ML081350176

IR 05000482-08-006; 01/28/08 - 4/22/08; Wolf Creek Generating Station; Identification and Resolution of Problems

ML081350176
Person / Time
Site:	Wolf Creek
Issue date:	05/14/2008
From:	Smith L J NRC/RGN-IV/DRS/EB2
To:	Muench R A Wolf Creek
References
IR-08-006
Download: ML081350176 (32)

See also: IR 05000482/2008006

Text

May 14, 2008

Rick A. Muench, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Burlington, KS 66839

SUBJECT: WOLF CREEK GENERATING STATION - NRC IDENTIFICATION AND RESOLUTION OF PROBLEMS INSPECTION REPORT 05000482/2008006

Dear Mr. Muench,

On February 29, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of a team inspection at your Wolf Creek Generating Station. The enclosed inspection report documents the inspection findings which were discussed on February 29, 2008, with you and members of your staff, and telephonically on April 22, 2008.

This inspection reviewed activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commission's rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. The team reviewed cross-cutting aspects of NRC findings and interviewed personnel regarding the condition of your safety conscious work environment at Wolf Creek Nuclear Station.

The inspectors reviewed 224 condition reports, work orders, associated root and apparent cause evaluations, and other supporting documentation to assess problem identification and resolution activities. Overall, the team concluded that your program was generally effective in identifying, evaluating, and correcting problems. However, the team identified a significant

number of longstanding equipment problems that were not being resolved in a timely manner. The team concluded that you continue to have problems with corrective actions, and this is not being effectively addressed.

Six findings were evaluated under the risk significance determination process as having very

low safety significance (Green). Four of these findings were determined to be violations of NRC requirements. However, because these violations were of very low safety significance and the issues were entered into your corrective action program, the NRC is treating these findings as non-cited violations, consistent with Section VI.A.1 of the NRC's Enforcement Policy. The non-cited violations are described in the subject inspection report. If you contest the violations or the

significance of the violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the

UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4125

Wolf Creek Nuclear Operating Corp. - 2 -

Regional Administrator, U. S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas, 76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC resident inspector at the Grand Gulf Nuclear Station facility.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Linda J. Smith, Chief

Engineering Branch 2 Division of Reactor Safety

Docket: 50-482 License: NPF-42

Enclosure: NRC Inspection Report 05000482/2008006 w/attachments: 1. Supplemental Information 2. Information Request

cc w/enclosure: Vice President Operations/Plant Manager Wolf Creek Nuclear Operating Corp. P.O. Box 411

Burlington, KS 66839

Jay Silberg, Esq. Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW

Washington, DC 20037

Supervisor Licensing Wolf Creek Nuclear Operating Corp. P.O. Box 411 Burlington, KS 66839

Chief Engineer Utilities Division Kansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027

Office of the Governor State of Kansas Topeka, KS 66612

Attorney General 120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597

County Clerk Coffey County Courthouse 110 South 6th Street Burlington, KS 66839-1798

Chief, Radiation and Asbestos Control Section

Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366

Wolf Creek Nuclear Operating Corp. - 3 -

Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) DRP Director (Dwight.Chamberlain@nrc.gov)

DRS Director (Roy.Caniano@nrc.gov) DRS Deputy Director (Troy.Pruett@nrc.gov) Senior Resident Inspector (Steve.Cochrum@nrc.gov) Branch Chief, DRP/B (Vince.Gaddy@nrc.gov) Senior Project Engineer, (Peter.Jayroe@nrc.gov)

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov) DRS STA (Dale.Powers@nrc.gov) J. Adams, OEDO RIV Coordinator (John.Adams@nrc.gov) ROPreports Resourse WC Site Secretary (Shirley.Allen@nrc.gov)

SUNSI Review Completed: _NFO ___ ADAMS: Yes No Initials: _NFO __ Publicly Available Non-Publicly Available Sensitive Non-Sensitive S:DRS:REPORTS\WC 2008006 PIR-proulx SRI/EB2 RI/EB1 RI/PBB RI/EB2 SRI/PBB C/EB2 DLProulx JPAdams CHLong HAAbuseini SCochrum LJSmith /RA/ /E/ /E/ /E/ /E/ /RA/ 4/28/08 4/25/08 4/25/08 4/25/08 4/25/08 5/13/08

C/DRP C/EB2 VGGaddy LJSmith /RA/ /RA/

5/1/08 5/13/08 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

- 1 - Enclosure

U.S. NUCLEAR REGULATORY COMMISSION REGION IV

Docket: 50-482

License: NPF-42

Report: 05000482/2008006

Licensee: Wolf Creek Nuclear Operating Company . Facility: Wolf Creek Generating Station

Location: P.O. Box 411 Burlington, KS 66839

Dates: January 28 through April 22, 2008

Inspectors: D. Proulx, Senior Reactor Inspector (Team Leader) S. Cochrum, Senior Resident inspector H. Abuseini, Reactor Inspector

J. Adams, Reactor Inspector C. Long, Resident Inspector

Approved By: Linda Joy Smith, Chief Engineering Branch 2

Division of Reactor Safety

- 2 - Enclosure SUMMARY OF FINDINGS

IR 05000482/2008006; 01/28/08 - 4/22/08; Wolf Creek Generating Station: Identification and Resolution of Problems.

The report covered a 2-week period of inspection by two resident and three region-based inspectors. Four Green non-cited violations and two Green findings were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or 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 3, dated July 2000.

A. Problem Identification and Resolution Results

Cornerstone: NA

• The team reviewed approximately 224 risk significant issues, apparent and root cause analyses, and other related documents, to assess the effectiveness of the

licensee=s problem identification and resolution processes and systems. The team concluded that although problems were consistently identified and entered

into the corrective action program, several examples occurred during the assessment period, as well as five additional examples identified by the team, of failure to implement appropriate and timely corrective actions. Four examples were identified where ineffective use of operating experience led to issues

occurred during the assessment period. Although no additional examples of missed operational experience were identified by the team, the licensee was not employing their formal tracking system (as required by procedure) for the review of operational experience.

The licensee overall performed effective and critical self-assessments. However, the team noted because of the split between ownership of the condition report

and work order systems, no formal trending of equipment issues was performed for items tracked only by work order. The team concluded that the licensee maintained an overall safety-conscious work environment, based on 28 selected interviews. Many

individuals were not aware of the Ombudsman (employee concerns) program's ability to take nuclear safety issues and believed it to be a

resource to resolve industrial safety concerns, coworker conflicts, personal issues, or human resources issues. Most workers stated that management was supportive of a safety conscious work environment. All the interviewees believed that potential safety issues were being addressed and there were no instances identified where individuals had experienced adverse actions for bringing safety

issues to licensee management or the NRC.

- 3 - Enclosure NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

• Green. The team identified a non-cited violation of 10 CFR Part 50 Appendix B Criterion V, in which 21 scaffolds in 10 plant areas that were in contact with or closer to plant equipment than procedure allowed. The procedure required

engineering evaluations did not contain any technical bases as to the acceptability of as built scaffolds. Subsequent engineering evaluation of each of the incorrect scaffolding installations confirmed that the configurations did not challenge operability. The NRC identified previous concerns with the erection of scaffolds, yet the licensee failed to take action to correct this issue.

