ML20086B992

Submits Proposed Change to Operational QA Program for Review & Approval.Change Provides Alternative Method for Complying W/Requirement to Review Procedures Biennially

ML20086B992
Person / Time
Site:	Wolf Creek
Issue date:	06/28/1995
From:	Hagan R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ET-95-0059, ET-95-59, NUDOCS 9507060224
Download: ML20086B992 (7)

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W$LF CREEK NUCLEAR OPERATING CORPORATION Robert C. Hagan June 28, 1995 vice Presusent Engineenng ET 95-0059 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station: P1-137 Washington D. C. 20555 i

Subject:

Docket No. 50-482: Biennial Review of Plant Procedures Gentlemen:

In accordance with the requirements of 10 CFR 50.54 (a) (3), Wolf Creek Nuclear Operating Corporation (WCNOC) is submitting a proposed change to the Operational Quality Assurance program for review and approval. The proposed <

change provides an alter.iative method fer complying with the requirement to l review procedures biennially. Pursuant to 10 CFR 50.54 (a) (3) , this change has l been evaluated by WCNOC and has been determined a reduction in commitments ,

made in the approved Quality Assurance Program.

The intent of the biennial review is accomplished by other programmatic controls which make the biennial review redundant. Consistent with recent NRC and industry initiatives to reduce regulatory burden, WCNOC proposes to modify l the commitment to perform biennial reviews as described in the attachments to ,

this letter.

Attachment I provides a mark-up of the affected Updated Safety Analysis Report pages. Attachment II provides an evaluation and discussion of the proposed  ;

changes. In accordance with 10 CFR 50.54 (a) (3) (iv) , WCNOC plans to implement these changes following receipt of an NRC letter indicating acceptance or 60 days after the date of the submittal. If you have any questions concerning this matter, please contact me at (316) 364-8831, extension 4553, or l Mr. Richard Flannigan, at extension 4500. l Very truly ours y

Robert C. Haga RCH/jra Attachments cc: L. J. Callan (NRC) , w/a D. F. Kirsch (NRC) , w/a J. F. Ringwald (NRC), w/a J. C. St'ne o (NRC), w/a 9507060224 950628 PDR ADOCK 05000482 P PDR 0300 E'? e o Bo 4 ' B"riiaotoa. xs ee839 ' eaoae: <3'e> 364-883i An Equal Oppo'tunity Employer M/F/HC/ VET / p 1

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j Attdchment I to WM 95-0082 Page 1 of 2 WOLF CREEK REGULATORY GUIDE 1.31 REVISION 3 DATED 4/78 Control of Ferrite Content in Stainless Steel Weld Metal DISCUSSION:

The-recommendations of this regulatory guide are met as described in Table 6.1-9.

REGULATORY GUIDE 1.32 REVISION 2 DATED 2/77

. Criteria for Safety-Related. Electric Power Systems for Nuclear Power Plants DISCUSSION:

The recommendations of this regulatory guide are met. Refer to Sections

' 8.1.4.3 and 8.3.2.2.1.

REGULATORY GUIDE 1.33 REVISION 2 DATED 2/78 Quality Assurance Program Requirements (Operation)

DISCUSSION:

ANSI N18.7-1976, which is endorsed by Regulatory Guide 1.33, requires a biennial review of safety-related procedures. Section 5.2.15 of ANSI N18.7-1976 requires in part that plant procedurer be reviewed no less frequently than every two years. Wolf Creek Nuclear Operating Corporation (WCNOC) has determined that programmatic controls exist which are equivalent to or are more effective in meeting the intent of the standard than the static, fixed biennial review process. The alternative method implements a performance-based process for assuring procedural adequacy by initiating procedure reviews, changes or revisions based on a new or revised source material. The revision controls do not consider age as a requirement for procedure reviews.

WCNOC utilizes alternative programmatic coni.rols to ensure procedures are accurate.

The controls already in place to accomplish the alternative commitment include the design change process; the Industry Technical Information Programs the procedure feedback process; the corrective action programs the Quality Evaluation programs and the self assessment program. Procedures which are not used or revised within two years are reviewed biennially or reviewed

- before use. Procedures are in place which require a review of all applicable plant' procedures following an unusual incident, such as an accident, an unexpected-transient, significant operator error, or equipment malfunction.

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Att$chment I to WM 95-0082 Page 2 of 2 j l

These programs collectively provide procedure reviews equivalent to or exceeding the requirements of ANSI N18.7-1976, Section 5.2.15.

