ML14063A628

Annual Assessment Letter for Wolf Creek Generating Station (Report 05000482/2013001)

ML14063A628
Person / Time
Site:	Wolf Creek
Issue date:	03/04/2014
From:	Dapas M L Region 4 Administrator
To:	Heflin A C Wolf Creek
O'Keefe N F
References
IR-13-001
Download: ML14063A628 (6)

See also: IR 05000482/2013001

Text

March 4, 2014

Mr. Adam C. Heflin, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

SUBJECT: ANNUAL ASSESSMENT LETTER FOR WOLF CREEK GENERATING STATION (REPORT 05000482/2013001)

Dear Mr. Heflin:

On February 12, 2014, the NRC completed its end-of-cycle performance review of Wolf Creek Generating Station. The NRC reviewed the most recent quarterly performance indicators (PIs) in addition to inspection results and enforcement actions from January 1, 2013, through December 31, 2013. This letter informs you of the NRC's assessment of Wolf Creek Generating Station during this period and its plans for future inspections at that facility. The NRC determined that overall, Wolf Creek Generating Station was operated in a manner that preserved public health and safety and met all cornerstone objectives. The NRC determined the performance at Wolf Creek Generating Station during the most recent quarter was within the Licensee Response Column of the NRC's Reactor Oversight Process (ROP) Action Matrix because all inspection findings had very low (i.e., Green) safety significance, and all PIs indicated that plant performance was within the nominal, expected range (i.e., Green). Therefore, the NRC plans to conduct ROP baseline inspections at your facility. Although plant performance was within the Licensee Response Column, the NRC has not yet finalized the significance of a preliminary Greater-than-Green finding in the physical security cornerstone documented in NRC Inspection Report 05000482/2013403 (ML13346A227). The final safety significance determination may affect the NRC's assessment of plant performance and the enclosed inspection plan. You will be notified by separate correspondence of the final significance for this finding, as well as any changes to our performance assessment and associated inspection plan. At the beginning of this assessment cycle, Wolf Creek Generating Station was in the Degraded Cornerstone Column because there was one Yellow finding and one White performance indicator in the Mitigating Systems Cornerstone. The Yellow finding involved your staff's failure to provide adequate oversight of contractors while they performed work that could affect safety- related equipment in April 2011. The performance indicator for Mitigating Systems Performance Index - Emergency AC System (MSPI - EAC) had been reported as White since the first quarter of 2012. On June 7, 2013, the NRC completed a supplemental inspection pursuant to Inspection Procedure 95002, "Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area," at Wolf Creek Generating Station. This A.Heflin - 2 - inspection was performed to assess your staff's evaluation of the root causes, contributing causes, and corrective actions associated with the Yellow finding, and included an assessment of actions to address four open substantive cross-cutting issues. The team also performed a limited scope independent safety culture assessment follow-up in accordance with Inspection Procedure 40100, "Independent Safety Culture Assessment Follow-up." The inspectors determined that your staff performed a comprehensive evaluation to identify appropriate causes for the Yellow finding, and corrective actions were appropriate to address those causes. Based on the results of this inspection, the Yellow finding was closed in NRC Inspection Report 05000482/2013010 (ML13203A329). On April 29, 2013, the NRC completed the supplemental inspection to review the action taken to address the White MSPI - EAC, pursuant to Inspection Procedure 95001, "Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area." As documented in NRC Inspection Report 05000482/2013009 (ML13126A197), this inspection was performed to assess your staff's evaluation of the root causes, contributing causes, and corrective actions associated with the White PI. The PI data reported for Wolf Creek Generating Station for the second quarter of 2013 indicated that MSPI - EAC had returned to Green. Therefore, since four quarters had passed since the White PI was identified; the NRC had concluded based on the 95001 supplemental inspection results, that you had adequately evaluated and addressed the performance issues; and given that the PI had returned to Green as of June 30, 2013, Wolf Creek Generating Station was returned to the Licensee Response column as of July 1, 2013. The NRC also issued a Chilling Effect Letter (CEL) (ADAMS ML13233A208) to Wolf Creek Nuclear Operating Corporation on August 19, 2013. The CEL was issued because the Occupational Safety and Health Administration (OSHA) had issued a finding of discrimination for raising safety concerns against a former employee of an engineering contractor employed by Wolf Creek Nuclear Operating Corporation, and due to the NRC identifying that a chilled work environment existed within your facility's Quality Assurance Group. Issuance of a CEL meets the NRC criteria in Inspection Manual Chapter (IMC) 0305, "Operating Reactor Assessment Program," for the identification of a cross-cutting theme in the area of safety conscious work environment (SCWE). However, the NRC has assessed your 30-day and 6-month responses to the CEL, and conducted a public meeting in the Region IV office on January 22, 2014, to discuss the actions that you are taking to address the working environment at your facility. The NRC has decided not to open a substantive cross-cutting issue in the area of SCWE at this time because the NRC staff does not have a concern with your actions. This theme will continue to be reviewed during the next two performance assessments as we continue to monitor your staff's actions to ensure Wolf Creek Generating Station is a workplace that fosters an environment where employees feel free, and are encouraged, to raise safety concerns. The enclosed inspection plan lists the inspections scheduled through June 30, 2015. Routine inspections performed by resident inspectors are not included in the inspection plan. The inspections scheduled to be conducted during the last nine months are tentative and may be revised based on the results of the mid-cycle performance review. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact your staff as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. This inspection plan does not include security related inspections, which will be sent via separate, non-publicly available correspondence.

