ML14223B221

IR 05000482-14-003, on 03/29/2014 & 06/27/2014, Wolf Creek Generating Station, Integrated Resident and Regional Report; Maintenance Risk Assessments and Emergent Work Control

ML14223B221
Person / Time
Site:	Wolf Creek
Issue date:	08/11/2014
From:	O'Keefe N F NRC/RGN-IV/DRP/RPB-B
To:	Heflin A C Wolf Creek
C. Peabody
References
IR-14-003
Download: ML14223B221 (46)

See also: IR 05000482/2014003

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD. ARLINGTON, TX 76011-4511 August 11, 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 INTEGRATED INSPECTION REPORT 05000482/2014003 Dear Mr. Heflin: On June 27, 2014, the U.S. Nuclear Regulatory Commission completed an inspection at the Wolf Creek Generating Station. On July 8, 2014, the Nuclear Regulatory Commission inspectors 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. The Nuclear Regulatory Commission inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of Nuclear Regulatory

Commission requirements. The Nuclear Regulatory Commission is treating this violation as

non-cited violation consistent with Section 2.3.2.a of the Nuclear Regulatory Commission Enforcement Policy.

If you contest the violation or significance of the non-cited violation, you should provide a 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 Nuclear Regulatory Commission resident inspector at the Wolf Creek Generating Station.

If you disagree with the 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 Nuclear Regulatory Commission resident inspector at the Wolf Creek Generating Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your

response (if any) will be available electronically for public inspection in the NRC's Public

A. Heflin - 2 -

Document Room or from the Publicly Available Records component of the Nuclear Regulatory Commission Agencywide Documents Access and Management System. Agencywide Documents Access and Management System is accessible from the Nuclear Regulatory Commission Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely,

/RA/

Neil O'Keefe, Chief

Project Branch B Division of Reactor Projects

Docket Nos.: 50-482

License Nos: NPF-42

Enclosure: Inspection Report 05000482/2014003 w/Attachments 1. Supplemental Information

2. Public Radiation Safety Inspection Request

cc w/encl: Electronic Distribution to Wolf Creek Nuclear Operating Corporation

Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000482 License: NPF-42 Report: 05000482/2014003 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane NE Burlington, Kansas Dates: March 29 through June 27, 2014 Inspectors: C. Peabody, Senior Resident Inspector R. Stroble, Resident Inspector

L. Carson II, Senior Health Physicist

N. Greene, PhD, Health Physicist

P. Hernandez, Health Physicist J. O'Donnell, Health Physicist D. Proulx, Senior Project Engineer Approved By: Neil O'Keefe Chief, Project Branch B

Division of Reactor Projects

- 2 - SUMMARY IR 05000482/2014003; 03/29/2014 - 06/27/2014; Wolf Creek Generating Station, Integrated Resident and Regional Report; Maintenance Risk Assessments and Emergent Work Control.

The inspection activities described in this report were performed between March 29 and June 27, 2014, by the resident inspectors at Wolf Creek Generating Station and inspectors from

the Nuclear Regulatory Commission Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of Nuclear Regulatory Commission requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual

Chapter 0609, "Significance Determination Process." Their cross-cutting aspects are

determined using Inspection Manual Chapter 0310, "Components Within the Cross-Cutting

Areas." Violations of NRC requirements are dispositioned in accordance with the Nuclear Regulatory Commission Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process."

Findings No findings were identified.

Licensee Identified Findings

No findings were identified.

- 3 - PLANT STATUS Wolf Creek began the inspection period with the unit in Mode 5 (cold shutdown) for a planned

mid-cycle outage. On May 8, 2014, the reactor was restarted then promptly shut down due to a leaking steam generator bowl drain valve inside containment. On May 10, 2014, the reactor

was again restarted and promptly shut down due to a reactor coolant pump oil leak inside

containment. On May 13, 2014, the reactor was restarted successfully, reached 100 percent

power on May 15, 2014, and remained at that power level for the remainder of the inspection

period.

REPORT DETAILS 1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

Summer Readiness for Offsite and Alternate AC Power Systems a. Inspection Scope

On May 2, 2014, the inspectors completed an inspection of the station's off-site and

alternate-ac power systems. The inspectors inspected the material condition of these systems, including transformers and other switchyard equipment to verify that plant features and procedures were appropriate for operation and continued availability of off-

site and alternate-ac power systems. The inspectors reviewed outstanding work orders

and open condition reports for these systems. The inspectors walked down the switchyard to observe the material condition of equipment providing off-site power sources. The inspectors verified that the licensee's procedures included appropriate measures to monitor and maintain availability and reliability of the off-site and alternate-ac power systems.

These activities constituted one sample of summer readiness of off-site and alternate-ac

power systems, as defined in Inspection Procedure 71111.01. b. Findings

No findings were identified.

1R04 Equipment Alignment (71111.04)

Partial Walkdown a. Inspection Scope The inspectors performed partial system walk-downs of the following risk-significant systems:

• April 7, 2014, residual heat removal shutdown cooling train B

- 4 - * April 7, 2014, control room air conditioning system and control room emergency ventilation system train B * June 17, 2014, safety injection system train A The inspectors reviewed the licensee's procedures and system design information to

determine the correct lineup for the systems. They visually verified that critical portions of the systems or trains were correctly aligned for the existing plant configuration.

These activities constituted three partial system walk-down samples as defined in

Inspection Procedure 71111.04. b. Findings

No findings were identified. 1R05 Fire Protection (71111.05) .1 Quarterly Inspection a. Inspection Scope

The inspectors evaluated the licensee's fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:

• May 1, 2014, radiological controlled area and health physics office space * May 1, 2014, lower cable spreading room * May 7, 2014, upper cable spreading room * May 8, 2014, auxiliary feedwater pump room train A For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's fire protection program. The inspectors

evaluated control of transient combustibles and ignition sources, fire detection and

suppression systems, manual firefighting equipment and capability, passive fire

protection features, and compensatory measures for degraded conditions. These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05. b. Findings No findings were identified.

- 5 - .2 Annual Inspection a. Inspection Scope On June 27, 2014, the inspectors completed their annual evaluation of the licensee's fire

brigade performance. This evaluation included observation of an unannounced fire drill

for 2016, control building non-vital switchgear room B on June 27, 2014.

During this drill, the inspectors evaluated the capability of the fire brigade members, the leadership ability of the brigade leader, the brigade's use of turnout gear and fire-fighting equipment, and the effectiveness of the fire brigade's team operation. The inspectors

also reviewed whether the licensee's fire brigade met NRC requirements for training,

dedicated size and membership, and equipment.

These activities constituted one annual inspection sample, as defined in Inspection Procedure 71111.05. b. Findings No findings were identified. 1R11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11) Review of Licensed Operator Requalification a. Inspection Scope

On June 18, 2014, the inspectors evaluated a simulator scenario performed by an

operating crew. The inspectors assessed the performance of the operators and the evaluators' critique of their performance.

These activities constitute completion of one quarterly licensed operator requalification

program sample, as defined in Inspection Procedure 71111.11. b. Findings No findings were identified. 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) a. Inspection Scope

The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in

response to elevated risk:

• May 19-25, 2014, train A essential service water and emergency diesel generator planned maintenance outage

- 6 - * June 16-22, 2014, train B safety injection planned maintenance outage and train B containment spray planned maintenance outage The inspectors verified that these risk assessments were performed timely and in

accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensee's risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

The inspectors also observed portions of one emergent work activities that had the

potential to affect the functional capability of mitigating systems: * June 9-11, 2014, emergency diesel generator B governor testing failure and replacement

The inspectors verified that the licensee appropriately developed and followed a work

plan for these activities. The inspectors verified that the licensee took precautions to

minimize the impact of the work activities on unaffected structures, systems, and components (SSCs).

