ML25069A711

License Renewal Phase 2 Inspection

ML25069A711
Person / Time
Site:	Wolf Creek
Issue date:	03/18/2025
From:	Greg Warnick NRC/RGN-IV/DORS/EB2
To:	Reasoner C Wolf Creek
References
IR 2025010
Download: ML25069A711 (40)

Text

March 18, 2025 Cleve Reasoner, Chief Executive Officer and Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION - LICENSE RENEWAL PHASE 2 INSPECTION REPORT 05000482/2025010

Dear Cleve Reasoner:

On February 6, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Wolf Creek Generating Station. On February 6, 2025, the NRC inspectors discussed the results of this inspection with Cleve Reasoner, Chief Executive Officer and Chief Nuclear Officer, and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Gregory G. Warnick, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000482 License No. NPF-42

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV Signed by Warnick, Gregory on 03/18/25

ML25069A711 X SUNSI Review ADAMS:

Non-Publicly Available X Non-Sensitive By:JFD X Yes No X Publicly Available Sensitive OFFICE SRI:DORS:EB2 RI:DORS:EB1 RI:DORS:EB2 SRI:DORS:EB2 C:DORS:PBB NAME SGraves JTalavera JMejia JDrake AAgrawal SIGNATURE

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DATE 03/11/25 03/11/25 03/11/25 03/10/25 03/12/25 OFFICE C:DORS:EB2 NAME GWarnick SIGNATURE

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DATE 03/18/25

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:

05000482 License Number:

NPF-42 Report Number:

05000482/2025010 Enterprise Identifier:

I-2025-010-0017 Licensee:

Wolf Creek Nuclear Operating Corporation Facility:

Wolf Creek Generating Station Location:

Burlington, KS Inspection Dates:

January 20, 2025, to February 14, 2025 Inspectors:

J. Drake, Senior Reactor Inspector S. Graves, Senior Reactor Inspector J. Mejia, Reactor Inspector C. Smith, Senior Reactor Inspector J. Talavera, Reactor Inspector Approved By:

Gregory G. Warnick, Chief Engineering Branch 2 Division of Operating Reactor Safety

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SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a License Renewal Phase 2 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 No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

3 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) 2516, Policy and Guidance for The License Renewal Inspection Program. 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 - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 71003 - Post-Approval Site Inspection for License Renewal (39 Samples)

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The team conducted a Phase 2 license renewal inspection. The following aging management programs (AMPs) were evaluated by the team:

WCLR-01, Time-Limited Aging Analysis (TLAA) - Environmental Qualification EQ of Electrical Components WCLR-02, TLAA - Metal Fatigue Reactor Coolant Pressure Boundary WCLR-03, TLAA - Concrete Containment Tendon Prestress WCLR-04, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements - ALEE WCLR-06, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements WCLR-07, ASME Section XI, Subsection IWE WCLR-08, Lubricating Oil Analysis WCLR-09, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components WCLR-11, External Surfaces Monitoring of Mechanical Components WCLR-12, One-Time Inspection of ASME Code Class 1 Small Bore-Piping WCLR-13, Fuel Oil Chemistry WCLR-14, Fire Water System WCLR-15, Fire Protection WCLR-16, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems WCLR-17, Closed Cycle Cooling Water Systems (CCCW)

WCLR-18, Open-Cycle Cooling Water WCLR-19, Regulatory Guidance (RG) 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants WCLR-20, Structures Monitoring WCLR-21, Masonry Walls WCLR-22, 10 CFR 50, Appendix J WCLR-23, ASME Section XI, Subsection IWF WCLR-24, ASME Section XI, Subsection IWL WCLR-25, Steam Generator Tube Integrity WCLR-26, Bolting Integrity WCLR-27, Flow-Accelerated Corrosion

4 WCLR-28, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components WCLR-29, Boric Acid Corrosion WCLR-30, Reactor Head Closure Studs WCLR-31, Water Chemistry WCLR-32, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD WCLR-35, Selective Leaching WCLR-36, One-Time Inspection WCLR-37, Reactor Vessel Surveillance WCLR-51, Wolf Creek RVI (reactor vessel internals) Inspection Plan Areas toured:

emergency diesel generator (EDG) rooms EDG storage tank fill and vent lines diesel fire pump room essential cooling water pump room essential cooling water heat exchangers and associated piping containment tendon gallery intake structure (circulating water and fire water) cable manholes The licensee had 39 commitments:

Commitments 22 (deleted), 24, 25, 29, 31, 33, 34, 35, 36, 37, 38, and 39 were closed in the Safety Evaluation Report (SER).

Commitments 9, 13, 20, 26, and 28 were closed in the Phase 1 inspection.

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A1.1 ASME SECTION XI INSERVICE INSPECTION, SUBSECTIONS IWB, IWC, AND IWD This is an existing program that performs inspections to manage cracking, surface and subsurface discontinuities, loss of fracture toughness, loss of material, and physical damage in Class 1, 2, and 3 piping and components, pressure boundary items and integral attachments that could result in loss of intended function. The programs methods of detection include periodic volumetric, surface, and/or visual examinations and leakage testing in accordance with ASME Section XI, Subsection IWB, IWC, and IWD.

There were no specific commitments related to this program.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed inspection activities. The inspectors concluded that the licensees implementing procedures were adequate.

Based on the review of the procedures, records and discussions with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

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A1.2 WATER CHEMISTRY This is an existing mitigation program, consistent with the Generic Aging Lessons Learned (GALL) Report, NUREG-1801, revision 1, credited with managing chemistry in the primary and secondary water systems. The program required no enhancement or exception, and the licensee based this program on EPRI water chemistry guidelines and relevant industry standards. The program continues to conduct periodic sampling of primary and secondary water for contaminants as specified in the EPRI PWR Primary and Secondary Water Chemistry Guidelines, and concentrations of corrosive impurities listed in the water chemistry guidelines are monitored to mitigate loss of material, cracking, and reduction of heat transfer.

Primary chemistry control uses filtration and ion exchange to control contaminants in makeup water, addition of lithium hydroxide for elevated pH control, and boric acid for reactivity control. Secondary chemistry control uses demineralizers and steam generator blowdown, addition of organic amines and all volatile treatment for pH control, hydrazine scavenges dissolved oxygen present in the feedwater and condensate systems. Water quality is maintained in accordance with the guidance, and chemical species and water quality are monitored by in-process methods or through sampling. The chemical integrity of the samples is maintained and verified to ensure that the method of sampling and storage will not cause a change in the concentration of the chemical species in the samples.

There were no specific commitments associated with this program.

A gap analysis was performed between GALL revision 1 and revision 2 for this program with no significant differences noted.

The inspectors reviewed the aging management program notebook, held discussions with program managers and staff, reviewed implementing procedures, and chemistry parameter trends. The inspectors verified that licensee procedures provide instructions and specifications for chemical species, impurities and additives, sampling and analysis frequencies, and corrective actions for out-of-specification primary and secondary water chemistry. The inspectors verified the control of selected parameters for both primary and secondary chemistry. The inspectors confirmed the licensee implemented the requirements of this program prior to the period of extended operation.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

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A1.3 REACTOR HEAD CLOSURE STUDS This is an existing program, consistent with the GALL report, NUREG-1801, without any present enhancements or commitments. Two exceptions exist and were previously documented in NUREG 1915 (the Safety Evaluation Report or SER). The program was originally written in accordance with revision 1 of the GALL report and a

6 subsequent gap analysis (WCLR-52) has been completed to address revision 2 of the GALL report.

This program monitors and manages aging effects of cracking and loss of material due to wear and corrosion for reactor vessel closure stud bolting (studs, washers, nuts, and threads in reactor vessel flange) via the inservice inspection program (WCRE-30) and preventative measures spanning several implementing procedures.

The licensee's procedures direct visual, surface, and volumetric examinations to identify cracking and or loss of material.

There were no specific commitments associated with this program.

Based on the review of the program, implementing procedures, records of completed activities, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.4 BORIC ACID CORROSION AND COMMITMENT 1 This is an existing program that relies in part on implementation of recommendations in NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants. The program manages material degradation due to borated water leakage. The program monitors mechanical, electrical, and structural components within the scope of license renewal susceptible to boric acid corrosion from systems that contain reactor coolant or treated borated water. Wolf Creek credited no exceptions and one enhancement to NUREG-1801 revision 1 Program XI.M10.

The enhancement to NUREG-1801 is Commitment 1 (RCMS 2006-198) which is Prior to the period of extended operation, procedures will be enhanced to state that susceptible components adjacent to potential leakage sources will include electrical components and connectors. Commitment 1 was satisfied by revising AP 16F-001 Boric Acid Corrosion Control Program, to include inspections of electrical components and connectors.

The inspectors determined that the Boric Acid Corrosion AMP is consistent with GALL AMP XI.M10 and found that it follows the recommendations in the GALL report with the enhancement.

Commitment 1 specified:

Prior to the period of extended operation, procedures will be enhanced to state that susceptible components adjacent to potential leakage sources will include electrical components and connectors. This commitment is related to the Boric Acid Corrosion AMP XI.M10 (WCLR-29). Wolf Creek met the commitment by revising site procedure AP 16F-001 Boric Acid Corrosion Control Program, to include inspections of electrical components and connectors.

