ML20117K680
| ML20117K680 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/04/1996 |
| From: | Carns N WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-96-0094, WM-96-94, NUDOCS 9609120086 | |
| Download: ML20117K680 (3) | |
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WfdLF CREEK NUCLEAR OPERATING CORPORATION Neil S.
- Buzz" Cams Chairman, President and September 4, 1996 l
WM 96-0094 U.
S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.
C.
20555
Reference:
Letter dated August 9, 1994, from J.
E. Dyer, NRC, to N.
S.
Carns, WCNOC j
Subject:
Docket No. 50-482: Response to Notice of Violation i
j 50-482/9612-04 l
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Gentlemen:
This letter transmits Wolf Creek Nuclear Operating Corporat4on's (WCNOC) response to Notice of Violation 50-482/9612-04.
The violation ancerned the failure of WCNOC to have procedures which implement the quality program's l
procurement process as specified in Chapter 17 of the WCNOC Updated Safety Analysis Report (USAR).
WCNOC's response to this violation is in the attachment. If you have any questions regarding this response, please contact me at (316) 364-8831, extension *100, or Mr. Terry S. Morrill at extension 8707.
i Very truly yours, 9609120086 960904 PDR ADOCK 05000402 G
PDR Neil S. Carns NSC/jad Attachment I
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cc:
L. J.
Callan (NRC), w/a J. E. Dyer (NRC), w/a l
W. D.
Johnson (NRC), w/a J
F. Ringwald (NRC), w/a J
C. Stone (NRC), w/a 1(. bb k/
1 PO Box 411 i Burhngton, KS 66839 / Phone (316) 364-8831 l
An Equal 06vysturwy Empioyer M F HCVET i
. ~. -.----.-. -. _. _. ~. -. ~. - ~...
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Attachment to WM 96-0094 Page 1 of 2 Reply to Notica of violation 50-482/9612-04 Violation 50-482/9612-04:
Failure to procure r 'ety-related material in the manner described in the Updated Safety Analysis Report.
"A.
10 CFR 50.54 (a) (1) requires, in part, that nuclear power plants
?mplement the quality assurance program described in the Safety Analysis Report.
The Wolf Creek quality assurance program is contained in Chapter 17 of the Updated Safety Analysis Report.
This quality assurance program requires, in part, provisions for supplier evaluations in paragraphs 17.2.7.2 prior to award, and ongoing monitoring of suppliers in paragraph 17.2.7.7.
Contrary to the aborb since at least January 1994, safety-related materials have been p. : cured from certain suppliers without supplier evaluation and monitoring of suppliers.
In particular, on April 1,
- 1996, bearings for the motor-driven auxiliary feedwater pump were procured from another NRC licensed utility without a supplier evaluation and without ongoing monitoring of the supplier, to the extent that the commercial grade dedication process used by the supplier for the bearings was not reviewed or understood.
This is & Severity Level IV violation (Supplement I) (482/9612-04)."
Admin u e of violation Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges that a violation of 10 CFR 50.54 (a) (1) occurred in that Chapter 17.2 of the Updated Safety Analysis Report (USAR) requires measures for the evaluation and selection of procurement sources be specified in procedures.
WCNOC procedures failed to adequately detail the procurement process in relation to procurement of safety-related items from other licensees.
l Ramaon for Violation The root cause of this event is personnel arror.
At the time of the event, WCNOC did not procedurally require a renew, prior to procurement, of the selling utility's procurement package to assure that the item was appropriate t
for use in the WCNOC application.
Due to personnel error it was not formally included in the appropriate procedare.
Basis for the Root cause Determination i
l The procurement of items from licensed utilities is a common industry j
practice.
The guidance of this process is detailed in USAR secticn 17.2.7.2, j
" Source Evaluation and Selection," which allows an evaluation of a suppliers j
capability, prior to award, by 1) source evaluation; 2) review for objective
- vidence of quality; at 3) a review of supplier history.
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Attachment to WM S6-0094 Page E of 2 l
This section also states that suppliers of hardware / services which are manufactured prior to award, an off-the-shelf item, or implemented under the operating Agent's Operating Quality or Surveillance programs may not require preaward source evaluation or audits to assure quality.
The information to be considered during a procurement source evaluation includes one or more of the i
following: 1) experience of users; 2) evaluation of supplier's current quality records: and 3) source evaluation.
Source evaluations are not typically conducted for licensed utilities by WONOC.
WCNOC recognizes that licensed utilities perform internal audits of
-their programs; perform external audits of their suppliers / manufacturers; and receive oversight by the Nuclear Regulatory Commission including.the inspection of their procurement process and commercial grade dedication program.
The NRC inspection process is documented in NUREG-0040 and used by WCNOC to verify the experience of the supplier and satisfies the requirements of source evaluation documented above. These requirements are outlined in the WCNOC administrative procedures (AP 24 series) that govern the WCNOC procurement process.
Contrary to the requirements of USAR paragraph 17.2.7.2, regarding evaluation of supplier's current quality records, WCNOC procedures did not address the need to perform a review of licensee documentation to assure that the part being procured satisfied the WCNOC application.
USAR Chapter 17.2.7.7,
" Monitoring of Suppliers," indicates that this process is used or should be considered when the item being procured is vital to plant safety; if its quality characteristics are difficult to verify after receipt; or if the item is complex in design, manufacture, inspection, or test.
It is WCNOC's position that this section does not apply to the example addressed in the inspection report.
The requirements of USAR paragraph 17.2. 7.2 are the controlling requirements.
Based on the above discussion, detail in USAR Chapter 17.2 is sufficient to guide the procurement process.
However, due to personnel error, WCNOC procedures did not include the needed review of documentation for dedicated parts / items from other utilities to assure their acceptability in the WCNOC application.
Corrective Stens Taken and Resulta Achievedt i
" Procurement of Items and Services," was revised to i
require a review of the selling licensee's procurement package to assure that l
the parts are appropriate for use at WCNOC and meets our application, i
i Date when Full Ca=aliance Will Be Achievedt I
j Full compliance was achieved on September 3, 1996.
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