance testing on
August 14, 2024
(3)
train B condensate storage tank to motor-driven auxiliary feedwater pump B isolation
valve, ALHV0034, bushing replacement post-maintenance testing on August 19,
2024
(4)
train A component cooling water service loop supply and return motor-operated
isolation valves, EGVH53 and EGHV15, post-maintenance testing on August 19,
2024
(5)
turbine-driven auxiliary feedwater turbine governor valve actuator replacement
post-maintenance testing on September 10, 2024
Surveillance Testing (IP Section 03.01) (3 Samples)
(1)
train A and B essential service water to component cooling water heat exchanger
valves, EFHV51/52, inservice testing and surveillance testing requirements on
August 29, 2024
(2)
turbine-driven auxiliary feedwater pump discharge header to steam generator B
air-operated isolation valve, ALHV0010, repair post-maintenance testing and
establishing reference stroke time value on September 13, 2024
(3)
feedwater isolation valve A solenoid replacement post-maintenance testing and
establishing reference stroke time value on September 13, 2024
7
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)
train A and B component cooling water heat exchanger outlet cross-connect header
check valves, EGV0036 and EGV0061, inservice testing requirements on August 29,
2024
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
(1)
The inspectors evaluated the licensee's maintenance, testing, and audit program for
the alert and notification (ANS) system between January 1, 2023, and June 30,
2024. Wolf Creek utilizes the Coffey County IPAWS (Integrated Public Alert and
Warning System) for their ANS function. They perform an annual audit of the Coffey
County program.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
(1)
The inspectors evaluated the readiness of the Emergency Preparedness
Organization between January 1, 2023, and June 24, 2024. Inspectors also evaluated
the licensee's ability to staff their emergency response facilities in accordance with
emergency plan commitments.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
The inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and
practices between January 1, 2023, and June 24, 2024. The evaluation reviewed screenings
and evaluations documenting implementation of the process. In addition, the inspectors
evaluated Radiological Emergency Response Plan, AP 06-002, revision 24, effective
June 26, 2024. The inspectors evaluated the following submitted Emergency Action Level
and Emergency Plan changes.
(1)
APF 06-002-02, Emergency Action Levels Technical Bases, revision 2,
10/5/2023
AP 06-002, Radiological Emergency Response Plan, revision 24, 6/26/2024
EPP 06-001, Control Room Organization, revision 32, 6/26/2024
EPF 06-001-03, Site Area Emergency Announcement, revision 5, 6/26/2024
EPF 06-001-04, General Emergency Announcement. revision 4, 6/26/2024
EPP 06-006, Protective Action Recommendations, revision 11, 6/26/2024
EPF 06-007-02, WCGS Emergency Immediate Notification, revision 1,
3/27/2023
EPF 06-007-03, WCGS Follow-up Emergency Immediate Notification,
revision 1, 3/27/2023
EPP 06-009, Drill and Exercise Requirements, revision 13, 7/24/2023
EPP 06-012, Dose Assessment, revision 18, 4/21/2023
EPP 06-013-04, Potassium Iodide Issue Record, revision 3, 5/11/2023
8
EPP 06-021, Training Programs, revision 16, 6/25/2023
EPP 06-024, Alert and Notification System, revision 1, 6/5/2024
This evaluation does not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
(1)
The inspectors evaluated the maintenance of the emergency preparedness program
between January 1, 2023, and June 10, 2024. The evaluation reviewed evidence of
completing various emergency plan commitments, the conduct of drills and exercises,
licensee audits and assessments, and the maintenance of equipment important to
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
(1)
simulated loss of offsite power, automatic reactor trip, loss of coolant accident, and
loss of all onsite power on July 17, 2024
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiation Worker Performance and Radiation Protection Technician Proficiency
(IP Section 03.06) (1 Sample)
(1)
The inspectors evaluated radiation worker and radiation protection technician
performance as it pertains to radiation protection requirements.
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (7 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant
walkdowns:
(1)
Mirion GEM-5 gamma exit monitor ID WC096670
(2)
Mirion TSE II whole body contamination monitor ID WC096005
(3)
Rados tool monitor ID WC095757
(4)
Mirion iSolo bench counter ID WC093661
(5)
Mirion Telepole ID WC010175
(6)
Ludlum REM ball neutron survey meter ID WC010256
(7)
Ludlum Model 177 survey meter ID WC011278
9
Calibration and Testing Program (IP Section 03.02) (12 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection
instruments:
(1)
containment high-range radiation monitor GTRE0059
(2)
new fuel storage vault criticality monitor SDRE0035
(3)
ORTEC HPGe whole body counting chair WBC-200-ICS-E-GEM10
(4)
Thermo-Fisher Scientific PM12 ID WC093694
(5)
Mirion GEM 5 gamma exit monitor ID WC096670
(6)
Mirion TSE whole body contamination monitor ID WC096005
(7)
Rados tool monitor ID WC095757
(8)
Mirion iSolo bench counter ID WC093661
(9)
Ludlum REM ball neutron survey meter ID WC010256
(10)
Thermo-Fisher Scientific SAM12 small articles monitor ID WC095941
(11)
Ludlum Model 54R-11 small articles monitor ID WC097181
(12)
Mirion Argos 5A/B gas flow personnel contamination monitor ID WC097287
Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive
effluent monitoring and measurement instrumentation:
(1)
steam generator blowdown discharge radiation monitor, BMRE0052
(2)
radwaste building ventilation system radiation monitor, GHRE0010B
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01) (1 Sample)
The inspectors evaluated the licensees performance in controlling, labeling and securing
the following radioactive materials:
(1)
radwaste building 2000-foot elevation block storage room - low level storage
and new radwaste storage building
Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)
The inspectors walked down the following accessible portions of the solid radioactive waste
systems and evaluated system configuration and functionality:
(1)
resin handling system
(2)
filter handling system
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
The inspectors evaluated the following characterization and classification of radioactive
waste:
(1)
- 13 dry active waste, effective December 6, 2023
10
(2)
- 5 cation resin, effective February 13, 2024
Shipment Preparation (IP Section 03.04)
No shipment was observed during this inspection, however, a radioactive waste shipment
was observed and documented during a previous inspection in March 2024.
