ML13203A329

IR 05000482-13-010, June 3, 2013 Through June 7, 2013, Wolf Creek Generating Station, Inspection Procedure 95002 Supplemental Inspection Report and Assessment Follow-Up Letter

ML13203A329
Person / Time
Site:	Wolf Creek
Issue date:	07/22/2013
From:	O'Keefe N Division of Nuclear Materials Safety IV
To:	Matthew Sunseri Wolf Creek
O'Keefe N
References
IR-13-010
Download: ML13203A329 (45)

See also: IR 05000482/2013010

Text

U N IT E D S TA TE S

N U C LE AR R E GU LA TOR Y C OM MI S S I ON

R E G IO N I V

1600 EAST LAMAR BLVD

AR L I NG TO N , TE X AS 7 60 1 1 - 4511

July 22, 2013

Matthew W. Sunseri, President and

Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

SUBJECT: WOLF CREEK GENERATING STATION - NRC INSPECTION

PROCEDURE 95002 SUPPLEMENTAL INSPECTION REPORT

05000482/2013010 AND ASSESSMENT FOLLOW-UP LETTER

Dear Mr. Sunseri:

On June 7, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental

inspection pursuant to Inspection Procedure 95002, "Supplemental Inspection for One

Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area," at your

Wolf Creek Generating Station facility. This inspection included an assessment of your

actions to address each of four open substantive cross-cutting issues. The team also

performed a limited scope independent safety culture assessment follow-up in accordance

with Inspection Procedure 40100, Independent Safety Culture Assessment Follow up.

The enclosed inspection report documents the inspection results, which were discussed

during the exit meeting on June 7, 2013, with you and members of your staff.

In accordance with the NRC Reactor Oversight Process Action Matrix, this supplemental

inspection was performed to address a Yellow finding with substantial safety significance in

the Initiating Events cornerstone which was issued in the third quarter of 2012. This finding

resulted in the station being placed in Degraded Cornerstone column of the Action Matrix.

This issue was previously documented and assessed in NRC Inspection Reports

05000482/2012009 and 05000482/2012010. The NRC was informed on April 30, 2013, of

your staff's readiness for this inspection.

The objectives of this supplemental inspection were to provide assurance that: (1) the root

causes and the contributing causes for the risk-significant issues were understood; (2) the

extent of condition and extent of cause of the issues were identified; and (3) corrective actions

were or will be sufficient to address and preclude repetition of the root and contributing causes.

This inspection also included an independent NRC review of the extent of condition and extent

of cause for the Yellow finding and an assessment of whether any safety culture component

caused or significantly contributed to the performance issue. The objectives of the

independent safety culture assessment follow-up were: (1) to provide assurance that the

licensee recognizes the safety culture cross-cutting component deficiencies that caused or

significantly contributed to risk-significant performance issues and repetitive substantive cross-

cutting issues; and (2) to assess whether completed and proposed corrective actions should be

M. Sunseri -2-

considered sufficient and appropriate to address recognized cross-cutting component

deficiencies identified during the licensees independent safety culture assessment.

The objectives of the substantive cross-cutting issue review were: (1) to assess the licensees

cause evaluations for each substantive cross-cutting issue; (2) to assess whether the

corrective actions adequately addressed the causes identified; and (3) to assess the

effectiveness of corrective actions taken.

The inspectors determined that your staff performed a comprehensive evaluation to identify

appropriate causes and corrective actions associated with the Yellow finding. Your staff's

evaluation identified the root cause of the issue to be the failure to recognize the

risk/consequence of having a vendor perform work on the startup transformer, in accordance

with vendor procedures and processes, without an established verification method for ensuring

work quality, resulting in an undetected human performance error. The inspectors determined

that your staff identified appropriate corrective actions to enhance the station requirements for

oversight of supplemental workers performing contract work activities, which, if successfully

implemented, appear to be adequate to address the identified performance issues.

The NRC has determined that the inspection objectives stated above have been met. Based

on the results of this inspection, the Yellow finding is closed. Therefore, in accordance with

IMC 0305, Operating Reactor Assessment Program, because the Yellow finding is closed and

four quarters have passed, we have determined that the performance issues associated with

the Yellow finding will not be considered in the Action Matrix after the end of the second quarter

of 2013.

As a result of its continuous review of plant performance, including the results of this

inspection, the NRC has updated its assessment of Wolf Creek Generating Stations

performance. The NRCs evaluation consisted of a review of performance indicators and

inspection results. The NRC determined the performance at Wolf Creek Generating Station to

be in the Regulatory Response Column of the ROP Action Matrix as of July 1, 2013, due to one

performance indicator, the Mitigating System Performance Index - Emergency AC Power

System (MSPI - EAC), remaining White. The MSPI - EAC performance indicator will only be

considered in the Action Matrix until it returns to Green status. Your actions to address this

performance indicator have previously been inspected. Therefore, the NRC plans ROP

baseline inspections at your facility for the remainder of the assessment cycle.

The inspectors determined that your staff performed comprehensive evaluations to identify

appropriate causes and corrective actions associated with each of four open substantive cross-

cutting issues. The corrective actions identified, once fully implemented, appear to be adequate

to address the performance issues associated with these cross-cutting areas.

The inspectors also determined that your staff performed a comprehensive evaluation to identify

appropriate causes and corrective actions associated with safety culture challenges at the

station. The inspectors noted many indications of improvement in safety culture, as well as

indications of some remaining challenges in specific areas.

No findings were identified during this inspection.

M. Sunseri -3-

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in

the NRC Public Document Room or from the Publicly Available Records (PARS) component

of NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is

accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA/

Neil OKeefe, Chief

Project Branch B

Division of Reactor Projects

Docket: 50-482

License: NPF-42

Enclosure: Inspection Report 05000482/2013010

w/Attachment: Supplemental Information

cc w/ encl: Electronic Distribution

M. Sunseri -4-

Electronic distribution by RIV:

Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

DRP Deputy Director (Troy.Pruett@nrc.gov)

DRS Director (Tom.Blount@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Charles.Peabody@nrc.gov)

Acting Resident Inspector (Christopher.Hunt@nrc.gov)

WC Administrative Assistant (Carey.Spoon@nrc.gov)

Branch Chief, DRP/B (Neil.OKeefe@nrc.gov)

Senior Project Engineer, DRP/B (Mike.Bloodgood@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Fred.Lyon@nrc.gov)

Branch Chief, IPAB, NRR (Rani.Franovich@nrc.gov)

Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV/ETA: OEDO (Vivian.Campbell@nrc.gov)

ROPreports

R:\_Reactors\_WC\2013\WC 2013010 95002 060713.docx

ADAMS: No Yes SUNSI Review Complete Reviewer Initials: NFO

Publicly Available Non-Sensitive

Non-publicly Available Sensitive

DRP:SRI/B DRS DRP DRP - TL

T. Hartman C. Osterholtz M. Bloodgood C. Young

/RA/E-OKeefe /RA/ /RA/ /RA/

TSB TSB DRP/BC:

E. Ruesch E. Uribe NOKeefe

/RA/E-Okeefe /RA/ /RA/

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000482

License: NPF-42

Report: 05000482/2013010

Licensee: Wolf Creek Nuclear Operating Corporation

Facility: Wolf Creek Generating Station

Location: 1550 Oxen Lane NE

Burlington, Kansas

Dates: June 3, 2013 through June 7, 2013

Inspectors: C. Young, Senior Project Engineer (Team Leader)

T. Hartman, Senior Resident Inspector

C. Osterholtz, Senior Operations Engineer

M. Bloodgood, Senior Project Engineer

E. Ruesch, Senior Reactor Inspector

E. Uribe, Reactor Inspector

Approved By: Neil OKeefe, Chief

Project Branch B

Division of Reactor Projects

-1- Enclosure

SUMMARY OF FINDINGS

IR 05000482/2013010, 06/03/2013 - 06/07/2013, Wolf Creek Generating Station, Supplemental

Inspection (IP 95002); Independent Safety Culture Assessment Follow-up (IP 40100);

Substantive Cross-Cutting Issue Follow-up.

This supplemental inspection was conducted by four region-based inspectors and a senior

resident inspector. No findings were identified. The NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor

Oversight Process," Revision 4, dated December 2006.

Cornerstone: Initiating Events

The NRC staff performed this supplemental inspection in accordance with Inspection

Procedure 95002, "Supplemental Inspection for One Degraded Cornerstone or Any

Three White Inputs in a Strategic Performance Area," to assess the licensee's evaluation

associated with the failure of a startup transformer due to a failure to follow maintenance

procedures, which resulted in a loss of offsite power event at the station in January 2012.

The NRC staff previously characterized this issue as having substantial safety

significance (Yellow), as documented in NRC Inspection Reports 05000482/2012009

and 05000482/2012010. A follow-up assessment letter dated September 21, 2012,

transitioned Wolf Creek to the Degraded Cornerstone Column beginning August 6,

2012, due to one Yellow input in the Initiating Events Cornerstone, and identified the

intention to perform Inspection Procedure 95002.

The inspectors determined that the licensee performed a comprehensive evaluation of

the issues related to the Yellow finding, which appropriately identified the root cause of

the issue to be the failure to recognize the risk/consequence of having a vendor perform

work, in accordance with vendor procedures and processes, without an established

verification method for ensuring work quality, resulting in an undetected human

performance error. The failure to follow maintenance procedures during a maintenance

activity in April 2011, resulted in a subsequent failure of the startup transformer and a

loss of offsite power during an event on January 13, 2012. The inspectors determined

that the licensee identified appropriate corrective actions to enhance the oversight of

supplemental workers performing work activities, which appear to be adequate to address

the identified performance issue.

In addition to assessing the licensee's evaluations, the inspection team performed an

independent extent of condition and extent of cause review and a focused inspection of

the site safety culture as it related to the root cause evaluation. The team concluded that

the licensees root cause evaluation and corrective actions, both completed and

planned, adequately addressed the extent of condition and extent of cause, and were

adequate to address the cause and prevent recurrence. Based on independent

inspection, the team also determined that the licensee's assessment of site safety culture

contribution to the issue was adequate.

-2- Enclosure

The NRC has determined that the inspection objectives stated above have been met.

Based on the results of this inspection, the Yellow finding is closed. Therefore, in

accordance with IMC 0305, Operating Reactor Assessment Program, because the

Yellow finding is closed and four quarters have passed, we have determined that the

performance issues associated with the Yellow finding will no longer be considered in the

Action Matrix after the end of the second quarter of 2013.

