ML12191A269

IR 05000482-12-006, on May 7, 2012 & May 24, 2012, Wolf Creek Biennial Baseline Inspection of the Identification and Resolution of Problems.

ML12191A269
Person / Time
Site:	Wolf Creek
Issue date:	07/05/2012
From:	Powers D Division of Reactor Safety IV
To:	Matthew Sunseri Wolf Creek
References
EA-12-135 IR-12-007
Download: ML12191A269 (47)

See also: IR 05000482/2012006

Text

UNITE D S TATE S

NUC LEAR RE GULATOR Y C OMMI S SI ON

RE G IO N I V

1600 EAST LAMAR BLVD

AR L INGTON , TEXAS 7 60 11 - 4511

July 5, 2012

EA-12-135

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 PROBLEM IDENTIFICATION

AND RESOLUTION INSPECTION REPORT 05000482/2012007 and NOTICE

OF VIOLATION

Dear Mr. Sunseri:

On May 24, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a biennial

Problem Identification and Resolution inspection at your Wolf Creek Generating Station. The

enclosed inspection report documents the inspection results, which the team discussed on May

24, 2012, with you and members of your staff.

This inspection was an examination of activities conducted under your license as they relate to

problem identification and resolution and compliance with the Commissions rules and

regulations and the conditions of your license. Within these areas, the inspection involved

examination of selected procedures and representative records, observations of activities, and

interviews with personnel.

Based on the inspection sample, the inspection team concluded that the implementation of the

corrective action program and overall performance related to identifying, evaluating, and

resolving problems at Wolf Creek was adequate. Licensee-identified problems were generally

entered into the corrective action program at a low threshold, though the team noted some

exceptions, as documented in the enclosed report. Problems were generally prioritized and

evaluated commensurate with the safety significance of the problems. And, though the team

identified challenges to corrective action timeliness, most actions were implemented in a timely

manner commensurate with their safety significance and addressed the causes of the problems.

Lessons learned from industry operating experience were effectively reviewed and applied

when appropriate. Audits and self-assessments were effectively used to identify problems and

determine appropriate actions. Finally, the team determined that the station maintains a safety

conscious work environment where employees feel free to raise nuclear safety concerns without

fear of retaliation.

Six NRC-identified and two self-revealing findings of very low safety significance (Green) were

identified during this inspection and are documented in the enclosed report.

M. Sunseri -2-

Seven of these findings were determined to involve violations of NRC requirements.

Additionally, the NRC determined that one Severity Level IV traditional enforcement violation

occurred; this violation had no associated finding. The NRC is treating six of the eight violations

as non-cited violations (NCVs), consistent with Section 2.3.2 of the Enforcement Policy.

Two of the findings that the NRC evaluated under the risk significance determination process as

having very low safety significance (Green) did not meet the criteria to be treated as non-cited

violations. The violations associated with both of these issues were evaluated in accordance

with the NRC Enforcement Policy. The current version of this Policy is available on the NRC

website at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. These

violations are cited in the enclosed Notice of Violation (Notice) and the circumstances

surrounding them are described in detail in the subject inspection report. The violations are

being cited in the Notice because after the violations were previously documented as non-cited

violations, you failed to restore compliance within a reasonable time.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. Specifically, you are requested to provide a

firm commitment as to when plant modifications will be completed to prevent future water

hammer events in the essential service water system. If you have additional information that

you believe the NRC should consider, you may provide it in your response to the Notice. The

NRCs review of your response to the Notice will also determine whether further enforcement

action is necessary to ensure compliance with regulatory requirements.

If you contest any of these findings, you should provide a response within 30 days of the date of

this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission,

ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional

Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory

Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Wolf Creek.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at

Wolf Creek.

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 Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA/

Dr. Dale A. Powers, Chief (Acting)

Technical Support Branch

Division of Reactor Safety

Docket No: 50-482

License No: NPF-42

Enclosures:

1. Notice of Violation EA-12-135

2. Inspection Report 05000482/2012007

w/ Attachments:

1. Supplemental Information

2. Information Request

cc w/ encls: Electronic Distribution for Wolf Creek

ML12191A269

SUNSI Rev Compl. ;Yes No ADAMS ;Yes No Reviewer Initials EAR

Publicly Avail. ;Yes No Sensitive Yes ; No Sens. Type Initials EAR

RIV/DRS/TSB DRS/EB2 DRS/OB DRS/EB2 DRP/PBB

ERuesch SMakor TFarina MWilliams LWilloughby

/RA/ /RA/ /RA-E/ /RA/ /RA/ - e-mail

7/05/2012 6/27/2012 6/27/2012 7/3/2012 7/03/2012

DRP/PBB NRR/DRA/AHPB C:DRP/PBB C:ORA/ACES AC:DRS/TSB

CPeabody KMartin NOKeefe HGepford DPowers

/RA/ - e-mail /RA-E/ /RA/ - e-mail RKellar for /RA/ /RA/

6/26/2012 6/21/12 7/03/2012 7/05/2012 7/05/2012

NOTICE OF VIOLATION

Wolf Creek Nuclear Operating Company Docket No: 50-482

Wolf Creek Generating Station License No: NPF-42

EA-12-135

During an NRC inspection, conducted from May 7 through 24, 2012, two violations of NRC

requirements were identified. In accordance with the NRC Enforcement Policy, the violations

are listed below:

1. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in

part, that in the case of significant conditions adverse to quality, measures shall

assure that the cause of the condition is determined and corrective action taken

to preclude repetition.

Contrary to the above, from December 4, 2009, to May 24, 2012, the licensee

failed to assure that the cause of a significant condition adverse to quality was

determined and corrective action was taken to preclude repetition. Specifically,

after a water hammer event on August 19, 2009, the licensee failed to perform an

adequate evaluation to determine the cause of water hammers and of internal

corrosion in the essential service water system, and did not take corrective action

to preclude repetition of additional water hammer events and system leaks. The

condition recurred on January 13, 2012. This violation was identified on two

occasions by the NRC as NCV 05000482/2009007-03 and VIO

05000482/2012007-03; the licensee failed to restore compliance.

2. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in

part, that measures be established to assure that conditions adverse to quality

are promptly identified and corrected.

Contrary to the above, as of May 24, 2012, the licensee had failed to establish

measures to assure that a condition adverse to quality was promptly corrected.

Specifically, after identifying that safety-related spring-loaded tornado dampers

required testing to verify operability, the licensee failed to implement procedures

to test these dampers in the emergency diesel generator and essential service

water rooms. This violation was previously identified by the NRC as

NCV 05000482/2010007-02; the licensee failed to restore compliance.

These violations are associated with Green Significance Determination Process findings.

Pursuant to the provisions of 10 CFR 2.201, Wolf Creek Nuclear Operating Company is hereby

required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the

Regional Administrator, Region IV, and a copy to the NRC Resident Inspector Wolf Creek

Generating Station, within 30 days of the date of the letter transmitting this Notice of Violation

(Notice). This reply should be clearly marked as a "Reply to Notice of Violation EA-12-135," and

should include: (1) the reason for the violation, or, if contested, the basis for disputing the

violation or severity level, (2) the corrective steps that have been taken and the results

achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date

when full compliance will be achieved. Your response may reference or include previous

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docketed correspondence, if the correspondence adequately addresses the required response.

If an adequate reply is not received within the time specified in this Notice, an order or a

Demand for Information may be issued as to why the license should not be modified,

suspended, or revoked, or why such other action as may be proper should not be taken. Where

good cause is shown, consideration will be given to extending the response time. If you contest

this enforcement action, you should also provide a copy of your response, with the basis for

your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory

Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the

NRC website at www.nrc.gov/reading-rm/pdr.html or www.nrc.gov/reading-rm/adams.html, to

the extent possible, it should not include any personal privacy, proprietary, or safeguards

information so that it can be made available to the public without redaction. If personal privacy

or proprietary information is necessary to provide an acceptable response, then please provide

a bracketed copy of your response that identifies the information that should be protected and a

redacted copy of your response that deletes such information. If you request withholding of

such material, you must specifically identify the portions of your response that you seek to have

withheld and provide in detail the basis for your claim of withholding (e.g., explain why the

disclosure of information will create an unwarranted invasion of personal privacy or provide the

information required by 10 CFR 2.390(b) to support a request for withholding confidential

commercial or financial information).

Dated this 5th day of July, 2012.

-2-

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-482

License: NPF-42

Report: 05000482/2012007

Licensee: Wolf Creek Nuclear Operating Corporation

Facility: Wolf Creek Generating Station

Location: 1550 Oxen Lane SE

Burlington, Kansas

Dates: May 7 through May 24, 2012

Team Leader: E. Ruesch, Senior Reactor Inspector

Inspectors: L. Willoughby, Senior Project Engineer

C. Peabody, Resident Inspector

M. Williams, Reactor Inspector

T. Farina, Operations Engineer

S. Makor, Reactor Inspector

K. Martin, Human Factors Engineer

Accompanying C. Franklin, General Engineer (NSPDP)

Personnel:

Approved By: Dr. Dale A. Powers, Chief (Acting)

Technical Support Branch

Division of Reactor Safety

-1- Enclosure 2

SUMMARY OF FINDINGS

IR 05000482/2012006; May 7, 2012 - May 24, 2012; Wolf Creek "Biennial Baseline Inspection

of the Identification and Resolution of Problems."

The team inspection was performed by one senior reactor inspector, one senior project

engineer, one resident inspector, one operations engineer, two reactor inspectors, and one

human factors engineer. Two cited violations and six non-cited violations of very low safety

significance (Green) were identified during this inspection. One severity level IV (SL-IV)

violation was also identified. The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination

Process." Findings for which the significance determination process does not apply may be

Green or be assigned a severity level after NRC management review. 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.

Identification and Resolution of Problems

The team reviewed approximately 300 condition reports, work orders, engineering evaluations,

root and apparent cause evaluations, and other supporting documentation to determine if

problems were being properly identified, characterized, and entered into the corrective action

program for evaluation and resolution. The team reviewed a sample of system health reports,

self-assessments, trending reports and metrics, and various other documents related to the

corrective action program.

Based on these reviews, the team concluded that the licensees corrective action program and

its other processes to identify and correct nuclear safety problems were adequate to support

nuclear safety. However, the team noted several challenges to licensee staffs willingness to

use the corrective action program for problems that were perceived as minor. The team also

noted several challenges to timely evaluations of adverse conditions. Further, the licensee had

several long-standing issues which had been in process for several years without resolution.

The team also concluded that the licensee thoroughly evaluated industry operating experience

for relevance to the facility, generally took prompt actions in response to relevant items, and

entered them into the corrective action program as appropriate. The licensee used industry

operating experience when performing root and apparent cause evaluations. The licensee

performed effective audits and self-assessments, demonstrated by self-identification of

marginally effective corrective action program performance and some identification of ineffective

corrective actions. While there had been some weaknesses in the quality assurance

organizations follow-up on audit findings, the team determined that recent program changes

had addressed these issues.

Finally, the team determined that the station continued to maintain a safety conscious work

environment. Employees felt free to raise nuclear safety concerns to the attention of

management without fear of retaliation.

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A. NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

• Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix

B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to

adequately translate design information into procedures and requirements.

Specifically, the licensee had information that its calculation for vital switchgear

cooling included nonconservative assumptions. These assumptions called into

question the ability of air conditioning systems to adequately cool Class 1E

switchgear under all design conditions. The licensee failed to revise procedures to

include compensatory actions necessary to ensure the vital switchgear remained

operable. The licensee entered this finding in its corrective action program as

condition report 53393.