Shipping Records (IP Section 03.05) (3 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through
a record review:
(1)
shipment 22R35 - radioactive material, low specific activity (LSA-II), consisting of
mixed bed class B bead resin, in an 8-120 poly liner on October 6, 2022
(2)
shipment 23R20 - radioactive material, low specific activity (LSA-II), consisting of
class B mechanical filters in overpacks on October 11, 2023
(3)
shipment 24R26 - radioactive material, low specific activity (LSA-II), consisting of a
bag of class A high radiation dry active waste on June 25, 2024
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures Sample (IP Section 02.04) (1 Sample)
(1)
July 1, 2023, through June 30, 2024
MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)
(1)
July 1, 2023, through June 30, 2024
EP01: Drill/Exercise Performance Sample (IP Section 02.12) (1 Sample)
(1)
January 1, 2023, through June 30, 2024
EP02: Emergency Response Organization Drill Participation (IP Section 02.13) (1 Sample)
(1)
January 1, 2023, through June 30, 2024
EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14)
The licensee transitioned its ANS to a purely non-siren-based system in April 2020. The
ANS performance indicator and associated data is no longer required to be reported by Wolf
Creek, and thus is not subject to further inspection/verification per IP 71151. Evaluation of
the licensee's non-siren-based ANS is completed separately per IP 71114.02, "Alert and
Notification System Evaluation."
11
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Follow up (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated the unplanned technical specification shutdown due to
failure of the turbine-driven auxiliary feedwater pump discharge to steam generator B
air-operated valve and licensees response on August 26, 2024.
Notice of Enforcement Discretion (IP Section 03.04) (1 Sample)
(1)
The inspectors evaluated the licensee actions surrounding Notice of Enforcement
Discretion EA-24-091 which can be accessed at https://www.nrc.gov/reading-rm/doc-
collections/enforcement/notices/noedreactor.html, on August 23, 2024.
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
92702 CONF - Enforcement Related Order Follow-Up-Only
Enforcement Related Order Follow-Up-Only (1 Sample)
(1)
The inspectors verified the actions committed to in Confirmatory Order EA-18-165
were completed.
INSPECTION RESULTS
Failure to Remove Motor-Operated Valve Thermal Overload Bypass Jumpers during
Surveillance Testing and System Maintenance
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
None (NPP)
The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part
50, Appendix B, Criterion III, Design Control, for the licensees failure to assure the
applicable design requirements associated with the licensees commitment to Regulatory
Guide 1.106, Thermal Overload Protection for Electric Motors on Motor-Operated Valves,
revision 1, was correctly translated into procedures and instructions. Specifically, the licensee
failed to translate that the thermal overloads be placed in force during stroking of
safety-related motor-operated valves for surveillance testing and routine maintenance into
procedures and instructions.
Description: The inspectors reviewed Condition Report 10023559, the licensing and design
basis for safety-related motor-operated valves, and operating experience search of the
licensees motor-operated valve program. The inspectors identified the following:
Condition Report 10023559 referenced operating experience with train B essential
service water travel screen wash motor-operated valve, EFHV0092 (1/2 horsepower
or less motor-operated valve), that occurred on March 29, 2014, during the
performance of surveillance Procedure STS KJ-001B, Integrated Diesel Generator
and Safeguards Actuation Test - Train B, documented in Condition Report 81790.
Specifically, operators identified the 480 volt motor control center breaker cubical, for
12
valve EFHV0092, was smoking heavily. In response to the smoke, the operators
opened the breaker for valve EFHV0092 and the smoke began to dissipate. The
operators found valve EFHV0092 actuator was hot to the touch due to a locked rotor
overthrust condition. The operator actions were required to remove power from valve
EFHV0092 because the thermal overloads were not placed in force during
surveillance testing in accordance with the design as specified in the Updated Safety
Analysis Report (USAR), section 8.3.1.1.2.e, and appendix 3A, which states, in part,
all starters for motor-operated valves are equipped with thermal overload relays. The
thermal overload relay trip contacts located in 480 volt motor control centers for all
safety-related valves, are bypassed in accordance with Regulatory Guide 1.106,
Thermal Overload Protection for Electric Motors on Motor-Operated Valves,
revision 1, dated March 1977. Regulatory Guide 1.106, revision 1, position 1 states, in
part, provided that the completion of the safety function is not jeopardized or that other
safety systems are not degraded, (a) the thermal overload protection devices should
be continuously bypassed and temporarily placed in force only when the valve motors
are undergoing periodic or maintenance testing. The NRC defines maintenance, in
accordance with Regulatory Guide 1.160, Monitoring the Effectiveness of
Maintenance at Nuclear Power Plants, revision 4, as follows:
As discussed in the Federal Register (FR) notice, Final Commission
Policy Statement on Maintenance at Nuclear Power Plants, dated
March 23, 1988 (Ref. 5), maintenance is defined as the aggregate of
those functions required to preserve or restore safety, reliability, and
availability of plant SSCs. Maintenance includes not only activities
traditionally associated with identifying and correcting actual or
potential degraded conditions (i.e., repair, surveillance, diagnostic
examination, and preventive measures), but extends to all supporting
functions for the conduct of these activities. The activities and
supporting functions that are included in the definition of Maintenance
are listed in the policy statement.
Regulatory Guide 1.106 also states, in part, where the thermal overload protection
devices are bypassed, it is important to ensure that the bypassing does not result in
jeopardizing the completion of the safety function or in degrading other safety systems
because of any sustained abnormal motor circuit currents that may be present. As an
example, for small motors (1/2 horsepower or less), the magnetic trip devices
provided in the motor combination starter breaker may not adequately protect the
circuit at all times against sustained locked rotor currents. This was the condition
described in Condition Report 81790 when EFHV0092 was at sustained locked rotor
currents causing damage to the motor and impacting the safety-related 480 volt motor
control center (i.e., smoke emitting from the motor control center).
NRC Component Design Bases Inspection Report 0500482/2013008 documented
non-cited violation (NCV) 2013008-10, Failure to Provide Procedure Instructions to
Remove Thermal Overload Bypass Jumpers, for the licensees failure to translate the
requirements into motor-operated valve diagnostics testing Procedure MGE LT-099,
MOV Diagnostic Testing. Also, the Wolf Creek USAR, section 8.3.1.1.2, had
incomplete information which does not support Regulatory Guide 1.106, revision 1.
