IR 05000482/2022003

Integrated Inspection Report 05000482/2022003

ML22294A090
Person / Time
Site:	Wolf Creek
Issue date:	10/25/2022
From:	Greg Werner NRC/RGN-IV/DORS/PBB
To:	Reasoner C Wolf Creek
Werner G
References
IR 2022003
Download: ML22294A090 (39)

Text

October 25, 2022

SUBJECT:

WOLF CREEK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000482/2022003

Dear Mr. Reasoner:

On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Wolf Creek Generating Station. On October 4, 2022, the NRC inspectors discussed the results of this inspection with Mr. B.J. Bayer, General Manager Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.

Four findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, 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 Wolf Creek Generating Station.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Werner, Gregory on 10/25/22 Gregory E. Werner, Chief Projects Branch B Division of Operating Reactor Safety Docket No. 05000482 License No. NPF-42

Enclosure:

As stated

Inspection Report

Docket Number: 05000482 License Number: NPF-42 Report Number: 05000482/2022003 Enterprise Identifier: I-2022-003-0002 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: Burlington, Kansas Inspection Dates: July 1 to September 30, 2022 Inspectors: R. Alexander, Regional State Liaison Officer B. Baca, Health Physicist S. Hedger, Senior Emergency Preparedness Inspector C. Henderson, Senior Resident Inspector J. Melfi, Project Engineer J. O'Donnell, Senior Health Physicist C. Osterholtz, Senior Operations Engineer E. Simpson, Health Physicist H. Strittmatter, Emergency Preparedness Inspector W. Tejada, Physical Security Inspector R. Williams, Operations Engineer D. You, Operations Engineer Approved By: Gregory E. Werner, Chief Projects Branch B Division of Operating Reactor Safety Enclosure

SUMMARY

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

List of Findings and Violations

Failure to Translate Refueling Water Storage Tank Technical Specification Minimum Water Level into Design Calculations Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.8] - 71111.15 Systems NCV 05000482/2022003-01 Procedure Open/Closed Adherence The inspectors identified a Green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure the applicable design requirements associated with the refueling water storage tank were correctly translated into specifications, drawings, procedure, and instructions. Specifically, the licensee failed to translate the refueling water storage tank technical specification minimum water level of 94 percent into design calculations.

Protective Action Recommendation Developed During an Exercise for Subzone Experiencing No Radiological Consequence Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green None (NPP) 71114.01 Preparedness NCV 05000482/2022003-02 Open/Closed The inspectors identified a finding of very low safety significance (Green) with an associated non-cited violation of Title 10 of the Code of Federal Regulations 50.54(q)(2) for the licensees failure to maintain an emergency plan that follows the requirements of Title 10 of the Code of Federal Regulations 50.47(b)(10). Specifically, the licensee made a change to their emergency notification form, combining two subzones for protective action recommendations.

This resulted in the licensee issuing protective action recommendations during an exercise for a subzone that was not affected by the simulated release.

Failure to Periodically Calibrate Radiation Monitors as Required by 10 CFR 20.1501(c)

Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.4] - 71124.05 Radiation Safety NCV 05000482/2022003-04 Teamwork Open/Closed The inspectors identified a Green non-cited violation of Title 10 of the Code of Federal Regulations 20.1501(c) for a failure to periodically calibrate radiation monitoring equipment used to perform dose rate and effluent measurements. Specifically, on December 7, 2020, the licensee discontinued periodic calibrations of 35 area radiation monitors distributed throughout the plant and began operating them in a run-to-maintenance mode. In addition, 16 process and effluent radiation monitors were changed to a three-year frequency. Both sets of monitors were not verified to be in calibration prior to the mode and frequency change.

Failure to Properly Evaluate the Use of Anti-Seize Lubricant and Have Adequate Work Instructions Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green None (NPP) 71153 FIN 05000482/2022003-05 Open/Closed The inspectors reviewed a self-revealed Green finding for the licensees failure to properly evaluate the use of anti-seize lubricant and have adequate work instructions to prevent its use in the packing gland area of the main feedwater regulating valves. This resulted in stress corrosion cracking in the B main feedwater regulating valve which caused stem separation and an automatic reactor trip on steam generator B low level.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000482/2022003-03 Protective Action 71114.01 Open Recommendation Developed During an Exercise May Not Have Been Warranted LER 05000482/2022-001-00 Low Steam Generator Level 71153 Closed due to Main Feedwater Valve Failure Caused Reactor Trip

PLANT STATUS

Wolf Creek Generating Station began the inspection period at full power. On July 18, 2022, an automatic reactor trip from 100 percent reactor power occurred due to a loss of main feedwater flow to the B steam generator caused by a stem separation of the B main feedwater regulating valve. The licensee commenced forced outage 25-03 to repair the B main feedwater regulating valve and performed extent of condition reviews of the remaining three main feedwater regulating valves. On July 21, 2022, the unit commenced reactor startup, and the reactor was made critical. The unit was returned to full power on July 23,

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 inspection 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures on September 8, 2022, for the following systems:

station blackout diesel generators condensate storage tank refueling water storage tank

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on July 26, 2022.

startup transformer and engineering safeguards transformers 1 and 2

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

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

(1) main feedwater system B following main feedwater regulating valve stem failure on July 19, 2022

(2) train A component cooling water on August 31, 2022

(3) establish remote control of power operated relief valves and train B excess letdown valves on September 20, 2022

(4) turbine driven auxiliary feedwater pump following maintenance activities on

September 27, 2022 Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the 4160 V safety-related air conditioning distribution system on September 19, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

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

(1) control room, fire area C-27, on July 14, 2022

(2) south small electrical chase 2047 elevation, fire area C-32, on July 14, 2022

(3) fuel building general area, fire area F-1, on August 2, 2022

(4) trains A and B engineering safety feature transforms, fire area Yard - ESF, on September 6, 2022

(5) train B spent fuel pool heat exchanger and pump room, fire area F-2, on September 6, 2022

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from May 23 to July 7, 2022.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered from May 24 to July 5, 2022.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during reactor startup and power accession from forced outage 25-03 on July 21, 2022.

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

(1) The inspectors observed and evaluated the licensed operator simulator evaluation scenarios on September 13, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

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

(1) alternating current distribution system on September 19, 2022

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) train A battery charger, NK25, failures on August 2, 2022

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)

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

(1) train A containment spray system technical specification equipment outage on July 12, 2022

(2) emergent work activities for troubleshooting for the B main feedwater regulating valve failure on July 19, 2022

(3) train B emergency diesel generator and essential service water technical specification equipment outage with nitrogen supply to auxiliary feedwater safety-related accumulators unavailable on July 26, 2022

(4) emergent work activities for trouble shooting train B safety injection pump room cooler due to degraded air flow on August 3, 2022

(5) emergent work activities for stator cooling water pump B motor replacement on September 21, 2022

(6) emergency diesel generator B monthly operability run with engineering safety feature transformer B load tap changer in automatic and removal of switchyard #6 transformer on September 26, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

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

(1) refueling water storage tank potential non-conservative technical specification for minimum required level operability determination on July 27, 2022

(2) train B safety injection room cooler blocked tubes past operability determination on July 28, 2022

(3) condensate storage tank temperature limit operability determination on September 15, 2022

(4) trains A and B essential service water air operated air compressor isolation valve single failure and ultimate heat sink margin operability determination on September 15, 2022

(5) train B safety injection room cooler degraded air flow operability determination on September 27, 2022

71111.18 - Plant Modifications

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

(1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) switchyard permanent modification and transformer replacements on September 26, 2022

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

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

(1) train A 4 kV channel 4 loss of voltage relay failure replacement post-maintenance testing on July 13, 2022

