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Category:Letter type:WO
MONTHYEARWO 23-0002, Operating Corp., Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-0082023-12-26026 December 2023 Operating Corp., Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008 WO 23-0014, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-17017 May 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations WO 23-0009, Financial Protection Levels2023-03-31031 March 2023 Financial Protection Levels WO 22-0056, Operating Corporations Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-0082022-12-19019 December 2022 Operating Corporations Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008 WO 22-0021, Technical Specification 5.6.8 - Post Accident Monitoring (PAM) Report2022-08-29029 August 2022 Technical Specification 5.6.8 - Post Accident Monitoring (PAM) Report WO 22-0015, Generation Station - Guarantee of Payment of Deferred Premiums2022-05-0606 May 2022 Generation Station - Guarantee of Payment of Deferred Premiums WO 22-0011, Operating Corp., Financial Protection Levels2022-03-29029 March 2022 Operating Corp., Financial Protection Levels WO 22-0007, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations2022-03-0909 March 2022 Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations WO 21-0064, Operating Corporation, Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-0082021-12-29029 December 2021 Operating Corporation, Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008 WO 21-0031, (Wcgs), Supplement to One-Time Request for Exemption from the Biennial Emergency Preparedness2021-08-12012 August 2021 (Wcgs), Supplement to One-Time Request for Exemption from the Biennial Emergency Preparedness WO 21-0027, One-Time Request for Exemption from the Biennial Emergency Preparedness2021-07-29029 July 2021 One-Time Request for Exemption from the Biennial Emergency Preparedness WO 21-0015, License Amendment Request (LAR) for Revision to the Emergency Plan2021-05-25025 May 2021 License Amendment Request (LAR) for Revision to the Emergency Plan WO 21-0020, Operating Corp - Guarantee of Payment of Deferred Premiums2021-05-0707 May 2021 Operating Corp - Guarantee of Payment of Deferred Premiums WO 21-0019, Operating Corp Response to NRC Regulatory Issue Summary 2021-01, Preparation and Scheduling of Operator Licensing Examinations2021-04-14014 April 2021 Operating Corp Response to NRC Regulatory Issue Summary 2021-01, Preparation and Scheduling of Operator Licensing Examinations WO 21-0014, Financial Protection Levels2021-03-30030 March 2021 Financial Protection Levels WO 21-0010, Submittal of Revision 34 to Updated Safety Analysis Report2021-03-11011 March 2021 Submittal of Revision 34 to Updated Safety Analysis Report WO 21-0002, Notification of Readiness for Supplemental Inspection 927232021-01-28028 January 2021 Notification of Readiness for Supplemental Inspection 92723 WO 20-0058, Operating Corporation'S Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-0082020-12-23023 December 2020 Operating Corporation'S Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008 WO 20-0050, License Amendment Request to Revise Technical Specification 3.6.3 and Surveillance Requirement 3.6.3.1 to Allow Use of a Blind Flange2020-11-10010 November 2020 License Amendment Request to Revise Technical Specification 3.6.3 and Surveillance Requirement 3.6.3.1 to Allow Use of a Blind Flange WO 20-0040, Corrected Revision 33 of the Wolf Creek Generating Station Updated Safety Analysis Report2020-07-23023 July 2020 Corrected Revision 33 of the Wolf Creek Generating Station Updated Safety Analysis Report WO 20-0048, Request for Notice of Enforcement Discretion for Technical Specifications 3.8.1, AC Sources - Operating2020-06-30030 June 2020 Request for Notice of Enforcement Discretion for Technical Specifications 3.8.1, AC Sources - Operating WO 20-0047, Guarantee of Payment of Deferred Premiums2020-05-0707 May 2020 Guarantee of Payment of Deferred Premiums WO 20-0029, License Amendment Request to Revise Specification 5.5.16 for Permanent Extension of Type a and Type C Leak Rate Test Frequencies2020-04-20020 April 2020 License Amendment Request to Revise Specification 5.5.16 for Permanent Extension of Type a and