ML12219A181

IR 05000482-12-003; 03/31/2012 06/29/2012; Wolf Creek Generation Station, Integrated Resident and Regional Report; Flood Protection Measures, Plant Modifications

ML12219A181
Person / Time
Site:	Wolf Creek
Issue date:	08/03/2012
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Matthew Sunseri Wolf Creek
O'Keefe N
References
IR-12-003
Download: ML12219A181 (52)

See also: IR 05000482/2012003

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I V

1600 EAST LAMAR BLVD

ARLINGTON, TEXAS 76011-4511

August 3, 2012

Matthew W. Sunseri, President and

Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P. O. Box 411

Burlington, KS 66839

SUBJECT: WOLF CREEK GENERATING STATION - INTEGRATED INSPECTION

REPORT 05000482/2012003

Dear Mr. Sunseri:

On June 29, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

your Wolf Creek facility. The enclosed inspection report documents the inspection results which

were discussed on July 18, 2012, with Mr. Richard Clemens and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

One NRC identified finding and one self-revealing finding of very low safety significance (Green)

were identified during this inspection. Both of these findings were determined to involve

violations of NRC requirements. Further, a licensee-identified violation which was determined to

be of very low safety significance is listed in this report. The NRC is treating these violations as

non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest these non-cited violations, you should provide a response within 30 days of the

date of this inspection report, with the basis for your denial, to the Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the

Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the

Wolf Creek Generating Station.

If you disagree with a crosscutting aspect assignment in this report, you should provide a

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

disagreement, to the Regional Administrator, Region IV; and the NRC Resident Inspector at the

Wolf Creek Generating Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is

M. Suneri -2-

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA/

Neil OKeefe, Chief

Project Branch B

Division of Reactor Projects

Docket No.: 05000482

License No: NPF-42

Enclosure: Inspection Report 05000482/2012003

w/ Attachment: Supplemental Information

cc w/ encl: Electronic Distribution

M. Suneri -3-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

Acting DRP Deputy Director (Allen.Howe@nrc.gov)

Acting DRS Director (Tom.Blount @nrc.gov)

Acting DRS Deputy Director (Patrick.Louden@nrc.gov)

Senior Resident Inspector (Chris.Long@nrc.gov)

Resident Inspector (Charles.Peabody@nrc.gov)

WC Administrative Assistant (Shirley.Allen@nrc.gov)

Branch Chief, DRP/B (Neil.OKeefe@nrc.gov)

Senior Project Engineer, DRP/B (Leonard.Willoughby@nrc.gov)

Project Engineer, DRP/B (Nestor.Makris@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Terry.Beltz@nrc.gov)

Acting Branch Chief, DRS/TSB (Dale.Powers@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

OEMail Resource

DRS/TSB STA (Dale.Powers@nrc.gov)

Executive Technical Assistant (Silas.Kennedy@nrc.gov)

R:\_REACTORS\_WC\2012\2012003.docx ML 12219A181

SUNSI Rev Compl. Yes x No ADAMS Yes No Reviewer Initials NFO

Publicly Avail. Yes No Sensitive

X Yes X No Sens. Type Initials NFO

SRI:DRP/B RI:DRP/B SPE:DRP/B C:DRS/EB1 C:DRS/EB2 C:DRS/OB

CLong CPeabody LWilloughby TFarnholtz GMiller MHaire

/NFO via E/ /NFO via E/ /RA via E/ /RA/ /RA/ /NFO via T/

7/20/12 7/20/12 8/9/12 7/31/12 7/31/12 8/1/12

C:DRS/PSB1 C:DRS/PSB2 AC:DRS/TSB BC:DRP/B

MHay JDrake RKellar NOKeefe

/RA/ /RA/ DPowers for /RA/

8/1/12 8/1/12 8/1/12 8/3/12

OFFICIAL RECORD COPY T=Telephone E=Email F=Fax

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000482

License: NPF-042

Report: 05000482/2012003

Licensee: Wolf Creek Nuclear Operating Corporation

Facility: Wolf Creek Generating Station

Location: 1550 Oxen Lane NE, Burlington, Kansas

Dates: March 31 through June 29, 2012

Inspectors: C. Long, Senior Resident Inspector

C. Peabody, Resident Inspector

N. Makris, Project Engineer

C. Alldredge, Health Physicist

N. Greene, PhD, Health Physicist

L. Carson II, Senior Health Physicist

J. ODonnell, Health Physicist

L. Ricketson, P.E., Senior Health Physicist

Approved Neil OKeefe, Chief, Project Branch B

By: Division of Reactor Projects

SUMMARY OF FINDINGS

IR 05000482/2012003; 03/31/2012 - 06/29/2012; Wolf Creek Generation Station, Integrated

Resident and Regional Report; Flood Protection Measures, Plant Modifications.

The report covered a 3-month period of inspection by resident inspectors and an announced

baseline inspection by region-based inspectors. Two Green noncited violations of significance

were identified. The significance of most findings is indicated by their color (Green, White,

Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process.

The crosscutting aspect is determined using Inspection Manual Chapter 0310, Components

Within the Cross Cutting Areas. Findings for which the significance determination process

does not apply may be Green or be assigned a severity level after NRC management review.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is

described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

A. NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Initiating Events

• Green. The inspectors identified a non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for a work

order that did not accomplish a leak seal repair in accordance with its

engineering evaluation. Valve BMV0037 is a safety related ASME Code Class 2

steam generator blowdown valve that had a body-to-bonnet steam leak. Wolf

Creek and its vendor produced modification documents to perform a leak-seal

repair. The inspectors identified that on December 10, 2011, Wolf Creek installed

an injection port in the valve body in close proximity of another injection port.

Work orders allowed the location of the injection ports to be determined by the

work. The pair was not installed in accordance with change package 9385. After

inspector questioning, Wolf Creek performed an evaluation that demonstrated

that the valve body retained structural integrity. This issue was entered into the

corrective action program under condition report 52992.

The failure to ensure that the configuration of a safety-related steam generator

blowdown was controlled in accordance with the approved engineering change

package during leak seal activities is a performance deficiency. This finding was

more than minor because it impacted the procedure quality attribute of the

Initiating Events Cornerstone and affected the objective to limit the likelihood of

those events that upset plant stability and challenge critical safety functions

during shutdown as well as power operations. Using Inspection Manual Chapter 0609, Appendix A, this finding was determined to be of very low safety

significance because an evaluation after the modification was able to

demonstrate structural integrity. Therefore, the finding does not contribute to both

the likelihood of a reactor trip and the likelihood that mitigation equipment will not

be available. The inspectors identified the cause of the finding had a human

performance crosscutting aspect in the area of resources. Specifically, the

licensee did not ensure that the work order instructions were complete, accurate,

and reflected up-to-date design documentation sufficiently to control plant

configuration in accordance with design H.2.c] (Section 1R18).

-2- Enclosure

Cornerstone: Mitigating Systems

• Green. A self-revealing non-cited violation of 10 CFR 50, Appendix B,

Criterion V, Inspections, Procedures, and Drawings, was identified as a result of

a leaking watertight door that was observed on January 13, 2012. Station

procedure MPM XX-002, Watertight Door Preventive Maintenance Activities,

failed to ensure the proper position of the alignment screws, which resulted in

leakage through a misalignment between the door and its threshold. During the

January 13, 2012, loss of offsite power, the auxiliary building general area sump

pumps did not operate for approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Condensed steam and other

effluents slowly accrued in the stairwell area outside the containment spray pump

rooms to a depth of 24 to 36 inches. The train B containment spray pump room

watertight door leaked approximately 10 gallons per minute and pooled in both

the containment spray pump room and the residual heat removal pump room to a

depth of three inches. This issue was entered into the corrective action program

under condition report 51622. The licensee corrected the procedure and

realigned the affected watertight doors.

Failure to properly adjust safety-related watertight door alignment screws during

testing activities is a performance deficiency. The performance deficiency is

more than minor and therefore a finding because, if left uncorrected it could lead

to a more significant safety concern. Using Inspection Manual Chapter 0609,

Appendix A, the finding was characterized using Exhibit 4, Seismic, Flooding,

and Severe Weather Screening Criteria. The finding was determined to be of

very low safety significance (Green) because the degraded flood protection

equipment would not have caused a plant trip or other initiating event, would not

degrade two or more trains of a multi-train safety system, would not degrade one

or more trains of a supporting system, and the finding does not involve the total

loss of any safety function. The inspectors determined the cause of this finding

was not indicative of current performance. (Section 1R06).

B. Licensee-Identified Violations

A violation of very low safety significance was identified by the licensee and has been

reviewed by the inspectors. Corrective actions taken or planned by the licensee have

been entered into the licensees corrective action program. This violation and

associated corrective action tracking numbers are listed in Section 4OA7 of this report.

-3- Enclosure

REPORT DETAILS

Summary of Plant Status

Wolf Creek began the inspection period on March 31 at 100 percent power and remained at full

power until May 24, when power was reduced to 69 percent for planned turbine thermal

performance testing. Wolf Creek returned to 100 percent power later on May 24. On June 6,

Wolf Creek reduced power to 88 percent when it entered Limiting Condition of Operation 3.0.3

due to having the train A vital switchgear and battery air conditioning unit inoperable. Wolf

Creek returned to 100 percent power later on June 6 and remained at 100 percent for the rest of

the inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

.1 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

Since thunderstorms with potential tornados and high winds were forecast in the vicinity

of the facility for April 14, 2012, the inspectors reviewed the plant personnels overall

preparations/protection for the expected weather conditions. On April 13, 2012, the

inspectors walked down the condensate storage tank, demineralized water storage tank,

reactor makeup water, and refueling water storage tank because their functions could be

affected, or required, as a result of high winds or tornado-generated missiles or the loss

of offsite power. The inspectors evaluated the plant staffs preparations against the sites

procedures and determined that the staffs actions were adequate. During the

inspection, the inspectors focused on plant-specific design features and the licensees

procedures used to respond to specified adverse weather conditions. The inspectors

also toured the plant grounds to look for any loose debris that could become missiles

during a tornado. The inspectors evaluated operator staffing and accessibility of

controls and indications for those systems required to control the plant. Additionally, the

inspectors reviewed the Updated Safety Analysis Report (USAR) and performance

requirements for the systems selected for inspection, and verified that operator actions

were appropriate as specified by plant-specific procedures. The inspectors also

reviewed a sample of corrective action program items to verify that the licensee-

identified adverse weather issues at an appropriate threshold and dispositioned them

through the corrective action program in accordance with station corrective action

procedures. Specific documents reviewed during this inspection are listed in the

attachment.