(2) main feedwater B regulating valve repair post-maintenance testing July 21, 2022

(3) main feedwater C regulating valve actuator diaphragm replacement on July 21, 2022

(4) train B safety injection pump room cooler belt replacement post-maintenance testing on August 1, 2022

(5) containment personnel inner hatch position indicator chain replacement and door seal checks on August 10, 2022

(6) turbine driven auxiliary feedwater pump technical specification equipment outage post-maintenance testing on August 18, 2022

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (2 Samples)

(1) train A 4 kV loss of voltage and degraded voltage trip actuating device operational test on July 27, 2022

(2) molded case circuit breaker instantaneous trip surveillance testing acceptance criteria on September 21, 2022

Inservice Testing (IP Section 03.01) (1 Sample)

(1) main feedwater regulating valve B re-baseline following stem and seat replacement on September 21, 2022

71114.01 - Exercise Evaluation

Inspection Review (IP Section 02.01-02.11) (1 Sample)

(1) The inspectors evaluated the biennial emergency plan exercise conducted on August 31, 2022. The exercise scenario simulated a seismic event while the plant was in Mode 5 on the 28th day of a refueling outage, resulting in damage to several onsite structures including the switchyard and fuel building. The simulated damage led to a loss of spent fuel pool water inventory and an unmonitored radiological liquid release from the spent fuel pool to a storm drain. After another simulated seismic event caused further damage to the fuel building and spent fuel inside the pool, there was a simulated monitored gaseous release resulting in the issuance of protective action recommendations to the offsite authorities. The scenario included demonstration of one of the station's extensive damage mitigation guideline strategies, per the requirements of 10 CFR 50.155(b)(2), in mitigating the loss of spent fuel pool water inventory.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:

EPP 06-009, Drill and Exercise Requirements, revision 12, effective 08/16/2022 EPF 06-001-08, Off-Site Communicator Checklist, revision 3, effective 07/11/2022 EPF 06-002-01, Emergency Manager Turnover Sheet, revision 2, effective 08/15/2022 EPF 06-002-04, Facility Briefing, revision 2, effective 08/15/2022 This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) emergency preparedness drill involving evacuation of the control room, partial loss of offsite power, and loss of coolant accident on August 18, 2022

71114.08 - Exercise Evaluation - Scenario Review

Inspection Review (IP Section 02.01 - 02.04) (1 Sample)

(1) The inspectors reviewed the licensee's preliminary exercise scenario that was submitted to the NRC on May 25, 2022, (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML22145A592 and ML22145A593)for the exercise scheduled to occur on August 31, 2022. The inspectors discussed the preliminary scenario with Mr. M. Dekat, Manager, Emergency Preparedness, and other members of the emergency preparedness staff on August 1, 2022. The inspectors' review does not constitute NRC approval of the scenario.

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (9 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) airborne radiation monitors (particulate, iodine, and gaseous) for the unit ventilation and fuel building ventilation

(2) area radiation monitors in the auxiliary building, fuel building, radwaste building, control room and technical support center

(3) Self-reading dosimeters stationed for use at the radiologically controlled area entrance

(4) portable instruments, such as friskers and scalers, used at the radiologically controlled area exit

(5) stationary survey instruments, such as small article monitors, portal monitors and personnel contamination monitors, used at the radiologically controlled area exit

(6) portable radiation instruments, such as friskers, ion chambers, telepoles, AMP-100s, scalers, and continuous air monitoring systems (AMS4s) staged for used to support radiation surveys in the auxiliary building, fuel building, and radwaste building

(7) stationary radiation instruments (portal monitors) used to exit the protected area in the security building

(8) radiation instrumentation in the chemistry laboratory such as high purity germanium detectors, iSolo counter, and liquid scintillation counter

(9) stationary instruments in the radwaste building, such as a small article monitor

Calibration and Testing Program (IP Section 03.02) (15 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Bicron Analyst: WC011334 calibrated November 15, 2021

(2) Canberra GEM-5: WC096667, WC096668, WC096669, and WC096670 batch calibrated February 8, 2022

(3) Canberra iSolo: WC093661 calibrated March 2, 2022

(4) Eberline AMS-4: WC011409 calibrated September 30, 2021, and WC011746 and WC011747 batch calibrated December 13, 2021

(5) Eberline ASP-1: WC010259 calibrated May 9, 2022, and WC096170 calibrated August 27, 2021

(6) Eberline SAC-4: WC096422 calibrated January 4, 2022, and WC011020 calibrated May 17, 2022

(7) high purity germanium detector: detector #1 calibration verification dated June 29, 2021, and detector #8 calibration verification dated June 29, 2021

(8) Ludlum 177: WC011262 calibrated September 9, 2021, WC011272 calibrated June 1, 2022, WC093590 calibrated August 31, 2021, WC093631 calibrated January 5, 2022, and WC093638 calibrated August 31, 2021

(9) Ludlum 2401-P: WC096588 calibrated May 18, 2022

(10) Ludlum 9-4: WC095065 calibrated February 15, 2022, WC095084 calibrated October 7, 2021, and WC095254 calibrated October 18, 2021

(11) MGP TSGII: WC095743 calibrated October 20, 2021, WC095744 calibrated March 17, 2022, WC096003 calibrated March 30, 2022, and WC096004 calibrated February 1, 2022

(12) MGP Tele-Pole: WC094213 calibrated November 15, 2021, WC094211 calibrated November 15, 2021, WC092744 calibrated October 30, 2021, and WC010179 calibrated November 15, 2021

(13) Thermo-Fisher Scientific PM12: WC093328 calibrated March 1, 2021, and WC095921 calibrated December 2, 2021

(14) Thermo-Fisher Scientific SAM12: WC095941 calibrated March 2, 2022

(15) Sorrento Electronics containment high range area radiation monitor: GTRE0059 calibrated March 22, 2021 (electronic) and March 31, 2021 (source), and GTRE0060 calibrated March 11, 2021 (electronic) and March 31, 2021 (source)

Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) containment purge exhaust: GTRE22 work order 20-461478 dated March 18, 2022, and GTRE33 work order 21-475684 dated May 23, 2022

(2) liquid radwaste monitor: HBRT-18 work order 21-471906 dated February 22, 2022

(3) unit ventilation exhaust: GTRE21A work order 21-476209 dated June 6, 2022, and GTRE21B work order 21-471909 dated March 8, 2022

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:

(1) radioactive source storage and labeling, including J. L. Shepherd calibrator unit, serial number JLS-81-CS-S57; J.L. Shepherd Model 51 probe calibrator, serial number 7946GS; J.L. Shepherd irradiator, serial number 2949; and AmBe source, serial number 5670-NE

(2) various containers and dry active waste bags inside the radwaste building

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) solid radwaste system in the radwaste building

(2) main condensate system

Waste Characterization and Classification (IP Section 03.03) (3 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1) reactor coolant system cleanup system (mixed bed resins) sample from 2022

(2) reactor coolant system mechanical filter sample from 2022

(3) reactor coolant system crud for dry active waste sample from 2022

Shipment Preparation (IP Section 03.04) (1 Sample)

(1) The inspectors observed that a shipment containing radioactive material was prepared according to regulatory requirements. The shipment included a residual heat removal pump to Westinghouse shipped as a limited quantity-excepted package, shipment 22-24.

