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| {{Adams | | {{Adams |
| | number = ML060750294 | | | number = ML060120484 |
| | issue date = 12/29/2005 | | | issue date = 01/12/2006 |
| | title = Draft Copy of Inspection Report 05000482-05-004 | | | title = NRC IR 05000482-2005-004 Errata Letter for Inspection Conducted on June 27 - July 1, 2005 |
| | author name = | | | author name = Shannon M |
| | author affiliation = - No Known Affiliation | | | author affiliation = NRC/RGN-IV/DRS/PSB |
| | addressee name = | | | addressee name = Muench R |
| | addressee affiliation = NRC/NRR | | | addressee affiliation = Wolf Creek Nuclear Operating Corp |
| | docket = 05000482 | | | docket = 05000482 |
| | license number = NPF-042 | | | license number = NPF-042 |
| | contact person = | | | contact person = |
| | case reference number = FOIA/PA-2006-0095
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| | document report number = IR-05-004 | | | document report number = IR-05-004 |
| | document type = Inspection Report | | | document type = Inspection Report, Letter |
| | page count = 7 | | | page count = 6 |
| }} | | }} |
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| {{#Wiki_filter:-i9 I v b SUMMARY OF FINDINGS IR 500482/2005004; 10/24/05 -12/29/05; Wolf Creek Nuclear Operating Corporation; Wolf Creek Generating Station; Fire Protection (Triennial) | | {{#Wiki_filter:January 12, 2006Rick A. Muench, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation |
| The NRC conducted an inspection with a team of four regional inspectors and one contractor.
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| The inspection identified two apparent violations (AV), two Green noncited violations (NCV) and two unresolved items (URI). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609 "Significance Determination Process" (SDP).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 described its program for overseeing the safe operation of commercial nuclear power reactors in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A. NRC-Identified and Self Revealing Findings Cornerstone:
| | P.O. Box 411 Burlington, KS 66839 Wolf Creek Nuclear Operating CorporationSUBJECT:NRC INSPECTION REPORT 05000482/2005004 |
| Mitigating Systems* Green. The team identified a noncited violation (NCV) for failure to comply with Technical Specification (TS) 5.4, "Procedures", in that a procedure required for post-fire safe shutdown was found to be inadequat Procedure OFN RP-014, "Hot Standby to Cold Shutdown from Outside the Control Room", was inadequate because it did not provide a method to provide sufficiently borated water to the reactor coolant system so that cold shutdown could be achieved and maintained within 72 hours after a control room fire. Procedure OFN RP-014 requires monitoring of the boron concentration in the reactor and, if necessary, starting the acid transfer pumps to draw borated Water from the boric acid tanks. However, this procedure did not include sufficient instructions for refilling and borating the Refueling Water Storage Tank for a potential loss of offsite power or fire inducted damage to circuits related to the pumps.This finding is greater than minor because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to external events (such as fire) to prevent undesirable consequences (i.e., core damage). The inspectors evaluated the finding using MC 0609, Appendix F, and determined that it screens as very low safety significance (Green) because it is related to the ability to achieve and maintain cold shutdown. (Section 1 R05.1.b.(1))
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| * TBD. The team identified an Apparent Violation (AV) of Wolf Creek License Condition 2.C. (5) (a) concerning an inadequate alternate shutdown analysi The licensee's alternate shutdown analysis was inadequate in that it used acceptance criteria which were inconsistent with and less conservative than those required by the approved Fire Protection Program. The licensee developed Calculation Number AN-02-021, Revision 0, "OFN RP-017 "Control Room Evacuation" Consequence Evaluation", to demonstrate alternative shutdown capability for W01olf Creek in response to NRC identified noncited violation 200208-01, Inadequate alternative shutdown procedur The licensee used no fuel damage as an acceptance criteri The calculation predicted that during an alternative shutdown, the reactor coolant system subcooling margin would not maintained, significant voiding would occur in the core, and a steam void would form in Intorinatio:n in this record was; deleted Enclosure in accordance with the Freedom of Information At, exemptions
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| ' G EOIA- `'--0 2S-2-the reactor vessel head. The licensee found the results of the calculation to be acceptable since it demonstrated that the void formation would be limited, natural circulation in the reactor coolant system would be maintained, sufficient decay heat removal would be maintained, and no fuel damage would occur. This is not consistent with the license condition to meet the technical requirements of 10 CFR Part 50, Appendix R. Section II.L of 10 CFR Part 50 Appendix R, "Alternative and dedicated shutdown capability", states in part, "During the postfire shutdown, the reactor process variables shall be maintained within those predicted for a loss of normal a.c. power".This finding is greater than minor because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to external events (such as fire) to prevent undesirable consequences (i.e., core damage). The licensee considers the spurious operation of multiple components to be outside of the plant licensing basis for the Fire Protection Program. Specifically, in this case, both pressurizer power-operated relief valves are assumed to spuriously open due to fire induced circuit damage. It is the NRC's understanding that the licensee does not consider these circuit vulnerabilities to be violations of NRC requirement The NRC staff and the industry are currently working on developing a resolution methodology to address these types of potential fire-inducted circuit failure The team concluded that this violation meets the criteria of the NRC Enforcement Manual Section 8.1.7.1 for deferring enforcement actions for postulated fire induced circuit failures. (Section 1 R05.1 .b.(2))Green. The team identified a noncited violation of License Condition 2.C.