Because the storm of April 14, 2012, caused the temporary diesel-driven fire water pump

to be locally shut down due to wave action on Coffey County lake, and a second storm

with similar behavior was predicted to arrive on April 19, the inspectors reviewed

corrective action documents and the temporary fire pump operating procedures. The

inspectors discussed applicable equipment and staffing requirements with the operations

-4- Enclosure

superintendent. The inspectors reviewed plans to secure the pump during periods of

high wave action for the long-term safety and reliability of the pump, and to have the

dedicated operator stationed in an adjacent building to restart the pump in the event of

an actual fire. The inspectors reviewed station procedures for operation of the

temporary diesel-driven fire water pump and walked down the pump, as well as the

suction, and discharge system connection. The inspectors also walked down the electric

motor-driven fire water pump and service water pumps in the adjacent circulating water

screen house building to verify that the area was free from any wind-driven missiles and

that the equipment would be available to respond to a valid demand in the event of a

fire. Specific documents reviewed are listed in the attachment.

These activities constitute completion of two readiness for impending adverse weather

condition samples as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

.2 Summer Readiness for Offsite and Alternate-ac Power

a. Inspection Scope

The inspectors performed a review of preparations for summer weather for selected

systems, including conditions that could lead to loss-of-offsite power and conditions that

could result from high temperatures. The inspectors reviewed the procedures affecting

these areas and the communications protocols between the transmission system

operator and the plant to verify that the appropriate information was being exchanged

when issues arose that could affect the offsite power system. Examples of aspects

considered in the inspectors review included:

• The coordination between the transmission system operator and the plants

operations personnel during off-normal or emergency events

• The explanations for the events

• The estimates of when the offsite power system would be returned to a normal

state

• The notifications from the transmission system operator to the plant when the

offsite power system was returned to normal

During the inspection, the inspectors focused on plant-specific design features and the

procedures used by plant personnel to mitigate or respond to adverse weather

conditions. Additionally, the inspectors reviewed the USAR and performance

requirements for systems selected for inspection, and verified that operator actions were

appropriate as specified by plant-specific procedures. Specific documents reviewed

during this inspection are listed in the attachment. The inspectors also reviewed

corrective action program items to verify that the licensee was identifying adverse

-5- Enclosure

weather issues at an appropriate threshold and entering them into their corrective action

program in accordance with station corrective action procedures.

These activities constitute completion of one readiness for summer weather affect on

offsite and alternate-ac power sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment (71111.04)

Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant

systems:

• April 14, 2012, Auxiliary building watertight doors and internal flood barriers with

train B emergency core cooling watertight door out of service

• June 19, 2012, Boron injection tank depressurization flowpath through the safety

injection test line

The inspectors selected these systems based on their risk significance relative to the

Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted

to identify any discrepancies that could affect the function of the system, and, therefore,

potentially increase risk. The inspectors reviewed applicable operating procedures,

system diagrams, USAR, technical specification requirements, administrative technical

specifications, outstanding work orders, condition reports, and the impact of ongoing

work activities on redundant trains of equipment in order to identify conditions that could

have rendered the systems incapable of performing their intended functions. The

inspectors also inspected accessible portions of the systems to verify system

components and support equipment were aligned correctly and operable. The

inspectors examined the material condition of the components and observed operating

parameters of equipment to verify that there were no obvious deficiencies. The

inspectors also verified that the licensee had properly identified and resolved equipment

alignment problems that could cause initiating events or impact the capability of

mitigating systems or barriers and entered them into the corrective action program with

the appropriate significance characterization. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of two partial system walkdown samples as

defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

-6- Enclosure

1R05 Fire Protection (71111.05)

Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability,

accessibility, and the condition of firefighting equipment in the following risk-significant

plant areas:

• April 4, 2012, Train A motor-driven auxiliary feedwater pump and valve rooms

• April 4, 2012, Train B motor-driven auxiliary feedwater pump and valve rooms

• April 5, 2012, Turbine-driven auxiliary feedwater pump and valve rooms

The inspectors reviewed areas to assess if licensee personnel had implemented a fire

protection program that adequately controlled combustibles and ignition sources within

the plant; effectively maintained fire detection and suppression capability; maintained

passive fire protection features in good material condition; and had implemented

adequate compensatory measures for out of service, degraded or inoperable fire

protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk

as documented in the plants Individual Plant Examination of External Events with later

additional insights, their potential to affect equipment that could initiate or mitigate a

plant transient, or their impact on the plants ability to respond to a security event. Using

the documents listed in the attachment, the inspectors verified that fire hoses and

extinguishers were in their designated locations and available for immediate use; that

fire detectors and sprinklers were unobstructed; that transient material loading was

within the analyzed limits; and fire doors, dampers, and penetration seals appeared to

be in satisfactory condition. The inspectors also verified that minor issues identified

during the inspection were entered into the licensees corrective action program.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three quarterly fire-protection inspection

samples as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope

The inspectors reviewed the USAR, the flooding analysis, and plant procedures to

assess susceptibilities involving internal flooding; reviewed the corrective action program

to determine if licensee personnel identified and corrected flooding problems; inspected

underground bunkers/manholes to verify the adequacy of sump pumps, level alarm

circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and

-7- Enclosure

verified that operator actions for coping with flooding can reasonably achieve the desired

outcomes. The inspectors also inspected the areas listed below to verify the adequacy

of equipment seals located below the flood line, floor and wall penetration seals,

watertight door seals, common drain lines and sumps, sump pumps, level alarms, and

control circuits, and temporary or removable flood barriers. Specific documents

reviewed during this inspection are listed in the attachment.

• April 17, 2012, Containment spray train B and residual heat removal train B

pump rooms

These activities constitute completion of one flood protection measures inspection

sample as defined in Inspection Procedure 71111.06-05.

b. Findings

Introduction. A Green, self-revealing, non-cited violation of 10 CFR 50, Appendix B,

Criterion V, Inspections, Procedures, and Drawings, was identified as a result of a

leaking watertight door that was observed on January 13, 2012. Station Procedure

MPM XX-002 Watertight Door Preventive Maintenance Activities, failed to ensure the

proper position of the alignment screws, which resulted in leakage through a

misalignment between the door and its threshold.

Description. On January 13, 2012, Wolf Creek tripped due to a main generator breaker

fault. Many non-safety systems were without power for several days until temporary

power could be arranged. One such system was the auxiliary building general area

sumps, which were without power for approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Condensed steam and

other effluents slowly accrued in the stairwell area outside the containment spray pump

rooms. The containment spray pump rooms lead to the corresponding train residual

heat removal pump rooms. Each train of containment spray pump rooms is separated

from the stairwell by a watertight door. There is no flood protection between the

corresponding containment spray and residual heat removal pump rooms. Over the

36-hour period without power, the general area water level rose to approximately 24 to

30 inches in depth, which was above the bottom of the watertight doors. The train A

containment spray pump room door passed minimal leakage with no impact to

safety-related equipment in the rooms. The train B containment spray pump room door

passed an unacceptable amount of leakage estimated to be approximately 10 gpm and

pooled into both the containment spray pump room and the residual heat removal pump

room to a depth of three inches.

On April 17, 2012, Wolf Creek identified that a previous condition report screening

resulted in a nonconservative operability assessment of door leakage. The licensee

discovered that corrective actions had not been taken and at 2:53 p.m., control room

operators promptly declared the door and the train B containment spray and train B

residual heat removal pumps inoperable and entered the appropriate technical

specification action statements. The licensee inspected the material condition of the

gasket and determined that it met the requirements of its preventive maintenance activity

detailed in station procedure MPM XX-002, Watertight Doors Preventive Maintenance

Activity. At that point, the licensee determined that the procedure must be in some way

inadequate. The licensee contacted another facility for information and compared their

-8- Enclosure

respective procedures. The licensee determined that another facility was regularly

adjusting the doors alignment screws (dog ears) whereas Wolf Creeks procedure

directed the mechanic to skip that step if the door passed its chalk test in the previous

step.

The chalk test checks engagement between the door frame and the door seal.

Operations personnel determined that the chalk test had a high likelihood of producing a

false positive because the chalk is transferred around the entire perimeter of the seal

when the mechanic closes the door, appearing to demonstrate a proper seal. However,

actual sealing occurs when the hand wheel is turned to engage the dog ears. If the dog

ears are properly aligned, the door will seal around the entire seating surface. However,

if they are loose, the door may rest ajar in the threshold allowing water to pass. A field

inspection observed that six of eight dog ears were loose on the containment spray room

B watertight door, whereas only two of eight dog ears on the train A door were loose and

it performed satisfactorily under the same flood conditions. The licensee completed the

adjustments of the to the alignment screws, door jamb welding, and seal replacement

and returned the train B containment spray and emergency core cooling systems to

service at 2:48 p.m. on April 18, 2011.

Analysis. Failure to properly adjust safety-related watertight door alignment screws

during testing activities is a performance deficiency. The performance deficiency is

more than minor, and therefore a finding because, if left uncorrected it could lead to a

more significant safety concern. Using Inspection Manual Chapter 0609, Appendix A,

the finding was characterized under the Exhibit 4, Seismic, Flooding, and Severe

Weather Screening Criteria. The finding was determined to be of very low safety

significance (Green) because the degraded flood protection equipment would not have

caused a plant trip or other initiating event, would not degrade two or more trains of a

multi-train safety system, would not degrade one or more trains of a supporting system,

and the finding does not involve the total loss of any safety function. The inspectors

determined the cause of this finding was not indicative of current performance.

Enforcement. Title 10 CFR 50, Appendix B, Criterion V, states that: Activities affecting

quality shall be prescribed by documented instructions, procedures, or drawings of a

type appropriate to the circumstances and shall be accomplished in accordance with

these instructions, procedures, or drawings. Instructions, procedures, or drawings shall

include appropriate quantitative or qualitative acceptance criteria for determining that

important activities have been satisfactorily accomplished. Procedure MPM XX-002,

Watertight Doors Preventive Maintenance Activity, Revision 4, a safety-related

procedure, was intended to implement activities affecting quality for flood doors.

Contrary to the above, from original plant construction in 1985 through April 18, 2012,

the licensee performed activities affecting the quality of watertight doors using a

procedure that was not appropriate to the circumstances. Specifically, Wolf Creek

station procedure MPM XX-002, Watertight Doors Preventive Maintenance Activity,

Revision 4, failed to ensure the proper position of the door alignment screws, which

resulted in leakage due to misalignment. Because this finding is of very low safety

significance and was entered into the licensee corrective action program as condition

report 51622, this violation is being treated as a non-cited violation in accordance with

Section 2.3.2 of the Enforcement Policy: NCV 05000482/2012003-01, Unacceptable

Leakage Through Safety-Related Watertight Door During Loss of Offsite Power.

-9- Enclosure

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11)

.1 Quarterly Review of Licensed Operator Requalification Program

a. Inspection Scope

On June 18, 2012, the inspectors observed a crew of licensed operators in the plants

simulator during requalification testing. The inspectors assessed the following areas:

• Licensed operator performance

• The ability of the licensee to administer the evaluations

• The modeling and performance of the control room simulator

• The quality of post-scenario critiques

• Followup actions taken by the licensee for identified discrepancies

These activities constitute completion of one quarterly licensed operator requalification

program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Quarterly Observation of Licensed Operator Performance

a. Inspection Scope

On the evening of April 5, 2012, the inspectors observed the performance of on-shift

licensed operators in the plants main control room. At the time of the observations, the

plant was in a period of heightened activity due to Security Force on Force drills being

conducted throughout the plant. The inspectors observed the operators performance of

the following activities:

• Shift turnover brief

• Drill communication brief

• Routine reactivity manipulations.

