ML20055E113

WC2019006 Annual Assessment Letter

ML20055E113
Person / Time
Site:	Wolf Creek
Issue date:	03/03/2020
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Reasoner C Wolf Creek
References
IR 2019006
Download: ML20055E113 (6)

Text

March 3, 2020 Mr. Cleve Reasoner, Chief Executive Officer and Chief Nuclear Officer Wolf Creek Nuclear Operating Corp.

P.O. Box 411 Burlington, KS 66839

SUBJECT:

ANNUAL ASSESSMENT LETTER FOR WOLF CREEK GENERATING STATION (REPORT 05000482/2019006)

Dear Mr. Reasoner:

The U.S. Nuclear Regulatory Commission (NRC) has completed its end-of-cycle performance assessment of Wolf Creek Generating Station, reviewing performance indicators, inspection results, and enforcement actions from January 1, 2019, through December 31, 2019. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility. The NRC concluded that overall performance at your facility preserved public health and safety.

The NRC determined the performance at Wolf Creek Generating Station during the most recent quarter was within the Licensee Response Column, the highest performance category of the NRCs Reactor Oversight Process (ROP) Action Matrix, because all inspection findings had very low safety significance (i.e., Green) and all performance indicators were within the expected range (i.e., Green). Therefore, the NRC plans to conduct ROP baseline inspections at your facility.

On December 17, 2018, the NRC issued a Severity Level II Notice of Violation and Proposed Imposition of Civil Penalty associated with a violation of 10 CFR 50.7, Employee Protection, for actions Wolf Creek took in response to a contract employee raising nuclear safety concerns (Agency Documents Access and Management System (ADAMS) Accession No. ML18333A043). On January 15, 2019, Wolf Creek notified the NRC of its acceptance of the violation (ADAMS ML19024A206). Therefore, the NRC plans to conduct Inspection Procedure 92722, Follow Up Inspection for Any Severity Level I or II Traditional Enforcement Violation or For Two or More Severity Level III Traditional Enforcement Violations in a 12 Month Period, to follow up on this violation.

From August 2018 through August 2019, the NRC issued four Severity Level IV non-cited violations associated with impeding the regulatory process. Therefore, the NRC plans to conduct Inspection Procedure 92723, Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, to follow up on these violations.

The 92722 and the 92723 inspections will be scheduled together after you provide written notification to the NRC of your readiness for the inspection.

C. Reasoner 2 On July 18, 2019, the NRC issued a Confirmatory Order (EA-18-165) documenting the commitments made as part of a settlement agreement between Wolf Creek and the NRC. The settlement agreement relates to the apparent violation of NRC requirements as discussed in our letter dated April 2, 2019 (ADAMS ML19092A335). That letter provided you with the results of an investigation conducted by the NRC's Office of Investigations at the Wolf Creek Generating Station to determine whether a maintenance worker and a supervisor willfully documented inaccurate information in a required record regarding the cleaning and inspection of control rod drive mechanisms on October 31, 2016. Therefore, the NRC plans to conduct Inspection Procedure 92702, Follow Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, And Alternative Dispute Resolution Confirmatory Orders to follow up on your actions to address these commitments.

The schedule for this inspection will be decided at a later date since the Confirmatory Order contains actions that are due in 2023.

The NRC notified you in the 2017 annual assessment letter (ADAMS ML19024A206) of a cross-cutting theme related to the inconsistent implementation of Safety-Conscious Work Environment (SCWE) Policy (S.1). The NRC conducted several inspections to assess the corrective actions taken to address this theme (Inspection Reports 05000482/2018007 (ADAMS ML18218A265), 05000482/2018004 (ADAMS ML19042A089), 05000482/2019002 (ADAMS ML19225D316), and 05000482/2019004 (ADAMS ML20035C736). Based on these inspections and our review of your actions taken and planned, as well as the issuance of the aforementioned violation of 10 CFR 50.7, the NRC determined that a theme in the SCWE area continues to exist. In the 2018 annual assessment letter, the NRC informed you of our plan to conduct Inspection Procedure 93100, Safety-Conscious Work Environment Issue of Concern Follow-up, to assess your progress in addressing the open SCWE theme at Wolf Creek.