(5), Fire Protection (Section 9.5.1, SER, Section 9.5.1.8, SSER #5), for failure to ensure that redundant trains of safe shutdown systems in the same fire area were free of fire damage. The licensee credited manual actions to mitigate the effects of fire damage in lieu of providing the physical protection required by 10 CFR Part 50, Appendix R, Section III.G.2.SNUPPS FSAR Appendix 9.5E provided the design comparison between the plant's fire protection program and 10 CFR 50, Appendix R. The comparison to Section III.G, Fire Protection of Safe Shutdown Capability, states, "Redundant trains of systems required to achieve and maintain hot standby are separated by 3-hour-rated fire barriers, or the equivalent provided by III.G.2, or else a diverse means of providing the safe shutdown capabilitv exists that is unaffected by the fire." Wolf Creek has interpreted "diverse means" to mean by any reasonable means including local valve and breaker operations as long as they are within the scope of normal operator duties. The team disagrees with this interpretatio The NRC staff does not recognize the use of manual actions as meeting the technical requirements of Appendix R, Section III.G.2. The components being operated are identified as required for operation of safe shutdown systems or are subject to potential spurious operation impacting the shutdow The local manual actions are being performed due to fire damage to electrical cables related to those components and are meant to compensate for damage or maloperation of safe shutdown equipment caused by fire.Enclosure-3-This finding is greater than minor because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to external events (such as fire) to prevent undesirable consequences (i.e., core damage). The team found that the manual operator actions implemented to mitigate the effects of fire damage were reasonable (as defined in Enclosure 2 of NRC Inspection Procedure 71111 .05T, "Fire Protection (Triennial)"), and could be performed within the analyzed time limits. Therefore, in accordance with Enclosure 2 of NRC Inspection Procedure 71111 .05T, the finding was determined to be of very low safety significance (green), and the significance determination process was not entered.(Section 1 R05.2)TBD. The team identified an Apparent Violation (AV) of Technical Specification 5.4, Procedures, clue to an inadequate alternate shutdown procedure which is required fo implementation of the Fire Protection Program. The team found that some time critical actions required to safely shutdown the plant following a control room fire could not be accomplished within the requied time periods. Specifically, the licensee's procedure meets the recommendations by Westinghouse Owners Group for assuring RCP seal reliability and avoiding component cooling water thermal barrier water hammer concerns based on a time line assuming operators only have to respond to one spurious operation from the fire-induced damage during the scenari The team disagrees which this limitation of potential spurious operations.
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| This finding is greater than minor because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to external events (such as fire) to prevent undesirable consequences (i.e., core damage). The licensee considers the spurious operation of multiple components to be outside of the plant licensing basis for the Fire Protection Program. It is the NRC's understanding that the licensee does not consider these circuit vulnerabilities to be violations of NRC requirement The NRC staff and the industry are currently working on developing a resolution methodology to address these types of potential fire-inducted circuit failure The team concluded that this violation meets the criteria of the NRC Enforcement Manual Section 8.1.7.1 for deferring enforcement actions for postulated fire induced circuit failures. (Section 1 R05.6.b.(2))
| | ==Dear Mr. Muench:== |
| B. Licensee-identified Violations None Enclosure I S-6-.2 Protection of Safe Shutdown Capabilities a. Inspection Scope The team reviewed the licensee's piping and instrumentation diagrams, safe shutdown equipment list, safe shutdown design basis documents, and the post-fire safe shutdown analysis to verify whether the licensee's shutdown methodology had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions for equipment in the fire areas selected for review. The team also reviewed and observed walkdowns of the licensee's procedures for achieving and maintaining safe shutdown in the event of a fire to verify that the safe shutdown analysis provisions were properly implemente The team focused on the following functions that must be ensured to achieve and maintain post-fire safe shutdown conditions:
| | Because of an error in documenting the completed inspection scope for the ALARAinspection conducted June 27 - July 1, 2005, insert the enclosure to this letter as replacements for pages 13 - 15 of NRC Inspection Report 05000482/2005004.Please accept my apology for any inconvenience these actions may have caused. |
| (1) reactivity control capable of achieving and maintaining cold shutdown reactivity conditions, (2) reactor coolant makeup capable of maintaining the reactor coolant level within the level indication in the pressurizer, (3) reactor heat removal capable of achieving and maintaining decay heat removal, (4) supporting systems capable of providing all other services necessary to permit extended operation of equipment necessary to achieving and maintaining hot shutdown conditions, and (5) process monitoring capable of providing direct readings to perform and control the above functions.
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| The team reviewed the separation of safe shutdown cables, equipment, and components within the same fire areas, and reviewed the licensee's methodology for meeting the requirements of 10 CFR 50.48, Appendix A to Branch Technical Position 9.5-1 and 10 CFR Part 50, Appendix R, Section III.G. Specifically, this was to determine whether at least one post-fire safe shutdown success path was free of fire damage in the event of a fire in the selected areas. The evaluation focused on the cabling of selected components for the chemical and volume control system, high pressure safely injection system, and the auxiliary feedwater system. A sample of components was selected whose inadvertent operation could significantly affect the shutdown capability credited in the licensee's safe shutdown analysi The specific components selected are listed in the attachmen In addition, the team reviewed license documentation, such as NRC safety evaluation reports, the Wolf Creek Updated Final Safety Analysis Report, submittals made to the NRC by the licensee in support of the NRC's review of their fire protection program, and deviations from NRC regulations to verify that the licensee met license commitments.
