ML053130249
| ML053130249 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/09/2005 |
| From: | William Jones NRC/RGN-IV/DRP/RPB-B |
| To: | Muench R Wolf Creek |
| References | |
| IR-05-004 | |
| Download: ML053130249 (29) | |
See also: IR 05000482/2005004
Text
November 9, 2005
Rick A. Muench, President and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, KS 66839 Wolf Creek Nuclear Operating Corporation
SUBJECT: WOLF CREEK GENERATING STATION - NRC INTEGRATED INSPECTION
REPORT 05000482/2005004
Dear Mr. Muench:
On September 26, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Wolf Creek Generating Station. The enclosed integrated report documents
the inspection findings which were discussed on September 28, 2005, with Mr. Steve Hedges
and other members of your staff.
The inspections examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
Inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
This report documents one NRC identified and two self-revealing findings of very low safety
significance (Green). The findings were determined to involve violations of NRC requirements;
however, because of the very low safety significance and because the findings were entered
into your corrective action program, the NRC is treating these violations as noncited violations
consistent with Section VI.A of the NRC Enforcement Policy. In addition, an apparent violation
was identified involving fire protection suppression water system degradation. The NRC is
performing a significance determination process Phase 3 analysis to determine the safety
significance. If you contest these violations, you should provide a response within 30 days 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.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its
enclosure, will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records component of NRCs document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room).
Wolf Creek Nuclear Operating Corporation -2-
Should you have any questions concerning this inspection, we will be pleased to discuss them
with you.
Sincerely,
/RA/
William B. Jones, Chief
Project Branch B
Division of Reactor Projects
Docket: 50-482
License: NPF-42
Enclosure:
NRC Inspection Report 05000482/2005004
w/attachment: Supplemental Information
cc w/enclosure:
Vice President Operations/Plant Manager
Wolf Creek Nuclear Operating Corp.
P.O. Box 411
Burlington, KS 66839
Jay Silberg, Esq.
Shaw Pittman, LLP
2300 N Street, NW
Washington, DC 20037
Supervisor Licensing
Wolf Creek Nuclear Operating Corp.
P.O. Box 411
Burlington, KS 66839
Chief Engineer
Utilities Division
Kansas Corporation Commission
1500 SW Arrowhead Road
Topeka, KS 66604-4027
Office of the Governor
State of Kansas
Topeka, KS 66612
Attorney General
120 S.W. 10th Avenue, 2nd Floor
Topeka, KS 66612-1597
Wolf Creek Nuclear Operating Corporation -3-
County Clerk
Coffey County Courthouse
110 South 6th Street
Burlington, KS 66839-1798
Vick L. Cooper, Chief, Air Operating
Permit and Compliance Section
Kansas Department of Health and
Environment
Bureau of Air and Radiation
1000 SW Jackson, Suite 310
Topeka, KS 66612-1366
Chief Technological Services Branch
National Preparedness Division
Department of Homeland Security
Emergency Preparedness & Response Directorate
FEMA Region VII
2323 Grand Boulevard, Suite 900
Kansas City, MO 64108-2670
Wolf Creek Nuclear Operating Corporation -4-
Electronic distribution by RIV:
Regional Administrator (BSM1)
DRP Director (ATH)
DRS Director (DDC)
DRS Deputy Director (KMK)
Senior Resident Inspector (ELC1)
Resident Inspector (TBR2)
SRI, Callaway (MSP)
Branch Chief, DRP/B (WBJ)
Senior Project Engineer, DRP/B (RAK1)
Team Leader, DRP/TSS (RLN1)
RITS Coordinator (KEG)
J. Dixon-Herrity, OEDO RIV Coordinator (JLD)
ROPreports
WC Site Secretary (SLA2)
SISP Review Completed: __WBJ__ ADAMS: / Yes G No Initials: __WBJ____
/ Publicly Available G Non-Publicly Available G Sensitive / Non-Sensitive
R:REACTORS\_WC\2005\WC2005-04RP-ELC.wpd
RIV:SRI:DRP/B RI:DRP/B ASRI:DRP/B C:DRS/EB
FLBrush TBRhoades ELCrowe CJPaulk
E-WBJones E-WBJones T-WBJones /RA/
11/7/05 11/7/05 11/8/05 11/7/05
C:DRP/OB C:DRS/PS C:DRS/PEB C:DRP/PBB
ATGody MPShannon LJSmith WBJones
/RA/ /RA/ /RA/ /RA/
11/8/05 11/8/05 11/4/05 11/9/05
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 50-482
License: NPF-42
Report: 5000482/2005004
Licensee: Wolf Creek Nuclear Operating Corporation
Wolf Creek Generating Station
Location: 1550 Oxen Lane NE
Burlington, Kansas
Dates: June 27 through September 26, 2005
Inspectors: F. L. Brush, Senior Resident Inspector
E. L. Crowe, Acting Senior Resident Inspector
T. B. Rhoades, Resident Inspector
L. C. Carson II, Senior Health Physicist
J. L. Dixon, Resident Inspector, Arkansas Nuclear One
R. A. Kopriva, Senior Project Engineer
M. S. Peck, Senior Resident Inspector, Callaway
B. K. Tharakan, Health Physicist
Approved By: W. B. Jones, Chief, Project Branch B
Enclosure
SUMMARY OF FINDINGS
IR 500482/2005004; 6/27/05 - 9/26/05; Wolf Creek Generating Station; Operator Performance
During Nonroutine Evolutions and Events, Operability Evaluations, Access Control to
Radiologically Significant Areas, and Identification and Resolution of Problems
The report covers a 3-month period of inspection by resident inspectors and regional specialist
inspectors. The inspection identified three Green noncited violations and an apparent violation.
The significance of most findings is indicated by their color (Green, White, Yellow, or Red)
using Inspection Manual Chapter 0609, Significance Determination Process. Findings for
which the significance determination process does not apply may be Green or be assigned a
severity level after NRC management review. The NRCs program for overseeing the safe
operation of commercial nuclear power reactors is described in NUREG-1649, Reactor
Oversight Process, Revision 3, dated July 2000.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green. A self-revealing noncited violation of Technical Specification 5.4.1a, occurred
when station personnel failed to adequately evaluate a maintenance activity on safety-
related equipment for potential energy/fluid transfer paths as required by Station
Procedure AP 21D-002, "Evaluation For Potential Energy/Fluid Transfer Paths." On
June 28, 2005, planned motor-operated valve actuator work on an isolation valve in the
safety injection system lead to the unplanned transfer of water from the volume control
tank to the refueling water storage tank. This issue involved human performance
crosscutting aspects associated with station personnel not following a station procedure.
