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 4-2018-008

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

ML20358A272
Person / Time
Site:	Wolf Creek
Issue date:	12/23/2020
From:	Mccoy J Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-18-165, Investigation Report 4-2018-008, IR 2019010, OI 4-2018-008, WO 20-0058
Download: ML20358A272 (19)

Text

Jaime H. McCoy Site Vice President December 23, 2020 WO 20-0058 Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511

Reference:

Letter dated July 18, 2019, from S. A. Morris, USNRC, to A. C. Heflin, WCNOC, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008

Subject:

Docket No. 50-482: Wolf Creek Nuclear Operating Corporations Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008

Dear Mr. Morris,

On July 18, 2019, the Nuclear Regulatory Commission (NRC) issued Order EA-18-165 to Wolf Creek Nuclear Operating Corporation (WCNOC). The Reference summarizes corrective actions already taken by Wolf Creek that were discussed in the Alternative Dispute Resolution and additional commitments made in the preliminary settlement agreement.

Item Q in the Reference requires the submission in writing of the actions implemented under this Confirmatory Order, the results achieved, and any additional corrective actions initiated as a result of this Confirmatory Order. Sixteen items have been completed and a summary of the action closures are provided in the attachment to this letter. Further work continues to develop closure packages for the actions to aid in the inspection process.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4156, or Ron Benham (620) 364-4204.

Sincerely, Jaime H. McCoy JHM/rlt

WO 20-0058 Page 2 of 3

Attachment:

Wolf Creek Nuclear Operating Corporations Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008 cc: Document Control Desk (NRC), w/a Senior Resident Inspector (NRC), w/a

WO 20-0058 Page 3 of 3 STATE OF KANSAS )

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Jaime H. McCoy, of lawful age, being first duly sworn upon oath says that he is Site Vice President of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

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Attachment to WO 20-0058 Page 1 of 16 Wolf Creek Nuclear Operating Corporations (WCNOC) Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008 The following is a summary of actions implemented under Confirmatory Order EA-18-165 (Item Q). The Confirmatory Order commitments are being tracked in the Corrective Action Program under Condition Report (CR)134185.

Closed Commitment Summary Actions Item D Within 6 months of the issuance Communications developed a number of (134185- date of the Confirmatory Order, graphic elements and Communications 01-04, due Wolf Creek will complete its messages for Professional to the Core and date efforts to reinforce site the behaviors Treat Your Signature as Your 1/14/2020) expectations through posters Word, Look for, Understand, and Mitigate and the morning brief Risk, and Adhere to Procedures and communications, which will Follow the Rules. These behaviors were 134185 specifically address 10 CFR connected to communications regarding 04 was 50.9 and 10 CFR 50.5, and its documentation and 10 CFR 50.9.

closed in applicable Professional to the Communications on Treat Your Signature Asset Suite Core behaviors meant to as Your Word and other Professional to the on ensure high quality work and Core behaviors and were published in the 1/13/2020. high-quality work products. online biweekly employee newsletter and the outage daily newsletter during RF23 in 2019.

A series of visuals on these topics were developed in September 2019 and were included in the rotation of images on Wolf Creeks internal digital signage system, which are shown on approximately 25 TV displays across the station. Similar-style posters were developed in 2019 and were installed in January 2020. Slides on these topics were also developed for use on the back page of the daily Shift Manager Operational Focus Items for use in morning meetings.

Attachment to WO 20-0058 Page 2 of 16 Closed Commitment Summary Actions Within 6 months of the issuance A presentation titled, Treat Your Signature date of this Confirmatory Order, as Your Word, was developed and provided Item E Wolf Creek will develop a to the NRC for their review/approval. The (134185-presentation to be delivered to presentation includes: a discussion of the 01-05, due an appropriate industry forum initiating event, consequences, the date (e.g., Regional Utility Group or responsibility of 10 CFR 50.9, Professional 1/14/2020)

Strategic Teaming and to the Core Behaviors, corrective actions, Resource Sharing) subject to communication actions, and training actions.

