Text

NRC Integrated Inspection Report 05000482/2018001
	ML18131A017
Person / Time
Site:	Wolf Creek
Issue date:	05/14/2018
From:	Nick Taylor; NRC/RGN-IV/DRP/RPB-B
To:	Heflin A; Wolf Creek
	Taylor N
References
	IR 2018001
	Download: ML18131A017 (32)
	v • d • e

SUBJECT:

WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000482/2018001

Dear Mr. Heflin:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Wolf Creek Generating Station. On April 25, 2018, the NRC inspectors discussed the results of this inspection with Mr. C. Reasoner, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance of this 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; and the NRC resident inspector at the Wolf Creek Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Wolf Creek Generating Station. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects Docket No. 50-482 License No. NPF-42 Enclosure:

Inspection Report 05000482/2018001 w/ Attachments:

1. Supplemental Information 2. Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000482 License Number: NPF-42 Report Number: 05000482/2018001 Enterprise Identifier: I-2018-001-0012 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane NE Burlington, KS 66839 Inspection Dates: January 1, 2018, to March 31, 2018 Inspectors: D. Dodson, Senior Resident Inspector F. Thomas, Resident Inspector D. Bradley, Senior Resident Inspector, Callaway Approved By: N. Taylor, Chief, Project Branch B, Division of Reactor Projects 1 Enclosure

SUMMARY

The 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. NRC-identified and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations Inadequate Functionality Assessment Associated with the Emergency Excess Letdown Flowpath Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Green [H.14] - Human 71111.15 -

Systems NCV 05000482/2018001-01 Performance, Operability Closed Conservative Bias Determinations and Functionality Assessments The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to adequately implement the operability determination and functionality assessment procedure.

Specifically, the licensee failed to document a functionality assessment of sufficient scope to address the capability of a safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and the excess letdown system to perform their specified safety functions, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional.

PLANT STATUS

Wolf Creek Generating Station began the inspection period at rated thermal power. On March 30, 2018, a plant shutdown was completed to begin Refueling Outage

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 performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

REACTOR SAFETY

71111.01 - Adverse Weather Protection Impending Severe Weather

Main article: IP 71111.01

The inspectors evaluated readiness for impending adverse weather conditions for extreme low temperatures on January 2 and 3, 2018.

71111.04 - Equipment Alignment Partial Walkdown

Main article: IP 71111.04

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

(1) turbine-driven auxiliary feedwater train on February 6, 2018

(2) residual heat removal pump B on March 21, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the component cooling water system on February 23, 2018.

71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection

Main article: IP 71111.05AQ

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) fire area A-16, general area, elevation 2,026 feet on January 30, and March 28, 2018

(2) fire area A-18, electrical penetration room (north), elevation 2,026 feet on January 30, 2018

(3) fire area A-17, electrical penetration room (south), elevation 2,026 feet on March 28, 2018

(4) fire area A-26, decontamination area for I&C shop, elevation 2,026 feet on March 28, 2018

(5) fire area A-27, reactor trip switchgear, motor-generator sets, load centers, rod control and rod-drive power supply control cabinets 125 volt direct current panel on March 28, 2018.

71111.06 - Flood Protection Measures Internal Flooding

Main article: IP 71111.06

The inspectors evaluated internal flooding mitigation protections in rooms 1203 and 1203A, Pipe Space B on January 9, 2018.

71111.07 - Heat Sink Performance Heat Sink

Main article: IP 71111.07

The inspectors evaluated containment spray train A room cooler (SGL13A) performance on January 17, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

Main article: IP 71111.11

The inspectors observed and evaluated licensed operator simulator requalification activities that included a loss of all alternating current power during shutdown scenario on February 22, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated operator performance during end of life core moderator temperature coefficient measurement activities on February 5, 2018.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

Main article: IP 71111.12

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

Auxiliary building heating ventilation and air conditioning (GL) system including safety-related pump and electrical penetration room coolers on January 29, 2018.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) reactor partial trip alarm troubleshooting and main generator transformer B loss of two cooling groups on January 4, 2018

(2) emergent maintenance on Class 1E electrical equipment air conditioning unit train A on January 24, 2018

(3) planned maintenance on component cooling water train B on March 5, 2018

(4) emergent maintenance associated with the failed control room envelope pressure test on March 6, 2018

(5) emergent maintenance on Class 1E electrical equipment air conditioning unit train B on March 12, 2018.

71111.15 - Operability Determinations and Functionality Assessments

Main article: IP 71111.15

The inspectors evaluated the following operability determinations and functionality assessments:

(1) auxiliary building elevation 1988 foot south pipe chase drain functionality with three clogged floor drains on January 10, 2018

(2) 125 volt direct current to 120 volt alternating current NN15 inverter operability after a high voltage alarm would not clear on January 18, 2018

(3) emergency diesel generator A lubrication oil leakage on January 31, 2018

(4) Class 1E electrical equipment air conditioning unit train B operability following a step controller failure on February 12, 2018

(5) reactor coolant pump A standpipe not filling on the expected frequency on February 25, 2018

(6) Technical Specification 3.7.10 mitigating actions to ensure the control room envelope occupant radiological exposures would not exceed limits and control room envelope occupants are protected from chemical and smoke hazards while the control room envelope was inoperable on March 6, 2018

(7) excess letdown heat exchanger outlet to pressurizer relief tank isolation valve functionality after failed stoke testing on March 12, 2018

(8) station blackout diesel generator functionality after post maintenance testing on March 20, 2018.

71111.19 - Post Maintenance Testing

Main article: IP 71111.19

The inspectors evaluated the following post maintenance tests:

(1) Class 1E electrical equipment air conditioning unit train A following planned maintenance on January 24, 2018

(2) motor-driven auxiliary feedwater train B pump discharge to steam generators A and D auxiliary feed water flow regulating valve testing following planned maintenance on February 6, 2018

(3) component cooling water pump A following planned maintenance on February 15, 2018

(4) residual heat removal pump A following planned maintenance on March 21, 2018.

