Text

NRC Integrated Inspection Report 05000482/2015004 and Notice of Violation
	ML16043A054
Person / Time
Site:	Wolf Creek
Issue date:	02/11/2016
From:	Nick Taylor; NRC/RGN-IV/DRP/RPB-B
To:	Heflin A; Wolf Creek
	Taylor N
References
	EA-16-018 IR 2015004
	Download: ML16043A054 (57)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

February 11, 2016

EA-16-018

Mr. Adam C. Heflin, President and

Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

SUBJECT: WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION

REPORT 05000482/2015004 AND NOTICE OF VIOLATION

Dear Mr. Heflin:

On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Wolf Creek Generating Station. On January 27, 2016, the NRC inspectors

discussed the results of this inspection with Stephen Smith, Plant Manager, and other members

of your staff. Inspectors documented the results of this inspection in the enclosed inspection

report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

Both of these findings involved violations of NRC requirements. The NRC is treating these

violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC

Enforcement Policy.

The enclosed inspection report also discusses a violation associated with a finding of very

low safety significance (Green). The NRC evaluated this violation in accordance with

Section 2.3.2.a of the NRC Enforcement Policy, which appears on the NRCs Web site at

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in

the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in

the subject inspection report. The violation is being cited because the licensee did not establish

adequate measures to assure that the cause of train A Class 1E electrical equipment

air-conditioning system (SGK05A unit) trips that occurred on October 18, 2013, was determined

and corrective action taken to preclude repetition of SGK05A unit trips. The condition recurred

twice on May 15, 2015. This violation was previously identified by the NRC as NCV 05000482/2013005-04, after which the licensee failed to restore compliance.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. If you have additional information that you

believe the NRC should consider, you may provide it in your response to the Notice. The NRCs

review of your response to the Notice will also determine whether further enforcement action is

necessary to ensure your compliance with regulatory requirements.

A. Heflin -2-

If you contest the violations or significance of the NCVs, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement,

U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident

inspector at the Wolf Creek Generating Station.

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

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

disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the

Wolf Creek Generating Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your

response (if any) will be available electronically for public inspection in the NRCs Public

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

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible

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

Reading Room).

Sincerely,

/RA/

Nicholas H. Taylor, Branch Chief

Project Branch B

Division of Reactor Projects

Docket No.: 50-482

License No.: NPF-42

Enclosure 1: Notice of Violation

Enclosure 2: Inspection Report 05000482/2015004

w/ Attachment: Supplemental Information

cc w/ encl: Electronic Distribution

ML16043A054

SUNSI Review ADAMS Non- Publicly Available Keyword:

By: NHT Yes No Sensitive Non-Publicly Available NRC-002

Sensitive

OFFICE SRI/DRP/B RI/DRP/B AC:ACES C:DRS/PSB C:DRS/PSB2 C:DRS/EB1 C:DRS/EB2

1

NAME DDodson FThomas JRollins MHaire HGepford TFarnholtz GWerner

SIGNATURE /RA/-E /RA/E- /RA/ /RA/ /RA/ /RA/ /RA/

DATE 2/10/16 2/10/16 2/11/16 2/4/16 2/5/16 2/2/16 2/2/16

OFFICE TL/DRS/TSS C:DRS/OB C:DRP/B

NAME THipschman VGaddy NTaylor

SIGNATURE /RA/ /RA/ /RA/

DATE 2/2/16 2/2/16 2/11/16

Letter to Adam Heflin from Nicholas Taylor dated February 11, 2016

SUBJECT: WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION

REPORT 05000482/2015004

DISTRIBUTION:

Regional Administrator (Marc.Dapas@nrc.gov)

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

DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

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

Senior Resident Inspector (Douglas.Dodson@nrc.gov)

Resident Inspector (Fabian.Thomas@nrc.gov)

WC Administrative Assistant (Vacant)

Branch Chief, DRP/B (Nick.Taylor@nrc.gov)

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

Project Engineer, DRP/B (Shawn.Money@nrc.gov)

Project Engineer, DRP/B (Steven.Janicki@nrc.gov)

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

Project Manager (Fred.Lyon@nrc.gov)

Team Leader, DRS/TSS (Thomas.Hipschman@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

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

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

OEWEB Resource (OEWEB.Resource@nrc.gov)

OEWEB Resource (Sue.Bogle@nrc.gov)

RIV/ETA: OEDO (Raj.Iyengar@nrc.gov)

ROPreports.Resource@nrc.gov

ROPassessment.Resource@nrc.gov

NOTICE OF VIOLATION

Wolf Creek Nuclear Operating Company Docket No: 50-482

Wolf Creek Generating Station License No: NPF-42

EA-16-018

During an NRC inspection, conducted from September 27 through December 31, 2015, a

violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy,

the violation is listed below:

Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, in

the case of significant conditions adverse to quality, that measures shall assure that the

cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, from October 18, 2013, to May 16, 2015, the licensee failed, in

the case of a significant condition adverse to quality, to assure that the cause of the

condition was determined and corrective action taken to preclude repetition.

Specifically, the licensee did not establish adequate measures to assure that the cause

of train A Class 1E electrical equipment air-conditioning system (SGK05A) unit trips that

occurred on October 18, 2013, was determined and corrective action taken to preclude

repetition of the SGK05A unit trips. The condition recurred twice on May 15, 2015. This

violation was previously identified by the NRC as non-cited

violation 05000482/2013005-04, after which the licensee failed to restore compliance.

This violation is associated with a Green significance determination process finding.

Pursuant to the provisions of 10 CFR 2.201, Wolf Creek Nuclear Operating Company is

hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the

Regional Administrator, Region IV, 1600 East Lamar Blvd, Arlington, TX 76011, and a copy to

the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the

date of the letter transmitting this Notice of Violation. This reply should be clearly marked as a

"Reply to Notice of Violation EA-16-018," and should include: (1) the reason for the violation, or,

if contested, the basis for disputing the violation or severity level, (2) the corrective steps that

have been taken and the results achieved, (3) the corrective steps that will be taken, and (4) the

date when full compliance will be achieved. Your response may reference or include previous

docketed correspondence, if the correspondence adequately addresses the required response.

If an adequate reply is not received within the time specified in this Notice, an order or a

Demand for Information may be issued as to why the license should not be modified,

suspended, or revoked, or why such other action as may be proper should not be taken. Where

good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

E1-1 Enclosure 1

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the

NRC website at www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not

include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. If personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. If you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in

detail the basis for your claim of withholding (e.g., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required by

10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). If safeguards information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working

days of receipt.

Dated this 11th day of February, 2016.

E1-2

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000482

License: NPF-42

Report: 05000482/2015004

Licensee: Wolf Creek Nuclear Operating Corporation

Facility: Wolf Creek Generating Station

Location: 1550 Oxen Lane NE

Burlington, KS 66839

Dates: September 27 through December 31, 2015

Inspectors: D. Dodson, Senior Resident Inspector

F. Thomas, Resident Inspector

K. Clayton, Senior Operations Engineer

P. Elkmann, Senior Emergency Preparedness Inspector

G. Guerra, CHP, Emergency Preparedness Inspector

A. Meyen, Physical Security Inspector

G. Pick, Senior Reactor Inspector

Approved By: Nicholas H. Taylor

Chief, Project Branch B

Division of Reactor Projects

E2-1 Enclosure 2

SUMMARY

IR 05000482/2015004; 09/27/2015 - 12/31/2015; Wolf Creek Generating Station;

Problem Identification and Resolution

The inspection activities described in this report were performed between September 27 and

December 31, 2015, by the resident inspectors at Wolf Creek Generating Station and inspectors

from the NRCs Region IV office. Three findings of very low safety significance (Green) are

documented in this report. All of these findings involved violations of NRC requirements.

Additionally, NRC inspectors documented one licensee-identified violation of very low safety

significance. The significance of inspection findings is indicated by their color (Green, White,

Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance

Determination Process, issued April 29, 2015. Their cross-cutting aspects are determined

using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas, Issued

December 4, 2014. Violations of NRC requirements are dispositioned in accordance with the

NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial

nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Mitigating Systems

Green. The inspectors identified a Green cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, for the licensees inadequate measures to assure that

corrective action was taken to preclude repetition of a significant condition adverse to

quality. Specifically, measures to correct train A Class 1E electrical equipment

air-conditioning system (SGK05A) issues following two trips of the unit on October 18, 2013,

failed to preclude repetition, which resulted in the SGK05A unit tripping twice on May 15,

2015; the train A safety-related batteries, inverters, and alternating and direct current buses

being declared inoperable due to the loss of area cooling; two separate Technical

Specification 3.0.3 entries; and separate technical specification required reactor power

reductions to 93 and 94.7 percent. The licensees immediate corrective actions included

troubleshooting to determine the direct cause of the compressor trips, stationing a dedicated

operator following the second trip on May 15, 2015, and subsequently implementing

Temporary Modification 15-013-GK-00, which restored compliance. Actions to prevent

recurrence following the May 15, 2015, SGK05A trips, documented in apparent cause

evaluation 96392, included conducting a seminar with station managers to review lessons

learned from the event, completing a change package to replace the SGK05A compressor

that has been the source of residual contamination that has led to numerous trips of the unit,

and tracking of the timely replacement of the SGK05A compressor with a due date of

December 15, 2016. Wolf Creek entered this issue into its corrective action program as

Condition Reports 96392 and 96397.

