ML20129D423
| ML20129D423 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/11/1984 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| KMLNRC-84-227, NUDOCS 8507160516 | |
| Download: ML20129D423 (51) | |
Text
r i
5)- V/.?)/ y. v' G'l KANSAS GAS AND ELECTRIC COMPANY T>E ELECTAC COMPANY r
7 OLENN L MOESTER December 11, 1984 Mr. Robert D. Martin Regional Administrator
%=-Q Region IV U.S. Nuclear Regulatory Commission uEC 1I N i
i d
611 Ryan Plaza Drive, Suite 1000 y
Arlington, Texas 76011 p
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Jh7 KMLNRC 84-227 Re:
Docket No. STN 50-482 Ref: Letter of 11/28/84 from RDMartin, NRC, to GLKoester, KG&E Subj: Wolf Creek Preoperational Test Program
Dear Mr. Martin:
The Reference identified the logistics for an Enforcement Conference on December 4,1984 concerning the Wolf Creek Preoperational Test Program.
The enclosure to this letter documents KG&E's commitments made during the meeting and provides a current status of those activities.
Yours very truly,
?!(/
GLK:bb Enc.
xc:PO'Connor (2)
RPDenise WBGuldemond HBundy 8507160516 841211 PDR ADOCK 05000492 G
- p/
l \\
201 N. Market - Wochita, Kansas - Mas! Address: RO. Box 208 l Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451 a
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,s EtCLOSURE 1 to KMLNRC 84-227 WOLF CREEK GENERATING STATION PREOPERATIONAL TEST PROGRAM CORRECTIVE ACTIONS The Wolf Creek Preoperational Test Program (PTP) was developed to verify
^
that the as-constructed plant components and systems, including alarms and indications, fulfill their design intent; to demonstrate, to the extent practicable, proper component and system response to postulated accidents; and to familiarize operating, technical and maintenance personnel with
~'
aspects of plant operation.
Prior to the Enforcement Conference, KG&E had recognized probles with meeting these objectives and had utilized internal vehicles of the overall KG&E QA program to begin corrective action.
'Ihese vehicles were in the form of Corrective Action Request (CAR) 20 issued on November 9, 1984 by the Quality Assurance organization, and Internal Operations Program Deficiency (IOPD) 84-08, also issued on November 9, 1984 by the Plant organization.
This enclosure sumarizes the activities associated with these two vehicles arxl provides a description of additional elements of KG&E's extensive corrective actions.
It is recognized that previous corrective actions concerning PTP activities had, in some instances, been ineffective.
However, KG&E believes that now, with the upper KG&E management attention being applied to the PTP, similar programatic deficiencies will not occur.
The NRC stated that the meeting was called to address the numerous instances of PPP deficiencies and was not called as a result of any specific occurrence.
The NRC also stated that an inspection report would be issued later documenting the findings discussed.
The findings were categorized as two violations and several weaknesses of the PrP.
NBC Inspection Report 84-38 discusses sme of the specific findings, but most have not been addressed in an inspection report.
As such, KG&E's description of these findings may differ in minor details of the findings, but we believe the generic underlying causes of the PrP problems are addressed herein, and this information is being provided now so that an l
expedited review by the NRC is possible.
Violation A - Failure to Test Functional Requirments in Accordance with FSAR Comitments The NRC had reviewed a small sampling of PTP results and found a proportionally large number (5) of FSAR comitments not included in the f
testing.
Response
These problems with the technical adequacy of the PrP had been identified individually over the pt months.
KG&E had been treating each as isolated instances of noncompliar.ce.
KG&E came to the realization, however, that there was potentially a generic problem, because of the NRC's small sample size, with the PrP. (
.s Consequently, a review team of sme of the most qualified personnel from the Operations, Quality, and Startup organizations was mobilized to review KG&E licensing documents for testing conmitments and then subssquently to check KG&E PTP activities for compliance with those committants.
'Ihat review effort is contin'2ing.
To date, the following documents have been reviewed:
1.
SNUPPS FSAR through Revision 16 and identified Revision 17 material.
~
2.
Wolf Creek FSAR Addendum through Revision 14 and identified Revision 15 material.
3.
Wolf Creek SER and Supplements through SSER #4.
This effort identified about 1250 design verification comnitments of which 7 were not included in the PTP, plus the 5 identified by the NRC.
Documents for which the review is not yet complete include the following:
1.
Wolf Creek " Final Draft" Technical Specifications.
2.
Regulatory Guide compliance was, and is, intensively reviewed as part of the normal preoperational test program procedure preparation effort.
In addition, selected Regulatory Guides, per Attachment 1 will be re-reviewed for PrP cmpliance.
A Results Report documenting activities ccmpleted as of December 3,1984 was provided to the NRC at the meeting.
Because of the low numbers of additional items found, KG&E believes that each item is an isolated instance and the PTP activities are technically adequate and do reflect FSAR comnitments.
The itms found have been included in appropriate test instructions.
KG&E believes that this conclusion will still be valid when all the above review activities are complete.
KG&E will document to the NRC the completion of these reviews, including KG&E upper management review of the review results, by December 31, 1984.
KG&E will perform a similar indepth coamitment compliance review of Initial Startup Test Program compliance. KG&E will cmplete this effort and document the review results to the NRC by December 31, 1984.
Violation B - Preoperational Test Program Procedural Violations During NRC review of completed preoperational tests, several instances of procedural noncompliances have been found.
Examples of such noncompliances include:
1.
Temporary modification controls not in accordance with procedures.
2.
Test discrepancy documentation errors.
3.
Suspended test control activities not in accordance with procedures.
4.
Inadequate test discrepancy log entries.
5.
Preoperational test procedural violations.
6.
Test change control program violations. :
Response
KG&E QA conducted an audit from August 31 to October 24,
- 1984, and identified an adverse trend concerning strict compliance with Startup Administrative procedures.
A management meeting was held on September 7,
- 1984, between QA, Operations, and Startup to discuss the high average of about 9 procedural discrepancies in test packages reviewed by QA.
Specific corrective actions were agreed to in the meeting.
A subsequent QA audit which began October 8, 1984, noted a 24% improvement to about 7 errors per test package.
KG&E managenent decided that this was still an unacceptably high error rate.
KG&E activities associated with CAR 20 and IOPD 84-08 were initiated and primarily directed towards minimizing errors in the adninistrative controls
-~
of the PIP.
'Ibese two documents are enclosed as Attachments 2 and 3,
respectively.
Specific corrective actions were taken to correct the specific problems identified and they are described in the attachments. The corrective actions for programnatic concerns are discussed herein.
KG&E has identified two significant root causes for the high procedural error rate.
They were:
1.
Schedular pressures.
2.
Combersome Startup Administrative procedures.
Each of these root causes will be addressed in turn.
The most significant cause is the schedular pressures which apparently resulted in a lack of attention to detail.
This should never have happened because KG&E management has always enphasized that the schedule was secondary in importance relative to quality performance of activities.
However, as construction was completed, the pressure to complete preop tests on a tight schedule was allowed, through oversight, to unduly influence test engineers. To relieve perceived schedular pressures, the following actions were taken:
1.
Upper management conducted meetings with everyone in the Startup and Operations organizations to discuss project priorities and requirements.
The requirement to adhere to procedures was enphasized. Each meeting group was informed that they were expected and required to take the time to do an activity properly, regardless of schedular impact.
Proper preparation and coordination to permit activities to be performed right the first time was stressed.
Similar meetings were also conducted with the Quality and Construction groups.
2.
A new scheduling method was developed.
The fuel load / plant ccmpletion schedules issued November 24, 1984, and subsequently, reflect the new method.
The schedule has no contingency for unidentified problens, but does include increased time allowances for the completion of activities of.the types which were identified in the past to have unrealistic schedules. L
=
3.
Daily site management meetings are held to go over quality concerns,
~
tasks in progress, and problem areas.
tese meetings, along with the weekly schedule review meeting, provide for prompt feedback to management of schedular problems.
Management is then available to revise schedules, if appropriate, and thereby relieve undue pressures.
The schedule has subsequently been adjusted in this manner several times, and should have demonstrated to test personnel that the schedul.e is secondary to quality.
4.
Management involvement in planning and coordinating activities has been increased.
Line managers were instructed, in the' meetings described in 1) above, to spend more time in the field to verify that procedures are being followed and to provide coordination of problem areas.
Cumbersome Startup Administrative procedures is the other root cause.
To improve procedure ccxnpliance and better understanding of Administrative procedures the following actions have been taken or directed:
1.
Individuals key to the direction and control of the FTP were examined to determine their knowledge of program administrative requirements.
Of the 185 individuals examined, 148 passed initially.
Wirty were retrained, tested and recertified.
One individual was decertified, and 6 individuals not involved in testing activities are to be retrained.
2.
To ensure that the Nuclear Department personnel fully understand the significance of proper adherence to procedures, and to provide a consistent policy for disciplinary action for non-adherence to procedures, a Nuclear Department policy entitled " Adhering to Established Guidelines" was issued on November 16, 1984. The policy will be placed on the required reading list for plant operating personnel. Startup supervision will review the policy with all test engineers. Wese activities will be complete by December 21, 1984.
3.
Startup Adninistrative Procedure ADM 14-200 (Preoperational Testing Implementation Procedure) is being revised to include criteria for the use of Temporary Change Notices and to limit the number of test discrepancies. We revised procedure will be issued by December 14, 1984.
4.
We Operations organization has initiated a 100% re-review of all FSAR required PTP packages for compliance with Startup administrative requirements, to insure that any administrative errors missed during the initial preop post test review do not compromise the test validity.
Consistent evaluation criteria is being applied during the review.
The re-review does include in its scope already vaulted PPP packagos.
The elements of this enhanced review will be applied to those preop tests not yet completed.
This effort will be complete by Wolf Creek fuel load. -
r 5.
Startup management activities have been enhanced to requira more detailed involvenent by the respnsible supervisor prior to written test start authorization, and to provide more comprehensive daily
- coaching, direction, and monitoring of test engineers by their supervision.
'Ihe Startup Technical Support Group also conducts daily independent review of active plant testing.
Review results are provided to the engineer and to his supervisor for follow-up during the daily coaching sessions.
Details of these enhancements are provided in Attachment 3,Section III.B.1.
6.
Control Room activities are 'also being monitored by the Shift Advisors.
Written observations of activities taking place are reported to the Superintendent of Operations.
Corrective action is taken based upon the observations, when required.
The observations will continue until the Plant Manager concurs they are no longer needed.
More detail concerning these observations is given in Attachmant 3,Section III.B.3.
i Since the PrP is almost complete, it must be recognized that Startup activities will be complete in a short time,
- and, therefore, extensive efforts to correct Startup procedures would have little effect.