134185 acceptance of the conference 05 was organizing committees.

closed in Asset Suite on 1/14/2020.

Item H Within 6 months of the issuance Benchmarking was conducted at Diablo (134185- date of this Confirmatory Order, Canyon from 12/2/2019 to 12/3/2019 and at 01-08, due Wolf Creek will benchmark 2 South Texas from 1/6/2020 to 1/7/2020. The date other licensee sites to benchmark at both sites was specifically 1/14/2020) determine how other licensees focused on determining how the licensee detect and address incomplete detects and addresses incomplete and and inaccurate information, inaccurate information, including falsified 134185 including falsified records, and records. Additional benchmarking was 08 was then develop actions from the conducted on the topics of Employee closed in benchmarks as appropriate. Concerns, Corrective Action Program and Asset Suite Regulatory Affairs. The full benchmark on report is captured within self-assessment 1/13/2020. report SA 2019-0149.

Findings from each station are as follows:

Diablo Canyon benchmarking results:

Recent Operating Experience (OE) and corrective actions related to record related violations within the company (Diablo Canyon) as well as in the nuclear industry (WC) highlighted the need for increased focus and attention on record accuracy and integrity, record verification and communication. To improve performance, Diablo Canyon created a Records Integrity Verification initiative which was kicked off in 2Q19. This initiative is currently underway in several departments including Security, Operations, Radiation Protection, Chemistry, Engineering, Maintenance and Cyber Security. The initiative focuses on industry OE and implements industry best

Attachment to WO 20-0058 Page 3 of 16 practices in the areas of independent assessment of record accuracy, regular communication, and training. These enhancements helped improve station awareness on the importance of records accuracy and impacts of willful violations and nuclear safety culture. This initiative was rolled out from the top down as an expectation for station leaders to integrate this into their everyday business. The new program owner for Integrity Verification met face to face with each department manager to determined how to implement this process specific to their department. Example - Fire watch may pull 20 records a quarter and verify them for completeness and accuracy where Chemistry may pull 9. Numbers are based on total number of quality records produced in a quarter and areas of concern.

If there were to be a finding as a result of the preliminary sample, the scope would be increased to look at additional records from that time period. Their Nuclear Safety Culture Panel looks at the results each quarter. Integrity Verification has been added to their New Employee On-Boarding, site specific Nantel training and communications are sent out prior to and during outage focused on willful misconduct (what it is and the consequences).

South Texas Benchmarking Results:

Recently South Texas has had concerns in the area of Fire Protection documentation as documentation has been falsified. South Texas does not have a formal process to recognize inconsistencies or falsification/errors. They rely on Quality audits to periodically review documentation and look for errors. Other than Quality, they only investigate potential for errors if there is a question or a condition report is written alleging an error may have taken place. It was recommended in a 2019 Regional Utility Group - Region IV (RUGIV) meeting for each station to go back to their site and look into what their station was doing regarding an integrity verification plan. Since that meeting, the Manager of Regulatory Affairs has retired, and a new Manager has been

Attachment to WO 20-0058 Page 4 of 16 hired. The recently hired manager was not aware of the RUGIV discussion regarding an Integrity Verification plan.

South Texas is using Operating Experience to identify and communicate 10CFR50.7 and 50.9 issues. A condition report was written in 2019 that identified 50.9 issues at Wolf Creek and Watts Bar. The operating experience was shared with all licensed operators and operations instructors.

Condition Reports written as a result of the benchmarks are CR 139819 - Records Integrity Verification, CR 139820 -

Corrective Action Program Improvement, CR139822 - Regulatory Affairs Practices, and CR 139821 - Employee Concerns Program Recommendation.