Type C Leak Rate Test Frequencies WO 20-0024, Financial Protection Levels2020-03-31031 March 2020 Financial Protection Levels WO 19-0059, Docket No. 50-482: Wolf Creek Nuclear Operating Corporation'S Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-0082019-12-23023 December 2019 Docket No. 50-482: Wolf Creek Nuclear Operating Corporation'S Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008 WO 19-0033, License Amendment Request for Revision to Technical Specification 3.7.5, Auxiliary Feedwater (AFW) System2019-08-29029 August 2019 License Amendment Request for Revision to Technical Specification 3.7.5, Auxiliary Feedwater (AFW) System WO 19-0031, Supplement 1 to Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 42019-08-0808 August 2019 Supplement 1 to Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4 WO 19-0011, Financial Protection Levels2019-03-27027 March 2019 Financial Protection Levels WO 19-0013, Supplement to Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 42019-03-11011 March 2019 Supplement to Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4 WO 18-0045, Submittal of Response to Requests for Additional Information (RAI) Regarding License Amendment Request (LAR) for Revision to the Emergency Plan2018-11-19019 November 2018 Submittal of Response to Requests for Additional Information (RAI) Regarding License Amendment Request (LAR) for Revision to the Emergency Plan WO 18-0047, Timeline for Response to RAI for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-11-15015 November 2018 Timeline for Response to RAI for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term WO 18-0044, Clean Revised Technical Specification Pages for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-11-15015 November 2018 Clean Revised Technical Specification Pages for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term WO 18-0036, Operating Corporation (WCNOC) - Notification of Readiness for Supplemental Inspection2018-08-15015 August 2018 Operating Corporation (WCNOC) - Notification of Readiness for Supplemental Inspection WO 18-0034, Operating Corp., Additional Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-08-0909 August 2018 Operating Corp., Additional Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term WO 18-0031, Inservice Inspection (ISI) Program Relief Request from the Requirements of American Society of Mechanical Engineers (ASME) Code Case N-666-1, Weld Overlay of Class 1, 2, and 3 Socket Welded Connections, Section XI, Division 12018-07-23023 July 2018 Inservice Inspection (ISI) Program Relief Request from the Requirements of American Society of Mechanical Engineers (ASME) Code Case N-666-1, Weld Overlay of Class 1, 2, and 3 Socket Welded Connections, Section XI, Division 1 WO 18-0016, License Amendment Request for Revision to the Emergency Plan2018-05-0909 May 2018 License Amendment Request for Revision to the Emergency Plan WO 18-0014, Response to NRC Regulatory Issue Summary 2018-02, Preparation and Scheduling of Operator Licensing Examinations2018-04-16016 April 2018 Response to NRC Regulatory Issue Summary 2018-02, Preparation and Scheduling of Operator Licensing Examinations WO 18-0015, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors 10 CFR 50.75(f)(1)2018-04-0505 April 2018 Financial Assurance Requirements for Decommissioning Nuclear Power Reactors 10 CFR 50.75(f)(1) WO 18-0004, Response to Request for Additional Information Re License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of ...2018-01-15015 January 2018 Response to Request for Additional Information Re License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of ... WO 17-0093, License Amendment Request (LAR) for Revision to the Emergency Plan2017-12-19019 December 2017 License Amendment Request (LAR) for Revision to the Emergency Plan WO 17-0092, Request for Regulatory Conference (EA-17-149)2017-11-0808 November 2017 Request for Regulatory Conference (EA-17-149) WO 17-0065, Submittal of LER 17-S01-00 for Wolf Creek Nuclear Operating Corp., Regarding Contraband Introduced Into the Protected Area Boundary2017-10-10010 October 2017 Submittal of LER 17-S01-00 for Wolf Creek Nuclear Operating Corp., Regarding Contraband Introduced Into the Protected Area Boundary WO 