IR 05000482/2014008

Ir 05000482-14-008; 10/20/2014 - 11/06/2014; Wolf Creek Generating Station; Triennial Fire Protection Team Inspection

ML14352A342
Person / Time
Site:	Wolf Creek
Issue date:	12/18/2014
From:	Werner G E NRC/RGN-IV/DRS/EB-2
To:	Heflin A C Wolf Creek
References
IR 2014008
Download: ML14352A342 (44)

Text

December 18, 2014

Adam C. Heflin, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

SUBJECT: WOLF CREEK GENERATING STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000482/2014008

Dear Mr. Heflin:

On November 6, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Wolf Creek Generating Station and discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report. NRC inspectors documented two findings of very low safety significance (Green) in this report.

Both of these findings involved violations of NRC requirements. The inspectors also documented a licensee-identified violation which was determined to be of very low safety significance. The NRC is treating these violations as non-cited violations consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of the violations in this report, you should provide a written response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the 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 the Wolf Creek Generating Station. In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," 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). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-482 License No. NPF-42

Enclosure:

Inspection Report 05000482/2014008

w/Attachment:

Supplemental Information cc w/ encl: Electronic Distribution

SUMMARY

IR 05000482/2014008; 10/20/2014 - 11/06/2014; Wolf Creek Generating Station; Triennial Fire

Protection Team Inspection.

The report covered a two-week triennial fire protection team inspection by specialist inspectors from Region IV. Two findings of very low safety significance (Green) are documented in this report. All of these findings involved violations of NRC requirements. Additionally, the NRC inspectors documented one licensee-identified violation of very low safety significance. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red) and is determined using Inspection Manual Chapter 0609, "Significance Determination Process," dated June 2, 2011. Cross-cutting aspects are determined using Inspection Manual Chapter 0310, "Aspects within the Cross-Cutting Areas," dated December 19, 2013. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy, dated July 9, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4.

Cornerstone: Mitigating Systems

Green.

The team identified a non-cited violation of Technical Specification 5.4.1.d for the failure to implement and maintain adequate written procedures covering fire protection program implementation. Specifically, the licensee failed to maintain an alternative shutdown procedure that ensured operators could safely shut down the plant under all postulated fire scenarios. A scenario which could impact the operation of the required diesel generator was not adequately addressed. The licensee implemented a fire watch in the control room as a compensatory measure until corrective actions can be taken. The licensee documented the deficiencies with Procedure OFN RP-017, "Control Room Evacuation," Revision 45, in Condition Report 00089788. The failure to maintain adequate written procedures covering fire protection program implementation was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire)attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. A senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding since it involved a postulated control room fire that led to control room evacuation and determined that the finding was of very low safety significance. The finding did not have a cross-cutting aspect since the performance deficiency was more than three years old and not indicative of current performance. (Section 1R05.05)

Green.

The team identified a non-cited violation of Technical Specification 5.4.1.d for the failure to implement and maintain adequate written procedures covering fire protection program implementation. Specifically, the licensee failed to adequately label equipment and provide an adequate procedure for performing cold shutdown repairs required for post-fire safe shutdown. Since the plant would already be stable in hot shutdown, no immediate compensatory or corrective actions were required to assure safety. The licensee was evaluating corrective actions. The licensee documented the deficiencies in Condition Report 00089130.

The failure to ensure that Procedure OFN RP-017A, "Hot Standby to Cold Shutdown from Outside the Control Room Due To Fire," Revision 9, could be implemented as written was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events (fire) to prevent undesirable consequences. The finding was evaluated for safety significance using NRC Inspection Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process." Since the finding was related to the ability to achieve safe shutdown and the plant would remain in stable hot shutdown, the finding screened to

Green.

This performance deficiency had a cross-cutting aspect in the area of human performance associated with documentation because the licensee did not prepare an accurate and up-to-date procedure that assured nuclear safety. Specifically, personnel did not verify that the steps in the revised procedure could be performed as written and that the components had proper labeling [H.7]. (Section 1R05.09)

B. Licensee-Identified Violations

A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and the corrective action tracking number are listed in Section 4OA7 of this report.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection

This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure 71111.05T, "Fire Protection (Triennial)," at the Wolf Creek Generating Station. The inspection team evaluated the implementation of the approved fire protection program in selected risk-significant areas with an emphasis on the procedures, equipment, fire barriers, and systems that ensure the post-fire capability to safely shutdown the plant.

Inspection Procedure 71111.05T requires the selection of three to five fire areas and one or more mitigating strategies for review. The inspection team used the fire hazards analysis section of the Wolf Creek Generating Station Individual Plant Examination of External Events to select the following three fire areas (inspection samples) for review: Fire Area Description A-18 Auxiliary Building - 2026' Elevation, Electrical Penetration Room (North) A-24 North Pipe Penetration Room 1323 C-9 Control Building 2000' Elevation, ESF Switchgear Room (North)

The inspection team evaluated the licensee's fire protection program using the applicable requirements, which included plant Technical Specifications, Operating License Condition 2.C.(5), NRC safety evaluations, 10 CFR 50.48, and Branch Technical Position 9.5-1. The team also reviewed related documents that included the Updated Safety Analysis Report, Section 9.5; the fire hazards analysis; and the post-fire safe shutdown analysis. Specific documents reviewed by the team are listed in the attachment.

Three fire area inspection samples and five mitigating strategy samples were completed.

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the piping and instrumentation diagrams, safe shutdown equipment list, safe shutdown design basis documents, and the post-fire safe shutdown analysis to verify that the licensee properly identified the components and systems necessary to achieve and maintain safe shutdown conditions for fires in the selected fire areas. The team observed walkdowns of the procedures used for achieving and maintaining safe shutdown in the event of a fire to verify that the procedures properly implemented the safe shutdown analysis provisions.

For each of the selected fire areas, the team reviewed the separation of redundant safe shutdown cables, equipment, and components located within the same fire area. The team also reviewed the licensee's method for meeting the requirements of 10 CFR 50.48; Branch Technical Position 9.5-1, Appendix A; and 10 CFR Part 50, Appendix R, Section III.G. Specifically, the team evaluated whether at least one post-fire safe shutdown success path remained free of fire damage in the event of a fire.

In addition, the team verified that the licensee met applicable license commitments.

b. Findings

No findings were identified.

.02 Passive Fire Protection

a. Inspection Scope

The team walked down accessible portions of the selected fire areas to observe the material condition and configuration of the installed fire area boundaries (including walls, fire doors, and fire dampers) and verify that the electrical raceway fire barriers were appropriate for the fire hazards in the area. The team compared the installed configurations to the approved construction details, supporting fire tests, and applicable license commitments.

The team reviewed installation, repair, and qualification records for a sample of penetration seals to ensure the fill material possessed an appropriate fire rating and that the installation met the engineering design. The team also reviewed similar records for the rated fire wraps to ensure the material possessed an appropriate fire rating and that the installation met the engineering design.

b. Findings

No findings were identified.

.03 Active Fire Protection

a. Inspection Scope

The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected fire areas. The team verified the automatic detection systems and the manual and automatic suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association code of record or approved deviations and that each suppression system was appropriate for the hazards in the selected fire areas.

The team performed a walkdown of accessible portions of the detection and suppression systems in the selected fire areas. The team also performed a walkdown of major system support equipment in other areas (e.g., fire pumps and halon supply systems) to assess the material condition of these systems and components.

The team reviewed the electric and diesel fire pumps' flow and pressure tests to verify that the pumps met their design requirements. The team reviewed the fire water supply system flow and pressure tests confirming the system met its design requirements. The team also reviewed the halon suppression functional tests to verify that the system capability met the design requirements.

The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed pre-fire plans and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation and to facilitate suppression of a fire that could impact post-fire safe shutdown capability. In addition, the team inspected fire brigade equipment to determine operational readiness for fire-fighting. The team observed an unannounced fire drill and subsequent drill critique on November 5, 2014, using the guidance contained in Inspection Procedure 71111.05AQ, "Fire Protection Annual/Quarterly." The team observed fire brigade members fight a simulated fire in a motor control center, located in the turbine building. The team verified that the licensee identified problems, openly discussed them in a self-critical manner at the drill debrief, and identified 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 was brought to the scene; (5) effectiveness of fire brigade leader communications, command, and control; (6) search for victims and propagation of the fire into other areas; (7) smoke removal operations; (8) utilization of pre-planned strategies; (9) adherence to the pre-planned drill scenario; and (10) drill objectives.

b. Findings

No findings were identified.

