IR 05000482/1992099

Forwards Final SALP Rept 50-482/92-99 for Period of 911006-921010

ML20127F375
Person / Time
Site:	Wolf Creek
Issue date:	01/13/1993
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 9301200221
Download: ML20127F375 (5)

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Docket No. STN 50-482-License No. NPF-42

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Wolf Creek-Nuclear Operating Corporation-ATIN

Bart-D. Withers:

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President and. Chief Executive Officer

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P.O.LBox 411-

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Burlington, Kansas 66839

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Gentlemen:

-SUBJECT:

FINAL SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT N0. 50-482/92-99 This forwards the finai SALP report for the Wolf Creek Generating

' Station (WCGS)'for the period.of October 6,-'1991, through October 10, 1992.

This final SALP report includes:

-lc The cover letter for the initial SALP: report (no revisions to the

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initial report were._made).

2.

.A summary and list of-attendees at our December-16, 1992, meeting at,the Eisenhower Training Center in Burlington, Kansas.

3.

-Your January 5, 1993, response to the initial-SALP report.

We have reviewed your letter dated January 5, 1992,-in responts:to our request

--for your planned corrective action to improve performance in the Safety Assessment / Quality Verification functional area, We will review-your progress

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to achieve these improvements'in-inspection _ efforts-during this<SALP_ period.

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The next_ SALP period' for the WCGS --is scneduled to.:last approximately 16 months,_from October 11, 1992;. through February 12, 1994.

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Sincerely, b

a M. M lho n-egional-Administrator:

Enclasures:

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? Cover letter forj the initial SALP report -

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NRC.a'nd WCNOC Meeting Summaries and Attendance list-

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~WCNOC response 1to the initial-.SALP report

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1, 9301200221 930113' V I

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Wolf Creek Nuclear Operating Corp.

ATTN: _ Otto Maynard, Director

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Plant Operations P.O. Box 411 Burlington, Kansas 66839 Shaw, Pittman, Potts & Trowbridge AlTN: Jay Silberg, Esq.

2300 M Street, NW Washington, D.C.

20037 Public Service Commission ATTN:

C. John Renken Policy & Federal Department P.O. Box 360 Jefferson City, Missouri 65102 U.S. Nuclear Regulatory Commission ATIN:

Regional Administrator, Region 111 799 Roosevelt Road

' Glen Ellyn, Illinois 60137 Wolf Creek Nuclear Operating Corp.

ATTN: Kevin J. Moles Manager Regulatory Services P.O. Box 411 Burlington, Kansas 66839 Kansas Corporation Commission ATIN:

Robert Elliot, Chief Engineer Utilities Division

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L 1500 SW Ariowhead Rd.

l-Topeka, Kansas 66604-4027 l'-

Office of the Governor L

State of Kansas L

Topeka, Kansas 66612 f

Attorney General-

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Topeka, Kansas 66612 Chairman _, Cof fey County Commission l

Coffey County Courthouse Burlington, Kansas 66839-1798 l

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Corporation Kansas Department of Health and Environment-Bureau of Air Quality & Radiation Control ATTN: Gerald Allen, Public Health Physicist

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Division of Environment Forbes Field Building 321-Topeka, Kansas 66620

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Kansas Department of Health and Environment ATTN:

Robert Eye, General Counsel LSOB, 9th Floor 900 SW Jackson lopeka, Kansas 66612 s

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Ef1 CLOSURE 1

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Docket No. STN 50-482 License No. NPF-42 Wolf Creek Nuclear Operating Corporation ATTN:

Bart O. Withers President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839 Gentlemen:

SUBJECT:

INITIAL SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT This fomards the initial SALP report (50-482/92-99) for the Wolf Creek Generating Station.

The SALP Board met on November 17, 1992, to evaluate Wolf Creek Generating Station's performance for the period October 6, 1991, through October 10, 1992.

The performance analyses and resulting evaluations are documented in the enclosed initial SALP report.

in accordance with NRC policy, I have reviewed the SALP Board's assessment and concur with their ratings. Good performance in the areas of Plant Operations, Maintenance / Surveillance, and Engineering / Technical Support resulted in a Category 2 rating for these areas of performance.

Good performance in the Emergency Preparedness functional area resulted in a Category 2 rating, but this represents a decline from the superior level of perfonnance that was observed during the previous assessment period. Performance in the Radiological Controls functional area was rated as Category 1.

The improving trend that was identified in the previous assessment period was sustained, resulting in a superior level of performance.

Continued superior performance was noted in the area of Security, which was rated as Category 1.

Overall, licensee performance was good, but continuing problems were again An identified with the self-assessment and corrective action programs.

acceptable level of performance was noted in the area of Safety Assessment / Quality Verification which was rated as Category 3, with some improvements noted.

The results of some NRC inspections indicated that plant workers have not fully accepted all the recent and planned changes that are intended to enhance self-assessment and corrective action effectiveness, in particular, some workers are still reluctant to initiate performance improvement request documents for known problems.

This performance problem was identified during previous assessments and actions to fully resolve it have not been fully effective or timely given its significance.

Additional We do view management attention in these areas still appears to be warranted.

as a positive action those steps that you have taken to better define and resolve weaknesses associated with the organizational structure, human

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Wolf Creek Nuclear Operating-2-Corporation performance, and plant programs.

The Performance Enhancement Program is still in the developmental phase and its effectiveness will depend on the quality of the action plans and their implementation.

At the end of this assessment period, several apparent violations were identified as the result of an NRC special inspection that was initiated to review the circumstances surrounding a degraded essential service water system flow condition.

Although some of these issues are addressed in this report, a final NRC assessment of these apparent violations will be completed during the current assessment period.

On the basis of the SALP Coard's assessment, the length of the ' R P period will be approximately 16 months.

Accordingly, the next SALP p< s.d will be from October 11, 1992, to February 26, 1994.

A management meeting will be scheduled with you and your staff to review the results of the initial SALP report.

The schedule for this meeting will be established by separate correspondence.

Within 20 days of this management meeting, you are required to provide planned corrective actions to achieve improved perfomance in the Safety Assessment / Quality Verification functional area.

You may also provide comments on and amplification of, as approprit e, other aspects of the initial SALP report.

Your written comments, a summary of our meeting, and the results of my consideration of your comments will be issued as an appendix to the enclosed initial SALP report and will constitute the final SALP report.

Sincerely

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- LMC ames L. Milhoan Phgional Administrator Enclosure:

Initial SALP Report 50-482/92-99 cc w/ enclosure:

Wolf Creek Nuclear Operating Corp.

ATTN:

Otto Maynard, Director Plant Operations P.O. Box 411 Burlington, Kansas 66839

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Wolf Creek Nuclear Operating-3-Corporation'

Shaw, Pittman, Potts & Trowbridge

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ATTN: Jay Silberg, Esq.

2300 M Street, NW Washington, D.C.

20037 Public Service Commission ATTN:

C. John Renken Policy & Federal Department P.O. Box 360 Jefferson City, Missouri 65102 U.S. Nuclear Regulatory Commission ATTN:

Regional Administrator, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Wolf Creek Nuclear Operating Corp.

ATTN:

Kevin J. Moles Manager Regulatory Services P.O. Box 411 Burlington, Kansas 66839 Kansas Corporation Commission ATTN:

Robert Elliot, Chief' Engineer Utilities Division 1500 SW Arrowneaa Rd.

Topeka, Kansas 66604-4027 Office of the Governor State of Kansas Topeka, Kansas 66612 Attorney General 1st Floor - The Statehouse

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Tooeka, Kansas 66612 Chairman, Coffey County Commission Coffey County Courthouse Burlington, Kansas 66839-1798 Kansas Department of Health and Environment Bureau.of Air Quality & Radiation Control ATTN:

Gerald Allen Public-Health Physicist Division of Environment Forces Field Building 321 Tocexa, Kansas 66620

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.i ENCLOSURE.2

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SALP MEETING ATTENDEES l

Name Affiliation T. Riley WCNOC K. Moles WCNOC C. Sprout WCN00 R. Logsdon WCNOC M. Williams WCNOC G. Pendergrass WCNOC

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J. Johnson WCNOC D. Dees WCNOC G. Smith WCNOC

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T. Morrill WCNOC M. Grimsley WCNOC 0. Maynard WCNOC B. Withers WCN0C F. Rhodes WCNOC R. Hagan WCNOC-W. Lindsay WCNOC C Parry WCNOC J. Weeks

~WCNOC C. Fowler WCNOC J. Clark Western Resources K. Mazacheck Western Resources

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M. Cummings Coffey Co. Commissioner R.-Wasson KCPL J. Milhoan NRC - RIV A, Howell NRC - RIV S. Collins NRC - RIV A. Beach NRC - RIV'

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C. Hackney NRC - RIV G. Pick NRC - RIV L. Myers-NRC - RIV S. Allen NRC ---RIV

- S. Black NRC - NRR W. Reckley NRC - NRR

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ENCLOSURE 2

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) MEETING WCNOC PRESENTATION TO NRC

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w DECEMB R 16,1992 WOLF CREEK EDUCATION CENTER ROOMS 125-128 1:00 P.M.

