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05000482/FIN-2018003-0230 September 2018 23:59:59Wolf CreekNRC identifiedFailure to Submit a Licensee Event Report for a Condition Prohibited by Technical SpecificationsThe inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.73(a)(2)(i)(B), because the licensee did not provide a written licensee event report (LER) to the NRC within 60 days. Specifically, the licensee did not provide a written LER to the NRC within 60 days of identifying a condition prohibited by the plants Technical Specifications associated with inoperability of control room emergency ventilation system train B for longer than its Technical Specification allowed outage time. As a result, the NRCs ability to regulate was impacted.
05000482/FIN-2018002-0130 June 2018 23:59:59Wolf CreekNRC identifiedAnnouncement of an NRC Inspectors Presence by Station PersonnelThe inspectors identified a Severity Level IV non-cited violation (NCV) of 10 CFR 50.70(b)(4), Inspections, associated with the licensees failure to ensure the arrival and presence of NRC Inspectors, who had been properly authorized facility access as described in 10 CFR 50.70(b)(3), were not announced or otherwise communicated by its employees or contractors to other persons at the facility without a specific request by the NRC inspector. Specifically, a contract radiation protection technician entered the spent fuel pool building where the resident inspector was present and observing core offload activities, and the technician informed members of a work crew of the whereabouts of an NRC radiation protection inspection team without being requested to do so; this impacts the NRCs ability to regulate and perform unannounced inspections.
05000482/FIN-2016408-0430 September 2016 23:59:59Wolf CreekNRC identifiedSecurity
05000482/FIN-2016406-0131 March 2016 23:59:59Wolf CreekLicensee-identifiedSecurity
05000482/FIN-2013003-0630 June 2013 23:59:59Wolf CreekNRC identifiedFailure to Maintain Complete and Accurate Housekeeping RecordsThe inspectors identified a Severity Level IV violation of 10 CFR 50.9, Completeness and accuracy of information, for the Wolf Creek Nuclear Generating Stations failure to maintain complete and accurate records required by a license condition. Title 10 CFR 50.9 requires, in part, that information required by statute, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. Contrary to the above, between October and December 2008, the licensee failed to maintain records required by License Condition 2.C.5 that were complete and accurate in all material respects. Specifically, the Housekeeping Inspection Card for the spent fuel pool area indicated that the inspection had been completed when security access logs indicate that the individual that completed the record had not entered the area. The NRC investigation determined that the assigned individual did not walk down the assigned area, and did not assign a designee to do so (EA-13-084). The failure to maintain records required by License Condition that are complete and accurate in all material respects in accordance with 10 CFR 50.9 was a violation. Because the violation is associated with willfulness and impacted the regulatory process it was evaluated under the traditional enforcement process as set forth in the NRC Enforcement Policy. Since this violation was the result of a willful action, the NRC considers the violation to be more than minor, and therefore, the NRC has classified the violation at Severity Level IV, in accordance with the NRC Enforcement Policy.
05000482/FIN-2012007-0230 June 2012 23:59:59Wolf CreekNRC identifiedFailure to Report Conditions That Could Have Prevented Fulfillment of a Safety FunctionThe inspectors identified a non-cited violation of 10 CFR 50.73(a)(2)(i)(b) for the licensees failure to submit a licensee event report upon discovery that a condition prohibited by technical specifications had existed in the preceding three years. On April 18, 2011, the licensee issued calculation GK-06-W, SGK05A/B Class 1E Electrical Equipment Rooms A/C Units, Single Unit Operation Capability, Revision 2. This calculation concluded that with one of the two air conditioning units inoperable, the use portable fans and the opening of doors was required to maintain vital switchgear rooms below the maximum operability limits. The calculation further concluded that even with these compensatory actions, required temperatures could be maintained only if the temperature of all surrounding areas remained below 78F. Calculation GK-06-W thus demonstrated that a single cooler was incapable of maintaining the switchgear rooms within technical specification limits, without compensatory actions. Because one of the two air conditioning units had been out of service on multiple occasions during the preceding three years with no compensatory actions taken, the condition was reportable. The licensee entered this finding in its corrective action program as condition report 53452. The failure to submit a licensee event report was a performance deficiency. The team evaluated this performance deficiency using the NRCs significance determination process (SDP) and determined that it was of minor safety significance. It is therefore not associated with a finding or assigned a color. However, performance deficiencies which impact the NRCs regulatory ability are processed using traditional enforcement separately from the SDP evaluation. The NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function. When this is not done, the regulatory function is impacted. Therefore, the team determined that this performance deficiency was most appropriately processed using traditional enforcement. Using the Enforcement Policy and the available risk information, the inspectors concluded that this violation is a traditional enforcement violation of Severity Level IV.