.04 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The team performed plant walkdowns and document reviews to verify that redundant trains of systems required for hot shutdown, which are located in the same fire area, would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified:

• A fire in one of the selected fire areas would not directly, through production of smoke, heat, or hot gases, cause activation of suppression systems that could potentially damage all redundant safe shutdown trains

• A fire in one of the selected fire areas or the inadvertent actuation or rupture of a fire suppression system would not directly cause damage to all redundant trains (e.g., sprinkler-caused flooding of other than the locally affected train)

• Adequate drainage is provided in areas protected by water suppression systems

b. Findings

No findings were identified.

.05 Alternative Shutdown Capability

a. Inspection Scope

Review of Methodology The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings, electrical drawings, the Updated Safety Analysis Report, and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that require evacuation of the control room, with or without offsite power available.

The team conducted plant walkdowns to verify that the plant configuration was consistent with the description contained in the safe shutdown and fire hazards analyses. The team focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation, and support systems functions.

The team also verified that the systems and components credited for shutdown would remain free from fire damage. Finally, the team verified that the transfer of control from the control room to the alternative shutdown location would not be affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits). Review of Operational Implementation The team verified that licensed and non-licensed operators received training on alternative shutdown procedures. The team also verified that sufficient personnel to perform a safe shutdown were trained and available on-site at all times, exclusive of those assigned as fire brigade members.

The team performed a timed walkdown of the alternative shutdown procedure with licensed and non-licensed operators to determine the adequacy of the procedure. The team verified that the operators could reasonably be expected to perform specific actions within the time required to maintain plant parameters within specified limits. Time critical actions that were verified included restoring electrical power, establishing control at the remote shutdown and local shutdown panels, establishing reactor coolant makeup, and establishing decay heat removal.

The team also reviewed the periodic testing of the alternative shutdown transfer capability and instrumentation and control functions to verify that the tests were adequate to demonstrate the functionality of the alternative shutdown capability.

b. Findings

Introduction.

The team identified a Green non-cited violation of Technical Specification 5.4.1.d for the failure to implement and maintain adequate written procedures covering fire protection program implementation. Specifically, the licensee failed to maintain an alternative shutdown procedure that ensured operators could safely shut down the plant under all postulated fire scenarios.

Description.

The licensee would use Procedure OFN RP-017, "Control Room Evacuation," Revision 45, to perform an alternative shutdown from the auxiliary shutdown panel and other control stations outside of the control room in the event a fire required evacuation of the control room. This procedure provides directions for operators to shut down the plant using only train B equipment. These directions include actions to start and load the train B emergency diesel generator. The team performed a timed walkdown of the alternative shutdown procedure. Based on the timed walkdown results, the team determined that operators would remove any loads from the emergency diesel generator within 3 minutes 40 seconds. The operators would then proceed to ensure the emergency diesel generator was running, and close the breaker for the essential service water pump within 8 minutes 45 seconds. The team noted that the safe shutdown analysis credited emergency diesel generator cooling when valve EF HS-26A was closed, and the team determined that operators would close this valve within 9 minutes 50 seconds.

Based on these results, the team identified one alternative shutdown scenario where operators would not be able to successfully provide emergency diesel generator cooling prior to the emergency diesel generator reaching a high temperature trip setpoint. If this occurred, operators would need to wait until the emergency diesel generator cooled down before they could restart the emergency diesel generator and provide power to the required safe shutdown equipment (e.g., the charging pump, motor-driven auxiliary feedwater pump, and various motor-operated valves). The specific scenario involved a control room fire coincident with a loss of offsite power and the expected automatic starting and loading of the train B emergency diesel generator. The team determined that fire damage (e.g., a blown fuse) could prevent the essential service water pump from automatically starting and cooling the emergency diesel generator.

The licensee used Calculation KJ-M-017, "Emergency Diesel Standby Generator (KKJ01B) Runtime Without ESW Flow," Revision 0, to determine the amount of time that the emergency diesel generator could run without essential service water cooling water.

The team used the same methodology to estimate the amount of heat transferred to the emergency diesel generator jacket water based on the steps in the alternative shutdown procedure and the timed walkdown results. For the scenario under consideration, the team determined that the emergency diesel generator would reach the high temperature trip setpoint prior to operators starting the essential service water pump and closing valve EF HS-26A.

The team noted that the control room fire could also cause a spurious actuation that resulted in the addition of another large load to the emergency diesel generator that was not normally sequenced onto the emergency diesel generator following a loss of offsite power. In this instance, additional heat would be added to the emergency diesel generator jacket water and operators would have less time to ensure cooling was provided to the emergency diesel generator before it reached the high temperature trip.

Analysis.

The failure to maintain adequate written procedures covering fire protection program implementation was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," dated September 20, 2013.

Because it affected the ability to reach and maintain safe shutdown conditions in case of a fire that led to control room evacuation and the Phase 2 methodology of Inspection Manual Chapter 0609, Appendix F, was not appropriate for this finding, a senior reactor analyst performed a Phase 3 evaluation to determine the risk significance. The senior reactor analyst assigned a generic fire ignition frequency for the control room (FIFCR), which was slightly higher than the value in Calculation AN-95-029, "Control Room Fire Analysis," Revision 1. The analyst multiplied the fire ignition frequency by a severity factor (SF) and a non-suppression probability indicating that operators failed to extinguish the fire within 20 minutes, assuming a 2-minute detection that required a control room evacuation (NPCRE). The resulting control room evacuation frequency (FEVAC) was:

FEVAC = FIFCR

• SF

• NPCRE = 1.09E-2/year

• 0.1

• 1.30E-2

= 1.42E-5/year

The control room had a total of 103 cabinets. The analyst determined that a single fire in one of these cabinets could lead to the loss of essential service water cooling water to the emergency diesel generator and a single fire in two other cabinets could lead to a loss of offsite power. Therefore, a bounding change in core damage frequency for a control room fire that leads to evacuation and the loss of the emergency diesel generator (FEVAC+EDG) was determined to be:

FEVAC+EDG = FEVAC

• 3 / 103 = 1.42E-5/year

• 3 / 103

= 4.14E-7/year

This frequency was considered to be bounding since it assumed: 1) A fire in any of the applicable cabinets would cause a loss of offsite power and a loss of essential service water cooling water, resulting in a loss of the emergency diesel generator 2) The conditional core damage probability given a control room fire with evacuation and the loss of the emergency diesel generator was equal to one 3) The performance deficiency accounted for the entire change in core damage frequency (i.e., the baseline core damage frequency for this event was zero) In accordance with the guidance in Inspection Manual Chapter 0609, Appendix H, "Containment Integrity Significance Determination Process," dated May 6, 2004, the senior reactor analyst screened the performance deficiency for its potential risk contribution to large early release frequency since the bounding change in core damage frequency provided a risk significance estimate greater than 1E-7/yr. Given that Wolf Creek has a large, dry containment and that control room evacuation sequences do not include steam generator tube ruptures or intersystem loss of coolant accidents, the analyst determined that this example was not significant with respect to large early release frequency. The analyst determined this example was of very low risk significance (Green).

The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than three years ago.

Enforcement.

Technical Specification 5.4.1.d states that written procedures shall be established, implemented, and maintained covering fire protection program implementation. Procedure OFN RP-017, "Control Room Evacuation," is a procedure required for fire protection program implementation. Contrary to the above, prior to November 6, 2014, the licensee failed to maintain adequate written procedures covering fire protection program. Specifically, the licensee failed to maintain Procedure OFN RP-017 so that it allowed operators to successfully implement the procedure as written under all required conditions. If the operators implemented the procedure when emergency diesel generator B had automatically started, emergency diesel generator B could have tripped on high temperature and the plant could not have been safely shut down.

Because this violation was of very low safety significance, has been entered into the corrective action program as Condition Report 89788, and the licensee has a fire watch in the control room as a compensatory measure until corrective actions can be taken, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000482/2014008-01, "Inadequate Alternative Shutdown Procedure."

.06 Circuit Analysis

a. Inspection Scope

The team reviewed the post-fire safe shutdown analysis to verify that the licensee identified the circuits that may impact the ability to achieve and maintain safe shutdown.

The team verified, on a sample basis, that the licensee properly identified the cables for equipment required to achieve and maintain hot shutdown conditions in the event of a fire in the selected fire areas. The team verified that these cables were either adequately protected from the potentially adverse effects of fire damage or were analyzed to show that fire-induced circuit faults (e.g., hot shorts, open circuits, and shorts to ground) would not prevent safe shutdown.