W$LF CREEK NUCLEAR OPERATING CORPORATION

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L fWCNOC SALP PRESENTATIONS l

- Introductions and Opening Remarks B. Withers

- Operations, Maintenance / Surveillance, Radiological O. Maynard Controls & Security l

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- Engineering / Technical Support

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- Quality Assurance improvements (Part of SA/QV) and R.Hagan

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Emergency Preparedness

- Safety Assessment / Quality Verification B. Withers

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NRC/WCNOC

- Concluding Remarks l

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l PLANT OPERATIONS l PROCEDURAL ADEQUACY AND COMPLIANCE

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• Root Cause of Weaknesses t

- Overall Complexity of Procedures

- Attention.to Detail Sometimes Lacking (

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- Living.with Existing inadequacies

- Not Always Using Required Procedure "In Front"

- Adherence - Use Skills and Judgmental Capabilities - But Must Be

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Controlled

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- Need Standardized Guidance - Improved Procedures, Streamlined

. Change Process & Accountability for Correctness and Adherence

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• ActionsTaken and Results Achieved to Date

- Established " Writer's Group" in Operations - Improved Coordination, Standards, Communication & Overall Effectiveness

- Incorporated INPO Guidelines on Infrequently Performed. Evolutions

- Procedure (s) "In Front" When _ Performing Evolutions

- Operations. Manager andVP Plant Operations Meetings with. Shift

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Supervisors / Crews - Stressed Professionalism, Appropriate Procedure Use and Compliance i

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l PLANT OPERATIONS l PROCEDURAL ADEQUACY AND COMPLIANCE

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eActionsTaken and Results Achieved to Date

- Emergency Operating Procedures (EMGs)

Completed Revision 3 in May 1992 - Operators Trained EMGs Were Computerized - Provides Cross-References for j

Transitions. Further Enhancements Planned

Simulator Performance by Crews improved. Post-Scenario Reviews

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' Indicate Procedures Provide Properly Sequenced Guidance

Significant Contribution During Licensed Operator Requalification I

- Improved Operation's Administrative Controls ForTemporary Change

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Notices

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PLANT OPERATIONS l PROCEDURAL ADEQUACY AND COMPLIANCE eActionsTo Betaken or Underway and Expected Results

- Revision 4 to EMGs - Major Upgrade - Complete Following Refuel VI

• Human Factors - Major Overhaul

• lmprove Documentation / Justification for Exceptions to Westinghouse Emergency Response Guidelines Enhance Criteria For Verification & Validation (V&V)

Techniques / improve Documentation

• Establish Specific Duties and Responsibilities Enhance Program Controlling Procedures - Maintenance NUREG-1358, Supplement No.1," Lessons Learned From the Special inspection Program for Emergency Operating Procedures", Utilized i

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PROCEDURAL ADEQUACY AND COMPLIANCE

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• Actions To Betaken or Underway and Results Expected

- Supervisory Monitoring of Adherence Continues

- Currentiv Planned Upgrades:

- Criteria: Technical Accuracy Programmatic issues Human Factors

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Training in Expectations lq

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- Operations: Address " Mitigation & Diagnostic" First i

EMGs & Off-Normal-Finish May 1993

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- Alarm Response - September 1992

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- Surveillance & General - January 1993

- System & Checklists - June 1993

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Overall: 1-2 Years Complete Various Stages

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PROCEDURAL ADEQUACY AND COMPLIANCE eActions To Betaken or Underway and Expected Results

- PEP Action Plan 3.3.2 - Procedures

- SCOPE: " Develop Management Expectations for Procedural Adherence,

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Provide Standardization Criteria For Procedure Writing, Provide a l

Streamlined Procedure Control Infrastructure and implement a Procedure Upgrade Program" l

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- OBJECTIVF_S-1. Improve Performance and Plant / Personnel Safety

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2. Improve Use and Usefulness of Procedures 3. Streamline Change Process & Review / Approval Adherence l

4. Accountability for Procedure Correctness and Adherence 5. Improve Interdepartmental Cooperation & Communications 6. Serve the Customers - Promote Ownership j

7. Long-Term: Significant Resource Savings - Effective Procedure l

Maintenance and Centralized of Focus l

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PROCEDURAL ADEQUACY AND COMPLIANCE

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eSoecific Goals / Deliverables:

- Matrix of Relationships

- Policy Statement & Procedure on Use and Adherence

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- Comprehensive Writer's Guide and User's Guide

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- Qualified Reviewer Program"

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- Proactive Feedback Loop j

- lrhproved Licensing Basis Screening Process

- Enhanced CommitmentTracking - User Friendly l

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- Administrative Controls Program for Governing Upgrades t

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- Procedures Upgrade

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- Training

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Schedule: 1993

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l PLANT OPERATIONS l OPERATOR INATTENTION TO DETAIL / COMMUNICATIONS ISSUES eRoot Cause of Weaknesses

- Expectations Need Continual Communication

- Use of Procedurec

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- Thinking Through Evolutions / Stopping to Resolve Problems

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- Self-CheckingTechniques Not Embraced as a Routine "Way of Life"

- Heavily Emphasized Personnel Knowledge

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- First-Line Supervision Needs to Accept Responsibility to Enforce Accountability and Expectations

- Performance Appraisals - Stress " People Skills" as Well (PEP)

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- Some Communications Lack Formality.

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l PLANT OPERATIONS l OPERATOP INATTENTION TO DETAIL / COMMUNICATIONS ISSUES

• ActionTaken and Results Achieved to Date

- Implemented " Positive Discipline" Program - Mid-1992 Individual (s) Involved Review - Develop " Lessons Learned" They Present Resu!ts to Management and Peers

• Promotes Ownership and Accountability

- WCGS Standing Order 24, Revision 5 - Issued 07/29/92

" Operations Performance Standards"

Focus on Communications

" Repeat Backs"

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' Plant Status Awareness

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Critiques - Constructive / Recognize Good Practices

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l PLANT OPERATIONS l OPERATOR INATTENTION TO DETAIL / COMMUNICATIONS ISSUES

• ActionsTaken and Results AchievedTo Date i

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- WCGS Standing Order 7, Revision 3 - Issued 09/03/92

" Discussion of-General Operating Philosophy Regarding Plant Evolutions"

Conservative Approach to Problem Solving

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" Detail Of" and "Use Of" Procedures

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Notification Control of Work Activities Technical Specification Philosophy i

eActionsTaken and Results AchievedTo Date

- Full-Time Person to be Assigned to RepresentTraining Needs Ensure Management Expectations Are Fulfilled l

Monitoring Operator Performance r

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- VP Plant Operations Holds Individual Plant Work Group Meetings

- Personalized Approach

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Emphasizing Management Expectations

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Direct Performance Feedback

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OPERATOR INATTENTION TO DETAIL / COMMUNICATIONS ISSUES

• Actions To Betaken or Underway and Expected Results

- Self-Checking Program Enhancements - Start Early 1993 l

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Simplify Process - PreviousTraining Good ButToo Many Concepts i

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AdditionalTraining Emphasize Formality - Communications and Professionalism Use MarketingTools As Constant Reminder Company-Wide Effort

- Operations Manager Meet with Cre'us & Review SALP Rpt.- Early 1993 Regulatory Awareness Ensure Areas of Weakness Addressed

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OPERATOR LOG DISCREPANCIES

• Completion of Required Watch Room Entries / Tours eManagement Fully UnderstandsThe Significance of These Potential l

Performance issues f

eQPV/PIR Written - investigations Performed, Root Cause(s) Being Evaluated and Measures to Prevent Recurrence Being identified - Due 12/31/92 j

• Human Factor Logs

'i eDiscussed Procedure ADM 02-030 Requirements with Shift Crews eQuarterly Operations Audits - Self-Assessment of Performance

- First Audit in December 1992

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AINTENANCE/ SURVEILLANCE l

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WORK CONTROLS

• Root Causes of Weaknesses-

- Overly Complex Process -Too Many Barriers

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- Less Than Effective Coordination and Communications

- Enhancements to Work Prioritization Scheme Needed

- Sometimes Ambiguous Work instructions l

- Improved.Perfortnance. indicators and Tracking for Plant Equipment Needed

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- Inattention.to Detail

- Procedural improvements Needed

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WORK CONTROLS

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• ActionsTaken and Results Achieved to Date

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- Organizational Changes - Mechanical & Electrical " Work Planning

Groups

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• Develops Uniform Process

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Improves Communications & Coordination

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• Standardized Preparation of Work Packages

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- Work Controls Procedure, ADM 01-057, Revised - includes Attachment on.

Post-MaintenanceTesting (PMT)

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• Meetings Were Conducted With Group Supervisors & SS's

• Standardized Process for Establishing Required PMT l

Uniform Evaluations-

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-INPO AssistVisit Performed

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- INPO - Coordination Batween Groups has improved

• More Effective Work Preparation Better Communication on Plant Needs

• Overall Enhancement - Interfaces with System Engineers

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WORK CONTROLS

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• ActionsTaken and Results AchievedTo Date j

- MAP Action Reviewed Plant EquipmentTroubleshooting Guidelines i

- Functional Groups Supporting Plant Operations Attend Control Room Shift

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Turnovers, Daily Morning Meeting on Plant Status, & Planning / Scheduling l

Meetings j-lmproved. Coordination Between Functional Groups l

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t Better Support of Plant Operational Needs/ Awareness

- Mechanical Coordinators Established to Review Packages for Workability, i

Parts Staging, SpecialTools, etc.

