ML092400145

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Midcycle Assessment
ML092400145
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 09/01/2009
From: Chamberlain D
NRC/RGN-IV/DRP
To: Muench R
Wolf Creek
References
Download: ML092400145 (7)


Text

UNITED STATES NU C LE AR RE G ULATO RY C O M M I S S I O N R E GI ON I V 612 EAST LAMAR BLVD , SU ITE 400 AR LIN GTON , TEXAS 76011-4125 September 1, 2009 Rick A. Muench, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

SUBJECT:

MIDCYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - WOLF CREEK GENERATING STATION

Dear Mr. Muench:

On August 4, 2009, the NRC staff completed its performance review of the Wolf Creek Generating Staion. Our technical staff reviewed performance indicators for the most recent quarter and inspection results for the period from July 1, 2008 through June 30, 2009. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as "Official Use Only -- Security Information" will include the security cornerstone review and resultant inspection plan.

Plant performance for the most recent quarter at the Wolf Creek Generating Station was within the Licensee Response column of the NRC=s Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all performance indicators indicating performance at a level requiring no additional NRC oversight (Green).

Our midcycle assessment letter dated September 2, 2008, identified a substantive crosscutting issue in the area of human performance associated with instances of failure to have complete, accurate, and up-to-date documentation, procedures, and/or work packages within the resources component H.2(c). The basis for identifying the substantive crosscutting issue was five findings, which composed a theme in this area. Our end-of-cycle assessment letter dated March 4, 2009, sustained this substantive crosscutting issue. During that assessment period, the number of findings increased to six findings related to the theme. During a public meeting with the NRC on October 21, 2008, you informed us that you had completed a root cause analysis of your human performance issues and provided details on your Human Performance Initiative Plan and your Maintenance Work Package Quality Initiative Plan, which you were using to address human performance issues. Additionally, during a public meeting with the NRC on July 1, 2009, you further informed us of additional initiatives taken as corrective actions in accordance with your improvement plan. We have observed a decrease in the number of human performance related findings which relate to having complete, accurate, and up-to-date documentation, procedures, and/or work packages H.2(c). During this assessment period, only two findings were identified with this common theme, none coming in the last half of the assessment period. As a result of your implemented corrective actions and in light of fewer human performance related findings with this common theme, this substantive crosscutting issue is closed.

Wolf Creek Nuclear Operating Corp. At the 2008 midcycle and end-of-cycle assessments, a theme for an inadequate threshold for identifying problems [P.1 (a)] was identified as part of a substantive crosscutting issue in problem identification and resolution. In our 2008 assessment letters, we stated that this theme would remain open until we determined that your corrective actions had been effective. During public meetings with the NRC on October 21, 2008, and July 1, 2009, you informed us that you had taken corrective action to improve your threshold for reporting issues. These corrective actions have resulted in an increase in the number of condition reports and work requests your staff has generated. We also noted this specific improvement by observing there was only one finding in the most recent end-of-cycle assessment and two findings in the current assessment related to the theme of failure to have an adequate threshold for identifying problems. Finally, we also have observed a declining trend in the number of NRC identified issues, from over 30 NRC identified findings in each of the previous two assessment periods to 18 in the current assessment period. Your corrective actions have shown an improving trend; therefore, this substantive crosscutting theme associated with a low enough threshold for identifying problems

[P.1 (a)] is closed.

At the 2008 midcycle and end-of-cycle assessments, a theme associated with the thoroughness of problem evaluation P.1(c) was also identified as part of a substantive crosscutting issue in problem identification and resolution based on seven and eight related findings, respectively. In both the 2008 midcycle and end-of-cycle assessment letters, we stated that this new substantive crosscutting issue would remain open until we determined that your corrective actions had been effective. During public meetings with the NRC on October 21, 2008, and July 1, 2009, you informed us that you had completed a root cause analysis for noted deficiencies related to problem identification and resolution. You also informed us that you had implemented significant changes in improving the quality of problem evaluation, including root cause evaluator training, conducting a management alignment seminar, and increasing management oversight of problem evaluation. We have noted through recent inspection efforts, including a focused baseline inspection of the residual heat removal system, that you have shown some improvement in this area; however, we did not observe sustained improvement over the entire assessment period. We continue to identify findings associated with this theme including four Green findings associated with this theme identified during this assessment period. Therefore, the substantive crosscutting theme associated with the thoroughness of problem evaluation

P.1(c) will remain open pending further demonstration of the effectiveness of your corrective actions.

Finally, at the 2008 midcycle and end-of-cycle assessments, a theme associated with the appropriateness of corrective actions [P.1 (d)] was also identified as part of a substantive crosscutting issue in problem identification and resolution based on seven and eight related findings, respectively. In both the 2008 midcycle and end-of-cycle assessment letter, we stated that this new substantive crosscutting issue would remain open until we determined that your corrective actions had been effective. During public meetings with the NRC on October 21, 2008 and July 1, 2009, you informed us that you had completed a root cause analysis for noted deficiencies related to problem identification and resolution and implemented corrective actions.