However, the NRC no longer plans to conduct this inspection for the following reasons:

Your corrective action plan has been reviewed and is extensive and thorough in addressing the problems and underlying causes.

Three semiannual inspections have concluded that you completed many of the planned actions and improvement has been noted.

The last of the current SCWE theme inputs will expire in June 2020 and no new inputs for a SCWE theme have been identified.

Nevertheless, if there is another SCWE theme input identified during 2020, an SCWE cross-cutting issue will be identified in the next annual assessment letter.

Additionally, during this period the NRC will schedule an additional inspection per a revised version of Temporary Instruction (TI) 2515/194, Inspection of the Licensees Implementation of Industry Initiative Associated with the Open Phase Condition Design Vulnerability in Electrical Power Systems (NRC Bulletin 2012-01), for any sites who elect to implement the guidance of the Industry Initiative on Open Phase Condition, Revision 3 (ML19163A176), which included an option for relying on annunciation and operator manual actions instead of automatic protective features to isolate a power supply affected by an open phase condition. Licensees will be individually notified when the NRC schedules these inspections.

The enclosed inspection plan lists the inspections scheduled through December 31, 2021. This updated inspection plan now includes security inspections which were formerly transmitted under separate correspondence. The NRC provides the inspection plan to allow for the

C. Reasoner 3 resolution of any scheduling conflicts and personnel availability issues. Routine inspections performed by resident inspectors are not included in the inspection plan. You should be aware that the agency is pursuing potential changes to the ROP, including changes to engineering inspections (SECY-18-0113, Recommendations for Modifying the Reactor Oversight Process Engineering Inspections), and other changes to the baseline inspection program described in SECY-19-0067, Recommendations for Enhancing the Reactor Oversight Process. Should these changes to the ROP be implemented, the engineering and other region-based inspections are subject to change in scope, as well as schedule. The inspections listed during the last 12 months of the inspection plan are tentative and may be revised. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Please contact me at 817-200-1141 with any questions you have regarding this letter.

Sincerely,

/RA/

Neil F. OKeefe, Chief Reactor Projects Branch B Division of Reactor Projects Docket No. 05000482 License No. NPF-42

Enclosure:

Inspection Plan cc w/ encl: Distribution via LISTSERV

IP 22 Inspection Activity Plan Report Wolf Creek 01/01/2020 - 12/31/2021 Unit Start End Activity CAC Title Staff Count RS13PI Radiation Safety 2 1 03/02/2020 03/06/2020 IP 71124.01 000725 Radiological Hazard Assessment and Exposure Controls 1 03/02/2020 03/06/2020 IP 71124.03 000727 In-Plant Airborne Radioactivity Control and Mitigation Wolf Creek 1 - Power Operated Valve Inspection 3 1 04/06/2020 04/10/2020 IP 71111.21N.02 001645 Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements 1 04/20/2020 04/24/2020 IP 71111.21N.02 001645 Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements Security Equipment .04 and Training .07 2 1 05/18/2020 05/22/2020 IP 71130.04 000736 Equipment Performance, Testing, and Maintenance 1 05/18/2020 05/22/2020 IP 71130.07 000739 Security Training BIENNIAL PI&R 4 1 06/08/2020 06/12/2020 IP 71152B 000747 Problem Identification and Resolution 1 06/22/2020 06/26/2020 IP 71152B 000747 Problem Identification and Resolution WC 2020 BRQ 2 1 06/21/2020 06/27/2020 IP 71111.11B 000704 Licensed Operator Requalification Program and Licensed Operator Performance RS5678 Radiation Safety PS Team 4 1 07/06/2020 07/10/2020 IP 71124.05 000729 Radiation Monitoring Instrumentation 1 07/06/2020 07/10/2020 IP 71124.06 000730 Radioactive Gaseous and Liquid Effluent Treatment 1 07/06/2020 07/10/2020 IP 71124.07 000731 Radiological Environmental Monitoring Program 1 07/06/2020 07/10/2020 IP 71124.08 000732 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation EP Program Inspection 1 1 08/03/2020 08/07/2020 IP 71114.02 000717 Alert and Notification System Testing 1 08/03/2020 08/07/2020 IP 71114.03 000718 Emergency Response Organization Staffing and Augmentation System 1 08/03/2020 08/07/2020 IP 71114.04 000719 Emergency Action Level and Emergency Plan Changes 1 08/03/2020 08/07/2020 IP 71114.05 000720 Maintenance of Emergency Preparedness 1 08/03/2020 08/07/2020 IP 71151 001397 Performance Indicator Verification Security Access Control .02 1 1 09/21/2020 09/25/2020 IP 71130.02 000734 Access Control 1 09/21/2020 09/25/2020 IP 71151 001338 Performance Indicator Verification This report does not include INPO and OUTAGE activities. Page 1 of 3 This report shows only on-site and announced inspection procedures.

