ML102560258
| ML102560258 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/13/2010 |
| From: | Vegel T NRC Region 4 |
| To: | Matthew Sunseri Wolf Creek |
| References | |
| EA-10-160 IR-10-006 | |
| Download: ML102560258 (46) | |
See also: IR 05000482/2010006
Text
NU C LE AR RE G UL AT O RY C O M M I S S I O N
REGION IV
6 12 EAST LAMAR BL VD , S U I T E 4 0 0
A R L I N G T O N , T E X A S 7 6 0 1 1 -41 25
September 13, 2010
Matthew W. Sunseri, President and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, KS 66839
SUBJECT: WOLF CREEK GENERATING STATION - NRC PROBLEM IDENTIFICATION
AND RESOLUTION INSPECTION REPORT 05000482/2010006 AND NOTICE OF
VIOLATION
Dear Mr. Sunseri:
On July 30, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
your Wolf Creek Generating Station. The enclosed report documents the inspection findings
discussed with you and members of your staff during an exit briefing on July 30, 2010.
The inspection examined activities conducted under your license as they relate to identification
and resolution of problems, safety and compliance with the Commissions rules and regulations
and with the conditions of your operating license. The inspectors reviewed selected procedures
and records, observed activities, and interviewed personnel. The inspectors also interviewed a
representative sample of personnel regarding the condition of your safety-conscious work
environment.
The NRC noted that a number of plant deficiencies were not being effectively resolved in your
corrective action program. For example, the results of metallurgical examinations performed to
assess piping corrosion and an analysis of water hammer issues affecting the essential service
water system were performed outside the corrective action process and not used to update a
currently open operability evaluation or a completed root cause evaluation. Another example
involves the failure to effectively track and prioritize for corrective actions degraded or non-
conforming conditions. The NRC noted a number of examples that involved deficiencies not
being corrected during the first available opportunity, without adequate justification for the delay.
In addition, the team identified that a large number of control room instrumentation and control
deficiencies currently exist. The NRC identified that some of these deficiencies have not been
corrected for a number of years, the deficiencies impact on plant operations were not well
understood by all plant operators, the deficiencies were not effectively being tracked in the
control room deficiency log, and control room operators were not consistently reviewing these
deficiencies during shift turnover. The NRC determined that additional actions are warranted to
ensure that these control room deficiencies are promptly addressed before they have the
potential to impact plant operations.
Wolf Creek Nuclear -2-
Operating Corporation
This report documents six noncited violations, one cited violation, and one finding, all of very low
safety significance (Green). Because of the very low safety significance of the violations and
because they were entered into your corrective action program, the NRC is treating these
violations as noncited violations consistent with Section VI.A.1 of the NRC Enforcement Policy.
If you contest these noncited violations, you should provide a response within 30 days of the
date of this inspection report, with the basis for your denial, to the Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the
Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd.,
Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, United States
Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector
at the Wolf Creek Generating Station.
An NRC-identified violation is cited in the enclosed Notice of Violation (Enclosure 1). The
violation involved the failure to perform an adequate cause evaluation and to take corrective
actions to preclude repetition for a significant condition adverse to quality. Although determined
to be of very low safety significance (Green), this violation is being cited in the Notice of
Violation because not all of the criteria specified in Section VI.A.1 of the NRC Enforcement
Policy were satisfied (EA-10-160). Specifically, the Wolf Creek Generating Station failed to
restore compliance within a reasonable time after a previously-identified was identified in NRC
Inspection Report 05000482/2009007-03. You are required to respond to this letter and should
follow the instructions specified in the enclosed Notice when preparing your response. The
NRC will use your response, in part, to determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
If you disagree with the crosscutting aspect assigned to any finding in this report, you should
provide a response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at the
Wolf Creek Generating Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web-site at
www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). To the extent
possible, your response should not include any personal privacy, proprietary, or safeguards
information so that it can be made available to the Public without redaction.
Sincerely,
/RA/
Tony Vegel, Deputy Director
Division of Reactor Projects
Docket No. 50-482
License No. NPF-42
Wolf Creek Nuclear -3-
Operating Corporation
Enclosures:
1. Notice of Violation
2. NRC Inspection Report 05000482/2010006
w/Attachment: Supplemental Information
cc w/Enclosures:
Site Vice President
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, KS 66839
Jay Silberg, Esq.
Pillsbury Winthrop Shaw Pittman LLP
2300 N Street, NW
Washington, DC 20037
Supervisor Licensing
Wolf Creek Nuclear Operating Corporation
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 66612-1590
Attorney General
120 S.W. 10th Avenue, 2nd Floor
Topeka, KS 66612-1597
Chairman
Coffey County Courthouse
110 South 6th Street
Burlington, KS 66839
Chief, Radiation and Asbestos
Control Section
Bureau of Air and Radiation
Kansas Department of Health and
Environment
1000 SW Jackson, Suite 310
Topeka, KS 66612-1366
Wolf Creek Nuclear -4-
Operating Corporation
Chief, Technological Hazards
Branch
FEMA, Region VII
9221 Ward Parkway
Suite 300
Kansas City, MO 64114-3372
Wolf Creek Nuclear -5-
Operating Corporation
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Chuck.Casto@nrc.gov)
DRP Acting Director (Tony.Vegel@nrc.gov)
DRP Acting Deputy Director (Troy.Pruett@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Acting Deputy Director(Jeff.Clark@nrc.gov)
Senior Resident Inspector (Chris.Long@nrc.gov)
Resident Inspector(Charles.Peabody@nrc.gov)
WC Administrative Assistant (Shirley.Allen@nrc.gov)
Branch Chief, DRP/B (Geoffrey.Miller@nrc.gov)
Senior Project Engineer, DRP/B (Rick.Deese@nrc.gov)
Project Engineer, DRP/B (Greg.Tutak@nrc.gov)
Project Engineer, DRP/B (Nestor.Makris@nrc.gov)
Reactor Inspector, DRP/B (Christine.Denissen@nrc.gov)
R4Enforcement (Ray.Keller@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
PublicAffairsOfficer(Lara.Uselding@nrc.gov)
Project Manager (Balwant.Singal@nrc.gov)
Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)
RITS Coordinator(Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
OEMail Resource
ROPreports
OEDO RIV Coordinator (Margie.Kotzalas@nrc.gov)
Team Members on Concurrence
R:\_REACTORS\_WC\2010\2010006-RPT-GMV.docx ADAMS ML
SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials gmv
Publicly Avail Yes No Sensitive Yes No Sens. Type Initials gmv
RIV:TL:DRS/TSB SRI:DRP/PBD PE:DRP/PBE PE:DRP/PBB RI:DRP/PBB
MVasquez GWarnick JMelfi GTutak CPeabody
/ RA/ /RA/ per T w/gmv /RA/ by E /RA/ by E /RA/ by E
9/1/2010 9/2/2010 9/2/2010 9/2/2010 9/2/2010
C:DRP/PBB RIV:C:DRS/TSB SES:ACES D/DRP
GMiller MHay RKellar AVegel
/RA/ /RA/ /RA/ by E /RA/
9/8/2010 9/12/10 9/9/2010 9/13/2010
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
NOTICE OF VIOLATION
Wolf Creek Nuclear Operating Company Docket No: 50-482
Wolf Creek Generating Station License No: NPF-42
During an NRC inspection, conducted from July 12 through 30, 2010, 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 that
in the case of significant conditions adverse to quality, measures shall assure
that the cause of the condition is determined and corrective action taken to
preclude repetition.
Contrary to the above, from December 4, 2009, to July 30, 2010, the licensee
failed to assure that the cause of a significant condition adverse to quality was
determined and corrective actions were taken to preclude repetition. Specifically,
after a loss of offsite power event on August 19, 2009, the licensee failed to
perform an adequate evaluation to determine the cause of loss of offsite power
induced water hammers and internal corrosion in the essential service water
system, and did not take corrective actions to preclude repetition of additional
water hammer events and system leaks. The licensee performed an apparent
cause evaluation when a root cause evaluation was required.
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, and a copy to the NRC Resident Inspector Wolf Creek
Generating Station, within 30 days of the date of the letter transmitting this Notice of Violation
(Notice). This reply should be clearly marked as a "Reply to Notice of Violation EA-10-160," 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 to avoid further violations, 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.
Wolf Creek Nuclear -2-
Operating Corporation
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/pdr.html or 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).
Dated this 13th day of September 2010.
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000482
License: NPF-42
Report: 05000482/2001006
Licensee: Wolf Creek Nuclear Operating Corporation
Facility: Wolf Creek Generating Station
Location: 1550 Oxen Lane SE
Burlington, Kansas
Dates: July 12 through 30, 2010
Team Leader: M. Vasquez, Senior Reactor Inspector, Technical Support Branch, DRS
Inspectors: G. Warnick Senior Resident Inspector
C. Peabody, Resident Inspector
J. Melfi, Project Engineer
G. Tutak, Project Engineer
Approved By: Michael C. Hay, Chief
Technical Support Branch
Division of Reactor Safety
-1- Enclosure
SUMMARY OF FINDINGS
IR05000482/2010006; February 16, 2008, through July 30, 2010: Wolf Creek Generating
Station, Biennial Baseline Inspection of the Identification and Resolution of Problems
The report covers a 2-week period of onsite inspection by a senior reactor inspector, a senior
resident inspector, a resident inspector, and two project engineers. The findings from this
inspection include five Green NRC-identified noncited violations, one Green self-revealing
violation, one Green finding, and one Green cited violation. The significance of most findings
is indicated by their color (greater than Green, or Green, White, Yellow, Red), and was
determined using Inspection Manual Chapter 0609, Significance Determination Process.
The crosscutting aspect was determined using Inspection Manual Chapter 0310,
Components Within the Cross Cutting Areas. The findings for which the significance
determination process does not apply may be Green or be assigned a severity level after
NRC management review. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG 1649, Reactor Oversight Process,
Revision 4, dated December 2006.
Identification and Resolution of Problems
The team concluded that the corrective action program at Wolf Creek Generating Station was
generally performing in a satisfactory manner to ensure safe plant operations. However, as
previously discussed in the past four NRC assessment letters, Wolf Creeks ability to thoroughly
evaluate and prioritize problems such that the resolutions effectively address the causes and
extent of conditions is of concern. Wolf Creek Generating Stations efforts to reverse the trend
of substantive crosscutting issues in problem identification and resolution areas have not shown
to be effective.
The team identified a number of issues that the licensees staff had previous opportunities to
identify. The team also identified instances in which the licensee takes actions outside of the
corrective action program in order to evaluate or correct issues of concern. The inspectors
noted several examples where degraded or nonconforming conditions were not corrected in a
timely manner and no evaluation had been performed that justified delayed correction of the
issue. In addition, the team identified examples where the licensee has taken ineffective
corrective actions, including one example of a cited violation based on the licensees failure to
take corrective actions to restore compliance within a reasonable time after a violation had been
identified.
The team determined that the licensee adequately evaluated industry operating experience for
relevance to the facility, and entered applicable items in the corrective action program. And,
based on focus group interviews, the team concluded that the licensee had a strong safety
conscious work environment. Workers stated they felt they could raise safety concerns without
fear of retaliation.
-2- Enclosure
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Action, for the licensees failure to
promptly correct degraded or nonconforming conditions in that the conditions
were not corrected at the first available opportunity or appropriately justify a
longer completion schedule. Some examples of affected degraded or
nonconforming conditions included degraded atmospheric relief valve
discharge line silencer, essential service water system water hammer events
and internal corrosion, and 23 items on the Operability Evaluation Database
that had not been corrected prior to the start of the last refuel outage. As
corrective actions for this issue, the licensee implemented interim procedural
guidance and initiated Condition Report 27071 to evaluate the adequacy of
tracking methods used for degraded, nonconforming, or unanalyzed
conditions. In addition, the licensee initiated a review of work requests,
condition reports, and other items for degraded, nonconforming, or
unanalyzed conditions and is assessing the justification for delayed
implementation of these corrective actions.