Additionally, the inspectors reviewed the risk assessments associated with two planned

maintenance activities performed during a time in the outage when the primary plant was

in a water-solid condition that resulted in unplanned pressure transients. * March 14, 2014, reactor coolant system pressure transient during bus switching * April 1, 2014, reactor coolant system pressure transient during motor-operated valve testing These activities constitute completion of four maintenance risk assessments and

emergent work control inspection samples, as defined in Inspection Procedure 71111.13. (Note: The March 14, 2014, sample was counted in Inspection Report 2014002).

b. Findings No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15) a. Inspection Scope

The inspectors reviewed four operability determinations that the licensee performed for

degraded or nonconforming SSCs:

• April 5, 2014, operability determination of train B emergency diesel generator heating, ventilation, and air conditioning inlet damper hydramotor oil analysis * April 23, 2014, operability determination of containment cooler corrosion extent of condition

- 7 - * May 19, 2014, operability determination of NB01 under voltage surveillance failure * June 11, 2014, operability determination of train B emergency diesel generator governor hydraulic actuator SKJ09B The inspectors reviewed the timeliness and technical adequacy of the licensee's evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensee's compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee

had considered the effect of other degraded conditions on the operability of the

degraded SSC. In the case of the containment cooler issues, the inspectors obtained the assistance of

specialist inspectors from the Region IV office and experts from the Office of Nuclear

Reactor Regulation. The NRC conducted several calls with licensee technical and

management personnel. Based on NRC concerns, the licensee decided to perform

hydrostatic testing of the remaining coolers to provide provide test data to support continued operabililty with continuing pitting corrosion. The inspectors observed one of the pressure tests and reviewed the revised operability determination.

These activities constitute completion of four operability review samples, as defined in

Inspection Procedure 71111.15. b. Findings

No findings were identified. 1R19 Post-Maintenance Testing (71111.19) a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected risk-

significant SSCs: * April 14, 2014, essential service water train A flow balance * April 15, 2014, emergency diesel generator train A jacket water leak * April 23, 2014, reactor coolant pump C bump test and break away torque * May 8, 2014, steam generator B bowl valve testing The inspectors reviewed licensing and design basis documents for the SSCs and the

maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

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

- 8 - b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities (71111.20) a. Inspection Scope

During the station's mid-cycle outage that concluded on May 13, 2014, the inspectors evaluated the licensee's outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions.

This verification included the following:

• Review of the licensee's outage plan prior to the outage * Monitoring of shut-down and cool-down activities * Verification that the licensee maintained defense-in-depth during outage activities * Monitoring of heat-up and startup activities These activities constitute completion of one planned outage sample outage activities

sample, as defined in Inspection Procedure 71111.20. b. Findings

No findings were identified. 1R22 Surveillance Testing (71111.22) a. Inspection Scope

The inspectors observed six risk-significant surveillance tests and reviewed test results

to verify that these tests adequately demonstrated that the SSCs were capable of

performing their safety functions: In-service tests:

• April 25, 2014, accumulator vent valve EPV0109 Reactor Coolant System Leak Detection:

• May 31, 2014, reactor coolant system water inventory balance Other surveillance tests: * March 28-29, 2014, train A engineered safety features actuating safety testing * April 25-28, 2014, station blackout diesel functional testing * May 6, 2014, containment closeout walkdown * May 19, 2014, reactor coolant system xenon-133 specific activity determination

- 9 - The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of

the test satisfied appropriate acceptance criteria. These activities constitute completion of six surveillance testing inspection samples, as

defined in Inspection Procedure 71111.22. b. Findings No findings were identified. Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

Emergency Preparedness Drill Observation a. Inspection Scope The inspectors observed an emergency preparedness drill on June 18, 2014, to verify the adequacy and capability of the licensee's assessment of drill performance. The

inspectors reviewed the drill scenario, observed the drill from the simulator and

emergency operations facility, and attended the post-drill critique. The inspectors

verified that the licensee's emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.

These activities constitute completion of one emergency preparedness drill observation

sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified. 2 RADIATION SAFETY Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation (71124.05)

a. Inspection Scope The inspectors evaluated the accuracy and operability of the radiation monitoring

equipment used by the licensee (1) to monitor areas, materials, and workers to ensure a

radiologically safe work environment, and (2) to detect and quantify radioactive process

streams and effluent releases. The inspectors interviewed licensee personnel, walked

down various portions of the plant, and reviewed licensee performance in the following areas:

- 10 - * Selected plant configurations and alignments of process, post-accident, and effluent monitors with descriptions in the Final Safety Analysis Report and the offsite dose calculation manual * Select instrumentation, including effluent monitoring instrument, portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks * Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air

samplers, and continuous air monitors * Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection These activities constitute completion of one sample of radiation monitoring

instrumentation as defined in Inspection Procedure 71124.05.

b. Findings No findings were identified. 2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

a. Inspection Scope The inspectors evaluated whether the licensee maintained gaseous and liquid effluent

processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal

radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensee's quality control program ensured radioactive effluent sampling and analysis adequately

quantified and evaluated discharges of radioactive materials. The inspectors verified the

adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed or observed the following items: * Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection * Effluent program implementing procedures, including sampling, monitor setpoint determinations, and dose calculations * Equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, and significant changes to their effluent release points, if any, and associated 10 CFR 50.59 reviews

- 11 - * Selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents (including sample collection and analysis) * Controls used to ensure representative sampling and appropriate compensatory sampling * Results of the inter-laboratory comparison program * Effluent stack flow rates * Surveillance test results of technical specification-required ventilation effluent discharge systems since the previous inspection * Significant changes in reported dose values * A selection of radioactive liquid and gaseous waste discharge permits * Part 61 analyses and methods used to determine which isotopes are included in the source term * Offsite dose calculation manual changes * Meteorological dispersion and deposition factors * Latest land use census * Records of abnormal gaseous or liquid tank discharges * Groundwater monitoring results * Changes to the licensee's written program for identifying and controlling contaminated spills/leaks to groundwater * Identified leakage or spill events and entries made into 10 CFR 50.75(g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term

• Offsite notifications and reports of events associated with spills, leaks, or groundwater monitoring results * Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection These activities constitute completion of one sample of radioactive gaseous and liquid

effluent treatment, as defined in Inspection Procedure 71124.06.

b. Findings No findings were identified.

- 12 - 2RS7 Radiological Environmental Monitoring Program (71124.07) a. Inspection Scope The inspectors evaluated whether the licensee's radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment and

sufficiently validated the integrity of the radioactive gaseous and liquid effluent release

program. The inspectors verified that the radiological environmental monitoring program

was implemented consistent with the licensee's technical specifications and offsite dose calculation manual, and that the radioactive effluent release program met the design objective in Appendix I to 10 CFR Part 50. The inspectors verified that the licensee's

radiological environmental monitoring program monitored non-effluent exposure pathways, was based on sound principles and assumptions, and validated that doses to

members of the public were within regulatory dose limits. The inspectors reviewed or observed the following items: * Annual environmental monitoring reports and offsite dose calculation manual * Selected air sampling and dosimeter monitoring stations * Collection and preparation of environmental samples * Operability, calibration, and maintenance of meteorological instruments * Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost dosimeter, or anomalous measurement * Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach ground water * Records required by 10 CFR 50.75(g) * Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection * Calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation * Inter-laboratory comparison program results * Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection These activities constitute completion of one sample of the radiological environmental monitoring program as defined in Inspection Procedure 71124.07.