This finding is more than minor because it is associated with the equipment performance

attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone

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

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

train A safety-related batteries, inverters, and alternating and direct current buses became

inoperable and their capability to respond to initiating events to prevent undesirable

consequences was impacted as a result of the SGK05A unit tripping. In accordance with

Inspection Manual Chapter 0609.04, Initial Characterization of Findings, and Exhibit 3 of

Inspection Manual Chapter 0609, Appendix A, The Significance Determination

Process (SDP) for Findings At-Power, issued June 19, 2012, and April 29, 2015,

E2-2

respectively, the performance deficiency affects a mitigating structure, system, and

component. The performance deficiency does not affect the design or qualification of a

mitigating structure, system, and component, and the structure, system, and component did

not maintain its functionality. Additionally, the finding does not represent a loss of system

and/or function, the finding does not represent an actual loss of function of at least a single

train for greater than its technical specification allowed outage time or two separate safety

systems out-of-service for greater than their technical specification allowed outage time, and

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

specification trains of equipment designated as high safety-significant in accordance with

the licensees maintenance rule program for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Therefore, the

inspectors determined that this finding is of very low safety significance (Green). In

accordance with Inspection Manual Chapter 0310, Aspects Within The Cross-Cutting

Areas, issued December 4, 2014, the finding has a cross-cutting aspect in the area of

human performance, resources, because the licensee did not ensure that personnel,

equipment, procedures, and other resources were available and adequate to support

nuclear safety. Specifically, senior managers did not ensure successful completion of the

replacement of the SGK05A compressor in Refueling Outage 20, which was a missed

opportunity that resulted in the SGK05A unit tripping twice on May 15, 2015, as a result of

the same direct cause [H.1]. (Section 4OA2)

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

Appendix B, Criterion III, Design Control, for the licensees failure to establish measures to

assure that applicable regulatory requirements and the design basis, for applicable

structures, systems, and components, are correctly translated into specifications, drawings,

procedures, and instructions. Specifically, the licensee failed to ensure that safety-related

essential service water valves in the control building were adequately protected from

external flooding hazards in the event of a design basis local intense precipitation event,

which resulted in a reasonable doubt on the operability of safety-related essential service

water valves. The stations immediate corrective actions included entering the condition into

the corrective action program and performing a prompt operability evaluation that showed

the essential service water valves remained operable. Additional corrective actions include

accelerating three Fukushima project schedules that include a new sump pump in the

turbine building area four cable vault, ground and surface water improvements for

non-safety related electrical duct banks, and new sump pumps in electrical manholes near

the turbine building. The violation was entered into the licensees corrective action program

as Condition Report 102250.

This finding is more than minor because it is associated with the design control attribute of

the Mitigating Systems Cornerstone and affected the associated cornerstone objective to

ensure the availability, reliability, and capability of systems that respond to initiating events

to prevent undesirable consequences (i.e., core damage). Specifically, during design basis

local intense precipitation events, the safety-related essential service water train A and B

service water cross-connect motor-operated valves EFHV0023, EFHV0024, EFHV0025, and

EFHV0026, and the essential service water train A and B to service water system valves

EFHV0039, EFHV0040, EFHV0041, and EFHV0042 were susceptible to external flooding

hazards, and there was a reasonable doubt on the operability of these essential service

water valves; however, subsequent evaluation determined that the essential service water

valves would not have been impacted in the event of a design basis local intense

precipitation event, and the valves were determined to be operable. In accordance with

Inspection Manual Chapter 0609.04, Initial Characterization of Findings, and Exhibit 2 of

Inspection Manual Chapter 0609, Appendix A, The Significance Determination

E2-3

Process (SDP) for Findings At-Power, issued June 19, 2012, and April 29, 2015,

respectively, the performance deficiency affects mitigating structures, systems, and

components. The finding is a deficiency affecting the design or qualification of mitigating

structures, systems, and components, and the structures, systems, and components

maintained their operability and functionality. Therefore, the inspectors determined that this

finding is of very low safety significance (Green). In accordance with Inspection Manual

Chapter 0310, Aspects Within The Cross-Cutting Areas, issued December 4, 2014, the

finding has a cross cutting aspect in the area of human performance, challenge the

unknown, because Wolf Creek individuals did not stop when faced with uncertain conditions.

Specifically, the licensee did not maintain a questioning attitude during flooding walk-downs

performed in accordance with NEI 12-07 or during evaluation of Condition Report 59257 to

identify and resolve unexpected conditions like the floor drain pathway from the

communication corridor to the control building basement (room 3101), which was an

opportunity for the station to identify the open pathway from the exterior of the plant [H.11].

(Section 4OA2)

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

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure

to accomplish activities affecting quality in accordance with Procedure AP 26C-004,

Operability Determination and Functionality Assessment, Revision 31. Specifically, the

licensee failed to document an operability determination of sufficient scope to address the

capability of safety-related essential service water valves in the control building to perform

their specified safety functions in the event of a design basis local intense precipitation

event. Immediate corrective actions included completing a prompt operability determination

and performing analyses that determined the valves remained operable. Additional

corrective actions include accelerating three Fukushima project schedules that include a

new sump pump in the turbine building area four cable vault, ground and surface water

improvements for non-safety related electrical duct banks, and new sump pumps in

electrical manholes near the turbine building. The violation was entered into the licensees

corrective action program as Condition Report 100299.

This finding is more than minor because it is associated with the equipment performance

attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone

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

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

during design basis local intense precipitation events, the safety-related essential service

water train A and B service water cross-connect motor-operated valves EFHV0023,

EFHV0024, EFHV0025, and EFHV0026, and the essential service water train A and B to

service water system valves EFHV0039, EFHV0040, EFHV0041, and EFHV0042 were

susceptible to external flooding hazards, and there was a reasonable doubt on the

operability of these essential service water valves; however, subsequent evaluation

determined that the essential service water valves would not have been impacted in the

event of a design basis local intense precipitation event, and the valves were determined to

be operable. In accordance with Inspection Manual Chapter 0609.04, Initial

Characterization of Findings, and Exhibit 2 of Inspection Manual Chapter 0609,

Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued

June 19, 2012, and April 29, 2015, respectively, the performance deficiency affects

mitigating structures, systems, and components. The finding is not a deficiency affecting the

design or qualification of mitigating structures, systems, and components; the finding does

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

of function of at least a single train or two separate safety systems out-of-service for greater

E2-4

than their allowed outage times; and the finding does not represent an actual loss of function

of one or more non-technical specification trains of equipment. Therefore, the inspectors

determined that this finding is of very low safety significance (Green). In accordance with

Inspection Manual Chapter 0310, Aspects Within The Cross-Cutting Areas, issued

December 4, 2014, the finding has a cross-cutting aspect in the area of human

performance, conservative bias, because Wolf Creek did not use decision making-practices

that emphasize prudent choices over those that are simply allowable, and proposed action

was not determined to be safe in order to proceed, rather than unsafe in order to stop.

Specifically, the licensee did not consider long-term consequences or design basis events

when determining how to resolve emergent concerns like the unexpected water in room

3101, which resulted in the licensees failure to thoroughly evaluate and assess impacts to

the plant when Condition Report 96404 was entered into the corrective action program on

May 17, 2015 [H.14]. (Section 4OA2)

E2-5

PLANT STATUS

Wolf Creek began the inspection period at 100 percent power and remained at or near

100 percent power for the entire inspection period.

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On December 14, 2015, the inspectors completed an inspection of the stations

readiness for seasonal extreme weather conditions. The inspectors reviewed the

licensees adverse weather procedures for extreme cold weather and evaluated the

licensees implementation of these procedures. The inspectors verified that prior to the

onset of extreme cold weather, the licensee had corrected weather-related equipment

deficiencies identified during the previous winter.

The inspectors selected two risk-significant systems that were required to be protected

from cold weather conditions:

Refueling water storage tank supply to emergency core cooling systems

Essential service water system

The inspectors reviewed the licensees procedures and design information to ensure the

systems would remain functional when challenged by adverse cold weather. The

inspectors verified that operator actions described in the licensees procedures were

adequate to maintain readiness of these systems. The inspectors walked down portions

of these systems to verify the physical condition of the adverse weather protection

features.