In addition, the inspectors assessed the operators adherence to plant procedures,

including procedure AP 21-001, Conduct of Operations, and other operations

department policies.

These activities constitute completion of one quarterly licensed-operator performance

sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

- 10 - Enclosure

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk

significant systems:

• May 15, 2012, Startup main feedwater pump performance monitoring,

maintenance rule function AE-04

• June 21, 2012, Reactor protection system card replacements, maintenance rule

function SP-02

The inspectors reviewed events such as where ineffective equipment maintenance has

resulted in valid or invalid automatic actuations of engineered safeguards systems and

independently verified the licensee's actions to address system performance or condition

problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

• Scoping of systems in accordance with 10 CFR 50.65(b)

• Characterizing system reliability issues for performance monitoring

• Charging unavailability for performance monitoring

• Trending key parameters for condition monitoring

• Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)

• Verifying appropriate performance criteria for structures, systems, and

components classified as having an adequate demonstration of performance

through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as

requiring the establishment of appropriate and adequate goals and corrective

actions for systems classified as not having adequate performance, as described

in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability,

and condition monitoring of the system. In addition, the inspectors verified maintenance

effectiveness issues were entered into the corrective action program with the appropriate

significance characterization. Specific documents reviewed during this inspection are

listed in the attachment.

These activities constitute completion of two quarterly maintenance effectiveness

samples as defined in Inspection Procedure 71111.12-05.

- 11 - Enclosure

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk

for the maintenance and emergent work activities affecting risk-significant and safety-

related equipment listed below to verify that the appropriate risk assessments were

performed prior to removing equipment for work:

• April 10 and 15, 2012, NK02 DC bus voltage and current fluctuations

The inspectors selected these activities based on potential risk significance relative to

the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified

that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)

and that the assessments were accurate and complete. When licensee personnel

performed emergent work, the inspectors verified that the licensee personnel promptly

assessed and managed plant risk. The inspectors reviewed the scope of maintenance

work, discussed the results of the assessment with the licensee's probabilistic risk

analyst or shift technical advisor, and verified plant conditions were consistent with the

risk assessment. The inspectors also reviewed the technical specification requirements

and inspected portions of redundant safety systems, when applicable, to verify risk

analysis assumptions were valid and applicable requirements were met. Specific

documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one maintenance risk assessments and

emergent work control inspection sample as defined in Inspection

Procedure 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations and Functionality Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed the following issues:

• April 13, 2012, Chemical and volume control system alternate charging line

check valves BBV8379A and BBV8379B potential stud degradation

• April 18, 2012, Flood door operability in Auxiliary Building

• May 2, 2012, Operator Manual Actions for control room ventilation damper GKD-

181

- 12 - Enclosure

• May 23, 2012, Refueling water storage tank valve BNV-11 manual actions during

sump recirculation

• June 16, 2012, Vital Switchgear room temperatures after loss of train B air

conditioning unit

• January 24 and February 13, 2012, residual heat removal transients following

non-vital power loss with normal service water running in Mode 5

The inspectors selected these potential operability issues based on the risk significance

of the associated components and systems. The inspectors evaluated the technical

adequacy of the evaluations to ensure that technical specification operability was

properly justified and the subject component or system remained available such that no

unrecognized increase in risk occurred. The inspectors compared the operability and

design criteria in the appropriate sections of the technical specifications and USAR to

the licensee personnels evaluations to determine whether the components or systems

were operable. Where compensatory measures were required to maintain operability,

the inspectors determined whether the measures in place would function as intended

and were properly controlled. The inspectors determined, where appropriate,

compliance with bounding limitations associated with the evaluations. Additionally, the

inspectors also reviewed a sampling of corrective action documents to verify that the

licensee was identifying and correcting any deficiencies associated with operability

evaluations. Specific documents reviewed during this inspection are listed in the

attachment.

These activities constitute completion of six operability evaluation inspection samples as

defined in Inspection Procedure 71111.15-05.

b. Findings

No findings were identified.

1R18 Plant Modifications (71111.18)

Temporary Modifications

a. Inspection Scope

To verify that the safety functions of important safety systems were not degraded, the

inspectors reviewed the temporary modification for leak seal repair of steam generator

tube sheet drain valve BMV0037.

The inspectors reviewed the temporary modification and the associated safety-

evaluation screening against the system design bases documentation, including the

USAR and the technical specifications, and verified that the modification did not

adversely affect the system operability/availability. The inspectors also verified that the

installation and restoration were consistent with the modification documents and that

configuration control was adequate. Additionally, the inspectors verified that the

- 13 - Enclosure

temporary modification was identified on control room drawings, appropriate tags were

placed on the affected equipment, and licensee personnel evaluated the combined

effects on mitigating systems and the integrity of radiological barriers.

These activities constitute completion of one sample for temporary plant modifications as

defined in Inspection Procedure 71111.18-05.

b. Findings

Introduction. The inspectors identified a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for a work order that

did not accomplish a leak seal repair in accordance with its engineering evaluation.

Description. Valve BMV0037 is a 2-inch safety-related ASME Code Class 2 valve that

isolates the steam generator B tube sheet drain. This diaphragm type valve is not

required to change position but it is required to be a pressure boundary for the

secondary side of the steam generator. This safety-related quality valve is normally

closed and cannot be isolated from the steam generator.

On September 9, 2010, Wolf Creek experienced a leak at the body-to-bonnet joint for

valve BMV0037. Wolf Creek engineering utilized a previously approved a leak seal

repair using configuration change package 9385. Change package 13482 re-approved

change package 9385 for use. This change package approved drilling injection ports

into the valve body. On September 30, 2010, Wolf Creek and its contractor drilled two

injection ports 180 degrees apart on valve BMV0037 and injected leak sealant. From

September 30, 2010, to November 30, 2011, valve BMV0037 leaked and was injected

four times. On December 5, 2011, BMV0037 began leaking again and a third injection

port was installed.

The inspectors selected the inspection because the valve had leaked multiple times and

was not replaced. The inspectors made a containment entry on March 27, 2012, and

observed the sealant injection. The inspectors observed two injection ports drilled at

angles to the valve body in close proximity to one another and a third approximately 180

degrees on the other side of the valve body. Two of the injection ports were visually

estimated at three quarters of an inch apart and at a shallow angle to the valve body.

Valve BMV0037 was injected again on March 28, 2012, and May 8, 2012.

The inspectors reviewed work order 10-333183-002 that was used on September 30,

2010, to install the injection ports. The inspectors found no instructions in work

order 10-333183-002 for the orientation of the drilling for the injection ports, although

they were drilled 180 degrees apart. Step 1.7.5 of work order 10-333183-002 stated that

the activity was not to exceed three injection ports. The inspectors reviewed work

order 11-346576-006, which installed a third injection port on December 10, 2011,

adjacent to one of the existing injection ports. The inspectors noted that Step 1.8.4 of

work order 11-346576-006 allowed the location of the third injection port to be

determined by the vendor technician, and also noted that the third injection port was not

installed in accordance with change package 9385.

- 14 - Enclosure

The inspectors concluded that, despite repeated re-injections, Wolf Creek did not

exceed the evaluated limits for the amount of sealant allowed to be injected. However,

the inspectors noted that Wolf Creeks leak seal process did not require a valve with a

temporary leak seal repair to be replaced at the next outage, and it did not include a

caution that cooling down a hot system was likely to cause changes in the sealant

properties and result in another leak. The inspectors questioned why the valve was not

replaced during the previous refueling outage or the forced outage and were told that

Wolf Creek had had difficulty locating a replacement valve.

The inspectors reviewed configuration change packages 13482 and 9385. The

inspectors noted that configuration change package 9385 stated that three injection

ports shall be installed 120 degrees apart around the circumference of the valve body.

The holes for those injection ports were said not to require reinforcement because ASME

Code Section III, NC-3332.1 does not require reinforcement since the injection ports are

less than 2-inch nominal pipe size. ASME Code Section III, article NC-3300 is for

pressure vessels. The inspectors, with assistance from the Office of Nuclear Reactor

Regulation, determined that the use of article NC-3300 was reasonable, but the

application of article NC-3332.1 was not appropriate for multiple openings in a valve

body. The inspectors questioned if the reinforcement requirements of article NC-3330

were met. Wolf Creek subsequently evaluated the article NC-3330 reinforcement criteria

using dimensions reasonably estimated from a photo and the manufacturers valve

drawing. The inspectors concluded that the evaluation did not include the angles of the

injection ports. Drilling the injection ports at an angle other than 90 degrees (to the valve

body) results in a deeper hole to reach the body-to-bonnet threaded joint (the area

where the sealant was injected). This required more surrounding re-enforcement

material. The inspectors again questioned the loss of material, this time due to the

additional material lost to the injection port angles. Wolf Creek subsequently took actual

measurements during a containment entry and re-performed the ASME Code evaluation.

The evaluation considered the angled injection ports to be oval shaped holes through

the wall of the valve body per article NC-3331(a). This increased the amount of material

required for reinforcement. The inspectors reviewed the calculation and concluded that

the reinforcement requirements were met.

Analysis. The failure to ensure that the configuration of a safety-related steam generator

blowdown valve was controlled in accordance with the approved engineering change

package during leak seal activities is a performance deficiency. This finding was more

than minor because it impacted the procedure quality attribute of the Initiating Events

Cornerstone, and it affected the objective to limit the likelihood of those events that upset

plant stability and challenge critical safety functions during shutdown as well as power

operations. Using Inspection Manual Chapter 0609, Appendix A, The Significance

Determination Process (SDP) for Findings At-Power, this finding was determined to be

of very low safety significance because an evaluation after the modification was able to

demonstrate structural integrity. Therefore, the finding does not contribute to both the

likelihood of a reactor trip and the likelihood that mitigation equipment will not be

available. The inspectors identified the cause of the finding had a in the human

performance crosscutting aspect in the area of resources. Specifically, the licensee did

not ensure that the work order instructions were sufficiently complete, accurate and

reflected up-to-date design documentation sufficient to control plant configuration in

accordance with design H.2.c.

- 15 - Enclosure

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,

and Drawings, requires, in part, that activities affecting quality shall be prescribed by

documented instructions, procedures, or drawings, of a type appropriate to the

circumstances and shall be accomplished in accordance with these instructions,

procedures, or drawings. Instructions, procedures, or drawings shall include acceptance

criteria for determining that activities have been satisfactorily accomplished. Wolf Creek

configuration change package 9385 allowed up to three injection ports 120 degrees

apart on the valve body. Contrary to the above, on September 30, 2010, the licensee

performed an activity affecting quality using documented instructions that were not

appropriate to the circumstances. Work order 10-333183-002 contained no instructions

for the modification of the safety-related valve BMV0037 by installing injection ports.

