IR 05000482/2024010
| ML24254A437 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/10/2024 |
| From: | Ami Agrawal NRC/RGN-IV/DORS |
| To: | Reasoner C Wolf Creek |
| References | |
| IR 2024010 | |
| Preceding documents: |
|
| Download: ML24254A437 (21) | |
Text
September 10, 2024
SUBJECT:
WOLF CREEK GENERATING STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000482/2024010
Dear Cleve Reasoner:
On July 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Wolf Creek Generating Station and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program to confirm that the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight Process can continue to be implemented.
The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and the stations use of industry and NRC operating experience information. The results of these evaluations are in the enclosures.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
One finding of very low safety significance (Green) is documented in this report (Enclosure 2).
Enclosure 2 transmitted herewith contains SUNSI. When separated from Enclosure 2, this transmittal document and Enclosure 1 are decontrolled. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation 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 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, Enclosure 1, 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. Enclosure 2 contains Security-Related Information, so Enclosure 2 will not be made publicly available in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390(d)(1). If you choose to provide a response that contains Security-Related Information, please mark your entire response, Security-Related Information-Withhold from public disclosure under 10 CFR 2.390, in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). The NRC is waiving the affidavit requirements for your response in accordance with 10 CFR 2.390(b)(1)(ii).
Sincerely, Ami N. Agrawal, Team Leader Inspection Programs & Assessment Team Division of Operating Reactor Safety Docket No. 05000482 License No. NPF-42
Enclosures:
As stated
Inspection Report
Docket Number:
05000482 License Number:
NPF-42 Report Number:
05000482/2024010 Enterprise Identifier:
I-2024-010-0006 Licensee:
Wolf Creek Nuclear Operating Corp.
Facility:
Wolf Creek Generating Station Location:
Burlington, KS Inspection Dates:
July 22, 2024, to July 30, 2024 Inspectors:
D. Dodson, Senior Reactor Inspector J. Drake, Senior Reactor Inspector C. Henderson, Senior Resident Inspector S. Obadina, Reactor Operations Engineer Approved By:
Ami N. Agrawal, Team Leader Inspection Programs & Assessment Team Division of Operating Reactor Safety Enclosure 2 transmitted herewith contains SUNSI. When separated from Enclosure 2, the transmittal document and Enclosure 1 are decontrolled. 2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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 Use the Site Corrective Action Program to Correct Failures and Deficiencies in the Physical Protection Program Cornerstone Significance Cross-Cutting Aspect Report Section Security Green NCV 05000482/2024010-01 Open/Closed
[P.2] -
Evaluation 71152B The NRC identified a Green non-cited violation of 10 CFR 73.55(b)(10) for the licensees failure to take effective corrective actions to prevent recurrence of failures and deficiencies in the physical protection program. This non-cited violation is described in of this report.
Additional Tracking Items
None. 3
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees problem identification and resolution program, use of operating experience, audits and self-assessments, and safety-conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action program and the licensees effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspection team evaluated the stations compliance with NRC regulations and licensee standards like procedures for implementing the corrective action program. The inspectors sampled over 160 condition reports and their associated cause evaluations, as applicable. The inspectors also conducted a focused review of steam generator water level control modifications (7300 system). The corrective actions for the following non-cited violations (NCVs) and findings were evaluated as part of the assessment: NCV 05000482/2022001-01; NCV 05000482/2022001-02; NCV 05000482/2022002-01; NCV 05000482/2022003-01; NCV 05000482/2022003-04; NCV 05000482/2022004-01; NCV 05000482/2022050-01; NCV 05000482/2022050-04; NCV 05000482/2022401-03; NCV 05000482/2022402-02; NCV 05000482/2022404-01; NCV 05000482/2022404-02; NCV 05000482/2023001-01; NCV 05000482/2023002-01; NCV 05000482/2023003-01; and NCV 05000482/2024001-02.
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments. 4
- Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Effectiveness Based on the samples reviewed, the inspectors determined that the licensee's corrective action program was adequate and supported nuclear safety during the assessed timeframe.
However, the inspectors noted one weakness in the area of effectiveness of corrective actions; additionally, the inspectors noted recent performance challenges in the areas of problem identification, prioritization and evaluation of issues, use of self-assessments and audits, and operating experience.