The team evaluated the significance of this finding using Phase 1 of Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations," and determined that the finding was of very low safety significance because the issue resulted in 21 unevaluated scaffolds which are likely not to challenge the ability of the plant to safely shutdown after an earthquake. As such, under Phase 1 screening, the deficiency

is not related to a qualification or design deficiency, it did not represent a loss of safety function for a train or system as defined in the plant specific risk-informed inspection notebook, and did not screen as risk significant for seismic external events, because the affected systems were considered degraded, but operable. Using these inputs, the performance deficiency screened to Green. The team

determined that the finding had a human performance crosscutting aspect in the area associated with decision making because the licensee failed to adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action. Specifically, Wolf Creek Generating Station did not conduct any

review of engineering decisions to verify the validity of the underlying assumption that equipment and scaffolding could be in contact or closer than the established limit (H.1(b)) (Section 40A2.e(1)).

• Green. The team identified a finding because the licensee failed to take timely corrective actions to address a previously identified NRC finding. Finding 2007002-04 was issued because the licensee had failed to establish

compensatory actions in response to the failure of all main annunciator board alarms. Failure to have compensatory measures inhibited the licensee in their efforts to determine the cause of the alarm failures. Corrective actions repaired the equipment that caused of the annunciator failure, but were unrelated to the failure to follow procedures and take compensatory measures.

The team determined that this was a performance deficiency because the licensee had committed to take corrective actions in response to the previous non-cited violation but failed to do so in a timely manner. The inspectors determined that this violation was greater than minor because it met the intent of Manual Chapter 0612, Appendix E, Example 4.a., in that, there were several examples of the licensee failing to take corrective actions in response to NRC

- 4 - Enclosure identified non-cited violations and findings, indicating that the licensee routinely failed to perform engineering evaluations on similar issues. The inspectors performed a Phase I Significance Determination Process evaluation and determined that the violation was screened as being very low safety significance, Green, because all of the answers to the Phase I Worksheet Mitigating Systems

Column were "no". The team also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed to implement timely or effective corrective actions (P.1(d) (Section 40A2.e (2)).

• Green. The team identified a violation of 10 CFR Part 50 Appendix B Criterion XVI because the licensee failed to take timely corrective actions to address a previously identified non-cited violation. Non-cited Violation 2007003-05 was issued because the licensee had failed to perform an operability evaluation following bearing replacement on the Train B emergency exhaust system fan. Corrective actions were not related to the missed performance of the operability evaluation, but the equipment failure.

The team determined that this was a performance deficiency because the

licensee had committed to take corrective actions in response to the previous non-cited violation but failed to do so in a timely manner. The inspectors determined that this violation was greater than minor because it met the intent of Manual Chapter 0612, Appendix E, Example 4.a. in that there were several examples of the licensee failing to take corrective actions in response to NRC

identified non-cited violations and findings, indicating that "The licensee routinely failed to perform engineering evaluations on similar issues." The inspectors performed a Phase I Significance Determination Process evaluation and determined that the violation was screened as being very low safety significance, Green, because all of the answers to the Phase I Worksheet Mitigating Systems

Column were "no". The team also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed to implement timely or effective corrective actions. (P.1(d) (Section 40A2.e (3)).

• Green. The team identified a violation of 10 CFR Part 50 Appendix B Criterion XVI because the licensee failed to take timely corrective actions to address a previously identified finding. Finding 05000482/2008010 was issued because the licensee had failed to establish an acceptable monitoring frequency on their turbine driven auxiliary feedwater pump speed governor null-drift as recommended by a Part 21 report from Engine Systems, Inc. The corrective actions to establish the monitoring for the null-drift were not implemented.

The team determined that this was a performance deficiency because the licensee had committed to take corrective actions in response to the previous non-cited violation but failed to do so in a timely manner. The team determined that this violation was greater than minor because it met the intent of Manual Chapter 0612, Appendix E, Example 4.a., in that, there were several examples of the licensee failing to take corrective actions in response to NRC identified non-

- 5 - Enclosure cited violations and findings, indicating that "The licensee routinely failed to perform engineering evaluations on similar issues." The team performed a Phase I Significance Determination Process evaluation and determined that the violation was screened as being very low safety significance, Green, because all of the answers to the Phase I Worksheet Mitigating Systems Column were "no."

The team also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed to implement timely or effective corrective actions (P.1(d) (Section 40A2.e (4)).

• Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, regarding the failure to identify and correct conditions adverse to quality associated with non-cited violation 2006-004-02 documented in Inspection Report 2006-004. Specifically, the licensee did not address in the apparent cause evaluation and corrective actions the failure to follow procedures for inspecting the transmitters resulting in an inadequate inspection of installed Barton pressure transmitters for known potential manufacturing defects which resulted in a previous violation of Administrative Procedure (AP)28-011, "Resolving Deficiencies Impacting SSC's," Revision 1. The licensee

inappropriately credited transmitter inspections that occurred several years prior to receipt of the vendor recommendation as sufficient to resolve this issue.

This finding was more than minor because it could reasonably be viewed a precursor to a significant event and affected the equipment performance attribute

of the mitigating systems cornerstone and the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Using Manual Chapter 0609, "Significance Determination Process," Phase 1 worksheets, the inspectors determined that the finding is of very low significance because it did not represent an actual loss of a safety function or

operability and was not potentially risk significant due to external events. The inspectors also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed to identify the issue completely and thoroughly evaluate the problem such that the problem was resolved (P.1(a), P.1(c) (Section

40A2.e (5)).

• Green. The team identified a finding for failure to implement corrective action for abandoned in place annunciator feed wiring deficiencies. Condition Report 2005-003275 was initiated because Cables ST-009 and ST-019 were field-spliced together to prevent electrical shocks such that the system configuration did not match the system drawing. Work Order 07-292004-000

was initiated to correct this condition but was closed as unworkable. Condition Report 2005-003275 was closed to this closed work order even though the condition was not corrected, leaving the system in a condition not reflected in drawings or design documents. This configuration could result in further shocks, and further configuration control issues. The main annunciator system and its feeds are not safety-related, and therefore this performance deficiency is not a violation of NRC requirements.

- 6 - Enclosure

The failure to implement corrective actions for an identified configuration control issue is a performance deficiency. This item affects the mitigating systems cornerstone. The team determined that this violation was greater than minor because it met the intent of Manual Chapter 0612, Appendix E, Example 4.a. in that there were several examples of the licensee failing to take corrective actions in response to findings, indicating that "The licensee routinely failed to perform engineering evaluations on similar issues." The team performed a Phase I Significance Determination Process evaluation and determined that the violation was screened as being very low safety significance, Green, because all of the

answers to the Phase I Worksheet Mitigating Systems Column were "no." The team also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed to implement timely or effective corrective actions. (P.1(d) (Section 40A2.e (6)).

B. Licensee-Identified Violations

None

- 7 - Enclosure REPORT DETAILS

4 OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution (71152B)

The inspectors based the following conclusions, in part, on a review of issues that were identified in the assessment period, which ranged from January 1, 2006, (the last biennial problem identification and resolution inspection) to December 15, 2007. The issues discussed in this report are divided into two groups. The first group (current

issues) included problems identified during the assessment period where at least one performance deficiency occurred during the assessment period. The second group (historical issues) included issues that were identified during the assessment period where all the performance deficiencies occurred prior to the assessment period.

a. Assessment of Corrective Action Program Effectiveness

1. Inspection Scope

The team reviewed items selected across the seven cornerstones of safety to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. Specifically, the team selected and

reviewed approximately 224 condition reports (CRs) from those issued between January 1, 2006 and December 15, 2007. The team also performed field walkdowns of selected systems and equipment. Additionally, the team reviewed a sample of self-assessments, trending reports and metrics, system health reports, and various other documents related to the corrective action program.

