IR 05000482/2014505

IR 05000482/2014505; 12/02/2014 12/04/2014; Wolf Creek Generating Station; Inspection Report; Supplemental Inspection - Inspection Procedure 95001

ML15007A298
Person / Time
Site:	Wolf Creek
Issue date:	01/06/2015
From:	Mark Haire Plant Support Branch-1
To:	Heflin A Wolf Creek
G. Guerra
References
IR 2014505
Download: ML15007A298 (15)

Text

ary 6, 2015

SUBJECT:

WOLF CREEK GENERATING STATION - NRC INSPECTION PROCEDURE 95001 SUPPLEMENTAL INSPECTION REPORT 05000482/2014505

Dear Mr. Heflin:

On December 4, 2014, the Nuclear Regulatory Commission (NRC) completed a supplemental inspection pursuant to Inspection Procedure 95001, Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area, at the Wolf Creek Generating Station. The enclosed inspection report documents the inspection results, which were discussed during the exit meeting on December 4, 2014, with Mr. C. Reasoner, Site Vice President and Chief Nuclear Operations Officer, and other members of your staff.

As required by the NRC Reactor Oversight Process Action Matrix, this supplemental inspection was performed because one finding of White safety significance in the Emergency Preparedness Cornerstone was identified. Wolf Creek Generating Station was already in the Regulatory Response Column beginning the fourth quarter of 2013 for a Greater-than-Green finding in the Security Cornerstone (Follow-up Assessment letter, dated March 26, 2014, ML14085A376). The finding involved a failure to maintain adequate methods for assessing the potential consequences of a radiological emergency condition in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b)(9), Emergency Plans.

This violation was previously documented in NRC Inspection Report 05000482/2014503, dated July 1, 2014 (ML14182A628). The NRC staff was informed by your letter, dated November 3, 2014 (ML14316A437), of your readiness for us to conduct this supplemental inspection.

The objectives of this supplemental inspection were to provide assurance that: (1) the root causes and the contributing causes for the risk-significant performance issue were understood; (2) the extent of condition and extent of cause of the issue were identified; and (3) corrective actions were or will be sufficient to address and preclude repetition of the root and contributing causes.

The inspection included a review of the extent of condition and extent of cause for this issue, and a review of whether any safety culture component caused or significantly contributed to the issue. The inspection consisted of examination of activities conducted under your license as they related to safety, compliance with the Commissions rules and regulations, and the conditions of your operating license.

The inspector determined that your corrective actions, as itemized in the root cause evaluation, were appropriate to resolve the deficiency related to risk-significant performance issues. The inspector also concluded that your root cause, extent of condition, and extent of cause evaluations appropriately considered the safety culture components as described in Inspection Manual Chapter 0305, "Operating Reactor Assessment Program." The corrective actions completed, and those scheduled for completion, appear to be sufficient to prevent recurrence of these issues.

Based on the results of this inspection, the White finding is closed. Since four calendar quarters have passed since this finding was entered into the Action Matrix, it will no longer be considered in the Action Matrix. The NRC will issue a follow-up assessment letter informing the Wolf Creek Generating Station when overall station performance is considered to be in the Licensee Response Column of the Reactor Oversight Process Action Matrix.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mark S. Haire Chief, Plant Support Branch 1 Division of Reactor Safety Docket No.: 50-482 License No.: NPF-42 Enclosure:

Inspection Report 05000482/2014505 w/Attachments: Supplemental Information Electronic Distribution to Wolf Creek Generating Station

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000482 License: NPF-42 Report: 05000482/2014505 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane NE Burlington, Kansas Dates: December 2 through December 4, 2014 Inspector: G. Guerra, CHP, Emergency Preparedness Inspector Approved Mark S. Haire By: Chief, Plant Support Branch 1 Division of Reactor Safety-1- Enclosure

SUMMARY

IR 05000482/2014505; 12/02/2014 - 12/04/2014; Wolf Creek Generating Station; Inspection

Report; Supplemental Inspection - Inspection Procedure 95001 This supplemental inspection was conducted by an emergency preparedness Inspector. No findings were identified. The Nuclear Regulatory Commission (NRC's) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Emergency Preparedness

The inspector performed this supplemental inspection in accordance with Inspection Procedure (IP) 95001, Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area, to assess the licensees evaluation associated with a failure to maintain adequate methods for assessing the potential consequences of a radiological emergency condition in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b)(9), Emergency Plans. The finding associated with this issue was first documented in IR 05000482/2014502 (ML14092A618) on April 2, 2014. The NRC provided the final significance determination of these issues to the licensee on July 1, 2014, (ML14182A628).