The licensee entered this deficiency into their corrective action program as Condition
Reports 73120 and 73421. The licensees corrective actions were to (1) update
USAR, section 8.3.1.1.2, to reflect the requirements of Regulatory Guide 1.106
13
(USAR change request 2013-049) and (2) update the diagnostic testing procedure for
motor-operated valves to remove the thermal overload bypass jumpers. The licensee
revised Procedure MGE LT-100, Limitorque Valve Operator General Notes and
Details, to include thermal overload protection requirements that the thermal overload
protection device be continuously bypassed and temporarily placed in force when the
valve motors undergo periodic or maintenance testing. Procedure MGE LT-100,
revision 13, step 7.3.11, states in part, Regulatory Guide 1.106, revision 1 requires
thermal overload protection devices be continuously bypassed and temporarily placed
in force when the valve motors are undergoing periodic, or maintenance,
testing. Maintenance testing was defined as the performance of activities associated
with maintenance procedures, and/or work instructions that remove limit switch
compartment cover on safety-related motor-operated valves with thermal overload
bypass jumpers. However, this is contrary to Regulatory Guide 1.160; NRC, Final
Commission Policy Statement on Maintenance of Nuclear Power Plants, Federal
Register, Volume 53, Number 56, pp. 9430-9431 (53 FR 9430) March 23, 1998; and
licensee Procedure AP 23M-001, WCGS Maintenance Rule Program, revision 14,
step 4.15.
From the above, the inspectors concluded that the licensee corrected the performance
deficiency associated with NCV 2013008-10, Failure to Provide Procedure Instructions to
Remove Thermal Overload Bypass Jumpers, for the licensees failure to translate the
requirements into motor-operated valve diagnostics testing Procedure MGE LT-099, MOV
Diagnostic Testing. However, the licensee failed to translate the applicable design
requirements associated with the licensees commitment to Regulatory Guide 1.106,
revision 1, position 1, for safety-related motor-operated valves were correctly translated into
specifications, drawings, procedure, and instructions. Specifically, as part of their extent of
condition review, the licensee failed to translate the position that the thermal overloads be
placed in force (bypass jumpers removed) during stroking of safety-related motor-operated
valves for periodic or maintenance testing into procedures and instructions, which included
surveillance and all types of maintenance testing.
In response to the inspectors conclusions, the licensee asserted the proposed NCV was a
backfit. Specifically, the licensee was committed and approved to Regulatory Guide 1.106,
revision 1; however, in the Safety Evaluation Report (SER) for Wolf Creek, NUREG-0881,
supplement 5, issued in March 1985, acknowledged the licensees statement that thermal
overloads on class 1E motor-operated valves will be permanently bypassed with no
discussion of removal during surveillance testing. The licensee thus claimed the agency had
approved the use of permanently bypassed thermal overload during the application
process. The inspectors determined the wording in the SER stated that the use of thermal
overloads (i.e., removing the bypass jumpers) during testing was a prudent operational
practice as a staff observation, nonetheless, the inspectors entered the backfit process
and engaged backfit community of best practices to review the above referenced documents
to determine if the backfit claim was valid. From the review of the above documents, the
backfit community of best practices concluded the USAR did not contain all the appropriate
information associated with the requirements of Regulatory Guide 1.106, revision 1, which
includes regulatory position 1(a) and concluded the proposed NCV was not a backfit. Lastly,
the licensee stated they would contest the NCV based on their definition of maintenance
testing contained in Procedure MGE LT-100.
Corrective Actions: Condition Reports 10028066 and 10037302
14
Corrective Action References: The licensee plans to contest the NCV based on their
definition of maintenance testing contained in Procedure MGE LT-100.
Performance Assessment:
Performance Deficiency: The licensees failure to place the thermal overloads in force during
stroking of motor-operated valves for surveillance testing and routine maintenance was a
performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Configuration Control attribute of the Mitigating Systems
cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, the failure to place the thermal overloads in force during
surveillance testing resulted in the 480 volt motor control center for EFHV0092 to heavily
smoke when the motor-operated valve went to a locked rotor condition due to a limit switch
failure in June 2014.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The
finding was determined to be of very low safety significance (Green) because it (1) was not a
deficiency affecting design or qualification of a mitigating system, (2) does not represent a
loss of the probability risk analysis (PRA) function of a single train technical specification
system for greater than allowed outage time, (3) does not represent a loss of PRA function of
one train of a multi-train technical specification for greater than its allowed outage time, (4)
does not represent a loss of the PRA function of two separate technical specification systems
for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, (5) does not represent a loss of PRA system and/or function as
defined by the plant risk information e-book or licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and
(6) does not result in the loss of a high safety-significant, nontechnical specification train for
greater than 3 days.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to
this finding because the inspectors determined the finding did not reflect present licensee
performance. Specifically, the performance deficiency occurred in 2013 when the licensee
failed to include procedures for surveillance testing and routine maintenance, such as
post-maintenance testing and preventive maintenance procedures that stroke safety-related
motor-operated valves other than diagnostics testing and motor-operated valve maintenance
when performing the extent of condition for NCV 2013008-10, Failure to Provide Procedure
Instructions to Remove Thermal Overload Bypass Jumpers.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part,
that measures shall be established to assure that applicable regulatory requirements and the
design basis, as defined in 50.2 and as specified in the license application, for those
structures, systems, and components to which this appendix applies are correctly translated
into procedures and instructions.
Contrary to the above, from November 2013 to September 2024, the licensee failed to
establish measures to assure that applicable regulatory requirements and the design basis,
as defined in 50.2, and as specified in the license application assure the applicable design
requirements were correctly translated into procedures and instructions. Specifically, the
licensee failed to implement their design basis commitment to Regulatory Guide 1.106,
15
Thermal Overload Protection for Electric Motors on Motor-Operated Valves, by failing to
translate into maintenance and surveillance procedures and instructions, the regulatory guide
position to place thermal overloads in force during stroking of safety-related motor-operated
valves.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
section 2.3.2 of the Enforcement Policy.
Unresolved Item
(Open)
Failure to Perform Adequate Audit of the Integrated Public
Alert Warning System
Description: The NRC identified a deviation between the audit practices implemented by the
licensee compared to what is described in their Federal Emergency Management Agency
(FEMA) approved Alert and Notification System (ANS) design report and its implementing
procedures.
