IR 05000482/2020004

Integrated Inspection Report 05000482/2020004

ML21040A411
Person / Time
Site:	Wolf Creek
Issue date:	02/09/2021
From:	O'Keefe C NRC/RGN-IV/DNMS/NMSB-B
To:	Reasoner C Wolf Creek
References
IR 2020004
Download: ML21040A411 (14)

Text

February 9, 2021

SUBJECT:

WOLF CREEK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000482/2020004

Dear Mr. Reasoner:

On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Wolf Creek Generating Station. On January 6, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

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

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

Sincerely, Cornelius Digitally signed by Cornelius F. O'Keefe F. O'Keefe Date: 2021.02.09 13:15:36 -06'00'

Neil F. O'Keefe, Chief Reactor Projects Branch B Division of Reactor Projects Docket No. 05000482 License No. NPF-42

Enclosure:

As stated

Inspection Report

Docket Number: 05000482 License Number: NPF-42 Report Number: 05000482/2020004 Enterprise Identifier: I-2020-004-0008 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: Burlington, KS Inspection Dates: October 1, 2020, to December 31, 2020 Inspectors: C. Henderson, Senior Resident Inspector J. Vera, Resident Inspector Approved By: Neil F. O'Keefe, Chief Reactor Projects Branch B Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Wolf Creek Generating Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

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

Additional Tracking Items

None.

PLANT STATUS

Wolf Creek Generating Station began the inspection period at full power, except for the four occasions in the month of November when the licensee reduced power to 70 percent for flexible power operations (based on daily market demand) and returned to full power after each occasion. On December 11, 2020, the licensee reduced power to 70 percent to perform main turbine valve surveillance testing and data gathering for future flexible power operation cycles, the unit was returned to full power on December 12, 2020, where it remained for the rest of the reporting period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed onsite portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and onsite. The inspections documented below met the objectives and requirements for completion of the IP.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (1 Sample)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Emergency diesel generator A jacket water and intercooler system on October 22, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Auxiliary feedwater pump B room door 13271 breach authorization for maintenance, fire area A-13 on December 29, 2020

(2) Auxiliary feedwater pump A room door 13261 breach authorization for degraded door gasket, fire area A-14 on December 29, 2020

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated operator performance during power changes as part of flexible power operations on November 14, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator simulator training activities on November 16, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Emergency diesel generator A placed in 10 CFR 50.65(a)(1) due to temperature control valve failures on October 22, 2020

(2) Train B containment coolers due to essential service water outlet valve EFHV0046 failure to open on December 2, 2020.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Emergent work for shutdown bank C reactor control rods failing to insert during surveillance testing on December 18, 2020

(2) Emergent work for reactor trip breaker A block switch for the automatic shunt trip failure during surveillance testing on December 21, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Emergency diesel generator A fuel oil transfer pump polarization index operability determination on November 2, 2020

(2) Train B safety-related 480 volt bus NG02 exceeding 506 volts AC operability determination on December 18, 2020

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Change in time critical operator action to establish Class 1E room cooling air recirculation and shifting safety-related battery chargers following a failure of the safety-related air conditioning unit on November 17, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Emergency diesel generator A fuel oil pump replacement and fuel oil system maintenance on October 26, 2020

(2) Emergency diesel generator B, 7-day technical specification maintenance outage on November 5, 2020

(3) Emergency diesel generator A, 7-day technical specification maintenance outage on October 22, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Emergency diesel generator A monthly operability and lube oil inventory surveillance testing on October 27, 2020

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Reactor coolant leakage surveillance testing on November 3, 2020

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) The inspectors observed emergency preparedness drills with no drill and exercise performance indication opportunity (DEP) and emergency preparedness table-tops with DEP on November 18,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS08: Heat Removal Systems (IP Section 02.07) ===

(1) October 1, 2019, through September 30, 2020

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) October 1, 2019, through September 30, 2020

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in human performance tool usage and control of evaluations that might be indicative of a more significant safety issue on December 17,

INSPECTION RESULTS

Observation: Semi-Annual Trend Review 71152 The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation available to help identify performance trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address the identified adverse trends. The inspectors did not review any cross-cutting themes because none existed at the site.

