ML20086S270
| ML20086S270 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/26/1995 |
| From: | Carns N WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-95-0117, WM-95-117, NUDOCS 9508010167 | |
| Download: ML20086S270 (7) | |
Text
.
' I W$LF CREEK
~
NUCLEAR OPERATING CORPORATION Neil S. " Buzz" Carna July 26, 1995 Cha rman, President and Chsef Executive Officer 2
i U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station P1-137 Washington, D.
C. 20555
{
Reference:
Letter dated June 30, 1995, from T. P. Gwynn, NRC/RIV, to N.
S.
Carns, WCNOC (Inspection Report 50-482/95-07)
Subject:
Docket No. 50-482: Reply to Notice of i
Violations 50-482/9507-02 and 9507-05 Gentlemen:
Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC's) reply to Notice of Violations 50-482/9507-02 and 9507-05.
Violation 9507-02 concerned two examples of WCNOC's failure to adequately evaluate plant modification packages.
Violation 9507-05 concerned a failure to document concerns regarding deficiencies in a calculation package.
WCNOC's response to these Notice of Violations is in the attachment to this letter.
If you should have any questions regarding the responses, please
-l contact me at (316) 364-8831, extension 4000, or Mr. William M. Lindsay at extension 8760.
Very truly yours,
<W' Neil S.
Carns
_j l
NSC/jad i
E Attachment cc:
L. J. Callan (NRC), w/a T.
P.
Gwynn (NRC), w/a D'.
F. Kirsch (NRC), w/a J. F. Ringwald (NRC), w/a J. C. Stone (NRC), w/a l
'(
9500010167 950726 I
PDR ADOCK 05000482 O
[ Of PO Box 411/ Burlington. KS 66839 / Phone: (316) 364-8831 An Equal Opportunity Employer M F/HC/ VET
'II j
Attechment to WM 95-0117 Page 1 of 6 4
Reply to Notice of violation 50-482/9507-02 and 9507-05 Violatic 50-402/9507-02:
Two examples of WCNOC's failure to adequately evaluate plant modification packages.
"A.
Title 10, CFR
- 50. 59 (a) (1) allows licensees to make changes to the facility as described in the final safety analysis report without prior Commission approval unless the proposed change involves an unreviewed safety question.
Title 10, CFR
- 50. 59 (b) (1) states, in part, "The licensee shall maintain records of changes in the facility... These records must include a written safety evaluation which provides the basis for the determination that the change...
does not involve an unreviewed safety question."
1.
Contrary to the above, as of May 8,
1995, the safety evaluation for the change in the operation of the fuel oil transfer system for the emergency diesel generator did not address the agitation of the fuel oil storage tank by the continuous recirculation of the fuel oil when the emergency diesel generator was operating and the possible resuspension of the sediment in the tank.
This could negatively impact the performance of the strainers and filters in the system and ultimately affect the performance of the emergency diesel generator.
2.
Contrary to the above, on or about March 21, 1995, the motor-operators for four safety-related seismically qualified Essential Service Water Valves KJHV-01,
-2,
-101, and -102, were removed under Design Change Package 5101, Revision 1,
without performing an evaluation of the effect of the modification on the seismic analysis of the essential service water system.
The documented safety evaluation for the modification did not provide a basis for the determination chat the consequences of an seismic event previously evaluated in the safety analysis report would not be increased."
Admissien of Violations Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that a violation of Title 10, CFR50. 59 (b) (1) occurred for the above discussed design changes.
The responsible WCNOC personnel failed to effectively document the basis of the acceptability for the design changes.
RainczLfO LYinlationi WCNOC conducted an extensive review of its design change process. This review clearly showed the process, as a whole, is sound.
However, errors were noted in WCNOC engineering dispositions.
The causes of these errors were a lack of attention to detail by the disposition preparers and the failure of Engineering management to provide effective oversight and guidance.
- Further, Engineering management failed to provide and enforce clear management i
expectations to Engineering personnel.
Therefore the root cause of this
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- Attachm:nt;to WM 95-011_7
'Page 2'of:6 z.
l violation - has ' been. determined to be a lack of attention to detail and the failure'to provide offective management oversight.