The inspectors reviewed the aging management program notebook, held discussions

7 with program managers and staff, reviewed implementing procedures, and boric acid leak trends. The inspectors verified that licensee procedures provide instructions and specifications for walkdowns, evaluations, and corrective actions. The inspectors confirmed the licensee implemented the requirements of this program prior to the period of extended operation and concluded that Wolf Creek has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation, as required by 10 CFR 54.21(a)(3). Commitment 1 is closed.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.5 NICKEL-ALLOY PENETRATION NOZZLES WELDED TO THE UPPER REACTOR VESSEL CLOSURE HEADS OF PRESSURIZED WATER REACTORS This is an existing program that aligns with NUREG-1801, revision 2, Program XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components, and manages loss of material caused by boric acid-induced corrosion in susceptible safety-related components in the vicinity of nickel-alloy reactor coolant pressure boundary components, as well as cracking of nickel-alloy components and associated welds in reactor coolant pressure boundary components. The program provides inspection requirements for the reactor pressure vessel, pressurizer, and reactor coolant pressure boundary piping components if they contain primary water stress corrosion cracking susceptible materials designated alloys 600/82/182. The program also includes inspection requirements for the reactor pressure vessel upper head.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed inspection activities. The inspectors concluded that the station's implementing procedures were adequate to implement these required programs, and the program appears to be implemented appropriately in accordance with station procedures.

There were no specific commitments associated with this program.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.6 FLOW-ACCELERATED CORROSION This is an existing program, and it is consistent with NUREG-1801, revision 1, Program XI.M17, Flow-Accelerated Corrosion Program. Implementation of the Flow-Accelerated Corrosion (FAC) Program provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation. The Wolf Creek FAC program methodology is based on EPRI NSAC-202L guidelines. Detailed description of the Flow Accelerated Corrosion Aging Management Program bases is provided in WCLR-27, Flow-Accelerated Corrosion B2.1.6 NUREG-1801 Program XI.M17 Aging

8 Management Program, refer to (TAB 4) for detailed information. Activities discussed in this program document are credited for managing aging, as part of Wolf Creek License Renewal to meet the requirements of the License Renewal Rule 10 CFR 54.

Wolf Creek had one exception to NUREG-1801 revision 1 Program XI.M17 identified that was related to the revision of NSAC-202L in use. However, the NRC staff found the Flow-Accelerated Corrosion B2.1.6 NUREG-1801 Program XI.M17 Aging Management Program adheres to the NSAC-202L-R3 guidance, is consistent with NSAC-202L-R2 is acceptable as the staff found that the exception to the program improves the program.

Based on its audit and review of the Flow-Accelerated Corrosion B2.1.6 NUREG-1801 Program XI.M17 Aging Management Program, the NRC determined that those program elements for which the applicant claimed consistency with the GALL report are consistent. It was concluded that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The inspectors reviewed the updated safety analysis report (USAR) supplement for this aging management program and concluded that it provides an adequate summary description of the program, as required by 10 CFR 54.21 (d).

The inspectors reviewed the aging management program basis document, implementing procedures, completed inspection activities, and corrective action program evaluation of related issues. The inspectors confirmed the licensee completed the required examinations, and implemented the procedures associated with this program prior to the period of extended operation.

There were no specific commitments associated with this program.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.7 BOLTING INTEGRITY This is an existing program that manages the aging effects of cracking, loss of material, and loss of preload for pressure-retaining bolting and ASME component support bolting. The program includes preload control, selection of bolting material, use of lubricants and sealants consistent with EPRI bolting practices, and periodic inspections for indications of aging effects.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed inspection activities. The inspectors concluded that the licensees implementing procedures were adequate.

There were no specific commitments related to this program.

Based on the review of the procedures, records and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.8 STEAM GENERATOR TUBE INTEGRITY This is an existing program, consistent with the GALL report, NUREG-1801, without any present exceptions or enhancements as originally documented in the SER, NUREG 1915. The program was originally written in accordance with revision 1 of the GALL report and a subsequent gap analysis (WCLR-52) has been completed to address revision 2 of the GALL report and License Renewal Interim Staff Guidance (LR-ISG-2016-01).

This program monitors and manages aging effects of steam generator tubes, plugs, and secondary side components (internal to the steam generator) in accordance with their technical specifications and NEI 97-06, Steam Generator Program Guidelines, revision 3. This is accomplished via periodic inspections and preventative measures spanning several implementing procedures and overlapping aging management programs. Program overlap to include, Water Chemistry B2.1.2 NUREG-1801 Program XI.M2 Aging Management Program (WCLR-31) & Inservice Inspections (WCRE-30).

1.

The licensee's procedures primarily direct eddy current examinations and situational in-situ pressure testing or nondestructive testing to identify cracking and or loss of material for the steam generator tubes.

2.

The licensee's procedures direct visual examinations of primary side cladding, divider plate, stub runner, and their associated welds as well as all previously installed plugs, for loss of material or damage.

3.

The licensee's procedures direct visual, surface, and/or eddy current examinations to identify cracking and or loss of material for the secondary side components (internal to the steam generator).

There were no specific commitments related to this program.

Based on the review of the program, implementing procedures, records of completed activities, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.9 OPEN-CYCLE COOLING WATER SYSTEM This is an existing program, consistent with the GALL report, NUREG-1801, without any present exceptions or enhancements as originally documented in the SER, NUREG 1915. The program was originally written in accordance with revision 1 of the GALL report and a subsequent gap analysis (WCLR-52) has been completed to address revision 2 of the GALL report and License Renewal Interim Staff Guidance (LR-ISG-2012-01, 2012-02, & 2013-01).

The Licensees AMP technical basis defines open-cycle cooling water systems as those systems that transfer heat from systems required for safe shutdown of the plant to the ultimate heat sink.

This program monitors and manages the aging effects of material loss and fouling due to micro-or macro-organisms and various corrosion mechanisms found in piping

10 components with or without protective coating exposed to open-cycle cooling water (raw water). The Open-Cycle Cooling Water (OCCW) program encompasses portions and/or components of:

essential service water component cooling water (component cooling water heat exchangers) spent fuel pool cooling and clean-up (spent fuel pool make-up piping) stand-by diesel engine (DG intercoolers, DG lube oil coolers, and DG jacket water heat exchangers) auxiliary building HVAC (component cooling water pump room coolers, centrifugal charging pump room coolers, containment spray pump room coolers, electrical penetration room coolers, residual heat removal pump room coolers, and safety injection pump room coolers) containment cooling (containment coolers) control building HVAC (control room A/C unit condensers and class1E switchgear A/C unit condensers) fuel building HVAC (spent fuel pool pump room cooler) miscellaneous buildings HVAC (auxiliary feedwater pump room cooler)

This is accomplished via periodic inspections, various testing methods that are component dependent, and preventative measures spanning several implementing procedures and overlapping aging management programs. Program overlap and implementation include Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (WCLR-09) and Lake Water Systems Corrosion and Fouling Mitigation Program (AP 23L-001).

There were no specific commitments related to this program.

Based on the review of the program, implementing procedures, records of completed activities, and walkdowns of portions of the system/discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.10 CLOSED-CYCLE COOLING WATER SYSTEM, COMMITMENTS 3 AND 32 This is an existing program, consistent with the GALL report, NUREG-1801, with two exceptions and two enhancements as originally documented in the SER, NUREG 1915. The program was originally written in accordance with revision 1 of the GALL report and a subsequent gap analysis (WCLR-52) has been completed to address revision 2 of the GALL report and License Renewal Interim Staff Guidance (LR-ISG-2012-02 & 2013-01).

The Licensees AMP technical basis defines closed-cycle cooling water systems as closed systems that are not subject to significant sources of contamination, in which the water chemistry is controlled, monitored, and kept within specified limits, and in which the heat is not directly rejected to the ultimate heat sink.

This program monitors and manages the aging effects of reduction of heat transfer due to fouling, or the loss of material and/or cracking of the internal surfaces of piping, piping components, and piping elements exposed to treated water. This is accomplished via periodic inspections, various testing methods, and preventative

11 measures spanning several implementing procedures and overlapping aging management programs. Program overlap and implementation include Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (WCLR-09) and Chemistry Surveillance Program (AP 02-002).

The Closed-Cycle Cooling Water (CLCCW) program encompasses portions and/or components of:

component cooling water emergency diesel generator cooling water system reactor coolant system chemical & volume control system fuel pool cooling and cleanup system residual heat removal system high pressure coolant injection system liquid radwaste system nuclear sampling system Commitment 3 (RCMS 2006-200) specified:

Prior to the period of extended operation, a new periodic preventive maintenance activity will be developed to specify performing inspections of the internal surfaces of valve bodies and accessible piping while the valves are disassembled for operational readiness inspections to detect loss of material and fouling. The acceptance criteria will be specified in this preventive maintenance activity.

Commitment 32 (RCMS 2007-253) specified:

Site procedure QCP-20-518, "Visual System Examination of Heat Exchangers and Piping Components," will be revised to define cracking, provide additional guidance for detection of cracking and specific acceptance criteria relating to "as found" cracking.

Since issuance of RCMS 2006-200 and 2007-253, the commitments have been met, prior to the period of extended operation. Commitments 3 and 32 are closed.

Based on the review of the program, implementing procedures, records of completed activities, and walkdowns of portions of the system/discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.11 INSPECTION OF OVERHEAD HEAVY LOAD AND LIGHT LOAD (RELATED TO REFUELING) HANDLING SYSTEMS AND COMMITMENT 4 This is an existing program that manages loss of material and loss of preload for bolting for all cranes, bridges, trolley and hoist structural components, fuel handling equipment, and crane rail wear within the scope of license renewal. This includes visual inspection of structural components and structural bolts for loss of materials caused by corrosion of structural members and bolting, loss of materials caused by wear of rails, and loss of preload for bolted connections. Prior to March 11, 2025, the licensee was required to complete the below enhancements to the existing overhead crane program.

12 Commitment 4 (RCMS 2006-201) specified:

Prior to the period of extended operation, procedures will be enhanced to: (1) identify industry standards or Wolf Creek Generating Station specifications that are applicable to the component, and (2) specifically inspect for loss of material due to corrosion or rail wear.