These activities constituted one sample of readiness for seasonal adverse weather, as

defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment (71111.04)

.1 Partial Walkdown

a. Inspection Scope

On October 21, 2015, the inspectors performed a partial system walk-down of the train A

residual heat removal system, a risk-significant system.

E2-6

The inspectors reviewed the licensees procedures and system design information to

determine the correct lineup for the systems. They visually verified that critical portions

of the system were correctly aligned for the existing plant configuration.

These activities constituted one partial system walk-down sample as defined in

Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On November 16, 2015, the inspectors performed a complete system walk-down

inspection of the B emergency diesel generator. The inspectors reviewed the licensees

procedures and system design information to determine the correct B emergency diesel

generator lineup for the existing plant configuration. The inspectors also reviewed

outstanding work orders, open condition reports, in-process design changes, temporary

modifications, and other open items tracked by the licensees operations and

engineering departments. The inspectors then visually verified that the system was

correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in

Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection (71111.05)

Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status

and material condition. The inspectors focused their inspection on four plant areas

important to safety:

October 21, 2015, Fire Area A-2, auxiliary building A train safety-related

pump rooms, elevation 1974 feet

November 3, 2015, Fire Area C-10, engineered safety feature switchgear room

number 2, elevation 2000 feet

December 15, 2015, Fire Area A-3, boric acid tank rooms, elevations 1974 feet

and 2026 feet

E2-7

December 15, 2015, Fire Area C-22, upper cable spreading room, elevation

2073 feet 6 inches

For each area, the inspectors evaluated the fire plan against defined hazards and

defense-in-depth features in the licensees fire protection program. The inspectors

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

suppression systems, manual firefighting equipment and capability, passive fire

protection features, and compensatory measures for degraded conditions.

These activities constituted four quarterly inspection samples, as defined in Inspection

Procedure 71111.05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11)

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On November 10, 2015, the inspectors observed an evaluated simulator scenario

performed by an operating crew. The inspectors assessed the performance of the

operators and the evaluators critique of their performance in executing Requalification

Simulator Exam Scenario LR4412801. The inspectors also assessed the modeling and

performance of the simulator during the requalification activities.

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 Review of Licensed Operator Performance

a. Inspection Scope

On December 18, 2015, 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 the control rooms response to a plant status

control issue in the control room during the completion of Procedure STS IC-618B,

Slave Relay Test K618 Train B Safety Injection, Revision 22.

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

including AP 21-001, Conduct of Operations, Revision 74, and other operations

department policies.

E2-8

These activities constitute completion of one quarterly licensed operator performance

sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Annual Review of Requalification Examination Results

The licensed operator requalification program involves two training cycles that are

conducted over a 2-year period. In the first cycle, the annual cycle, the operators are

administered an operating test consisting of job performance measures and simulator

scenarios. In the second part of the training cycle, the biennial cycle, operators are

administered an operating test and a comprehensive written examination. For this

annual inspection requirement, the licensee was in the first part of the training cycle.

a. Inspection Scope

The inspector conducted an in-office review of the annual requalification training

program to determine the results of this program.

On December 2, 2015, the licensee informed the lead inspector of the following results:

Of the 49 total licensed operators, 49 operators were tested

10 of 10 crews passed the simulator portion of the operating test

49 of 49 licensed operators passed the simulator portion of the operating test

48 of 49 licensed operators passed the job performance measure portion of the

examination

The individual that failed the job performance measure portions of the operating test was

remediated, retested, and passed his retake tests prior to returning to shift.

The inspector completed one inspection sample of the annual licensed operator

requalification program.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors reviewed four instances of degraded performance or condition of

structures, systems, and components (SSCs):

December 9, 2015, condensate pump unplanned outages that occurred on

April 26, 2014, November 15, 2014, and May 5, 2015

E2-9

December 29, 2015, B auxiliary feedwater pump trip on March 11, 2014, and

turbine-driven auxiliary feedwater pump control power panel non-functional on

April 4, 2015

December 29, 2015, non-safety auxiliary feedwater pump trips on August 24,

2015, and September 13, 2015

December 29, 2015, two A train Class 1E electrical equipment air-conditioning

system (SGK05A) unit trips on May 15, 2015

The inspectors reviewed the extent of condition of possible common cause SSC failures

and evaluated the adequacy of the licensees corrective actions. The inspectors

reviewed the licensees work practices to evaluate whether these may have played a

role in the degradation of the SSCs. The inspectors assessed the licensees

characterization of the degradation in accordance with 10 CFR 50.65 (the

Maintenance Rule), and verified that the licensee was appropriately tracking degraded

performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of four maintenance effectiveness samples, as

defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

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

a. Inspection Scope

The inspectors reviewed three risk assessments performed by the licensee prior to

changes in plant configuration and the risk management actions taken by the licensee in

response to elevated risk:

October 6, 2015, extended motor-driven feedwater pump maintenance

October 13 and 14, 2015, planned B centrifugal charging pump and residual heat

removal pump maintenance, respectively

November 3, 2015, planned B component cooling water pump breaker

maintenance

The inspectors verified that these risk assessments were performed timely and in

accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant

procedures. The inspectors reviewed the accuracy and completeness of the licensees

risk assessments and verified that the licensee implemented appropriate risk

management actions based on the results of the assessments.

Additionally, on November 9, 10, and 11, 2015, the inspectors observed emergent

maintenance activities associated with the NB02 safety-related bus breakers for the

B safety injection, B residual heat removal, and B containment spray pumps, which had

the potential to affect the functional capability of mitigating systems.

E2-10

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

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

minimize the impact of the work activities on unaffected SSCs.

These activities constitute completion of four maintenance risk assessments and

emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed three operability determinations that the licensee performed for

degraded or nonconforming SSCs:

October 19, 2015, Condition Report 100380, operability determination of the

degraded breaker clip condition associated with the NB0111 B emergency diesel

generator output breaker to the NB01 Class 1E electrical bus with degraded

breaker clips

October 21, 2015, Condition Report 100299, operability determination of the

essential service water train A and B service water cross-connect valves

EFHV0023, EFHV0024, EFHV0025, and EFHV0026, and the essential service

water train A and B to service water system valves EFHV0039, EFHV0040,

EFHV0041, and EFHV0042 with degraded turbine building area four cable vault

penetrations

November 9, 2015, Condition Report 100760, operability determination of the

B essential service water system following a failed surveillance

The inspectors reviewed the timeliness and technical adequacy of the licensees

evaluations. Where the licensee determined the degraded SSCs to be operable, the

inspectors verified that the licensees compensatory measures were appropriate to

provide reasonable assurance of operability. The inspectors verified that the licensee

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

degraded SSCs.

The inspectors reviewed operator actions taken or planned to compensate for degraded

or nonconforming conditions. The inspectors verified that the licensee effectively

managed these operator workarounds to prevent adverse effects on the function of

mitigating systems and to minimize their impact on the operators ability to implement

abnormal and emergency operating procedures.

These activities constitute completion of four operability and functionality review

samples, which included one operator work-around sample, as defined in Inspection

Procedure 71111.15.

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b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected

risk-significant SSCs:

November 4, 2015, B emergency diesel generator and feeder breaker following

planned maintenance

November 5, 2015, B essential service water pump and feeder breaker following

planned maintenance

November 9, 2015, B safety injection pump and feeder breaker following planned

maintenance

November 10, 2015, B containment spray pump and feeder breaker following

planned maintenance

The inspectors reviewed licensing- and design-basis documents for the SSCs and the

maintenance and post-maintenance test procedures. The inspectors observed the

performance of the post-maintenance tests to verify that the licensee performed the tests

in accordance with approved procedures, satisfied the established acceptance criteria,

and restored the operability of the affected SSCs.

These activities constitute completion of four post-maintenance testing inspection

samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

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

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

performing their safety functions:

Other surveillance tests:

October 7, 2015, STN RP-002E, EDG B Control CKT and FO XFER Pump

ISO Switch, Revision 2A

December 21, 2015, STS BG-100A, Centrifugal Charging System A Train

Inservice Pump Test, Revision 46

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The inspectors verified that these tests met technical specification requirements, that the

licensee performed the tests in accordance with their procedures, and that the results of

the test satisfied appropriate acceptance criteria. The inspectors verified that the

licensee restored the operability of the affected SSCs following testing.