The failure to correctly perform a required step of a station procedure for evalauting
emergency core cooling system interfaces is a performance deficiency. This finding
was determined to be more than minor because it affected the mitigating systems
cornerstone objective of ensuring the availability, reliability, and capability of systems
that respond to initiating events to prevent undesirable consequences (i.e., core
damage). Using the Phase 1 worksheets in Manual Chapter 0609, "Significance
Determination Process," the finding was determined to have very low safety significance
because the finding did not represent a loss of a safety function or a train of safety
function and is not potentially risk significant due to external events. Wolf Creek
Nuclear Operating Corporation entered this finding into their corrective action program
as Performance Improvement Request 2005-2004 (Section R14).
- Green. The inspectors documented a self-revealing, noncited violation of 10 CFR
Part 50, Appendix B, Criterion XVI, because Wolf Creek Nuclear Operating Corporation
failed to assure corrective actions taken in response to a significant condition adverse to
quality preclude repetition of the condition. On May 5, 2005, auxiliary feedwater flow
Transmitter ALFT-0011 indicated flow without existing flow in the auxiliary feedwater
system due to the buildup of debris from a previous steam generator chemical cleaning.
Following the May 5, 2005, event, Wolf Creek Nuclear Operating Corporation flushed all
auxiliary feedwater flow transmitters and the level transmitters for the steam generators.
On July 11, 2005, another auxiliary feedwater flow Transmitter ALFT-0003 indicated flow
-2-
without existing flow in the auxiliary feedwater system. This transmitter was flushed and
the conditions found on May 5, 2005, existed in this transmitter. This issue involved
problem identification and resolution crosscutting aspects, in that, station personnel did
not properly evaluate a condition adverse to quality that resulted in an auxiliary
feedwater flow transmitter becoming inoperable.
The failure to take appropriate corrective measures to address a significant condition
adverse to quality is a performance deficiency. This finding was determined to be more
than minor because it affected the mitigating systems cornerstone objective of ensuring
the availability, reliability, and capability of the auxiliary feedwater system that responds
to initiating events to prevent undesirable consequences (i.e., core damage). Using the
Phase 1 worksheets in Manual Chapter 0609, Significance Determination Process, the
finding was determined to have very low safety significance because the finding did not
represent a loss of a safety function and is not potentially risk significant due to external
events. Wolf Creek Nuclear Operating Corporation entered this finding into their
corrective action program as PIR 2005-2149 (Section R15).
- TBD. A self-revealing noncited violation of a Technical Specification 5.4.1a occurred
when station personnel failed to follow Procedure AP 21E-001, Clearance Orders, and
operated a temporary component that had been established within a fire protection
suppression water system clearance boundary without instructions and authorization.
Specifically, personnel started a temporary fire pump which had been connected to the
stations fire protection suppression water system causing water to spray from an open
vent valve. The water spray wetted the control panel for the diesel driven fire pump
which resulted in the pump becoming inoperable for approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This issue
involved human performance crosscutting aspects associated with personnel not
following a station procedure.
The failure to follow station procedures is a performance deficiency. The finding was
determined to be more than minor because if affected the mitigating systems
cornerstone objective of ensuring the availability, reliability, and capability of systems
that respond to initiating events to prevent undesirable consequences. Using the
Phase 1 worksheets in Manual Chapter 0609, Significance Determination Process, the
finding was determined to degrade the fire protection system suppression and was
evaluated using Appendix F, Fire Protection Significance Determination Process. This
finding requires a Phase 3 analysis and is currently under evaluation. Wolf Creek
Nuclear Operating Corporation entered this finding into their corrective action program
as PIR 2005-2142 (Section 4OA2).
Cornerstone: Occupational Radiation Safety
- Green. The inspector identified a noncited violation of a Technical Specification 5.4.1a
which requires procedures for radiation protection and personnel monitoring.
Specifically, on September 22, 2003, Wolf Creek Nuclear Operating Corporation failed
to perform an exit whole body count for a radiation worker that had entered the
radiologically controlled area and terminated their employment with Wolf Creek Nuclear
Operating Corporation.
Enclosure
-3-
The failure to perform an exit whole body count was a performance deficiency. The
finding was determined to be more than minor because it was associated with the
Occupational Radiation Safety cornerstone attribute of Programs and Process and
affected the cornerstone objective to ensure the adequate protection of worker health
and safety from exposure to radiation and radioactive materials. Because the
occurrence involved conditions that were contrary to licensee procedures related to
measuring worker dose, this finding was processed through the Occupational Radiation
Safety Significance Determination Process. The finding was determined to be of very
low safety significance (Green) because it did not involve: (1) as low as is reasonably
achievable planning and work controls, (2) an overexposure, (3) a substantial potential
for an overexposure, or (4) an impaired ability to assess dose. The finding was entered
into Wolf Creek Nuclear Operating Corporation's corrective action program as
PIR 2005-1653 (Section 2OS1).
B. Licensee-Identified Violations
A violation of very low safety significance, which was identified by Wolf Creek Nuclear
Operating Corporation, has been reviewed by the inspectors. Corrective actions taken
or planned by Wolf Creek Nuclear Operating Corporation have been entered into Wolf
Creek Nuclear Operating Corporation's corrective action program. This violation and
corrective actions are listed in Section 4OA7 of this report.