- 13 - b. Findings No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (71124.08) a. Inspection Scope The inspectors evaluated the effectiveness of the licensee's programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed

licensee personnel and reviewed the following items:

• The solid radioactive waste system description, process control program, and the scope of the licensee's audit program * Control of radioactive waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition * Changes to the liquid and solid waste processing system configuration including a review of waste processing equipment that is not operational or abandoned in place * Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides * Processes for waste classification including use of scaling factors and 10 CFR Part 61 analysis * Shipment, packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest * Audits, self-assessments, reports, and corrective action reports on radioactive solid waste processing and radioactive material handling, storage, and transportation performed since the last inspection These activities constitute completion of one sample of radioactive solid waste

processing, and radioactive material handling, storage, and transportation as defined in Inspection Procedure 71124.08. b. Findings

No findings were identified. 4. OTHER ACTIVITIES Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Security

- 14 - 4OA1 Performance Indicator Verification (71151) .1 Reactor Coolant System Specific Activity (BI01) a. Inspection Scope The inspectors reviewed the licensee's reactor coolant system chemistry sample analyses for the period of April 1, 2013, through March 31, 2014, to verify the accuracy

and completeness of the reported data. The inspectors reviewed the surveillance paperwork for the reactor coolant system sample taken on May 19, 2014. The inspectors used definitions and guidance contained in Nuclear Energy Institute

Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7,

to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system specific activity performance indicator, as defined in Inspection Procedure 71151. b. Findings No findings were identified. .2 Reactor Coolant System Identified Leakage (BI02) a. Inspection Scope The inspectors reviewed the licensee's records of reactor coolant system identified leakage for the period of April 1, 2013 through March 31, 2014 to verify the accuracy and

completeness of the reported data. The inspectors reviewed the performance

of STS BB-006 "RCS Water Inventory Balance" on May 31, 2014. The inspectors used

definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system leakage

performance indicator, as defined in Inspection Procedure 71151. b. Findings

No findings were identified. 4OA2 Problem Identification and Resolution (71152)

.1 Routine Review a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensee's corrective action program and periodically attended the licensee's condition report screening meetings. The inspectors verified that licensee

personnel were identifying problems at an appropriate threshold and entering these

problems into the corrective action program for resolution. The inspectors verified that

- 15 - the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensee's

problem identification and resolution activities during the performance of the other inspection activities documented in this report. b. Findings

No findings were identified.

.2 Semiannual Trend Review a. Inspection Scope 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 reviewed corrective action program documentation associated with the following

licensee-identified trends:

• High backlogs in the design implementation and configuration control process area Also, the inspectors identified the following trends that might indicate the existence of a more significant safety issue, and reviewed the licensee's response to them:

• Inadequate technical verification and validation of temporary and permanent plant modifications * The licensee's corrective action program group is not trending data at a station-wide level (i.e., above the department level), nor are they prioritizing departmental issues and trends which are significantly affecting overall station

performance The NRC identified a theme in NRC inspection findings with cross-cutting aspects in maintaining design margins [H.6] during the 2013 End Of Cycle Assessment. The

inspectors reviewed the licensee's response to that trend to verify that the licensee was

taking appropriate actions to address it. These activities constitute completion of one semiannual trend review sample, as

defined in Inspection Procedure 71152.

b. Observations and Assessments The inspectors' review of the trends identified above produced the following observations

and assessments:

• Design Control Backlogs. In July of 2013, an industry group assessment of station performance noted an unusually high number of open design change packages. The backlog included approximately 1700 change packages, some

open since the early 1990s, including some SSCs with multiple open design changes. Some change packages had targeted completion dates that were

- 16 - beyond the expiration date of the plant operating license. Historically, the station has had challenges with design control, as noted in NRC inspection reports.

The licensee performed an apparent cause evaluation under Condition Reports 72164, 72166, and 72167 to identify the organizational causes. Among

the licensee's conclusions, management oversight of configuration control was

lacking, there was not an awareness of the vulnerability created by incomplete

configuration changes, and there was no single owner of design change products

to ensure configuration management documents are kept up to date. The licensee took corrective actions to develop a configuration management health plan to improve the design control program as well as developing a

comprehensive backlog reduction strategy. The inspectors also noted that the

licensee performed an aggregate risk assessment of the backlog to ensure that

items with more significant safety impacts were addressed more quickly. The inspectors also noted that the backlog reduction program has reduced the number of open change packages to 400 at the end of June 2014, with a goal of

less than 200 planned by January 2015.

• Findings with Design Margins Cross Cutting Aspect [H6]. A theme in findings with cross-cutting aspects in the area of maintaining design margins was identified during the NRC's 2013 End of Cycle Assessment for Wolf Creek. The licensee performed an apparent cause evaluation under Condition Reports 74508 and 78794. The inspectors noted that this trend was related to

the larger problem of backlog management. Because this trend is related to

other improvement efforts, the inspectors noted that the licensee has evaluated

and taken actions related to this theme in the areas of corrective action,

preventive maintenance, and procedure revision backlog reductions under Condition Reports 62394, 68194, and 78708. Most of the backlog improvement efforts were making a notable reduction. The inspectors observed that most

backlog reduction efforts remained on target through the mid-cycle 20 outage in

March and April of 2014. Overall outage management and scope control

performance improvement was observed, and as a result, the corrective action and work order backlogs did not see the growth observed during previous outages. The licensee has taken corrective actions to establish and validate new

internal performance indicators for the engineering and maintenance

departments. Furthermore the licensee has scheduled actions to track these

new indicators and backlogs to specific goals based on industry standards in the

future. Also, while completing this trend review, the inspectors identified the following trends

that the licensee had not previously identified. The inspectors also reviewed the

licensee's response to these trends:

• Quality of Plant Modifications. Over the past 2 years, Wolf Creek has been implementing a large number of modifications. Additional non-safety related diesel generators and an auxiliary feed water pump were added to improve plant safety. The plant has also been addressing long standing corrosion and water

hammer issues in the essential service water system by replacing piping above

and below ground. Obsolete analog controllers have been replaced with digital

control systems. However, the inspectors have observed a number of plant events and equipment failures associated with inadequate technical validation

- 17 - and verification associated with these modifications. On May 2, 2013, an unplanned and uncontrolled 11 percent power increase occurred as a result of operator training deficiencies while swapping from the full arc to partial arc steam admission shortly after

installing the new Westinghouse Ovation digital turbine controls. It was

subsequently determined that additional functions and flexibilities of the

new digital control system allowed operators to manipulate the plant in

configurations prohibited by the old analog system, and that system response varied with power level, but this was not recognized and incorporated into procedures and training. Condition Report 68711,

Non-Cited Violation NCV 05000482/2013003-05.