| | Sincerely, |
| | //RA// |
| | Michael P. Shannon, ChiefPlant Support Branch Division of Reactor SafetyDocket: 50-482License: NPF-42Enclosure:Pages 13 - 15 of NRC Inspection Report 05000482/2005004cc w/enclosure: |
| | Vice President Operations/Plant ManagerWolf Creek Nuclear Operating Corp. |
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| b. Findings Introduction:
| | P.O. Box 411 Burlington, KS 66839 Wolf Creek Nuclear Operating Corp.-2-Jay Silberg, Esq.Shaw Pittman, LLP 2300 N Street, NW Washington, DC 20037Supervisor LicensingWolf Creek Nuclear Operating Corp. |
| The team identified a noncited violation of License Condition 2.C.(5), Fire Protection (Section 9.5.1, SER, Section 9.5.1.8, SSER #5), for failure to ensure that redundant trains of safe shutdown systems in the same fire area were free of fire damage. The licensee credited manual actions to mitigate the effects of fire damage in lieu of providing the physical protection required by 10 CFR Part 50, Appendix R, Section III.G.2. The team determined that the violation was of very low safety significance (green).Enclosure-7-Descriptio Wolf Creek License Condition 2.C. (5) (a) states "The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, and as approved in the SER through Supplement 5, subject to provisions b & c below." SER Section 9.5.1.7, Appendix R Statement, states "The staff will condition the operating license to require the applicant to meet the technical requirements fo Appendix R to 10 CFR 50, or provide equivalent protection." Section III.G.2 of 10 CFR 50, Appendix R, describes three acceptable methods for protecting at least one safe shutdown train when redundant trains are located in the same fire area. The Section III.G.2 requirements are based on the combination of physical barriers, spacial separation, fire detection and automatic suppression systems.SNUPPS FSAR Appendix 9.5E provided the design comparison between the plant's fire protection program and 10 CFR 50, Appendix R. The comparison to Section III.G, Fire Protection of Safe Shutdown Capability, states, "Redundant trains of systems required to achieve and maintain hot standby are separated by 3-hour-rated fire barriers, or the equivalent provided by III.G.2, or else a diverse means of providing the safe shutdown capability exists that is unaffected be the fire." Wolf Creek has interpreted "diverse means" to mean by any reasonable means including local valve and breaker operations as long as they are within the scope of normal operator duties. The team disagrees with this interpretatio The NRC staff does not recognize the use of manual actions as meeting the technical requirements of Appendix R. The components being operated are identified as required for operation of safe shutdown systems or are subject to potential spurious operation impacting the shutdow The local manual actions are being performed due to fire damage to electrical cables related to those components and are meant to compensate for damage or maloperation of safe shutdown equipment caused by fire. Manual actions are not a method of satisfying Appendix R, Section III.G.2 requirement Plant specific manual actions may be acceptable based on detailed specific exemptions or deviations for each case identified.
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| Analysi This finding is of greater than minor safety significance because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to external events (such as fire) to prevent undesirable consequence The team reviewed Procedure OFN KC-016, "Fire Response" and stepped through the manual actions directed in the procedure with licensee operations personne The team found that the manual operator actions were reasonable (as defined in Enclosure 2 of Inspection Procedure 71111 .05T), and could be performed within the analyzed time limits. Since the manual operator actions was considered reasonable, the significance determination process was not entered. The team determined that this finding is of very low safety significance (green) in accordance with the guidance in Enclosure 2 to Inspection Procedure 71111 .05T.Enforcemen The licensee's Fire Hazard Analysis states that it will comply with the technical requirements of Appendix R or utilize a diverse means to do so. Appendix R, Section III.G.2 to 10 CFR Part 50 requires that cables whose fire damage could prevent the operation or cause maloperation of safe shutdown functions be physically protected Enclosure-8-from fire damage. Contrary to this requirement, the licensee implemented a methodology that utilized manual operator actions as a diverse means to mitigate the effects of fire damage in lieu of providing physical protection from fire damage. This is a violation of Wolf Creek License Condition 2.C. (5) (a) for failing to meet the technical requirements of 10 CFR 50, Appendix R, as required by SER Section 9.5.1.7. Because this finding is of very low safety significance, this violation is being treated as a noncited violation, consistent with Section VL.A of the NRC Enforcement Policy: NCV 05000482/2005008-03, Failure to Ensure Redundant Safe Shutdown Systems Located In the Same F:ire Area Are Free of Fire Damage..3 Passive Fire Protection a. Inspection Scope For the selected fire areas, the team evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers and fire rated electrical cables. The team observed the material condition and configuration of the installed barriers, seals, doors, and cables. The team compared the as-installed configurations to the approved construction details and supporting fire tests. In addition, the team reviewed license documentation, such as NRC safety evaluation reports, and deviations from NRC regulations and the National Fire Protection Association code to verify that fire protection features met license commitments.