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- Brought Additional Personnel into Ma;ntenance to Work Backlogs and

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-Other.lssues Affecting Work Completion

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WORK CONTROLS t

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- PIRs Initiated 11/09/92 - PMT and Other Management Expectations Not.

Always Effectively Carried Out Efficient Communications Still a Concern-

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• Revision to. Procedure ADM 08-240," Post MaintenanceTesting"-

Expected to be issued During December 1992

- Corrective Action From ESW Low Flow - Pending Preventive Maintenance i

Activities being. Reviewed,via a PIR,for Potential Ambiguity in Work Instructions

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,

l MAINTENANCE / SURVEILLANCE l WORK CONTROLS

• Actions To Betaken or Underway and Expected Results

.

- Reliability Centered Maintenance Program (RCMP)

-

- Revised Maintenance Rule implementation Group Established: NUMARC

Regulatory Program

'

i KEY ELEMENTS:

- Develop Site-Wide Responsibility Procedure j

l

- Implement "Living Program"

,

~

- Establish _ Screening Criteria, Risk Significance Factors, and Performance

,

Goals:

'

l

-. Monitoring of Performance

~

SCHEDULE: 10CFR50.65 - 07/10/96 l

Actual Monitoring Commencing About 4th Otr.1994

,

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l MAINTENANCE / SURVEILLANCE l

I;.

WORK CONTROLS-

!

Following Refueling Outage VI - Establishment of New " Integrated Plant

!

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,

Scheduling" Group.

'

i Manager'and Supervisory Staff Identified - Experienced Personnel,

'

.

?

• Organizational / Functional Elements:

,

'

E* Coordinate Daily Work

.

.* Coordinate. Refueling, Other Outages, Long-Term (5-Year Plan)

' Work

t

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• Uniform / Coordinated Approach

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• Centralized Focus for Work Activities.

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Y.

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l MAINTENANCE / SURVEILLANCE l I-WORK CONTROLS

!

^

• Actions To Betaken or Underway and Expected Results

- PEP Action Plan 3.3.3 - Work Control Processes i

,

- SCOPE: " Analyze and Flowchart Each of the Principle Work Control l

.

!

Processes. Then Streamline Each and implement the ChangesThrough

!

!

Revisions to Procedures andTraining of Affected Personnel" l

- OBJECTIVES:

'

j 1. Improved ' fficiency

[

2. Improved Effectiveness

'

3. More User Friendly Process

4. Includes Work Requests and Supporting Documents i.

-

l 3-l

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l MAINTENANCE / SURVEILLANCE l

i WORK CONTROLS i

PEP Action Plan 3.3.3.(continued)

-

t

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- SPECIFIC GOALS / DELIVERABLES:

- Analysis of Current Process

!

-

- Root Causes of Problems / identify improvements

-

- Develop Improved Process Steps l

'

- Write New or Revised Procedures (

,

i

- Develop Feedback Process

- Train Users

,

- Computerized Work Preparation and Planning Tool ESTIMATED COMPLETION: MID-1994 j

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l MAINTENANCE / SURVEILLANCE CORRECTIVE MAINTENANCE BACKLOG / RECURRING EQUIPMENT PROBLEMS elssues Related to Work Controls eParts and Programmatic issues for Accomplishment of Work eWork Request (WR) Process l

- Each Key Element of a Job Gets a WR l

- Low Priority WRs being Re-Evaluated for Need

- Remove Non-Power Block Facilities from Normal WR Process

• Recurring Equipment Problems Concern:

- Computer Program Established

- Program to be Enhanced to Look for Similar Equipment

- Hardware Failure Analysis Report (HFAR) Process improved - Better Evaluation of Root Causes

- System Engineering - Will be initiating Detailed Program for System Performance Monitoring:

Availability Performance of Equipment Be " Anticipatory"

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l MAINTENANCE / SURVEILLANCE l SURVEILLANCE ANDTESTING ACTIVITIES PERFORMANCE

eRoot Causes:

- Concerns on Procedural Adequacy & Compliance, Attention to Detail, Prioritization and Understanding of Requirements eAdditional Personnel Have Been Assigned - Specific Area was IST Pump &

Valve Program oPIR Written -Technical Specification Violations From 1990-1992

- Experience Captured and Analyzed

- Root Causes and Corrective Actions Categorized

- Comparisons Were Made to Other Plants

- Recommendations Were Made eManagement Expectations are Clear-Technical Specifications Govern Safe Plant Operation

- Continue to Focus Attention -Timeliness & Effectiveness

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l MAINTENANCE / SURVEILLANCE l lNSERVICE TESTING PROGRAM (IST)

I eStatus of Activities Underway:

- Complete Valve Procedures Review Against NRC Generic Letter 89-04 -

Issue By 03/01/93 70 of 90 Procedure Reviews Are Done Valve Procedures being Upgraded

- Creation of an IST " Design Basis Document":

Approximately 75% Complete To be Completed by Mid-1993 l

- Establish Limits for Detecting Degradation of Valves l

Methodology has been Established Procedure By 03/01/93

- Clarification of IST Interfaces l

• Draft of Procedures Approval Scheduled for 03/01/93

- Correlation of Pump Vibration Limits with New PumpTest Data Points Have Completed Review Procedure Changes Scheduled for 03/01/93

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l l RADIOLOGICAL CONTROLS(RC)l

,

i-i l

i j

NRC SALP Report Assessment of SA/QV - Category "1" Rating

,

elmproving Trends Sustained eProvided Strong Support to the Radiation Protection Program - Recognized

.

i

AP issue #

Acti it es

- Professionalism Class Conducted for HP Personnel

'

l

- Management Monitoring of HPTechnician Performance

- Monthly HP Trend Report Was Developed -Trends and Adherence to

Program and Management Expectations have been Very Good

~

- VP Plant Operations Reiterated Management's Expectations -

.

Performance for (1) All Personnel,(2) First-Line Supervision and (3)

i

.

Health PhysicsTechnicians

'

eContaminated Areas in the RCA are Quite Low - Plant Workers Using Good Radiological Controls eVideo Presentation on Proper Work Practices - being Presented in " Radiation Worker" Training

24

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eNRC SALP Report Assessment of Security - Category "1" Rating

• Continuing Superior Level of Performance - WCNOC Management Recognizes Need to Maintain High Level Attention eNo NRC Enforcement issues

• High Quality and Effective Security Program Maintained eSecurity Systems were Upgraded

• Reporting of Safeguards Events - High-Quality Procedures were Maintained -

'

In-Depth Analysis. Conducted for Event Reports

-

• Excellent I&C Support for Security Equipment

!

ePreventive Maintenance Program in Place for Security Systems

'

• Personnel are Well Qualified and EffectivelyTrained

.

• High. Quality Security Audits were Performed

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.

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l ENGINEERING / TECHNICAL SUPPORT l l

WCNOC IMPROVEMENTS

• Enforcement History - Overall Good Performance

.

L~

eMotor-Operated ValveTesting (MOVT) Program:

l

- Restructured - Detailed, Well Proceduralized, and Comprehensive

,

i -

- WCNOC-85 Program - Significant Enhancements

- INPO Assist Visit on "MOVT" l

- Program is Aggressive and Meets Generic Letter 89-10

eNRC Electrical Distribution System Functional inspection Found Systems Design Superior

- Detailed Design Documentation Availability a Strength

!

eMaintained Strona Fire Protection Proaram:

!

- Fire Protection Coordinator f

- Procedures Well. Maintained and Followed

- Training and Equipment Well Maintained j

- Systems Surveillances Fulfilled

]

- Quality Assurance involved

?s

_

_- _-- - _ -__

_ _ - _ - _ - _ - -

_ -- -_ _

. _ - _ _

.

.

.

l ENGINEERING / TECHNICAL SUPPOR

-

.

WCNOC IMPROVEMENTS

ePlant Desian & Confiauration Controls.

l

'

- Modification and Temporary Modification Processes Effective

- Actions in Progress - Reduce " Backlogs":

Procurement Documents. Backlog Decreasing Engineering Plant Generated Documents Backlog Steady

"

,

- Improved Coordination, Planning, Scheduling and Prioritization

'

eLicensed Operator Reaualification Program:

- Significant. Resources and Management Attention Expended - Program Excellence Returned-l

- Conduct and Content of Licensed OperatorTraining and Evaluation -

Strong Initiatives were Effective & Timely

- Improvements in Examination Materials

!

i

- On-The-Job Training Thorough - Emphasized Effective Communication i

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.

.

l ENGINEERING / TECHNICAL SUPPORT SYSTEM ENGINEER PROGRAM / SUPPORT FOR PLANT OPERATIONS

-

• Qrganization Well Established and FundamentalsTraining Now Complete:

- 41 Personnel - Well-Focused Talents - Completed 10/92

'

- Day-To-Day Support of Plant Activities

- All System Engineers Completed " Fundamentals Training - 12/11/92 ewe're "In Business" Now - Group Functioning Well, Focus on immediate and Longer-Term Needs

'

• Communications With Operations -Timely and Effective

,eBroadened Global Look At Hardware Root Causes and Actions:

- HFARS Now MoreThorough j

- Trending HFARS - Continue to Refine Information

- CAP and PIRTraining has been Effective i

eContinuous Support for Operability Determinations:

KGP-1215 Procedure - Detailed Guidance & 24-Hour Response Time

,

'

ADM 05-001 Procedure:

- Follow-up Operability Reviews of Corrective Work Requests (C'#Rs)

.