The team evaluated condition reports, work orders, and operability evaluations to assess the licensee's threshold for identifying problems, entering them into the corrective action program, and the ability to evaluate the importance of adverse conditions. Also, the licensee's efforts in establishing the scope of problems were evaluated 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 licensee's daily 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 team reviewed a sample of condition reports, apparent cause evaluations, and root cause evaluations performed during this period to ascertain whether the licensee properly considered the full extent of cause and extent of condition for problems, as well as assessing 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 also conducted interviews with plant personnel to identify other processes that may exist where problems may be identified and addressed outside the corrective action program.

- 8 - Enclosure

A review of the auxiliary feedwater system was performed for a 5-year period to determine whether problems were being effectively addressed. The team conducted a walkdown of this system to assess whether problems were identified and entered into the work order process.

2. Assessments

(a) Assessment - Effectiveness of Problem Identification

The team concluded that problems were generally identified and documented in accordance with the licensee's corrective action program guidance and NRC requirements. The licensee was identifying problems at an appropriately low threshold and entering them into the corrective action program, with two isolated exceptions.

The team noted that two current examples occurred where the licensee did not always completely identify problems and document them in the corrective action program.

Current Issues

• The licensee failed to promptly identify the non-conservative methodology for calculating vortexing in the refueling water storage tank suction to the containment spray pumps (non-cited violation (NCV)05000482/2007006-02).

• The licensee failed to promptly identify that the technical specification surveillance for battery intercell resistance verified battery operability (NCV 05000482/2007006-04).

(b) Assessment - Effectiveness of Prioritization and Evaluation of Issues

The team assessed the licensee's effectiveness of prioritization and evaluation of issues

entered into the corrective action program, including technical evaluation, operability assessments and extent of condition reviews. The inspectors concluded that the licensee was generally effective in prioritization and evaluation of issues with several exceptions. Four current and two historical examples of evaluation problems included:

Current Issues

• The licensee failed to evaluate the extent of condition of similar components when a Train A emergency service water screen wash valve had failed. Upon later examination of a similar Train B emergency service water screen wash valve, the valve was found to have similar corrosion, and was degraded but operable (NCV 2007005-02).

• The licensee failed to perform an adequate common cause evaluation for failure of the Emergency Diesel Generator A electronic speed control card, as required by Technical Specification 3.8.1. Upon proper evaluation, the condition was found to exist on Emergency Diesel Generator B as well (NCV 2007005-03).

- 9 - Enclosure

• The licensee failed to adequately evaluate boric acid deposits (and subsequent wastage) at the base of the refueling water storage tank and take action to correct for 9 years (NCV 2007006-03).

• The team identified a green non-cited violation of 10 CFR 50 Appendix B Criterion V, in which 21 scaffolds in 10 plant areas that were in contact with or closer to plant equipment than the procedure allowed. The procedure required engineering evaluations which did not contain any technical bases as to the acceptability of as built scaffolds, which indicated inadequate and untimely evaluations of identified condition (Section 40A2.e(1)).

Historical Issues

• The licensee failed to properly evaluate the long term affect of axial shaft movement for a component cooling water pump with respect to post accident conditions, resulting in the issue not being addressed for 18 years (Finding (FIN) 05000482/2006010).

• The licensee failed to properly evaluate and determine the cause of reactor coolant pump thermal barrier cooling water outlet isolation valves going closed. Multiple opportunities existed for the licensee to evaluate and correct this condition, which could have challenged the reactor coolant pump seal boundary (NCV 2007003-03).

The team reviewed the root cause evaluation and apparent cause evaluation procedures, as well as samples of both types of evaluations. The qualifications records for the root cause evaluators were also reviewed. The team concluded that Wolf Creek Generating Station had a good root cause determination process and effectively implemented these processes. A variety of root cause analysis methodologies were utilized in a team setting, and in general, were able to determine the cause for the specific problem. Appropriate corrective actions were identified to address each cause.

External operating experience and off-site expertise were generally appropriately utilized in their evaluations, with the above exceptions.

(c) Assessment - Effectiveness of Corrective Actions

The inspectors reviewed plant records, primarily CRs and work orders, to verify that corrective actions were developed and implemented. Additionally, the inspectors reviewed a sample of CRs that addressed past NRC identified violations for each cornerstone to ensure that the corrective actions adequately addressed the issues as described in the inspection reports. The inspectors also reviewed a sample of corrective

actions closed to other CRs, work orders, or tracking programs to ensure that corrective actions were still appropriate and timely.

The team identified five new examples of longstanding problems that have not been effectively resolved. The nature and extent of these examples demonstrated that the

corrective actions were either not sufficiently broad or were not timely. This is in addition

- 10 - Enclosure to similar issues identified previously in the assessment period. A number of NRC identified violations were not corrected. Current and historical examples included:

Current Issues

• The licensee failed to provide adequate corrective actions for repeat occurrences of failure to properly isolate sump pump motors prior to work, resulting in identification that the circuits were unintentionally energized (NCV 2006003-01).

• The licensee failed to provide adequate corrective actions for multiple occurrences of foreign material in the spent fuel pool. The licensee failed to identify the source of the material, resulting in repeat occurrences of this issue (NCV 2006010-03).

• The licensee failed to provide adequate corrective actions for elevated vibration levels on the Train B emergency exhaust system fan. The condition was not corrected because the licensee did not identify that the fan was not adequately lubricated (NCV 2007003-04).

• The licensee failed to provide timely corrective actions for elevated vibration levels on the charging pump balance line. Because of the failure to correct this condition, the balancing line cracked rendering the charging pump inoperable. This condition was permitted to exist for extended period of time without

correction, resulting in failure (FIN 2007006).

• The team identified a Green finding because the licensee failed to establish corrective actions for a violation previously identified in an NCV associated with missed compensatory actions during an extended period when the main annunciator board failed (Section 4OA2.e(2)).

• The team identified a Green NCV for failure to establish corrective actions for a violation previously identified in an NCV, with respect to a failure to perform an operability evaluation following bearing replacement on the Train B emergency exhaust system fan (Section 4OA2.e(3)).

• The team identified a Green NCV for failure to establish corrective actions for a violation previously identified in an NRC finding associated with establishing an acceptable monitoring frequency for their turbine driven auxiliary feedwater pump speed governor null-drift (Section 4OA2.e(4)).

• The team identified a Green NCV for failure to take corrective actions for NCV 2006-004-02. Specifically, the licensee did not address in the apparent cause evaluation and corrective actions the failure to follow procedures resulting

in an inadequate inspection of installed Barton pressure transmitters for known potential manufacturing defects which resulted in a previous violation (Section 4OA2.e(5)).

- 11 - Enclosure

• The team identified a Green finding for failure to correct sewage treatment plant annunciator feed deficiencies. Condition Report 2005-003275 was initiated to correct discrepancies between the as-build configuration and drawings, but was closed with no corrective action implemented (Section 40A2.e(6)).

b. Assessment of the Use of Operating Experience (OE)

1. Inspection Scope

The team examined the licensee's program for reviewing industry operating experience, including reviewing the governing procedure and self-assessments and interviewing the OE program owner. A sample of operating experience notification documents that had

been issued during the assessment period were reviewed to assess whether the licensee had appropriately evaluated the notification for relevance to the facility. The team also then examined whether the licensee had entered those items into their corrective action program and assigned actions to address the issues. The team reviewed a sample of root cause evaluations and significant CRs to verify if the licensee had appropriately included industry operating experience.

2. 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 concluded that the licensee was also evaluating

industry operating experience when performing root cause and apparent cause evaluations. The team concluded that ineffective use of operating experience resulted in four issues that occurred during the assessment period. The team identified no additional examples. Current examples of inadequate use of operating experience included:

• Ineffective use of operating experience contributed to the failure to follow procedure with respect to a reactor vessel head lift, which violated height requirements. This issue had also occurred during a previous refueling outage (NCV 2006005-01).