| | P.O. Box 411 Burlington, KS 66839Chief EngineerUtilities Division Kansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027Office of the GovernorState of Kansas Topeka, KS 66612Attorney General120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597County ClerkCoffey County Courthouse 110 South 6th Street Burlington, KS 66839-1798Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310Topeka, KS 66612-1366 Wolf Creek Nuclear Operating Corp.-3-Electronic distribution by RIV:Regional Administrator (BSM1)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (SDC)Resident Inspector (TBR2)SRI, Callaway (MSP)Branch Chief, DRP/B (WBJ)Senior Project Engineer, DRP/B (RAK1)Team Leader, DRP/TSS (RLN1)RITS Coordinator (KEG)Only inspection reports to the following:DRS STA (DAP)J. Dixon-Herrity, OEDO RIV Coordinator (JLD)ROPreports WC Site Secretary (SLA2)SUNSI Review Completed: __Yes____ADAMS: Yes G No Initials: GLG____ Publicly Available G Non-Publicly Available G Sensitive Non-SensitiveS\DRS\DRSLTRS\WC2005004errata.wpdRIV: DRS/PSB/HPIC:PSBGLGuerraMPShannon |
| | /RA//RA/ |
| | 1/ 12 /061/ 12 /06OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax-13-Enclosure*Self-assessments, audits, and special reports related to the ALARA programsince the last inspection*Effectiveness of self-assessment activities with respect to identifying andaddressing repetitive deficiencies or significant individual deficiencies *Radiation worker and radiation protection technician performance during work lactivities in radiation areas, airborne radioactivity areas, or high radiation areas lThe inspector completed 7 of the required 15 samples and 7 of the optional samples. |
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| b. Findinas No findings of significance were identified. | | l b.FindingsNo findings of significance were identified. |
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| .4 Active Fire Protection a. Inspection Scope For the selected fire areas, the team evaluated the adequacy of fire suppression and detection systems. The team observed the material condition and configuration of the installed fire detection and suppression systems. The team reviewed design documents and supporting calculation In addition, the team reviewed license basis documentation, such as NRC safety evaluation reports, and deviations from NRC regulations and the National Fire Prctection Association codes to verify that fire suppression and detection systems met license commitments. | | 4.OTHER ACTIVITIES4OA2Identification and Resolution of ProblemsResident Inspector Annual Sample Review a.Inspection ScopeThe inspectors evaluated the effectiveness of WCNOC's corrective action program asapplied to corrective action document PIR 2005-2142. This document was initiated to address the conditions and events that led to the inoperability of both site fire protectionpumps. Attributes considered during this review included the following: *Completeness, accuracy, and timeliness of problem identification *Operability and reportability evaluation *Extent of condition evaluation |
| | *Apparent cause evaluation |
| | *Prioritization |
| | *Corrective action effectiveness |
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| The team also observed an announced site fire brigade drill and the subsequent drill critique using the guidance in Inspection Procedure 71111.05A Team members observed the fire brigade simulate fire fighting activities in plant Fire Area T-4 (Lube Oil Storage Room). The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were: (1) proper wearing of turnout gear and self-contained breathing apparatus; (2) proper use and layout of fire hoses; (3)employment of appropriate fire fighting techniques; (4) sufficient fire fighting equipment Enclosure c ITEMS OPENED AND CLOSED Opened 05000482/2005008-02 05000482/2005008-04 05000482/2005008-05 05000482/2005008-06 AV Failure to Maintain Reactor Coolant System Subcooling During the Alternate Shutdown (1 R05.1.b(2)) | | The inspectors completed one sample. |
| URI Lack of Evaluations of Changes to The Approved Fire Protection Program (1 R05.6.b(1))
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| AV Inadequate Alternative Shutdown Procedure (1 RC)5.6.b(2))
| | b.FindingsFailure to Follow the Clearance Order ProcedureIntroduction: An apparent violation (AV) of Technical Specification 5.4.1a occurredwhen station personnel failed to follow Procedure AP 21E-001, "Clearance Orders," and manipulated a component inside a fire protection piping clearance boundary without instructions and authorization. The starting of a temporary fire pump resulted in water-14-Enclosurespraying on the controller of the operable diesel-driven fire pump through an open ventvalve, which rendered the pump inoperable.Description: On June 30, 2005, the motor of the electric fire pump experienced a shortin its winding which led to a fire at the motor. The plant took the appropriate compensatory measures and started parallel paths to restore the fire suppression water system within the allotted 14 days. One path involved a temporary modification to thefire protection system that installed a temporary motor-driven fire pump, which was accomplished on July 11, 2005. The temporary fire pump was tested on July 12, 2005, to verify it would provide the required flow of water suppression; however, the pump failed this test. Station fire protection personnel requested a clearance order to isolate the temporaryfire pump from the fire protection piping but failed to make station operations personnel aware of the desire to run the temporary fire pump following repairs. Once repairs to the pump were completed, the vendor under the direction of station fire protectionpersonnel started the pump believing they had authorization to operate the temporaryfire pump. This resulted in water issuing from an open vent valve which sprayed the controller of the diesel-driven fire pump. Station fire protection personnel discovered the wet controller and notified the control room. Control room personnel declared the diesel-driven fire pump inoperable. The diesel-driven fire pump was returned to service in approximately 4 hours. The inspectors reviewed Procedure AP-10-103, Fire Protection Impairment Control, Revision 19, which identified the compensatory measures for the loss of fire suppression water systems. With the motor driven and the diesel driven fire pumpinoperable (approximately 4 hours) the impairment control procedure required that abackup fire pump be provided within 24 hours. In this case, both the motor driven and the diesel driven fire pumps were restored within approximately 18 hours. This issue involved human performance crosscutting aspects associated with station personnel notfollowing a station procedure.Analysis: The failure to follow station procedures is a performance deficiency. Thefinding was determined to be more than minor because it affected the mitigating systems cornerstone objective of ensuring the availability, reliability, and capability ofsystems that respond to initiating events to prevent undesirable consequences. Usingthe Phase 1 worksheets in Manual Chapter 0609, "Significance Determination Process," |
