ML20127K465
| ML20127K465 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/19/1993 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| NUDOCS 9301260128 | |
| Download: ML20127K465 (26) | |
Text
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NUCLEAR REGULATORY COMMISSION
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Docket No. STN 50-482 License No. NPF-42 Wolf Creek Nuclear Operating Corporation ATTN:
Bart D. Withers President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839 Gentlemen:
This refers to the management meeting that was conducted, at your request, in the Region IV office on January 14, 1993.
This meeting related to activities authorized by NRC License No. NPF-42 and was attended by those on the attached Attendance List.
This meeting was held to discuss Wolf Creek Nuclear Operating Corporation's' Quality Assurance organization and initiatives taken to enhance quality assurance effectiveness, It is our opinion that this meeting was beneficial and has provided a better understanding of the Quality Assurance initiatives at Wolf Creek Gei:erating Station.
The subjects discussed at this meeting are described in the enclosed Meeting Summary.
In accordance with Section 2.790 of the NRC's '" Rules of Practice," Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Room.
Should you have any questions concerning this matter, we will be pleased to discuss them with you.
Sincerely, Bill Beach, Director Division of Reactor Projects
Enclosure:
Meeting Summary w/ attachments l
cc w/ enclosure:
Walf Creek Nuclear Operating Corp.
ATTN:
Otto Maynard, Director l
Plant Operations l
P.O. Box 411 1
Burlington, Kansas 66839
/p6 9301260128 930119 l
PDR ADOCK 05000482 I
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Wolf-Creek Nuclear Operating; Corporation Shaw, Pittman, Potts & Trowbridge AT1N: Jay Silberg, Esq.
2300 M Street, NW
~ Washington, D.C._
20037 Public Service Commission ATTN:
C. John Renken Policy.& Federal Department P.O. Box 360 Jefferson City, Missouri 65102 U.S. Nuclear Regulatory Commission
~
ATTN:
Regional Administrator, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Wolf Creek Nuclear Operating Corp.
ATTN:
Kevin J. Moles Manager Regulatory Services
_P.O.. Box.411 Burlington, Kansas _ 66839 Kansas Corporation Commission ATTN: Robert Elliot, Chief Engineer Utilities-Division 1500 SW Arrowhead-Rd.
Topeka, Kansas 66604-4027 Office of the Governor State of Kansas Topeka, Kansas 66612 Attorney General-
-1st Floor-- The Statehouse.
Topeka,-_ Kansas-66612 Chairman, Coffey County Commission Coffey County Courthouse Burlington, Kansas 66839-1798 Kansas Department of Health and-Environment Bureau of Air-Quality-'& Radiation
' Control ATTN: Gerald Allen, Public Health Physicist Division of Environment
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Forbes Field Building 321 Topeka. Kansas.66620
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ATTN:. Robert Eye, General Counsel LSOB, 9th floor 900 SW Jackson
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J. L. Milhoan Resident Inspector Section Chief (DRP/D)
DRP DRSS-FIPS Section Chief (RIII, DRP/3C)
RIV File SRI, Callaway, RIII MIS System Lisa Shea, RM/ALF, MS: MNBB 4503 Project Engineer (DRP/0)
Section Chief (DRP/TSS)
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J. L. Milhoan Resident Inspector Section Chief (DRP/D)
DRP DRSS-FIPS Section Chief (Rill DRP/3C)
RIV File SRI, Callaway, RIII MIS System Lisa Shea, RM/ALF, MS: MNBB 4503 Project Engineer (DRP/D)
Section Chief (DRP/TSS)
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AC:DRP/D D:lRP LEMyers:df,h MASatorius AEQach k
1/ \\k/93 1/k/93 1/3\\/93 0
MEETING
SUMMARY
Licensee:
Wolf Creek' Nuclear Operating Corporation-(WCNOC)
W facilityi
_ olf Creek Generating Station (WCGS).