Shipping Records (IP Section 03.05) (3 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) shipment 21-R08, low specific activity (LSA-II), dry active waste, dated February 23, 2021

(2) shipment 21-R10, low specific activity (LSA-II), dry active waste, dated April 6, 2021

(3) shipment 21-R12, low specific activity (LSA-I), liquid concentrates, dated April 13,

OTHER ACTIVITIES - BASELINE

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

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) ===

(1) October 1, 2022 through June 30, 2022 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13)

(1 Sample)

(1) October 1, 2022 through June 30, 2022 EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14)

In that the licensee transitioned its alert and notification system (ANS) to a purely non-siren based system in April 2020. The ANS performance indicator and associated data is no longer required to be reported by the licensee, and thus is not subject to further inspection/verification per IP 71151. Evaluation of the licensee's non-siren based ANS is completed separately per IP 71114.02, Alert and Notification System Evaluation.

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)

(1) July 1, 2021 through June 30, 2022

MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)

(1) July 1, 2021 through June 30, 2022

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

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

(1) security department fitness-for-duty work hour limitations for increase trend in overtime on September 27, 2022

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

(1) The inspectors evaluated the July 18, 2022, reactor trip due to the B main feedwater regulating valve stem failure and licensees response on July 21, 2022.

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000482/2022-001-00, Low Steam Generator Level Due to Main Feedwater Valve Failure Caused Reactor Trip (ML22257A207). The inspection conclusions associated with this LER are documented in this report under Inspection Results below.

Personnel Performance (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated a July 22, 2022, operator error during startup of the main feedwater pump B, which resulted in actuation of both motor driven auxiliary feedwater pumps on main feedwater pump low pressure, and licensees performance on August 4,

INSPECTION RESULTS

Failure to Translate Refueling Water Storage Tank Technical Specification Minimum Water Level into Design Calculations Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.8] - 71111.15 Systems NCV 05000482/2022003-01 Procedure Open/Closed Adherence The inspectors identified a Green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure the applicable design requirements associated with the refueling water storage tank were correctly translated into specifications, drawings, procedure, and instructions. Specifically, the licensee failed to translate the refueling water storage tank technical specification minimum water level of 94 percent into design calculations.

Description:

The inspectors reviewed licensed operator time critical actions associated with shifting the emergency core cooling system and containment spray pumps suction from the refueling water storage tank (RWST) to the containment recirculation sump. As part of this review, the inspectors reviewed design calculation BN-20, RWST Volumes and Set Points, revision 4, which was revised in November 2021 to account for new instrument uncertainty specifications due to digital control system modification and instrument upgrades in accordance with procedure AP 05D-001, Calculation, revision 22A. During the inspectors review of calculation BN-20, it was identified the licensee did not use the Technical Specification 3.5.4, Refueling Water Storage Tank (RWST), minimum water level of greater than or equal to 394,000 gallons (94 percent). Instead, the licensee used the RWST low level alarm water level (96 percent) which first occurred in August 2009 when the licensee approved calculation BN-20 revision 3. Additionally, the inspectors reviewed procedure AP 05D-001 and determined the licensee failed to implement the requirements of the procedure when revising calculation BN-20 for the updated instrument uncertainty.

Specifically, the licensee failed to implement the following step:

Step 6.13.3.5.c: During the verification process, the engineer shall verify calculation assumptions, analytical methods, mathematical accuracy when performing detailed design review, completeness, compliance with design criteria, licensing commitments, the adequacy of the design, and the reasonableness of the results.

The inspectors informed the licensee of their issue of concern with BN-20, revision 3 and 4 using an incorrect calculation assumption for minimum RWST water level and they initiated condition report 10015262.

Corrective Action: The licensee implemented the following corrective actions:

(1) performed an extent of condition review of setpoint calculations associated with the following components: accumulators, condensate storage tank, and sodium hydroxide tank;

(2) issued a change package to update BN-20 and the associated downstream safety analysis documents;

(3) revised procedures STS CR-001, Shift Log for Modes 1,2, and 3, and STS CR-002, Shift Log for Modes 4, 5, and 6, to declare the RWST inoperable when level is less than 97 percent until BN-20 and the associated safety analysis are updated; and (4)performed a past operability review to verify the RWST level was not less than 96 percent in the last 3 years.

Corrective Action Reference: Condition report 10015262

Performance Assessment:

Performance Deficiency: The licensees failure to translate RWST technical specification minimum water level into design calculations was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, accident analysis assumed a value higher than the required technical specification minimum RWST level which allowed more time for operator actions to be accomplished and required the licensee to re-perform accident analysis calculations to assure accident analysis requirements were met.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because it

(1) was not a deficiency affecting the design or qualification of a mitigating system,

(2) does not represent a loss of the probability risk analysis (PRA) function of a single train technical specification system for greater than its allowed outage time,

(3) does not represent a loss of PRA function of one train of a multi-train technical specification system for greater than its allowed outage time, (4)does not represent a loss of the PRA function of two separate technical specification systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,

(5) does not represent a loss of PRA system and/or function as defined by the plant risk information e-book or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and

(6) does not result in the loss of a high safety-significant, nontechnical specification train for greater than 3 days.

Cross-cutting Aspect: H.8 Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, in 2021, the licensee failed to implement procedure AP 05D-001, in part, that engineers shall verify calculation assumptions as part of the adequacy of the design.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, the licensee failed to establish measures to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application for the RWST was correctly translated into specifications, drawings, procedures, and instructions. Specifically, from August 2009 to June 2022, the licensee failed to translate the RWST technical specification minimum water level into the revised design calculations used in part to develop/ensure specifications for the new water level instrumentation were appropriate.

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

Protective Action Recommendation Developed During an Exercise for Subzone Experiencing No Radiological Consequence Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green None (NPP) 71114.01 Preparedness NCV 05000482/2022003-02 Open/Closed The inspectors identified a finding of very low safety significance (Green) with an associated non-cited violation of 10 CFR 50.54(q)(2) for the licensees failure to maintain an emergency plan that follows the requirements of 10 CFR 50.47(b)(10). Specifically, the licensee made a change to their emergency notification form, combining two subzones for protective action recommendations (PARs). This resulted in the licensee issuing a PAR during an exercise for a subzone that was not affected by the simulated release.

Description:

On August 31, 2022, the inspectors observed the licensee perform a biennial full-scale emergency preparedness exercise. The exercise scenario began with the plant in Mode 5 and a seismic event that caused damage to the switchyard, fuel building, and a loss of spent fuel pool inventory to a storm drain which feeds into Coffey County Lake (CCL),located adjacent to the plant site. Due to the damaged switchyard and other in-plant failures, there was a loss of all onsite and offsite AC power to the safety busses for greater than 15 minutes, so the licensee declared an Alert in accordance with their emergency classification procedure. The stations procedure, EPP 06-006, Protective Action Recommendations, revision 10A, step 7.1.1, states in part that upon the declaration of an Alert or higher emergency, evaluate the need for making PARs based on actual or potential radiological releases based on plant conditions. Based on this guidance, the licensee assessed that a PAR to evacuate CCL was warranted due to the unmonitored liquid release from the spent fuel pool to CCL via a storm drain. Using station procedure EPP 06-007, Emergency Notifications, revision 27, and its associated form EPF 06-007-02, WCGS Immediate Emergency Notification, revision 0C, the licensee documented the PAR development as recommending the evacuation of CCL and John Redmond Reservoir (JRR),because the two subzones were together on the form; CCL and JRR are identified by EPP 06-006 as automatic PARs at a Site Area Emergency or General Emergency. At the time there was no radiological release to JRR.