The Quality Evaluation program is structured such that a random sampling of l procedures is audited every two years to determine the effectiveness of plant l procedurec. Procedure effectiveness, as well as procedure usage, is evaluated during the performance of all scheduled audits and surveillances. The Quality Evaluation review will ensure that the procedure review program and the Qualified Reviewer process continues to be effectively implemented.

The alternative program, to ANSI N18.7-1976, Section 5.2.15, does not apply to the Emergency Plan Implementing Procedures which are used by amargency ]

response personnel, nor does it apply to Emergency Operating Procedures and i Off-Normal Procedures. These procedures will continue to be reviewed very two years.

The recommendations of this guide and the ANSI Standards listed in Table 17.2-3 are met except where specific alternatives are indicated. The provision to automatically incorporate the latest issued ANSI standards as set out in the last paragraph of ANSI N18.7 is not adopted.

REGULATORY GUIDE 1.34 REVISION 0 DATED 12/72 Control of Electroslag Weld Properties DISCUSSION:

Electroslag welding is not used for items within the Bechtel scope of supply.

Where electroslag welding is used in fabricating nuclear plant components, the Westinghouse procurement practice requires vendors to follow the recommendations of Regulatory Guide 1.34.

DRAFT REGULATORY GUIDE 1.35 REVISION 3 DATED 4/79 Inservice Inspection of Ungrouted Tendons in Prestressed Concrete Containment Structures 1

3A-2 Rev. XX l

1 Attachment II to WM 95-0082 Page 1 of 4 ALTERNATIVE TO ANSI N18.7 BIENNIAL REVIEW

Background

Wolf Creek Nuclear Operating Corporation is committed to Regulatory Guide l 1.33, ." Quality Assurance Program Requirements (Operational) . " Regulatory Guide 1.33 endorses ANSI N18.7-1976/ANS 3.2, " Administrative Controls and Quality Assurance for Operational Phase of Nuclear Power Plants." ANSI N18.7,  ;

Section 5.2.15, prescribes a biennial review of each safety-related plant procedure, "to determine if changes are necessary or desirable." The biennial review is intended to ensure plant operating experience, industry experience,  ;

and recent technical information is factored into plant procedures.

Regulatory Guide 1.33 permits the licensee to propose an acceptable ,

alternative method for compliance with the biennial procedure review  ;

requirement.  ;

Alternative In lieu of performing the biennial review of all procedures, Wolf Creek i Nuclear Operating Corporation proposes to: 1) utilize existing programs th t '

will cause procedures to be revised, and 2) continue performing a biennial review of non-routine procedures such as Emergency Operating Procedures, Off- l Normal Procedures, and Emergency Plan Implementing Procedures used by emergency response personnel. Those procedures which are not performed on a  !

less than two year frequency will either continue to be reviewed on a biennial basis or will be reviewed before use. As part of existing audit activities, a ,

L selection of WCNOC quality program procedures are reviewed to ensure procedures are being maintained.

Evaluation j I

The Wolf Creek Generating Station plant procedures which are used at least [

once every two years will be excluded from the mandatory biennial review l requirement. Emergency Operating Procedures, Off-Normal Procedures, and  !

Emergency Plan Implementing Procedures used by emergency response personnel, [

will continue to be subject to biennial review requirements. Procedures not  !

performed at least once every two years will continue to be subject to the  ;

biennial review requirements or will be reviewed before use. A procedure revision for these procedures constitutes a biennial review.

t Numerous programmatic controls have been established by Wolf Creek Nuclear {

Operating Corporation that accomplish the intent of the biennial review.

These controls ensure that procedures are appropriately reviewed and revised to incorporate information based on plant operations, design changes, vendor recommendations, regulatory requirements, corrective actions, industry ,

experience, and other conditions that may impact plant procedures. The controls are sufficiently comprehensive to ensure required procedure changes are timely and accurate. Performing biennial reviews in addition to these controls is redundant and requires plant resources to perform. Most plant procedures used at Wolf Creek Generating Station, which are used at least once every two years, will be excluded from the required biennial review. Tha

4 l Attachment II to WM 95-0082 i Page 2 of 4 following discussion identifies specific Wolf Creek Nuclear Operating 1 Corporation programmatic controls, already in place, which require an assessment of impact on procedures, l

{ Procedure Requirements and Review The emphasis of procedure controls is that WCNOC personnel are responsible to  ;

ensure procedures used in performance of their assigned activities _are ,

technically correct, useable, and include the necessary requirements to j accomplish the activity in a safe manner.  :

l e- Procedure AP 15C-002, " Procedure Use and Adherence," contains the following j statements which assure personnel provide input to keep procedures current  ;

and relevant ,

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1) All personnel provide feedback to appropriate supervisors on ,

procedure problems and assist as necessary in resolving them. '

2) All personnel evaluate procedure problems and ensure appropriate  ;

corrective measures.  !