17-0042, Operating Corporation Supplement to RAI Response Regarding Adopting New EAL Scheme2017-04-26026 April 2017 Operating Corporation Supplement to RAI Response Regarding Adopting New EAL Scheme WO 17-0041, Supplement to Technical Specification 5.6.8 - Post Accident Monitoring (PAM) Report2017-04-20020 April 2017 Supplement to Technical Specification 5.6.8 - Post Accident Monitoring (PAM) Report WO 17-0033, Response to NRC Regulatory Issue Summary 2017-03, Preparation and Scheduling of Operator Licensing Examinations.2017-04-17017 April 2017 Response to NRC Regulatory Issue Summary 2017-03, Preparation and Scheduling of Operator Licensing Examinations. WO 17-0023, Submittal of Technical Specification 5.6.8 - Post Accident Monitoring (PAM) Report2017-03-27027 March 2017 Submittal of Technical Specification 5.6.8 - Post Accident Monitoring (PAM) Report WO 17-0026, Errata for License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses2017-03-22022 March 2017 Errata for License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses WO 17-0013, Response to Request for Additional Information Regarding License Amendment Request for Adopting Revised Emergency Action Level Scheme2017-03-16016 March 2017 Response to Request for Additional Information Regarding License Amendment Request for Adopting Revised Emergency Action Level Scheme WO 17-0009, Revision 30 to Updated Safety Analysis Report2017-03-0909 March 2017 Revision 30 to Updated Safety Analysis Report WO 16-0068, Docket No. 50-482: Request for Regulatory Conference2016-12-21021 December 2016 Docket No. 50-482: Request for Regulatory Conference 2023-05-17
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARWO 21-0064, Operating Corporation, Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-0082021-12-29029 December 2021 Operating Corporation, Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008 WM 19-0003, Notice of Violation and Proposed Imposition of Civil Penalty Statement of Method of Payment2019-01-16016 January 2019 Notice of Violation and Proposed Imposition of Civil Penalty Statement of Method of Payment WM 16-0016, Response to Non-Cited Violation 050000482/2016003-012016-12-0808 December 2016 Response to Non-Cited Violation 050000482/2016003-01 WM 16-0006, Reply to Notice of Violation EA-16-0182016-03-10010 March 2016 Reply to Notice of Violation EA-16-018 WM 14-0017, Reply to a Notice of Violation; EA-14-0242014-07-29029 July 2014 Reply to a Notice of Violation; EA-14-024 WO 13-0070, Reply to Notice of Violation EA-13-0842013-09-12012 September 2013 Reply to Notice of Violation EA-13-084 ET 13-0012, Request for Review of Information to Support Resolution of Example 2 of Non-cited Violation 05000482/2011007-03, Failure to Ensure Post-Fire Safe Shutdown Components Remain Free of Fire Damage2013-03-29029 March 2013 Request for Review of Information to Support Resolution of Example 2 of Non-cited Violation 05000482/2011007-03, Failure to Ensure Post-Fire Safe Shutdown Components Remain Free of Fire Damage WM 12-0039, Reply to Notice of Violation EA-12-1522012-10-18018 October 2012 Reply to Notice of Violation EA-12-152 WM 12-0023, Reply to Notice of Violation EA-12-1352012-08-0202 August 2012 Reply to Notice of Violation EA-12-135 WM 10-0029, Reply to Notice of Violation EA-10-1602010-10-11011 October 2010 Reply to Notice of Violation EA-10-160 WO 10-0012, Reply to Notice of Violation EA-10-004 and EA-10-0202010-03-11011 March 2010 Reply to Notice of Violation EA-10-004 and EA-10-020 WM 09-0065, Response to NRC Integrated Inspection Report 05000482/20090042009-12-0909 December 2009 Response to NRC Integrated Inspection Report 05000482/2009004 WM 09-0045, Revision to Reply to Notice of Violation EA-09-1102009-07-31031 July 2009 Revision to Reply to Notice of Violation EA-09-110 WM 09-0040, Reply to Notice of Violation EA-09-1102009-06-12012 June 2009 Reply to Notice of Violation EA-09-110 2021-12-29
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W LF CREEK NUCLEAR OPERATING CORPORATION September 12, 2013 Russell A. Smith Site Vice President and Chief Nuclear Operating Officer WO 13-0070 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555
Reference:
Letter dated August 14, 2013, from N. O'Keefe, USNRC, to M. W.