On August 31, 2022, the inspectors observed the post-exercise critique in which the licensee evaluated the aforementioned PAR as accurate although not a PAR identified in the exercise scenario. On September 8, 2022, the inspectors observed the emergency preparedness departments presentation to management on the results of the exercise and reviewed the condition report (CR) 10017337 which documented the evaluation of the PAR to be acceptable, but that procedure EPP 06-006 needed to be evaluated for possible enhancement. Upon discussion with the licensee about the acceptability of the PAR that was developed, the inspectors observed that the licensee had concluded that the performance (issuing the PAR for both CCL and JRR) was in accordance with the stations procedures and emergency plan.

The inspectors questioned the basis for why CCL and JRR were grouped together on the emergency notification form. The licensee made the determination that the subzones CCL and JRR were grouped together in a revision of the emergency notification form in 1998.

Based on the inspectors questioning, the licensee documented in CR 10017704 that this change to the emergency notification form was evaluated as not impacting the emergency plan and that it should be reevaluated.

Federal guidance contained in EPA-400-R-92-001, the Environmental Protection Agencys Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (1992),section 1.2 states, in part, that the risk to health from a protective action should not itself exceed the risk to health from the dose that would be avoided. The inspectors concluded that, because evacuation of any population carries some risk, and in this scenario, there was no actual or imminent radiological risk to JRR, the guidelines in place for the choice of protective actions to evacuate JRR was inconsistent with this Federal guidance.

Corrective Actions: The licensee has initiated a review of the effects of the 1998 notification form change on emergency plan implementation.

Corrective Action References: condition report 10017704

Performance Assessment:

Performance Deficiency: The licensees failure to maintain the effectiveness of their emergency plan was a performance deficiency. Specifically, during an exercise, the licensee failed to implement protective actions at an Alert classification consistent with Federal guidance.

Screening: Using Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening Directions, the inspectors determined that the performance deficiency was more than minor because it was associated with the procedure quality attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the ability to implement adequate protective action recommendations is adversely affected when notification procedures direct issuing PARs to evacuate public from areas that have no commensurate radiological exposure risks during a radiological emergency.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix B, Emergency Preparedness SDP. Using IMC 0609, Attachment 4, Initial Characterization of Findings, and IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, table 5.10-1 and attachment 2; the performance deficiency was determined have very low safety significance (Green) because the finding represented a failure to comply with the planning standard found in 10 CFR 50.47(b)(10), did not constitute a loss or degradation of a risk significant planning standard function and did not constitute a loss of a planning standard function.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. No cross-cutting aspect was assigned to this finding. The cause for the finding occurred in 1998 and was determined to not reflect present licensee performance.

Enforcement:

Violation: Title 10 CFR 50.54(q)(2) requires, in part, that licensees shall follow and maintain the effectiveness of an emergency plan that meets the requirements of the planning standards of 10 CFR 50.47(b). The planning standard described by 10 CFR 50.47(b)(10)requires, in part, that guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed, and in place.

Contrary to the above, from October 28, 1998 to present, the licensee failed to maintain the effectiveness of the emergency plan. Specifically, the licensee had guidelines developed and in place for the choice of protective actions during an emergency that were inconsistent with Federal guidance in that they resulted in a PAR developed at an Alert level during an exercise for a subzone that was experiencing no actual or imminent radiological consequences.

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

Unresolved Item Protective Action Recommendation Developed During an 71114.01 (Open) Exercise May Not Have Been Warranted URI 05000482/2022003-03

Description:

The inspectors identified an unresolved item related to the licensees development of a protective action recommendation (PAR) during a full-scope, NRC evaluated emergency preparedness exercise conducted on August 31, 2022. Specifically, the licensees Emergency Response Organization (ERO) developed a PAR at the General Emergency classification, using station procedure EP 06-006, Protective Action Recommendations, revision 10A, that recommended members of the public within 0-2 miles of the site and 2-10 miles downwind evacuate from those areas. The inspectors questioned the PAR developed by the licensee and whether the appropriate PAR should instead have been either to:

(1) evacuate 0-2 miles based on plant conditions, or

(2) evacuate 0-2 miles and 2-5 miles downwind based on a dose assessment completed based on the release information available to the ERO participating in the exercise at the time. However, based on observations during the exercise and a review of the available records at the time, the inspectors were unable to conclude what information was available or should have been available to the licensee exercise participants at the time of the PAR development, and the basis for implementing that data in the licensees PAR development process.

During the exercise, licensee personnel evaluated that the simulated plant conditions constituted an actual or imminent loss of all three fission product barriers, because there was a radiological release from damaged fuel in the SFP directly to the environment. The inspectors noted that the event took place during Mode 5 and that the release was from damaged fuel in the spent fuel pool (SFP), not the reactor core. Furthermore, the reactor coolant system and containment barriers were not lost or in imminent danger of being lost.

Subsequently, the licensees exercise critique process did not identify the development of the PAR as a weakness in ERO performance or a failure to comply with an emergency plan requirement because they evaluated that the interpretation of the release from damaged fuel in the SFP as an actual or imminent loss of all three fission product barriers to be accurate and consistent with licensee procedures. Therefore, the inspectors concluded that a further review of the licensees training records; basis for their PAR procedure; simulated radiological data during the exercise; and the results of a hypothetical dose assessment is required to determine if the issue of concern has an associated performance deficiency.

Planned Closure Actions: This unresolved item will remain open until a review of the additional requested documents such that the inspectors are able to determine if the issue of concern has an associated performance deficiency or not.

Licensee Actions: There are no pending licensee actions.

Corrective Action References: None.

Failure to Periodically Calibrate Radiation Monitors as Required by 10 CFR 20.1501(c).

Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.4] - 71124.05 Radiation Safety NCV 05000482/2022003-04 Teamwork Open/Closed The inspectors identified a Green NCV of 10 CFR 20.1501(c) for a failure to periodically calibrate radiation monitoring equipment used to perform dose rate and effluent measurements. Specifically, on December 7, 2020, the licensee discontinued periodic calibrations of 35 area radiation monitors (ARMs) distributed throughout the plant and began operating them in a run-to-maintenance mode. In addition, 16 process and effluent radiation monitors were changed to a three-year frequency. Both sets of monitors were not verified to be in calibration prior to the mode and frequency change.

Description:

During a review of calibration records, inspectors identified a total of 51 radiation monitors which had not been periodically calibrated since 2019. Upon further review, the inspectors identified that on December 7, 2020, the licensee changed the calibration frequency for selected radiation monitors throughout the plant. These monitors were not verified to be in calibration prior to the change nor was a technical justification provided for the operational mode or frequency change. The prior calibration frequency for these radiation monitors was 18 months (546 days).

The affected radiation monitors are listed in the Wolf Creek Updated Safety Analysis Report, chapter 11, table 11.5-1 and chapter 12, table 12.3-2 and are used to supplement the personnel and area radiation survey provisions of the plant health physics program and ensure compliance with the personnel radiation protection guidelines of 10 CFR Part 20, 10 CFR Part 50, 10 CFR Part 70, and Regulatory Guides 8.2, 8.8, and 8.12.

A change evaluation was completed on December 7, 2020, during a preventative maintenance ownership group meeting which resulted in 35 ARMs being removed from a routine preventative maintenance and/or calibration schedule and were placed in a run-to-maintenance operating mode. Run-to-maintenance is not a frequency; it is a maintenance strategy. In addition, 16 process and effluent radiation monitors were moved to a three-year calibration frequency. During the change process, these monitors were not verified as being within calibration prior to the monitors being placed in the run-to-maintenance mode or changed to a three-year frequency. Further, a technical justification to support the mode or frequency change was not documented.

The inspectors determined the change was approved by the preventative maintenance ownership group without the involvement of impacted stakeholders (radiation protection organization, emergency planning, or licensing). In addition, the ownership group did not recognize these radiation monitors were used to provide radiological surveys and information as defined in 10 CFR Part 20, meet the requirements of the discharge concentration limits of 10 CFR Part 20 and the as low as is reasonably achievable (ALARA) dose objective of 10 CFR Part 50, Appendix I, and support operator decision making and emergency response.

