ML20083A024
| ML20083A024 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/30/1991 |
| From: | Rhodes F WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20083A022 | List: |
| References | |
| ET-91-0158, ET-91-158, NUDOCS 9109240005 | |
| Download: ML20083A024 (3) | |
Text
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WMF CREEK NUCLEAR OPERATING CORPORATION Forrest T. Rhodes August 30, 1991 vie. e m.oeni engm nng a t.cnn.co serv.ces ET 91-0158 Kr. R. D. Martin, Regional Administrator U. S. Noclear Regulatory Co= mission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011
Subject:
Docket No. 50-482:
Operational Quality Assurance Program Changes Pursuant to 10 CFR 50.54(a)(3)
Gentlemen:
This letter documents Wolf Creek Nuclear Operating Corporation's (VCNOC) conclusion that the attached proposed changes to the Wolf Creek Generating Station Operational Quality Assurance Program do not involyw a reduction in cocmitment s.
Therefore, the proposed changes may be implemented without prior NRC approval in accordance with 10 CFR 50.54(a)(3).
This conclusion was discussed with Mr. W. M. McNeill, NRC, on August 27, 1991.
Mr.
Mc!!aill indicated that NRC Region IV had concurred with VCNOC's assessment of the j
proposed changes.
]
On the basis of the evaluation of the proposed changes pursuant to 10 CFR 50.54(a)(3),
10 CFR 50.59 and discussions with NRC Region IV, VCNOC will incorporate the proposed changes into the Operational Quality Assurance Program according to existing procedures.
If you have any questions concerning this matter, please contact me or Hr. H. K. Chernoff of my staff.
Very truly yours, 6
Forrest T. Rhodes h9240005910913 Vice President ADOCK oso 2
Engineering & Technical Services P
FTR/jra cct I. Barnes (NRC), w/a L. L. Gundrum (NRC), w/a A. T. Howell (NRC), w/a V. H. McNeill (NRC), w/a W. D. Reckley (NRC), w/a Document Centrol Desk (NRC), w/a PO. Box 411 Bur 4ngton, KS 66839 / Phone (316) 364 8831 An Ecuas Coportunity Ernosoy.e MF HCVET
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Attachment to ET 91 0138
-Page 1-of 2 7-Revision B Date 8/23/91 17.2.16 CORRECTIVE ACTION 17.2.16.1= Scoce
- Corrective action control measures have been established to assure that conditions adverse to quality are promptly identified, reported and corrected. When _necessary, corrective action includes actions to preclude recurrence and any-mesessary follow-up verification. performed.--Carreetive action-is-neessaary-to-servest-emissiens-sad-probless-in-the-Operating Quality-Program, Corrective _ actions associated with the resolution of hardware related nonconformance reports and audits /surveillances and programustie/presedural-findings are processed in accordance with Sections 17.2.15.and 17.'2.10, respectively.
Significant condition = adverse to quality which impede the-implamentation or reduce the effectiveness.of the QA program are identified and documented in accordance.with approved procedures.
Procedures provide instructions for
-identifying, reporting, documenting, and initiating corrective action to preclude recurrence of significant adverse conditions.
These conditions are reported:to appropriate management, evaluated, documented, and corrected.
The PSRC _ reviews all significant adverse conditions adverse to quality identified at the plant._and recommends corrective-action on significant conditions adverse to'cafety regarding operating procedures.
Significant adverse conditions are docussented by measures described herein. a, tiek These conditions may include-an-isolated a-gross noncompliance with to procedural requirements, a recurring condition for-whiek where past corrective actions has have been ineffective, significant adverse nonconformance or noncampliance trends, or significant operating Quality Program deficiencies.
are-desumented-by-measures-deseribed-herein, Corrective Action documents which may be-used to identify significant conditions adverse to quality are Psegrammaatie-Defisioney-Reporte-f PDRs) Performance Improvement Requests
. (:PIRs). Quality: Program Violations (QPVs)._and Corrective Action Requests ECorrective Action for significant conditions adverse to quality
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(CARS)._
shall-assure ensures the elimination of the causeiof the conditions and provide-for. includes provisions that-ensure for ensuring that corrective actions are not inadvertently nullified =by subsequent actions.