The inspectors determined that the licensees failure to adequately translate design

information into procedures was a performance deficiency. The performance

deficiency is more than minor because it affected the equipment performance

attribute of the Mitigating Systems cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences. Using Inspection Manual Chapter 0609.04, Phase 1 -

Initial Screening an Characterization of Findings, the team determined the finding

was of very low safety significance (Green) because it did not represent a loss of

system safety function, did not represent the actual loss of safety function of a single

train for greater than its technical specification allowed outage time, and did not

screen as potentially risk significant due to a seismic, flooding, or severe weather

initiating event. The finding has a cross-cutting aspect in the corrective action

component of the problem identification and resolution cross-cutting area because

the licensee failed to thoroughly evaluate the problem such that its resolution

addressed its causes and extent of conditions (P.1(c)). (Section 4OA2.5.a)

• Green. The inspectors identified a violation of 10 CFR 50, Appendix B, Criterion XVI,

Corrective Action, for the licensees failure to take corrective action to preclude

repetition of system leaks due to water hammer events in the essential service water

system. Extensive inadequately evaluated corrosion in the system has led to

multiple water-hammer-induced leaks of essential service water piping. These leaks

were the subject of two previous violations issued by the NRC. The licensee failed to

take timely corrective action to restore compliance. The licensee entered this finding

in its corrective action program as condition report 53443.

The failure to preclude recurrence of water hammer in the essential service water

system and the failure to take adequate corrective action to control internal pitting

corrosion in essential service water system piping was a performance deficiency.

The deficiency was more than minor because it is associated with the equipment

performance attribute of the mitigating systems cornerstone objective to ensure the

availability, reliability, and capability of systems that respond to initiating events to

prevent undesirable consequences. It is therefore a finding. Using Inspection

Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of

Findings, the team determined that the finding was of very low safety significance

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(Green) because the finding was a design or qualification deficiency that was

confirmed not to result in loss of system operability or functionality. This finding has

a cross-cutting aspect in the corrective action program component of the problem

identification and resolution cross-cutting area because the licensee failed to take

appropriate corrective actions to address safety issues and adverse trends in a

timely manner, commensurate with their safety significance (P.1(d)). (Section

4OA2.5.c)

• Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, for the licensees failure to effectively correct

deficient procedures regarding the use of clearance orders. A number of clearance-

related problems revealed several deficiences in procedures to ensure that safe tag-

out of equipment occurred prior to the start of work, that independent reviews of

qualified individuals were being completed during clearance order preparation, and

that effective training was being conducted where performance gaps were identified.

The licensee failed to correct these deficiencies in a timely manner. The licensee

entered this finding in its corrective action program as condition report 53451.

The team determined that the failure to correct an adverse trend in the use of

clearance orders was a performance deficiency. This finding was more than minor

because if left uncorrected, it could lead to a more significant safety concern.

Specifically, continued failure to establish the correct clearance order boundaries

could result in the loss of configuration control for systems required to maintain

nuclear safety. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and

Characterization of Findings, the team determined that this finding was of very low

safety significance (Green) because it was not a design or qualification deficiency,

did not represent a loss of system safety function, and did not screen as potentially

risk significant due to a seismic, flooding, or severe weather initiating event. The

team determined that this finding has a cross-cutting aspect in the resources

component of the human performance cross-cutting area because the licensee failed

to ensure complete, accurate and up-to-date design documentation, procedures, and

work packages were available and adequate to support nuclear safety (H.2(c)).

(Section 4OA2.5.d)

• Green. The team identified a non-cited violation of 10 CFR Part 50, Criterion V,

Instructions, Procedures, and Drawings, for the licensees failure to establish

adequate procedures for resolution of corrective actions. Specifically, the licensee

failed to establish procedures to ensure that planned corrective actions were

effectively implemented. The licensee entered this finding in its corrective action

program as condition report 53432.

The failure to establish adequate procedures for resolution of corrective actions was

a performance deficiency. This finding was more than minor because if left

uncorrected, it would have the potential to lead to a more significant safety concern.

Specifically, failure to establish adequate procedures for resolution of corrective

actions could result in important actions not being accomplished. Using Manual

Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, this

finding was determined to be of very low safety significance (Green) because it was

not a design or qualification deficiency, did not represent a loss of system safety

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function, and did not screen as potentially risk significant due to a seismic, flooding,

or severe weather initiating event. This finding has a cross-cutting aspect in the

decision making component of the human performance cross-cutting area because

the licensee failed to demonstrate that nuclear safety is an overriding priority by

making safety-significant or risk-significant decisions using a systematic process

(H.1(a)). (Section 4OA2.5.e)

• Green. The team identified a violation of 10 CFR Part 50, Appendix B, Criterion XVI,

Corrective Action, for the licensees failure to perform testing of safety-related

spring-loaded tornado dampers in the emergency diesel generator and essential

service water rooms. In 2008, the licensee identified that because the updated

safety analysis report (USAR) incorrectly classified these active components as

passive, they had not been included in a periodic testing or surveillance program.

Since 2010, action items to test the dampers have received four due date

extensions. Additonally, required training for this testing was completed and closed.

However, no testing or surveillance was accomplished. This failure was the subject

of a previous violation issued by the NRC. The licensee failed to take timely

corrective actions to restore compliance. The licensee entered this finding in its

corrective action program as condition report 53363.

The team determined that the licensees failure to implement corrective action was a

performance deficiency. This finding was more than minor because it affected the

equipment reliability attribute of the mitigating systems cornerstone objective to

ensure the availability, reliability, and capability of systems that respond to initiating

events to prevent undesirable consequences. Specifically, failure to implement this

corrective action could result in reduced reliability of safety-related equipment during

an event initiated by a tornado. Using Chapter 0609.04, Phase 1 - Initial Screening

and Characterization of Findings, the team determined that this finding was of very

low safety significance (Green) because it was not a design or qualification

deficiency, did not represent a loss of system safety function, and during a tornado,

would not cause a plant trip if failed, would not degrade two or more trains of a multi-

train safety system, and would not degrade one or more trains of a system that

supports a safety system or function. This finding has a cross-cutting aspect in the

resources component of the human performance cross-cutting area because the

licensee failed to provide complete, accurate, and up-to-date design documentation,

procedures, and work packages were available and adequate to support nuclear

safety (H.2(c)). (Section 4OA2.5.f)

• Green. On February 23, 2011, a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, was revealed when an anomalous start of

component cooling water pump B indicated gas voiding in the component cooling

water piping. This violation was due to the licensees inadequate root cause

evaluation and failure to prevent recurrence of the voiding that had previously

occurred in May 2010. The licensee entered this finding in its corrective action

program as condition report 33925.

The failure to properly identify design issues as a root cause and to take action to

prevent the recurrence of a component cooling water system voiding was a

performance deficiency. The performance deficiency is more than minor because it

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impacted the equipment performance attribute of the mitigating systems cornerstone

objective to ensure the availability, reliability, and capability of systems that respond

to initiating events to prevent undesirable consequences. Specifically, excessive

voiding of the component cooling water system could lead to lack of cooling to

important safety-related components. Using Manual Chapter 0609.04, "Phase 1 -

Initial Screening and Characterization of Findings," the team determined that the

issue was of very low safety significance (Green) because it did not represent a loss

of system safety function or loss of a single train longer than its technical

specification allowed outage time. This finding has a cross-cutting aspect in the

corrective action program component of the problem identification and resolution

cross-cutting area because the licensee failed to thoroughly evaluate a problem such

that its resolution addressed its cause and extent of condition. Specifically, condition

report 25918 did not properly identify design issues as a root cause requiring

immediate system modifications to preclude recurrence (P.1(c)). (Section 4OA2.5.g)

• Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion III, Design Control, for the licensees failure to evaluate the suitability of

nonsafety-related gaskets, o-rings, and seals installed in safety-related components.

These nonsafety-related parts were originally installed due to erroneous Safety

Classification Assessments. After determining that the parts were inappropriate in

safety-related joints, the licensee failed to promptly correct the condition and failed to

fully identify which components were affected. The licensee entered this finding in its

corrective action program as condition report 53456.

The failure of the licensee to evaluate the suitability of the specific nonsafety-related

material installed in safety-related equipment and to determine the extent to which

this condition existed was a performance deficiency. This performance deficiency

was more than minor because it affected the design control attribute of the mitigating

systems cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences.

Specifically, the inadequate evaluation of nonsafety-related gaskets, o-rings, and

seals installed in safety-related equipment adversely affected the reliability of the

affected systems. Using Manual Chapter 0609.04, "Phase 1 - Initial Screening and

Characterization of Findings," the team determined that the finding was of very low

safety significance (Green) because the finding was a design or qualification

deficiency confirmed not to result in loss of operability or functionality. This

performance deficiency had a cross-cutting aspect in the corrective action program

component of the problem identification and resolution cross-cutting area because

the licensee did not take appropriate corrective actions to address safety issues and

adverse trends in a timely manner, commensurate with their safety significance and

complexity (P.1(d)). (Section 4OA2.5.h)

• Green. The team identified a finding for the licensees failure to ensure that condition

reports were initiated as required by procedure. The licensees implementing

procedure for its corrective action program did not contain clear guidance as to what

conditions were required to be entered into the corrective action program, or how

soon after discovery the condition report was required to be generated. The team

identified several examples where condition reports were not generated, though it

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appeared from the guidance that they were required. The licensee entered this

finding in its corrective action program as condition report 53445.

The failure of licensee personnel to promply initiate condition reports for identified

issues, contrary to procedural requirements, is a performance deficiency. This

performance deficiency is more than minor because if left uncorrected, it could lead

to a more significant safety concern. Using Inspection Manual Chapter 0609.04,

Phase 1 - Initial Screening and Characterization of Findings, the team determined

that this finding was of very low safety significance (Green) because it did not involve

a design or qualification deficiency, did not represent a loss of system safety

function, and did not screen as potentially risk significant due to a seismic, flooding,

or severe weather initiating event. This finding has a cross-cutting aspect in the

resources component of the human performance cross-cutting area because the

licensee failed to ensure procedures necessary for complete, accurate, and up-to-

date procedures were available and adequate to support nuclear safety. Specifically,

the corrective action program procedure was vague in its guidance as to when a

condition report was required (H.2(c)). (Section 4OA2.5.i)

Cornerstone: Miscellaneous

• SL-IV. The inspectors identified a non-cited violation of 10 CFR 50.73(a)(2)(i)(b) for

the licensees failure to submit a licensee event report upon discovery that a

condition prohibited by technical specifications had existed in the preceding three

years. On April 18, 2011, the licensee issued calculation GK-06-W, SGK05A/B

Class 1E Electrical Equipment Rooms A/C Units, Single Unit Operation Capability,

Revision 2. This calculation concluded that with one of the two air conditioning units

inoperable, the use portable fans and the opening of doors was required to maintain

vital switchgear rooms below the maximum operability limits. The calculation further

concluded that even with these compensatory actions, required temperatures could

be maintained only if the temperature of all surrounding areas remained below 78F.

Calculation GK-06-W thus demonstrated that a single cooler was incapable of

maintaining the switchgear rooms within technical specification limits, without

compensatory actions. Because one of the two air conditioning units had been out of

service on multiple occasions during the preceding three years with no

compensatory actions taken, the condition was reportable. The licensee entered this

finding in its corrective action program as condition report 53452.

The failure to submit a licensee event report was a performance deficiency. The

team evaluated this performance deficiency using the NRCs significance

determination process (SDP) and determined that it was of minor safety significance.

It is therefore not associated with a finding or assigned a color. However,

performance deficiencies which impact the NRCs regulatory ability are processed

using traditional enforcement separately from the SDP evaluation. The NRC relies

on the licensee to identify and report conditions or events meeting the criteria

specified in regulations in order to perform its regulatory function. When this is not

done, the regulatory function is impacted. Therefore, the team determined that this

performance deficiency was most appropriately processed using traditional

enforcement. Using the Enforcement Policy and the available risk information, the

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inspectors concluded that this violation is a traditional enforcement violation of

Severity Level IV. (Section 4OA2.5.b)

B. Licensee-Identified Violations

None

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REPORT DETAILS

4. OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution (71152)

The team based the following conclusions on the sample of corrective action documents

that were initiated in the assessment period, which ranged from May 26, 2010, to the

end of the on-site portion of the this inspection on May 24, 2012.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed approximately 300 corrective action program documents, including

associated root cause, apparent cause, and direct cause evaluations, from

approximately 25,000 that had been initiated between May 26, 2010, and May 24, 2012.