This issue was more than minor because it affected the equipment
performance attribute of the Mitigating Systems Cornerstone objective to
ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Using Inspection
Manual Chapter 0609, the issue is determined to have very low safety
significance because the finding is not a design or qualification issue
confirmed not to result in a loss of operability or functionality; did not
represent an actual loss of safety function of the system or train; did not result
in the loss of one or more trains of nontechnical specification equipment; and
did not screen as potentially risk significant due to a seismic, flooding, or
severe weather initiating event. The inspectors determined that the finding
has a crosscutting aspect in the area of human performance associated with
the component of resources because the licensee failed to provide adequate
procedures to assure timely resolution of degraded or nonconforming
conditions H.2(c) (Section 4OA2.5a).
Green. The inspectors identified a noncited violation of Technical
Specification 5.4.1.a for failure to properly implement Procedure AP 14A-003,
Scaffold Construction and Use, Revision 17, when scaffolding was erected
near operable safety-related equipment. On July 14, 15, and 28, the
inspectors identified a total of four instances where the minimum separation
distance between scaffolding and safety-related components was less than
the minimum allowed by procedure and an approved engineering evaluation
to justify the deviation was not performed. The licensee entered the issue
into its corrective action program as Condition Reports 26752 and 27010,
corrected each scaffolding deficiency, and performed comprehensive
-3- Enclosure
walkdowns of all scaffolding around safety-related structures, systems, and
components.
The deficiency was more than minor because if left uncorrected, it would
have the potential to lead to a more significant safety concern. The finding
was associated with the Mitigating Systems Cornerstone. Using Inspection
Manual Chapter 0609, the issue is determined to have very low safety
significance because the finding is not a design or qualification issue
confirmed not to result in a loss of operability or functionality; did not
represent an actual loss of safety function of the system or train; did not result
in the loss of one or more trains of nontechnical specification equipment; and
did not screen as potentially risk significant due to a seismic, flooding, or
severe weather initiating event. The inspectors determined the finding has a
crosscutting aspect in the area of problem identification and resolution
associated with corrective action program because the licensee did not take
appropriate corrective actions to address previously identified scaffolding
construction issues in a timely manner P.1(d) (Section 4OA2.5b).
Green. The inspectors identified a finding for the failure to follow
Procedure AI 22A-001, Operator Work Arounds/Burdens/Control Room
Deficiencies, Revision 8, to adequately identify, document, and track control
room deficiencies associated with instruments and controls to ensure proper
prioritization and timely corrective actions. Specifically, inspectors observed
that the licensee had approximately 52 WR (work request) buttons on the
control boards indicating that work requests had been initiated to correct
problems on instruments and controls. However, not all deficiencies were
logged, and some of the deficiencies had existed for years without correction
or justification. The licensee initiated Condition Report 27034 to document
and evaluate this concern.
The deficiency was more than minor because if left uncorrected, it would
have the potential to lead to a more significant safety concern, in that, the
deficient condition could cause an operator to take an inappropriate action
based on expected plant response or conversely cause an operator not to
take action when action is required. The finding is associated with the
Mitigating Systems Cornerstone. The senior reactor analyst determined that
this finding was not appropriate to be evaluated using the significance
determination process since this finding was associated with numerous
equipment issues and associated human performance aspects that might
impact equipment operation. Using Inspection Manual Chapter 0609,
Appendix M, Significance Determination Process Using Qualitative Criteria,
the finding is determined to have very low safety significance because there
was no adverse impact to plant equipment. The inspectors determined that
the cause of the finding has a crosscutting aspect in the area of problem
identification and resolution associated with the component of corrective
action program because the licensee did not identify issues completely,
accurately, and in a timely manner commensurate with their safety
significance P.1(a) (Section 4OA2.5c).
-4- Enclosure
Green. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures and Drawings, for the
failure to implement Procedure AP 26C-004, Technical Specification
Operability, Revision 20, to adequately evaluate the operability of a
degraded essential service water system. Specifically, operations and
engineering personnel failed to adequately evaluate the operability of the
essential service water system when relevant new information was identified
that challenged a previously performed operability determination and which
challenged the reasonable expectation for operability. Condition Report
27288 was initiated to evaluate the failure to perform adequate operability
determinations.
The issue was more than minor because if left uncorrected, it would have the
potential to lead to a more significant safety concern. The finding is
associated with the Mitigating Systems Cornerstone. Using Inspection
Manual Chapter 0609, the issue is determined to have very low safety
significance because the finding is not a design or qualification issue
confirmed not to result in a loss of operability or functionality; did not
represent an actual loss of safety function of the system or train; did not result
in the loss of one or more trains of nontechnical specification equipment; and
did not screen as potentially risk significant due to a seismic, flooding, or
severe weather initiating event. The inspectors determined that the cause of
the finding has a crosscutting aspect in the area of human performance
associated with resources because the licensee failed to provide complete,
accurate, and up-to-date procedures for performing operability evaluations
H.2(c) (Section 4OA2.5d).
Green. The inspectors identified a cited violation 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Action, because the licensee failed to
perform an adequate evaluation to determine the cause of loss of offsite
power induced water hammers and internal corrosion in the essential service
water system and did not take corrective actions to preclude repetition of
additional water hammer events and system leaks. Specifically, the licensee
performed an apparent cause evaluation instead of a root cause evaluation
as required, and the licensees evaluation did not consider metallurgical
evaluations that were performed outside the corrective action program. The
inspectors found that the licensee had not corrected a previous
NCV 05000482/2009007-03, Failure to Correctly Screen ESW Piping Leaks
for Significance, which resulted in the licensee failing to perform a root cause
evaluation. Because the licensee failed to restore compliance within a
reasonable time after NCV 05000482/2009007-03 was identified, this
violation is being cited in a Notice of Violation in accordance with
Section VI.A.1 of the NRCs Enforcement Policy. The licensees corrective
action to this cited violation was to initiate Condition Reports 27212, 26466,
and 27075, to evaluate and correct the identified conditions, to start a root
cause evaluation and, separately, to evaluate the licensees failure to
properly respond to NCV 05000482/2009007-03.
-5- Enclosure
The issue was more than minor because it is associated with the equipment
performance attribute of the Mitigating Systems Cornerstone and affects the
associated cornerstone objective to ensure the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable
consequences, and is therefore a finding. Using Inspection Manual
Chapter 0609, the issue is determined to have very low safety significance
because the finding is not a design or qualification issue confirmed not to
result in a loss of operability or functionality; did not represent an actual loss
of safety function of the system or train; did not result in the loss of one or
more trains of nontechnical specification equipment; and did not screen as
potentially risk significant due to a seismic, flooding, or severe weather
initiating event. The inspectors determined that the cause of the finding has a
crosscutting aspect in the area of problem identification and resolution
associated with the component of corrective action program because the
licensee failed to thoroughly evaluate problems such that the resolutions
address causes and extent of conditions P.1(c) (Section 4OA2.5e).
Green. The team identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the
failure to follow the requirements of Procedure AP 26C-004, Technical
Specification Operability, Revision 20. Specifically, Wolf Creek Generating
Station failed to confirm if a deficiency existed with the ability of the ultimate
heat sink to perform its safety function after delaying the 5-year scheduled
dredging of the channel. The licensee initiated Condition Report 27080 and
performed an operability determination to evaluate the deficiency.
The issue was more than minor because it was associated with the
equipment performance attribute of the Mitigating Systems Cornerstone, and
it affected the cornerstone objective to ensure the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable
consequences. Using Inspection Manual Chapter 0609, the issue is
determined to have very low safety significance because the finding is not a
design or qualification issue confirmed not to result in a loss of operability or
functionality; did not represent an actual loss of safety function of the system
or train; did not result in the loss of one or more trains of nontechnical
specification equipment; and did not screen as potentially risk significant due
to a seismic, flooding, or severe weather initiating event. This finding has a
crosscutting aspect in the area of problem identification and resolution
associated with the corrective action program component because licensee
personnel failed to identify a potential deficiency in the ultimate heat sink in a
timely manner P.1(a) (Section 4OA2.5f).
Green. The inspectors reviewed a self-revealing noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for failure to identify a
degraded equipment condition in December 2006. As a result, the
emergency diesel generator system experienced a failure on October 22,
2009, which caused the plant to make a notice of unusual event emergency
declaration. Licensee personnel missed an opportunity to identify the
-6- Enclosure
condition because they did not thoroughly evaluate a surveillance failure and
post-mortem testing data available in December 2006.
The finding is more than minor because it was associated with the equipment
performance attribute of the Mitigating Systems Cornerstone, and it affected
the cornerstone objective to ensure the availability, reliability, and capability
of systems that respond to initiating events to prevent undesirable
consequences. Using Inspection Manual Chapter 0609, the issue is
determined to have very low safety significance because the finding is not a
design or qualification issue confirmed not to result in a loss of operability or
functionality; did not represent an actual loss of safety function of the system
or train; did not result in the loss of one or more trains of nontechnical
specification equipment; and did not screen as potentially risk significant due
to a seismic, flooding, or severe weather initiating event. A crosscutting
aspect was identified in the problem identification and resolution in that the
licensee did not thoroughly evaluate problems such that the resolution
addressed causes P.1(c) (Section 4OA2.5g).
Green. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion III, Design Control, for the failure to translate criteria
from the atmospheric relief valve accumulator leakage calculation into
proceduralized leakage criteria. Specifically, engineering personnel did not
translate the calculated design basis leakage criteria and the required
minimum pressure to start the test into the procedure. The licensee entered
this in to the corrective action program as Condition Report 26771, and the
licensee was developing plans to revise the leakage criteria in the procedure.
This issue was more than minor because it affected the design control
attribute of the Mitigating Systems Cornerstone and affected the objective to
ensure the reliability and capability of systems that respond to initiating
events to prevent undesirable consequences. Using Inspection Manual
Chapter 0609, the issue is determined to have very low safety significance
because the finding is not a design or qualification issue confirmed not to
result in a loss of operability or functionality; did not represent an actual loss
of safety function of the system or train; did not result in the loss of one or
more trains of nontechnical specification equipment; and did not screen as
potentially risk significant due to a seismic, flooding, or severe weather
initiating event. This finding has a crosscutting aspect in the area of problem
identification and resolution associated with the corrective action program
component because licensee personnel failed to take appropriate corrective
actions to previously identified problems P.1(d) (Section 4OA2.5h).
-7- Enclosure
REPORT DETAILS
4. OTHER ACTIVITIES
4OA2 Problem Identification and Resolution (71152)
The inspectors based the following conclusions on the sample of corrective action
documents that were initiated in the assessment period, which ranged from February 16,
2008, to the end of the onsite portion of this inspection on July 30, 2010.
.1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed approximately 275 condition reports, including associated root
cause, apparent cause, and direct cause evaluations that were completed between
February 16, 2008, and July 30, 2010, to determine if problems were being properly
identified, characterized, and entered into the corrective action program for evaluation and
resolution. The inspectors also reviewed system health reports, operability
determinations, self-assessments, trending reports, metrics, and various other documents
related to the corrective action program. The inspectors reviewed work requests and
condition reports to assess the reporting threshold and prioritization processes. The
inspectors review included verifying that the licensee considered the full extent of cause
and extent of condition for problems, as well as how the licensee assessed generic
implications and previous occurrences. The inspectors assessed the timeliness and
effectiveness of corrective actions, completed or planned, and looked for additional
examples of similar problems.