Prior to the issuance of the final significance determination, Wolf Creek Generating Station was already in the Regulatory Response Column beginning the fourth quarter of 2013 for a Greater-than-Green finding in the Security Cornerstone (Follow-up Assessment letter, dated March 26, 2014, ML14085A376). This finding extended performance in the Regulatory Response Column to at least the fourth quarter 2014.

The inspector determined that the licensee performed an adequate evaluation of the issue.

The inspector also determined that the root cause evaluation for the risk-significant performance issue appropriately evaluated the root and contributing causes, adequately addressed the extent of condition and extent of cause, assessed safety culture, and established corrective actions. The inspector concluded that the licensees root cause evaluation and corrective actions were sufficient to address the causes and prevent recurrence. The inspector also concluded that the licensees assessment of the Wolf Creek Generating Station safety culture accurately reflected the conditions at the site. As a result, the inspector concluded that the licensee appropriately addressed the White finding, and in accordance with the guidance in NRC Inspection Manual Chapter 0305, Operating Reactor Assessment Program, the White finding will be considered in assessing plant performance for a total of four quarters. The licensees implementation of corrective actions will be reviewed during future inspections.

Licensee-Identified Violations

None.

REPORT DETAILS

4OA4 Supplemental Inspection

.01 Inspection Scope

The inspector performed this inspection in accordance with IP 95001, Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area, because the licensee entered the Regulatory Response Column of the NRC Action Matrix in the first quarter of 2014 as a result of one NRC-white inspection finding in the Emergency Preparedness Cornerstone. The finding is summarized below:

• Failure to maintain adequate methods for assessing the potential consequences of a radiological emergency condition in accordance with the requirements of 10 CFR 50.47(b)(9), Emergency Plans. The licensees dose assessment model incorrectly calculated the concentration of iodine and particulate radioactive material released through the main vent stack when the effluent monitor was in accident mode.

The objectives of this supplemental inspection included the following:

• provide assurance that the root causes and contributing causes of risk-significant performance issues were understood

• provide assurance that the extent of condition and extent of cause of risk-significant performance issues were identified

• provide assurance that the licensees corrective actions for risk-significant performance issues were sufficient to address the root and contributing causes and prevent recurrence The licensee staff informed the NRC staff by letter, dated November 3, 2014, of their readiness for this supplemental inspection. In preparation for the inspection, the licensee performed a root cause evaluation (RCE) to identify weaknesses that existed in processes and organization that resulted in the White finding. As part of the RCE, the licensee also assessed safety culture for any contribution to the root or contributing causes. The licensee provided the NRC inspector a copy of their RCE on December 2, 2014, along with other supporting evaluations and documentation.

The inspector reviewed the licensees RCE and other corrective action program evaluations the licensee conducted in support of, or as a result of, the RCE. The inspector reviewed corrective actions that the licensee had taken to address the identified causes. The inspector also held discussions and conducted interviews with licensee personnel to determine if the root and contributing causes, and the contribution of safety culture components, were understood, as well as whether completed or planned corrective actions were adequate to address the causes and prevent recurrence.

.02 Evaluation of Inspection Requirements

02.01 Problem Identification a. Determine that the evaluation documented who identified the issue (i.e., licensee-identified, self-revealing, or NRC-identified) and under what conditions the issue was identified.

The licensees Root Cause Analysis (CR 80308, RCA) included a detailed section on discovery information. On November 13, 2012, during an emergency preparedness (EP) drill, the licensee identified that the Emergency Dose Calculation Program (EDCP)filtration factor toggle button was suspected to be nonfunctional based on performance of dose assessments during the drill. A drill controller over the dose assessment area compared the drill dose assessment results to predicted results; he noted a discrepancy and wrote Condition Report (CR) 59832. This CR was later closed to service request (SR) 126710 on January 10, 2013. The EDCP filtration factor toggle was again suspected to be nonfunctional during a November 5, 2013, NRC graded exercise. The dose assessment coordinator tested the EDCP outputs with and without the filtration factor and noted the problem. The dose assessment coordinator wrote CR 76084 and the issue was validated two days later by a controller and the Information Services Supervisor. The error affected the licensees ability to appropriately assess the consequences of a radiological accident and issue appropriate protective action recommendations for offsite authorities to use.