The team's evaluation focused on the cables of selected components from the reactor coolant system, refueling water storage tank, containment sump, essential service water, main steam atmospheric vent, emergency diesel, and chemical volume and control system. For the sample of components selected, the team reviewed electrical elementary and block diagrams and identified power, control, and instrument cables necessary to support their operation. In addition, the team reviewed cable routing information to verify that fire protection features were in place, as needed, to satisfy the separation requirements specified in the fire protection license basis. Specific components reviewed by the team are listed in the attachment.

b. Findings

No findings were identified.

.07 Communications

a. Inspection Scope

The team inspected the contents of designated emergency storage lockers and reviewed the alternative shutdown procedure to verify that portable radio communications and fixed emergency communications systems were available, operable, and adequate for the performance of designated activities. The team verified the capability of the communication systems to support the operators in the conduct and coordination of their required actions. The team also verified that the design and location of communications equipment such as repeaters and transmitters would not cause a loss of communications during a fire. The team discussed system design, testing, and maintenance with the system engineer.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The team reviewed the portion of the emergency lighting system required for alternative shutdown to verify that it was adequate to support the performance of manual actions required to achieve and maintain hot shutdown conditions and to illuminate access and egress routes to the areas where manual actions would be required. The team evaluated the locations and positioning of the emergency lights during a walkdown of the alternative shutdown procedure.

The team verified that the licensee installed emergency lights with an 8-hour capacity, maintained the emergency light batteries in accordance with manufacturer recommendations, and tested and performed maintenance in accordance with plant procedures and industry practices.

b. Findings

No findings were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

The team evaluated whether the licensee identified repairs needed to reach and maintain cold shutdown and had dedicated repair procedures, equipment, and materials to accomplish these repairs. Using these procedures, the team evaluated whether these components could be repaired in time to bring the plant to cold shutdown within the timeframes specified in their design and licensing bases. The team reviewed whether the repair equipment, components, tools, and materials needed for the repairs were available and accessible on-site.

b. Findings

Introduction.

The team identified a Green non-cited violation of Technical Specification 5.4.1.d for the failure to implement and maintain adequate written procedures covering fire protection program implementation. Specifically, the licensee failed to provide an adequate procedure for performing cold shutdown repairs required for post-fire safe shutdown. The licensee documented the deficiencies in Condition Report 00089130.

Description.

The team reviewed a sample of repairs required for achieving and maintaining cold shutdown that required personnel to lift leads and/or install jumpers associated with the boric acid transfer pump BATP2. During the walkthrough of Procedure OFN RP-017A, "Hot Standby to Cold Shutdown from Outside the Control Room Due To Fire," Revision 9, with plant personnel, a plant operator and electrical maintenance technician were unable to demonstrate that they could successfully complete Attachment B, "Jumper Installation for Boric Acid Pump Operation."

Step B2 required wire 16BGG27BH to be removed from a starter/contactor located inside motor control center cubicle NG02AAF4, which is located on the front side of motor control center NG02A. The procedure identified this starter/contactor as terminal block M/terminal point Z (identified as M/Z in the table for Step B2). However, the starter/contactor was not labeled. It is important to note that there is not a traditional terminal block, only terminal points associated with these particular style starter/contactors. The associated drawing, E-13BG27, identified the starter/contactor as device 42. Similar motor control center cubicles were looked at and the starter/contactors were labeled in accordance with their associated drawing, by a number. Step B3 required electrical maintenance personnel to lift and tape two additional cables that are indicated to be located in the rear of motor control center NG02A. Step B4 required the labeling and installation of a jumper to bypass the starter/contactor device 42 (by Step B2 designated as M/Z); however, the procedure did not specify the location as being on the front side of motor control center NG02A.

When asked, both the operator and electrical maintenance technician simulating the jumper installation for the boric acid pump were unsure of the location and stated that they could not perform the procedure as written and would have to contact the technical support center for assistance during an emergency.

The licensee entered these issues into their corrective action program as Condition Report 00089130.

Analysis.

The failure to ensure that Procedure OFN RP-017A could be implemented as written was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events (fire) to prevent undesirable consequences. The finding was evaluated for safety significance using NRC Inspection Manual Chapter 0609, Appendix F. Per Step 1.3, since the finding was related to the ability to achieve safe shutdown with the plant being in a stable hot shutdown condition, and the finding would not impact the ability to maintain hot shutdown, the inspectors determined that the finding was of very low safety significance (Green). This performance deficiency had a cross-cutting aspect in the area of problem identification and resolution associated with evaluation because the licensee did not perform an adequate extent of condition review while taking corrective actions for non-cited Violation 05000482/2011007-04, "Procedure Inadequacies Related to Cold Shutdown Repairs." Specifically, personnel did not verify that the steps in the revised procedure could be performed as written and that the components had proper labeling [P.2].

Enforcement.

Technical Specification 5.4.1.d states that written procedures shall be established, implemented, and maintained covering fire protection program implementation. Procedure OFN RP-017A, "Hot Standby to Cold Shutdown from Outside the Control Room Due to a Fire," is a procedure required for fire protection program implementation. Contrary to the above, from April 2014 to November 6, 2014, the licensee failed to maintain written procedures that could be implemented covering fire protection program implementation. Specifically, the licensee failed to maintain an adequate procedure for performing cold shutdown repairs required for post-fire safe shutdown since Procedure OFN RP-017A could not be implemented as written. Since the finding was related to the ability to achieve safe shutdown and the plant would remain in stable hot shutdown, no immediate compensatory or corrective actions were required to assure safety. Because this violation was of very low safety significance and it was entered into the corrective action program as condition Report 00089130, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 0500482/2014008-02, "Procedure Inadequacies Related to Cold Shutdown Repairs."

.10 Compensatory Measures

a. Inspection Scope

The team verified that compensatory measures were implemented for out-of-service, degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems and equipment; passive fire barriers; or pumps, valves, or electrical devices providing safe shutdown functions). The team also verified that the short-term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.

The team reviewed operator manual actions credited for achieving hot shutdown for fires that do not require an alternative shutdown. The team verified that operators could reasonably be expected to perform the actions within the applicable shutdown time requirements. The team reviewed these operator manual actions using the guidance contained in NUREG-1852, "Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire," dated October 2007.

b. Findings

No findings were identified.

.11 Review and Documentation of Fire Protection Program Changes

a. Inspection Scope

The team reviewed changes to the approved fire protection program. The team verified that the changes did not constitute an adverse effect on the ability to safely shutdown.

b. Findings

No findings were identified.

.12 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The team reviewed the licensee's approved fire protection program, implementing procedures, and programs for the control of ignition sources and transient combustibles. The team assessed the licensee's effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. The team performed plant walkdowns to independently verify that transient combustibles and ignition sources were being properly controlled in accordance with the administrative controls.

b. Findings

No findings were identified.

.13 Alternative Mitigation Strategy Inspection Activities

a. Inspection Scope

The team reviewed implementation of guidance and strategies intended to maintain or restore core, containment, and spent fuel pool cooling capabilities under the circumstances associated with the potential loss of large areas of the plant due to explosions or fire as required by 10 CFR 50.54(hh)(2). The team verified that the licensee maintained and implemented adequate procedures, maintained and tested equipment necessary to properly implement the strategies, and ensured station personnel were knowledgeable and capable of implementing the procedures. The team performed a visual inspection of portable equipment used to implement the strategy to ensure the availability and material readiness of the equipment, including the adequacy of portable pump trailer hitch attachments, and verify the availability of on-site vehicles capable of towing the portable pump. The team assessed the offsite ability to obtain fuel for the portable pump and foam used for firefighting efforts. The team reviewed the following mitigating strategies during this inspection:

• Attachment C - Spent Fuel Pool Makeup Using Fire Protection Standpipe

• Attachment F - Spent Fuel Pool Makeup Using 4-inch Drain Connection and Fire Truck

• Attachment L - CST Makeup Using Fire Protection Standpipe

• Attachment S - Local Manual SG Depressurization

• Attachment U - Low Pressure SG Injection Using Fire Truck Five mitigating strategy samples were completed.

b. Findings

No findings were identified.