These activities constitute completion of two surveillance testing inspection samples, as

defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)

a. Inspection Scope

The inspectors performed an on-site review of the following emergency plan documents:

Procedure AP 06-002, Radiological Emergency Response Plan, Revision 18

Form APF 06-002-1, Emergency Action Levels, Revision 17A

These revisions added a new figure, Airborne Pathway Sampling Locations, added

references to NRC Regulatory Guide 1.101, Emergency Planning and Preparedness for

Nuclear Power Reactors, changed the contamination limits for food and water to the

ingestion pathway protective action guidelines implemented by the state of Kansas,

added the Neosho Rapids Grade School as a reception center, implemented the

chemistry shop laboratory as the environmental laboratory, changed the direct radiation

pathway sampling locations to match those in the Offsite Dose Calculation Manual, and

implemented several editorial changes.

These revisions were compared to their previous revisions, to the criteria of

NUREG 0654, Criteria for Preparation and Evaluation of Radiological Emergency

Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, to

NEI 99-01, Methodology for the Development of Emergency Action Levels, Revision 5,

and to the standards in 10 CFR 50.47(b) to determine if the revision adequately

implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspectors

verified that the revisions did not reduce the effectiveness of the emergency plan. This

review was not documented in a safety evaluation report and did not constitute approval

of licensee-generated changes; therefore, these revisions are subject to

future inspection.

These activities constitute completion of two emergency action level and emergency

plan change samples, as defined in Inspection Procedure 71114.04.

b. Findings

No findings were identified.

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1EP6 Drill Evaluation (71114.06)

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on November 3, 2015, to

verify the adequacy and capability of the licensees assessment of drill performance.

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

emergency offsite facility, and alternate technical support center, and attended the

post-drill critique. The inspectors verified that the licensees emergency classifications,

off-site notifications, and protective action recommendations were appropriate and

timely. The inspectors verified that any emergency preparedness weaknesses were

appropriately identified by the licensee in the post-drill critique and entered into the

corrective action program for resolution.

These activities constitute completion of one emergency preparedness drill observation

sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

1EP7 Exercise Evaluation - Hostile Action Event (71114.07)

a. Inspection Scope

The inspectors observed the December 8, 2015, biennial emergency plan exercise to

verify the exercise acceptably tested the major elements of the emergency plan,

provided opportunities for the emergency response organization to demonstrate key

skills and functions, and demonstrated the licensees ability to coordinate with offsite

emergency responders. The scenario simulated:

An assault on the station by waterborne and land-based adversaries

Faults on two vital electrical buses

An explosion and fire at a fuel oil storage tank

Injured plant employees

Damage to spent fuel pool cooling pumps and piping resulting in a lowering of

the spent fuel pool level

The scenario was designed to demonstrate the licensees capability to implement its

emergency plan under conditions of uncertain physical security.

During the exercise the inspectors observed activities in the control room simulator and

the following emergency response facilities:

Alternate technical support center

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Alternate operations support center

Emergency operations facility

Central and/or secondary alarm stations

Incident command post

The inspectors focused their evaluation of the licensees performance on event

classification, offsite notification, recognition of offsite dose consequences, development

of protective action recommendations, staffing of alternate emergency response

facilities, and the coordination between the licensee and offsite agencies to ensure

reactor safety under conditions of uncertain physical security.

The inspectors also assessed recognition of, and response to, abnormal and emergency

plant conditions, the transfer of decision-making authority and emergency function

responsibilities between facilities, on-site and offsite communications, protection of plant

employees and emergency workers in an uncertain physical security environment,

emergency repair evaluation and capability, and the overall implementation of the

emergency plan to protect public health and safety and the environment. The inspectors

reviewed the current revision of the facility emergency plan, emergency plan

implementing procedures associated with operation of the licensees primary and

alternate emergency response facilities, and procedures for the performance of

associated emergency and security functions.

The inspectors attended the post-exercise critiques in each emergency response facility

to evaluate the initial licensee self-assessment of exercise performance. The inspectors

also attended a presentation of critique items to plant management conducted on

December 15, 2015. The specific documents reviewed during this inspection are listed

in the attachment.

The inspectors reviewed the scenarios of two previous biennial exercises and records of

licensee drills and exercises, conducted between January 2014 and November 2015, to

determine whether the December 8, 2015, exercise was independent and avoided

participant preconditioning, in accordance with the requirements of 10 CFR Part 50,

Appendix E, IV.F(2)(g). The inspectors also compared observed exercise performance

with corrective action program entries and after-action reports for drills and exercises

and events that occurred between January 2014 and November 2015 to determine

whether previously identified weaknesses had been corrected in accordance with the

requirements of 10 CFR 50.47(b)(14) and 10 CFR Part 50, Appendix E, IV.F.

These activities constituted completion of one exercise evaluation sample, as defined in

Inspection Procedure 71114.07.

b. Findings

No findings were identified.

1EP8 Exercise Evaluation - Scenario Review (71114.08)

a. Inspection Scope

The licensee submitted the preliminary exercise scenario for the December 8, 2015,

biennial exercise to the NRC on October 6, 2015, in accordance with the requirements of

E2-15

10 CFR Part 50, Appendix E, IV.F(2)(b). The inspectors performed an in-office review of

the proposed scenario to determine whether it would acceptably test the major elements

of the licensees emergency plan and provide opportunities for the emergency response

organization to demonstrate key skills and functions.

These activities constituted completion of one exercise evaluation scenario review

sample, as defined in Inspection Procedure 71114.08.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

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

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Security

4OA1 Performance Indicator Verification (71151)

.1 Safety System Functional Failures (MS05)

a. Inspection Scope

For the period of October 1, 2014, through September 30, 2015, the inspectors reviewed

licensee event reports, maintenance rule evaluations, and other records that could

indicate whether safety system functional failures had occurred. The inspectors used

definitions and guidance contained in Nuclear Energy Institute Document 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 7, and

NUREG 1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 3, to

determine the accuracy of the data reported.

These activities constituted verification of the safety system functional failures

performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index: Heat Removal Systems (MS08)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the

period of October 1, 2014, through September 30, 2015, to verify the accuracy and

completeness of the reported data. The inspectors used definitions and guidance

contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment

Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported

data.

These activities constituted verification of the mitigating system performance index for

heat removal systems, as defined in Inspection Procedure 71151.

E2-16

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index: Residual Heat Removal Systems (MS09)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the

period of October 1, 2014, through September 30, 2015, to verify the accuracy and

completeness of the reported data. The inspectors used definitions and guidance

contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment

Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported

data.

These activities constituted verification of the mitigating system performance index for

residual heat removal systems, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspectors reviewed the licensees evaluated exercises, emergency plan

implementations, and selected drill and training evolutions that occurred between

October 2014 and September 2015 to verify the accuracy of the licensees data for

classification, notification, and protective action recommendation opportunities. The

inspectors reviewed a sample of the licensees completed classifications, notifications,

and protective action recommendations to verify their timeliness and accuracy. The

inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment

Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported

data. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the drill/exercise performance indicator, as

defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.5 Emergency Response Organization Readiness (EP02)

a. Inspection Scope

The inspectors reviewed the licensees records for participation in drill and training

evolutions between October 2014 and September 2015 to verify the accuracy of the

licensees data for drill participation opportunities. The inspectors verified that all

members of the licensees emergency response organization in the identified key

E2-17

positions had been counted in the reported performance indicator data. The inspectors

reviewed the licensees basis for reporting the percentage of emergency response

organization members who participated in a drill. The inspectors reviewed drill

attendance records and verified a sample of those reported as participating. The

inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment

Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported

data. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the emergency response organization drill

participation performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.6 Alert and Notification System Reliability (EP03)

a. Inspection Scope

The inspectors reviewed the licensees records of alert and notification system tests

conducted between October 2014 and September 2015 to verify the accuracy of the

licensees data for siren system testing opportunities. The inspectors reviewed

procedural guidance on assessing alert and notification system opportunities and the

results of periodic alert and notification system operability tests. The inspectors used

Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance

Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The

specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the alert and notification system reliability

performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152)

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items

entered into the licensees corrective action program and periodically attended the

licensees condition report screening meetings. The inspectors verified that licensee

personnel were identifying problems at an appropriate threshold and entering these

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

the licensee developed and implemented corrective actions commensurate with the

significance of the problems identified. The inspectors also reviewed the licensees

problem identification and resolution activities during the performance of the other

inspection activities documented in this report.

E2-18

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

The inspectors reviewed the licensees corrective action program, performance

indicators, station performance reports, and other documentation to identify trends that

might indicate the existence of a more significant safety issue. The inspectors verified

that the licensee was taking corrective actions to address identified adverse trends.