Enclosure
REPORT DETAILS
Summary of Plant Status
The plant started the inspection period at 100 percent rated thermal power and remained at or
near this power level for the entire report period.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather (71111.01)
a. Inspection Scope
The inspectors completed a review of Wolf Creek Nuclear Operating
Corporation's (WCNOC) readiness of seasonal susceptibilities involving extreme high
temperatures. The inspectors: (1) reviewed plant procedures, the Updated Final Safety
Analysis Report, and Technical Specifications to ensure that operator actions defined in
adverse weather procedures maintained the readiness of essential systems, (2) walked
down portions of the systems listed below to ensure that adverse weather protection
features were sufficient to support operability including the ability to perform safe
shutdown functions, (3) evaluated operator staffing levels to ensure WCNOC would
maintain the readiness of essential systems required by plant procedures, and
(4) reviewed the corrective action program to determine if WCNOC identified and
corrected problems related to adverse weather conditions.
- July 15, 2005, WCNOC preparations for summer weather which included:
Steam heating for outdoor tanks, ventilation lineups for power block buildings,
and discussion of aspects of hot weather operations with licensee personnel.
The inspectors completed one sample.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment (71111.04)
a. Inspection Scope
The inspectors: (1) walked down portions of the three risk important systems listed
below and reviewed plant procedures and documents to verify that critical portions of the
selected systems were correctly aligned and (2) compared deficiencies identified during
the walk down to WCNOC's corrective action program to ensure problems were being
identified and corrected.
C July 15, 2005, Train B motor-driven auxiliary feedwater system
C August 4, 2005, Train B safety injection system
Enclosure
-2-
C September 15, 2005, component cooling water system
The inspectors completed three samples.
b. Findings
No findings of significance were identified.
1R05 Fire Protection (71111.05)
Quarterly Fire Area Walkdowns
a. Inspection Scope
The inspectors walked down the six plant areas listed below to assess the material
condition of active and passive fire protection features, their operational lineup, and their
operational effectiveness. The inspectors: (1) verified that transient combustibles and
hot work activities were controlled in accordance with plant procedures; (2) observed the
condition of fire detection devices to verify they remained functional; (3) observed fire
suppression systems to verify they remained functional; (4) verified that fire
extinguishers and hose stations were provided at their designated locations and that
they were in a satisfactory condition; (5) verified that passive fire protection features
(electrical raceway barriers, fire doors, fire dampers, steel fire proofing, penetration
seals, and oil collection systems) were in a satisfactory material condition; (6) verified
that adequate compensatory measures were established for degraded or inoperable fire
protection features; and (7) reviewed the corrective action program to determine if
WCNOC identified and corrected fire protection problems.
C July 5, 2005, circulating water screen house
C July 19, 2005, main steam enclosure
C August 4, 2005, residual heat removal Pump B room
C August 4, 2005, room containing safety injection Pump B, centrifugal charging
Pump B, and containment spray Pump B
C August 26, 2005, motor-driven auxiliary feedwater Pumps A and B rooms
C August 26, 2005, turbine-driven auxiliary feedwater pump room
The inspectors completed six samples.
b. Findings
No findings of significance were identified.
Enclosure
-3-
1R11 Licensed Operator Requalification (71111.11)
Resident Inspector Review
a. Inspection Scope
The inspectors observed testing and training of senior reactor operators and reactor
operators to identify deficiencies and discrepancies in the training, to assess operator
performance, and to assess the evaluator's critique of the scenario listed below:
C August 3, 2005, training scenario, LR5001005, Large Break LOCA,
Revision 10, which involved a large break loss of coolant accident including
recovery and shifting to cold leg recirculation.
The inspectors completed one sample.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
The inspectors reviewed the two maintenance activities listed below to: (1) verify the
appropriate handling of structure, system, and component (SSC) performance or
condition problems; (2) verify the appropriate handling of degraded SSC functional
performance; (3) evaluate the role of work practices and common cause problems; and
(4) evaluate the handling of SSC issues reviewed under the requirements of the
Maintenance Rule, 10 CFR Part 50, Appendix B, and Technical Specifications.
C August 12, 2005, residual heat removal system
C Septernber 16, 2005, essential service water system
The inspectors reviewed two samples.
b. Findings
No findings of significance were identified.
Enclosure
-4-
1R13 Maintenance Risk Assessments and Emergent Work Evaluation (71111.13)
Risk Assessment and Management of Risk
a. Inspection Scope
The inspectors reviewed the assessment activities listed below to verify:
(1) performance of risk assessments when required by 10 CFR 50.65 (a)(4) and
licensee procedures prior to changes in plant configuration for maintenance activities
and plant operations; (2) the accuracy, adequacy, and completeness of the information
considered in the risk assessment; (3) that WCNOC recognizes, and/or enters as
applicable, the appropriate licensee established risk category according to the risk
assessment results and licensee procedures; and (4) that WCNOC identified and
corrected problems related to maintenance risk assessments.
The inspectors reviewed operational risk assessments for planned maintenance and
actual, planned, and emergent work schedules for the following weeks:
C July 11, 2005
C August 29, 2005
C September 12, 2005
C September 19, 2005
The inspectors completed four samples.
b. Findings
No findings of significance were identified.
1R14 Operator Performance During Nonroutine Evolutions and Events (71111.14)
a. Inspection Scope
For the plant evolution and event listed below, the inspectors: (1) reviewed operator
logs, plant computer data, and/or strip charts for the below evolutions to evaluate
operator performance in coping with nonroutine events and transients, (2) verified that
the operators response was in accordance with the response required by plant
procedures and training, and (3) verified that WCNOC has identified and implemented
appropriate corrective actions associated with personnel performance problems that
occurred during the nonroutine evolutions sampled.
- June 28, 2005, inadvertent transfer of water from volume control tank (VCT) to
refueling water storage tank (RWST).
- September 20, 2005, unplanned entry into Technical Specification 3.0.3 due to
declaration of both trains of residual heat removal system containment sump
suction isolation Valves EJHV8811A and -8811B inoperable.
Enclosure
-5-
The inspectors completed two samples.
b. Findings
Introduction. The inspectors documented a self-revealing noncited violation of
Technical Specification 5.4.1a, which occurred when station personnel failed to
adequately evaluate a maintenance activity on safety-related equipment for a potential
energy/fluid transfer path as required by Station Procedure AP 21D-002, "Evaluation For
Potential Energy/Fluid Transfer Paths." Subsequently, maintenance on a motor-
operated isolation valve in the safety injection system lead to the unplanned transfer of
water from the VCT to the RWST.