With regard to the effluent monitors, the inspectors reviewed the licensees 2019, 2020, and 2021 annual effluent release reports and determined the licensee did not fail to implement the effluent program nor had public doses greater than the 10 CFR Part 50, Appendix I criterion, or 10 CFR 20.1301(e) annual public dose equivalent in excess of 25 millirems to the whole body, 75 millirems to the thyroid, and 25 millirems to any other organ. The inspectors determined the effluent monitors were able to assess public dose.

In addition, the inspectors reviewed a listing of condition reports for deficiencies identified for the table 11.5-1 liquid and airborne process and effluent monitors and table 12.3-2 ARMs since July 2019. All 16 process and effluent radiation monitors and 8 ARMs were identified with some form of calibration, source check, material/component, or other performance deficiency during this time period. The inspectors were not able to identify how the licensee used or considered the documented issues regarding each monitor in the decision to modify its preventative maintenance and/or calibration frequency.

Corrective Actions: The licensee entered the issue in the corrective action program, implemented a prompt calibration verification for two ARMs used in emergency action level declarations, and are to re-evaluate the periodic calibration of affected radiation monitors.

Corrective Action References: condition report 10016222

Performance Assessment:

Performance Deficiency: Failure to periodically calibrate radiation monitors as required by 10 CFR 20.1501(c) is a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the program and process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the licensee did not verify the radiation monitors as being within calibration prior to the frequency change.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding to be of very low safety significance (Green) because

(1) it was not associated with ALARA planning or work controls,

(2) there was no overexposure,

(3) there was no substantial potential for an overexposure, and

(4) the ability to assess dose was not compromised.

Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, impacted stakeholders (radiation protection, emergency planning, and licensing) were not included on decisions that negatively affected the preventative maintenance, calibration commitments, and regulatory requirements for installed radiation monitors.

Enforcement:

Violation: Title 10 CFR 20.1501(c) requires in part, the licensee ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluents) are calibrated periodically for the radiation measured.

Contrary to the above, as of December 7, 2020, the licensee failed to ensure radiation monitors were calibrated periodically for the radiation measured. Specifically, the licensee discontinued the periodic calibrations of 35 ARMs and began operating them in a run--to-

-maintenance mode without verifying the monitors were in calibration. In addition, 16 process and effluent monitors were not verified in calibration prior their frequency being changed to three years.

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

Failure to Properly Evaluate the Use of Anti-Seize Lubricant and Have Adequate Work Instructions Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green None (NPP) 71153 FIN 05000482/2022003-05 Open/Closed The inspectors reviewed a self-revealed Green finding for the licensees failure to properly evaluate the use of anti-seize lubricant and have adequate work instructions to prevent its use in the packing gland area of the main feedwater regulating valves. This resulted in stress corrosion cracking in the B main feedwater regulating valve which caused stem separation and an automatic reactor trip on steam generator B low level.

Description:

On July 18, 2022, the B main feedwater regulating valve (MFRV) stem failed causing the valve to go closed. This caused a sudden reduction in feedwater flow to the B steam generator and resulted in an automatic reactor trip on B steam generator low level.

The licensee entered this issue into their corrective action program as condition report 10016103, classified it a significant condition adverse to quality, performed a root cause evaluation, and submitted Licensee Event Report 05000482/2022-001-00, Low Steam Generator Level due to Main Feedwater Valve Failure Caused Reactor Trip, revision 0.

The cause of the valve stem failure was due to stress corrosion cracking (SCC) starting in the region where the valve stem entered the packing area of the valve, which resulted from using the anti-seize lubricant along with high temperatures and susceptible material. The work instructions for assembling the MFRVs included a note that allowed the use of a lubricant that contained chlorides and fluoride concentrations greater than what was allowed by procedure AP 14B-001, Chemical Control Program, revision 16, for that application.

The inspectors reviewed the above information and concluded the licensee failed to implement the self-imposed standard to appropriately evaluate the use of anti-seize lubricant during the disassembly and reassembly of the MFRV in accordance with procedure AP 14B-001. Specifically, the licensee failed to have adequate work instructions for assembling the MFRVs to prevent the use of anti-seize lubricant that contained chlorides and fluoride to contact stainless steel without the surface being cleaned with a category I cleaner and rinsed off with de-ionized water prior to process fluids exceeding 150oF. The MFRV gland packing area has main feedwater exceeding 150oF, therefore gland packing area with increased chloride and fluoride concentration would provide an atmosphere conductive to stress corrosion cracking of stainless steel.

Corrective Actions: The licensee performed the following corrective actions:

(1) replaced B main feedwater regulating valve stem;

(2) updated core work instructions for main feedwater regulating valve disassembly and reassembly to ensure no anti-seize lubricant is used on the unthreaded portion of the stem to prevent reoccurrence;

(3) initiated training for planners and implementers on the effects of chemicals on stainless steel components; and

(4) sent out the stems on the four MFRVs for examination during refueling outage 25.

Corrective Action References: condition report 10016103

Performance Assessment:

Performance Deficiency: The licensees failure to properly evaluate the use of anti-seize lubricant and have adequate work instructions to prevent the use in the packing gland area was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensee failed to appropriately evaluate the use of anti-seize lubricant for the main feedwater regulating valves. This resulted in stress corrosion cracking to occur in the B main feedwater regulating valves which resulted in a stem separation and an automatic reactor trip on steam generator B low level.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using exhibit 1, section B, the inspectors determined the finding was of very low safety significance (Green) because the finding did cause a reactor trip, but not the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (e.g., loss of condenser, loss of feedwater).

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. Specifically, the failure to properly evaluate and the changes to the work order instructions occurred in May 2007.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

EXIT MEETINGS AND DEBRIEFS

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

On June 30, 2022, the inspectors presented the technical debrief for the biennial requalification inspection results to Mr. B.J. Bayer, General Manager Plant Operations, and other members of the licensee staff.

On July 21, 2022, the inspectors presented the radiation monitoring instrumentation, radioactive solid wastes processing, and radioactive material handling, storage and transportation inspection results inspection results to Mr. C. Reasoner, Chief Executive Officer, and other members of the licensee staff.

On July 28, 2022, the inspectors presented the biennial requalification inspection results to Mr. E. Carlson, Director of Operations, and other members of the licensee staff.

On August 1, 2022, the inspectors presented the emergency preparedness exercise scenario review inspection results to Mr. M. Dekat, Manager, Emergency Preparedness, and other members of the licensee staff.

On October 4, 2022, the inspectors presented the integrated inspection results to Mr. B.J. Bayer, General Manager Plant Operations, and other members of the licensee staff.