- Work Request Log Reviewed for Non-Conformances

!

- Operability Review Forms Utilized i

-

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ENGINEERING / TECHNICAL SUPPORTj SYSTEM ENGINEER. PROGRAM / SUPPORT FOR PLANT OPERATIONS ePrograms and Processes Will Continue to improve:

- Systems SpecificTraining - IndividualTraining Plan Being Prepared -To Start Summer 1993

- OBJECTIVES:

1. On-The-Job Training, Classroom & Vendor Seminars 2. Design Basis, Accident Mitigation & Normal Operations Basis 3. Each System Engineer to be up on Work and Testing Activities eSystem Performance Monitoring improving:

- Focus - Unavailability & Recurring Equipment Problems

- Economic And Responsible-Trending and Reporting

- Move to " Anticipatory" Mode eCommitted to Continuous improvements:

- PEP Action Plan 3.4.1 - Systems Engineering Program

- Follow-up and Participation on Other PEP Action Plans

- Addressing Generic implications j

- Streamlining Processes, Roles & Goals

'

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ENGINEERING / TECHNICAL SUPPORT l

'

e

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INDUSTRY TECHNICAL INFORMATION nROGRAM (ITIP)

eSeveral Program Enhancements Made

• Transferred to Nuclear Safety Engineering in February 1992

-

- ITIP Coordinator Position Established

!

• Procedure, KGP-1311, UndergoneTwo Major Revisions to Refine Process elNPO AssistVisit

,

eKey Elements of ITIP Program

l

- IndustryTechnical Information Reviewed is Comprehensive

- Initial Reviews for Potential impact On Plant Safety and/or Pseliability

- CAP Documents (PIRs, RERs, etc.) Prepared as Needed i

- Due Date for initial Evaluations Siiortened to 45 Days i

- Extension Requests - Requires Escalating Management Level Approval

- Effectiveness Reviews Periodically Performed Per INPO 89-005,

" Guidelines for Use of Operating Experience"

'

- Plant Safety Review Committee (PSRC) Provides Overview

- ITIP Monthly Status Report Provided to Senior Management

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t l ENGINEERING / TECHNICAL SUPPORT

!

ITIP (continued)

~

eReview Current 50 Oldest ITIPs (>18 Months) for Potential Safety Significance and/or Plant Reliability impact - Started - 1st Quarter 1993

-

eCurrent Status: Approximately 160-170 Total Open ITIPs

Approximately 7 Overdue ITIPs Average Age for initial Reviews = 0 i

eGoals for ITIP Performance Indicators o

- Average Overdue ITIPs Have Decreased Significantly From 30.8 in 1989

'

to 7.8 in 1992

-

- Goals: Overdue - Short -Term 55

!

' Long-Term = 0

'

NSE Prompt initial Review -510 Days ePEP Action Plan 3.4.2," Training", incorporate ITIPs into Lesson Plans i

!

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l EMERGENCY PREPAREDNESS (EP)l

WCNOC E-PLAN STRENGTHS eWCNOC Management's Strong Commitment to Superior and Effective EP Program - Aggressive Actions BeingTaken to Restore to SALP "1" elmprovements Made to Emergency Response Facilities - New Plant Computer

& Terminals Installed to Upgrade Capabilities

"

• Equipment Maintained - Excellent State of Operational Readiness

elmprovements Made in. Organization - Moved Personnel and Activity Controls Onsite

• Excellent Level of Staffing and Training eDose Assessment improvements:

- Use Laptop Computers

- Personnel Responsible for Dose Assessment (e.g., Chemistry Technicians) Worked with Shift Crews on Simulator

'

- QA Surveillance was Favorable

• Strong Working Relationship with State & County

'

eScenario Committee - More Realistic Scenarios Developed

,

eSeparated Controller & Evaluator Functions

eUsed Experienced QA Auditors in Exercise u

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EMERGENCY PREPAREDNESS (EP)

_

_

E-PLAN WEAKNESSES

• Most Significant was Failure to Recognize Emergency Action Level (EAL)

Initiating Conditions

- Emergency Plan Practical" ClassroomTraining Retaught During Recent

"

Operator Requalification Training Cycle 1. Re-Reviewed Emergency Classification Procedure i

2. Crews Practiced Scenario Proficiency (

- Effectiveness Evident - Crew's Performance in 1992 Annual Exercise

- Continually Assessed During instructor Reviews

'

- Proper Classification Part of Training. Results Reviewed with Crews.

- Overall Objective: Operators Must Maintain Proficiency i

!

- Root Cause an Unclear Emergency Preparedness Procedure Step. What Censtituted a Loss of Containment Integrity.

!

!

• Protective Action Recommendations Monitored / Evaluated

eintegrated Dose Projections

'

eFacility Activation

.

• QA Surveillance Requested - Determine Effectiveness

'

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SAFETY ASSESSMENT / QUALITY VERIFICATION i

r KEY AREAS - CHALLENGES f

. CORRECTIVE ACTION PROGRAM

~

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i eSELF-ASSESSMENT PROGRAM

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EQUALITY ASSURANCE IMPROVEMENTS

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QUALITY ASSURANCE IMPROVEMENTS l

L

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einput From

- ATLAS / PEP Survey

-

- INPO

-NRC

- NUS - Haliburton eConclusion - QA Not Effectively Utilized

,

eGoal - More Effective interfaces Between QA & Evaluated Organizations i

eActionTaken

- Advanced Communication SkillsTraining for QA

-

- QA/ Group interfaces

- NSRC & it's Subcommittees

- MAP Action item-PEP

- IRG

- PIR Review Group

- IRRG

- Meeting with Operations Manager & QA Manager / Supervisors

-.

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-

.

.

l SAFETY ASSESSMENT / QUALITY VERIF L

QUALITY ASSURANCE IMPROVEMENTS i

eActions To Betaken

!

- Audited Group Feedback Form l

- Feedback Meetings - QA & Audited Groups i

[

eGoal - Expand Lise of Technical Experts

eActions Taken

- Use of Region IVTechnical Experts (Security, ER HR Rad.Env.)

- Job Rotation (Op & QA)

- Owner /Other WCNOC Personnel Used on Audits (Fire Protection)

- QA Loaned Personnel for Self-Assessments (ER Procurement, INPO

Assessment

-

eActionsTo Betaken

- Expand Use of Technical Experts (ASME, Flow Accelerated Corrosion)

- Continued QA Availability for Self-Assessments

- Continued Development of Rotation

38

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l SAFETY ASSESSMENT / QUALITY VERI QUALITY ASSURANCE IMPROVEMENTS

eGoal-Enhance Audit / Surveillance Processes

!eActionsTaken

'

- Eliminated Specific Descriptive Corrective Actions

- QPDs/QPVs Changing to PIRs

- New Audit Exit Meeting Format i

eActions To BeTcken

- Consolidation of Corrective Action Vehicles i

i

- Audit / Surveillance Process to Solicit Management Needs

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SAFETY ASSESSMENT / QUALITY VERIFICATION CORRECTIVE ACTION PROGRAM (CAP)

• Root Causes of Weaknesses

- Personnel needed more familiarity with CAP Process - PIRs

!

- CAP " Cultural Attitudes" at " Grass Roots"

- PIR Significance - Lack Adequate Assessment Criteria

- Logging & Tracking PIRs - Good Controls

- Root Cause Evaluations Often Superficial

- Corrective Actions & Independent Reviews Need improvement

- Follow-up Effectiveness Verifications not in-Depth

- Recognition of Hardware Deficiencies

'

- Handling Recurring Problems

- Lower-Tier Programs Need Coordinated

- Premature Closure of Some PIRs i

l I

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SAFETY ASSESSMENT / QUALITY VERIFICATION CAP (continued)

i

• ActionsTaken and Results Achieved to Date

- Personnel interviews and Surveys

- Major Overhaul of CAP Process - Procedures, PIRs, Root Cause Eva!uations, Significance Criteria, Effectiveness Reviews, Non-Hardware Deficiencies, Etc.

- Processes Flow Charted - Human Factors l

- Root CauseTraining Conducted - Good Mechanical and AnalyticalTechniques l

- Management Continually Encourages Use of PIRs

- Training on Procedures / Process Conducted (Approx.850 WCNOC Personnel)

l l

- PIR Review Group - Monitors Use and Effectiveness - Oversight Positive l

- Computerized Site-Wide PIR Log implemented

'

- Significance Determinations Simplified and Standardized

- Follow-up Effectiveness Verifications now MoreThorough l

- Personnel Performing Root Cause Evaluations Trained (" Qualified Reviewer")

l l

- KGP-1209," Root Cause Analysis of Non-Hardware Problems", Guidance l

l

- Overall General Acceptance Noted l

,

41 l

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SAFETY ASSESSMENT / QUALITY VERIFICATION

CAP (continued)

l eActionsTo Betaken or Underway and Expected Results

- Quality Assurance Audit Underway Assessing Performance-12/31/92 i

- Every 6 Months O.A Required to Conduct Audits PerTechnical

.