The team focused its review on condition reports that were evaluated as significant to

determine if problems were being properly identified, characterized, and entered into the

corrective action program for evaluation and resolution. The team reviewed a sample of

system health reports, operability determinations, self-assessments, trending reports

and metrics, and other documents related to the corrective action program. The team

evaluated the licensees efforts in establishing the scope of problems by reviewing

selected logs, work requests, self-assessments results, audits, system health reports,

action plans, and results from surveillance tests and preventive maintenance tasks. The

team reviewed work requests and attended the licensees daily Screening Review Team

(SRT) and Senior Leadership Review Team (SLRT) meetings to assess the reporting

threshold, prioritization efforts, and significance determination process, as well as

observing the interfaces with the operability assessment and work control processes.

The teams review included verifying that the licensee considered the full extent of cause

and extent of condition for problems as well as how the licensee assessed generic

implications and previous occurrences. The team assessed the timeliness and

effectiveness of corrective actions, completed or planned, and looked for additional

examples of similar problems. The team conducted interviews with plant personnel to

identify other processes that may exist where problems may be identified and addressed

outside the corrective action program.

The team also reviewed corrective action documents that addressed past NRC-identified

violations to ensure that the corrective action addressed the issues as described in the

inspection reports. The inspectors reviewed a sample of corrective actions closed to

other corrective action documents to determine whether corrective actions were still

appropriate and timely.

The team considered risk insights from both the NRCs and Wolf Creeks risk

assessments to focus the sample selection and plant tours on risk significant systems

and components. Based on this review, samples reviewed by the team focused on, but

were not limited to, the essential service water and emergency diesel generator

systems. The team also expanded its review to include a five-year in-depth review of

-9-

the emergency diesel generator system to determine whether problems were being

effectively addressed. The team conducted a walkdown of these systems to assess

whether problems were identified and entered into the corrective action program.

b. Assessments

1. Assessment - Effectiveness of Problem Identification

The team concluded that in most cases, the licensee identified issues and adverse

conditions in accordance with the licensees corrective action program guidance and

NRC requirements. The team determined that the licensee generally identified these

problems at a low threshold and entered them into the corrective action program.

The team further noted that the licensees condition report initiation rate had

increased significantly in recent years. This increase included a change in the

condition report initiation process in 2010 that required all work orders to be initiated

with a condition report, resulting in a large increase in the initiation rate. The

average number of condition reports initiated per year had increased from fewer than

4000 in 2005 to over 8000 before the change was implemented. Under the new

process in 2011, the licensee initiated over 15,000 condition reports.

The team noted that this high rate of condition report generation is generally a sign of

a healthy corrective action program. However, the team identified several issues

and adverse conditions that were not entered into the corrective action program.

Some of these were the subject of finding FIN 2012007-09, included in this report.

See section 4OA2.5.i.

2. Assessment - Effectiveness of Prioritization and Evaluation of Issues

In general, the licensee adequately performed and documented evaluations of

conditions adverse to quality during this assessment period. However, the team

noted that the licensee had some challenges with timeliness of evaluations:

• The stations evaluation timeliness goal was 30 days for all corrective action

program cause evaluation products. The average age at closure for these

evaluations was 43 days in March and 53 days in April. The licensee had

documented this in condition report 52961.

• Condition report 51292 was initiated anonymously on April 5, 2012,

documenting multiple past-due corrective actions. This condition report went

past due on May 9, 2012, with no actions taken.

• Many condition reports had multiple due date extensions for their corrective

actions. Many actions were not completed until well after the 120-day base

completion metric; in the sample of higher-tier corrective action program

documents the team reviewed, few significant actions were completed within

120 days. Two examples follow:

o Condition report 34987 identified three deficiencies in procedures for

recovery from a safety injection actuation. It took 30 days for the condition

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report to be approved and then six more months to implement the

procedure changes.

o Condition report 34964 included an action to track completion of an action

from CR 37931. After several extensions of the latter action, the actions

were completed nine months after the deficiencies were identified that the

actions were designed to address. The team concluded that these

corrective actions were untimely.

Additionally, the team reviewed several condition reports that involved potential

challenges to operability. The team assessed the quality, timeliness, and

prioritization of these operability assessments. In general, the licensee

completed these operability assessments adequately and evaluated operability

appropriately.

3. Assessment - Effectiveness of Corrective Action Program

Overall, the team concluded that the licensee generally developed appropriate

corrective actions to address problems. However, the team identified a number of

corrective actions associated with conditions adverse to quality that were not

completed in a timely manner:

• The average age of corrective actions to prevent recurrence (CAPRs) was 428

days in March 2012, having increased from 180 days in November 2011. The

stations goal is to complete CAPRs within 180 days when they do not require

an outage or other long-term constraint.

• In March 2012, the station had 52 open condition reports associated with NRC-

issued findings. The average age of these condition reports was 438 days.

• After determining that nonsafety-related gaskets had been installed in safety-

related components, the licensee took some actions to replace these materials,

but did not track these actions through the corrective action program. Further,

the licensee inappropriately determined that because the gaskets had not yet

leaked, they would not leak under any service condition until the next time

maintenance was performed on the affected joint. This performance deficiency

is the subject of a non-cited violation documented in section 4OA2.5.h.

• The licensee failed to take timely corrective actions to prevent water-hammer-

induced leaks from the essential service water system. This is further discussed

in section 4OA2.5.c of this report.

• Similarly, after identifying voiding in the component cooling water system, the

station failed to adequately identify the cause of the voiding and to take

appropriate actions to prevent its recurrence. The team documented this issue

as a self-revealing non-cited violation in section 4OA2.5.g of this report.

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• The licensee identified that safety-related tornado dampers on the essential

service water and emergency diesel generator buildings required periodic

testing, and that this testing had never been performed. Although this condition

was originally identified by the licensee in 2008, and was documented by the

NRC as a violation in a 2010 report, the licensee took no actions to correct this

deficiency. This is further discussed in section 4OA2.5.f of this report.

Additionally, the team identified several instances where identified corrective actions,

which had been approved by the stations corrective action review board (CARB),

were unilaterally canceledor were marked as complete with no action takenby

the condition report owner. The team determined that the licensees failure to ensure

corrective actions were accomplished was a violation of NRC requirements; this

violation is further discussed in section 4OA2.5.e of this report.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team examined the licensee's program for reviewing industry operating experience,

including reviewing the governing procedure and self assessments. The team reviewed

a sample of condition reports examining operating experience documents that had been

issued during the assessment period to assess whether the licensee had appropriately

evaluated the notification for relevance to the facility. The inspectors also examined

whether the licensee had entered those items into their corrective action program and

assigned actions to address the issues. The inspectors reviewed a sample of root cause

evaluations and significant condition reports to evaluate whether the licensee had

appropriately included industry operating experience.

b. Assessment

Overall, the team determined that the licensee had appropriately evaluated industry

operating experience for relevance to the facility, and had entered applicable items in the

corrective action program. The team observed several interactions in management

meetings where operating experience information was discussed in near-real time, and

where prompt action was taken to determine whether the station was vulnerable to a

similar adverse condition. The team determined that this was a highly effective method

of incorporating operating experience into plant operations. The team noted that both

internal and external operating experience was being incorporated into lessons learned

for training and in pre-job briefs for routine and non-routine tasks.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of licensee self-assessments and audits to assess

whether the licensee was regularly identifying performance trends and effectively

addressing them. The inspectors also reviewed audit reports to assess the

effectiveness of assessments in specific areas. The specific self-assessment

documents and audits reviewed are listed in Attachment 1.

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b. Assessment

The inspectors concluded that the licensee had an effective self-assessment process.

Licensee management was involved in developing the topics and objectives of self-

assessments. Attention was given to assigning team members with the proper skills and

experience to do effective self-assessments and to include people from outside

organizations. Audits were self-critical and identified deficiencies in various programs

such as the corrective action program and several root cause evaluations. While the

team identified that there had been some weaknesses in the quality assurance

organizations follow-up of audit findings, recent changes to the licensees quality

programs had addressed and begun to correct many of these issues.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The team conducted ten focus groups that included more than 60 individuals from a

cross-section of functional organizations: engineering, operations, maintenance, quality

programs (quality assurance, quality verification, and quality control), heath physics, and

chemistry. Both supervisory and non-supervisory personnel were included, though

separate focus groups were conducted for supervisors. The discussions assessed

whether conditions existed that would challenge an effective safety conscious work

environment (SCWE). The team also interviewed the ombudsmanWolf Creeks

employee concerns program managerand reviewed the last two safety culture self-

assessment documents.

b. Assessment

Overall, the team concluded that a safety conscious work environment exists at Wolf

Creek. Employees demonstrated familiarity with the various avenues available to raise

safety concerns. They appeared comfortable with submitting all nuclear safety issues.

The team noted a potential vulnerability in the licensees safety conscious work

environment in discussions with security personnel. There was a perception among

some members of the plant staff that management was not willing to address security-

related issues with the same rigor with which it addressed issues of nuclear safety not

related to physical security. Also, security personnel stated that they generally did not

write condition reports, but rather passed the comments along to supervisors who would

enter them into the corrective action program.

Overall, individuals were familiar with the employee concerns program and its location

on site. There was visibility of the program throughout the site; the resolutions of

anonymous issues were reported site-wide through an article in the site newsletter.

Many of the individuals interviewed had had direct interactions with the ombudsman with

varying degrees of satisfaction. Some personnel were unsure of the ombudsmans

authority to resolve issues raised through him. But personnel understood and were

confident in the confidentiality of the program.

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Site personnel were required to participate in a read and sign training annually which

covers the SCWE policies. Many individuals who were interviewed were familiar with

this training and with the overall message in the training. But not everyone was familiar

with the details of the policy. None of the individuals interviewed cited any examples of

harassment, intimidation, retaliation or discrimination or any negative reactions from

management when individuals raised nuclear safety concerns. The message from

management that nuclear safety is more important than production goals was well-

received by plant personnel. Finally, individuals indicated that if they were to believe

unsafe conditions existed, they would feel comfortable stopping work without fear of

retaliation, even if such actions would prolong an outage or extend a planned schedule.

.5 Specific Issues Identified During This Inspection

a. Inadequate Procedure for Compensatory Measures

Introduction. The inspectors identified a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees

failure to adequately translate design information into procedures and requirements.

Specifically, the licensee had information that its calculation for vital switchgear cooling

included nonconservative assumptions. These assumptions called into question the

ability of air conditioning systems to adequately cool Class 1E switchgear under all

design conditions. However, the licensee failed to revise procedures to include

compensatory actions necessary to ensure the vital switchgear remained operable.

Description. Wolf Creek is designed with two vital switchgear air conditioning units.

Each air conditioning unit cools one vital 4160V switchgear room, two sets of vital dc

battery rooms, and two sets of vital dc switchgear. In 2010, the NRC identified that the

heat transfer calculation for the sizing of these units was inadequate (see NCV 2011002-

05). In reviewing the licensees corrective actions for this violation, the team reviewed

the licensees compensatory actions and calculation GK-06-W, SGK05A/B Class 1E

Electrical Equipment Rooms A/C Units, Single Unit Operation Capability, Revision 2.

This calculation concluded that using portable fans and opening the room doors would

maintain temperatures in the switchgear rooms below 104F for at least 7 days if

temperatures in all surrounding areas remained below 78F.