05000482/FIN-2011005-0531 December 2011 23:59:59Wolf CreekNRC identifiedIncorrect Retraction of an Event that Could Have Prevented Fulfillment of a Safety FunctionThe inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.73 because the licensee inappropriately retracted a licensee event report. On September 29, 2011, Wolf Creek issued Licensee Event Report 2011-004-01 which retracted the 10 CFR 50.73(a)(2)(v)(D) portion of the report for loss of both trains of automatic safety injection on March 19, 2011. The automatic functioning of safety injection is required by Technical Specification 3.3.2, function 1.b. Wolf Creek licensee event report 2011-004-00 was correct in its reporting the loss of safety function. In retracting this aspect, Wolf Creek credited manual action to restart safety injection and the long standing logic design. However, NUREG 1022, Section 3.2.7, specifies that inoperable systems required by the technical specifications be reported. This issue is entered into the licensees corrective action program as condition report 46110. The inspectors reviewed this issue in accordance with Inspection Manual Chapter 0612 and the NRC Enforcement Manual and determined that traditional enforcement was applicable to this issue because the NRC\\\'s regulatory ability was affected. Specifically, the NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done, the regulatory function is impacted. The inspectors used the Enforcement Policy and the available risk information to conclude that this violation is appropriately characterized as Severity Level IV.
05000482/FIN-2009005-1531 December 2009 23:59:59Wolf CreekNRC identifiedFailure to Report a Condition that Could Have Prevented Fulfillment of a Safety FunctionThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73 in which the licensee failed to submit a licensee event report within 60 days following discovery of events or conditions meeting the reportability criteria. On December 31, 2009, the inspectors identified a licensee event report that was no timely. Licensee Event Report 2009-009-00 was not issued within 60 days for a condition prohibited by technical specifications, and the event report did not identify that the disabling of both trains of the P-4 interlock on August 22, 2009 was also reportable per 10 CFR 50.73(a)(2)(v). The P-4 interlock was required by Technical Specification 3.3.2, function 8.a, and is discussed in USAR, Section 7.3.8, NSSS Engineered Safety Feature Actuation System. Wolf Creek licensee event report 2009-009 was correct in that the interlock is not credited in accident analysis. However, NUREG 1022, Section 3.2.6, specifies that inoperable systems required by the technical specifications be reported, even if there are other diverse operable means of accomplishing the safety function. The inspectors reviewed this issue in accordance with Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. Specifically, the NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done, the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management, and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding was determined to have a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program in that the licensee failed to appropriately and thoroughly evaluate for reportability aspects all factors and time frames associated with the inoperability of the engineered safety features actuation system (P.1(c)) (Section 4OA3)
05000482/FIN-2009004-0730 September 2009 23:59:59Wolf CreekNRC identifiedFailure to Report Conditions that Could have Presented Fulfillment of a Safety FunctionThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73, Licensee Event Report System, with three examples in which the licensee failed to submit licensee event reports within 60 days following discovery of an event meeting the reportability criteria. First, on April 10, 2008, Wolf Creek submitted Licensee Event Report 2008-002-00 under 10 CFR 50.73(a)(2)(i)(B) which is operation prohibited by technical specifications but failed to make a report for a loss of safety function per 10 CFR 50.73(a)(2)(v) for the same event in which both trains of the emergency core cooling system were inoperable on February 13-14, 2008. Second, Wolf Creek filed Licensee Event Report 2008-004-00 on June 6, 2008 under 50.73(a)(2)(iv)(A) for an event that caused automatic start of an emergency diesel during a loss of offsite power on April 16, 2008. No report was made under 50.73(a)(2)(v) for an event or condition that could have prevented a safety function due to the loss of offsite power. Third, on April 10, 2008, Wolf Creek filed Event Notification Report 44131 under 10 CFR 50.72(b)(3)(ii)(B) based on a possible trip of all four containment coolers. The notification was later retracted. The inspectors found insufficient evidence to show that the containment coolers would not trip and concluded the event should have been reported under 10 CFR 50.73(a)(2)(v). All three issues are collectively captured in Condition Report 15318. The inspectors reviewed this issue in accordance with Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\\\'s regulatory ability was affected. Specifically, the NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done, the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management, and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding was determined to have a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program in that the licensee failed to appropriately and thoroughly evaluate for reportability aspects all factors and time frames associated with the inoperability of the emergency core cooling system, the offsite power system, and the containment heat removal system (P.1(c)) (Section 4OA3)