- Instead, KG&E has started converting the necessary Startup procedures over to permanent Operating procedures. This effort is to be complete by fuel load.
The potential also exists for some Operations Adninistrative procedures to be considered cumbersome. However, since KG&E management has stresced to the affected personnel the importance of compliance with procedures, KG&E will strictly follow any procedure until such time as the procedure is revised.
KG&E procedures have been, and will continue to be, revised in this manner when the need for such revisions are identified and approved.
Weaknesses in the Preoperational Test Program The NIC stated that the following were weaknesses in the Wolf Creek PTP:
l l.
Acceptance criteria for tests were not evaluated against technical specification acceptance criteria.
2.
Testing methods and acceptance criteria were not reflective of potentially limiting plant conditions.
a 3.
Inappropriate instrumentation was used during testing.
4.
Substantial test procedure changes were required throughout the PTP.
5.
Several tests were voided late in the PrP package review process.
6.
Test packages were vaulted without controls to ensure that the packages were complete... -.
o 7.
Test package review time is untimely.
8.
Preoperational' test scheduling creates undue pressure.
9.
Test engineers were not familiar with system operation.
- 10. Control Rom Operations' personnel were not aware of testing activities in progress.
Response
1.
The actual concern was a preop test which was more restrictive than the requirements of Regulatory Guide 1.108 in the testing of the emergency diesel generator.
The Technical Specification correction was due to a reference in the Technical Specifications to the Regulatory Guides.
This Regulatory Guide, however, is also a comnitment of the FSAR.
As stated above, in order to insure there are no other corrections to the PrP fran the Technical Specifications, a review of the Preop Acceptance Test Criteria will be made of each preop test against the Technical Specifications for that system.
2.
As stated above, the FSAR commitment compliance reviews have determined that the PTP does, except for isolated instances, reflect limiting' plant conditions.
For those ' isolated instances test results will be evaluated and extrapolated as appropriate.
3.
Increased awareness by the various reviewing organizations, i.e.,
Operations, Results Engineering, Quality Engineering, and Quality Control, of this weakness will insure this type of concern is prevented.
4.
'Ihe corrective actions of CAR-20 and IOPD 84-08 address this weakness.
5.
'Ihe Startup supervision review efforts, the increased Startup supervision presence in the plant, and the Startup administrative procedure revision criteria, described above, have given lower tier Startup personnel guidelines and checks on testing activities such that late test voiding should be minimized in the future.
These guidelines will ensure that when test packages reach the JTG significant deficiencies will no longer exist.
6.
A system is now in place to insure all vaulted packages are page numbered prior to submittal to the vault.
In addition, the JTG preop procedure review comnents will be added to the vaulted completed test package.
7.
KG&E acknowledges that test reviews have taken longer than is desirable.
Elements of the corrective actions described in this letter will result in more timely test review.
8.
Activities to reduce scheduling pressures were described above.
O 9.
The test start authorization program will reconfirm that each test engineer is knowledgeable and prepared to conduct the specific test.
10.
The Plant Manager met with all the Shift Supervisors and Supervising Operators stressing that Control Room Operations personnel must be cognizant of all activities ongoing in the plant, including Startup testing activities.
KG&E management observations have since identified that Operations personnel are now more knowledgeable of plant testing activities down to the level of the specific step being worked for tests in progress.
Sumary KG&E acknowledges that PTP deficiencies did exist.
While each in the 1,ast were treated as isolated instances, the number of such instances caused KG&E to evaluate the underlying causes for the deficiencies.
The main causes were determined to be schedular pressures and difficult to use administrative procedures.
KG&E management has taken the appropriate preventative and remedial actions to address these effects so that future activities will not have similar deficiencies.
Management has reinforced to the JTG that their PSRC Subconmittee role, as the final authority for approval of PTP results, places the burden for a quality PTP on them.
Management has also put more emphasis on converting from a construction atmosphere and controls to an operating environment and controls, including more supervisory involvement in ongoing activities.
One of supervisions primary functions will be to stress the Wolf Creek "do it right the first time" philosophy.
KG&E is providing this response to the NRC prior to the issuance of your inspection report so as to help resolve the noted violations and weaknesses in an expeditious manner.
' to Enclosure to KMLNRC 84-227 KG&E Page 1 REGULATORY GUIDE REVIEW
SUMMARY
12/11/84 REGGUIDE REY DATE TITLE (SUBJECT)
REYlEW REASON Y@
1.1 0
11/2/70 SAFEGUARDS PUMPS NPSH YES 1.2 0
11/2/70 RV THERMAL SH0CK N0 3,4 1.3 2
6/74 ASSUMPTIONS FOR BWR RADIOLOGIC.. ANAL NO N/A 1.4 2
6/74 ASSUMPTIONS FOR PWR RADIOLOGICAi ANAL YES 1.5 0
3/71 ASSUMPTIONS FOR BWR STEAM LINE BREAK NO N/A 1.6 0
3/71 IND OF POWER SYSTEMS YES 1.7 2
11/78 LOCA COMBUSTIBLE GAS CONTROL YES 1.8 2
2/79 PERSONNEL SELECTION & TRAINING NO 5
~
1.9 1
11/78 QUAllflCATION OF DIESEL GENERATORS YES 1.10 1
1/73 CONCRETE CADWELD SPLICES NO 7,1 1.11 0
3/71 CTMT INSTRUMENT LINE PENETRATIONS YES 1.12 1
4/74 INSTRUMENTATION FOR EARTHQUAKES YES 1.13 1
12/75 SPENT FUEL STORAGE DESIGN YES 1.14 1
8/75 RCP FLYWHEEL INTEGRITY NO 1,3,4 q.g 1.1S 1
12/72 REBAR TESTING NO 7
j 1.16 REPORTING 0F 0PERATING INFORMATl0N NO 5,6 (If 1.17 INDUSTRIAL SAB0TAGE PROTECTION YES 1.18 1
12/72 STRUCTURAL ACCEPiANCE TEST YES'
[f}
1.19 1
8/72 NDE OF CONTAlllMENT LINER WELDS NO 7,1
+
1.20 2
5/76 REACTOR VESSEL INTERNALS VIBRATION YES j{
u-1.21 1
6/74
' RAD RELEASE MEASUREMENT / REPORTING YES
,.;;cg?,
- . w an 1.22 0
2/72 PERIODIC TESTING 0F PROT SYSTEMS YES d[h.-
..g m
,..hf! JA 1.23 ONSITE METEOROLOGICAL PROGRAM YES
- ~f" Q'
1.24 0
3/72 ASSUMPTIONS FOR WASTE GAS TANK FAILURE YES
. 2.9/O
~ ? ' -
,,' jk?$
1.25 0
3/72 FUEL HANDLING ACCIDENT ASSUMPTIONS
- YEL g -
e-O-
?
.,.. A;.; pm,q7:im;p;np'. Ww;niEFuu nM2
_.........-.::::,..f$$ $ 'Y" EuV.m V ~%.h kE'2In
l' KG&E Pege 2 REGULATORY GUIDE REVIEW SUt1 MARY 12/11/64 REGGUIDE REY DATE TITLE (SUBJECT)
REVIEW REASON b
1.26 3
2/76 QUAllTY GROUP CLASSIFICATIONS NO 5
1.27 2
1/76 ULTIMATE HEAT SINK YES 1.28 2
2/79 QA REQUIREMENTS (DESIGN & CONSTRUCTION) ND 5,1 1.29 3
9/78 SEISMIC DESIGN CLASSIflCATION NO 5
1.30 0
8/72 QA REQUIREMENTS (INST & ELEC TESTING)
YES 1.31 3
4/78 FERRITE CONTROL IN WELDING N0 5,7 1.32 2
2/77 SAFETY-RELATED ELECTRICAL POWER SYSTEMS YES 1.33 2
2/78 QA PROGRAM (OPERATIONS)
NO 5,6 1.34 0
12/72 ELECTR03 LAG WELDING CONTROL NO 5,7 1.35 3
4/79 ISI FOR UNGROUTED TENDONS YES 1.36 0
2/73 NON-METALLIC INSULATION NO 1,7 1.37 0
3/73 OA FOR CLEANING NO 5
1.38 2
5/77 QA FOR SHIPPING, STORAGE, ETC.
NO 5
1.39 2
9/77 HOUSEKEEPING REQUIREMENTS N0 5
.ty.k 4
1.40 0
3/73 CONTAINMENT MOTOR QUALITY TESTING YES 17 M
1.41 0
3/73 PRE 0P TESTING 0F ONSITE ELECTRICAL YES 72
~ 9.0 1.42 (NONE - WITHDRAWN)
NO N/A
!?/k
?i?
1.43 0
5/73 STAINLESS WELD CLdD CONTROL NO 5,7 Misi) i."'ll 1.44 0
5/73 SEN3ITIZED STAINLESS STEEL CONTROL NO 5,7
- {
]
1.45 0
5/73 RCPB LEAK DETECTION SYSTEMS YES
- 1) j M
l 1.46 0
5/73
, PIPE WHIP PROTECTION NO 1,7
.CM 1.47 0
5/73 STATUS INDICATION YES l
l 1.48 0
5/73 SEISMIC i OPERABILITY TESTING / LOADS NO 3,4
=r.12$U
~.
...yg 1.49 1
12/73 POWER LEVELS NO 1*4 app..Q.MY yyM e.n,,r.o - M.
l 1.50 0
5/73 WELDING PREHEAT CONTROL _
NO..s 5,7. g'~
s
. g.a.; y$..
~..,.. e. ; ;; :
w vmm N
NI
.1 N '. *.
_1 m _...
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KG&E Page 3 REGULATORY GUIDE REVIEW SUl1 MARY 12/11/84 REGGUIDE REY DATE TITLE (SUBJECT)
REVIEW REASON Yi 1.51 (NONE - WITHDRAWN)
NO N/A 1.52 2
3/78 HEPA/CHARC0AL flLTER TESTING YES
!.53 0
6/73 SINGLE FAILURE CRITERIA YES 1.54 0
6/73 QA FOR PROTECTIVE COATINGS NO 5,7 1.55 0
6/73 CONCRETE PLACEMENT NO 7,1 1.56 1
7/78 WATER PURITY MAINTENANCE (BWR)
NO N/A 1.57 0
6/73 DESIGN / LOADING LIMITS FOR CTMT LINER NO 1,4,7 1.58 1
9/80 QUAllflCATl0N 0f TESTING PERSONNEL NO 5
1.59 2
8/77 DESIGN BASIS FLOODS NO 1
1.60 1
12/73 RESPONSE SPECTRA NO 1,4 1.61 0
10/73 DAMPING VALUES NO 1,4 1.62 0
10/73 MANUAL INITIATl0fl0F PROT ACTIONS YES 1.63 2
7/78 CONTAINMENT ELECTRICAL PENETRATIONS YES 1.64 2
6/76 QA FOR DESIGN NO 1,5
,.$,i M
1.65 0
10/73 MATERIALS INSPECTIONS FOR RY STUDS NO 5,7,1
]
.5 1.66 (NONE - WITHDRAWN)
NO N/A IDf j y's 1.67 0
10/73 INSTALLATION OT 0/P PROT DEVICES YES
'0/$
i
~
L25 l
1.68 2
8/78 INITIAL TEST PROGRhM YES' M)b
. p-j; 1.68.1 1
1/77 TEST Of FEEDWATER/COND f0R SWR 3 NO N/A M
4h[z$
1.68.2 1
7/78 TEST Of REMOTE SHUTDOWN CAPABillTY YES
. ~:::;
i 1.68.3 0
4/82
' TEST Of I & C AIR SYSTEMS NO N/A lishf af 3,45. "pH i
1.69 0
12/73 RADIATION SHIELDS N0 1,7 l
.?N)Sk l
1.70 3
11/78 FSAR FORMAT GUIDE NO 5
46Hif n;.lgy.aq 1.71 0
12/73 WELDER QUAL (LIMITED ACCESS)
NO 5
- ..jTGp '
....~.RTiG$d.!!??