The inspectors also reviewed a sample of corrective action documents that addressed
past NRC-identified violations to ensure that the corrective actions addressed the issues
as described in the inspection reports. The inspectors reviewed a sample of corrective
actions closed to other corrective action documents to verify that corrective actions were
appropriate and timely.
The inspectors considered risk insights to focus the sample selection and plant tours on
risk significant systems and components. Based on this review, the samples reviewed by
the inspectors focused on, but were not limited to, these systems. The inspectors also
expanded this review to include 5 years of evaluations involving portions of the component
cooling water system and essential service water system interfaces, and the nitrogen
accumulators for the steam generator atmospheric relief valves to determine whether
problems were being effectively addressed. The inspectors conducted a walkdown of
these systems to assess whether problems were identified and entered into the corrective
action program.
-8- Enclosure
b. Assessments
Assessment - Effectiveness of Problem Identification
In general, the inspectors found that the licensee has been identifying problems and
entering them into their corrective action program at appropriately low thresholds.
However, the team identified issues that the licensee should have identified prior to the
NRC. Examples of ineffective identification of issues include the following:
NRC inspectors identified deficiencies in scaffolding that were erected near
operable safety-related equipment (Section 4OA2.5b).
Wolf Creek Generating Station failed to identify completely and accurately
deficiencies with instruments and controls associated with 52 WR (work request)
buttons on the control boards indicating that work requests had been initiated to
correct problems. All deficiencies were not logged, and some buttons were near
more than one control item such that it was not clear which buttons went with which
control (Section 4OA2.5c).
The licensee failed to identify a potential operability concern associated with
delaying the 5-year preventive maintenance (dredging) of the ultimate heat sink
(Section 4OA2.5f).
Wolf Creek Generating Station has not given new system engineers training to
identify issues that could impact their ability to identify deficiencies with safety-
related systems. This includes items such as clearance between scaffolding and
safety-related equipment and requirements for chocking carts near safety-related
equipment that would assist system engineers in identifying deficiencies that could
impact safety-related equipment. In addition, Wolf Creek Generating Station did not
require system engineers to attend classroom training on the system assigned to
them. This observation was more important for system engineers who had been
employed at the plant less than 3 years.
Assessment - Effectiveness of Prioritization and Evaluation of Issues
Overall, the team concluded that Wolf Creek Generating Stations staff is correctly
prioritizing and evaluating issues. The inspectors found that Wolf Creek Generating
Station had improved the cause evaluations by training individuals on various levels of
cause evaluations, by establishing teams of trained individuals to perform root cause
evaluations instead of one individual, providing a management sponsor for root cause
evaluation team, and providing greater senior leadership oversight over the cause
evaluations. However, the inspectors also found numerous instances where Wolf Creek
Generating Station failed to adequately evaluate the potential deficiencies with delays in
correcting degraded or nonconforming conditions. While most initial operability
determinations were appropriate, the inspectors identified several examples where poor
evaluations were performed or the basis for operability used engineering judgment that
was not supported by appropriate documentation. The following are examples of
ineffective or inadequate evaluation of issues:
-9- Enclosure
The team identified numerous examples of degraded or nonconforming conditions
with equipment problems that were not fixed prior to restart from the last outage (on
November 21, 2009) with no evaluation performed to justify the delay for fixing the
problem (Section 4OA2.5a).
Licensee personnel failed to adequately evaluate the operability of the essential
service water system when relevant new information was identified that challenged a
previously performed operability determination (Section 4OA2.5d).
The inspectors identified that the licensee failed to perform an adequate evaluation
to determine the cause of loss of offsite power induced water hammers and internal
corrosion in the essential service water system. Specifically, the licensee performed
an apparent cause evaluation instead of a root cause evaluation, and the licensees
evaluation did not consider metallurgical evaluations that were performed outside the
corrective action program (Section 4OA2.5e).
Wolf Creek Generating Station did not evaluate the cause for an emergency diesel
generator speed switch which could not be properly calibrated in December 2006.
Instead, the licensee replaced the speed switch and power supply without
determining that the cause was actually a degraded capacitor in the power supply.
As a result, the emergency diesel generator failed on October 22, 2009, from a
degraded capacitor in the power supply causing the plant to declare a notice of
unusual event emergency declaration (Section 4OA2.5g).
While performing an immediate operability evaluation of an emergency diesel
generator on May 20, 2010, (discussed above), the inspectors noted that testing and
analytical bases for establishing the acceptance criteria for the power supply noise
filter degradation was performed informally and not under the proper purviews of the
corrective action, quality assurance, or other applicable licensee programs.
Furthermore the test results and analysis conclusions were not properly documented
under such program or in any other engineering process document.
The inspectors observed that the licensee conducted activities outside of the
corrective action program in order to address problems related to the essential water
system water hammer events and internal corrosion. For example, the licensee
performed metallurgical analyses of piping corrosion and an analysis of water
hammer issues, outside of the corrective action program. As a result, the
conclusions of the evaluations were not evaluated through an updated operability
determination nor in an updated cause evaluation (Sections 4OA2.5d and 4OA2.5e).
Assessment - Effectiveness of Corrective Action Program
The inspectors concluded that actions to correct conditions adverse to quality were
generally effective. However, the team identified some notable examples where the
licensee had not implemented effective corrective actions or addressed extent of
condition. Some examples included:
- 10 - Enclosure
After the inspectors identified deficiencies with the minimum separation distance
between scaffolding and safety-related equipment, the licensee performed a
walkdown of all impacted scaffolding. After the licensees review, the inspectors
identified another example of the same deficiency. Two weeks later, the inspectors
identified two more examples of the same deficiency, which was reflective of
ineffective corrective actions.
After a previous NRC inspection identified a noncited violation (NCV) involving the
licensees failure to perform a root cause evaluation to determine the cause of the
loss of offsite power induced water hammers and internal corrosion in the essential
service water system, the licensees corrective action addressed the screening
criteria for the condition and failed to perform an adequate evaluation. The licensee
failed to restore compliance to NCV 05000482/2009007-003, Failure to Correctly
Screen ESW Piping Leaks for Significance, and, as a result, the team is issuing a
cited violation for this failure (4OA2.5e).
The licensee failed to take appropriate corrective actions to previously identified
deficiencies involving the failure to translate into procedures appropriate design basis
criteria for the nitrogen accumulators for the atmospheric relief valves. As a result,
the inspectors identified an NCV involving additional failures (Section 4OA2.5h).
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors examined the licensee's program for reviewing industry operating
experience, including reviewing the governing procedure and self-assessments. The
team reviewed a sample of condition reports examining operating experience documents
that had been issued during the assessment period to assess whether the licensee had
appropriately evaluated the notification for relevance to the facility. The inspectors also
examined whether the licensee had entered those items into their corrective action
program and assigned actions to address the issues. The inspectors reviewed a sample
of root cause evaluations and significant condition reports to verify if the licensee had
appropriately included industry operating experience.
b. Assessment
Overall, the inspectors determined that the licensee had appropriately evaluated industry
operating experience for relevance to the facility, and had entered applicable items in the
corrective action program. Both internal and external operating experience was being
incorporated into lessons learned for training and pre-job briefs.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of licensee self-assessments and audits to assess
whether the licensee was regularly identifying performance trends and effectively
- 11 - Enclosure
addressing them. The inspectors also reviewed audit reports to assess the
effectiveness of assessments in specific areas. The specific self-assessment
documents and audits reviewed are listed in the attachment.
b. Assessment
The inspectors concluded that the licensee had an effective self-assessment process.
Licensee management was involved in developing the topics and objectives of self-
assessments. Attention was given to assigning inspectors members with the proper
skills and experience to do an effective self-assessment and to include people from
outside organizations. Audits were self-critical and identified deficiencies in various
programs such as the corrective action program and several root cause evaluations.
.4 Assessment of Safety-Conscious Work Environment
a. Inspection Scope
The inspection team conducted four focus group sessions consisting of approximately
10 individuals randomly chosen. Focus groups were conducted with individuals from
operations, maintenance, planners, and system engineers. These sessions were
designed to elicit a qualitative assessment of the degree to which the participants
believed Wolf Creek Generating Station management had established and maintained a
safety conscious work environment and were based upon the NRCs definition of a
safety conscious work environment:
An environment in which employees feel free to raise safety concerns,
both to their management and to the NRC, without fear of retaliation
and where such concerns are promptly reviewed, given the proper
priority based on their potential safety significance, and appropriately
resolved with timely feedback to employees.
Focus group participants were also asked questions in order for the team to make a
qualitative assessment of Wolf Creek Generating Stations safety culture as defined by
the crosscutting aspects described in NRCs Manual Chapter 0310. The team also
reviewed the results of the licensees 2008 and 2010 Nuclear Safety Culture
Assessment results. In particular, the inspectors reviewed licensee actions related to
issues to reverse the trend of a substantive crosscutting issue in the area of problem
identification and resolution involving Wolf Creek Generating Station personnels ability
to thoroughly evaluate and prioritize problems such that the resolutions effectively
address the causes and extent of conditions. The NRC has identified four consecutive
assessment cycles with this substantive crosscutting issue.
- 12 - Enclosure
comfortable raising concerns in each of the avenues available to them including raising
concerns with the NRC. Workers who had been at the site many years knew the Wolf
Creek Generating Station Ombudsman because the Ombudsman is a long time
employee. Newer employees were also aware of the Ombudsman.
Wolf Creek Generating Stations 2010 Nuclear Safety Culture Assessments identified
several issues which were entered into the licensees corrective action program. Some
of the findings dealt with the substantive crosscutting issue involving Wolf Creek
Generating Station personnels ability to thoroughly evaluate and prioritize problems
such that the resolutions effectively address the causes and extent of conditions. For
example, Condition Report 24196 reviewed the finding that some station personnel
believe root cause analyses are not effective in identifying the fundamental causes of
events. The licensees evaluation of this finding noted the substantial improvements that
had been made to the stations performance in conducting root cause evaluations which
occurred in 2009. These improvements included training for evaluators, dedicating a
team of trained individuals instead of a single individual to perform these evaluations,
assigning a manager to each root cause evaluation, and additional senior management
oversight over the evaluations. The licensee has seen 100 percent corrective action
review board approval of root causes since the beginning of 2009. The condition report
stated that the results of these improvements were not widely communicated to all
employees. In addition, the condition report noted that communications of the root
cause evaluations (the causes and the corrective actions) were not communicated to
station personnel. As a result, the corrective action was to develop corporate
communication strategies. The condition report was closed on June 15, 2010, after
procedure changes were made to improve station communication of root cause
evaluations and corrective actions. Based on this, the team concluded that Wolf Creek
Generating Station management believed its workers perceptions were in error related
to the effectiveness of the cause evaluations.
The team noted that on January 23, 2010, the licensee initiated Condition Report 23032
which was a root cause evaluation dealing with the significant human and corrective
action performance gaps. The condition report also noted that Wolf Creek Generating
Station has had four consecutive assessment cycles of the substantive crosscutting
issue in the area of problem identification and resolution involving Wolf Creek
Generating Station personnels ability to thoroughly evaluate and prioritize problems
such that the resolutions effectively address the causes and extent of conditions. The
condition report also noted that Wolf Creek Generating Station is on the threshold of
exceeding more than three crosscutting aspects in other human performance and
problem identification and resolution themes. The licensees corrective actions
associated with Condition Report 23032 were intended to reverse the trend of
substantive crosscutting issues.
