ML20087F748

Forwards Response to SALP Rept by Providing Actions Taken to Improve Performance in Safety Assessment/Quality Verification Functional Area

ML20087F748
Person / Time
Site:	Wolf Creek
Issue date:	01/06/1992
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20087F700	List: ML20087F748
References
WM-92-0002, WM-92-2, NUDOCS 9201240166
Download: ML20087F748 (4)

Text

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ENCLOSURE 3 I

LF CREEK W@NUClf.AR OPERATING C c

Bart D withers January 6, 1992 ww and ChW cse%utw Ohcor WM 92-0002 R. D. Martin, Regional Administrator U. S. Nuclear Regulatory Commission P.egien IV 611 Ryan Plass Dttve, Suite 400 Arlington, TX 76011-8064

Reference:

Letter dated December 9, 1991 from R. D. Martin, NRC, to B. D. Withers. WCNOC

Subject:

Docket No. 50-482:

Response to Systematic Assessment of Licanse Performance Peport f

Dear Mr. Martin:

The purpose of this letter is to provide Wolf Creek Nuclear Operating Corporation's (WCNOC) response to the Reference.

As identified in the Reference, WCN00 is required to provide planned corrective actions to achieve improved performance in che Saf ety Assessment / Quality Verification functional area, The Attachment to this letter provides tne actions being taken by VCNOC to improve performance in the Safety Assessment / Quality Verification functional area.

WCNOC is implementing a Corporate Performance Improvement Plan (PIP) which was briefly discussed in meetings on December 6, 1991 and December le, 1991.

The Attachment discusses two of the issues to be addressed by the PIP.

It is VCNOC's intent to further discuss the issues to be address?d and t.he implementation of the PIP with you in February 1992.

If you have any questions concerning this matter.

please contact me or Mr. S. G. Videman of my staff.

Very truly yours, s

Bart D. Vithers President and Chief Executive Officer BDW/nem Attachment cci A. T. Ecrwell (NRC), w/a G. A. Pick (NRC), w/a V. D. Reckley (NRC), w/a Document Control Desk (NRC), w/a 8200 E. 32nd St. No. Wichita, Kansas - Mail Addrets: RO. Box 2:08 Wichits, Kansai 67:T)1 Telephone: (316) 636-6700 - Fax Number. 016) 6364888 9201240166 920117 PDR ADOCK 05000482 An Equal Opponunity Ernployer M/F/HC/ VET G

PDR

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Attachment to WM 92-0002 Page 1 of 3 Response to Systematic Assessment of License Performance The Systematic Assessment of Licensee Performance (SALP) Report noted weaknesses in assessing aperability concerns:

responding to tiRC findingas documenting problem areas:

effectively resolving previously identified programmatic weaknesses:

and establishing and communicating msnagement's expectations to the plant staff with regard to problem identification and correction.

The report indicated that these weaknesses are indicative of incufficient management involvement in and oversight of the self-assessment and corrective action programs.

Wolf Creek Nuclear Operating Corporation's (WCNOC) response addresses four major areas that encompass the weaknesses identified in the report.

The four major areas consist of Management Oversight, Corrective Action, Self-Assessment and Operability /Reportability Determinations.

Management Oversight On December 11.

1991, the President and Chief Executive Officer held a meeting with department headr, managers and supervisors to reiterate executive managements expectations concerning the corrective action process and oversight of plant activities and programs.

On December 16,

1991, the Director Plant Operations issued a letter to the Operetions Department Managers to convey operational philosophy and management expectations.

Through these efforts WCNOC management has expressed its expectations on corrective actions and management oversight of plant activities as well as programs._

Training will be provided to managers and supervisors on the methods and techniques for conducting performance-based observations to be utilized in the implementation of management oversight.

WCNOC is developing an issue management program to effectively resolve significant issues that are identified from operational events, regulatory L

issues or industry events.

The program will require identification of

issues, assignment of a responsible manager, development of a plan ar.d schedule for resolution of the issue, approval of the plan and schedule by the Issue Management Group and implementation of actions.