The inspectors reviewed the aging management program basis document, implementing procedures, nondestructive evaluation reports, crane inspection reports, completed work orders, and commitment closure documentation. The inspectors verified the various crane inspection procedures included the enhancements in the commitments prior to the deadline. The procedures included the appropriate inspection frequency, inspection of various components and materials, and disposition of issues identified would follow the appropriate ASME B30 series and Crane Manufactures Association of America (CMAA) 70 standards. Commitment 4 is closed.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.12 FIRE PROTECTION AND COMMITMENT 5 This is an existing program, consistent with the GALL report, NUREG-1801, revision 1, after enhancements and exception, credited with managing loss of material of fire barrier walls, doors, ceilings, floors, fire dampers, and penetration seals that perform a fire barrier function; managing elastomer aging of penetration seals and Halon fire suppression system flexible hoses not periodically replaced in locations where ambient temperatures are above 95 F; and performs tests and inspections of the fuel oil supply line of the diesel driven fire pump.

Commitment 5 (RCMS 2006-202) specified that prior to the period of extended operation:

Fire damper inspection and drop test procedures will be enhanced to inspect damper housing for signs of corrosion.

Fire barrier and fire door inspection procedures will be enhanced to specify fire barriers and doors described in USAR Appendix 9.5A, WVCGS Fire Protection Comparison to APCSB 9.5-1 Appendix A," and Wolf Creek Generating Station Fire Hazards Analysis.

Training for technicians performing the fire door and fire damper visual inspection will be enhanced to include fire protection inspection requirements and training documentation.

Halon fire suppression system inspection procedures will be enhanced to include visual inspection of Halon tank flexible hoses (that do not have scheduled periodic replacement intervals) for hardening - loss of strength The inspectors reviewed the aging management program notebook and the commitment notebook (RCMS 2006-202), revised implementing procedures and completed program activities, performed walkdowns of fire barriers and held discussions with the site program owner and system engineer. Specifically, the inspectors reviewed updated implementation procedures satisfying the commitment,

13 completed work orders, fire barrier inspection results including fire damper functional tests and visual inspections, and corrective action documents. The inspectors also reviewed training and lesson plans for performing fire door and damper inspections.

The inspectors confirmed the licensee implemented the requirements of this program prior to the period of extended operation. Commitment 5 is closed.

Based on the walkdown, review of procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.13 FIRE WATER SYSTEM This is an existing program, consistent with the GALL report, NUREG-1801, revision 1, with exceptions, credited with managing the loss of material for water-based fire protection systems to ensure that in-scope components can perform their intended function through the period of extended operation. The program manages loss of material due to general, pitting, crevice, and galvanic corrosion, microbiological corrosion, or biofouling of carbon steel, cast-iron, copper, bronze, brass, galvanized, and ductile iron components in the fire water system. The program manages the aging of hose stations, piping, piping components, pump casings, spray nozzles, and sprinkler heads. Periodic hydrant inspections, fire main flushing, sprinkler inspections and flow tests are performed considering applicable National Fire Protection Association (NFPA) codes and standards. The program also tests samples of fire protection sprinkler heads and replaces those in service 50 years with the guidance of NFPA Code 25, 2002 Edition, and tests at 10-year intervals thereafter during the period of extended operation. Visual inspections of the fire protection system piping exposed to water and evaluating wall thickness to identify evidence of loss of material due to corrosion are covered by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components aging management program (XI.M38). The licensee does not use fire water storage tanks, instead using treated raw water directly from the reservoir.

The licensee performed a program gap analysis between the guidance in NUREG-1801, revision 1, and revision 2, including LR-ISG-2012-02, and supplemented their program with additional guidance in these references.

The inspectors performed a system walkdown, reviewed the aging management program notebook, updated implementing procedures, gap analysis and completed program activities, and held discussions with the site program owner, and system engineer. Specifically, the inspectors reviewed updated implementation procedures, completed inspections contained in the Basic Engineering Disposition: Augmented Inspections for Normally Dry, Non-Draining Fire Water Piping, completed work orders and corrective action documents. The inspectors confirmed the licensee implemented the requirements of this program prior to the period of extended operation.

There were no specific commitments related to this program.

Based on the walkdown, review of procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.14 FUEL OIL CHEMISTRY AND COMMITMENT 6 This is an existing program that manages loss of material on the internal surface of components in the emergency diesel fuel oil storage and transfer system and diesel fire pump fuel oil system. The program includes (a) surveillance and monitoring procedures for maintaining fuel oil quality by controlling contaminants in accordance with applicable ASTM Standards, (b) periodic draining of water from fuel oil tanks, (c) visual inspection of internal surfaces during periodic draining and cleaning of fuel oil tanks in the emergency diesel fuel oil storage and transfer system, (d) ultrasonic wall thickness measurements from external surfaces of fuel oil tanks, (e) inspection of new fuel oil before it is introduced into the storage tanks, and (f) one-time inspections of a representative sample of components in systems that contain fuel oil by the One-Time Inspection Program.

Commitment 6 (RCMS 2006-203 ) specified that prior to the period of extended operation:

Add the emergency fuel oil day tanks (TJE02A and TJE02B) to the ten-year drain, clean, and internal inspection program.

Enhance procedures to provide for supplemental ultrasonic thickness measurements if there are indications of reduced cross-sectional thickness found during the visual inspection of the emergency fuel oil storage tanks (TJE01A and TJE01B).

Perform a one-time ultrasonic or pulsed eddy current thickness examination on the external surface of engine driven fire pump fuel oil tank (1DO002T) to detect corrosion related wall thinning. If ultrasonic is used, the examination will be on a 4-inch grid. The examination will be performed once between 10 and 2 years prior to the period of extended operation.

The inspectors noted that the licensee changed Element 3 of Commitment 6 under USAR change requests 2015-014 and 2018-001. Specifically, in lieu of performing nondestructive examinations on diesel fire pump fuel oil storage tank 1DO002T, the licensee replaced the entire diesel fire pump, motor, gear drives, engine controller, and diesel fuel oil storage tank with new models under design change 013923.

Because the diesel fire pump fuel oil storage tank was replaced, there was no need to examine the corrosion on the previous tank. The inspectors did not identify any concerns with the commitment change. The inspectors confirmed the licensee implemented Commitment 6 prior to the period of extended operation. Commitment 6 is closed.

The inspectors performed a system walkdown of accessible components, reviewed the aging management program notebook, updated implementing procedures, gap analysis and completed program activities, and held discussions with the site program owner, and system engineer. Specifically, the inspectors reviewed completed inspection results, enhanced procedures, chemistry analyses, completed work orders, and corrective action documents.

Based on the walkdown, review of procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.15 REACTOR VESSEL SURVEILLANCE AND COMMITMENT 27 This is an existing program, consistent with the GALL report, NUREG-1801, without any present exceptions or enhancements as originally documented in the SER, NUREG 1915. The program was originally written in accordance with revision 1 of the GALL report and a subsequent gap analysis (WCLR-52) has been completed to address revision 2 of the GALL report.

This program monitors aging effects of reactor vessel beltline materials as defined by 10 CFR 50, Appendix G, Section II.F, and materials monitored within the scope of the licensees existing 10 CFR Part 50, Appendix H, materials surveillance program. This program is to provide sufficient material data and dosimetry to (a) monitor irradiation embrittlement at the end of the period of extended operation and (b) establish operating restrictions on the inlet temperature, neutron spectrum, and neutron flux after a surveillance capsule is withdrawn for testing.

Presently all capsules (internal vessel coupons) have been removed, remaining capsules are secured in storage for potential reinsertion, and operating restrictions have been set for the duration of period of extended operation. Presently the period of extended operation is 54 effective full power years refer to Commitment 27, based on the last removed internal vessel coupon. An external vessel program with ex-vessel dosimetry is in place to monitor/confirm projected fluence.

Commitment 27 (RCMS 2006-224) specified:

Wolf Creek will revise the Pressure and Temperature Limits Report for a 60-year licensed operating life.

Since issuance of RCMS 2006-224, the commitment has been met, the Pressure and Temperature Limits Report has undergone two revisions, with the first accounting for the 60-year licensed operating life. Commitment 27 is closed.

Based on the review of the program, implementing procedures, records of completed activities, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.16 ONE-TIME INSPECTION This is a new program that conducts one-time inspections of plant system piping and components to verify the effectiveness of the Water Chemistry Program WCLR-31 (A1.2), Fuel Oil Chemistry Program WCLR-13 (A1.14), and Lubricating Oil Analysis Program WCLR-08 (A1.23). The aging effects to be evaluated by the One-Time Inspection Program are loss of material, cracking, and reduction of heat transfer. The One-Time Inspection Program determines non-destructive examination (NDE) sample size for each material-environment group using established statistical methodologies and selects piping/component inspection locations within the sample that are based on service period, operating conditions, and design margins. The One-Time Inspection Program specifies corrective actions and increased sampling of components if aging effects are found. The One-Time Inspection Program is part of the overall strategy for maintaining the plant into the period of extended operation.

Wolf Creek credited no enhancements and no exception to NUREG-1801, revision 1,

16 Program XI.M32. The NRC staff found the One-Time Inspection Program acceptable.

The program included activities to verify effectiveness of aging management programs and activities to confirm the insignificance of aging effects as described below:

Water Chemistry Control - Primary and Secondary Program - One-time inspection activity verified the effectiveness of the Water Chemistry Control -

Primary and Secondary Programs by confirming that cracking, loss of material, and reduction of heat transfer were not occurring.

Oil Analysis Program - One-time inspection activity verified the effectiveness of the Oil Analysis Program by confirming that cracking, loss of material, and reduction of heat transfer were not occurring.

Diesel Fuel Monitoring Program - One-time inspection activity verified the effectiveness of the Diesel Fuel Monitoring Program by confirming that loss of material or reduction of heat transfer due to fouling were not occurring.

Reactor vessel flange leak detection line - One-time inspection activity confirmed that cracking and loss of material were not occurring.

Plant stack radiation monitor stainless steel tubing exposed to air-outdoor -

One-time inspection activity confirmed that cracking was not occurring.

This program required no enhancements or exceptions.

The inspectors reviewed the aging management program basis document, implementing procedures, completed inspection activities, and corrective action program evaluation of related issues. The inspectors confirmed the licensee completed the required examinations associated with this program prior to the period of extended operation.