These actions appear to have been effective, since there were only two findings related to the theme of failing to employ effective corrective actions, with none coming in the last three quarters of the assessment period. Therefore, the substantive crosscutting theme associated with the appropriateness of corrective actions [P.1 (d)] is closed.

The substantive crosscutting issue in problem identification and resolution will remain open, based solely on a theme associated with the thoroughness of problem evaluation P.1(c). This

Wolf Creek Nuclear Operating Corp. substantive crosscutting issue will remain open until we determine, through our inspections, that corrective actions implemented in accordance with your improvement plan have resulted in improved performance in this area. Of note, this is the third consecutive assessment with a substantive crosscutting area in problem identification and resolution with this common theme.

NRC Manual Chapter 0305, Operating Reactor Assessment Program, states, that In the third consecutive assessment letter identifying the same substantive crosscutting issue with the same crosscutting aspect, the regional office would typically request that the licensee perform an assessment of safety culture. The regional office could conclude a safety culture assessment is not warranted if the licensee has made reasonable progress in addressing the issue but has not yet met the specific closure criteria for the issue. We note that, although you have not met our criteria for closing this crosscutting theme, you have made reasonable progress in addressing this issue. As such, we have concluded that a safety culture assessment is not warranted at this time. However, we do request that you schedule a public meeting to discuss your continued progress in addressing this area before our next end-of-cycle assessment. We are also evaluating potential changes to the inspection program in the radiation safety cornerstone. Consequently, some specific inspection procedures and the inspection schedule may be revised for 2010.

The enclosed inspection plan details the inspections, less those related to physical protection scheduled through December 31, 2010. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last nine months of the inspection plan are tentative and may be revised at the end-of-cycle review.

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

If circumstances arise which cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact me at 817-860-8141 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Dwight D. Chamberlain, Director Division of Reactor Projects Docket: 50-482 License: NPF-42

Wolf Creek Nuclear Operating Corp.

Enclosure:

Wolf Creek Inspection Activity Plan cc w/

Enclosure:

Vice President Operations/Plant Manager Attorney General Wolf Creek Nuclear Operating Corporation 120 S.W. 10th Avenue, 2nd Floor P.O. Box 411 Topeka, KS 66612-1597 Burlington, KS 66839 County Clerk Jay Silberg, Esq. Coffey County Courthouse Pillsbury Winthrop Shaw Pittman LLP 110 South 6th Street 2300 N Street, NW Burlington, KS 66839 Washington, DC 20037 Chief, Radiation and Asbestos Supervisor Licensing Control Section Wolf Creek Nuclear Operating Corporation Bureau of Air and Radiation P.O. Box 411 Kansas Department of Health and Burlington, KS 66839 Environment 1000 SW Jackson, Suite 310 Chief Engineer Topeka, KS 66612-1366 Utilities Division Kansas Corporation Commission Chief, Technological Hazards 1500 SW Arrowhead Road Branch Topeka, KS 66604-4027 FEMA, Region VII 9221 Ward Parkway Office of the Governor Suite 300 State of Kansas Kansas City, MO 64114-3372 Topeka, KS 66612-1590

Wolf Creek Nuclear Operating Corp. 5 Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.goV)

DRP Director (Roy.Caniano@nrc.gov)

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

Branch Chief, DRP (Vincent.Gaddy@nrc.gov)

Senior Project Engineer, DRP (Rick.Deese@nrc.gov)

Senior Resident Inspector (Chris.Long@nrc.gov)

Resident Inspector (Charles.Peabody@nrc.gov)

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

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

Regional State Liaison Officer (Bill.Maier@nrc.gov)

RA Secretary (Lucy.Owen@nrc.gov)

DRA Secretary (Judy.Kilcrease@nrc.gov)

Branch Chief, DRS/EB1 (Thomas.Farnholtz@nrc.gov)

Branch Chief, DRS/EB2 (Neil.OKeefe@nrc.gov)

Branch Chief, DRS/PSB1 (Michael.Shannon@nrc.gov)

Branch Chief, DRS/PSB2 (Greg.Werner@nrc.gov)

Branch Chief, DRS/OB (Ryan.Lantz@nrc.gov)

OEDO RIV Coordinator, Primary (Leigh.Trocine@nrc.gov)

OEDO, TRPS (Tamara.Bloomer@nrc.gov)

Deputy Director, DIRS, NRR (Frederick.Brown@nrc.gov)

Director, DORL, NRR (Joseph Giitter@nrc.gov)

Deputy Director, DORL, NRR (Timothy.McGinty@nrc.gov)

Chief, PLB IV, DORL, NRR (Thomas.Hiltz@nrc.gov)

NRR Project Manager (Balwant.Singal@nrc.gov)