Specifically, there were no instructions or acceptance criteria for injection port positioning

or orientation, even though the position and orientation to the drilled holes affect the

structural integrity of the valve body. Because this issue was determined to be of very

low safety significance (Green) and was entered into the licensees corrective action

program as condition report 52992, this violation is being treated as a non-cited violation

in accordance with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000482/2012003-02, Incorrect Leak Seal Injection Port Installation.

1R19 Post Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the following postmaintenance activities to verify that

procedures and test activities were adequate to ensure system operability and functional

capability:

• May 31, 2012, Vital switchgear cooler SGK05B after compressor replacement

• June 21, 2012, Containment spray room cooler after inspection

• June 18-25, 2012, Over-temperature delta-temperature circuit card replacements

The inspectors selected these activities based upon the structure, system, or

component's ability to affect risk. The inspectors evaluated these activities for the

following (as applicable):

• The effect of testing on the plant had been adequately addressed; testing was

adequate for the maintenance performed

• Acceptance criteria were clear and demonstrated operational readiness; test

instrumentation was appropriate

The inspectors evaluated the activities against the technical specifications, the USAR,

10 CFR Part 50 requirements, licensee procedures, and various NRC generic

communications to ensure that the test results adequately ensured that the equipment

met the licensing basis and design requirements. In addition, the inspectors reviewed

corrective action documents associated with postmaintenance tests to determine

whether the licensee was identifying problems and entering them in the corrective action

program and that the problems were being corrected commensurate with their

- 16 - Enclosure

importance to safety. Specific documents reviewed during this inspection are listed in

the attachment.

These activities constitute completion of three postmaintenance testing inspection

samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors reviewed the USAR, procedure requirements, and technical

specifications to ensure that the surveillance activities listed below demonstrated that the

systems, structures, and/or components tested were capable of performing their

intended safety functions. The inspectors either witnessed or reviewed test data to

verify that the significant surveillance test attributes were adequate to address the

following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

• Engineering evaluations, root causes, and bases for returning tested systems,

structures, and components not meeting the test acceptance criteria were correct

- 17 - Enclosure

• Reference setting data

• Annunciators and alarms setpoints

The inspectors also verified that licensee personnel identified and implemented any

needed corrective actions associated with the surveillance testing.

• June 10, 2012, Spent fuel pool pump B inservice testing

• March 19, 2012, Main steam isolation valve inservice testing

• June 20, 2012, STS BB-006, reactor coolant system leak rate calculation

• June 21, 2012, Containment spray pump B inservice testing

• June 27, 2012, Residual heat removal pump A inservice testing

• June 28, 2012, TMP 11-013, Reactor coolant system to emergency core cooling

system check valve leak test

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of six surveillance testing inspection samples as

defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

2. RADIATION SAFETY

Cornerstone: Occupational and Public Radiation Safety

2RS05 Radiation Monitoring Instrumentation (71124.05)

a. Inspection Scope

This area was inspected to verify the licensee is assuring the accuracy and operability of

radiation monitoring instruments that are used to: (1) monitor areas, materials, and

workers to ensure a radiologically safe work environment and (2) detect and quantify

radioactive process streams and effluent releases. The inspectors used the

requirements in 10 CFR Part 20, the technical specifications, and the licensees

procedures required by technical specifications as criteria for determining compliance.

During the inspection, the inspectors interviewed licensee personnel, performed

walkdowns of various portions of the plant, and reviewed the following items:

- 18 - Enclosure

• Selected plant configurations and alignments of process, post-accident, and

effluent monitors with descriptions in the USAR and the offsite dose calculation

manual

• Select instrumentation, including effluent monitoring instrument, portable survey

instruments, area radiation monitors, continuous air monitors, personnel

contamination monitors, portal monitors, and small article monitors to examine

their configurations and source checks

• Calibration and testing of process and effluent monitors, laboratory

instrumentation, whole body counters, post-accident monitoring instrumentation,

portal monitors, personnel contamination monitors, small article monitors,

portable survey instruments, area radiation monitors, electronic dosimetry, air

samplers, continuous air monitors

• Audits, self-assessments, and corrective action documents related to radiation

monitoring instrumentation since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in

Inspection Procedure 71124.05-05.

b. Findings

No findings were identified.

2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

a. Inspection Scope

This area was inspected to: (1) ensure the gaseous and liquid effluent processing

systems are maintained so radiological discharges are properly mitigated, monitored,

and evaluated with respect to public exposure; (2) ensure abnormal radioactive gaseous

or liquid discharges and conditions, when effluent radiation monitors are out-of-service,

are controlled in accordance with the applicable regulatory requirements and licensee

procedures; (3) verify the licensee=s quality control program ensures the radioactive

effluent sampling and analysis requirements are satisfied so discharges of radioactive

materials are adequately quantified and evaluated; and (4) verify the adequacy of public

dose projections resulting from radioactive effluent discharges. The inspectors used the

requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190;

the offsite dose calculation manual, and licensee procedures required by the technical

specifications as criteria for determining compliance. The inspectors interviewed

licensee personnel and reviewed and/or observed the following items:

• Radiological effluent release reports since the previous inspection and reports

related to the effluent program issued since the previous inspection, if any

- 19 - Enclosure

• Effluent program implementing procedures, including sampling, monitor setpoint

determinations and dose calculations

• Equipment configuration and flow paths of selected gaseous and liquid discharge

system components, filtered ventilation system material condition, and significant

changes to their effluent release points, if any, and associated 10 CFR 50.59

reviews

• Selected portions of the routine processing and discharge of radioactive gaseous

and liquid effluents (including sample collection and analysis)

• Controls used to ensure representative sampling and appropriate compensatory

sampling

• Results of the inter-laboratory comparison program

• Effluent stack flow rates

• Surveillance test results of technical specification-required ventilation effluent

discharge systems since the previous inspection

• Significant changes in reported dose values, if any

• A selection of radioactive liquid and gaseous waste discharge permits

• Part 61 analyses and methods used to determine which isotopes are included in

the source term

• Offsite dose calculation manual changes, if any

• Meteorological dispersion and deposition factors

• Latest land use census

• Records of abnormal gaseous or liquid tank discharges, if any

• Groundwater monitoring results

• Changes to the licensees written program for indentifying and controlling

contaminated spills/leaks to groundwater, if any

• Identified leakage or spill events and entries made into 10 CFR 50.75 (g)

records, if any, and associated evaluations of the extent of the contamination and

the radiological source term

• Offsite notifications, and reports of events associated with spills, leaks, or

groundwater monitoring results, if any

- 20 - Enclosure

• Audits, self-assessments, reports, and corrective action documents related to

radioactive gaseous and liquid effluent treatment since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample, as defined in

Inspection Procedure 71124.06-05.

b. Findings

No findings were identified.

2RS07 Radiological Environmental Monitoring Program (71124.07)

a. Inspection Scope

This area was inspected to: (1) ensure that the radiological environmental monitoring

program verifies the impact of radioactive effluent releases to the environment and

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

program; (2) verify that the radiological environmental monitoring program is

implemented consistent with the licensees technical specifications and/or offsite dose

calculation manual, and to validate that the radioactive effluent release program meets

the design objective contained in Appendix I to 10 CFR Part 50; and (3) ensure that the

radiological environmental monitoring program monitors non-effluent exposure

pathways, is based on sound principles and assumptions, and validates that doses to

members of the public are within the dose limits of 10 CFR Part 20 and

40 CFR Part 190, as applicable. The inspectors reviewed and/or observed the following

items:

• Annual environmental monitoring reports and offsite dose calculation manual

• Selected air sampling and thermoluminescence dosimeter monitoring stations

• Collection and preparation of environmental samples

• Operability, calibration, and maintenance of meteorological instruments

• Selected events documented in the annual environmental monitoring report

which involved a missed sample, inoperable sampler, lost thermoluminescence

dosimeter, or anomalous measurement

• Selected structures, systems, or components that may contain licensed material

and has a credible mechanism for licensed material to reach ground water

• Records required by 10 CFR 50.75(g)

- 21 - Enclosure

• Significant changes made by the licensee to the offsite dose calculation manual

as the result of changes to the land census or sampler station modifications since

the last inspection

• Calibration and maintenance records for selected air samplers, composite water

samplers, and environmental sample radiation measurement instrumentation

• Interlaboratory comparison program results

• Audits, self-assessments, reports, and corrective action documents related to the

radiological environmental monitoring program since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in

Inspection Procedure 71124.07-05.

b. Findings

No findings were identified.

2RS08 Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

This area was inspected to verify the effectiveness of the licensee=s programs for

processing, handling, storage, and transportation of radioactive material. The inspectors

used the requirements of 10 CFR Parts 20, 61, and 71 and Department of

Transportation regulations contained in 49 CFR Parts 171-180 for determining

compliance. The inspectors interviewed licensee personnel and reviewed the following

items:

• The solid radioactive waste system description, process control program, and the

scope of the licensee=s audit program

• Control of radioactive waste storage areas including container labeling/marking

and monitoring containers for deformation or signs of waste decomposition

• Changes to the liquid and solid waste processing system configuration including

a review of waste processing equipment that is not operational or abandoned in

place

• Radio-chemical sample analysis results for radioactive waste streams and use of

scaling factors and calculations to account for difficult-to-measure radionuclides

• Processes for waste classification including use of scaling factors and

10 CFR Part 61 analysis

- 22 - Enclosure

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking,

driver instructing, and preparation of the disposal manifest

• Audits, self-assessments, reports, and corrective action reports radioactive solid

waste processing, and radioactive material handling, storage, and transportation

performed since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in

Inspection Procedure 71124.08-05.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Physical Protection

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the

licensee for the first Quarter 2012 performance indicators for any obvious

inconsistencies prior to its public release in accordance with Inspection Manual

Chapter 0608, Performance Indicator Program.

This review was performed as part of the inspectors normal plant status activities and,

as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Reactor Coolant System Specific Activity (BI01)

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system specific

activity performance indicator for the period from the second quarter 2012 through the

first quarter 2012. To determine the accuracy of the performance indicator data reported

during those periods, the inspectors used definitions and guidance contained in NEI

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6.

- 23 - Enclosure

The inspectors reviewed the licensees reactor coolant system chemistry samples,

technical specification requirements, issue reports, event reports, and NRC integrated

inspection reports for the period of April 1, 2011, through March 30, 2012, to validate the

accuracy of the submittals. The inspectors also reviewed the licensees issue report

database to determine if any problems had been identified with the performance

indicator data collected or transmitted for this indicator and none were identified.

