ML19092A335
| ML19092A335 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/02/2019 |
| From: | Anton Vegel NRC/RGN-IV/DRP |
| To: | Heflin A Wolf Creek |
| References | |
| 4-2018-008, EA-18-165 IR 2019010 | |
| Download: ML19092A335 (10) | |
See also: IR 05000482/2019010
Text
April 2, 2019
Adam C. Heflin, President and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, KS 66839
SUBJECT: WOLF CREEK GENERATING STATION - NRC INSPECTION
REPORT 05000482/2019010 AND NRC INVESTIGATION REPORT 4-2018-008
Dear Mr. Heflin:
This letter refers to the investigation completed on November 13, 2018, by the U.S. Nuclear
Regulatory Commission (NRC) Office of Investigations (OI) at the Wolf Creek Generating
Station (Wolf Creek). The investigation was conducted, in part, to determine whether a
maintenance worker and a supervisor at Wolf Creek willfully documented inaccurate information
in a required record regarding the cleaning and inspection of control rod drive mechanisms on
October 31, 2016. Enclosure 1 provides a factual summary of the basis for the NRCs concern
that willfulness was associated with the apparent violation in this case. This issue was
discussed with Mr. Jaime McCoy, Site Vice President, and other members of your staff, during a
telephonic exit on March 26, 2019.
Based on the information acquired during the investigation, one apparent violation was identified
and is being considered for escalated enforcement action in accordance with the NRC
Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The apparent violation is
against Title 10 of the Code of Federal Regulations (10 CFR) Section 50.9, which requires, in
part, information required by the Commissions regulations, orders, or license conditions to be
maintained by the licensee shall be complete and accurate in all material respects. Further
details regarding this apparent violation are documented in Enclosure 2 to this letter. The
circumstances surrounding the apparent willful violation, the potential significance of the issue,
and the need for lasting and effective corrective action were discussed with members of your
staff at the inspection exit meeting on March 26, 2019.
Before the NRC makes its enforcement decision, we are providing you an opportunity to:
(1) respond in writing to the apparent violation addressed in this inspection report within 30 days
of the date of this letter; (2) request a predecisional enforcement conference (PEC); or
(3) request alternative dispute resolution (ADR). If a PEC is held, the PEC will be closed to
public observation since information related to an OI report will be discussed and the report has
not been made public. If you decide to participate in a PEC or pursue ADR, please contact
Mr. Nicholas Taylor, Chief, Division of Reactor Projects, Branch B, at 817-200-1141,
A. Heflin 2
within 10 days of the date of this letter. A PEC should be held within 30 days and an ADR
session within 45 days of the date of this letter.
If you choose to provide a written response, it should be clearly marked as a Response to
Apparent Violation in NRC Inspection Report 05000482/2019010; EA-18-165 and should
include for the apparent violation: (1) the reason for the apparent violation or, if contested, the
basis for disputing the apparent violation; (2) the corrective steps that have been taken and the
results achieved; (3) the corrective steps that will be taken; and (4) the date when full
compliance will be achieved. Your response may reference or include previously docketed
correspondence if the correspondence adequately addresses the required response.
Additionally, your response should be sent to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy mailed to the
Director, Division of Reactor Projects, U.S. Nuclear Regulatory Commission, Region IV,
1600 E. Lamar Blvd., Arlington, TX 76011-4511, within 30 days of the date of this letter. If an
adequate response is not received within the time specified or an extension of time has not
been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a
PEC.
If you choose to request a PEC, the conference will afford you the opportunity to provide your
perspective on these matters and any other information that you believe the NRC should take
into consideration before making an enforcement decision. The decision to hold a PEC does
not mean that the NRC has determined that a violation has occurred or that enforcement action
will be taken. This conference would be conducted to obtain information to assist the NRC in
making an enforcement decision. The topics discussed during the conference may include
information to determine whether a violation occurred, information to determine the significance
of a violation, information related to the identification of a violation, and information related to
any corrective actions taken or planned.
In lieu of a PEC, you may also request ADR with the NRC in an attempt to resolve this issue.