License No.: NPF-42 Docket No.:
50-482 Subject)
MANAGEMENT MEETING CONCERNING WCNOC'S QUALITY ASSURANCE (QA)
ORGANIZATION AND QA ENHANCEMENT INITIATIVES
- On January 14, 1993, representatives of WCNOC met with'NRC personnel in the:
Region IV office to discuss the-licensee's QA organization'and: enhancement initiatives.
The NRC staff found the meeting to be beneficial in-providing information about these initiatives.
Attachments:
1.
Attendance List 2.
Licensee Presentation (partial NRC distribution only) k J
Y
ATTACHMENT 1 AITENDANCE LIST Attendance at the management meeting between WCNOC and NRC on January 14, 1993, in the Region IV office:
WCNOC R. C. Hagan, Vice President, Nuclear Assurance K. J. Moles, Manager, Regulatory Services W. M. Lindsay, Manager, Quality Assurance T. S. Morrill, Manager, Radiation Protection E. M. Peterson, Supervisor, Audits (QA)
T. M. Damashek, Supervisor, Surveillance (QA)
ERC J. L. Milhoan, Regional Administrator A. B. Beach, Director, Division of Reactor Projects (DRP)
A. T. Howell, Chief, Project Section D, DRP G. L. Constable, Chief, Plant Support Section, Division of Reactor Safety (DRS)
- 1. Barnes, Technical Assistant, DRS M. A. Satorius, Project Engineer, Project Section D, DRP L. E. Myers, Resident inspector, WCGS, Project Section D, DRP
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ATTACHMENT 2
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Wo f Cree < Nluclear 03 era":ing Cor3 oration (WCNOC)
Meeting with NRC on Quality Assurance improvements and Quality Enhancement initiatives at Wolf Creek Generating Station
[Q January 14,1993 BDa{Date:
fy j Time:
11:00 am to 12:30 pm A
I Location:
NRC Region IV Offices Arlington, Texas L
Presented by:
R. C..Hagan, Vice President Nuclear Assurance W. M. Lindsay, Manager Quality Assurance E. M. Peterson, II, Supervisor QA Audits I M. Damashek, Supervisor QA Surveillances I S. Morrill, Manager Health Physics-K. J. Moles, Manager Regulatory Services
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,e WCNOC QA ORGANIZATION President /CEO B. D. Withers - P/CEO l
Vice President l
Nuclear R. C. Hagan - VP Nuclear Assurance Assurance I
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Manager QA (27)
W. M. Lindsay - Hgr. QA Quality Systems (4)
S. F. Hatch - Supv.
Quality Audits (6)
E.M. Peterson - Supv.
Quality Surveillances (6)
T. M. Damachek - Supv.
Supplier Quality (9)
J. E. Fletcher - Supv.
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MANAGER e
QUAL.ITY ASSURANCE W. M. Lindsay (76/27) 5
- S. J. Somerhalder Adminlettative Secretary
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QUALITT SYSTDt$
l QUALITY (6/4)
QUALITY AUDITS SURvt1LLANCES (6I6)
SUPPLIER-(516)
- S. F. Ratch - Supw.
QUALITY (9/9)
T. M. Dameshek Supw.
- R. A. Meister**
- E. M. Peterson - Supv.
R. F. Buta
- J. E. pletcher - Supv.
- D. A. Birk
- R. S. Ferguson***
- D. L. Donohoe
- M. L. Litch
- E. D. Booth
- C. A. McClelland C. J. Holmen
-J.A.