The inspectors determined that the licensee performed comprehensive evaluations of the

issues relating to each of four open substantive cross-cutting issues. The inspectors

determined that the licensee identified appropriate corrective actions to address these

issues, which, once fully implemented, appear to be adequate to address the performance

issues associated with these cross-cutting areas.

The inspectors also determined that the licensee performed a comprehensive evaluation to

identify appropriate causes and corrective actions associated with safety culture challenges

at the station. The inspectors noted many indications of improvement in safety culture, as

well as indications of some remaining challenges in specific areas.

A. NRC-Identified or Self-Revealing Findings

None

B. Licensee-Identified Violations

None

-3- Enclosure

REPORT DETAILS

4. OTHER ACTIVITIES

4OA4 Supplemental Inspection (95002)

.01 Inspection Scope

The NRC staff performed this supplemental inspection in accordance with Inspection

Procedure 95002, "Inspection for One Degraded Cornerstone or Any Three White Inputs

in a Strategic Performance Area," to assess the licensees evaluation of a Yellow finding,

which affected the initiating events cornerstone in the reactor safety strategic performance

area. The inspection objectives were to:

provide assurance that the root and contributing causes of risk-significant issues

were understood

provide assurance that the extent of condition and extent of cause of risk-

significant issues were identified and to independently assess the extent of

condition and extent of cause of individual and collective risk-significant issues

independently determine if safety culture components caused or significantly

contributed to the risk significant issues

provide assurance that the licensee's corrective actions for risk-significant issues

were or will be sufficient to address the root and contributing causes and to

preclude repetition

The licensee entered the Degraded Cornerstone Column of the NRCs Action Matrix in

the third quarter of 2012 as a result of one inspection finding of substantial safety

significance (Yellow). The finding was associated with the failure of a startup

transformer during a power transient which occurred on January 13, 2012, resulting in

a loss of offsite power event at the station. The startup transformer failure was the

result of an inadequately performed maintenance activity conducted by contracted

workers in April 2011, in which maintenance procedure requirements were not

adequately followed. The finding was characterized as having Yellow safety

significance, as discussed in NRC Inspection Reports 05000482/2012009 and

05000482/2012010.

The licensee staff informed the NRC on April 30, 2013, that Wolf Creek was ready for the

supplemental inspection. In preparation for the inspection, the licensee performed a root

cause evaluation (RCE) to identify weaknesses that existed, which allowed for a risk-

significant finding and Degraded Cornerstone, and to determine the organizational

attributes that resulted in the Yellow finding. The licensee also conducted assessments to

determine whether safety culture aspects contributed to the performance issues that led to

the Yellow finding.

-4- Enclosure

The inspection team reviewed the licensees RCE in addition to other associated

evaluations conducted in support and as a result of the RCE. The inspection team

reviewed corrective actions that were taken or planned to address the identified causes.

The inspection team also held discussions with licensee personnel to ensure that the root

and contributing causes and the contribution of safety culture components were

understood and corrective actions taken or planned were appropriate to address the

causes and preclude repetition. The inspection team also independently assessed the

extent of condition and extent of cause of the identified issue, and performed an

assessment of whether any safety culture components caused or significantly contributed

to the finding.

.02 Evaluation of Inspection Requirements

02.01 Problem Identification

a. Identification of the issue (i.e., licensee-identified, self-revealing, or NRC-identified) and

under what conditions the issue was identified.

On January 13, 2012, the site experienced a loss of offsite power event. Wolf Creek was

operating at 100 percent rated thermal power with no plant evolutions in progress, no

transmission switching events occurring, and no severe weather conditions. The licensee

determined that the event resulted from two distinct faults. The first fault was on the C

phase of the main generator output breaker. The second fault occurred on the B phase of

the startup transformer. The inspectors determined that the issue was self-revealing as a

pair of failures which caused a plant-level event. The inspectors determined that the

licensees evaluation adequately documented who identified the issue and under what

conditions the issue was identified.

b. Issue duration and prior opportunities for identification.

The licensees root cause evaluation documented that the issue related to the startup

transformer fault existed since an inadequately performed maintenance activity was

conducted on the startup transformer in April 2011. The evaluation provided a detailed

timeline of the maintenance performed, surveillance tests conducted, and corrective

actions. The licensees timeline identified missed opportunities for earlier identification of

the issues. The licensees evaluation determined that previous visual inspections

conducted by the licensee did not recognize that the cover to the startup transformer

junction box containing the wiring terminations that were the source of the fault could be

removed for access to any wiring. The inspectors determined that the licensees

evaluation was adequate with respect to identifying how long the issue existed and prior

opportunities for identification.

c. Licensees documentation of the plant-specific risk consequences, and compliance

concerns associated with the issues, both individually and collectively.

The licensees root cause evaluation concluded that the lack of controls and oversight for

contract services caused degraded equipment reliability.

-5- Enclosure

The errors introduced as a result of a failure to comply with maintenance procedure

requirements impacted the stations ability to mitigate a switchyard transient and maintain

power to electrical buses by transferring power to an energized offsite source. This

increased the risk associated with a loss of offsite power initiating event. The licensees

evaluation provided information to describe what actions (e.g. procedure compliance)

would have prevented the error from being introduced during maintenance on the startup

transformer. The inspectors concluded that the licensee appropriately documented the

risk consequences and compliance concerns associated with the issue.

d. Findings

No findings were identified.

02.02 Root Cause, Extent of Condition, and Extent of Cause Evaluation

a. Root and contributing cause evaluation methodology.

The licensee conducted a root cause evaluation to identify the causes for the inadequate

workmanship by maintenance personnel that led to the failure to install sleeves for the

insulation of exposed wiring, which caused a failure of the startup transformer. The

licensees analysis included: a detailed description of the event, an event timeline and

decisions made, a summary of root and contributing causes, a discussion of relevant

internal and external operating experience, a discussion of Quality Assurance (QA)

oversight activities related to the issues, an extent of condition analysis and resulting

actions, an extent of cause analysis and resulting actions, and a safety culture

assessment. The licensees evaluation identified the following direct cause, root cause,

and contributing cause associated with the Yellow finding:

The direct cause for the loss of the Startup Transformer was the Startup

Transformer high voltage side current transformer (CT) wires on A and B Phase

were shorted

Wolf Creek did not recognize the risk/consequence of having a vendor perform

work, in accordance with vendor procedures and processes, without a Wolf Creek

approved verification method for ensuring work quality, resulting in an undetected

human performance error

Wolf Creek personnel, at all levels, failed to implement and enforce the companys

accountability model, primarily with respect to procedural use and adherence

The inspection team concluded that the licensee performed a comprehensive and

thorough analysis of the issue, using multiple analysis methods that were appropriate to

identify root and contributing causes of the events. Two Event and Causal Factor (E&CF)

Charts (overview and details) were developed using a detailed Sequence of Events (SOE)

report. Fault Tree Analysis, Evidence and Action Matrix, Change Analysis, Barrier

Analysis, Why Tree, and Safety Culture Analysis methods were used to identify causal

factors and determine corrective actions. A Management Oversight and Risk Tree

(MORT) analysis was used to evaluate the completeness of the analysis and to identify or

confirm areas of causality.

-6- Enclosure

The inspectors concluded that the licensees evaluation was adequate to identify

appropriate causes.

b. Root cause evaluation level of detail.

The licensee conducted a root cause analysis to evaluate causes for the inadequate

workmanship by maintenance personnel that led to the failure of the startup transformer.

The licensees analysis included: a detailed description of the event, an event timeline and

decisions made, a summary of root and contributing causes, a discussion of internal and

external operating experience, a discussion of Quality Assurance oversight activities

related to the issues, an extent of condition analysis and resulting actions, an extent of

cause analysis and resulting actions, and a safety culture assessment. The licensee

identified one direct cause, one root cause, and one contributing cause related to the

failure of the startup transformer along with various interim corrective actions and two

corrective actions to prevent recurrence. The licensee evaluation also included numerous

actions to address the extent of condition and extent of cause.

The inspectors concluded the licensees root cause evaluation was adequately performed,

and included a level of detail commensurate with the significance of the problem. The

inspectors concluded that 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 comprehensive. The level of detail was reflected in the extensive event

timeline and the evaluation attachments of the licensees root cause evaluation.

The inspectors also noted that the licensee took the additional step to complete an

independent evaluation of the root cause evaluation to ensure that it addressed and

documented all applicable aspects of the deficiency.

c. Root cause evaluation consideration of prior occurrences and operating experience.

The inspectors confirmed that the licensees evaluation included a discussion and

consideration of similar previous plant trips and loss of offsite power events. The licensee

also performed benchmarking efforts to gauge other nuclear plants responses to

applicable generic communications and operating experience regarding current

transformer saturation levels.

The inspectors concluded that the root cause evaluation included a thorough review of

prior and precursor problems, and properly evaluated internal and industry operating

experience. The inspectors did not identify any examples where a review of prior

operating experience could have prevented the condition that led to this event from

occurring.

d. Evaluation of the extent of condition and the extent of cause.

The licensees evaluation included an analysis of the extent of condition, which consisted

of determining whether the identified conditions could exist in other plant equipment,

processes or human performance. In this case, the extent of condition review examined

whether other similar inadequate workmanship issues existed on similar equipment.

-7- Enclosure

The licensee determined that inspections of the two remaining similar startup transformer

CT junction blocks, as well as similar connections for the three main transformers, were

necessary. These inspections were performed as part of the licensees extent of condition

review. This resulted in the identification of other workmanship issues involving the

splicing of CT wires for one of the main transformers.

The licensees evaluation also included the extent of cause for the root cause to determine

if other departments or activities involving similar processes could be vulnerable to the root

causes identified in the evaluation with respect to control of contractor performed

maintenance activities. The licensee identified that the failure to recognize the risk and

consequence of having a vendor perform work under their program, without sufficient

verification, could have existed for any service labor requisitions and applicable projects.

The licensees evaluation recognized the need to determine whether other supplemental

work activities have been performed at the station without proper oversight, and determine

whether additional associated latent equipment problems may exist. The licensee initiated

a review of work completed by service labor contracts, which included a review of 92

applicable purchase requisitions approved between 2009 and 2012. These were reviewed

by the licensees Quality Assurance organization. The licensees review did not identify

any instances where other activities were performed without appropriate oversight.