1.72 2
11/78 FIBERGLASS SPRAY PANEL PIPING N0 cN/A E cc M G W % f i
m 3
me:saw w m w
.t me l
- -* A *f; E. i IJ
. - A:%.,l'
%,$C 7 $s # ** M *4 *
, ' O* Y$$$YW,;rL... '.,.' -Yht '.YOY.':,.8NbN YA'W '
KG&E Page 4 REGULATORY GUIDE REVIEW
SUMMARY
12/11/64 REGGUIDE REY DATE TITLE (SUBJECT)
REYlEW REASON
~'T-1.73 0
1/74 QUAL TESTS Of CONT EMG'S YES 1.74 0
2/74 QA DEflNITIONS NO 5
1.75 2
9/78 PHYSICAL IND Of ELECT SYSTEMS YES 1.76 0
4/74 DESIGN BASIS TORNADO NO 1,4 1.77 0
5/74 CONTROL R0D EJECTION ASSUMPTIONS N0 4
1.78 0
6/74 CONTROL ROOM HABITABillTY ASSUMPTIONS YES 1.79 1
9/75 ECCS PREOPERATIONAL TESTING YES 1.80 0
6/74 INSTRUMENT AIR PRE 0PERATIONAL TESTING YES 1.81 1
1/75 SHARED ELECT SYSTEMS FOR MULTI-PLANTS NO N/A 1.82 0
7/75 ISI FOR STEAM GENERATOR TUBES NO 7
1.84 16 5/80 ASME CODE CASES NO 1,5 1.85 16 5/80 ASME CODE CASES (MATERIALS)
NO 1,5 1.86 0
6/74 TERMINATl0N0f 0PERATING LICENSES N0 5,6 1.87 1
6/75 C0flSTRUCT10fl 0F HIGH TEMP REACTORS NO N/A 1.88 2
10/76 HANDLING OF GA RECORDS NO 5
l
- '$$If 1.89 0
11/74 QUAliFICATl0N OF 1E EQUIPMENT N0 3
73 1.90 1
8/77 ISI f0R GROUTED TENDONS N0 N/A
. -,.,d j
1.91
' TRANSPORT ROUTE EXPLOSIONS NO 4,5 M.
1.92 1
2/76 SEISMIC MODAL RESPONSE COMB N0 4,1 pqy 5
1.93 0
12/74
. AVAILABILITY OF ELECTRICAL POWER SOURCESYES gy;.
. e.. < mix -
1.94 1
4/76 QA FOR CONSTRUCTION N0 5,7
.t;;mug l
- ; %,:WNE
~ 16W.w 4 1.95 1
1/77 CONTROL ROOM PROT FOR CHLORINE YES
";i
^ ' 352.
...,.' N ' if, 8 1.96 1
6/76 BWR MSlV3 NO N/A
. a y gll,3 7
1.97 1
8/77 POST-ACCIDENT MONITORING YES... W{d[E{kfd m%ies:',,~
%Mrafi;3k q;.hha.wh-o @,sny&i)f S?.;624 >- -
e.
..+
~
0.
KG&E Page 5 REGULATORY GUIDE REVIEW
SUMMARY
12/11/64 REGGUIDE REY DATE TITLE (SUBJECT)
REYlEW REASON 5-k 1.98 0
3/76 BWR OfFGAS ASSUMPTIONS NO N/A 1.99 1
4/77 RX YESSEL MATERIAL RADIATION DAMAGE N0 3,4 1.100 1
8/77 SEISMICQUALOf ELECTRICAL EQUIPMENT N0 3,4 1.101 (NONE - WITHDRAWN)
NO N/A 1.102 1
9/76 FLOOD PROTECTION YES 1.103 1
10/76 POST-TENSIONED / PRE-STRESSED CONT YES 1.104 0
2/76 OVERHEAD CRANE SYSTEMS NO WiD 1.105 1
11/76 INSTRUMENT SETPOINTS YES 1.106 1
11/76 EMD THERMAL OVERLOADS YES 1.107 1
2/77 QUAL FOR TENDON GROUTING NO N/A 1.108 1
8/77 DIESEL GENERATOR TESTING YES 1.109 1
10/77 APPENDIX i DOSE CALCULATIONS NO 4
1.110 0
3/76 RADWASTE COST /BENEflTS ANALYSIS N0 4
1.111 1
7/77 ESTIMATING AIR RELEASE DISPERSION N0 4
1.112 0
S/77 EFFLUENT RELEASE CALCULATIONS NO 4
1.113 1
4/77 ESTIMATING WATER RELEASE DISPERSION N0 4
.; }
1.114 1
11/76 OPERATOR GUIDANCE NO S,6 r.;
1.11S 1
7/77 TUR8INE MISSILE P50TECTl0N NO 1,4 jf
- 5;f;l 1.116 0
S/77 QA FOR MECHANICAL EQUIPMENT N0 5
.9k Onw 1.117 1
4/78 TORNADO DESIGN CLASSiflCATION NO 1,5 Nk
- m 1.118 2
6/78
' TESTING 0F ELECTRICAL SYSTEt13 YES J$7 gk 1.119 (NONE - WITHDRAWN)
NO N/A VM[
.,. @U -
E 1.120 1
11/77 flRE PROTECTION YES
~:&gjj
li..
1.121 0
8/76 STEAM GENEPATOR TUBE PLUGGING N0 6,7 lj
..g
. L.Wl:bar-1.122 1
2/78 FLOOR RESPONSE SPECTRA NO 14..c.'M bSp2
- i.;njp Mf@,"-
. m.,
..,,w
_kbedNh9254_:*'.
<d%GA E
2
~
.=
r KG&E Page 6 REGULATORY GUIDE REVIEW
SUMMARY
12/11/84 REGGUIDE REY DATE TITLE (SUBJECT)
REYlEW REASON 5-1.123 1
7/77 QA FOR PROCUREMENT NO 5
1.124 1
1/78 COMP SUPP SERYlCE LIMITS N0 4
1.125 1
10/78 MODELS FOR HYDRAULIC STRUCTURES NO 3,4 1.126 1
3/78 FUEL DENSlflCATION MODEL N0 4
1.127 1
3/78 WATER CONTROL STRUCTURE INSPECTION NO 5,7 1.128 1
10'/78 STORAGE BATTERY INSTALLATION YES 1.129 1
2/78 MAINTENANCE & TESTING 0F BATTERIES YES 1.130 1
10/78 COMP SUPPORT SERVICE LIMITS NO 1,4 1.131 0
8/77 QUAL TESTS 0f ELECTRICAL CABLES N0 3
1.132 1
3/79 SITE INVEST. FOR FOUNDATIONS NO 5,7 1.133 1
5/81 LOOSE PARTS MONITORING YES 1.134 1
3/79 MEDICAL EVALUATION Of OPERATORS N0 5
1.135 0
9/79 NORMAL WATER LEVEL & DISCHARGE YES 1.136 1
10/78 MATERIAL FOR CONCRETE CONTAINMENT NO 1
1.137 1
10/79 DIESEL GENERATOR FUEL Olt YES 1.138 0
4/78 SOILS ENGINEERING ANALYSIS N0 4
fr:{4 I
1.139 1
2/80 RESIDUAL HEAT REM 0YAL YES as 1.140 0
3/78 AIR flLTRATION CRITERIA YES' 1.141 0
4/78 CONTAINMENT ISOLATION SYSTEM YES
{'jf x
1.142 0
4/78 SAFETV-RELATED CONCRETE STRUCTURES-NO 1,4 H.g,
.,2 -
1.143 0
7/78
' RADWASTE DESIGN GUIDANCE NO 1
5 vn 1.144 1
9/80 QA AUDITING N0 5
- I*
,my 9:
l 1.145 0
8/79 ATMOSPHERIC DISPERSION MODELS N0 4
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-D' 1.146 8/80 QUAliflCATIONS FOR QA AUDIT PERSONNEL N0 5
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1.150 1
2/83 REACTOR YESSEL UT NO
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Page 7 CODE REASON 1
DESIGN -
Design statement only, or commitment satisfied by the design process alone. Also
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includes construction-related activities.
2 TYPICAL -
Not an acceptance criterion requiring preoperational test verification.
3 TEST -
A commitment satisfied by '.ype,
[
model or vendor testing alone.
4 ANALYSIS -
A commitment satisfied by analysis only, or a combination of analysis and test.
5 PROGRAM -
A commitment satisfied by programmatic controls, which 1:
needs not be reflected in individual preoperational tests.
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STARTUP -
A commitment satisfied by post 2jd '
fuel load testing, rather than
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l preoperational testing.
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7 COMPONENT - Satisfied by component or NDT testing, rather than MA
..w preoperational testing.
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DUPLICATE -
An item which duplicates other F
identified commitments.
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a av N/A NOT APPLICABLE - Not appilcable to WCGS
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" to Enclosure to KMLNRC 84-227
,o.. ori inv. i. 7 INTEROFFICE CORRESPONDENCE
'IO:
R.T. Rhodes KCWLKWO 84-655 FROM:
W.J. Rudolph II N
DATE:
Novmber 9, 1984 SUBJECr:
Corrective Action Request (CAR) No. 20 Attached is Corrective Action Request (CAR) #20 which is being issued to obtain corrective actions to probims associated with procedural empliance (implementation).
The. problem was initially identified while performing Audit TE: 50140-K007 "Preoperational Testing" and resulted in a senior managment meeting on September 7,1984.
A subsequent QA audit and an analysis of previous audit and surveillance reports have indicated continuing implementation probles.