The issue was identified by plant staff during EP drill critiques in November 2012 and November 2013, and both times the issue was documented in the licensees corrective action program. The licensee determined that it could and should have rectified the issue in 2012, but that it had not. The licensee failed to recognize the significance of the issue and effect prompt corrective action in accordance with the safety significance.

This was not recognized, in part, because dose assessment was not flagged as one of the risk-significant EP planning standards in their programs and processes as were the other EP risk-significant planning standards of classification, notification, and protective action recommendation. During the graded exercise inspection, the NRC inspector determined this issue to be self-revealing on the second occurrence because no corrective action had been completed or implemented since initial identification one year earlier.

The inspector determined that the licensees evaluation adequately documented who identified the issue and under what conditions the issue was identified.

b. Determine that the evaluation documented how long the issue existed and prior opportunities for identification.

The issue was first identified on November 13, 2012. The licensees RCE included a detailed event narrative identifying that EDCP software, version 3.6, implemented on February 18, 2003, did not include a functional filtration factor; thus the problem existed from that time, until February 25, 2014, when EDCP, version 4.9, corrected it. Prior opportunities for identification were missed because complete software verification and validation (V&V) were not performed.

The inspector determined that the licensees evaluation was adequate with respect to identifying how long the issue existed and prior opportunities for identification.

c. Determine that the evaluation documented the plant-specific risk consequences, as applicable, and compliance concerns associated with the issue.

The licensees RCE included a risk consequences and compliance section documenting that there were no plant specific risk consequences associated with this event. The licensee concluded that the errors caused the radiological emergency response plan to be degraded relative to not fully meeting the risk-significant planning standard required by 10 CFR 50.47(b)(9) and how a malfunction or problem leading to an inaccurate dose assessment could adversely impact the ability to meet the risk-significant EP planning standard. The error impacted the licensees ability to properly recommend appropriate off-site protective action measures. There was no reporting compliance issue and the issue was not considered to be a loss of EP function. The issue affected a small part of the EDCP and other means of making protective action recommendations remained in place and were not affected.

The inspector concluded that the licensee appropriately documented the risk consequences and compliance concerns associated with the issue.

d. Findings and Observations

.

No findings were identified.

02.02 Root Cause, Extent of Condition, and Extent of Cause Evaluation a. Determine that the problem was evaluated using a systematic methodology to identify the root and contributing causes.

The licensees RCE included systematic methods to identify root and contributing causes. The systematic methods used included an event and causal factors analysis, a barrier analysis, a "why tree" analysis, and an organizational and programmatic issues analysis. Additionally, the licensee included an event description, a summary of root and contributing causes, a discussion of internal and external operating experience, an extent of condition analysis, an extent of cause analysis, and a safety culture assessment. The licensee identified a direct cause (DC), one root cause (RC) and three contributing causes (CC):

• (DC) the verification and validation for version 4.8 of EDCP was less than adequate because it did not include a check of the filtration factor functionality;

• (RC1) information services procedures and guidance do not require comprehensive verification and validation for risk-significant software;

• (CC1) less than adequate EP oversight of risk-significant drill identified issues;

• (CC2) Procedure AI 28A-010, Screening Condition Reports, does not have specific screening guidance for the risk-significant planning standard area of dose assessment;

• (CC3) information services procedures and guidance do not require application owner input for software priority changes involving computer software management and service requests.

The inspector concluded the licensee performed a thorough analysis of the issues, using appropriate analysis methods to identify root and contributing causes of the event.

b. Determine that the root cause evaluation was conducted to a level of detail commensurate with the significance of the problem.