Alternative dispute resolution is a general term encompassing various techniques for resolving
conflicts using a neutral third party. The technique that the NRC has decided to employ is
mediation. Mediation is a voluntary, informal process in which a trained neutral mediator works
with parties to help them reach resolution. If the parties agree to use ADR, they select a
mutually agreeable neutral mediator who has no stake in the outcome and no power to make
decisions. Mediation gives parties an opportunity to discuss issues, clear up
misunderstandings, be creative, find areas of agreement, and reach a final resolution of the
issues.
Additional information concerning the NRCs ADR program can be obtained at
http://www.nrc.gov/about-nrc/regulatory/enforcement/adr.html, as well as NRC brochure
NUREG/BR-0317, Enforcement Alternative Dispute Resolution Program, Revision 2
(Agencywide Documents Access and Management System (ADAMS) Accession
ML18122A101). The Institute on Conflict Resolution (ICR) at Cornell University has agreed to
facilitate the NRC's program as a neutral third party. Please contact ICR at 877-733-9415
within 10 days of the date of this letter if you are interested in pursuing resolution of this issue
through ADR.
In addition, please be advised that the number and characterization of the apparent violation
described in the Enclosure 2 may change as a result of further NRC review. You will be advised
by separate correspondence of the results of our deliberations on this matter.
A. Heflin 3
For administrative purposes, this letter and enclosures are issued as NRC Inspection
Report 05000482/2019010. The apparent violation will be issued as AV 05000482/2019010-01,
as described in Enclosure 2.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a
copy of this letter, its enclosures, and your responses, if you choose to provide them, will be
made available electronically for public inspection in the NRC Public Document Room or from
the NRCs ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html. To the extent possible, your response should not include any personal privacy
or proprietary information so that it can be made available to the public without redaction. You
should also be aware that all final NRC documents, including the final Office of Investigations
report, are official agency records and may be made available to the public under the Freedom
of Information Act, subject to redaction of certain information in accordance with the Freedom of
Information Act.
If you have any questions concerning this matter, please contact Mr. Nicholas Taylor of my staff
at 817-200-1141.
Sincerely,
/RA Michael C. Hay Acting for/
Anton Vegel, Director
Division of Reactor Projects
Docket No. 50-482
License No. NPF-42
Enclosures:
1. Factual Summary
2. Inspection Report 05000482/2019010
FACTUAL SUMMARY
OFFICE OF INVESTIGATIONS REPORT 4-2018-008
On November 22, 2017, the U.S. Nuclear Regulatory Commission Office of Investigations
initiated an investigation to determine whether a maintenance worker and a supervisor at
Wolf Creek Generating Station willfully documented inaccurate information in a required record
regarding the cleaning and inspection of control rod drive mechanisms (CRDMs) on October 31,
2016. The investigation was completed on November 13, 2018.
In September 2016, several CRDM components were coated with a layer of boric acid residue
as a result of a leak identified at the canopy seal weld on penetration 77 on the reactor vessel
head. The licensee initiated work orders to clean the boric acid off the affected structures,
systems, and components, including 15 of the most-affected CRDMs. Due to problems with
removal, three of the CRDMs (4, 35, and 53), that were planned to be cleaned, were not
removed from the head, inspected, and cleaned as planned.
The Office of Investigations interviewed the maintenance worker involved in the documentation
of the cleaning and inspection of the CRDMs. During the interview, the maintenance
worker admitted to falsifying the as found conditions for CRDMs 4, 35, and 53 in Work
Order 16-417262-015, Revision 1, Attachment B. Specifically, the maintenance worker testified
that he completed documentation of Step B.2 of the work order, which described the as found
condition of CRDMs 4, 35, and 53. The maintenance worker admitted that the CRDMs had not
been removed and that his as found descriptions were based on assumptions rather than
observations. The maintenance worker also testified that he understood his actions were wrong
and did not comply with the work procedure.