Please respond to this Corrective Action Request by completing Section 5 of the subject CAR.
Your schedule for 'impimenting corrective actions and an explanation of any actions you have already taken should be suhnitted to me by November 16, 1984.
WJR/sjs Attachments 5
cc:
G.L. Koester R.M. Grant C.C. Mason R.J. Glover C.G. Patrick C.E. Parry
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KQF-60 Fav. 2/84 E 50501 WOLF CREEK M%TI!G STATIO1 E
y CORRECTIVE ACTION REQUEST CAR ED.
>n 1.
CCNDITICN DESCRIFFICN:
See attached,Section I 2.
RESPONSIBLE CBGANIZATIG4:
KG&E Operations and Startup 3.
CAUSE CF CCNDITICN:
See attached,Section IV 4.
RECOMMENDED CCRRECTIVE ACTICN:
See attached,Section V 099
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2 st-9 ~94 Faviewer Date (d J d f]d // - P-W Quall-@ch Representative Date 5.
SCliEDULE FCR IMPI.EMENTATICN CF ACTICN:
Responsible Supervisor Date
~
6.
NBC REPCRTABLE: Yes 7.
SICP WORK ACTICN TAKEN: Yes mg If Yes, Report #
8.
CCRRECTIVE ACTION VERIFIED - Medied or Verirication:
Quality Brancn Representative Date Supervisor s
Date 9.
CAR CLCSED:
Yes i
s
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Quality Brancn Representative Date Supervisor Date;
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- 10. APPROVAL
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[Wllf Director - Quality 9b
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IC&E OPL GR #29 Page 2 I.
ENDITICH TR9fitIPTIN A.
Procedural Ccupliance The continued lack of procedural etnpliance in the Startup.and Operations organizations has diminished the effectiveness of their Quality Assurance Fr@ asis and hence constitutes a Quality Program Breakdown.
This is particularly relevant to pre-operational testing activities.
B.
Management Discipline Problems associated with procedural ocupliance were previously brought to the attention of Startup/ Operations managenent.
The corrective action measures taken thus far have been relatively ineffective.
II.
OBJECTIVFS To determine the primary causes for the Quality Program Breakdown.
e To firmly obtain nanagement awareness of the significance of the e
problens.
e To obtain the necessary level of management discipline that will facilitate procedural carpliance.
e To ensure that the personnel performing safety-related activities are aware of procedural requirements.
e To ensure that the proper quality attitude is established and maintained throughout the Operations and Start-up organizations.
e To obtain objective evidence of ratedial actions for items that have not been previously evaluated and/or corrected.
e To obtain objective evidence of measures taken that will prevent recurrence.
III. BACICRCEMD INFORRTICN
>H e Between January, 1984 and the present, fourteen (14) audits and thirty-seven (37) surveillances resulted in the identification of f
ninety (90) instances of procedure noncoupliances. The majority of s
the findings represent minor instances of procedural noncoupliance however the cumnulative effect represents a significant Quality
, ( '.h concern.
(See Attachment A).
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KG&E QA CAR 929 Page 3 e On September 7, 1984, a management meeting was held to discuss concerns raised by the Manager Quality Assurance (WCGS) at the September 6, 1984 Project Quality Review Meeting.
The concerns specifically addressed a continuing negative trend associated with the administrative cmpliance to Startup test procedures.
Startup and Operations nanag ment cocTnitted to the impleentation of corrective actions designed to eliminate procedural noncompliances.
(See Attachment B) e On October 26, 1984 the Manager Quality Assurance (NCGS) and a NRC Reactor Inspector discussed NRC concerns relative to procedural cmpliance in the Startup and Operations organizations.
It was noted by the NRC that this issue would be a topic of discussion during a scheduled meeting with senior NRC and KG&E management personnel at Region IV headquarters on October 29, 1984.
o On October 29, 1984 the above noted meeting took place during which senior NRC personnel expressed significant concerns relative to the issue of procedure compliance and that an escalation process associated with NRC violation levels was being imple ented.
e On October 30, 1984 the KG&E Project Director convened a meeting to discuss the concerns expressed by the NRC.
Startup and Operations management were directed to prepare a detailed Corrective Action Plan to address the procedure compliance concerns..
On November 9,1984 KG&E QA issued Corrective Action Request #20.
o IV.
CAUSE OF C0t01 TION A.
The following causes have been identified as contributing to the continued lack of procedural empliance, Schedule pressures resulting in a lack of attention te detail.
e Failure of management and supervision to recognize the benefits e
of, establish and maintain a positive quality attitude at the
" worker" level (i.e. implementation level).
j Confusing and/or cumbersome implementation procedures coupled e
with the lack of training to Quality Program and procedural requirments.
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FIlOINGS, IMPMTS, RED 99!30ED CORRK2IVE ACPIONS Finding fl: Contrary to 10CFR50, Appendix B,
Criteria V titled
~
" Instructions, Procedures and Drawings"; there is a lack of procedural compliance associated with preoperational testing activities.
Impact:
The cumulative effect of the procedural noncompliances could adversely affect the validity of the test results.
Re m.e ded Corrective Action:,
la) Decrease the apparent schedule pressures on the personnel
~
performing testing activities.
lb) Perform and document a review of all FSAR required and currently vaulted (as of 11/09/84) pre-operational test packages to identify all instances of procedural noncom-3 pliance; Or, impiment the recomended corrective actions associated with QPV 9/84-59A.
lc) Test and re-certify all Startup/ Operations personnel actively engaged in performing startup testing.
.The examination should be documented and include the follow-ing topics:
Quality Prograni Requirments e
(e.g., Nuclear Department Policy :!anual, FSAR, etc.)
e The specific procedures that govern their scope of work.
(e.g., ADM's, etc.)
e Other applicable general site procedures (e.g., ADM 01-033, ADM 01-063, etc.)
NOTE: General Employee Training (GET) is not con-sidered sufficient.
ld) Develop and implement a Nuclear Departmnt Policy describing the importance of procedural compliance and providing actions to be taken, including disciplinary
- actions, if willful and/or repeative procedural noncom-pliance occurs.
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le) For individuals not achieving the requisite pass / fail criteria associated with the examination of Ic (above)
.f perform the following:
j Imediately relieve the individual of all Startup e
testing responsibilities.
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- y Re-train and re-exam the individual.
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',%.in e Upon re-examination, if failure occurs dismiss the Q:A individual or permanently relieve the of Startupjg,lg testing involvment.
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s KG&E QA CAR 629 Page 5 If) Reiterate to all personnel that verbatim compliance to the test procedures and administrative requirements is -,I ~
mandatory and takes precedence over schedule considerations.
Ig) Incorporate the following criteria in the preoperational testing implementation procedure, ADM 14-200:
a.
The issuance of five (5) or more major 'ICN's should require a procedure revision.
b.
Eliminate the use of minor 'ICN's.
~ - -
c.
In no case shall the number of test steps changed by
'ICN's exceed 30% unless the procedure is revised.
d.
If more than five (5) test discrepancies are identified due to procedural noncompliances, the entire test shall be repeated.
Exceptions to this recomendation may only be granted by the Plant Manager.
Findina 52: Contrary to 10CFR50 Appendix B, Criterion XVI, titled
" Corrective Action",
the significant conditions adverse to quality that have been identified in this document have not received the level of managanent attention necessary to correct the conditions and to prevent their recurrence.'
Impact:
The apparent lack of communication and reinforcement of positive quality attitudes on the part of management and supervision may have adversely affected the quality attitudes of the workers (implementation level).
Rem.oeided Correc[ive Action:
2a) Identify any additional " root causes" that have not been previously identified in this report.
i.~
,2b) Explain the failure of the 9-7-84 management meeting
?q (Attachment B) to rectify the procedural compliance i
probims.
M
~.A, 2c) Ensure that the causes identified in recomendation 2b s f @4 (above) will not preclude the effectiveness of the
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- 4 KG&E QA CAR 629 Page 6 2d) Explain the failure of Startup/ Operations management to utilize the means already established (e.g.,
Quality Assurance Trend Analysis Reports, Managenent inputs, Audit and Surveillance Reports, JTG Meeting Minutes) to identify a _significant trend adverse to quality associ-ated with the implementation of procedures.
2e) Explain the failure of Startup and Operations to:
management e Identify these generic concerns prior to Quality L.
Assurance reporting the problems.
Take prompt and thorough corrective action.
e 2f) Explain why the activities were not stopped prior to the issuance of this Corrective Action Request.
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- 4 KG&E QA CAR 426 A'ITACNENF A Page 1 of 8 BACKGROUIO INFORMATION SAMPLE OF IMPLEMINFATION FI E INGS - JANUARY, 1984 TO PRESENF
- ~
(Not All Inclusive)
Date Event Comments 08/22/84, S-lll6 Contrary to ADM 01-036 and ADM 08-300,Section XI repairs were conducted w/o implanenting the require-ments of the.above ADMs.
(QPV 8/84-36) 09/17/84.'
S-1153 Contrary to ADM 14-414, improper processing " Rework Plan Tracking & Completion" form.
(QPD 9/84-57) 03/23/84 57953-K030 Contrary to ADM 01-048, material requisitions did not reference the correct requirements on Level V evalu-ation sheets.
(QPV 3/84-01) 03/23/84 57953-K030 Contrary to ADM 07-406, procurenent documents were vaulted without the correct approval signatures.
(QPD 3/84-02) 05/08/84 57953-K042 Contrary to ADM 01-043, a Vendor Work Plan was not completed prior to Westinghouse performing work on S/G's.
(QPV 4/84-32) 05/23/84 S-1041 Contrary to ADM 14-200, S.U.E. failed to adequately verify system instru:nentation.
(QPD 5/84-39) 05/23/84 S-1039 Contrary to 10 CE'R 50, App.
"B", Crit. V, flushing &
hydro procedures and results were not "of a type appropriate to circu:nstances"; very difficult to follow.
=
(QPV 5/84-29) 06/14/84 S-1061 Contrary to ADM 14-406, Equipment Renoval Tags were being improperly utilized.
(QPV 6/84-47) r 06/14/84 S-1961 Contrary to ADM 14-104, Systen Cleanness Verification Diagrams failed to indicate proper flush pkg. scope.
(QPV 6/84-44) 4 06/22/84 S-1070 Contrary to FHP-01-001, fuel handling cable was
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tensioned while fuel assenbly was still clamped.
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(QPD 6/84-58) e[,
.s 07/12/84 S-1085 Contrary to ADM 14-200, 101 QC verification was not kye:48 properly N/A'd or signed.
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ATTAC19ENT A Page 2 of 8 Date Event i
Cuaaents 07/12/84 S-1985 Contrary to ADM 14-200, Improper chronolog entries were made regarding test discrepancies.
(QPD 7/84-17) 08/07/84 S-1102 Contrary to ADM 02-020, Operations did not properly maintain operating logs.