However, the team identified several examples that contradicted or failed to incorporate

the evaluated design requirements in calculation GK-06-W:

• The compensatory measures identified in procedure SYS GK-200, Inoperable

Class 1E A/C Unit, Revision 24, were not consistent with the conclusions in

calculation GK-06-W. Step 5.3 of SYS GK-200 stated, IF desired, THEN portable

fans and ducting are available. This allowed portable fans to be optionally installed

at the operators discretion, contradicting the assumptions of the calculation.

• The bases for Technical Requirement (TR) 3.7.23 stated, With the interior doors

opened as described above, portable fans may be installed to facilitate air

circulation among rooms; however, this is not required based on operating

experience.

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• A note in TR 3.7.23 required entry into the associated technical specification (TS)

action statementsTS 3.8.4 for dc power sources, TS 3.8.7 for inverters, and TS 3.8.9 for electrical distribution systemswhen room temperature was equal to or

greater than 104F. However, calculation GK-06-W only demonstrated that

operability of these systems can be maintained with a single operable air

conditioning unit when (1) portable fans are installed prior to the evaluated transient

and (2) surrounding areas remain below 78F.

• The box fans used in the compensatory actions to maintain operability of safety-

related equipment relied on nonsafety-related power. This power supply would not

be available under all design basis conditions where the compensatory actions

would be required.

• The box fans and trunks were not modeled in calculation GK-06-W to demonstrate

operability.

These discrepancies resulted in non-conservative entry assumptions into technical

specification action statements and invalid assumptions of continued operability.

Analysis. The inspectors determined that the licensees failure to adequately translate

design information into procedures was a performance deficiency. The performance

deficiency is more than minor because it affected the equipment performance attribute of

the Mitigating Systems cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening

an Characterization of Findings, the team determined the finding was of very low safety

significance (Green) because it did not represent a loss of system safety function, did

not represent the actual loss of safety function of a single train for greater than its

technical specification allowed outage time, and did not screen as potentially risk

significant due to a seismic, flooding, or severe weather initiating event. The finding has

a cross-cutting aspect in the corrective action component of the problem identification

and resolution cross-cutting area because the licensee failed to thoroughly evaluate the

problem such that its resolution addressed its causes and extent of conditions (P.1(c)).

Enforcement. Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, requires in part that activities

affecting quality be prescribed by documented instructions, procedures, or drawings, of a

type appropriate to the circumstances and shall be accomplished in accordance with

these instructions, procedures, and drawings. Contrary to this requirement, from 2010

through May 2012, the licensee failed to prescribe an activity affecting quality in an

instruction, procedure, or drawing appropriate to the circumstances. Specifically,

procedure SYS GK-200, Inoperable Class 1E A/C Unit, Revision 24, failed to provide

reasonable assurance that the electrical systems would be maintained operable under

postulated conditions. Because this violation was determined to be of very low safety

significance (Green) and was entered into the licensees corrective action program as

condition report 53393, this violation is being treated as a non-cited violation in

accordance with section 2.3.2 of the NRC Enforcement Policy: NCV 05000482/2012007-01, Inadequate Procedure to Implement Compensatory Measures.

- 15 -

b. Failure to Report Conditions that Could have Prevented Fulfillment of a Safety Function

Introduction. The inspectors identified a Severity Level IV non-cited violation of 10 CFR

50.73(a)(2)(i)(b) for the licensees failure to submit a licensee event report upon

discovery that a condition prohibited by technical specifications had existed in the

preceding three years. On April 18, 2011, the licensee issued calculation GK-06-W,

SGK05A/B Class 1E Electrical Equipment Rooms A/C Units, Single Unit Operation

Capability, Revision 2. This calculation concluded that with one of the two air

conditioning units inoperable, the use of portable fans and the opening of doors was

required to maintain vital switchgear rooms below the maximum operability limits. The

calculation further concluded that even with these compensatory actions, required

temperatures could be maintained only if the temperature of all surrounding areas

remained below 78F. Calculation GK-06-W thus demonstrated that a single cooler was

incapable of maintaining the switchgear rooms within technical specification limits,

without compensatory actions. Because one of the two air conditioning units had been

out of service on multiple occasions during the preceding three years with no

compensatory actions taken, the condition was reportable.

Description. On September 22, 2010, the licensee identified from operating experience

that with one Class 1E Electrical Equipment A/C train nonfunctional, single failure

protection would no longer exist for this support function. The licensees reportability

evaluation determined that the Class 1E electrical equipment rooms cooled by

SGK05A/B had not exceeded technical specification temperature limits. The licensee

incorrectly determined that because temperatures had not exceeded limits, a condition

prohibited by Technical Specifications had not existed. The licensee thus incorrectly

concluded that the condition did not require a report to the NRC.

On April 18, 2011, the licensee issued GK-06-W, SGK05A/B Class 1E Electrical

Equipment Rooms A/C Units, Single Unit Operation Capability, Revision 2. This

calculation concluded that with one of the two air conditioning units inoperable, the use

of portable fans and the opening of doors was required to maintain vital switchgear

rooms below the maximum operability limits. The calculation further concluded that

even with these compensatory actions, required temperatures could be maintained only

if the temperature of all surrounding areas remained below 78F.

The team concluded that this calculation demonstrated that with one cooler out of

service, the licensee was unable to provide reasonable assurance that room

temperatures could be maintained within technical specification operability limits without

compensatory actions. Operation with one cooler out of service would thus require entry

into the action statements of technical specifications 3.8.4 for dc power sources, 3.8.7

for inverters, and 3.8.9 for electrical distribution systems. The shortest of these action

statements requires plant shutdown within eight hours. The licensees reportability

evaluation determined that one cooler had been removed from service for more than two

hours on multiple occasions in the preceding three years. This represented a condition

prohibited by technical specification and required a report to the NRC in accordance with

10 CFR 50.73 requirements.

- 16 -

Analysis. The failure to submit a licensee event report was a performance deficiency.

The team evaluated this performance deficiency using the NRCs significance

determination process (SDP) and determined that it was of minor safety significance. It

is therefore not associated with a finding or assigned a color. However, performance

deficiencies which impact the NRCs regulatory ability are processed using traditional

enforcement separately from the SDP evaluation. The NRC relies on the licensee to

identify and report conditions or events meeting the criteria specified in regulations in

order to perform its regulatory function. When this is not done, the regulatory function is

impacted. Therefore, the team determined that this performance deficiency was most

appropriately processed using traditional enforcement. Using Enforcement Policy

section 6.9, the inspectors concluded that this violation is a traditional enforcement

violation of Severity Level IV.

Enforcement. Title 10 CFR 50.73(a)(2)(i)(B) requires, in part, that licensees submit a

Licensee Event Report to the NRC within 60 days of discovery of any operation or

condition which was prohibited by the plants Technical Specifications and that occurred

within three years of the date of discovery. Contrary to this requirement, in September

2010, the licensee failed to report to the NRC within 60 days of discovery a condition

that was prohibited by the plants Technical Specifications that had occurred withing

three years of the date of discovery. Specifically, the licensee failed to report a condition

in which it could not provide reasonable assurance of the operability of Class 1E

switchgear for greater than its technical specification allowed outage time. The licensee

documented this issue in its corrective action program as condition report 53452.

Reviewing the finding using the NRCs Enforcement Policy and the available risk

information, the team concluded that this violation is appropriately characterized as

Severity Level IV. Because it is a Severity Level IV violation and was entered into the

corrective action program, this violation is being treated as a non-cited violation,

consistent with section 2.3.2 of the NRC Enforcement Policy: NCV 05000482/2012007-

02, Failure to Report Conditions that Could Have Prevented Fulfillment of a Safety

Function.

c. Failure to Take Timely Corrective Actions to Preclude Repetition of a Significant

Condition Adverse to Quality

Introduction. The inspectors identified a Green violation of 10 CFR 50, Appendix B,

Criterion XVI, Corrective Action, for the licensees failure to take corrective actions to

preclude repetition of system leaks due to water hammer events in the essential service

water system. Extensive inadequately evaluated corrosion in the system has led to

multiple water-hammer-induced leaks of essential service water piping. These leaks

were the subject of two previous violations issued by the NRC. However, the licensee

failed to take timely corrective actions to restore compliance.

Description. During normal operations, normal service water supplies components in the

essential service water system. During a loss of off-site power, normal service water

pumps stop. Approximately twenty-five seconds later, after the emergency diesel

generators start and power the emergency buses, the essential service water pumps

start to provide cooling water to the essential service water loads. During these twenty-

five seconds when no pumps are running, the essential service water system partially

drains. The starting of the essential service water pumps rapidly fills the system and

- 17 -

causes water hammera rapid pressure spike. This pressure spike can cause leaks in

eroded or corroded sections of essential service water piping.

On August 19, 2009, Wolf Creek Station experienced a loss of off-site power. As a result

of pump cycling during the event, several water-hammer-induced leaks were initiated in

degraded essential service water system piping.

As a result of the 2009 event, the licensee initiated a program to non-destructively

inspect the above ground large bore piping and accessible portions of essential service

water piping located in underground bunkers. This program was intended to collect and

analyze data to determine when repairs were required and when sections of piping

would require replacement. The program was supposed to track the repaired and

replaced portions of piping. After discovering leaks in buried essential service water

piping, ground-penetrating radar was used to confirm these leaks; the ground-

penetrating radar was incorporated into the program.

On January 13, 2012, Wolf Creek experienced another loss of off-site power. Similar to

the 2009 event, this loss of off-site power caused a water hammer of sufficient

magnitude to cause a through-wall leak in corroded essential service water piping. This

leak occurred in the riser piping of the Train C containment cooler. Though this piping is

part of the essential service water flowpath, it was not scoped into the licensees

inspection and tracking program. The licensees system designation for the piping

changed at the flange joints between essential service water and the containment

coolers. Containment coolers were never included in the non-destructive inspection

program.

The team determined that the licensees corrective actions from the August 2009 loss-of-

off-site-power event, which developed the non-destructive inspection program of the

essential service water system, were inadequate because the inspection program did

not include the containment coolers. Additionally, the team noted that the program did

not accurately track and document which sections of essential service water piping had

been inspected and which had not. At the conclusion of the inspection, the licensee was

developing a design change to mitigate the impact of pump restarts on the essential

service water system. The licensee was also performing localized pipe repairs on

corroded areas while evaluating which sections of pipe require larger-scale replacement.

The NRC previously issued Wolf Creek two violations for failure to adequately evaluate

the essential service water system for corrosion and for the effects of water hammer on

corroded areas: NCV 05000482/2009007-03 was identified during a special inspection

following the 2009 water hammer event; VIO 05000482/2010006-05 was identified

during the 2010 problem identification and resolution inspection. The second violation

was cited because the licensee failed to restore compliance within a reasonable time

following the identification of the first violation. Because the licensee still has not

restored compliance, this violation is also cited.

Analysis. The failure to preclude recurrence of water hammer in the essential service

water system and the failure to take adequate corrective action to control internal pitting

corrosion in essential service water piping was a performance deficiency. The deficiency

was more than minor because it is associated with the equipment performance attribute

- 18 -

of the mitigating systems cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences. It is therefore a finding. Using Inspection Manual Chapter 0609.04,

Phase 1 - Initial Screening and Characterization of Findings, the team determined that

the finding was of very low safety significance (Green) because the finding was a design

or qualification deficiency that was confirmed not to result in loss of system operability or

functionality; the January 12, 2012, leak was too small to cause a loss of system

function. This finding has a cross-cutting aspect in the corrective action program

component of the problem identification and resolution cross-cutting area because the

licensee failed to take appropriate corrective actions to address safety issues and

adverse trends in a timely manner, commensurate with their safety significance (P.1(d)).

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,

requires, in part, that in the case of significant conditions adverse to quality, measures

shall assure that the cause of the condition is determined and corrective action taken to

preclude repetition. Contrary to this requirement, from August 19, 2009, through May

25, 2012, the licensee failed to assure that the cause of a significant condition adverse

to quality was determined and corrective action was taken to preclude repetition.