Description. On June 28, 2005, WCNOC performed maintenance on the motor-
operated valve actuator for residual heat removal heat exchanger/chemical volume
control system to safety injection Pump A downstream isolation Valve EMHV8807B.
This maintenance involved the removal of the actuator from the valve which resulted in
partial opening of Valve EMHV8807B. This created an open pathway for the transfer of
water from the VCT to the RWST. Wolf Creek Nuclear Operating Corporation evaluated
the potential for water in the RWST to transfer to the VCT if VCT pressure was less than
25 psig. However, WCNOC failed to assess flow in the opposite direction. The
pressure in the VCT was sufficiently high to cause lowering of the VCT level due to
transfer of water to the RWST. Wolf Creek Nuclear Operating Corporation entered
Procedure OFN BB-007, "RCS Leakage High," to determine the location of the leak and
Technical Specification 3.4.13, "RCS Leakage," due to the appearance of a greater than
1 gallon per minute unidentified leak. The leak was isolated when the valve actuator
was re-installed and the valve closed. The leak existed for approximately 24 minutes.
Analysis
The failure to properly follow station procedures is a performance deficiency. This
finding was determined to be more than minor because it affected the mitigating
systems cornerstone objective of ensuring the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences (i.e.,
core damage). Using the Phase 1 worksheets in Manual Chapter 0609, "Significance
Determination Process," the finding was determined to have very low safety significance
because the finding did not represent a loss of a safety function and is not potentially
risk significant due to external events. This issue involved human performance
crosscutting aspects associated with station personnel failing to adequately implement
procedural requirements to evaluate potential fluid transfer paths.
Enforcement
Technical Specification 5.4.1a requires procedures be implemented in accordance with
Regulatory Guide 1.33, Revision 2, Appendix A. Section 9 to Regulatory Guide 1.33
requires maintenance that can affect the performance of safety-related equipment
should be properly preplanned and performed in accordance with written procedures,
Enclosure
-6-
documented instructions, or drawings appropriate to the circumstances. Contrary to the
above, on June 28, 2005, WCNOC personnel performed an inadequate evaluation of
potential energy/fluid transfer paths for planned maintenance on Valve EMHV8807B
which resulted in an inadvertent transfer of water from the VCT to the RWST. A similar
event occurred in 1995. Because the failure to prevent transfer of water was of very low
safety significance and was entered into the corrective action program as PIR 2005-
2004, this violation is being treated as a noncited violation, consistent with Section VI.A
of the NRC Enforcement Policy: NCV 05000482/0500401, failure to adequately
implement station procedures results in transfer of water from VCT to RWST.
1R15 Operability Evaluations (71111.15)
a. Inspection Scope
For the three operability evaluations listed below, the inspectors: (1) reviewed plant
status documents such as operator shift logs, emergent work documentation, deferred
modifications, and standing orders to determine if an operability evaluation was
warranted for degraded components; (2) referred to the Updated Safety Analysis
Report and design basis documents to review the technical adequacy of licensee
operability evaluations; (3) evaluated compensatory measures associated with
operability evaluations; (4) determined degraded component impact on any Technical
Specifications; (5) used the significance determination process to evaluate the risk
significance of degraded or inoperable equipment; and (6) verified that WCNOC has
identified and implemented appropriate corrective actions associated with degraded
components.
- PIR 2005-1477 July 20, 2005, residual heat removal Pumps A and B
containment recirculation valves
PIR 2005-2149 July 13, 2005, auxiliary feedwater flow
Transmitters ALFT0003, -0004, -0009, and -0011
- PIR 2005-2478 August 29, 2005, grid disturbances resulting in low
voltage alarms
The inspectors completed three samples.
b. Findings
Introduction. The inspectors documented a Green self-revealing, noncited violation of
10 CFR Part 50, Appendix B, Criterion XVI, because WCNOC failed to prevent the
recurrence of a plant event which resulted in the additional failures of auxiliary
feedwater flow transmitters following steam generator chemical cleaning.
Description. On April 10, 2005, WCNOC injected advanced scale conditioning agent
(ASCA) into steam Generator B. Steam Generator C was injected with ASCA on
Enclosure
-7-
April 11, 2005. ASCA is a chemical formulation that aids to soften, dislodge, and
partially dissolved sludge and scale deposits. Immediately following the April 11, 2005,
injection, WCNOC found steam Generator C auxiliary feedwater flow
Transmitter ALFT0011 indicating 22,000 lbm/hr without any flow in the auxiliary
feedwater system. Approximately during the same period, a second auxiliary feedwater
flow transmitter on steam Generator C (ALFT0004) indicated approximately
40,000 lbm/hr without auxiliary feedwater flow. Wolf Creek Nuclear Operating
Corporation flushed both transmitters and a dark black liquid with suspended solids
issued from the flush lines. No other auxiliary feedwater flow transmitters were flushed
at this time. These transmitters are utilized in the Wolf Creek emergency operating
procedures to verify proper auxiliary feedwater flow during accident conditions. On
May 5, 2005, WCNOC discovered auxiliary feedwater flow Transmitter ALFT0011
indicating 22,000 lbm/hr without corresponding auxiliary feedwater flow. This
transmitter was flushed on May 6, 2005, and the dark black liquid with suspended
solids issued from the flush lines. On May 8, 2005, WCNOC flushed auxiliary
feedwater flow Transmitters ALFT0003 and -0009 which provide auxiliary feedwater
flow indication for steam Generator B and discovered the dark black liquid with
suspended solids in these transmitters. Wolf Creek Nuclear Operating Corporation
also flushed low point drains in the auxiliary feedwater system and took samples of the
dark black liquid which were sent to an offsite vendor for analysis.
On July 11, 2005, control room operators identified that an auxiliary feedwater flow
Transmitter ALFT0003 was indicating a flow rate of approximately 15,000 lbm/hr flow
with no auxiliary feedwater flow. Wolf Creek Nuclear Operating Corporation removed
and cleaned the flow transmitter on July 13, 2005, and discovered a black substance
plugging the sensing line and at several instrument line fittings. Wolf Creek Nuclear
Operating Corporation stated this substance was similar to that identified during the
previous erroneous auxiliary feedwater flow transmitter indications. Wolf Creek
Nuclear Operating Corporation again flushed the other auxiliary feedwater flow
transmitters for steam Generators B and C and did not observe any foreign substance.