Based on a review of the evaluation and discussions with licensee management and staff

personnel, the inspectors concluded that the licensees evaluation addressed the extent of

condition and the extent of cause of the problem through a disciplined process. Additional

discussion is provided in Section 02.04.

f. Findings

No findings of significance were identified.

02.03 Corrective Actions

a. Appropriateness of corrective actions for each root and contributing cause.

The licensees evaluation identified a direct cause, a root cause, and a contributing cause,

and identified corresponding interim corrective actions, two corrective actions to prevent

recurrence, and numerous extent of condition and extent of cause corrective actions. The

licensees evaluation identified a total of 50 corrective actions to address the identified

causes. The licensees principal corrective action to prevent recurrence included revision of

station procedural requirements for:

Oversight of supplemental workers performing contract work activities

Work order planning

Work order implementation

The inspectors also determined that the licensee was working with WESTAR, the

transmission and distribution company for the local grid, to take actions to improve the

overall reliability of offsite power, in light of the event which was a result of this

performance deficiency being the third loss of offsite power event that has occurred at the

station over the past five years. These actions included the performance of an

independent review of all previously identified grid reliability and switchyard enhancements

to ensure that industry best practices have been appropriately incorporated. This review

resulted in the identification of several best practices upgrade projects in areas such as:

-8- Enclosure

preventive maintenance improvement, protective relay scheme upgrades, reconfiguration

of substation layout/components and installation of additional switchyard components to

increase reliability. The inspectors also noted that the licensee had implemented

additional oversight measures to control and coordinate maintenance activities occurring in

the switchyard/substation, and that the licensee had taken action to include switchyard

components in the stations maintenance rule (10 CFR 50.65) monitoring program.

Overall, the inspectors concluded that appropriate corrective actions were developed to

address the identified causes of the performance deficiency.

b. Prioritization of corrective actions with consideration of risk significance and regulatory

compliance.

The inspectors determined that licensee has identified numerous (50) corrective actions

associated with this issue since the event occurred on January 13, 2011. All but two of

these corrective actions had been completed and were closed prior to the beginning of this

inspection (June 3, 2013). The two corrective actions remaining to be completed were

associated with future business planning actions.

The inspectors concluded the licensee had appropriately prioritized and scheduled

corrective actions for the identified direct, root and contributing causes, and had completed

them in a timely manner.

c. Schedule for implementing and completing the corrective actions.

As discussed in Section 02.03.b, the inspectors determined that the licensee has

completed all but two of the identified corrective actions as of June 3, 2013. The

inspectors determined that the assigned schedule for completion dates of these actions

was appropriate. Completion dates were assigned for the remaining two corrective actions

related to business planning and are expected to be complete later in 2013.

The inspectors concluded that an appropriate schedule was established for implementing

and completing the corrective actions.

d. Measures for determining the effectiveness of the corrective actions.

The licensee scheduled an overall effectiveness review to ensure that the problems

identified in the root cause evaluation are adequately addressed by the implementation of

the corrective actions. The evaluation was scheduled to be performed by December 27,

2013. The inspectors noted that this schedule did not appear to be timely relative to the

completion dates of the major corrective actions. The inspectors determined that the

licensee used their standard effectiveness review schedule of 6 months following

completion of the last action. The inspectors observed that the standard scheduling might

not be appropriate for this situation because the significance of the issues and the large

number and extent of corrective actions made the need for an effectiveness review

desirable, such that prompt changes could be made if needed. However, the inspectors

did note that the licensee planned and had already implemented interim effectiveness

review actions in the form of QA surveillances for activities involving contractor work

oversight.

The inspectors independently assessed the effectiveness of the licensees corrective

actions to improve oversight of contractor work by observing work in progress to install

-9- Enclosure

new essential service water piping and new diesel generators. The inspectors found that

the corrective actions implemented have been effective. The licensee personnel observed

by the inspectors demonstrated a clear understanding of the oversight requirements and

the work being performed by contractors.

The inspectors also reviewed the results of QA surveillances of maintenance activities

involving contractor oversight, which had been performed by the licensee as an interim

effectiveness review action. QA identified several instances where the corrective actions

were not fully effective and identified additional vulnerabilities regarding control of contract

services. The inspectors determined that, although the findings identified by QA were not

safety significant, the licensee was performing a separate root cause evaluation to address

these issues at the time of the inspection. The inspectors observed that this demonstrated

a heightened sensitivity to the identification of potential vulnerabilities in this area and a

high level of rigor being applied to effectiveness review efforts.

Overall, the inspectors concluded that the licensee had developed adequate evaluation

criteria for each corrective action to prevent recurrence, addressed additional interim

corrective actions following the results of recent Quality Assurance surveillances, and was

tracking completion of the reviews. The inspectors concluded this was appropriate given

the implementation schedule and the complexity of some corrective actions.

e. Adequacy of corrective actions to address the Notice of Violation (NOV).

The NRC issued a Notice of Violation, VIO 05000482/2012009-01, to the licensee on

September 21, 2012 for the failure to perform maintenance that affected safety-related

equipment in accordance with written procedures (ML12265A310). During this inspection,

the inspectors confirmed that the licensees root cause evaluation and corrective actions

adequately addressed the Notice of Violation. The licensee restored full compliance by

correcting procedures associated with the control of contract services.

The licensees principal corrective action to prevent recurrence involved the enhancement of

station procedural requirements for oversight of supplemental workers performing contract

work activities. The inspectors identified a potential vulnerability that existed in the

resulting procedures, in that the procedures contained a provision for delegation of the

oversight role to other designated qualified personnel, without any provision to ensure

these individuals would be independent of the contracted organization performing the

activity. The licensee entered this observation into their corrective action program as

Condition Report 69954. Overall, the inspectors determined that the corrective actions

taken or planned were adequate to address the NOV that was the basis for the

supplemental inspection.

f. Findings

No findings were identified.

- 10 - Enclosure

02.04 Independent Assessment of Extent of Condition and Extent of Cause

a. Inspection Scope

Inspection Procedure 95002 requires that the inspection staff perform a focused inspection

to independently assess the validity of the licensee's conclusions regarding the extent of

condition and extent of cause of the issue. The objective of this requirement is to

independently sample performance, as necessary, within the key attributes of the

cornerstones that are related to the subject issue, to ensure that the licensee's evaluation

regarding the extent of condition and extent of cause is sufficiently comprehensive.

The inspectors conducted independent extent of condition and extent of cause reviews of

the issues associated with the Yellow finding. The Yellow finding resulted from Wolf Creek

Stations failure to follow maintenance procedures in accordance with Work Order 11-

240360-006, Revision 3. The inspectors independently reviewed the licensees actions

specified in the root cause evaluation for extent of cause/extent of condition. The

inspectors also conducted additional independent sampling of activities, specifically

focusing on other documents and work activities where a failure to follow maintenance

procedure by contract services would have the potential to contribute to a significant event.

The inspectors independently sampled the documentation of selected contracted

maintenance activities completed during the most recent refueling outage. The inspectors

also observed several work activities which were in progress during the inspection

involving station oversight of contracted personnel. The inspectors independently

assessed the effectiveness of the licensees corrective actions to improve oversight of

contractor work by directly observing work activities in progress involving the installation of

new essential service water system piping, as well as new diesel generators.

In conducting this review, the inspectors interviewed station management and

personnel, reviewed program and process documentation, reviewed station program

monitoring and improvement efforts, and reviewed corrective action documents.

b. Assessment

The inspectors independent assessment of the extent of condition/extent of cause

determined that the licensee had done a comprehensive job identifying and addressing the

significant issues.

Interviews were conducted with station management and personnel to assess the

effectiveness of documented actions taken, the understanding of their implementation, as

well as the logic and justifications used for the documented extent of condition/extent of

cause actions from the licensees root cause evaluation. The interviews demonstrated a

general awareness and adequate implementation of the actions taken.

- 11 - Enclosure

The inspectors noted that the licensee was in the process of performing a high level

evaluation for three different events:

The loss of offsite power event of January 13, 2012

The Emergency Diesel Generator Performance Indicator threshold crossing of

March 12, 2012

Previous corrective actions addressed during the 95002 Inspection of May 20,

2011, for the threshold crossings of the Unplanned Scrams per 7000 Critical Hours,

Unplanned Scrams with Complications, and Safety System Functional Failures

performance indicators

The licensee has established an improvement plan to reinforce the use and effectiveness

of the sites Accountability and Culpability models to achieve improved performance.

Through interviews with a cross-section of station personnel, the inspectors determined

that this model has gained broad acceptance and was being used effectively to drive

improvement and higher standards in many different work activities.

The inspectors observations were entered into the corrective action program as

Condition Report 69954. Overall, the inspectors independent assessment concluded

that the licensee conducted an adequate RCE with respect to extent of condition and

extent of cause.

02.05 Safety Culture Consideration

a. Inspection Scope

The inspection team conducted a focused inspection to independently determine whether

the licensees root cause evaluation appropriately considered whether any safety culture

component caused or significantly contributed to any risk significant performance issues.

The inspectors reviewed corrective actions, training requests, performance indicators,

and procedures as part of the assessment. The inspection team reviewed condition

reports and procedures, and conducted interviews with licensee personnel.

b. Assessment

As part of the collective root cause evaluation, the licensee conducted a safety culture

analysis which evaluated the identified direct, root and contributing causes against the

safety culture components that could have contributed to the issue.

- 12 - Enclosure

The inspectors verified that the licensee's root cause evaluation included an assessment

and consideration of the applicable safety culture components as they applied to the

Yellow finding which affected the Initiating Events cornerstone. The licensees analysis

determined that deficiencies in the following five safety culture aspects that contributed to

the performance deficiency:

H.4.b(Work practices - personnel follow procedures)

H.1.a(Systematic process for risk-significant decision-making)

O.4.c (Organizational decisions and actions are consistent with a policy that

nuclear safety is an overriding priority)

H.3.b(Work control - coordination of work activities)

H.4.c(Work practices - supervisory oversight of work activities)

The inspectors concluded that several safety culture deficiencies provided the underlying

conditions that allowed the events of January 13, 2012, to occur. The licensee has had

multiple substantive cross-cutting issues (SCCIs) for a prolonged period of time. The

current SCCIs were evaluated during this inspection because of their relationship to the

Yellow finding, and the results of this review are discussed in later sections of this report.