The Office of Investigations interviewed the supervisor involved in the documentation of the
cleaning and inspection of the CRDMs. During the interview, the supervisor testified he
completed the as left condition in Step B.3 of the Work Order 16-417262-015, Revision 1,
Attachment B and acknowledged that CRDMs 4, 35, and 53 were not removed for inspection
and cleaning. The supervisor testified that he assumed the CRDMs had been cleaned. The
supervisor stated that he should not have completed any paperwork unless he knew and could
verify the CRDMs were cleaned. The supervisor stated that he knew his conduct was wrong
and against the work procedure.
Based on the evidence, it appears that the maintenance worker and the supervisor deliberately
falsified information in the work order. This appears to have caused Wolf Creek Nuclear
Operating Corporation to be in violation of 10 CFR 50.9, Completeness and accuracy of
information.
Enclosure 1
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000482
License Numbers: NPF-42
Report Numbers: 05000482/2019010
Enterprise Identifier: I-2019-010-0054
Licensee: Wolf Creek Nuclear Operating Corporation
Facility: Wolf Creek Generating Station
Location: Burlington, Kansas
Inspection Dates: November 13, 2018, to February 28, 2019
Inspectors: D. Dodson, Senior Resident Inspector
F. Thomas, Resident Inspector
B. Tharakan, Senior Project Engineer
Approved By: Nicholas H. Taylor
Chief, Project Branch B
Division of Reactor Projects
Enclosure 2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an inspection at Wolf Creek Generating Station in accordance with
the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and
self-revealed findings, violations, and additional items are summarized in the table below.
List of Findings and Violations
Failure to Maintain Quality Records Complete and Accurate in All Material Respects
Cornerstone Significance Cross-cutting Inspection
Aspect Procedure
Not Apparent Violation Not 71152-
Applicable AV 05000482/2019010-01 Applicable Problem
Open Identification
EA-18-165 and
Resolution
The inspectors identified an apparent violation of 10 CFR 50.9, associated with the licensees
failure to ensure information required by the Commissions regulations is complete and
accurate in all material respects. Specifically, the licensee failed to maintain complete
information when documenting the as found condition of control rod drive mechanisms in
accordance with Work Order 16-417262-015; and following the cleaning of control rod drive
mechanisms the licensee failed to maintain accurate information when documenting that
cleaning of control rod drive mechanisms 4, 35, and 53 was performed and that the post-
cleaning inspection met the acceptance criteria.
2
INSPECTION SCOPE
The inspection was conducted using the appropriate portions of the inspection procedures (IPs)
in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/
reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were
declared complete when the IP requirements most appropriate to the inspection activity were
met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71152-Problem Identification and Resolution
INSPECTION RESULTS
Failure to Maintain Quality Records Complete and Accurate in All Material Respects
Cornerstone Significance Cross-cutting Inspection
Aspect Procedure
Not Applicable Apparent Violation Not 71152-
AV 05000482/2019010-01 Applicable Problem
Open Identification
EA-18-165 and
Resolution
The inspectors identified an apparent violation of 10 CFR 50.9, associated with the licensees
failure to ensure information required by the Commissions regulations is complete and
accurate in all material respects. Specifically, the licensee failed to maintain complete
information when documenting the as found condition of control rod drive mechanisms
(CRDMs) in accordance with Work Order 16-417262-015; and following the cleaning of
CRDMs the licensee failed to maintain accurate information when documenting that cleaning
of CRDMs 4, 35, and 53 was performed and that the post-cleaning inspection met the
acceptance criteria.
Description: On September 2, 2016, reactor coolant system unidentified leakage was
calculated to be greater than allowed, and the licensee completed a plant shutdown as
required by plant Technical Specifications. Following shutdown and containment entry, the
source of the leak was identified as the canopy seal weld on penetration 77 on the reactor
vessel head (not pressure boundary leakage), which serves one of the core exit
thermocouples. The licensee maintained the plant in Mode 3 rather than continue to Mode 5,
resulting in highly borated reactor coolant spraying onto the reactor vessel head for six days
until September 7, 2016, at which time the plant was cooled down to Mode 5 and
depressurized.