(QPD 8/84-11) 08/07/84 S-1102 Contrary to ADM 02-020 and Standing Order #26, clear and concise entries with regard to equipment opera-
^
tions are not being made in C/R logs.
(QPD 9/84-12) 09/10/84 S-ll45 Contrary to ADM 14-200, preop test SU3 BG06 was started w/o authorization.
(QPV 9/84-15) 09/10/84 S-ll45 Contrary to ADM 14-200, second party verification of valve line-up was not performed.
(QPV 9/84-16) 09/24/84 S-ll62 Contrary to ADM 14-200, systen walkdown to verify readiness was not performed adequately.
(QPV 9/84-68) 10/09/84 S-ll81 Contrary to ADM 14-200, proper chronolog entries were not made pertaining to test discrepancies and test validity.
(QPD 10/84-13) 02/23/84 57953-K031 Contrary to SOCI-09, S/U failed to respond to Deficiency Reports 103 and 111.
(QPV 2/84-08) 02/23/84 57953-K031 Contrary to SOCI-09, S/U QC failed to issue Delin-quecy Notices to S/U for not responding to Deficiency Notices.
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(QPV 2/84-09) s 03/07/84 57953-K032 Contrary to ADM 14-200, S.U.E. used a superseded drawing for the conduct of SU3 NG02 preop.
4 (QPD 2/84-48) t 03/08/84 57953-K034 Contrary to SOCI-08, S/U QC failed to adequately
.3 monitor and ensure compliance to Startup Information d
Bulletins (SIB's).
(QPD 2/84-51)
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d 03/08/84 57953-K034 Contrary to SOCI-08, failure to adequately complete N4 S/U QC Monitoring Reports.
NTI (QPD 2/84-52) a($s38 uh
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r is KG&E QA CAR 920 ATTA09ENF A Page 3 of 8 Date Event Coments 03/23/84 57953-K035 Contrary to ADM 14-401, a superseded form was utilized for the completion of " Design Comnent Peport S/U-1" (QPD 3/84-10) 03/23/84 57953-K035 Contrary to ADM 14-003, ACN's were processed, accepted and placed in the vault w/o the proper attachments.
(QPD 3/84-09).
04/18/84 57953-K037 Contrary to ADM 14-411, S.U.E. failed to ensure
~
vendor work was not started prior to approval.
(QPV 4/84-02) 04/18/84 57953-K037 Contrary to ADM 14-411, Vendor Work Plans failed to contain applicable Receiving Inspection Report Numbers.
(QPV 4/84-03) 04/18/84 57953-K037 Contrary to ADM 14-411, S/U processed and placed into the vault incomplete Vendor Work Plans.
(QPV 4/84-04) 03/26/84 S-955 Contrary to ADM 14-201, insufficient instructions were provided to perform activities contained on App. "D" of SUl JE100.
(QPV 3/84-56) 04/27/84 S-10ll Contrary to ADM 14-404, work on cent. charging pump "B" was performed that was not delineated in original CNP or subsequent instructions.
(QPV 4/84-43) 04/27/84 S-10ll Contrary to ADM 14-411, Work Plan Change Notice was processed and implemented w/o CC or STS approval.
(QPV 4/84-42) 04/27/84 S-10ll Contrary to SOCI-ll, S/U QC failed to properly complete the S/U QC Insp./ Verification Plan.
j (QPV 4/84-44)
I 05/09/84 S-1029 Contrary to ADM 14-404, S/U failed to verify by d
initial and date all of the mini-test procedure steps.
a (QPV 5/84-14) l i
4 05/09/84 S-1029 Contrary to ADM 14-106, testing was started prior to
- 1. - J completion of test prerequisites.
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(CPV 5/84-15) gg
" fDm; 05/09/84 S-1029 Contrary to SUl-EP100, seven (7) unacceptable flush a;QM samples were obtained w/o notification and evaluation M
z by the Flush & Hydro Engineer.
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,s ATTAClfENT A Page 4 of 8 Date Event Coninents 05/09/84, S-1929 Centrary to ADM 14-196, three (3) personnel verified steps within SUl-EP100 w/o signing App. "A" of the
/
test procedure.
(QPD 5/84-17) 06/28/84 S-1976 Contrary to ADM's14-200 & 14-404, S.U.E. performed test steps out of sequence.
(QPV 6/84-71) 06/28/84-S-1076 Contrary to App.
"B", Crit. V, flow path 2.8 was established and used contrary to Subsection 7.8 of the procedure.
(QPV 6/84-72) 06/28/84 S-1076 Contrary to ANSI N45.2.1, four (4) flow paths were flushed at less than normal design velocity.
(QPD 6/84-73) 09/11/84 S-ll40 Contrary to ADM 07-100, ninety-seven (97) tenporary procedure changes were not reviewed or approved by PSRC or Plant Manager.
(QPD 9/84-01) 09/11/84 S-ll49 Contrary to ADM 07-100, Tanp. Procedure Change "HFT-122" is missing.
(QPD 9/84-27) 09/17/84 S-ll57 Contrary to ADM 14-200, test discrepancy noted w/o explanation.
(QPV 9/84-56) 02/17/84 S-889 Contrary to ADM 14-404, S/U issued CXP to KG&E Maintenance w/o Appendix "B" attached.
(QPD 2/34-37) 02/17/84 S-889 Contrary to ADM 14-200, SU3 8811 test steps were l
performed out of sequence.
(QPV 2/84-38) 06/12/84 57953-K048 Contrary to ADM 14-106, code stamp holder failed to review Major TCN's.
3 (QPV 6/84-17A)
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06/12/84 57953-K048 Contrary to ADM 14-105, code stamp holder failed to
'I sign off equipment removal and installation appendix.
j (QPV 6/84-18)
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stamp holder on signatures list.
;dj (OPV 6/84-19)
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KG&E 'OA CAR 626 ATTAOttENT A Page 5 of 8 Date Event Coments 06/19/84 S-1065 Contrary to ADM 01-002, " Walk-through" JM ACN approval forms are not being retained as lifetime QA records.
(QPV 6/84-51) 06/19/84 S-1065 Contrary to ADM 01-002, JM procedure review coments not consistently " attached to" or " referenced in" meeting minut,es'.
(QPV 6/84-53) 07/06/84 57953-K050 Contrary to ADM 01-033, Wolf Creek Event Reports were initiated contrary to procedural requirenents.
(QPV 7/84-03) 10/18/84 50140-K003 ContrarytoADM14-402,S/UfailedtoidentifyShR's as tCR's when required.
(CAR-18; Work Hold #22)
ContrarytoADM14-402,S/Ufailedtoidentifyth[
10/18/84 50140-K003 method of SFR implementation.
(CAR-18; Work Hold #22) 08/30/84 50140-K005 Contrary tio NDPM-III-ll, Operations failed to retain signature registration forms as permanent plant records.
(QPV 8/84-40)
+
10/19/84 S-1191 Contrary to ADM 03-101, an individual was observed in a radiation controlled area and was not conforming to the requirements of EWP 6840012T.
(QPD 10/84-34) 10/19/84 S-1191 Contrary to ADM 03-300, the H.P. failed to provide for adequate logging of serial numbers of self-reading dosimeters.
(QPD 10/84-36)
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10/19/84 S-1191 Contrary to ADM 03-300, the H.P. failed to log 3
" time out" and " dosimeter' reading".
5 (QPV 10/84-37) t 09/28/84 S-ll73 Contrary to MGE-E00P-07, six (6) units of electrical Pj equipment on tte "NG" systen had moderate to heavy dea accumulationw of dirt.
I (QPD9/84-34[
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. :. :M 09/11/84 S-ll53 "SAFiGUARDS"
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(QPC 9/G4-28)
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08/08/84 S-1105 Contrary to ADM 05-600, Fuel Transfer Record 6A fj ;
contained incorrect dates for the transfer of fuel
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(QPD 8/84-15)
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10/25/84 50140-K004 Contrary to ANSI N18.7, S/U failed to provide ade-quate control for items labelled as " reject" on RIRs.
(QPV 10/84-05) 10/25/84 50140-K004 Contrary to ADM 07-408, failed to classify an SFR containing safeguards information as such.
(QPD 10/84-08) 10/25/84-50140-K304 Contrary to ADM 14-407 & ADM 01-033, S/U failed to generate a Defect / Deficiency Report for RIR's that i
had the "Reportability" block checked (yes).
(QPV 10/84-09) 07/17/84 S-1088 Contrary to ANSI N45.2.9, ops. allowed the test approval signature on a Comoonent Test Record to be obliterated (i.e., invalidated).
(QPD 7/84-20) 07/17/84 S-1088 Contrary to SU6 ell 7-03, S/U failed to provide "significant digits" on the test record that is required to validate the acceptance criteria.
(QPD 7/84-21)
Contrary to A'M 14-413, S/U failed to initiate a CWP 02/23/84 S-892 D
to document and authorize work an instr. sensing lines and supoorts.
(QPV 2/84-40) 02/23/84 S-892 Contrary to 10 CFR 50, App. B, Crit. V, S/U verbally directed DIC to perform work on safety related equip-ment w/o approved procedures.
(QPV 2/84-40) 02/23/84 S-892 Contrary to ADM 14-404, S/U directed DIC to dis-asserl ole an ASME III/3 pressure boundary w/o notification of the code stamp holder.
(QPV 2/84-40) j 4
02/22/84 S-866 Contrary to ADM 14-200, S/U conducted SU4-EC01 preop I,
w/o impleenting the latest design changes.
(Unknown j
to System Engr.).
/I (QPV 2/84-23)
Jj 05/08/84 57953-K040 Contrary to ADM 02-101, Ops. failed to provide required information on eleven (11) " wire and jumper" i
reports that were vaulted.
(QPD 4/84-17)
.}j af 05/08/84 57953-K040 Contrary to ADM 02-101, Ops, failed to " provide for",, Mh and " maintain objective evidence of" a smi-annual
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review of lifted wires and jumpers.
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KG&E QA CAR #20 A?fAOPENT A Page 7 of 8 J
Date Event Comnents 1-04/10/84 S-971 Contrary to 10 GR 50, App. B, Crit. XV, S/U failed to document a nonconforming condition identified during hydro of the CVCS system.
l (QPV 4/84-09) 06/14/84 S-1061 Contrary to ADM 14-106, S/U failed to write a TCN that would allow a step sequence change during a
" mini-test".
(OPV 6/84-43) 06/14/84 - S-1061 Contrary to ADM 14-405, S/U failed to control
" temporary nudifications" in accordance with procedure.
(QPV 6/84-46) 06/14/84 S-1061 Contrary to ADM 14-406, S/U failed to properly utilize Equipment Renoval Tags and the Equipment Renoval Log.