• Ineffective use of operating experience contributed to the failure to establish appropriate procedures for testing of the turbine-drive auxiliary feedwater pump. The licensee did not implement a 10 CFR Part 21 notification to ensure that a

null voltage drift in the controller did not adversely affect the governor (FIN 2006010).

• Ineffective use of operating experience contributed to the failure to establish appropriate procedures to inspect submerged cables with the potential for cable degradation (NCV 2006010-04).

- 12 - Enclosure

• Ineffective use of operating experience (vendor recommendation) contributed to the failure to inspect for a potential defect in emergency diesel generator governor control cards (FIN 2007005).

c. Assessment of Self-Assessments and Audits

1. 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 team also reviewed audit reports to assess the effectiveness of assessments in specific areas. The specific self-assessment documents reviewed are

listed in the Attachment.

2. Assessment

The team concluded that the licensee had a good self-assessment process, but was still making progress towards implementing the process as it was intended. The team concluded that trending processes required improvement

Current Issue

• The licensee did not have an effective, formal program for trending equipment failures documented in work orders that do not have a corresponding condition report. d. Assessment of Safety Conscious Work Environment

1. Inspection Scope

The team interviewed 28 members of the plant staff, which represented a cross-section

of functional organizations and supervisory and nonsupervisory personnel, to assess the establishment of a safety conscious work environment (SCWE) at Wolf Creek Generating Station. In this context, a SCWE refers to an environment in which employees feel free to raise safety concerns, both to their management and to the NRC, without fear of retaliation. The typical interview questions were similar to those listed in

the appendix, "Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R [Problem Identification and Resolution] Issues," to NRC Inspection Procedure 71152. During interviews, document reviews, and observations of activities relevant to the Identification and Resolution of Problems inspection, the inspectors looked for evidence that suggested plant employees were reluctant to raise safety

concerns. The team reviewed procedures and training materials used to implement the safety conscious work environment and safety culture programs at the site, and discussed them with the site Employee Concerns Program coordinator(Ombudsman). The team also interviewed the Employee Concerns Program coordinator (Ombudsman) and reviewed selected files from closed employee concerns.

- 13 - Enclosure 2. Assessment

The team concluded that the licensee maintained an overall safety-conscious work environment, based on 28 selected interviews. Many

individuals were not aware of the Ombudsman (employee concerns) program's ability to take nuclear safety issues and

believed it to be a resource to resolve industrial safety concerns, coworker conflicts, personal issues, or human resources issues. Most workers stated that management was supportive of a safety conscious work environment but most could not define safety conscious work environment. However, all the interviewees believed that potential safety issues were being addressed and there were no instances identified where

individuals had experienced adverse actions for bringing safety issues to licensee management or the NRC.

Current Issues

• The majority of the interviewees made comments regarding the lack of knowledge of the employee concerns program and purpose. All were knowledgeable of the Ombudsman but did not associate him with the employee concerns program, but believed him to be a resource to resolve industrial safety

concerns, coworker conflicts, personal issues, or human resources issues.

• More than half of the interviewees were not comfortable or lacked knowledge with inputting a condition report into PILOT (corrective action database) and would rather provide the concern to management for input, but did not believe safety issues were not being identified

• More than half of the interviewees were not aware of Wolf Creek Generating Station SCWE policy or guidance.

• The team received isolated comments about training weeks being used for not job specific training, the lack of qualified staff to allow for additional training during the workday and the routine use of overtime to ensure minimum staffing for crews.

• The interviewees all believed that potential safety issues were being addressed and there were no instances identified where individuals had experienced adverse actions for bringing safety issues to licensee management or the NRC.

e. Specific Issues Identified During This Inspection

(1) Failure to Correct Procedure Deviations to Demonstrate Seismic Acceptability

Introduction. On January 31, 2008, the team identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion V, in which, 21 scaffolds in 10 plant areas that were in contact with or closer to plant equipment than procedure allowed. The procedure required engineering evaluations which did not contain any technical bases as to the acceptability of as built scaffolds.

- 14 - Enclosure

Description. On January 31, 2008, the team identified 21 scaffolds in 10 areas of the plant that exceeded the limit of 2 inches between erected scaffolding and safety equipment which is established in Administrative Procedure (AP) 14A-003, "Scaffold Construction and Use." Procedure AP 14A-003, Step F.4.2, states that if the gap was

less than 2 inches, that engineering was required to evaluate the scaffold. The team requested the engineering evaluations for all the scaffolds. The evaluation contained on the associated scaffolding request form that had an engineer's signature and a box checked "Yes" for "Scaffolding is required to be seismically qualified." The team questioned engineering if there were any other technical bases or formal documentation

for the scaffolds. The team reviewed generic Scaffold Construction Calculation XX-C-018, "Evaluation of Seismically Qualified Scaffolding" and could not locate the acceptability of having scaffolding closer than 2 inches or in contact with safety equipment. The inspectors met with plant management to discuss the concerns on February 1. Plant management informed the inspector that engineering judgment was an acceptable criterion to establish the adequacy of the scaffolds. Wolf Creek Generating Station did not have any technical justification such that interactions between

safety equipment and the scaffolding would not cause equipment damage.

Wolf Creek Generating Station subsequently re-evaluated the scaffolds of concern. On February 4, inspectors reviewed the re-evaluated scaffolds' documentation. One set of scaffold were acceptable because the equipment in contact with the scaffold was

nitrogen lines used for testing in the electrical penetration room, and wood planking still in contact with or closer than 2 inches to the electrical penetrations were non-safety cables. One of the scaffolds was moved, such as the scaffold that was threaded through an electrical cable tray. However, the scaffolds in contact with or closer than the 2 inch limit were informally justified along two principles. First, if the safety equipment was a

cable tray, instrument air line, or heating, ventilation, and air conditioning (HVAC) ducting, engineering stated that contact during an earthquake would be acceptable because the scaffold would support the equipment or that such equipment was flexible and could tolerate contact. Second, if the safety equipment was a pipe, engineering stated that contact during an earthquake would be acceptable because piping is robust

and would not be damaged. In consultation with a senior engineer from the Office of Nuclear Reactor Regulation's Engineering Mechanics Branch, the inspectors judged these evaluations not to be sufficient to demonstrate that the equipment would not be damaged during an earthquake.

The scaffolding in the Containment Spray Rooms A and B, the 1988' pipe chase, the Residual Heat Removal Heat Exchanger A room, both electrical penetration rooms, the 2047' HVAC room, Emergency Exhaust Fan Room A, Emergency Diesel Generator Room A, and Auxiliary Feedwater Pump Room A were not moved. One scaffold in the 2047' HVAC room was removed, as well as scaffolding in one of the electrical penetration rooms. Scaffolding in the Emergency Diesel Generator Room A received additional bracing to prevent flexing in the direction of the air start line. However, the

inspectors judged that none of these examples would prevent the safe shutdown of Wolf Creek Generating Station because these systems were degraded, but operable.. During a further meeting on February 20, Wolf Creek Generating Station engineering was able to show that one of the scaffolds of concern on the 2047' of the auxiliary building was

- 15 - Enclosure partially not a concern because while the scaffold was in contact with an air line, the line served only pneumatic tools used during maintenance and not any safety related or risk significant equipment. Nonetheless, this particular scaffold was in contact with two electrical cable trays.

Analysis. The failure to follow AP 14A-003 to evaluate the clearance between scaffolding and safety equipment per procedure is a performance deficiency. The inspectors determined that this finding was more than minor because it is consistent with Manual Chapter (MC) 0612, Appendix E, example 4.a in that Wolf Creek Generating Station consistently failed to evaluate scaffolding that exceeded the 2 inch acceptance

criteria.