Problem Identification The inspectors found that the licensee was generally identifying and documenting problems at an appropriately low threshold that supported nuclear safety. During the prior 24 months, the licensee entered approximately 5,700 condition reports into the corrective action program as conditions adverse to quality and initiated about 16,800 total condition reports. However, the inspectors noted some current performance challenges associated with identification of issues and entering issues into the corrective action program. Specifically, this report documents one minor performance deficiency with eight examples associated with identification of conditions adverse to quality during the screening process and an observation associated with identifying nuclear safety culture assessment trends as conditions adverse to quality.
Problem Prioritization and Evaluation The inspectors found that the licensee was adequately prioritizing and evaluating problems such that nuclear safety was supported. However, the inspectors noted some current performance challenges associated with evaluation of issues. Specifically, this report documents two observations associated with extent of condition reviews and evaluation documentation quality.
In addition to these issues identified by the team, the inspectors noted three other performance challenges documented in recent NRC inspection reports. Specifically, relevant issues included NCV 05000482/2022050-04, NCV 05000482/2022402-02, and NCV 05000482/2022404-02. In each case, the performance deficiency or underlying causes related to inadequate evaluation of a condition adverse to quality or a finding that was assigned a P.2, Evaluation, cross-cutting aspect.
Effectiveness of Corrective Actions The inspectors concluded that the station is adequately developing effective corrective actions and timely implementing those actions for the problems evaluated in the corrective action program, commensurate with their safety significance. However, the inspectors concluded that the station has a weakness associated with effectiveness of corrective actions 5 based on a review of recently documented performance issues and additional concerns identified during the inspection. Specifically, this report includes one reoccurring NCV associated with effectiveness of corrective actions (NCV 05000482/2024010-01, which is included in Enclosure 2), one minor violation with three examples associated with failures to implement corrective actions that fully address the causes identified, and an observation associated with the licensee missing two opportunities to take more robust actions that might have prevented a July 2022 reactor trip. Additionally, the inspectors noted two other performance challenges associated with effectiveness of corrective actions, which were documented in recent NRC inspection reports. These included NCV 05000482/2022001-01 and NCV 05000482/2022401-03. In each case, the performance deficiency or underlying causes related to effectiveness of corrective actions and the NCVs were assigned a P.3, Resolution, cross-cutting aspect.
Assessment 71152B Operating Experience, Self-Assessments, and Audits The inspectors reviewed a variety of sources of operating experience including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups. The inspectors also reviewed a sample of the station's self-assessments and audits to assess whether performance trends were regularly identified and effectively addressed. Additionally, the inspectors reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the inspectors concluded that the licensee is adequately screening and addressing issues identified through operational experience that applies to the station, and this information is being evaluated in a timely manner once it is being received. The inspectors also concluded that the licensee had an adequate self-assessment and audit process. However, the inspectors did note some recent performance challenges in these areas that were documented in other recent NRC inspection reports. These issues included NCV 05000482/2022001-02, which was assigned a P.5, Operating Experience, cross-cutting aspect, and NCV 05000482/2022050-01, which was assigned a P.6, Self-Assessment, cross-cutting aspect.
Assessment 71152B Safety-Conscious Work Environment The inspectors conducted safety-conscious work environment focus group interviews with approximately 49 individuals from various departments and organizations across the site, including: non-licensed and licensed operators; and mechanical, electrical, and instrumentation and control maintenance; engineering; security; radiation protection; and chemistry personnel. The inspectors also observed interactions between employees during routine meetings; interviewed the Employee Concerns Program lead; and reviewed the results of the latest safety culture surveys and case files that relate to safety-conscious work environment. Based upon all these interviews, observations, and document reviews, the inspectors concluded that the station has an adequate safety-conscious work environment where individuals feel free to raise safety concerns without fear of retaliation.
While the inspectors determined that the station has an adequate conscious work environment where individuals feel free to raise safety concerns without fear of retaliation, the inspectors noted a few observations from our interactions with security and engineering personnel and other observations discussed in this report that have potential to impact safety-conscious work environment if not monitored and addressed appropriately. 6 Specifically, some individuals indicated that concerns important to security are often the last to get addressed. Personnel indicated that some of these concerns ranged from heating and cooling issues in isolated workspaces to other equipment concerns. Similarly, some engineering personnel noted that condition reports documenting necessary temporary or permanent equipment to complete work are sometimes not addressed until a third or fourth condition report is written for the same concern. Multiple groups also expressed that there is little to no feedback provided to some personnel on how condition reports are resolved.
