IR 05000482/1988020

Ack Receipt of 881130 & Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/88-20

ML20246A416
Person / Time
Site:	Wolf Creek
Issue date:	06/26/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 8907060272
Download: ML20246A416 (2)

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. . . . JuR 261989 In Reply Refer To:

Docket: STN 50-482/88-200 Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers President and Chief Executive Officer.-

P.O. Box 411 Burlington, Kansas 66839:

Gentlemen:

Thank you for your' letters of November'30,1988, and' June 1, 1989', in respons to our letters and Notice of Violation _ dated September 16, and October'19., 1988,

' and May 2, 1989. We.have reviewed your replies, and find them to be responsive to the concerns raised:in the. Notice of Violatio You have described a program, whereby you are now aggressively obtaining and reviewing vendor' technical. information, but you 'also indicate that by so"doing',

'you believe that you are exceeding the commitments made in response to Generic-Letter 83-28 as stated in your letter of December. 10, 1986. .You further indicate that the commitments made in thisLletter should be considered the applicable regulatory position as defined in NRC Manual. Chapter 0514, Section'05 Without reference to the merits >of your position, our discussions with NRR indicate that additional. generic guidan'ce is planned to clarify-the issue of obtaining vendor-technical information. Since'this proposed l generic guidance, if issued', willl definitively resolve the issue in question and since the sum l total' of ytur: current activities in;this area would appear to meet or exceed  !

the planned guidance, we have no further. questions.at this time. We shal review >your t.orrective actions during a future inspectio ;

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Sincerely,

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DrIginal Signed By J. L. Milhoad . <

James L. Milboan, Director- i Division of Reactor Projects

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Wolf Creek Nuclear Operating Corporation ATTN: -Otto Maynard, Manager of Licensing ,

P.O. Box 411 Burlington, Kansas 66839

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Wolf Creek Nuclear Operating

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Corporation Wolf. Creek-Nuclear OperatingC'orporation ATTN: Gary Boyer, Plant Manager-  ;

P.O. Box 411' '1 Burlington, Kansas 66839 1 Kansas Corporation Commission-ATTN: Robert D. Elliott, Chief. Engineer Fourth Floor, Docking State Office Buildin Topeka, Kansas 66612-1571 Kansas Radiation Control Program Director . ,

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'bec distrib. by RIV: 3 RRI~ . .R;..D. Martin,-RA Section: Chief,(DRP/D) DRP.,,

RPB-DRSS- ..- R. DeFayette, RIII-RIV File SRI, Callaway, RIII:

MIS System RSTSL 0perator:

Project ~ Engineer (DRP/D) Lisa Shea, RM/ALF ]

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D."V. Pickett, NRR. Project Manager (MS: 13-D-18) )

~ E. Gagliardo D. R. Hunte j

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W$LF CREEK NUCLEAR OPERATING CORPORATION Bart D. Withers President and l choemecutsve Omcor

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June 1,1989

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WM 89-0160 ---

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I U. S. Nuclear Regulatory Commission ATTH: Document Control Desk it jly _ 7 Mall Station F1-137 '

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Washington, D. C. 20555 Reference: Letter dated May 2, 1989 from R. D. Martin, NRC to B. D. Withers, WCNOC Subject: Docket No. 50-482: Response to Request for Additional Information on Violations 482/88200-03 and 04 '

Gentlemen:

i This letter provides Wolf Creek Nuclear Operatitig Corporation's (WCNOC)

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response to the request for additional information documented in the Referenc The request for additional information was in conjunction with violation 482/85200-03 involving an inadequate procedure and violation 482/88200-04 involving a failure to establish procedure If.you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staf Very truly yours, .

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l Bart D. Withers i President and I

Chief Executive Officer BDW/jad

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Attachment cc: B. L. Bartlett (NRC), w/a E. J. Holler (NRC), w/a l R. D. Martin (NRC), w/a l

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D. V. Pickett (NRC), w/a j l  !

tQ PO. Box 411/ Burlington, KS 66839 / Phone (316) 364 8831 yn9 - ~ , ,e.-c-

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7 Attachmeat to WM 89-0160'

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Violation ~B (482/88200-03): Inadeauste Procedure Reauest We request that you provide additional information regarding the training and qualifications standards which define " skill of the craft." We further request that you provide information on how planners, engineers or others drafting work instructions are knowledgeable of what is -encompassed- in

" skill of the craft * for the various maintenance discipline Response:

The On the Job Training (0JT) program developed from craft involved Job Task Analysis serves as a standard for acquired skills. . This program requires both satisfactory training attendance and the demonstration of' ability to-perform to the standar This program did.not specifically- address- the heating Lof couplings for removal' and- re-installation. , OJT module HH1327408 ' Coupling Removal and Installation", has since been developed and is presently being incorporated into the ongoing training progra Engineers, Planners, and others drafting work instructions are aware of and have access to the information conta,ined within the 0JT1 program to ~ become knowledgeable of what is encompasse However, 's requirement'of the work'

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assignments for individuals to perform work in the field requires.a check of !

the individuals qualification attainment be made at the time.of assignmen It is known by the work Instruction'.preparerf^that the ' craft ' worker's J

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j supervisor will review the instruction.for necessary details and will match j the skill of the individuals to'the task being performed.