| URI Failure to Adequately Evaluate Fire Protection Program Deficiencies (40A2)Opened and Closed 05000482/2005008-01 05000482/2005008-03 NCV Failure to Provide Adequate Post-Fire Shutdown Procedures (1 R05.1.b(1))
| | the finding was determined to degrade the fire protecti on system suppression and wasevaluated using Appendix F, Fire Protection Significance Determination Process. This finding requires a Phase 3 analysis and is currently under evaluation. Wolf Creek Nuclear Operating Corporation entered this finding into their corrective action program as PIR 2005-2142 Enforcement: Technical Specification 5.4.1a requires procedures be implemented inaccordance with Regulatory Guide 1.33, Revision 2, Appendix A. RegulatoryGuide 1.33, Appendix A, Section 9, requires procedures for the performance of stationmaintenance. Contrary to the above, on July 13, 2005, station personnel operated-15-Enclosurecomponents inside an established fire protection piping clearance boundary withoutwork instructions or control room authorization as required by Station Procedure AP 21E-001, "Clearance Orders," Section 6.6.8. This resulted in an adjacent diesel-driven fire pump becoming inoperable. Pending determination of the final safety significance of this issue, this violation is being treated as an AV consistent with Section VI.A of the NRC Enforcement Policy: AV 05000482/0500404, manipulation ofplant component without proper authorization results in inoperable fire protection pumps.Corrective Action EffectivenessThere were no findings identified that were associated with the corrective actions for thisevent. However, the inspectors made the following observations from their review of the apparent cause evaluation and the associated corrective actions: The apparent cause evaluation states that some fire protection personnel are unfamiliar with the clearanceorder program because, for them, clearance orders are infrequently performed evolutions. Additionally, the evaluation states that some "groups" mistakenly believed itwas acceptable to work on vendor equipment inside clearance order boundaries without proper authorization or an approved procedure. These evaluation results suggest a clearance order program knowledge deficiency within the fire protection group. Yet, the corrective action for these contributing causes was counseling only the one individual involved with this event. .2Cross-References to Problem Identification & Resolution Findings DocumentedElsewhereSection 1R15 documents a condition where station personnel did not properly evaluatea condition adverse to quality regarding debris in the auxiliary feedwater flowtransmitters..3Access Control to Radiologically Significant Areas and ALARA InspectionsSection 2OS1 evaluated the effectiveness of WCNOC's problem identification andresolution processes regarding access controls to radiologically significant areas and radiation worker practices. The inspectors reviewed corrective action documents for root cause/apparent cause analysis against WCNOC's PI&R process. No findings of significance were identified.Section 2OS2 evaluated the effectiveness of WCNOC's PI&R processes regardingexposure tracking, higher than planned exposure levels, and radiation worker practices. |
| NCV Failure to Ensure Redundant Safe Shutdown Systems Located In the Same Fire Area Are Free of Fire Damage (1 R05.2)Closed None Discussed None A-2 Attachment
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| | The inspector reviewed the corrective action documents listed in the attachment against WCNOC's PI&R program requirements. No findings of significance were identified. |
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Category:Inspection Report
MONTHYEARIR 05000482/20230042024-01-11011 January 2024
Integrated Inspection Report 05000482/2023004
IR 05000482/20233012023-12-19019 December 2023
NRC Examination Report 05000482/2023301
IR 05000482/20230052023-08-23023 August 2023
Updated Inspection Plan for Wolf Creek Nuclear Operating Corporation, Unit 1 (Report 05000482/2023005) - Mid-Cycle Letter 2023
IR 05000482/20234202023-07-12012 July 2023
Security Baseline Inspection Report 05000482/2023420 - Cover Letter
IR 05000482/20230022023-07-11011 July 2023
Integrated Inspection Report 05000482/2023002
IR 05000482/20234012023-06-21021 June 2023
Security Baseline Inspection Report 05000482/2023401
ML23111A0662023-04-20020 April 2023
(Cover Letter Only) Wolf Creek Generating Station Special Inspection Reactive Report 05000482-20220502
IR 05000482/20230012023-04-19019 April 2023
Integrated Inspection Report 05000482/2023001
IR 05000482/20220062023-03-0101 March 2023
Annual Assessment Letter for Wolf Creek Generating Station (Report 05000482/2022006)
IR 05000482/20234022023-02-0606 February 2023
Security Baseline Inspection Report 050004822023402
ML23017A2092023-01-18018 January 2023
Emergency Preparedness Biennial Exercise Inspection URI Closure Report
IR 05000482/20220042023-01-17017 January 2023
Integrated Inspection Report 05000482/2022004
ML22333A7132022-12-0202 December 2022
License Renewal Phase 1 Report
IR 05000482/20220032022-10-25025 October 2022
Integrated Inspection Report 05000482/2022003
IR 05000482/20224032022-08-31031 August 2022
NRC Security Baseline Inspection Report 05000482/2022403
IR 05000482/20220052022-08-23023 August 2022
Updated Inspection Plan for Wolf Creek Generating Station (Report 05000482/2022005)