On October 12, 2022, the inspectors presented the emergency preparedness exercise inspection results to Mr. J. McCoy, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Calculations AL-16-W Determine the Available NPSH for the Auxiliary Feedwater 1

Pumps, with Dissolved Nitrogen in the Condensate Storage

Tank

BN-M-016 RWST Temperature Indication at Detector (BNTI0002, 0

BNTI0005) vs RWST Bulk Water Temperature

XX-C-075 Peak Flood Discharge Calculation 1

XX-C-076 Flood Water Surface Elevation Calculation 1

Corrective Action Condition Report 10016140

Documents

Corrective Action Condition Reports 10015840, 10016237, 10016238, 10016770

Documents

Resulting from

Inspection

Procedures OFN SG-003 Natural Events 39

OFN SG-048 Flash Flood Warning 6

STS CR-001 Shift Log for Modes 1, 2, and 3 114

SYS OPS-009 Hot Weather Operations 4

71111.04 Calculations XX-E-006 AC System Analysis 9

Corrective Action Condition Reports 99349, 117441, 127269, 10012127, 10006961, 10012599

Documents

Corrective Action Condition Reports 10017267, 10017628

Documents

Resulting from

Inspection

Drawings E-009B-00013 Fastener Location Operator W01

E-11001 Main Single Line Diagram 13

M-12AE01 Piping and Instrumentation Diagram Feedwater System 46

M-12AL01 Piping and Instrumentation Diagram Aux Feedwater System 32

M-13AE03 Piping Isometric Main Feedwater Turbine Building 11

Miscellaneous E-1F9920 Design Basis Document for OFN RP-017A, Hot Standby to 3

Cold Shutdown Form Outside the Control Room Due to Fire

WCNOC-17-0007 Large Power Transformer Replacement Plan 06/30/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures CKL AL-120 Aux Feedwater Normal Lineup 44A

EMG C-0 Loss of All AC Power 45A

EMG CS-01 Loss of All AC Power Recovery without SI Required 29

OFN NB-030 Loss of AC Emergency Bus NB01 (NB02) 40

OFN PR-017A Hot Standby to Cold Shutdown from Outside the Control due 13

to Fire

OFN RP-017 Control Room Evacuation 54

STN IC-234 Channel Calibration Boric Acid Transfer Pup to Charging 4A

Pump Suction Flow Instrument Loop BG LPF-0183

STS NB-005 Breaker Alignment Verification 36

SYS NB-201 Transferring NB01 Power Sources 65

Work Orders WO 15-404126-014, 15-404126-030, 15-408281-007,

15-408281-088, 15-408281-095, 15-408281-110,

17-433510-000, 17-433510-008, 20-458869-000,

20-459217-000

71111.05 Calculations XX-E-013 Post-Fire Safe Shutdown (PFSSD) Analysis 4

Corrective Action Condition Reports 116489, 116831

Documents

Corrective Action Condition Reports 10016514, 10017431, 10017860, 10017863

Documents

Resulting from

Inspection

Drawings M-12BB02 Piping and Instrumentation Diagram Reactor Coolant 34

System

Miscellaneous BAP-17-0008 Breach Authorization Permit

E-1F9910 Post-Fire Safe Shutdown Area Analysis 17

TCMP-22-0022 Transient Combustible Permit 0

TCMP-22-0088 Transient Combustible Permit 0

WCRE-35 Boundary Matrix 9

Procedures AP 10-106 Fire Preplans 21

OFN RP-017 Control Room Evacuation 54

OFN RP-017A Hot Standby to Cold Shutdown from Outside the Control 13

Room Due to Fire

STN FP-224 Fire Door Position Verification - Closed, Unlocked, 18

Inspection Type Designation Description or Title Revision or

Procedure Date

Unalarmed

STN FP-440 Fire Door Visual Inspection 17

Work Orders WO 17-432820-003, 19-448431-001, 21-471354-000,

21-472551-006, 22-480675-000

71111.11B Corrective Action Condition Report 10014872

Documents

Miscellaneous Week 6 JPMs

Written Exam Tracking Tool

22 Written Exam for Week 7

Exam Remediation Packages

Wolf Creek Cycle 25 Simulator Data

22 Week 4 JPMs

22 Week 2 JPMs

LOR 2021-2022 Sample Plan

21-2022 Operating Test Overlap Analysis

22 Week 5 Written Exam

AFP 30B-001-02 Reactor Operator Active Status Restoration 7A

AI 13G-003 Medical Examinations for Licensed Personnel 18

AIF 13G-002-01 Medical Clearance Form 11

AIF 13G-002-05 Licensed Operator Medical History 0

APF 30B-001-01 Senior Reactor Operator Active Status Restoration 10A

IC314 2022 Week 3 Scenario

IC316 2022 Week 2 Scenario

IC319 2022 Week 1 Scenario

IC325 2022 Week 5 Scenario

NISP TR-01 Form Form 10 - Remediation 3.2

Procedures AIF 30B-015-09 NRC Exam - Simulator Security Checklist 9

AP 30B-001 Licensed Operator Requalification Training Program

71111.11Q Procedures ALR 00-057A SR Flux Doubled 10

ALR 00-110B SG C Lev Dev 12

GEN 00-003 Hot Standby to Minimum Load 108

71111.12 Calculations XX-E-009 CN 6, System NB, NG, PG Undervoltage/Degraded Voltage 1

Inspection Type Designation Description or Title Revision or

Procedure Date

Corrective Action Condition Reports 127972, 141961, 10012090, 10012220, 10012304,

Documents 10014681, 10015024, 10015164, 10015381, 10017247

Engineering CP 014372 Obsolete Type NGV 120 VAC Undervoltage Relay 0

Changes

Procedures STS IC-802A 4KV Loss of Voltage and Loss of Offsite Power Channel 9

Calibration Train A

Work Orders WO 12-358878-000, 19-454090-004, 19-454090-006

71111.13 Calculations FL-02 Flooding of Auxiliary Building Rooms 1107-1114 2

Corrective Action Condition Reports 10016141, 10016320, 10016321, 10016406, 10016449,

Documents 10017684

Corrective Action Condition Report 10016404

Documents

Resulting from

Inspection

Drawings M-12AL01 Piping and Instrumentation Diagram Auxiliary Feedwater 32

System

M-724-00254 Feed Water Control Valve W25

M-724-00827 AEFV0520 Stem W02

Miscellaneous EQSD-I Equipment Qualification Program Description 16

SWA 2022-005N Wolf Creek Substation Work Authorization 09/22/2022

WCRE-35 Boundary Matrix 9

Procedures AI 14-011 Lifting and Rigging 9

AI 22C-013 Protected Equipment Program 24

ALR 00-130C ESF N2 ACC Press LOLO 8

ALR 00-130D ESF N2 ACC Press LO 11

AP 10-104 Breach Authorization 39A

AP 22C-003 On-Line Nuclear Safety and Generation Risk Assessment 25

MPM XX-002 Watertight Doors Preventive Maintenance Activity 7B

STS KJ-005B Manual/Auto Start, Sync, and Loading of EDG NE02 69

Work Orders WO 22-476908-001, 22-477629-000, 22-480583-000, 22-

480641-001, 22-480641-002, 22-481724-001

71111.15 Calculations AL-16-W Determine the Available NPSH for the Auxiliary Feedwater 1

Pumps, with Dissolved Nitrogen in the Condensate Storage

Tank

Inspection Type Designation Description or Title Revision or

Procedure Date

AL-30-WC CN0005, AFW System Setpoints: Pump Suction Pressure; 3

Automatic ESW Switchover, and CST Low Level

BN-20 RWST Volumes and Level Set Points 1, 2, 3, 4

CKL ZL-003 Control Room Daily Readings 77

DEB Potential Free Gas Concentration 0

EF-M-046 UHS Analysis with Initial Lake Temperature Up to 94 0

degrees F

FL-018 Containment Flood Levels for LCOA and MSLB 4

GL-M-007 Calculate Cooling Load in SR Pump Rooms Post LOCA: 0

1107, 1108, 1109, 1110, 1111, 1112, 1113, 1114, 1401, and

1406

GL-M-007 Calculate Cooling Load in SR Pump Rooms Post LOCA: 0

1107, 1108, 1109, 1110, 1111, 1112, 1113, 1114, 1401 and

1406

XX-M-068 Tube Plugging Criteria for Safety-Related Room Cooler 2

(Aerofin AL6XN) Cooling Coils

XX-M-080 Wolf Creek Generating Station Pump Room Heat-up 1

Analysis

Corrective Action Condition Report 10015041

Documents

Corrective Action Condition Reports 10014873, 10015106, 10015262, 10015654, 10015802,

