IR 05000482/2013004

IR 05000482-13-004; 07/01/2013 - 09/28/2013; Wolf Creek Generating Station, Integrated Resident and Regional Report; Fire Protection

ML13318B072
Person / Time
Site:	Wolf Creek
Issue date:	11/14/2013
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Matthew Sunseri Wolf Creek
References
IR-13-004
Download: ML13318B072 (32)

Text

ber 14, 2013

SUBJECT:

WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000482/2013004

Dear Mr. Sunseri:

On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Wolf Creek Generating Station. On October 8, 2013, the NRC inspectors discussed the results of this inspection with Mr. M. Sunseri, President and Chief Executive Officer, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements. Further, inspectors documented licensee-identified violations which were determined `to be of very low safety significance in this

report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the non-cited violations or significance of the NCVs , you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Wolf Creek Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC Resident Inspector at Wolf Creek Generating Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding,"

of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV1600 EAST LAMAR BLVDARLINGTON, TEXAS 76011-4511 ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ David L. Proulx for

Neil O'Keefe, Chief

Project Branch B

Division of Reactor Projects

Docket Nos.: 50-482 License Nos: NPF-42

Enclosure:

Inspection Report 05000482/2013004 w/ Attachment: Supplemental Information

REGION IV Docket: 05000482 License: NPF 42 Report: 05000482/2013004 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane NE, Burlington, Kansas Dates: July 1 through September 28, 2013 Inspectors: C. Peabody, Senior Resident Inspector C. Hunt, Acting Resident Inspector R. Stroble, Resident Inspector J. Laughlin, Emergency Preparedness Inspector, NSIR

M. Williams, Reactor Inspector Approved By: Neil O'Keefe, Chief, Project Branch B Division of Reactor Projects

- 2 -

SUMMARY OF FINDINGS

IR 05000482/2013004; 07/01 - 09/28/2013; WOLF CREEK GENERATING STATION, Integrated Resident and Regional Report;

Fire Protection.

The report covered a 3-month period of inspection by resident inspectors and a region-based inspector. One Green non-cited violation of very low safety significance was identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process." The cross-cutting aspect is determined using Inspection Manual Chapter 0310, "Components Within the Cross-Cutting Areas." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Proce ss," Revision 4, dated December 2006.

Cornerstone: Initiating Events

Green.

The inspectors identified a non-cited violation of Technical Specification 5.4.1.d, "Fire Protection Program Procedures," for the failure to analyze scaffolding for fire protection impairments and transient combustible loading. The cause of the finding was a procedure change that allowed for a grace period of one working day to complete a fire protection review of newly erected scaffolding. As a result, there was no longer a direct interface with the scaffold builders and fire protection engineers, which complicated scoping and tracking the required inspections. This violation was entered into the corrective action program as Condition Report 71910.

Failure to analyze scaffolding for fire impairment and transient combustible loading is a performance deficiency. The performance deficiency is more than minor because it affects the protection against external factors attribute of the Initiating Events Cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, "Significance Determination for Findings at Power," which required screening using MC 0609, Appendix F, "Fire Protection Significance Determination Process." Using screening question 1.3.1 of this Appendix, the inspectors determined that the finding was of very low safety significance (Green) because the finding did not affect the ability to achieve and maintain safe shutdown. The inspectors determined that this finding had a cross-cutting aspect in the human performance area of work control because the licensee failed to appropriately coordinate work activities by incorporating the need for planned compensatory actions. Specifically, Wolf Creek did not ensure that a fire protection assessment of scaffold 13-S100 and 13-S134 was performed in a timely manner which resulted in compensatory measures for the impaired sprinkler heads and transient combustible material not being established. H.3(a)(Section 1R05.1.b)

B. Licensee-Identified Violations

Violations of very low safety significance or Severity Level IV that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

PLANT STATUS

Wolf Creek began the inspection period at 100 percent power. On September 11, 2013, Wolf Creek performed a technical specification-required shutdown due to a non-functional Class 1E air conditioning unit. Wolf Creek remained offline for the remainder of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

Since thunderstorms with potential tornados and high winds were forecast in the vicinity of the facility for September 19, 2013, the inspectors reviewed the plant personnel's overall preparations and protection for the expected weather conditions. On September 19, 2013, the inspectors walked down the offsite power transformers, diesel generators, and Class 1E distribution systems because their safety-related functions could be affected or required as a result of high winds, tornado-generated missiles, or the loss of offsite power. The inspectors evaluated the plant staff's preparations against the site's procedures and determined that the staff's actions were adequate. During the inspection, the inspectors focused on plant design features and the licensee's procedures to respond to tornados and high winds. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the Updated Safety Analysis Report (USAR) and performance requirements for the systems selected for inspection and verified that operator actions were appropriate as specified by plant-specific procedures. The inspectors also reviewed a sample of corrective action program items to verify that the licensee had identified adverse weather issues at an appropriate threshold and entered them into the corrective action program for resolution.