- 13 - Enclosure
In May 2010, Wolf Creek Generating Station performed a self-assessment which
concluded that several root cause evaluations, including the root cause evaluation
associated with Condition Report 23032, had deficiencies with the causes or the
corrective actions. Therefore, the licensee undertook an effort to re-perform the root
cause evaluations. As of the close of this inspection, the licensee had not completed the
root cause evaluation and, as such, the team could not review the licensees plans to
address the substantive crosscutting issue. The team also noted that the deficiencies
found in these root cause evaluations could reinforce workers perceptions that cause
evaluations were not effective in identifying the fundamental causes of events.
.5 Specific Issues Identified During This Inspection
a. Failure to Resolve Degraded Conditions in a Timely Manner
Introduction. The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B,
Criterion XVI, Corrective Action, for the licensees failure to assure that conditions
adverse to quality were corrected in a time frame commensurate with the safety
significance of the condition. Specifically, the licensee failed to resolve degraded or
nonconforming conditions at the first available opportunity or appropriately justify a
longer completion schedule.
Description. During the inspection, numerous adverse conditions were identified
associated with safety-related structures, systems, or components and that were initially
identified prior to restart from Refueling Outage 17 on November 21, 2009. Examples of
these degraded or nonconforming conditions included degraded atmospheric relief valve
discharge line silencer, essential service water system water hammers and internal
corrosion, vibration associated with essential service water system Valves EFV58 and
EFV90, fisher butterfly valves, and essential service water system pump room
penetration seals. The inspectors also observed that the Operability Evaluation
Database listed 23 items that were evaluated as operable by a prompt operability
determination prior to the start of the last refueling outage. Further, the inspectors
identified that the licensee had no formal method to track and correct degraded or
nonconforming conditions that were only reviewed by an immediate operability
determination.
Regulatory Information Summary 2005-20, associated with Inspection Manual,
Part 9900: Technical Guidance, Operability Determinations and Functionality
Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to
Quality or Safety, dated April 16, 2008, describes the appropriate time frame for
correcting degraded or nonconforming conditions as the first available opportunity (i.e.,
prior to restart from the next outage). If corrective actions cannot be implemented at the
first available opportunity, then the licensee should appropriately justify a longer
completion schedule. For the degraded or nonconforming conditions described above,
the inspectors concluded that the licensee had not implemented a timely schedule for
completing corrective actions for structures, systems, and components, to correct the
conditions adverse to quality prior to restart after Refueling Outage 17 on November 21,
2009, or appropriately justify a longer completion schedule.
- 14 - Enclosure
On December 17, 2009, Condition Report 22501 was initiated to document issues
associated with Violation 05000482/2009005-11. One of the issues communicated to
the licensee by the NRC senior resident inspector was the lack of timely corrective
actions for degraded condition associated with the violation. Further, the inspector
explained that the timeframe in which corrective actions should be implemented for
degraded or nonconforming conditions was described in Regulatory Information
Summary 2005-20. The licensees evaluation identified that there was not adequate
procedural guidance to assure that degraded or nonconforming conditions were resolved
at the first available opportunity or appropriately justify a longer completion schedule.
The licensee identified corrective actions for interim guidance, until additional procedure
guidance could be developed. Also, a review was in-progress to review for degraded,
nonconforming, or unanalyzed conditions to ensure that any items that have been
delayed or not completed have proper justification for delayed implementation of
corrective actions based on the risk. The licensee initiated Condition Report 27071 to
further evaluate the adequacy of tracking methods used for degraded, nonconforming, or
Analysis. The inspectors determined that the failure to take timely corrective actions for
conditions adverse to quality was a performance deficiency. The deficiency was more
than minor because it affected the equipment performance attribute of the Mitigating
Systems Cornerstone objective to ensure the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences. Using
Inspection Manual Chapter 0609, the issue is determined to have very low safety
significance because the finding is not a design or qualification issue confirmed not to
result in a loss of operability or functionality; did not represent an actual loss of safety
function of the system or train; did not result in the loss of one or more trains of
nontechnical specification equipment; and did not screen as potentially risk significant
due to a seismic, flooding, or severe weather initiating event. The inspectors determined
that the cause of the finding has a crosscutting aspect in the area of human performance
associated with the component of resources because the licensee failed to provide
adequate procedures to assure timely resolution of degraded or nonconforming
conditions H.2(c).
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,
requires, in part, that measures shall be established to assure that conditions adverse to
quality are promptly identified and corrected. Contrary to the above, prior to
November 21, 2009, the licensee failed to assure that conditions adverse to quality were
corrected in a time frame commensurate with the safety significance of the condition.
Specifically, the licensee failed to resolve degraded or nonconforming conditions at the
first available opportunity, which was prior to restart after Refueling Outage 17 on
November 21, 2009, or appropriately justify a longer completion schedule. Because this
finding is of very low safety significance and has been entered into the licensees
corrective action program as Condition Reports 22501 and 27071, this violation is being
treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy:
NCV 05000482/2010006-01, Failure to Resolve Degraded Conditions in a Timely
Manner.
- 15 - Enclosure
b. Scaffolding Installation Inadequacy
Introduction. The inspectors identified a Green NCV of Technical Specification 5.4.1.a
for failure to properly implement Procedure AP 14A-003, Scaffold Construction and
Use, Revision 17, when scaffolding was erected near operable safety-related
equipment. The inspectors identified four instances where the minimum separation
distance between scaffolding and safety-related components was less than the minimum
allowed by procedure and an approved engineering evaluation to justify the deviation
was not performed.
Description. On July 14, 2010, during a walkdown of the component cooling water
system with the system engineer, the inspectors identified scaffolding erected less than
1 inch from safety-related piping. The inspectors reviewed Procedure AP 14A-003,
which included installation and use guidelines for seismically qualified scaffolding, and
observed that the criteria included a 2 inch minimum clearance requirement between
scaffolding and sensitive safety-related or special scope equipment and/or components.
Further, this minimum clearance could be reduced to 1 inch between scaffolding and
piping with diameter equal or greater than 3 inches. When the criteria for seismically
qualified scaffolding could not be met, an engineering evaluation was required. The
inspectors reviewed Scaffolding Request 10-S0109, documented on
Form APF 14A-003-01, and observed that an engineering evaluation and post-
installation inspections had not been completed. The inspectors concluded that the
scaffolding observed on July 14 did not meet the clearance criteria of
Procedure AP 14A-003 and did not have an engineering evaluation. The system
engineer initiated Condition Report 26752 to document the inspectors observation. The
scaffolding was modified to meet the requirements of Procedure AP 14A-003. The
extent of condition associated with the condition report noted that the condition could
exist on other scaffolding near safety-related equipment. Consequently, on July 14,
2010, the licensee performed a walkdown of all scaffolding erected around safety-related
equipment to verify compliance with the requirements of Procedure AP 14A-003.
On July 15, 2010, during a walk down of the essential service water system with the
system engineer, the inspectors identified another instance where scaffolding was
erected less than 1 inch from safety-related piping with diameter greater than 3 inches.
The condition observed by the inspectors was added to Condition Report 26752. The
inspectors questioned why this additional scaffolding problem was not identified during
the extent of condition review in response to the inspectors July 14 observation.
Maintenance personnel stated that the control side was not inspected as part of the
extent of condition walk down, so this scaffolding was not verified. Based on the
inspectors additional observations, the licensee performed a more extensive walkdown
on July 16 which identified two additional installed scaffolding that may not have the
minimum clearances required by Procedure AP 14A-003. These two additional
scaffolding issues were documented in Condition Report 26752. All scaffolding was
modified to meet the requirements of Procedure AP 14A-003.
- 16 - Enclosure
On July 28, 2010, during a walkdown of the essential service water system pump house
with the system engineer, the inspectors identified two instances where scaffold to
instrument tubing clearance was less than the 2-inch minimum clearance requirement of
Procedure AP 14A-003, and no engineering evaluations had been performed for the
conditions. The system engineer initiated Condition Report 27010 to document the
inspectors observation. The scaffolding was modified to meet the requirements of
A previous NCV (NCV 05000482/2009005-12) was identified when component cooling
water Train B was in contact with a seismically unqualified scaffold while component
cooling water was required to be operable. One of the causes identified was associated
with failing to properly fill out Form APF 14A-003-01. This indicates the licensee has
been challenged with correcting scaffolding issues.
Analysis. The inspectors determined that the failure to properly install and inspect
scaffolding in safety-related areas was contrary to written procedural requirements and
was a performance deficiency. The deficiency was more than minor because if left
uncorrected, it would have the potential to lead to a more significant safety concern. The
finding was associated with the Mitigating Systems Cornerstone. Using Inspection
Manual Chapter 0609, the issue is determined to have very low safety significance
because the finding is not a design or qualification issue confirmed not to result in a loss
of operability or functionality; did not represent an actual loss of safety function of the
system or train; did not result in the loss of one or more trains of nontechnical
specification equipment; and did not screen as potentially risk significant due to a
seismic, flooding, or severe weather initiating event. The inspectors determined that the
cause of the finding has a crosscutting aspect in the area of problem identification and
resolution associated with the component of corrective action program because the
licensee did not take appropriate corrective actions to address previously identified
scaffolding construction issues in a timely manner P.1(d).
Enforcement. Technical Specification 5.4.1.a requires that procedures be established,
implemented and maintained as recommended in Regulatory Guide 1.33, Appendix A.
Section 9.a of Appendix A, requires, in part, that maintenance affecting safety-related
equipment be accomplished in accordance with procedures. Procedure AP 14A-003
Scaffold Construction and Use, Revision 17, step F.4.1, required a 2 inch minimum
clearance between scaffolding and sensitive safety-related equipment, such as,
instrument tubing lines. The minimum clearance could be reduced to 1 inch between
scaffolding and safety-related piping with diameter equal or greater than 3 inches.
Procedure AP 14A-003, step F.4.2, required an engineering evaluation of the scaffolding
if these clearances could not be met. Contrary to the above, on July 14, 15, and 28,
2010, the inspectors identified four examples where the separation distance between
scaffolding and safety-related components was less than the minimum allowed by
procedure and an approved engineering evaluation to justify the deviation was not
performed. Specifically, the inspectors identified two scaffold poles that were less than 1
inch from the component cooling water and essential cooling water system piping with
diameter greater than 3 inches. The inspectors also identified two locations where
scaffold poles were less than 2 inches from essential service water system instrument
tubing. The licensee inspected other scaffolding erected near safety-related equipment
- 17 - Enclosure
and identified two additional instances where the separation distance between
scaffolding and safety-related components was less than the minimum allowed by
procedure. Because the finding is of very low safety significance and has been entered
into the corrective action program as Condition Reports CRs 26752 and 27010, this
violation is being treated as an NCV, consistent with Section VI.A of the NRC
Enforcement Policy: NCV 05000482/2010006-02, Scaffolding Installation Inadequacy.
c. Control Room Deficiency Tracking
Introduction. The inspectors identified a Green Finding for the failure of operations
personnel to follow Procedure AI 22A-001, Operator Work Arounds/Burdens/Control
Room Deficiencies, Revision 8, to adequately identify, document, and track control
room deficiencies associated with instruments and controls to ensure proper
prioritization and timely corrective actions.