On May 28, 2013, and again on September 5, 2013, the turbine driven auxiliary feed water pump control system failed unexpectedly, rendering the pump incapable of operation. The digital control system positioner

locked up and required replacement. It was later determined that an

additional unused input to the positioner was experiencing noise, and if

the noise came in at a certain point in the digital computer program's subroutine, the control software would crash. The problem was fixed by jumpering out the unused input connection and a vendor technical bulletin

was issued to correct vulnerabilities at other nuclear power plants utilizing

the same control system. Condition Reports 69721, 69754, and 73624.

On April 25, 2014, during station blackout diesel generator testing, the licensee was unable to connect the train A Class 1E 4kV distribution bus to the station blackout diesel generators due to a protective relay

actuating to lock out the bus. The diesels had been declared functional

and were credited in performance indicators and probabilistic risk

assessment models since October 2013, when construction was completed but testing had not been fully completed. Troubleshooting as a result of the failed test found incorrect wiring of a protective relay to be

the cause. Extent of condition inspections found that the train B bus

connection was also wired incorrectly, and neither safety related bus

would have been able to have been powered from the station blackout

diesel generators. The licensee had intended to perform testing during the previous refueling outage, but construction delays caused work to extend beyond the outage. Plant conditions for this test necessitated the

plant be shut down. The inspectors had engaged the licensee concerning

their testing plan when construction was complete, but the licensee

concluded that their quality checks were adequate to have a high confidence that testing to connect the generators to the safety buses would be adequate until plant conditions for the testing were available.

The inspectors concluded that those quality checks were inadequate,

although this did not constitute a violation because the diesel generators

and protective relaying were non-safety equipment and were not credited

to meet any regulatory requirements. Condition Report 83379.

- 18 - Not all of the validation and verification oversights resulted in plant events or failures. Some of the items were caught very late in the planning process,

but still impacted regulatory commitments. In February of 2014 the licensee commitment to correct long standing water hammer conditions in the essential service water system was

delayed. The 2010 and 2012 Problem Identification and Resolution

inspections have assessed cited violations regarding long-standing

essential service water corrosion and water hammer issues not being addressed in a timely manner. Wolf Creek responded on the docket and committed to fixing the essential service water corrosion and water

hammer issues by the spring 2014 mid-cycle outage. However, after

over 3 years of planning, shortly before a modification was to be installed

to correct the water hammer, it was discovered that the mitigating strategy would invalidate the essential service water design basis safety function to provide a source of auxiliary feed water during a design basis external

event that compromises the condensate storage tank. This was

documented in Condition Reports 53443 and 79619. The licensee

concluded that there was inadequate contractor oversight during the modification development process. A revised modification was tentatively rescheduled for the next refueling outage.

On March 30, 2014, a containment cooler tube bundle failed (small tube leaks) as a result of water hammer during the engineered safety features

actuation system testing. A similar failure occurred when the opposite train was tested a few weeks later. While reviewing the cause evaluation, the inspectors noted the failure mechanism was due to a combination of

pitting corrosion and sudden pressure spike during the essential service

water system water hammer. The ispectors determined that corrective

actions to address corrosion in carbon steel essential service water piping had not addressed the copper-nickel containment cooler tubes. The inspectors reviewed the history of containment cooler degradation and

noted that all 48 of the tube bundles had already been replaced due to

widespread degradation in the late 1990s, and now the 2nd generation like-for-like replacements were beginning to fail. The problem was further

complicated because non-destructive testing to monitor corrosion was not possible because the cooler design and complex cooler geometry prevented this. The licensee plans to correct the condition by replacing

all coolers dueing the next outage, then replacing the original design with

stainless steel cooler tubes that will allow for eddy current testing.

Condition Reports 81809 and 82904. On November 18, 2011, an NRC Component Design Basis Inspection assessed NCV 05000482/2010007-01 for the failure to properly analyze

the isolation between the safety-related and non-safety related portions of

the component cooling water system. Portions of the non-safety piping

leading to the rad waste building are non-seismically qualified, and should they fail, could result in a loss of inventory greater than can be accommodated by the component cooling water surge tanks. The

inspector noted that the licensee promptly manually isolated this piping

and has been working on installing a combination of check valves and

- 19 - orifices, for the past four years. The planned modification to correct this violation has been delayed a number of times since 2012 because the

licensee has found problems with the design. Condition Reports 28237 and 85328.

The inspectors determined that the licensee was aware of these issues

individually, but had not identified the collective trend. The licensee wrote

Condition Report 85907 to evaluate and address this trend.

• Lack Trending and Prioritization above the Department Level. In reviewing the station roll-up reports that record corrective action program activities at the station and departmental levels, the inspectors noted that the analytical trending ends at the departmental summaries. The station corrective action staff was not

summarizing analytical trends across divisions, nor were they giving additional priority to departmental trends which were having a significant impact on station

performance. (e.g. design control, procedure quality, etc.) The inspectors reviewed additional documentation associated with station

improvement initiatives and determined that at a station level, senior leadership

was performing some station level trend analysis and setting station priorities

based on the available data, but this was being done outside the corrective action program, and was not proceduralized and therefore would not continue when the improvement initiatives were completed. The licensee has written

Condition Report 85905 to evaluate and address this issue.

The inspectors' assessment noted improved corrective action trending at the

department level. The operations department continues to be a station leader in this area. The maintenance and engineering departments have made notable advancements in the past year to improve the quality of their corrective action program work products. The inspectors have also witnessed a significant

improving trend in the quality, detail, and technical rigor, of apparent cause

evaluations and root cause analyses performed by station personnel. c. Findings No findings were identified.

.3 Annual Follow-up of Selected Issues a. Inspection Scope

The inspectors selected one issues for an in-depth follow-up:

• On May 1, 2014, below ground essential service water piping replacement to correct long standing corrosion issues. The inspectors assessed the licensee's problem identification threshold, cause

analyses, extent of condition reviews and compensatory actions. The inspectors

reviewed modifications paperwork and observed pipe fitting and welding activities

in the field. The inspectors verified that the licensee appropriately prioritized the

- 20 - planned corrective actions and that these actions were adequate to correct the condition. These activities constitute completion of one annual follow-up sample as defined in Inspection Procedure 71152.

b. Findings

No findings were identified. 4OA6 Meetings, Including Exit Exit Meeting Summary On June 5, 2014, the inspectors presented the results of the radiation safety inspection to Mr. C. Reasoner, Engineering, Vice President, and other members of the licensee staff. The

licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On July 8, 2014, the inspectors presented the inspection results to Mr. A. Heflin, Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged the issues

presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

Attachment 1 SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel

L. Aiken, Health Physicist II

D. Campbell, Superintendent, Electrical Maintenance

C. Carman, Supervisor, Chemistry S. Carpenter, Technician, Instruments and Controls B. Crow, System Engineering

D. Dees, Superintendent, Operations Support

D. Erbe, Manager, Security

R. Flannigan, Manager, Nuclear Engineering K. Fredrickson, Engineer, Licensing J. Freeman, Supervisor, Operations

C. Garcia, Supervisor, Engineering

D. Gibson, Technician, Radiation Protection

M. Guyer, Training R. Hammond, Supervisor, Regulatory Support A. Heflin, President and Chief Executive Officer

S. Henry, Manager, Integrated Plant Scheduling

P. Herrman, Manager, Programs Engineering

R. Hobby, Licensing Engineer

S. Hossain, Engineer, System Engineering B. Kiley, Technician III, Chemistry S. Koenig, Manager, Regulatory Affairs

R. Lane, Superintendent, Operations

M. McMullen, Design Engineer, Engineering

C. Medenciy, Supervisor, Radiation Protection K. Miller, Technician Level III, Instruments and Controls K. Mitchell, Master Chemistry Technician