To verify that the licensee was taking corrective actions to address identified adverse trends that might indicate the existence of a more significant safety issue, the inspectors noted an apparent negative trend in work management that resulted human performance errors and reviewed the corrective action program documentation from April through December 2020.

Selected examples of these events that illustrate the performance included:

• Condition Report (CR) 141893: During the performance of Procedure SYS GK-201, Mitigating Actions for Inoperable SKG05 Train, Rev. 0, for an emergent refrigerant leak on the train B Class 1E electrical air conditioning unit (SGK05B), both safety-related batteries became inoperable when placing the swing battery chargers into services. Specifically, the licensee lowered the output voltage of both normally aligned safety-related chargers concurrently causing both trains of safety-related batteries to become inoperable. This issue was documented in NRC Inspection Report 05000482/2020002 (Adams ML20224A354) as NCV 05000482/2020002-01.

• CR 143812: The licensees failure to implement Procedure AI 16C-005, Toolpouch and Minor Maintenance Preparation and Implementation, Revision 0. Specifically, the licensee failed to inform operations personnel of safety injection pump A oil leakage during post maintenance testing per Procedure AI 16C-005 to determine whether the safety-related function of the system or component would be affected prior to attempting to repair the leakage. This was evaluated as a minor issue because it was identified and corrected during maintenance in progress.

• CR 144243: During the restoration of steam generator blowdown from planned maintenance activities in accordance with Procedure SYS BM-127, Blow Down Flow Adjustments, Revision 15, the steam generator blowdown system unexpectedly automatically isolated due to a high flash tank level. This event occurred because the licensee failed to ensure all individuals involved were in place and ready to perform the evolution. Specifically, an operator was assigned to throttle radiation monitor flow and perform an independent verification for hanging a clearance order. The control room and the other assigned local operator did not verify that the individual was in place to throttle radiation monitor flow, resulting in the isolation of steam generator blow down. This was evaluated as a minor issue because it did not result in a plant transient.

• CR 144908: The licensee released approximately 180 gallons from the A train secondary liquid waste tank (THF04A), however the release permit was for discharging the contents of THF04B. Prior to the release, one of the on-shift field operators unexpectedly had to leave the site. The replacement watch-stander failed to review the liquid release permit to ensure the correct THF04 was aligned for release. This was evaluated as a minor issue because it did not result in a release greater than the release approved in the permit for THF04B.

The inspectors performed an independent assessment of the adverse trend that resulted in human performance issues at the station and concluded there was a potential adverse trend associated with Work Management. Specifically, the inspectors identified that the licensee did not implement the following aspects of the Work Management Process in the following instances:

• Effectively plan and execute work by incorporating risk insights, job site conditions and for coordination with different groups or job activities (CR 144243)

• Consider the impact of changes to the work scope and the need to keep personnel apprised of work status (CR 143812)

• Ensure individuals are aware of plant status, the nuclear safety risks associated with work in the field, and other parallel station activities (CR 144908)

• Coordinate work activities to address conflicting or changing priorities across the whole spectrum of activities contributing to nuclear safety, which includes emergent work activities (CR 141893)