These activities constitute completion of one reactor coolant system specific activity

sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.3 Reactor Coolant System Leakage (BI02)

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system leakage

performance indicator for the period from the second quarter 2011 through the first

quarter 2012. To determine the accuracy of the performance indicator data reported

during those periods, the inspectors used definitions and guidance contained in NEI

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6.

The inspectors reviewed the licensees operator logs; reactor coolant system leakage

tracking data, issue reports, event reports, and NRC integrated inspection reports for the

period of April 1, 2011, through March 31, 2012, to validate the accuracy of the

submittals. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the performance indicator data

collected or transmitted for this indicator and none were identified. Specific documents

reviewed are described in the attachment to this report.

These activities constitute completion of one reactor coolant system leakage sample as

defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152)

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of

this report, the inspectors routinely reviewed issues during baseline inspection activities

and plant status reviews to verify that they were being entered into the licensees

corrective action program at an appropriate threshold, that adequate attention was being

given to timely corrective actions, and that adverse trends were identified and

addressed. The inspectors reviewed attributes that included the complete and accurate

- 24 - Enclosure

identification of the problem; the timely correction, commensurate with the safety

significance; the evaluation and disposition of performance issues, generic implications,

common causes, contributing factors, root causes, extent of condition reviews, and

previous occurrences reviews; and the classification, prioritization, focus, and timeliness

of corrective actions. Minor issues entered into the licensees corrective action program

because of the inspectors observations are included in the attached list of documents

reviewed.

These routine reviews for the identification and resolution of problems did not constitute

any additional inspection samples. Instead, by procedure, they were considered an

integral part of the inspections performed during the quarter and documented in

Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific

human performance issues for follow-up, the inspectors performed a daily screening of

items entered into the licensees corrective action program. The inspectors

accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status

monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Selected Issue Follow-up Inspection

a. Inspection Scope

The inspectors reviewed the causes and corrective actions for failure of containment

penetration assembly 274 electrical module A. This resulted in the loss of the

pressurizer backup group 1 heaters on March 18, 2012. The inspectors reviewed the

vendor hardware failure analysis report stating that a high resistance connection

developed in the butt splice inside the epoxy seal. The inspectors reviewed Wolf

Creeks apparent cause and extent of condition corrective actions and found that Wolf

Creek has visually inspected other similar penetrations. Wolf Creek also has corrective

actions perform thermography while penetrations are energized in order to detect failure

at an earlier stage. The inspectors compared Wolf Creeks evaluation with guidance

from the EPRI on containment building electrical penetration modules and did not find

any missing maintenance activities that may have prevented the loss of the pressurizer

backup group 1 heaters. Most degradation related to aging of the rubber seals in

- 25 - Enclosure

contact with the inner and outer surfaces of containment and not the electrical

conductors.

These activities constitute completion of one in-depth problem identification and

resolution sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion (71153)

(Closed) Licensee Event Report 05000482/2012003-00, Train B ECCS Inoperable Due

to Damaged Watertight Containment Spray Pump Door Seal

On April 17, 2012, at 2:53 p.m., the watertight door seal for the train B containment spray

pump room was determined to be nonfunctional and the equipment supported by the

door was inoperable. The equipment supported by the door is the train B residual heat

removal pump and the train B containment spray pump. The door was repaired on

April 18, 2012, at 2:48 p.m. The watertight seal was replaced, welding was performed

on the knife-edge of the door and the door lugs were tightened. The apparent cause of

this condition was a less than adequate preventive maintenance to identify potentially

deficient door seals. This event is reportable under 10 CFR 50.73(a)(2)(i)(B) as an

operation or condition prohibited by Technical Specifications 3.5.2, 3.5.3, 3.6.6, and

Limiting Condition of Operation (LCO) 3.0.4. This condition is also reportable pursuant

10 CFR 50.73(a)(2)(v) as an event or condition that could have prevented the fulfillment

of a safety function because the opposite train was out of service several times while the

seal was degraded.

At the time of this licensee event report issued on June 18, 2012, the inspectors had

already inspected this event under baseline inspection procedure 71111.06. The results

of that inspection can be found in section 1R06 of this report.

These activities constitute completion of one event follow-up sample as defined in

Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA5 Other Activities

Assessment of Corrective Action to Address Substantive Crosscutting Issues P.1.a,

P.1.c, and P.1.d

a. Inspection Scope

Wolf Creeks letter dated May 7, 2012, informed the NRC of its readiness for inspection

of substantive crosscutting issues P.1.a(problem identification), P.1.c(evaluation), and

- 26 - Enclosure

P.1.d(corrective action). From June 18 to 21, 2012, the inspectors gathered information

to inform managements decision in the mid-2012 performance assessment.

Consideration of possible closure of these substantive crosscutting issues will be an

NRC decision using information from this inspection, guidance in Inspection Manual

Chapter 0305, and the information discussed at a June 25, 2012, public meeting. The

inspectors reviewed whether the substantive crosscutting issues were entered into the

corrective action program (CAP), the causes identified, the corrective actions identified

to address those causes, the measures of effectiveness used by the licensee to monitor

improvement, and actual data for those effectiveness reviews.

This inspection activity constituted one sample of semi-annual trend review under

inspection procedure 1152-05.

b. Findings and Assessment

No findings were identified.

P.1.a entry into the CAP

Wolf Creek addressed all P.1 substantive crosscutting issues in two main condition

reports. Condition report 23032 was a root cause evaluation completed for a second

time in September 2010. Condition report 23032 was written in response to the problem

identification and resolution and human performance substantive crosscutting issues

that led the site to Column III of the NRCs action matrix. Wolf Creek identified 63

corrective actions that were to correct the problem identification and resolution problems.

Condition report 34455 was also a root cause in response to the 2010 end of cycle

assessment letter from the NRC. Condition report 34455 identified 27 corrective actions.

The inspectors concluded that the licensee appropriately entered this issue into the

CAP.

P.1.a Causes

Root and apparent cause evaluations were self-critical and they found a lack of

management involvement and oversight in the corrective action program over the last

3 years. These were the same causes identified for White performance indicators that

the 95002 team examined under condition report 23032. Condition report 23032 had a

second root cause that the station was over-confident in using the work controls process

to manage critical equipment problems. Root cause 34455 had a similar root cause of

leadership not aligning station behaviors for timely problem identification and resolution.

Root cause 34455 had a contributing cause that the station had inadequate training on

the design and licensing basis which is inhibiting effective problem evaluation. Further,

the root cause found that there was no regular training for certain personnel on the

design basis or its controls. The inspectors concluded that the licensee effectively

identified the causes for this substantive crosscutting issue.

P.1.a Corrective actions

The inspectors sampled corrective actions. The previous large change in the corrective

action program was to create the single point of entry for all issues into the CAP. This

- 27 - Enclosure

eliminated the previous practice of writing a work order for a problem, and only allowed

writing a condition report for each problem. While either method would work, the new

method added working level and management level scrutiny to each condition report.

The number of condition reports written increased since this change, often with multiple

condition reports on the same problem. This was implemented in January 2011, and

was responsive to 23032 root cause number two.

The inspectors observed that an important programmatic change to the Wolf Creek

corrective action software was implemented on April 26, 2012. Although it does not

appear to be directly linked to root cause 23032, a new department was formed which

added more oversight to operability determinations and work control, which was

responsive the root causes. Changes were made to track and evaluate degraded or

nonconforming conditions with a new department named operations work control. The

inspectors observed that the more recent immediate operability evaluations more closely

tie the equipment requirements to the observed problems to confirm or refute operability

or functionality (P.1.c). Also, the new changes track each degraded condition, and

prevent equipment from being returned to full service without a review of all corrective

actions by a senior reactor operator. The inspectors concluded that the added problem

evaluation scrutiny was consistent with the identified causes. Although many methods

of finding, evaluating, and fixing problems can work across the power reactor industry,

Wolf Creek chose to make CAP changes while instituting new guidance on the

accountability of the CAP. Based on a sampling review, the inspectors concluded that

the corrective actions were appropriate to address the identified causes.

P.1.a Corrective Action Effectiveness Measures

Wolf Creek internal metrics consisted of monitoring and trending the condition report

initiation rate overall by the site and department. Identification of the issues by the NRC

or other organizations, rather than by licensee personnel, negatively impact the metric.

Condition report initiation rate metrics showed a steady increase with most departments

having a high self identification rates in Green with the exception of three in the Red due

to NRC and external organization identification. The inspectors concluded that the

licensee had developed reasonable effectiveness measures, and that those

effectiveness measures demonstrated an improving trend for the station, but that the red

indicators reflected a continuation of a long standing trend in those areas.

P.1.a Results

The inspectors observed a low threshold for problems and condition reports. Personnel

interviewed indicated no hesitation to initiate condition reports. The inspectors observed

several issues had two or more condition reports for the same problem. Some problems

were consolidated to one condition report while others were not. More than one person

or work group may write a condition report for the same problem. Condition report

problem statements for those condition reports were not always reconciled to ensure

that all aspects would be corrected. This was consistent with the observations of the

biennial problem identification and resolution inspection documented in Inspection

Report 2012007.

P.1.c Entry into the CAP

- 28 - Enclosure

Wolf Creek addressed all P.1 substantive crosscutting issues in two main condition

reports and one condition report from 2008. Condition report 23032 was a root cause

evaluation completed for a second time in September 2010. Condition report 23032 was

in response to the problem identification and resolution and human performance

substantive crosscutting issues that led the site to being placed in Column III of the

NRCs action matrix. Wolf Creek identified 63 corrective actions that were to correct the

problem identification and resolution problems. Condition report 34455 also

documented a root cause analysis in response to the 2010 end of cycle assessment

letter from the NRC. Condition report 34455 identified 27 corrective actions. In the past,

Wolf Creek also took action under condition report 2008-8810 for the P.1.csubstantive

crosscutting issue. The causes for 2008-8810 were nearly identical to the more recent

root causes. The inspectors concluded that the licensee appropriately entered this issue

into the CAP.

P.1.c Causes

Root and apparent causes have been self-critical and they found a lack of management

involvement and oversight in the corrective action program over the last 3 years. These

were the same causes identified for White performance indicators that the 95002 team

examined under condition report 23032. Root cause 34455 has a similar root cause of

leadership not aligning station behaviors for timely problem identification and resolution.

Root Cause 34455 was written in March 2011 in response to the NRCs 2010

Assessment Letter, with the cause evaluation not completed until June 30, 2011. Root

cause 34455 had a contributing cause of the station having poor training on the design

and licensing basis which is inhibiting effective problem evaluation. A contributing cause

was the over-reliance on the work control process to getting problems fixed. Wolf Creek

has repeatedly found that less than timely evaluations have contributed to delays in

corrective actions for substantive cross cutting issues. The inspectors concluded that

the licensee effectively identified the causes for this substantive crosscutting issue.

P.1.c Corrective Actions

The inspectors sampled corrective actions. The previous large change in the corrective

action program was to create the single point of entry for all issues into the CAP. This

eliminated the previous practice of writing a work order for a problem, and only allowed

writing a condition report for each problem. While either method would work, the new

method added working level and management level scrutiny to each condition report.