Item J Within 12 months of the The Maintenance Director performed (134185- issuance date of this training (MG8310801) during the 2Q20 01-10, due Confirmatory Order, Wolf Creek Maintenance Team Matters (MTM) re-date will provide training to all enforcing the documentation expectations 7/18/2020) maintenance personnel (craft, and the procedural requirements for work supervisors, and managers) that order implementation, expectations for work describes work order process order timeliness, signature and initial 134185 timeliness, signature or initial requirements, and the initiation of a 10 was requirements, and the process condition report if incomplete documentation closed in to follow if documents are is found and cannot be corrected by the Asset Suite incomplete (e.g., missing individuals that performed the work.

on signatures). Subsequently, a Attendance was taken for the training.

7/14/2020. training request will be initiated to analyze training frequency on this topic and Wolf Creek will follow its training process to completion.

Item K Within 12 months of the As a part of the consolidation efforts of the (134185- issuance date of this merger of Westar Energy and 01-11, due Confirmatory Order, Wolf Creek Great Plains Energy to form Evergy Inc., a date will implement annual new computer-based Code of 7/15/2020) compliance and ethics training Ethics (COE) training module (GT0335501) to all employees to address 10 was delivered to all Evergy employees, CFR 50.9 and 10 CFR 50.5, including WCNOC employees. WCNOC staff 134185 compliance therewith, and completed the computer-based training on 11 was consequences for non- COE between January and April of 2020.

closed in compliance. In addition, the Training attendance was taken. The training Asset Suite training will describe what it was developed by Evergy, and contained on means when an individual signs WCNOC specific material, but did not 7/15/2020. or initials a document. address the additional required elements related to 10 CFR 50.9 and 10 CFR 50.5 as stated in Commitment K of the

Attachment to WO 20-0058 Page 5 of 16 Confirmatory Order. The remaining elements have been covered in other forums such as:

+ Chief Nuclear Officer (CNO) communication to all WCNOC employees and supplemental personnel regarding lack of tolerance for willful violations, the importance of procedure adherence and potential consequences for engaging in willful violations (Confirmatory Order Commitment A completed on October 29, 2019).

+ Station leadership held meetings with all WCNOC employees and long-term contractor personnel to address integrity and trustworthiness, based on talking points and a Treat Your Signature as Your Word presentation, which included a video from the CNO (Confirmatory Order Commitment B completed on November 14, 2019).

+ Accuracy and Completeness of Documentation training was held for all badged personnel, including supplementals.

This training provided a) expectations for completeness and accuracy in documentation; b) the expectation to stop when unsure; c) the expectation to write a condition report if encountering unexpected conditions; and d) what it means when an individual signs or initials a document (Confirmatory Order Commitment I completed on November 13, 2019). All elements of Confirmatory Order Commitment K are being added to the Code of Ethics training which will be provided in 2021. CR action 134185-01-24 is tracking the addition of all required elements from the Confirmatory Order in the COE training with a due date of 2/19/2021.

Attachment to WO 20-0058 Page 6 of 16 Closed Commitment Summary Actions Item L Within 6 months of the On 4/30/2020 self-assessment SA-2020-(134185- completion of refueling outage 0156 was completed which reviewed work 01-12, due 23, Wolf Creek will perform a order documentation quality by sampling date self-assessment on work order more than 40 quality-related sub- work order 4/29/2020) documentation quality by packages performed during the Refuel 23.

sampling 40 quality-related sub- The SA was presented to CARB on work order packages performed 4/28/2020. The work order packages 134185 during the refueling outage. selected included substantial in-field work.

12 was The work order packages The sample scope was approved by the closed in selected shall include Regulatory Affairs Director and provided to Asset Suite substantial in-field work. The the Wolf Creek NRC resident staff.

on sample scope will be approved The self-assessment team was led by the 4/29/2020. by the regulatory affairs Maintenance supervisor of the Central manager and provided to the Processing Center with team members that Wolf Creek NRC resident staff. consisted of a Control Room Supervisor, a The assessment team Maintenance Specialist in Corrective Action composition shall include an Program, a Quality Control Supervisor, a external peer in addition to Maintenance Office Assistant that works in station personnel. The results the Central Processing Center and an of the self-assessment will be external peer from Callaway who was the reviewed by the Corrective Senior Manager Maintenance and has Action Review Board and previously been their Outage Manager and a documented in the corrective Shift Manager/Senior Reactor Operator.

action program system.