In particular, the SCCIs represented the following safety culture problems:

Tolerance of longstanding equipment reliability issues and untimely corrective

actions for the same

Willingness of workers to proceed when faced with unclear procedures or

documentation, rather than stopping to get the documents corrected

Evaluations and decision-making performed without clearly identifying all needed

information and the assumptions being made

An operability assessment process that did not track degraded or non-conforming

conditions, assess them collectively, or ensure prompt corrective action

The inspection team independently confirmed the licensees conclusion that improving

safety culture behaviors should be a high priority item for the recovery effort. The

inspectors concluded that the licensees analysis appropriately considered the safety

culture components.

c. Findings

No findings were identified.

- 13 - Enclosure

02.06 Evaluation of Inspection Manual Chapter 0305 teria for Treatment of Old Design Issues

The Yellow finding did not involve any old design issues.

4OA5 Other Activities

.1 Assessment of Corrective Action to Address Substantive Cross-cutting Issues

a. Inspection Scope

The licensees letter dated April 30, 2013, informed the NRC of its readiness for inspection

of the following four substantive cross-cutting issues: P.1.c(problem evaluation), P.1.d

(timely and effective corrective action), H.1.b(conservative decision-making), and H.2.c

(complete and accurate documentation and procedures). Consideration of possible

closure of these substantive cross-cutting issues will be further assessed using information

from this inspection and guidance in Inspection Manual Chapter 0305.

The inspectors reviewed: whether the SCCIs were entered into the corrective action

program (CAP), the causes identified, the corrective actions identified to address those

causes, the measures of effectiveness used by the licensee to monitor improvement, and

actual data for those effectiveness reviews.

b. Findings and Assessment

No findings were identified.

P.1.c - Problem Identification

Wolf Creek has had an SSCI in P.1.c, problem evaluation, for a total of 5 years. The

majority of the licensees recovery actions which addressed the P.1.c SCCI were

accomplished in three main Condition Reports (CRs) in the licensees corrective action

program (CAP): CR 51952 (Latent Organizational Weakness in Management Oversight,

4/25/2012), which included an apparent cause evaluation (ACE); CR 59217 (Perform

Collective Significance Evaluation, 10/28/2012), which included a common cause analysis

(CCA); and CR 34455 (End of Cycle Letter Identifies Ongoing Substantive Issue,

03/08/2011), which included a root cause evaluation (RCE) and was in response to the

2010 end-of-cycle NRC assessment letter.

The inspectors concluded that the licensee appropriately entered this issue into the CAP.

- 14 - Enclosure

P.1.c - Evaluation of Root Causes

The licensee conducted cause evaluations under the CRs referenced above to address

this SCCI. In CR 51952, the licensee identified the apparent cause of the SCCI to be:

CAP training has not been fully effective, resulting in a lack of rigor in the extent and

depth of analysis, leading to inadequate evaluations. A common cause identified from the

issues evaluated in CR 59217 was: Station leaders and managers have failed to model

and consistently drive the individual roles, responsibilities, and accountabilities needed to

reinforce Nuclear Safety Culture behaviors within CAP. In CR 34455, the licensee

identified a root cause of: Leadership has not been successful in aligning behaviors for

timely problem identification and effective resolution in all areas across the station.

The inspectors concluded that the licensees evaluations had been effective in identifying

the causes for this SCCI.

P.1.c - Corrective Action

The licensee identified a total of 39 corrective actions to address this SCCI. The

inspectors reviewed the key corrective actions taken by the licensee.

The licensee had a contractor provide training to all cause evaluators and Corrective

Action Review Board (CARB) members. This training was being tracked in the licensees

training database, and will include annual refresher training. If fully implemented and

continued, this training should improve the quality and consistency of cause evaluation

products.

The licensee recently implemented improvements in the CARB process. These included

developing a stand-alone CARB procedure to establish clearer expectations for CARB

reviews (April 24, 2013), revising CAP procedures to increase CARB ownership of

corrective actions for significant conditions (August 13, 2012, and subsequent revisions),

and implementing divisional CARBs to pre-screen cause evaluation products prior to

presentation to CARB (April 24, 2013).

The licensee is revising its CAP procedures, particularly its root and apparent cause

evaluation procedures, to make them easier to use. Several interviewees in the safety

culture focus groups conducted during this inspection expressed frustration with the

complexity of these procedures. Based on interviews with management, the inspectors

noted that station leadership had already recognized the difficulty and undertaken

improvement efforts.

Licensee management has begun a campaign to communicate to the workforce the

changes to CAP and to improve general employee training relative to the CAP. Based on

safety culture focus group interviews, the team determined that this communication has

been effective as a change management tool.

- 15 - Enclosure

The inspectors also assessed changes that the licensee had implemented in an effort to

improve their processes for evaluating conditions that have the potential to affect

operability of plant equipment and systems. The licensee had changed their corrective

action program to utilize a sole point of entry for problems, such that a condition report

became the single method used to identify and address equipment concerns. The

licensee had implemented a requirement for a senior reactor operator (SRO) to evaluate

every condition report written and perform an operability determination and/or functionality

assessment to evaluate the impact of the identified condition on the capability of plant

systems to perform their required safety functions. The licensee had also implemented a

process by which Operations department management performs subsequent reviews and

assigns grades to every operability/functionality evaluation on a 5-point scale. Any

evaluation that does not receive a grade of five requires some sort of feedback or

correction. The inspectors observed that the licensee did not have a rigorous process in

place to ensure this feedback or correction is performed. The inspectors identified that

several evaluations with low scores were not corrected, and that the associated condition

reports still had inaccurate information in them. The licensee entered these issues in their

corrective action program as Condition Reports 70004 and 70063.

The inspectors concluded that the corrective actions identified were appropriate to address

the identified causes.

P.1.c - Corrective Action Effectiveness Measures

The inspectors noted that many of the internal metrics being monitored have not yet

shown significant improvement. This is largely because of long lead times to see changes

in certain metrics, recent process changes that established more challenging standards,

and re-baselining of some metrics.

Additionally, after implementing the majority of the corrective actions from the three CRs

referenced above, the licensee performed gap analyses to evaluate performance between

the original CR initiation and the closure of the actions. As a result of these gap analyses,

the licensee added additional actions to incorporate lessons learned during that interim

period.

The inspectors also noted that the licensee was tracking the graded results of the

operability/functionality assessment reviews in a performance metric. This metric was a

3-month rolling average for each crew and the work control SRO group, and appeared to

be adequate to determine the effectiveness of those corrective actions.

The inspectors concluded that the licensee had developed meaningful and challenging

measures to apply to the identified corrective actions. Further, the licensee had

established high standards and long review periods for metrics such that they would help

drive long-term improvement. The recent data generally showed improving trends and

prompt re-baselining when significant program changes were made.

- 16 - Enclosure

P.1.c - Results

The inspectors observed that the station had made significant progress in revising their

guidance to address several concerns previously identified by the NRC and other sources.

In particular, the licensee had made extensive efforts to benchmark and incorporate

industry best practices into their corrective action program. In addition to the CRs

referenced above, other drivers used by the licensee to focus its recent process

improvements include the 2012 CAP Audit performed by the licensees Quality Assurance

organization (CR 51952), the 2012 NRC biennial Problem Identification & Resolution

inspection (CRs 53445 & 54072), and other self- and third-party assessments.

The inspectors concluded that the licensee appears to have gained a thorough

understanding of the scope of its problems with respect to evaluation quality and

timeliness. The team confirmed that many of the licensees changes to the CARB process

had improved the quality of both the process and the final products by improving the level

and quality of management involvement. The team noted that the combination of training

and management involvement was causing active discussions about performance

standards and the quality of documentation that had broad benefit. Additionally, the CARB

ownership of significant issues was improved. On June 5, 2013, the team observed a

CARB review of a RCE and several evaluations of industry recommendations. Based on

its observations, the team noted that the licensees CARB process is effective, but that

further improvement is warranted. Specifically, the inspectors observed that the ratings

assigned by the CARB for a RCE associated with CR 68393 were not consistent with the

deficiencies which were identified in the meeting regarding appropriateness of proposed

causes and corrective actions. The inspectors also noted that the metrics for CARB

grading of document quality did not reflect situations where a document was initially

rejected but subsequently accepted, as only the final grade was tracked. The inspectors

also noted that the licensee was still developing the role of Divisional CARBs in driving

improved evaluation quality prior to bringing the issues to CARB.

The inspectors concluded that changes to the operability determination and functionality

assessment processes, if fully implemented, will improve the quality of the evaluations.

The current level of oversight and attention will likely result in sustainable improvement at

the station.

The inspectors concluded that, overall, the quality of the licensees problem evaluation

processes improved demonstrably since the biennial NRC Problem Identification &

Resolution inspection performed in 2012. The team concluded that the licensees

implemented and planned improvements to the CARB and other CAP processes will likely

result in continued improvement.

P.1.d - Problem Identification

Wolf Creek has had a an SCCI in P.1.d, adequacy and timeliness of corrective actions,

SCCI for a total of 3 years. The licensee addressed recovery efforts for the P.1.d SCCI

under the same three principal CRs as discussed in the P.1.csections above: CR 51952

(Latent Organizational Weakness in Management Oversight, 4/25/2012), which included

an apparent cause evaluation CR 59217 (Perform Collective Significance Evaluation,

10/28/2012), which included a common cause analysis; and CR 34455 (End of Cycle

Letter Identifies Ongoing Substantive Issue, 03/08/2011), which included a root cause

evaluation. The inspectors also evaluated the status of the licensees corrective actions to

- 17 - Enclosure

address improvements to the preventive maintenance program. The licensee was

addressing preventative maintenance program issues affecting equipment reliability in

CRs 24445 and 34896. The licensee identified deficiencies in the plants preventive

maintenance program in CRs 24445 and 23119.

The inspectors also evaluated the status of the licensees corrective actions to address

long-standing issues related to deficiencies in the essential service water (ESW) system.

The licensee was addressing recovery actions for ESW system degradation issues with

Incident Investigation Team (IIT) 10-01 and CR 53443.

The inspectors concluded that the licensee appropriately entered these issues related to

the P.1.d SCCI into the CAP.