Reflecting on this feedback, some questioned how the organization views their importance and wondered why they would bother to write condition reports for something that never gets fixed. While these statements do not indicate issues with maintaining a safety-conscious work environment, the inspectors noted that individuals losing confidence in the corrective action program or management's response to their concerns could degrade individuals' willingness to raise safety concerns.
Minor Performance Deficiency 71152B Failures to Screen Condition Reports in Accordance with Corrective Action Program Procedures Minor Performance Deficiency: The inspectors identified eight examples of failures to screen condition reports in accordance with corrective action program procedures to ensure that conditions adverse to quality are evaluated and corrected in accordance with their safety significance.
Specifically, procedure AP 28A-100, "Corrective Action Program," step 6.2.1, states,
"[Screening Review Team] completes the screening process by assigning a [condition report]
owner, Category, and associated Assignment Types in accordance with procedure AI 28A-010, "Screening Condition Reports." Procedure AI 28A-010, "Screening Condition Reports," step 6.3.6, states, "The following attachments are tools provided to the [Screening Review Team] to assist with their determinations...Attachment A, Category and Levels." Step 6.3.7 also states, "Assess each issue based on the risk and vulnerability of the described issueby performing the following: Determine the issues category, level, and risk. Reference A, Category and Levels." Contrary to this standard, the licensee categorized seven condition reports as non-conditions adverse to quality even though the conditions were sufficiently similar to or the same as condition adverse to quality examples provided in procedure AI 28A-010, "Screening Condition Reports." The seven examples include the following:
- Condition report 10012518, associated with an incorrect protective action recommendation during a drill/training scenario, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 36 condition adverse to quality example A.6.3.d, which includes, A condition adversely affecting performance in the [emergency preparedness] program. This includes issues involving drill or exercise implementation issues, including scenarios and critiques.
- Condition report 10012584, associated with incorrect maintenance rule scoping of the NK025 swing charger, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 36 condition adverse to quality example A.13.3.1, which includes, "A condition that could lead or has led to an NRC minor violation or fatigue rule violations (Regulatory)." 7
- Condition report 10019184, associated with safety-related essential service water piping in containment being coated with non-containment qualified coatings impacting coating margin calculations that ensure the containment sump is not adversely impacted by a design basis event, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 37 condition adverse to quality example A.7.3.4, which includes, "Items that impact safety related programs or require programmatic controls for tracking."
- Condition report 10022543, associated with a human performance error impacting surveillance testing and manipulation of AL HV-12, steam generator C turbine driven auxiliary feedwater regulating control valve, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 38 condition adverse to quality example A.16.2.c, which includes, "Improper technical specification surveillance testing or maintenance."
- Condition report 10028635, documented AL HK-0006A, steam generator D turbine driven auxiliary feedwater regulating valve controller (a functional importance determination 2 safety-related component) indication issues and the valve failing to meet its maximum allowed time to close, which required corrective maintenance.
Procedure AI 28A-010, Revision 38, states, "Functional Importance Determination (FID) 1, 2, or safety related (SR) equipment issues should be [conditions adverse to quality] or higher."
- Condition report 10031043, associated with component cooling water room cooler calculation non-conservative single failure assumptions, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 38 condition adverse to quality example A.7.2.3, which includes, "A condition that has the potential to inhibit, or has inhibited, a safety-related or [Integrated Technical Specifications] structure, system or component from satisfactory performance of a safety-related or [Integrated Technical Specifications] function.
- Condition report 10035173, associated with an NRC-identified emergency diesel generator fuel oil line vibration and indication of rubbing, was categorized as a non-condition adverse to quality, but it was consistent with procedure AI 28A-010, Revision 39 condition adverse to quality example A.15.3.1, "Equipment non-conformances, deficiencies, etc., that do not pose a near-term challenge to equipment functionality or operability."
Similarly, condition report 10025950, associated with extent of condition actions to evaluate safety-related push buttons related to a DSGL13B containment spray pump room cooler auto-start circuit push button failure (documented in condition report 10025470, a condition adverse to quality), was categorized by the licensee as a non-condition adverse to quality condition report and closed to another non-condition adverse to quality condition report contrary to procedure AI 28A-100, "Condition Report Resolution," Revisions 23, 24, and 25, Step 6.1.3.1, which states, "A [condition report] may be closed to another [condition report] of equal or higher category and/or evaluation level."