W. Muilenburg, Supervisor, Licensing

T. Rice, Manager, Environmental Management

D. Scrogum, Systems Engineer, Engineering

M. Skiles, Acting Manager, Radiation Protection R. Smith, Site Vice President S. Smith, Plant Manager

T. Smith, Manager, Project Construction Engineering

J. Truelove, Supervisor, Chemistry

L. Upson, Manager, Strategic Initiatives B. Vickery, Manager, Financial Services J. Yunk, Manager, Corrective Actions

A1-2 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed 05000482-2014003-01 NCV Failure to Assess and Manage Risk of Planned Outage Maintenance Activities During Solid Plant Operations

(Section 1R13) LIST OF DOCUMENTS REVIEWED Section 1R01: Adverse Weather Protection Procedures Number Title Revision STS NB-005 Breaker Alignment Verification 26 Section 1R04: Equipment Alignment Procedures Number Title Date CKL EM-120 Safety Injection System Lineup Checklist September 17, 2014 Section 1R05: Fire Protection Procedures Number Title Revision AP 10-106 Fire Preplans 13 Section 1R11: Licensed Operator Requalification Program and Licensed Operator Performance Procedures Number Title Revision BD-EMG C-0 Loss of All AC Power 20 Section 1R13: Maintenance Risk Assessments and Emergent Work Control Procedures Number Title Revision/DateAI 22C-013 Protected Equipment Program 11

A1-3 Procedures Number Title Revision/DateAP 22B-001 Outage Risk Management 17 AP 21D-002 Evaluation for Potential Energy/Fluid Transfer Paths 11A APF 22B-001-10 Shutdown Safety Function Status and Risk Assessment Summary March 14, 2014 Night

Shift APF 22B-001-10 Shutdown Safety Function Status and Risk Assessment Summary April 1, 2014 Day Shift APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment, Schedule Week 2014-0211 May 28, 2014APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment Schedule Week 2014-0212 June 11, 2014 SYS PG-204 Energizing PG19 or PG20 from Alternate Power Source 21 TMP 14-002 CCW Train B Operations with Heat Exchanger Bypassed 0 Condition Reports 80870 81981

Work Order 12-359936-000 12-359637-000

Miscellaneous Number Title Revision/Date ODM 2014-05 Operations Decision Making Documentation Form: Wolf Creek will maintain solid pressurizer conditions with reduced

temperature and pressure control bands. 0 APF 22C-007 Shutdown Safety Contingency Planning Template: Decay Heat Removal Defense in Depth 1 M-EJ-A-001 Clearance Order: RHR to CVCS Centrifugal Charging Pumps Isolation Valve April 2, 2014 Work Week Manager Logs Control Room Logs

Weekly Major Activity Summary Week 2014-208 Weekly Major Activity Summary Week 2014-211 Weekly Major Activity Summary Week 2014-212

A1-4 Miscellaneous Number Title Revision/Date Wolf Creek Shift Outage Update March 13, 2014 Day Shift Section 1R15: Operability Determinations and Functionality Assessments Procedures Number Title Revision OE K-14-009 B-EDG Governor Hydraulic Actuator 0 STS IC-208A 4kV Loss of Voltage and Degraded Voltage TADOT NB01 Bus - Separation Group 1 5B Condition Reports 85015 81809 82266 84318

Engineering Disposition Title Revision Containment Cooler Tube Pitting 1 Section 1R19: Post-Maintenance Testing Procedures Number Title Revision/Date STN EF-220A ESW Train A Post-LOCA Flow Balance March 4, 2014 SYS BB-201 Reactor Coolant Pump Operation 58

SYS KJ-123-2 Post Maintenance Run of EDG A January 30, 2014 Work Orders 14-385808-006 11-347436-002 14-387407-002 14-386517-001

A1-5 Section 1R20: Refueling and Other Outage Activities Procedures Number Title Date NE 14-0005 Mid-Cycle 20 Level 1 Schedule and Outage Risk Assessment Report February 6, 2014 Section 1R22: Surveillance Testing Procedures Number Title Revision/Date STS BB-006 RCS Water Inventory Balance Using the NPIS Computer 12

STS CH-024 Reactor Coolant Dose Equivalent Xe-133 Determination 6A

STS IC-208A 4kv Loss of Voltage and Degraded Voltage TADOT NB01 Bus - Separation Group 1 5B STS KJ-001A Integrated D/G and Safeguards Actuation Text Train A March 14, 2014 STN KU-001A SBO DG NB01 Functional Test March 28, 2014

STN EJ-002 Containment Inspection 20 Section 2RS5: Radiation Monitoring Instrumentation Procedures Number Title Revision/DateCHS AC-001 Accident Sampling 4A WCIC-236 RMS Calibration Document November 13, 1995 STN SP-118 Channel Calibration Liquid Radwaste Discharge Radiation Monitor HB RE-0018 8 STN CH-010 Calibration of Liquid Radiation Monitors 3B STS CH-014 Calibration of Monitors GTRE21B and GHRE10B 12

STN CH-021 Calibration of the Particulate Detector for Radiation Monitors GTRE21A and GHRE10A 4A STN CH-022 Calibration of the Iodine Detector for Radiation Monitors GTRE21A and GHRE10B 1B AP 07B-003 Offsite Dose Calculation Model 8 RPP 01-405 HP Instrument Program 30

A1-6 Procedures Number Title Revision/DateRPP 03-407 Testing of Portal Monitors as Passive Whole Body Counters 1A RPP 05-707 Operation of Whole Body Counters 8 RPP 06-101 Eberline RO-2 and RO-2A Calibration 6

RPP 06-105 Eberline RO-20 Calibration 5

RPP 06-306 PM12 Calibration 8A

STN SP-118 Channel Calibration Liquid Radwaste Discharge Radiation Monitor HB RE-0018 8 STN CH-010 Calibration of Liquid Radiation Monitors 3B Condition Reports 00081759 00084854 00084863 00084815 00084820 00084817 00083254 00082997 00080994 00079621 00078962 00078548 00074873 00074445 00074219

00072691 00072303 00068426 00068295 00068064

00051785 00054489 00065431 00067627 00062921

Calibration Records Number Title Date WO12360791000 Channel Calibration Digital High Range Area Monitor GTRE-0059 Calibration Source Drop February 4, 2014 WO13381072000 Channel Calibration Digital High Range Area Radiation Monitor GTRE60 January 28, 2014 WO12360792000 Channel Calibration Digital High Range Area Radiation Monitor GTRE60 Calibration Source Drop February 3, 2014 WO13381018000 Channel Calibration Digital High Range Area Radiation Monitor GTRE59 January 24, 2014 11428 AMS4 March 9, 2014 11748 AMS4 March 9, 2014 11429 AMS4 February 24, 2014

A1-7 11376 PCM-1B February 5, 2009 11379 PCM-1B February 5, 2009 11378 PCM-1B April 17, 2014

10240 PCM-1C April 9, 2009

11005 SAM 11 January 29, 2014 11006 SAM 11 June 19, 2013 92874 RTM 110 March 23, 2014 92877 RTM 110 April 28, 2014

10260 ASP-1 February 6, 2014 93330 PM12 August 15, 2013 93573 PM12 February 5, 2014 11511 HD-29A January 29, 2014 10242 PCM-2 December 9, 2013 10066 Whole Body Counter Calibration Certificate July 18, 2011