==71111.20 - Refueling and Other Outage Activities (Partial Sample)

The inspectors evaluated Refueling Outage 22 activities from March 30 to 31, 2018. The inspectors completed inspection procedure Sections 03.01.a, 03.01.b, and 03.01.c.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine==

Main article: IP 71111.20

(1) STS IC-926B, Component Cooling Water System Automatic Valve Actuation Train B, Revision 6B, on January 4, 2018

(2) STS IC-915B, Channel Operational Test Train B Component Cooling Water System Non-Nuclear Safety-Related Isolation, Revision 8A, on January 8, 2018

(3) STS IC-926A, Component Cooling Water System Automatic Valve Actuation Train A, Revision 8A, on February 12, 2018

(4) STS IC-217, [Reactor Coolant Pump] Loss of Voltage and Underfrequency [Trip Actuation Device Operational Testing], on March 5, 2018

(5) STS PE-004, Auxiliary Building and Control Room Pressure Tests, Revision 16, on March 5 and March 12, 2018.

71114.06 - Drill Evaluation Emergency Planning Drill

Main article: IP 71114.06

The inspectors evaluated the emergency preparedness drill on February 27,

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

Main article: IP 71151

The inspectors verified licensee performance indicator submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017-12/31/2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017-12/31/2017)

(3) IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017-12/31/2017).

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) On February 8, 2018, the unit vent tornado damper failed to meet acceptance criteria for initial breakaway torque. This issue was documented in Condition Report 119330.

(2) On May 11, 2017, Condition Report 112960 documented that pressurizer safety valve 88010As as-found lift setting was 3.2 percent below the nominal setpoint.

INSPECTION RESULTS

Inadequate Functionality Assessment Associated with the Emergency Excess Letdown Flowpath Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Green [H.14] - Human

==71111.15 - Systems NCV 05000482/2018001-01 Performance, Operability

==

Closed Conservative Bias Determinations and Functionality Assessments The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to adequately implement the operability determination and functionality assessment procedure. Specifically, the licensee failed to document a functionality assessment of sufficient scope to address the capability of a safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and the excess letdown system to perform their specified safety functions, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional.

Description:

On March 12, 2018, the licensee was performing Procedure STN BB-201, Exercise of BB HV-8157A and BB HV-8157B, Revision 3, which tests and exercises the excess letdown heat exchanger to pressurizer relief tank isolation valves (BB HV-8157A and BB HV-8157B). The BB HV-8157B valve did not stroke fully closed as expected. Step 6.1.1 of Procedure STN BB-201 states, If the valve cannot be fully exercised, then valve shall be declared inoperable and corrective action initiated.

Condition Report 120287 was documented on March 12, 2018, reporting the valve failure. The immediate functionality assessment stated, The redundant path of excess letdown is still available. The system is functional but degraded. The system functionality is maintained by having a second redundant flow path for excess letdown. The inspectors noted that Section 6.4.7 of Procedure AP 26C-004, Operability Determination and Functionality Assessment, Revision 35, states, The scope of a functionality assessment must be sufficient to address the capability of SSCs to perform their specified functionsThe following things should be considered when performing functionality assessments: codes, standards and system requirements controlling the SSC.

The inspectors questioned the licensee concerning the immediate functionality determinations adequacy, and the licensee revised the functionality determination for the excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) and changed the determination to non-functional. The immediate functionality determination was updated to state:

The above screening gives an adequate justification for why the excess letdown po[r]tion of the [chemical and volume control system] remains functional but degraded. However, screening should be based on the component, not the system. Since BBHV8157B cannot be relied upon to go to the closed position using normal remote controls, the valve is considered nonfunctional. The system remains functional but degraded.

The inspectors also noted that Section 3.1.9, Boration Injection System - Operating, of the Technical Requirements Manual, requires two boration injection subsystems to be functional in MODES 1, 2, and 3. Section 3.1.9 of the Technical Requirements Manual Bases describes what is required for a boration injection subsystem to be considered functional. Specifically, both subsystems require the safety-related excess letdown flow path. Also, two independent boration injection subsystems are required to ensure single functional capability in the event an assumed failure renders one of the boration injection subsystems nonfunctional.

Updated Safety Analysis Report Section 7.4.3.3 describes the applicable single failure analysis. It states, The capability of the [residual heat removal system] to accommodate a single component failure and still perform a safety grade cooldown is demonstrated in the failure mode and effects analysis (FMEA) of the [residual heat removal] system for safety-related cold shutdown operations provided as Table 7.4-4. Table 7.4-4, Residual Heat Removal - Safety Related Cold Shutdown Operations - Failure Modes and Effects Analysis (FMEA), describes the function of the excess letdown to pressurizer relief tank isolation valves (8157A and 8157B), stating, Provides safety grade letdown flow path. Hence, in order for the safety-related excess letdown flowpath to the pressurizer relief tank to meet its safety function, either 8157A or 8157B must be functional and capable of opening.

The inspectors again questioned the updated immediate functionality determinations adequacy. Specifically, considering that 8157A and 8157B are parallel valves, that 8157B was non-functional, and assuming a design basis single failure (for example, assume 8157A fails to open or its power supply fails), the safety-related excess letdown flowpath would be non-functional, and both Technical Requirements Manual independent boration injection subsystems would be impacted. With the excess letdown heat exchanger to pressurizer relief tank isolation valve 8157B non-functional, current language in the Technical Requirements Manual would require one boration injection subsystem to be declared non-functional.

Corrective Actions: On March 20, 2018, the licensee changed the functionality assessment the excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) was determined to be non-functional. In response to the inspectors questions concerning system functionality and design basis information, the licensee initiated Condition Reports 120628 and 120822. The licensee restored the B train excess letdown heat exchanger to pressurizer relief tank isolation valve to service on April 9, 2018.

Corrective Action References: Condition Reports 120287, 120628, 120822 and 122411.

Performance Assessment:

Performance Deficiency: The licensee failed to document a functionality assessment of sufficient scope to address the capability of the safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and excess letdown system to perform their specified safety functions.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).

Specifically, the safety-related excess letdown heat exchanger to pressurizer relief tank isolation valve and excess letdown system were inappropriately determined to be functional but degraded and non-conforming, which resulted in the licensee failing to recognize that two independent Technical Requirements Manual required boration injection subsystems were not functional.

Significance: The inspectors assessed the significance of the finding using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter 0609, Appendix A, Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, and determined this finding is not a deficiency affecting the design or qualification of a mitigating SSC that maintained its operability or functionality; the finding does not represent a loss of system and/or function; the finding does not represent an actual loss of function of at least a single train for greater than its Technical Specification-allowed outage time; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as high safety-significant. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-cutting Aspect: The inspectors determined that the finding has a Human Performance cross-cutting aspect in the area of conservative bias in that individuals did not use decision making-practices that emphasize prudent choices over those that are simply allowable, and a proposed action was not determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, leaders did not take a conservative approach to decision making, particularly when information was incomplete or conditions were unusual when completing the functionality determination associated with the subject valve and system, which resulted in the valve and system being determined to be functional.