Sunseri, WCNOC
Subject:
Docket No. 50-482: Reply to Notice of Violation EA-1 3-084 Gentlemen:
In accordance with 10 CFR 2.201, the attachment provides Wolf Creek Nuclear Operating Corporation's (WCNOC) reply to Notice of Violation (NOV) EA-13-084 as contained in the Reference (Inspection Report 05000482/2013003).
This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4156, or Mr. Mike Westman at (620) 364-4009.
Sincerely, Russell A. Smith RAS/rlt Attachment cc: C. F. Lyon (NRC), w/a N. F. O'Keefe (NRC), w/a S. A. Reynolds (NRC), w/a Senior Resident Inspector (NRC), w/a P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HC/VET
- 3-tý-19
Attachment to WO 13-0070 Page 1 of 3 Reply to Notice of Violation (NOV) EA-13-084 Description of Violation Identified in NOV EA-13-084 10 CFR 50.9 requires, in part, that information required by statute, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects.
Wolf Creek License Condition 2.C.5, "Fire Protection," requires that the licensee shall maintain in effect all provisions of the approved fire protection program as described in the Standardized Nuclear Unit Power Plant System Final Safety Analysis Report. Section 9.5-1 of the Wolf Creek Updated Safety Analysis Report, dated March 10, 2013, describes the fire protection program and includes the licensee's commitment to meet Appendix 3A, "Conformance to NRC Regulatory Guides," and Appendix A, Table 9.5A-1 of Regulatory Guide 1.39, "Housekeeping Requirements for Water-Cooled Nuclear Power Plants," Revision 2. Regulatory Guide 1.39, Revision 2, endorses ANSI Standard N45.2.3-1973, "Housekeeping During the Construction Phase of Nuclear Power Plants."
ANSI Standard N45.2.3-1973, Section 3.5, states, in part, that periodic inspection and examination of the work areas shall be performed at scheduled intervals to assure adequacy of cleanliness and housekeeping practices. Section 4 of the above ANSI Standard states, in part, that copies of inspection and examination records shall be prepared and placed with other project records.
Section 6.1.8 of Procedure AP 12-001, "Housekeeping Control," Revisions 6C and 7, dated May 5, 2006, and November 10, 2008, respectively, intended to implement the inspection and examination requirements of ANSI Standard N45.2.3-1973, states, in part that "assigned personnel shall walk down their areas monthly" and that "personnel record and document their walkdowns using the Housekeeping Inspection Card."
Contrary to the above, between October and December 2008, the licensee failed to maintain records required by License Condition 2.C.5 that were complete and accurate in all material respects. Specifically, the Housekeeping Inspection Card for the spent fuel pool area indicated that the inspection had been completed by a certain individual. Security access logs, however indicated that the individual that completed the record (Housekeeping Inspection Card) had not entered the area. This information is material because it provides assurance to the NRC that the licensee has performed periodic inspection and examination of work areas at scheduled intervals to assure adequacy of cleanliness and housekeeping practices as required by the license condition.