The licensee recently implemented an important programmatic change involving

changes to the corrective action program software. Although it does not appear to be

directly linked to root cause 23032, a new department was formed which adds more

oversight to operability determinations and work control, which is responsive the root

causes. Changes were made to track and evaluate degraded or non-conforming

conditions with a new department named operations work control. The inspectors

observed that the more recent immediate operability evaluations more closely tie the

equipment requirements to the observed problems to confirm or refute operability or

functionality (P.1.c). Also, the new changes track each degraded condition and

equipment cannot be returned to full service without review of all corrective actions by a

senior reactor operator (P.1.d). The inspectors found the added problem evaluation

- 29 - Enclosure

scrutiny is consistent with the causes. Although many methods of finding, evaluating,

and fixing problems can work across the power reactor industry, Wolf Creek chose to

make CAP changes while instituting new guidance on the accountability of the CAP.

Most other corrective actions centered on recurring training for cause evaluators and

procedure changes to corrective action procedures, both directed at increasing the

quality of condition report causal evaluations.

P.1.c Corrective Action Effectiveness Measures.

The licensee developed evaluation quality internal performance indications, including the

results from corrective action review board and other challenge boards. The results of

these metrics were trending in a positive direction. These quality metrics and oversight

boards have undergone many changes in the last two years. The inspectors observed

that the trends reflect the refueling and forced outages, which typically cause an

increase in the number of evaluations needed. The operability evaluation metric up to

May showed a declining trend in quality over the last 6 months, though inspectors noted

that Wolf Creek did not find any evaluations that failed to demonstrate operability. Root

and apparent cause evaluation completion timeliness goals showed an improving trend

since October 2011, but are still Red and do not show average completion times that are

close to procedural limits. The inspectors concluded that the licensee had developed

reasonable effectiveness measures, although those effectiveness measures failed to

demonstrate sustained improvement.

P.1.c Results

Creating a single point of entry into the CAP was a significant change. The changes to

improve tracking of degraded or non-conforming conditions added some priority to fixing

problems, but giving priority to these types of items is still not a formal process

requirement. Corrective actions are still largely prioritized in the work control process.

Most corrective actions have focused on improving condition report evaluation

timeliness, providing evaluation methodology training (why tree, hazard-barrier-target,

etc.), and improving coding and trending of causes.

The inspectors interviewed department corrective action coordinators and found that

they had an active role in trending recurring problems in each department. The

inspectors saw this as a positive change but not directly related to evaluation quality.

Training on the plant design bases was positive and provided information on the overall

regulatory framework, but did not include specific requirements for the trainees systems

or engineering discipline. The inspectors saw improvement in the rejection of the root

cause by the corrective action review board for the January 13, 2012, loss of offsite

power, although not all rejections were captured by the stations metric.

The inspectors reviewed Wolf Creeks comprehensive event safety-significance

evaluation which examined all the problems revealed during the January 13, 2012, loss

of offsite power. Problem evaluation was stated as a contributing cause in that

self-assessment. Corrective actions were deferred to an apparent cause evaluation

stemming from a quality assurance audit that found the corrective action program

marginally effective. Corrective actions to that quality assurance assessment continued

the trend of changes to cause method training and CAP procedure changes. With

- 30 - Enclosure

design basis training being a self-identified weakness, inspectors observed that the

number and high-level content of those training courses will challenge the adequacy of

equipment specific problems, such as the leak seal repair in this report. The inspectors

concluded that progress was being made toward implementing the corrective actions for

this substantive cross-cutting issue, but that sustained improvement in the quality and

timeliness of evaluations had not been demonstrated.

P.1.d Entry into the CAP

Wolf Creek addressed all P.1 substantive crosscutting issues in two main condition

reports. Condition report 23032 was a root cause evaluation completed for a second

time in September 2010. Condition report 23032 was in response to the problem

identification and resolution and human performance substantive crosscutting issues

that led the site to Column III of the NRCs action matrix. Wolf Creek identified 63

corrective actions that were to correct the problem identification and resolution problems.

Condition report 34455 was also a root cause in response to the 2010 end of cycle

assessment letter from the NRC. Condition report 34455 identified 27 corrective actions.

The inspectors concluded that the licensee appropriately entered this issue into the

CAP.

P.1.d Causes

Root and apparent cause evaluations for this substantive cross-cutting issue were self-

critical, and they documented a lack of management involvement and oversight in the

corrective action program over the last 3 years. These are the same causes the 95002

team examined under condition report 23032. Root cause 34455 had a similar root

cause of leadership not aligning station behaviors for timely problem identification and

resolution. Root cause 34455 had a contributing cause of the station having inadequate

training on the design and licensing basis which was inhibiting effective problem

evaluation. These causes are the same as those for the P.1.a and P.1.csubstantive

cross-cutting issues. The previous large change in the corrective action program was to

create the single point of entry for all issues into the CAP. This eliminated the previous

practice of writing a work order for a problem, and only allowed writing a condition report

for each problem. While either method would work, the new method added working

level and management level scrutiny to each condition report. The licensee recently

implemented an important programmatic change involving changes to the corrective

action program software. Although it does not appear to be directly linked to root cause

23032, a new department was formed which adds more oversight to operability

determinations and work control, which is responsive the root causes Changes were

made to track and evaluate degraded or non-conforming conditions with a new

department named operations work control. The inspectors observed that the more

recent immediate operability evaluations were more closely tied the equipment

requirements to the observed problems in order to be able to confirm or refute operability

or functionality. Also, the new changes track each degraded condition, and required that

equipment cannot be returned to full qualification without review of all corrective actions

by a senior reactor operator. The inspectors concluded that the increased problem

evaluation scrutiny was consistent with the causes. Although many methods of finding,

evaluating, and fixing problems can work across the power reactor industry, Wolf Creek

chose to make CAP changes while instituting new guidance on the accountability of the

- 31 - Enclosure

CAP. The inspectors concluded that the licensee effectively identified the causes for this

substantive crosscutting issue.

P.1.d Corrective Actions

The inspectors reviewed selected corrective actions that were most responsive to the

root causes. Condition report 23032, action 2-9, instituted on August 31, 2011, required

the corrective actions review board review each issue coded as being a corrective action

to prevent recurrence within 30 days of its closure. Separate from the root causes, the

inspectors found other condition reports responding to NRC violations on annunciator

power supplies, emergency diesel loading, operability evaluations, and maintenance rule

stating that there was a need for continuing engineering training on standards for each of

those issues. The inspectors reviewed training lesson plans for change package

continuing training [modifications], Regulatory, Current Licensing Basis, And Design

Basis, and operability evaluation training for engineers and licensed operators. The

inspectors observed that the training was conducted every 60 days. Wolf Creek has

instituted corrective action backlog measurement indicators as a corrective action. The

inspectors noted that the act of trending is not a corrective action. Those backlogs

remain high, but have made some progress since the forced outage earlier this year.

Engineering also had a significant backlog of over 5500 work orders in May 2012. The

corrective action backlog initiative plan required regular meetings for departments to

drive a reduction in their backlog, but no other specific actions were developed, such as

addressing actions by priorities. The inspectors also noted that there were a significant

number of open actions to correct NRC violations, especially for scoping of maintenance

rule functions. Based on a sampling review, the inspectors concluded that the

corrective actions to address this substantive cross-cutting aspect were partially

appropriate to address the identified causes, but specific actions to ensure that CAP

corrective actions were timely and effective were lacking.

P.1.d Corrective Action Effectiveness Measures

Wolf Creeks effectiveness review for root cause condition report 23032 concluded that

there was not sustained improvement in ensuring that corrective actions were timely and

effective due to not meeting internal station metrics set for maintenance backlogs,

repetitive maintenance rule functional failures, and two other failed effectiveness follow-

ups. The interim effectiveness follow-up for root cause condition report 34455 was met

with the exception of one internal performance indicator for too great a ratio of NRC

identified to licensee identified findings. The inspectors observed that the identification

credit is an NRC function and affects the indicator, which may not be insightful. The

conclusion of condition report 34455 interim effectiveness review stated that additional

time was needed to increase the internal self-identification metrics and that more time

was needed. This effectiveness review also gave credit for future expected

improvement in the equipment performance index, a licensee metric, and which was

Yellow at the time of the inspection. The final effectiveness follow-up was scheduled to

be completed by December 20, 2012. The non-cited violation closure effectiveness

performance indicator was Red in January, February, and March 2012. Wolf Creek has

written two condition reports on the non-cited violation effectiveness performance

indicator and the need to return it to Green and are due to have formulated corrective

actions by August 9, 2012. The inspectors concluded that the licensee had developed

- 32 - Enclosure

reasonable effectiveness measures, although those effectiveness measures failed to

demonstrate sustained improvement.

P.1.d Results

The inspectors sampled input data and observed that Wolf Creek had self-critical

internal performance measures because those measurement methods and inputs were

found to reflect NRC identified and licensee-identified issues. The internal metrics for

trends in closure of condition reports, corrective action age, and the maintenance

backlog show recent positive improvement. The condition report 23032 measures of

effectiveness stated that the root cause actions will be effective when the equipment

reliability index and performance index reflect sustained improvement. The inspectors

reviewed the equipment reliability index and found that it is a culmination of several sub

indicators, which was Red until April 2012 when it became Yellow. One important

indicator the inspectors reviewed was the critical equipment failure indicator. The

inspectors noted that this indicator went from White to Red to White over the last year.

The inspectors observed that there was not sustained improvement in these internal

metrics.

The inspectors found a significant challenge in the number of open corrective actions in

response to NRC violations and findings. The inspectors reviewed effectiveness

followup evaluations for findings and violations in NRC inspection reports, and found

these effectiveness follow-ups to be sufficiently untimely that they may not provide an

independent check prior to recurrence or prevent unnecessary corrective action delay.

With a large backlog and many long term actions, effectiveness follow-ups continue to

wait for final corrective action completion because the licensee had no process to

perform interim effectiveness reviews when long-term actions were assigned. For

example, the inspectors reviewed an open corrective action to install heat tracing for

boric acid piping. The modification was complete, but relief valves have not been

installed and Wolf Creek was having to rely on a control room annunciator to have

operators respond prior to over-pressurization of piping. No time limit was given to the

annunciator response. The inspectors calculated the operators time limit to respond by

using the heat trace kilowatt rating and the heat capacity of the piping and water. The

inspectors found that operators had a reasonable amount of time, but Wolf Creek

initiated condition report 54278 to add a time constraint. Despite this corrective action

being over 3 years old and having three effectiveness follow-up extensions, corrective

action was not complete at the time of the inspection because the relief valves had not

been procured.