Enforcement:

Violation: Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances. Licensee Procedure AP 26C-004, Operability Determination and Functionality Assessment, Revision 35, an Appendix B quality related procedure, provides instructions for performing functionality assessments. Procedure AP 26C-004, Section 6.4.7, states, in part, that the scope of a functionality assessment must be sufficient to address the capability of SSCs to perform their specified functions, and codes, standards, and system requirements controlling the SSC should be considered when performing functionality assessments.

Contrary to the above, from March 12, 2018, until April 9, 2018, the scope of a functionality assessment was not sufficient to address the capability of SSCs to perform their specified functions, and codes, standards, and system requirements controlling the SSC were not considered when performing functionality assessments. Specifically, the functionality assessment associated with the excess letdown heat exchanger outlet to pressurizer relief tank isolation valve and excess letdown system was not adequate and did not adequately consider design basis information, which caused the licensee to fail to identify non-functionality of safety-related SSCs.

Disposition: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

On April 25, 2018, the inspector presented the quarterly resident inspector inspection results to Mr. C. Reasoner, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

Number Title Revision

SYS EF-205 ESW/Circ Water Cold Weather Operations 40

Miscellaneous

Number Title Date

96-0316 Performance Improvement Request Initiated

February 5,

1996

2006-0006 Performance Improvement Request Initiated

January 4,

2006

APF 15C-002-01 Procedure Cover Sheet - ESW/Circ Water Cold Weather Completed

Operations - SYS EF-205 December 26,

2017

APF 15C-002-01 Procedure Cover Sheet - ESW/Circ Water Cold Weather Completed

Operations - SYS EF-205 January 2,

2018

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC January 19,

SRO/RO/BOP Review - Day Shift 2018

APF 29B-003-01 Surveillance Test Routing Sheet - ESW Train B Warming Completed

Line Verification - STN EF-020B January 3,

2018

WM 96-0081 Docket No 50-482: Response to Enforcement Action July 31, 1996

EA 96-124

Section 1R04: Equipment Alignment

Procedures

Number Title Revision

CKL Al-120 Auxiliary Feedwater Normal Lineup 42

CKL EG-120 Component Cooling Water System Valve, Switch and 49

Breaker Lineup

CKL EJ-120 RHR System Lineup 45B

Drawings

Number Title Revision

M-06EG07 Component Coolant Wtr. Sys. Aux. Bldg. 4

M-12AL01 Piping & Instrumentation Diagram Auxiliary Feedwater 28

System

M-12EG01 Piping & Instrumentation Diagram Component Cooling 24

Water System

M-12EG02 Piping & Instrumentation Diagram Component Cooling 27

Water System

M-12EG03 Piping & Instrumentation Diagram Component Cooling 19

Water System

M-12EJ01 Piping and Instrumentation Diagram Residual Heat 53

Removal System

M-12FC02 Piping & Instrumentation Diagram Auxiliary Feedwater 25

Pump Turbine

M-13EG07 Piping Isometric Component Cooling Water Sys. Aux. Bldg. 3

Common Header

M-15EG07 Hanger Location Drawing Component Cooling Water Sys 14

Aux. Bldg. Common Header

Condition Reports

119280 119401 120586

Section 1R05: Fire Protection

Procedures

Number Title Revision

AP 10-106 Fire Preplans 18A

CKL ZL-001 Auxiliary Building Reading Sheets 103

Condition Reports

119366 120782 120783 120784

Miscellaneous

Number Title Revision

E-1F9905 Fire Hazard Analysis 8

XX-X-004 Calculation Cover Sheet - Combustible Fire Loading For 4

Each Room In The Various Fire Areas at WCNOC

Section 1R06: Flood Protection Measures

Procedures

Number Title Revision

ALR 00-094F Misc Sumps Lev Hi 5

Drawings

Number Title Revision

M-12EJ01 Piping and Instrumentation Diagram Residual Heat 53

Removal System

M-13LF02 Piping Isometric Sump Discharge Auxiliary Bldg. 1

Condition Reports

118576 118586 118587 118592 118593

Miscellaneous

Number Title Revision

FL-03 Flooding of Individual Auxiliary Building Rooms 2

Section 1R07: Heat Sink Performance

Procedures

Number Title Revision

AP 23L-002 Heat Exchanger Program 5

Work Orders

17-428729-000 17-428729-002 17-428729-003 17-428729-005 17-428737-000

Miscellaneous

Number Title Date

GL-05 Maintenance Rule Final Scope Evaluation Printed

March 27,

2018

Section 1R11: Licensed Operator Requalification Program

Procedures

Number Title Revision

AP 21-001 Conduct of Operations 81

STS RE-006 EOL Core MTC Measurement 20B

STS SE-001 Power Range Adjustment to Calorimetric 35

Miscellaneous

Number Title Revision/Date

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC February 2,

SRO/RO/BOP Review - Day Shift 2018

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC February 3,

SRO/RO/BOP Review - Day Shift 2018

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC February 3,

SRO/RO/BOP Review - Night Shift 2018

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC February 4,

SRO/RO/BOP Review - Night Shift 2018

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC February 5,

SRO/RO/BOP Review - Night Shift 2018

APF 29B-003-01 Surveillance Test Routing Sheet - EOL Core MTC Completed

Measurement February 5,

2018

EPF 06-007-01 Wolf Creek Generating Station Emergency Notification February 22,

(Drill) 2018

LR5004005 Loss of All AC While Shutdown - Licensed Operator 12

Requal

Section 1R12: Maintenance Effectiveness

Drawings

Number Title Revision/Date

M-12GL01 Piping and Instrumentation Diagram Auxiliary Building 13

HVAC

M-612.00062 Carrier Air Handling Units and Room Coolers Imaged May

2017

Condition Reports

10539 114660 117759

Miscellaneous

Number Title Date

GL Room Cooler PM Schedule

Maintenance Rule Expert Panel Meeting Agenda November 1,

2017

114660 Functional Failure Determination Checklist August 17,

2017

GL-01 Maintenance Rule Final Scope Evaluation Printed

January 29,

2018

GL-02 Maintenance Rule Final Scope Evaluation Printed

January 29,

2018