The licensee documented these issues in their corrective action program as condition report 10035392. 8 Screening: The inspectors determined the performance deficiency was minor. The inspectors determined the examples of the performance deficiency did not adversely affect a cornerstone objective, would not lead to a more significant safety concern if left uncorrected, and could not reasonably be viewed as a precursor to a significant event.
Minor Violation 71152B Failure to Take Adequate Corrective Actions to Fully Address Causes Minor Violation: The inspectors identified three examples of the licensee failing to fully correct conditions adverse to quality. Specifically, 10 CFR 50, Appendix B, Criterion XVI, requires, in part, that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
- (1) Contrary to the above, from October 25, 2022, until August 1, 2024, the licensee did not ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances were promptly identified and corrected. Specifically, the licensee's failure to periodically calibrate radiation monitors as required (as documented in NCV 05000482/2023002-01), a condition adverse to quality, was not fully corrected.
While the licensee took some actions to update procedures, the corrective actions did not adequately address causes and ensure that the appropriate and responsible organizations were appropriately involved in preventive maintenance change decision making.
- (2) Contrary to the above, from July 11, 2023, until August 1, 2024, the licensee did not ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances were promptly identified and corrected. Specifically, the licensee's failure to maintain fire protection compensatory measures during control room ventilation isolation signal actuation (as documented in NCV 05000482/2023002-01), a condition adverse to quality, was not fully corrected. While the licensee took actions to update procedures and other actions, the corrective actions did not adequately address causes and ensure that knowledge gaps were adequately corrected.
- (3) Contrary to the above, from October 26, 2023, until August 1, 2024, the licensee did not ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances were promptly identified and corrected. Specifically, the licensee's failure to properly pre-plan and perform maintenance on 4160-volt Siemens breaker components (as documented in NCV 05000482/2023003-01), a condition adverse to quality, was not fully corrected. While the licensee took some actions to update procedures, the corrective actions did not adequately address causes and ensure adequate procedure changes to address loose connections.
The licensee documented these issues in their corrective action program as condition report 10035392. 9 Screening: The inspectors determined the performance deficiency was minor. The inspectors determined the examples of the performance deficiency did not adversely affect a cornerstone objective, would not lead to a more significant safety concern if left uncorrected, and could not reasonably be viewed as a precursor to a significant event.
Enforcement:
These failures to comply with 10 CFR Part 50, Appendix B, Criterion XVI, constitute minor violations that are not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Observation: Nuclear Safety Culture Assessment Trending 71152B The inspectors reviewed Nuclear Safety Culture Assessments completed in 2019, 2021, and 2023. The licensee documented condition report 10027781 in response to the 2023 safety culture survey self-assessment and repetitive survey indications associated with work environment. The inspectors noted the station categorized condition report 10027781 as a non-condition adverse to quality. The inspectors also noted that procedure AI 28A-010, "Screening Condition Reports," Revision 38 included condition adverse to quality examples A.9.3.1.b, "Work environment concerns with line of site to the core," and A.9.3.6, "Adverse trend impacting safety or reliability or a large number of similar performance problems that could result in more significant future problems," that the licensee did not invoke. Additionally, the inspectors noted that screening and management review procedures provide flexibility to elevate condition reports based on frequency of similar events, severity, potential risk, and judgment. However, the station did not exercise its flexibility and elevate the condition report to be a condition adverse to quality and perform more than a very informal and minimally documented evaluation.
Considering the importance of individuals feeling comfortable to share differing opinions and being willing to approach station leadership, considering the importance of work environment and its similarities with and potential impact on maintaining a safety-conscious work environment where individuals feel free to raise safety concerns without fear of retaliation, and considering the screening and management review procedure flexibility, the inspectors concluded that the licensee's response to 10027781 was a missed opportunity for the station to demonstrate conservative decision making and sensitivity to safety-conscious work environment adjacent concerns.
The station captured the inspector's observation as condition report 10035397.
Observation: Opportunities to Identify Degradation Mechanisms 71152B The inspectors reviewed the licensees actions associated with multiple stem failures and issues associated with the B steam generator main feedwater regulating valve (MFRV)
(AEFCV0520), and the inspectors noted that there were at least two opportunities for the licensee to have more thoroughly evaluated failures and conditions prior to the July 18, 2022, B steam generator MFRV failure and plant trip. These opportunities for more thorough evaluation and effective actions, which included performance of a root cause evaluation for a similar 2021 failure and abnormal operation of the same AEFCV0520 component in May 2022, could have led to identification of the failure mechanism earlier.