13027 Whole Body Counter Calibration Certificate September 15, 2008 Section 2RS6: Radioactive Gaseous and Liquid Effluent Treatment Procedures Number Title Revision AI 07-007 Onsite Groundwater Protection Program Monitoring 14 AI 07B-001 Radioactive Releases 19 AI 07B-020 Instructions for Composite Preparation 19

AI 07B-036 Liquid Release Permits Using RADEAS 01

AI 07B-037 Unit and Radwaste Vent Permits Using RADEAS 01

AI 07B-038 Unit and Radwaste Vent Permits Using RADEAS 01

A1-8 Procedures Number Title Revision AP 07B-003 Offsite Dose Calculation Manual 08 CHA RC-004 Gamma Isotopic, Total Curie Content and Dose Equivalent Iodine Determination 15 CHS RW-G02 Radwaste Vent Sampling and/or Exchange of Filters 3C CHS SJ-144A SJ-144 Sampling Instructions 0C

CHS TB-L03 Turbine Building Local Sampling - Mid-Frequency 06

RPP 07-111 Handling Cartridge Filters 17 Condition Reports 00051966 00053930 00055466 00055535 00055538 00056233 00056574 00056887 00059243 00059832 00061757 00064627 00064667 00064798 00065779 00066655 00066920 00068803 00069832 00069959

00070420 00070826 00072303 00076226 00077621

00077802 00078707 00082909 00083740 00084346 10 CFR 50.75(g) Condition Reports 00084942

Gaseous and Liquid Release Permits Permit No. System Release Type Date U1LC2014-080/2013060 Turbine Building Drains Liquid June 11, 2013 U1GB2014-093/2013081 Containment Purge Unit Vent Gaseous July 17, 2013

U1GB2014-099/2013087 Containment Purge Unit Vent Gaseous July 27, 2013

U1LC2014-091/2013071 Steam Generator Blowdown Liquid August 30, 2013

U1LC2014-110/2013090 Lime Sludge Pond Liquid November 19, 2013

U1GB2014-017/2014017 Containment Purge Unit Vent Gaseous February 4, 2014 U1LC2014-005/2014005 Steam Generator Blowdown Liquid March 1, 2014 U1GB2014-162/2014162 Containment Purge Unit Vent Gaseous April 7, 2014

A1-9 In-Place Filter Testing Records Work Order Test Date STS PE-006 Charcoal Adsorber In-Place Leak Test Safety-Related Units - FGK01B December 10, 2013 STS PE-005 HEPA Filter In-Place Leak Test Safety-Related Units - FGK01B December 10, 2013 STS PE-002 Charcoal Adsorbent Sampling for Nuclear Safety-Related Units - FGK01B December 23, 2013 STS PE-002 Charcoal Adsorbent Sampling for Nuclear Safety-Related Units - FGG02B December 23, 2013 STS PE-006 Charcoal Adsorber In-Place Leak Test Safety-Related Units - FGK01A February 24, 2014 STS PE-005 HEPA Filter In-Place Leak Test Safety-Related Units - FGK01A February 24, 2014 Miscellaneous Documents Number Title Revision/Date 11.1A-3 USAR Figure: Potential Gaseous Release 13

M-12HB01-5 WCNOC PID: Liquid Radwaste System 20 M-12EG01 WCNOC PID: Component Cooling Water System 24

System Health Report: Radiation Monitoring January 1 - September

30, 2013 RA 13-0052 WCNOC 2013 Annual Radioactive Effluent Release Report RPF 02-210-05 50.75(g) Radiological Occurrence Worksheet for Decommissioning Record June 2, 2014 2013-011-EG00 Temporary Modification Order: EG System (A/B Trains), EGV0357 & EGV0310, EGV0324 & EGV0388 August 19, 2013 RA 14-0043 WCNOC 2014 Annual Radioactive Effluent Release Report April 29, 2014 WC Radiation Monitors Considered for Maintenance Rule June 2, 2014 Section 2RS7: Radiological Environmental Monitoring Program Procedures Number Title Revision AI 07B-004 Reporting Requirements of the Radiological Environmental Monitoring Program 13

A1-10 Procedures Number Title Revision AI 07B-005 Radiological Environmental Monitoring Program Implementation 20 AI 07B-009 Collection, Preparation and Shipment of Sediment and Soil Samples 8 AI 07B-011 Collection, Preparation and Shipment of Water Samples 15 AI 07B-012 Collection, Preparation and Shipment of Crop, Vegetable, Fruit and Pasturage Samples 10 AI 07B-015 Land Use Census 11 AI 07B-034 Radiological Environmental Monitoring Program Air Sampling 11 AI 07B-035 REMP Optically Stimulated Luminescence (OSL) Dosimeters 6 AP 07B-003 Offsite Dose Calculation Manual 8 AP 07B-004 Offsite Dose Calculation Manual (Radiological Environmental Monitoring Program) 20 AP 07B-005 Ground Water Protection Program 3 AP 07E-001 Validation of Meteorological Data 3

STN CH-024 Quarterly/Yearly Dose Projections 3

STS IC-890A Channel Calibration of Wind Speed Meteorological Instrumentation 17 STS IC-890B Channel Calibration of Wind Direction/Deviation Meteorological Instrumentation 17 STS IC-890C Channel Calibration of 10M/60M Ambient and Differential Temperature Instrumentation 20 STS IC-890D Channel Calibration of Sonic Wind Speed/Direction/Deviation Meteorological Instrumentation 2 Audits, Self-Assessments, and Surveillances Number Title Date QH-2013-0654 NUPIC Audit Report of Landauer, Inc. December 16, 2013 11-2049 Evaluation Report of F&J Specialty Products, Inc. January 13, 2013 SQL 13-44 Evaluation Report of Landauer, Inc. - Glenwood, IL October 11, 2013 QH-2013-0660 Ground Water Protective Initiative 5-Year Follow-up Assessment December 16, 2013

A1-11 Audits, Self-Assessments, and Surveillances Number Title Date Audit Report No: 14-03-ENV Quality Assurance Audit Report of Environmental Management Plans April 17, 2014 Condition Reports 00051888 00052766 00054626 00070866 00082043 00083302 00084016 00084879 00084901 00084915 00084919 00084920 Calibration And Maintenance Records Number Title Date WO 13-375743 Surveillance Test Routing Sheet: Channel Calibration of 60m 10m Differential Temperature April 20, 2014 WO 13-375744 Surveillance Test Routing Sheet: Channel Calibration of Wind Speed April 6, 2014 WO 13-375741 Surveillance Test Routing Sheet: Channel Calibration of Wind Direction April10, 2014 WO 13-375742 Surveillance Test Channel Calibration of Sonic Wind Speed/Direction/Deviation April 6, 2014 Miscellaneous Documents Number Title Date SA-10-004 Relative Deposition per Unit Area (D/Q) 3 Year Update (2007-2009) November 2, 2010 2012 Annual Radiological Environmental Operating Report April 27, 2013 2013 Annual Radiological Environmental Operating Report April 15, 2012 QH-2011-0016 REMP Review of 2010 Wind Direction August 31, 2011 QH-2012-0242 REMP Review of 2011 Wind Direction July 30, 2012