GL-03 Maintenance Rule Final Scope Evaluation Printed

January 29,

2018

GL-04 Maintenance Rule Final Scope Evaluation Printed

January 29,

2018

GL-05 Maintenance Rule Final Scope Evaluation Printed

January 29,

2018

GL-06 Maintenance Rule Final Scope Evaluation Printed

January 29,

2018

GL-07 Maintenance Rule Final Scope Evaluation Printed

January 29,

2018

GL-08 Maintenance Rule Final Scope Evaluation Printed

January 29,

2018

GL-09 Maintenance Rule Final Scope Evaluation Printed

January 29,

2018

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

Procedures

Number Title Revision

AP 22C-003 On-Line Nuclear Safety and Generation Risk Assessment 22

Procedures

Number Title Revision

OFN AF-025 Unit Limitations 52

STS BB-201B Cycle Test of PORV Block Valve BB HV-800B 4

STS IC-447 Channel Calibration Nuclear Instrumentation System Power 46

Range Incore-Excore

STS MT-024B Functional Test of 480 and 120 Volt Molded Case Circuit 17

Breakers

Drawings

Number Title Revision

M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout W03

Condition Reports

118499 118938 118939 118940 118953

118958 118959 118963 118964

Work Orders

17-422791-003 17-427320-000 18-434985-000 18-435758-000 18-435758-001

Miscellaneous

Number Title Date

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC January 23,

SRO/RO/BOP Review - Day Shift 2018

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC January 23,

SRO/RO/BOP Review - Night Shift 2018

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC January 24,

SRO/RO/BOP Review - Day Shift 2018

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC January 24,

SRO/RO/BOP Review - Night Shift 2018

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC January 25,

SRO/RO/BOP Review - Night Shift 2018

APF 21-001-02 Control Room Turnover Checklist - On-Coming CRS/WC January 26,

SRO/RO/BOP Review - Night Shift 2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment: January 4,

18-0101 2018

Miscellaneous

Number Title Date

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment: March 13,

18-0111 2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment: February 15,

2018-0110 2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment: January 10,

2018-0104 2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment - February 14,

2018-0122 2018

APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-447 Completed

January 4,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - STS PE-004 (Train B) Completed

March 7,

2018

Section 1R15: Operability Evaluations

Procedures

Number Title Revision

AI 16C-006 Troubleshooting 9

AI 28B-005 Evidence and Action Matrix 4

AP 12-003 Foreign Material Exclusion 16

AP 26C-004 Operability Determination and Functionality Assessment 35

OFN BB-005 RCP Malfunctions 27

STN BB-201 Exercise of BB HV-8157A and BB HV-8157B 3

STS BG-001 Boron Injection Flow Path Verification 20

STS KJ-005A Manual/Auto Start, Sync and Loading of EDG NE01 67A

STS PE-004 Auxiliary Building and Control Room Pressure Test 16

SYS GK-122 Manual CRVIS Line-Up 24

SYS OPS-001 Weekly Equipment Rotation and Readings 80A

Drawings

Number Title Revision

E-13GG01 Schematic Diagram Emergency Exhaust Fans 6

E-13GG03 Schematic Diagram Emergency Exhaust Heating Coils 1

Drawings

Number Title Revision

E-13GG15 Schematic Diagram Emergency Exhaust Cross Connection 0

Dampers

J-02GG14B (Q) Fuel Building HVAC Spent Fuel Pool Normal/Emergency 0

Exhaust Radioactivity Sample Valve

M-12BB02 Piping & Instrumentation Diagram Reactor Coolant System 27

M-12BB03 Piping and Instrumentation Diagram Reactor Coolant System 15

M-12BG01 Piping & Instrumentation Diagram Chemical and Volume 19

Control System

M-12BL01 Piping & Instrumentation Diagram Reactor Make-Up Water 15

System

M-12GG01 Piping Instrumentation Diagram Fuel Building HVAC 8

M-12GT01 Piping & Instrumentation Diagram Containment Purge 24

Systems HVAC

M-12HB01 Piping and Instrumentation Diagram Liquid Radwaste 15

System

M-12LF01 Piping & Instrumentation Diagram Auxiliary Building Floor 3

and Equipment Drain System

M-12LF03 Piping & Instrumentation Diagram Auxiliary Building Floor 6

and Equipment Drain System

M-1H1531 Heating Ventilating and Air Cond. Auxiliary Building El. 2047- 5

Area-3

M-1H6311 Heating Ventilating & Air Cond. Fuel Building El. 2047-6 & 2

2065-0 Area 1

M-622.1A-00001 SGK05A & SGK05B Air Conditioner Refrigeration Schematic W12

M-622.1A-00002 SGK05A & SGK05B Air Conditioner Electrical Schematic W13

M-622.1A-00003 SGK05A & SGK05B Air Conditioner Electrical Schematic W09

M-622.1A-00257 Step Controllers W01

M-712-00063 Reactor Coolant Pump Data Sheets W04

M-OPIII Embedded Drainage Systems (LF) Auxiliary Building EL. 5

1967-0 & 1974-0 Area I

Condition Reports

24199 90975 107789 110377 117283

118586 118587 118592 118827 118830

Condition Reports

118831 118910 118922 119069 119085

119330 119334 119442 119446 119487

119616 119822 119859 119860 119861

20053 120056 120071 120179 120181

20246 120287 120408 120409 120410

20411 120489 120535 120664 120722

Work Orders

16-411783-010 17-428518-000 18-436340-000 18-436340-002

Miscellaneous

Number Title Revision/Date

107363 Functional Failure Determination Checklist October 12,

2016

118585 Function Failure Determination Checklist January 28,

2018

AIF 10-001-02 SCBA Inspection Completed

March 1, 2018

APF 05-002-05 Engineering Disposition - EDG Water, Lube Oil, and Fuel 00

Oil Leakage Guidance

APF 05C-004-01 Basic Engineering Disposition - Review of Regulatory and 00

License Basis Documents to evaluate the requirements of

Operability Determination when Safety Related or

Technical Specification Equipment is exposed to a hazard

APF 21-001-02 Control Room Turnover checklist - On-Coming CRS/WC March 14,

SRO/RO/BOP Review - Night Shift 2018

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment: February 14,

2018-0112 2018

APF30B-004-01 Wolf Creek Nuclear Operating Corporation Essential April 1, 2018

Required Reading - SBO Power Equipment Center (PEC)