05000482/FIN-2009004-0830 September 2009 23:59:59Wolf CreekNRC identifiedChanges to the Approved Fire Protection Program Without Prior Staff ApprovalThe inspectors identified a Severity Level IV noncited violation of License Condition 2.C.(5), Fire Protection, for making changes to the approved fire protection program without the required prior Commission approval. Specifically, the licensee made a change to the Updated Safety Analysis Report that allowed the licensee to violate the requirements of 10 CFR Part 50, Appendix R, Section III.L. Specifically, when the licensee recognized that fire damage could cause a pressurizer power operated relief valve to open long enough to create a void in the reactor vessel, this was documented as acceptable when it was not in compliance with this regulatory requirement. The licensee entered this issue into their corrective action program as Performance Improvement Request 2008-004869. This finding was assessed using traditional enforcement since it had the potential for impacting the NRCs ability to perform its regulatory function. This finding is more than minor since the change required prior staff review and approval prior to implementation and it did not receive the required approval. A senior reactor analyst performed a Phase 3 evaluation and determined this performance deficiency was of very low risk significance. In accordance with the guidance in Supplement I of the Enforcement Policy, this issue is considered a Severity Level IV noncited violation because it is of very low risk significance. This finding had a crosscutting aspect in the area of human performance associated with resources because the licensee failed to maintain long-term plant safety by maintaining design margins. Specifically, the licensees choice to allow reactor vessel head voiding during an alternative shutdown in lieu of restoring the plant to compliance with the requirements of 10 CFR Part 50, Appendix R, Section III.L constituted a reduction in safety margin (H.2(a)) (Section 40A5.3)
05000482/FIN-2009006-0230 September 2009 23:59:59Wolf CreekNRC identifiedInadequate Instructions for Changing Modes of Operation of the Residual Heat Removal systemThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73, Licensee Event Report System, associated with the licensees failure to submit a licensee event report within 60 days following discovery of an event meeting the reportability criteria as specified. Specifically, on December 8, 2008, the licensee completed analysis of an issue associated with the residual heat removal system which determined that both trains of the system were inoperable when suction side temperature exceeded 249F. Based on the results of this analysis as well as plant operating history, it was determined that the licensee failed to report instances where the system was operated in a condition prohibited by technical specifications, and a loss of safety function of the system existed between March 20, 2008, and December 8, 2008. The licensee entered this issue into their corrective action program as Condition Reports 2009-1261 and 2009-1326 and Action Requests 15244, 17776, and 15306. The inspectors reviewed this issue in accordance with Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. Specifically, the NRC relies on licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done, the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and, because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding was determined to have a crosscutting aspect in the area of Problem Identification and Resolution associated with the corrective action program in that the licensee failed to appropriately and thoroughly evaluate for reportability aspects all factors and time frames associated with the inoperability of residual heat removal system when suction temperatures were above 249F (P.1(c))(Section 2.1)
05000482/FIN-2008010-0631 December 2008 23:59:59Wolf CreekNRC identifiedFailure to Evaluate Changes to the Approved Fire Protection ProgramThe team identified a Severity Level IV non-cited violation for making changes to the approved fire protection program in a manner contrary to the requirements of License Condition 2.C.(5).(b). Prior to 2005, the licensee made multiple revisions to Procedure OFN RP-017, Control Room Evacuation, without demonstrating the changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Specifically, the licensee had revised the alternative shutdown procedure to allow some manual actions to be completed in times longer than the approved time commitments. When revising the alternative shutdown procedure, the licensee did not evaluate the changes to ensure they would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. The licensee entered this issue into the corrective action program as Performance Improvement Request 2005-3317. Failure to demonstrate that changes to the approved fire protection program would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire prior to changing the alternative shutdown procedure is a performance deficiency. This finding is more than minor because it is associated with the Protection Against External Factors attribute of the Mitigating Systems Cornerstone and could affect the availability, reliability, and capability of systems that respond to fire events to prevent undesirable consequences. This finding was assessed using traditional enforcement since it had the potential for impacting the NRCs ability to perform its regulatory function. Using the guidance in Section D.3 of Supplement I of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV violation since the licensee implemented corrective actions, provided a technical evaluation for the new alternative shutdown procedure, and performed an evaluation of the changes made in the alternative shutdown procedure. This finding was not assigned a cross-cutting aspect because the procedure changes were made in the 2005 timeframe and do not represent current performance. (Section 4OA5.02