17.2.16.2 Programmatie-Defieleney-Repera-fPDR) Perfo = =ce h ovement Recuest-(PIR)L PDRs-may-be-FIta are used'by any-plant personnel to document programmatie-er preeedural-eenditions nonhardware problesas adverse to quality.
PDRt P7Rs are evaluated by-the-Responsible-Kanager for validity, potential-
.reportability, potential applicability to other organizations,reet-eause-and l'
planned-eerreenive-setien-to-preelude-weeuvrenee, significant' recurring trends and the potential impact-to plant operability. The Responsible-L Manager is-responsible-to-ensures.that the corrective actions has-been eempleted,-verified,-and-assepted.--PDRs addressing NRC violations, LERs or j
other significant conditions. adverse to quality resolve an-independent g
review-ef-the-planned-servestive-aetion.--Additionally,-the-Responsible l
L Ma na g e r-d e t e rmine s -i f - f ellow-up-v e r i f ie nt ion-t o-ensu r e - t he -adequa e y-e i '
serreesive-astien-Laplementation-is-applisable, include-root cause determinations a-plan of action based on root cause, which includes action
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Attachm:nt to ET 91-0138 Pago 2 of 2 to preclude recurrence, and a scheduled completion dates an independent review of the action plan to ensure that the correct.ive action will be adequate sad an independent follow-up to determine if the corrective action was ef fective.--This-ilndependent reviews of-planned-sorrestive-aetion-and, when-app 14eable,-the and follow-up verificatien-is are performed by an individuals assigned by the Responsible Manager but who is were not responsible for implementing-the corrective action plan or corrective action implementation, respectively.
Prior to closing a PIX which required corrective action, the Responsible Manager ensures that corrective action was conspleted and accepted.
PDRs PIls are processed to the Quality Assurance Division for review, analysis,-and-the-Adentification-of to identify trends in quality pe rf orna nce.
These trends shall-be are reported to the appropriate levels of management and the Chaitaan of the NSRC.
17,2,16.3 Quality Program Violation (OPV)
QPVs are-may be used by the Quality Assurance Divisien to document both adverse-eendition-to-qualisy-and significant conditions adverse to quality identified during the audit / surveillance proceso.
Responses to QPVs are made by the audited organization using PDRs PIRs as described above.
!n addition, the Quality Assurance Division evaluates the completed corrective action for adequacy and performs follov.up verification to ensure corrective action has been implemented effectively.
17.2.16,4 Corrective Action Report Request-(CAR)_
CARS may-be are initiated to correct significant conditions adverse to quality which could not be corrected by other corrective action desumente means.
CARS are initiated by the Quality Department and CARS are transmitted to the Responsible Manager who identifies the cause(s) of the deficiency and, based on the root canse, specifies the action (s) necessary to correct the condition (s) te-eliminate-the-reen-eausets)-te and prevent recurrence.-and-provides-es-initiates The Responsible Manager ensures that the corrective action is impla= anted.
A PDR PIE is used by the Responsible Manager to document his the root cause determination, the corrective action plan and impirinentation and vesification the follow-up activities.
Th e -Qu a li t y -De p a r tmen t - e l e s s e - CARS - by -v e r i f yin g - the -impl eme n t a t i e n-and adequaay-of-servestive-astion, Clomeout of CAna by Q& is accomplished as promptly as practicable but occurs only after the implesmentation effectiveness of the corrective action has been verified. The Quality Department periodically preparee summaries of CARS and submits them these an=== ries to the NSRC and appropriate levels of management.
i Closecut-of-CARS-by-QA-le-assemplished-ae-promptly-as-practiemble-but-securs only-af ter-the-ef f eetiveness-of-the-sorreesive-aation-taken-has-been verified --Cerveenive-astien-ineludes-the-remedial-assion-nesessery-to l
s e n s e e t -the-d e f ie l ena y-a s-well-a s -m e tiens -ne e s s s a ry-t e-p r o elud e-r e su r r ens e.
l The-nature-es-the-defielemey-may-be-sush-that-remedial-setiens-must-be-taken imm e d i a t e l y, -howev e r, -d e ve l o pme n t, - imp l emant a t i o n-and -d e t e rmi na t i o n-o f - t h e effectiveness-ef-aetiens-to-preatudo-resurrenee-may-take-substantially lenger,