Specifications - June and December 1993 Audits will Also Evaluate the Current SALP Period

- More Simplistic in Concept - StillToo Complicated - PIR Review Group l

Looked at - Will Follow-up (also PEP)

l

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- Each Group Needs to Solicit More Assistance From QA-e.g. Flow l

Accelerated Errosion/ Corrosion Review i

- Centralized Trending - Focus on Performance - Ongoing Information Pefinements

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SAFETY ASSESSMENT / QUALITY VERIFICATION

CAP (continued)

eActionsTo Betaken or Unden.vay and Expected Results

- PEP Action Plan 3.4.5-[Non-Hardware] Corrective Actions

- SCOPE: "......lmproving the Effectiveness of WCNOC Activities Performed to identify, Evaluate, and 13emedy Non-Hardware Problems

-

and PreventThem From Recurring. Included are...... Measures Intended to improve the Use and Usability of Non-Hardware Corrective Action Mechanisms."

- OBJECTIVES:

l 1. Create a Productive Environment 2. Personnel Understand When Corrective Actions Necessary &

Sufficient 3. Problems Reported & Corrected l

4. Consolidate Existing Non-Hardware Corrective Action Programs 5. Simplify Process Overall

- ESSENTIAL ELEMENTS IDENTIFIED

- BOTTOM LINE: FOSTER IMPROVED CLIMATE & CULTURE

,

<

- Schedule: 1993 Through 1994

-

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SAFETY ASSESS VIENT/ QUALITY VERIFICATION SELF-ASSESSMENT PROGRAM

'

• Root Causes of Weaknesses

- NecessaryTechniqueTowards Continued improvements - Has Not Been Embraced By All WCNOC Organizations

- Organizational Focus Needed On Declining Performance Trends -

Timeliness and Attention to Resolution

- Procedure Developed Bu!Too Broad in Scope for Guidance Needed

- Cultural Attitudes need to Shift Regarding Usefulness l

l l

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SAFETY ASSESSMENT / QUALITY VERIFICATION

~

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SELF-ASSESSMENT PROGRAM (continued)

eActions iaken and Results Achieved to Date

- Senior Management Aware Significant and Resource issues -

Improvements to Enhance Performance (

- KGP-1205 Guidelines for Evaluating Overall Effectiveness, Efficiency and

'

Technical Adequacy of Organizational and Program Performance j

Planning & Scheduling Aspects General Methodology for Conduct Categorization of Results - (1) Strengths;(2) Weaknesses;(3)

,

Observations;(4) Recommendations

'

Reporting

- Issues Review Group (!RG) - Good Overall Management Action on Self-Assessment

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SAFETY ASSESSMENT / QUALITY VERIFICATION SELF-ASSESSMENT PROGRAM (continued)

eRecent Examples

- Radiological Controls OrganizationNendor Recently Performed "10CFR61 Practice Assessment". Covered Station Activities for By-Product Material Which is Processed, Packaged andTransported as Low Level Radwaste

.

(LLRW)

- No Major Concerns. Some Administrative Control and Procedural

!

Enhancements

- Excellent Example -Thorough Self-Assessment

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. 46

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SAFETY ASSESSMENT / QUALITY VERIFICATION

SELF-ASSESSMENT (continued)

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eRecent Examples

- Inservice Testing Program Self-Assessment By Results Engineering

- Improvement Project for Pumps and Valves

- Full-Time IST & Contractor Support

- Key Elements Reviewed:

- Daily Work Activities r

i

- Programmatic issues - NRC Audit items, Open PIRs & Administrative Procedures

- Technical Procedure Reviews

- ISTTraining

- Closecut Code issues

Leak Rate Limits

,

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Schedule: Currently Ongoing (through Mid-1993)

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471

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SAFETY ASSESSMENT / QUALITY VERIFICATION SELF-ASSESSMENT (continued)

• ActionsTaken and Results Achieved to Date

'

- InvestigationTeams Used Electrical Distribution System Functional Analysis - 4 Months

Fuel Pool Draindown Event Containment Noise Event - & Follow-up Hot Particle Investigation Reactor Water Storage Tank (RWST) Sample Boron Concentration Emergency Service Water (ESW) System Low Flow issues

• 11/10/92 Post-Scram investigation Team Reviews

- Provided Good Management Oversight & Guidance. Provided Multi-Disciplinary Reviews. Got Personnel involved in Solutions. Use of Investigation Teams Will Continue eActionsTo Betaken or Underway and Expected Results

- Development of Departmental 5-Year Plans - Self Assessment of Needs.

To Be Input into Overall WCNOC Long-Term Plan Schedule

- Self-Checking Techniques - BetterTraining/ Promotion /Use

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'

SAFETY ASSESSMENT / QUALITY VERIFICATION

,

SELF-ASSESSMENT PROGRAM (continued)

eActions To Betaken or Underway and Expect Results

- PEP Action Plan 3.2.1 ~Self-Assessment

-. SCOPE " Develop and institute a WCNOC Philosophy and Practice for t

Managers, Supervisors & Employees of Activities, Functions and Processes Performed at WCNOC. IncludingTrending, Assessment Criteria, Resources, and PracticesTo Be Used; Define WCNOC's ExpectationsTo Be Achieved...."

r

- Specific Goals / Deliverables:

- Self-Assessment Policy

-

- Revised KGP-1205; Upper-Tier Procedure

- Incident Investigation Teams - Guidelines

- Self-Checking Techniques

- Self-SALP Program

- Line Organization Self-Assessment Process Guide

- Organizational "PrideTeams"

- Mechanisms for Management Feedback, Training, Trending, and Marketing Strategy

- Schedule: 1993-1994

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.

.

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STATES

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\\UC_ EAR LEG JLATO RY

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OF

_:CENSEE 7ERFORMAhCIE (SALP)

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.

,

y WOLF CREEK NUCLEA.R OPERATING CORPI WOLF CREEK

'

GENERATING STATION.

'

SALP CYCLE 13 OCTOBER 6,1991

THROUGH OCTOBER 10, 1992 L

BURLINGTON, KANSAS-DECEMBER 16,1992

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AGENDA-

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t INTRODUCTIONS -

NRC WCNOC OPENING REMARKS JAMES L.'MILHOAN SALP PRESENTATION A. BILL' BEACH.

CLOSING REMARKS JAMES L. MILHOAN COMMENTS / QUESTIONS WCNOC BREAK

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COMMENTS / QUESTIONS PUBLIC/ MEDIA-

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EG Os V ORGAs ZA Os OmCE OF THE ADWESTRATOR ADuesTRATOR J. uumm

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DEPUTY J. WCWGOWDff

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DIVISION OF

_ DIVISION OF m or.

lJ REACTOR PROJECTS'

e sum RADIATION SAFET(.

AND SAFEGUARDS 3 DIR. 8. BEACH DIR. S. ColllNS -

DIR. 'J.- CALLAN-Om 0; mN !

DEPUTY P. GWYNN DEPUTY -J. JAUDON

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)VS 0\\ 07 REAC 0R 3RosEC~S

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O RGA s' ZA" O s DMSION OF REACTOR PROJECTS DIR.

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ECHNICAL SUPPORT CHIEF P. HARREli FORT CALHOUN l

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PROJECT SECT 10N A PROJECT SECTION B PROJECT SECTION O PROJECT SECTION D CHIEF W. JOHNSON CHIEF L YANDELL CHIEF J. GAGLIARDO CHIEF A. HOWEll.

P.E. W. SATORIUS COMANCHE PEAK COOPER SOUTH TEXAS ARK AS ONE l

(UNITS 1& 2)

(UNITS 1 & 2)

RIVER BEND (UNITS 1 & 2)

W0lf CREEK l

SRl - G. PICK RI - L MYERS l

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0FFICE OF NUCIIAR--REACTOR REGULATION

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DIR.

T. MURLEY

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ASSOC. DIRECTOR FOR ASSOC DIRECTOR FOR ASSOC. DIRECTOR FOR ADVANCED REACTORS &

INSPECTION AND:

R0JECTS LICENSE RENEWAL TECHNICAL ASSESSWENT J. PARTLOW D. CRUTCHFlELD W. RUSSELL.

'

DMS10N OF REACTOR-DMS10N of-PROJECTS 1/11 ENGINEERING

-

'

DMSION OF REACTOR ONH0

"

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DMSION OF REACTOR F CT PROJECTS lil/IV/V DMSION~OF REACTOR

.J. ROE, DIR. Ill/IV/V

-

INSPECTION-AND UCENSEE

-

PERFORMANCE.

W. VIRGlu0, ASSIST.-

- DlR. IV/V DMS10N OF RADIATION SAFETY ANDL

-

S. Bl.ACK,. DlR. IV-2 4 -

SAFEGUARDS:

W.D. RECKLEY, PROJ. MGR.--

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DMS10Nl0F SYSTEMS SAFETY AND ANALYSIS i-

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. DIVISION OF OPERATlHG.