IR 07200079/20224042022-08-0404 August 2022
NRC Security Inspection Report 07200079/2022404 (Cover Letter)
IR 05000482/20220022022-07-25025 July 2022
Integrated Inspection Report 05000482/2022002
IR 05000482/20224022022-06-29029 June 2022
Security Baseline Inspection Report 05000482/2022402 - Public
IR 05000482/20220102022-05-0505 May 2022
Biennial Problem Identification and Resolution Inspection Report 05000482/2022010
IR 05000482/20224012022-05-0303 May 2022
Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000482/2022401
IR 05000482/20220012022-04-25025 April 2022
Integrated Inspection Report 05000482/2022001 and Independent Spent Fuel Storage Installation Inspection Report 07200079/2022001
IR 05000482/20210062022-03-0202 March 2022
Annual Assessment Letter (Report 05000482/2021006)
IR 05000482/20213012022-01-19019 January 2022
NRC Examination Report 05000482/2021301
IR 05000482/20210042022-01-19019 January 2022
Integrated Inspection Report 05000482/2021004 and Independent Spent Fuel Storage Installation Inspection Report 07200079/2021002
IR 05000482/20210112021-12-0101 December 2021
Temporary Instruction 2515/194 Report 05000482/2021011
IR 05000482/20214202021-11-15015 November 2021
Inspection Report Cover Letter FOF 05000482/2021420
IR 05000482/20210032021-11-0505 November 2021
Integrated Inspection Report 05000482/2021003 and Independent Spent Fuel Storage Installation Inspection Report 07200079/2021001, WC2021003 IR Ch
IR 05000482/20210102021-09-0909 September 2021
Design Basis Assurance Inspection (Teams) Inspection Report 05000482/2021010
IR 05000482/20210022021-08-0909 August 2021
Integrated Inspection Report 05000482/2021002
IR 05000482/20214022021-07-27027 July 2021
NRC Security Baseline Inspection Report 05000482/2021402 (Cover Letter Without Enclosure)
IR 05000482/20210012021-05-0505 May 2021
Integrated Inspection Report 05000482/2021001
IR 05000482/20190062021-03-0303 March 2021
Annual Assessment Letter (Report 05000482/2019006)
IR 05000482/20214012021-02-26026 February 2021
NRC Security Inspection Report 05000482/2021401
IR 05000482/20200042021-02-0909 February 2021
Integrated Inspection Report 05000482/2020004
IR 05000482/20200132020-12-0303 December 2020
Traditional Enforcement Follow-Up Inspection Report 05000482/2020013
IR 05000482/20200122020-11-19019 November 2020
Triennial Fire Protection Inspection Report 05000482/2020012
IR 05000482/20200032020-11-12012 November 2020
Integrated Inspection Report 05000482/2020003
IR 05000482/20204102020-09-29029 September 2020
Security Baseline Inspection Report 05000482/2020410
IR 05000482/20200022020-08-12012 August 2020
Integrated Inspection Report 05000482/2020002 and Independent Spent Fuel Storage Installation Inspection Report 07200079/2020001
IR 05000482/20200102020-08-0303 August 2020
Biennial Problem Identification and Resolution Inspection Report 05000482/2020010
IR 05000482/20200112020-05-21021 May 2020
Design Basis Assurance Inspection (Programs) Inspection Report 05000482/2020011
IR 05000482/20200012020-05-0404 May 2020
Integrated Inspection Report 05000482/2020001
IR 05000482/20194132020-02-11011 February 2020
Security Baseline Inspection Report 05000482/2019413
IR 05000482/20190042020-02-0303 February 2020
Integrated Inspection Report 05000482/2019004
IR 05000482/20193012020-01-15015 January 2020
NRC Examination Report 05000482/2019301
IR 05000482/20190032019-10-25025 October 2019
Integrated Inspection Report 05000482/2019003
IR 05000482/20194102019-09-24024 September 2019
NRC Cyber Security Inspection Report 05000482/2019410
IR 05000482/20194122019-09-11011 September 2019
NRC Security Inspection Report 05000482/2019412
IR 05000482/20190052019-08-30030 August 2019
Updated Inspection Plan for Wolf Creek Generating Station, Report 05000482/2019005
2024-01-11
[Table view]
Category:Letter
MONTHYEARML24025A0992024-01-25025 January 2024
Withdrawal of Request for Exemption from Specific 10 CFR Part 73 Requirements
ML24018A0792024-01-22022 January 2024
Individual Notice of Consideration of Issuance of Amendment to Renewed Facility Operating License, Proposed Nshcd and Opportunity for a Hearing (EPID L-2024-LLA-0007) (Letter)
ML24018A1382024-01-18018 January 2024
Inservice Inspection Request for Information
ML24018A2482024-01-18018 January 2024
License Amendment Request to Modify the Implementation Date of License Amendment No. 238
IR 05000482/20230042024-01-11011 January 2024
Integrated Inspection Report 05000482/2023004
ML23356A0722024-01-0404 January 2024
Supplemental Information Needed for Acceptance of Requested Licensing Actions Exemption from Specific 10 CFR Part 73N Requirements (EPID L-2023-LLE-0048) (Redacted Version)
WO 23-0002, Operating Corp., Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-0082023-12-26026 December 2023
Operating Corp., Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008
ML23348A3662023-12-18018 December 2023
Notification of an NRC Fire Protection Baseline Inspection (NRC Inspection Report 05000482 2024012) and Request for Information
ML23334A2502023-11-30030 November 2023
Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation
ML23299A2662023-11-29029 November 2023
Issuance of Amendment No. 238 Modified Implementation Date of License Amendment No. 237
ML23331A4972023-11-27027 November 2023
Supplement to License Amendment Request to Modify the 90-Day Implementation of License Amendment No. 237
ML23325A2112023-11-20020 November 2023
Submittal of Request for Exemption from Specific Provisions in 10 CFR 73.55
ML23320A2772023-11-16016 November 2023
License Amendment Request to Revise Ventilation Filter Testing Program Criteria in Technical Specification 5.5.11.b and Administrative Correction of Absorber in Technical Specification 5.5.11
ML23311A2082023-11-0909 November 2023
Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV
ML23305A3472023-11-0101 November 2023
Revision of One Form That Implements the Radiological Emergency Response Plan (RERP)
ML23292A3592023-10-19019 October 2023
License Amendment Request to Modify the 90-Day Implementation of License Amendment No. 237
ML23292A3572023-10-19019 October 2023
Operating Corporation, Request for Correction in Response to Issuance of Amendment No. 237 and Corresponding Safety Evaluation
ML23277A2772023-10-11011 October 2023