3) All personnel evaluate procedure problems and ensure appropriate  ;

corrective measures are taken prior to and during performance of j these documents.

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• Procedure AP 15C-001, " Preparation, Review, and Approval of Documents,"

requires an individual trained and qualified as a Qualified Reviewer to be ,

responsible for the review of the procedure, ensuring technical adequacy, j and inclusion of program requirements. This process includes a cross-disciplinary review which may include individuals outside the Responsible Manager's organization. The cross-disciplinary review assists in the .

essurance of the technical adequacy and usability of the procedure. '

Procedure AP 15C-004 requires procedures to be reviewed following an l unusual incident, unexpected transient, significant operator error, or equipment malfunction which were being implemented at the time of a significant plant event. This review is performed to determine what impact ,

the procedure had in relation to the cause of the event. Problems are l documented through the corrective action program. Revisions are incorporated, if necessary, to correct any procedural inadequacies.

t The Quality Evaluation program is structured such that a random sampling of procedures is audited every two years to determine the effectiveness of )

plant procedures. Procedure effectiveness, as well as procedure usage, is '

evaluated during the performance of all scheduled audits and surveillances.

The Quality Evaluation review will ensure that the procedure review program and the Qualified Reviewer process continues to be effectively implemented.

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Attachment II to WM 95-0082 Page 3 of 4  ;

Design Change Process  !

• Procedure AP 05-001, " Permanent Modification Planning and Implementation,"

requires personnel reviewing the modification change package to identify j programs, procedures, and training lesson plans which require revision as a ,

result of the change package and to ensure the necessary changes are l incorporated. This ensures the proceduret. are current with the plant j configuration as a result of modifications.

Corrective Action ,

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• The Wolf Creek Nuclear Operating Corporation Corrective Action Program is I implemented and governed by procedure KGP 1201, " Corrective Action." This {

procedure provides the methodology for performing corrective action and is used to evaluate and correct hardware non-conformance and non-hardware j problems. Through the provisions of this procedure, Performance j Improvement Requests are generated to document problems, evaluate the l problems, and to implement corrective actions. Performance Improvement  ;

Requests are trended and adverse trends are analyzed and reported to }

management. Effectiveness Followup Reviews are performed to ensure the l corrective actions are effective in preventing recurrence of the problems. 9 The corrective action program necessitates procedure reviews in resolution l of many non-hardware problems identified through the Performance t i

Improvement Request process. ,

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• The Industry Technical Information Program provides for the review and l analysis of technical information to ensure industry lessons learned are i translated into actions to improve the safety and reliability of Wolf Creek  !

Generating Station. This program requires a Performance Improvement Request to be generated for all incoming Industry Technical Information  ;

Program documents.

Self-Assessment Program l l

• Procedure AP 28D-001, "Self Assessment Process," provides requirements and l I

guidelines for the performance of self assessments in order to evaluate the effectiveness of organizational processes and/or program performance. The self assessment is an evaluation to determine the effectiveness of a program, process, procedure, or activity. Self assessments are performed with an approved self assessment plan which identifies purpose, scope, methodology, and schedule. Copies of the self assessment plan are provided to management. Performance of the self assessment includes observations, document reviews, and interviews as the main methods of gathering information. Self assessment focus is both performance based and compliance based. The final salf assessment report is approved by the appropriate manager and distributed to the appropriate management personnel. The self assessment process involves the review of procedures associated with the area that is being assessed. The Performance Improvement Request is used to document identified problems and to track the resolution to completion.

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Attachment II to WM 95-0082 Page 4 of 4 Conclusion Based on the above evaluation, adequate controls are already in place to ensure the timely and accurate review of Wolf Creek Generating Station procedures. Modifying the requirements for the biennial relevancy review will not affect the ability of Wolf Creek Nuclear Operating Corporation to protect the health and safety of the public.

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