Wolf Creek Nuclear Operating Corporation also implemented a monthly flushing of all
the auxiliary feedwater flow transmitters. Wolf Creek Nuclear Operating Corporation
received the results of the vendors chemical analysis the second week of September
2005 which indicated the presence of the chemical ASCA.
Analysis
The failure to take appropriate corrective measures to address a significant condition
adverse to quality is a performance deficiency. This finding was determined to be more
than minor because it affected the mitigating systems cornerstone objective of ensuring
the availability, reliability, and capability of the auxiliary feedwater system that is used to
respond to initiating events to prevent undesirable consequences (i.e., core damage).
Using the Phase 1 worksheets in Manual Chapter 0609, Significance Determination
Process, the finding was determined to have very low safety significance because the
finding did not represent a loss of a safety function and is not potentially risk significant
due to external events. This issue involved problem identification and resolution
crosscutting aspects in that station personnel did not properly evaluate and implement
Enclosure
-8-
adequate corrective actions to prevent the accumulation of sludge in the auxiliary
feedwater flow transmitters.
Enforcement
In part, 10 CFR 50, Appendix B, Criterion XVI, states that for significant conditions
adverse to quality, measures shall be established to assure that corrective actions
taken preclude repetition. Contrary to the above, WCNOC personnel failed to
adequately evaluate and implement corrective actions to prevent the accumulation of
sludge in the auxiliary feedwater flow transmitters following the initial identification of
the concern in May 2005. Because the failure to adequately prevent the buildup of
sludge in the flow transmitters was determined to be of very low safety significance and
was entered into the corrective action program (PIR 2005-2149), this violation is being
treated as a noncited violation consistent with Section VI.A of the NRC Enforcement
Policy: NCV 05000482/200500402, inadequate corrective actions fail to prevent
subsequent failure of auxiliary feedwater flow transmitters.
1R16 Operator Workarounds (71111.16)
a. Inspection Scope
Cumulative Review of the Effects of Operator Workarounds
On September 8, 2005, the inspectors reviewed the cumulative effects of operator
workarounds to determine: (1) the reliability, availability, and potential for misoperation
of a system; (2) if multiple mitigating systems could be affected; (3) the ability of
operators to respond in a correct and timely manner to plant transients and accidents;
and (4) if WCNOC has identified and implemented appropriate corrective actions
associated with operator workarounds.
The inspectors completed one sample.
b. Findings
No findings of significance were identified.
1R19 Post Maintenance Testing (71111.19)
a. Inspection Scope
The inspectors selected three post maintenance test activities of risk significant
systems or components. For each item, the inspectors: (1) reviewed the applicable
licensing basis and/or design-basis documents to determine the safety functions,
(2) evaluated the safety functions that may have been affected by the maintenance
activity, and (3) reviewed the test procedure to ensure it adequately tested the safety
function that may have been affected. The inspectors either witnessed or reviewed test
data to verify that acceptance criteria were met, plant impacts were evaluated, test
Enclosure
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equipment was calibrated, procedures were followed, jumpers were properly controlled,
the test data results were complete and accurate, the test equipment was removed, the
system was properly realigned, and deficiencies during testing were documented. The
inspectors also reviewed the corrective action program to determine if WCNOC
identified and corrected problems related to post maintenance testing.
C June 28, 2005, safety injection system Valve EMHV-8807B
C August 5, 2005, auxiliary feedwater Pump A room cooler replacement
C September 19, 2005, turbine-driven auxiliary feedwater pump
The inspectors completed three samples.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
For the four surveillances listed below, the inspectors reviewed the Updated Final
Safety Analysis Report, procedure requirements, and Technical Specifications to
ensure that the four surveillance activities demonstrated that the SSCs tested were
capable of performing their intended safety functions. The inspectors either witnessed
or reviewed test data to verify that the following significant surveillance test attributes
were adequate: (1) preconditioning; (2) evaluation of testing impact on the plant;
(3) acceptance criteria; (4) test equipment; (5) procedures; (6) jumper/lifted lead
controls; (7) test data; (8) testing frequency and method demonstrated Technical
Specification operability; (9) test equipment removal; (10) restoration of plant systems;
(11) fulfillment of ASME Code requirements; (12) updating of performance indicator
data; (13) engineering evaluations, root causes, and bases for returning tested SSCs
not meeting the test acceptance criteria were correct; (14) reference setting data; and
(15) annunciators and alarms setpoints. The inspectors also verified that WCNOC
identified and implemented any needed corrective actions associated with the
surveillance testing.
Revision 29
- July 20, 2005, STS KJ-013B, Hot Restart of Emergency D/G NE02, Revision 4
Revision 5
- September 8, 2005, STS KJ-015A, Manual/Auto Fast Start, Sync and Loading
of EDG NE10, Revision 19
Enclosure
-10-
The inspectors completed four samples.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation (71114.06)
a. Inspection Scope
The drill listed below contributed to drill/exercise performance and emergency response
organization performance indicators. The inspectors: (1) observed the training
evolution to identify any weaknesses and deficiencies in classification, notification, and
protective action requirements development activities; (2) compared the identified
weaknesses and deficiencies against WCNOC identified findings to determine whether
WCNOC is properly identifying failures; and (3) determined whether licensee
performance is in accordance with the guidance of the Nuclear Energy Institute 99-02
documents acceptance criteria.
- June 29, 2005, the inspectors observed and reviewed emergency drill activities
in the simulator control room and the emergency offsite facility. The drill
scenario involved a loss of control room annunciators with a concurrent loss of
the plant computer, a generator trip with a failure of the control rods to
automatically trip, an offsite release due to a gas decay tank relief valve failure,
and a loss of normal power to the vital alternating current busses. The
inspectors attended the control room critique, reviewed drill related documents,
and discussed the drill activities with various licensee personnel.
b. Findings
No findings of significance were identified.