GG-01 Maintenance Rule Final Scope Evaluation Printed

March 22,

2018

GG-02 Maintenance Rule Final Scope Evaluation Printed

March 22,

2018

Miscellaneous

Number Title Revision/Date

GG-03 Maintenance Rule Final Scope Evaluation Printed

March 22,

2018

GG-04 Maintenance Rule Final Scope Evaluation Printed

March 22,

2018

Section 1R19: Post-Maintenance Testing

Procedures

Number Title Revision

STN AL-201 Auxiliary Feedwater System Valve Test 8

STN EG-205A Component Cooling Water System Valve Test 2

STS EG-100A Component Cooling Water Pumps A/C [Air Conditioning] 33A

Inservice Pump Test

STS EG-208A EG TV-029 CCW [Component Cooling Water] HX [Heat 1

Exchanger] A Temperature Control Valve Inservice Valve

Test

STS EJ-100A RHR [Residual Heat Removal] System Inservice Pump A 55

Test

STS IC-540A Channel Calibration Auxiliary Feedwater System Steam 9

Generator A

Drawings

Number Title Revision/Date

E-13GK13 Schematic Diagram Class 1E Electrical Equipment A/C [Air 6

Conditioning] Unit

M-12AL01 Piping & Instrumentation Diagram Auxiliary Feedwater 23

System

M-12AL01 Piping & Instrumentation Diagram Auxiliary Feedwater 28

System

M-622.1-00036 Electric Motor Data Sheet March 3, 1977

M-622.1A-00002 SKG05A & SGK05B Air Conditioner Electrical Schematic W13

M-622.1A-00142 SGK05A Terminal and Pressure Switch Enclosure Layout W03

Condition Reports

118881 118901 118920 118953 118958

118959 118963 118964 119289

Work Orders

15-407137-000

Miscellaneous

Number Title Revision/Date

WCGS Standing Order 1 - Valve Setup and Operation 45

36121 Preventative Maintenance Work Instruction

APF 22C-003-01 On-Line Nuclear Safety and Generation Risk Assessment January 23,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - Auxiliary Feedwater Completed

System Valve Test February 6,

2018

Section 1R20: Refueling and Other Outage Activities

Procedures

Number Title Revision

GEN 00-004 Power Operation 89

GEN 00-005 Minimum Load To Hot Standby 90

SYS AE-320 Turbine Driven Main Feedwater Pump Shutdown 28A

SYS AF-121 Heater Drain Pump Operation 24

Section 1R22: Surveillance Testing

Procedures

Number Title Revision

AP 23-009 Control Room Envelope Habitability Program 2

STS EG-100B Component Cooling Water Pumps B/D Inservice Pump Test 29

STS IC-217 RCP Loss of Voltage and Underfrequency TADOT 15C

STS IC-915B Channel Operational Test Train B Component Cooling 8A

Water System Non-Nuclear Safety-Related Isolation

STS IC-926A Component Cooling Water System Automatic Valve 8A

Actuation Train A

Procedures

Number Title Revision

STS IC-926B Component Cooling Water System Automatic Valve 6B

Actuation Train B

STS PE-004 Auxiliary Building and Control Room Pressure Test 16

Drawings

Number Title Revision

E-13EG01D Schematic Diagram Component Cooling Water Pump D 5

E-13EG08A Schematic Diagram Component Cooling Water Supply 3

Return From Radwaste Building

E-13EG11 Schematic Diagram Annunciation and Instrumentation 4

E-13EG20 Schematic Diagram Pass CCW Isolation Valves 3

M-12EG01 Piping & Instrumentation Diagram Component Cooling 24

Water System

M-12EG02 Piping & Instrumentation Diagram Component Cooling 27

Water System

M-12EG03 Piping & Instrumentation Diagram Component Cooling 19

Water System

Condition Reports

118493 118551 118552 119412 120061

20064 120148 120151 120408 120409

20410 120411

Work Orders

17-431050-000 17-431170-000 17-431759-000 17-432247-000

Miscellaneous

Number Title Date

APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-217 Completed

March 5,

2018

APF 29B-003-01 Surveillance Test Routing Sheet - STS IC-926B Completed

January 4,

2018

Miscellaneous

Number Title Date

APF 30B-004-01 Wolf Creek Nuclear Operating Corporation Essential March 7,

Required Reading: 18-0010 Accuracy of WCRE-35 2018

Section 1EP6: Drill Evaluation

Procedures

Number Title Revision

EPP 06-006 Protective Action Recommendations 9A

Condition Reports

119869 119870 119871 119872 119874

119877 119878 119879 119883 119885

119886 119887 119888 119889 119897

119901 119903 119904 119906 119911

119941 120017 120227 120323

Miscellaneous

Number Title Revision/Date

18-SA-01 Wolf Creek Generating Station - Emergency Planning Drill February 27,

2018

APF 06-002-01 Emergency Action Levels 17A

CR-001 Wolf Creek Generating Station Emergency Notification February 27,

(Drill) 2018

EOF-001 Wolf Creek Generating Station Emergency Notification February 27,

(Drill) 2018

EOF-002 Wolf Creek Generating Station Emergency Notification February 27,

(Drill) 2018

EOF-003 Wolf Creek Generating Station Emergency Notification February 27,

(Drill) 2018

EOF-004 Wolf Creek Generating Station Emergency Notification February 27,

(Drill) 2018

TSC-001 Wolf Creek Generating Station Emergency Notification February 27,

(Drill) 2018

Section 4OA1: Performance Indicator Verification

Miscellaneous

Number Title Revision

NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7

Section 4OA2: Identification and Resolution of Problems

Procedures

Number Title Revision

STS MT-005 Pressurizer Code Safety Valve Operability 20

Drawings

Number Title Revision

M-1H1531 Heating Ventilating and Air Cond. Auxiliary Building El. 5

2047-6 Area-3

Condition Reports

90975 110377 112960 118910 119330

Work Orders

17-428518-001

Miscellaneous

Number Title Date

Email from NWS <EXTERNAL> RE: Wolf Creek PSV failure - Questions November

Technologies to from our NRC Resident Inspector 30, 2017

Wolf Creek

P.O. # 692145 Valve Serial Number N60446-00-0001; Traveler 14-381 Testing

SR Completed

January 2015

PO # 779245 Valve Serial Number N60446-00-0001; Traveler 17-41 Testing

Completed

August 2017

NRC Letter to Wolf Creek Generating Station - Issuance of Amendment March 23,

Otto L. Maynard RE: Pressurizer Safety Valves (TAC NO. MA6969) 2000

White Paper Pressurizer Safety Valve NRC Follow-up Questions and

Answers

White Paper Why PZR Safety Valve Failure is NOT a Part 21 Issue

Initial Request for Information

Integrated Inspection

Wolf Creek Nuclear Generating Station

Inspection Report: 05000482/2018001

Inspection Dates: January 1 - March 31, 2018

Inspection Procedure: Integrated Inspection Procedures

Lead Inspector: Douglas Dodson, Senior Resident Inspector

I. Information Requested Prior to December 22, 2017

The following information should be provided in electronic format (Certrec IMS

preferred), to the attention of Douglas Dodson by December 22, 2017, to facilitate the

reduction in the items to be selected for a final list during inspection preparation. The

inspection team will finalize its sample selections and will provide an additional

information request with specific items. This information shall be made available by

December 22, 2017. The specific items selected from the lists shall be available and

ready for review on the day indicated in this request. *Please provide requested

documentation electronically in pdf files, Excel, or other searchable formats, if possible.