(QPV 6/84-47) 05/23/84 S-1041 Contrary to ADM 14-200, S/U failed to conduct an adequate test briefing resulting in an uncoordinated test with several unnecessary delays.
(QPD 5/84-37) 05/23/84 S-1041 Contrary to 10 GR 50, Aap.
"B", Crit. XIV, S/U failed to provide adequate measures to prevent inadvertant/ unauthorized manipulation of valves.
(QPD 5/84-38) 08/06/84 57953-K055 Contrary to.,HPH 02-005, the H.P. failed to conduct required sealed source leak checks.
(QPD 8/84-04) 08/06/84 57953-K055 Contrary to ADM 03-500, H.P. conducted calibrations with personnel who are tot qualified.
j' (QPD 8/84-05) t 08/22/84 S-ll25 Contrary to Abd
[ G+, Chemistry issued a revision 18 to the Chen. Sp.sc. Is.All w/o PSRC and Plant Manager y
approval.
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q 08/22/84 S-ll25 Contrary to ADM 04-011, KG&E Chemistry inadequately b
comploted daily logs, such that results appeared
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(QPD 8/84-39)
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09/14/84 S-ll54 Contrary to ADM 04-020, KG&E Chenistry failed to
,x perform required chenistry analysis.
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KG&E QA CAR 629 ATTA09ENF A Page 8 of 8 Date-Event Coninents 09/14/84 S-ll54 Contrary to 10 CFR 50, App.
"B", Crit. V, KG&E Chenistry conducted sulfate analysis on the S/G's w/o an approved procedure.
(QPD 9/84-52) 08/29/84 S-ll19 Contrary to ADM 14-408, S/U failed to receive adequate information relative to instrumentation used during testing and subsequently found out of calibration.
(QPD 8/84-26) 08/29/84 S-1119 Contrary to ADM 08-801, the I&C calibration Labora-tory Tech, was not reviewing the " History of Use Log's" when an instrument was found to be out.of calibration.
(QPD 8/84-41) 09/18/84 S-1159 Contrary to ADM 14-408, S/U failed to consistently send "M&TE Use Information" to I&C for evaluation as to use of out of cal. instruments.
(QPV 9/84-58) 09/21/84 S-1164 Contrary to ADM 08-210, NCGS Maintenance failed to perform / document evaluations on equipment where instrunentation found to be out of cal was used.
(QPV 9/84-72) 10/11/84 S-1183 Contrary to ADM 13-102 & ADM 01-034, Operations allowed storage of uncontrolled combustable materials f
in safety-related areas of the power block.
(QPV 10/84-18) 10/11/84 S-ll83 Contrary to ADM 01-034, Operations failed to perform and docu:mnt the required housekeeping / cleanliness inspections.
(QPD 10/84-19)
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't 10/11/84 S-ll83 Contrary to ADM 01-034, ADM 01-008, ADM 01-001 and 10 CFR 50, App.
"B", Crit. II, V, and VI, KG&E Plant
~f Support failed to utili::e proper procedures for
]
access control and failed to conduct training to these procedures.
i.5 (CPV 10/84-21) 08/30/84 S-ll29 Contrary to ADM 14-402, S/U failed to issue an SFR f
for installation of a Non-Q (Non-Conforming) spring
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can at Hanger BG22-H007.
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KG&E QA CAR 920 ATTACINENT B Page 1 of 3
,e.
.irr eiv i..r INTEROFFICE CORRESPONDENCE
'IO:
'IT: 50140-lG07 IO UCW 84-346 PfDf W.J. Rudolpt II DME:
Septerter 12, 1984 SUELTELT Minutes and Action Iterns: 9/7/84 Management Meeting i
en Procedure Ccnpliance A Managernent Meeting was held on 9/7/84 by the KG&E Project Director to discuss concerns raised by the Manager Cuality Assurance (WCGS) at the 9/6/84 Project Quality Review Meeting.
The concerns specifically addressed an increasing negative trend associated with ccr::pliance to Startup test procedures. KG&E Quality Assurance asserts that these procedural violations have been a contributing factor in the cm:plexity and difficulty associated with pre-operational test package content and review, respectively. The overall effect resulting in a risk of reduction in quality.
This document is being attached to Audit Report TE: 50140-lG07 as a means of documenting the above noted Quality concerns and, obtaining senior project r,anagement attentien and ecmnitment to take initial swift, w%siate corrective action.
thorough and a Meeting Sm mry The Manager Quality Assurance (NCGS) opened the meeting by outlining his relative to the identification of an adverse trend obcerved during concerns a review of preoperaticnal test results.
" Administrative Procedure Non-Ccrnpliance" has been a topic of concern for some time and several acticna have been taken in the past to co'rrect the problem, including retraining of.
Startup personnel.
- However, as a result of reviewing (5) Test Results
- packages, the problern appears to be continuing.
(See Attachment i for sunmary of package review.).
After identification of the problem, tra meeting was opened up to discussica cn how to correct the problem and
(
prevent reoccurence.
The Project Director expressed serious concerns with several aspects of this j
- problen, including plant licensing, Startup Engineer responsibilities and j
startup managenent/supervisicn obligations. 'Ihe Project Director then asked ij the Startup Manager to explain past and present actions taken to resolve j
this issue.
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ATTACHMENT B R3dGCW 84-346 f
Page 2 of 3 The Startun Manager and his representatives described actions that have been
- taken, and in-process changes that will relieve the Startup Egineers of sone of this adninistrative burden inherent with pre-cperaticral testing.
We follow 2ng items were presented:
Pre-Oo Implementation Training Conducted (9/83, 1/84, 3/84, 4/84, 7/84 e
l and 8/04)
Direction to Startup Engineers to:
e
- St@
a Evaluate a Correct problems
~
asil shift coverage of testing activities by the Tech. Support Group e
MI's routed through Tech. Support e
Increased surveillances by Supervisors e
Modification of the Administrative Procedures e
The Manager Quality Assurance (WCGS) reiterated, that the problera was one of inadequate attention to adninistrative detail that c:uld result in a risk to data validity.
We Startup Manager resp:rded by citing the added burden placed en startup engineers by the magnitude of the adninistrative 'etail in the Weiures.
We Project Director again stated his position that a timely schedule can be achieved: hcwever, it will be met with Quality as first priority.
He added that it was the respcesibility of startup managenent and supervisicn to identify the causes of this procMural violaticn trend and inplement w+iate acticns imnediately to correct this trend.
a
- 9 As a result of the wi=, the fh11n ring m=ih-r*m were made
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Mi's will be routal through Technical Support for review.
I 4
2.
Adninistrative Procalures will be revised to relieve the adninistrative turden cn the S/U Engineers.
d"s 3.
Disciplinary acticn will be take, when appropriate.
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3 4.
S/U will conduct a meeting with first line supervisors to ~ discuss the
~j 4
problem and QA will attend the meeting.
4 5.
QA will provide the Plant Manger with a list of all unresolved otmnents j;jj relative to the five (5) prmticral tests reviewed by QA.
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r KG&E QA CAR 920 ATTACHMENT B KQhTKCM 84-346 Page 3 of 3 Also, the issue of retention of package review "Comnent ~ Sheets" Records was addressed, and it was decided that a ceparate meeting to resolve as QA
' ' '1' the question would be held at a later date.
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9-#t-4 t KG&E Project Dirqt: tor W.J. R6dofen II Manager Quality Assurance (WCCS)
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WJR/dkb Attachments The following personnel attended the subject eneeting:
R.M. Grant Director - Quality F.J. Duddy SCCS Project Director W.J. Rudolph II Manager Quality Assurance (WCGS)
F.T. Rhodes WCGS Plant Manager R.J. Glover Startup Manager C.G. Patrick Superintendent Quality Evaluations T.G. Dempster Superintendent Startup QC J.A. Zell Superintendent of Operations T. Gardner Lead Systen Test Supervisor (S/U)
K. Ellison Technical Suppoort Supervisor R.M. Stambaugh Supervisor Audits C.A. Daley Caad Auditor T.E. Hough Auditor F.G. Gunnon Quality Engineer C.J. Hoch Quality Technologis,t i
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- 5. I ' to Encicsure to'KMLNRC 84-227 WCGS INTERNAL OPERATIONS PROGRAM DEFICLENCY I.
NUMBER 84 OS '
DATE 11-09-84
~
PAGE 1 OF 1 11.
CONTROLLING DOCUMENT / REQUIREMENT:
See attached Condition / Description III. ~ RESPOESIBLE SECTION/ GROUP:
All Operations Groups plus Startup
~
IV.
REQUIREMENT:
See attached V.
FINDING:
See attached VI.
RECOMMENDATION:
See attached VII.
REbPONSE DUE DATE V
PLANT &TNI 'dR EVIEW:
~
See attached h
DATE M M IX.
COPPECTIVE ACTION DOCUMENTATION RECEIVED:
DATE COMMENTS:
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IX.
ITEM CLOSED:
PLANT MANAGER OR DESIGNEE DATE
.s 44 g 4C 25-2 Page 1 of 1 ADM 01-025'y"f;sv4;?
Rev. 3;Af;fis Page'. 9]cff 291L
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Condition / Description The progra:tmic controls of the Startup and Operations Quality-Program _....
are not being implemented in a manner consistent with good operation of a nuclear plant.
II.
Background Information/ Findings A number of NRC concerns and Quality concerns have been addressed to the Startup and Operations area.
These concerns have been individually addressed, however, it is not obvious that the needed corrective action has taken place.
1.
CAR 17 - The mistakes made in the conduct of the Work Request Program.
Findings - The Work Request Program has been corrected to solve the identified concern of CAR 17.
The additional concerns in WRs are mentioned below.
2.
QA violations pertaining to mistakes in conduct of testing activities. Some, but not necessarily all, are listed below.
Number DeviationNiolt tion QPV 8/84-08 SU6MEll, Rev. 2, requires the code stamp holder be notified to participate 'in the disassembly of ASME itens.
The Equipment Removal and Installation Appendix for SU6MEll, Rev.2, BG02FP2 indicates the initials of a KG&E QC Inspector as the code stamp holder.
OPV 8/84-44 ADM 14-402:
Failure to issue SFR for installation of a non-Q (nonconforming) spring can at hanger BG22-H037.
QPV 9/84-15 ADM 14-200 - Section 6.0 of SU3BG06 was signed off prior to test start authorization contrary to ADM 14-200.
.i QPV 9/84-16 Contrary to ADM 14-200 CKL were completed by
+I Operations withNt second party verification by the
- q '
System Startup Engineer.
5
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QPD 9/84-57 Contrary to ADM 14-414, tracking and completion forms have not been processed for seven RWPs.
/
QPD 10/84-13 Contrary to ADM 14-200 Test Discrepancy to SU3NE01 was not explained in either the TD
[cq or W'
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Chronological Log.
