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{{Adams
#REDIRECT [[IR 05000482/2005004]]
| number = ML060120484
| issue date = 01/12/2006
| title = NRC IR 05000482-2005-004 Errata Letter for Inspection Conducted on June 27 - July 1, 2005
| author name = Shannon M
| author affiliation = NRC/RGN-IV/DRS/PSB
| addressee name = Muench R
| addressee affiliation = Wolf Creek Nuclear Operating Corp
| docket = 05000482
| license number = NPF-042
| contact person =
| document report number = IR-05-004
| document type = Inspection Report, Letter
| page count = 6
}}
See also: [[see also::IR 05000482/2005004]]
 
=Text=
{{#Wiki_filter:January 12, 2006Rick A. Muench, President and  Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
 
P.O. Box 411
Burlington, KS  66839 Wolf Creek Nuclear Operating CorporationSUBJECT:NRC INSPECTION REPORT 05000482/2005004Dear Mr. Muench:Because of an error in documenting the completed inspection scope for the ALARAinspection conducted June 27 - July 1, 2005, insert the enclosure to this letter as replacements
for pages 13 - 15 of NRC Inspection Report 05000482/2005004.Please accept my apology for any inconvenience these actions may have caused.Sincerely, //RA//
Michael P. Shannon, ChiefPlant Support Branch
Division of Reactor SafetyDocket:  50-482License: NPF-42Enclosure:Pages 13 - 15 of NRC Inspection Report 05000482/2005004cc w/enclosure:
Vice President Operations/Plant ManagerWolf Creek Nuclear Operating Corp.
 
P.O. Box 411
Burlington, KS  66839
Wolf Creek Nuclear Operating Corp.-2-Jay Silberg, Esq.Shaw Pittman, LLP
2300 N Street, NW
Washington, DC  20037Supervisor LicensingWolf Creek Nuclear Operating Corp.
 
P.O. Box 411
Burlington, KS  66839Chief EngineerUtilities Division
Kansas Corporation Commission
1500 SW Arrowhead Road
Topeka, KS  66604-4027Office of the GovernorState of Kansas
Topeka, KS  66612Attorney General120 S.W. 10th Avenue, 2nd Floor
Topeka, KS  66612-1597County ClerkCoffey County Courthouse
110 South 6th Street
Burlington, KS  66839-1798Chief, Radiation and Asbestos  Control Section
Kansas Department of Health and
  Environment
Bureau of Air and Radiation
1000 SW Jackson, Suite 310Topeka, KS  66612-1366
Wolf Creek Nuclear Operating Corp.-3-Electronic distribution by RIV:Regional Administrator (BSM1)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (SDC)Resident Inspector (TBR2)SRI, Callaway (MSP)Branch Chief, DRP/B (WBJ)Senior Project Engineer, DRP/B (RAK1)Team Leader, DRP/TSS (RLN1)RITS Coordinator (KEG)Only inspection reports to the following:DRS STA (DAP)J. Dixon-Herrity, OEDO RIV Coordinator (JLD)ROPreports
WC Site Secretary (SLA2)SUNSI Review Completed:  __Yes____ADAMS:  Yes G  No    Initials: GLG____    Publicly Available     
G  Non-Publicly Available     
G  Sensitive  Non-SensitiveS\DRS\DRSLTRS\WC2005004errata.wpdRIV: DRS/PSB/HPIC:PSBGLGuerraMPShannon
/RA//RA/
1/ 12  /061/ 12  /06OFFICIAL RECORD COPY T=Telephone          E=E-mail        F=Fax
-13-Enclosure*Self-assessments, audits, and special reports related to the ALARA programsince the last inspection*Effectiveness of self-assessment activities with respect to identifying andaddressing repetitive deficiencies or significant individual deficiencies *Radiation worker and radiation protection technician performance during work
lactivities in radiation areas, airborne radioactivity areas, or high radiation areas
lThe inspector completed 7 of the required 15 samples and 7 of the optional samples.
l b.FindingsNo findings of significance were identified.
4.OTHER ACTIVITIES4OA2Identification and Resolution of ProblemsResident Inspector Annual Sample Review    a.Inspection ScopeThe inspectors evaluated the effectiveness of WCNOC's corrective action program asapplied to corrective action document PIR 2005-2142.  This document was initiated to
address the conditions and events that led to the inoperability of both site fire protectionpumps.  Attributes considered during this review included the following: *Completeness, accuracy, and timeliness of problem identification *Operability and reportability evaluation *Extent of condition evaluation
*Apparent cause evaluation 
*Prioritization
*Corrective action effectiveness
 
The inspectors completed one sample.
 