There were no specific commitments associated with this program.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.17 SELECTIVE LEACHING OF MATERIALS AND COMMITMENT 8 This is a new program required to be implemented by Commitment 8 (RCMS 2006-205) prior to the period of extended operation. This aging management program is allowed to use visual and mechanical methods, or through destructive testing of a selected sample of component internal surfaces, to determine whether loss of material due to selective leaching is occurring. The program for selective leaching of materials ensures the integrity of the components made of gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc (> 15%

Zn) or greater than 8 percent aluminum (>8% Al in the case of aluminum-bronze) that are exposed to a raw water, closed cooling water, treated water, or ground water environment that may lead to selective leaching of one of the metal components.

Wolf Creek License Renewal WCLR-35-1 documents that, based on design specifications and confirmational testing all the pressure boundary copper alloy components in the license renewal scope at Wolf Creek do not contain greater than

17 15 percent zinc (> 15% Zn) or greater than 8 percent aluminum (>8% Al in the case of aluminum-bronze). Based on this, only gray-cast iron material components are required to be inspected at Wolf Creek. Commitment 8 is closed.

Based on the review of the procedures, records, and discussion with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.18 BURIED PIPING AND TANKS INSPECTION Previously closed in Phase 1 (20)

A1.19 ONE-TIME INSPECTION OF ASME CODE CLASS 1 SMALL-BORE PIPING AND COMMITMENT 10 This program is implemented as part of the existing site risk-informed ASME Section XI inservice inspection (RI-ISI) program and is credited with inspecting a representative sample of Class 1 stainless steel piping for cracking, with the one-time inspections completed during the 4th inservice inspection interval. The samples are ASME Code Class 1 piping less than 4 inches nominal pipe size (less than NPS 4) and greater than or equal to 1-inch nominal pipe size (greater than or equal to NPS 1). The RI-ISI program requires volumetric examinations (by ultrasonic testing) of these samples to detect cracking due to stress corrosion or thermal and mechanical loading. Weld locations were selected based on the guidelines provided in EPRI TR-112657, Revised Risk-Informed Inservice Inspection Evaluation Procedure.

Ultrasonic examinations were conducted in accordance with ASME Section XI with acceptance criteria from Paragraph IWB-3131 and IWB-2430.

Program scope requirements were compared to those in the GALL report, NUREG-1801, revision 2. The licensee's RI-ISI program only required testing a sample of high and medium risk locations greater than 1-inch. Twenty-five butt welds were selected for examination; no socket welds were identified as high safety significant locations requiring inspection.

Commitment 10 (RCMS 2006-207) specified:

The fourth interval of the ISI program at Wolf Creek will provide the results for the one-time inspection of ASME Code Class 1 small-bore piping.

The inspectors reviewed the aging management program notebook, sample selection documentation, completed program activities, and held discussions with the site program owner. All 25 required welds had been inspected with 11 welds in RF-21, one weld in RF-22, five welds in RF-23, two welds in RF-24, four welds in RF-25, and two welds in RF-26. The inspection results were all satisfactory. The inspectors confirmed the licensee implemented the requirements of this program prior to the period of extended operation. Commitment 10 is closed.

Based on the review of records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

18 (21)

A1.20 EXTERNAL SURFACES MONITORING PROGRAM This is an existing condition monitoring program, credited with managing aging effects on external surfaces of bolting, HVAC ducting, fans, ventilation flexible connections, piping, piping components, pumps, valves, tanks, expansion joints, insulation and jacketing. The External Surfaces Monitoring Program (ESMP) is credited with managing aging effects of elastomers / polymeric components by checking for evidence of loss of material, cracking, and change in material properties.

The program credits periodic visual inspections during proceduralized site engineering core duty walkdowns to detect aging effects. The program also credits opportunistic inspections as part of work activity planning. The program was updated to also address the corrosion under insulation (CUI) issue documented in LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation. Walkdowns for systems inside containment are conducted at least every refueling outage or as necessary based on system safety significance, accessibility, production significance, trending of inspection results, and operating experience.

The ESMP includes external surface inspection of two outdoor stainless-steel tanks (refueling water storage tank TBN01 and condensate storage tank TAP01) in lieu of an Aboveground Metallic Tanks program. The ESMP supplements the Bolting Integrity aging management program by providing the requirements for the inspection of in-scope pressure boundary closure bolting and supplements the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components aging management program by inspecting in-scope HVAC / duct elastomer, bolting and metallic surfaces where the external surface condition is representative of the internal surface condition. Carbon steel and cast-iron materials in the Halon system which are exposed to external environment of plant indoor air and external surfaces of the diesel-driven fire pump fuel oil supply line are visually inspected as part of this program. The program also supports the activities credited with the performance of the Boric Acid Corrosion aging management program by performing inspections of outside diameter stress corrosion cracking, using dye penetrant testing, on at least 25 locations in each 10-year period after entering the period of extended operation.

Program requirements were compared to those in the GALL report, NUREG-1801, revision 2, and amended to include physical manipulation of elastomeric materials.

There were no specific commitments related to this program.

The inspectors walked down the two in-scope tanks, reviewed the aging management program notebooks, updated implementing procedures, completed program inspection activities and work orders, and held discussions with the site program owner. The inspectors concluded that the implementing procedures appropriately implemented the external surface visual inspections. The inspectors confirmed the licensee implemented the requirements of this program prior to the period of extended operation.

Based on the review of procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

19 (22)

A1.21 FLUX THIMBLE TUBE INSPECTION Previously closed Phase 1 (23)

A1.22 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS PIPING AND DUCTING COMPONENTS AND COMMITMENT 11 This is a new program developed to conduct the monitoring of internal surfaces of piping, piping components, ducting and other components that are not covered by other aging management programs. The program will inspect, at a minimum, a representative sample of 20 percent of the population (defined as components having the same combination of material, environment, and aging effect) or a maximum of 25 components per population. Visual inspections are performed during periodic maintenance, predictive maintenance, surveillance testing and corrective maintenance (opportunistic in nature) to manage cracking, loss of material and hardening - loss of strength to detect aging effects that could result in a loss of component intended function. The program also addresses the acceptance criteria and how components are chosen for inspection to ensure all material/environment combinations are inspected.

Commitment 11 (RCMS 2006-208) specified:

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program that will be implemented prior to the period of extended operation. For those systems or components where inspections of opportunity are insufficient, an inspection will be conducted prior to the period of extended operation to provide reasonable assurance that the intended functions are maintained.

The inspectors reviewed the aging management program basis document, implementing procedure AI 23I-008, Implementation of the Inspection of Internal Surfaces AMP, and documentation of planned inspection activities. The inspectors concluded that the licensees implementing procedures were adequate. Commitment 11 is closed.

Based on the review of the procedures, records and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.23 LUBRICATING OIL ANALYSIS This is an existing program that manages loss of material and reduction of heat transfer for components within the scope of license renewal. The program maintains lubricating oil quality by limiting contaminants to acceptable limits. The licensee periodically samples lubricating oil to ensure it meets acceptance criteria based on industry guidelines for oil chemical and physical properties, wear metals, contaminants, additives, and water. the systems in the scope of this program are reactor coolant, high pressure coolant injection, chemical and volume control, fire protection, emergency diesel generator, and auxiliary feedwater.

The inspectors reviewed the aging management program notebook, implementing procedures, completed program activities, and held discussions with the site program

20 owner, and system engineer. The inspectors observed an oil sample collection on component cooling water pump train C and reviewed previous lubricating oil sample results for the steam-driven auxiliary feedwater pump for particulates, lubricity, water, etc. and for trends for all systems in the scope of the program. The inspectors confirmed the licensee implemented the procedures associated with this program prior to the period of extended operation.

There were no specific commitments related to this program.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.24 ELECTRICAL CABLES AND CONNECTIONS NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION REQUIREMENTS AND COMMITMENT 12 This is a new program, consistent with the GALL report, NUREG-1801, revision 1, created with managing the aging effects of embrittlement, melting, cracking, swelling, surface contamination, or discoloration to ensure that the electrical cables and connections within the scope of license renewal not subject to environmental qualification (EQ) requirements of 10 CFR 50.49 can perform the intended function through the period of extended operation. Non-EQ cables and connections within the scope of license renewal in accessible areas with adverse environments were visually inspected for signs of localized accelerated aging on their outer insulation or jacket material. The inspections searched for signs of aging included embrittlement, discoloration, cracking, melting, swelling and surface contamination. The acceptance criteria was the absence of anomalous indication of degradation.

Program requirements were compared to those in the GALL report, NUREG-1801, revision 2, and no changes were required.

Commitment 12 (RCMS 2006-209) specified:

The Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements program is a new program that will be implemented prior to the period of extended operation.

Walkdowns are credited with identifying adverse localized environments with in-scope cables and connections, and will be performed at least once every 10 years with the first walkdowns completed before the period of extended operation. Walkdowns outside of containment were performed in November 2017 and December 2023.

Walkdowns in containment (reactor building) were performed both in October 2022 (RF25) and repeated again in April 2024 (RF26) to validate the RF25 effort. Site procedure AP 23R-001, Cable Aging Management Program implements the requirements of this program.

The inspectors reviewed the aging management program notebooks, implementing procedures, completed program activities, and held discussions with the site program owner. Specifically, the inspectors reviewed completed work orders, job plan details, walkdown inspection forms, and corrective action documents. The inspectors confirmed the licensee implemented the requirements of this program prior to the

21 period of extended operation. Commitment 12 is closed.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.25 ELECTRICAL CABLES AND CONNECTIONS NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION REQUIREMENTS USED IN INSTRUMENTATION CIRCUITS Previously closed in Phase 1 (27)

A1.26 INACCESSIBLE POWER CABLES NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION REQUIREMENTS AND COMMITMENT 14 This is a new program, originally consistent with the GALL report, NUREG-1801, revision 1, and amended to reflect expansion of scope to include low voltage power cables above 400V as directed by the GALL report, revision 2. The program is credited with managing the aging effects of in-scope inaccessible power cables with operating voltage greater than or equal to 400V that have the potential to be exposed to moisture that lasts more than a few days. The program includes periodic inspection of manholes containing in-scope cables for water accumulation and removal of water as necessary. Manhole inspection and water removal are performed based on plant operating experience with the frequency being at least once every two years for electrical manholes without sump pumps and inspection frequency being at least once every five years for electrical manholes with sump pumps. The licensee developed site procedure AP 23R-001, Cable Aging Management Program to implement the requirements of this program.