A.Heflin - 3 - An NRC audit of licensee efforts towards compliance with Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," is ongoing. This audit includes an onsite component in order for the NRC to evaluate mitigating strategies as described in licensee submittals, and to receive and review information relative to associated open items. This onsite activity will aid the NRC staff in development of an ultimate Safety Evaluation for the site. The NRC staff will be working with your staff to establish a date for the onsite component audit. A site-specific audit plan for the visit will be provided in advance to allow sufficient time for preparations. As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised effective January 1, 2014. New cross-cutting aspects will be coded in accordance with the latest revision to NRC Inspection Manual Chapter (IMC) 0310, "Aspects within Cross-Cutting Areas", dated December 19, 2013. Cross-cutting aspects identified in the last six months of 2013 using the previous terminology will be converted to the revised language in accordance with the cross-reference in IMC 0310. The revised cross- cutting aspects will be evaluated for cross-cutting themes and potential substantive cross- cutting issues in accordance with IMC 0305 starting with the calendar year 2014 mid-cycle assessment. In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter will be 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). Please contact Neil O'Keefe at 817-200-1141 with any questions you or your staff may have regarding this letter.

Sincerely,/RA/ Marc L. Dapas, Regional Administrator Docket No. 50-482 License No. NPF-42

Enclosure:

Inspection Plan A.Heflin - 4 -

R:\_REACTORS\EOC 2013\WC2013 EOC LTR NFO 140304.docx ML14063A628 ADAMS: No Yes SUNSI Review Complete Reviewer Initials: NFO Publicly Available Non-Sensitive Non-publicly Available Sensitive DRP B/BC DRS/DIR DRP/DIR RA NO'Keefe JClark KKennedy MDapas /RA/ /RA/ /RA/ /RA/ 02/26/2014 02/28/2014 02/28/2014 03/03/2014 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax WolfCreek Inspection I Activity Plan 03/01/2014 - 06/30/2015 Page 1 of 2 02/27/2014 Report22 13:10:28 This report shows only on-site and announced inspection procedures. Enclosure RS 12 PI - RADIATION SAFETY Title 2 03/17/2014 03/21/2014 03/17/2014 03/21/2014 IP 71124.01 IP 71124.02 RadiologicalHazard Assessment and Exposure Controls Occupational ALARA Planning and Controls 03/17/2014 03/21/2014 03/17/2014 03/21/2014 IP 71151-0R01 Occupational Exposure Control Effectiveness IP 71151-PR01 RETS/ODCM Radiological Effluent TSB 52B - BIENNIAL PI&R 4 05/19/2014 05/23/2014 IP 71152B Problem Identification and Resolution 06/02/2014 06/06/2014 IP 711528 Problem Identification and Resolution RS 5678 - RADIATION SAFETY- TEAM 4 06/02/2014 06/06/2014 06/02/2014 06/06/2014 06/02/2014 06/06/2014 06/02/2014 06/06/2014 IP '11124.05 IP 71124.06 IP 71124.0'1 IP 71124.08 INSP Radiation Monitoring Instrumentation Radioactive Gaseous and Liquid Effluent Treatment Radiological Environmental Monitoring Program Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation - BIENNIAL REQUAL INSPECTION 3 08/25/2014 08/29/2014 10/20/2014 10/24/2014 11/03/2014 11/07/2014 IP 7111111B Licensed Operator Requalification Program EB2-05T - TRIENNIAL FIRE PROTECTION INSPECTION 4 IP 7111105T Fire Protection [Triennial] IP 7111105T Fire Protection [Triennial] EP-1 - EP PERFORMANCE INDICATORS 11/17/2014 11/1712014 11/17/2014 11/21/2014 11/21/2014 11/21/2014 IP 71151-EP01 IP 71151-EP02 IP 71151-EP03 Drill/Exercise Performance ERO Drill Participation Alert & Notification System EP-2 - EP PROGRAM INSPECTION 11/17/2014 11/1712014 11/17/2014 11/17/2014 11121/2014 11/21/2014 11/2112014 11121/2014 IP 7111402 IP 7111403 IP 7111404 IP 7111405 71111.08 Alert and Notification System Testing Emergency Preparedness Organization Staffing and Augmentation System Emergency Action Level and Emergency Plan Changes Correction of Emergency Preparedness Weaknesses and Deficiencies - INSERVICE INSPECTION 02/23/2015 03/06/2015 IP 7111108P lnservice Inspection Activities - PWR RS 13 PI - RADIATION SAFETY 2 03/09/2015 03/13/2015 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 03/09/2015 03/13/2015 IP '11124.03 In-Plant Airborne Radioactivity Control and Mitigation 03/09/2015 03/13/2015 IP '11151-0R01 Occupational Exposure Control Effectiveness rfhis report does not include INPO and OUTAGE adlvffles.

WolfCreek Inspection I Activity Plan 03/01/2014 - 06/30/2015 Page 2 of 2 02/27/2014 Report22 13:10:28 *This report shows only on-site and announced inspection procedures. Enclosure i Unit i Number Planned Dates Start End RS 13 PI -RADIATION SAFETY - --*L. Title No. of Staff on Site 2 03/09/2015 03/13/2015 IP 71151-PR01 RETS/ODCM Radiological Effluent EB1-17T - WC PERMANENT PLANT MODS & 50.59 06/15/2015 06/26/2015 IP 7111117T Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications

Ttiis report does not inClude INPO and OUTAGE activities.