E Corrective SEmpa Takan and Resulta Ar*hlavadt' Supporting Information:
}
I To address the above noted concern and additional concerns resulting from j
WCNOC Self Assessment Report SE 95-001, " Engineering Change Process," dated March 24, 1995, WCNOC developed a comprehensive action plan to correct.
l
, deficiencies associated with the Engineering Change Process.
This plan j
-includes both corrective actions and enhancements.
The corrective actions were designed to correct known concerns and to prevent recurrence of these concerns.
The enhancements will further streamline WCNOC's design change process. Below is a discussion of the corrective actions and enhancements.
i Corrective Actions and Enhancements Implemented:
}
WCNOC evaluated the potential for suspension of sedimentation in the fuel oil storage tank due to continuous operation of the fuel oil transfer pump when the emergency diesel generator is operating.
This evaluation determined.that operating the transfer pump in the recirculation mode does not stir up enough sediment in the bottom of the storage tank to impact emergency diesel f
generator operation.
Revision 2 to Plant Modification Request 04253 was issued to document this evaluation.
i
[
WCNOC evaluated the removal of valves cited in example two of this. violation and determined their removal did not result in the system being susceptible to damage from a seismic event not previously~ evaluated or outside the limits of a previously analyzed event.
WCNOC revised the design change package and the updated safety analysis report to document this evaluation, j
r WCNOC recently implemented several key management changes within the l
Engineering Department. These changes put in place personnel who will' provide enhanced managerial support and oversight.
This oversight will ensure personnel have the tools necessary to accurately complete their assigned tasks.
- Further, this oversight will ensure that personnel are held i
accountable for the acNrate performance of assigned tasks and adherence to WCNOC policies and procedures.
On July 7,
- 1995, WCNOC established written management expectations and 3
measures of excellence for Engineering personnel.
This action established clear and concise management expectations and removed the ambiguous f
expectations established by earlier management. The expectations and measures of excellence were discussed with Engineering personnel.
The discussions clearly communicated management's expectations that supervisors will support Engineering personnel in the performance of assigned duties, that supervisors shall ensure work performed by Engineering personnel is accurately completed, and'that Engineering personnel are responsible for performing their assigned I
duties accurately, in a timely manner, and in accordance with established WCNOC policies and procedures.
l
i Attachment to WM 95-0117 i
Page 3 of 6 Engineering has established written performance measures.
The measures provide indicators for performance in terms of productivity, quality, and customer sati!., faction. Goals for meeting these performance measures have been established.
Management clearly communicated, through
- meetings, the performance measures and goals.
To reinforce these expectations management provided a written copy of these measures to Engineering personnel.
Senior Management will reinforce these performance measures and ensure Engineering personnel are receiving the necessary support and oversight.
As part of WCNOC's on-going commitment to excellence, the following enhancements have been taken or will be taken:
I e
WCNOC has implemented several design change process enhancements.
These I
enhancements were implemented to streamline the design change process and to incorporate lessons learned from Self Assessment Report SE 95-001.
WCNOC will continue to evaluate and enhance its design change process to ensure the process provides the best tools for the Engineering staff.
- To further support the above discussed enhancement WCNOC plans to provide training to Engineering personnel.
This training will be designed to enhance personnel skills in implementing the design change process in an accurate and timely manner.
The initial phases of this training will be completed in December of 1995.
Additional training will be provided as needed.
Date When Full Comoliance Will Be Achievadt Full compliance with the above noted requirements has been obtained and all corrective actions to prevent recurrence have been completed.
i i
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Attachment to WM 95-0117
)
Page 4 of 6 Violation 50-482/9507-05:
One example of a WCNOC's failure to document concerns regarding deficiencies in a calculation I
package.
"B.
Title 10 CFR Part 50, Appendix B, Criteria XVI, requires that measures i
be established to assure that conditions adverse to quality are promptly identified and corrected.
Procedure AP28A-001, " Performance Improvement Request," paragraph 6.1.1, requires anyone identifying an actual or potential non-hardware problem, concern, or recommendation to document the item on a performance improvement request initiation form.
Contrary to the above requirement, the emergency diesel generator system engineer failed to document, in early 1995, his concerns regarding deficiencies in the calculations for fuel oil transfer pump start /stop day tank levels, or the day tank low level alarm setpoints."
AdmisAisn of Violationi Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that a violation of 10CFR50, Appendix B, criteria XVI occurred when the responsible system engineer failed to issue a kerformance Improvement Request (PIR) to document his concerns.