      b.FindingsFailure to Follow the Clearance Order ProcedureIntroduction:  An apparent violation (AV) of Technical Specification 5.4.1a occurredwhen station personnel failed to follow Procedure AP 21E-001, "Clearance Orders," and
manipulated a component inside a fire protection piping clearance boundary without
instructions and authorization.  The starting of a temporary fire pump resulted in water
-14-Enclosurespraying on the controller of the operable diesel-driven fire pump through an open ventvalve, which rendered the pump inoperable.Description:  On June 30, 2005, the motor of the electric fire pump experienced a shortin its winding which led to a fire at the motor.  The plant took the appropriate
compensatory measures and started parallel paths to restore the fire suppression water
system within the allotted 14 days.  One path involved a temporary modification to thefire protection system that installed a temporary motor-driven fire pump, which was
accomplished on July 11, 2005.  The temporary fire pump was tested on July 12, 2005,
to verify it would provide the required flow of water suppression; however, the pump
failed this test.  Station fire protection personnel requested a clearance order to isolate the temporaryfire pump from the fire protection piping but failed to make station operations personnel
aware of the desire to run the temporary fire pump following repairs.  Once repairs to
the pump were completed, the vendor under the direction of station fire protectionpersonnel started the pump believing they had authorization to operate the temporaryfire pump.  This resulted in water issuing from an open vent valve which sprayed the
controller of the diesel-driven fire pump.  Station fire protection personnel discovered the
wet controller and notified the control room.  Control room personnel declared the
diesel-driven fire pump inoperable.  The diesel-driven fire pump was returned to service
in approximately 4 hours.  The inspectors reviewed Procedure AP-10-103, Fire Protection Impairment Control, Revision 19, which identified the compensatory measures for the loss of fire
suppression water systems.  With the motor driven and the diesel driven fire pumpinoperable (approximately 4 hours) the impairment control procedure required that abackup fire pump be provided within 24 hours.  In this case, both the motor driven and
the diesel driven fire pumps were restored within approximately 18 hours.  This issue
involved human performance crosscutting aspects associated with station personnel notfollowing a station procedure.Analysis:  The failure to follow station procedures is a performance deficiency.  Thefinding was determined to be more than minor because it affected the mitigating
systems cornerstone objective of ensuring the availability, reliability, and capability ofsystems that respond to initiating events to prevent undesirable consequences.  Usingthe Phase 1 worksheets in Manual Chapter 0609, "Significance Determination Process,"
the finding was determined to degrade the fire protecti
on system suppression and wasevaluated using Appendix F, Fire Protection Significance Determination Process.  This
finding requires a Phase 3 analysis and is currently under evaluation.  Wolf Creek
Nuclear Operating Corporation entered this finding into their corrective action program
as PIR 2005-2142 Enforcement:  Technical Specification 5.4.1a requires procedures be implemented inaccordance with Regulatory Guide 1.33, Revision 2, Appendix A.  RegulatoryGuide 1.33, Appendix A, Section 9, requires procedures for the performance of stationmaintenance.  Contrary to the above, on July 13, 2005, station personnel operated
-15-Enclosurecomponents inside an established fire protection piping clearance boundary withoutwork instructions or control room authorization as required by Station
Procedure AP 21E-001, "Clearance Orders," Section 6.6.8.  This resulted in an adjacent
diesel-driven fire pump becoming inoperable.  Pending determination of the final safety
significance of this issue, this violation is being treated as an AV consistent with
Section VI.A of the NRC Enforcement Policy:  AV 05000482/0500404, manipulation ofplant component without proper authorization results in inoperable fire protection pumps.Corrective Action EffectivenessThere were no findings identified that were associated with the corrective actions for thisevent.  However, the inspectors made the following observations from their review of the
apparent cause evaluation and the associated corrective actions:  The apparent cause
evaluation states that some fire protection personnel are unfamiliar with the clearanceorder program because, for them, clearance orders are infrequently performed
evolutions.  Additionally, the evaluation states that some "groups" mistakenly believed itwas acceptable to work on vendor equipment inside clearance order boundaries without
proper authorization or an approved procedure.  These evaluation results suggest a
clearance order program knowledge deficiency within the fire protection group.  Yet, the
corrective action for these contributing causes was counseling only the one individual
involved with this event. .2Cross-References to Problem Identification & Resolution Findings DocumentedElsewhereSection 1R15 documents a condition where station personnel did not properly evaluatea condition adverse to quality regarding debris in the auxiliary feedwater flowtransmitters..3Access Control to Radiologically Significant Areas and ALARA InspectionsSection 2OS1 evaluated the effectiveness of WCNOC's problem identification andresolution processes regarding access controls to radiologically significant areas and
radiation worker practices.  The inspectors reviewed corrective action documents for
root cause/apparent cause analysis against WCNOC's PI&R process.  No findings of
significance were identified.Section 2OS2 evaluated the effectiveness of WCNOC's PI&R processes regardingexposure tracking, higher than planned exposure levels, and radiation worker practices.
The inspector reviewed the corrective action documents listed in the attachment against
WCNOC's PI&R program requirements.  No findings of significance were identified.
}}

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