The licensees RCE included a condition statement, a risk consequence and compliance analysis, an event description, a summary of root and contributing causes, a discussion of internal and external Operating Experience, an extent of condition analysis and resulting actions, an extent of cause analysis and resulting actions, and a safety culture assessment. The use of several systematic methods of analysis reinforced the identified causes. The licensee identified a direct cause, a root cause, and three contributing causes; and implemented and completed 13 corrective actions to correct the issue and prevent recurrence of the root and contributing causes.

The inspector concluded the licensees RCE was adequately performed and included a level of detail commensurate with the identified performance deficiency. The inspector concluded the identified causes, corrective actions, and actions taken to identify the extent of problems provided evidence of a process that was methodical, in-depth, and thorough.

c. Determine that the root cause evaluation included a consideration of prior occurrences of the problem and knowledge of prior operating experience.

The licensees RCE included a discussion of internal and external operating experience.

Also, the licensee performed a survey of other operating nuclear facilities to identify similar issues. As a result of a readiness review for this inspection the licensee performed further reviews of external operating experience.

The inspector concluded that the root cause evaluation included a thorough review of prior and precursor problems, and properly evaluated internal and industry operating experience.

d. Determine that the root cause evaluation addresses the extent of condition and the extent of cause of the problem.

The licensees evaluation included an evaluation of the extent of condition; however, it focused only on software in use by the EP department or emergency response organization. A licensee readiness review prior to this inspection identified that this review should be expanded to include other plant equipment and processes which was performed under CR 88276. The extent of condition reviewed whether EDCP software was incorrectly configured for other inputs used for dose assessment purposes and whether other software applications were not subject to appropriate software quality assurance controls. The licensee identified that another similar radio selection button in the dose assessment software was also nonfunctional; this was also corrected with version 4.9 of EDCP. The nonfunctional button involved the filtration factor for containment spray. The licensee presented this to the NRC during the Regulatory Conference held on April 30, 2014. The NRC determined this to be a second example of the issue reviewed in this report and no further violations of NRC requirements were identified.

The licensees evaluation also included an evaluation of the extent of cause for the root cause to determine if other departments or activities with similar processes could be vulnerable to the root cause. Initially the licensee sampled 10 software packages in use by various plant departments for this evaluation. The licensee has expanded this review to all software owned by Wolf Creek Generation Station under CR 88208.

Based on a review of the evaluation and discussions with licensee staff personnel; the inspector concluded that the licensees evaluation addressed the extent of condition and the extent of cause of the problem through a disciplined process.

e. Determine that the root cause, extent of condition, and extent of cause evaluations appropriately considered the safety culture components as described in Inspection Manual Chapter (IMC) 0305.

The licensee performed a safety culture assessment and included a safety culture worksheet in the RCE. The licensee identified that the aspect of Avoid Complacency, individuals recognize and plan for the possibility of mistakes, latent problems, and inherent risk, even while expecting successful outcomes, was applicable to the root cause. The licensees prior process of only performing functionality testing associated with a particular software change did not recognize and plan for the possibility of mistakes that could have been made during the change process or missed during previous changes and repeated use of this approach masks past problems and increases the risk of future errors. Additionally, the licensee recognized that the NRC identified aspect of Evaluation, the organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance, was applicable to the contributing causes. The issue was initially identified on November 13, 2012, but not appropriately evaluated in order to ensure a timely resolution commensurate with the risk significance of the issue.

The inspector concluded that the licensee appropriately considered the safety culture components in the root cause and contributing causes; and that corrective actions addressed the weaknesses.

f. Findings

No findings were identified.

02.03 Corrective Actions a. Determine that appropriate corrective actions are specified for each root and contributing cause or that the licensee has an adequate evaluation for why no corrective actions are necessary.

The licensees RCE identified a direct cause, one root cause, and three contributing causes. These were addressed initially with 13 corrective actions to prevent recurrence under CR 80308. The corrective actions fixed the issues identified. The RCE includes an Action Matrix identifying how each corrective action relates to the identified causes.

The licensee later decided to expand the scope to some of these actions to include a review of all software owned by Wolf Creek Generating Station.

The inspector concluded that appropriate corrective actions were developed for the root cause, contributing causes, extent of condition, and extent of cause.

b. Determine that the corrective actions have been prioritized with consideration of risk-significance and regulatory compliance.