A review of the selected work orders was performed to ensure procedural compliance in each of the focus areas. The team determined criteria based on procedural reviews and identified those requirements that used the terms should or shall be performed by either the workers or the reviewers. The team lead also met with the Supervisor Document Services and a long-term Document Services Analyst to determine the criteria that would be used when evaluating the work orders for compliance with AP 15A-003, Records.

During these reviews, the team found documentation issues in AP 15C-002, Procedure Use and Adherence and AI 16C-008, Work Order Implementation. The less than adequate behaviors include incomplete documentation or incomplete records and inconsistent use of place-keeping and documentation of N/A standards that were not followed.

Attachment to WO 20-0058 Page 7 of 16 While there were deficiencies identified and CRs written in each of the focus areas, the areas of M&TE and Surveillance Testing were overall satisfactory. In the areas of Procedure Use and Adherence and Work Order Implementation, several instances of incomplete documentation or incomplete records were identified during the review.

These deficiencies were not isolated to any one work group and apply to most organizations across the site. Although individuals were contacted, and the complete story was communicated or could be re-created, the sites documentation does not tell the complete story on its own.

Workers are not stopping when work cant be performed as written. Even though the team did not identify any nuclear safety concerns or conditions that would impact operability, the records reviewed do not meet station standards or the requirements of 10CFR50, Appendix B, Quality Assurance Records. (CR 141957 has been generated to capture this condition.) Twenty-one additional condition reports were initiated to capture identified deficiencies. The team did not identify any signs of misconduct or intentional falsification of records.

Attachment to WO 20-0058 Page 8 of 16 Closed Commitment Summary Actions Item P By December 31 of 2020, 2021, This effectiveness follow-up (EFU) is (134185- and 2020, Wolf Creek will documented in self-assessment SA-2020-01-16, due perform an annual effectiveness 0154 and was approved by the Director date review of its corrective actions Regulatory Affairs on 12/14/2020. The self-12/31/2020) associated with the assessment was reviewed and accepted Confirmatory Order. The with comments by CARB on 12/22/2020 and annual effectiveness review will comments were incorporated and verified on 134185 include the insights from 12/23/2020. The annual effectiveness review 16 was benchmarks, site performance, included insights from benchmarks, site closed in self-assessments, and safety performance, self-assessments, and safety Asset Suite culture surveys. Wolf Creek will culture surveys. The review concluded that on modify its corrective actions, as with a few exceptions, CR corrective actions 12/15/2020. needed and consistent with this were closed with quality in a timely manner.

Confirmatory Order, based on Conditions reports have been generated to the results of the annual correct the identified closure deficiencies.

effectiveness review.

The actions taken have been effective and additional CRs have been noted in this assessment where improvement areas were identified.

Additionally, it is concluded that no modifications are needed to the corrective actions contained in the confirmatory order at this time.

Item Q By December 31 of each year A summary of actions completed in 2019 (134185- until 2023, Wolf Creek will were submitted to the NRC Regional 01-19, due provide in writing to the Administrator on 12/23/2019 via letter WO-date Regional Administrator, Region 19-0059.

12/31/2019) IV, a summary of the actions implemented under this Confirmatory Order, the results 134185 achieved, and any additional 19 was corrective actions initiated as a closed in result of this Confirmatory Asset Suite Order.

on 12/30/2019.

Attachment to WO 20-0058 Page 9 of 16 Results Achieved:

1) Increased site awareness of 10 CFR 50.5, Deliberate misconduct and 10 CFR 50.9, Completeness and accuracy of information, through site communications and graphic elements which focused on Treat Your Signature as Your Word, Look for, Understand, and Mitigate Risk, and Adhere to Procedures and Follow the Rules.