Program requirements were compared to those in the GALL report, NUREG-1801, revision 2, and the program scope amended to include low voltage power cables, address manhole inspection and cable testing criteria.

Commitment 14 (RCMS 2006-211) specified:

The Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements program is a new program that will be implemented prior to the period of extended operation.

The inspectors performed walkdowns of selected in-scope manholes, reviewed the aging management program notebook, implementing procedures, plant drawings for manholes, completed program activities, and held discussions with the site program owner. Specifically, the inspectors reviewed completed work orders, job plan details, walkdown inspection forms, and corrective action documents. The licensee removed manhole covers for visual inspections. The inspectors questioned the inspection periodicity for manholes as it differs from the annual recommendations in the GALL report, revision 2. The licensee explained that their in-scope manhole designs had automatic dewatering features, and in some cases both solar powered and AC sources to ensure pump operability. The manhole designs also had both remote sensing and alarm functions to alert operators to adverse conditions. Plant operating experience was also included in developing inspection and testing periodicities. The inspectors identified no issues with this approach.

22 The inspectors also discussed the licensee's current testing program for shielded medium voltage cables, and the licensee entered this topic into their corrective action program to review other contemporary cable testing approaches, including Tan-Delta tests. The inspectors confirmed the licensee implemented the requirements of this program prior to the period of extended operation. Commitment 14 is closed.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.27 ASME SECTION XI, SUBSECTION IWE This is an existing program that was developed in accordance with the applicable requirements of 10 CFR 50.55a and the ASME Code Section XI, Subsection IWE, that manages steel liner of the concrete containment building, including piping and electrical penetrations, access hatches, the fuel transfer tube, pressure retaining bolting and integral attachments. The ASME Code Section XI, Subsection IWE Aging Management Program is part of the overall strategy for maintaining the plant into the period of extended operation. This program identifies and manages aging effects of the containment structure pressure retaining components (metallic shell liner and penetrations). Examinations are performed on ASME pressure retaining components and their integral attachments to containment per applicable requirements of 10 CFR 50.55a and the ASME Code Section XI, Subsection IWE. The examination method and testing for containment seals and gaskets for all pressure retaining components, is part of the 10 CFR Part 50, Appendix J, Leak Rate Testing Program. The aging management of ASME Section XI - IWE pressure retaining bolting related to selection of lubrication, loss of preload is performed per Bolting Integrity Aging Management Program. The ASME Section XI, Subsection IWE Aging Management Program is credited for managing aging, as part of Wolf Creek License Renewal to meet the requirements of the License Renewal Rule 10 CFR 54.

The ASME Section XI, Subsection IWE Aging Management Program provides reasonable assurance that the intended functions of containments steel liner within the scope of license renewal are maintained consistent with the current licensing basis through the period of extended operation. The ASME Section XI, Containment Inservice Inspection Program (CISI) is required by 10 CFR 50.55a. The Wolf Creek CISI Program is updated during each successive 120-month inspection interval to comply with the requirements of the latest edition and addenda of the ASME Code specified 18 months before the start of the inspection interval and condition noted in 10 CFR 50.55a. For the current CISI Inspection Program, 3rd Interval, the period extends from September 10, 2018, to September 9, 2028, which will be in place at the start of the period of extended operation. The 3rd Interval, Wolf Creek CISI IWE Program performs inservice inspections in accordance with ASME Section XI, Subsection IWE, 2013 Edition.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, and

23 corrective action program evaluation of related issues. The inspectors concluded that the station's implementing procedures were adequate to implement the required inspection activities, and that this program has been adequately implemented.

There were no specific commitments associated with this program.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.28 ASME SECTION XI, SUBSECTION IWL, COMMITMENTS 15, 17, AND 23 This is an existing program that identifies and manages aging effects of the concrete containment structure (including the tendon gallery ceiling), the concrete dome, and the post-tensioning system. Inspections are performed on a 5-year frequency to identify and manage any containment concrete aging effects that could result in loss of intended function. Additional inspections are performed for concrete surface areas and/or tendons affected by a repair/replacement activity. The program further states during the period of extended operation, the licensee must perform the technical evaluation under IWL-2512(b) of inaccessible below-grade concrete surfaces exposed to foundation soil, back-fill, or ground water at periodic intervals not to exceed 5 years. In addition, the licensee must examine representative samples of the exposed portions of the below-grade concrete, when such below-grade concrete is excavated for any reason.

Commitment 15 (RCMS 2006-212) specified that prior to the period of extended operation, procedures will be enhanced to include two new provisions regarding inspection of repair/replacement activities. The 2001 edition with 2002 and 2003 addenda of ASME Code Section XI, Subsection IWL, Article IWL-2000, includes two provisions that are not required by the 1998 edition. IWL-2410(d) specifies additional inspections for concrete surface areas affected by a repair/replacement activity, and IWL-2521.2 specifies additional inspections for tendons affected by a repair/replacement activity. In accordance with 10 CFR 50.55a, Wolf Creek will revise their CISI program prior to the next inspection interval to incorporate the ASME Code edition and addenda incorporated into 10 CFR 50.55a at that time. Commitment 15 has been incorporated into the concrete containment implementing documents and is closed.

Commitment 17 (RCMS 2006-214) specified that prior to period of extended operation, procedures will be enhanced to add inspection parameters for treated wood and monitor groundwater for pH, sulfates, and chlorides. Two samples of groundwater will be tested every five years. Commitment 17 meets the requirement for determining the condition of inaccessible containment concrete through ground water monitoring and is closed.

Commitment 23 (RCMS 2006-220) specified that prior to the period of extended operation, procedures will be revised to: (1) extend the list of surveillance tendons to include random samples for the year 40, 45, 50, and 55-year surveillances, (2) explicitly require a regression analysis for each tendon group after every surveillance, (3) invoke and describe regression analysis methods used to construct the lift-off

24 trend lines, (4) extend surveillance program predicted force lines for the vertical and hoop tendon groups to 60 years, and (5) conform procedure descriptions of acceptance criteria action levels to the ASME Code, Subsection IWL-3221 descriptions. Since the tendon surveillance is controlled by specification C-158 Technical Specification for Containment Tendon Surveillance," this specification was revised to include the five noted requirements of Commitment 23. Commitment 23 has been incorporated into the Wolf Creeks Concrete Containment documents and is closed.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed inspection activities. The inspectors concluded that the licensees implementing procedures were adequate.

Based on the review of the procedures, records and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.29 ASME SECTION XI, SUBSECTION IWF This is an existing program that performs inspections to manage loss of material, cracking, and loss of mechanical function that could result in loss of intended function for Class 1, 2, and 3 piping and Class MC Component supports through regularly scheduled visual examinations in accordance with ASME Section XI, Subsection IWF.

There are no Class MC supports at Wolf Creek.

There were no specific commitments related to this program.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed inspection activities. The inspectors concluded that the licensees implementing procedures were adequate.

Based on the review of the procedures, records and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.30 10 CFR 50, APPENDIX J This is an existing program that monitors leakage rates through the containment pressure boundary penetrations and access openings, to detect degradation of containment pressure boundary elements, or components, including seals, gaskets, and bolted connections. The program relies on periodic leak testing through Type A, Type, B and Type C testing in accordance with 10 CFR 50 Appendix J, Option B and NEI 94-01.

There were no specific commitments related to this program.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed inspection activities. The inspectors concluded that the licensees implementing procedures are adequate.

Based on the review of the procedures, records and discussions with licensee

25 personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.31 MASONRY WALL PROGRAM AND COMMITMENT 16 This is an existing program implemented as part of the structures monitoring program.

The masonry wall program performs inspections to manage aging for masonry walls and steel restraint systems of the masonry walls in the following buildings: auxiliary building, control building, turbine building, radwaste building, communications corridor, and circulating water screen house. The program requires periodic visual inspection of masonry walls to detect loss of material and cracking of masonry units and mortar.

Commitment 16 (RCMS 2006-213) specified:

Prior to the period of extended operation, procedures will be enhanced to identify un-reinforced masonry in the radwaste building within the scope of license renewal that requires aging management.

Procedure AI 23M-007, Structures Monitoring Program was revised prior to the period of extended operation to identify the un-reinforced masonry in the radwaste building within the scope of this program. Commitment 16 is closed.

Masonry walls are inspected every 5 years, except in areas where significant loss of material or cracking is observed, more frequent inspections may be performed to ensure there is no loss of intended function between inspections. Qualified engineers perform visual inspections and categorize observations. Masonry walls are monitored for cracks that cut through the blocks and mortar joints, distortion or displacement, presence of water, evidence of shrinkage and/or separation, and aging effects at joints between the masonry wall and supporting slabs. The program includes monitoring of steel bracing and other steel components for corrosion, missing or damaged bolts, deformations, anchorage, and pullout.

The inspectors performed system walkdowns, reviewed the aging management program notebook, updated implementing procedures, gap analysis and completed program activities, and held discussions with the site program owner, and system engineer. Specifically, the inspectors reviewed updated implementation procedures, completed inspections, completed work orders and corrective action documents. The licensee generated condition report CR10039553 to revise station procedures to ensure opportunistic masonry wall inspections and structural inspections occur. The inspectors confirmed the licensee implemented the requirements of this program prior to the period of extended operation.