The licensee documented 13 corrective actions in CR 80308 and all have been completed as of November 18, 2014, with the exception of the Final Effectiveness Review scheduled for completion April 30, 2015. The inspectors determined that the additional corrective actions which expanded the scope of some of the performed actions were a licensee enhancement-initiative and are not required to address the causes or regulatory compliance of the issue that resulted in this inspection. Additional CRs reviewed are listed in the attachment to this report.

The inspector concluded the licensee had appropriately prioritized and scheduled corrective actions for the identified root and contributing causes.

c. Determine that a schedule has been established for implementing and completing the corrective actions.

As discussed in Section 02.03.b, the licensee documented 13 corrective actions as completed as of November 18, 2014. A final effectiveness review has been scheduled for April 30, 2015.

The inspector concluded that an appropriate schedule had been established for implementing and completing the corrective actions.

d. Determine that quantitative or qualitative measures of success have been developed for determining the effectiveness of the corrective actions to prevent recurrence.

The licensee performed an Interim Monitoring Assessment (QH 2014-0866) on August 14, 2014, to determine if appropriate priorities were assigned and to review completed actions to verify completion as intended or required. Additionally, a final effectiveness review has been scheduled for April 30, 2015. The licensees RCE includes an Effectiveness Review Plan that establishes the success criteria to help ensure corrective actions were appropriate and effective.

The inspector concluded the licensee has developed appropriate evaluation criteria for performing effectiveness reviews of the corrective actions. The inspector concluded the schedule was appropriate given the implementation schedule of the corrective actions.

e. Determine that the corrective actions planned or taken adequately address a Notice of Violation (NOV) that was the basis for the supplemental inspection, if applicable.

The NRC issued an NOV to the licensee for the failure to maintain adequate methods for assessing the potential consequences of a radiological emergency condition in accordance with the requirements of 10 CFR 50.47(b)(9), Emergency Plans. The licensees dose assessment model incorrectly calculated the concentration of iodine and particulate radioactive material released through the main vent stack when the effluent monitor was in accident mode. The licensee responded to the NOV by letter, dated July 29, 2014 (ML14224A006). The licensee committed to performing a comprehensive verification and validation on version 4.10 of EDCP by September 15, 2014. This action was completed on September 9, 2014. The inspector confirmed that the licensees RCE and corrective actions addressed the NOV.

f. Findings

No findings were identified.

02.04 Evaluation of IMC 0305 Criteria for Treatment of Old Design Issues.

The licensee did not request credit for self-identification of an old design issue.

Therefore, the subject risk-significant issues were not evaluated against the IMC 0305 criteria for treatment of an old design issue.

4OA5 Other Activities

Failure to Maintain Accurate Methods for Dose Assessment NRC Inspection Report 05000482/2014505, "Final Significance Determination of White Finding and Notice of Violation," documented a violation for failure to maintain accurate methods for dose assessment. The licensee responded to the NOV by letter, dated July 29, 2014 (ML14224A006). This supplemental inspection documents that appropriate corrective actions have been implemented by the licensee. This violation is closed.

4OA6 Meetings

Exit Meeting Summary

On December 4, 2014, the inspector presented the results of the onsite inspection to Mr. C.

Reasoner, Site Vice President and Chief Nuclear Operations Officer, Wolf Creek Generating Station, and other members of the licensee staff. The licensee acknowledged the information presented. The licensee confirmed that any proprietary information reviewed by the inspector had been returned or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

C. Reasoner, Site Vice President and

Chief Nuclear Operations Officer

J. McCoy, Vice President Engineering

A. Broyles, Manager Information Services

T. East, Superintendent, Emergency Planning

J. Edwards, Manager, Operations

K. Egan, Quality

N. Good, Licensing

R. Hobby, Licensing Engineer

S. Koenig, Manager, Regulatory Affairs

S. Smith, Plant Manager

M. Skiles, Manager, Health Physics

K. Thrall, Emergency Planning

B. Vickery, Manager, Financial Services

R. Thompson, Supervisor, Corrective Actions

NRC Personnel

D. Dodson, Senior Resident Inspector

R. Stroble, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

None

Closed

05000482/2014502-01 NOV Failure to Maintain Accurate Methods for Dose Assessment

-1- Attachment