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IP 22 Inspection Activity Plan Report Wolf Creek 01/01/2020 - 12/31/2021 Unit Start End Activity CAC Title Staff Count Fire Protection Inspection - WC 3 1 10/19/2020 10/23/2020 IP 71111.21N.05 001646 Fire Protection Team Inspection (FPTI) 1 11/02/2020 11/06/2020 IP 71111.21N.05 001646 Fire Protection Team Inspection (FPTI)

Security FFD .08 1 1 01/25/2021 01/29/2021 IP 71130.08 000740 Fitness For Duty Program Inservice Inspection RF24 - WC 1 1 03/22/2021 04/02/2021 IP 71111.08P 000702 Inservice Inspection Activities (PWR)

RP 1,2,PI 2 1 03/29/2021 04/02/2021 IP 71124.01 000725 Radiological Hazard Assessment and Exposure Controls 1 03/29/2021 04/02/2021 IP 71124.02 000726 Occupational ALARA Planning and Controls Security Access Authorization .01 and Access Control .02 w/PIV 2 1 06/14/2021 06/18/2021 IP 71130.01 000733 Access Authorization 1 06/14/2021 06/18/2021 IP 71130.02 000734 Access Control 1 06/14/2021 06/18/2021 IP 71151 001338 Performance Indicator Verification Design Bases Assurance (Team) 21M - Wolf Creek 6 1 07/19/2021 08/06/2021 IP 71111.21M 000713 Design Bases Assurance Inspection (Teams)

FORCE-ON-FORCE PLANNING AND EXERCISE WEEKS - WC 6 1 08/30/2021 09/03/2021 IP 71130.03 000735 Contingency Response - Force-On-Force Testing 1 09/20/2021 09/24/2021 IP 71130.03 000735 Contingency Response - Force-On-Force Testing WC 2021 INITIAL EXAM 6 1 09/19/2021 09/25/2021 OV 000956 VALIDATION OF INITIAL LICENSE EXAMINATION (OV) 1 10/31/2021 11/06/2021 EXAD 000500 LICENSE EXAM ADMINISTRATION (EXAD)

RP 2,4 2 1 10/04/2021 10/08/2021 IP 71124.02 000726 Occupational ALARA Planning and Controls 1 10/04/2021 10/08/2021 IP 71124.04 000728 Occupational Dose Assessment EP Exercise and PI Inspection 4 1 11/15/2021 11/19/2021 IP 71114.01 000716 Exercise Evaluation 1 11/15/2021 11/19/2021 IP 71114.04 000719 Emergency Action Level and Emergency Plan Changes This report does not include INPO and OUTAGE activities. Page 2 of 3 This report shows only on-site and announced inspection procedures.

2/19/2020 11:38:55 AM

IP 22 Inspection Activity Plan Report Wolf Creek 01/01/2020 - 12/31/2021 Unit Start End Activity CAC Title Staff Count EP Exercise and PI Inspection 4 1 11/15/2021 11/19/2021 IP 71151 001397 Performance Indicator Verification This report does not include INPO and OUTAGE activities. Page 3 of 3 This report shows only on-site and announced inspection procedures.

2/19/2020 11:38:55 AM