.14 Multiple Spurious Operation Circuit Issues

a. Inspection Scope

Enforcement Guidance Memorandum 09-002, "Enforcement Discretion for Fire Induced Circuit Faults," dated May 14, 2009, specified that licensees would have 6 months from the issuance of Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants,"

Revision 2, to include multiple spurious noncompliances in their corrective action program. Enforcement Guidance Memorandum 09-002 also specified that licensees would have 3 years from issuance of Regulatory Guide 1.189, Revision 2, to complete any required corrective actions (see Section

4OA3 for details of the review).

The team reviewed the expert panel report, corrective action program documents, plant modifications, and engineering analyses. The team interviewed plant personnel involved with developing the modifications and implementing the corrective actions. The team walked down the modifications implemented in the plant. The team performed a detailed review of 28 of the identified multiple spurious operation scenarios (see Section

4OA3 for details of the review).

b. Findings

No findings were identified.

OTHER ACTIVITIES

[OA]

4OA2 Identification and Resolution of Problems

Corrective Actions for Fire Protection Deficiencies

a. Inspection Scope

The team selected a sample of condition reports associated with the licensee's fire protection program to verify that the licensee had an appropriate threshold for identifying deficiencies. The team reviewed the corrective actions proposed and implemented to verify that they were effective in correcting identified deficiencies. The team evaluated the corrective actions for findings identified in previous inspections. The specific condition reports evaluated included:

• Condition Report 045434 associated with Finding 05000482/2011007-01, "Failure to Verify Isolation of Associated Circuits on Isolation Switches"

• Condition Report 045442 associated with non-cited Violation 05000482/2011007-02, "Inadequate Alternative Shutdown Procedure"

• Condition Reports 044912 and 045452 associated with non-cited Violation 05000482/2011007-03, "Failure to Ensure Post-Fire Safe Shutdown Components Remain Free of Fire Damage"

• Condition Reports 045397, 045399, 045401, and 045417 associated with non-cited Violation 05000482/2011007-04, "Procedure Inadequacies Related to Cold Shutdown Repairs" During its review of the findings related to circuits, the team evaluated whether the licensee effectively implemented the corrective actions documented in correspondence related to the spurious operation of the power-operated relief valves.

b. Findings

No findings were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion

(Closed) Licensee Event Report 05000482/2010-007-00 and 05000482/2010-007-01: Post-Fire Safe Shutdown Fire-Induced Multiple Spurious Operation Issues This licensee event report documented that the licensee had identified five multiple spurious operation issues that had insufficient operator guidance for responding to equipment maloperation. The licensee had identified the following issues during their post-fire safe shutdown by fire area re-analysis of multiple spurious circuit failures. The five multiple spurious issues included:

• Three issues that affected operation of the residual heat removal pumps

• Spurious actuation of pressurizer spray valves

• Spurious start of a centrifugal charging pump and overfill of the pressurizer The licensee had completed modifications for each of these reported deficiencies. In addition, the licensee had identified six other multiple spurious issues that required reanalysis and, in some cases, design document changes, but no plant modifications. The licensee documented these 11 multiple spurious operation issues in Condition Report 25002.

The team performed a detailed review of the information related to this deficiency. The team reviewed drawings, design documents, and discussed the implemented modifications with fire protection personnel to gain an understanding of the actions taken to address the deficiency. The team verified that the licensee established appropriate compensatory measures and corrective actions.

The team reviewed these deficiencies as part of the review of licensee evaluation and resolution of multiple spurious operation scenarios. In addition to the 61 Pressurized Water Reactor Owners Group multiple spurious operation scenarios, the licensee expert panel had identified 14 scenarios and plant operations personnel identified one additional scenario. The team reviewed the scenario table and selected 28 of the multiple spurious operation evaluations for additional review, which included the five modifications and six other items discussed earlier.

Enforcement Guidance Memorandum (EGM) 09-002, "Enforcement Discretion for Fire Induced Circuit Faults," dated May 14, 2009, specified that licensees would have 6 months from issuance of Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants," Revision 2, dated November 2, 2009, to include multiple spurious noncompliances in their corrective action program. Licensees would then have 3 years from issuance of Regulatory Guide 1.189, Revision 2, to complete any required corrective actions.

Corrective actions were scheduled to be completed during the Refueling Outage 19, which was originally scheduled to be started for September 2012. However, Refueling Outage 19 was rescheduled to February 2013 due to a longer than expected previous refueling outage and an extended forced outage in January 2012. Missing the EGM deadline for completing the corrective actions was a performance deficiency and was screened in accordance with Manual Chapter 0612, Appendix B, "Issue Screening."

It was determined that the performance deficiency was a minor violation due to the low safety impact of the additional time necessary to implement the corrective actions and did not affect the cornerstone objective. The team verified that the corrective actions were completed during Refueling Outage 19 which began in February 2013.

.2 (Closed) Licensee Event Report 05000482/2013-009-00:

Unanalyzed Condition - Post-Fire Safe Shutdown Design Issue May Impact Ability to Achieve Safe Shutdown This licensee event report documented that the licensee had ammeters installed on the main control board without circuit overcurrent protection. Because of the lack of circuit overcurrent protection, a fire affecting the eight safety-related ammeter circuits could create a secondary fire in another area of the plant. The licensee had confirmed that only safety-related circuits were affected and required modification.

The team performed a detailed review of the information related to this deficiency. The team reviewed drawings, design documents, and discussed the event with plant personnel to gain an understanding of the actions taken to address the deficiency. The team verified that the licensee established appropriate compensatory measures, corrective actions, and planned modifications.

The licensee documented this deficiency in their corrective action program as Condition Report 00074959 and initiated actions to review the applicable circuits. As compensatory measures, the licensee established roving fire watches in the fire areas where the circuits were routed.

The team reviewed the planned circuit modifications and verified that they will correct the deficiency. This licensee-identified finding involved a violation of License Condition 2.C(5). The team discussed the enforcement related to this deficiency in Section 4OA7.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented the inspection results to Mr. A. Heflin, President and Chief Executive Officer, and other members of the licensee staff at an exit meeting on November 6, 2014. The licensee acknowledged the findings presented.

The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements that meets the criteria of Section 2.3.2.a of the NRC Enforcement Policy for being dispositioned as a non-cited violation.

Unanalyzed Condition - Post-Fire Safe Shutdown Design Issue May Impact Ability to Achieve Safe Shutdown On October 9, 2013, Licensee Event Report 05000482/2013-009 described an unanalyzed condition wherein a fire in fire areas containing certain unprotected, shunt, direct current ammeter circuits could result in secondary fires outside the initial fire area. This condition can occur only under specific circuit fault conditions wherein a fire causes a short to ground on cables associated with the DC ammeters, concurrent with a short to ground on a safety-related 125V DC circuit on the negative side of the same battery source. This condition is known as a ground equivalent hot short. The ammeter circuits are not overcurrent protected and, consequentially, could overheat and ignite anywhere along the route of the associated ammeter cables. The licensee determined in a cause analysis and extent of condition review that the only affected circuits were the eight DC ammeters associated with the safety-related 125V DC batteries and battery chargers. The team determined the routing of the affected cables involved five fire areas. The five fire areas were switchboard rooms/battery rooms FA C16, locked cable chase FA C18, locked cable chase FA C24, lower cable spreading room FA C21, and control room FA C27. The team evaluated the various scenarios of where the primary fire could start and where the secondary fire(s) could develop. The team determined that there were no normal ignition sources (electrical cabinets or equipment) in the two locked cable chases or the lower cable spreading room. Transient combustibles in these areas were strictly controlled by Procedure AP 10-102, "Control of Combustible Materials," Revision 18, and the cable chases are protected by a wet pipe automatic sprinkler system and automatic smoke detection alarms in the main control room. A fire in the switchboard rooms/battery room FA C16 is the area where the ammeter shunts are

located and a primary fire there would not result in a secondary fire outside this area. The only remaining fire area to evaluate was the control room FA C27, which had a low combustible loading, all cables entering the control room are IEEE 383 rated, and the cables and cable trenches were protected by an automatic halon extinguishing system and automatic smoke detectors. While a primary fire in the control room could cause a secondary fire to develop along the cable route, the team determined that in the event that a secondary fire did occur that the impact would be limited to the same train as the primary fire. Therefore, the redundant post-fire safe shutdown success path would be unaffected by the fire.