QH-2013-0016 REMP Review of 2012 Wind Direction August 14, 2011

A1-12 Section 2RS8: Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Procedures Number Title Revisions AP 31A-100 Solid Radwaste Process Control Program 7 and 8 RPP 07-110 Solid Radwaste Packaging 9

RPP 07-111 Handling Filter Cartridges 17 and 18

RPP 07-112 Processing Cartridge Filters 5 RPP 07-131 Bead Resin/Activated Carbon Dewatering Procedures for CNSI 14-215 or Smaller Liners 4 RPP 07-212 Requirements of Radioactive Materials Stored Outdoors 0

Audits and Self-Assessments Number Title Date QS-2014-0629 Quality Surveillance performed on the Radwaste Group by WCNOC and Tech Specialist from Nine Mile Point February 26, 2014 Condition Reports 00051881 00056346 00056839 00062522 00066895 00066920 00073358 00079817 00081750 00081752

00084772 00084856 00084857 00084880 00084932

00084951

Radiation Work Permits Number Title Revision 13-0121 ALARA Review Package 1 130121 Cartridge Filter Change-out 000 130121 Cartridge Filter Change-out 001

130121 Cartridge Filter Change-out 002

140029 Resin Transfer to Primary Spent Resin Storage Tank (THC08) 000

A1-13 Radioactive Material Shipments Number Title Revision 12R26 Radioactive Material LSA-I; UN 2912 1 13R30 Radioactive Material LSA-II; UN 3321 000 13R49 Radioactive Material LSA-II; UN 3321 001

14R18 Radioactive Material LSA-II; UN 3321 002

12R26 Radioactive Material LSA-I; UN 2912 000

Radioactive Waste Stream Characterization Number Title Date 7 Primary Resin (CVCS, SFP) April 15, 2013

7 Primary Resin (CVCS, SFP) January 23, 2014 13 Dry Active Waste April 19, 2012 13 Dry Active Waste March 4, 2014

Miscellaneous Documents Number Title Date Access Control Shift Log (01:25 to 17:39) April 1, 2013 Filter Characterization Reports (13F044, 13F046, 13F047, 13F048, 13F049, 13F051, 13F052, 13F053, 13F055, 13F058, 13F059, 13F060, 13F061, 13F097) August 20, 2013 13-063ES Characterization and Classification of Wolf Creek Excore Detectors May 31, 2013 36 Annual Radioactive Effluent Release Report January 1, 2012 - December 31, 2012 37 Annual Radioactive Effluent Release Report January 1, 2013 -

December 31,

2013 HW1215801 Training Course Regulations and Requirements January 11, 2010 OTSC 13-0056 On the Spot Change to RPP 07-111 Rev 17 April 3, 2013

A1-14 Miscellaneous Documents Number Title Date RPF 07-111-01 Filter Information Log April 3, 2014 RPF 07-123-01 Radioactive Shipment Log 2012 RPF 07-123-01 Radioactive Shipment Log 2013 RPF 07-123-01 Radioactive Shipment Log 2014

Section 4OA2: Problem Identification and Resolution Procedures Number Title Revision AP 05-005 Design, Implementation, and Configuration Control of Modifications 20 AP 05-010 Design Drawings 9 AP 05F-001 Design Verification 3A Condition Reports 79619 53443 82904 70384 70383 69721 69754 73624 71624 74508 78794 72166 72164 72167 68194 62394 78708

Miscellaneous Number Title Revision/Date WM 14-0011 Letter from Wolf Creek Nuclear Operating Corp. to U.S.NRC: Docket No. 50-482: Change to Essential Service Water System Water Hammer Mitigation Commitment May 8, 2014 WM 14-0013 Letter from Wolf Creek Nuclear Operating Corp. to U.S.NRC: Docket No. 50-482: Voluntary Commitment Regarding

Containment Coolers at Wolf Creek Generating Station May 8, 2014

A1-15 Miscellaneous Number Title Revision/Date Wolf Creek Corrective Action Program Station Roll-Up Performance Results 4th Quarter 2013 March 6, 2014 Wolf Creek Corrective Action Program Station Roll-Up Performance Results 1st Quarter 2014 June 6, 2014 Wolf Creek Rebuilding Plan June 6, 2014 Engineering Excellence Plan - Product Quality Strategic Area 00

Wolf Creek Change Management Plan - Engineering Technical Rigor Improvement September 5, 2013

Attachment 2 The following items are requested for the Public Radiation Safety Inspection Wolf Creek Generating Station June 2 through June 6, 2014 Integrated Report 2014003 Inspection areas are listed in the attachments below. Please provide the requested information on or before May 19, 2014. Please submit this information using the same lettering system as below. For example,

all contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled "1- A," applicable organization charts in file/folder "1- B," updated final safety analysis report If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the inspectors will have access to the information while writing the report. In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting. The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found. If you have any questions or comments, please contact Louis Carson at (817) 200-1221 or

Louis.Carson@nrc.gov. PAPERWORK REDUCTION ACT STATEMENT This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0011.

A2-2 5. Radiation Monitoring Instrumentation (71124.05) Date of Last Inspection: April 23, 2012 A. List of contacts and telephone numbers for the following areas: 1. Effluent monitor calibration

2. Radiation protection instrument calibration

3. Installed instrument calibrations

4. Count room and Laboratory instrument calibrations B. Applicable organization charts C. Copies of audits, self-assessments, vendor or Nuclear Procurement Issues Committee (NUPIC) audits for contractor support and licensee event reports (LERs), written since

date of last inspection, related to:

1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey instruments, electronic dosimeters, teledosimetry, personnel contamination monitors, or whole body counters 2. Installed radiation monitors D. Procedure index for: 1. Calibration, use and operation of continuous air monitors, criticality monitors, portable survey instruments, temporary area radiation monitors, electronic

dosimeters, teledosimetry, personnel contamination monitors, and whole body counters 2. Calibration of installed radiation monitors E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes. 1. Calibration of portable radiation detection instruments (for portable ion chambers) 2. Whole body counter calibration

3. Laboratory instrumentation quality control F. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection, related to the following programs: 1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey instruments, electronic dosimeters, teledosimetry, personnel contamination monitors, whole body counters 2. Installed radiation monitors

3. Effluent radiation monitors

4. Count room radiation instruments NOTE: The lists should indicate the significance level of each issue and the search criteria used. Please provide in document formats which are "searchable" so that the inspector can perform word searches. G. Offsite dose calculation manual, technical requirements manual, or licensee controlled specifications which lists the effluent monitors and calibration requirements H. Current calibration data for the whole body counters I. Primary to secondary source calibration correlation for effluent monitors

J. A list of the point of discharge effluent monitors with the two most recent calibration dates and the work order numbers associated with the calibrations K. Radiation Monitoring System health report for the previous 12 months

A2-3 6. Radioactive Gaseous and Liquid Effluent Treatment (71124.06) Date of Last Inspection: April 23, 2012 A. List of contacts and telephone numbers for the following areas: 1. Radiological effluent control

2. Engineered safety feature air cleaning systems B. Applicable organization charts C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection, related to: 1. Radioactive effluents

2. Engineered Safety Feature Air cleaning systems D. Procedure indexes for the following areas 1. Radioactive effluents 2. Engineered Safety Feature Air cleaning systems E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Sampling of radioactive effluents 2. Sample analysis 3. Generating radioactive effluent release permits