The primary method of notification, Integrated Public Alert Warning System (IPAWS), is
operated by Coffey County. However, per ANS design report section H.B.11, "Quality
Assurance," and its implementing Procedure EPP 06-024, Alert and Notification System,
revision 1, the licensee is required to conduct an annual audit of the county's program to
maintain IPAWS operation. Audit documentation for 2023 did not provide adequate basis for
the inspector to determine that the IPAWS reliability standards of 94 percent or greater were
met. The standards and guidelines for what is an acceptable level of documentation to
support the audit do not currently exist and therefore the inspector needs guidance from
FEMA to determine if the audit met their expectations.
Areas of the audit that require specific guidelines from FEMA for proper documentation in
order to evaluate are:
1) Verification of IPAWS Certification
2) Verification of System Training
3) Verification of Systems Testing
4) Verification of Wireless Emergency Alerting Coverage
5) Verification of Cellular Provider Coverage Maps
6) Verification of Maintenance of IPAWS Reliability/Availability and Changes as
Reported by FEMA
7) Verification of Reliability/Availability and changes as reported by the Coffey County
Public Notification System contractor
Planned Closure Actions: As ANS design reports require FEMA approval, this deviation from
the approved design report requires a review and determination from FEMA regarding its
acceptability. This URI will remain open pending determination of acceptability from FEMA. A
determination of whether the deviation constitutes a performance deficiency will be made
after FEMA's determination of acceptability.
Licensee Actions: Licensee entered the issue into their corrective action program.
Corrective Action References: Condition Report 10035589
16
Unresolved Item
(Open)
Turbine-Driven Auxiliary Feedwater Pump Turbine Governor
Valve Actuator Failure (EA-24-091)
Description: On August 20, 2024, at 5:00 a.m. CDT, the licensee entered a planned
maintenance outage of the turbine-driven auxiliary feedwater (TDAFW) pump, under
Technical Specification (TS) Limiting Condition for Operation (LCO) 3.7.5, action C, which
requires the licensee to return the pump to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3
within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. While conducting AFW testing, valve AL-HV-10, the AFW flow control
for steam generator B, did not respond as expected. The licensee calibrated the valve
controller and completed diagnostic valve testing, and no issues were identified, so the
licensee concluded that valve AL-HV-10 was operating correctly. On August 22, 2024, at
3:16 a.m. CDT, during post-maintenance testing activities on valve AL-HV-10, with the
TDAFW pump running, the turbine tripped on electronic overspeed. The licensee commenced
troubleshooting activities for the turbine trip. The licensee was able to identify that the cause
of the turbine trip as a faulty actuator on the turbine speed governing valve, FV-313. The
licensee determined that the repairs to correct the condition with the TDAFW pump would
exceed the TS 3.7.5 LCO completion time and initiated the notice of enforcement discretion
(NOED) process with the NRC by contacting the senior resident inspector.
Based on the NRC staffs evaluation of the licensees request, the staff determined that
granting this NOED was consistent with the NRCs Enforcement Policy and staff guidance.
NRC staff independently evaluated the risk insights associated with the requested NOED
condition and obtained results consistent with the licensees assertions relative to satisfying
the incremental conditional core damage probability and incremental conditional large early
relace probability criteria referenced above. The NOED request met the criteria specified in
NRCs Enforcement Manual, appendix F, sections 2.2 and 2.5. Therefore, as communicated
orally to the licensee at 1:05 a.m. CDT on August 23, 2024, the NRC exercised discretion to
not enforce compliance with TS LCO 3.7.5 requirements that Wolf Creek Generating Station
be in Mode 3 by 11:00 a.m. CDT on August 23, 2024. The NRC extended the Wolf Creek
Generating Station Mode 3 entry by 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to 11:00 p.m. CDT on August 24, 2024, and
subsequent mode changes required by TS 3.7.5 were extended as well. Subsequent to the
NRC verbal approval of the NOED request, and prior to entering the period of enforcement
discretion, the licensee discovered an additional issue, not related to the NOED, with the
AFW system that would require extensive troubleshooting to determine the cause-and-effect
repairs. Thus, following the expiration of the 72-hour TS 3.7.5 LCO at 5:00 a.m. CDT, the
licensee entered TS 3.7.5, condition D, requiring the plant to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and
Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Operators initiated a TS required shutdown at 8:00 a.m. CDT on
August 23, 2024, as required by action D of TS 3.7.5 LCO. The licensee completed the
shutdown to Mode 3 at 10:24 a.m. CDT, and Mode 4 at 4:51 pm CDT on August 23, 2024.
The licensee submitted its written request for enforcement discretion in letter WO 24-0609,
Docket No. 50-482: Request for Notice of Enforcement Discretion Regarding Technical
Specification 3.7.5, Auxiliary Feedwater (AFW) System, dated August 27, 2024,
Agencywide Documents Access and Management System (ADAMS) Accession No.
ML24240A264. The NOED letter from the NRC staff was sent to the licensee on August 29,
2024 (ML24241A221).
Planned Closure Actions: In accordance with the NRC Enforcement Manual, appendix F, an
unresolved item is being issued to review the cause of the need for enforcement discretion to
determine if there is a violation associated with that cause. The inspectors plan to review the
17
licensees hardware failure analysis and cause evaluation associated with the failure of the
TDAFW pump actuator on the turbine speed governing valve, FV-313.
Licensee Actions: The licensee replaced the TDAFW pump actuator on the turbine speed
governing valve, FV-313, and performed post-maintenance testing satisfactorily.
Corrective Action References: Condition Report 10036008
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 18, 2024, the inspectors presented the confirmatory order closeout inspection
results to Jamie McCoy, Site Vice President, and other members of the licensee staff.
On July 25, 2024, the inspectors presented the public radiation safety inspection results
to Jaime McCoy, Site Vice President, and other members of the licensee staff.
On July 29, 2024, the inspectors presented the biennial requalification inspection results
to Jamie McCoy, Site Vice President, and other members of the licensee staff.
On August 8, 2024, the inspectors presented the emergency preparedness program
inspection results to Jaime McCoy, Site Vice President, and other members of the
licensee staff.
On October 15, 2024, the inspectors presented the integrated inspection results to
Robert Bayer, General Manager, Plant Operations, and other members of the licensee
staff.