RidsNrrDirslpab (Resource@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov) mortensengk@INPO.org ROP Reports File located: R:\EOC and Midcycle\Midcycle Assessment Letters\2009\WC.doc SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials VGG Publicly Avail Yes No Sensitive Yes No Sens. Type Initials VGG RIV:SPE/DRP/PBB C:DRP/PBB D:DRS D:DRP RWDeese VGGaddy RJCaniano DDChamberlain

/RA/ /RA/ /RA/ /RA/

8/18/09 8/19/09 8/20/09 8/24/09 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Wolf Creek Nuclear Operating Corp. 6 Page 1 of 2 Wolf Creek 08/17/2009 14:27:55 Inspection / Activity Plan Report 22 09/01/2009 - 12/31/2010 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site EXAM - INITIAL EXAM 3 1 08/31/2009 09/04/2009 X02419 INITIAL EXAM-WC (8/2009)

EB1-08 - INSERVICE INSPECTION 3 1 10/10/2009 10/30/2009 IP 2515/172 Reactor Coolant System Dissimiliar Metal Butt Welds 1 10/10/2009 10/30/2009 IP 7111108P Inservice Inspection Activities - PWR RP-ORS3 - OCCUPATIONAL RADIATION SAFETY - ALARA 1 1 10/19/2009 10/23/2009 IP 7112101 Access Control to Radiologically Significant Areas 1 10/19/2009 10/23/2009 IP 7112102 ALARA Planning and Controls 1 10/19/2009 10/23/2009 IP 71151 Performance Indicator Verification RP-ORS4 - OCCUPATIONAL RADIATION SAFETY - ACCESS 1 1 10/19/2009 10/23/2009 IP 7112101 Access Control to Radiologically Significant Areas 1 10/19/2009 10/23/2009 IP 7112102 ALARA Planning and Controls 1 10/19/2009 10/23/2009 IP 71151 Performance Indicator Verification RP-ORS1 - OCCUPATIONAL RADIATION SAFETY - ALARA 1 1 03/15/2010 03/19/2010 IP 7112101 Access Control to Radiologically Significant Areas 1 03/15/2010 03/19/2010 IP 7112102 ALARA Planning and Controls 1 03/15/2010 03/19/2010 IP 71151-OR01 Occupational Exposure Control Effectiveness 1 03/15/2010 03/19/2010 IP 71151-PR01 RETS/ODCM Radiological Effluent EP-1 - BIENNIAL EP PROGRAM INSPECTION 1 1 04/12/2010 04/16/2010 IP 7111402 Alert and Notification System Testing 1 04/12/2010 04/16/2010 IP 7111403 Emergency Response Organization Augmentation Testing 1 04/12/2010 04/16/2010 IP 7111404 Emergency Action Level and Emergency Plan Changes 1 04/12/2010 04/16/2010 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 1 04/12/2010 04/16/2010 IP 71151-EP01 Drill/Exercise Performance 1 04/12/2010 04/16/2010 IP 71151-EP02 ERO Drill Participation 1 04/12/2010 04/16/2010 IP 71151-EP03 Alert & Notification System RP-ORS1 - OCCUPATIONAL RADIATION SAFETY-ACRSA 1 1 05/10/2010 05/14/2010 IP 7112101 Access Control to Radiologically Significant Areas 1 05/10/2010 05/14/2010 IP 7112102 ALARA Planning and Controls 1 05/10/2010 05/14/2010 IP 71151 Performance Indicator Verification PSB2-52B - BIENNIAL PI&R 4 1 07/12/2010 07/16/2010 IP 71152B Identification and Resolution of Problems 1 07/26/2010 07/30/2010 IP 71152B Identification and Resolution of Problems EB1-21 - COMPONENT DESIGN BASIS INSPECTION 6 1 09/07/2010 09/10/2010 IP 7111121 Component Design Bases Inspection This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 Wolf Creek 08/17/2009 14:27:55 Inspection / Activity Plan Report 22 09/01/2009 - 12/31/2010 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site EB1-21 - COMPONENT DESIGN BASIS INSPECTION 6 1 09/20/2010 10/01/2010 IP 7111121 Component Design Bases Inspection BRQ - OPERATOR REQUAL INSP 2 1 10/04/2010 10/08/2010 IP 7111111B Licensed Operator Requalification Program RP TEAM - RADIATION SAFETY TEAM INSPECTION 4 1 10/18/2010 10/22/2010 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 1 10/18/2010 10/22/2010 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 1 10/18/2010 10/22/2010 IP 7112202 Radioactive Material Processing and Transportation 1 10/18/2010 10/22/2010 IP 7112203 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 1 10/18/2010 10/22/2010 IP 7113011 Material Control and Accounting (MC&A)

EB2-07T - TRIENNIAL HEAT SINK PERFORMANCE 1 1 10/25/2010 10/29/2010 IP 7111107T Heat Sink Performance EXAM - INITIAL EXAM 4 1 11/08/2010 11/12/2010 X02451 INITIAL EXAM -WC (11/2010) 1 12/06/2010 12/17/2010 X02451 INITIAL EXAM -WC (11/2010)

This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.