Specifically, the inspectors noted that on July 18, 2022, the B steam generator MFRV (AEFCV0520) 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. The licensee entered this issue into the stations corrective action program as condition report 10 10016103, classified it as 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 licensee ultimately determined that the cause of the valve stem failure was stress corrosion cracking 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 the use of susceptible material. The NRC documented FIN 05000482/2022003-05, Failure to Properly Evaluate the Use of Anti-Seize Lubricant and Have Adequate Work Instructions, related to the issues.
The inspectors also noted that on August 18, 2021, the subject MFRVs valve stem had previously failed and resulted in a plant trip. After the failure on August 18, 2021, the licensee performed a root cause evaluation and determined that a fatigue crack propagated through the valve stem of the MFRV, causing the stem to fracture and subsequent plant trip. The NRC did not identify any performance deficiencies associated with this instance and documented this conclusion in NRC inspection report 05000482/2021004 (ML22012A444).
The licensees evaluation for the August 2021 failure did not identify that the stem was susceptible to stress corrosion cracking and that the mechanism was already occurringthis was later identified when the licensee performed a hardware failure analysis on the stem that failed in July 2022 and retroactively looked at the stem that failed in August 2021.
Additionally, the inspectors noted that on May 1, 2022, while at 60 percent reactor power, the licensee observed B steam generator level oscillating up to 2.5 percent on narrow range indications as a result of the subject MFRV cycling; at the same time, the other three steam generators were steady at approximately 50 percent steam generator level. The licensee documented condition report 10014005 but chose to continue with power ascension activities without fully understanding the causes behind the level oscillations. Per licensee engineering evaluation, the most likely cause of the steam generator level swings was increased packing friction, causing a higher hysteresis in the valve stroke and slight overshoot when the valve stroked, which set up the level swings that were seen. The licensee neither adjusted the valves packing prior to nor immediately following initiation of condition report 10014005. Less than 2 months later, the MFRV valve stem failed.
A new violation is not being documented here because FIN 05000482/2022003-05 documented the more-than-minor failure to properly evaluate the use of anti-seize lubricant and have adequate work instructions. However, this valve stems failure in August 2021 and the oscillations of the same valve in May 2022 represented opportunities for the licensee to identifyprior to the July 2022 failurethe failure mechanism that was identified as the cause of the July 2022 failure. Had more conservative decisions been made to conduct a more thorough evaluation of the August 2021 and May 2022 issues as they occurred, the licensee might have identified the degradation mechanism and taken action to prevent the July 2022 failure.
Observation: Reactor Trip Breaker Evaluation and Extent of Condition 71152B The inspectors reviewed NCV 05000482/2024001-02, "Failure to Perform Post-Maintenance Testing Following Maintenance and Installation of the Bypass Reactor Trip Breaker," and associated evaluations and noted that the extent of condition identified by the licensee focused narrowly on the reactor trip breakers. The licensee determined the failure to perform post-maintenance testing resulted from shifting the reactor trip breaker replacements from outage work to online work. However, the licensee's extent of condition did not focus on 11 maintenance that was moved from outage work to online work. Additionally, this narrow extent of condition was not identified by the site's corrective action review board. The inspectors communicated this observation to the licensee, and the licensee documented condition reports 10035095 and 10035111.
Observation: Documentation and Evaluation 71152B The inspectors noted examples of evaluation and action documentation not capturing all the actions being taken or planned. For example, following a safety-related room cooler stop push button failing, the licensee planned corrective actions to replace the push button and extent of condition push buttons, including safety-related push buttons. However, the licensee's evaluation did not consider the probability of the equipment failing and determine a risk ranking for prioritizing replacements. The licensee later recognized the need to prioritize the push button repairs when they learned that there were obsolete parts involved. The licensee's plan was not thoroughly communicated throughout the organization and lacked documentation tied to the corrective action program documents necessary for correcting the conditions.
Similarly, a root cause evaluation associated with NCV 05000482/2022050-01, an issue impacting the Security cornerstone and associated with modifying equipment and introducing deficiencies, included an extent of cause evaluation and actions to addresses potential concerns in other areas of the plant. The licensee indicated that a review of locked high radiation areas was completed to partially address the extent of cause, but these actions were not documented.
The licensee documented condition reports 10035336 and 10035403 related to these observations.