Description. On July 16, 2010, the inspectors performed a walkdown of the main control
room area. The inspectors observed small blue, round magnets, labeled WR at
various locations on the main control boards. When asked, the reactor operator
informed the inspectors that the magnets were called Buttons, and they were used to
identify control board components that had work requests written against them, and
were placed near the affected equipment. The inspectors estimated that approximately
52 WR buttons were on the control boards, and observed that it was not clear which WR
button corresponded to which control board component since there was no information
provided on the button. The inspectors were informed that the buttons were
implemented several years ago as a method to reduce control board clutter by replacing
larger tags that hung from the control boards with the small blue magnets.
The inspectors questioned the reactor operators how they were able to determine the
equipment issue associated with a WR button. Operations personnel stated that the
information could be retrieved from various methods, including a review of the control
room tag book. The control room tag book, located in the shift managers office,
contained work request tags that tracked the open work requests written against control
room equipment. The inspectors reviewed the control room tag book and observed that
not every WR button had a corresponding work request tag and several tags did not
have corresponding WR buttons.
The inspectors reviewed Procedure AI 22A-001, Operator Work
Arounds/Burdens/Control Room Deficiencies, Revision 8, and noted that a control room
deficiency was defined as, A deficiency involving components in the control room such
that the indication in the control room does not accurately reflect actual plant condition or
the direct control room control is hindered. Procedure AI 22A-001 also directed that
control room deficiencies be monitored to ensure the following: (1) the item meets the
definition of control room deficiency; (2) the proper priority has been assigned; and (3)
the items are progressing to completion in a timely manner.
The inspectors reviewed the control room deficiency log and determined that only eight
items were categorized as control room deficiencies. The inspectors concluded that
numerous open work requests met the definition of a control room deficiency, as defined
in Procedure AI 22A-001, but were not listed in the control room deficiency log. Further,
- 18 - Enclosure
the inconsistent methods used to track control board component issues, such as, WR
buttons, a control room tag book, an information tag book, and the control room
deficiency log, have resulted in deficient equipment conditions that were not receiving
the appropriate prioritization and were not being corrected in a timely manner. For
example, the inspectors noted that one work request tag has been open since 2005
without correction or appropriate justification.
The absence of information and the inability to determine which WR button was
associated with which control board component issue was a concern to the inspectors.
Specifically, the inconsistent method used to track control board component issues was
a concern since important information may not be readily available to operations
personnel while trying to diagnose proper equipment and plant response during routine
and nonroutine operations. The ability to appropriately diagnose proper response during
nonroutine operations, such as, alarm, abnormal, or emergency response situations was
of particular concern. Operations personnel initiated Condition Report 27034 to
document this concern in the corrective action program.
Analysis. The inspectors determined that the failure of operations personnel to follow
administrative requirements for control room deficiency monitoring to ensure proper
prioritization and timely corrective actions was a performance deficiency. The deficiency
was more than minor because if left uncorrected, it would have the potential to lead to a
more significant safety concern, in that, the deficient condition could cause an operator
to take an inappropriate action based on expected plant response or conversely cause
an operator not to take action when action is required. The finding is associated with the
Mitigating Systems Cornerstone. The senior reactor analyst determined that this finding
was not appropriate to be evaluated using the significance determination process since
this finding was associated with numerous equipment issues and associated human
performance aspects that might impact equipment operation. Using Inspection Manual
Chapter 0609, Appendix M, Significance Determination Process Using Qualitative
Criteria, the finding is determined to have very low safety significance because there
was no adverse impact to plant equipment. The inspectors determined that the cause of
the finding has a crosscutting aspect in the area of problem identification and resolution
associated with the component of corrective action program because the licensee did
not identify issues completely, accurately, and in a timely manner commensurate with
their safety significance P.1(a).
Enforcement. No violation of regulatory requirements occurred. The inspectors
determined that the finding did not represent a noncompliance because the
administrative procedure to track control room discrepancies is not required by technical
specifications. The licensee entered the finding into the corrective action program as
Condition Report 27034 to evaluate the issue and identify corrective actions. Because
this finding does not involve a violation of regulatory requirements and has very low
safety significance, it is identified as FIN 05000482/2010006-03, Control Room
Deficiency Tracking.
- 19 - Enclosure
d. Failure to Update an Operability Evaluation
Introduction. The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures and Drawings, for the failure of operations and
engineering personnel to follow procedures and adequately evaluate degraded
conditions to support operability decision-making.
Description. The inspectors reviewed Operability Evaluation OE EF 09-007 to determine
the adequacy of the evaluation to address essential service water system degraded
conditions. The inspectors also reviewed the operability evaluation to determine
whether it met the requirements of Procedure AP 26C-004, Technical Specification
Operability, Revision 20, OTSC 09-0103, and Procedure AP 28-001, Operability
Evaluations, Revision 17, OTSC 10-0029.
Operability Evaluation OE EF 09-007, Revision 0, was initiated on September 24, 2009,
to support the operations shift managers determination of operability for the essential
service water system (See NCV 05000482/2009007-02). The operability evaluation
compiled the issues associated with essential service water system water hammer
susceptibility and mitigation for determination of continued operability of the system.
Revision 0 of the operability evaluation specifically addressed the effects of pressure
transients as a result of essential service water pump starts and the combined effects of
corrosion in essential service water piping. The inspectors observed that the operability
evaluation primarily focused on the effects of water hammer on only the four
containment cooling units. The operability impact of the degraded water hammer
susceptibility condition for other safety-related essential service water structures,
systems, and components was partially considered, in that previously performed
engineering reviews, operations procedures, and testing practices were credited as the
basis for system operability. The operability evaluation also considered essential service
water corrosion as evaluated in Apparent Cause Evaluation Condition Report 18785,
which determined that the previous through wall leakage events were a result of
localized pits that continued to propagate, over a period of time, from the inner pipe
diameter until the corrosion was through wall. The apparent cause evaluation concluded
that of the three major types of localized corrosion (crevice corrosion, under-deposit
corrosion, and microbiological influenced corrosion), under-deposit corrosion was the
cause of the pitting found at Wolf Creek Generating Station; and that the nature of the
pitting was understood and documented. Microbiological-induced corrosion was
determined to be minimal due to the chemical control measures in place.
Operability Evaluation OE EF 09-007, Revision 1, was initiated on June 29, 2010, to
address the affects of localized pitting corrosion from inside the piping resulting in
through wall leaks. The revised operability evaluation identified a through wall leak that
developed on June 29, 2010, which was determined to be degraded, but operable,
through application of Code Case N-513-2. The revision also discussed testing
performed as a corrective action from Apparent Cause Evaluation Condition
Report 18785 for the evaluated corrosion mechanism, and referenced Project Report
WCN005-PR-01, Analysis of Water Hammer Issues, Revision 0, that was completed
on March 8, 2010. The operability evaluation stated that no immediate concerns were
identified during review of the project report.
- 20 - Enclosure
The inspectors reviewed Apparent Cause Evaluation Condition Report 21127, which
was initiated on October 24, 2009, to document the identification that essential service
water system piping welds and/or their heat affected zones may be affected by a
corrosion mechanism different than the typical under deposit pitting corrosion generally
seen at Wolf Creek. This condition was identified during destructive examination of a
portion of essential service water piping associated with a through wall leak that
occurred on July 27, 2009. The apparent cause evaluation concluded, in part that:
(1) pipe wall thinning specifically and uniquely at welds had not been a noted issue with
essential service water piping prior to this event; (2) the through wall leak resulted from a
combination of erosion and corrosion; (3) turbulence is adding an erosion mechanism;
(4) the essential service water pipe wall-thinning program does not give direction to look
at wall thinning under welds, or potential wall thinning at weldolets; (5) recent history at
Wolf Creek indicates that large bore piping may be more susceptible to through wall
leaks than small bore piping; and (6) past history indicates piping exhibiting low and no
flow rates may be more susceptible to through wall leaks.
The inspectors reviewed metallurgical investigation reports dated October 27, 2009, and
November 25, 2009, performed outside the corrective action program. The inspectors
observed that both reports concluded that the cause of the corrosion that resulted in the
July 27, 2009, and another 30 inch diameter essential service water pipe leak was most
likely caused by microbiologically induced corrosion. The report further concluded that
tubercles formed on the surface of the piping inner diameter which covered the
underlying bacteria on the metallic surface. This helped to shield it from the
antimicrobial chemicals and biocides that were used to chemically control water and
prevent this corrosion mechanism. Once this under deposit corrosion was protected, the
area experienced extremely localized and likely rapidly progressing corrosion.
The inspectors reviewed internal operating experience that was relevant to the essential
service water system degraded condition and found that it had not been fully considered
in Operability Evaluation OE EF 09-007, Revisions 0 and 1. On August 19, 2009, a leak
of approximately 20 gpm from the essential service water system piping occurred on the
1988 elevation level of the auxiliary building concurrent with a loss of offsite power
event. This leak was identified by the NRC resident inspectors since
Procedure STN PE-040G, Transient Event Walkdown, did not identify the essential
service water system as vulnerable to off-normal dynamic forces
(NCV 05000482/2009007-06). The leak was identified when the resident inspector
noted 1 to 3 inches of water buildup on the floor one level below the elevation where the
leak had occurred 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> earlier. During the refueling outage that concluded on
November 21, 2009, and subsequent to initiation of emergency safety features actuation
systems testing, two components connected to the essential service water system
experienced leaks. One was the result of an extruded gasket on the residual heat
removal Train A pump room cooler. The second leak was due to a split in a dissimilar
metal joint in Containment Cooler SGN01C. The inspectors concluded that these
internal operating experience events illustrate that previous corrective actions credited in
Operability Evaluation OE EF 09-007 have been ineffective, and the locations of water
hammer induced leaks following loss of offsite power events are largely unpredictable.
- 21 - Enclosure
The inspectors reviewed Project Report WCN005-PR-01, Analysis of Water Hammer
Issues, Revision 0, dated March 8, 2010, and observed that much of the information,
including the conclusions and recommendations, were not consistent with previously
performed engineering evaluations and calculations described in Operability
Evaluation OE EF 09-007. Procedure AP 28-001, step 6.2.6.1.c, required the evaluator to
consider consequential failures in the evaluation of the deficiency when discussing the
systems capability of performing specified safety functions. The inspectors concluded that
Operability Evaluation OE EF 09-007, Revisions 0 and 1, failed to consider the
consequential failure of safety-related equipment adjacent to essential service water
structures and components that were susceptible to water hammer induced leakage as a
result of the degraded condition.
On July 29, 2010, the inspectors observations were communicated to licensee.
Operability Evaluation OE EF 09-007, Revision 2, was completed on July 30, however, the
revision only acknowledged that microbiologically induced corrosion was present, but
indicated that past history shows that bacteria were not an aggressive contributor to
corrosion due to chemical controls. On August 10, the inspectors informed the licensee
that Operability Evaluation OE EF 09-07, Revision 2, was still inadequate. As a result, the
licensee completed Revision 3 on August 12, 2010, to document an adequate basis for
operability. Condition Report 27288 was initiated to evaluate the failure to perform
adequate operability determinations.
Procedure AP 26C-004, Technical Specification Operability, Revision 20,
OTSC 09-0103, Section 6.1, required that identified deficiencies that could affect the
operability of a structure, system, or component subject to technical specifications be
evaluated for operability. However, there was no specific procedure guidance to ensure
that new information which challenges/changes the assumptions or basis for previously
performed operability determinations, be presented to operations personnel to evaluate
the condition and assure the continued reasonable expectation for operability.