Raamon for violatinni Background / Supporting Information:
In May 1995, WCNOC conducted an evaluation to determine Engineering personnel support for and use of WCNOC corrective action program.
During this evaluation WCNOC selected and interviewed a representative sample of 42 engineers, nine supervisors, and five nanagers within the Engineering Department.
The results of this evaluation clearly indicated that a positive and proactive culture exists within Engineering, with respect to the use of the WCNOC corrective action program. All personnel interviewed indicated that they understood their right and responsibility to identify concerns or problema encountered during the performance of their assigned duties.
Root Cause:
The failure of the emergency diesel generator system engineer to document his concerns in accordance with the WCNOC corrective action program is considered an isolated case resulting from this individual's lack of complete acceptance and use of the WCNOC corrective action program.
WCNOC management is responsible for assuring a positive work culture exists at WCNOC.
Therefore, the root cause of this violation is insufficient management oversight.
Contributing Factors:
Management's expectations and support of Engineering personnel's use of the WCNOC corrective action program were not well understood by the system engineer.
Attcchm:nt to WM 95-0117 Page 5 of 6 Management's followup or monitoring of this system engineer's activities were not rigorous or proactive and did not identify and correct the system engineer's lack of understanding c f management's expectations.
The individual's supervisor was not held accountable for assuring the individual assigned to him used and adhered to the established programs and procedures.
The system engineer was not held accountable for his actions relating to the use and adherence to the WCNOC corrective action program.
Correshlyg_,Jigpa_ Tg] ten to Avoid Further violations:
The Manager System Engineering met with the system engineer and his supervisor.
They discussed expectations for the use and adherence to the WCNOC corrective action program.
During this meeting management conveyed the issue of personal accountability and the division's expectations for timely documentation of concerns.
The Manager System Engineering has alsdlscheduled periodic n4eetings with the selected personnel to reiterate expectatt ans on the use of the WCNOC corrective action program.
The meetings will be used to provide an open forum for discussing corrective action issues, management's support for engineering's use of the program, and other related issues with this individual.
The following actions, although not directly implemented to address this violation, have been evaluated and determined to contain actions which will aid in preventing recurrence of this violation:
WCNOC's response to Notice of Violation 482/9506-01 (WCNOC Letter WM 95-0097, issued on June 14,1995):
- WCNOC implemented several management changes within the Engineering Department.
These changes brought personnel who better understand and support the WCNOC corrective action program to key positions within Engineering.
Engineering management held meetings to clearly express their expectations for Engineering personnel support and use of the WCNOC corrective action program.
- WCNOC established written management expectations and measures of excellence for Engineering personnel. These enhancements will ensure Engineering personnel understand their accountability for accuracy of work and clarity of communications.
The enhancements will also provide management's vision of how to make Engineering a world class performer.
Engineering management discussed the written expectations and measures of excellence with Engineering personnel.
WCNOC's response to Notice of Violation 9507-02:
l
)
Attechment to WM 95-0117' Pagel6 of;6
- WCNOC recently implemented several key management changes within the Engineering Department.
These changes put in place personnel who will provide enhanced managerial support and oversight.
This oversight will ensure personnel have the tools necessary to accurately complete their assigned tasks.
Further, this oversight will ensure that personnel are held accountable for the accurate performance of assigned tasks and adherence to WCNOC policies and procedures.
On July 7, 1995, WCNOC established written management expectations and measures of excellence for Engineering personnel.
This action established clear and concise management expectations and removed the ambiguous expectations established by earlier management.
The expectations and measures of excellence were discussed with Engineering personnel.
The discussions clearly communicated management's expectations that supervism's will support Engineering personnel in the performance of assigned
- ies, that supervisors shall ensure work performed by Engineering personnel is accurately completed, and that Engineering personnel are responsible for performing their assigned duties accurately, in a timely manner, and in accordance with established WCNOC policies and procedures.
Corrective Steps That Will Be Taken To Avoid Further Violationet Training will be provided on the WCNOC corrective acticn program for all engineers assigned to Engineering.
This training will be completed by August 31, 1995.
Date When Full ca=aliance Will Be Achievedt Full compliance has been achieved and all corrective actions associated with this violation will be completed by August 31, 1995.
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