Additionally, the inspectors identified the licensee also noted declining human performance, which resulted in the licensee performing a self-assessment, Gap to Excellence in Human Performance, (CR 144353) and a common cause evaluation, Organizational Performance Review of Site Events. (CR 142240). The licensee concluded the most probable cause was leaders and workers have not consistently implemented their roles and responsibilities as identified in the Human Performance program. Specifically, the licensee did not implement effective communications, there were gaps in procedure use and adherence, and failures to stop when unsure. The licensee implemented corrective actions for each of the gaps identified in the implementation of the Human Performance program. The corrective actions included re-enforcing the roles and responsibilities of the Human Performance program for leaders and workers and a Human Performance action plan focusing on error prevention tools (i.e., effective communication, procedure use and adherence, and self-checks). The inspectors concluded the licensee self-assessment and common cause evaluation did not identify the potential adverse trend in terms of work management, but the inspectors noted the licensees Nuclear Safety Culture subcommittee initiated CR 146284 identifying 12 examples associated with work management with respect to scheduling of maintenance activities. In response, the licensee assigned a corrective action to complete a formal trend analysis, scheduled to be completed in January 2021, to implement an appropriate corrective action plan.

EXIT MEETINGS AND DEBRIEFS

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

• On January 6, 2021, the inspectors presented the integrated inspection results to Mr. C. Reasoner, Chief Executive Officer and Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Calculations XX-M-052 Wolf Creek Tank Document Verifications 0

Corrective Action Condition Reports 024199

Documents

Corrective Action Condition Reports 145756, 145854, 145853

Documents

Resulting from

Inspection

Drawings M-12KJ01 Piping and Instrumentation Diagram Standby Diesel 14

Generator A Cooling Water System

M-13KJ03 Small Piping Isometric Standby Diesel System Lube Oil and 3

Jacket Water

Miscellaneous WCRE-01 WCNOC Total Plant Setpoint Document 94

WCRE-03 Tank Document 31

WCRE-34 Fourth 10-year Interval Inservice Testing Program 11

Procedures ALR 00-020D DG NE01 Trouble 10

ALR 00-095B DG RM A Sump LEV HI 10

ALR 501 Standby Diesel Engine System Control Panel KJ-121 30

AP 26C-004 Operability Determination and Functionality Assessment 41

STS KJ-005A Manual/Auto Start, Sync, and Loading of EDG NE01 69A

71111.05 Corrective Action Condition Reports 10000367, 10000161, 10000097

Documents

Miscellaneous Breach BAP 20-0300, BAP 20-0294

Authorization

Permit

E-1F9905 Fire Hazard Analysis 10

WCRE-35 Boundary Matrix 8

Procedures AP 10-103 Fire Protection Impairment Control 36

AP 10-104 Breach Authorization 39

AP 10-106 Fire Preplans 20

Work Orders 20-463920-002

71111.11Q Procedures AI 21-300 Flexible Power Operations 0

AP 21-001 Conduct of Operations 85

Inspection Type Designation Description or Title Revision or

Procedure Date

BD-EMG C-0 Loss of All AC Power 27

EMG C-0 Loss of All AC Power 44

EMG E-0 Reactor Trip or Safety Injection 42

GEN 00-004 Power Operation 95

71111.12 Corrective Action Condition Reports 134814, 135452, 138206, 137244, 137247, 002671, 135086,

Documents 145497, 145845

Drawings M-12KJ01 Piping & Instrumentation Diagram Standby Diesel Generator 13

A Cooling Water System

Miscellaneous E-025-00005 Instruction Manual for Limitorque Actuator Instructions and W06

Maintenance

SCA-91-0084

SCA-92-0143 0

WCRE-34 Fourth 10-Year Interval Inservice Testing Basis Document 11

Procedures AP 23-006 System Engineering Program 27A

AP 26C-004 Operability Determination and Functionality Assessment 41

MGE LT-008 Routine Electrical Limitorque Operator Maintenance 8A

MGE LT-100 Limitorque Valve Operator General Notes and Details 13

MPM KJ-004 Robertshaw Model 1285 Temperature Control Valve 3

MPM LT-001 Limitorque Operator Minor Maintenance, Lubrication, and 15

Inspection

SYS KJ-130 Removal and Restoration of EDG Support Systems 11

Work Orders 15-406452-000, 17-430103-000, 18-441495-000, 19-

455530-004, 19-454101-000, 19-450841-000, 19-450840-

000

71111.13 Corrective Action Condition Reports 10000223, 10000247

Documents

Procedures OFN SF-011 Realignment of Dropped, Misaligned Rod(s), and Rod 13

Control Malfunctions

STN SF-001 Control Rod Parking 21A

71111.15 Corrective Action Condition Reports 145356, 145358, 145667

Documents

Drawings E-11013 Installation, Inspection and Testing Details for Electrical 49

Equipment and Cables

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures MGE EOOP-05 Insulation Resistance Testing 27