2. RADIATION SAFETY
Cornerstone: Occupational Radiation Safety (OS)
2OS1 Access Control to Radiologically Significant Areas (71121.01)
a. Inspection Scope
This area was inspected to assess WCNOCs performance in implementing physical
and administrative controls for airborne radioactivity areas, radiation areas, high
radiation areas, and worker adherence to these controls. The inspector used the
requirements in 10 CFR Part 20, Technical Specifications, and WCNOCs procedures
required by Technical Specifications as criteria for determining compliance. The
Enclosure
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inspector interviewed the stations ombudsman, licensing and radiation protection
personnel, and reviewed the following items:
- Corrective action documents related to the access control program
- Special report related to the access control program
The inspector completed 2 of the required 21 samples.
b. Findings
1. Introduction: The inspector identified a Green noncited violation of Technical
Specification 5.4.1a procedure. Specifically, on September 22, 2003, WCNOC failed to
perform an exit whole body count on a radiation worker who had terminated their
employment with WCNOC.
Description: On May 3, 2005, the NRC requested that WCNOC respond to a concern
about whether an exit whole body count was performed as required by procedure.
Wolf Creek Nuclear Operating Corporation conducted an investigation and concluded
that on September 22, 2003, WCNOC failed to perform an exit whole body count on a
radiation worker during their last day at work, and that no subsequent whole body count
had been performed. An entry was made into the radiologically controlled area since
the last whole body count for the individual. The investigation also concluded that
WCNOC did not generate a required form when an exit whole body count was not
performed.
Analysis: The failure to perform an exit whole body count is a performance deficiency.
This finding is determined to be more than minor because it is associated with the
Occupational Radiation Safety Cornerstone Attribute of Programs and Process, and it
affected the cornerstone objective to ensure the adequate protection of worker health
and safety from exposure to radiation and radioactive materials. This finding was
processed through the occupational radiation safety significant determination process
because the occurrence involved conditions that were contrary to licensee procedures
related to measuring worker dose. The finding was determined to be of very low safety
significance (Green) because it did not involve: (1) as low as is reasonably
achievable (ALARA) planning and work controls, (2) an overexposure, (3) a substantial
potential for an overexposure, or (4) an impaired ability to assess dose.
Enforcement: Technical Specification 5.4.1a requires procedures be implemented in
accordance with Regulatory Guide 1.33, Revision 2, Appendix A. Section 7e, to
Regulatory Guide 1.33 requires radiation protection procedures for personnel
monitoring. Station Procedure RPP 03-405, step 9.5.2, requires that a whole body
count be performed. In addition, step 9.5.4 of the procedure states, in part, that if a
whole body count is not performed, and an entry was made into the radiologically
controlled area since the last whole body count, generate a request for exit whole body
count. It was determined that this request for exit whole body count could not be
located and that an exit whole body count was not performed. Because this violation
was of very low safety significance and was entered into WCNOCs corrective action
Enclosure
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program as PIR 2005-1653, it is being treated as a noncited violation, consistent with
Section VI.A of the NRC Enforcement Policy: NCV 005000482/200500403, failure to
perform an exit whole body count.
2OS2 ALARA Planning and Controls (71121.02)
a. Inspection Scope
The inspectors assessed licensee performance with respect to maintaining individual
and collective radiation exposures ALARA. The inspectors used the requirements in
10 CFR Part 20 and WCNOCs procedures required by Technical Specifications as
criteria for determining compliance. The inspectors interviewed licensee personnel and
reviewed:
- Five outage and online maintenance work activities scheduled during the
inspection period and associated work activity exposure estimates which were
likely to result in the highest personnel collective exposures
- Use of engineering controls to achieve dose reductions and dose reduction
benefits afforded by shielding
- Exposure tracking system
- Workers use of the low dose waiting areas
- Exposures of individuals from selected work groups
- Records detailing the historical trends and current status of tracked plant source
terms and contingency plans for expected changes in the source term due to
changes in plant fuel performance issues or changes in plant primary chemistry
- Source-term control strategy or justifications for not pursuing such exposure
reduction initiatives
- Specific sources identified by WCNOC for exposure reduction actions and
priorities established for these actions and results achieved against since the
last refueling cycle
- Declared pregnant workers during the current assessment period, monitoring
controls, and exposure results
- Resolution through the corrective action process of problems identified through
postjob reviews and postoutage ALARA report critiques
- Corrective action documents related to the ALARA program and followup
activities such as initial problem identification, characterization, and tracking
Enclosure
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- Self-assessments, audits, and special reports related to the ALARA program
since the last inspection
- Effectiveness of self-assessment activities with respect to identifying and
addressing repetitive deficiencies or significant individual deficiencies
The inspector completed 6 of the required 15 samples and 7 of the optional samples.
b. Findings
No findings of significance were identified.
4. OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
Resident Inspector Annual Sample Review
a. Inspection Scope
The inspectors evaluated the effectiveness of WCNOCs corrective action program as
applied to corrective action document PIR 2005-2142. This document was initiated to
address the conditions and events that led to the inoperability of both site fire protection
pumps. Attributes considered during this review included the following:
- Completeness, accuracy, and timeliness of problem identification
- Operability and reportability evaluation
- Extent of condition evaluation
- Apparent cause evaluation
- Prioritization
- Corrective action effectiveness
The inspectors completed one sample.
b. Findings
Failure to Follow the Clearance Order Procedure
Introduction: An apparent violation (AV) of Technical Specification 5.4.1a occurred
when station personnel failed to follow Procedure AP 21E-001, Clearance Orders,
and manipulated a component inside a fire protection piping clearance boundary
without instructions and authorization. The starting of a temporary fire pump resulted in
water spraying on the controller of the operable diesel-driven fire pump through an
open vent valve, which rendered the pump inoperable.
Enclosure
-14-
Description: On June 30, 2005, the motor of the electric fire pump experienced a short
in its winding which led to a fire at the motor. The plant took the appropriate
compensatory measures and started parallel paths to restore the fire suppression water
system within the allotted 14 days. One path involved a temporary modification to the
fire protection system that installed a temporary motor-driven fire pump, which was
accomplished on July 11, 2005. The temporary fire pump was tested on July 12, 2005,
to verify it would provide the required flow of water suppression; however, the pump
failed this test.