Specifically, water hammer in a safety-related system that leads to through-wall leaks

from corroded piping is a significant condition adverse to quality. On August 19, 2009, a

loss-of-off-site-power event caused a water hammer in safety-related essential service

water piping. This water hammer resulted in a leak from corroded portions of piping.

The licensee failed to take corrective action to preclude repetition of additional water

hammer events and system leaks due to internal pitting corrosion in the essential service

water system. This was demonstrated on January 13, 2012, when a loss-of-off-site-

power event caused a water hammer event and system leak due to internal pitting

corrosion in the essential service water system. The finding has been entered into the

licensees corrective action program as condition report 53443. Due to the licensees

failure to restore compliance within a reasonable time following previous

NCV 05000482/2009007-03 and VIO 05000482/2012006-05, this violation is being cited

in a Notice of Violation consistent with Section 2.3.2 of the NRC Enforcement Policy:

VIO 05000482/2012007-03, Failure to Take Timely Corrective Action to Preclude

Repetition.

d. Untimely Corrective Actions

Introduction. The team identified a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, for the licensees failure to effectively

correct deficient procedures regarding the use of clearance orders. A number of

clearance-related problems revealed several deficiences in procedures to ensure that

safe tag-out of equipment occurred prior to the start of work, that independent reviews of

qualified individuals were being completed during clearance order preparation, and that

effective training was being conducted where performance gaps were identified. The

licensee failed to correct these deficiencies in a timely manner. This finding was entered

into the licensees corrective action program as condition report 53451.

Description. The team determined that effective corrective actions had not been

implemented in a reasonable time following identification of an adverse trend in

clearance order performance during maintenance of both safety-related and nonsafety-

- 19 -

related systems. On September 21, 2010, clearance order D-QA-N-041 included a tag-

out of breaker 8 for the replacement of a light socket. When proceeding with the work, a

live-dead-live test indicated that the circuit was still energized. Further examination

revealed that the wrong breaker had been tagged open. The licensee documented this

error in condition report 28224 and perfomed a root cause evaluation. Though the event

evaluated in the root cause did not involve safety-related equipment, the evaluation

documented a history of work order preparation errors, inadequate clearance order

boundaries, and negative feedback on the use of clearance orders from self-

assessments and surveys. These included a number of issues with safety-related

systems. Corrective actions included procedure changes and training. However, the

root cause indicated that corrective actions to prevent recurrence were not effective.

The most recent post-training survey, completed in February 2012, indicated that the

Clearance Order Group had not noticed a change or improvement since the training on

the revised procedures. This resulted in training needs analysis (TNA) 2012-1087-1,

which was delayed from being reviewed by management for several months due to the

stations forced outage in early 2012. The team determined that effective corrective

actions had not been timely implemented.

Analysis. The team determined that the failure to correct an adverse trend in the use of

clearance orders when performing maintenance on safety-related systems was a

performance deficiency. This finding was more than minor because if left uncorrected, it

could lead to a more significant safety concern. Specifically, continued failure to

establish the correct clearance order boundaries could result in the loss of configuration

control for systems required to maintain nuclear safety. Using Manual Chapter 0609.04,

Phase 1 - Initial Screening and Characterization of Findings, the team determined that

this finding was of very low safety significance (Green) because it was not a design or

qualification deficiency, did not represent a loss of system safety function, and did not

screen as potentially risk significant due to a seismic, flooding, or severe weather

initiating event. The team determined that this finding has a cross-cutting aspect in the

resources component of the human performance cross-cutting area because the

licensee failed to ensure complete, accurate and up-to-date design documentation,

procedures, and work packages were available and adequate to support nuclear safety

(H.2(c)).

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,

requires, in part, that measures be established to assure that conditions adverse to

quality are promptly identified and corrected. Contrary to this requirement, from

September 2010 through February 2012, the licensee failed to assure that measures

were established to assure that a condition adverse to quality was promptly corrected.

Specifically, following identification of an adverse trend in the effective use of clearance

orders for safety-related and nonsafety-related equipment maintenance, the licensee

failed to implement corrective action to ensure safe tag-out of equipment had occurred

prior to the start of work, that independent reviews of qualified individuals were being

completed in the clearance order preparation, and that effective training was being

conducted where performance gaps were identified. This finding was entered into the

licensees corrective action program as condition report 53451. Because this finding is

of very low safety significance (Green) and has been entered into the licensees

corrective action program, this violation is being treated as a non-cited violation

- 20 -

consistent with section 2.3.2 of the NRC Enforcement Policy: NCV 05000482/2012007-

04, Untimely Corrective Action.

e. Failure to Establish Procedures to Ensure Completion of Corrective Actions

Introduction. The team identified a Green non-cited violation of 10 CFR Part 50,

Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to

establish adequate procedures for resolution of corrective actions. Specifically, the

licensee failed to establish procedures to ensure that planned corrective actions were

effectively implemented. This finding was entered into the licensees corrective action

program as condition report 53432.

Description. The team identified two examples where the licensee had failed to

establish procedures to ensure that corrective actions were completed as intended:

Attachment G to Procedure AP 28A-100, Condition Reports, Revision 16, noted that

level 3 (apparent cause) condition reports fall under the oversight of the corrective action

review board (CARB). Paragraph 6.14.1.2 of this procedure required that the condition

report owner ensure that actions have been satisfactorily performed prior to closing the

action. Contrary to this, on June 8, 2011, actions 02-06, 02-07, and 02-08 of apparent

cause 34661 to add caution statements or notes to work order templates or instructions

were closed by the assigned action owner without the procedure changes being made.

In the closure documentation, the action owner stated that he did not feel the changes

should be made to the documents listed. Instead, the action owner added a document

to the maintenance history noting a need for these notes. However, the team noted that

there was no procedural requirement that such comments from maintenance history be

incorporated into new work orders. Rather, procedure AI 16C-007, Work Order

Planning, Revision 31, noted that when developing a work instruction, a check for

existing instructions or procedures and a review of maintenance history were among a

six-page list of elements to consider for the planners. The most recent revision of AI

16C-007Revision 38contained identical language.

Corrective actions for the apparent cause documented in condition report 27015

included action 02-03 to investigate plants that received violations for not having

evaluations for crimping failure on the external Emergency Diesel Generator exhaust.

On September 10, 2010, this item was closed by the assigned action owner citing a

statement in the updated safety analysis report (USAR) that diesel operation inhibition

was extremely unlikely due to tornado missiles. Closure of this item due to existing

USAR reference did not meet the intent of evaluating other plant violations for

vulnerabilities at Wolf Creek. The original actions were assigned by the stations CARB,

a management-level group. The action owner closing the item with no actions

completed did so at a lower organizational level; there was no management or CARB

review of this closure. It should also be noted that the historical USAR reference does

not necessarily negate the need for a current evaluation of crimping.

Analysis. The failure to establish adequate procedures for resolution of corrective

actions was a performance deficiency. This finding was more than minor because if left

uncorrected, it would have the potential to lead to a more significant safety concern.

Specifically, failure to establish adequate procedures for resolution of corrective actions

- 21 -

could result in important actions not being accomplished. Using Manual Chapter

0609.04, Phase 1 - Initial Screening and Characterization of Findings, this finding was

determined to be of very low safety significance (Green) because it was not a design or

qualification deficiency, did not represent a loss of system safety function, and did not

screen as potentially risk significant due to a seismic, flooding, or severe weather

initiating event. This finding has a cross-cutting aspect in the decision making

component of the human performance cross-cutting area because the licensee failed to

demonstrate that nuclear safety is an overriding priority by making safety-significant or

risk-significant decisions using a systematic process (H.1(a)).

Enforcement. Title 10 CFR Part 50, Criterion V, Corrective Action, requires, in part,

that activities affecting quality be prescribed by documented instructions, procedures, or

drawings of a type appropriate to the circumstances and shall be accomplished in

accordance with those instructions, procedures, and drawings. Contrary to this

requirement, on September 10, 2010, and June 8, 2011, the licensee failed to ensure

that activities affecting quality were prescribed in documented procedures and

accomplished in accordance with those procedures. Specifically, the licensee failed to

establish adequate procedures to ensure that corrective actions were completed as

intended. Because this finding is of very low safety significance and has been entered

into the licensees corrective action program as condition report 53432, this violation is

being treated as a non-cited violation consistent with section 2.3.2 of the NRC

Enforcement Policy: NCV 05000482/2012007-05, Failure to Establish Procedures to

Ensure Completion of Corrective Actions.

f. Failure to Implement Corrective Actions to Test Safety-Related Equipment

Introduction. The team identified a Green violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, for the licensees failure to perform testing of safety-

related spring-loaded tornado dampers in the emergency diesel generator and essential

service water rooms. In 2008, the licensee identified that because the updated safety

analysis report (USAR) incorrectly classified these active components as passive, they

had not been included in a periodic testing or surveillance program. Since 2010, action

items to test the dampers have received four extensions. Additionally, required training

for this testing was completed and closed. No testing or surveillance had been

accomplished. This failure was the subject of a previous violation issued by the NRC.

However, the licensee failed to take timely corrective actions to restore compliance.

Description. The Wolf Creek emergency diesel generator room and essential service

water room ventilation system design includes four spring-loaded dampers that are

required to automatically close in the event of high differential pressures associated with

a design basis tornado. The safety function of these dampers is to protect the heating

ventilation and air conditioning system ductwork and components from postulated high-

pressure differentials. In 2008, Wolf Creek personnel identified that these dampers had

been incorrectly classified as passive components and were not being periodically

tested; Condition Report 2008-003276 was initiated to revise Procedure MPE VD-001,

Ventilation Damper Maintenance, to accomplish testing. Later in 2008, the procedure

was updated and the corrective action was closed. However, no action was taken to

ensure that the required testing would be performed as part of the scheduled preventive

maintenance activities.

- 22 -

In 2010, the NRC issued a violation (NCV 05000482/2010007-02) for the licensees

failure to implement the planned corrective actions. On September 20, 2010, the

licensee initiated condition report 28185, noting that the procedure change was never

communicated to the planners and that there was no corrective action initiated to write a

work order for the testing. Condition report 29602 was written in October 2010

documenting NCV 2010007-02. Since 2010, corrective actions from these condition

reports have received four due date extensions. No testing or surveillance had ever

been accomplished.

This finding was entered into the licensees corrective action program as condition report

53363.

Analysis. The team determined that the licensees failure to implement corrective action

was a performance deficiency. This finding was more than minor because it affected the

equipment reliability attribute of the mitigating systems cornerstone objective to ensure

the availability, reliability, and capability of systems that respond to initiating events to

prevent undesirable consequences. Specifically, failure to implement this corrective

action could result in reduced reliability of safety-related equipment during an event

initiated by a tornado. Using Chapter 0609.04, Phase 1 - Initial Screening and

Characterization of Findings, the team determined that this finding was of very low

safety significance (Green) because it was not a design or qualification deficiency, did

not represent a loss of system safety function, and during a tornado, would not cause a

plant trip if failed, would not degrade two or more trains of a multi-train safety system,

and would not degrade one or more trains of a system that supports a safety system or

function. This finding has a cross-cutting aspect in the resources component of the

human performance cross-cutting area because the licensee failed to provide complete,

accurate, and up-to-date design documentation, procedures, and work packages

available and adequate to support nuclear safety (H.2(c)).