5 rooks
- C. S. Miller J. D. Pa ppan J.R. Enfinger
- R. J. Ryan C. C. Reek 19 C. J. Itoch
- Open (Electrical Engineer)*
S. R. Koenig
- T. L. Krause R. E. Rigdon Nior Accountabilitices Major Accountabilities:
- B. F. Senn o Coordinate & Review Major accomatsbilitiese o Quality Surveillances select procedures Ma or Acceentabilities:
o Internal Audits Flen & coordinate o PSRC Representative Interface 1.geent Docume Q eview of Flan & notification of performance of report o Maintain Quality Program o
urc ase' Requisitions (FR) performance of report generation Manuale Quality Program Requirements (QPR) generation Follow.up Verification o Provide Training for Standard Program Requirements (SFR)
Follow-up Verification of o coordinate Qualite Material -Procuremen* Requirements (MPR)
Group Findings Assessmente & Aescessent o Maintain QA databases o Auditor Certification Assistance o Provide ASME MPT/NR Frogram o Audits of $gpp Program o Track & report on QA Administration ee Plan and Notif cat on Initial Certification Performance of Report Ceneration Requal. Certification e Interface with NSRC URIA o Participate in Special Follow-up Actions o coordinate enchange of Subcommittee Nint.f o Interface with M5tc Projects Audit Technical Espertise
- sury, Subcomalttet o parve 111ances t4 SuJpl{e,Is o Track and report on RF1s e Interface with the Operations s
Planning and WoLilication e Interface with NSRC Performance of poport Generation Subcomunittee - Rad Controls /
Outage Flanning Group Follow.up Actione Security /E. Plan o Supp[ler.Evalusjjon!.s Initial Evaluation Interim Evaluations Annual Evaluations Final Evaluations Update SIL o Review Vdndor CA Manuale initl G 3 revisions 1/16/93 Update Evaluations Files
- Offer estended If6/93 1118193
- To be transf erred to Begulatory Compliance Open on
- 0n loan from Operations for 24 months - Sao
LA DIVISION BACKGRODWD & INTERFACES o
Background
o Quality Systems (4) 2 previous Licensed Personnel (SRO & RO)
Three active and past Certified Lead Auditors 2 college degrees (Physical Science & Business) 48 years total nuclear industry experience of which 37 years is at WCGS o Quality Evaluations Personnel (Audits /Surveillances) (11) 1 previous RO at WCGS 1 current SRO at WCGS
- 4 BS Degrees (Physical Sciences, Chemistry Electrical Engineering Tech.,
Envir./*.sonit0"ing Tech.)
2 Asse,ciates Degree.
132 total years of nuclear industry experience of which 99 years of WCGS experience (92 years in Quality Assurance or QC, QE at either WCGS or other companies).
NOTE: QA Rotation Program - SRO (Supervising Operator) to rotate into QA for 24 months effective - January 1993 til January 1995, o Supplier Quality
- AA Engineering Technology 89 total years of nuclear industry experience of which 76 years of QA/QC/QE experience (a total of approx. 51 years at WCGS) f
o Interfaces l
Manager OA o
SKUPPS QA Subcommittee Member o
NRC Inspection Report Review Group Member o
Issues Review Group Member o
NSRC SAQV Subcommittee Member o
Alternate Member of the NSRC o
Region IV QA Managers Group o
PEP Action Plan Manager for OA Improvements, 3.2.3 o
MAP Action Item Issues _on Corrective Action Supervisor Quality Systems o
Chairman of the NPT/NR/R Steering Committee NSRC Operations Subcommittee Member o
o PEP Action Plan Member for Management Selection, 2.3.1 Supervisor Audits:
o NSRC Radiological Controls / Security / Emergency Preparedness Subcommittee Member o
PEP Action Plan Member for OA Improvements, 3.2.3 and Vision / Mission, 1.2.1 Supervisor Surveillance:
o NSRC Maintenance / Surveillance Subcommittee Member o
PEP Action Plan Member for Procedures, 3.3.2 Outage Planning Group Interface o
Supervisor Supplier Quality:
o Interfaces with NUPIC & INDEX o
PEP Action Plan Member for Management Selection, 2.3.1 and Procurement, 3.3.4.
o Supplier Data Bank
)
9A - Vision one of.
WCNOC QA will continue to improve its performance to support WCGS as the best run nuclear operations in the industry QA - Mission Support WCNOC organizations in meeting quality,. technical and regulatory.
requirements i
AUDIT PROCESS 1.
BASIS FOR AUDITS AT VCGS A.
The WCNOC QA Audit Program consists of the performance of 58 audits-over a two year period.
These audits cover 40 topical areas which are grouped into four areas based on the following:
1.
Technical Specifications 2.