The inspectors also reviewed two issues related to NRC-identified problems with

emergency diesel generator testing. The inspectors found that the issue occurred a

second time due to inadequate corrective actions from a previous finding. The issue

was work in progress and thus was considered to be a minor issue within the inspection

program. Also, open corrective actions were inappropriately categorized as

enhancements to fix the post-maintenance testing deficiency. Wolf Creek subsequently

wrote action 49551-02-01 to make the necessary changes. The inspectors concluded

that progress was being made toward implementing the corrective actions for this

substantive cross-cutting issue, but that sustained improvement in the quality and

timeliness of evaluations had not been demonstrated.

- 33 - Enclosure

Overall Observations and Conclusions

Wolf Creek showed improvement in all three substantive cross-cutting areas by its

internal effectiveness measures and by a reduced number of NRC findings with those

crosscutting attributes. Wolf Creek has instituted many internal performance measures

as corrective actions. Every station has a policy or overarching safety guidance

document. Wolf Creek has made changes to that policy and instituted new ones for a

healthy safety culture. In addition to the stations policy, each department has

developed its own policy. Wolf Creek made changes to its accountability of personnel

for problem identification and resolution and other aspects of safety culture. This

includes changes to Wolf Creeks enforcement of these policies. The inspectors

observed that previous efforts to reinforce theses practices and organizational values

have not been successful. The inspectors interviewed selected personnel about the

safety culture changes. All staff interviewed welcomed changes to fix problems

promptly, but their feedback was mixed as to the effectiveness of changes such as

procedures and training. Nearly all interviewees expressed concern about their work

load and stations ability to correct problems.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On April 26, 2012, the inspectors presented the results of the radiation safety inspection to

Mr. M. Sunseri, President and Chief Executive Officer, and other members of the licensee staff.

The licensee acknowledged the issues presented. The inspectors asked the licensee whether

any materials examined during the inspection should be considered proprietary. No proprietary

information was identified.

On July 18, 2012, the inspectors presented the inspection results to Mr. Richard Clemens, Vice

President of Strategic Projects, and other members of the licensee staff. The licensee

acknowledged the issues presented. The inspector asked the licensee whether any materials

examined during the inspection should be considered proprietary. All proprietary information

was returned or destroyed.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and

is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for

being dispositioned as a non-cited violation.

.1 On January 31, 2012, Wolf Creek identified that inservice inspection for the second

10-year period were missed for two valves. Valves BB8379A and BB8379B are

chemical and volume control system alternate charging check valves to reactor coolant

system loop four. Both are ASME Code Class 1 valves. In 1987, valve BB8379B had a

leak at the body-to-bonnet joint and its studs were re-torqued. The valve continued to

leak a small amount. Subsequently, valves BB8379A and BB8379B each had a seal

cap, or leakage control device, installed on December 9, and 28, 1987, respectively.

- 34 - Enclosure

Title 10 CFR 50.55a(g)(4) requires licensees to follow the pressure test requirements of

the ASME Code Section XI. ASME Code,Section XI, IWA-5240, requires visual

examinations as part of system pressure tests. ASME Code Section XI, IWA-5242,

1998 Edition through 2000 addenda, requires pressure retaining bolted connections for

VT-2 visual examinations in borated water systems. Contrary to the above, from

September 3, 1995, to the present, Wolf Creek did not perform a visual inspection of the

valve body-to-bonnet studs. This finding was more than minor because it impacted the

Initiating Events Cornerstone and its attribute of equipment performance. Specifically, it

affected the objective to limit the likelihood of those events that upset plant stability and

challenge critical safety functions during shutdown as well as power operations. Using

Inspection Manual Chapter 0609, Appendix A ,The Significance Determination Process

(SDP) for Findings At-Power, this finding was determined to be of very low safety

significance because an evaluation was able to demonstrate structural integrity.

Specifically, stud stress was not sufficiently close to the yield stress to cause a loss of

integrity. Therefore, the finding does not contribute to both the likelihood of a reactor trip

and the likelihood that mitigation equipment will not be available. The licensee has

entered this issue into their corrective action program as condition reports 48493 and

48494. Wolf Creek planned to remove the seal caps and perform the inspection in the

next refueling outage.

- 35 - Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Baban, Manager, Systems Engineering

P. Bedgood, Manager, Radiation Protection

J. Broschak, Vice President, Engineering

S. Carpenter, Technician, Instruments and Controls

R. Clemons, Vice President, Strategic Projects

D. Dees, Superintendant, Operations

T. East, Superintendent, Emergency Planning

R. Evenson, Requalification Program Supervisor

R. Flannigan, Manager, Nuclear Engineering

K. Fredrickson, Engineer, Licensing

D. Gibson, Technician, Radiation Protection

R. Hammond, Supervisor, Regulatory Support

J. Harris, System Engineer

S. Henry, Operations Manager

R. Hobby, Licensing Engineer

S. Hossain, Engineer, System Engineering

T. Jensen, Manager, Chemistry

T. Just, Senior Technician, Chemistry

J. Keim, Support Engineering Supervisor

S. Koenig, Manager, Corrective Actions

M. McMullen, Technician, Engineering

C. Medenciy, Supervisor, Radiation Protection

W. Muilenburg, Licensing Engineer

M. McMullen, Design Engineer, Engineering

K. Miller, Technician Level III, Instruments and Controls

R. Murray, Simulator Supervisor

E. Ray, Manager, Training

L. Ratzlaff, Manager, Maintenance

T. Rice, Manager, Environmental Management

L. Rockers, Licensing Engineer

R. Ruman, Manager, Quality

G. Sen, Regulatory Affairs Manager

D. Scrogum, Systems Engineer, Engineering

R. Smith, Plant Manager

L. Solorio, Senior Engineer

M. Sunseri, President and Chief Executive Officer

J. Truelove, Supervisor, Chemistry

J. Weeks, System Engineer

M. Westman, Assistant to Site Vice President

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

A-1 Attachment

Opened and Closed

05000482/2012003-01 NCV Unacceptable Leakage Through Safety Related Watertight Door

During Loss of Offsite Power (Section 1R06)05000482/2012003-02 NCV Incorrect Leak Seal Injection Port Installation.

(Section 1R18)

Closed

05000482/2012-03-00 LER Train B ECCS Inoperable Due to Damaged Watertight

Containment Spray Pump Door Seal (Section 4OA3)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

PROCEDURES

NUMBER TITLE REVISION

OFN SG-003 Natural Events 22

AI 14-006 Severe Weather 12

OFN AF-025 Unit Limitations 36

DRAWINGS

A-1320 Fuel Building Floor Plan 2047-6 and Roof 0

MISCELLANEOUS

OpESS 2012/01 Operating Experience Smart Sample High Wind Generated 0

Missile hazards

CONDITION REPORTS

51552 51562 46940

Section 1R04: Equipment Alignment

PROCEDURES

NUMBER TITLE REVISION

SYS GK-200 Inoperable Class IE A/C Unit 24

SYS EM-120 BIT Depressurization 2

A-2

DRAWINGS

NUMBER TITLE REVISION

M-12EM01 Piping & Instrumentation Diagram High Pressure Coolant 38

Injection System

M-12EM02 Piping & Instrumentation Diagram High Pressure Coolant 19

Injection System

CONDITION REPORTS

00053393 00053472 00053452 00053549 00053625

00053671 00053672 00053685 00053696 00053703

00053709 00053710 00053791 00053785 00053793

00053796 00053798 00048882

Section 1R05: Fire Protection

PROCEDURES

NUMBER TITLE REVISION

AP 10-106 Fire Preplans 12

AP 10-104 Breach Authorization 26

DRAWINGS

NUMBER TITLE REVISION

E-1F9905 Fire Hazard Analysis, Fire Area A-13 (Reference A-1803) 4

E-1F9905 Fire Hazard Analysis, Fire Area A-14 (Reference A-1804) 4

E-1F9905 Fire Hazard Analysis, Fire Area A-15 (Reference A-1804) 4

M-663-00017A Fire Protection Evaluations for Unique or Unbounded 3

Fire Barrier Configurations

Section 1R06: Flood Protection Measures

PROCEDURE

NUMBER TITLE REVISION

MPM XX-002 Water Tight Door Preventive Maintenance Activity 4

CONDITION REPORTS

A-3

51570 51622 52975 52794

Section 1R11: Licensed Operator Requalification Program

MISCELLANEOUS

NUMBER TITLE REVISION

LR4607005 Requal Simulator Exam Scenario 2

AP 21-001 Conduct of Operations 57

Section 1R12: Maintenance Effectiveness

PROCEDURES

NUMBER TITLE REVISION

WCOP-24 Operations EMG/OFN Setpoints 8

STN AE-007 Startup Main Feedwater Pump Operational Test 2 and 3

AP 16E-002 Post Maintenance Testing Development 10 and 11

MDI 06-01 Guidelines for Work Order Peer Review 6

EDI 23M-050 Engineering Desktop Instruction Monitoring Performance to 8

Criteria and Goals

STS ML-001 Monthly Surveillance Log 45

SB-01 Reactor Protection systems

CONDITION REPORTS

51655 51706 41997 53417 35413

35426 35532 35533 35535 35537

35539 35540 35541 35542 35544

35545 35546 35547 35548 35549

35550 35551 35552 35553 35554

35555 35558 35560 35614 35615

35617 35619 35620 35621 35622

35623 35624 35625 35626 35627

35628 35629 35882 36012 35013

36014 36038 36039 36040 36041

36042 36043 36044 36045 36057

A-4

36058 36060 36061 36062 36064

36065 36078 36079 36080 36081

36082 3608336084 36117 36118 36119

36134 36135 38108 40687 40753

46341 48955 49672 49738

WORK ORDER

11-346146-003

PERFORMANCE IMPROVEMENT REQUESTS

36518 36777 37048 37107 37439

37482 37615 38003 38023 38106

38162 38108 38369 38487 38488

38873 39349 39350 39351 39365

43639 49672 54110 54163 54164

45414

CALCULATIONS

NUMBER TITLE REVISION

AN-11-007 Startup Feedwater Pump (PAE02) Flow Rate Required to 0

Remove Decay Heat Following Reactor Shutdown

DRAWINGS

NUMBER TITLE REVISION

M-12AE01 Piping & Instrumentation Diagram Feedwater System 38

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

PROCEDURES

NUMBER TITLE REVISION

NK-022 Load Test 2

STS-MT-020 125 Volt DC Battery Inspection/Charger Operational Test 25B

CONDITION REPORTS

A-5

51421 51565

WORK ORDERS

06-281938-000 04-259540-000 04-259542-000 12-353322-000 12-353322-001

DRAWINGS

NUMBER TITLE REVISION

E-051-00058 Three phase SCR Controller Battery Charger Schematic WO7

WIP-M-761- SNUPPS Process Control Block Diagram+ 00

00075-W08-A-1

MISCELLANEOUS

NUMBER TITLE DATE

N/A On-Line Nuclear safety and Generation Risk Assessment May 30, 2012

Section 1R15: Operability Evaluations

DRAWINGS

NUMBER TITLE REVISION

M-724-00276 Swing Check Valve W04

OE BB12-004 BB8397A/B CVCS Alternate Charging to Loop 4 Check 1

Valve

MGM MOOP-08 Torquing Guidelines for Bolted Connections 13

RR-87-060 ASME Section XI Repair/Replacement Plan 0

RR-87-060 ASME Section XI Repair/Replacement Plan 1

PROCEDURES

NUMBER TITLE REVISION

EPP 06-002 Technical Support Center Operations 30A

EPP 06-013 Exposure Control and Personnel Protection 6

EMG E-0 Reactor Trip or Safety Injection 27

CALCULATIONS

NUMBER TITLE REVISION

AN 99-020 Control Room Habitability of a Postulated LOCA, based on a 2

Control Room Unfiltered Inleakage of 20.0 cfm

A-6

CALCULATIONS

NUMBER TITLE REVISION

GK-M-001 Safety Related Control Room Building HVAC Capabilities 2

During Accident Conditions (SGK04A/B and SGK05A/B)