EXIT MEETINGS AND DEBRIEFS
On July 30, 2024, the inspectors presented the biennial problem identification and resolution inspection results to Cleve Reasoner, Chief Executive Officer and Chief Nuclear Officer, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Calculations
Alternative Start and Stop Pushbutton for Motor Control
Center Breaker Cubicles
71152B
Corrective Action
Documents
Action
19509240; 19509242; 19509244; 19509247; 19509249;
19562046; 19574193; 19574195; 19574197; 19574199;
19574201; 19574203; 19639799
71152B
Corrective Action
Documents
CR-
00011637; 00099349; 00142922; 00116831; 00136802;
00142179; 00143672; 01001806; 10000916; 10001080;
10003704; 10005735; 10005736; 10005736; 10005953;
10005991; 10005992; 10005994; 10007252; 10007386;
10007567; 10008876; 10009753; 10010478; 10011538;
10011637; 10011639; 10011645; 10011703; 10011896;
10011967; 10012135; 10012220; 10012238; 10012254;
10012478; 10012518; 10012584; 10012628; 10012707;
10013298; 10013554; 10014417; 10015098; 10015100;
10015102; 10015559; 10015736; 10016097; 10016103;
10016103; 10016194; 10016195; 10016196; 10016222;
10016223; 10015414; 10016681; 10016849; 10017247;
10017506; 10017950; 10017952; 10018051; 10018064;
10018065; 10018255; 10018470; 10019184; 10019265;
10019281; 10019914; 10020002; 10020043; 10020045;
10020786; 10021267; 10021273; 10021276; 10021277;
10021278; 10021309; 10021310; 10021482; 10021663;
10021746; 10021110; 10021866; 10022150; 10022543;
10022990; 10022993; 10023133; 10023402; 10024766;
10025080; 10025351; 10025392; 10025453; 10025615;
10025950; 10025987; 10025990; 10026429; 10027042;
10027781; 10027814; 10027996; 10028128; 10028305;
10028635; 10028646; 10028662; 10028663; 10028664;
10029005; 10029110; 10029246; 10029488; 10029579;
10029701; 10031043; 10031432; 10031684; 10031879;
10031968; 10032414; 10032572; 10033341; 10033341;
10034299; 10034299; 10035111; 10035173
2)),&,$/86(21/<+/-6(&85,7<5(/$7(',1)250$7,21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Corrective Action
Documents
Resulting from
Inspection
CR-
10035095; 10035111; 10035147; 10035173; 10035251;
10035259; 10035260; 10035265; 10035266; 10035267;
10035281; 10035287; 10035336; 10035347; 10035365;
10035385; 10035392; 10035395; 10035396; 10035397;
10035403; 10035409
71152B
Drawings
Type Test Report for Pressure Transmitters Rosemount
Model 1153 Series B
71152B
Drawings
Certified Installation Drawing for Rosemount Model 1154
Series H Pressure Transmitter
W02
71152B
Drawings
Qualification Report for Pressure Transmitter Model 1154
Rosemount Report
W02
71152B
Drawings
Rosemount 1153 Series B Alphaline Nuclear Pressure
Transmitter
W01
71152B
Drawings
M-12AL
Piping and Instrumentation Diagram Auxiliary Feedwater
System
71152B
Engineering
Changes
013324
Steam Generator Level Control, 7300system
71152B
Engineering
Changes
21-003-RP-000
Remove Thermocouple BBT/C00S0 (R-10) from scan for the
Thermocouple Core Cooling Monitor
71152B
Engineering
Changes
21-003-RP-000
Remove Thermocouple BBT/C00S0 (R-10) from scan for the
Thermocouple Core Cooling Monitor
71152B
Engineering
Changes
23-003-MR-00
Cable Tray for startup transformer
71152B
Engineering
Changes
23-003-MR-00
Cable Tray for startup transformer
71152B
Engineering
Changes
23-005-EF-00
EFPDT0043
Hi Side Pressure, Alternate Supply
71152B
Engineering
Changes
23-005-EF-00
EFPDT0043
Hi Side Pressure, Alternate Supply
71152B
Engineering
Changes
CCP 13531
MFRV (Main Feedwater Regulating Valve) Valve Stem
Refurbishment
71152B
Engineering
Changes
CCP 13531