REACTOR SUPPORT-

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i SALP PROGRA W OBJECTIVES 1. IDENTIFY TRENDS IN LICENSEE PERFORMANCE

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2. PROVIDE A BASIS FOR ALLOCATION OF i:

NRC RESOURCES L

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PERFORMANCE ANALYSIS AMAS PLANT OPERATIONS RADIOLOGICAL CONTROLS MAINTENANCE / SURVEILLANCE EMERGENCY PREPAREDNESS SECURITY ENGINEERING /TECIINICAL SUPPORT SAFETY ASSESSMENT / QUALITY VERIFICATION L

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SYSTEMATIC ASSESSMENT CF NRC APPENDIX 0516 LICENSEE DERFORMANCE Table - 2 EVALUATICH MATRI) FOR OPERATING PHASE FUNCTION AL AREAS

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t EERFORMANCE RATING CATEGORYI LICENSEE MANAGEMENT ATTENTION TO AND

-

INVOLVEMENT IN NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES RESULTED IN A SUPERIOR LEWL OF PERFORMANCE. NRC WILL CONSIDER REDUCED LEVELS OF INSPECTION EFFORT.

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PERFORMANCE RATING

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_ CATEGORY 2 LICENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT IN NUCLEAR SAFETY OR SAFEGUARDS

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ACTIVITIES RESULTED IN A GOOD LEVEL OF PERFCRMANCE. NRC WILL CONSIDER MAINTAINING

- NORMAL LEVELS OF INSPECTION EFFORT.

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PERFORMANCE RATINGL

CATEGORY 3

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LICENSEE MANAGEMENT ATTENTION TO-AND

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INVOLVENENT IN-NUCLEAR SAFETY OR SAFEGUARDS-

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ACTIVITES RESULTED IN AN ACCEPTABLE LEVEL-OF PERFORMANCE. HOWEVER, BECAUSE OF THE NRC's CONCERN THAT A DECREASE IN PERFORMANCE MAY

'

APPROACH OR REACH AN UNACCEPTABLE. LEVEL, NRCs WILL CONSIDER INCREASED LEVELS'OF INSPECTION l

. EFFORT.

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PERFORMANCE TREND

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AN APPRAISAL OF A PERFORMANCE TREND IN A

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FUNCTIONAL AREA IS USED AS -A PREDICTIVE

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INDICATOR. A PERFORMANCE TREND SHOULD ONLY BE

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USED IF BOTH A DEFINITE TREND IS DISCERNIBLE.-

EITHER IMPROVING OR DECLINING, AND CONTINUATION

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OF THE TREND MAY RESULT IN A CHANGE IN'

PERFORMANCE RATING.-

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WO_LF C_ REEK OVERALL PERFORMA3 CE SUWWARY-FUNCTIONAL AREA RATING LAST PERIOD RATING THIS PERIOD 07/01/90-10/05/91 10/06/91-10/10/92 PLANT OPERATIONS

2 RADIOLOGICAL. CONTROLS 2 IMPROVING

'

MAINTENANCE / -

SURVEILLANCE

2 EMERGENCY PREPAREDNESS'

1 DECLINING-

SECURITY I

ENGINEERING /

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TECHNICAL SUPPORT

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' SAFETY ASSESSMENT /.

-QUALITY VERIFICATION

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PLAN % OPERATIONS-

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T' CATEGORY 2L

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OVERALL PERFORMANCE WAS GOOD, MANAGEMENT OVERSIGHT AND INVOLVEMENT IMPROVED AS EVIDENCED BY A-NUMBER OF POSITIVE INITIATIVES.

STRENGTHS

GOOD LEVEL OF OPERATOR PROFESSIONALISM AND DECORUM

OPERATOR PERFORMANCE DURING ROUTINE PLANT-OPERATIONS

,

VERY GOOD HOUSEKEEPING THROUGHOUT THE PLANT

FEW CHALLENGES TO THE OPERATORS FROM EQUIPMENT FAILURES s

IMPROVEMENTS IN LICENSED OPERATOR TRAINING EFFECTIVENESS

REDUCTION IN THE NUMBER OF NUISANCE ANNUNCIATOR-ALARMS

_

CHALLENGES

OPERATOR INATTENTION TO DETAIL-RESULTING IN MINOR EVENTS AND TECHNICAL SPECIFICATION VIOLATIONS

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PROCEDURAL ADEQUACY OF OPERATING PROCEDURES.

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OPERATOR LOG DISCREPANCIES-i

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STAFFING TO SUPPORT IMPROVEMENT INITIATIVES f

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(CATEGORY 11 PERFORMANCE IMPROVED TO A SUPi:RiOR LEVEL. A SUPERIOR

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RADIATION PROTECTION PROGRAM HAD BEEN IMPLEMENTED,

,

STRENGTHS

STRONG MANAGEMENT SUPPORT TO THE RADIATION PROTECTION PROGRAM

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EXCELLENT RADIOLOGICAL ENVIRONMENTAL MONITORING,

RADIOACTIVE EFFLUENT CONTROLS, RADWASTE MANAGEMENT, AND-TRANSPORTATION PROGRAMS

. COMPREHENSIVE QUALITY ASSURANCE-AUDITS

,

-

GOOD QUALITY RADIATION PROTECTION PROCEDURES

EFFECTIVE RADIATION PROTECTION TRAINING

- *

VERY GOOD RADIOLOGICAL-HOUSEKEEPING e

LOW PERSON-REM RADIATION EXPOSURE-

EFFECTIVE-ALARA INITI ATIVES CHALLENGES

INADVERTENT RADIOACTIVE GASEOUS RELEASESL

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MAINTENANCE / SURVEILLANCE (CATEGORY 2)

OVERALL PERFORMANCE WAS GOOD. EQUIPMENT CONTINUED TO PERFORM WELL, BUT WORK CONTROL PROBLEMS CONTINUED TO BE IDENTIFIED.

STRENGTHS

OVERALL MATERIAL CONDITION OF THE PLANT IS VERY GOOD e

STRONG SURVEILLANCE TEST PROGRAM

KNOWLEDGEABLE AND QUALIFIED STAFF

GOOD IMPLEMENTATION OF THE INSERVICE INSPECTION PROGRAM CHALLENGES

IMPROVING MAINTENANCE WORK CONTROLS

ASSESSING THE INCREASING CORRECTIVE MAINTENANCE

'

BACKLOG

• RESOLVING REMAINING INSERVICE TEST PROGRAM ISSUES

IMPROVING MAINTENANCE AND SURVEILLANCE PROCEDURAL ADEQUACY BOARD RECOMMENDATIONS

ASSESS WORK CONTROL EFFECTIVENESS AND-lMPLEMENT APPROPRIATE CORRECTIVE ACTIONS

.

.. _. _

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EMERGENCY PREPAREDNESS (CATEGORY 2)

OVERALL PERFORMANCE WAS GOOD; HOWEVER, PERFORMANCE HAS DECLINED SINCE THE LAST.SALP CYCLE. MANAGEMENT DEMONSTRATED SUPERIOR SUPPORT FOR-THE EMERGENCY PREPAREDNESS PROGRAM, BUT THE FAILURE OF SOME SHIFT CREWS TO IDENTIFY EMERGENCY ACTION LEVEL INITIATING

'

CONDITIONS WAS CONS!DERED A SIGNIFICANT WEAKNESS.

STRENGTHS

EMERGENCY PLANNING ORGANIZATION ENHANCEMENTS -

COMPREHENSIVE QUALITY ASSURANCE AUDIT.

• GOOD LEVEL OF STAFFING

EMERGENCY RESPONSE FACILITIES-MAINTAINED IN AN EXCELLENT STATE OF OPERATIONAL READINESS

.

CHALLENGING EXERCISE SCENARIO

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CHALLENGES-i e

CONSISTENCY OF SHIFT CREW RECOGNITION OF EMERGENC-Y ACTION LEVEL INITIATING CONDITIONS.

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A SUPERIOR LEVEL OF PERFORMANCE WAS MAINTAINED. THE SECURITY PROGRAM WAS IMPLEMENTED BY A WELL TRAINED, STABLE STAFF.

STRENGTHS

STRONG MANAGEMENT SUPPORT

ENFORCEMENT HISTORY

SECURITY SYSTEM UPGRADES

EFFECTIVE MAINTENANCE SUPPORT OF SECURITY EQUIPMENT RESULTING IN FEW COMPENSATORY POSTINGS OF SECURITY OFFICERS

EXCELLENT SECURITY AND OPERATIONS INTERFACE

HIGH QUALITY SECURITY PLAN CHANGES

WELL TRAINED AND STABLE STAFF

COMPREHENSIVE QUALITY ASSURANCE AUDIT

______

____

_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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ENGINEERING / TECHNICAL SUPPORT (CATEGORY 2)

OVERALL PERFORMANCE WAS GOOD; HOWEVER PERFORMANCE WAS INCONSISTENT. ENGINEERING SUPPORT OF PLANT OPERATIONS WAS STRONG IN SOME AREAS, WEAK IN OTHERS.