The information should contain descriptive names, and be indexed and hyperlinked to

facilitate ease of use. Information in lists should contain enough information to be

easily understood by someone who has knowledge of pressurized water reactor

technology. If requested documents are large and/or only hard copy formats are

available, please inform the inspector(s), and provide subject documentation.

1. Any pre-existing evaluation or list of component cooling water system components

and associated calculations with low design margins.

2. A list of high risk component cooling water system maintenance rule components

and functions based on engineering or expert panel judgment.

3. A list of component cooling water system related operating experience evaluations

for the last 3 years.

4. A list of all component cooling water system time-critical operator actions in

procedures.

5. A list of permanent and temporary modifications related to component cooling water

system sorted by component.

6. A list of current component cooling water system related operator work

arounds/burdens.

7. A list of the component cooling water system design calculations, which provide the

design margin information for components.

8. List of component cooling water system root cause evaluations associated with

component failures or design issues initiated/completed in the last 5 years.

9. A list of any component cooling water system common-cause failures of

components in the last 3 years.

10. An electronic copy of the component cooling water system design bases documents

and any open, pending, or recently completed changes. Although not an exhaustive

list, please include any open, pending, or recently completed (last 3 years) changes

to temporary modifications, permanent modifications, engineering change

packages, and/or procedure change packages. Specifically, please include any

open, pending, or recently completed changes to emergency operating, abnormal

operating, normal operating, alarm response, system alignment, surveillance, or

other procedure.

11. An electronic copy of the component cooling water system System Health notebook.

2. A copy of component cooling water system related audits completed in the last 2

years.

13. A list of component cooling water system motor operated valves (MOVs) in the

program, design margin and risk ranking.

14. A list of component cooling water system air operated valves (AOVs) in the valve

program, design margin and risk ranking.

15. Component cooling water system structure, system, and components maintenance

rule category, scoping, unavailability data, unreliability data, functional failure

evaluations, (a)(1) determinations, (a)(1) goals, and any supporting basis

documentation.

16. A list of component cooling water system licensee contacts for the inspection team

with pager or phone numbers.

17. An excel spreadsheet of component cooling water system related PRA human

action basic events or risk ranking of operator actions from your site specific PSA

sorted by RAW and FV. Provide copies of your human reliability worksheets for

these items.

18. In so far as there are recent or pending changes, please provide an Excel

spreadsheet of component cooling water system related equipment basic events

(with definitions) including importance measures sorted by risk achievement worth

(RAW) and Fussell- Vesely (FV) from your internal events probabilistic risk

assessment (PRA). Include basic events with RAW value of 1.3 or greater.

19. In so far as there are recent or pending changes, please provide a list of the top 50

cut-sets from your PR

A.

20. In so far as there are recent or pending changes, please provide copies of PRA

system notebooks, and the latest PRA summary document.

21. In so far as there are recent or pending changes, and if you have an external events

or fire PSA model, provide the information requested in items 17-19 for external

events and fire, as it relates to the component cooling water system.

2. In so far as there are recent or pending changes, please provide a copy of the Wolf

Creek Nuclear Generating Station IPEEE changes, if available electronically.

ML18131A017

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: NHT/rdr Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:DRP/B RI:DRP/B C:DRS/OB C:DRS/PSB2 C:DRS/EB1 C:DRS/EB2

NAME DDodson FThomas VGaddy HGepford TFarnholtz JDrake

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 5/9/2018 5/10/18 5/3/18 5/3/18 5/3/2018 5/9/18

OFFICE TL:DRS/IPAT SRI/DRP/B BC:DRP/B

NAME GGeorge DBradley NTaylor

SIGNATURE /RA - /RA/ /RA/

HFreeman for/

DATE 5/10/18 5/7/18 5/14/18

May 14, 2018

Mr. 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 05000482/2018001

Dear Mr. Heflin:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Wolf Creek Generating Station. On April 25, 2018, the NRC inspectors discussed the

results of this inspection with Mr.

C. Reasoner, Site Vice President, and other members of your

staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a

non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance of this 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; and the NRC resident inspector at the Wolf Creek Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the

U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the

NRC resident inspector at the Wolf Creek Generating Station.

A. Heflin 2

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

/RA/

Nicholas

H. Taylor, Chief

Project Branch B

Division of Reactor Projects

Docket No. 50-482

License No. NPF-42

Enclosure:

Inspection Report 05000482/2018001

w/ Attachments:

1. Supplemental Information

2. Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000482

License Number: NPF-42

Report Number: 05000482/2018001

Enterprise Identifier: I-2018-001-0012

Licensee: Wolf Creek Nuclear Operating Corporation

Facility: Wolf Creek Generating Station

Location: 1550 Oxen Lane NE

Burlington, KS 66839

Inspection Dates: January 1, 2018, to March 31, 2018

Inspectors:

D. Dodson, Senior Resident Inspector

F. Thomas, Resident Inspector

D. Bradley, Senior Resident Inspector, Callaway

Approved By:

N. Taylor, Chief, Project Branch B, Division of Reactor Projects

Enclosure

SUMMARY

The 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. NRC-identified and

self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations

Inadequate Functionality Assessment Associated with the Emergency Excess Letdown

Flowpath

Cornerstone Significance Cross-cutting Aspect Report Section

Mitigating Green [H.14] - Human 71111.15 -

Systems NCV 05000482/2018001-01 Performance, Operability

Closed Conservative Bias Determinations

and Functionality

Assessments

The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to

adequately implement the operability determination and functionality assessment procedure.

Specifically, the licensee failed to document a functionality assessment of sufficient scope to

address the capability of a safety-related excess letdown heat exchanger to pressurizer relief

tank isolation valve and the excess letdown system to perform their specified safety functions,

which resulted in the licensee failing to recognize that two independent Technical

Requirements Manual required boration injection subsystems were not functional.