P.1.d - Evaluation of Root Causes

The licensees cause evaluations associated with the preventive maintenance (PM)

program issues affecting equipment reliability identified several causes. The evaluation in

CR 34896 determined that causes included: lack of detailed PM scope, inadequate PM

implementation, lack of a first time PM implementation strategy, and inadequate

management oversight. The licensee determined in RCE 24445 that the content and

timeliness of preventive maintenance activities was insufficient to support reliable plant

operation. RCE 23119 determined that the root cause for the White safety system

functional failures performance indicator was insufficient preventive maintenance. The

evaluations for the preventive maintenance program issues were self-critical, and they

documented that the preventive maintenance programs did not support reliable plant

operation. These corrective actions were incorporated into the licensees Preventive

Maintenance Optimization (PMO) project.

The licensees cause evaluations associated with the ESW system degradation issues

identified the following causes:

Through-wall leakage developed due to localized pitting developed in low flow

areas resulting in leaks during operation at normal system pressure

Failure to effectively preserve the material condition of systems exposed to lake

water, ensure plans and contingencies were in place to respond to underground

piping issues

Failure to effectively prevent pressure transients due to water hammer which

resulted in ESW piping leaks

Management was not effectively developing, overseeing or implementing priorities

to ensure regulatory issues are addressed in a timely manner, including actions to

address the adverse effects of water hammer in the ESW system

The evaluations for the ESW degradation issues were self-critical, and documented that

the station did not effectively address the degrading condition of the ESW system,

including the effects of water hammer caused by water column separation with subsequent

flow initiation, in a timely manner. The associated corrective actions were incorporated

into the licensees Essential Service Water Replacement and Management Project.

- 18 - Enclosure

The inspectors concluded that the licensees evaluations were effective in identifying the

causes associated with this SCCI.

P.1.d - Corrective Action

The inspectors reviewed the key corrective actions taken by the licensee to address the

causes described above. The licensee appeared to have a thorough understanding of the

scope of its problems and identified strategies to improve performance. The licensee had

a contractor provide training to CARB members. This training is being tracked in the

licensees training database and will include annual refresher training. If fully implemented

and continued, this training should improve the adequacy of the identified corrective

actions.

The licensee recently implemented a CR Evaluation Challenge Board and a Corrective

Action Challenge Board, which were intended to ensure that the actions associated with

the CR meet specific qualitative requirements associated with the quality of the action,

including timeliness. The inspectors observed a CAP Challenge Board which reviewed

action closure for multiple CRs. The inspectors observed that the licensee adequately

implemented the performance metrics in accordance with their guidance. The licensee

issued two CRs as the result of the board identifying instances of proposed action closure

not reasonably addressing and/or work performed not fully satisfying, the action during a

meeting observed by the inspectors.

Licensee management began a campaign to communicate to the workforce the changes

to CAP and to improve general employee training relative to the CAP. Based on safety

culture focus group interviews, the team determined that this communication has been

effective.

The licensee increased the awareness and visibility of the current CAP backlog. Having a

large backlog of corrective actions demonstrated untimely corrective action and impeded

future timeliness. The licensees division managers were providing weekly backlog reports

to the Senior Leadership Review Team which included the status of the CAP backlog

reduction curves. This was designed to provide manager accountability for reducing the

number of CAP backlog. Current CAP backlog numbers have been reduced since the

completion of the last refueling outage.

The inspectors also reviewed the status of the licensees completion of corrective actions

associated with issues that were the subject of the NRC 95002 inspection conducted at

Wolf Creek in March 2011 (NRC Inspection Report 05000482/2011006) in order to

determine whether the corrective actions associated with these regulatory issues had been

completed as planned. No significant discrepancies were identified.

The inspectors also reviewed the status of the licensees implementation of two major

improvement projects - ESW system modifications and the PMO project - to improve the

plants equipment reliability and address multiple open, long-term corrective actions. The

ESW improvement project addresses the NRC violation 05000482/2012007-03, Failure to

Take Timely Corrective Action to Preclude Repetition, issued during the 2012 Problem

Identification and Resolution (PI&R) inspection (Inspection Report 05000482/2012007).

- 19 - Enclosure

The associated actions include:

Installation of a system modification to eliminate adverse effects of water

hammer caused by water column separation due to loss of flow and

subsequent flow restoration. At the time of the inspection the modification

design and approval was still in progress.

Installation of approximately 30,000 feet of improved underground ESW piping,

scheduled for completion. The licensee designed the replacement piping to be

thicker and more accessible for condition monitoring. In areas of restricted

inspection capability, the replacement piping will be of a material less

susceptible to degradation.

Monitoring the condition of approximately 9,000 feet of above ground ESW

piping, with plans to replace approximately 2,600 feet of piping. The licensee

was conducting surveys using guided wave technology to monitor and trend the

corrosion status in the above ground piping until the piping replacement

activities are complete.

A chemical injection system upgrade was planned to reduce piping corrosion.

Improved inspection strategies and programs for monitoring the conditions of

lake water piping. System fouling, corrosion, and piping inspection program

procedures were revised to better address long term ESW system degradation

concerns due to chemistry, corrosion, and piping inspection challenges. The

licensees buried piping and tanks program procedure was also revised to

include enhanced guidance for actions in response to the identification of

leakage in buried ESW system piping.

The licensee has developed a PMO project to identify components most important to

normal plant operations and nuclear safety and then develop an improved preventive

maintenance program to improve plant equipment reliability. This program was developed

in response to recent operating history demonstrating issues with regard to reliable plant

operation, including issues captured in CRs 24445 and 23119. The inspectors reviewed

the status of associated actions to implement the PMO project, which included:

Completion of the first of three phases of the PMO project on May 1, 2013. This

phase identified the most significant plant components (described as assets),

including those included in the systems tracked by the Mitigating Systems

Performance Index (MSPI) performance indicator, portions of systems that support

MSPI systems, systems that are most likely to cause a plant trip, and a single point

vulnerability (SPV) analysis of all systems that could contain a potential SPV. The

existing preventive maintenance for these assets was then compared to the PM

templates used in an industry best practices guideline. This effort included

verifying that vendor recommendations for PM were adequately addressed. This

resulted in creating 4,700 new PM activities and improving 2,200 existing PM

activities to industry standards.

- 20 - Enclosure

The licensee commenced the second phase, which will focus on the optimization of

the remaining assets not addressed in phase one. The licensee initially scheduled

completion of phase two in December of 2013. However, phase one completion

was delayed five months resulting in delays in commencing phase two.

Phase three will consist of monitoring and reporting of the implementation of the

new PM strategies and the status of the mitigation activities for identified SPVs.

The licensee plans to complete the new PM activities for SPV by February 2015.

The licensee plans to complete new PM activities for high risk components by

October 2016.

By the time of the inspection, the licensee had completed 267 of the new PM activities.

The inspectors noted that improvement to plant equipment reliability was dependent on

completing the new and improved PM activities, not on completion of the PM documents

themselves. The delay in completing the PMO documentation contributed to performing

relatively few of the new and improved PM activities during the recently-completed

refueling outage. The inspectors determined that the licensee planned to implement the

new and improved PM activities over the 4-year period recommended in the industry

guideline. However, the inspectors pointed out that the industry guideline did not assume

that the licensee was implementing the new PM program to address a known problem with

equipment reliability. The inspectors also determined that the licensee did not prioritize

implementation of the new and improved PM activities based on the current system health

or the safety significance of the assets. The licensee documented this observation in CR

70125 and agreed to consider an implementation schedule that improved the prioritization

of new and improved PM activities.

The inspectors also noted that the PMO equipment screening process was previously

initiated in 2005. However, the screening and categorization was re-performed during the

latest effort because categories had previously been assigned at the system level, which

resulted in over-classifying many assets. The licensee identified numerous assets that

had not previously had an equipment identification number assigned, and therefore had

not been evaluated for needing PM. As a result of more detailed reviews, the number of

assets identified, evaluated, and assigned identification numbers increased from 50,000 to

137,000. Much of this increase was due to the identification of electrical components

located inside cabinets which had previously only been collectively identified with the

cabinet. The licensee identified that these assets included limited-life components, such

as relays and capacitors. The inspectors determined that the licensee did not prioritize

these components for PM or replacement based on their safety significance or age relative

to expected useful life. The licensee entered this into the CAP under CR 70060.

The inspectors also reviewed the licensees efforts to reduce significant backlogs in

maintenance work, engineering work, and the corrective action program. These backlogs

contributed to equipment reliability and procedure and document quality. The inspectors

noted significant progress in each of these areas.

- 21 - Enclosure

P.1.d - Corrective Action Effectiveness Measures

The licensee was using CAP backlog and Equipment Reliability Performance Indicators to

monitor the effectiveness of the corrective actions for the P.1.d SCCI. In addition, the

ESW and PMO projects, when implemented, will significantly reduce the number of open

long term corrective actions identified in the licensees CAP. The licensees goal was to

work off the backlog of corrective actions and shift the plant from having the need to

perform primarily corrective maintenance to having a predominantly preventive

maintenance work load.

The licensee tracked the performance of the PMO project using metrics of monthly status

reports and trending and monitoring implementation status. The inspectors reviewed the

status of the licensees implementation of their effectiveness measures and identified that

no monthly status reports were completed for February through April 2013. The licensee

did complete the status report for the month of May. The inspectors noted that this effort

tracked the completion of PM improvement paperwork, rather than completion of actual

new and improved PM items in the plant. As such, it was not monitoring the completion of

actions that directly improved plant reliability. PM effectiveness was being monitored

using the Equipment Reliability Index developed by EPRI, which uses 19 individual

weighted indicators.

The licensees effectiveness measures for the implementation of the ESW project

consisted of: successful completion of the ESW below ground piping and water hammer

modification by early 2014, zero out-of-service time due to leaking ESW piping, and

performance based self-assessments evaluating the effectiveness of inspection and

monitoring programs of underground piping and tanks scheduled in 2013. The inspectors

noted that these measures were primarily tracking milestone completion, although this was

reasonable given that the milestones were replacing degraded pipe with new pipe.

P.1.d - Results

The inspectors sampled input data and observed that Wolf Creek had self-critical internal

performance measures. The internal metrics for trends in closure of condition reports,

corrective action age, and the maintenance backlog show recent positive improvement,

but the licensee still had major efforts underway to improve known equipment reliability

issues. The licensee had extensive corrective actions in progress that will significantly

improve these metrics by reducing the amount of long term corrective action resulting from

the degraded condition of the ESW system. The licensees ESW underground piping

replacement, corrosion inhibitor injection system and water hammer modifications are

scheduled to be completed by early 2014. Completion of these corrective actions is

essential to the licensees improvement in this area.