2) Benchmarking was conducted at Diablo Canyon and South Texas specifically focused on determining how the licensee detects and addresses incomplete and inaccurate information, including falsified records. Condition reports were initiated from the benchmarking.

3) Maintenance personnel received training on the procedural requirements for work order implementation, expectations for work order timeliness, signature and initial requirements, and the initiation of a condition report if incomplete documentation is found and cannot be corrected by the individuals that performed the work.

4) Implemented annual training on 10 CFR 50.5 and 10 CFR 50.9 which includes the consequences for non-compliance.

5) Completed a self-assessment which included the review of more than 40 quality-related sub-work order packages performed during the Refuel 23. The team did not identify any signs of misconduct or intentional falsification of records. Condition reports were initiated to correct any documentation issues identified.

Condition Report

References:

1. Condition Report 134185, Confirmatory Order Letter Receipt and Action Tracking

2. Condition Report 131147, Proposed SLIV Traditional Enforcement Violation

3. Condition Report 139819, Records Integrity Verification

4. Condition Report 141957, SA-2020-0156, Area for Improvement

Attachment to WO 20-0058 Page 10 of 16 The following actions were submitted to the NRC on 12/23/2019 via letter WO 19-0059 Closed Commitment Summary Actions Item A Within 1 month of the issuance date of On 8/14/2019, the Chief Nuclear (134185- the Confirmatory Order, Wolf Creek will Officer (CNO) released a Corporate 01-01, due issue a stand-alone communication Communications stand-alone date from the Chief Nuclear Officer to all electronic mail message to WCNOC 8/20/2019) employees and contractor personnel employees that reiterated that willful that willful violations will not be violations will not be tolerated, tolerated. The communication will stressed the importance of 134185 stress the importance of procedural procedural adherence and 01 was adherence, ensuring that documents consequences for willful violations, closed in are complete and accurate, and of recognized that people make Asset Suite potential consequences for engaging in mistakes, and that on willful violations. This message will be employees/contractors should 8/20/2019. balanced with the recognition that identify and document issues in people do make mistakes and when accordance with procedures.

that happens, it is Wolf Creek's expectation that its employees and After this initial communication was contractors will identify and document electronically mailed, it was issues in accordance with licensee recognized that not all supplemental procedures. personnel, particularly those without site e-mail access, received the CNOs message. CR 135634 was initiated on 9/17/2019 to capture this in the Corrective Action Program.

To address CR 135634, the action taken was to mail the initial CNO communication through the U.S.

Postal Service. Active WCNOC employees addresses were obtained through the Human Resources program People Soft, and supplemental personnels mailing addresses were obtained from Access Screening. A total of 1,776 letters were mailed, comprised of 863 active WCNOC employees and 913 supplemental personnel. The letters were taken to the Burlington, KS Post Office on 10/15/2019. CR 135634 was closed on 10/29/2019.

Attachment to WO 20-0058 Page 11 of 16 Closed Actions Commitment Summary Item B Within 4 months of the issuance date Leadership held meetings with all (134185- of the Confirmatory Order, Wolf Creek Wolf Creek employees and long-term 01-02, due will hold meetings with all employees contractor personnel to address date and long-term contractor personnel to integrity and trustworthiness, based 11/15/2019) address integrity and trustworthiness. on the material provided through an The meetings will: (1) stress the 8/27/2019 Leaders Digest importance of procedural adherence, communication. This material 134185 ensuring that documents are complete included Talking Points and a Treat 02 was and accurate, and of potential Your Signature as Your Word closed in consequences for engaging in willful presentation, which included a video Asset Suite violations; (2) describe the from the CNO.

on circumstances of this case, the results 11/14/2019. of the root cause evaluation, and Wolf Through the use of the Talking Creek's corrective actions; (3) include Points, the meetings and the expectation to immediately raise presentation 1) stressed the safety concerns when observed; (4) importance of procedural adherence, address how to proceed when work documents are complete/accurate, order documentation is incomplete. potential consequences for willful violations; 2) described circumstances of case, results of root cause and Wolf Creeks corrective actions; 3) included expectation to immediately raise safety concerns when observed; 4) addressed how to proceed when Work Order documentation is incomplete.