STREAjGTHS

SUPERIOR DESIGN OF ELECTRICAL DISTRIBUTION SYSTEM

STRONG FIRE PROTECTION / PREVENTION PROGRAM

LICENSED OPERATOR TRAINING PROGRAM IMPROVEMENTS

EFFECTIVE 10 CFR 21 EVALUATIONS

STRONG SUPPORT DURING OUTAGES CHALLENGES

INITIAL RESPONSE TO GL 89-10 WAS INEFFECTIVE

FULLY IMPLEMENTING THE SYSTEM ENGINEER PROGRAM

CORRECTING OUT-OF-DATE VENDOR DRAWINGS e

REDUCTION OF THE LARGE MODIFICATION BACKLOG

CONSOLIDATION OF THE ENGINEERING FUNCTIONS ONSITE

TECHNICAL STAFF ' TRAINING PROGRAM WEAKNESSES BOARD RECOMMENDATIONS

CONDUCT INSPECTIONS IN THE AREAS OF ORGANIZATIONAL STRUCTURE, SYSTEM ENGINEER PROGRAM, DESIGN BASIS PROGRAM, AND MOD. BACKLOG.

-

_ -

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SAFETY ASSESSMENT /

QUALITY VERIFICATION (CATEGORY 3?

.

PERFORMANCE IN THIS-AREA WAS ACCEPTABLE. INCREASED INVOLVEMENT AND OVERS!GHT BY MANAGEMENT _ WERE NOTED;

.

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HOWEVER, SIGNIFICANT WEAKNESSES WITH THE SELF-ASSESSMENT AND CORRECTIVE ACTION PROGRAM WERE OBSERVED.-

STRENGIliS e

INCREASED MANAGEMENT INVOLVEMENT IN DAY-T0-DAY OPERATIONAL ACTIVITIES-e GOOD QUALITY LICENSE SUBMITTALS

'

GOOD EVALUATION OF CHANGES---TO THE FACILITY e

COMPREHENSIVE QUALITY ASSURANCE AUDITS e

IMPLEMENTATION OF ROOT CAUSE ANALYSIS TRAINING CHALLENGES o

EFFECTIVENESS AND TIMELINESS-0F CORRECTIVE ACTIONS

,

RAISING THE LEVEL OF ACCEPTANCE-0F-IMPROVEMENT INITIATIVES BY THE PLANT.

-

STAFF e

IMPROVING THE ADEQUACY AND TIMELINESS OF INDUSTRY OPERATING-EXPERIENCE REVIEWS j

_ PERFORMANCE ENHANCEMENT PROGRAM (PEP) IMPLEMENTATION e

l-

SELF-ASSESSMENT OF MOTOR-0PERATED VALVE PROGRAM l

e CONSISTENCY OF-EVENT RESPONSE BOARD REECOMMENDATIONS L

!

e

. RAISE THE LEVEL OF CORRECTIVE ACTION PROGRAM ACCEP_TANCE BY THE STAFF l-

IMPLEMENT EFFECTIVE PEP ACTION PLANS a

"

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t NEXT SALP PERIOD

SCHEDULED OCTOBER 11,1992

.

T11 ROUGH FEBRUARY 26,1994 16 MONTHS l

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ENCLOSURE 3

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.

W$LF CREEK NUCLEAR OPERATING CORPORATION January 5, 1993 Bart o W.tners WM 93-0001

%som ano CNet E accutne Othce, J. L. Milhcan, Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Reference:

Letter dated December 4, 1992 from J. L. Milhoan.

-

NRC, to L. D. Withers, WCNOC Subject:

Docket No. 50-482:

Response to Systematic Assessment of Licensee Performance Report Dear Mr. Milhoan Provided as an attachment to this l e t t e.- is Wolf Creek Nuclear Operating Corporation's (WCN0C) response to the Refereace, which transmitted the initial Systematic Assessment or Licensee Performance (SALP) report for Wolf Creek Generatin6 Station (WCGS). WCNOC is required to provide corrective actions to achieve improved performance in the Safety Assessment / Quality Verification functional area.

The Attachment to this letter provides the actions currently being taken or planned by WCNOC to improve perf or.aiace in the Sciety Assesament/ Quality Verification functional area.

As discussed at the Region IV otfice during an October 23, 1992 meeting, WCNOC is implementing the Performaace Enhancement Program (PEP).

The Attachment discusses several of the PEP Action Plans which were developed to improve WCNOC's performance in the areas of Self Assessment

_

and Quality Verification.

If you have any questions concerning this matter, please contact me at (316)

354-8831 extension 4000 or Mr. Kevin J. Moles at extension 4565.

Very truly yours,

. J Bart D. Withers President and Chief Executive Officer BDW!jan Attachment cc:

A.

T. Howell (NRC), w/a G. A.

Pick (NRC), w/a V.

D. Reckley (NRC), w/a Document Control Desk (NRC), w/a i

PO Box 411 Burlington KS 66839 Pnone 1316) 364 8831 An Esai occortunity Empicyer M F HC VET

_ _ _ _ _ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _. _

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l Attachment to WM 93-0001 Page 1 of 5 Response to NRC Systematic Assessment of Licensee Performance (SALP)

Reference:

NRC Letter dated 12/04/92 frnm J.

L.

Milhoan, NRC, tv B.

D.

Withers, WCNOC.

Wolf Creek Generating Station (WCGS) SALP Evaluation Period:

10/05/91 through 10/11/92.

Section G,

" Safety Assessment / Quality Verification * (SA/QV), of the Reference noted weaknesses in the areas of self-assessment and corrective action.

Although self-assessment was noted to have improved during the SALP period, significant prograccatic problems including motor-operated valve program weaknesses near the beginning of the SALP period contributed to a significant breakdown to the self-assessment process within WCNOC.

In the area of

--

corrective action several examples of less than adequate or untimely corrective actions ware identified.

Untimely actions to resolve long-standing essential service water system water hammer ever ts and a failure to replace a defective flow transmittec following a surveillance were cited within the SALP report.

The NRC also noted that actions to correct procedural noncompliance, inadequate procedures, and inattention to cetail were not fully successful.

WCNOC's response addresses enhancements / improvements to the (1) Corrective Action Program, (II) Sel.0 Assessment Program, (III) Quality Assurance progran, and (IV) Industry Technical Information Program (ITIP).

I.

CORRECTIVE ACTION PROGR/M:

In the previous SALP report, WCNOC was noted to be weak in tne area of corrective action.

In response to the previous SALP report WCNOC expanded the scope of the corrective action program to include any condition that could adversely effect plant performance or work activities.

This was accomplished, in part, by revising the P r og racca tic Deficiency Report to the Performance Improvement Request (PIR).

WCNOC also committed to train various levels of

_

technical staff on the corrective action program and root cause evaluations.

Approximately 850 plant personnel completed training on the revised corrective action program and the new PIR process.

Also, 142 plant personnel completed a 3 day root cause evaluation techniques course and 37 Managers attended a 1 day d

root cause course.

Performanco Enhancement Program (PEP) Action Plan 3.4.5 has been developed, in part, to further improve the effectiveness of WCNOC activities performed to identify, evaluate, and remedy non-hardware problems, and prevent them from recurring.

Although the PEP was initiated during the SALP period, significant improvements to WCNOC performance were not anticipated to occur by che end of the SALP period.

Instead, gradual, progressive change is being promoted.

The o b j e :.t iv e s of this action plan are to create an environment where identifying and correcting problems is seen as good and productive, to ensure personnel anderstand when corrective actions are necessary and s t.f f ic ient, to verify that completed actions resolve the problem, to ensure an environment where problems are reported and corrected without hindrance, and to consolidate existing ron-hardware corrective action programs to eliminate redundancies and s mplify the process.

Essential to these objectives is changing WCNOC culture and climate.

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s A t t a c hme r.t to WM 9 3 M 1 Page ! ut b TLt e igh this ;rocess af positive change WC!iOC will better ensure problems are properly self-identified, initiate u=e d i a t e remedial actions, determine the cause, extent, preventive actions and significance of the problem, implement appropriate and thorough actions, and ensure effectiveness follow-up ahl verifications are appropriate.

WC1100 anticipates this change in culture to tecume evident throughout 1993 and 1994.

Several acticns have been initiated to monitor and focus the change process and to assist acceptance of the corrective action changes by plant personnel.

A Pe r f ormance Improvement Request (PIR) review group has been established to monitor the PIR process and provide input on timeliness and ongoing corrective actions.

The Quality Asturance semi-annual torrective action audit also measures the effectiveness of the changes to the corrective action program, These audits have provided feedback concerning the progress these changes are ru k i n g a s, well as areas for improvement where greater management attention is tequired.

It was recognized through these audits, and flRC inspection activities, that some plant personnel have shown a reluctance to change, Management's expectations have been made clear on the need for change.

II.

Self-Assessment Programt It was noted in the previous WCGS SALP report that areas of weakness were apparent wit h WC!iOC 's self-assessment program.

WC!l0C management understands

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the need for acceptable self-assessment capabilities and the need for

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!=provement in tnis area.

It has bean observed by mansgement that all WCliOC organizations have not fully embraced the benefits of and/or necessity for fully effective self-assessment techniques.

It is also realized that at t ent ion must be focused on declining performance trenos such as timeliness and attention to resolution of problems.

Procedur ; guidance has been developed to aid WC!iOC in sei!-assessment, but it has been determined that these procedures are currently too broad in scope to be fully effective, It was also determined that cultural attitudes are less taan desired for management's expectations to be fully effective regarding the use' u.ne s s of the selt-assessment program.

Several actions have been initiated to enhance this performance.

These improvements include raising management's awareness of significant issues, establishing investigatio-teams for signiffcant events.

developing leng-term objectives for self-checking techniques, and following goals ret by PEP.