- 22 - Enclosure

The effectiveness of increasing the plants equipment reliability due to the implementation

of the PMO program was difficult to determine because of the relatively low number of new

and improved PMs that had been implemented. When fully implemented, the inspectors

concluded that plant reliability will be improved, but the implementation schedule for

completing the Phase 1 PMs in the plant did not appear timely or appropriately prioritized

in light of the known equipment reliability issues.

In response to inspector concerns that certain key equipment reliability issues remain

incomplete, the licensee submitted a letter dated June 27, 2013, which committed to

complete the following actions by the end of the spring 2014 outage:

Install a modification to mitigate ESW system water hammer.

Install and tie-in all below-ground ESW piping.

Replace a minimum of 1200 linear feet of above-ground ESW piping.

H.1.b - Problem Identification

Wolf Creek has had an SCCI in H.1.b, conservative decision-making, for a total of 2 years.

Wolf Creek addressed the H.1.bsubstantive crosscutting issues in three condition reports.

Condition Report 23032 included a root cause evaluation completed for a second time in

September 2010. Condition Report 23032 was initiated in response to the NRCs

identification of problem identification and resolution and human performance SCCIs,

which contributed to the licensees performance that resulted in Wolf Creek being placed

in Column 3 of the NRCs Action Matrix. Condition Reports 32092 and 64785 were also

generated to specifically address conservative decision-making at the station. The

inspectors concluded that the licensee appropriately entered this issue into the CAP.

H.1.b - Evaluation of Root Causes

The inspectors determined that the root and apparent cause evaluations conducted to

address this SCCI were self-critical, and they documented a lack of management

involvement and oversight in effectively overseeing and implementing changes in

behaviors to align organizations and priorities. Another contributing cause identified by the

licensee in Condition Report 32092 was that the procedure used for directing the creation,

review, and approval of basic engineering dispositions did not provide sufficient

instructions for making and documenting assumptions. In addition, the Condition Report

64785 evaluation determined that procedural use and adherence practices were weak,

and that station leadership did not consistently enforce procedure compliance

accountability, allowing some workers to make ill-informed decisions. Also, the licensee

identified in Condition Report 64785 that the station had not developed, implemented,

trained, or enforced a consistent, well understood position-specific and hierarchical level-

specific decision making model. The inspectors concluded that the licensee effectively

identified the causes associated with this SCCI.

- 23 - Enclosure

H.1.b - Corrective Action

The inspectors reviewed the key corrective actions that were most responsive to the

identified root causes. These corrective actions included:

Conduct human performance training for Wolf Creek personnel and supplemental

work force on procedure use and adherence and document quality prior to

refueling outage 19 (Condition Report 55574-02; completed February 2013)

Conduct fundamental training on assessment techniques for operability

determinations and evaluations including extent of condition, justification, and rigor

(Condition Report 23032-02-40,-49,-50; completed March 2011)

Develop and implement a Conduct of Engineering procedure to clearly state

expectations for engineering products and guide engineers in their work with the

various tasks and activities associated with engineering decisions (Condition

Report 64146-01-08; completion planned November 2013)

Communicate key elements of established station procedures regarding usage

standards, specifically the need to stop when unsure and referencing the

accountability and culpability models (Condition Report 65524-02-06; completed

May 2013)

Develop and implement a Change Management Plan to implement the READE

decision making model (Recognize, Express, Appraise, Decide, and Evaluate) at

Wolf Creek Generating Station (Condition Report 64785-02-01; completion planned

September 2013)

Develop and deliver training to groups identified in the training needs analysis for

the READE decision making model before the start of the next planned outage

(Condition Report 64785-02-03; completion planned January 2014)

Based on a sampling review, the inspectors concluded that the corrective actions were

appropriate to address the identified causes associated with this SCCI.

H.1.b - Corrective Action Effectiveness Measures

Wolf Creeks effectiveness review associated with the root cause evaluation documented

in CR 23032 concluded that there was improvement in the decision making area as

demonstrated by:

Improved performance as reflected in site wide performance metrics

Improved performance as reflected in challenge review board data indicating an

average grade of >90%

No apparent cause evaluations or root cause evaluations that had linkage to H.1.b

aspects

- 24 - Enclosure

The final effectiveness follow-up was scheduled to be completed in early 2014. The

inspectors noted that the majority of the proposed corrective actions had only been

relatively recently implemented, and thus had yet to yield a substantial history of

measurable results. The inspectors concluded that the licensee had developed

reasonable effectiveness measures to eventually confirm sustained improvement in

making conservative assumptions and decision making.

H.1.b - Results

The inspectors sampled input data and observed that Wolf Creek had self-critical internal

performance measures because those measurement methods and inputs were found to

reflect NRC identified and licensee-identified issues.

The inspectors noted that, over the last 15 months, the licensee has demonstrated

improved conservative decision making. Inspectors have noted a deliberate effort to

identify assumptions during the decision making process and efforts to confirm or eliminate

those assumptions. This included an increase in the use of vendor representatives,

independent experts, and labs to assess failed parts or samples and help identify

appropriate corrective action. The licensee has also demonstrated an improved record of

undertaking substantial repairs for emergent equipment issues, rather than operating with

a degraded condition until the next outage. Examples included:

Following the January 13, 2012, event, the licensee evaluated each of the

equipment performance problems and completed overhauls or major work to

improve the reliability of those systems.

In response to the declining trend in emergency diesel generator (EDG) reliability

that led to the White MSPI - EAC performance indicator, the licensee undertook a

comprehensive evaluation of EDG maintenance and made improvements and

modifications to both improve reliability and reduce the risk importance of EDGs.

The latter included installation of three non-safety diesel generators to add a

diverse power source.

When a broken cylinder head bolt was identified on an EDG, the licensee sent the

bolt to a lab for analysis and obtained the assistance of an independent expert and

the vendor. The vendor provided an analysis that indicated that the EDG would be

operable with one broken bolt, but the licensee conservatively replaced the broken

bolt and both adjacent bolts, then promptly performed non-destructive

examinations of the head bolts on all EDGs.

When elevated vibrations were observed on the turbine-driven auxiliary feedwater

pump, the licensee promptly performed maintenance and conservatively replaced

the affected bearing.

On two occasions, the licensee initiated plant shutdowns due to degraded

performance of the Class 1E chillers. The licensees evaluations of the condition in

each case demonstrated conservative decision making with respect to

determinations of the equipments ability to perform for its full mission time that did

not rely on unverified assumptions.

- 25 - Enclosure

The licensee conservatively took the unit off line to promptly repair a stator cooling

water leak at a weld, in order to avoid a challenging to safety if the leak were to

degrade suddenly. This decision was made in part because the licensee could not

verify the extent of the weld flaw due to the geometry.

The inspectors noted that recent initiatives to improve plant safety margin, such as

replacement of reactor coolant pump seal packages, and proposed addition of station

blackout diesel generators as well as adding a fourth auxiliary feedwater pump,

demonstrated an increase in conservative philosophy.

The licensees metrics established for monitoring performance trends show recent positive

improvement. The inspectors concluded that the identified corrective actions, when fully

implemented, should be adequate to appropriately address the identified problems in

conservative assumptions and decision making. The inspectors also noted that the

number of NRC findings caused by non-conservative decision making has significantly

improved for the most recent 12 month period. While the licensee has scheduled further

corrective actions to improve the stations culture for making decisions at all levels, station

management has clearly had a positive impact on decision making in high-visibility

examples.

H.2.c - Problem Identification

Wolf Creek has had an SCCI in H.2.c, complete and accurate documentation, procedures

and work packages, substantive crosscutting issue for a total of 2 1/2 years. Wolf Creek

addressed the H.2.csubstantive crosscutting issue in two main condition reports.

Condition Report 65224 included a common cause evaluation performed as a result of

numerous previous condition reports to ensure the previously identified incorrect behaviors

and products are identified and resolved. Condition Report 59217 involved a collective

significance evaluation to address the inability to sustain improved performance following

the 2011 IP 95002 NRC inspection. The inspectors concluded that the licensee

appropriately entered this issue into the CAP.

- 26 - Enclosure

H.2.c - Evaluation of Root Causes

The licensees evaluations identified that the common and contributing causes involved

operations, engineering and maintenance department procedures that lacked clarity and

accuracy, and that management had established a culture that promoted harmony rather

than performance improvement, accountability, and adherence to standards. Additionally,

the licensee identified that personnel were willing to work around procedure adequacy

issues and perform the task as they assumed it should be done, rather than stopping to

get the procedure fixed. The Condition Report 59217 evaluation identified similar common

causes of leadership not aligning station behaviors. The inspectors determined that the

licensees evaluations appropriately identified the causes associated with this SCCI.

H.2.c - Corrective Action

The inspectors reviewed the key corrective actions in this area. The licensee implemented

a Procedure Upgrade Project, in which a review of all the maintenance procedures

currently in use (approximately 1,550) is planned, including revisions if necessary. This

plan included prioritization of the procedures into six groups. The plan will work from the

highest priority to the lowest with a expected completion in 2016. At the time of this

inspection, the licensee had approximately 1,062 maintenance procedures remaining to

review.

Additionally, the licensee implemented an in-line review process for all work orders. This

review evaluates all work orders for adequacy once they have been placed in the

planning complete status prior to the applicable work group performing in-plant

walkdowns of the work orders. As discussed, the licensee was also addressing PM

instructions through the PMO project. The licensee also created a process for workers to

provide feedback for procedure improvement.

The licensee also implemented an Operations Procedure Optimization Project to address

concerns within the operations procedures. This project is focused on human factoring of

the procedures, specifically related to ambiguity and wordiness of procedure steps. This

effort was primarily focused on general operating procedures because their evaluation

identified that most operator procedure issues involved these complex and infrequently

used procedures. The team noted that the licensee had recently upgraded their

emergency operating procedures and related support procedures. An evaluation showed

that other procedures were written to industry standards. The licensee also planned to

upgrade their system operating procedures and surveillance procedures by 2016.