Regulatory Audit Summary Concerning Review of Request Number CI3R-01 for Proposed Alternative Inspection Frequency for Containment Unbonded Post Tensioning System Components
ML23284A2392023-10-11011 October 2023
NRC Initial Operator Licensing Examination Approval 05000482/2023301
ML23276B4552023-10-0303 October 2023
Technical Specification 5.6.8 Post Accident Monitoring (PAM) Report
ML23264A8682023-09-21021 September 2023
Independent Spent Fuel Storage Installation Registration of Dry Storage Canister WC-EOS-37PTH-008-B4L, WC-EOS-37PTH-007-B4L, and WC-EOS-37PTH-002-B4L
ML23256A2062023-09-14014 September 2023
Withdrawal of Requested Licensing Action Exemption from Specific 10 CFR Part 73 Requirements
ML23165A2502023-08-31031 August 2023
Issuance of Amendment No. 237 Request for Deviation from Fire Protection Requirements
ML23243A0002023-08-31031 August 2023
Wolf Generating Station - Withdrawal of Request for Exemption from Specific 10 CFR Part 73 Requirements
IR 05000482/20230052023-08-23023 August 2023
Updated Inspection Plan for Wolf Creek Nuclear Operating Corporation, Unit 1 (Report 05000482/2023005) - Mid-Cycle Letter 2023
ML23232A0012023-08-19019 August 2023
Revision of One Procedure That Implements the Radiological Emergency Response Plan (Rerp). Includes EPP 06-009, Rev. 13
ML23221A3932023-08-0909 August 2023
Submittal of Request for Exemption from Specific 10 CFR Part 73 Requirements
ML23220A4222023-08-0808 August 2023
Supplement to License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements
ML23201A1212023-08-0707 August 2023
Issuance of Amendment No. 236 Revision to Technical Specifications to Adopt TSTF-554, Revise Reactor Coolant Leakage Requirements
ML23130A2902023-07-26026 July 2023
Issuance of Amendment No. 235 Revision to Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections
IR 05000482/20230022023-07-11011 July 2023
Integrated Inspection Report 05000482/2023002
ML23167A0042023-06-26026 June 2023
Audit Plan to Support Review of Request for Alternative Containment Inservice Inspection Frequency
IR 05000482/20234012023-06-21021 June 2023
Security Baseline Inspection Report 05000482/2023401
ML23171B1312023-06-20020 June 2023
Additional Supplement to License Amendment Request to Adopt TSTF-577-A, Revision 1, Revised Frequencies for Steam Generator Tube Inspections
ML23151A4162023-05-31031 May 2023
Revision of One Form That Implements the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS)
ET 23-0006, CFR 50.55a Request Number CI3R-01 for the Third Containment Inservice Inspection Program Interval for Proposed Alternative Frequency to Containment Unbonded Post-Tensioning System Components2023-05-17017 May 2023
CFR 50.55a Request Number CI3R-01 for the Third Containment Inservice Inspection Program Interval for Proposed Alternative Frequency to Containment Unbonded Post-Tensioning System Components
WO 23-0014, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-17017 May 2023
Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations
ML23132A1532023-05-12012 May 2023
Transmittal of 2022 Annual Financial Reports
WM 23-0009, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors 10 CFR 50.75(f)(1)2023-05-10010 May 2023
Financial Assurance Requirements for Decommissioning Nuclear Power Reactors 10 CFR 50.75(f)(1)
ML23135A1172023-05-0808 May 2023
Redacted Version of Revision 36 to Updated Safety Analysis Report
ML23117A2112023-04-27027 April 2023
Annual Exposure Report (2022)
ML23117A1342023-04-27027 April 2023
2022 Annual Radioactive Effluent Release Report Report 46
2024-01-04
[Table view] |
Text
January 12, 2006Rick A. Muench, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation
P.O. Box 411 Burlington, KS 66839 Wolf Creek Nuclear Operating CorporationSUBJECT:NRC INSPECTION REPORT 05000482/2005004
Dear Mr. Muench:
Because of an error in documenting the completed inspection scope for the ALARAinspection conducted June 27 - July 1, 2005, insert the enclosure to this letter as replacements for pages 13 - 15 of NRC Inspection Report 05000482/2005004.Please accept my apology for any inconvenience these actions may have caused.
Sincerely,
//RA//
Michael P. Shannon, ChiefPlant Support Branch Division of Reactor SafetyDocket: 50-482License: NPF-42Enclosure:Pages 13 - 15 of NRC Inspection Report 05000482/2005004cc w/enclosure:
Vice President Operations/Plant ManagerWolf Creek Nuclear Operating Corp.
P.O. Box 411 Burlington, KS 66839 Wolf Creek Nuclear Operating Corp.-2-Jay Silberg, Esq.Shaw Pittman, LLP 2300 N Street, NW Washington, DC 20037Supervisor LicensingWolf Creek Nuclear Operating Corp.
P.O. Box 411 Burlington, KS 66839Chief EngineerUtilities Division Kansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027Office of the GovernorState of Kansas Topeka, KS 66612Attorney General120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597County ClerkCoffey County Courthouse 110 South 6th Street Burlington, KS 66839-1798Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310Topeka, KS 66612-1366 Wolf Creek Nuclear Operating Corp.-3-Electronic distribution by RIV:Regional Administrator (BSM1)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (SDC)Resident Inspector (TBR2)SRI, Callaway (MSP)Branch Chief, DRP/B (WBJ)Senior Project Engineer, DRP/B (RAK1)Team Leader, DRP/TSS (RLN1)RITS Coordinator (KEG)Only inspection reports to the following:DRS STA (DAP)J. Dixon-Herrity, OEDO RIV Coordinator (JLD)ROPreports WC Site Secretary (SLA2)SUNSI Review Completed: __Yes____ADAMS: Yes G No Initials: GLG____ Publicly Available G Non-Publicly Available G Sensitive Non-SensitiveS\DRS\DRSLTRS\WC2005004errata.wpdRIV: DRS/PSB/HPIC:PSBGLGuerraMPShannon
/RA//RA/
1/ 12 /061/ 12 /06OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax-13-Enclosure*Self-assessments, audits, and special reports related to the ALARA programsince the last inspection*Effectiveness of self-assessment activities with respect to identifying andaddressing repetitive deficiencies or significant individual deficiencies *Radiation worker and radiation protection technician performance during work lactivities in radiation areas, airborne radioactivity areas, or high radiation areas lThe inspector completed 7 of the required 15 samples and 7 of the optional samples.
l b.FindingsNo findings of significance were identified.
