ML20116L990
| ML20116L990 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/01/1985 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| KMLNRC-85-095, KMLNRC-85-95, NUDOCS 8505060071 | |
| Download: ML20116L990 (12) | |
Text
O KANSAS GAS AND ELECTRIC COMPANY T>E ELECTmC COMPANY CLENN L KOESTER wect Paaseormt muctsan May 1, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 KMLNRC 85-095 Re:
Docket No. STN 50-482 Subj: FSAR Changes Relating to the Operating Quality Program Ref: KMLNRC 85-063 dated 2/22/85 from GLKoester, KG&E, to HRDenton, NRC
Dear Mr. Denton:
As requested by Mr. Paul O'Connor, NRC Licensing Project Manager for Wolf Creek Generating Station, and Jack Spraul, NRC Quality Assurance Branch, Attachment A contains marked up changed pages to Chapters 3A, 13 and 17 of the Wolf Creek Final Safety Analysis Report (FSAR). These changes incorporate information provided in the Reference and/or provide further clarification on the information previously provided. The attached changes will be incorporated into the first annual update of the Wolf Creek FSAR.
Yours very truly, pQ W
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(C r Glenn L. Koester Vice President - Nuclear GLK:bb Attach xc:PO'Connor, w/a (2)
JSpraul, w/a JCummins, w/a
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Il 8505060071 850501 PDR ADOCK 05000482 P
PDR 201 N. Market - Wictuta, Kansas - Mail Address: PO. Box 208 l W'chita, Kansas 67201 - Telephone: Area Code (316) 261-6451
OATH OF AFFIRMATION STATE OF KANSAS
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SS:
COUNTY OF SEDGWICK )
I, Kent R. Brown, of lawful age, being duly sworn upon oath, do depose, state and affirm that I am Group Vice President - Technical Services of Kansas Gas and Electric Company, Wichita, Kansas, that I have signed the foregoing letter of transmittal for Glenn L. Koester, Vice President -
Nuclear of Kansas Gas and Electric Company, know the contents thereof, and that all statements contained therein are true.
KANSAS GAS AND ELECTRIC COMPANY ATTEST:
al By (C4V W,
m Kent R. Brown Group Vice President-Technical Services E. D. Prothro, Assistant Secretary STATE OF KANSAS
)
)
SS:
COUNTY OF SEDGWICK )
BE IT REMEMBERED that on this 1st day of May, 1985
, before me, Evelyn L. Fry, a Notary, personally appeared Kent R. Brown, Group Vice President - Technical Services of Kansas Gas and Electric Company, Wichita, Kansas, who is personally known.to me and who executed the foregoing instru-ment, and he duly acknowledged the execution of the same for and on behalf of and as the act and deed of said Corporation.
"{tN,ITNESSWHEREOF,Ihavehereuntosetmyhandandaffixedmysealthe
ond year above written.
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Ev'elyn L Fry,' Notary 3
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..,$,(,hedommissionexpiresonAugust 15, 1985.
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SNUPPS-WC REGULATORY GUIDE 1.30 REVISION 0 DATED 8/72 Quality Assurance Requirements for the Installation, Inspec-tion, and Testing of Instrumentation and Electric Equipment (Safety Guide 30)
DISCUSSION:
KG&E concurs with major vendor's instruction manuals but does not necessarily apply a signature of approval (ANSI N45.2.4, Section 3(2)).
KG&E uniquely identifies each safety-related item of pro-cess control instrumentation.
This identification provides Traceability to calibration data.
These actions are KG&E's alternative to the tagging or labeling of items to indicate the calibration date and the identity of the persons who performed the calibration (ANSI N45.2.4, Section 6.2.1).
At WCGS, the adequacy of protective measures for items in storage is verified by warehouse, Quality Control and Quality Assurance personnel on an audit / surveillance basis
/h5 Ear ( ANSI N4 5. 2. 4, Section 3.3).