The inspectors assessed workers willingness to stop when they identify procedure

problems through interviews and focus group discussions. The inspectors determined that

the licensee has successfully ingrained in workers the expectation that they should not

accept poorly written procedures, and to stop and get the procedure fixed. Additionally,

the inspectors observed that station management is more engaged with aligning the

station to be more focused on accountability and procedure adherence, and not accepting

sub-standard performances.

- 27 - Enclosure

H.2.c - Corrective Action Effectiveness Measures

The licensee developed internal performance indicators for evaluation quality, including

the results from the operations, engineering, and maintenance procedure quality feedback

processes. These metrics were noted to have a declining trend, but this was indicative of

station personnel being less tolerant of procedure issues, and more sensitive to the

identification of potential procedure problems. This trend is expected during the onset of

the change in process and will provide insight into the effectiveness of the corrective

actions. Additionally, the station will rely on feedback from challenge review boards such

as the Nuclear Safety Review Board (NSRB), Management Review Meeting (MRM) and

the Plant Safety Review Committee (PSRC).

H.2.c - Results

The inspectors concluded that the actions identified by the licensee have the potential to

be effective if completed as planned. The corrective action to review and upgrade

procedures is scheduled to be completed through 2016. The inspectors expressed

concern that this might not be appropriately prioritized or timely. However, the inspectors

noted that the licensee had clearly strengthened the first line of defense, namely getting

workers to identify unclear procedures and stop work in order to get the document

corrected. This action has been effective in reducing the number of NRC findings

involving inadequate procedures.

In response, the license submitted a letter dated June 27, 2013, committing to completing

the reviews of the highest priority procedures below by the end of the spring 2014 outage:

General operating procedures that direct operation from full power to cold

shutdown, and cold shutdown back to full power. These procedures were involved

in the majority of NRC findings involving inadequate operations procedures.

Forty percent (107 of 267) of the technical specification surveillance procedures

performed by maintenance personnel will be reviewed and prioritized on the basis

of importance and frequency so that the most commonly performed procedures will

be reviewed first.

The inspectors concluded that the identified corrective actions, when fully implemented,

should be adequate to appropriately address the identified problems in the area of

complete and accurate documentation. While a substantial portion of the reviews to

ensure that procedures are up to industry standards have not been completed, the

inspectors noted that the number of NRC findings caused by inadequate procedures and

documentation has significantly improved for the most recent 12 months. This was likely

caused by changes in the culture that had previously tolerated unclear procedures.

- 28 - Enclosure

.2 Independent Safety Culture Assessment Follow-up

a. Inspection Scope

Due to the potential causal contributions of safety culture issues to the Yellow finding, a

limited scope independent safety culture assessment follow-up inspection using the

guidance in IP 40100, Independent Safety Culture Assessment Follow-up, was included

in this supplemental inspection. The purpose of the assessment was to follow-up on the

results of independent safety culture assessments that had been performed by the

licensee. The inspection team assessed the licensees response to the results of its

independent safety culture assessments, including whether improvement has been

demonstrated in areas of concern. The inspectors also independently assessed the state

of safety culture at the station, including its safety-conscious work environment (SCWE)

through a series of focus group interviews conducted during the inspection.

b. Findings and Assessment

No findings were identified.

To assess Wolf Creeks safety culture, the team conducted five focus groups, interviewing

a total of 46 licensee personnel at the individual contributor level. These personnel had

been at Wolf Creek for as long as 35 years and as short as six months (mean tenure was

17.5 years; median 20.5 years). The team also met with several managers to discuss the

status of the stations safety culture improvement efforts.

The inspectors determined that the licensees nuclear safety culture was adequate to

support nuclear safety, and was improving. However, the team noted a number of safety

culture challenges within a few work groups, primarily in the communication of supervisor

expectations and in the ability and willingness of some personnel to document potential

issues in the CAP. This is supported by the following examples:

During a CARB meeting observed by the inspection team, the CARB observed that

an individual had failed to initiate CRs for several conditions identified during an

evaluation.

A small minority of individuals expressed hesitation with using the CAP. In a

survey conducted by the licensee the week of April 2, 2013, the vast majority (96%)

of respondents indicated that their supervisors encourage them to write CRs for

adverse conditions. However, a number of write-in comments indicated that some

individuals may feel differently. The licensee administered the survey and

addressed these comments under CR 66222. In response to the survey, actions

were assigned to several managers to reinforce managements expectation that

CRs be initiated for all adverse conditions. On May 16 and 22, 2013, the licensees

Nuclear Safety Culture Monitoring Panel reviewed the results of these discussions.

Based on the panels review, the licensees senior leadership team initiated

additional follow-up actions on May 31, 2013, under CR 69884.

- 29 - Enclosure

Several individuals (both survey respondents and focus group interviewees) noted

that some supervisors expect that they be consulted before individuals initiate CRs.

It was not clear whether the intent of this expectation is to ensure clarity or to avoid

issues being placed into the CAP. However, it is possible that this could result in

some issues not being documented in the CAP. Further, on April 2, 2013, in a

licensee safety culture survey, 17.6% of respondents agreed with the statement I

work with my supervisor to fix problems without having to document it in the

corrective action program.

The difficulty of responding to CRs, mostly because of the unwieldiness of the

software, intimidates many individuals and likely prevents some CRs from being

initiated when it would be appropriate.

The inspectors noted that the licensee was taking actions to address individuals hesitancy

to initiate CRs, as documented in CRs 66222 and 69884. Licensee management had

recognized a weakness in CR initiation and was taking actions to attempt to remedy the

problem. However, not all first-line supervisors appear to have accepted the philosophy;

this appears to be largely due to high workload and limited resources, though part of the

problem appears to be the licensees CAP software.

Several individuals expressed frustration with both the quantity and quality of procedure

changes implemented in response to station events:

Individuals who will implement the procedures are not always consulted in their

development. This has led to some potential improvements being overlooked.

The large number of procedures results in unwieldy processes. Several individuals

noted that they often have to have as many as five procedures open at once while

accomplishing work tasks on their job sites.

To address the overall station safety culture, licensee management implemented an

accountability model. This model includes expectations that leaders and individual

contributors work together to establish and meet expectations. The licensee noted that

when this model was initially implemented in August 2011, it was not universally accepted.

The inspectors determined that station management has since reestablished the

expectation that the model be used. While most workgroups at the station use the model,

the team identified two groups that have not fully implemented it:

The Quality group does not effectively implement the accountability model.

Individuals interviewed by the team noted that at least one supervisor in QA

specifically declined to explicitly define expectations for the workgroup.

The Clearance Order group has also not fully implemented the accountability

model. Licensee personnel noted that this may be due to a large number of long-

term contractors in the group.

- 30 - Enclosure

Additionally, even in the groups that fully use the model, the implementation of the model

is not always consistent. Several focus group interviewees noted that though the model

includes involving employees in setting expectations, some supervisors simply dictate

these expectations. The interviewees noted that this made the model less effective. This

lack of involvement of employees in setting expectations and the previously discussed lack

of involvement of individual contributors in drafting or changing procedures both indicate a

potential challenge in communication at non-management levels of the organization.

Following the licensees 2012 safety culture survey, licensee management identified two

work groups as needing to improve their safety culture due to responses on the 2012

safety culture assessment. The inspectors selected these groups for two of the focus

group sessions. The focus group discussions indicated significant improvement in one of

the groups, primarily due to the manager of that organization using an inclusive method to

identify the issues and identify ways to improve. However, improvement was not apparent

in the Quality group. The Quality management team apparently did not conduct an

evaluation of the causes, or involve workers in assessing challenges and corrective action.

The inspectors noted that the licensee created a program to identify and improve safety

culture, but failed to provide resources or tools to assess the causes or identify

improvement items. Additional actions will be needed to improve the safety culture

challenges in the Quality group.

Additionally, the inspectors determined that the licensee has challenges in the safety-

conscious work environment (SCWE) in its Quality organization. The inspectors identified

that individuals in this group do not feel free to raise some types of concerns in condition

reports or to discuss some types of issues with their management. Individuals in the QA

organization also stated that they feel that they have been discouraged from initiating CRs.

This was also indicated by the licensees survey results and was corroborated by focus

group interviews conducted by the inspection team. However, despite these challenges,

individuals in the Quality organization indicated no hesitance to raise nuclear safety

concerns and to enter such concerns into CAP.

The team also identified an issue with the licensees training program. During two focus

groups, interviewees identified that there were problems with training across the

organization. The identified challenges mostly fell into two categories: instructor quality in

some training groups and implementation of the on-the-job training/task performance

evaluation (OJT/TPE) program. Interviewees also noted specific problems with some of

the licensees initial training, particularly for outage contractors, in that the training is not

designed for workers who are new or unfamiliar with nuclear plants, but is still given to

individuals who are new to the nuclear industry.

Overall, the inspectors concluded that the licensee was aware of its safety culture

problems, beyond just those indicated by its substantive cross-cutting issues. The

licensee was taking significant actions to remedy the problems. These actions included

implementing periodic training for all employees, establishing a Nuclear Safety Culture

Monitoring Team, and lowering thresholds for identification of safety culture precursors.

However, based on its focus group interviews and recent survey results, the team

concluded that these process improvements have not been in place long enough to be

fully effective, and that additional action is needed in the QA Group. Despite these specific

challenges, the inspectors concluded that the licensee was maintaining a SCWE that was

adequate to support nuclear safety.

- 31 - Enclosure

4OA6 Meetings

Exit Meeting Summary

On June 7, 2013, the inspectors presented the inspection results to Mr. M. Sunseri and

other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors identified that proprietary information was reviewed but would not be

retained following report issuance or included in the inspection report.

