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Burlington, Kansas-based Wolf Creek Nuclear Operating Co., inked a confirmatory order documenting mutually agreed-upon actions with the Nuclear Regulatory Commission (NRC) to implement programs designed to prevent willful misconduct by employees.

Following an investigation at the Wolf Creek nuclear power plant, the NRC determined a maintenance worker and a supervisor falsified a record regarding the cleaning and inspection of the reactor’s control rod drive mechanisms on Oct. 31, 2016.

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Company officials requested the Alternative Dispute Resolution (ADR) process with the NRC to discuss corrective actions. The process uses a neutral mediator with no decision-making authority to assist the NRC and its licensees in reaching an agreement.

Following a meeting on May 30, the NRC issued a confirmatory order documenting actions the company has agreed to take.

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What was at issue was on November 22, 2017, the NRC 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, according to the NRC report. 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.

Admitted Falsification
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 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 the CRDMs had not been removed and his “as found” descriptions were based on assumptions rather than observations. The maintenance worker also testified 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 he assumed the CRDMs had been cleaned. The supervisor stated he should not have completed any paperwork unless he knew and could verify the CRDMs were cleaned. The supervisor stated he knew his conduct was wrong and against the work procedure.

Based on the evidence, it appears 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.”

During the ADR session held on May 30, Wolf Creek and the NRC reached a preliminary settlement agreement. Corrective actions already taken by Wolf Creek were discussed included:

A. The Chief Nuclear Officer issued a communication to the entire plant regarding expectations for accurately performing and documenting·work activities, focusing on “Your Signature Is Your Word” and “Look for, Understand, and Mitigate Risk” related to making assumptions.
B. Wolf Creek performed remediation with the individuals involved to reinforce and institutionalize Wolf Creek standards and expectations with a focus on complete and accurate documentation, which included face-to-face discussion with the plant manager and the ‘site vice president.
C. Wolf Creek developed a procedure AP18-001, “Emerging Concerns,” to improve the quality of investigations, including investigations involving deliberate misconduct.
D. Wolf Creek conducted an internal investigation into employee deliberate misconduct with external counsel.

Reach Agreement
In terms of communications, Wolf Creek will also:

A. Within 1 month of the issuance date of the confirmatory order, Wolf Creek will issue a stand-alone communication from the Chief Nuclear Officer to all employees and contractor personnel that willful violations will not be tolerated. The communication will stress the importance of procedural adherence, ensuring that documents are complete and accurate, and of potential consequences for engaging in willful violations. This message will be balanced with the recognition that people do make mistakes and when that happens, it is Wolf Creek’s expectation its employees and contractors will identify and document issues in accordance with licensee procedures.
B. Within 4 months of the issuance date of the confirmatory order, Wolf Creek will hold meetings with all employees and long-term contractor personnel to address integrity and trustworthiness. The meetings will: (1) stress the importance of procedural adherence, ensuring that documents are complete and accurate, and of potential consequences for engaging in willful violations; (2) describe the circumstances of this case, the results of the root cause evaluation, and Wolf Creek’s corrective actions; (3) include the expectation to immediately raise safety concerns when observed; (4) address how to proceed when work order documentation is incomplete.
C. Within 4 months of the issuance date of the confirmatory order, Wolf Creek will reinforce expectations with regards to 10 CFR 50.9, completeness and accuracy of information, and 10 CFR 50.5, deliberate misconduct, by providing an overview of the last 5 years of pertinent NRC enforcement actions with Operations, Fire Watch, Maintenance, and Radiation Protection staff.
D. Within 6 months of the issuance date of the confirmatory order, Wolf Creek will complete its efforts to reinforce site expectations through posters and the morning brief communications, which will specifically address 10 CFR 50.9 and 10 CFR 50.5, and its applicable “Professional to the Core” behaviors meant to ensure high quality work and high-quality work products.
E. Within 6 months of the issuance date of this confirmatory order, Wolf Creek will develop a presentation to be delivered to an appropriate industry forum (e.g., Regional Utility Group or Strategic Teaming and Resource Sharing) subject to acceptance of the conference organizing committees.
F. Within 3 months of the issuance date of the confirmatory order, Wolf Creek will complete a root cause analysis of the circumstances that led to the incomplete and inaccurate information violation and develop corrective actions.

Click here to view the multiple other aspects to the confirmatory order the NRC and Wolf Creek will continue to work on.

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