I -t REGULATORY GUIDE 1.33 REVISION 2 DATED 2/78 Quality Assurance Program Requirements (Operation)
DISCUSSION:
The recommendations of this guide and the ANSI Standards listed in Table 17.2-3 are met except where specific alter-natives 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 1.37 REVISION 0 DATED 3/73 Quality Assurance Requirements for Cleaning of Fluid Sys-tems and Associated Components of Water-Cooled Nuclear Power Plants DISCUSSION:
KG&E complies with the recommendations of this regulatory guide.
REGULATORY GUIDE 1.38_
REVISION 2 DATED 5/77 Quality Assurance Requirements for Packaging,
- Shipping, Receiving, Storage, and Handling of items for Water-Cooled Nuclear Power Plants Rev.
15 3A-2 1/85
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SNUPPS-WC REGULATORY GUIDE 1.111 REVISION 1 DATED 7/77 l
Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors DISCUSSION:
The recommendations of this regulatory guide are met.
Refer to Section 2.3.
REGULATORY GUIDE 1.113 REVISION 1 DATED 4/77 Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implement-ing Appendix I DISCUSSION:
The recommendations of this regulatory guide are met.
Refer to Section 11.2.
REGULATORY GUIDE 1.114 REVISION 1 DATED 11/76 Guidance on Being Operator at the Controls of a Nuclear Power Plant DISCUSSION:
The recommendations of this regulatory guide are met.
Refer to Section 13.1.
REGULATORY GUIDE 1.116 REVISION 0-R DATED 5/77 Quality Assurance Requirements for Installation, Inspec-
- tion, and Testing of Mechanical Equipment and Systems
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DISCUSSION:
KG&E complies with the recommendations of this regul'atory guide with the clarification that at WCGS the adequacy of protective measures for items in storage is verified by Warehouse, Quality Control and Quality Assurance personnel on an audit / surveillance basis (ANSI N45.2.8, Section 3.4.1).
/MD74 i
REGULATORY GUIDE 1.123 REVISION 1 DATED 7/77 Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants DISCUSSION:
KG&E complies with the recommendations of this regulatory guide.
Rev. 15 3A-6 01/85
w SNUPPS-WC 13.1.1.2.3 Director Nuclear Operations The Director Nuclear Operations reports to the Vice Presi-dent - Nuclear for overall program direction.
He is respon-sible for the Operations, Project Planning and Controls and Training departments.
The Plant Manager, the Manager Oper-ations Support, the Supervisor Project Planning and Controls and the Manager Nuclear Training report to the Director Nuclear Operations for overall program direction.
13.1.1.2.3.1 Plant Manager h as m. pr.he. tesym. L /Hy He is rcspo[nsibic for the safe operation of "CCS :nd-The Plant Manager reports to the Director Nuclear Opera-
/e/ M tions.
he controls plant activities through his staf f, as described in
- "f*k' / U this section.
Under his direction, the plant staff develops detailed procedures and instructions for testing and oper-ation of the station.
In additica the Startup Man 2ger rcpcrt tc th Plant Man ger.
13.1.1.2.3.1.1 Startup Manager The Startup Manager reports to the Plant Manager for overall program direction and to the Wolf Creek Site Director for day-to-day project direction.
He is responsible for the overall direction and administration of the functions and activities required to conduct the WCGS Startup program.
Chapter 14.0 presents a description of the Startup Organiza-tion and delineates the Startup Manager's responsibilities.
When the Startup program has concluded, the Startup Organi-zation will be dissolved.
13.1.1.2.3.2 Manager Operations Support-The Manager Operations Support reports to the Director Nuclear Operations and is responsible for providing staff support to the Director Nuclear Operations.
The Manager Operations Support supervises the activities of the Operations Support Group.
He reviews nuclear operational activities and coordinates home office support to plant operations.
13.1.1.2.3.3 Manager Nuclear Training The Manager Nuclear Training reports to the Director Nuclear Operations and is responsible for the overall training acti-vities of the Nuclear Department.
He is responsible for insuring training staff qualifications, including reviewing instructor evaluation records with the Training Supervisor and Simulator Supervisor.