18
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
EF-M-046
UHS Analysis with Initial Lake Temperature Up to 94
degrees F
0
Corrective Action
Documents
Condition Reports
10005547, 10013793, 10029678
Corrective Action
Documents
Resulting from
Inspection
Condition Reports
10035329, 10036506, 10036508
Drawings
E-025-00007
Sheet 197
W15
Drawings
E-025-0007
Sheet 150
W15
Drawings
M-12EF1
Piping Instrumentation Diagram Essential Service Water
System
30
Drawings
M-12EF2
Piping and Instrumentation Diagram Essential Service Water
System
46
Drawings
WCOP-02
Inservice Testing Program for Pumps, Valves, and Snubbers
16
Miscellaneous
M-721-00093
Instruction Manual for Charging/Safety Injection Pump
W50
Miscellaneous
WCRE-34
Fourth 10-Year Interval Inservice Basis Document
14
Miscellaneous
WCRE-34
Fourth 10-Year Interval Inservice Testing Basis Document
13
Procedures
ALR 00-127B
10
Procedures
CKL EF-120
Essential Service Water Valve, Breaker and Switch Lineup
57
Procedures
EMG E-0
Rector Trip or Safety Injection
48
Procedures
EMG ES-12
Transfer to Cold Leg Recirculation
25
Procedures
MPM BG-002
CCP Main Lube Oil Pump Pin Type Coupling Maintenance
2
Procedures
OFN SG-003
Natural Events
40
Procedures
STS BN-206
Borated Refueling Water Storage System Inservice Valve
Test
29
Procedures
STS IC-616B
Slave Relay Test K616 Train B Safety Injection
20A
Procedures
STS KJ-001A
Integrated D/G and Safeguards Actuation Test- Train A
73A
Procedures
STS KJ-001B
Integrated D/G and Safeguards Actuation Test - Train B
71
Procedures
STS PE-007
Periodic Verification of Motor Operated Valves
5A
19
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
STS VT-001
Verification of OMN-1, MOV Exercise Requirements
6
Procedures
SYS EF-200
Operation of the ESW System
46
Procedures
SYS EF-300B
ESW/Service Water Macrofoul Treatment for Train B
2
Procedures
SYS EG-120
Component Cooling Water System
44
Work Orders
WO 23717, 40594, 17-430298-000, 21-471249-000,
23-485525-000
Corrective Action
Documents
Condition Reports
10034839, 10034954, 10035057, 10035376
Miscellaneous
FPPM-009
Control BLDG., EL 2000
Miscellaneous
FPPM-050
Circulating Water Screen House & Chemical Addition,
EL 2000
Procedures
AP 10-100
26A
Procedures
AP 10-103
Fire Protection Impairment Control
41A
Procedures
AP 10-106
Fire Preplans
25
Procedures
OFN KC-016
Fire Response
54
Procedures
STN FP-209
Fire Pump Performance and Sequential Start Test
35
Work Orders
Miscellaneous
Table 03.03-1
Examination
Results
Requalification Examination Results
0
Corrective Action
Documents
CR-10023848, -
10023436, -
10025407, -
10025432, -
10015837, -
10032606,
10024701
Various Operator Training Related CRs
Corrective Action
Documents
SMP A17-039,
A21-082, A16-
073, A18-082,
A21-030, A21-
072, A21-074,
A21-083, A23-
Various simulator corrective actions
20
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
012, A21-079
Miscellaneous
03.04e. Cycle 23-3, Crew A Remediation Package
Miscellaneous
03.04B.3 2024 Week 1 (Staff Crew) JPM Package
Miscellaneous
03.04B.3 2024 Week 2 (F Crew) JPM Package
Miscellaneous
4. Wolf Creek 2023, Week 3 - Crew C - JPM Package
Miscellaneous
03.04d.3, AI 30B-015 (Rev 15) See paragraphs 6.4.4.6,
6,5,7, and 6.6.6
Miscellaneous
03.04d.3, AIF 30B-015-09
9
Miscellaneous
03.04d.3, AIF 30B-015-15
1
Miscellaneous
03.04d.3, AIF 30B-015-18
2
Miscellaneous
4. Wolf Creek 2023, Week 3 - Crew C - 23-06 Scenario
Package
Miscellaneous
03.04e. Cycle 23-2, Crew E Exam Package
Miscellaneous
Cycle 26 Simulator Steady State Tests
Miscellaneous
Cycle 26 Simulator Core Tests (BOL, MOL, EOL)
Miscellaneous
Post Event Cycle 24 Simulator Test
Miscellaneous
03.04e. Cycle 23-2, Crew C Remediation package
Miscellaneous
03.04e. Cycle 23-2, Crew C Exam Package
Miscellaneous
Personnel Qualification Expirations Functions 10000147 and
10000148 RO/SRO
06/25/2024
Miscellaneous
2023-01 NSRB
Wolf Creek Nuclear Safety Review
Board January 2023
01/01/2023
Miscellaneous
Cycle 26 Simulator Transient Tests
Miscellaneous
APF 30B-001-02
Reactor Operator Active Status Restoration - RO 6/23
7A
Miscellaneous
C17-B Crew
Scenario 1
2024 Annual Requalification Exam Simulator Scenario
0
Miscellaneous
C6-B Crew
Scenario 2
2024 Annual Requalification Exam Simulator Scenario
0
Miscellaneous
Exam ID: 41747
(RO),
41647(SRO)
2024 Biennial Written Exam (Week 1 - Staff Crew)
0
Miscellaneous
JPM P-4S-04
Reset the TD AFW Pump Mechanical Trip Mechanism
0
21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
JPM S-1-06-A
Establish Emergency Boration IAW OFN BG-009
0
Miscellaneous
JPM S-2-05
Adjust letdown flow from 75 to 45 gpm IAW SYS BG-203
0
Miscellaneous
JPM S-3-06-A
Energize a Set of PZR Backup Heaters IAW SYS BB-203
and Respond to failed open Spray Valve IAW OFN SB-00,
Attachment V)
0
Miscellaneous
LR1610201
Lesson Plan: Miscellaneous SRO Tasks
07/19/2023
Miscellaneous
(Selected RO-
3/SRO-3)
Medical Record Review for Six Licensed Operators
Procedures
Continued Assurance of Simulator Fidelity
18
Procedures
Simulator Steady State Testing
10A
Procedures
AI 30C-006
Simulator Transient Testing
13A
Procedures
AI 30C-007
Simulator Core Testing
4A
Procedures
AI 30C-008
Scenario Based Testing
3A
Procedures
AI 30C-010
Post Event Simulator Testing
1B
Procedures
STN SF-001
Control Rod Parking
22
Work Orders
Calculations
NK-E-001