Based on the walkdown, review of procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.32 STRUCTURES MONITORING PROGRAM AND COMMITMENT 17 This is an existing program originally implemented in response to 10 CFR 50.65 (Maintenance Rule). This program was credited in the license renewal application to satisfy 10 CFR 54 (license renewal) requirements for implementation of a Structures

26 Monitoring B2.1.32 NUREG-1801 XI.S6 Aging Management Program. The program manages cracking, loss of material, and change in material properties by monitoring the condition of structures and structural supports that are within the scope of license renewal. The program provides inspection guidelines and walkdown checklists for concrete elements, structural steel, masonry walls, treated wood, structural features (e.g., caulking, sealants, roofs, etc.), structural supports, and miscellaneous components such as doors. The program includes all masonry walls within the scope of license renewal and inspects supports for equipment, piping, conduit, cable tray, HVAC, and instrument components. Though coatings may have been applied to the external surfaces of structural members, no credit was taken for these coatings in the determination of aging effects for the underlying materials. The Structures Monitoring Program evaluates the condition of the coatings as an indication of the condition of the underlying materials. The Structures Monitoring Program is described in USAR Chapter 18, Appendix A1.32.

Commitment 17 (RCMS 2006-214) specified:

Prior to the period of extended operation, procedures will be enhanced to add inspection parameters for treated wood, to add the disconnect enclosure and foundation in the switchyard, and to monitor groundwater for pH, sulfates, and chlorides. Two samples of groundwater will be tested every 6 years.

Procedure AI 23M-007, "Structures Monitoring Program" was revised prior to the period of extended operation to inspect the items above and test the groundwater.

Commitment 17 is closed.

The inspectors performed a system walkdown, reviewed the aging management program notebook, updated implementing procedures, gap analysis and completed program activities, and held discussions with the site program owner, and system engineer. Specifically, the inspectors reviewed updated implementation procedures, completed inspections contained in the completed work orders and corrective action documents. The licensee generated condition report 10039554 to revise station procedures such that areas previously deemed 'inaccessible' due to elevated radiation levels would be inspected with remote means. The inspectors confirmed the licensee implemented the requirements of this program prior to the period of extended operation.

Based on the walkdown, review of procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.33 RG 1.127, INSPECTION OF WATER-CONTROL STRUCTURES ASSOCIATED WITH NUCLEAR POWER PLANTS AND COMMITMENT 18 This program manages aging due to extreme environmental conditions and the effects of natural phenomena that may affect water-control structures. This program includes inspection and surveillance activities for dams, slopes, canals, and other water-control structures associated with emergency cooling water systems or flood protection. The program includes periodic visual inspections of in-scope concrete structures, periodic monitoring of the hydraulic and structural condition of the ultimate heat sink (UHS), as well as associated structures, main dam service spillway, and auxiliary spillway, periodic dredging of the UHS reservoir and channel connecting the

27 reservoir to the essential service water pumphouse, and survey of the UHS dam for vertical movement.

Commitment 18 (RCMS 2006-215) specified that prior to the period of extended operation, procedures will be enhanced to: (1) the main dam service spillway and the auxiliary spillway will be inspected in accordance with the same specification, (2) clarify the scope of inspections for the spillways, (3) add the 5-year inspection frequency for the main dam service spillway, and (4) add cavitation to the list of concrete aging effects for surfaces other than spillways.

The inspectors reviewed Specification C-403, "Periodic surveillance of non-safety related water structures and reservoir for the Wolf Creek Generating Station," revision 6, and noted they were revised to add cavitation to the list of concrete aging effects found. In addition, the inspectors found Specification C-403 requires a 3-year inspection frequency for the main dam service and auxiliary spillways, which is required by the state of Kansas regulations. The licensee will follow the more conservative 3-year surveillance interval for both main dam spillways.

The inspectors reviewed the aging management program basis document, implementing procedures, surveillances, and completed preventive maintenance tasks. The inspectors noted that Specification C-404 and AP 29-005, "Examination of safety-related concrete water control structures, revision 3, and procedure AP 29D-001, UHS monitoring program, revision 4, implemented aging management as well as activities such as clearing brush, performing inspections, dredging the ultimate heat sink, and performing hydrograph sounding data to verify the UHS retains its required form and water inventory. During inspections of the essential service water discharge flow orifice, the licensee identified a potential indication and generated condition report 10017164 to inspect the affected area with remote means, which should provide better resolution and allow the station to quantify the indication. The inspectors confirmed the licensee implemented the requirements of this program prior to the period of extended operation. Commitment 18 is closed.

Based on the walkdown, review of procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

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A1.34 NICKEL ALLOY AGING MANAGEMENT PROGRAM, COMMITMENTS 2, 19, AND 30 This is an existing program that aligns with NUREG-1801, revision 2 program XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components.

The license renewal application and SER, NUREG-1915, were based on the GALL report, NUREG-1801, revision 1. Those documents outlined two programs and a commitment to manage primary water stress corrosion cracking and boric acid corrosion. Those items were as follows:

Nickel Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads (URVCH) of Pressurized Water Reactors AMP per NUREG-1801, revision 1, program XI.M11A.

28 Nickel Alloy which is a plant specific program with no associated NUREG-1801, revision 1, program.

Wolf Creek committed to implement applicable (1) NRC orders, bulletins and generic letters associated with nickel alloys, and (2) staff-accepted industry guidelines.

The NRC subsequently issued NUREG-1801 revision 2, which created a new aging management program, program XI.M11B, Cracking of Nickel Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components. This action combined the three items submitted in the original license renewal application and approved via the SER.

Program XI.M11B supersedes program XI.11A and includes two major changes:

(1) ASME Code Case N-729-6 replaces NRC Order EA-03-009 as the basis for the Upper Reactor Vessel Closure Head (URVCH) inspections; and (2) the scope of the program was increased to account for all Alloy 600 RCS pressure boundary components.

Wolf Creek performed a gap analysis between requirements in NUREG-1801, revision 1 and revision 2 as documented in WCLR-52. Wolf Creek combined these requirements into the Nickel Alloy program.

Commitment 2 (RCMS 2006-199) required that prior to the period of extended operation, procedures will be enhanced to indicate that detection of leakage or evidence of cracking in the vessel head penetration nozzles or associated welds will cause an immediate reclassification to the High susceptibility ranking, commencing from the same outage in which the leakage or cracking is detected as defined in NRC Order EA-03-009. After the original commitment was made, NRC Order EA-03-009 was replaced with the regulation 10 CFR 50.55a to implement ASME Code Case N-729-1 with conditions. Subsequent revisions were made to 10 CFR 50.55a, where the NRC adopted later versions of Code Case N-729. Wolf Creek will continue to comply with the requirements of 10 CFR 50.55a for inspection of Reactor Vessel Closure Head using ASME Code Case N-729 with the additional condition of 10 CFR 50.55a.

Once the requirements of 10 CFR 50.55a were implemented, the NRC Order EA 009 no longer applied. Commitment 2 is no longer applicable and is closed.

Commitment 19 (RCMS 2006-216), Part A, Reactor Coolant System Nickel Alloy Pressure Boundary Components, addresses the reactor coolant system nickel alloy pressure boundary components and reactor vessel internals to implement applicable:

NRC orders, bulletins and generic letters associated with nickel alloy; staff-accepted industry guideline; participate in the industry initiative, such as owners group programs and the EPRI Materials Reliability Program, for managing aging effects associated with nickel alloys; and upon completion of these programs, but not less than 24 months before entering the period of extended operation, Wolf Creek will submit an inspection plan for reactor coolant system nickel alloy pressure boundary components to the NRC for review and approval.

29 Commitment 30 (RCMS 2007-251) required that the inservice inspection program be supplemented with implementation of: (1) NRC orders, bulletins and generic letters associated with nickel alloy, (2) staff-accepted industry guidelines, (3) participate in the industry initiative, and (4) submit an inspection plan for reactor coolant system nickel alloy pressure boundary components. The commitment was changed to allow an annual review of the key characteristics be verified to comply with above guidance documents. Commitment 30 is closed.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(36)

A1.35 REACTOR COOLANT SYSTEM SUPPLEMENT AND COMMITMENT 19 This is an existing program that manages the effects of aging in the reactor vessel internals and implements the industry recommended guidance for managing these aging concerns. The program supports the implementing protocol under the NEI 03-08, Guideline for the Management of Materials Issues, and the implementation guidelines defined by MRP-227-1-A and MRP-228.

This program coordinates with the existing ASME Section XI inservice inspection program, supplements that program with augmented examinations for managing the potential aging effects and appropriate monitoring to maintain the reactor vessel internals functionality.

Commitment 19 (RCMS 2006-216), Part B, Reactor Vessel Internals, specified:

participate in the industry programs for investigating and managing aging effects on reactor internals; evaluate and implement the results of the industry programs as applicable to the reactor internals; and upon completion of these programs, but not less than 24 months before entering the period of extended operation, Wolf Creek will submit an inspection plan for reactor internals to the NRC for review and approval.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed inspection activities. The inspectors concluded that the licensees implementing procedures are adequate.

Commitment 19 is closed.

Based on the review of the procedures, records and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(37)

A1.36 ELECTRICAL CABLE CONNECTIONS NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION REQUIREMENTS Previously closed in Phase 1 (38)

A1.37 METAL FATIGUE OF REACTOR COOLANT PRESSURE BOUNDARY, COMMITMENTS 21, 38, 40 AND 41

30 This existing program ensures that actual plant experience remains bounded by assumptions used in design calculations, or that appropriate corrective measures maintain the design and licensing basis by other acceptable means. The Metal Fatigue of Reactor Coolant Pressure Boundary aging management program credits the Wolf Creek Fatigue Management Program, which is an existing program. To fulfill license renewal requirements, the licensee committed to implement four enhancements to the Fatigue Management Program prior to entering the period of extended operation; Commitments 21, 38, 40 and 41. The Metal Fatigue of Reactor Coolant Pressure Boundary aging management program is described in Updated Safety Analysis Report, Sections 18 A2.1 and 18 A3.2. The Wolf Creek Metal Fatigue of Reactor Coolant Pressure Boundary aging management program basis document is WCLR-02.