Station fire protection personnel requested a clearance order to isolate the temporary
fire pump from the fire protection piping but failed to make station operations personnel
aware of the desire to run the temporary fire pump following repairs. Once repairs to
the pump were completed, the vendor under the direction of station fire protection
personnel started the pump believing they had authorization to operate the temporary
fire pump. This resulted in water issuing from an open vent valve which sprayed the
controller of the diesel-driven fire pump. Station fire protection personnel discovered
the wet controller and notified the control room. Control room personnel declared the
diesel-driven fire pump inoperable. The diesel-driven fire pump was returned to service
in approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
The inspectors reviewed Procedure AP-10-103, Fire Protection Impairment Control,
Revision 19, which identified the compensatory measures for the loss of fire
suppression water systems. With the motor driven and the diesel driven fire pump
inoperable (approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) the impairment control procedure required that a
backup fire pump be provided within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In this case, both the motor driven and
the diesel driven fire pumps were restored within approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. This issue
involved human performance crosscutting aspects associated with station personnel
not following a station procedure.
Analysis: The failure to follow station procedures is a performance deficiency. The
finding was determined to be more than minor because it affected the mitigating
systems cornerstone objective of ensuring the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences. Using
the Phase 1 worksheets in Manual Chapter 0609, Significance Determination
Process, the finding was determined to degrade the fire protection system suppression
and was evaluated using Appendix F, Fire Protection Significance Determination
Process. This finding requires a Phase 3 analysis and is currently under evaluation.
Wolf Creek Nuclear Operating Corporation entered this finding into their corrective
action program as PIR 2005-2142
Enforcement: Technical Specification 5.4.1a requires procedures be implemented in
accordance with Regulatory Guide 1.33, Revision 2, Appendix A. Regulatory
Guide 1.33, Appendix A, Section 9, requires procedures for the performance of station
maintenance. Contrary to the above, on July 13, 2005, station personnel operated
components inside an established fire protection piping clearance boundary without
work instructions or control room authorization as required by Station
Procedure AP 21E-001, Clearance Orders, Section 6.6.8. This resulted in an
Enclosure
-15-
adjacent diesel-driven fire pump becoming inoperable. Pending determination of the
final safety significance of this issue, this violation is being treated as an AV consistent
with Section VI.A of the NRC Enforcement Policy: AV 05000482/0500404,
manipulation of plant component without proper authorization results in inoperable fire
protection pumps.
Corrective Action Effectiveness
There were no findings identified that were associated with the corrective actions for
this event. However, the inspectors made the following observations from their review
of the apparent cause evaluation and the associated corrective actions: The apparent
cause evaluation states that some fire protection personnel are unfamiliar with the
clearance order program because, for them, clearance orders are infrequently
performed evolutions. Additionally, the evaluation states that some groups mistakenly
believed it was acceptable to work on vendor equipment inside clearance order
boundaries without proper authorization or an approved procedure. These evaluation
results suggest a clearance order program knowledge deficiency within the fire
protection group. Yet, the corrective action for these contributing causes was
counseling only the one individual involved with this event.
.2 Cross-References to Problem Identification & Resolution Findings Documented
Elsewhere
Section 1R15 documents a condition where station personnel did not properly evaluate
a condition adverse to quality regarding debris in the auxiliary feedwater flow
transmitters.
.3 Access Control to Radiologically Significant Areas and ALARA Inspections
Section 2OS1 evaluated the effectiveness of WCNOC's problem identification and
resolution processes regarding access controls to radiologically significant areas and
radiation worker practices. The inspectors reviewed corrective action documents for
root cause/apparent cause analysis against WCNOCs PI&R process. No findings of
significance were identified.
Section 2OS2 evaluated the effectiveness of WCNOC's PI&R processes regarding
exposure tracking, higher than planned exposure levels, and radiation worker practices.
The inspector reviewed the corrective action documents listed in the attachment
against WCNOCs PI&R program requirements. No findings of significance were
identified.
Enclosure
-16-
4OA4 Crosscutting Aspects of Findings
Cross-Reference to Human Performance Findings Documented Elsewhere
Section 1R14 describes a condition associated with station personnel failing to follow
procedure requirements to adequately complete an evaluation of energy/fluid transfer
paths.
Section 2OS1 describes a condition associated with station personnel not following a
procedure for the performance of an exit whole body count.
Section 4OA2 describes a condition associated with station personnel not following a
clearance order procedure that rendered the remaining fire pump inoperable.
4OA5 Other
1. Temporary Instruction (TI) 2515/161 - Transportation of Reactor Control Rod Drives in
Type A Packages
a. Inspection Scope
This area was inspected to verify that WCNOCs radioactive material transportation
program complies with specific requirements of 10 CFR Parts 20 and 71, and
Department of Transportation regulations contained in 49 CFR Part 173. The inspector
interviewed licensee personnel and determined that WCNOC had undergone
refueling/defueling activities between January 1, 2002, and present, but it had not
shipped irradiated control rod drives in Department of Transportation Specification 7A,
Type A packages.
b. Findings and Observations
No findings of significance were identified.
4OA6 Meetings, including Exit
On May 12, 2005, the inspector discussed the TI 2515/161 inspection findings with
Ms. P. Bedgood, Superintendent, Chemistry/Radiation Protection. The inspectors
asked WCNOC whether any materials examined during the inspections should be
considered proprietary. No proprietary information was identified.
On July 1, 2005, the inspector discussed the access control to radiologically significant
areas inspection findings with Ms. P. Bedgood, Superintendent, Chemistry/Radiation
Protection, and other members of your staff who acknowledged the findings. The
inspector verified that no proprietary information was provided during the inspection.
On July 1, 2005, the inspector presented the ALARA planning and controls inspection
results to Mr. M. Sunseri, Vice President Oversight, and other members of his staff who
Enclosure
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acknowledged the findings. The inspector confirmed that proprietary information was
not reviewed during the inspection.
On July 14, 2005, the inspector discussed the inspection findings with Ms. P. Bedgood,
Superintendent, Chemistry/Radiation Protection, and Mr. B. Muilenburg, Licensing
Engineer, Licensing, who acknowledged the findings. The inspector verified that no
proprietary information was provided during the inspection.