The inspectors evaluated the significance of this finding using Phase 1 of Inspection Manual Chapter (IMC) 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations," and determined that the finding was of very low safety significance because the issue resulted in 21 unevaluated scaffolds which are likely not to challenge the ability of the plant to safely shutdown after an earthquake. As

such, under Phase 1 screening, the deficiency is not related to a qualification or design deficiency, it did not represent a loss of safety function for a train or system as defined in the plant specific risk-informed inspection notebook, and did not screen as risk significant for seismic external events, because the affected systems were considered degraded but operable. Using these inputs, the performance deficiency screened to

Green. The inspectors also determined that the finding had a human performance crosscutting aspect in the area associated with decision making because the licensee failed to adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action. Specifically, Wolf Creek did not conduct any review of engineering decisions

to verify the validity of the underlying assumption that equipment and scaffolding could be in contact or closer than the established limit (H.1(b)).

Enforcement. Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion V, "Instructions, Procedures, and Drawings" requires, in part that activities

affecting quality be prescribed by procedures appropriate to the circumstances and shall be accomplished according to these procedures. Wolf Creek Generating Station AP 14A-003, "Scaffold Construction and Use," Revision 14, implements the seismic design requirements contained in Calculation XX-C-18 for scaffolds in safety related areas and establishes acceptance criteria.

Contrary to the above, from November 13, 2003 to February 4, 2008, the licensee did not construct 21 scaffolds in safety related plant areas in accordance with AP 14A-003. Specifically, Wolf Creek Generating Station did not modify the scaffolds or evaluate the deviations with appropriate acceptance criteria to demonstrate that the seismic design bases remained valid. This issue and the corrective actions are being tracked by Wolf Creek Generating Station in CR 2008-000383. Because the violation was of very low

safety significance and the issue was captured in the licensee's corrective action program as CR 2008-000118, this violation is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000482/2008006-01, Twenty-one examples of failure to follow seismic requirements of scaffolding procedure.

- 16 - Enclosure

(2) Failure to Implement Corrective Actions to Correct a Finding Associated with Compensatory Measures following Main Annunciator Failure. Introduction. The team identified a Green finding because the licensee failed to establish corrective actions for a violation previously identified in an NCV associated with missed compensatory actions during an extended period when the main annunciator board failed.

Description. NRC inspectors had previously issued NCV 2007002-04 to document an NCV in that the licensee failed to establish compensatory actions during an extended period when the main annunciator board failed. The licensee initiated CR 2007-000362 to place this issue into the corrective action program to correct the NCV. The team noted that the corrective actions in the CR only addressed the hardware failure and not the failure to establish compensatory measures, and therefore, were not appropriate to the circumstances. The team determined that the licensee had not established any corrective action plan to address this NCV and considered this to be a performance

deficiency, although the main annunciator is not a safety related system.

Analysis. The failure to establish corrective actions for each aspect of NCV 2007002-04 is a performance deficiency. This violation is considered to be greater than minor because it meets the intent of MC 0612, Appendix E, Example 4.a, in that there are

multiple examples of a failure to establish corrective actions associated with NCVs and findings, indicating that "The licensee routinely failed to perform engineering evaluations on similar issues." The team performed a Phase I SDP evaluation and determined that the violation is of very low safety significance, Green, because all of the answers to the Phase I Worksheet Mitigating Systems Column were "no". This finding has a

cross-cutting aspect in the area of corrective action program because the licensee failed to put all aspects of NCV 2007002-04 into their corrective action program (P.1(d)).

Enforcement. Although the licensee failed to identify corrective actions to address the lack of compensatory actions associated with the failure of their main annunciator board,

the main annunciator system is not safety-related, and thus was not a violation of NRC requirements. This finding was placed in the corrective action program as CR 2008-000777. Finding 05000482/2008006-02, Failure to take corrective action for missed compensatory measures.

(3) Failure to Implement Corrective Actions for a Missed Operability Assessment

Introduction. The team identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI because the licensee failed to establish corrective actions for a violation previously identified in an NCV, with respect to a failure to perform an operability evaluation following bearing replacement on the Train B emergency exhaust system fan.

Description. NRC inspectors had previously issued NCV 2007003-05 to document a non-cited violation where the licensee failed to perform an operability evaluation following bearing replacement on the Train B emergency exhaust system fan. The licensee initiated CR 2007-002411-0 place this issue into the corrective action program

- 17 - Enclosure to correct the NCV. The team noted that the corrective actions in the CR only addressed the hardware failure and not the failure to perform an operability evaluation, and therefore, were not appropriate to the circumstances. The team determined that the licensee had not established any corrective action plan to address this NCV and considered this to be a performance deficiency.

Analysis. The failure to take corrective action to establish corrective actions for each aspect of NCV 2007003-05 is a performance deficiency. This finding is considered to be greater than minor because it meets the intent of MC 0612, Appendix E, Example 4.a, in that there are multiple examples of a failure to establish corrective actions associated

with NRC NCVs and findings, indicating that "The licensee routinely failed to perform engineering evaluations on similar issues." The team performed a Phase I Significance Determination Process (SDP) evaluation and determined that the violation is of very low safety significance, Green, because all of the answers to the Phase I Worksheet Mitigating Systems Column were "no". This violation has a problem identification and resolution cross-cutting aspect in the area of corrective action program because the licensee failed to put all aspects of NCV 2007003-05 into their corrective action program

(P.1(d)).

Enforcement. Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion XVI requires conditions adverse to quality to be promptly identified and corrected. Contrary to this requirement, the licensee failed to identify corrective actions

to address where the licensee failed to perform an operability evaluation following bearing replacement on the Train B emergency exhaust system fan. Because this finding is of very low safety significance and was entered into the licensee's corrective action program as CR 2008-000777, this violation is being treated as a non-cited violation in accordance with Section VI.A.1 of the Enforcement Policy:

NCV 05000482/2008006-03, Failure to take corrective actions for missed operability assessment.

(4) Failure to Correct Finding Associated with Auxilary Feedwater Pump Governor Null Setting Introduction. The team identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI when the licensee failed to establish corrective actions for a violation previously identified in an NRC finding associated with establishing an acceptable monitoring frequency for their turbine driven auxiliary feedwater (AFW) pump speed

governor null-drift.

Description. NRC inspectors had previously issued FIN 2006010 to document their determination that the licensee had failed to establish an acceptable monitoring frequency for their turbine driven AFW pump speed governor null-drift as recommended by a Part 21 report from Engine Systems, Inc. The licensee initiated CR 2005-002241 to place this issue into the corrective action program to correct the NCV. The team noted

that the corrective action in the CR again did not establish a monitoring frequency for the turbine driven AFW pump speed governor null-drift, and therefore, was not appropriate to the circumstances. The team determined that the licensee had not established a

- 18 - Enclosure corrective action plan to address this finding and considered this to be a performance deficiency.

Analysis. The failure to establish corrective actions for each aspect of FIN 2006010 is a performance deficiency. This finding is considered to be greater than minor because it

meets the intent of MC 0612, Appendix E, Example 4.a, in that there are multiple examples of a failure to establish corrective actions associated with NRC NCVs and findings, indicating that "The licensee routinely failed to perform engineering evaluations on similar issues." The inspectors performed a Phase I SDP evaluation and determined that the violation is of very low safety significance, Green, because all of the answers to

the Phase I Worksheet Mitigating Systems Column were "no". This violation has a problem identification and resolution cross-cutting aspect in the area of corrective action program because the licensee failed to put all aspects of FIN 2006010 into the corrective action program (P.1(d)).