I h While all the previous criteria was generally met,. both in generating' the {

work instructions and in assigning personnel to perform this activity,. the concern raised is recognized as an improvement to present practices.- j Violation C (482/88200-04): Failure to Establish Procedure Reauest: i

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l The violation was written to state that you had failed to obtain three ,

Service Information Letters (SILs) affecting your Emergency Diesel Generator (EDG) and that you had failed affecting your ECG to'. review or evaluate five' other SILs !

In'your response, you state that your only' commitment I is to review vendor information, not to obtain vendor.-informatio We reject this argument, for the intent of Generic Letter-(GL) 83-28 was to '

assure that pertinent .information related to ~ maintaining safety-related equipment operable was identified and use Your position indicated that'

.you may not have grasped the safety significance'of GL 83-2 We request that your , provide- us with a fuller description of your corrective action with regard to the review and.use of vendor information for ::afety related j equipmen !

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Attachment to WM 89-0160 Page 2 of 3 j

Response:

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l WCNOC fully recognizes the safety significance of Generic Letter 83-28 and, j as indicated during the telephone discussion, is doing more than what is  ;]

currently require The statements made during the April 14, 1989 ]

discussion which may have resulted in some misunderstandings vere relative to the differences between what WCNOC is doing and what WCNOC is required to d !

As stated earlier. WCNOC fully recognizes the need to obtain and evaluate vendor information to the maximum extent practical and we agree with the NRC ]

that pertinent information relating to maintaining safety related equipment i operable- should be -identified and used. WCNOC has initiated actions to i obtain information from vendors in order to evaluate any problame or changes 1 relative to the application of their products at Wolf Creek Generating  ;

Station (WCGS). I Procedure KGP-1311 " Industry Technical Information Program" establishes the guidelines for the review and analysis of industry technical information (including unsolicited vendor letters identifying potential problems) to ensure that vendor information is translated into corrective actions, if required, to improve the safety and reliability of WCG Upon receipt of industry technical information, an initial review is conducted to determine its applicability to WCG As determined by the initial review, if the information requires a more detailed evaluation, it is transmitted to the appropriate organization for further evaluation. This evaluation involves a review of WCGS programs, procedures and design information for the purpose of resolving concerns and identifying corrective actions such as changes to procedures, training and plant or equipment desig In November 1987, WCNOC detenmined that it.was not receiving emergency diesel generator (EDG) Service'Information Letters (SILs) from the vendo At that point, which was prior to the NRC inspection, actions were taken to obtain previous SILc that pertained to the WCGS EDGs. At the time, WCGS was relying on the vendor to identify those SILs applicable to WCGS, which resulted in WCGS receiving five SILs that were potentially applicabl The evaluation of the SILs did not identify any substantial safety concern In letter dated November 30, 1988 from B. D. Withers, WCNOC to the NRC, l WCNOC discussed its plans to develop a program to enhance the technical information progra Supplier Quality procedure SMQP 7.10 " Supplier Problem / Service Information Bulletins", was initiated in December 1988 to provide a method for periodically contacting equipment vendors on the WCNOC Supplier Information List to determine if they have issued letters / bulletins which could impact components or systems at WCG Upon receipt of a supplier letter / bulletin, a copy is forwarded to the Industry Technical Information Program (ITIP) Coordinator for inclusion into the ITI As of May 8, 1989, letters have been transmitted to 71 vendors requesting a

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Attachment to WM 89-0160 Page 3 of 3 technical contact and to identify if any letters / bulletins have been issued which affect WCG Twenty responses have been received with only one (1)

bulletin being transmitted to WCGS as a result of this effor The information provided in this bulletin was the subject of a previously received NRC Information Notice and was already being evaluate The statements made during the April 14, 1989 discussion relative to requirements which may have contributed to some confusion, were that WCNOC considers the commitments made in its response to Generic Letter 83-28 to be the applicable regulatory positions as defined in NRC Manual Chapter 0514, Section 05 The NRC Staff review of the Generic Letter 83-28 vendor interface issue is ongoing and WCNOC fully recognizes that changes in the applicable regulatory position may occur through the provisions of 10 CFR 50.109. However, until the Staff review is complete, WCNOC considers the commitments made in the December 10, 1986 letter to be the applicable regulatory position for WCGS.

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