4.OTHER ACTIVITIES4OA2Identification and Resolution of ProblemsResident Inspector Annual Sample Review a.Inspection ScopeThe inspectors evaluated the effectiveness of WCNOC's corrective action program asapplied to corrective action document PIR 2005-2142. This document was initiated to address the conditions and events that led to the inoperability of both site fire protectionpumps. Attributes considered during this review included the following: *Completeness, accuracy, and timeliness of problem identification *Operability and reportability evaluation *Extent of condition evaluation
- Apparent cause evaluation
- Corrective action effectiveness
The inspectors completed one sample.
b.FindingsFailure to Follow the Clearance Order ProcedureIntroduction: An apparent violation (AV) of Technical Specification 5.4.1a occurredwhen station personnel failed to follow Procedure AP 21E-001, "Clearance Orders," and manipulated a component inside a fire protection piping clearance boundary without instructions and authorization. The starting of a temporary fire pump resulted in water-14-Enclosurespraying on the controller of the operable diesel-driven fire pump through an open ventvalve, which rendered the pump inoperable.Description: On June 30, 2005, the motor of the electric fire pump experienced a shortin its winding which led to a fire at the motor. The plant took the appropriate compensatory measures and started parallel paths to restore the fire suppression water system within the allotted 14 days. One path involved a temporary modification to thefire protection system that installed a temporary motor-driven fire pump, which was accomplished on July 11, 2005. The temporary fire pump was tested on July 12, 2005, to verify it would provide the required flow of water suppression; however, the pump failed this test. Station fire protection personnel requested a clearance order to isolate the temporaryfire pump from the fire protection piping but failed to make station operations personnel aware of the desire to run the temporary fire pump following repairs. Once repairs to the pump were completed, the vendor under the direction of station fire protectionpersonnel started the pump believing they had authorization to operate the temporaryfire pump. This resulted in water issuing from an open vent valve which sprayed the controller of the diesel-driven fire pump. Station fire protection personnel discovered the wet controller and notified the control room. Control room personnel declared the diesel-driven fire pump inoperable. The diesel-driven fire pump was returned to service in approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The inspectors reviewed Procedure AP-10-103, Fire Protection Impairment Control, Revision 19, which identified the compensatory measures for the loss of fire suppression water systems. With the motor driven and the diesel driven fire pumpinoperable (approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) the impairment control procedure required that abackup fire pump be provided within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In this case, both the motor driven and the diesel driven fire pumps were restored within approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. This issue involved human performance crosscutting aspects associated with station personnel notfollowing a station procedure.Analysis: The failure to follow station procedures is a performance deficiency. Thefinding was determined to be more than minor because it affected the mitigating systems cornerstone objective of ensuring the availability, reliability, and capability ofsystems that respond to initiating events to prevent undesirable consequences. Usingthe Phase 1 worksheets in Manual Chapter 0609, "Significance Determination Process,"
the finding was determined to degrade the fire protecti on system suppression and wasevaluated using Appendix F, Fire Protection Significance Determination Process. This finding requires a Phase 3 analysis and is currently under evaluation. Wolf Creek Nuclear Operating Corporation entered this finding into their corrective action program as PIR 2005-2142 Enforcement: Technical Specification 5.4.1a requires procedures be implemented inaccordance with Regulatory Guide 1.33, Revision 2, Appendix A. RegulatoryGuide 1.33, Appendix A, Section 9, requires procedures for the performance of stationmaintenance. Contrary to the above, on July 13, 2005, station personnel operated-15-Enclosurecomponents inside an established fire protection piping clearance boundary withoutwork instructions or control room authorization as required by Station Procedure AP 21E-001, "Clearance Orders," Section 6.6.8. This resulted in an adjacent diesel-driven fire pump becoming inoperable. Pending determination of the final safety significance of this issue, this violation is being treated as an AV consistent with Section VI.A of the NRC Enforcement Policy: AV 05000482/0500404, manipulation ofplant component without proper authorization results in inoperable fire protection pumps.Corrective Action EffectivenessThere were no findings identified that were associated with the corrective actions for thisevent. However, the inspectors made the following observations from their review of the apparent cause evaluation and the associated corrective actions: The apparent cause evaluation states that some fire protection personnel are unfamiliar with the clearanceorder program because, for them, clearance orders are infrequently performed evolutions. Additionally, the evaluation states that some "groups" mistakenly believed itwas acceptable to work on vendor equipment inside clearance order boundaries without proper authorization or an approved procedure. These evaluation results suggest a clearance order program knowledge deficiency within the fire protection group. Yet, the corrective action for these contributing causes was counseling only the one individual involved with this event. .2Cross-References to Problem Identification & Resolution Findings DocumentedElsewhereSection 1R15 documents a condition where station personnel did not properly evaluatea condition adverse to quality regarding debris in the auxiliary feedwater flowtransmitters..3Access Control to Radiologically Significant Areas and ALARA InspectionsSection 2OS1 evaluated the effectiveness of WCNOC's problem identification andresolution processes regarding access controls to radiologically significant areas and radiation worker practices. The inspectors reviewed corrective action documents for root cause/apparent cause analysis against WCNOC's PI&R process. No findings of significance were identified.Section 2OS2 evaluated the effectiveness of WCNOC's PI&R processes regardingexposure tracking, higher than planned exposure levels, and radiation worker practices.
The inspector reviewed the corrective action documents listed in the attachment against WCNOC's PI&R program requirements. No findings of significance were identified.