Other Regulation and Corporate Requirements B.
Audits which are based on Technical Specifications and 10CFR50.
Appendix B are performed under the cognizance of the Nuclear Safety Review Committee (NSRC).
The NSRC Chairman assigns a NSRC Member to interface with the audit team for each of these audits.
C.
The 24 Month (Biennial) Audit Schedule establishes the windows for performing audits to ensure comprehensive coverage of all 40 topical areas at the every six months, required audit frequency (i.e.,
Corrective Action Security - once every year. Document Control - once every two years).
1.
The Biennial Audit Schedule includes:
a)
The topical areas to be audited, b)
Basis for the audit, c)
The applicable Audit Planning Guide number, d) Whather the audit is performed during=an odd year, even year, or both.
e) The month the audit is required.
D.
The 6 Month Audit / Surveillance Schedule is developed from the Biennial Audit Schedule and also factors in plant, regulatory, and industry issues.
Additionally, line managers' input is solicited.
1.
The 6 Month Audit Schedule includes:
a) The topical areas to be audited.
b) Audit Team assignments.
c) NSRC Interface assignments, as applicable.
d)
The basis for the audit and the applicable Audit Planning' Guide.
AUDIT PROCESS e) Any pertinent reference documents to be used during the -audit plan development, f)
Previous audits of the topical area.
g) Scoping stateuents identifying specific topics to be evaluated during the audit.
II.
PLANNING AND SCHEDULING A.
Audit Planning Guides (APG) are used by the auditor during the audit planning process. The APGs contain:
1.
A statement describing the purpose of the audit.
2.
A comprehensive reference document section.
3.
A listing of objectives from which the auditor chooses in developing the audit plan.
a) When applicable, specific objectives are listed as mandatory, b) The objectives are based on upper-tier regulatory and corporate requirements.
B.
Our goal is to begin development of the audit plan a month before the scheduled audit.
Audit notification is made to Management one week prior to the scheduled entrance date.
III.
EXCHANGE OF TECUNICAL EXPERTISE DURING AUDITS A.
QA Management actively pursues the use of technical expertise both from within the company and external to the company to help with audits.
The following technical experts were used to help with 1991/1992 audits:
1.
Security (11/91 - HL&P [STP). 7/92 - Entergy (Riverbend Station]).
2.
Radiation Protection (5/91 - OPPD [ Fort Calhoun),
5/92 - TUE (Comanche Peak])
3.
REMP (6/91 and 6/92 - OPPD (Fort Calhoun])
4.
E-Plan (7/91 - Iowa Electric (Duane Arnold), 7/92 - Entergy ( ANO))
5.
Fire Protection (11/91 and 11/92 - KCP&L) (11/91 and 11/93
- WONOC NSE Eng.)
6.
ASME NPT/NR Program (9/92 WONOC Results Engineering)
-~
AUDIT PROCESS B.
WCNOC has been active in supplying technical expertise to other plant in 1992 as follows:
1.
Security - Riverbend Station 2.
Radiation Protection - South Texas Project and Comanche Peak 3.
Radwaste Transpcrtation - Fort St. Vrain 4.
PERFORMANCE AND REPORTING A.
Entrance Meeting 1.
The audit process formally starts with the entrance meeting.
2.
The audit team and team leader are introduced.
3.
Audit plan is handed out and discussed.
4.
Organization's interface is assigned.
B.
Audit Conduct 1.
Auditors are directed to concentrate on performing the audit in a performance based approach as per NUREG/CR 5151, a) Auditors have participated in three training sessicas provided by John Johnson and company (JETS) to sharpen their skills in performance based assessments.
2.
Audit teams typically consist of at least two members or more.
3.
Audits generally are performed in a one month period.
4.
For audits performed under the cognizance of the NSRC, the assigned NSRC Interface is updated during the audit process as requested.
C.
Findings - Categories (Also applicable for Surveillance Process) 1.
Stop Work Order Manager QA has the authority to stop any WCNOC activity per' the USAR which pertains to repair, maintenance, and refueling activity.