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,

requires, in part, that measures be established to assure that conditions adverse to

quality are promptly identified and corrected. Contrary to this requirement, from 2008

through May 2012, the licensee failed to establish measures to assure that a condition

adverse to quality was promptly identified and corrected. Specifically, the licensee failed

to assure that the identified emergency diesel generator and essential service water

pump room tornado damper testing deficiency was corrected. This finding was entered

into the licensees corrective action program as condition report 53363. Because the

licensee failed to restore compliance in a timely manner after this condition was

identified as a non-cited violation in inspection report 05000482/2010007, this violation is

being cited in a Notice of Violation consistent with Section 2.3.2 of the NRC Enforcement

Policy: VIO 05000482/2012007-06, Failure to Implement Corrective Actions to Test

Safety-Related Equipment.

g. Failure to Determine the Cause of a Significant Condition Adverse to Quality

Introduction. On February 23, 2011, a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, was revealed when an anomalous start of

component cooling water (CCW) pump B indicated gas voiding in the CCW piping. This

- 23 -

violation was due to the licensees inadequate root cause evaluation and failure to

prevent recurrence of the voiding that had previously occurred in May 2010.

Description. On May 24, 2010, the licensee observed acoustic anomolies during the

start of a test of CCW pump A. During investigation, ultrasonic testing revealed multiple

voids in the pump suction piping, the pump discharge piping, and the shell side of the

residual heat removal heat exchanger. The licensee took immediate corrective action to

vent the voids where possible; however, they were unable to get the piping sufficiently

vented to justify continued operability. Train A CCW was declared inoperable on June 3,

2010.

On September 1, 2010, the licensee completed a root cause evaluation of this event.

The evaluation identified the root cause was personnels misconceptions and

misunderstanding of gas voiding and gas accumulation within the CCW piping.

Specifically, the evaluation identified that operators and engineers believed that the

system was self-venting through the CCW surge tank. Further, personnel did not

understand the mechanisms of void formation (i.e., gas coming out of solution with

increases in temperature). The licensee identified plant design issues only as a

contributing cause, not as a root cause. The licensee failed to recognize that without

system modifications to install additional high point vents, there would not be a

significant reduction in the likelihood of this voiding condition occurring, regardless of the

knowledge level of personnel. While the action plan did specify evaluation and

installation of such vents, implementation was deferred until the next scheduled outage

in March 2011 despite a forced outage opportunity in October 2010.

On February 23, 2011, Wolf Creek experienced a similar anamolous start of CCW pump

B. During this event, the CCW system pressure dropped such that the second pump on

the train started automatically. Once again, ultrasonic readings confirmed unsatisfactory

voiding and the CCW train was declared inoperable. On July 24, 2011, Wolf Creek

completed another root cause analysis as part of condition report 33925. This root

cause evaluation properly identified the plant design issues as the root cause. By the

time the root cause evaluation was completed, the additional eight high-point vents had

already been installed during the Spring 2011 refueling outage. Since the installation of

the additional vents, routine CCW void monitoring has identified only very small voids

well below the established operability limits.

The team determined that the corrective actions to install the required vents were not

implemented timely to prevent recurrence. The root cause performed under condition

report 33925 also identified the inadequacies in evaluation and actions implemented by

condition report 25918. However, because the significant condition adverse to quality

recurred, the inspectors determined that the finding was self-revealing rather than

licensee-identified.

Analysis. The failure to properly identify design issues as a root cause and to take

action to prevent the recurrence of a CCW system voiding was a performance

deficiency. The performance deficiency is more than minor because it impacted the

equipment performance attribute of the mitigating systems cornerstone objective to

ensure the availability, reliability, and capability of systems that respond to initiating

events to prevent undesirable consequences. Specifically, excessive voiding of the

- 24 -

CCW system could lead to lack of cooling to important safety-related components.

Using Manual Chapter 0609.04, "Phase 1 - Initial Screening and Characterization of

Findings," the team determined that the issue was of very low safety significance

(Green) because it did not represent a loss of system safety function or loss of a single

train for longer than its technical specification allowed outage time. This finding has a

cross-cutting aspect in the corrective action program component of the problem

identification and resolution cross-cutting area because the licensee failed to thoroughly

evaluate a problem such that its resolution addressed its cause and extent of condition.

Specifically, condition report 25918 did not properly identify design issues as a root

cause requiring immediate system modifications to preclude recurrence (P.1(c)).

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,

requires, in part, that for significant conditions adverse to quality, measures shall assure

that the cause of the condition is determined and that corrective actions are taken that

preclude repetition. Contrary to this requirement, from May 24, 2010, through February

23, 2011, the licensee failed to assure that the cause of a significant condition adverse to

quality was determined and that corrective actions were taken to preclude repetition.

Specifically, voiding of the CCW system that could lead to lack of cooling to important

safety related components is a significant condition adverse to quality. After a May 2010

CCW voiding event, the licensee failed to preclude repetition of this voiding by taking

appropriate corrective actions; voiding recurred in February 2011. Because this finding

was determined to be of very low safety significance (Green) and was entered into the

licensees corrective action program as condition report 33925, this violation is being

treated as a non-cited violation consistent with section 2.3.2 of the NRC Enforcement

Policy: NCV 05000482/2012007-07, Failure to Determine the Cause of Component

Cooling Water System Voiding.

h. Failure to adequately evaluate the suitability of nonsafety-related gaskets, o-rings, and

seals installed in safety-related equipment and to identify extent of the condition

Introduction. The team identified a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion III, Design Control, for the licensees failure to evaluate the

suitability of nonsafety-related gaskets, o-rings, and seals installed in safety-related

components. These nonsafety-related parts were originally installed due to erroneous

Safety Classification Assessments (SCAs). After determining that the parts were

inappropriate in safety-related joints, the licensee failed to promptly correct the condition

and failed to fully identify which components were affected.

Description. On September 21, 2010, a licensee maintenance planner recognized that

during planned maintenance, a nonsafety-related (NSR) pump casing gasket had been

installed on the safety-related (SR) jacket water keep-warm pump for emergency diesel

generator (EDG) B. The planner initiated condition report 28208 to address the issue.

The NSR gasket had been approved for use in SCA 91-0408, a generic SCA for gaskets.

The SCA was written by a vendor and approved for use in August 1991. It permitted the

use of nonsafety-related gaskets in safety-related systems that only interface with water

or steam, where those systems had unlimited make-up capability. This SCA assumed

that all water and steam systems are capable of making up water and steam gasket

leakage losses. The EDG jacket water cooling system has makeup capability provided

- 25 -

by the demineralized water storage and transfer system. This system is not safety-

related and cannot be assumed to be available during a design-basis accident.

Therefore, the application of SCA 91-0408 to allow nonsafety-related gaskets to be used

in the safety-related EDG jacket water cooling system was inappropriate. More broadly,

this SCA and various locally-generated subcomponent SCAs were used to place

nonsafety-related gaskets, o-rings, and seals in many other safety-related systems,

some of which also may not have unlimited makeup capability. This was identified by

the licensee in the root cause evaluation conducted under condition report 28208.

In response to this condition, all nonsafety-related SCAs associated with safety-related

components were reviewed by the licensee, and administratively revised or replaced if

found to be faulted. Nonsafety-related gaskets, o-rings, and seals which were

determined to be inappropriately installed were replaced with safety-related material on

the EDG system only. This effort to replace nonsafety-related components did not

extend to the other affected safety-related systems; the licensee did not review work

history to determine which components in the affected systems actually contained

nonsafety-related material. For example, SCA 10-0086 covers gaskets in the

emergency fuel oil system. This SCA was administratively revised because of an

inadequate nonsafety-related evaluation, but the nonsafety-related gaskets in that

system were not specifically identified or replaced. Other affected systems include,

among others, the reactor coolant system, the residual heat removal system, the

essential service water system, and the auxiliary feedwater system. Engineering

Disposition/Configuration Change Package 13716 described below was generated as

justification.

The licensee approved Engineering Disposition/Configuration Change Package 13716 to

address the inappropriate installation of nonsafety-related gaskets, o-rings, and seals in

safety-related equipment due to the erroneous application of SCA 91-0408. Revision 3

of this Engineering Disposition allowed the facility to use-as-is the affected gaskets

until the next planned work in which the affected joints were to be opened. At that time,

the gaskets would be replaced; the licensee concluded that no new field work was

needed to address the non-conformance. The licensee did not evaluate exactly which

components were affected by this SCA, but rather justified generic acceptance of all

NSR gaskets, o-rings, and seals if they had not leaked prior to refueling outage 18. The

licensee cited historic non-leakage, skill of the craft of maintenance persons installing

the gaskets, and historic high acceptance rate of nonsafety-related gaskets during

commercial grade dedication as sufficient evidence that the affected components were

acceptable for continued use until eventual replacement at indeterminate dates.

The licensee defined critical gasket acceptance characteristics by citing EPRI TE

CGIGA01, Commercial Grade Item Evaluation for Gaskets, Non-Metallic and Spiral

Wound. Critical characteristics for acceptance were (emphasis added):

• Markings indication the proper item was received

• Configuration proper fit-up

• Material the most important characteristic as it covers a significant number of

critical characteristics for design, such as compressibility, creep relaxation,

pressure rating and resistance to internal and external elements.

- 26 -

• Thickness ensures sealability and pressure retention. Inadequate thickness =

poor seal. Excessive thickness = reduced resistance to internal / external

pressure due to large force acting radially.

The team noted in the above statement that the most important acceptance

characteristic for gaskets was material such as compressibility, creep relaxation,

pressure rating and resistance to internal and external elements. None of the

justifications for accepting continued usage of the non-conforming components can

adequately verify these material characteristics without knowing what materials were

actually installed. Additionally, the licensee cited USA 5059 Resource Manual, Applying

10 CFR 50.59 to Compensatory Actions to Address Nonconforming or Degraded

Conditions, Section 4.2.5, as their method for addressing the non-conformance. This

section allowed three courses of action for addressing non-conforming conditions; the

licensee chose to employ the first of the three, which reads:

If the licensee intends to restore the SSC back to its as-designed condition then this

corrective action should be performed in accordance with 10 CFR 50 Appendix B

(i.e., in a timely manner commensurate with safety). This activity is not subject to 10

CFR 50.59. (emphasis added)

NRC Inspection Manual Part 9900, Section 7.2, Timing of Corrective Actions, requires

that The licensee should establish a schedule for completing a corrective action when

an SSC is determined to be degraded or nonconforming. The team determined that an

indefinite replacement schedule dependent upon the regular course of maintenance for

unidentified nonconforming components did not meet the definition of timely. This

approach will also not allow the licensee to know when conformance has been restored,

because the actual extent of the condition is not known. The licensee documented this

issue in Condition Report 53456.

Analysis. The failure of the licensee to evaluate the suitability of the specific nonsafety-

related material installed in safety-related equipment and to determine the extent to

which this condition existed was a performance deficiency. This performance deficiency

was more than minor because it affected the design control attribute of the mitigating

systems cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences.

Specifically, the inadequate evaluation of nonsafety-related gaskets, o-rings, and seals

installed in safety-related equipment adversely affected the reliability of the affected

systems. Using Manual Chapter 0609.04, "Phase 1 - Initial Screening and

Characterization of Findings," the team determined that the finding was of very low

safety significance (Green) because the finding was a design or qualification deficiency

confirmed not to result in loss of operability or functionality. This performance deficiency

had a cross-cutting aspect in the corrective action program component of the problem

identification and resolution cross-cutting area because the licensee did not take

appropriate corrective actions to address safety issues and adverse trends in a timely

manner, commensurate with their safety significance and complexity (P.1(d)).

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III Design Control, requires,

in part, that measures be shall established for the selection and review for suitability of

application of materials, parts, equipment, and processes that are essential to the safety-

- 27 -

related functions of the structures, systems and components. Contrary to this

requirement, on September 12, 2011, the licensee failed to establish measures for the

selection and review for suitability of application of materials and parts that are essential

to the safety-related functions of structures, systems, and components. Specifically, the

licensee approved Engineering Disposition/Configuration Change Package 013716,

Revision 3, which allowed nonsafety-related gaskets, o-rings, and seals to remain

installed in safety-related piping joints until such time as the affected joints were next

opened in the normal course of maintenance; the engineering disposition did not identify

the specific components affected or the suitability of the installed materials. Because

this finding is of very low safety significance (Green) and was entered into the corrective

action program as condition report 53456, this violation is being treated as a non-cited

violation, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000482/2012006-08, Failure to Adequately Evaluate the Suitability of Nonsafety-

related Gaskets, O-Rings, and Seals Installed in Safety-Related Equipment and to

Identify Extent of the Condition.

i. Inappropriately High Threshold for Condition Report Initiation

Introduction. The team identified a Green finding for the licensees failure to ensure that

condition reports were initiated as required by procedure. The licensees implementing

procedure for its corrective action program did not contain clear guidance as to what

conditions were required to be entered into the corrective action program, or how soon

after discovery a condition report was required to be generated. The team identified

several examples where condition reports were not generated, though it appeared from

the guidance that one was required.