License Condition 2.C(5)(a) specifies, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Standardized Nuclear Power Plant System Final Safety Analysis Report through Revision 17, the Wolf Creek site addendum through Revision 15, and as approved in the Safety Evaluation Report through Supplement 5, Amendment No. 191, Amendment No. 193, and Amendment No 205. Section 4.4.1.1 of the Fire Hazards Analysis states that "only one fire is postulated to occur at any one time and multiple fires are not postulated." Contrary to the above, since initial construction until November 6, 2014, the licensee failed to implement the fire protection program that ensured only one fire will occur at one time. Specifically, the licensee failed to ensure that direct current ammeter circuits were properly protected to prevent secondary fires from initiating in other areas of the plant. The performance deficiency was more than minor because it was associated with the protection against external factors attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events (fire) to prevent undesirable consequences. The finding was evaluated for safety significance using NRC Inspection Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," dated September 20, 2013. Since the finding was related to the ability to achieve safe shutdown and safe shutdown would be unaffected, the inspectors determined the finding had a very low safety significance (Green). Specifically, no secondary fires resulting from a primary fire could prevent the reactor from achieving safe shutdown. The licensee documented this issue in their corrective action program as Condition Report 00074959. This violation is also discussed in Section 4OA3.

A-1 Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Alford, Engineering

D. Anderson, Supervisor, IMR

R. Audano, Superintendent, Maintenance

T. Baban, Manager, Systems Engineering

R. Birk, Superintendent, Mechanical Maintenance

L. Brinkly, Supervisor, Maintenance Corrective Action Program

A. Broyles, Manager, Information Services

K. Clark, Fire Protection Technician

R. Coombes, Reactor Operator

J. Cuffe, Supervisor, Health Physics

D. Dees, Superintendent, Operations Support

D. Erbe, Manager, Security

R. Flannigan, Manager, Nuclear Engineering

R. Fincher, Manager, Quality

B. Fox, Engineer, Appendix R Safe Shutdown

J. Fritton, PWR Owners Group

C. Garland, Nuclear Station Operator

N. Good, Licensing

D. Grove, Superintendent, Maintenance Support

A. Heflin, President and Chief Executive Officer

S. Henry, Manager, Integrated Plant Services

P. Herrman, Manager, Programs

D. Hess, FIN Electrician

R. Hobby, Licensing

J. Keating, Reactor Operator

W. Ketchum, Supervisor, Engineering

J. Knust, Licensing

S. Koenig, Manager, Regulatory Affairs

B. Logan, Master IMR Technician

D. Mand, Manager, Design Engineering

J. McCory, Vice President, Engineering

E. McIntyre, Manager, Human Resources

W. Muilenburg, Supervisor, Licensing

B. Reasoner, Site Vice President and Chief Nuclear Operations Officer

S. Schrum, Nuclear Station Operator

T. Slenker, Operations

A. Stull, Vice President and Chief Administrative Officer

E. Smith, Design Engineer

S. Smith, Plant Manager

T. Smith, Manager, Project Construction

J. Suter, Supervisor, Fire Protection Engineering

D. Sullivan, Manager, Supply Chain Services

S. Teal, Supervisor, Organizational Effectiveness

K. Thompson, Superintendent, Site Safety

L. Upson, Manager, Strategic Initiatives

Licensee Personnel

A. Vickery, Manager, Financial Services

R. Wolfe, Non-licensed Nuclear Operator

J. Yunk, Manager, Corrective Action

NRC Personnel

C. Peabody, Senior Resident Inspector

R. Stroble, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

0500482/2014008-01 NCV Inadequate Alternative Shutdown Procedure (Section 1R05.05)0500482/2014008-02 NCV Procedure Inadequacies Related to Cold Shutdown Repairs (Section 1R05.09)

Closed

05000482/LER-2010-007-00 LER Post-Fire Safe Shutdown Fire-Induced Multiple Spurious Operation Issues

05000482/LER-2010-007-01 LER Post-Fire Safe Shutdown Fire-Induced Multiple Spurious Operation Issues

05000482/LER-2013-009-00 LER Unanalyzed Condition - Post-Fire Safe Shutdown Design Issue May Impact Ability to Achieve Safe Shutdown

LIST OF DOCUMENTS REVIEWED

Calculations

Number Title Revision

AN 98-023 WCGS Fire risk Evaluation Re-Analysis 0

BG-M-052 Evaluate the Potential for Overheating a Charging Pump When Procedure OFN

EG-004, "CCW System Malfunctions," is invoked 0 E-1F9900 Post-Fire Safe Shutdown Operator Manual Actions 8 E-1F9900-005-A-1 Post-Fire Safe Shutdown Operator Manual Actions

E-1F9905 Fire Hazards Analysis 5

E-1F9910 Post-Fire Safe Shutdown Area Analysis 12

E-1F9915 Design Basis Document for OFN

RP-017, Control Room Evacuation 5 and 6

KC-M-006 Water-Based Fire Protection System and Standpipe System Hydraulic Calculation 1

KJ-M-017 Emergency Diesel Standby Generator (KKJ01B) Runtime Without ESW Flow 0

SA-08-006

RETRAN-3D Post-Fire Safe Shutdown (PFSSD) Consequence Evaluation for a Postulated Control Room Fire 3

WCNOC-CP-002 Wolf Creek Fire Protection Transient Analysis with

RETRAN-3D 1

WCNOC-166 Hydraulic Calculations for

EDMG-T01 Strategies W01

XX-E-004 AC Motor Operated Valve Minimum Terminal Voltage CN007 13

XX-E-012 Safety Related MCC Control Circuit Allowable Wire Lengths CN002 2

XX-E-012 Safety Related MCC Control Circuit Allowable Wire Lengths CN002 3

XX-E-012 Safety Related MCC Control Circuit Allowable Wire Lengths CN003 3

XX-E-013 Post-Fire Safe Shutdown (PFSSD) Analysis 3

Calculations

Number Title Revision

XX-E-013, CN002 Post-Fire Safe Shutdown Analysis 3

XX-E-013, CN003 Post-Fire Safe Shutdown Analysis 3

XX-E-013, CN004 Post-Fire Safe Shutdown Analysis 3

XX-E-013,CN005 Post-Fire Safe Shutdown Analysis 3

XX-E-013, CN007 Post-Fire Safe Shutdown Analysis 3

Condition Reports

88360

88361

30350

216 89216 89161*

88168

89136* 89076* 89130*

89117*

89101* 89102* 89103*

89079*

89099* 89100* 89074*

13079

13114 19239 20153

45442

89161* 89413* 89509*

25002

44912 45397 74959

89397*

89788* *Issued as a result of inspection activities.

Drawings

Number Title Revision E-1L3604 Lighting, Grounding, & Communications; Communications Corridor, Containment, & Diesel Generators Buildings; Plan Elevation 2047'-6" 28 E-1L8900 Lighting Notes, Symbols, and Details 71 E-11NB01 Lower Medium Voltage System Class 1E 4.16 KV Single Line Meter and Relay Diagram 7 E-11NB02 Lower Medium Voltage System Class 1E 4.16 KV Single Line Meter and Relay Diagram 7 E-11NG01 Low Voltage System Class 1E 480 V Single Line Meter and Relay Diagram 11 E-11NG02 Low Voltage System Class 1E 480 V Single Line Meter and Relay Diagram 11 E-11NK01 Class 1E 125V DC System Meter and Relay Diagram 13

Drawings

Number Title Revision E-11NK02 Class 1E 125V DC System Meter and Relay Diagram 9 E-13AB01 Schematic Diagram Main Steam Supply Valve to Turbine Driven Auxiliary Feedwater Pump 3 E-13AB01A Schematic Diagram Main Steam Supply Valve to Turbine Driven Auxiliary Feedwater Pump 3 E-13AB06B Schematic Diagram Main Steam Atmospheric Vent Valve Position Indicating Lights 4 E-13AL01B Schematic Diagram Motor Driven Auxiliary Feedwater Pump B 5 E-13AL02B Schematic Diagram Motor Operated Valve ALHV0034 6 E-13AL04B Schematic Diagram Supply from ESS Service Water System 9 E-13BB24 Schematic Diagram Pressurizer Heater Backup Group B 2 E-13BB39 Schematic Diagram Pressurizer Relief Isolation Valves 9 E-13BB40 Schematic Diagram Pressurizer Relief Valves 7 E-13BG11C Schematic Diagram Charging Pump to Reactor Coolant and Miniflow Isolation Valve BGHV8111 1 E-13BG12A Schematic Diagram Volume Control Tank Outlet Isolation Valve 7 E-13BG17 Schematic Diagram Letdown Line Isolation Valve 2 E-13BG27 Schematic Diagram Boric Acid Transfer Pumps 1 E-13BL04 Schematic Diagram - Reactor Make-up Water Transfer Pump A 1 E-13BL05 Schematic Diagram - Reactor Make-up Water Transfer Pump B 1 E-13BN03A Schematic Diagram Refueling Water Storage Tank to RHR Pump Motor Operated Valve 11 E-13EF02A Schematic Diagram ESW to SW System Isolation Valves 5 E-13EF04A, Sheet 1 Schematic Diagram ESW from Component Cooling Water Heat Exchanger Isolation Valve EFHV0060 1