Enforcement. Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion XVI requires that conditions adverse to quality are promptly identified and

corrected. Contrary to this requirement, the licensee failed to identify corrective actions to address the lack of an acceptable monitoring frequency on their turbine driven AFW pump speed governor null-drift. Because this finding is of very low safety significance and was entered into the licensee's corrective action program as CR 2008-000777 this violation is being treated as an NCV in accordance with Section VI.A.1 of the

Enforcement Policy: NCV 05000482/2008006-04, Failure to take timely corrective actions to establish monitoring frequency for AFW Pump null set drift.

(5) Failure to Take Timely Corrective Action for Barton Transmitter Defects

Introduction. The team identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, for failure to identify and correct conditions adverse quality associated with NRC NCV 2006-004-02 documented in Inspection Report 2006-004. Specifically, the licensee did not address in the apparent cause evaluation and corrective actions the failure to follow procedures resulting in an inadequate inspection of installed Barton

pressure transmitters for known potential manufacturing defects which resulted in a previous violation.

Description. On May 18, 2006, PRIME Measurement Products issued a Nuclear Industry Advisory that Barton Model 763 and 763A gage pressure transmitters and

Model 764 differential pressure transmitters may have defective external lead-wire connectors. The advisory described a defect where the insulated portions of the wires in the connectors may not be embedded deeply enough into the epoxy potting used to structurally support the soldered wire connections and establish a seal to protect the solder connections from shorting. The advisory warned that shorting of conductors could occur in an electrically conductive accident environment. The advisory stated the affected transmitters were manufactured after May 1982 and shipped from the factory

prior to April 1, 2006. Transmitters manufactured prior to June 1982 and assembled with heat shrinking embedded in the epoxy potting were not subject to the concerns of the PRIME advisory. PRIME recommended that all connectors in transmitters manufactured after May 1982 be inspected for exposure of the external lead wire conductors at the

- 19 - Enclosure surface of the connector and that any transmitter with exposed conductors should be considered defective and replaced. Because of the design and configuration of the transmitters, the inspections would necessitate the connector be unscrewed from the transmitter and the external lead wires flexed 90 degrees to ensure the insulated portions of the wires are securely embedded in the epoxy potting material. On June 21,

2006, following inspection of warehouse stock potentially affected by the PRIME advisory, Callaway plant made a 10 CFR Part 21 report notifying the NRC of defects in Barton pressure transmitters.

Wolf Creek Generating Station determined that the affected Barton models were used

onsite with a total of 39 safety-related transmitters installed. System engineering performed an operability evaluation to assess if any of the installed transmitters were defective. As part of the operability justification basis, system engineering referred to previous inspections performed by instrumentation and control technicians under Work Request 00077-93. These inspections were performed in 1993 and were in response to Westinghouse Letter SAP-92-182 that identified the potential for damage to lead wire insulation on Barton pressure transmitters. The letter identified a potential defect caused

by lead wire rubbing against the internal threads of the housing boss, resulting in insulation damage. Westinghouse recommended that each transmitter be inspected for wire insulation damage; however, this only required inspection at the entrance to the transmitter housing. Work Request 00077-93 contained steps to inspect the transmitters addressed in the Westinghouse letter, which included removing the conduit flex cable

and conduit connector and inspecting the transmitter lead wire at point of exit from the transmitter housing. The inspection criteria established in the work order only required that the wire insulation be smooth, unblemished, and free of nicks. Specifically, the work order did not contain the requirements to unscrew the connector from the transmitter and that the external lead wires be flexed 90 degrees to ensure the insulated portions of the

wires are securely embedded in the epoxy potting material as recommended in the current PRIME advisory.

The licensee performed inspections on June 27, 2006, of two Barton pressure transmitters affected by the PRIME advisory that were not included in the scope of the

1993 inspections. The resident inspector observed the inspections of these two transmitters. In both cases, the inspection revealed that the transmitters were assembled with heat shrinking embedded in the epoxy potting and, therefore, not subject to the advisory. However, the inspectors questioned how the 1993 inspections could identify the defective condition. Specifically, the inspectors questioned how the previous

inspections could take credit to identify the insulated portions of the wires were securely embedded in the epoxy potting material, since the connectors were not unscrewed from the transmitter and the external lead wires were not flexed 90 degrees. Additionally, the inspectors noted that the lead wires and epoxy potting are inaccessible without removal of the connector; therefore, the recommended inspection could not be completed.

- 20 - Enclosure Procedure AP 28-011 requires that, during the operability determination process, a reasonable expectation must exist that the structure, system or component (SSC) is operable and that the prompt determination process will support that expectation. Contrary to this requirement, "reasonable expectation" was not established because the 1993 inspections did not support the engineering judgment used based on the 1993

inspections which did not look at epoxy defects.

A review of the inspections performed in 1993 revealed 14 of 39 installed Barton pressure transmitters manufactured without heat shrinking embedded in the epoxy potting and, therefore, potentially affected by the PRIME advisory. The licensee

corrective actions to date have only inspected several spare lead wire assemblies in warehouse stock and two installed transmitters that were not originally inspected in 1993. The licensee also plans to replace 10 transmitters that were identified without heat shrinking. However, no evaluation or corrective actions address the failure to follow AP 28-011, "Resolving Deficiencies Impacting SSC's," Revision 1.

Analysis. The failure to evaluate and implement appropriate corrective actions for a condition adverse to quality was a performance deficiency. This finding was more than minor because it could reasonably be viewed a precursor to a significant event and affected the equipment performance attribute of the mitigating systems cornerstone and the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Using MC 0609, "Significance Determination Process,"

Phase 1 worksheets, the inspectors determined that the finding is of very low significance because it did not represent an actual loss of a safety function or operability and was not potentially risk significant due to external events. The inspectors also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed

to identify the issue completely and thoroughly evaluate the problem such that the problem was resolved (P.1(a), P.1(c)).

Enforcement. Part 50 of Title10 of the Code of Federal Regulations, 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, on January 16, 2007, the licensee failed to identify and correct the failure to follow AP 28-011 which resulted in an inadequate inspection of installed Barton pressure transmitters for known potential manufacturing. Because the violation was of very low safety significance and has been entered into the licensee's Corrective Action Program

as Condition Report 2008-000777, this violation is being treated as an NCV, consistent with Section VI.A of the Enforcement Policy: NCV 05000482/2008006-05, Failure to take timely corrective action to correct Barton transmitter defects.

(6) Failure to Take Corrective Actions to Correct Annunciator Feed Deficiencies

Introduction. The team identified a Green finding for failure to correct sewage treatment plant annunciator feed deficiencies. Condition Report 2005-003275 was initiated to correct discrepancies between the as-build configuration and drawings, but was closed with no corrective action implemented.

- 21 - Enclosure Description. In 2005, a sewage treatment process plant was being decommissioned when workers kept complaining of electric shocks while digging in the vicinity of the sewage treatment plant. When it was investigated by the electrician, the electrician found that because Cable ST009 (extending between the local junction box at the sewage treatment plant area and the main Control Room Board RL013-RL014)

(Drawings E-1142 and E-1146) was still connected to the daisy chained control room 125vdc annunciator alarm power supplies disconnected Cable ST019 from the local junction box (extending between the local junction box and the local lift station) and shorted out and spliced Cable ST009 in order to prevent shocks and control room annunciator alarms. The electrician performed this modification without documenting

this action.