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'QPV 10/84-05 Contrary to ADM 14-407, control of items removed or rejected has not been adequately controlled.
QPD 10/84-07 Contrary to ADM
'14-416, the resiEnsible
~
reevaluation engineer did not enter the ICR number on the closed NDC.
QPD 10/84-08 Contrary to ADM 07-408, an SFR containing i
safeguards information was not classified as a safeguards -document and was transmitted to the-QARR.
Findings - Although specific action was taken in each case, this concern is valid - see corrective action.
3.
Identified NRC Concerns A.
Failure to take appropriate action covering Daniel QC Hold Tags in field on Startup or Operations controlled systems.
Findings - This concern is valid. See corrective action.
B.
Inadequate control ofl records going to Training, such that unsigned records were entered into the system as complete.
Findings - This concern is valid. See corrective action.
C.
Inadequate knowledge of procedures by Startup and Operations during testing.
Findings -
Th'is concern is not substantiated although it is recognized that depth of knowledge is a subjective matter..
See-corrective action.
9 D.
Improper use of Work Request Program on Q/Non-Q identification and priority assignments.
3 1
Findings - This concern is partially substantiated.
The-e >i Q/Non-Q concern is not valid.
The referenced work was
. I classified correctly as Non-Q.
The concern on improper use of Priority 1 is valid. See corrective action.
I, z
E.
Excessive delay in Document Control function in Control Room T 3 J procedures between issuance and entry into Control Room 9"h procedure manuals.
- 1[,9 Findings - This concern is valid.
See corrective action.
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Failure to follow requirements for Control Room required reading.
q ~ ' s,s Findings This concern is not valid.
The required"teading program is being conducted correctly.
The inadequacy noted appears -to have been-caused by a misunderstanding of the procedural requirements.
G. - A' perception-that excessive schedule demands were causing errors.
Findings - This concern is valid. See corrective action.
H.
A perception that Operations and Startup perceived the QA Department as a ' necessary evil" or " paper tiger".
Findings - This perception is subjective in nature.
Although it cannot be directly verified, see corrective action.
4.
An overall concern with the adequacy of ~the management of the Startup Program in the prevention of these kinds of problems.
Findings '
This perception is subjective and by default correct, i.e.,
if management had performed correctly one can assume these problems would not have occurred - see corrective action.
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.c III. Corrective' Action In order to address corrective actions in both the narrow specific 7..
cases and the generic cases, the following corrective actions _uill,be
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taken.
'A.
Specific Corrective Action for. individual items.
~~1.L Inadequate control of training records.
A complete review of the licensed operator training records has been made.
This task involved 2,600 Qual cards and about 25 cards with missing dates or signatures. were found and corrected.
In order to insure all necessary training records are checked a program has been initiated to completely check the records base and verify the adequacy of the computer data base.
The schedule for this activity will proceed into 1985,
- however, all hard copy records necessary for plant licensing will be checked by December 20, 1984.
This review will be
~
based on training comnitments in the FSAR.
2.
Failure to properly observe and take appropriate action on non-KG&E tags such as Daniel QC liold Tags.
The corrective action is in several parts.
A memo will be distributed to all KG&E Operations, Startup and QC personnel reminding them that any tag, regardless of its source, must be followed until such time as it is properly removed.
In
- addition, these specific instructions will be added to the Operators required reading, instructing them to be extranely observant during operations, including normal rounds, valvo lineups, etc., Specific attention to this area will also be addressed during the transfer fu*1ction from Startup to Operations of system jurisdictional responsibility.
3.
Improper use of Priority 1 on Work Requests.
The responsibility of proper priority classification is y
designated to the Shift Supervisor.
In order to insure that
_1 this is enforced, the Superintendent of Operations has instructed his personnel to insure these rules are correctly
' 'd followed.
In addition, the Plant Manager is meeting with each as shift Supervisor and Supervising Operator and re-emphasizing the requirement of the Adninistrative System.
This action to j
be complete by November 9,1984.
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Excessive de' lay in Procedural Document Control distribution.
This problem occurred due to the failure of managenent to Properly prioritize the Document period of very heavy procedure distribution. Control function during a
~
(21,585-~ copies of procedures were distributed in the affected 31-day period.)
This prioritization has been done effective Novettber
~
2,
- 1984, by the Superintendent of Regulatory, Quality and Administrative Services per letter hWOLKNO 84-687.
Effective irrmediately all Administrative procedures will receive a priority such that a maximum of two days will be allowed in word processing and Manager approval for properno longer than two days following Plant distribution.
This action is complete.
D.
The generic areas of concern will be handled as follows.
1.
In order to insure an achievable objective of 0 errors in the administrative control of the Startup Program the following actions will be taken.
1.1 Individuals key to the direction and control of the Preoperational Test Program will be examined and retrained as necessary to assure a high conridence in their knowledge of program administrative requirements.
- System Test Supervisors
- System Lead Engineers
- Test Directors (Control Room)
- Shift Test Supervisors 1.2 System Engineers, Technical Support Engineers and others directly participating in the conduct of preoperational
?
tests will be examined and retrained as necessary.
NOTF. The testing will be scheduled as soon as practical.
If a person requiring the test fails to get 800 they will be relieved of their plant testing responsibilities until
,j such time as they are retrained as necessary and they have passed a similar t'est.
The testing results will ba j4 sutmitted to the Nuclear Training Manager for pennanent retention.
The conduct of the tests will be under the Dj Startup Training Supervisor to insure test security is
'I maintained.
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1.3 Prior to the start of any test, the Lead Startup Engineer -
(or designee) signature on the test cover sheet.is required to authorize the The information he requires to grant test start enhanced to assure that:
authorization Gill 'be The procedure is current and correct.
The system (s) or area (s) to be tested are ready to be tested in accordance with the approved procedure.
The Test Engineer is thoroughly familiar with and knowledgeable of the system status, the details of the test procedure, and administrative requirements.
Preparations and planning for the conduct of the test
- personnel, test equipment, operations interfaces, etc., have been appropriately addressed.
The engineer understands what other plant activities are on-going or planned that could impact his test and
~
the relationship of his test to these other activities.
'Ibe engineer understands the absolute requirements to corduct his test without administrative and procedural errors (verbatum compliance) - even at the expanse the project schedule of 1.4 The requirement for direct involvement of supervision in the cerduct of testing will be enforced to assure daily coaching, direction and monitoring of test engineers.
1.5 Supplemental training / briefings will be conducted as Indicated by trends or specific situatior.s.
This may be directed to individuals,
- groups, or all personnel involved in preoperational testing.
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1.6 Daily independent reviews of all active test procedures will be conducted by Startup Technical Support.
.q Review results will be reviewed with the test engineer and a di copy of the review comments will be delivered to the test supervisor for follow-up during his daily coaching, 1.1 s
l direction and monitoring of the test engineers.
These reviews will be done and documented using checkoff lists to insure all important points are covered.
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1.7 All personnel will again be advised that verbatum compliance to the test procedures and administrative requirements is an absolute requirement and takes precedence over schedule considerations.
Failure to" ' '
follow procedures constitutes a real jeopardy-lo the entire Wolf Creek Generating Station Project and consequently, individuals failing to comply with these requirements will be subject to which could include dismissal.
disciplinary action, 2.
One source of. errors is the misuse.of minor TCNs when major should have been used.
Effective November 9,
- 1984, the use of minor TCNs in the Preop Startup Test Program will be Z
discontinued.
All procedural changes will be made by Major TCN.
In addition the following guidelines will be used by the -
Joint Test Group in evaluating the approval of TNs vice a procedural revision.
a.
The issuance of 5 or more 'ICNs will be considered as a
" normal" level to cause a revision to the procedure.
This is not a firm requirement and can be modified if the specific TCNs are of a minor nature.
b.
In no case shall the number of test steps changed by K Ns exceed 25's of total steps.
c.
If mare than 5 test discrepancies are identified due to procedural non-compliance on tests cemenced after November 7,
- 1984, the entire test snail be repeated.
Exceptions to this may only be granted by the Plant Manager.
3.
In order to achieve the 0 error objective in Operations the following specific actions are being taken.
f In the Operations Section, the "Shif t Advisors" have taken on a new roll.
They are now performing a regular observation program of Control Room activities with and including written 3
observations of the activities taking place.
These observations.are using specific checklists to insure all necessary areas are observed.
Observed problems will be repc:ted to the Superintendent of Operations immediately and 1
necessary corrective action taken.
This action is complete i
and ongoing.
It will continue until its function is no longer "f
needed.
The decision to stop will to made by the l
l Superintendent of Operations af ter consultation with the Plant Manager.
The Plant Manager has met with all affected Superintendents, the Training Manager, and the Startup Manager
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unphasizing the concept of 0 errors.
In addition, the v
Director of Nuclear Operations and the Plant l'anager will meet -
NW with all anployes on t
specific concerns and to insure the necessary understanding dg all personnel of what it takes to achieve this level of q ff accomplishment.
'this activity wilI be scheduled during to be W" #
the.
weeks of November 5 and Nnvember 12 with action
- I complated by November 16, 1984
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In these meetings the specific subject of schedule impact will' be addressed to insure that no individual involved believes now or in the future that schedule adherence is as important
.- r- -
as O errors and or safe operation.
In addition, ths:Bubject
~'
of the level of understanding as to the importance of QA will.
be addressed.
In order to insure a consistent policy is taken regarding disciplinary action for procedure adherence, and to insure all Nuclear Department personnel fully understand the significance of, or proper adherence to procedures, a Nuclear Department policy will be proposed to management.
In addition to the above corrective action, effective November 12, 1984, daily meetings will be held by the Plant Manager.
Attendees will be, at a minimum, the PSRC members or a
- representative.
Subject of the meetings will be such. areas
- 1) Quality prchlems/ outstanding QPVs, QPDs,. CARS, etc.,
as:
- 2) Work in progress, administrative 1y and in field, 3) Problem areas.
These meetings will. continue until such time as the need no longer exists.
Sumnary:
The programs outlined in this memo are considered appropriate to control and solve the noted concerns. A schedule of completion is attached.
Forrest T. Rhodes Plant Manager i
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m Completion Schedule of Remaining Corrective Action Training Records l- "
1.
Cold License training for operators
~
and staff personnel, including STA and mitigating core damage training.
December 3, 1984 2.
Health Physics / Chemistry Groups training
-; technician course
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.practica1 training
- PdR plant chemistry December 10, 1984 3.
I&C Training i
- technic'lan course
- vendor training
- GE
- radiation monitoring
- microcomputers
- ventilation December 20, 1984 4.
Reactor Engineers (Nuclear Engineer's Course)
November 23, 1984 i
5.