Drawings

Number Title Revision E-13EF05A Schematic Diagram ESW to Component Cooling Water Heat Exchanger Isolation Valve EFHV0052 1 E-13EF06A Schematic Diagram ESW to Ultimate Heat Sink Isolation Valves 5 E-13EG05A Schematic Diagram - Component Cooling Water Return From Nuclear Aux. Component EGHV0016 7 E-13EG05D Schematic Diagram - Component Cooling Water Return From Nuclear Aux. Component EGHV0054 4 E-13EM02 Schematic Diagram - Boron Injection Tank Discharge & Inlet Isolation Valves 6 E-13EM02A Schematic Diagram - Boron Injection Tank Discharge Isolation Valves EMHV8801B 1 and 4 E-13EM02C Schematic Diagram - Boron Injection Tank Discharge Isolation Valve EMHV8801A 1 E-13EM05A Schematic Diagram Charging Pumps Cold Leg Test Line Valve 0 E-13FC23 Schematic Diagram Auxiliary Feedwater Pump Turbine Trip and Throttle Valve 15 E-13FC25 Schematic Diagram Auxiliary Feedwater Pump Turbine Governor Valve Position Indication 1 E-13GK13 Schematic Diagram Class 1E Electrical Equipment Air Conditioning Unit 5 E-13GL12A Schematic Diagram Penetration Room Cooler B 5 E-13JE01A Schematic Diagram Emergency Fuel Oil Transfer Pump PJE01B 2 E-13KJ03A Schematic Diagram Diesel Generator KKJ01B Engine Control (Start/Stop Circuit) 17 E-13KJ03B Schematic Diagram, Diesel Generator KKJ01B Engine Control (D/G Trips) 6 E-13KJ04 Schematic Diagram Diesel Generator KKJ01B Annunciator and Miscellaneous Circuits 8 E-13KJ07 Diesel Generator KKJ01B Governor Control 6 E-13NE11 Schematic Diagram 4.16 KV Diesel Generator NE02 17

Drawings

Number Title Revision Feeder Breaker 152NB0211 E-13NE13 Schematic Diagram Diesel Generator KKJ01B Exciter/Voltage Control 14 E-13NG11A Schematic Diagram 480V Load Center Main Feeder Breaker 52NG0401 1 E-13NG11B Schematic Diagram 480V Load Center Main Feeder Breaker 52NG0201 1 E-13NK11 125 Volt DC Class 1E Power System Schematic 2 E-13PG12A Schematic Diagram 4.16 KV Load Center Feeder Breaker 152NB0208 5 E-13RP11 Schematic Diagram Lock-Out Relay Contact Development SEP Group 2 1 E-13RP12 Schematic Diagram Lock-Out Relay Contact Development SEP Group 4 2 E-13RP13 Schematic Diagram Lock-Out Relay Contact Development SEP Group 6 1 E-13RP15 Schematic Diagram Lock-Out Relay Control Circuits RP334/RP335 1 E-093-0095 Sheet 1 Auxiliary Relay Rack Wiring Diagram

RP-335 4 E-093-0096 Sheet 2 Auxiliary Relay Rack Wiring Diagram

RP-335 4 E-11005 List of Loads Supplied by Emergency Diesel Generator 36 and 42

H-SP-2955 PB605A & B D

J-110-00216 Instrument Loop Diagram Main Steam System Atmospheric Steam Dump Steam Generator A W06 J-110-00217 Instrument Loop Diagram Main Steam System Atmospheric Steam Dump Steam Generator A W06 J-110-00218 Instrument Loop Diagram Main Steam System Atmospheric Steam Dump Steam Generator B W09 J-110-00219 Instrument Loop Diagram Main Steam System Atmospheric Steam Dump Steam Generator B W012 J-110-0933 Instrument Loop Diagram Main Steam System Atmospheric Steam Dump Steam Generator B W03

Drawings

Number Title Revision J-110-0220 Instrument Loop Diagram Main Steam System Atmospheric Steam Dump Steam Generator C W07 J-110-0221 Instrument Loop Diagram Main Steam System Atmospheric Steam Dump Steam Generator C W07 J-110-0222 Instrument Loop Diagram Main Steam System Atmospheric Steam Dump Steam Generator D W08 J-110-0223 Instrument Loop Diagram Main Steam System Atmospheric Steam Dump Steam Generator D W11 J-110-0933 Instrument Loop Diagram Main Steam System Atmospheric Steam Dump Steam Generator D W03

KD-7496 One Line Diagram 15 and 53 M-0023, Sheet 1 P&ID Fire Protection System (FP) 61

M-0023, Sheet 2 P&ID Fire Protection System (FP) 21

M-0023, Sheet 3 P&ID Fire Protection System (FP) 37

M-0023, Sheet 4 P&ID Fire Protection System (FP) 16

M-1G021 Equipment Location Auxiliary Building Partial Plan Elevation 1988'-0" and Elevation 2013'-6" 3 M-1G023 Equipment Locations Reactor and

Auxiliary Building

Plan Elevation 2016'-0" 9 M-12AB01, Sheet 1 Piping & Instrumentation Diagram Main Steam System 16 M-12AB02 Piping & Instrumentation Diagram, Main Steam System 15 M-12AB03 Piping and Instrumentation Diagram Main Steam System 19 M-12AL01, Sheet 1 Piping & Instrumentation Auxiliary Feedwater System 23 M-12BB01 Piping and Instrumentation Diagram Reactor Coolant System 29 M-12BB02 Piping & Instrumentation Reactor Coolant System 20 M-12BB03 Piping and Instrumentation Diagram Reactor Coolant System 14 M-12BG01 Piping and Instrumentation Diagram Chemical and Volume Control System 18

Drawings

Number Title Revision M-12BG02 Piping and Instrumentation Diagram Chemical and Volume Control System 16 M-12BG03 Piping & Instrumentation Chemical & Volume Control System 48 M-12BG04 Piping and Instrumentation Diagram Chemical and Volume Control System 7 M-12BG05 Piping and Instrumentation Diagram Chemical and Volume Control System 23 M-12BM01 Piping & Instrumentation Steam Generator Blowdown System 19 M-12BM02 Piping and Instrumentation Diagram Steam Generator Blowdown System 13 M-12BM03 Piping and Instrumentation Diagram Steam Generator Blowdown System 3 M-12BN01 Piping & Instrumentation Borated Refueling Water Storage System 16 M-12EF01 Piping & Instrumentation Essential Service Water System 27 M-12EF02 Piping & Instrumentation Essential Service Water System 34 M012EG01 Piping & Instrumentation Component Cooling Water System 24 M012EG02 Piping & Instrumentation Component Cooling Water System 23 M012EG03 Piping & Instrumentation Component Cooling Water System 12 M-12EJ01 Piping and Instrumentation Diagram Residual Heat Removal System 49 M-12EM02 Piping & Instrumentation Diagram, High Pressure Coolant Injection System 20 M012EN01 Piping & Instrumentation Containment Spray System 13

Drawings

Number Title Revision M-12KJ04 Piping & Instrumentation Diagram, Standby Diesel Generator "B" Cooling Water System 16 M-12JE01 Piping and Instrumentation Diagram Emergency Fuel Oil System 19 M-12KC01 Piping & Instrumentation Diagram Fire Protection Turbine Building 20 M-12KC02 Piping & Instrumentation Diagram Fire Protection System 17 M-12KC04 Piping & Instrumentation Diagram Fire Protection Halon System 3 M-12KC05 Piping & Instrumentation Diagram Fire Protection System 2 M-12KC07 Piping & Instrumentation Diagram Fire Protection Halon System 3 M-12LE02 Piping & Instrumentation Diagram Control & Diesel Generator Building Oily Waste System 3

DS-C-67970-13, Sheet 3 Crosby Valve and Gage Company Solenoid Assembly M

DS-C-67970-13, Sheet 4 Crosby Valve and Gage Company Solenoid Power Operated Relief Valve M