Evidence of meetings resides in the attendance sheets that were used to track completion.

Attachment to WO 20-0058 Page 12 of 16 Closed Commitment Summary Actions Item C Within 4 months of the issuance date of CERTREC provided a list of 10 CFR (134185- the Confirmatory Order, Wolf Creek will 50.9 and 10 CFR 50.5 violations and 01-03, due reinforce expectations with regards to enforcement actions for the last 5 date 10 CFR 50.9, completeness and years, as of 10/22/2019. An 11/15/2019) accuracy of information, and 10 CFR additional column was added to 50.5, deliberate misconduct, by identify the pertinent departments providing an overview of the last 5 that need to review each example.

134185 years of pertinent NRC enforcement 03 was actions with Operations, Fire Watch, On 10/31/2019, a common database closed in Maintenance, and Radiation Protection export of active WCNOC employees Asset Suite staff. was pulled to identify personnel on within the Operations, Maintenance 11/14/2019. and Radiation Protection (RP) departments. The Qual Tool was then used to identify personnel with a Fire Watch qualification, so that they could be pulled into the spreadsheet for proper coverage in this action.

There were 508 employees identified.

An email communication, with the CERTREC results attached, was sent to the leadership of those identified as Operations, Fire Watch, Maintenance and RP. This communication was to be discussed in morning meetings or regularly scheduled staff meetings to reinforce expectations and the significance of accurate and complete documentation with their applicable personnel. Talking points were also provided, and included details of the proposed violation, summaries of the CERTREC results by pertinent departments and final takeaways.

An additional email communication was then sent to the 508 Operations, Fire Watch, Maintenance and RP personnel (including the talking points and CERTREC results) to reinforce the significance of accurate and complete documentation.

Attachment to WO 20-0058 Page 13 of 16 Closed Commitment Summary Actions Item G Within 3 months of the issuance date of Condition Report 131147 was written (134185- the Confirmatory Order, Wolf Creek will on 3/27/2019 to document a 01-07, due complete a root cause analysis of the potentially escalated greater than date circumstances that led to the Severity Level IV Traditional 10/16/2019) incomplete and inaccurate information Enforcement violation concerning the violation and develop corrective failure to meet 10CFR50.9, actions. Completeness and accuracy of 134185 information. This CR was screened 07 was as a Root Cause. The root cause closed in analysis was completed and Asset Suite approved by the Corrective Action on Review Board (CARB) on 5/28/2019.

10/15/2019. The evaluation was closed on 6/12/19.

On 8/20/2019, CR 134871 was initiated due to a review of the root cause analysis determining that changes to the document, including an additional contributing cause, would provide a more complete analysis. Revision 1 of the root cause analysis was completed and approved by CARB on 10/14/2019.

The root cause was determined to be the Control Rod Drive Mechanism (CRDM) installation and removal status was not formally tracked by either work order. The corrective action to prevent recurrence (CAPR) was to revise procedure MCM BB-007, Installation and Removal Canopy Seal Clamp Assemblies (CSCA), to incorporate a step in the prerequisites to state that if CRDMs/Digital Rod Position Indicators (DRPIs) are to be removed during the evolution, then the implementing work order shall provide a formal method for tracking and verification of which CRDMs/DRPIs are removed and re-installed on the reactor vessel head:

Revision 7 of MCM BB-007 was released on 6/25/2019 to address the CAPR.

Attachment to WO 20-0058 Page 14 of 16 Two contributing causes were identified: (1) Technicians performing the work failed to fully document progress in the work order during work execution, and (2) Employees 1 and 2 failed to correctly respond to incomplete documentation identified in the work order.