These activities constitute completion of one semiannual trend review sample, as

defined in Inspection Procedure 71152.

b. Observations and Assessments

The inspectors evaluated a sample of issues and events that occurred over the course

of the past two quarters to determine whether issues were appropriately considered as

emerging or adverse trends. The inspectors verified that these issues were addressed

within the scope of the corrective action program or through department review and

documentation in the quarterly trend presentation for overall assessment. The

inspectors noted NRC Inspection Report 05000482/2015002 documented a trend with

respect to the licensees procedure adherence. Apparent increases in the number of

issues associated with following Procedure AP 10-104, Breach Authorization, and

Procedure AP 26C-004, Operability Determination and Functionality Assessment,

relate to the previously identified trend in procedure adherence.

The inspectors noted an apparent increase in the number of issues associated with

following Procedure AP 10-104, Breach Authorization:

NRC Inspection Report 05000482/2015001 documents an inspector identified

non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V,

Instructions, Procedures, Drawings, associated with the licensees failure to

follow the requirements of Procedure AP 10-104, Breach Authorization,

Revision 32. Specifically, on February 24, 2015, the licensee failed to initiate a

breach permit and station a boundary watch when the auxiliary building

emergency exhaust system boundary door 41015 was opened multiple times for

transporting scaffolding from the turbine building to the auxiliary building; opening

this door without compensatory measures rendered the auxiliary building

emergency exhaust system inoperable. This issue was entered into the

corrective action program for resolution as Condition Reports 92315 and 92630.

NRC Inspection Report 05000482/2015003 documents an inspector identified

NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,

Drawings, associated with the licensees inadequate implementation of

Procedure AP 10-104, Breach Authorization, Revision 34. Specifically, on

August 28, 2015, control room door 36043, which is a fire, security, and control

room ventilation isolation signal barrier, was fully opened prior to the breaching

party obtaining written authorization in accordance with procedure. This issue

E2-19

was entered into the corrective action program for resolution as Condition Report

99097.

On October 19, 2015, the inspectors identified the A residual heat removal pump

room door blocked open by a sign that had fallen between the door and the

frame. This issue is associated with the licensees failure to follow the

requirements of Procedure AP 10-104, Breach Authorization, Revision 34.

Specifically, the licensee failed to initiate a breach permit when the A residual

heat removal pump room door was blocked open. With the door blocked open,

all functions of the boundary could still be met. The door was immediately closed

and the issue was entered into the corrective action program as Condition Report

100385.

The inspectors identified on November 3, 2015, that a halon boundary between

the B train engineered safety feature switchgear room number 2 (room 3302) and

a small electrical chase was breached prior to the breaching party obtaining

required written authorization in accordance with Procedure AP 10-104, Breach

Authorization. Personnel were continuously posted at the breached boundary

and the inspectors would not have expected additional actions to be performed

had the breach authorization been obtained properly. Immediate corrective

actions included restoring the breached halon boundary and delaying other

ongoing work until the breached boundary was adequately sealed. The issue

was entered into the licensees correction action program as Condition Report

100700.

The inspectors discussed the apparent increase in the number of issues associated with

following Procedure AP 10-104, Breach Authorization, at the exit meeting on

January 27, 2016. The licensee entered this apparent trend into the corrective action

program as Condition Report 102289.

The inspectors also noted that licensee personnel had appropriately documented in the

corrective action program an operations division performance report operability

determination quality focus area, on May 2, 2015, in Condition Report 96033. Similarly,

the inspectors noted an apparent increase in the number of operability evaluation issues:

NRC Inspection Report 05000482/2015001 documents an inspector identified

NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,

Drawings, associated with the licensees failure to complete an adequate

operability evaluation in accordance with Procedure AP 28-001, Operability

Evaluations, Revision 24, following the failure to meet a surveillance test

acceptance criteria. Specifically, on February 25, 2015, the licensee did not have

an accurate technical basis for declaring the train A control room air conditioning

unit operable when the minimum air flow rate was not met. This issue was

entered into the corrective action program for resolution as Condition Report

92274.

The inspectors identified that Procedure AP 26C-004, Determination and

Functionality Assessment, Revision 32, states that functionality assessments

should include whether there is a reasonable expectation of functionality,

including the basis for the assessment and any compensatory measures put in

E2-20

place to establish or restore functionality. This procedure was not adequately

implemented on May 15, 2015, after the SGK05A unit tripped and the SGK05A

unit was declared functional without documentation of compensatory actions to

provide reasonable assurance that the SGK05A unit would operate reliably.

Although the functionality assessment did not discuss compensatory actions,

less formal actions to monitor SGK05A operation every 10 minutes and actions to

reset the unit following an SGK05A trip were implemented. This issue was

entered into the corrective action program as Condition Report 101790.

As documented in NCV 05000482/2015004-03, Failure to Perform an Adequate

Operability Determination and Consider Design Basis Events, the inspectors

identified that the licensee failed to document an operability determination of

sufficient scope to address the capability of safety-related essential service water

valves in the control building to perform their specified safety functions in the

event of a design basis local intense precipitation event, which resulted in a

reasonable doubt on the operability of safety-related essential service water

valves. Please see NCV 05000482/2015004-03 for additional details regarding

this specific issue.

The inspectors identified that Procedure AP 26C-004, Determination and

Functionality Assessment, Revision 32, Section 6.7, Surveillance Testing,

states, During a test, anomalous data with no clear indication of the cause must

be attributed to the equipment under test. In that case, a prompt determination of

operability is appropriate with follow-on corrective action as necessary, and this

procedure was not adequately implemented on November 9, 2015, after the B

essential service water pump failed surveillance testing in accordance with

Procedure STS EF-100B, ESW System Inservice Pump B & ESW B Check

Valve Test, Revision 46, and a prompt operability determination was not

completed to justify continued operability. Although a prompt operability

determination was not completed, the licensees immediate operability

determination and subsequent revisions adequately justified operability. This

issue was entered into the corrective action program for resolution as Condition

Report 100968.

The licensee documented in the evaluation associated with Condition Report 96033,

actions taken that included Operability Evaluation Update and Focus Topic training for

operations during the training cycle ending on October 8, 2015, and plans to perform the

training during subsequent cycles. The inspectors discussed the apparent increase in

the number of issues associated with operability determinations and compensatory

measures at the exit meeting on January 27, 2016.

c. Findings

No findings were identified.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

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

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On May 15, 2015, the SGK05A unit tripped twice, resulting in the train A

safety-related batteries, inverters, and alternating and direct current buses being

declared inoperable due to the loss of area cooling, two separate Technical

Specification 3.0.3 entries, and separate reactor power reductions to 93 and

94.7 percent.

The inspectors assessed the licensees problem identification threshold, cause

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

verified that the licensee appropriately prioritized the planned corrective actions

and that these actions were adequate to correct the condition.

On May 17, 2015, during a heavy rainstorm, Wolf Creek personnel identified

water coming out of the ceiling in the hot chemistry lab (room 3228) of the

communication corridor building, through penetration P322W0902, and the water

began flooding the floor of the room. Water also began accumulating in the

essential service water pipe chase at a lower level in the control building (room

3101).

The inspectors assessed the licensees problem identification threshold, extent of

condition reviews, and compensatory actions. The inspectors verified that the

licensee appropriately prioritized the planned corrective actions and that these

actions were adequate to correct the condition.

On November 24, 2015, November 25, 2015, December 14, 2015, and

December 19, 2015, the inspectors accompanied non-licensed operators during

their rounds, which included tours of the turbine building and adjacent areas, the

control building and adjacent areas, the auxiliary building and adjacent areas,

and areas outside of the main protected area.

The inspectors assessed the licensees problem identification threshold and

response to identification of adverse conditions. The inspectors verified that the

licensee appropriately prioritized the planned corrective actions, as applicable,

and that these actions were adequate.

These activities constitute completion of three annual follow-up samples, as defined in

Inspection Procedure 71152.

b. Findings

b.1 Inadequate Measures to Assure SGK05A Issues Were Promptly Corrected

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

Appendix B, Criterion XVI, Corrective Action, for the licensees inadequate measures to

assure that corrective action was taken to preclude repetition of a significant condition

adverse to quality. Specifically, measures to correct train A Class 1E electrical

equipment air-conditioning system (SGK05A) issues following two trips of the unit on

October 18, 2013, were inadequate, which resulted in the SGK05A unit tripping twice on

May 15, 2015, the train A safety-related batteries, inverters, and alternating and direct

current buses being declared inoperable due to the loss of area cooling, two separate

Technical Specification 3.0.3 entries, and resulting technical specification required

reactor power reductions to 93 and 94.7 percent.

E2-22

Description. On May 15, 2015, at 4:36 a.m., the SGK05A unit (the train A Class 1E

electrical equipment heating, ventilation, and air conditioning unit) tripped. A

non-licensed operator identified that the SGK05A unit was tripped with the Lube Oil

Failure indication in alarm. The train A safety-related batteries, inverters, and

alternating and direct current buses were declared inoperable when the SGK05A unit

tripped.