WIP-E-0R1906-009-A-1 Raceway Sections & Details - Auxiliary Building 0

WIP-E-0R3903-006-0A-1 Raceway Sections & Details - Control Building 1

WIP-E-1R1113-014-B-1 Exposed Conduit - Auxiliary Building Area 1, El 1974'-0" 0

WIP-E-1R1124-009-A-1 Exposed Conduit - Auxiliary Building Part Plan Area 2, El 1974'-0" 0

WIP-E-1R1233-004-B-1 Exposed Conduit - Auxiliary Building Area 3, El 1988'-0" 1

WIP-E-1R1313B-004-C-1 Exposed Conduit - Auxiliary Building Area 1, El 2000'-0" 0

Drawings

Number Title Revision

WIP-E-1R1313B-004-D-1 Exposed Conduit - Auxiliary Building Area 1, El 2000'-0" 0

WIP-E-1R1413D-006-A-1 Exposed Conduit - Auxiliary Building Area 1, El 2026'-0" 1

WIP-E-1R1423C-007-A-1 Exposed Conduit - Auxiliary Building Area 2, El 2026'-0" 0

WIP-E-1R1523D-003-A-1 Exposed Conduit - Auxiliary Building Area 2, El 2047'-6" 0

WIP-E-1R1523A-001-B-1 Exposed Conduit - Auxiliary Building Area 2, El 2047'-6" 1

WIP-E-1R1523B-003-B-1 Exposed Conduit - Auxiliary Building Area 2, El 2047'-6" 0

WIP-E-1R1523B-003-C-1 Exposed Conduit - Auxiliary Building Area 2, El 2047'-6" 0

WIP-E-1R1523B-006-A-1 Exposed Conduit - Auxiliary Building Area 2, El 2000'-0" 1

WIP-E-1R1523C-003-A-1 Exposed Conduit - Auxiliary Building Area 2, El 2047'-6" 0

WIP-E-1R1523D-003-A-1 Exposed Conduit - Auxiliary Building Area 2, El 2047'-6" 0

WIP-E-0R1906-009-A-1 Raceway Sections & Details - Auxiliary Building 0

WIP-E-0R3903-006-0A-1 Raceway Sections & Details - Control Building 1

WIP-E-1R1913-005-B-1 Raceway Sections & Details - Auxiliary Building 0

WIP-E-1R3312-011-C-1 Exposed Conduit - Control Building Area 1, El. 2000'-0" 0

WIP-E-1R3613-016-B-1 Exposed Conduit - Communication Corridor Area 1, El 2047'-6" 0

WIP-E-1R3613-016-C-1 Exposed Conduit - Communication Corridor Area 1, El 2047'-6" 1

Drawings

Number Title Revision

WIP-E-1R3614-012-B-1 Exposed Conduit - Control Building Area 1, El 2047'-6" 1

WIP-E-11NK01-012-B-1 Class 1E 125V DC System Meter and Relay Diagram 0

WIP-E-11NK02-008-D-1 Class 1E 125V DC System Meter and Relay Diagram 0

WIP-E-12BN03A-008-A-1 Schematic Diagram - Refueling Water Storage Tank to RHR Pump MOV 1

WIP-E-13BN07-002-A-1 Schematic Diagram - Miscellaneous Instruments 1

WIP-E-13EG05A-006-A-1 Schematic Diagram - Component Cooling Water Return from Nuclear Auxiliary Components EGHV0016 0

WIP-E-13EG05D-001-A-1 Schematic Diagram - Component Cooling Water Supply to Nuclear Auxiliary Components EGHV0054 1

WIP-E-13EJ06A-006-A-1 Schematic Diagram - Sump to No. 1 Residual Heat Removal Pump 0

WIP-E-13EJ06A-007-A-1 Schematic Diagram - Sump to No. 1 Residual Heat Removal Pump 0

WIP-E-13EJ06B-007-B-1 Schematic Diagram - Sump to No. 2 Residual Heat Removal Pump 0

WIP-E-13EJ06B-009-A-1 Schematic Diagram - Sump to No. 2 Residual Heat Removal Pump 0

WIP-E-13EJ08A-002-A-1 Schematic Diagram - Residual Heat Removal Pump Miniflow Valve EJFCV0611 0

WIP-E-13EM00-014-B-1 High Head Safety Injection System Schematic Index Sheet 0

WIP-E-13EM02-005-A-1 Schematic Diagram - Boron Injection Tank Inlet Isolation Valve EMHV8803A 1

WIP-E-13EM02A-001-A-1 Schematic Diagram - Boron Injection Tank Discharge Isolation Valve EMHV8801B 0

WIP-E-13EM02C-000-A-1 Schematic Diagram - Boron Injection Tank Discharge Isolation Valve EMHV8801A 1

Drawings

Number Title Revision

WIP-E-020-00015-W12-B-1 NK01 0

WIP-E-020-00016-W12-B-1 NK02 0

WIP-E-020-00017-W12-B-1 NK03 0

WIP-E-020-00018-W12-B-1 NK04 0

WIP-E-020-00025-W08-B-1 Wiring Diagram 0

WIP-E-020-00031-005-B-1 Connection Diagram 0

WIP-E-051B-00001-W03-A-1 Bill of Materials - Transfer Switch Enclosures: NK71 thru NK78 0

WIP-E-051B-00006-W02-A-1 Assembly Drawing-Back Panel Layout of Components: NK71 and NK74 0

WIP-E-051B-00009-W02-A-1 Assembly Drawing-Back Panel Layout of Components: NK72 and NK73 0

WIP-E-051B-00013-W02-A-1 Wire List - Transfer Switch Enclosure NK71 0

WIP-E-051B-00014-W02-A-1 Wire List - Transfer Switch Enclosure NK72 0

WIP-E-051B-00015-W02-A-1 Wire List - Transfer Switch Enclosure NK73 0

WIP-E-051B-00016-W02-A-1 Wire List - Transfer Switch Enclosure NK74 0

WIP-E-051B-00021-W02-A-1 Wiring Diagram - Transfer Switch Enclosure NK71 0

WIP-E-051B-00022-W02-A-1 Wiring Diagram - Transfer Switch Enclosure NK72 0

WIP-E-051B-00023-W02-A-1 Wiring Diagram - Transfer Switch Enclosure NK73 0

WIP-E-051B-00024-W02-A-1 Wiring Diagram - Transfer Switch Enclosure NK74 0

Drawings

Number Title Revision

WIP-M-1X3411-003-A-1 Control Building Area 1 Penetration Closure Plan Floor El. 2016,-0" 1

WIP-M-1X3511-001-A-1 Control Building Area 1 Penetration Closure Plan Floor El. 2016,-0" 0

WIP-M-1X3611-002-A-1 Control Building Area 1 Penetration Closure Plan Floor El. 2032',-0" 1 02-H74F/63-E3A Burgmann H-74 Seal (Drive End) C 02-H74F/63-E3B Burgmann H-74 Seal (Non-Drive End) A 271C335, Sheet 187 Westinghouse Electric Corporation Remote Operated Valve PCV

PCV-455A 7 10466-A-1802 Architectural Fire Delineation Floor Plan Elevation 2000'-0" 16 10466-A-1803 Fire Delineation Floor Plan Elevation 2026'-0" 8 7250D64, Sheet 11 SNUPPS Projects, Functional Diagram, Pressurizer Pressure & Level Control 1W 8025-C-KG1202 Site Plan 48 10466-A-1801 Architectural Fire Delineation Floor Plan, El 1974'-0" 12

10466-A-1802 Architectural Fire Delineation Floor Plan, El 2000'-0" 16 10466-A-1803 Architectural Fire Delineation Floor Plan, El 2026'-0" 8 10466-A-1804 Architectural Fire Delineation Floor Plan, El 2047'-6" 12

Engineering Change Packages (Cp-) Number Title Revision 07037 Installation of Darmatt Fire Barrier Material 0, 1, 2, 3 and 4

2307 PFSSD - Cable Reroute to Resolve RWST Draindown 0 and 1 12316 Post-Fire Safe Shutdown Area Analysis 0 12418 EGHV0016 and EGHV0054 Fire Resistive Cables 0, 1, 2, 3 and 4

2944 PORV BBPCV0455A and BBPCV0456A 0, 1, 2, 3 and 4

Engineering Change Packages (Cp-) Number Title Revision 13104 Post-Fire Safe Shutdown 0 and 1