Closed Commitment Summary Actions Item I Within 4 months of the issuance date of Accuracy and Completeness of (134185- this Confirmatory Order, Wolf Creek Documentation training was held for 01-09, due will provide in-person training to station all badged personnel (including date staff (employees and long-term supplementals) in July and August 11/15/2019) contractors) that emphasizes 2019, with a schedule of 31 regular expectations for completeness and class offerings. There were also accuracy in documentation, the specific sessions for Operations, and 134185 expectation to stop when unsure, the sessions were built into existing cycle 09 was expectation to write a condition report if training for Maintenance, RP and closed in encountering unexpected conditions, Security. Evidence of training Asset Suite and what it means when an individual completion was tracked.

on signs or initials a document. Wolf 11/13/2019. Creek will add training on these This training provided a) expectations subjects to initial or "onboarding" for completeness and accuracy in training. The scope of the initial training documentation; b) expectation to stop may differ between Wolf Creek when unsure; c) expectation to write employees and contractors. a CR if encountering unexpected conditions; and d) what it means when an individual signs or initials a document.

Accuracy and Completeness of Documentation has been added to the onboarding training that occurs every six months for new personnel, which includes long-term contractors (active > 180 days).

Attachment to WO 20-0058 Page 15 of 16 Closed Commitment Summary Actions Item N Within 4 months of the issuance date of A Nuclear Safety Culture Survey was (134185- the Confirmatory Order, Wolf Creek will conducted June/July 2019 using the 01-14, due conduct a nuclear safety culture survey Utilities Service Alliance (USA) date developed by a third-party. survey method. The survey was 11/15/2019) followed by a Nuclear Safety Culture Assessment (NSCA) conducted August 12-15, 2019. The NSCA was 134185 led by a member of USA with the 14 was team consisting of both external closed in peers and WCNOC employees. The Asset Suite final NSCA report was received on on 9/12/ 2019. Overall, the assessment 11/04/2019. team noted that WCNOC has a safety culture that supports all of the INPO Traits of a Healthy Nuclear Safety Culture, has a respect for nuclear safety, and assures that nuclear safety is not compromised by production priorities. There were no Strengths or Weaknesses identified.

Condition reports were generated for the Negative, Positive and General Observations.

Attachment to WO 20-0058 Page 16 of 16 Results Achieved:

1) Increased site awareness of 10 CFR 50.5, Deliberate misconduct and 10 CFR 50.9, Completeness and accuracy of information, with Operations, Fire Watch, Maintenance and RP staff through electronic communication and leadership meetings with their reports.

2) Provided in-person training to WCNOC and long-term contractors that emphasized the expectation for completeness and accuracy in documentation, the expectation to stop when unsure, the expectation to write a condition report if encountering unexpected conditions, and what it means when an individual signs or initials a document.

3) Added Accuracy and Completeness of Documentation to onboarding training that occurs every six months for new personnel.

4) Increased site awareness through written and electronic communication that willful violations will not be tolerated, the importance of procedural adherence, ensuring that documents are complete and accurate, the potential consequences for engaging in willful violations, and the expectation to identify and document issues.

5) Completed the corrective action to prevent recurrence to address the root cause of the escalated Severity Level Determined that WCNOC has a safety culture that supports all of the INPO Traits of a Healthy Nuclear Safety Culture, has a respect for nuclear safety, and assures that nuclear safety is not compromised by production priorities.

6) Determined that WCNOC has a safety culture that supports all of the INPO Traits of a Healthy Nuclear Safety Culture, has a respect for nuclear safety, and assures that nuclear safety is not compromised by production priorities.

Condition Report

References:

1. Condition Report 135634, Confirmatory Order Action A Concern

2. Condition Report 134185, Confirmatory Order Letter Receipt and Action Tracking

3. Condition Report 131147, Proposed SLIV Traditional Enforcement Violation

4. Condition Report 134871, Issue with Documentation Practices