The SGK05A unit is a support system for the train A safety-related switchgears,

batteries, and inverters, which are technical specification systems. Section 9.4.1.2.3,

System Operation, of the Updated Safety Analysis Report (USAR) discusses the

function of the Class 1E electrical equipment air-conditioning system, The Class 1E

electrical equipment air-conditioning system is operated in a continuous recirculation

mode to maintain the engineered safety feature switchgear room, the battery rooms, and

the direct current switchgear rooms at or below a temperature of 90 degrees

Fahrenheit. When the SGK05A unit is declared non-functional, the supported technical

specification systems are subsequently declared inoperable.

After the SGK05A unit tripped on May 15, 2015, at 4:36 a.m., the licensee entered

numerous technical specification conditions, including Technical Specification 3.0.3.

Technical Specification 3.0.3 required the licensee to initiate actions within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to

place the reactor in Mode 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months because the train A inverters were both

declared inoperable. The licensee completed a power reduction to 93 percent and

began returning power to 100 percent after restarting the SGK05A unit and exiting the

applicable technical specifications at 7:33 a.m.

On May 15, 2015, at 9:48 p.m., the SGK05A unit tripped again with the same Lube

Oil Failure indication in alarm. The licensee again entered Technical Specification 3.0.3

and others. The licensee completed a power reduction to 94.7 percent and began

returning power to 100 percent after the licensee restarted the SGK05A unit and

implemented additional compensatory measures. The licensees immediate corrective

actions and compensatory measures to ensure operability included troubleshooting to

determine the direct cause of the compressor trips, stationing a dedicated operator

following the second trip on May 15, 2015, documenting the issues in the corrective

action program as Condition Reports 96392 and 96397, and subsequently implementing

Temporary Modification 15-013-GK-00, which removed the lube oil failure trip feature

and restored compliance. Section 4OA2.2, Semiannual Trend Review, of this report,

includes additional discussion concerning the compensatory measures associated with

this issue.

In response to the two trips of the SGK05A unit on May 15, 2015, the licensee

completed an apparent cause evaluation associated with Condition Report 96392. The

Failure Evaluation section of the apparent cause evaluation concluded, The failed

component under evaluation was found to be [the] lube oil pressure sensor installed on

the SGK05A compressor. Based on the analysis tools and evaluationthe most likely

reason for failure was blockage of the lube oil pressure sensor inlet screen by residual

contaminants found within [the] compressor. The apparent cause is also described and

states, Senior managers failed to ensure supervisory and management oversight of

work activities to ensure successful completion of the replacement of the SGK05A

compressor in RF [(refueling outage)] 20. This missed opportunity allowed residual

contaminants entrained within the compressor sump to migrate to the lube oil sensor

inlet screen resulting in a false low lube oil signal.

E2-23

The inspectors reviewed a history of SGK05A equipment reliability issues. Prior to the

issues identified on May 15, 2015, the SGK05A unit tripped twice on October 18, 2013.

The direct cause of the October 18, 2013, SGK05A unit tripping twice was described in

the root cause analysis for Condition Report 75337. It states, The direct cause of this

condition is attributed to the loss of lube oil pressure sensing to the pressure switch of

the SGK05A compressor. To address the direct cause, the compressor was removed

from the system and a gravity flush of the crankcase was performed. The root cause is

also described and states, The root cause of this condition is attributed to the lack of

station awareness in relation to how Procedure AP 12-002 applies to the refrigerant side

of the GK [(control building heating, ventilation, and air conditioning)] HVAC [(heating,

ventilation, and air conditioning)] system. All actions associated with Condition

Report 75337 were completed by March 5, 2015. These actions included generating

specific guidance for flushing/restoring the control building heating, ventilation, and air

conditioning systems back to operability, including developing criterion for the flushing

and restoration processes; revising Procedure AP 12-002 to direct technicians to core

work instructions on heating, ventilation, and air conditioning cleanliness; and

incorporating the cause and actions into technician training.

Prior to the issues of 2013, the licensee began having issues with the SGK05A

compressor when it tripped on low oil pressure on June 4, 2012. The evaluation

associated with this issue and Condition Report 53709 stated, Moisture degraded the

compressor lube oil causing sludge and metal particulate to plug the internal oil screen

and restrict flow to the compressor oil pump. The inspectors confirmed through

interviews with licensee personnel that the direct cause of the trip on June 4, 2012, was

the same direct cause that impacted the SGK05A unit on October 18, 2013, and again

on May 15, 2015. The inspectors reviewed NRC Enforcement Manual Revision 9,

Section 2.2.2, Circumstances Resulting in Consideration of an NOV (vs. an NCV) for

Licensees and Non-Licensees with an Approved Corrective Action Program, and the

inspectors concluded that the licensee neither took appropriate action to restore

compliance in a reasonable period of time after becoming aware of a violation, nor took

compensatory measures until compliance was restored when compliance could not be

reasonably restored within a reasonable period of time. Specifically, the licensee did not

take appropriate action to restore compliance and correct the direct cause of SGK05A

trips, contaminants found within the compressor, in a reasonable period of time after

becoming aware of the violation as documented in NCV 05000482/2013005-04, Failure

to Preclude Repetition of a Significant Condition Adverse to Quality Affecting Class 1E

Air Conditioning Unit, (ADAMS Accession Number ML14041A484). Compliance was

restored on May 16, 2015, with the implementation of Temporary

Modification 15-013-GK-00, which removed the lube oil failure trip feature being

impacted by the contaminants found within the compressor.

NCV 05000482/2013005-04, Failure to Preclude Repetition of a Significant Condition

Adverse to Quality Affecting Class 1E Air Conditioning Unit, (ADAMS Accession

Number ML14041A484), which details the licensees failure to preclude repetition of a

significant condition adverse to quality. The NCV discusses SGK05A issues that

occurred on May 6, June 17, September 11, and October 18, 2013, and resulted in

Technical Specification 3.0.3 entries, plant shutdowns to complete repairs, and/or a

request for a Notice of Enforcement Discretion to continue operating and complete

repairs. NCV 05000482/2013005-04 concludes, Between September 11 and October

18, 2013, the licensee failed to preclude repetition of a significant condition adverse to

quality. Specifically, the train A Class 1E air conditioning unit had to be removed from

E2-24

service due to internal debris on June 17, September 11, and October 18, 2013, before

the cause was identified and corrected. The root cause evaluation associated with

Condition Report 75337 outlined the corrective actions to prevent recurrence and actions

to address the direct cause, as previously discussed.

This issue is NRC-identified because the inspectors identified that the two trips of the

SGK05A unit on May 15, 2015, were inappropriately characterized as a condition

adverse to quality, and an apparent cause evaluation was not appropriate to address

this issue in accordance with Procedure AI 28A-010, Screening Condition Reports,

Revision 21, effective December 12, 2014. Wolf Creek entered this issue into its

corrective action program as Condition Report 101788. The inspectors also identified

that the licensee did not propose corrective actions in the Condition Report 96392

evaluation that addressed the failure of the Condition Report 75337 evaluation to identify

adequate corrective actions. Specifically, the Condition Report 96392 evaluation

discusses a potential missed opportunity to prevent the event, and states that the

timeliness of the compressor replacement was [identified to have contributed to this

event], but there are not any corrective actions that directly address this concern. The

licensee entered this issue into its corrective action program as Condition Report

102331.

Actions to prevent recurrence following the May 15, 2015, SGK05A trips, documented in

apparent cause evaluation 96392, included conducting a seminar with station managers

to review lessons learned from the event, completing a change package to replace the

SGK05A compressor that has been the source of residual contamination that has led to

numerous trips of the unit, and tracking of the timely replacement of the SGK05A

compressor with a due date of December 15, 2016.

Analysis. The inspectors determined that the licensees failure to take adequate

corrective actions to preclude repetition of a significant condition adverse to quality in

accordance with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was a

performance deficiency. This finding is more than minor because it is associated with

the equipment performance attribute of the Mitigating Systems Cornerstone and affected

the associated cornerstone objective to ensure the availability, reliability, and capability

of systems that respond to initiating events to prevent undesirable consequences (i.e.,

core damage). Specifically, the train A safety-related batteries, inverters, and alternating

and direct current buses became inoperable and their capability to respond to initiating

events to prevent undesirable consequences was impacted as a result of the SGK05A

unit tripping.

In accordance with Inspection Manual Chapter 0609.04, Initial Characterization of

Findings, and Exhibit 3 of Inspection Manual Chapter 0609, Appendix A, The

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

2012, and April 29, 2015, respectively, the performance deficiency affects a mitigating

structure, system, and component. The performance deficiency does not affect the

design or qualification of a mitigating SSC, and the SSC did not maintain its functionality.