Reason for the Violation Between October and December 2008, an individual documented that housekeeping observations in the spent fuel pool area had been completed. However, security access logs indicated that the individual that completed the record for the housekeeping observations had not entered the area. Following Quality Surveillance 31096, which originally reported the discrepancy between the housekeeping inspection cards and security access logs, the individual was interviewed in April 2009. There was willful misconduct by the individual both for the documentation of performance of the housekeeping observations in 2008 and by misrepresenting the facts in April 2009 during the initial investigation of this condition. A follow-up interview with the individual in October 2012 revealed that the individual documented the
Attachment to WO 13-0070 Page 2 of 3 housekeeping inspection for the spent fuel pool area between October and December 2008, but in fact did not perform the inspection or delegate the responsibility for the inspection.
The cause for the willful action could not be determined, as the responsible individual has resigned.
Corrective Steps That Have Been Taken and Results Achieved
- Following admission of falsifying housekeeping inspection cards for the spent fuel pool area, the responsible employee resigned October 18, 2012.
- Quality Assurance surveillance QS-2012-0314, Housekeeping Inspections, was completed December 12, 2012. QS-2012-0314 was a follow-up surveillance to Quality Surveillance 31096, which originally reported the discrepancy between the housekeeping inspection cards and security access logs between October and December 2008. Housekeeping inspection cards from April through September 2012 were reviewed for discrepancies between the housekeeping inspection cards and security access logs. All housekeeping inspection reports reviewed were confirmed to have occurred as reported.
- Station-wide publication, Crucial Times, September 11, 2013 edition published an article titled, "Maintaining a Strong Safety Culture is Key to Avoiding Willful Misconduct."
Crucial Times is distributed electronically to all employees. This article was identified as a face-to-face discussion between leadership and their direct reports. The content of the article is as follows:
"Because nuclear power is special and unique, we have a greater responsibility for protecting the health and safety of the public and are subject to higher standards.
Nuclear Regulatory Commission (NRC) regulations state that information required by statutes or by the Commission's regulations, orders or license conditions to be maintained by the applicant or licensee shall be complete and accurate. Deliberate misconduct, including willful falsification of records, by all personnel applying for unescorted access and working at Wolf Creek is strictly prohibited.
Recently, the NRC issued Information Notice 2013-15, "Willful Misconduct/Record Falsification and Nuclear Safety Culture." The notice addresses several incidents of willful misconduct and record falsification at U.S. nuclear sites. The document emphasizes the importance of establishing and maintaining an effective safety culture by applicants, licensees and their contractors. In several cases, the violation involved work or signatures involving supplemental employees with the appropriate licensee oversight.
Maintaining quality records is a requirement of our operating license. Company records that are applicable may include Access Screening paperwork, housekeeping inspections, qualifying examinations and work packages. It is our obligation to provide complete and accurate information. This includes reporting when that does not occur.
That is why it is important when providing your signature on any document that you ensure the information is accurate and that work performed under these guidelines has been completed as written. Failure to exercise proper regard for complete and accurate documents can be perceived by the NRC as deliberate misconduct, an offense punishable as a civil or criminal violation.
Attachment to WO 13-0070 Page 3 of 3 One way that we can minimize willful misconduct at Wolf Creek is to create a strong safety culture environment. Most importantly, it is critical that personnel understand station expectations and that consequences are clearly stated and understood, and they are encouraged to freely raise concerns or issues. The key behaviors for a healthy safety culture include personal accountability (including admitting mistakes),
demonstrating a questioning attitude and a willingness to raise concerns and engage with management in problem resolution. Trust and respect need to permeate each organization while communications maintain a focus on nuclear safety and leaders demonstrate a commitment to safety in their decisions and behaviors."
Corrective Steps That Will Be Taken to Avoid Future Violation A cascading message will be developed that starts with the Site Vice President and Chief Nuclear Operating Officer and cascades through the organization that facilitates a discussion on willfulness and personal integrity. This discussion will result in a personal signed letter by employees and long-term contractors attesting to/or certifying that they understand the expectations and consequences of willful misconduct.
The annual code of ethics review will be revised to encompass the entire code of ethics by station personnel, not just the conflict of interest considerations.
These corrective actions are being taken as part of our corrective action program but are not being taken to restore compliance.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.