MFRV Valve Stem Refurbishment
2)),&,$/86(21/<+/-6(&85,7<5(/$7(',1)250$7,21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Miscellaneous
Gore PTFE Facts
08/2021
71152B
Miscellaneous
Siemens Type 3AF-GER Vertical Lift Direct Replacement
Vacuum Circuit Breakers
B
71152B
Miscellaneous
Siemens Vacuum Circuit Breakers (Vehicle) Type GER 5kV
to 15kV
B
71152B
Miscellaneous
Mechanical-Packing-Safety-Data-Sheet-AP-STYLE-5000
71152B
Miscellaneous
05-2024
Monthly CAP Report
71152B
Miscellaneous
2-01-RP/PC
QA Audit Plan 22-01-RP/PC Radiological Protection &
Process Control
2/15/2021
71152B
Miscellaneous
2-04-OPS
Quality Assurance Audit Report Operations
06/02/2022
71152B
Miscellaneous
2-10-CHM
Quality Assurance Audit Report Chemistry
10/26/2022
71152B
Miscellaneous
24-01-RP/PC
Quality Assurance Audit Report Radiological Protection &
71152B
Miscellaneous
24-02-CAP
Quality Assurance Audit Report CAP Audit
03/30/2024
71152B
Miscellaneous
3002008059
Valve Packing Maintenance and Program Practices _ Update
to__3002005353
71152B
Miscellaneous
3002023768
Cross-Linked Polytetrafluoroethylene Research for Fluid
Sealing Applications_ Final Report
07/2022
71152B
Miscellaneous
AMS 2460
Aerospace Material Specification Plating, Chromium
07/2007
71152B
Miscellaneous
APF 26A-011-02
CFR 21 Evaluation
71152B
Miscellaneous
COG-02-4065
Qualification Of Lattygraf 6940 EF And 6940 Braided
Graphite Valve Packing AT 20.7 MPA Gland Stress
03/2003
71152B
Miscellaneous
ECP Files22-005; 2022-007; 2022-010; 2022-012; 2022-015; 2022-
016; 2022-017; 2022-018; 2022-020; 2022-024; 2022-025;22-028; 2022-029; 2023-001; 2023-005; 2023-014; 2023-
018; 2023-019; 2023-020; 2023-021; 2023-025; 2024-001;24-003; 2024-005; 2024-017; 2024-019; 2024-024
71152B
Miscellaneous
EQSC-I
Equipment Qualification Design Basis Document Equipment
Qualification
71152B
Miscellaneous
GNP-30839-
REPT-001
AP Style 5000 Valve Packing
71152B
Miscellaneous
M-10GL
System Description for Auxiliary Building Ventilation System
71152B
Miscellaneous
M-250
Valve Packing Standard
2)),&,$/86(21/<+/-6(&85,7<5(/$7(',1)250$7,21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Miscellaneous
MEC-046
18" Containment Isolation Purge Valves
71152B
Miscellaneous
MEC-047
36" Containment Isolation Purge Valves
71152B
Miscellaneous
MEC-048
71152B
Miscellaneous
Monthly CAP
Report 2023
to 12
71152B
Miscellaneous
Monthly CAP
Report 2024
to 6
71152B
Miscellaneous
PQE-J-301-P02
Rosemount Pressure and Differential Transmitter Models
1154 Series H
71152B
Miscellaneous
PQE-J-301-P05
Rosemount Pressure and Differential Transmitter Models
1154 Series H
71152B
Miscellaneous
QA-2023-0593
Screening Review Team (SRT) of Corrective Action Program
(CAP) Surveillance
09/21/2023
71152B
Miscellaneous
WCNOC-163
Mitigating System Performance Index (MSPI) Basis
Document
71152B
Miscellaneous
WCRE-34
Fourth 10-Year Interval Inservice Testing Basis Document
71152B
Miscellaneous
WCRE-35
Boundary Matrix
71152B
Miscellaneous
Weekly CAP
Reports 2022
3-7-2022 to 12-12-2022
71152B
Procedures
AI 01A-002
Fitness for Duty Screening
71152B
Procedures
AI 20-001
WCGS Quality Oversight Report
71152B
Procedures
AI 23M-007
Structures Monitoring Program
71152B
Procedures
AI 28A-010
Screening Condition Reports
71152B
Procedures
AI 28A-010
Screening Condition Reports
71152B
Procedures
AI 28A-010
Screening Condition Reports
71152B
Procedures
AI 28A-010
Screening Condition Reports
71152B
Procedures
AI 28A-100
Condition Report Resolution
71152B
Procedures
AI 28A-102
Root Cause Analysis
71152B
Procedures
AI 36-002