Additionally, the finding does not represent a loss of system and/or function, the finding

does not represent an actual loss of function of a least a single train for greater than its

technical specification allowed outage time or two separate safety systems

out-of-service for greater than their technical specification allowed outage time, and the

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

specification trains of equipment designated as high safety-significant in accordance with

E2-25

the licensees maintenance rule program for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Therefore, the

inspectors determined that this finding is of very low safety significance (Green).

In accordance with Inspection Manual Chapter 0310, Aspects Within The Cross-Cutting

Areas, issued December 4, 2014, the finding has a cross-cutting aspect in the area of

human performance, resources, because the licensee did not ensure that personnel,

equipment, procedures, and other resources were available and adequate to support

nuclear safety. Specifically, the licensee did not ensure successful completion of the

replacement of the SGK05A compressor in Refueling Outage 20, which was a missed

opportunity that resulted in the SGK05A unit tripping twice on May 15, 2015, as a result

of the same direct cause [H.1].

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,

requires, in part, that in the case of significant conditions adverse to quality, the

measures shall assure that the cause of the condition is determined and corrective

action taken to preclude repetition. Contrary to the above, from October 18, 2013, to

May 16, 2015, in the case of a significant condition adverse to quality, measures did not

to assure that the cause of the condition was determined and corrective action taken to

preclude repetition. Specifically, the licensee did not establish adequate measures to

assure that the cause of a significant condition adverse to quality, contaminants

impacting the reliability of the SGK05A unit, were determined and corrective action taken

to preclude repetition, and the same significant condition adverse to quality resulted in

the train A safety-related batteries, inverters, and alternating and direct current buses

becoming inoperable and their capability to respond to initiating events to prevent

undesirable consequences being impacted on June 12, 2012, October 18, 2013, and

May 15, 2015. The licensees immediate corrective actions included troubleshooting to

determine the direct cause of the compressor trips, stationing a dedicated operator

following the second trip on May 15, 2015, and subsequently implementing Temporary

Modification 15-013-GK-00, which restored compliance. This violation was of very low

safety significance (Green), and the licensee entered this issue into its corrective action

program as Condition Reports 96392, 96397, and 101788. This violation is being

treated as a cited violation, consistent with Section 2.3.2 of the Enforcement Policy,

because the licensee did not restore compliance (or demonstrate objective evidence of

plans to restore compliance) within a reasonable period of time (i.e., in a timeframe

commensurate with the significance of the violation) after a violation was identified. This

is a violation of Title 10 of the Code of Federal Regulations Part 50, Appendix B,

Criterion XVI, Corrective Action. A Notice of Violation is attached:

VIO 05000482/2015004-01, "Inadequate Measures to Assure SGK05A Issues Were

Promptly Corrected."

b2. Failure to Ensure Essential Service Water Valves Were Adequately Protected From

External Flooding Hazards

Introduction. The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B,

Criterion III, Design Control, for the licensees failure to establish measures to assure

that applicable regulatory requirements and the design basis, for applicable SSCs, are

correctly translated into specifications, drawings, procedures, and instructions.

Specifically, the licensee failed to ensure that safety-related essential service water

valves in the control building were adequately protected from external flooding hazards

in the event of a design basis local intense precipitation event, which resulted in a

reasonable doubt on the operability of safety-related essential service water valves.

E2-26

Description. Located on the lower level of the control building (room 3101) are the

safety-related essential service water train A and B service water cross-connect motor-

operated valves EFHV0023, EFHV0024, EFHV0025, and EFHV0026, and the essential

service water train A and B to service water system valves EFHV0039, EFHV0040,

EFHV0041, and EFHV0042. The safety-related function of these valves is to isolate the

non-safety related service water system from the safety-related essential service water

system. USAR Section 3.3.7.4, Internal Flooding Results, describes the impact of

water accumulating in room 3101, where the eight subject safety-related valves are

located. It states, Submersion of motor operated valves HV0023, HV0024, HV0025 and

HV0026, which are located in this room, would occur, resulting in a loss of service water.

Isolation of the flood and the non-essential service water (NESW) system from the

essential service water (ESW) system would be impossible until the control building

basement is drained.

With respect to external flood level hazards, Table 1.2-1, Design Envelope, of the

Wolf Creek USAR, states, Flooding is precluded by the elevation of the plant and by the

site drainage systemNo special flood protection measures (such as external flood

doors) are incorporated.

Section 3.4.1.1.1, External Flood Protection, of the Wolf Creek USAR, states:

All seismic Category I structures and the systems they house are designed to

withstand the effects of natural phenomena, such as flooding and groundwater

level (GDC-2). Flood elevations, including the probable maximum flood (PMF)

and the maximum groundwater elevations used in the design of powerblock

seismic Category I structures for buoyancy and hydrostatic pressure, are shown

in Tables 1.2-1 and 3.4-1 and are discussed in Section 2.4Safety-related

systems located below grade are protected from groundwater inleakage by a

combination of a waterproofing system for the structures and other features such

as the location of safety-related systems in watertight compartments, sump

pumps, alarms and other water level indications and administrative controls.

Should groundwater inleakage occur, the design features and administrative

controls would protect the safety related systemsAlthough not serving a

safety-related function, additional waterproofing is provided below grade by

means of waterstops and waterproofing materials to minimize inleakage.

Waterstops are provided at expansion and construction joints and electrical duct

bank penetrations located below grade."

Finally, Section 9.2.1.2.1.1, Safety Design Basis, related to the essential service water

system, describes the safety design bases and states, The ESWS [(essential service

water system)] is protected from the effects of natural phenomena, such as earthquakes,

tornadoes, hurricanes, floods, and external missiles (GDC-2).

On May 17, 2015, during a heavy rainstorm, Wolf Creek personnel identified water

coming out of the ceiling in the hot chemistry lab (room 3228) of the communication

corridor building, through penetration P322W0902, and the water began flooding the

floor of the room. Water also began accumulating in room 3101. Wolf Creek

documented the condition in Condition Report 96404.

The station determined that water entered the control building sumps room 3101 via

floor drains in the hot chemistry lab of the communication corridor building. The floor

drains in the hot chemistry lab of the communication corridor building are directly routed

E2-27

to the control building sumps and room 3101. The station also determined that water

entered the hot chemistry lab via conduits from the turbine building area four cable vault

with degraded non-safety related conduit penetration seals.

Historical pictures of the turbine building area four cable vault, which were taken on April

13, 2009, May 22, 2011, June 15, 2011, and September 3, 2014, show a penetration

seal in the turbine building area four cable vault that was not in place. Additionally, Wolf

Creek personnel and the inspectors verified the configuration of the seals via tours of the

turbine building area four cable vault on November 18, 2015.

The inspectors also noted that Condition Report 59257, which was entered into the

corrective action program on October 29, 2012, and documented past leakage through

electrical penetration P322W0902, was documented in response to flooding walk-downs

performed in accordance with NEI 12-07, Guidelines for Performing Verification

Walkdowns of Plan Flood Protection Features and NTTF [(Near Term Task Force)]

Recommendation 2.3 Flooding. Condition Report 59257 did not adequately consider

the potential impact and implications of the leakage indication. Specifically, neither the

source of the leakage nor the pathway into the chemistry lab were considered.

Additionally, the flooding walk-downs included reviews of piping and instrumentation

drawings, which included drawings showing the drain pathway from the communication

corridor building to the control building basement. These concerns were entered into the

stations corrective action program as Condition Report 102273.

The inspectors also questioned the stations immediate operability determination

associated with Condition Report 96404; please see NCV 05000482/2015004-03, also

documented in this report, for additional discussion concerning the inadequate

operability determination. In response to the inspectors questions, the station entered

Condition Report 100299 into its corrective action program, which documented the

stations failure to adequately evaluate the concern with respect to design basis local

intense precipitation conditions. On October 15, 2015, a prompt operability evaluation

associated with Condition Report 100299 was completed that showed the essential

service water valves remained operable.

To understand the significance of the concern, the inspectors noted that

Calculation FL-05, Control Building Flooding, Revision 2, calculates the maximum flood

level in control building room 3101 due to the rupture of a service water pipe and also

states that the essential service water to service water isolation valves begin to be

impacted when water in the room reaches a height of 33 inches.