Condition Report 2005-003275 was initiated to identify problems with abandoned in place sewage treatment plant equipment on Drawings E-1005-ST01, ST02, ST03, ST05 and ST06. This condition report indicated that the equipment was removed and not abandoned in place. In order to prevent power supply and control room alarm problems, the condition report requested that the condition be corrected to reflect the field

configuration. The condition report also recommended that Cable ST009 be removed from Terminal TB2 (87,88) or be used for the lift station that was still required to pump sewage to a lagoon outside the plant. There were no corrective actions to this condition report. However the electrician was directed to perform Work Order (WO) 07-292004-000. This WO directed the electrician to ensure that

Cables ST009, S016 and ST019 are installed in accordance with Drawings E-1005-ST03 and ST06. The WO summary concluded that the work was not workable because Cable ST019 had been removed, and thus the WO was closed. Because WO 07-292004-000, was closed the licensee inappropriately closed CR 2005-003275 to the WO, without reviewing the results to determine if the condition had been properly

corrected. The failure to correct this condition is a finding.

Analysis. The failure to implement corrective actions for an identified configuration control issue is a performance deficiency. This item affects the mitigating systems cornerstone. The team determined that this violation was greater than minor because it

met the intent of MC 0612, Appendix E, Example 4.a., in that, there were several examples of the licensee failing to take corrective actions in response to findings, indicating that "The licensee routinely failed to perform engineering evaluations on similar issues." The team performed a Phase I SDP evaluation and determined that the violation was screened as being very low safety significance, Green, because all of the

answers to the Phase I Worksheet Mitigating Systems Column were "no." The team also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed to implement timely or effective corrective actions. (P.1(d)).

Enforcement. The main annunciator system and its feeds are not safety-related, and therefore this performance deficiency is not a violation of NRC requirements. This

finding was placed in the corrective action system as CR 2008-000778. Finding 05000482/2008006-06, Failure to take timely corrective actions to correct annunciator feed deficiencies.

- 22 - Enclosure 4OA6 Management Meetings

On February 29, 2008, an exit meeting was conducted on the last day of the onsite inspection. The tentative results of the inspection were discussed with Mr. R. Muench and other members of the staff. The licensee confirmed that no proprietary information

was handled during this inspection.

On April 22, 2008, a telephonic re-exit was conducted with Mr. W. Muilenburg to discuss the final categorization of six issues and cross-cutting aspects of the findings.

ATTACHMENTS: 1. Supplemental Information 2. Information request

A1-1 Attachment 1

ATTACHMENT 1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Erbe, Manager, Security R. Flannigan, Manager, Regulatory Affairs

S. Henry, Manager, Operations D. Hooper, Supervisor, Licensing T. Krause, Manager, Quality R. Muench, President and CEO W. Muilenburg, Licensing E. Peterson, Ombudsman L. Ratzlaff, Manager, Support

E. Ray, Manager, Chemistry A. Stull, Vice President and Chief Administrative Manager M. Sunseri, Vice President Operations and Plant Manager J. Yunk, Manager, Human Resources

NRC Personnel

D. Proulx, Team Leader, Senior Reactor Inspector S. Cochrum, Senior Resident Inspector C. Long, Resident Inspector

H. Abuseini, Reactor Inspector J. Adams, Reactor Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000482/2008006-01 NCV Twenty-One Examples of Failure to Follow Seismic Requirements of

Scaffolding Procedure (Section 4OA2.e (1))05000482/2008006-02 FIN Failure to Take Corrective Action For Missed Compensatory Measures (Section 4OA2.e (2))05000482/2008006-03 NCV Failure to Take Corrective Actions For Missed Operability Evaluation (Section 4OA2.e (3))

A1-2 Attachment 1 05000482/2008006-04 NCV Failure to Take Timely Corrective Action To Establish Monitoring Frequency Of AFW Pump Governor Null Set Drift (Section 4OA2.e (4))05000482/2008006-05 NCV Failure to Take Timely Corrective Action to Correct Barton Transmitter Defects (Section 4OA2.e (5))05000482/2008006-06 FIN Failure to Take Timely Corrective Action to Correct Annunciator Feed Configuration Deficiencies (Section 4OA2.e (6))

LIST OF DOCUMENTS REVIEWED

Procedures

AI 28A-001, "Root Cause Analysis," Revision 5 AI 28A-005, "Common Cause Analysis," Revision 0

AI 28E-007, "PIR Trending and Analysis," Revision 4A AI 28A-006 'Apparent Cause Evaluations" Rev.3 AP 14A-003, "Scaffold Construction and Use," Revision 14 AP 26C-004, "Technical Specification Operability," Revision 16 AP 28A-100, "Condition Reports," Revision 4.

AP 20E-001, "Industry Operating Experience Program," Revision 9. AP 28-011, "Resolving Deficiencies Impacting SSC's," Revision 1A. AP 16C-006, "MPAC Work Request Work Order Process Controls," Revision 11A. AP 22C-002, "Work Controls," Revision 16 AP 28-007, "Nonconformance Control," Revision 4

AP 28-001, "Operability Evaluations," Revision 15 OFN AF-025, "Unit Limitations," Revision 26 ALR 00-103E, "Heater Drn Tk Dump," Revision 11A ALR 00-120B, "MVP A Suct Press Lo," Revision 10 ALR 00-110B, "SG C Lev Dev," Revision 6

SYS AF-121, "Heater Drain Pump Operation," Revision 12 STS AL-103, "TDAFW Inservice Pump Test," Revision 43

Drawings: E-1146, "Wiring Diagram Surge Tank Control Panel 1ST01J," Rev.12 E-1005-ST06, "Schematic Diagram Surge Tank Control Panel," Rev.12

E-1005-ST01, "Schematic Rate (DR) Filter No.1 Control Panel (1ST01F)," Rev.7 E-1005-ST02, "Schematic Diagram Design Rate (DR) Filter No.2 Control Panel (1

ST02F)," Rev.7 E-1005-ST03, "Schematic Diagram Lift Station No.1 (1ST01S)," Rev.8 E-1005-ST05, "Schematic Diagram Sewage Treatment Plant Control Panel (IST02J)," Rev.6

A1-3 Attachment 1 E-1449, "External Wiring Diagram Annunciator Input/Output Cabinet RK0445C4," Rev.10 E-1442, "External Wiring Diagram Main Control Board RL013-14 PT.2," Rev. J

Reports

0102-2007, "Vibration Analysis Report: DPEM01B/Safety Injection Pump Motor, June 15, 2007 0103-2007, "Vibration Analysis Report: CGG02B/FB Emergency Exhaust Fan, July 3, 2007

Calculation

XX-C-018, "Evaluation of Seismically Qualified Scaffolding," Revision 01

Operational Experience Reports

10 CFR Part 21 Report 2006-10-00 concerning Weld Repairs on Sulzer Pumps dated September 21, 2006

10 CFR Part 21 Report concerning 3" and 4" Borg Warner Check Valves, dated May 17, 2007

10 CFR Part 21 Report concerning Rosemount Nuclear Instruments, dated April 6, 2007

NRC Information Notice 2006-05 Evaluation, "POSSIBLE DEFECT IN BUSSMANN KWN-R

AND KTN-R FUSES"

NRC Information Notice 2006-06 Evaluation, "LOSS OF OFFSITE POWER AND STATION BLACKOUT ARE MORE PROBABLE DURING SUMMER PERIOD"

NRC Information Notice 2006-08 Evaluation, "SECONDARY PIPING RUPTURE AT THE MIHAMA POWER STATION IN JAPAN"

NRC Information Notice 2006-09 Evaluation, "PERFORMANCE OF NRC-LICENSED INDIVIDUALS WHILE ON DUTY WITH RESPECT TO CONTROL ROOM ATTENTIVENESS"

NRC Information Notice 2007-01, "Recent Operating Experience Concerning Hydrostatic Barriers"

NRC Information Notice 2007-29, "Temporary Scaffolding Affects Operability of Safety-Related

Equipment"