These activities constitute completion of one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• July 23, 2013, high pressure coolant injection system train B

• August 9, 2013, train A 120Vac Class 1E instrument power distribution

• August 14, 2013, train B 125Vdc Class 1E power distribution The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected, while considering out of service time, inoperable or degraded conditions, recent system outages, and maintenance, modification, and testing. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, USAR, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could

have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three partial system walkdown samples as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• July 2, 2013, essential service water pipe chase, southeast stairway to auxiliary building, and duct chase, fire areas C-1, C-2, and C-3.

• July 24, 2013, train A emergency diesel generator room, fire area D-1

• July 24 2013 , train B emergency diesel generator room, fire area D-2

• September 24, 2013, fire zone 16C, battery and switchgear room (2016' floor)

The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition and verified that adequate compensatory measures were put in place by the licensee for out of service, degraded, or inoperable fire protection equipment systems or features. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four quarterly fire-protection inspection samples, as defined in Inspection Procedure 71111.05-05.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation (NCV) of Technical Specification 5.4.1.d, "Fire Protection Program Procedures," for the failure to analyze erected scaffolding for fire protection equipment impairments and transient combustible loading.

Description.

On July 24, 2013, the inspectors performed a fire protection quarterly inspection in both the east and west diesel generator rooms using the Wolf Creek Fire Hazard Analysis procedure E-1F9905, Rev 4. According to the Fire Hazard Analysis, both of the diesel generator rooms were equipped with an automatic pre-action sprinkler system. Wolf Creek procedure AP-10-106, "Fire Preplans", Attachment B, also indicated that the sprinkler system provides suppression coverage for the entire diesel generator room in which it is located. While performing the inspection, the inspectors identified two scaffolds, scaffold 13-S134 in the west diesel generator room and 13-S100 in the east diesel generator room, that were directly beneath two sprinkler heads toward the north end of each respective room. The inspectors observed that no fire impairment permits were completed for the two scaffolds in question and then conferred with the work control senior reactor operator (SRO) to determine the applicable guidance for scaffolding built in the vicinity of fire protection systems. The work control SRO directed the inspector to AP-14A-003, "Scaffold Construction and Use". Section 6.4.33.5 of AP-14A-003 specifies that, scaffolding located in a fire protection sprinkler protected area is required to have a fire protection review if the scaffold deck length or width is 48 inches or greater, or the scaffold deck is within 36 inches of a fire protection sprinkler head. This review is required to determine the impact on the fire protection system itself as well as any administrative fire protection controls that may also be affected. The inspectors noted that the fire protection impact review tag described in attachment D of AP-14A-003 was attached to each scaffold and both tags indicated that a fire protection review was required based on a "Yes" response to question five, "Scaffold >48" wide and constructed in a sprinkler area, or within 36" of a sprinkler head". In addition to question five indicating the need for a fire protection review, the fire protection impact review tag for scaffold 13-S134 also required a fire protection review based on a "Yes" response for question four, "In safety-related areas, do cumulative scaffold combustibles within a 20 feet horizontal radius exceed 200 pounds?". Both fire protection impact review tags indicated that fire protection was notified based on a "Yes" response to question seven, "Fire protection notified?". Although the "constructor or evaluator" signature block was signed on both tags and dated May 10, 2013, and July 18, 2013, for 13-S100 and 13-S134, respectively, the inspectors noted that the signature block for the fire protection review on both tags was blank. The inspectors immediately discussed these observations with the work control SRO and a fire protection representative. When the inspectors informed the fire protection representative of the dates on the tags and the absence of a fire protection signature, the fire protection representative immediately proceeded to both scaffolds to perform the required assessment. Upon completing his review, the fire protection representative concluded that one hour compensatory fire watches were required in accordance with AP-10-103, "Fire Protection Impairment Control", Appendix D, Section D.1.3, for both scaffolds.