The Metal Fatigue of Reactor Coolant Pressure Boundary aging management program is implemented in accordance with procedure AP 23I-001, RCS Stress and Cycle Management (previously titled Fatigue Management). Upgrades have been made to the fatigue monitoring program to satisfy the evolving needs of the plant through the original license, the license renewal process, and in preparation for the period of extended operation. In particular, the fatigue monitoring program has been enhanced using FatiguePro 4.0 software for on-going monitoring of design transients and fatigue usage, including Environmentally-Assisted Fatigue. This notebook includes a summary report, FP-WOLF-410, that includes a general description of the FatiguePro 4.0 software and information about which transients and components are monitored at Wolf Creek. This report also includes a summary of the action limits for fatigue and Environmentally-Assisted Fatigue, along with recommendations and corrective actions for resolving any issues that have been identified through monitoring.

Commitment 21 (RCMS 2006-218) includes a list of procedure enhancements required to be implemented prior to the period of extended operation. This commitment was met by revising procedure AP 23I-001, RCS Stress and Cycle Management. Commitment 21 is closed.

Commitment 38 (RCMS 2007-283) - Wolf Creek agreed to calculate an updated baseline fatigue usage factor that adequately bounds transients experienced before the monitoring of cumulative usage factors was started. This commitment was completed and accepted by the NRC prior to issuance of the SER (reference SER Section 4.3.2.7.2). Commitment 38 is closed.

Commitment 40 (RCMS 2008-320) - Wolf Creek agreed to update the fatigue monitoring program analyses if thermal sleeves were determined to be not present in the charging nozzles. Further investigation determined that thermal sleeves are not present in the charging nozzles. The charging nozzle fatigue analyses were subsequently re-performed and incorporated into Fatigue Pro monitoring program analysis packages. Commitment 40 is closed.

Commitment 41 (RCMS 2008-323) - Wolf Creek committed to update the fatigue monitoring program to adjust baselines for; (1) the pressurizer hot leg surge nozzle CUF based on the additional insurge/outsurge cycles accumulated in a pre-Modified Operating Procedure (pre-MOP) environment, and (2) the charging nozzles with

31 consideration for the differential contribution of fatigue for each category of charging event. Wolf Creek completed Commitment 41 as part of the 2007 fatigue monitoring program baseline update. Commitment 41 is closed.

Based on the walkdown, review of procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(39)

A1.38 CONCRETE CONTAINMENT TENDON PRESTRESS, COMMITMENTS 15 AND 23 This is an existing program that is implemented in accordance with the applicable requirements of 10 CFR 50.55a and ASME Code Section XI, Subsection IWL, that manages aging effects for concrete containments that could result in loss of intended function. The Concrete Containment Tendon Prestress Program manages the loss of tendon prestress in the post-tensioning system, which consists of inverted U-shaped tendons extending up through the basemat through the full height of the cylindrical walls and over the dome and of horizontal circumferential (hoop) tendons at intervals from the top of the basemat to about the 45-degree elevation of the dome. The post-tensioning system consists of two tendon groups: (1) vertical, inverted-U-shaped tendons, and (2) horizontal circumferential tendons. The vertical inverted-U tendons are anchored through the bottom of the conventionally reinforced concrete basemat.

The horizontal hoop tendons are anchored at three exterior buttresses 120 degrees apart. Each hoop tendon extends 240 degrees around the containment building, passing under an intervening buttress. The tendons are not bonded to the concrete but inserted in tendon ducts, after concrete cure, and tensioned in the prescribed sequence. Each tendon consists of up to 170, 11/4 inch high-strength steel wires with cold-formed button heads on each end bearing on stressing washers. The total tendon load is carried by a shim stack to steel bearing plates embedded in the structure. The basemat is conventionally reinforced. The tendons are ungrouted in grease-filled ducts. This program identifies and manages aging effects of the post-tensioning system of the concrete structure and dome. Examinations/testing are performed on containment tendon anchorage concrete, tendons, tendon wires, tendon anchorage hardware, corrosion protection medium and free water. The Concrete Containment Tendon Prestress program is part of the Containment Inservice Inspection (CISI) program which implements the requirements of 10 CFR 50.55a and the ASME Code Section XI, Subsection IWL.

The program had four enhancements:

Enhancement 1. In the license renewal application, the applicant credited an enhancement to the GALL report program element "scope of program." Specifically, the enhancement stated:

Procedures which list surveillance tendons will be extended to include random samples for the 40, 45, 50, and 55-year surveillances. Tendons for surveillance have been selected in a random manner and are representative of the various types of tendons and conditions of exposure existing in containment. This enhancement only adds lists of additional randomly selected surveillance tendons for the 40, 45, 50 and 55-year surveillances.

These additional surveillance tendons will be selected on the same basis as

32 the surveillance tendons currently listed in the procedures for the intervals through year 35.

Enhancement 2. In the license renewal application, the applicant credited an enhancement to the GALL report program elements Monitoring and Trending, and Acceptance Criteria. Specifically, the enhancement stated:

Procedures will be enhanced to explicitly require a regression analysis for each tendon group after every surveillance; and to invoke and describe regression analysis methods used to construct the lift-off trend lines, including the use of individual tendon data in accordance with NRC Information Notice (IN) 99 10, Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments. There is no difference for the regression analysis between the enhanced method for the period of extended operation and the current method and that the method is consistent with IN 99-10.

Enhancement 3. In the license renewal application, the applicant credited an enhancement to the GALL report program element Monitoring and Trending.

Specifically, the enhancement stated:

Surveillance program predicted force lines for the vertical and hoop tendon groups will be extended to 60 years. Program updated to elements consistent with the GALL report.

Enhancement 4. In the license renewal application, the applicant credited an enhancement to the GALL report program element Corrective Actions. Specifically, the enhancement stated:

Procedure descriptions of acceptance criteria action levels will be revised to conform to the ASME Code, Subsection IWL 3221 descriptions.

Commitment 15 (RCMS 2006-212) specified that prior to the period of extended operation, procedures will be enhanced to include two new provisions regarding inspection of repair/replacement activities. The 2001 edition with 2002 and 2003 addenda of ASME Code Section XI, Subsection IWL, Article IWL-2000, includes two provisions that are not required by the 1998 edition. IWL-2410(d) specifies additional inspections for concrete surface areas affected by a repair/replacement activity, and IWL-2521.2 specifies additional inspections for tendons affected by a repair/replacement activity. In accordance with 10 CFR 50.55a, Wolf Creek will revise their CISI program prior to the next inspection interval to incorporate the ASME Code edition and addenda incorporated into 10 CFR 50.55a at that time. Commitment 15 has been incorporated into the Wolf Creeks Concrete Containment documents and is closed.

Commitment 23 (RCMS 2006-220) specified that prior to the period of extended operation, procedures will be revised to: (1) extend the list of surveillance tendons to include random samples for the year 40, 45, 50, and 55-year surveillances, (2) explicitly require a regression analysis for each tendon group after every surveillance, (3) invoke and describe regression analysis methods used to construct the lift-off trend lines, (4) extend surveillance program predicted force lines for the vertical and hoop tendon groups to 60 years, and (5) conform procedure descriptions of acceptance criteria action levels to the ASME Code, Subsection IWL 3221 descriptions. Since the tendon surveillance is controlled by specification C-158, Technical Specification for Containment Tendon Surveillance, this specification was

33 revised to include the five noted requirements of the Commitment 23. Commitment 23 has been incorporated into the Wolf Creeks Concrete Containment documents and is closed.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

INSPECTION RESULTS No findings were identified.

EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.

On February 6, 2025, the inspectors presented the License Renewal Phase 2 inspection results to Cleve Reasoner, Chief Executive Officer and Chief Nuclear Officer and other members of the licensee staff.

34 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 71003 Corrective Action Documents CR -

00026316, 00027166, 00027208, 00117113, 10013796, 10020283, 10020318, 10020461, 10020637, 10032636, 10037611, 10037613, 71003 Corrective Action Documents Resulting from Inspection CR -

10039080, 10039191, 10039228, 10039237, 10039241, 10039262, 10039283, 10039292, 10039293, 10039294, 10039295, 10039338, 10039409 71003 Drawings C-101 Site Plan 24131 71003 Drawings C-K278 Essential Service Water Buried Pipe Replacement Project Sections 5

71003 Drawings E-0006 Outdoor Elect Duct runs Turbine Building North Area 07 71003 Drawings E-0096 Cable Routing Out-Door 28 71003 Drawings E-0096R Cable Routing Outdoor for Internal Use 28 71003 Drawings E-0099 Cable Sheath Grounding & Termination Data 12 71003 Drawings E-15 Electrical Manholes Part 1 H

71003 Drawings S-0080 Ultimate Heat Sink Plan & Sections 16 71003 Drawings S-81 Ultimate Heat Sink Dam Plan Profile G

71003 Engineering Evaluations Basic Engineering Disposition Augmented Inspections for Normally Dry, Non-Draining Fire Water Piping 01/07/2025 71003 Miscellaneous NE-23-02-1 Vendor Report - Lepson Consulting Enterprises (ICE) /

EXCEL Services Corporation Non-EQ Insulated Cables and Connections Program 12/29/2023 71003 Miscellaneous ET 07-0007 Docket No. 50-482: 90-day response to NRC Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients 05/02/2007 71003 Miscellaneous ET 07-0053 Docket No. 50-482: Response to NRC Request for Additional Information on Response to Generic Letter 2007-01 11/13/2007 71003 Miscellaneous MJ1308605 Lesson Plan - Fire Door Maintenance 07/20/2022 71003 Miscellaneous MK1237640 Lesson Plan - Ventilation Damper Maintenance 07/20/2022 71003 Miscellaneous NEI 14-13 Use of Operating Experience for Age-Related Degradation 2