O AUDIT PROCESS 2.
Corrective Action Request (CAR)
Used when other corrective action systems have not been effective in correcting a significant condition adverse to quality.
Since Commercial Operations, there have been six CARS initiated. The last CAR was concerning the chronic performance problems existing with the NPE Corrective Action System. All CARS have been closed.
3.
Quality Program Violation (QPV) a)
Issued to document significant conditiens adverse to quality.
o QPVs are those conditions which significantly impede the implementation or reduce the effectiveness of the program.
They require a root cause analysis by the PIR process.
4.
Quality Program Deviation (QPD) a)
Issued to document conditions adverse to quality which are not considered significant.
o QPDs are deficiencies of a programmatic or implementation nature which if left uncorrected could have an adverse effect on the program or the plant. They don't require a PIR and Root cause.
5.
Unresolved Item (URI) a) Used to document areas for which further investigation is warranted at a later date.
o An identified condition that verrants tracking by QA.
6.
Recommendation For Improvement (RFI) a)
Issued to identify areas for improvement in programs or performance.
o A mechanism to identify -and transmit information concerning opportunities for improvement, in performance of activities to appropriate levels of management for evaluation.
RFIs are not contrary to the Quality Program or may be applicable in areas for which explicit regulatory requirements may not currently exist.
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AUDIT PROCRSS D.
Audit Exit Meeting 1.
An informal pre-exit meeting is held with the audited organizations prior to the formal exit meeting.
2.
The formal exit meeting includes presentation of results for all audits performed during the month.
3.
The exit meeting typically includes line Management and Vice-Presidents and CEO.
E.
Reports 1.
Audit reports are generally issued within two weeks of the exit-meeting and are provided toi a) Management or the organizations audited, b)
Plant Safety Review Committee (PSRC) c) Nuclear Safety Review Committee (NSRC) 4 d) Executive Management e) NRC (QA has recently started providing the Resident NRC Inspectors with a copy of audit reports.)
V.
ENHANCEMENTS A.
QPVs and QPDs will be discontinued by documenting all conditions adverse to quality on PIRs, l'
- l. -PIRs will be issued during the audit as opposed to being issued with the audit report as QPVs and QPDs currently are.
2.
PIRs may not be closed in process without concurrence of the Manager-QA.
3.
The audited organization will be responsible for the significance.
deternination.
4.
The audited organization will be required to provide a corrective action.
plan and schedule'for completion to QA within 30 days of receipt.of-the
- PIR, 5.
Extension to corrective action due dates for PIRs will require approval from the Manager.QA.
6.
Upon receipt of' a completed PIR, QA vill schedule a follow-up j
effectiveness verification, i
AgDIT PROCESS 7.
Benefits to this change include:
a) Reducing the number of corrective action processes used-by VCNOC.
b)
Placing of ownership of the deficiency with the responsible organization, c)
Potentially, better root cause assessments by the responsible organizations for significant conditions.
B.
Fostering better relations with audited organizations.
1.
Improving incerpersonal skills of the evaluations personnel, a) This will be achieved through training and ongoing work with the evaluators.
2.
Proactively seeking input from the line organizations relative to upcoming audits of their activities.
3.
Development of an audit feedback survey for both the audited organizations and the evaluators.
4.
Interviews with line supervision and management to better determine their needs.
5.
Improvement of the audit report format.
6.
Establishment of an evaluator loan program where an evaluator is loaned for a period of time (e.g.,
1 month) to help the organization perform internal self-assessments.
C.
Reorganization of the Biennial Audit Schedule topics.
1.
Perform 10CFR50, Appendix B audits wbere all 18 Criteria, as applicable, are evaluated during one audit of a specific organization, thereby giving the Manager a better overall status of his organizations performance.
D.
Assign evaluators specific key functional areas for which he/she is responsible.
1.
Provides organizations with a dedicated QA person for discussing program and process issues.
2.
Allows for better defined training needs for the particular functional area for which the evaluator is assigned.