- 32 - Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Baban, Manager Systems Engineering

P. Bedgood, Manager, Radiation Protection

R. Bowie, Senior Project Manager, Major Modifications

J. Broschak, Vice President, Engineering

A. Camp, Plant Manager

R. Clemens, Vice President, Strategic Projects

S. Henry, Manager Operations

W. Muilenburg, Supervisor Licensing

G. Pendergrass, Manager Station Recovery

L. Ratzlaff, Manager Maintenance

R. Rumas, Manager Quality Assurance

R. Smith, Site Vice President

M. Sunseri, President and CEO

M. Westman, Manager Regulatory Affairs

J. Yunk, Manager Corrective Actions

NRC Personnel

C. Peabody, Senior Resident Inspector

A1-1 Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

05000482/2012009-01 NOV Failure to Provide Adequate Oversight of Contractors During

Maintenance on the Startup Transformer (Section 4OA4)

Discussed

05000482/2012007-03 NOV Failure to Take Timely Corrective Action to Preclude

Repetition (Section 4OA4)

LIST OF DOCUMENTS REVIEWED

PROCEDURES

NUMBER TITLE REVISION

AP 15C-001 Procedure Writers Guide 26

AP 15C-002 Procedure Use and Adherence

AP 22C-004 Operability Determination and Functionality 27

Assessment

AP 27-007 Nonconforming and Degraded Conditions 9

AI 28A-018 Corrective Action Review Board 0

AI 22C-010 Operation Work Control 16

AI 22C-012 Quality Review Team (QRT) for Maintenance Work 3

Planning

AP 09F-001 Business Planning Draft

GEN 00-003 Hot Standby to Minimum Load 91

AI 28A-018 Corrective Action Review Board 0

AI 36-001 Nuclear Safety Culture Monitoring 1 (with

OTSC 13-

0022)

AP 36-001 Nuclear Safety Culture 3

AP 20B-001 Plant Safety Review Committee 12

AI 13E-015 Wolf Creek Leadership and Accountability Model 5A

AI 13E-015 Wolf Creek Leadership and Accountability Model 0

AI 34-010 Human Performance Tools 0

AP 28A-100 Condition Reports 20A

AI 28A-100 Cause Analysis 4

AI 28A-010 Screening Condition Reports 15

A1-2 Attachment

AI 28A-017 Effectiveness Follow-up 3

APF 24-002-09 WCNOC Service Requisition Check List 16

AP 24-002 Requisition and Procurement Process 26

AP 20A-008 QA Surveillance and Station Monitoring Program 13

AI 24A-009 Non-Stock Requisition Processing for Service Labor 16

Items

AP 05-013 Review of Vendor Technical Documents 8

CONDITION REPORTS

23032 23119 24445 32092 34886

55574 59217 59491 60371 60460

60929 61559 64146 64785 65524

66222 68760 69139 34281 54136

50009 47670 47653 49386 37200

22444 49616 33692 47937 56134

68875 54083 54084 54085 54086

66459 68680 66719 67789 68165

60767 25062 33909 34465 46105

64183 64992 66350 67272 68137

67318 68345 15409 69250 69251

62999 63128 34455 55994 69777

53445 54994 59762 59760 59761

25662 36789 38165 68393 69884

36743 38520 42367 65249 68482

25887 28474 31111 31455 33102

33869 38517 34609 34896 36724

42357 42362 42363 42364 42365

42366 48636 42368 42369 51952

52419 52694 53443 23852 63969

65178 26805 66982 68108 68111

68355 68479 25896 68685 68487

68489 68751 69067 25817 19245

34280 33435 33750 33395 39844

68801 32705 68115 43710 41915

A1-3 Attachment

34279 67873 26608 27877 70131*

70171* 70064* 70132* 70133* 70110*

70123* 70122* 70121* 70120* 70125*

70106* 70093* 70088* 70087* 70047*

70028* 70096* 70088* 70087* 70004*

70072* 69956* 69955* 70073* 70063*

70016* 70060* 70061* 69983* 69982*

69967* 69954* 69945* 70100* 70004*

69982* 70078* 70130*

• Condition Reports generated during the inspection

A1-4 Attachment

DRAWINGS

NUMBER TITLE REVISION

E-13PA12 Startup Source 13.8kV Bus PA01 Feeder Brkr 5

252PA0110

E-13PA12 Startup Source 13.8kV Bus PA01 Feeder Brkr 5

252PA0110

M-13EF01 Piping Isometric Essential Service Water System 26

Control Bldg. A & B Train

M-13EF02 Piping Isometric Essential Service Water System Aux. 10

Bldg. A & B Train

M-13EF03 Piping Isometric Essential Service Water System Aux. 21

Bldg. A Train

M-13EF04 Piping Isometric Essential Service Water System Aux. 13

Bldg. B Train

M-13EF05 Piping Isometric Essential Service Water System Aux. 13

Bldg. B Train Return

M-13EF06 Piping Isometric Essential Service Water System Aux. 16

Bldg. A & B Train Supply & Return

M-13EF07 Piping Isometric Essential Service Wtr. Sys. Control 3

Bldg. D.G. Cooler (A&B) Train Supply & Rtn.

M-13EF14 Piping Iso./Essential Service Wtr. Sys. Class 1E 6

Switchgear A/C Condenser Control Bldg. A Train

M-13EF15 Piping Isometric Essential Service Water System Class 5

1E Switchgear A/C Condenser Control Building B

Train

M-13GN01 Piping Isometric Containment cooling System Reactor 4

Building Train A

M-13GN02 Piping Isometric Containment cooling System Reactor 5

Building Train B

M-KC0111 ESWS Pumphouse Piping Plan 25

LERs

NUMBER TITLE DATE

2013-003-00 Movement of Irradiated Fuel Progressed After April 15, 2013

Non-Conservative Decision Making Resulted in

Removal of One Source Range Monitor from Service

A1-5 Attachment

WORK ORDERS

12-351611-014 12-351847-000 12-351850-000 12-351851-000 12-351852-000

11-342808-006 11-342821-014 11-342432-026 11-342-808-002 10-333110-026

10-333111-145 12-361103-198 12-361103-199

PURCHASE ORDERS

765347 765193 742810 750883 755955

757508 764579

SURVEILLANCES

QS 2012-0313 QS 2012-0242 QS 2012-0422 QS 2013-0512

MISCELLANEOUS

NUMBER TITLE REVISION /

DATE

Quality Division Fundamental Behaviors June 18,

2012

Engineering Department Fundamental Behaviors June 18,

2012

Operations Division Fundamental Behaviors June 4, 2012

Maintenance Division Fundamental Behaviors April 10,

2012

Health Physics Division Fundamental Behaviors May 18, 2012

Wolf Creek Engineering Technical Rigor Expectations May 2013

TIN# HU Pre-Outage Dynamic Learning Activity - The Film

HU1445501 Festival

Prompt Operability Determination Challenge Checklist

Maintenance Procedure Improvement Project - #500408

List and Status of Priority One Maintenance Procedures June 6, 2013

Recovery team H2C Closure Package Status May 31, 2013

Summary of Open PRCs by Priority June 6, 2013

Closure Review Board Package for 25062-02-01 Quality May 15, 2013

Review Team Procedure

A1-6 Attachment

MISCELLANEOUS

NUMBER TITLE REVISION /

DATE

Closure Review Board Package for 25062-02-02 Quality May 15, 2013

Review Team Procedure

Condition Reports for Daily SRT Meeting June 5, 2013

Grading Criteria for CR Immediate Operability

Determination (IOD) and Functionality Assessment (FA)

Performance Indicator

P.1(c) and P.1(d) SCCI Performance Monitoring Metrics April 2013

AIF 28A-018-01 CARB Grading Standard for RCA 0

AIF 28A-018-02 CARB Grading Standard for ACE 0

Corrective Action Review Board Agenda June 5, 2013

Nuclear Safety Culture Monitoring Senior Leadership Team May 16, 2013

Minutes

Nuclear Safety Culture Monitoring Senior Leadership Team May 22, 2013

Minutes

Nuclear Safety Culture Monitoring Senior Leadership Team May 31, 2013

Minutes

P.1(c) and P.1(d) SCCI Performance Monitoring Metrics March 2013

P.1(c) and P.1(d) SCCI Performance Monitoring Metrics April 2013

Training Materials: Wolf Creek Generating Station Cause

Evaluation Techniques

Training Materials: Wolf Creek Generating Station

Corrective Action Review Board

Training Materials: Wolf Creek Generating Station Human

Performance

Training Materials: Wolf Creek Generating Station

Interviewing

Training Materials: Wolf Creek Generating Station

Introduction to Cause Evaluations

AIF 28A-018-01 CARB Grading Standard for RCA 0

AIF 28A-018-02 CARB Grading Standard for ACE 0

GT1245001 Lesson Plan: Site Access Training Site Specific 26

TG1645500 Lesson Plan: Safety Culture - Whats at Stake? 0

A1-7 Attachment

MISCELLANEOUS

NUMBER TITLE REVISION /

DATE

Plant Health Committee Meeting Agenda June 3, 2012

2012 System Health Report - Component Cooling Water May 22, 2013

2012 System Health Report - Control Building HVAC May 22, 2013

2012 System Health Report - Emergency Diesel May 22, 2013

Generators

2012 System Health Report - Low Voltage Non-Class 1E May 22, 2013

2012 System Health Report - Essential Service Water May 22, 2013

Closure Review Board for 34886-02-02, 09, 10 Leadership May 15, 2013

Model

Closure Review Board for 34886-02-02, 13 Fundamental May 15, 2013

Behaviors

PMO Status Report January 2013 January 2013

PMO Status Report May 2013 May 2013

PMO Project Report 4, 7

Single Point Vulnerability (SPV) Review Phase V Report June 2012

PMO Phase 1 Assets List

QH 1921 Quick Hit Detail Report September

30, 2010

QH 1942 Quick Hit Detail Report October 7,

2010

QH 2011-0021 Quick Hit Detail Report October 6,

2011

QH 2035 Quick Hit Detail Report April 5, 2011

CSM 3386 Computer Software Management Freeform May 16, 2012

PMC Backlog April 2013

P-WCNOC- PMO-Current Transformer Templates

000400

P-WCNOC- PMO-Panel Templates

000404

P-WCNOC- PMO Current Transformer Templates

000401

A1-8 Attachment

MISCELLANEOUS

NUMBER TITLE REVISION /

DATE

CARB Meeting Minutes May 8, 2013

CARB Meeting Minutes May 15, 2013

CARB Meeting Minutes May 22, 2013

CARB Meeting Minutes May 29, 2013

Plant Health Committee Meeting Agenda June 3, 2013

Current WCNOC Maintenance Rule (a)(1) Issues May 22, 2013

IIT 10-01 Investigation into the material Condition of ESW Piping and

Events from CR 00026466 and CR 00028474

Corrective Action Backlog Reduction Initiative May 6, 2013

Essential Service Water Presentation June 3, 2013

P.1(c) and P.1(d) SCCI Performance Monitoring Metrics April 2013

ES1337401 Lesson Plan: Troubleshooting DLA 000

CN-RAM-13-010 Wolf Creek PSA Revision 6 Model-of-Record 0

A1-9 Attachment