Additionally, scaffold 13-S134 required a one hour compensatory watch for cumulative combustible material exceeding 200 pounds in accordance with AP-10-102, "Control of Combustible Material", Section 6.2.2.2 and 6.4.2.1. Condition Report 71910 was written in response to this issue. The inspectors discussed the apparent cause evaluation associated with Condition Report 71910 with the evaluators. The licensee indicated that the cause of the event was due to an administrative procedure change in 2008 which allowed for a grace period of one working day to conduct a fire protection review. Specifically, this no longer required a direct interface with the scaffold builders which complicated scoping and tracking the required inspections. The procedure was corrected to require the fire protection inspection immediately upon erection of scaffolding as corrective action.

Analysis.

Failure to analyze scaffolding for fire impairment and transient combustible loading is a performance deficiency. The performance deficiency is more than minor because it affects the protection against external factors attribute of the Initiating Events Cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, "Significance Determination for Findings at Power", which required screening using MC 0609, Appendix F, "Fire Protection Significance Determination Process." Using screening question 1.3.1 of this Appendix, the inspectors determined that the finding was of very low safety significance (Green) because the finding did not impact the ability to achieve and maintain safe shutdown. The inspectors determined that this finding had a cross-cutting aspect in the human performance area of work control because the licensee failed to appropriately coordinate work activities by incorporating the need for planned compensatory actions. Specifically, Wolf Creek did not ensure that a fire protection assessment of scaffold 13-S100 and 13-S134 was performed in a timely manner which resulted in compensatory measures for the impaired sprinkler heads and transient combustible material not being established H.3(a).

Enforcement.

Wolf Creek Technical Specification 5.4.1.d requires that written procedures be established, implemented, and maintained covering fire protection program implementation. These procedures include AP-10-102, "Control of Combustible Material", AP-10-103, "Fire Protection Impairment Control", and AP-14A-003, "Scaffold Construction and Use". Procedure AP-14A-003, "Scaffold Construction and Use," Revision 20, required that scaffolding located in a fire protection sprinkler protected area having a scaffold deck length or width greater than 48", or having a scaffold deck within 36" of a fire protection sprinkler head, be reviewed by fire protection to assess its impact on fire protection systems and/or fire protection administrative control. Contrary to the above, from May 10, 2013, to July 24, 2013, not parallel scaffold 13-S100 in the east diesel generator room and from July 18, 2013, to July 24, 2013, scaffold 13-S134 in the west diesel generator room, did not receive a fire protection assessment. Procedure AP-10-103, "Fire Protection Impairment Control," Revision 27, required that any spray and/or sprinkler system that is non-functional, other than in the reactor containment, not in an area containing redundant equipment, shall have an established hourly fire watch to patrol the affected area. Contrary to the above, from May 10, 2013, to July 24, 2013, scaffold 13-S100 in the east diesel generator room, and from July 18, 2013, to July 24, 2013, not parallel scaffold 13-S134 in the west diesel generator room, did not receive hourly fire watches. Procedure AP-10-102, "Control of Combustible Material," Revision 17, required a transient combustible materials permit for transient combustible scaffold materials if the scaffold is constructed in a safety-related area, and the cumulative amount of combustible scaffold material within a 20 foot horizontal radius of the scaffold location

exceeds two hundred pounds. Contrary to the above, from July 18, 2013, to July 24, 2013, not parallel scaffold 13-S134 in the safety-relate west diesel generator room was within 20 feet of more than 200 cumulative pounds of combustible scaffolding material, but did not have an associated transient combustible material permit completed and hourly compensatory watches were not established for the affected area. This violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensee's corrective action program as Condition Report 71910. (NCV 05000482/2013004-01, "Failure to Analyze Erected Scaffolding for Fire Impairment and Transient Combustible Loading.")

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed the USAR, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems; inspected

underground bunkers/manholes to verify the adequacy of sump pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also inspected the areas listed below to verify the adequacy of equipment seals located below the flood line, floor and wall penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, and control circuits, and temporary or removable flood barriers. Specific documents reviewed during this inspection are listed in the attachment.