PLANT STATUS

Wolf Creek Generating Station began the inspection period at rated thermal power. On

March 30, 2018, a plant shutdown was completed to begin Refueling Outage 22.

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 performed plant status activities described in

IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem

Identification and Resolution. 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.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for extreme

low temperatures on January 2 and 3, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) turbine-driven auxiliary feedwater train on February 6, 2018

(2) residual heat removal pump B on March 21, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the

component cooling water system on February 23, 2018.

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) fire area A-16, general area, elevation 2,026 feet on January 30, and March 28, 2018

(2) fire area A-18, electrical penetration room (north), elevation 2,026 feet on January 30,

2018

(3) fire area A-17, electrical penetration room (south), elevation 2,026 feet on March 28,

2018

(4) fire area A-26, decontamination area for I&C shop, elevation 2,026 feet on March 28,

2018

(5) fire area A-27, reactor trip switchgear, motor-generator sets, load centers, rod control

and rod-drive power supply control cabinets 125 volt direct current panel on March 28,

2018.

71111.06 - Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protections in rooms 1203 and 1203A,

Pipe Space B on January 9, 2018.

71111.07 - Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated containment spray train A room cooler (SGL13A) performance on

January 17, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated licensed operator simulator requalification activities

that included a loss of all alternating current power during shutdown scenario on February 22,

2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated operator performance during end of life core moderator

temperature coefficient measurement activities on February 5, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

Auxiliary building heating ventilation and air conditioning (GL) system including safety-

related pump and electrical penetration room coolers on January 29, 2018.

71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) reactor partial trip alarm troubleshooting and main generator transformer B loss of two

cooling groups on January 4, 2018

(2) emergent maintenance on Class 1E electrical equipment air conditioning unit train A on

January 24, 2018

(3) planned maintenance on component cooling water train B on March 5, 2018

(4) emergent maintenance associated with the failed control room envelope pressure test

on March 6, 2018

(5) emergent maintenance on Class 1E electrical equipment air conditioning unit train B on

March 12, 2018.

71111.15 - Operability Determinations and Functionality Assessments (8 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) auxiliary building elevation 1988 foot south pipe chase drain functionality with three

clogged floor drains on January 10, 2018

(2) 125 volt direct current to 120 volt alternating current NN15 inverter operability after a

high voltage alarm would not clear on January 18, 2018

(3) emergency diesel generator A lubrication oil leakage on January 31, 2018

(4) Class 1E electrical equipment air conditioning unit train B operability following a step

controller failure on February 12, 2018

(5) reactor coolant pump A standpipe not filling on the expected frequency on February 25,

2018

(6) Technical Specification 3.7.10 mitigating actions to ensure the control room envelope

occupant radiological exposures would not exceed limits and control room envelope

occupants are protected from chemical and smoke hazards while the control room

envelope was inoperable on March 6, 2018

(7) excess letdown heat exchanger outlet to pressurizer relief tank isolation valve

functionality after failed stoke testing on March 12, 2018

(8) station blackout diesel generator functionality after post maintenance testing on

March 20, 2018.

71111.19 - Post Maintenance Testing (4 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Class 1E electrical equipment air conditioning unit train A following planned maintenance

on January 24, 2018

(2) motor-driven auxiliary feedwater train B pump discharge to steam generators A and D

auxiliary feed water flow regulating valve testing following planned maintenance on

February 6, 2018

(3) component cooling water pump A following planned maintenance on February 15, 2018

(4) residual heat removal pump A following planned maintenance on March 21, 2018.

71111.20 - Refueling and Other Outage Activities (Partial Sample)

The inspectors evaluated Refueling Outage 22 activities from March 30 to 31, 2018. The

inspectors completed inspection procedure Sections 03.01.a, 03.01.b, and 03.01.c.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (5 Samples)

(1) STS IC-926B, Component Cooling Water System Automatic Valve Actuation Train B,

Revision 6B, on January 4, 2018

(2) STS IC-915B, Channel Operational Test Train B Component Cooling Water System

Non-Nuclear Safety-Related Isolation, Revision 8A, on January 8, 2018

(3) STS IC-926A, Component Cooling Water System Automatic Valve Actuation Train A,

Revision 8A, on February 12, 2018

(4) STS IC-217, [Reactor Coolant Pump] Loss of Voltage and Underfrequency [Trip

Actuation Device Operational Testing], on March 5, 2018

(5) STS PE-004, Auxiliary Building and Control Room Pressure Tests, Revision 16, on

March 5 and March 12, 2018.

71114.06 - Drill Evaluation

Emergency Planning Drill (1 Sample)

The inspectors evaluated the emergency preparedness drill on February 27, 2018.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification (3 Samples)

The inspectors verified licensee performance indicator submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017-12/31/2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017-

2/31/2017)

(3) IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017-12/31/2017).

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1) On February 8, 2018, the unit vent tornado damper failed to meet acceptance criteria for

initial breakaway torque. This issue was documented in Condition Report 119330.

(2) On May 11, 2017, Condition Report 112960 documented that pressurizer safety valve

88010As as-found lift setting was 3.2 percent below the nominal setpoint.

INSPECTION RESULTS

Inadequate Functionality Assessment Associated with the Emergency Excess Letdown

Flowpath

Cornerstone Significance Cross-cutting Aspect Report Section

Mitigating Green [H.14] - Human 71111.15 -

Systems NCV 05000482/2018001-01 Performance, Operability

Closed Conservative Bias Determinations

and Functionality

Assessments

The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee

failed to adequately implement the operability determination and functionality assessment

procedure. Specifically, the licensee failed to document a functionality assessment of

sufficient scope to address the capability of a safety-related excess letdown heat exchanger

to pressurizer relief tank isolation valve and the excess letdown system to perform their

specified safety functions, which resulted in the licensee failing to recognize that two

independent Technical Requirements Manual required boration injection subsystems were

not functional.

Description: On March 12, 2018, the licensee was performing Procedure STN BB-201,

Exercise of BB HV-8157A and BB HV-8157B, Revision 3, which tests and exercises the

excess letdown heat exchanger to pressurizer relief tank isolation valves (BB HV-8157A and

BB HV-8157B). The BB HV-8157B valve did not stroke fully closed as expected. Step 6.1.1

of Procedure STN BB-201 states, If the valve cannot be fully exercised, then valve shall be

declared inoperable and corrective action initiated.