125 VDC Class 1E Battery System Sizing, Voltage Drop and
Short Circuit Studies
4
Calculations
WCN00-PR-01
Worst Case Brake Horse Power Requirements on
Containment Air Cooler (CAC) Fan Motors
0
Calculations
XX-E-006
AC System Analysis
9
Calculations
XX-E-042
Class 1E 480VAC and 208/120VAC System Coordination
0
Corrective Action
Documents
Condition Reports
129028, 91851, 10019448, 10034848, 10034912,
10035157, 10035374, 2008-001307
Corrective Action
Documents
Resulting from
Inspection
Condition Report
10035452
Drawings
E-018-00273
Ambient Compensated Overload Relay Heater Chart
1
Drawings
E-13GN02
Schematic Diagram Containment Cooler Fans A and C
17
Engineering
Changes
CCP 14332
Float and Equalize Voltages for NK Batteries
0
Engineering
DCP 012697
Change Containment Cooler Fan Control Circuit to Allow
0
22
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Changes
Slow Speed Start on Fast Speed Trip
Miscellaneous
E-050A
Technical Specification for the Class 1E Batteries for the
Wolf Creek Generating Station
2
Miscellaneous
E-050A-00011
Lucent Technologies Lineage 2000 Round Cell Battery
Miscellaneous
E-11NG20
Low Voltage System Class 1E Motor Control Center
Summary
321
Miscellaneous
M-620-00060
Instruction Manual for Containment Cooler
W31
Procedures
MPE E050Q-05
Battery Equalizing Procedure
16A
Procedures
STS MT-019A
125 VDC Class 1E Quarterly Inspection for NK11 and NK13
Batteries
3
Procedures
STS MT-024C
Functional Test of 480 and 120 Volt Molded Case Circuit
Breakers
16
Procedures
STS MT-058
Modified Performance Test for 125 VDC Class 1E Batteries
8
Work Orders
WO 32426, 35157, 35161, 73937, 74514, 76031, 77710,
09-320884-000, 14-382559-004, 14-382559-005,
21-475117-000
Corrective Action
Documents
Condition Reports
1003561, 1003958, 10034848, 10034997, 10035034,
10035713, 10036008, 10036056
Drawings
M-12AB01
Piping and Instrumentation Diagram Main Steam System
17
Drawings
M-12AL01
Piping and Instrumentation Diagram Auxiliary Feedwater
System
33
Miscellaneous
D-AB-N-005
Clearance Order
0
Procedures
AI 22C-013
Protected Equipment Program
27
Procedures
On-Line Nuclear Safety and Generation Risk Assessment
29
Procedures
EMG E-3
Steam Generator Tube Rupture
41
Procedures
MPE E050Q-06
Battery Equalizing Procedure
16A
Procedures
OFN RP-017
Control Room Evacuation
57
Procedures
STS MT-019A
125 VDC Class 1E Quarterly Inspection for NK11 and NK13
Batteries
3
Work Orders
WO 66320, 73937, 82770
Calculations
AN-07-009
Gothic Model for CCW Pump Room Temperature
1
Calculations
EF-M-046
UHS Analysis with Initial Lake Temperature Up to 94
degrees F
0
23
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
NK-E-001
125 VDC Class 1E Battery System Sizing, Voltage Drop and
Short Circuit Studies
4
Calculations
XX-E-006
AC System Analysis
9
Corrective Action
Documents
Condition Reports
10026730, 10027614, 10027941, 10029488, 10031043,
10031387, 10034848, 10035374, 10036541, 10036670
Corrective Action
Documents
Resulting from
Inspection
Condition Report
10035949
Engineering
Changes
CP 14332
Float and Equalize Voltages for the NK Batteries
0
Miscellaneous
E-050A-00011
Lucent Technologies Lineage 2000 Round Cell Battery
W03
Miscellaneous
EQSD-I
Equipment Qualification Design Basis Document
20
Miscellaneous
M-000
Mechanical/Nuclear Design Criteria for Wolf Creek
Generating Station
22
Miscellaneous
M-10EJ
System Description Residual Heat Removal
7
Miscellaneous
Single Train RHR Cooldown Runs with Increased Service
Water Temperature and Decreased Power Levels
10/29/1998
Procedures
AI 28A-010
Screening Condition Reports
39
Procedures
ALR 00-059D
CPIS
12A
Procedures
ALR 00-062D
FBIS
15
Procedures
ALR 00-063A
CRVIS
18A
Procedures
Operability Determinations and Functionality Assessments
48
Procedures
AP 28-007
Nonconformance Control
10A
Procedures
E-11005
List of Loads Supplied by Emergency Diesel Generator
63
Procedures
EMG ES-11
Post LOCA Cooldown and Depressurization
28
Procedures
M-10EG
Wolf Creek System Description Component Cooling Water
System
6
Procedures
MPE E050Q-06
Battery Equalizing Procedure
16A
Procedures
STS CR-001
Shift Log for Modes 1, 2, and 3
117A
Procedures
STS IC-455A
Channel Calibration Control Room Air Intake Radiation
Monitor GK RE-005
21C
Procedures
STS KJ-001A
Integrated D/G and Safeguards Actuation Test - Train A
73A
24
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
STS KJ-001B
Integrated D/G and Safeguards Actuation Test - Train B
71
Procedures
STS KJ-005A
Manual/Auto Start, Sync and Loading of ENG NE01
75
Procedures
STS MT-019A
125 VDC Class 1E Quarterly Inspection for NK11 and NK13
Batteries
3
Procedures
SYS NB-205
XNB01 Load Tap Changer Operation
1
Work Orders
WO 32422, 73937, 77710, 23-485656-000, 23-487600-000,
23-487723-000
Calculations
AL-M-003
ALHV-0034/35/36 MEDP Determination
3
Corrective Action
Documents
Condition Reports
10013793, 10023021, 10023659, 10034997, 10035034,
10035329, 10035961, 10036008, 10036032, 10036056
Corrective Action
Documents
Resulting from
Inspection
Condition Reports
10035479, 10035907, 10035944, 10036543, 10036546
Drawings
E-025-00007
Sheet 197
W15
Drawings
M-025-00007
Sheet 114
W14
Drawings
M-12AL01
Piping and instrumentation Diagram Auxiliary Feedwater
System
33
Drawings
M-12AL01
Piping and Instrumentation Diagram Auxiliary Feedwater
System
33
Drawings
M-12EF1