Documents 10015805, 10016320, 10016321, 10016406, 10016770

Resulting from

Inspection

Drawings M-13AL01 Piping Isometric Auxiliary Feedwater Pumps Suction Piping 19

Engineering 012968 System Descriptions M-10BN and M-10EN Changes - 0

Changes Resolve CDBI 2007 Issues

CP 020550 System Description M-10BN Update 0

Engineering BED Blocked Tubes on SGL09B - CR 10015041 0

Evaluations DED CST Low Temperature Limit for Available NPSH with 0

Dissolved Nitrogen

Miscellaneous EQSD-1 Equipment Qualification Design Basis document; Equipment 16

Qualification Program Description

M-10AP System Description Condensate Storage and Transfer 4

Inspection Type Designation Description or Title Revision or

Procedure Date

System

WCRE-01 WCNOC Total Plant Setpoint Document 112

WCRE-39 Ovation TPSD Information 0

Procedures AP 26C-004 Operability Determination and Functionality Assessment 46

STN PE-036 Safety Related Room Cooler Heat Transfer Verification and 17

Performance Trending

STS CR-001 Shift Log for Modes 1, 2, and 3 114

STS CR-002 Shift Log for Modes 4, 5, and 6 91

Work Orders WO 08-302031-009, 12-362212-003, 22-480641-000

71111.18 Drawings KD-7496 One Line Diagram 76

WIP-KD-7496- One Line Diagram 0

073-B-1

Engineering DCP 020292 Substation Transformers No. 8, 9, 10, and 11 and Breaker 0

Changes Replacement R25

Engineering SY-E-002 Switchyard Transformer Nos 8, 9, 10, and Impedance and 0

Evaluations Sizing Study

Procedures ALR 00-025E NG02 Bus Trouble 11

SYS NB-200 Transformer XBN01 Supply Between SL7 and #7 21

Transformer

SYS NB-204 XNB02 Load Tap Changer Operation 1

71111.19 Corrective Action Condition Reports 10015899, 10016406

Documents

Procedures AP 29B-002 ASME Code Testing of Pumps and Valves 12A

STS IC-208A 4kV Loss of Voltage and Degraded Voltage TADOT NB01 7

Bus - SEP GRP 1

STS IC-802A 4kV Loss of Voltage and Loss of Offsite Power Channel 9

Calibration Train A

Work Orders WO 22-477206-001, 22-477629-000, 22-478842-000,

2-480583-005, 22-480583-006, 22-480583-007,

2-480641-001, 22-480641-002,

71111.22 Corrective Action Condition Reports 10006670, 10012475, 10013605, 10015381, 10015899,

Documents 10015900, 10015905,

Corrective Action Condition Reports 10015906, 10017815, 10017816

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from

Inspection

Miscellaneous APF 29B-002-08 Post Maintenance Data Sheet for Potential Stroke Time 4A

Changes

Procedures AP 29B-002 ASME Code Testing of Pumps and Valves 12A

MGE EOOP-11 Molded Case Circuit Breaker and Ground Fault Sensor 37A, 38

Testing

OFN SB-008 Instrument Malfunctions 53

STS AE-211 Main Feed Reg Valve Inservice Test 6

STS IC-208A 4kV Loss of Voltage and Degraded Voltage TADOT NB01 7

Bus - SEP GRP 1

Work Orders WO 21-471613-000, 21-471873-000, 21-472268-000,

21-472408-000, 21-475262-000, 21-476606-000,

2-477206-000

71114.01 Corrective Action Condition Reports 00139044, 10001986, 10009202, 10009679, 10009715,

Documents 00140349, 00145276, 00145285, 10008518, 10009546,

10014262, 10015816, 10001992, 00146690, 00139416,

00143612, 10008569, 10013976, 10016938, 10016941,

10016950, 00140898, 00139443, 00117456, 00117458,

00117471, 00117481, 00139002, 00139063, 00145524,

00145793, 10001964, 10006686, 10006784, 10008468,

10013870, 10014181, 10014212, 10016954

Corrective Action Condition Report 10017704

Documents

Resulting from

Inspection

Miscellaneous 2022 Wolf Creek Generating Station Evaluated Exercise 08/22/2022

Extent of Play Agreement

Procedures AP 06-002 Radiological Emergency Response Plan 22

EDMG-001 Extensive Damage Mitigation Guideline 6B

EDMG-T01 EDMG Tool Box 18

EPP 06-005 Emergency Classification 9A

EPP 06-006 Protective Action Recommendations 10A

EPP 06-007 Emergency Notifications 27

Inspection Type Designation Description or Title Revision or

Procedure Date

EPP 06-012 Dose Assessment 17B

EPP 06-013 Exposure Control and Personnel Protection 6A

OFN NB-030 Loss of AC Emergency Bus NB01 (NB02) 40

OFN NB-034 Loss Of All AC Power - Shutdown Conditions 33

OFN SG-003 Natural Events 39

SAM DPG Diagnostic Process Guideline 0

SAM SAG-01 Control SFP Level 0

SAM SAG-01 Initial Response 2A

SAM SAG-02 TSC Recommending Strategies 2

SYS KU-121 Energizing NB01 From Station Blackout Diesel Generators 10

71114.04 Miscellaneous E-Plan Screening for EPF 06-001-08, Rev. 3 06/22/2022

E-Plan Screening for EPP 06-009, Rev 12 07/12/2022

E-Plan Evaluation for EPP 06-009, Rev 12 08/15/2022

E-Plan Screening for EPF 06-002-01, Rev. 2, & EPF 06-002- 08/11/2022

04, Rev. 2

E-Plan Evaluation for EPF 06-002-01, Rev. 2, & EPF 06- 08/15/2022

2-04, Rev. 2

EPF 06-001-08 Off-Site Communicator Checklist 2

EPF 06-001-08 Off-Site Communicator Checklist 3

EPF 06-002-01 Emergency Manager Turnover Sheet 1

EPF 06-002-01 Emergency Manager Turnover Sheet 2

EPF 06-002-04 Facility Briefing 2

EPF 06-002-04 Facility Briefing 1

Procedures AI 26A-003 Regulatory Evaluations (Other than 10 CFR 50.59) 17

EPP 06-009 Drill and Exercise Requirements 11

EPP 06-009 Drill and Exercise Requirements 12

71114.08 Miscellaneous ML22145A593 WCGS Emergency Planning Drill 22-EVAL 05/25/2022

71124.05 Calibration WBC-200-ICS-E-GEM10 High Purity Germanium Body 09/03/2021

Records Counting Chair

Purchase Order Sorrento Electronics Certificate of Calibration - A10683 11/07/1991

544358 Serial Number 291

Purchase Order Sorrento Electronics Certificate of Calibration - A10686 11/07/1991

544358 Serial Number 309

Inspection Type Designation Description or Title Revision or

Procedure Date

WC1609 Hidex Quality Assurance Report: 300SL, Serial Number 02/24/2017

2170628

Work Order 19- Channel Calibration: Turbine Building Effluent Monitor: 12/20/2019

2744 LERE59

Corrective Action Condition Reports 00133240, 00133298, 00134482, 00134850, 00135383,