Work Orders 19-456424-000

71111.18 Corrective Action Condition Reports 141893

Documents

Procedures AP 26A-002 Implementation and Revision of TS Bases, TRM, PTLR 2A

AP 26A-003 10 CFR 50.59 Reviews 14

AP 26B-001 Revisions to the Operating License and/or Technical 12

Specifications

GK-M-016 Wolf Creek Control Building Loss of Class 1E A/C GOTHIC 3

Room Heat Up Analysis with Installed Crosstie Fans and

Louvers

SYS GK-201 Mitigating Actions for Inoperable SGK05 Train 1

71111.19 Corrective Action Condition Reports 145678, 145639, 145662, 145668, 145634, 145633, 145632,

Documents 145708, 145703, 145912, 145940, 145962, 145963, 145964,

145969, 145903

Corrective Action Condition Reports 145715

Documents

Resulting from

Inspection

Miscellaneous M-018-00309 Instruction Manual for Emergency Diesel Generator System W139

Procedures AP 23E-001 Emergency Diesel Generator Reliability Program 8

CKL ZL-005A A EDG Operating Log 6A

MEC-038 Emergency Diesel Engine Injection Pump Replacement 3

MPM M018Q-01 Standby Diesel Generator Inspection 26A

STS KJ-005A Manual/Auto Start, Sync, and Loading of EDG NE01 69A

SYS KJ-123 Post Maintenance Run of Emergency Diesel Generator A 67A

SYS KJ-130 Removal and Restoration of EDG Support Systems 11

Work Orders 19-450868-001, 20-463519001-001, 19-452880006-001, 14-

396122-001, 14-396122-005, 20-466446-003, 19-454576-

000, 20-461902-000

71111.22 Corrective Action Condition Reports 144501, 145273, 145433, 145419, 024199, 145832, 146222

Documents

Corrective Action Condition Reports 145714, 145713, 146110, 10000593, 10000594, 10000598

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from

Inspection

Procedures AP 26C-004 Operability Determination and Functionality Assessment 41

AP 29G-001 RCS Unidentified Leak Rate Monitoring Program 6

OFN NB-042 Loss of Offsite Power to NB01 (NB02) with EDG Paralleled 15

STS BB-004 RCS Water Inventory Balance 51A

STS BB-006 RCS Water Inventory Balance Using the NPIS Computer 21

STS KJ-005A Manual/Auto Start, Sync, and Loading of EDG NE01 69A

STS KJ-005B Manual/Auto Start, Sync, and Loading of EDG NE02 65A

STS KJ-013A Hot Restart of EDG NE01 22

Work Orders 20-458467-000

71151 Corrective Action Condition Reports 145401

Documents

Miscellaneous WCNOC-163 Mitigating System Performance Index (MSPI) Basis 13

Document

71152 Corrective Action Condition Reports 133793, 141893, 144257, 141893, 136241, 144908, 144243,

Documents 144353, 144362, 142240, 146052, 146284

Corrective Action Condition Reports 145507, 10000597

Documents

Resulting from

Inspection

Drawings M-12EF02 Piping Instrumentation Diagram Essential Service Water 43

System

Procedures AI 28A-010 Screening Condition Reports 33

AI 28E-007 Corrective Action Coding and Trend Analysis 17

AP 28A-100 Corrective Action Program 25

AP 34-001 Human Performance 16A

SYS BM-127 Blowdown Flow Adjustments 15

SYS EF-300B ESW/Service Water Macrofoul Treatment for Train B 0A

2