Piping Instrumentation Diagram Essential Service Water
System
30
Drawings
M-12EF2
Piping and Instrumentation Diagram Essential Service Water
System
46
Drawings
M-12EG02
Piping and Instrumentation Diagram Component Cooling
Water System
29
Drawings
M-12EG03
Piping and Instrumentation Diagram Component Cooling
Water System
19
Drawings
M-12EG04
Piping and Instrumentation Diagram Component Cooling
Water System
29
Miscellaneous
WCRE-09-EG
IST Design Basis Document System EG
0
Miscellaneous
WCRE-19
Third 10-Year Interval Inservice Testing Basis Document
18
25
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
WCRE-34
Fourth 10-Year Interval Inservice Testing Basis Document
13, 14
Procedures
ASME Code Testing of Pumps and Valves
12A
Procedures
OFN BN-030
Loss of AC Emergency Bus NB01 (NB02)
43
Procedures
STN AL-201
Auxiliary Feedwater System Valve Test
9
Procedures
STS AB-201D
Atmospheric Relief Valve Inservice Valve Testing
31
Procedures
STS AE-205
Feedwater System Inservice Valve Test
28
Procedures
STS AL-104
TDAFW ESF Response Time and Flow Path Verification
31A
Procedures
STS AL-201C
Turbine Driven Auxiliary Feedwater System Inservice Valve
Test
13
Procedures
STS IC-616B
Slave Relay Test K616 Train B Safety Injection
20AS
Procedures
STS KJ-001B
Integrated D/G and Safeguards Actuation Test - Train B
71
Procedures
STS NB-005
Breaker Alignment Verification
38A
Procedures
SYS EF-300B
ESW/Service Water Macrofoul Treatment for Train B
2
Procedures
SYS EG-201
Transferring Supply of CCW Service Loop and CCW Train
Shutdown
59
Procedures
SYS NN-200B
Transferring NN02 and NN04 Buses Between Power
Sources
1A
Work Orders
WO 26631, 33721, 38227, 40804, 66320, 74906, 74910, 82770,
83159, 83193, 83254, 83301, 83302, 83303, 83304, 83362,
83365, 83373, 83380, 18-444647-001, 23-488478-000
Corrective Action
Documents
Resulting from
Inspection
Condition Reports
10035569, 10035589
Miscellaneous
Wolf Creek Design Report IPAWS (Integrated Public Alert
and Warning System) Design Report Submission
1
Corrective Action
Documents
Condition Reports
10034391, 10034655, 10023321, 10024694, 10026375,
10026524, 10026530, 10028390, 10034666, 10034688,
10034894, 10034895
Miscellaneous
23-Q1
Callout Report Team A
03/28/2023
Miscellaneous
23-Q2
Callout Report Team C
06/20/2023
Miscellaneous
23-Q3
Callout Report Team B
09/28/2023
Miscellaneous
23-Q4
Callout Report Team D
12/19/2023
Miscellaneous
24-Q1
Callout Report Team B
03/06/2024
26
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
24-Q2
Callout Report Team A
06/24/2024
Procedures
AP 06-002
Radiological Emergency Response Plan (RERP)
24
Procedures
APF 06-002-02
Emergency Action Levels Technical Bases
2
Procedures
EPF 06-001-03
Site Area Emergency Announcement
5
Procedures
EPF 06-001-04
General Emergency Announcement
4
Procedures
EPF 06-007-02
WCGS Emergency Immediate Notification
1
Procedures
EPF 06-007-03
WCGS Follow-up Emergency Immediate Notification
1
Procedures
EPP 06-001
Control Room Organization
32
Procedures
EPP 06-006
Protective Action Recommendations
11
Procedures
EPP 06-009
Drill And Exercise Requirements
13
Procedures
EPP 06-012
Dose Assessment
18
Procedures
EPP 06-013-04
Potassium Iodide Issue Record
3
Procedures
EPP 06-021
Training Programs
16
Procedures
EPP 06-024
Alert And Notification System
1
Miscellaneous
Wolf Creek Design Report IPAWS Design Report
Submission
1
Miscellaneous
Tool Kit-041
Evacuation Time Estimate Update
12/06/2023
Procedures
EMG ES-02
Reactor Trip Response
42
Corrective Action
Documents
Condition Report
10033853
Corrective Action
Documents
Resulting from
Inspection
Condition Report
10035335
Radiation
Surveys
M-20240516-5
ALARA Survey for EJFCV0611
05/16/2024
Radiation
Surveys
M-20240524-2
Dose Rate Alarm verification
05/24/2024
Radiation
Surveys
M20240528-5
"B" RHR Pump Room Entrance Following Dose Rate Alarm
05/28/2024
Radiation Work
Permits (RWPs)
240009
Station Personnel Access to RCA
0
Calibration
Calibration Documentation WBC-200-ICS-E-GEM10 High
11/2/2023
27
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Records
Purity Germanium Body Counting Chair
Calibration
Records
WO 22-479435-
000
STN SP-110B Chanel Calibration of the Radwaste Building
Ventilation System Radiation Monitor GHRE0010B
12/7/2022
Calibration
Records
WO 23-487785-
000
STS-IC-460A Channel Calibration of the Digital High Range
Area Radiation Monitor GTRE0059 (electronics portion)
3/20/2024
Calibration
Records
WO 23-487992-
000
STS IC-660A Channel Calibration of the Digital High Range
Area Radiation Monitor GTRE0059
4/21/2024
Calibration
Records
WO 23-488569-
000
STS IC-452A Channel Calibration of the New Fuel Storage
Facility Criticality Monitor SDRE0035
9/14/2023
Calibration
Records
STN SP-152 Chanel Calibration of the Steam Generator
Blowdown Discharge Radiation Monitor BMRE0052
3/5/2024
Corrective Action
Documents
Condition Reports
10016222, 10016754, 10017487, 10026056, 10033777,
10035110
Corrective Action
Documents
Resulting from
Inspection
Condition Reports
10035204, 10035216,10035237, 10035264
Miscellaneous
Lessons Learned from Issues Affecting Radiation Monitors -
White Paper (Chem Letter 2023-018) - Status Update Phase
1 & 2 [Presentation]
March 2024
Miscellaneous
Results of Radiochemistry Cross Check Program - Wolf
Creek Burlington - 2nd Quarter 2024
06/26/2024
Miscellaneous