13600 Post-Fire Safe Shutdown Analysis 0 and 1 13612 Re-route BNLT0932 Cable to Address Post-fire Safe Shutdown Issue 0 and 1 13613 PFSSD - Install Meggitt Fire Resistive Cable to Protect BNHV8812B Control Circuit 0, 1, 2, and 3 13614 PFSSD - Protect Control Circuit Cables for Motor-Operated Valves EMHV8801A and EMHV8801B 0, 1, 2, 3 and 4 13615 Relocate EJFIS0611 from Room 1301 to Room 1107 0, 1, 2, and 3 14325 PFSSD - EJHV8811A and B Control Circuit Modification 0 and 1

Fire Impairments

2014-105 2014-176

2014-232 2014-242 2014-295

2014-306 2014-335 2014-342

2014-344 2014-358

Licensing Correspondence Number Title Date License Amendment 189 Wolf Creek Generating Station - Issuance of Amendment RE:

License Amendment Request for Use of Fire-Resistive Electrical Cable September 30, 2010 License Amendment 190 Wolf Creek Generating Station - Issuance of Amendment RE:

Revision to Technical Specification 3.6.3, "Containment Isolation Valves" November 3, 2010 License Amendment 191 Wolf Creek Generating Station - Issuance of Amendment RE:

Deviation from Fire Protection Program Requirements December 16, 2010 License Amendment 193 Wolf Creek Generating Station - Issuance of Amendment RE:

Removing High/Low Pressure Designation from the Pressurizer Power-Operated Relief Valves March 9, 2011 License Amendment 205 Wolf Creek Generating Station - Issuance of Amendment RE:

Deviation from Fire Protection August 23, 2013

Licensing Correspondence Number Title Date Requirements for Volume Control Tank Outlet Valves Letter

ET 09-0007 License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements March 4, 2009 Letter

ET 09-0018 License Amendment Request (LAR) for Use of Fire-Resistive Electrical Cable December 16, 2009 Letter

ET 10-0003 Application to Revise Technical Specification 3.6.3, "Containment Isolation Valves" January 28, 2010 Letter

ET 10-0013 License Amendment Request (LAR) to the Approved Fire Protection Program to Remove the High/Low Pressure Interface Designation from the Pressurizer Power-Operated Relief Valves (PORVs) and their Associated Block Valves April 13, 2010 Letter

ET 12-0022 License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements -

Volume Control Tank Outlet Valves October 18, 2012 Letter

ET 13-0012 Request for Review of Information to Support Resolution of Example 2 of Non-cited Violation 05000482/2011007-03, "Failure to Ensure Post-

Fire Safe Shutdown Components Remain Free of Fire Damage March 29, 2013 Letter

ET 13-0015 Completion of Actions to Resolve Three Noncompliance's Related to Multiple Fire Induced Circuit Failures May 22, 2013 Letter

ET 13-0035 License Amendment Request (LAR) for Revision to the Wolf Creek Generating Station Fire Protection Program Related to Alternative Shutdown Capability November 21, 2013 Letter

WM 12-0019 Licensee Event Report 2010-007-01, "Post-Fire Safe Shutdown Fire-Induced Multiple Spurious Operation Issues" July 9, 2012 Letter

WO 07-0002 Response Providing Information Regarding Implementation Details for the Phase 2 and 3

Mitigation Strategies February 23, 2007 Letter

WO 10-0042 Licensee Event Report 2010-007-00, "Post-Fire Safe Shutdown Fire-Induced Multiple Spurious June 21, 2010

Licensing Correspondence Number Title Date Operation Issues"

NUREG-0881 Safety Evaluation Report Related to The Operation of Wolf Creek Generating Station, Unit No. 1 April 1982

NUREG-0881 Supplement 3 Safety Evaluation Report Related to The Operation of Wolf Creek Generating Station, Unit No. 1 August 1983

NUREG-0881 Supplement 5 Safety Evaluation Report Related to The Operation of Wolf Creek Generating Station, Unit No. 1 March 1985

Miscellaneous Documents

Number Title Revision/Date E-025-00007, Sheet 1 MOV Design Configuration Document General Notes June 12, 2012 Lesson Plan FL1224000 Fire Brigade 006 Lesson Plan FB1231400 Initial Fire Brigade Member 010

PIR 2002-2290 Performance Improvement Request September 11, 2003

PIR 2003-1925 Evaluate Centrifugal Charging Pump Temperatures with minimum flow of 32 gpm September 30, 2003 STN

GP-009 Emergency Equipment Verification October 14, 2014

USAR Section 9.5.1 Fire Protection Program 25

USAR Appendix

9.5A Design Comparison to Regulatory Positions of

Regulatory Guide 1.120, Revision 1, Dated November 1977, Titled "Fire Protection Guidelines for Nuclear Power Plants" 25 USAR Appendix

9.5E WCGS Fire Protection Comparison to 10CFR50 Appendix R 27

Fire Protection Program Regulatory Bases 3

Fire Protection Handbook, Eighteenth Edition, Section 6, Chapter 6, Hydraulics 1997

Miscellaneous Documents

Number Title Revision/Date

Fire Protection Program Regulatory Bases 3

International Fire Service Training Association Piping Apparatus DRIVER/OPERATOR

Handbook, 2nd Edition, Chapter 8, Theoretical Pressure Calculations (Customary) July 2006

Selected auxiliary building and control building fire preplans for fire areas with conduit and fire resistive cable routed

Procedures

Number Title Revision ALR

KC-888 Fire Protection Panel

KC-008 Alarm Response 22

AI 21-017 Timed Fire Protection Actions Validation 5

AI 26A-003 Regulatory Evaluations (Other Than 10

CFR 50.59) 16

AP 05-001 Change Package Planning and Implementation 9

AP 05-002 Dispositions and Change Packages 28

AI 10-001 Fire Brigade Equipment Inventory, Maintenance, and Cleaning 11

AI 21-017 Timed Fire Protection Actions Validation 5

AP 10-100 Fire Protection Program 19

AP 10-101 Control of Transient Ignition Sources 19

AP 10-102 Control of Combustible Materials 18

AP 10-103 Fire Protection Impairment Control 28

AP 10-104 Breach Authorization 30

AP 10-105 Fire Protection Training and Drills 17

AP 10-106 Fire Preplans 15

AP 10-109 Fire Protection Inspections 6

Procedures

Number Title Revision

EDMG-001 Extensive Damage Mitigation Guideline 6

EDMG-T01 EDMG Tool Box 13 MPE

BA-010 Preventive Maintenance on Teledyne Emergency Lighting 22A OFN

KC-016 Fire Response 40 OFN

RP-017 Control Room Evacuation 45

OFN

RP-017A Hot Standby To Cold Shutdown From

Outside The Control Room Due To Fire 9 STN

FP-204 Fire Protection System C-Factor Test 22 and 25 STN

FP-206 Spray and Sprinkler System Functional Testing 16

STN

FP-209 Fire Pump Performance and Sequential Start Test 24 and 25 STN

FP-225 Fire Barrier Inspection 8 STN

GP-009 Emergency Equipment Verification 70 STN

FP-400B Halon System/North Penetration Room (KC-224) 6A

STN

FP-405B Halon System/North Penetration Room (KC-224) 0

STN

FP-440 Fire Door Visual Inspection 13

STN

FP-450 Fire Damper Inspection and Drop Test 14A STN

FP-452 Fire Barrier Penetration Seals Inspection 6 STN

FP-817A Trip Actuation Device Operation Test for Bechtel Zones 100, 103, 104, 105, 106, 107, 112,113, and 114 10A STN

FP-817D Trip Actuation Device Operation Test for Bechtel Zones 108,

109, 110, 101, 117, 118 and 119 11A STN

FP-817E Trip Actuation Device Operation Test for Bechtel Zones 300, 301, 303 and 308 6C STN

FP-817F Trip Actuation Device Operation Test for Bechtel Zones 306, 037 and 314-317 7B

Procedures

Number Title Revision STN

KC-202 Fire Protection Header Flush From Yard Loop Through Power Block Interface 11 STN

KC-206 Spray and Sprinkler System Functional Testing - Wet-Pipe 16

Vendor Document

Number Title Date H-409B-35 Zetron Series 4000 Communications Control System Installation Manual December 17, 2004

Work Orders

13-365362-000

13-365363-000 13-365364-000 13-372932-000

13-372934-000

13-372937-000

13-375104-000 13-375106-000 13-375108-000 13-376333-000 13-379471-000

13-380694-000

13-380695-000

13-380696-000 13-380707-000 13-381700-000 14-382881-000 14-383766-000

14-383771-000

14-383789-000

14-383841-000 30082 30086 30090 36801

36803

63902