GK-E-001 Electrical Equipment Heat Loads in ESF SWGR, DC SWBD, 2

& Battery Rooms

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

ITLS Report 24045 Liquid Penetrant Inspection of Submitted Machined August 7, 1978

Parts

Jessop Steel Company - Ultrasonic Inspection Report June 28, 1978

Operability Evaluation OE BB-12-004 00

Case N-616 Cases of ASME Boiler and Pressure Vessel Code May 7, 1999

SAP-12-58 Westinghouse LTR-SEE-III-12-81 April 14, 2012

128136 Westinghouse Drawing Revision - Material Changes September 28,

1993

CA2412 1st & 2nd Off Check Valve PMs December 26,

2008

OE BB12-004 BB8397A/B CVCS Alternate Charging to Loop 4 Check 00

Valve

CA4790 Write PMC Work Request December 26,

2008

CA4791 Revise AP 23F-001 December 26,

2008

CA4792 Update BID-CV-1 December 26,

2008

M-622.1 (Q) Design Specifcation for Packaged Air Conditioning Units 9

WORK REQUESTS

03611-87 00122-87

CONDITION REPORTS

00048493 00048494 00051530 003419 0052822

A-7

WORK ORERS

07-295490-000 08-309436-000 10-324925-000 10-327516-000 10-327516-001

10-324925-000 10-331280-000 10-327516-000 11-339107-001 11-339107-002

11-339107-000 12-351057-000 00-223094-011

Section 1R18: Plant Modifications

NUMBER TITLE REVISION /

DATE

BMV0037 Furmanite Adapter Installation Evaluation 00

MPM LR-001 Leak Sealant Injection 7

WCN-00-001 Reedy Engineering, Inc. No 00-216961-000 0

ECW-119 Furmanite The Solutions Group 0

DRAWINGS

NUMBER TITLE REVISION /

DATE

M-240-00072 Valve Assembly - 2 IN Diaphragm Y Type, Globe 1522 3

LB.C.S

1974 ASME Code, Article NC-3000

1986 ASME Code, NC-3229

1983 ASME Code, NC3232.2

Fig NC3329(g)-1 1986 Edition ASME Code

MPM LR-001 Leak Sealant Injection 7

Change Package Furnmanite Adapter Fitting and BMV0037 Furmanite Repair 00

013482

ECW-119 Pressure Seal Calculation Sheet 0

CONDITION REPORT

52992

WORK ORDERS

10-333183-002 10-333183-009 11-346576-002 11-346576-003 11-346576-006

11-346576-009 11-346576-010 11-346576-015 11-346576-017

A-8

Section 1R19: Postmaintenance Testing

PROCEDURES

NUMBER TITLE REVISION

MPE GK-003 Control Room and Class 1E A/C Units Preventive 3A

Maintenance Activity

MPE GK-004 GK Unit Preparation for Work 4

STS IC-500G Channel Calibration DT/TAVG Instrumentation Loop 4 22A

STS IC-204A Channel Operational Test of TAVG, dT and Pressurizer 17B

Pressure Protection Set Four

INC C-0026 7300 Lead/Lag Card (NLL0G01 Artwork Revisions 12) 2A

INC C-0016 7300 Summing AMP Card (NSA1 and NSA2) 10A

STS IC-502B Channel Calibration of 7300 Process Pressurizer Pressure 16

Instrumentation

STS IC-444 Channel Calibration NIS Power Range N-44 11B

WORK ORDERS

12-354805-003 11-348929-000 11-348929-002 11-348929-003 11-348929-004

11-348929-005 12-355385-001 12-355293-001 12-355293-004 12-355293-005

DRAWINGS

NUMBER TITLE REVISION

E-13GK13A Schematic Diagram Class IE Electrical Equipment A/C Unit 6

QCP-20-514 Eddy Current Examination Technique Sheet 5C

Eddy Current Calibration Summaries

WIP-M-761- Interconnecting wiring diagram cabinet 04 SNUPPS Nuclear 00

02102-004-A-1 Power Plant Controls

WIP-M-761- Interconnecting wiring diagram cabinet 04 SNUPPS Nuclear 00

02088-W08-A-1 Power Plant Controls

M-761-02084 Interconnecting wiring diagram cabinet 04 SNUPPS Nuclear W20

Power Plant Controls

A-9

Section 1R22: Surveillance Testing

PROCEDURES

NUMBER TITLE REVISION

ABHV0011 Solenoid Block Replacement

STS AB-205 Main Steam System Inservice Valve Test 29

6101-00007 CS Innovations LLC 2008 Confidential and Proprietary 2

J-105A-00013 MSFIS Information, Operation & Maintenance Manual W02

SY1503900 Standard Functional Description of System Medium W01

Operated Isolation Valves

Main and Reheat Steam System 18

STS EJ-100A RHR System Inservice Pump A Test 45

STS EN-100B Containment Spray Pump B Inservice Pump Test 26

TMP 11-013 ECCS Check Valve Leak Check 2

WCOP-02 Inservice Testing Program Third Ten-Year Interval 14

CALCULATIONS

NUMBER TITLE REVISION

AN 06-017 Steamline Break Core Response Analysis to Support 0

MSIV/MFIV Replacement Project (DCP #09952)

AN 06-018 Feedwater Line Break Analysis to Support the MSIV/MFIV 0

Replacement Project (DCP #09952)

AN-06-019 0

SGTR Stuck Open ARV Analysis to Support the MSIV/MFIV

Replacement Project (DCP #09952)

AN-06-020 Steam Generator Tube Rupture Overfill Analysis to Support 0

the MSIV/MFIV Replacement Project (DCP #09952)

EJ-100A Pump: PEJ01A: Group A

DRAWINGS

NUMBER TITLE REVISION

M-628-00140 MSIV System Medium Actuator Schematic W01

M630-00124 Standard Functional Description of System Medium W01

Operated Isolation Valves

CONDITION REPORTS

A-10

51396 51995

Section 4OA1: Performance Indicator Verification

PROCEDURES

NUMBER TITLE REVISION

STS BB-006 Reactor Coolant System Inventory Balance Using NPIS 9

Computer

AP 26A-007 NRC Performance Indicators 8

STS CH-025 Reactor Coolant Dose Equivalent Iodine Determination 5

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION

NEI 99-02 Regulatory Assessment Performance Indicator Guidelines 6

Section 4OA2: Identification and Resolution of Problems

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

12-1119-L-01 Final Report on Laboratory Evaluation of Failed Containment May 8, 2012

50754 Electrical Penetration Assembly ZNE274 Module A; Purchase

Order No. 758996/0Pressurizer Heater Cables Found Burnt

WM 12-0013 Notification of Readiness for Inspection of Human May 7, 2012

Performance and Problem Identification and Resolution

Safety Culture Themes for the Wolf Creek Generating Station

Wolf Creek Station-Wide Fundamental Behaviors Mar 19, 2012

Corrective Action Recovering Monitoring Metrics May 2012

Corrective Action Recovering Monitoring Metrics September

2011

Letter No. SL- Transmittal of Summary of Results for RELAP ESW June 19,

WC-2012-003 Waterhammer Analysis 2012

IIT 12-001 Comprehensive Event Safety Significance Assessment

P.1(c) WCNOC Activities Associated with Resolutions of NRC June 6, 2012

Cross-Cutting Aspect P.1(c)

P.1(a) WCNOC Activities Associated with Resolution of NRC Cross- June 6, 2012

Cutting Aspect P.1(a)

A-11

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

P.1(d) WCNOC Activities Associated with Resolution of NRC Cross- June 6, 2012

Cutting Aspect P.1(d)

Corrective Action Backlog Reduction Initiative May 2012

AI 28A-006 Apparent Cause Evaluation 2

CONDITION REPORTS

15367 23032 26691 34455 51952

48182 48642 50807 50754 50809

51207 51290 51303 51408 51464

51429 51698 51952 53137 54278

Section 4OA5: Other Activities

PROCEDURES

NUMBER TITLE REVISION

AP 28A-100 Condition Reports 16

ALR 00-037E CVCS HT Trace 8

SYS BG-206 Boric Acid System Operation 40

AI-22A-001 Operator Work Arounds/Operator Burdens/Control Room 10A

Deficiencies

AE-04-51 Provide feedwater and controls to the steam generator

(startup feedpump)

DRAWINGS

NUMBER TITLE REVISION

M-12BG05 Piping & Instrumentation Diagram Checmical & Volume 17

Control System

CALCULATION

NUMBER TITLE REVISION

BG-M-051 0

QUICK HIT DETAIL REPORT

A-12

1953

CONDITION REPORTS

20709 20717 21039 27909 29602

30995 31129 31746 32129 34730

34065 34455 36600 39846 39847

39848 39849 39850 39851 39852

40714 43454 45218 48234 49551

50052 52151-01 5222-01 52447-01 52613-01

52580 52851 53024 53793-01 53791-01

54238 54239 54240

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

Page 15 0f 31 Apparent Cause Evaluation Time SCCI P.1/c

AL 28A-100 Cause Evaluations April 24, 2012

SEL 2010-189 RIS 2005-20 Alignment Benchmark November 8

and 22, 2010

Change Package 013130 15

WC-NRC Component Design Bases Inspection NRC January 11,

Inspection Report 05000482/2010007 2011

BLSE 578 SNUPPS Project Diesel Generator Building Ventilation March 27,

File 7854 System Description 1974

BLSE-435 SNUPPS Project Heating, Ventilation, and Air Conditioning

File 7850 Design Criteria

Maintenance Rule Expert Panel Meeting Minutes April 19, 2012

EDI 23M-250 Engineering Desktop Instruction Monitoring Performance to 3

Criteria and Goals

K15-002 Audit 12-04-CAP Corrective Action Program May 21, 2012

WORK ORDERS

10-332371-009 10-332371-022 10-332371-038

PERFORMANCE IMPROVEMENT REQUESTS

A-13

49220 42496

A-14