Analysis. The inspectors determined that the failure to adequately evaluate the degraded
conditions to support the operability determination was a performance deficiency. The
deficiency was more than minor because if left uncorrected, it would have the potential to
lead to a more significant safety concern. The finding is associated with the Mitigating
Systems Cornerstone. Using Inspection Manual Chapter 0609, the issue is determined to
have very low safety significance because the finding is not a design or qualification issue
confirmed not to result in a loss of operability or functionality; did not represent an actual
loss of safety function of the system or train; did not result in the loss of one or more trains
of nontechnical specification equipment; and did not screen as potentially risk significant
due to a seismic, flooding, or severe weather initiating event. The inspectors determined
that the cause of the finding has a crosscutting aspect in the area of human performance
associated with resources because the licensee failed to provide complete, accurate, and
up-to-date procedures for performing operability evaluations H.2(c).
- 22 - Enclosure
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures
and Drawings, requires that activities affecting quality shall be prescribed by
instructions, procedures, or drawings and shall be accomplished in accordance with
those instructions, procedures, and drawings. The determination of operability for
technical specification related systems, structures, and components needed to mitigate
accidents was an activity affecting quality and was implemented by
Procedure AP 26C-004, Technical Specification Operability, Revision 20,
OTSC 09-0103. Procedure AP 28-001, Operability Evaluations, Revision 17,
OTSC 10-0029, provided instructions and guidelines to engineering personnel for
performing operability evaluations in support of the prompt operability determination
required by Procedure AP 26C-004. Contrary to the above, from September 25, 2009,
through August 12, 2010, operations and engineering personnel failed to implement
Procedure AP 26C-004, Section 6.1, to adequately evaluate the operability of a
degraded essential service water system. Specifically, operations and engineering
personnel failed to adequately evaluate the operability of the essential service water
system when relevant new information was identified that challenged a previously
performed operability determination and challenged the reasonable expectation for
operability. Because the finding is of very low safety significance and has been entered
into the licensees corrective action program as Condition Report 27288, this violation is
being treated as an NCV, consistent with Section VI.A of the Enforcement Policy:
NCV 05000482/2010006-04, Failure to Update an Operability Evaluation.
e. Failure to Perform Adequate Evaluation for Significant Conditions
Introduction. The inspectors identified a Green cited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Action, for the licensees failure to perform an
adequate evaluation to determine the cause and take corrective actions to preclude
repetition of a significant condition adverse to quality associated with loss of offsite
power induced water hammers and internal corrosion in the essential service water
system.
Description. On December 4, 2009, the NRC completed a special inspection to examine
activities associated with the stations performance during a loss of offsite power on
August 19, 2009. During the inspection, NCV 05000482/2009007-03, Failure to
Correctly Screen ESW Piping Leaks for Significance, was identified for the failure to
correctly screen for significance occurrences of water hammer damage and essential
service water piping corrosion that resulted in system damage. Because of the failure to
correctly screen the issue for significance, the licensee did not perform a root cause
analysis to evaluate the additive effect of documented loss of offsite power induced
water hammers and internal corrosion. The licensee entered the finding into the
corrective action program as Condition Report 22239.
The inspectors reviewed the apparent cause evaluation to Condition Report 22239 and
noted that the evaluation was primarily focused on the significance screening issue of
concern. The screening error for Condition Report 18785 was not corrected, and
consequently, no root cause evaluation was performed for the significant condition
adverse to quality.
- 23 - Enclosure
The inspectors reviewed the corrective action documents, project plans, and
metallurgical investigation reports, associated with the water hammer and internal
corrosion issues to determine the evaluation adequacy for the significant essential
service water system problems. The inspectors also reviewed the action and project
plans to determine the adequacy of identified corrective actions to preclude repetition of
the significant condition. The inspectors determined that the licensee failed to fully
identify the cause of the condition and identify adequate corrective actions within the
corrective action program. Section 4OA2.5(d) of this report (the previous section)
documents NCV 05000482/2010006-04 and provides the technical description of the
essential service water system corrosion and water hammer degraded conditions.
Based on a review of the technical information, the inspectors determined that the
licensee has pursued a symptom-based approach, both inside and outside the corrective
action program, to evaluate and correct the different aspects of the issues. However, the
information has not been assembled and considered in a single cause determination
which evaluates the additive effect of documented loss of offsite power induced water
hammers and internal corrosion, from which the licensee can develop well-justified
corrective actions to preclude repeated essential service water system damage.
The licensee initiated Condition Report 27212 to document the failure to perform an
adequate evaluation for the significant essential service water system deficiencies.
Condition Report 26466 was in progress to perform a root cause evaluation for the
identified conditions. Additionally, Condition Report 27075 was initiated to evaluate the
failure to properly respond to NCV 05000482/2009007-03.
Analysis. Inspectors determined that the failure to determine the cause and preclude
repetition of a significant condition adverse to quality was a performance deficiency. The
deficiency was more than minor because it is associated with the equipment
performance attribute of the Mitigating Systems Cornerstone and affects the associated
cornerstone objective to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences, and is therefore a
finding. Using Inspection Manual Chapter 0609, the issue is determined to have very
low safety significance because the finding is not a design or qualification issue
confirmed not to result in a loss of operability or functionality; did not represent an actual
loss of safety function of the system or train; did not result in the loss of one or more
trains of nontechnical specification equipment; and did not screen as potentially risk
significant due to a seismic, flooding, or severe weather initiating event. The inspectors
determined that the cause of the finding has a crosscutting aspect in the area of problem
identification and resolution associated with the component of corrective action program
because the licensee failed to thoroughly evaluate problems such that the resolutions
address causes and extent of conditions P.1(c).
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,
requires that in the case of significant conditions adverse to quality, measures shall
assure that the cause of the condition is determined and corrective action taken to
preclude repetition. Contrary to the above, from December 4, 2009, through July 29,
2010, the licensee failed to perform an adequate evaluation to determine the cause of
loss of offsite power induced water hammers and internal corrosion in the essential
- 24 - Enclosure
service water system and did not take corrective actions to preclude repetition of
additional water hammer events and system leaks. The finding has been entered into the
licensees corrective action program as Condition Reports 27212, 26466, and 27075, to
evaluate and correct the identified conditions. Due to the licensees failure to restore
compliance from the previous NCV 05000482/2009007-03 within a reasonable time after
the violation was identified, this violation is being cited in a Notice of Violation consistent
with Section VI.A of the NRC Enforcement Policy: VIO 05000482/2010006-05, Failure
to Perform Adequate Evaluation for Significant Conditions.
f. Failure to Determine if a Deficiency Existed in the Ultimate Heat Sink
Introduction. The team identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion
V, Instructions, Procedures, and Drawings, for the failure to follow the requirements of
Procedure AP 26C-004, Technical Specification Operability, Revision 20. Specifically,
the licensee failed to confirm if a deficiency existed with the ability of the ultimate heat
sink to perform its safety function.
Description. On July 26, 2010, the NRC reviewed Condition Report 26744, which was
initiated on July 14, 2010, and discussed the licensees failure to budget the money
necessary to perform the dredging of the ultimate heat sink channel before its due date
of September 2009. The preventive maintenance to dredge the channel is performed on
a 5-year frequency and is required to maintain operability of the ultimate heat sink. The
licensee did not evaluate the potential deficiency related to delaying the preventive
maintenance dredging of the ultimate heat sink because Procedure AP 16B-003,
Planning and Scheduling Preventive Maintenance, Revision 3, allows a 25 percent
grace period. As a result, the preventive maintenance is allowed to be performed within
6.25 years before it is considered late. Although Wolf Creek Generating Station
personnel had initiated subwork Order 09-319153-000 on August 4, 2009, to perform the
dredging, Condition Report 26744 was initiated almost a year later when Wolf Creek
Generating Station personnel were concerned that they might miss performing the
preventive maintenance within the 6.25 year deadline.
Prior to 2003, the licensees USAR required annual sedimentation checks in order to
determine the annual growth of sediment in the ultimate heat sink. In 2003, the licensee
evaluated the sedimentation data in Calculation Z065-C-001, and determined that the
ultimate heat sink would remain operable if the channel was dredged every five years
and the entire reservoir was dredged every 15 years. As a result, the licensee changed
its USAR requirements and suspended annual sedimentation checks.
Calculation Z065-C-001 used 18 years of data and calculated an average annual growth
rate in the channel of approximately 3 inches per year. The acceptance criterion is
24 inches of sedimentation growth, and the licensee concluded that sediment would
reach a maximum of 18.75 inches when the preventive maintenance (dredging) was
performed in 6.25 years. However, the team noted that the sediment level grew
10 inches in 1993, which was an unusually wet year according to lake records kept by
the licensee. The licensee believed this was an anomaly and unlikely to recur.
However, in 2002 sediment level grew 8 inches, again possibly due to another wet year.
In its USAR change, the licensee did not take into account the conditions that could
cause the ultimate heat sink to exceed the 24-inch sediment limit and make it inoperable
in less than 6.25 years (e.g., consecutive years of greater than normal precipitation).
- 25 - Enclosure
The inspectors noted that the last time the licensee actual measured sediment growth
was in about 2004.
Wolf Creek Procedure AP 26C-004, step 4.1.1, defined a deficiency as an all-inclusive
term used in reference to any condition or circumstance that reduces the confidence that
a structure, system, or component will perform satisfactorily in service. Step 6.1.3 of
the procedure required: When a potential deficiency affecting plant hardware is
identified but the impact on the ability of an structure, systems, or component to perform
its specified safety function is not known, then action shall be taken without delay to
confirm if a deficiency exists. On July 30, 2010, the inspectors brought the issue to the
attention of the control room operators and questioned the basis for continued operability
of the system. The shift manager made a log entry which stated that the licensee did not
consider this an actual operability issue, and also entered the issue into the corrective
action program as Condition Report 27080. That condition report failed to properly
identify the issue as a potential nonconforming condition per Section 4.2 of the
Regulatory Issue Summary 2005-20 Operability Guidance and take the appropriate
corrective action of determining the current sedimentation depths. The following week,
when the inspectors observed that appropriate actions still had not been taken to
address a potential safety concern, the inspectors again contacted the control room and
discussed the guidance of Regulatory Issue Summary 2005-20 Operability Guidance
with the shift manager. At that time, the shift manager took actions to make a log entry
noting the nonconformance in control room log and equipment out of service logs. She
also directed Condition Report 27080 be revised to include requirements to perform a
hydrographic survey of the ultimate heat sink intake channel to verify that sedimentation
levels were within design basis and licensing basis required limits. The hydrographic
survey was completed on August 14, 2010, and the results were verified and the
ultimate heat sink returned to service on August 29, 2010.
Analysis. The failure to implement Procedure AP 26C-004 was a performance
deficiency. The inspectors determined that this finding was more than minor because it
was associated with the equipment performance attribute of the Mitigating Systems
Cornerstone and it affected the cornerstone objective to ensure the availability, reliability,
and capability of systems that respond to initiating events to prevent undesirable
consequences (i.e., core damage). Using Inspection Manual Chapter 0609, the issue is
determined to have very low safety significance because the finding is not a design or
qualification issue confirmed not to result in a loss of operability or functionality; did not
represent an actual loss of safety function of the system or train; did not result in the loss
of one or more trains of nontechnical specification equipment; and did not screen as
potentially risk significant due to a seismic, flooding, or severe weather initiating event.