With the CRDM fans running for these six days, the CRDM components were coated with a
heavy layer of boric acid residue. The licensee issued work orders to clean the boric acid off
of affected structures, systems, and components, including 15 of the most-affected CRDMs.
Due to problems with removal, three of the CRDMs (4, 35, and 53), planned to be cleaned,
were not removed from the head and were neither inspected nor cleaned as planned.
3
In response to questions from the NRC staff, the licensee wrote Condition Report 115392,
which documented that work order data sheets for three of the CRDMs were incorrect, in that
the work orders recorded that the CRDMs had been removed, inspected, cleaned,
reinspected and reinstalled when the CRDMs had not been removed from the head. The
licensee affirmed that the work order data sheets incorrectly recorded the inspection and
cleaning of CRDMs 4, 35, and 53 and the licensee subsequently filed a Record
Supplemental/Correction Sheet with the original vaulted Work Order 16-417262-015 on
December 5, 2017.
Work Order 16-417262-015, a safety-related work order, was required to be maintained by
Title 10 CFR Part 50, Appendix B, Criterion XVII, which requires, in part, that sufficient
records shall be maintained to furnish evidence of activities affecting quality.
Corrective Actions: The licensee filed a correction sheet with the original vaulted work order
and conducted an internal review of the matter. The licensees review did not identify the
individuals responsible and found no evidence of ill intent. The licensee described the
inaccurate records as a clerical error. No actions were taken or planned to address the
manner in which the work order records had been completed without actually performing the
work.
Corrective Action References: Condition Report 115392
Performance Assessment: The Reactor Oversight Process significance determination
process does not specifically consider willfulness in its assessment of licensee performance.
Therefore, it is necessary to address this violation, which involves willfulness, using traditional
enforcement to adequately deter non-compliance. The severity of this apparent violation will
be determined in accordance with the Enforcement Policy pending a final enforcement
determination.
Enforcement:
Apparent Violation: 10 CFR 50.9 requires, in part, that information required by the
Commissions regulations, orders, or license conditions to be maintained by the licensee shall
be complete and accurate in all material respects.
10 CFR Part 50, Appendix B, Criterion XVII, requires, in part, that sufficient records shall be
maintained to furnish evidence of activities affecting quality.
Procedure AP 15A-003, Records, Revision 13, a quality related procedure, Step 4.12.1
defined, in part, that quality records include those which furnish documentary evidence of the
quality of items and of activities affecting quality. Such activities are described in
10 CFR Part 50, Appendix B. A document shall be considered a QA record when it has been
completed, authenticated and has had the review required by the procedure governing that
document.
Contrary to the above, from October 31, 2016, to December 5, 2017, the licensee failed to
maintain information required by the Commissions regulations that was complete and
accurate in all material respects. Specifically, following the cleaning of CRDMs in Work
Order 16-417262-015, the licensee failed to maintain complete and accurate information
when documenting the cleaning of CRDMs 4, 35, and 53 was performed, and that the
post-cleaning inspection met the acceptance criteria. The information in the work order was
material to the NRC because it is subject to NRC inspection and informs the NRCs review of
and response to boric acid leaks affecting the reliability of equipment affecting safety.
4
Enforcement Action: This violation is being treated as an apparent violation pending a final
enforcement determination.
EXIT MEETINGS AND DEBRIEFS
On March 26, 2019, the NRC staff presented the inspection results to Mr. Jaime McCoy, Site
Vice President, and other licensee staff in a telephonic exit meeting. The NRC staff verified no
proprietary information was retained or documented in this report.
5
SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: JGK Yes No Publicly Available Sensitive
OFFICE SES:ACES C:DRP/B AC:DRP/B TL:ACES RC DD:DRP
NAME JKramer NTaylor DBradley MVasquez DCylkowski MHay
SIGNATURE /RA/ /RA/E /RA/E /RA/ /RA/ /RA/
DATE 03/08/19 03/11/19 03/11/19 03/12/19 03/14/19 03/14/19
NAME ETorres AWase AVegel
SIGNATURE /RA/ E /NLO/ E /MCH for/
DATE 03/14/19 03/28/19 04/02/19