Computer Personnel S
- BOP computer (floneywell),,
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- NSSS Computer (Westinghouse)
December 20, 1984 i
6.
Non-licensed Operator Training (systems)
December 17, 1984 1
7.
General thployee and Radiation Training December 20, 1984 r
I D.
IMR and Professional 'Iraining December 3, 1984
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ttitigating Coro Damage
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- IIcalth Physics personnel
- Chemistry personnel
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- I&C personnel December 17, 1984
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- 10. Firo 13rigade Training December 20, 1984
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. 4 Completion Sched de of Itsnaining Corrective Action (cont 'd)
Daniel /or.Other Type Ifold Tags 1.
Memo -
November 9, 1984
'2.
Inserted into Required Reading Program November 9, 1984 Work Request Processing
,1.
Interview by Plant Manager with each Shift Supervisor and Supervising Operator November 9, 1984 Startup Corrective Action l.
Program examination November 19, 1984 2.
Test Authorization November 9, 1984 3.
Daily independent review November 6, 1984 4.
Program change to eliminate minor 'ICNs November 9, 1984 3
Operations Corrective Action
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Plant Manager and Director l'uclear operations Meetings November 16, 1984 j
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- 2. 'Draf t Nuclear Department Policy on l
Procedure Compliance
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IOP0 84-08
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Attachment A
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INTEROFFICE CORRESPONDENCE To:
Distribution
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From:
Torrest Rhodes Date:
' November 9, 1984
Subject:
Transfer of Systems from Startup to operations f
ittou M 84-596 Please alert your respective personnel who are involved in the system transfer evolution as to the importance of insuring all tags hanging on the
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components are appropriate.
- Although in most cases we are not conducting a formal walkdown, I do expect a " tag walkdown".
I feel the failure of our organization to catch old Daniel tags, for example, may be indicative of a general feeling of invisibility to non-KG&E tags. This, of course, be put under control.
. is inappropriate and must l
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Forrest T. Rhodes Plant
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s IOPD 84-08 Posa inn eiv..n Attachment B
' INTEROFFICE CORRESPONDENCE To:
Distribution Frcm:
Forrest Rhodes Date:
November 9, 1984
Subject:
Hold Tags i
IC?OC !G1 84-594 On this job it is possible, and in many cases, probable that a number of
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different types of " Hold Tags" are encountered.
These range from Daniel QC
. Hold to KG&E "Do Not Operate" tags.
It is the policy of KG&E and this job that all installed tags are presumed correct and the requirements of the speciiTc' tag must be followed.
If a tag is found that prevents you from performing your assigned function, the appropriate action to remove / modify the tag must in followed. The requirements of the tag will not be violated.
Anyone who knowingly violates a tag requirement will be subject to disciplinary action.
Y' Forrest 7. !1bdies Plant A m + c FTR/jld Distribution:
1.
All KG&E Operations and QC employes 2.
All Startup mployes 3.
Required reading. list - Operations 4.
Gary Fouts 5.
Bill Rudolph (CAR #20 File) e' e
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IOPD 84-08
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Attachment C.
0, INTEROFFICE CORRESPONDENCE To:
Distribution
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From:
'Forrest Rhodes Date:
November 9, 1984
Subject:
Daily Meetings K!0LD1 84-595
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Effective November 12, 1984, a daily meeting will take place at 0800 in the Operations' Conference Room. The attendees will be:
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1) the PSRC members or a representative of the member, 2) the Startup Manager or representative,
- 3) additional personnel as designated separately.
Note:
These are not PSRC meetings per se and the PSRC Clerk is not required to attend.
The agenda of each meeting will include a five minute, or less, presentation by each member on the following areas:
1.
Outstanding Quality concerns, OPys, etc.
2.
Work in progress in field.
3.
Administrative work in progress.
4.
Problem areas.
The meetings will be expected to' last no longer than thirty minutes normally.
TM present Operations Staff Meeting on Mondays is cancelled.
Yd'Y i
Forrest T. Rhodes 1
Plant ibnager I
FTR/jld If
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Cary Pouts Chuck Mason p
. ;t Dob Glover RW Dill Rudolph (CAR #20 File)
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IOPD 84-08 Attachment D POent l117 9tv.t.47 INTEROFFICE CO R R ES PO N D E NC E
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To:
Bill Rudolph Frm:
Forrest Rhodes Date:
November 20, 1984
Subject:
Corrective Action Schedule CAR 20 L'OLKQW 84-227 Finding 41 Reconnended Corrective Action la., If. See attached Corrective Action Documentation lb.
This will be completed by a complete review per the first recomendation with the following change.
In addition to the vaulted records, all preop test packages now in the field will also be given an additional review in accordance with the response guidelines of OPV 9/84-59A.
This additional activity will be emplete by Deceber 15, 1984.
Ic., le. 'Ihe testing to insure the confidence necessary is being conducted at this time and will be emplete in accordance with IOPD 84-08.
Ic.
Exception is taken to the specific subject matter under bullet #1 of CAR 20 lc.
None of the observed problems appear to be caused by a lack of FSAR or Nuclear Department Policy Manual knowledge.
The inclusion of these areas into the exam would dilute the effectiveness of an exam which needs to carefully examine the ability of the Startup personnel to follow the lower tier procedures which carry out the directives and policy of the higher tier procedures and documents.
Id.
The development of a draft policy will be done per IOPD 84-08.
j This action is emplete, the proposed draft policy was subnitted to management November 16, 1984.
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Exception is taken to bullet #3 of Recomended Corrective Action le.
The decision to take disciplinary action will be done on a
- s case-by-case basis in accordance with KG&B policy.
Decisions in 77 this area are management decisions and are not considered a part " g$ @
of the formal CAR response.
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IMOLKQW 84-227 November 20, 1984 Page 2 Ig.
See IOPD 84-08.
We elimination of minor 'ICNs is complete as of Novmber 9, 1984.
The action is being -done under management directive.
We necessary corrections to the ADM 14-200 will be done by Wednesday, Novmber 21, 1984.
In addition to the corrective actions taken, or to be taken, a
number of additional steps are being taken.
An active program is underway to eliminate the procedures which are cumbersome by shifting the programs frcm the ADM 14 series to the regular Operations permanent ADM procedures.
This activity will be cmplete by December 20, 1984, for those procedures judged to require the action.
This effort will be a joint Quality, Operations and Construction effort and will concentrate initially on the CNP procedures.
Finding 42 Recomended Corrective Action 2a.
No additional " root" causes have been identified at this time.
2b.
The result of the actions taken by Startup and Operations management at the September 7, 1984, Management Meeting were in fact valid and considered appropriate at the time.
The number of administrative errors were decreased by the actions taken just before and after the meeting.
The actions taken, however, were not sufficient to completely resolve the problems identified since see of these same probles have continued to occur, specifically the administrative errors in the conduct of the Preop Test t
Program.
A re-evaluation of the identified course of action on d
September 7 has revealed one area where the action was not sufficient. The training given per the September 7 letter was not verified by examination.
This is now being done per the requirments of IOP0 84-08.
In addition to this particular requirement, the remaining portions of IOPD 84-08, Section B1, 4
directly affect this area and are part of the required corrective R-action.
2c.
The corrective action being performed in accordance with IOP0 84- * "M 08 does address the causes identified in CAR 20 and will enhance O
the effectiveness cf the Corrective Action Program.
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iMOLKQW 84-227 Novernber 20, 1984 Page 3
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2d., (3d. ), 2e., (3e.), 2f., (3f.)
The failure of Operations /Startup nonagement to identify the adverse trend is, of itself, not a cmplete statement of the condition.
Operations and Startup management have, during this period, used all available information to identify problens and take the appropriate corrective action.
The Joint Test Group, in carrying out its responsibilities over the past year, has required such actions as the reconduct of several preop tests due to excessive adninistrative errors. For a number of approved tests, the approval was rescinded due to excessive number of KNs.
Specific training, for example, was mandated by the JE in July due to the noted administrative errors on SU4EC01.
A number of changes in the adninistrative program in Startup were required in an attempt at the time (July 1984) to insure the T Ns were technically accurate, and to improve the Startup drawing control in the fiold.
In April 1984 SU3AB05 was halted by the JM due to excessive KNs and a possible loss of test control.
All AB05 personnel were required to be retrained.
The primary aim and direction has been to insure a quality product in the field in every case, and to require retest if the completed Preop Test Package left any significant doubt to that conclusion.
1 The result of these efforts has been the correction of many problems to insure the conduct of a proper program of high quality in the Startup area.
The concern over these potential concerns, usually technical in nature, has j
been at a high level during the emplete Startup Program.
The trend that has not, until now, been sufficiently addressed, primarily the mistake of an adninistrative nature, was basically that the operations / Start 9 management.
did not come to an awareness level wherein the necessary corrective action i
would have been taken.
That level of awareness has now occurred and will remain as an integral part of the managanent philosophy of Wolf Creek i
Generating Station Operations.
Forrest T. Rhodes Plant Manager
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CORRECTIVE ACTION DOC'UMENTATION Reference Document #:
IOPD 84-08 v : *s..
pate:
11-16-84 Deficiency:
The programatic controis of the startup and operations Quality Progra bsing implemented in a manner consistent with good operation of a Immediate Action (as applicable):
' Issuance of IOPD 84-08 and implementation of Corrective Actions
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Cause:
See iOPD 84-08 and CAR //20, finding la, if J
Action to Correct Observed
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Conoition:
See Attached Date Completed: 11-16-84 Remedial Actions (if required)
II/A Preventive Action Plan:
Management will continue to monitor closely 'for any Administrative erro immediately address and Investigate any such errors noted.
I Co.ntinued on Suppl. Sheets?_ Yes Preparer signature:
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Date:
_il-l'6-84 tk.
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Approval: M
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' Bection Superintendent Dat'e: _11-16-84 d'
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Approval:
N/A Date:
Plant Manager (For NRC Items) h 7.j
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COMPLCTION:
Date Completed li-16-84
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Reg, NQual, Admiri.fe' At tac'hment 0 25-1 k,pFNO;I?MdD#' ' #"
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IOPD 84-(18 Corrective Action Continued Action to Correct Observed Condition:
The Plant Manager has net with all Superintendents, the Training tbnager, and the Startup Manager to emphasize the concept of zero errors. The Director of Nuclear Operations and the Plant Manager met with all available employees on a group-by-group basis between November 9, 1984 and November 16, 1984. During these neetings it was emphasized to all employees that compliance to procedures and administrative controls is an absolute requirement and takes preceedence over any schedule considerations.
It was stressed to all individuals that schedule adherence is not as important as zero errors and/or safe operation. The inportance of OA was also addressed and emphasized.
The small number of employees who were unavailable, such as back shift workers, vacations, etc., are being rescheduled to attend the neetings prior to November 30, 1984.
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