• August 1, 2013, essential service water cable vault 5A (bunker/manhole)

• August 5, 2013, essential service water cable vault 1B (bunker/manhole)

• September 25, 2013, turbine building condensate pit, and pathways from the overflow of the pit during a postulated circulating water system pipe rupture to outside building and protection of overflow into safety-related spaces (flood protection walkdown)

• September 25, 2013, control room alarm panels for hi level alarms in condensate pit, and operator procedures for compensatory actions for securing circulating water pumps during postulated internal flooding from circulating water system pipe rupture (flood protection walkdown)

These activities constitute completion of two flood protection measures inspection sample and two bunker/manhole samples, as defined in Inspection

Procedure 71111.06-05

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Quarterly Review of Licensed Operator Requalification Program

a. Inspection Scope

On September 11, 2013, the inspectors observed a crew of licensed operators in the plant's simulator during requalification testing. The inspectors assessed the following areas:

• Licensed operator performance

• The ability of the licensee to administer the evaluations

• The modeling and performance of the control room simulator

• The quality of post-scenario critiques

• Follow-up actions taken by the licensee for identified discrepancies These activities constitute completion of one quarterly licensed operator requalification program samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Quarterly Observation of Licensed Operator Performance

a. Inspection Scope

On August 7, 2013, the inspectors observed the performance of on-shift licensed operators in the plant's main control room. At the time of the observations, the plant was in a period of heightened activity due to restoring non-safety electrical power following a lightning strike. This activity also occurred during essential service water and emergency diesel generator planned maintenance outages. The inspectors observed the operators' performance of the following activities:

• Shift Turnover and Reactivity Briefs

• 13kV and 4kV Non-Class 1E Power Distribution Switching

• Essential Service Water Pump Testing

• Emergency Diesel Generator Testing

• Chemical and Volume Control System routine boron dilutions to maintain power In addition, the inspectors assessed the operators' adherence to plant procedures, including AP 21-001, Conduct of Operations, and other operations department policies.

These activities constitute completion of one quarterly licensed-operator performance samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• July 29, 2013 - August 5, 2013, weekly risk assessment

• August 26, 2013, emergent work - voids found in train A component cooling water system following pump maintenance

• September 5, 2013, emergent work - tu rbine driven auxiliary feedwater pump positioner fault during trip throttle valve testing

• September 11, 2013, emergent work - Class 1E air conditioning unit failure The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four maintenance risk assessments and emergent work control inspection samples, as defined in Inspection

Procedure 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed the following assessments:

• August 5, 2013, reactor coolant system loop 2 delta temperature indication oscillations

• August 15, 2013, nonsafety diaphragms installed in reactor coolant drain tank gaseous effluent containment isolation valves

• August 22, 2013, containment temperature indications instrument uncertainty

• September 7, 2013, restoration of turbine-driven auxiliary feedwater pump following configuration change package to jumper out of governor valve motor thermal overload signal

• September 11, 2013, power block buildings seismic qualification The inspectors selected these operability and functionality assessments based on the risk significance of the associated components and systems along with other factors, such as engineering analysis and judgment, operating experience, and performance history. The inspectors evaluated the technical adequacy of the evaluations to ensure technical specification operability was properly justified and to verify the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and USAR to the licensee's evaluations to

determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five operability evaluations inspection samples, as defined in Inspection Procedure 71111.15-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• August 22, 2013, component cooling water pump A casing ultrasonic tests

• August 23, 2013, steam generator B pressure transmitter replacement

• August 29, 2013, steam generator feedwater bypass flow control valve I/P converter replacements

The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

• The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed

• Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate The inspectors evaluated the activities against the technical specifications, the USAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in

the attachment.

These activities constitute completion of three post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

During the unplanned outage that started on September 11, 2013, the inspectors observed portions of the shutdown and cooldown processes and monitored licensee controls over the outage activities listed below.

• Configuration management, including maintenance of defense in depth, is commensurate with the outage safety plan for key safety functions and compliance with the applicable technical specifications when taking equipment out of service.

• Clearance activities, including confirmation that tags were properly hung and equipment appropriately configured to safely support the work or testing.

• Reactor water inventory controls, including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss.

• Controls over activities that could affect reactivity.

• Startup and ascension to full power operation, tracking of startup prerequisites, walkdown of the drywell (primary containment) to verify that debris had not been left which could block emergency core cooling system suction strainers, and reactor physics testing.

• Licensee identification and resolution of problems related to forced outage activities.

These activities constitute completion of one other outage inspection samples, as defined in Inspection Procedure 71111.20-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors selected risk-significant surveillance activities based on risk information and reviewed the USAR, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions.

The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Reference setting data

• Annunciators and alarms setpoints The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

• July 15, 2013, containment purge valve leakage test for valves (HZ 8,9,11,12, and HZ 4,5,6,7)

• August 15, 2013, control and shutdown rod operability verification Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of two surveillance testing inspection samples, as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

===Cornerstone: Emergency Preparedness

=

a. Inspection Scope

The NSIR headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures and the Emergency Plan located under ADAMS accession number ML13156A380 as listed in the Attachment.