System Health Report - Radiation Monitoring (1/1/2023 -
6/30/2023)
6/30/2023
Miscellaneous
Update Final Safety Analysis Report - Chapter 12.0
Radiation Protection
29
Miscellaneous
Instruction Manual for Digital High-Range Radiation Monitor
System (Addendum)
12/13/2017
Procedures
Chemistry Calibration Program
40
Procedures
Offsite Dose Calculation Manual
10
Procedures
RPP 01-405
RP Instrument Program
37
Procedures
RPP 05-306
PM12 Operation
7
Self-Assessments Audit Report 24-
01-RP/PC
Quality Assurance Audit Report, Radiological Protection &
02/28/2024
28
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Condition Reports
10014512, 10016221, 10022981, 1030180, 10030181,
10030182, 10032004,
Corrective Action
Documents
Resulting from
Inspection
Condition Reports
10035248, 10035249, 10035335
Miscellaneous
Sources with Activity > Category 1 or 2 Value
06/03/2024
Miscellaneous
RPF 02-605-03,
Rev 2
Licensed Quantity Source Inventory
06/03/2024
Miscellaneous
RPF 02-605-03,
Rev 2
Chemistry Exempt Source Inventory
07/25/2024
Procedures
Solid Waste Process Control Program
9
Procedures
RPP 07-110
Solid Radwaste Packaging
11
Procedures
RPP 07-112
Processing Cartridge Filters
5
Procedures
RPP 07-123
Preparation and Shipment of Radioactive Waste and
Material
9D
Procedures
RPP 07-124
Physical Security and Transportation Notification
Requirements for Category 1 and 2 Radioactive Material
4
Procedures
RPP 07-212
Requirements for Radioactive Materials Stored Outdoors
1
Radiation
Surveys
STS-HP-001
Sealed Source Contamination Surveillance Test (semi-
annual)
12/20/2023
Radiation
Surveys
STS-HP-001
Sealed Source Contamination Surveillance Test (semi-
annual)
06/27/2023
Self-Assessments 24-01-RP/PC
Audit Report: Radiological Protection and Process Control
Programs
02/26/2024
Self-Assessments QH-2022-2348
2022 Part 37 Protection of Category 1 and 2 Materials
Annual Review
06/28/2022
Self-Assessments QH-2023-2527
2023 Part 37 Annual Review
07/13/2023
Self-Assessments QH-2024-2662
2024 Part 37 Annual Review
06/19/2024
Shipping Records
2022, 2023, 2024
Shipping Logs
71151
Corrective Action
Documents
Resulting from
Inspection
Condition Reports
10035579, 10035582, 10035584
29
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71151
Miscellaneous
Wolf Creek Design Report IPAWS Design Report
Submission
1
71151
Miscellaneous
Tool Kit-017
IPAWS Audit Tool Kit
12/13/2023
Corrective Action
Documents
Condition Reports
1003561, 1003958, 10036008, 10036032, 10036035,
10036037, 10036038, 10036049, 10036058, 10036059,
10036068
Drawings
M-021A-00016
TDAFP Turbine Control Schematic
W04
Drawings
M-12AL01
Piping and Instrumentation Diagram Auxiliary Feedwater
System
33
Procedures
AI 22C-013
Protected Equipment Program
27
Procedures
On-Line Nuclear Safety and Generation Risk Assessment
30
Procedures
EMG FR-H1
Response to Loss of Secondary Heat Sink
37
Procedures
OFN MA-038
Rapid Plant Shutdown
32A
Work Orders
WO 83387, 83388
92702
CONF
Corrective Action
Documents
Condition Reports
134185, 135634, 00141956, 10016724, 10021053,
10030533, 10030549
92702
CONF
Corrective Action
Documents
CR-RCA-131147
Root Cause Analysis for Failure to Properly Document
CRDM Cleaning
1
92702
CONF
Miscellaneous
Root Cause Analysis Independent Review
05/07/2019
92702
CONF
Miscellaneous
STARS Meeting Agenda
01/24/2024
92702
CONF
Miscellaneous
Leader Talking Points
04/09/2024
92702
CONF
Miscellaneous
Treat Your Signature as Your Word Presentation
04/09/2024
92702
CONF
Miscellaneous
Compiled List of Personnel
04/09/2024
92702
CONF
Miscellaneous
Past Five Years of NRC Enforcement Actions
02/20/2024
92702
CONF
Miscellaneous
20026145
Industry Presentation
04/09/2024
92702
CONF
Miscellaneous
20026277
Communication Product
01/24/2024
30
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
92702
CONF
Miscellaneous
GT0335501
Evergy Code of Ethics Training
0
92702
CONF
Miscellaneous
GT1245012
New Wolf Creek Employee and Long Term Supplemental
Onboarding
1
92702
CONF
Miscellaneous
MGB310801
Maintenance Team Matters Training
13
92702
CONF
Miscellaneous
SA.2019.0149
Confirmatory Order Action H Benchmarking Summary
01/15/2020
92702
CONF
Procedures
AI-36-003
Integrity Verification
1
Attachment
Request for Information
From: David Proulx
Sent: Monday, June 24, 2024 1:15 PM
To: Lisa.Ketchum@evergy.com
Cc: Christopher Henderson <Christopher.Henderson@nrc.gov>
Subject: Request for Information
Wolf Creek team,
This email serves as my request for information:
Please provide the following via CERTREC:
1. Objective evidence of closure of each line item in the order.
2. All full condition reports generated related to the confirmatory order.
3. Any condition reports where willful/careless disregard was suspected.
4. All procedures changed as a result of the confirmatory order.
5. Any changes to the training program, and any training materials used to
communicate CO issues (e.g. general employee training).
6. All self-assessments related to completion of confirmatory order items.
7. All 3rd party assessments related to completion of the confirmatory order.
8. All letters generated to the NRC certifying annual/final completion of CO items.
This is my best list as of now. If I find the need for other items, I will contact under
separate e- mail.
-David Proulx
Senior Project Engineer
NRC Region IV
817-200-156