SURVEILLANCE AND ASSESSMENT PROCESS Planning and Scheduling Surveillances o
6 month Audit / Surveillance Schedule Topics are scheduled based on several factors, including:
Regulatory Issues or Concerns o
o Industry Issues or Concerns o
Follow-up of previously identified concerns o
Changes or revisions to programs To supplement coverage provided by audits o
Requests from other organizations o
Jump-up Surveillances These surveillances are planned and scoped based on ongoing plant activities or issues, or when requested.
During the last half of. 1992, and for future schedules, we have left open or unscheduled times to facilitate performing jump-up or requested evaluations, o
Requested'Surveillances o
Reauested Audits /Surveillances Conducted S-1878 Category III PMRs (3/91)
Director NPE S-1883 Diesel Generator Supply Fans (4/91)
Director Quality S-1896 Follow-up on LER 90-24 (9/91)
NSRC S-1947 Review of Contract Services (12/91) o Director Plant Operations o Director NPE-S-1961 Dose Assessment Capability (1/92)
Director Nuclear Services S-1971 Unauthorized Temp. Mod. (3/92)
MAP. Item IX.A.4' S-1972 Selection of Replacement Parts (3/92) WCNOC Executive Board Member S-1973 Access Authorization Rule (4/92)
HR S-1984 Unauthorized Temp. Mods. (9/92)
MAP Item IX.A.4 o-Reauested Audits / Surveillance to be conducted
-Audit - FAC Audit (during 1/93)
FAC Steering Committee l
Surveillance - Unauthorized Temp. Mods.
MAP Item - Ongoing Surveillance - E-Plan (ongoing through 5/93) Manager Technical Services i
,ra
'o Performance and Reporting of Surveillances Surveillances normally involve direct observation of an activity or activities, but may include reviews, or interviews as appropriate.
Surveillances can be performed by personnel who are not Certified Audit Team f,ead e r s.
Formal entrances are seldom used management and supervision responsible for the areas being evaluated are informed in advance.
Findings or concerns identified during surv' 111ances are discussed with responsible personnel and documented in the same manner as those identified during audits, t
Surveillance exits are scheduled upon completion of the surveillance.
During exits the results of the-surveillance are presented and discussed with management and supervision responsible for the activity or area evaluated.
Surveillance Reports use the same format as those for audits. Distribution of these reports ir.clude s Executive Management, and responsible management /
supervision.
Summaries of completed surveillances are presented at the monthly executive /
management audit exit meeting.
o Planning and Scheduling of Assessments o
Assessments are evaluations performed outside of the regular Audit / Surveillance Process, in accordance with KGP-1205, "Self Assessment Process'.
o Assessments are performed upon request from management.
o Assessments can be factored into the 6 month Audit / Surveillance Schedule or be performed as jump-ups, o
Planning and scoping is coordinated with and approved by the requesting-manager.
Assessment results are documented and reported to the requesting managers.
o o
The requesting manager is responsible for any corrective action which may be appropriate,.and for approval and distribution of the report, QA has been requested to conduct several assessments during 1992.
o INPO Follow-up Assessment:
2/92 (4 member team)
NUMARC Comprehensive Procurement' Initiative Assessment:
4/92 (4 member
-team)
E-Plan Pre Exercise 6/92 & 7/92 (10 member team)-
E-Plan Drill:
9/92 (10 member team) l
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Organizations have conducted their own assessment during 1992.
o Doors - Haintenance-IST - Results Engineering Radiological Controls for By-Product Haterial which is-processed, packaged, and transported as LLRW - HP RCA Tool Control - HP and Maintenance.
o ENHANCEMENTS o
In addition to those enhancements discussed in the audit process section, other enhancements include:
Development of a long-range surveillance schedule or plan.
or requested Continued use of open schedule space to facilitate jump-up evaluations.
Use of input from Nuclear Safety Analysis Group in the scheduling of' Outage Surveillance coverage.
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WCNOC OA SUMMARIES FOR 1991 & 1992 o"
Number of Audits /Surveillances Performed (1991 and 1992)
'o Quarterly Quality Findings (1991~& 1992)
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