In respense to the previous SALP report, specifically addressing self-assessment weakne sses, WCt40C cocunitted t o develop a company-wide procedure f or selt-assessment.

Cn March 30, 1992, KGP-1205, 'Self Assessment Process", was issued.

P.SP-12C5 provides some guidance towards evaluating overall ette;tiveness, etficiency, and technical adequacy of organizational and progran performance The initiation of this procedure was intended to allev

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Attachment to WM 93 0001 Page 3 of 6

4 organizations to better understand what weaknesses are evident prior to a

significant problem arising.

These problems could then be directed to l

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management's attention.

The issues Review Group (IRG) was also developed to ensure appropriate management oversight is given to more significant industry and WCGS events.

Through the IRG a designated lead _ person is selected to take

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direct responsibility of identified problems or areas requiring action.

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Another enhancement to the self-assessment program was initiated during the SALP period.

Thi was to initiate an investigation team upon discovery of potentially significant events or other events of generic interest / concern.

The purpose of these teams is to determine root cause and contributing factors of the event, and establish corrective actient Recent examples of the use of

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these teams are the spent fuel pool drain dcva event, the containment ' noise *

event, and essential service water system low flow event.

The advantages of-utilizing an investigation team are that a multi-disciplinary group of individuals is being utilized, it allows personnel to get involved with plant events, and it provides good management oversight and guidance into the i

investigation.

The use of investigation teams will continue in the future.

PEP Action Plan 3.2.1,

• $ elf Assessment *, has been developed to promote ownership and accountability for the resolution of issues, which is expected to result in potentially significant cost savings and _ create safer, more efficient plant operation and organizational performance.

This PEP Action Plan defines WCNOC management expectations, and will establish - trending,-

assessment criteria, and practices to be used during self-assessment.

Meeting these specific goals will not only provide a uniform method for improving WCNOC performance, but it will also provide management feedback'on_ progress in self-assessment capabilities.

Several specific goals of PEP Action Plan 3.2.1 are to create a VCNOC self-assessment policy, to revise and enhance upon the guidance in KGP-1205, provide guidelines for investigatian teams, further define self-checking techniques, initiate a self-SALP program, and establish

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self-organizational evaluation processes, i

i III. Gunlity Assurance Imp _rovemen t s :

I Improvements in the SA/QV SALP functional area are also being implemented through enhancements to the Quality Assurance. program.

To identify where improvements could - be made to the Quality group and where areas of weakness are evident. WCNOC has compiled pertinent information from outside and within the company.

Through the recent PEP survey, - using ATLAS, INPO assistance visits. NRC inspection activities, and Haliburton NUS Corporation, it has been concluded that the WCNOC Quality Assurance _ group has not been - ef fectively utilized.

Goals have been developed to make - Quality Program - and - group improvements.

As discussed below soveral of these goals involve-- more effective communica tion,--- the expanded use - of technical: experts,-enhancing-the Audit and Surveillance processes, and-increasing the general level of solicitation of QA by other groups in resolving concerns.

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Elf ec tiva communicatic,n is essential between the Quality Assurance group and

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evaluated organizations.

This communication involves not only face-to-face speaking and listening skills, but also interfacing with the different quality

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verification groups.

In an effort to better improve communications skills within the Quality Assurance group, communication skills training has been

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provided for their members. Also. Quality Assurance has representatives in the

Management Action Plan (MAP). PEP. Issues Review Group (1RG). Performance

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improvement Request (PIR) review group, and the Inspection Report Review Group (1RRG).

The Quality Asserance group is initiating better feedback mechanisms.

These include meetings and personal interviews to obtain feedback from the evaluated groups.

To obtain this feedback an effectiveness form is being developed.

The purpose of this form is to collect information from evaluated groups to grade the effectiveness of the evaluation and of the auditors themselves.

WCNOC is confident that these efforts will increase Quality

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Assurance communications skills and awareness, as well as more effectively utilire QA skills throughout WCNOC.

t lt is realized that. although the Quality Assurance group consist s-of a -vide

variety of knowledgeable staff, there are situations where greater technical

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expertise is required.

The Quality Assurance group has previously utilized technical experts from other Region IV utilities in assisting VCNOC auditors.

This practice has met with considerable success as was demonstrated in the

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areas of Security. Emergency Preparedness. Health Physics, and Radiological

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Environmental Monitoring.

Not only will other utilities be utilized - to provide technical experts, but VCHOC personnel outside of the audit group are also being utilized for their technical expertise.

This assistance will be accomplished through, for example, a member of the operations group being assigned to the Quality Assurance group for a period of time.

Also. personnel outside of Quality Assurance will participate in audits.

This approach not _only provides the Quality group greater knowledge during evaluations, but it allows those. participating to better understand their jobs from a different perspective.

Quality Assurance also provides assistance in performing self-assessment for other groups within VCNOC.

Quality Assurance-personnel have previously been ' loaned".to other - departments to assist - in self-assessment.

Quality Assurance will continue to make themselves available for these self-assessments.

i Significant programmatic enhancements are also being made in the Quality Assurance area.

Recommendations have identified the need for these changes, which include eliminating specific descriptive corrective actions in audit / surveillance reports, and QA utilizing. PIRs to document findings, thereby eliminating the use of Quality Program Violations (QPV) and Quality Program Deviations (QPD).

This consolidates corrective action vehicles and

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reduces redundancy.

One other recent improvement was the change'in format to QA audit exits.

Near the beginning of'the SALP. period Quality Assurance exit

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Attachment to VM 93 0001 Page $ of 6 meetings were consolidated.

One exit meeting is held for all audits conducted during the month.

This practice allows greater management attention by providing less difficult exit attendance schedules.

Another change has been to the meeting formats to include the results of monthly Quality surveillances.

A short summa ry of Surveillance results is usually provided during the monthly exit meetings which has increased management and personnel t

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awareness, and the effectiveness and resolution of issues.

IV.

Industry Technical Infor1nat ion Prostramt In the Reference the NRC stated that *several weaknesses were identified in the area of review adequacy and timeliness of actions taken to resolve industry concerns."

Industry operating experiences are assessed by the Industry technical Information Program (ITIP).

In February 1992, the ITIP was-transferred to Nuclear Safety Engineering.

Several enhancements to the ITIP.

including programmatic improvements, procedural changes, and development of i

group goals, are fully expected to further improve performance in this

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important area.

The ITIP coordinator is responsible for oversight of the ITIP process, initial ITIP reviews, assignment of responsibility, and reviews for adequacy of evaluations and actions taken.

Other programmatic changes include shortening the initial response date for assigned organizations to 45 days. and requiring

requests for extensions in due dates for activity / evaluation completion to be-

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escalated to higher management levels for review and approval.

Procedure KGP-1311

' Industry Technical Information Program *, has undergone major revisions to enhance user understanding of the ITIP process and to identify the appropriate interfaces.

This procedure provides for periodic program effectiveness reviews in accordance with INPO 89-005, ' Guidelines for

Use of operating Experience'.

These reviews monitot and evaluate program success in attaining pertinent objectives, such as to prevent similar industry events at WCGS, ensure all relevant issues are addressed, and make recommendations for improvements to the program.

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Having established ITIP goals should also continue to increase the overall

program ef f ectiveness.

Several of these goals include a current - ef fort to I

review the 50 oldest ITIPs (which are greater than 18 months - old) for potential safety significance and plant reliability impact. an effort to

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reduce the number of open INPO Significant Operating Experience Reports (SOER)

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recommendations, and the ' establishment of overdue limits and initial ITIP l

review timeframes.

Some of the benefits of these changes can already be senn.

l One example is the reduction of average overdue ITIPs from 30.8 in 1989 to 7.8 in 1992.

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A t t a ; h:r.e n t ta WM 93.D001 P a..e d at 6 conclusionsi

!t should be understood that the improvements being made to these areas are dynsmic in nature and will likely evolve with time and e x pe r i e r.c e.

As discussed between WC!40C and the !4RC, quarterly status meetings on PEP are planned and the Resident Inspectors will be informed of PEP activities on a routine basis as required.

Several concerns were identified on the cover letter and within the text of the Reference that workers are reluctant to initiate PIRs and corrective actions are not timely.

The status of actions addressing these specific areas will be discussed in the first 1993 quarterly

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status meeting.

WCtJOC personnel irom the working level through Senior Management haves (1)

utilized the Corrective Action Program (CAP) process /PIRs to a much larger extents (2) determined the overall CAP process will continue to be enhanced and simplified as appropriate; (3) recognized that timely and effective utilization of self-assessment techniques are a cornerstone to continued self-recognition and resolution of problems; (4) implemented various improvements to the QA program / process and the group that will continue to embrace overall organizational performance betterments; and (5) changed the ITIP process to focus on timely completion of reviews and proper trending techniques.

WCtJOC is coamitted to continued improvements in the SA/QV SALP functional area.

Our goal is to achieve excellence and superior levels of performance in SA/QV.

As noted by the !!HC during the December 16, 1992, liRC/WC!iOC SALP Public Meeting.

• recognition" is the first big step towards effective change.

The many SA/QV

programs already put in place at WCGS and the PEP efforts underway, are fully expected to move WCt100 performance towards the "best in class".

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