The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment.

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.04-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of routine licensee emergency drills on July 8, 2013, July 10, 2013, and August 20, 2013, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Control Room Simulator, Technical Support Center, and Emergency Operations Facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the attachment.

These activities constitute completion of three emergency preparedness drill observation samples, as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the licensee for the second quarter 2013 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator Program."

This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index - Emergency ac Power System (MS06)

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance index - emergency ac power system performance indicator for the period from the third quarter 2012 through the second quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, mitigating systems performanc e index derivation reports, issue reports, event reports, and NRC integrated inspection reports for the period of July 2012 through

June 2013, to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

These activities constitute completion of one mitigating systems performance index -

emergency ac power system sample, as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index - High Pressure Injection Systems (MS07)

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance index - high pressure injection systems performance indicator for the period from the third quarter 2012 through the second quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, issue reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period of July 2012 through June 2013, to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection and, if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

These activities constitute completion of one mitigating systems performance index - high pressure injection system sample, as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.4 Mitigating Systems Performance Index - Cooling Water Systems (MS10)

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance index - cooling water systems performance indicator for the period from the third quarter 2012 through the second quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, issue reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period of July 2012 through June 2013 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

These activities constitute completion of one mitigating systems performance index -

cooling water system sample, as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. The inspectors accomplished this through review of the station's daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 In-depth Review of Operator Workarounds

a. Inspection Scope

Wolf Creek had two operator work-arounds affecting emergency operation of safety-related equipment and four operator burdens which detail work-around delays in normal day-to-day operations. The inspectors audited the operator work-arounds and operator burdens to verify that that no current plant equipment issues were impacting emergency operation of safety related equipment, that the licensee's quantification of the aggregate operator burden was accurate and that the total aggregate burden is not impacting safe operations of the facility. Furthermore, the inspectors performed a more detailed review of the operator work arounds and verified that the licensee has developed a plan to correct the deficiencies causing the operator work-arounds so that normal operation can be restored.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

.1 (Closed) Licensee Event Report 05000482/2011-002-00 and -01

Noncompliance with TS 3.8.1, "AC Sources - Operating" On February 22, 2011, operators declared the "A" diesel generator inoperable due to a control pin on the fuel rack not being installed correctly. The licensee returned the equipment back to service after replacing the control pin, washer, and cotter pin correctly. The inspectors dispositioned this violation of technical specifications as a licensee-identified violation in Section

4OA7 of NRC Integrated Inspection Report

05000482/2012005. No additional deficiencies were identified during the review of these Licensee Event Reports supplemental revisions.

This Licensee Event Report is closed.

.2 (Closed) Licensee Event Report 05000482/2013-004-00: Technical Specification Limiting Condition for Operation 3.0.3 Requiring Plant Shutdown

During Refueling Outage 19, the licensee was replacing the air conditioning unit SGK05A Class 1E electrical equipment air conditioning compressor. When the first mounting screw was being torqued to the 50 inch-pounds as required by the maintenance work instructions, it snapped off. The licensee determined that this torque value was too high. An extent of condition review revealed that over-torquing of fasteners on SGK04B and SGK05B had also occurred during their respective maintenance activities performed on August 12, 2011, and May 30, 2012. This is a violation of the following technical specifications because two trains of Class 1E electrical equipment for air conditioning were not functional in Modes one through four at the same time:

• Technical Specification 3.8.4, "DC Sources - Operating"

• Technical Specification 3.8.7, "Inverters - Operating"

• Technical Specification 3.8.9, "Distribution Systems - Operating"

• Technical Specification 3.7.11, "Control Room Air Conditioning System"

• Limiting Condition for Operation 3.0.3, The licensee determined that over torqued mounting screws could render the equipment inoperable, and unable to function during a seismic event.

Corrective actions included properly replacing mounting screws, and revising Procedure AI 16C-007, "Work Order Planning," to require a copy of the reference source document for any work instruction that includes torquing data for an installed safety

system or component.

Since the mounting screws on Train B had not failed and are only required to prevent failure in a seismic event, of which probability is low, safety significance of this condition is low. Additionally, the room temperatures, which are controlled by operating air conditioning equipment, remained below area limits for qualification of electrical equipment.

The licensee determined the event was reportable in accordance with 10 CFR 50.73, requiring reporting for plant shutdown required by technical specifications. The inspectors reviewed the Licensee Event Report and the corrective actions taken by plant personnel. The inspectors dispositioned this issue as a licensee-identified violation in Section 4OA7. No additional findings were identified during this review.

