ML092400145

09/01/2009 Wolf Creek 2009 Midcycle Assessment

ML092400145
Person / Time
Site:	Wolf Creek
Issue date:	09/01/2009
From:	Chamberlain D NRC/RGN-IV/DRP
To:	Muench R Wolf Creek
References
Download: ML092400145 (7)

Text

UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, 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 signi ficance (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 impl emented 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 th reshold 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 hav e 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 demonstrat ion 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 wi th your improvement plan have resulted in improved performance in this area. Of note, th is 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 Assessm ent 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 A Rules 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 Avail able 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

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

Jay Silberg, Esq.

Pillsbury Winthrop Shaw Pittman LLP

2300 N Street, NW Washington, DC 20037

Supervisor Licensing

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

Chief Engineer

Utilities Division

Kansas Corporation Commission

1500 SW Arrowhead Road

Topeka, KS 66604-4027

Office of the Governor

State of Kansas

Topeka, KS 66612-1590 Attorney General

120 S.W. 10th Avenue, 2nd Floor

Topeka, KS 66612-1597

County Clerk Coffey County Courthouse 110 South 6th Street

Burlington, KS 66839

Chief, Radiation and Asbestos

Control Section

Bureau of Air and Radiation

Kansas Department of Health and

Environment

1000 SW Jackson, Suite 310

Topeka, KS 66612-1366

Chief, Technological Hazards

Branch

FEMA, Region VII

9221 Ward Parkway

Suite 300

Kansas City, MO 64114-3372

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

Inspection / Activity Plan Page 1 of 2 08/17/2009 14:27:55 Report 22 09/01/2009

-12/31/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Wolf Creek EXAM-INITIAL EXAM 3 1 INITIAL EXAM-WC (8/2009)

X02419 08/31/2009 09/04/2009 EB1-08-INSERVICE INSPECTION 3 1 IP Reactor Coolant System Dissimiliar Metal Butt Welds 2515/172 10/10/2009 10/30/2009 1 IP Inservice Inspection Activities - PWR 7111108P 10/10/2009 10/30/2009 RP-ORS3-OCCUPATIONAL RADIATION SAFETY - ALARA 1 1 IP A ccess Control to Radiologically Significant Areas 7112101 10/19/2009 10/23/2009 1 IP A LARA Planning and Controls 7112102 10/19/2009 10/23/2009 1 IP Performance Indicator Verification 71151 10/19/2009 10/23/2009 RP-ORS4-OCCUPATIONAL RADIATION SAFETY - ACCESS 1 1 IP A ccess Control to Radiologically Significant Areas 7112101 10/19/2009 10/23/2009 1 IP A LARA Planning and Controls 7112102 10/19/2009 10/23/2009 1 IP Performance Indicator Verification 71151 10/19/2009 10/23/2009 RP-ORS1-OCCUPATIONAL RADIATION SAFETY - ALARA 1 1 IP A ccess Control to Radiologically Significant Areas 7112101 03/15/2010 03/19/2010 1 IP A LARA Planning and Controls 7112102 03/15/2010 03/19/2010 1 IP Occupational Exposure Control Effectiveness 71151-OR01 03/15/2010 03/19/2010 1 IP RETS/ODCM Radiological Effluent 71151-PR01 03/15/2010 03/19/2010 EP-1-BIENNIAL EP PROGRAM INSPECTION 1 1 IP A lert and Notification System Testing 7111402 04/12/2010 04/16/2010 1 IP Emergency Response Organization Augmentation Testing 7111403 04/12/2010 04/16/2010 1 IP Emergency Action Level and Emergency Plan Changes 7111404 04/12/2010 04/16/2010 1 IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 04/12/2010 04/16/2010 1 IP Drill/Exercise Performance 71151-EP01 04/12/2010 04/16/2010 1 IP ERO Drill Participation 71151-EP02 04/12/2010 04/16/2010 1 IP A lert & Notification System 71151-EP03 04/12/2010 04/16/2010 RP-ORS1-OCCUPATIONAL RADIATION SAFETY-ACRSA 1 1 IP A ccess Control to Radiologically Significant Areas 7112101 05/10/2010 05/14/2010 1 IP A LARA Planning and Controls 7112102 05/10/2010 05/14/2010 1 IP Performance Indicator Verification 71151 05/10/2010 05/14/2010 PSB2-52B-BIENNIAL PI&R 4 1 IP Identification and Resolution of Problems 71152B 07/12/2010 07/16/2010 1 IP Identification and Resolution of Problems 71152B 07/26/2010 07/30/2010 EB1-21-COMPONENT DESIGN BASIS INSPECTION 6 1 IP Component Design Bases Inspection 7111121 09/07/2010 09/10/2010 This report does not include INPO and OUTAGE activities.

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

Inspection / Activity Plan Page 2 of 2 08/17/2009 14:27:55 Report 22 09/01/2009

-12/31/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Wolf Creek EB1-21-COMPONENT DESIGN BASIS INSPECTION 6 1 IP Component Design Bases Inspection 7111121 09/20/2010 10/01/2010 BRQ-OPERATOR REQUAL INSP 2 1 IP Licensed Operator Requalification Program 7111111B 10/04/2010 10/08/2010 RP TEAM-RADIATION SAFETY TEAM INSPECTION 4 1 IP Radiation Monitoring Instrumentation and Protective Equipment 7112103 10/18/2010 10/22/2010 1 IP Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 7112201 10/18/2010 10/22/2010 1 IP Radioactive Material Processing and Transportation 7112202 10/18/2010 10/22/2010 1 IP Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 7112203 10/18/2010 10/22/2010 1 IP Material Control and Accounting (MC&A) 7113011 10/18/2010 10/22/2010 EB2-07T-TRIENNIAL HEAT SINK PERFORMANCE 1 1 IP Heat Sink Performance 7111107T 10/25/2010 10/29/2010 EXAM-INITIAL EXAM 4 1 INITIAL EXAM -WC (11/2010)

X02451 11/08/2010 11/12/2010 1 INITIAL EXAM -WC (11/2010)

X02451 12/06/2010 12/17/2010 This report does not include INPO and OUTAGE activities.

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