ML081350176
| ML081350176 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/14/2008 |
| From: | Laura Smith NRC/RGN-IV/DRS/EB2 |
| To: | Muench R Wolf Creek |
| References | |
| IR-08-006 | |
| Download: ML081350176 (32) | |
See also: IR 05000482/2008006
Text
UNITED STATES
NUC LE AR RE G ULATO RY CO M M I S S I O N
R E GI ON I V
612 EAST LAMAR BLVD , SU I TE 400
AR LIN GTON , TEXAS 76011-4125
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 NRCs 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
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 NRCs
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 Office of the Governor
Wolf Creek Nuclear Operating Corp. State of Kansas
P.O. Box 411 Topeka, KS 66612
Burlington, KS 66839
Attorney General
Jay Silberg, Esq. 120 S.W. 10th Avenue, 2nd Floor
Pillsbury Winthrop Shaw Pittman LLP Topeka, KS 66612-1597
2300 N Street, NW
Washington, DC 20037 County Clerk
Coffey County Courthouse
Supervisor Licensing 110 South 6th Street
Wolf Creek Nuclear Operating Corp. Burlington, KS 66839-1798
P.O. Box 411
Burlington, KS 66839 Chief, Radiation and Asbestos
Control Section
Chief Engineer Kansas Department of Health and
Utilities Division Environment
Kansas Corporation Commission Bureau of Air and Radiation
1500 SW Arrowhead Road 1000 SW Jackson, Suite 310
Topeka, KS 66604-4027 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)
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
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
-1- 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) programs 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.
-2- 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
-3- 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-
-4- 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 SSCs, 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.
-5- 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
-6- 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 licensees threshold for identifying problems, entering them into the corrective action
program, and the ability to evaluate the importance of adverse conditions. Also, the
licensees 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 licensees 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.
-7- 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 licensees 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
(b) Assessment - Effectiveness of Prioritization and Evaluation of Issues
The team assessed the licensees 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
- 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).
-8- 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)
- 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
-9- 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)).
- 10 - 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).
- 11 - 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.
- 12 - 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) programs 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.
- 13 - 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 engineers 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 Regulations 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
- 14 - 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 licensees 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.
- 15 - 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
- 16 - 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 licensees 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
- 17 - 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 licensees 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
- 18 - 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.
- 19 - 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 SSCs, 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 licensees 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.
- 20 - 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.
- 21 - 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
- 22 - Enclosure
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))
A1-1 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 SSCs, 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 (1ST02F), 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
A1-2 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
A1-3 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
Stations 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 07-292004-000 07-300768-006 06-286540-000 07-062648-000
05-274442-001 06-290862-000 06-290525-001 06-286541-000 07-061866-000
05-274442-002 06-289721-000 06-289589-000 06-289735-000
07-294638-000 08-302410-000 08-302131-001 06-289736-000
04-267785-011 07-301313-000 07-300862-000 06-285693-000
07-297313-000 07-300768-003 05-279097-000 06-289831-000
Condition Reports
2008-000118 2006-000058 2006-000325 2006-001838 2007-002662
2008-000383 2005-002241 2006-000375 2006-001866 2007-003088
2008-000341 2006-000366 2006-000377 2006-001906 2007-003759
2006-000761 2004-002685 2006-000385 2006-002527 2007-002753
2006-000441 2004-002684 2006-000456 2006-003055 2007-000362
2006-000815 2006-000007 2006-000603 2006-003088 2007-001352
2006-003154 2006-000023 2006-000703 2006-003105 2007-002411
2005-002149 2006-000056 2006-000757 2007-000221 2005-002770
2004-001224 2006-000068 2006-000761 2007-000826 2007-002742
2006-000674 2006-000128 2006-000786 2007-000879 2007-002742
2006-000646 2006-000138 2006-000803 2007-001002 2007-002580
2005-001648 2006-000145 2006-001046 2007-001189 2007-004700
2005-001722 2006-000162 2005-002844 2007-001626 2005-002241
2006-000753 2006-000165 2006-001127 2007-002753 2005-001490
2003-000969 2006-000167 2006-001709 2007-002411 2005-001843
2004-002613 2006-000218 2006-001724 2007-001692 2005-001968
2006-000648 2006-000318 2006-001754 2007-002477 2005-001981
A1-4 Attachment 1
2005-003322 2006-000808 2006-003721 2007-000004 2007-000298
2006-000298 2006-000806 2007-004744 2007-000302 2005-000824
2006-000348 2007-002599 2007-002974 2006-000360 2006-002668
2006-000648 2007-002492 2007-004702 2006-000361 2006-000448
2006-000757 2007-000597 2007-004674 2006-000434 2006-002385
2006-000815 2007-002601 2007-003704 2006-001663 2007-001805
2006-000895 2007-000206 2007-004657 2006-000560 2007-002028
2006-000938 2006-000390 2007-004629 2006-000139 2007-002042
2006-001376 2006-000043 2007-004608 2006-000551 2007-002082
2006-001499 2006-000080 2007-004606 2006-002468 2007-002287
2006-002030 2006-000269 2007-004601 2006-000589 2007-002740
2007-000280 2006-000057 2006-002066 2006-000483 2007-002781
2007-000368 2006-000060 2006-002159 2005-000257 2007-002929
2007-000543 2006-000072 2007-004576 2007-003759 2007-002952
2007-000589 2006-000075 2007-004389 2007-003345 2007-003007
2007-001352 2006-000819 2007-003896 2007-003037 2007-003009
2007-002742 2006-000156 2007-003293 2007-003003 2007-003128
2007-003039 2006-000203 2007-001497 2007-003000 2007-003130
2007-003124 2006-000241 2007-000930 2007-002966 2007-003347
2007-003416 2006-000295 2006-000267 2005-003275 2007-003542
2007-003613 2005-000322 2006-000327 2007-002790 2007-003649
2007-002339 2007-004733 2006-000938 2007-003295 2007-003669
2007-002291 2008-000155 2007-004643 2007-000661 2007-003671
2007-002597 2006-000477 2006-002321 2007-000941
Scaffolding Requests
08-S0039 07-S0140 07-S0153 04-S0067 06-S0079
08-S0044 08-S0013 06-S6014 00-S0109 04-S9010
08-S0036 06-S0080 06-S6677 04-S0008 04-S0076
08-S0031 07-S0151 06-S6681 04-S0073 00-S0111
08-S0009 07-S0030 07-S0135 00-S0096 03-S0155
07-S0146 08-S0066 04-S9002 07-S0144
A1-5 Attachment 1
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
A2-1 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).
A2-2 Attachment 2