He is responsible for reviewing the content of training programs for technical completeness Rev. 15 13.1-Sa 1/85
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13.1.1.2.7 Manager Quality First The Manager Quality First reports directly to the Group Vice President - Technical Services.
He is responsible for directing the Quality First Program which providcc an inde pendent crgani: tion to in/catigatc
.:;a f e ty end quai ny ceneerns.
13.1.1.2.8 Manager Construction The Manager Construction reports directly to the Group Vice President - Nuclear.
He provides construction support to the proj ectf a f. l.%,ny kCaE p/a,,f m a,J [ cat.% a,,al m.,,n /anas,s.
ftor.salarse, slabl,'kes
//sv n e c e.rsa ry a simo n,4 Yrsh *Ve an el sh ves8) s W.re s
/h e a su ra iA ctY all gaa lo fy a.oncsens re. /a To c) to
+c, suuure.
sa &,o /a n 't opercr fion,sj fu en la Yy of nine/r a n r} c,ain /,,, n c.,_ w,ff
,o e,f
,y
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y, y,,,, p af' Veri 0e,c} a n d dOCurnero /e.d.
6L Rev. 15 13.1-7b 1/85 N
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1 SNUPPS-WC 17.2.1.4.4 Quality Branch Personnel Independence The authorities and duties of QA and QC personnel and other organizations performing quality verification functions are clearly established in written procedures.
Such persons have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solu-tions; and to verify corrective action.
Assurance of quality by auditing, inspecting,
- checking, or otherwise verifying program activities is by personnel independent of the indi-vidual or group performing the specific activity.
17.2.1.5 Manager Nuclear Plant Engineering The Manager Nuclear Plant Engineering reports to the Director of Engineering and Technical Services for overall program direction.
He is responsible for station modifications, additions, engineering studies, and design reviews which are conducted at the general office or subcontracted by the general office to an outside organization.
17.2.1.6 Manager Nuclear Services The Manager Nuclear Services reports to the Director of Engi-neering and Technical Services for overall program direction.
He is responsible for providing services in the areas of licensing, fuels management, fuel procurement, and safety analysis.
He is responsible for home office support of the plant in nuclear engineering, chemistry, health physics, and environmental areas.
17.2.1.7 Director Nuclear Operations The Director Nuclear Operations reports to the Vice President-Nuclear for overall program direction.
He is responsible for the operations, training and startup departments.
The Plant
- Manager, the Manager Operations Support, Supervisor Project Planning and Controls, and the Manager Nuclear Training report to the Director Nuclear Operations for overall program direc-tion.
The Director Nuclear Operations is also responsible for preparing those portions of the WCGS operating and maintenance budget not specifically assigned to other divisions.
17.2.1.7.1 Plant Manager The Plant Manager reports to the Director Nuclear Operations.
He 1: :=spac,;lbic 6,,
Me y,,,,,
, c.sp,, j, / fy Rev. 15 17.2-5
,1/85
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SNUPPS-WC Mon t an d ouray c.. acne,n a-I t c "CS.
He controls plant activ-for the safe operation of ities through Superintendents as dis. cussed in Section 13.1.
He has the prime responsibility for safe operation of the plant.
The plant staff, under the direction of the Plant Manager, develops detailed procedures and instructions for testing and operation of the station.
17.2.1.7.2 Startup Manager The Startup Manager reports to the Plant Manager for overall program direction and to the Wolf Creek site Director for day-to-day project direction.
He is responsible for the overall direction and administration of the functions and activities required to conduct the WCGS startup program.
Chapter 14.0 presents a description of the Startup organiza-tion and delineates the Startup Manager's responsibilities.
When the startup program has concluded, the Startup Organiza-tion will be dissolved.
17.2.1.7.3 Manager Nuclear Training The Manager Nuclear Training will report to the Director Nuclear Operations.
He is responsible for insuring training staff qualifications, including reviewing instructor evalua-tion records with the Training Supervisor and Simulator Supervisor.