This program will be directed by the Issue Managemant Group, which consists of the WCNOC l

nuclear department heads (Director Plant Operations, Director Quality and l

Safety. Director Nuclear Services and Director Nuclear Plant Engineering).

The chairman of the Issue Management Group is the Director Plant Operations.

The first meeting of the Issue Management Group was conducted l

to develop a charter for the program.

This program will be implemented by l

January 31, 1992.

WCNOC is developing a fermalized management monitoring program.

This l

program will include periodic unscheduled performance-based observations of l

ongoing plant activities by management.

The monitoring ogram will provide l

management overview of various aspects of WCGS activities.

The management monitoring program will be implemented by Pebruary 21, 1992.

l

Attachment to VM 92 0002 Page 2 of 3 Corrective Action WCNOC is continuing to enhan:e the corrective action program.

These enhancements have included a centralized tracking system and a review of corrective action documents (Programmatic Deficiency Reports) for impact on other areas or organizations.

In August 1991, a char.ge was made to the corrective action program which revised the Programmatic Deficiency Report.

4 to ths Performance Improvement Request (PIR).

The intent of this change was to eliminate the confucion surrounding the definition of ' programmatic conditions rdveres to quality' and expand the scope of the program to include at condition that could adversely effect plant performance or work s

activities.

To provide an increased understanding of the corrective action

program, training will be provided to various levels of the technical staff by July 1, 1992.

Additional training on root cause evaluations will be completed by April 30, 1992.

Executive management is periodically reviewing selected PIRs to monitor their use to determine if rdditional enhancements to the corrective action program are necessary.

Additionally, executive management attends the monthly Quality Aesurance audit exit meetings to understand the findings first hand.

iglf-Asse m 1 In September 1991, WCNOC initiated a review of Quality Assurance Audits and Surveillances, Litunsee Event Reports, NRC inspection reports and INFO arsessments to categorize the findings identified in these documents.

Nine performance and program implementation issues were identified and formed the initial basis for the Corporate Performance Improvement Plan (PIP).

The PIP will address significant performance and program issues at WCGS.

The PIP proceso entails th;e identification of a PIP issue, assignment of a PIP Project Manager, development of a plan and schedule with executive management approval, implementation of the plan and a measurement of the effectiveness of the actions taken.

Implementation of the PIP p-ara *a vill l

be completed by February 21, 1992.

Two of the initial PIP-issues to be addressed are management effectiveness and the corrective action process.

Functional self-assessment le an integral part of the line managers responsibilities.

A procedure will be developed and implemented'for i

I controlling line organization self-assessments by March 31, 1992.

This procedure will ensure that line management effectively uses the self-assessment process to monitor performance.

A standard distribution for self-assessment reports will ensure executive management and department head awareness of significant and resources required for corrective action.

Additionally, this procedure will require the initiation of Performance Improvement Requests (PIRs) in accordance with KGP-1210

' Performance Improvement Requests' when self-assessments identify conditions adverse to perfoonance.

The Quality Assurance organizations will perform a verification that nuclear related activities have adequate oversight responcibilities assigned.

This review will be completed by June 1, 1992.

Attachment to %&1 92 0002 Page 3 of 3 operab111tvlRecortability Determinations The SALP report identified several examples where operability determinations were considered inadequate or untimely.

VCNOC will perform a review of the operability determination process.

The guidance provided in Generic Letter 91-18

'information to Licensees Regarding Two NRC inspection manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability' vill be considered in this reviest.

Enhancements to existing procedural controls or additional procedures an appropriate will be completed by March 31. 1992.

Procedure ADM 01-033

' Instructions Describing Reportability, Review and Documentation of Licensee Event Report (LERs),

and Defect Deficiencies

• was revised in April 1991 to provide more definitive guidance on timeliness of reportability evaluations.

This procedure was revised ag.in in May 1991 and changed the Defect /Deficisney Report to the current Reportability Evalus'. ion Request (RER) format.

Additienally, a status tracking system for RERs was implemented with periodic reports to management.

The details of the rpecific changes were provided 30 the hRC in lotter NO 91-0212 dated August 1, 1991.

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