Description. Step 6.2.1 of the licensees condition reporting procedure, AP 28A-100,

Condition Reports, Revision 15A, requires personnel to promptly initiate a condition

report for equipment, human, organizational, program, process, or procedure

performance issues. Contrary to this requirement, the team identified a number of

examples where, prior to May 24, 2012, licensee personnel failed to initiate a condition

report:

• On May 10, 2012, during a walkdown of emergency core cooling system (ECCS)

pumps in response to industry operating experience, an operator noted several oil

leaks that appeared to be long-standing but were not documented in an open

condition report, work order, or work request. The team determined that these oil

leaks were adverse conditions as defined in AP 28A-100, and should therefore

have been documented in the corrective action program.

• Also on May 10, 2012, during the ECCS walkdown, the operator noted at least two

deficiency tags that were old, faded, and unreadable. While the operator took

action to replace the tags with readable ones, no condition report was initiated to

document the existence of the old, worn tags. The team determined that the

condition of these tags indicated an issue either (a) of operators and engineers not

routinely reading the tags to ensure existing leaks had not worsened or (b) of

complacency on the part of plant personnel to the tags deteriorating to an

unreadable condition. Thus the team concluded that the licensee failed to initiate a

condition report for a human performance issue as required by AP 28A-100.

- 28 -

• In condition report 51480, initiated on April 11, 2012, the licensee identified an

undocumented diesel fuel oil leak that was found with an absorbant pad underneath

it to collect the leaking oil. The team determined that the existence of the absorbant

pad indicated that the leak had been previously discovered by licensee personnel,

but that the personnel had failed to document the adverse condition in the corrective

action program.

The team further noted two potential discrepancies in procedure AP 28A-100 that could

cause confusion:

First, step 6.1.1 of AP 28A-100 states, Anyone can, and is expected to, initate a

Condition Report (CR) when they discover an Adverse Condition (emphasis added).

Adverse condition is defined in Attachment B as one of seven conditions or trends and is

amplified with a 42-item list of examples. However, as noted above, step 6.2.1 of AP

28A-100 states the requirement that personnel shall promply initate a CR for

equipment, human, organizational, program, process, or procedure performance issues

(emphasis added). The team determined that the difference in language between the

two procedure steps indicated that step 6.2.1 was a requirement while step 6.1.1 was

not.

Second, step 6.2.4 of AP 28A-100 reads, If the issue has any potential to impact the

plant or personnel safety, initiation shall not be later than the end of the work shift. The

team determined that the conditional statement required the condition report initiator to

perform a field evaluation of an adverse condition to determine whether or not it might

impact safety. The initiator may not be the most knowledgable individual about the

identified condition or the most qualified to evaluate it. The initiator may therefore

incorrectly decide that there is no potential safety impact and opt to delay entering the

condition into the corrective action program. The team determined that this could lead to

a potentially safety-significant condition not being promply addressed.

Analysis. The failure of licensee personnel to promptly initiate condition reports for

identified issues, contrary to procedural requirements, is a performance deficiency. This

performance deficiency is more than minor because if left uncorrected, it could lead to a

more significant safety concern. Using Inspection Manual Chapter 0609.04, Phase 1 -

Initial Screening and Characterization of Findings, the team determined that this finding

was of very low safety significance (Green) because it did not involve a design or

qualification deficiency, did not represent a loss of system safety function, and did not

screen as potentially risk significant due to a seismic, flooding, or severe weather

initiating event. This finding has a cross-cutting aspect in the resources component of

the human performance cross-cutting area because the licensee failed to ensure

procedures necessary for complete, accurate, and up-to-date procedures were available

and adequate to support nuclear safety. Specifically, the corrective action program

procedure was vague in its guidance as to when a condition report was required

(H.2(c)).

Enforcement. There was no identified violation of NRC requirements associated with

this finding. The licensee documented this deficiency in its corrective action program as

Condition Report 53445. Because this finding did not involve a violation of regulatory

- 29 -

requirements and had very low safety significance (Green), it is identified as a finding:

FIN 05000482/2012007-09, Inappropriate Threshold for Condition Report Initiation.

.6 Miscellaneous Issue Follow-Up

a. (Closed) URI 05000482/2012008-06, Review Actions to Correct Water Hammer Events

in the ESW System

Unresolved Item (URI)05000482/2012008-06 documents long-standing problems of

water hammer events in the essential service water system and the concern that the

actions to correct this problem have not been timely. The team determined that the

licensees efforts to correct a water hammer problem in the essential service water

system warranted additional NRC review and follow-up because this phenomenon has

repetitively challenged the integrity of a risk-significant safety-related system.

This URI was evaluated as part of the violation documented in section 4OA2.5.c of the

report. URI 05000482/2012008-06 is closed.

b. (Closed) URI 05000482/2012008-07, Review ESW Piping Corrosion Inspections

URI 05000482/2012008-07 documented why previous efforts were not sufficient to

detect corrosion problems before they developed into leaks and that water hammer

events made leaks more likely. The team determined that the licensees failure to

examine the condition of vendor-supplied piping associated with the containment coolers

as well as other areas of ESW piping warranted additional NRC review and follow-up.

This URI was evaluated as part of the violation documented in section 4OA2.5.c of the

report. URI 05000482/2012008-07 is closed.

4OA6 Meetings

Exit Meeting Summary

On May 24, 2012, the team presented the inspection results to Mr. M. Sunseri, President and

Chief Executive Officer, and other members of the licensee staff. Licensee management

acknowledged the issues presented. The inspector asked the licensees management whether

any materials examined during the inspection should be considered proprietary. No proprietary

information was identified.

ATTACHMENT: SUPPLEMENTAL INFORMATION

- 30 -

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Baban, Manager Systems

K. Hargis, Supervisor Corrective Action

L. Hauth, Work Control Senior Reactor Operator

S. Henry, Manager Operations

J. Isch, Superintendant Operations Work Controls

W. Muilenburg, Supvervisor Licensing

E. Peterson, Ombudsman

R. Rumas, Manager Quality

G. Sen, Manager Regulatory Affairs

J. Yunk, Manager Corrective Action

NRC personnel

C. Long, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000482/2012007-03 VIO Failure to Take Timely Corrective Action to Preclude Repetition

(Section 4OA2.5.c)05000482/2012007-06 VIO Failure to Implement Procedures to Test Safety-Related

Equipment (Section 4OA2.5.f)

Opened and Closed

05000482/2012007-01 NCV Inadequate Procedure to Implement Compensatory Measures

(Section 4OA2.5.a)05000482/2012007-02 NCV Failure to Report Conditions that Could have Prevented

Fulfillment of a Safety Function (Section 4OA2.5.b)05000482/2012007-04 NCV Untimely Corrective Action (Section 4OA2.5.d)05000482/2012007-05 NCV Failure to Complete Corrective Actions (Section 4OA2.5.e)05000482/2012007-07 NCV Failure to Prevent Recurrence of Component Cooling Water

System Voiding (Section 4OA2.5.g)05000482/2012007-08 NCV Failure to Adequately Evaluate the Suitability of Nonsafety-related

Gaskets, O-Rings, and Seals Installed in Safety-Related

Equipment and to Identify Extent of the Condition (Section

4OA2.5.h)05000482/2012007-09 FIN Inappropriately High Threshold for Condition Report Initiation

(Section 4OA2.5.i)

-1- Attachment 1

Closed

05000482/2012008-06 URI Review Actions to Correct Water Hammer Events in the ESW

System (Section 4OA2.6.a)05000482/2012008-07 URI Review ESW Piping Corrosion Inspections (Section 4OA2.6.b)

Discussed

None

LIST OF DOCUMENTS REVIEWED

CONDITION REPORTS

11247 25866 26712 28077 29163 31783 34620 40842 49716

12913 25867 26752 28088 29164 31818 34661 40933 50271 15077 25868 26753 28175 29252 31839 34896 40959 51292

20099 25869 26760 28187 29464 31848 34900 41151 51480

20153 25870 26826 28208 29467 32081 34902 41569 51931

20717 25871 26855 28224 29538 32227 34964 41613 51949

21039 25872 26940 28234 29559 32228 34987 41853 51951

21703 25873 27015 28252 29601 32233 35341 41975 51982

22296 25874 27027 28303 29602 32487 35343 41997 52917 22989 25880 27032 28346 30151 32680 36600 42349 52918 23024 25881 27034 28367 30201 32689 36973 42537 52981 23108 25882 27073 28376 30219 32761 36992 42618 52984 23110 25883 27077 28403 30235 32792 36993 42635 52985 23331 25884 27106 28474 30374 32886 36994 42737 53005