He is responsible for reviewing the content of l
training programs for technical completeness and compliance with regulatory standards.
He is also responsible for auditing the quality of on-site training programs.
The Manager Nuclear Training is also responsible for training programs for Corporate office personnel involved in support of WCGS during normal ope rations, preparedness for response to off-normal incidents, and long-term recovery programs.
17.2.1.7.4 Manager Operations Support The Manager Operations Support reports to the Director Nuclear Operations and is ~ responsible for providing staff support to the Director Nuclear Operations.
The Manager Operations Sup-port supervises the activities of the Operations Support Group.
He reviews nuclear operational activities and coordi-nates home of fice support to plant operations.
l Rev. 15 17.2-Sa 1/85
SNUPPS-WC 17.2.1.11 Manager Quality First The Manager Quality First reports directly to the Group Vice President-Technical Services.
He is responsible for directing 0.-
independent crg:n-the Quality First Program which providc iz&tica to invcstigatc sfaty and quality concerns.
17.2.1.12 Manager Construction The Manager Construction reports directly to the Orr7 Vice President - Nuclear.
He provides Construction Suppo rt to the projecty' u f /, z.r'ny /cG+E planr mad, Caa lo'o n and m a s'n fanana fraced ras. O u /s.ds. Con fre e for.r M cO' o /so de. usec/ fo n.rAtm sa B.f - r ela f J
- c. an s fr u t f. An a> ora ao 1ae app to ved an y
q u a l, ~/y a ssu r a,, a pro gram,
sr /allsles //s nee stacy adm.s,sfrcJ: k ascl tomnfak me a sa re e fa
.ra 4 p Ais t ope,a A on,
a.n r ra
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<e A. m J fo qa a /. 'fy a f werd a n d c onf a n a.~
uss /df rnie s l re y u. ram erd.r a ee-.
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ffref ria fe/7 a. u a / a fa d, i k u erf y a A. d, ots.spoes?%ed, deto /"ec/ asef do c aes,hd, I
t Rev. 15 17.2-6a 1/85
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SNUPPS-WC 17.2.2.6 Operating Quality Program Verification of Implementation Achievement of the requirements of the operating Quality pro-gram shall be verified through independent and integral con-trol activities.
The Quality Branch under the Director Quality shall audit general office internal and interfacing quality activities and shall conduct audits and surveillance of the operating plant.
These audits shall assure overall implementation verification of the operating Quality program.
Quality Branch personnel will perform audit, surveillance and inspection of quality activities performed by the operating organization, consultants, suppliers, and other KG&E personnel. in a del ), o n a n na a / n, ctop en, ten t ama,n,,,,7 c/' ff,..
an a /L%u.s / /Ja mwry /
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pr ranz sAa h he.- /no da u,, da,.
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17.2.2.7 Personnel Traini g and uali 1 cation j,., _
g General indoctrination and training programs sh I N e rovNe8".
for the general office and plant site personnel to assure that they are knowledgeable regarding quality procedures and re-quirements.
The requirements for training of WCGS personnel are described in Section 13.2.
The training of plant operat-ing personnel is the responsibility of the plant Training Supervisor.
Records of training shall be maintained to demon-strate compliance with the qualification requirements of 10 CFR 55 and ANSI N18.1/ANS-3.1,
" Selection and Training of Nuclear Power Plant Personnel".
KG&E personnel performing
- complex, unusual, or potentially hazardous work shall be instructed in special indoctrination or briefing sessions.
Emphasis shall be on special requirements for safety of per-sonnel, radiation control and protection, unique features of l
equipment and
- systems, operating constraints, and control I
requirements in effect during performance of work.
Where required by codes and standards, personnel are trained or qualified according to written procedures in the principles and techniques of performing specific activities described in sections 17.2.9, 17.2.10, and 17.2.11 of this chapter.
Training will be conducted in a time frame adequate to allow i
personnel to prepare for their job responsibilities. Retrain-l ing will be scheduled as necessary to assure adequate skills are maintained.