This Licensee Event Report is closed.

4OA6 Meetings, Including Exit Exit Meeting Summary

On October 8, 2013, the resident inspectors presented the inspection results to Mr. M. Sunseri, President and Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations The following violations of very low safety signi

ficance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as non-cited violations.

.1 Technical Specification (TS) 3.8.4, "DC Sources - Operating," requires two operable trains of DC sources while in Modes 1 through 4.

TS 3.8.7, "Inverters - Operating,"

requires two operable trains of inverters while in Modes 1 through 4. Technical Specification 3.8.9, "Distribution Systems

- Operating," requires the Train A and Train B subsystems of the DC and AC vital bus systems be operable in Modes 1 through 4. Technical Specifications 3.7.11, "Control Room Air Conditioning System," requires two trains of Control Room Air Conditioning be operable in Modes 1 through 6. Technical Specification Limiting Condition for Operation (LCO) 3.0.3 requires, in part, that when an LCO is not met and the associated actions are not met or an action is not provided, the unit shall be placed in a Mode in which the LCO is not applicable, or take action within one hour to place the plant in Mode 3 within the next 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, Mode 4 within the next 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and Mode 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Contrary to the above, two trains of Class 1E electrical equipment air conditioning were not functional in Modes 1 through 4, but the licensee did not take action within one hour to place the plant in Mode 3 within the next 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, Mode 4 within the next 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and Mode 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. Specifically , the licensee over-torqued mounting screws on air conditioning units SGK04B and SGK05B during their respective maintenance activities performed on August 12, 2011, and May 30, 2012, rendering these air conditioning units and their supported systems inoperable. The licensee failed to restore air conditioning units SGK04B and SGK05B to operable status until March 22 and March 23, 2013; and thus exceeded the allowed action times of the respective Technical Specifications. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the inspectors performed a significance determination screening and determined that a more detailed risk evaluation was required because the finding potentially represented an actual loss of safety function for a single train for greater than the technical specification allowed outage time. The Senior Reactor Analyst determined that since the mounting screws did not actually fail, and their function is to prevent failure during a seismic event, and because of the low probability of a seismic event leading to core

damage or early release, this violation is of very low safety significance (Green). This violation was entered into the licensee's corrective action program as Condition

Report 65421.

.2 Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," states, in part, that activities affecting quality

shall be prescribed by procedures appropriate to the circumstances. Contrary to the above, a procedure for an activity affecting quality was not appropriate to the circumstances. Specifically, as of May 6, 2013, Procedure MPE GK-004 "GK Unit Preparation for Work," Revision 4, was inadequate to prevent over-tightening of the wing screws on the filter dryer assembly, in that the procedure did not specify how tight to leave the wing screws. This led to failure of the filter drier, pieces of which blocked the thermostatic expansion valves and overheated the Class 1E electrical equipment air conditioning chiller. Using Inspection Manual Chapter 609, Appendix A, Exhibit 2, Mitigating Systems Cornerstone screening questions, Section A, the finding was determined to be of very low safety significance (Green) because only one train of Class 1E electrical equipment was affected and room temperatures remained below maximum limits. This violation was entered into the licensee's corrective action program as Condition Report 68818.

A-1 Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Baban, Manager Systems Engineering

P. Bedgood, Manager, Radiation Protection

M. Brinkmeyer, Fire Protection Technician

J. Broschak, Engineering VP

A. Camp, Plant Manager

R. Clemens, Strategic Projects VP

D. Erbe, Manager Security

S. Henry, Manager Operations

R. Hobby, Licensing Engineer

M. McMullen, Design Engineer

W. Muilenburg, Supervisor Licensing

L. Ratzlaff, Manager Maintenance

T. Slenker, Operations CAPCO

R. Smith, Site Vice President

M. Sunseri, President and CEO

M. Westman, Manager Regulatory Affairs

S. Wideman, Licensing Engineer

J. Yunk, Manager Corrective Actions

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000482/2013004-

NCV "Failure to Analyze Erected Scaffolding for Fire Impairment and Transient Combustible Loading." (Section 1R05.1)

Closed

05000482/2011-

2-00 and -01

LER Noncompliance with TS 3.8.1, "AC Sources - Operating" (Section 4OA3.1)

05000482/2013-

004-00 LER Technical Specification Limiting Condition for Operation 3.0.3 Requiring Plant Shutdown (Section 4OA3.2)