23992 25885 27108 28539 30566 32887 36996 43265 53047

24073 25886 27110 28562 30610 33199 37244 43278 53051

24183 25887 27145 28564 30918 33253 37374 43435 53058

24646 25888 27147 28575 31024 33258 37690 43515 53061

25058 25896 27172 28579 31039 33357 37931 44963 53062

25224 25918 27336 28620 31136 33395 38593 45320 53064

25228 25951 27484 28644 31193 33603 38965 45333 53200

25353 26001 27603 28652 31265 33773 39173 45758 53319

25404 26050 27605 28722 31428 33909 39187 45839 53342

25460 26070 27650 28854 31430 33925 39338 46131 53363

25463 26216 27718 28945 31432 33982 39494 46137 53369

-2-

CONDITION REPORTS

25478 26223 27949 28959 31557 34029 39995 46163 53390

25498 26302 27976 28990 31586 34206 40047 46814 53393

25658 26335 27982 29027 31617 34267 40219 47094 53394

25848 26354 28046 29105 31626 34455 40555 47813 53407

25863 26651 28048 29108 31641 34463 40707 47993 53456

25864 26678 28050 29152 31745 34465 40802 48141 53458

25865 26686 28067 29162 31746 34604 40841 49276

PROCEDURES

REVISION /

NUMBER TITLE DATE

AI 14-006 Severe Weather 12

AI 16C-006 MPAC Work Request/Work Order Process Controls 19

AI 16C-007 Work Order Planning 31

AI 16C-007 Work Order Planning 38

AI 20-001 WCNOC Quality Oversight Report 3

AI 20-004 QA Continuous Improvement 3

AI 20A-005 Quality Assurance Standards and Expectations 1A

AI 20E-001 Industry Operating Experience Group 8

AI 21D-006 Response to Plant Status Control Problems 8

AI 21D-007 Response to Clearance Order Issues 6

AI 21E-003 Clearance Order Improvement 3

AI 22A-001 Operator Work Arounds/Burdens/Control Room Deficiencies 10A

AI 22C-016 Unit Condition and Operational Residual Risk 0

AI 28A-010 Screening Condition Reports 11

AI 28A-010 Screening Condition Reports 12

AI 28A-023 Evaluation of Maintenance Rule Functional Failure CRs 2A

AI 28A-100 Cause Evaluations 0

AI 28A-100 Cause Evaluations 1A

AI 28A-100 Condition Reports 15A

AI 29B-003 Guidance to Prevent Unacceptable Preconditioning Prior to 2

Testing

AI 30E-003 Training Needs Analysis/Design Scope and Planning 14

-3-

PROCEDURES

REVISION /

NUMBER TITLE DATE

AI-28A-100 Cause Evaluations 0

AIF-16C-011-02 Walkdown Form ----

AP 05J-001 Quality Group D (Augmented) Quality Program 5

Requirements

AP 10-002 Fire Protection Program Requirements 7

AP 14A-003 Scaffold Construction and Use, For Category I Building and 18A

Structures

AP 14A-004 Scaffold Construction and Use, For Non-Category I Building 2

and Structures

AP 15C-002 Procedure Use and Adherence 35

AP 15C-004 Preparation, Review and Approval of Procedures, 41

Instructions and Forms

AP 20-001 Quality Stop Work and Escalation Processes 5

AP 20A-003 QA Audit Requirements, Frequencies and Scheduling 22

AP 20A-004 Conduct of Internal Audits 15

AP 20A-006 QA Issue Development, Reporting and Follow-up Processes 14

AP 20A-008 QA Surveillance and Station Monitoring Program 13

AP 20A-009 Quality Organization 4A

AP 20E-001 Industry Operating Experience Program 20

AP 20G-001 Control of Inspection Planning and Inspection Activities 13

AP 21-001 Conduct of Operations 54A

AP 21D-005 Plant Component Status Control 12

AP 21E-001 Clearance Orders 30

AP 21I-001 Temporary Modifications 8A

AP 22-001 Conduct of Pre-Job and Post-Job Briefs 13

AP 23-008 Equipment Reliability Program 4

AP 23E-001 Emergency Diesel Generator Reliability Program 7A

AP 24E-006 Replacement Item Selection 4

AP 28-007 Nonconforming and Degraded Conditions 9

AP 28A-100 Condition Reports 15A

-4-

PROCEDURES

REVISION /

NUMBER TITLE DATE

AP 28A-100 Condition Reports 16

AP 30D-010 Supplemental Personnel Training and Qualification 9

AP 30G-001 Training, Qualification, and Certification of Audit Personnel 8

AP 30G-002 Training by Quality 4C

AP-13-001 Fatigue Management 18

APF 22-001-01 Pre-Job Brief Checklist 16

APF 26A-003-01 Applicability Determination 12

APF 26B-003-01 USAR Change Request for 9.4 Tornado Damper 5

APF 30E-004-01 Basic Bearing and Lubrication Lesson Plan: Fabricate and 5

Install Threaded Piping

APF 30E-004-01 Corrective Action Program Leadership Process/Software 4

Training

GEN 00-004 Power Operation 69

GEN 00-005 Minimum Load to Hot Standby 71

I-ENG-004 Lubricating Oil Analysis 4

MGE LT-008 Routine Electrical Limitorque Operator Maintenance 6

MPM LT-001 Limitorque Operator Minor Maintenance, Lubrication, and 13A

Inspection

OFN AF-025 Unit Limitations 37

OFN BB-031 Shutdown LOCA 21

OFN MA-001 Load Rejection or Turbine Trip 17

OFN RP-013 Control Room Not Habitable 17

OFN RP-013A Hot Standby to Cold Shutdown from Outside the Control 1

Room

OFN RP-014 Hot Standby to Cold Shutdown from Outside the Control 14

Room

OFN RP-017 Control Room Evacuation 40

SEC 50-123 Security of Normal Requirements 23

STN AC-007 Turbine Overspeed Trip Test 28

STS AB-205 Main Steam System Inservice Valve Test 29

-5-

PROCEDURES

REVISION /

NUMBER TITLE DATE

STS AB-206 Main Steam System Inservice Valve Test (MSIVs Retest) 8

STS AC-001 Main Turbine Valve Cycle Test 26

STS PE-007 Periodic Verification of Motor Operated Valves 4

SYS AB-120 Main Steam and Steam Dump Startup and Operations 30A

SYS BG-201 Shifting Charging Pumps 50

WCQPM Wolf Creek Quality Program Manual 8

OPERATIONAL BURDENS / WORK-AROUNDS / CONTROL ROOM DEFICIENCIES

11-OW108 11-OB107 10-CRD120 11-CRD118 12-CRD119

12-OW101 11-OB125 08-CRD100 11-CRD195 12-CRD122

10-OB117 12-CRD111 11-CRD203

WORK ORDERS

08-305414 11-340104 11-346698 11-346174

10-325126 10-325125 10-325123 10-324270

08-308675 08-308676 08-308673 07-294389

09-322158-002 09-322158-001 10-325122 08-305212

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

Corrective Action Backlog Reduction Initiative 2

Corrective Action Recovery Monitoring Metrics March 2012

Corrective Action Recovery Monitoring Metrics April 2012

New Employee Orientation Checklist 11/10/11

QA Audit 12-04-CAP Corrective Action Program Exit

QA Audit Report 12-04-12: Corrective Action Program 5/21/12

Reportability Evaluation Request 2010-079 9/22/10

Temporary Modifications Log

-6-

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

---

Control Room Deficiency / Operator Workaround / 5/11/2012

Operator Burden / Work Request Tag Log

---

EDG SCA Review - Procurement Engineering ----

---

EDG System Performance Team Charter ----

---

Emergency Diesel Generator Reliability / Availability 6

Improvement Plan

---

Management Review Meeting Presentation: EDG 3/23/2012

Reliability Improvement Program

---

NSR SCA in SR System Review - Procurement ----

Engineering

---

Operations Crews D and E Work Hours: 1/5/2012 to ----

1/27/2012

---

WCNOC Westinghouse Sensitivity Study for MSPI ----

Margin

10-04-CAP Quality Assurance Audit Report Corrective Action 6/7/10

Program

10-07-FP Quality Assurance Audit Report Fire Protection 10/05/10

Program

10-11-FM QA Audit Report of Fatigue Management Program 6/7/2010

11-03-SEC Quality Assurance Audit Report Security 4/5/11

11-04-ENG Quality Assurance Audit Report Engineering Programs 9/14/11

11-05-SEC Quality Assurance Audit Report Security Program 7/19/11

11-06-EP Quality Assurance Audit Report Emergency 8/18/11

Preparedness Program

11-07-QA Quality Assurance Audit Report Quality Assurance 9/9/11

Program

12-04 CAP Corrective Action Program 4/25/2012

2010-1195-8 Status Control Training 8/2/2010

2011-1175-1 Status Control Training Rev 1 7/12/2011

2011-1205-1 Status Control Errors Continue 7/29/2011

2011-1375-1 Status Control Training 12/20/2011

-7-

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION /

DATE

APF 05-002-01 Engineering Screening: NSR Gaskets Installed in SR 0

Equipment. CCP 13716

APF 20-002-01 Plant Personnel Statements: January 2012 Post-Trip 10

Interviews (13)

CCP 13716 NSR Gaskets Installed in SR Equipment Revs 1-3

CR 40555 Class 1E equipment temperatures on loss of A/C unit 0

NO1131601 NSO Watchstanding Principles 1

OP1333201 Plant Status Control 0

PI 113 18 01 Overview of Trending Process for Corrective Action 000

Program

QA-OBS-54464 Fatigue Management ----

SA-2012-0021 2012 Mid Cycle Self Assessment 2/17/2012

SCA-91-0408 Safety Classification Analysis 91-0408 Revs 4-6

SEL 2009-150 Corrective Action Program Improvements 8/17/2009

TNA 2011-1002-1 Procedure Changes Gap

TNA 2012-1087-1 Extra COW Training Needed

WCNOC-12-21456 Life Cycle Management Plan for Emergency Diesel April 2012

Generators

-8-

Information Request

February 8, 2012

Biennial Problem Identification and Resolution Inspection

May 7 - May 25, 2012

Wolf Creek Generating Station

Inspection Report 05000482/2012007

This inspection will cover the period from May 26, 2010 to May 25, 2012. All requested

information should be limited to this period or to the date of this request unless otherwise

specified. To the extent possible, the requested information should be provided electronically in

Adobe PDF or Microsoft Office format. Lists of documents should be provided in Microsoft

Excel or a similar sortable format.

A supplemental information request will likely be sent during the week of April 30, 2012.

Please provide the following no later than April 16, 2012:

1. Document Lists

Note: For these summary lists, please include the document/reference number, the

document title or description of the issue, initiation date, current status, and long text

descriptions of the issues.

a. Summary list of all corrective action documents related to significant conditions

adverse to quality that were opened, closed, or evaluated during the period

b. Summary list of all corrective action documents related to conditions adverse to

quality that were opened or closed during the period

c. Summary lists of all corrective action documents which were upgraded or

downgraded in priority/significance during the period

d. Summary list of all corrective action documents that subsume or roll up one or

more smaller issues for the period

e. Summary lists of operator workarounds, engineering review requests and/or

operability evaluations, temporary modifications, and control room and safety

system deficiencies opened, closed, or evaluated during the period

f. Summary list of plant safety issues raised or addressed by the Employee

Concerns Program (or equivalent)

g. Summary list of all Apparent Cause Evaluations completed during the period

h. Summary list of all Root Cause Evaluations planned or in progress but not

complete at the end of the period

2. Full Documents with Attachments

a. Root Cause Evaluations completed during the period

b. Quality assurance audits performed during the period

Attachment 2

c. All audits/surveillances performed during the period of the Corrective Action

Program, of individual corrective actions, and of cause evaluations

d. Corrective action activity reports, functional area self-assessments, and non-

NRC third party assessments completed during the period (do not include INPO

assessments)

e. Corrective action documents generated during the period for the following:

i. All Cited and Non-Cited Violations issued to Wolf Creek Generating

Station

ii. All Licensee Event Reports issued by Wolf Creek Generating Station

f. Corrective action documents generated for the following, if they were determined

to be applicable to Wolf Creek Generating Station (for those that were evaluated

but determined not to be applicable, provide a summary list):

i. NRC Information Notices, Bulletins, and Generic Letters issued or

evaluated during the period

ii. Part 21 reports issued or evaluated during the period

iii. Vendor safety information letters (or equivalent) issued or evaluated

during the period

iv. Other external events and/or Operating Experience evaluated for

applicability during the period

g. Corrective action documents generated for the following:

i. Emergency planning drills and tabletop exercises performed during the

period

ii. Maintenance preventable functional failures which occurred or were

evaluated during the period

iii. Adverse trends in equipment, processes, procedures, or programs which

were evaluated during the period

iv. Action items generated or addressed by plant safety review committees

during the period

3. Logs and Reports

a. Corrective action performance trending/tracking information generated during the

period and broken down by functional organization

b. Corrective action effectiveness review reports generated during the period

c. Current system health reports or similar information

d. Radiation protection event logs during the period

e. Security event logs and security incidents during the period (sensitive information

can be provided by hard copy during first week on site)

f. Employee Concern Program (or equivalent) logs (sensitive information can be

provided by hard copy during first week on site)

g. List of Training deficiencies, requests for training improvements, and simulator

deficiencies for the period

4. Procedures

a. Corrective action program procedures, to include initiation and evaluation

procedures, operability determination procedures, apparent and root cause

evaluation/determination procedures, and any other procedures which implement

the corrective action program at Wolf Creek Generating Station

b. Quality Assurance program procedures

c. Employee Concerns Program (or equivalent) procedures

d. Procedures which implement/maintain a Safety Conscious Work Environment

5. Other

a. List of risk significant components and systems

b. Organization charts for plant staff and long-term/permanent contractors

Note: Corrective action documents refers to condition reports, notifications, action requests,

cause evaluations, and/or other similar documents, as applicable to Wolf Creek Generating

Station.

As it becomes available, but no later than April 16, 2012, this information should be uploaded

onto the Certrec IMS website. When these documents have been compiled (and by April 17,

2012), please download these documents onto a CD or DVD and send 4 copies via overnight

carrier to:

Ron Cohen

U.S. NRC Region IV

1600 East Lamar Blvd.

Arlington, TX 76011-4511

Please note that the NRC is not able to accept electronic documents on thumb drives or other

similar digital media. However, CDs and DVDs are acceptable.