On August 17, 2005, the inspector presented the results of TI 2515/163, Operational
Readiness of Offsite Power, Follow-up, with Mr. K. J. Moles, Manager, Regulatory
Affairs, and other members of the staff, who acknowledged the findings. The inspector
verified that no proprietary information was provided during the inspection.
On September 28, 2005, the inspectors presented the resident inspection results to Mr.
S. E. Hedges and other members of licensee management after the conclusion of the
inspection. The inspector verified that no proprietary information was provided during
the inspection.
4OA7 Licensee-Identified Violations
The following finding is of very low significance, was identified by WCNOC and is a
violation of NRC requirements which meet the criteria of Section VI of the NRC
Enforcement Policy, NUREG-1600, for being dispositioned as a noncited violation.
In part, 10 CFR 50.9(a) requires that information provided to the Commission by a
licensee shall be complete and accurate in all material respects. A Severity Level IV
violation of 10 CFR 50.9(a) was identified because from January 1, 1994, through
December 31, 2003, more than 850 radiation dose reports were submitted to the
Commission with inaccurate radiation dose information. The finding is greater than
minor because of the number of records involved and the duration of the
noncompliance. The finding is not suitable for significant determination process
evaluation, but has been reviewed by NRC management and is determined to be a
Green finding of very low safety significance. This finding is documented in WCNOCs
corrective action program as PIR 2004-2700.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Enclosure
-1-
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
R. A. Muench, President and Chief Executive Officer
M. Sunseri, Vice President Oversight
K. A. Harris, Director, Performance Improvement and Learning
S. E. Hedges, Vice President Operations and Plant Manager
K. Scherich, Director Engineering
T. East, Manager, Emergency Planning
P. Bedgood, Superintendent, Chemistry/Radiation Protection
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
050000482/200500404 AV Manipulation of plant component without proper
authorization results in inoperable fire protection pumps
(Section 4OA2)
Opened and Closed
050000482/200500401 NCV Failure to follow station procedures results in transfer of
water from VCT to RWST (Section 1R14)
050000482/200500402 NCV Inadequate corrective actions fail to prevent subsequent
failure of auxiliary feedwater flow transmitters
(Section 1R15)
050000482/200500403 NCV Failure to perform an exit whole body count
(Section 2OS1)
LIST OF DOCUMENTS REVIEWED
In addition to the documents referred to in the inspection report, the following documents were
selected and reviewed by the inspectors to accomplish the objectives and scope of the
inspection and to support any findings:
A-1 Attachment
-2-
Section 1R01: Adverse Weather
STN GP-001, Plant Winterization, Revision 34
Section 1R04: Equipment Alignment
CKL AL-120, Auxiliary Feedwater Normal Lineup, Revision 33A
CKL EG-120, Component Cooling Water System Valve, Switch and Breaker Lineup,
Revision 36
CKL EM-120, Safety Injection System Lineup Checklists, Revision 22A
Station Drawings:
M-12AL01, Revision 6
M-12EG01, Revision 9
M-12EG02, Revision 4
M-12EG03, Revision 3
M-12EM01, Revision 16
M-12EP01, Revision 5
Section 1R12: Maintenance Effectiveness
Residual heat removal system health report
Maintenance rule performance evaluations
Functional failure evaluations - residual heat removal and essential service water systems
Final scope evaluations for the residual heat removal system
Maintenance rule expert panel meeting minutes for residual heat removal system
PIRs 2005-1175, -1336, and -1477
Section 1R13: Maintenance Risk Assessments and Emergent Work Evaluation
Procedure AP 22C-003, Operational Risk Assessment Program, Revision 9.
Section 1R14: Operator Performance During Nonroutine Evolutions and Events
AP 21D-002, Evaluation for Potential Energy/Fluid Transfer Paths, Revision 8
OFN BB-007, RCS Leakage High, Revision 12
PIR 19952808
Section 1R15: Operability Evaluations
OE AL-05-001
PIRs 2005-1514 and -2247
Section 1R19: Postmaintenance Testing
A-2 Attachment
-3-
Proto HX model verification for room Cooler SGF02A
STN PE-036, Safety-Related Room Cooler Heat Transfer Verification and Performance
Trending, Revision 10
STN PE-037A, ESW Train A Heat Exchanger Flow and DP Trending, Revision 8
STS AL -103, TDAFW Pump Inservice Pump Test, Revision 38
STS PE-007, Periodic Verification of Motor-Operated Valves, Revision 2
Work Orders: 04-259616-009, 04-260057-000, -001, 05-273227-000, 05-273363-001, and
05-273773-002
Section 1R22: Surveillance Testing
STS-IC-615A, Slave Relay Test K615 Train a Safety Injection, Revision 18
Section 1EP6: Drill Evaluation
Emergency notification forms
Emergency response log
Sequence of events logs
Section 2OS1: Access to Radiologically Significant Areas
PIRs 2005-1652, -1653, and -1662
Special Report
Licensee response to Allegation No. RIV-2005-A-0046, dated June 2, 2005
Section 2OS2: ALARA Planning and Controls
Procedures
AP 25A-001, Radiation Protection Manual, Revision 11
AP 25B-100, Radiation Worker Guidelines, Revision 23
RPP 02-215, Posting of Radiological Controlled Areas, Revision 21
RPP 02-210, Radiation Survey Methods, Revision 25
RPP 02-105, Radiation Work Permit, Revision 22
RPP-03-405, Exposure History Files, Revision 13
ALARA Work Packages and Radiation Work Permits
050070, 051000, 051102, 053220, 053230, 054006, 054007, 054420, 055000, and 055031
A-3 Attachment
-4-
PIRs 2004-0734, -1044, -1120, -1254, -1341, -1420, -1597, -2700, 2005-0013, -0129, -0863, -
0943, -1171, -1324, and -1992
Self-Assessments/Audits
K-615, radiation protection
K-621, radiation protection program
OB-05-1062, RWP and ALARA review for steam generator bowl repair
Miscellaneous Documents
Wolf Creek ALARA long-range exposure/source-term reduction Plan 2002-2006
Strategic Primary Water Chemistry Plan, Revision 2
Personnel contamination event records
Dosimetry records
A-4 Attachment