This finding has a crosscutting aspect in the area of problem identification and resolution
associated with the corrective action program component because licensee personnel
failed to identify a potential deficiency in the ultimate heat sink in a timely manner
Enforcement. Title 10 of the Code of Federal Regulations, Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities
affecting quality shall be prescribed by documented instructions or drawings of a type
appropriate to the circumstances and shall be accomplished in accordance with these
- 26 - Enclosure
instructions or drawings. Wolf Creek Generating Station Procedure AP 26C-004,
Technical Specification Operability, step 6.1.3 required when a potential deficiency
affecting plant hardware is identified but the impact on the ability of an structure, system,
or component to perform its specified safety function is not known, then action shall be
taken without delay to confirm if a deficiency exists. Contrary to the above, from
September 2009 through July 30, 2010, the licensee failed to take action without delay
to determine if a potential deficiency existed that could have affected the operability of
the ultimate heat sink when the licensee decided to delay dredging beyond the
preventive maintenance frequency of 5 years. Because of the very low safety
significance and Wolf Creek Generating Stations action to place this issue in their
corrective action program as Condition Report 27080, this violation is being treated as
an NCV in accordance with Section VI.A.1 of the Enforcement Policy:
NCV 05000482/2010006-07, Failure to Determine if a Deficiency Existed in the Ultimate
Heat Sink.
g. Notice of Unusual Event Due to Loss of Both Emergency Diesel Generators
Introduction. The inspectors reviewed a self-revealing violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Action for failure to promptly identify a degraded
equipment condition which resulted in a functional failure of the emergency diesel
generator system and a notice of unusual event emergency declaration during a
refueling outage.
Description. At 12:06 p.m. on October 22, 2009, during Refueling Outage 17 with the
reactor defueled, and the Emergency Diesel Generator B and Transformer XNB02 out of
service for planned maintenance, control room operators received an alarm indicating an
undervoltage or underfrequency condition on the Emergency Diesel Generator A.
Station operators were dispatched to the Emergency Diesel Generator A to investigate
and found that the engine had not started. At 12:08 p.m. the Emergency Diesel
Generator A was taken out of service for troubleshooting. The licensee determined that
a degraded nonsafety-related capacitor was passing ac noise beyond the filtering
capability of the dc speed switches, from the local annunciator cabinet power supply to
dc speed switches that feed into the emergency diesel generator starting circuit. As a
result the speed switches actuated, giving the control system a false indication that the
engine was running, and the appearance of undervoltage and underfrequency on the
generator. This false indication also disabled the starting capability of the engine
because the circuitry assumed the engine was already running. Therefore, the engine
would not have started as designed on a loss of offsite power.
The emergency preparedness manager reviewing the situation later observed that it met
the criteria for a notice of unusual event, and one was declared at 5:40 p.m. The repairs
to the control system were completed at 7:38 a.m. on October 23, 2009, and the notice
of unusual event was exited at 7:40 a.m.
Wolf Creek Generating Station entered this condition into the corrective action program
as Condition Report 21039 and performed an Apparent Cause Evaluation which
determined that the cause of the event was failure to implement preventive maintenance
to monitor a known potential equipment degradation of the nonsafety-related capacitor.
Electrical noise compromising the dc speed switches was first identified during
- 27 - Enclosure
troubleshooting in 1991. As a corrective action, a temporary modification (which later
became permanent) was implemented to install the nonsafety capacitor to provide the
additional noise filtration required. During routine calibration surveillance in December
2006, the dc speed switch could not be properly calibrated. At that time, the as-found
ripple voltage across the speed switch was observed to be 1.35V however it dropped to
0.2V when the ac power supply was de-energized. Both the speed switch and the
power supply were replaced and the control system began functioning within normal
parameters. The speed switch was subsequently bench tested, found to be working
properly, and returned to the warehouse for future use. However, the licensee had not
identified that the power supply was the cause of the problem; specifically, that over time
the nonsafety-related capacitor was becoming a less effective noise filter. If Wolf Creek
Generating Station personnel had properly assembled all of the information from the
2006 troubleshooting, they would have identified the capacitor degradation as the cause,
and implemented the preventive maintenance activities to monitor capacitor degradation
and replace the capacitors in time to preclude future failures of the emergency diesel
generator local control system. As part of the corrective actions of Condition
Report 21039, the licensee implemented a regular preventive maintenance activity to
monitor capacitor degradation. The licensee entered this violation into the corrective
action program as Condition Report 27077 and was evaluating the issue.
Analysis. The inspectors determined that the licensees missed opportunity to identify a
degraded equipment condition in December 2006 was a performance deficiency and is
reflective of current performance. This issue was more than minor because it was
associated with the equipment performance attribute of the Mitigating Systems
Cornerstone. Using Inspection Manual Chapter 0609, the issue is determined to have
very low safety significance because the finding is not a design or qualification issue
confirmed not to result in a loss of operability or functionality; did not represent an actual
loss of safety function of the system or train; did not result in the loss of one or more
trains of nontechnical specification equipment; and did not screen as potentially risk
significant due to a seismic, flooding, or severe weather initiating event. A crosscutting
aspect was identified in the problem identification and resolution in that the licensee did
not thoroughly evaluate problems such that the resolution addressed causes. P.1(c)
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,
requires, in part, that measures shall be established to assure that conditions adverse to
quality, such as failures, malfunctions, deficiencies, deviations, defective material and
equipment, and nonconformances are promptly identified and corrected. Contrary to the
above, in December 2006, during troubleshooting of an apparent failure of an
emergency diesel generator speed switch, Wolf Creek failed to identify the true cause of
the engine failure. Specifically, Wolf Creek personnel failed to promptly identify that the
condition adverse to quality was a degraded nonsafety-related capacitor. As a result, on
October 22, 2009, Emergency Diesel Generator A experienced a failure and caused the
plant to declare a notice of unusual event emergency declaration. Because this violation
was determined to be of very low safety significance and was placed in the corrective
action program as Condition Report 27077, this violation is being treated as an NCV in
accordance with Section VI.A.1 of the Enforcement Policy: NCV 05000482/2010006-08,
Notice of Unusual Event Due to Loss of Both Emergency Diesel Generators.
- 28 - Enclosure
h. Failure to Translate Design Information Into a Procedure
Introduction. The team identified a Green NCV of 10 CFR Part 50, Appendix B,
Criterion III, Design Control, for the failure to translate criteria from the atmospheric
relief valve accumulator leakage calculation into proceduralized leakage criteria.
Specifically, engineering personnel did not translate the calculated design basis leakage
criteria and the required minimum pressure to start the test into the procedure. The
licensee entered this into the corrective action program as Condition Report 26771, and
the licensee was developing plans to revise the leakage criteria in the procedure.
Description. During a review of corrective actions associated with the atmospheric relief
valve accumulator leakage criteria, the team observed that there were previous recent
condition reports noting problems with Calculation KA-03-W, "KA system Back-up
Nitrogen Accumulators, Revision 15. Condition Report 15280 had corrective actions to
reduce the allowed leakage rate in Procedure STS KA-010, N2 Accumulator Inservice
Check Valve Test, Revision 14, from 80 psi/hour to 70 psi/hour. Revision 15 was
revised on June 9, 2010, to include a 17 psi drop in 15 minutes (i.e., equivalent to
68 psi/hour).
The team noted the design basis leakage calculation for the atmospheric relief valve
accumulator assumes a consumption rate for the air-operated valves. The licensee has
four essentially identical accumulator tanks, and each tank provides air to an
atmospheric relief valve, and an auxiliary feedwater flow valve. USAR Table 9.3-1,
provides a required bases of three atmospheric relief valve strokes per hour for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
and three auxiliary feedwater valves strokes per hour for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The calculation
provided the valve pressure usage rates for the valves, and assumed a leakage rate out
of the system. The inspectors noted that Calculation KA-03-W included acceptance
criteria for a 65 psi/hour drop (equivalent to 16.25 psi/15 minutes), with an assumed
initial starting pressure of 700 psi would provide enough pressurized air to stroke the
valves for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The accumulator system operates with a nominal 750 psi pressure to
the accumulator tanks and a low pressure alarm of 670 psi. The inspectors concluded
that the criteria contained in Procedure STS KA-010 was inadequate because it did not
contain the calculated design basis leakage criteria and the required minimum pressure
to start the test into the procedure. The licensee initiated Condition Report 26771 to
document the inadequate procedure revision and was developing plans to revise the
leakage criteria in the procedure.
The inspectors reviewed the results of previous surveillance tests and noted that the
leakage rate was substantially less than the assumed leakage rate of the calculation.
Subsequently, the licensee reviewed the calculation and concluded that there was no
impact on operability of the atmospheric relief valves. The inspectors reviewed the
licensees analysis and concurred with the determination.
Analysis. The inspectors determined that the licensees failure to translate design
information into procedures was a performance deficiency. This issue was more than
minor because it affected the design control attribute of the Mitigating Systems
Cornerstone and affected the objective to ensure the reliability and capability of systems
that respond to initiating events to prevent undesirable consequences. Using Inspection
Manual Chapter 0609, the issue is determined to have very low safety significance
- 29 - Enclosure
because the finding is not a design or qualification issue confirmed not to result in a loss
of operability or functionality; did not represent an actual loss of safety function of the
system or train; did not result in the loss of one or more trains of nontechnical
specification equipment; and did not screen as potentially risk significant due to a
seismic, flooding, or severe weather initiating event. This finding has a crosscutting
aspect in the area of problem identification and resolution associated with the corrective
action program component because licensee personnel failed to take appropriate
corrective actions to previously identified problems P.1(d).
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires,
in part, that measures shall be established to assure that the design basis for those
structures, systems, and components to which this appendix applies are correctly
translated into specifications, drawings, procedures, and instructions. Contrary to the
above, prior to July 30, 2010, the licensee failed to translate the design bases
requirements into adequate procedural criteria. Specifically, Procedure STS KA-010 ,
N2 Accumulator Inservice Check Valve Test, Revision 15, did not include the
calculated design basis leakage criteria and the required minimum pressure to start the
test into the procedure from Calculation KA-03-W, KA system Back-up Nitrogen
Accumulators, Revision 15. Because this violation was of very low safety significance
and it was entered into the licensees corrective action program as Condition Report
26771, this violation is being treated as an NCV consistent with Section VI.A.1 of the
Enforcement Policy: NCV 05000482/2010006-09, Failure to Translate Design
Information into a Procedure.
4OA5 Other Activities
.1 (Closed) Licensee Event Report 05000482/2009005-00: Loss of Both Diesel Generators
With All Fuel in the Spent Fuel Pool
On December 21, 2009, Wolf Creek submitted LER 2009005 which described a loss of
onsite emergency power generation capability which occurred on October 22 and 23,
2009, during Refueling Outage 17. The Emergency Diesel Generator B was out of
service for planned maintenance when the Emergency Diesel Generator A failed
unexpectedly at 12:06 p.m. on October 22, 2009. This condition resulted in a notice of
unusual event emergency declaration. The cause of the failure was actuation of the
speed switches due to degradation of the capacitor responsible for filtering out noise on
the dc input feed to the annunciators power supply. The annunciator power supply was
replaced and the Emergency Diesel Generator A returned to service at 7:38 a.m. on
October 23, 2009. Wolf Creek Generating Station determined that the root cause of this
event was failure to implement preventive maintenance activities to monitor degradation
of the capacitors. Wolf Creek Generating Station performed a hazard barrier-target
analysis as part of Apparent Cause Evaluation Condition Report 24356 and determined
that they were previously aware the potential for ac noise to adversely impact the speed
switch. Since the licensee was aware of the potential for degradation and had missed
opportunities to fully evaluate and correct the condition as recently as 2006, and
because the event resulted in a loss of diesel generator system safety function and an
emergency declaration, the inspectors determined that this event constituted a
- 30 - Enclosure
self-revealing violation of NRC requirements. Enforcement aspects are discussed in
Section 4OA2.5h. This LER is closed.