Condition Report 120287 was documented on March 12, 2018, reporting the valve

failure. The immediate functionality assessment stated, The redundant path of

excess letdown is still available. The system is functional but degraded. The system

functionality is maintained by having a second redundant flow path for excess

letdown. The inspectors noted that Section 6.4.7 of Procedure AP 26C-004,

Operability Determination and Functionality Assessment, Revision 35, states, The

scope of a functionality assessment must be sufficient to address the capability of

SSCs to perform their specified functionsThe following things should be considered

when performing functionality assessments: codes, standards and system

requirements controlling the SSC.

The inspectors questioned the licensee concerning the immediate functionality

determinations adequacy, and the licensee revised the functionality determination for the

excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) and changed

the determination to non-functional. The immediate functionality determination was updated

to state:

The above screening gives an adequate justification for why the excess

letdown po[r]tion of the [chemical and volume control system] remains

functional but degraded. However, screening should be based on the

component, not the system. Since BBHV8157B cannot be relied upon to go to

the closed position using normal remote controls, the valve is considered

nonfunctional. The system remains functional but degraded.

The inspectors also noted that Section 3.1.9, Boration Injection System - Operating, of the

Technical Requirements Manual, requires two boration injection subsystems to be functional

in MODES 1, 2, and 3. Section 3.1.9 of the Technical Requirements Manual Bases describes

what is required for a boration injection subsystem to be considered functional. Specifically,

both subsystems require the safety-related excess letdown flow path. Also, two independent

boration injection subsystems are required to ensure single functional capability in the event

an assumed failure renders one of the boration injection subsystems nonfunctional.

Updated Safety Analysis Report Section 7.4.3.3 describes the applicable single failure

analysis. It states, The capability of the [residual heat removal system] to accommodate a

single component failure and still perform a safety grade cooldown is demonstrated in the

failure mode and effects analysis (FMEA) of the [residual heat removal] system for safety-

related cold shutdown operations provided as Table 7.4-4. Table 7.4-4, Residual Heat

Removal - Safety Related Cold Shutdown Operations - Failure Modes and Effects Analysis

(FMEA), describes the function of the excess letdown to pressurizer relief tank isolation

valves (8157A and 8157B), stating, Provides safety grade letdown flow path. Hence, in

order for the safety-related excess letdown flowpath to the pressurizer relief tank to meet its

safety function, either 8157A or 8157B must be functional and capable of opening.

The inspectors again questioned the updated immediate functionality determinations

adequacy. Specifically, considering that 8157A and 8157B are parallel valves, that 8157B

was non-functional, and assuming a design basis single failure (for example, assume 8157A

fails to open or its power supply fails), the safety-related excess letdown flowpath would be

non-functional, and both Technical Requirements Manual independent boration injection

subsystems would be impacted. With the excess letdown heat exchanger to pressurizer relief

tank isolation valve 8157B non-functional, current language in the Technical Requirements

Manual would require one boration injection subsystem to be declared non-functional.

Corrective Actions: On March 20, 2018, the licensee changed the functionality assessment

the excess letdown heat exchanger to pressurizer relief tank isolation valve (8157B) was

determined to be non-functional. In response to the inspectors questions concerning system

functionality and design basis information, the licensee initiated Condition Reports 120628

and 120822. The licensee restored the B train excess letdown heat exchanger to pressurizer

relief tank isolation valve to service on April 9, 2018.

Corrective Action References: Condition Reports 120287, 120628, 120822 and 122411.

Performance Assessment:

Performance Deficiency: The licensee failed to document a functionality assessment of

sufficient scope to address the capability of the safety-related excess letdown heat exchanger

to pressurizer relief tank isolation valve and excess letdown system to perform their specified

safety functions.

Screening: The inspectors determined the performance deficiency was more than minor

because it adversely affected the equipment performance attribute of the Mitigating Systems

Cornerstone objective to ensure the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences (i.e., core damage).

Specifically, the safety-related excess letdown heat exchanger to pressurizer relief tank

isolation valve and excess letdown system were inappropriately determined to be functional

but degraded and non-conforming, which resulted in the licensee failing to recognize that two

independent Technical Requirements Manual required boration injection subsystems were

not functional.

Significance: The inspectors assessed the significance of the finding using Exhibit 2,

Mitigating Systems Screening Questions, of Inspection Manual Chapter 0609, Appendix A,

Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012,

and determined this finding is not a deficiency affecting the design or qualification of a

mitigating SSC that maintained its operability or functionality; the finding does not represent a

loss of system and/or function; the finding does not represent an actual loss of function of at

least a single train for greater than its Technical Specification-allowed outage time; and the

finding does not represent an actual loss of function of one or more non-Technical

Specification trains of equipment designated as high safety-significant. Therefore, the

inspectors determined the finding was of very low safety significance (Green).

Cross-cutting Aspect: The inspectors determined that the finding has a Human Performance

cross-cutting aspect in the area of conservative bias in that individuals did not use decision

making-practices that emphasize prudent choices over those that are simply allowable, and a

proposed action was not determined to be safe in order to proceed, rather than unsafe in

order to stop. Specifically, leaders did not take a conservative approach to decision making,

particularly when information was incomplete or conditions were unusual when completing

the functionality determination associated with the subject valve and system, which resulted

in the valve and system being determined to be functional.

Enforcement:

Violation: Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and

Drawings, requires, in part, that activities affecting quality shall be accomplished in

accordance with documented instructions, procedures, or drawings of a type appropriate to

the circumstances. Licensee Procedure AP 26C-004, Operability Determination and

Functionality Assessment, Revision 35, an Appendix B quality related procedure, provides

instructions for performing functionality assessments. Procedure AP 26C-004, Section 6.4.7,

states, in part, that the scope of a functionality assessment must be sufficient to address the

capability of SSCs to perform their specified functions, and codes, standards, and system

requirements controlling the SSC should be considered when performing functionality

assessments.

Contrary to the above, from March 12, 2018, until April 9, 2018, the scope of a functionality

assessment was not sufficient to address the capability of SSCs to perform their specified

functions, and codes, standards, and system requirements controlling the SSC were not

considered when performing functionality assessments. Specifically, the functionality

assessment associated with the excess letdown heat exchanger outlet to pressurizer relief

tank isolation valve and excess letdown system was not adequate and did not adequately

consider design basis information, which caused the licensee to fail to identify non-

functionality of safety-related SSCs.

Disposition: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

On April 25, 2018, the inspector presented the quarterly resident inspector inspection results to

Mr.

C. Reasoner, Site Vice President, and other members of the licensee staff.