Westinghouse NSAL-07-02, "Revised Seismic Level for Type A200 Size 1 and Size 2 Motor Starters and Contactors," dated July 25, 2007

ASCO Safety Notice, "Potential manufacturing non-conformance of plunger tubes used in certain ASCO NH series hydrometer pumps and kits," dated September 18, 2006

NRC Regulatory Issue Summary 2007-21, "Adherence to Licensed Power Limits"

A1-4 Attachment 1 Self Assessments and Audits

Auxiliary Feedwater System Health Report February 2007 Corrective Action Program Health Index March 2007 Corrective Action Program Health Index

May 2007 Corrective Action Program Health Index June 2007 Corrective Action Program Health Index November 2007 Corrective Action Program Health Index Audit Report K-643, "Corrective Action," dated May 26, 2007 Safety Conscious Work Environment Self-Assessment, dated December 21, 2007

Nuclear Industry Evaluation Program (NIEP) of Wolf Creek Generating Station's Quality Organization, dated August 22, 2008

Miscellaneous

USAR Section 3.7B, "Seismic Design" USAR Section 9.4.3, "Auxiliary Building"

Operability Evaluation, XX-06-003, Revision 1

Work Orders

05-274442-000

05-274442-001 05-274442-002 07-294638-000 04-267785-011 07-297313-000 07-292004-000 06-290862-000 06-289721-000 08-302410-000 07-301313-000 07-300768-003 07-300768-006 06-290525-001 06-289589-000 08-302131-001 07-300862-000 05-279097-000 06-286540-000 06-286541-000 06-289735-000 06-289736-000 06-285693-000 06-289831-000 07-062648-000 07-061866-000

Condition Reports

2008-000118

2008-000383 2008-000341 2006-000761 2006-000441 2006-000815

2006-003154 2005-002149 2004-001224 2006-000674 2006-000646 2005-001648 2005-001722

2006-000753 2003-000969 2004-002613 2006-000648 2006-000058 2005-002241 2006-000366 2004-002685 2004-002684 2006-000007

2006-000023 2006-000056 2006-000068 2006-000128 2006-000138 2006-000145 2006-000162

2006-000165 2006-000167 2006-000218 2006-000318 2006-000325 2006-000375 2006-000377 2006-000385 2006-000456 2006-000603

2006-000703 2006-000757 2006-000761 2006-000786 2006-000803 2006-001046 2005-002844

2006-001127 2006-001709 2006-001724 2006-001754 2006-001838 2006-001866 2006-001906 2006-002527 2006-003055 2006-003088

2006-003105 2007-000221 2007-000826 2007-000879 2007-001002 2007-001189 2007-001626

2007-002753 2007-002411 2007-001692 2007-002477 2007-002662 2007-003088 2007-003759 2007-002753 2007-000362 2007-001352

2007-002411 2005-002770 2007-002742 2007-002742 2007-002580 2007-004700 2005-002241

2005-001490 2005-001843 2005-001968 2005-001981

A1-5 Attachment 1 2005-003322 2006-000298 2006-000348 2006-000648 2006-000757

2006-000815 2006-000895 2006-000938 2006-001376 2006-001499

2006-002030 2007-000280 2007-000368 2007-000543 2007-000589 2007-001352 2007-002742

2007-003039 2007-003124 2007-003416 2007-003613 2007-002339

2007-002291 2007-002597 2006-000808 2006-000806 2007-002599 2007-002492 2007-000597

2007-002601 2007-000206 2006-000390 2006-000043 2006-000080

2006-000269 2006-000057 2006-000060 2006-000072 2006-000075 2006-000819 2006-000156

2006-000203 2006-000241 2006-000295 2005-000322 2007-004733

2008-000155 2006-000477 2006-003721 2007-004744 2007-002974 2007-004702 2007-004674

2007-003704 2007-004657 2007-004629 2007-004608 2007-004606

2007-004601 2006-002066 2006-002159 2007-004576 2007-004389 2007-003896 2007-003293

2007-001497 2007-000930 2006-000267 2006-000327 2006-000938

2007-004643 2006-002321 2007-000004 2007-000302 2006-000360 2006-000361 2006-000434

2006-001663 2006-000560 2006-000139 2006-000551 2006-002468

2006-000589 2006-000483 2005-000257 2007-003759 2007-003345 2007-003037 2007-003003

2007-003000 2007-002966 2005-003275 2007-002790 2007-003295

2007-000661 2007-000941 2007-000298 2005-000824 2006-002668 2006-000448 2006-002385

2007-001805 2007-002028 2007-002042 2007-002082 2007-002287

2007-002740 2007-002781 2007-002929 2007-002952 2007-003007 2007-003009 2007-003128

2007-003130 2007-003347 2007-003542 2007-003649 2007-003669 2007-003671

Scaffolding Requests

08-S0039 08-S0044 08-S0036 08-S0031

08-S0009 07-S0146 07-S0140 08-S0013 06-S0080 07-S0151

07-S0030 08-S0066 07-S0153 06-S6014 06-S6677 06-S6681

07-S0135 04-S9002 04-S0067 00-S0109 04-S0008 04-S0073

00-S0096 07-S0144 06-S0079 04-S9010 04-S0076 00-S0111

03-S0155

A2-1 Attachment 2 ATTACHMENT 2

INFORMATION REQUEST

Information Request December 19, 2007 Wolf Creek Problem Identification and Resolution Inspection IP 71152; Inspection Report 05000482/2008-006

The inspection will cover the period of January 1, 2006 and December 15, 2007. All requested

information should be limited to this period unless otherwise specified. The information may be provided in either electronic or paper media or a combination of these. Information provided in electronic media may be in the form of e-mail attachment(s), CDs, thumb drives, 3 1/2 inch floppy disks, or posted on the Certrec website. The agency has document viewing capability for MS Word, Excel, Power Point, and Adobe Acrobat (.pdf) text files.

Please provide the following information to David Proulx by December 28, 2007:

Note: On summary lists please include a description of problem, status, initiating date, and owner organization. Summary list of all condition reports of significant conditions adverse to quality opened or closed during the period

1. Summary list of all condition reports which were generated during the period

2. A list of all corrective action documents that subsume or "roll-up" one or more smaller issues for the period

3. Summary list of all condition reports which were down-graded or up-graded in significance during the period

4. List of all root cause analyses completed during the period

5. List of root cause analyses planned, but not complete at end of the period

6. List of all apparent cause analyses completed during the period

7. List of plant safety issues raised or addressed by the employee concerns program during the period

8. List of action items generated or addressed by the plant safety review committees during the period

9. All quality assurance audits and surveillances of corrective action activities completed during the period

10. A list of all quality assurance audits and surveillances scheduled for completion during the period, but which were not completed

A2-2 Attachment 2 11. All corrective action activity reports, functional area self-assessments, and non-NRC third party assessments completed during the period

12. Corrective action performance trending/tracking information generated during the period and broken down by functional organization

13. Current revisions of corrective action program procedures

14. A listing of all external events evaluated for applicability at Wolf Creek during the period

15. Action requests or other actions generated for each of the items below:

I. A. Part 21 Reports:

B. NRC Information Notices:

C. All LERs issued by Wolf Creek during the period

D. NCVs and Violations issued to Wolf Creek during the period (including licensee identified violations)

I. Safeguards event logs for the period.

II. Radiation protection event logs.

III. Current system health reports or similar information.

IV. Current system health reports or similar information for the Auxiliary Feedwater (AFW) system. V. Current predictive performance summary reports or similar information for the AFW system. VI. Summary list of all Condition Reports generated for the AFW systems for the past 5 years. VII. Corrective action effectiveness review reports generated during the period.

VIII. List of risk significant components and systems (in descending order of importance).