KG&E personnel assigned to perform special-ized work tasks or to augment the plant staff for major modi-fications and contractor personnel performing work onsite shall receive indoctrination in the folluwing subjects as required prior to commencing work:
1.
Safety rules 2.
Ilealth-physics control and monitoring of radia-tion exposure Rev. 13 17.2-9 6/84
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SNUPPS-WC 17.2.15 NONCONFORMING MATERIAL, PARTS, OR COMPONENTS 17.2.15.1 Scope Nonconfomances are any deficiency in characteristics, docu-mentation, or procedure which renders the quality of an item unacceptable or indeterminate.
Noncon fo rmances,
therefore, include material deficiencies, malfunctioning or inoperative structures, systems and components, and departures from sceci-fied procedural requirements which impact the quality of an item.
Nonconforming activities which have not resulted in hardware nonconformances (i.e.,
programatic or procedural deficiencies which do not impact the quality of an item), are corrected in accordance with Chapter 17.2.16, Corrective Action.
17.2.15.2 Nonconformance Controls Nonconformances identified under the KG&E Quality Program shall be identified, documented, controlled, dispositioned and corrected in accordance with approved procedures.
These mea-sures shall provide for the notification of af fected parties and controls to prevent the inadvertent use of nonconforming items.
Nonconformances shall be controlled by report documentation, tagging, marking, logging, or physical segregation.
Noncon-formances shall be documented on records which identify the nonconforming condition, record the disposition, and register the signature of an appropriate approval authority.
Noncon-formances shall be reworked, rejected, repaired, or._accepte p //g 4 Repaired and reworked items shall be reinspectedgin accorcance wi
,plicable crocedures @ Reinspection results and opera-tional data, gathered subsequent to repair or rework, are
/M(g documented or referenced on nonconformance, test or inspec-g tion documentation.
easures shall be established to control the conditional re-MM lease of nonconformances for which correction is pending and a tf technical evaluation indicates that installation and/or test-ing, will not adversely affect nor preclude identification and correction of the nonconformance.
A conditional release to proceed installation and/or with testing of a system or sub-system with outstanding nonconfo rmances will consider the nature of the noncon fo rmance, its ef fect on installation and/
or testing and the need for supplemental tests or inspections af ter correction of the nonconformance. p Conditional release evaluations shall be_ documented.
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'QZy - ra ta n./ an et sp,eca s.1 sc,y>s'. casa tJQre kas s es omr o-.i ra r cl a d i
ffpedTfication [Q)*'#
Noncon fi:frming items requifed'for Technical Operability shall only be released fo r use through the com
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I pletion of a Plant Modification Request ( PMR)f an c7' //lu )
e a on d 4 un J, gen,, //y
,e fan suf pg,. o,o e,a f cny,
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Rev. 15 l'.2-50 1/85
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i INSERTS 4
t l
Insert 1 j
KG&E warehouse personnel are responsible for tracking and implementation l
of the warehouse storage / maintenance program. Additionally, warehouse 1
personnel perform regular inspections of storage areas for cleanliness
)
and orderliness.
KG&E Quality Control personnel perform inspections of maintenance activities r
as prescribed in approved procedures. Additionally, Ouality Control personnel perform periodic surveillance inspections of storage areas for compliance to applicable requirements.
'l KG&E Quality Assurance personnel perform periodic audits and surveillances l
of warehouse storage / maintenance activities to assure compliance to applicable requirements.
i Insert 2 to ensure that critical attributes possibly affected by the nonconforming condition remain acceptable. These procedures will be based on original I
inspection and test requirements or approved alternatives, i.
I Insert 3 1
Plant Modification Requests (PMRs) are used in the Nonconformance Program to f
carry out dispositions of "use-as-is" or " repair." The PMR process ensures that all aspects of plant operation are considered in light of the fact that j
the dispositioned item is now not exactly per original design. These l
considerations include revision of applicable drawings, possible revisions to operation, test, maintenance and inspection procedures; training of l
affected personnel, changes to spare parts inventory; unreviewed safety i
questions; and review of licensing documents, l
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