4OA6 Meetings
Exit Meeting Summary
On July 30, 2010, the inspectors presented the inspection results to Mr. M. Sunseri, President
and Chief Executive Officer, and other members of the licensee staff. The licensee
acknowledged the issues presented. The inspector asked the licensee whether any materials
examined during the inspection should be considered proprietary. No proprietary information
was identified.
- 31 - Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
S. Henry, Acting Plant Manager
S. Koenig, Manager, Corrective Action Program
B. Masters, Supervisor, Design Engineering
B. Muilenburg, Licensing Engineer
G. Pendergrass, Director, Plant Engineering
E. Peterson, Ombudsman
E. Ray, Manager, Quality Assurance
L. Rockers, Licensing Engineer
M. Sunseri, President and CEO
J. Suter, Acting Manager, Design Engineering
J. Yunk, Human Resources Manager
NRC Personnel
M. Hay, Chief, Technical Support Branch
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000482/2010006-05 VIO Failure to Perform Adequate Evaluation for Significant
Conditions (Section 4OA2.1.5e)
Opened and Closed
05000482/2010006-01 NCV Failure to Resolve Degraded Conditions in a Timely Manner
(Section 4OA2.1.5a)05000482/2010006-02 NCV Unqualified Scaffolding Erected Near Safety-Related Equipment
(Section 4OA2.1.5b)05000482/2010006-03 FIN Failure to Adequately Monitor Control Room Deficiencies
(Section 4OA2.1.5c)05000482/2010006-04 NCV Failure to Update an Operability Evaluation (Section 4OA2.1.5d)05000482/2010006-07 NCV Failure to Determine if a Deficiency Existed in the Ultimate Heat
Sink (Section 4OA2.1.5f)05000482/2010006-08 NCV Notice of Unusual Event Due to Loss of Both Emergency Diesel
Generators (Section 4OA2.1.5g)05000482/2010006-09 NCV Failure to Translate Design Information into a Procedure
(Section 4OA2.1.5h)
A-1 Attachment
LIST OF DOCUMENTS REVIEWED
CONDITION REPORTS
6347 24190 24192 24194 24187
24188 24189 27034 15402 15968
27010 26782 26752 26752 2008-005459
2008-001660 2008-004983 25709 26671 26670
26673 26672 9688 26658 26659
26306 26784 26466 18785 21127
22710 22798 22239 23446 11951
27071 9414 9728 9729 9753
9756 9812 9989 10234 10318
10327 10369 10534 10556 10643
10674 10710 11022 11297 11309
11760 12257 12321 12398 12857
12862 13021 13771 13166 13470
17144 15447 18025 18467 18497
20187 20190 20374 20380 20378
22628 22546 23446 23459 23586
25457 11487 13374 17752 22310
15521 25901 11951 24194 24196
24351 24096 25134 14112 14113
14177 14779 14827 22874 26930
26744 26744 26930 22874 14827
06107 10369 13021 18467 24194
06165 10534 13166 18497 24196
07247 10556 13374 20187 24268
07495 10643 13470 20190 24288
07930 10674 13711 20374 24336
08067 10710 13720 20378 24337
09414 11022 13771 20380 24339
09519 11297 14038 21039 24351
09728 11309 14112 21077 24356
09729 11487 14113 21775 25134
09753 11760 14177 22310 25457
2008-000865 2008-001599 15280 22127 22980
26990 26771 26773 26767 23032
24196 24351 24194 24189 24192
A-2 Attachment
CONDITION REPORTS
24197 24187 24188 24189 24190
24192 24194 24195 24351 24197
24198 24200
PROCEDURES
REVISION /
NUMBER TITLE DATE
AP 28-001 Operability Evaluations 17
AP 26C-004 Technical Specification Operability 20
AI 22A-001 Operator Work Arounds/Burdens/Control Room Deficiencies 8
AP 22-001 Conduct of Pre-Job and Post-Job Briefs 10
AP 21-001 Conduct of Operations 46
AP 22A-001 Screening, Prioritization and Pre-Approval 11
TMP 09-014 CCW Flow Balance for Trouble Shooting Thermal Barrier 0
Closure
SYSKJ-200 Inoperable Emergency Diesel 20
AP 22C-003 Operational Risk Assessment Program 14A
AP 28A-100 Condition Reports 12
AI 28A-010 Screening Condition Reports 5
AP 23L-001 Lake Water Systems Corrosion and Fouling Mitigation 2
Program
AP 28-011 Resolving Deficiencies Impacting SSCs 1C
AP 16C-006 MPAC Work Request/Work Order Process Controls 16
AP 23-008 Equipment Reliability Program 4
AP 16-001 Control of Maintenance 6
AI 16B-002 Updating the PM Activity Module 7
AP 26C-004 Technical Specification Operability 20
MPE NE-004 Alternator Inspection 8
AP 16B-003 Planning and Scheduling Preventive Maintenance 8
A-3 Attachment
PROCEDURES
REVISION /
NUMBER TITLE DATE
STS MT-023 Ultimate Heat Sink Dam Surveillance Vertical Movement 4
and Sedimentation
AP 10-100 Fire Protection Program 15
STS AB-201D Atmospheric Relief Valve Inservice Valve Test 24
STS-AL-201C Turbine Driven Auxiliary Feedwater System Inservice Valve 6A
Test
STS-KA-010 N2 Accumulator Inservice Check Valve Test 15
STS-MS-070 ASME Code Testing of Safety/Relief Valves 18
WORK ORDERS
08-309413-010 10-330408-001 10-330408-008 10-330408-009 10-330408-011
09-321437-000 02236874-001 10-325888-000 10-327384-003 04-262017-000
09-318651-000 04-266919-000 06-289655-000 07-297977-000 08-305497-000
08-307922-001 09-313715-000 09-316986-000 09-317878-000 09-319258-000
09-320005-000 09-320207-000 09-320629-000 09-320688-000 09-321867-000
09-321868-000 09-321869-000 09-320688-000 09-322079-000 09-322094-000
09-322137-001 09-322467-001 09-322607-001 09-322825-000 09-322842-000
09-322843-000 09-322912-001 09-323130-000 09-323159-000 09-319153-000
PROCEDURE CHANGE REQUESTS
53032 53031 52982
OPERATIONAL BURDENS
09-OB111 09-OW101 08-CRD100
A-4 Attachment
CALCULATION REVISION /
NUMBER DATE
TITLE
KA-03-W KA System Back-Up Nitrogen Accumulators Capacity 2
Calculation
DRAWINGS
NUMBER TITLE REVISION /
DATE
M-620-00111- Nuclear Containment Cooling Coil 1W
W04
M-620-00011- Type R Coil 31 Tube Face - Carrier Replacement - 6 Row 12/12/07
W05 - 4 Pass (1 1/2 Circuit)
M-12EG03 Piping and Instrumentation Diagram Component Cooling 09
Water System
M-12EG01 Piping and Instrumentation Diagram Component Cooling 16
Water System
M-12EG02 Piping and Instrumentation Diagram Component Cooling 19
Water System
KD7496 One line diagram 37
10466-A-081- Sonicbar Door Division - Schedule and Elevation
4/14/83
0002-X04
CP 15-1-12C Vent Silencer Model AAF - Pulsco BDM 78-2 C
CP 9-1-182 3/4 40-C Regulator F
M-12AB01 Piping and Instrument Diagram Main Steam System 11
M-12AL01 Piping and Instrument Diagram Auxiliary Feedwater System 10
M-12KA05 Piping and Instrument Diagram Compressed Air System 07
M-12KH01 Piping and Instrument Diagram Service Gas System 13
A-5 Attachment
DRAWINGS
NUMBER TITLE REVISION /
DATE
M-13KA51 Small Piping Isometric N2 Back-up Gas Supply Auxiliary
01
Building
MISCELLANEOUS DOCUMENTS
NUMBER TITLE REVISION /
DATE
System Health Report Essential Service Water 01/01-
03/31/10
System Health Report Component Cooling Water 01/01-
03/31/10
APF 21-001-02 Control Room Turnover Checklist 7/16/2010
08-02-OPS Wolf Creek Quality Assurance Audit Report 3/7/2008
10-S0109 WCGS Scaffolding Request 6
2010-052 Reportability Evaluation Request 8
10-S0069 WCGS Scaffolding Request 5A
10-S0066 WCGS Scaffolding Request 5A
10-S0068 WCGS Scaffolding Request 5A
Operator Work Arounds Logs
Operator Burdens Logs
Control Room Deficiency Logs
Control Room Log 7/14-15/2010
Component Cooling Water System Open Work Orders for EG
System Correctives
2005-2525 Performance Improvement Request 6
System Health Report Essential Service Water
USAR 3.4.1.1 Flood Protection Measures for Seismic
Category I
2005-074 USAR Change Request 12/14/2005
Essential Service Water EF System Correctives
A-6 Attachment
MISCELLANEOUS DOCUMENTS
NUMBER TITLE REVISION /
DATE
10-010-EF Temporary Modification Order 00
97-00230 Altran Corporation Technical Report 96227-TR-01 2
09-005-XX Temporary Modification Order 01
Safety Monitor Profile Core Damage Frequency versus Time
2010 Work Week 213
WM06-0011 Wolf Creek Nuclear Operating Corporation Response to NRC 3/31/2006
Generic Letter 2006-02 Grid Reliability and the Impact on
Plant Risk and the Operability of Offsite Power
Safety Monitor Profile Core Damage Frequency versus Time 2
2010 Work Week 211
9301 Section 11 Assessment of Risk Resulting from Performance of 2/22/2000
Maintenance Activities
2032 Action Plan Detail Report 2/26/2009
OE-EF 09-007 Operability Evaluation Section A - Responsible Engineer 0
OE-EF 09-007 Operability Evaluation Section A - Responsible Engineer 01
OE-EF 09-007 Operability Evaluation Section A - Responsible Engineer 02
WCN005-PR-01 Enercon Project Report Analysis of Water Hammer Issues A
WCN005-PR-01 Enercon Project Report Analysis of Water Hammer Issues 0
57809 Metallurgical Failure Evaluation of a Corroded 30 Elbow 11/25/2009
from the Outlet Side of the Self-Cleaning Strainer of an ESW
Line
57652 Metallurgical Investigation of a Corroded 18 Welded Pipe, 10/27/2009
150-HBC-18 from a ESW Lake Water Line
Essential Service Water Issues Project Plan 0
CCP 9952 MSIV/MFIV Replacement (Mechanical) 14
CCP 10414 ALS MSFIS Controls Replacement 1
C-302 Specification for Suction Dredging the Ultimate Heat Sink 2
TOD No. 0300 Outage of the Benton to Wolf Creek 345 kV Line 7/17/2007
TOD No. 0301 Outage of the Rose Hill to Wolf Creek 345 kV Line 7/17/2007
TOD No. 0302 Outage of the Lacygne to Wolf Creek 345 kV Line 7/17/2007
CKL ZL-004 Turbine Building Reading Sheets 0
A-7 Attachment
MISCELLANEOUS DOCUMENTS
NUMBER TITLE REVISION /
DATE
CCP 9952 MSIV/MFIV Replacement (Mechanical) 14
CCP 10414 ALS MSFIS Controls Replacement 1
C-302 Specification for Suction Dredging the Ultimate Heat Sink 2
OE GK-08-004 Control Room AC Unit SGK04B and SGK05B Heat 0
Exchangers
OK KJ-08-005 Emergency Diesel Generator 0
Safety Culture Survey 2008
Safety Culture Survey 2010
Engineering Vent Silencer ABX0003 Deficiency 7/17/2007
Disposition,
Vendor Manual, Masoneilan 40 Series Reducing and Back Pressure
Regulator Instructions
A-8 Attachment