Documents 00135747, 00135759, 00135984, 00136091, 00137040,

00137487, 00138039, 00138045, 00138082, 00138200,

00138223, 00138352, 00138565, 00138881, 00138883,

00138884, 00138936, 00138964, 00139105, 00139176,

00139305, 00139306, 00139385, 00139500, 00139550,

00139576, 00139586, 00139656, 00139761, 00139905,

00139933, 00139934, 00139935, 00139948, 00139956,

00139965, 00139978, 00139997, 00140361, 00140505,

00140522, 00140543, 00140593, 00140715, 00140716,

00140724, 00140729, 00140775, 00140794, 00140908,

00141118, 00141257, 00141266, 00141361, 00141398,

00141399, 00141540, 00141596, 00141683, 00141741,

00141779, 00141794, 00142217, 00142375, 00142506,

00142676, 00142698, 00142699, 00142717, 00142718,

00142808, 00142836, 00142898, 00142899, 00142932,

00142933, 00142939, 00142951, 00142961, 00142966,

00143150, 00143246, 00143261, 00143534, 00143544,

00143605, 00143607, 00143618, 00143619, 00143993,

00144235, 00144269, 00144306, 00144364, 00144379,

00144424, 00144519, 00144820, 00144866, 00144873,

00144947, 00144973, 00144991, 00144992, 00145196,

00145202, 00145313, 00145336, 00145345, 00145357,

00145437, 00145572, 00145580, 00145666, 00145741,

Inspection Type Designation Description or Title Revision or

Procedure Date

00145975, 00146058, 00146159, 00146174, 00146276,

00146280, 00146336, 00146392, 00146442, 00146503,

00146554, 00146595, 00146597, 00146630, 00146638,

00146661, 00146696, 10000292, 10000360, 10000442,

10000445, 10000557, 10000726, 10000990, 10000991,

10001090, 10001138, 10001346, 10001641, 10001865,

10002039, 10002256, 10002451, 10002453, 10002474,

10002564, 10002781, 10002839, 10003168, 10003266,

10005459, 10005679, 10005879, 10005922, 10006132,

10006378, 10006503, 10006519, 10006567, 10006698,

10006760, 10006765, 10007080, 10007082, 10007972,

10008209, 10008212, 10008248, 10008412, 10008579,

10008629, 10008712, 10008890, 10008891, 10008893,

10008974, 10009063, 10009223, 10009271, 10009272,

10009304, 10009404, 10009408, 10009409, 10009491,

10009544, 10009588, 10009651, 10009735, 10009737,

10009739, 10009820, 10010033, 10010035, 10010036,

10010037, 10010038, 10010039, 10010093, 10010192,

10010314, 10010375, 10010416, 10010491, 10010492,

10010574, 10010769, 10010777, 10010847, 10010935,

10010937, 10011092, 10011280, 10011446, 10011577,

10011659, 10011942, 10012037, 10012143, 10012456,

10012458, 10012766, 10012823, 10012865, 10012890,

10013163, 10013269, 10013501, 10013642, 10013752,

10013761, 10014206, 10014242, 10014325, 10014339,

10014361, 10014462, 10014491, 10014493, 10014535,

10014536, 10014580, 10014858, 10015004, 10015072

Corrective Action Condition Report 10016222

Documents

Resulting from

Inspection

Miscellaneous Preventive Maintenance Optimization Group (PMOG) 12/07/2020

Meeting

Preventive Maintenance Optimization Group (PMOG) 12/07/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Meeting - PMC Approvals

Licensed Quantity Source Inventory Report 05/18/2022

2018 Annual Radioactive Effluent Release Report - Report 04/30/2019

2019 Annual Radioactive Effluent Release Report - Report 04/26/2020

20 Annual Radioactive Effluent Release Report - Report 04/29/2021

21 Annual Radioactive Effluent Release Report - Report 04/25/2022

OP 19-0033 Plant Health Committee Meeting Minutes 09/16/2019

SP019018 Computer Database Change Request: GTRE059 11/02/2019

SP019026 Computer Database Change Request: LEL596 12/30/2019

Procedures AI 16B-002 Preventative Maintenance Change Process 19

APF 06-002-03 EAL Classification Matrix 1

71124.08 Corrective Action Condition Reports 00144222, 00145920, 10000149, 10002460, 10003182,

Documents 10005475, 10005969, 10006009, 10009948, 10009949,

10010255, 10011715, 10011716, 10011872

Corrective Action Condition Report 10016221

Documents

Resulting from

Inspection

Miscellaneous RA 21-0042 Wolf Creek Generating Station 2020 Annual Radioactive 04/29/2021

Effluent Release Report - Report 44

RA 22-0038 Wolf Creek Generating Station 2020 Annual Radioactive 04/25/2022

Effluent Release Report - Report 45

Procedures AP 07B-001 Radioactive Releases 24

AP 31A-100 Solid Radwaste Process Control Program 9

CHS RW-G02 Radwaste Vent Sampling and/or Exchange of Filters 5

CHS SJ-144A Sampling Instructions 2

RPP 02-210 Radiation Survey Methods 50A

RPP 07-110 Solid Radwaste Packaging 11

RPP 07-123 Preparation and Shipment of Radioactive Waste and 9B

Material

Inspection Type Designation Description or Title Revision or

Procedure Date

RPP 07-124 Physical Security and Transportation Notification 3A

Requirements for Category 1 and 2 Radioactive Material

Radiation Work K03-005 Waste Processing Activities, Cartridge Filter Change-out, 0

Permits (RWPs) and Resin Transfer

Self-Assessments 2022-2340 Quick Hit of NRC Inspection Procedure 71124.08 N/A

2-01-RP/PC Quality Assurance Audit Report Radiation Protection & 03/02/2022

Process Control

71151 Corrective Action Condition Reports 00143506, 10012628, 10013234, 10015837, 10009708,

Documents 10012518, 10013554, 10013886, 10009356, 00138999,

10008479, 10013157, 10013161, 10016905, 10009736,

10010142, 10010288, 10015394

Miscellaneous DEP PI Data 2021Q3 - 2022Q2

Quarterly Key ERO Member Drill Participation Data

21Q3 - 2022Q2

Procedures AI 26A-004 Emergency Planning Performance Indicators 9

AI 26A-008 NRC/INPO/WANO Performance Indicator and MOR 2

Reporting

SYS KU-122 Energizing NB02 From Station Blackout Diesel Generators 11

71152A Corrective Action Condition Reports 10015453, 10015454, 10015455, 10015456, 10015457,

Documents 10015458, 10015459, 10015460, 10015461, 10015462,

10015463, 10015464, 10015465, 10015466, 10015467,

10015468, 10015469, 10015470, 10015471, 10015479,

10015538, 10015539, 10015540, 10015541, 10015542,

10015543, 10015575, 10015576, 10015578, 10015579,

10016534, 10016635, 10016638

Miscellaneous APF 13-001-01 Fatigue Assessment 15A

APF-13-001-04 Fatigue Assessment 7

71153 Corrective Action Condition Reports 10016103, 10016194, 10016195, 10016196, 10016197,

Documents 10016205, 10016207, 10016210, 10016247

Procedures AI 16C-007 Work Order Planning 21

AI 16C-007 Work Activity Planning 57C

AP 20-002 Post-Trip Review 18

AP 21-001 Conduct of Operations 86

AP 26A-001 Reportable Events - Evaluation and Documentation 25

Inspection Type Designation Description or Title Revision or

Procedure Date

EMG E-0 Reactor Trip or Safety Injection 45

EMG ES-02 Reactor Trip Response 41

GEN 00-005 Minimum Load to Hot Standby 95

MGM MOOC-11 Valve Lapping 6A

SYS AE-121 Turbine Driven Main Feedwater Pump Startup 51

SYS AL-120 Motor Driven or Turbine Driven AFW Pump Operations 55A

Work Orders WO 21-473455-002

36