35 Inspection Procedure Type Designation Description or Title Revision or Date and Aging Management Programs 71003 Miscellaneous NEI 97-06 Steam Generator Program Guidelines 3

71003 Miscellaneous NUREG-1915 Safety Evaluation Report Related to the License Renewal of Wolf Creek Generating Station Docket No. 50-482 71003 Miscellaneous QC1141116 Presentation - Dow Corning 3-6548 Silicone RTV Foam Seals and Elastomer Top Cap 0

71003 Miscellaneous RCMS 2006-202 Commitment 5 (RCMS 2006-202) Notebook 71003 Miscellaneous Vendor Report Walkdown Report for Normally Dry Fire-Water Piping in Scope of License Renewal 71003 Miscellaneous WCAP-18270-NP Ex-Vessel Neutron Dosimetry Program for Wolf Creek Cycles 16-21 0

71003 Miscellaneous WCLR-04-1 Electrical Cable Aging Management Walkdown and Inspection Methodology 3

71003 Miscellaneous WCLR-04-NB Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements B2.1.24 NUREG-1801 Program XI.E1 Aging Management Program and Commitment #12 (RCMS 2006-209) Notebook 1

71003 Miscellaneous WCLR-06-NB Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements B2.1.26 NUREG-1801 Program XI.E3 Aging Management Program and Commitment #14 (RCMS 2006-211) Notebook 1

71003 Miscellaneous WCLR-09-NB Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, B2.1.22 NUREG-1801 Program XI.M38 Aging Management Program 1

71003 Miscellaneous WCLR-11-1 Inaccessible and Insulated Components and Misc. Support Information 2

71003 Miscellaneous WCLR-11-NB External Surfaces Monitoring B2.1.20 NUREG-1801 XI.M36 Aging Management Program Notebook 1

71003 Miscellaneous WCLR-12-NB One-Time Inspection of ASME Code Class 1 Small-Bore Piping B2.1.19 NUREG-1801 Program XI.M35 Aging Management Program and Commitment 10 (RCMS 2006-207) Notebook 1

71003 Miscellaneous WCLR-14-NB Fire Water System B2.1.13 NUREG-1801 XI.M27 Aging Management Program Notebook 1

36 Inspection Procedure Type Designation Description or Title Revision or Date 71003 Miscellaneous WCLR-15-NB Fire Protection B2.1.12 NUREG-1801 XI.M26 Aging Management Program Notebook 1

71003 Miscellaneous WCLR-17-NB Closed Cycle Cooling Water B2.1.10 NUREG-1801 Program XI.M21 Aging Management Program and Commitments No.

3 (RCMS 2006-200) and No. 32 (RCMS 2007-253) Notebook 1

71003 Miscellaneous WCLR-18-NB Open-Cycle Cooling Water System B2.1.9 NUREG-1801 XI.M20 Aging Management Program 1

71003 Miscellaneous WCLR-22-NB 10 CFR 50, Appendix J, B2.1.30 NUREG-1801 Program XI.S4 Aging Management Program 1

71003 Miscellaneous WCLR-23-NB ASME Section XI, Subsection IWF B2.1.29 NUREG-1801 Program XI.S3 1

71003 Miscellaneous WCLR-24-NB ASME Section XI, Subsection IWL B2.1.28 NUREG-1801 Program XI.S2 Aging Management Program and Commitment #15 (RCMS 2006-212) and Commitment #23 (RCMS 2006-220) Notebook 1

71003 Miscellaneous WCLR-25-NB Steam Generator Tube Integrity B2.1.8 NUREG-1801 Program XI.M19 Aging Management Program Notebook 1

71003 Miscellaneous WCLR-26-NB Bolting Integrity B2.1.7 NUREG-1801 Program XI.M18 Aging Management Program Notebook 1

71003 Miscellaneous WCLR-30-NB Reactor Head Closure Studs B2.1.3 NUREG-1801 Program XI.M3 Aging Management Program Notebook 2

71003 Miscellaneous WCLR-31-NB Water Chemistry B2.1.2 NUREG-1801 Program XI.M2 Aging Management Program Notebook 1

71003 Miscellaneous WCLR-32-NB ASME Section XI Inservice Inspection, Subsection IWB, IWC and IWD, B2.1.1 NUREG-1801 Program XI.M1 1

71003 Miscellaneous WCLR-37-NB Reactor Vessel Surveillance B2.1.15 NUREG-1801 Program XI.M31 Aging Management Program and Commitment No.

27 (RCMS 2006-224) Notebook 1

71003 Miscellaneous WCLR-51-NB Wolf Creek RVI Inspection Plan NUREG 1801 XI.M16A Program Aging Management Program 1

71003 Miscellaneous WCLR-52 Gap Analysis Between Wolf Creek Aging Management Programs, NUREG-1801 Rev. 2 and License Renewal Interim Staff Guidance Documents 5

71003 Miscellaneous WCRE-30 Inservice Inspection Program Plan 7

37 Inspection Procedure Type Designation Description or Title Revision or Date 71003 Procedures AI 07-007 Onsite Groundwater Protection Program Monitoring 18 71003 Procedures AI 23-012 External Surfaces Monitoring of Mechanical Components Program 1

71003 Procedures AI 23I-008 Implementation of the Inspection of Internal Surfaces AMP 1

71003 Procedures AI 23M-007 Structures Monitoring Program 10 71003 Procedures AI 23M-007 Structures Monitoring Program 11 71003 Procedures AP 02-002 Chemistry Surveillance Program 47 71003 Procedures AP 02-003 Chemistry Specification Manual 49 71003 Procedures AP 02A-001 Primary Chemistry Control 24 71003 Procedures AP 02B-001 Secondary Chemistry Control 21 71003 Procedures AP 05G-001 Equipment Qualification 4

71003 Procedures AP 05G-004 Equipment Qualification Summary Document 6

71003 Procedures AP 23-006 Strategic Engineering Program 29 71003 Procedures AP 23R-001 Cable Aging Management Program 1

71003 Procedures AP 24E-003 Warehouse Material Storage, Handling, Packaging, Shipping and Maintenance 13C 71003 Procedures AP 24E-007 Stored Item Maintenance, Shelf Life, Storage Level &

Storage Packaging 6A 71003 Procedures AP 29-005 Examination of Safety-Related Concrete Water Control Structures 3

71003 Procedures AP 29A-002 Inservice Inspection Program 15 71003 Procedures AP 29A-003 Steam Generator Management 20 71003 Procedures AP 29A-004 ASME Section XI System Pressure Testing 12A 71003 Procedures AP 29D-001 UHS Monitoring Program 4

71003 Procedures FHP 02-009A Reactor Vessel Stud Removal 11 71003 Procedures FHP 02-009B Reactor Vessel Stud Installation 12A 71003 Procedures FHP 02-009C Reactor Vessel Stud and Nut Cleaning 5

71003 Procedures I-ENG-004 Lubricating Oil Analysis 10 71003 Procedures KMS-4 Mechanical Standard for Bolting 5

71003 Procedures MGM MOOP-05 Routine Crane and Hoist Inspection - Mechanical 19 71003 Procedures MGM MOOP-08 Torquing Guidelines for Bolted Connections 19 71003 Procedures MPE CI-001 Cable Qualification Inspection 4

38 Inspection Procedure Type Designation Description or Title Revision or Date 71003 Procedures MPM M062-01 Cask Handling Crane Mechanical Inspection and Lubrication 15 71003 Procedures MPM M067-01 Spent Fuel Pool Crane Lubrication and Mechanical Inspection 17C 71003 Procedures QCP-20-518 Visual Examination of Heat Exchangers and Piping Components 8

71003 Procedures QCP-30-101 Qualification And Certification Of Inspection Personnel 11 71003 Procedures STN FP-431 Fire Hose Station Valve Functionality And Hose Replacement 11A 71003 Procedures STN FP-202 Yard Loop & Hydrant Flush & Hydrant Inspection 18 71003 Procedures STN FP-204 Fire Protection System C-Factor Test 31 71003 Procedures STN FP-206 Spray And Sprinkler System Functional Testing - Wet Pipe 17 71003 Procedures STN FP-207 Visual Inspection Of Pipe Headers And Nozzle/Sprinkler Areas 6

71003 Procedures STN FP-225 Fire Barrier Inspection 11 71003 Procedures STN FP-403 Control Room & Trenches Halon System Checkout 10A 71003 Procedures STN FP-450 Fire Damper Inspection and Drop Test 19 71003 Procedures STN FP-452 Fire Barrier Penetration Seals Inspection 7

71003 Procedures STN MT-002 Standby Diesel Fuel Oil Storage Tanks 7B 71003 Procedures STN MT-004 Ultimate Heat Sink Dam Surveillance Vertical Movement 6A 71003 Procedures STN PE-042L ODSCC Susceptible Location Inspection 004 71003 Procedures STS JE-004A Emergency Fuel Oil Storage Tank Water Check/Removal 22 71003 Procedures STS PE-022 Steam Generator Tube Inspection 21 71003 Procedures STS PE-264 LLRT Valve Lineup for the North Electrical Penetration 5

71003 Procedures STS PE-300 Inservice Inspection Examinations 13 71003 Work Orders WO 14-388219, 18-434901, 19-456696, 21-469299, 22-477892-000, 22-477892-006, 22-477897-000, 22-479068, 22-479713, 22-479717, 22-480822, 22-481225-000, 22-483379, 23-484702-000, 23-485019, 23-485022, 23-485030, 23-485452, 23-485508-002, 23-486078-000, 23-487421, 23-

39 Inspection Procedure Type Designation Description or Title Revision or Date 487554-000, 23-487757-000, 23-488242, 23-488698, 12348, 13254, 17081, 17101, 25858, 26303, 29048, 31979, 38335, 38340, 38342, 38538, 47516, 66916, 67102, 42106