Considering observed flows into the hot chemical lab room on May 17, 2015, and

inspections performed on November 18, 2015, and recognizing the elevation of

postulated external flood waters during a design basis local intense precipitation event,

the station estimated the peak probable maximum precipitation flood flow through the

duct bank into the hot chemistry laband ultimately the control building basementas

855 gallons per minute. Utilizing a hydrograph of the probable maximum flood flow to

estimate the total volume of flood water that could enter control building room 3101, the

total volume of the flood flow that would enter the room was estimated to be

approximately 92,799 gallons, which equates to a water level of 26.94 inches in room

3101. Considering that safety-related equipment is at a height of 33 inches in the room,

the safety-related essential service water equipment in room 3101 would not have been

impacted by a design basis probable maximum precipitation event even though a

E2-28

pathway existed for external flood waters from a local intense precipitation event to

reach control building room 3101 containing safety related essential service water valves

that must be protected from the effects of natural phenomena like floods. The licensee

was able to show through extensive analysis and later inspection that the subject valves

were shown to be operable even while the penetrations were degraded and a substantial

loss of margin occurred. Additional corrective actions include accelerating three

Fukushima project schedules that include a new sump pump in the turbine building area

four cable vault, ground and surface water improvements for non-safety related electrical

duct banks, and new sump pumps in electrical manholes (125 and 152) near the turbine

building. Each of these additional corrective actions is expected to reduce the amount of

water that would impact the turbine building area four cable vault during heavy and

design basis precipitation and are currently expected to be completed December 2016.

However, considering the USAR, the non-safety related design of the conduit

penetration seals, and the open drain pathway from the communication corridor building

to control building room 3101, the inspectors determined that the licensee failed to

ensure that safety-related essential service water valves in the control building were

adequately protected from external flooding hazards in the event of a design basis local

intense precipitation event.

Analysis. The inspectors determined that the licensees failure to ensure that essential

service water valves in the control building (room 3101) were adequately protected from

external flooding hazards in the event of a design basis local intense precipitation event

was a performance deficiency. This finding is more than minor because it is associated

with the design control attribute of the Mitigating Systems Cornerstone and affected the

associated cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences (i.e., core

damage). Specifically, during design basis local intense precipitation events, the

safety-related essential service water train A and B service water cross-connect

motor-operated valves EFHV0023, EFHV0024, EFHV0025, and EFHV0026, and the

essential service water train A and B to service water system valves EFHV0039,

EFHV0040, EFHV0041, and EFHV0042 were susceptible to external flooding hazards,

and there was a reasonable doubt on the operability of these essential service water

valves; however, subsequent evaluation determined that the essential service water

valves would not have been impacted in the event of a design basis local intense

precipitation event, and the valves were determined to be operable.

In accordance with Inspection Manual Chapter 0609.04, Initial Characterization of

Findings, and Exhibit 2 of Inspection Manual Chapter 0609, Appendix A, The

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

June 19, 2012, and April 29, 2015, respectively, the performance deficiency affects

mitigating SSCs. The finding is a deficiency affecting the design or qualification of

mitigating SSCs, and the SSCs maintained their operability and functionality. Therefore,

the inspectors determined that this finding is of very low safety significance (Green).

In accordance with Inspection Manual Chapter 0310, Aspects Within The Cross-Cutting

Areas, issued December 4, 2014, the finding has a cross-cutting aspect in the area of

human performance, challenge the unknown, because Wolf Creek individuals did not

stop when faced with uncertain conditions. Specifically, the licensee did not maintain a

questioning attitude during flooding walk-downs performed in accordance with NEI 12-07

or during evaluation of Condition Report 59257 to identify and resolve unexpected

E2-29

conditions like the floor drain pathway from the communication corridor to the control

building basement (room 3101), which was an opportunity for the station to identify the

open pathway from the exterior of the plant [H.11].

Enforcement. Title10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in

part, that for those SSCs to which this appendix applies, measures shall be established

to assure that applicable regulatory requirements and the design basis, are correctly

translated into specifications, drawings, procedures, and instructions. Contrary to the

above, since at least April 13, 2009, until October 15, 2015, for quality-related

components associated with the essential service water system, to which 10 CFR Part

50, Appendix B applies, the licensee failed to assure that applicable regulatory

requirements and the design basis, are correctly translated into specifications, drawings,

procedures, and instructions. Specifically, the licensee failed to ensure that

safety-related essential service water valves in the control building (room 3101) were

adequately protected from external flooding hazards in the event of a design basis local

intense precipitation event. The licensee evaluated the condition to ensure that a design

basis local intense precipitation event would not cause inoperability or unavailability of

essential service water valves. The stations immediate corrective actions included

entering the condition into the corrective action program and performing a prompt

operability evaluation that showed the essential service water valves remained operable.

This violation is being treated as an NCV consistent with Section 2.3.2 of the

Enforcement Policy. The violation was entered into the licensees corrective action

program as Condition Report 102250. (NCV 05000482/2015004-02: Failure to Ensure

Essential Service Water Valves were Adequately Protected from External Flooding

Hazards)

b3. Failure to Perform an Adequate Operability Determination and Consider Design

Basis Events

Introduction. The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to

accomplish activities affecting quality in accordance with Procedure AP 26C-004,

Operability Determination and Functionality Assessment, Revision 31. Specifically, the

licensee failed to document an operability determination of sufficient scope to address

the capability of safety-related essential service water valves in the control building

(room 3101) to perform their specified safety functions in the event of a design basis

local intense precipitation event, which resulted in a reasonable doubt on the operability

of safety-related essential service water valves.

Description. On May 17, 2015, during a heavy rainstorm, Wolf Creek personnel

identified water coming out of the ceiling in the hot chemistry lab (room 3228) of the

communication corridor building, through penetration P322W0902, and the water began

flooding the floor of the room. Water also began accumulating in a lower level in the

control building (room 3101). Wolf Creek documented the condition in Condition Report

96404.

Located on the lower level of the control building (room 3101) are the safety-related

essential service water train A and B service water cross-connect motor-operated valves

EFHV0023, EFHV0024, EFHV0025, and EFHV0026, and the essential service water

train A and B to service water system valves EFHV0039, EFHV0040, EFHV0041, and

E2-30

EFHV0042. The safety-related function of these valves is to isolate the non-safety

related service water system from the safety-related essential service water system.

Wolf Creek determined in its immediate operability screening for Condition Report 96404

that it would take about 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months for water to accumulate to a level of 33 inches in the

control building room 3101, based on a rate of influent of approximately 50 gallons per

minute from rain water through the hot chemistry lab. The immediate operability

screening concludes, Therefore, in the event the electrical duct bank overflows, there is

sufficient time to deploy additional sump pumps to reduce the level and terminate the

inleakage through the chemistry hot lab. Work Order 14-382942 was generated and

the Condition Report 96404 closure notes stated, Design Engineering will use three of

the four Fukushima ground water intrusion mitigation projects to mitigate the flooding in

the Hot Chemistry Lab. The three Fukushima projects schedules have been

accelerated. These projects included design change packages for a new sump pump in

the turbine building area four cable vault, ground and surface water improvements for

non-safety related electrical duct banks, and new sump pumps in electrical

manholes (125 and 152) near the turbine building. Each of these additional corrective

actions is expected to reduce the amount of water that would impact the turbine building

area four cable vault during heavy and design basis precipitation. Condition Report

96404 was closed to Condition Report Action 070319-01-03, which is currently planned

to be completed December 2016.

USAR Section 3.3.7.4, Internal Flooding Results, describes the impact of the design

basis internal flooding hazard in the essential service water pipe chase level of the

control building (room 3101). It states, Submersion of motor operated valves HV0023,

HV0024, HV0025 and HV0026, which are located in this room, would occur, resulting in

a loss of service water. Isolation of the flood and the non-essential service water

(NESW) system from the essential service water (ESW) system would be impossible

until the control building basement [(room 3101)] is drained. Calculation FL-05, Control

Building Flooding, Revision 2, calculates the maximum flood level in control building

room 3101 due to the rupture of a service water pipe and also states that the essential

service water to service water isolation valves begin to be impacted when water in the

room reaches a height of 33 inches.

After learning of an auxiliary operator action to Pump out SE electrical cable pit when

required (maintain level below cables), which was being tracked on the Turbine

Building Operator Relief Checklist, the inspectors inquired about the action and toured

applicable accessible portions of the plant. On September 15, 2015, the inspectors

raised concerns with the station regarding cables that were submerged in the turbine

building area four cable vault. Wolf Creek determined that the low voltage

non-safety related wetted cables condition had been previously identified and

documented in Condition Report 22210. In following up on this concern, the inspectors

noted that Table 1.2-1, Design Envelope, of the Wolf Creek USAR states, Flooding is

precluded by the elevation of the plant and by the site drainage systemNo special

flood protection measures (such as external flood doors) are incorporated.

The inspectors also noted that Section 3.4.1.1.1, External Flood Protection, of the

Wolf Creek USAR states:

All seismic Category I structures and the systems they house are designed to

withstand the effects of natural phenomena, such as flooding and groundwater

E2-31