Nuclear Safety Culture Assessment
71152B
Procedures
ALR KC-888
Fire Protection Panel KC-008 Alarm Response
71152B
Procedures
AP 06-002
Radiological Emergency Response Plan (RERP)
71152B
Procedures
AP 10-103
Fire Protection Impairment Control
71152B
Procedures
Chemical Control Program
2)),&,$/86(21/<+/-6(&85,7<5(/$7(',1)250$7,21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Procedures
Plant Safety Review Committee
20B
71152B
Procedures
Industry Operating Experience Program
71152B
Procedures
Control Of Inspection Planning and Inspection Activities
17B
71152B
Procedures
Temporary Configuration Changes Responsible Organization
16B
71152B
Procedures
71152B
Procedures
Quality Review of Procurement Documents
6D
71152B
Procedures
Supplier Audits and Commercial Grade Surveys
71152B
Procedures
Certification Of ASME Material
4A
71152B
Procedures
Commodity Discrepancies
6A
71152B
Procedures
Access to Locked High or Very High Radiation Areas
29A
71152B
Procedures
Reportable Events - Evaluation and Documentation
71152B
Procedures
CFR Part 21 Review Process
71152B
Procedures
AP 28-011
Resolving Degraded or Nonconforming Conditions Impacting
71152B
Procedures
Corrective Action Program
71152B
Procedures
Program Plan for Containment Leakage Measurement
17A
71152B
Procedures
EPP 06-009
Drill and Exercise Requirements
71152B
Procedures
EPP 06-009
Drill and Exercise Requirements
71152B
Procedures
MPE E009Q-03
Inspection And Testing of Siemens Vacuum Circuit Breakers
71152B
Procedures
MPE E009Q-03
Inspection And Testing of Siemens Vacuum Circuit Breakers
71152B
Procedures
OFN KC-016
Fire Response
71152B
Self-Assessments ASMNT 2021-
205, SA-2021-
0167
Pre-PI&R Self-Assessment 2021
71152B
Self-Assessments ASMNT 2021-
255, SA-2021-
0169
21 STARS Round Robin PI-HU Assessment
E 102
71152B
Self-Assessments ASMNT 2021-
24, SA-2021-
0172
NRC Triennial Heat Exchanger/Sink Performance Self-
Assessment
03/10/2022
71152B
Self-Assessments ASMNT 2022-
0072, SA-2022-
Self-assessment - Prep for January 2023 INPO Corporate
Evaluation
09/07/2022
2)),&,$/86(21/<+/-6(&85,7<5(/$7(',1)250$7,21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0173
71152B
Self-Assessments ASMNT 2022-
0073, SA-2022-
0174
Wolf Creek Employee Concerns Program Self-Assessment
T 81
71152B
Self-Assessments ASMNT 2022-
0131, SA-2022-
0177
22 Mid-Cycle Assessment
10/19/2022
71152B
Self-Assessments ASMNT 2022-
0149, SA-2022-
0178
Reactivity Management Self-Assessment
71152B
Self-Assessments ASMNT 2022-
242, SA-2022-
0179
Confirmatory Order, Item P (CR 134185-01-18) - Perform an
Annual Effectiveness Review of the Corrective Actions
Associated with NRC CO
71152B
Self-Assessments SA-2019-0147
71152B
Self-Assessments SA-2021-0166
71152B
Self-Assessments SA-2023-0181
71152B
Work Orders
08-305719-000
71152B
Work Orders
09-313843-000
71152B
Work Orders
2047
71152B
Work Orders
214
71152B
Work Orders
244
71152B
Work Orders
19703
71152B
Work Orders
19718
71152B
Work Orders
21-473455-002
TS3 Troubleshoot Risk Level
71152B
Work Orders
2-280609-000
71152B
Work Orders
2-480608-000
71152B
Work Orders
2-481103-000
71152B
Work Orders
2-482865-000
71152B
Work Orders
26959
71152B
Work Orders
26961
71152B
Work Orders
26962
71152B
Work Orders
26964
71152B
Work Orders
26967
2)),&,$/86(21/<+/-6(&85,7<5(/$7(',1)250$7,21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Work
Orders
26969
71152B
Work Orders
26971
71152B
Work Orders
2367
71152B
Work Orders
AEFCV0520, B Feedwater Control Valve Stem Replacement
And Repacking
07/22/2022
2)),&,$/86(21/<+/-6(&85,7<5(/$7(',1)250$7,21