4. Laboratory instrumentation quality control

5. In-place testing of HEPA filters and charcoal adsorbers

6. New or applicable procedures for effluent programs (e.g., including ground water monitoring programs) F. List of corrective action documents (including corporate and subtiered systems) written since date of last inspection, associated with:

1. Radioactive effluents

2. Effluent radiation monitors

3. Engineered Safety Feature Air cleaning systems NOTE: The lists should indicate the significance level of each issue and the search criteria used. Please provide in document formats which are "searchable" so that the inspector can perform word searches. G. 2012 and 2013 Annual Radioactive Effluent Release Report, or the two most recent reports. H. Current Copy of the Offsite Dose Calculation Manual I. Copy of the 2012 and 2013 interlaboratory comparison results for laboratory quality control performance of effluent sample analysis, or the two most recent results. J. Effluent sampling schedule for the week of the inspection

K. New entries into 10 CFR 50.75(g) files since date of last inspection L. Operations department (or other responsible department) log records for effluent monitors removed from service or out of service M. Listing or log of liquid and gaseous release permits since date of last inspection

A2-4 N. A list of the technical specification-required air cleaning systems with the two most recent surveillance test dates of in-place filter testing (of HEPA filters and charcoal

adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers associated with the surveillances O. System Health Report. Moreover, please provide a specific list of all effluent radiation monitors that were considered inoperable for 7 days or more since November 2011.

If applicable, please provide the relative Special Report and condition report(s). P. A list of all radiation monitors that are considered §50.65/Maintenance Rule equipment

Q. A list of all significant changes made to the Gaseous and Liquid Effluent Process Monitoring System since the last inspection. If applicable, please provide the corresponding updated final safety analysis report (UFSAR) section in which this change

was documented. R. A list of any occurrences in which a non-radioactive system was contaminated by a radioactive system. Please include any relative condition report(s).

A2-5 7. Radiological Environmental Monitoring Program (71124.07) Date of Last Inspection: April 23, 2012 A. List of contacts and telephone numbers for the following areas: 1. Radiological environmental monitoring 2. Meteorological monitoring B. Applicable organization charts

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection, related to: 1. Radiological environmental monitoring program (including contractor environmental laboratory audits, if used to perform environmental program functions) 2. Environmental TLD processing facility

3. Meteorological monitoring program D. Procedure index for the following areas: 1. Radiological environmental monitoring program 2. Meteorological monitoring program E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Environmental Program Description 2. Sampling, collection, and preparation of environmental samples 3. Sample analysis (if applicable)

4. Laboratory instrumentation quality control

5. Procedures associated with the Offsite Dose Calculation Manual

6. Appropriate QA Audit and program procedures, and/or sections of the station's QA manual (which pertain to the REMP) F. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection, related to the following programs: 1. Radiological environmental monitoring

2. Meteorological monitoring NOTE: The lists should indicate the significance level of each issue and the search criteria used. Please provide in document formats which are "searchable" so that the inspector can perform word searches. G. Wind Rose data and evaluations used for establishing environmental sampling locations H. Copies of the 2 most recent calibration packages for the meteorological tower instruments I. Copy of the 2012 and 2013 Annual Radiological Environmental Operating Report and Land Use Census, and current revision of the Offsite Dose Calculation Manual, or the two most recent reports. J. Copy of the environmental laboratory's interlaboratory comparison program results for 2012 and 2013, or the two most recent results, if not included in the annual radiological

environmental operating report K. Data from the environmental laboratory documenting the analytical detection sensitivities for the various environmental sample media (i.e., air, water, soil, vegetation, and milk) L. Quality Assurance audits (e.g., NUPIC) for contracted services

A2-6 M. Current NEI Groundwater Initiative Plan and status N. Technical requirements manual or licensee controlled specifications which lists the meteorological instruments calibration requirements O. A list of Regulatory Guides and/or NUREGs that you are currently committed to relative to the Radiological Environmental Monitoring Program. Please include the revision

and/or date for the committed item and where this can be located in your current

licensing basis/UFSAR. P. If applicable, per NEI 07-07, provide any reports that document any spills/leaks to groundwater since the last inspection.

A2-7 8. Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation (71124.08) Date of Last Inspection: April 23, 2012 A. List of contacts and telephone numbers for the following areas: 1. Solid Radioactive waste processing

2. Transportation of radioactive material/waste B. Applicable organization charts (and list of personnel involved in solid radwaste processing, transferring, and transportation of radioactive waste/materials) C. Copies of audits, department self-assessments, and LERs written since date of last inspection related to: 1. Solid radioactive waste management

2. Radioactive material/waste transportation program D. Procedure index for the following areas: 1. Solid radioactive waste management 2. Radioactive material/waste transportation E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Process control program 2. Solid and liquid radioactive waste processing 3. Radioactive material/waste shipping

4. Methodology used for waste concentration averaging, if applicable

5. Waste stream sampling and analysis F. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection related to: 1. Solid radioactive waste 2. Transportation of radioactive material/waste

NOTE: The lists should indicate the significance level of each issue and the search criteria used. Please provide in document formats which are "searchable" so that the inspector can perform word searches. G. Copies of training lesson plans for 49CFR172, subpart H, for radwaste processing, packaging, and shipping. H. A summary of radioactive material and radioactive waste shipments made from date of last inspection to present I. Waste stream sample analyses results and resulting scaling factors for 2012 and 2013, or the two most recent results. J. Waste classification reports if performed by vendors (such as for irradiated hardware)

K. A listing of all onsite radwaste storage facilities. Please include a summary or listing of the items stored in each facility, including the total amount of radioactivity and the highest general area dose rate. Although it is not necessary to compile the following information, the inspector will also review:

L. Training, and qualifications records of personnel responsible for the conduct of radioactive waste processing, package preparation, and shipping

ML14223B221 SUNSI Review By: NFO ADAMS Yes No Non-Sensitive Sensitive Publicly Available Non-Publicly Available Keyword NRC-002 OFFICE SRI:DRP/B RI:DRP/B C:DRS/TSB C:DRS/EB1 C:DRS/EB2 NAME CPeabody/tk RStroble GMiller TFarnholtz JDixon SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ DATE 7/23/14 8/11/14 8/8/14 8/6/14 8/6/14 OFFICE C:DRS/OB C:DRS/PSB1 C:DRS/PSB2 BC:DRP/B NAME VGaddy MHaire HGepford NOKeeefe SIGNATURE /RA/ /RA/ /RA/ /RA/ DATE 8/6/14 8/8/14 8/8/14 8/11/14

Letter to Adam Heflin from Neil O'Keefe, dated August 11, 2014

SUBJECT: WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000482/2014003

DISTRIBUTION: Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

Acting DRP Director (Troy.Pruett@nrc.gov) Acting DRP Deputy Director (Michael.Hay@nrc.gov) DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Charles.Peabody@nrc.gov)

Resident Inspector (Raja.Stroble@nrc.gov) WC Administrative Assistant (Carey.Spoon@nrc.gov) Branch Chief, DRP/B (Neil.OKeefe@nrc.gov)

Senior Project Engineer, DRP/B (David.Proulx@nrc.gov)

Project Engineer, DRP/B (Fabian.Thomas@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov) Public Affairs Officer (Lara.Uselding@nrc.gov) Project Manager (Fred.Lyon@nrc.gov)

Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov) Technical Support Assistant (Loretta.Williams@nrc.gov) Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV/ETA: OEDO (Anthony.Bowers@nrc.gov)

ROPreports