ML20141F406
| ML20141F406 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/24/1997 |
| From: | Warren C WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WO-97-0002, WO-97-2, NUDOCS 9707020339 | |
| Download: ML20141F406 (11) | |
Text
o i
WfdLF CREEK NUCLEAR OPERATING CORPORATION Clay C. Warren Chief Operating Officer June 24, 1997 WO 97-0002 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: P1-137 Washington, D. C. 20555
Subject:
Docket No. 50-482: Operational Quality Assurance Program Changes Pursuant to 10 CFR 50.54 (a) (3)
Gentlemen:
In accordance with the requirements of 10 CFR 50. 54 (a) (3) , Wolf Creek Nuclear Operating Corporation (WCNOC) is submitting proposed changes to the Operational Quality Assurance Program for approval. The proposed changes j replace the Corrective Action Request with the Performance Improvement '
Request, and also updates the program to support improved proficiency and efficiency in the way nonconformances are processed by WCNOC personnel.
Pursuant to 10 CFR 50.54 (a) (3), these changes have been evaluated by WCNOC and determined to reduce commitments made in the approved Quality Assurance Program as originally approved by the NRC. However, the evaluation also determined that the changes do not constitute an unreviewed safety question, do not reduce the effectiveness of the Quality Assurance Program, and that the Quality Assurance Program continues to satisfy the criteria of Appendix B of 10 CFR Part 50.
Pursuant to 10 CFR 50. 54 (a) (3) , a discussion and evaluation of the proposed changes are provided in Attachment I, and mark-ups of the affected Updated Safety Analysis Report Chapter 17 pages are provided for your review in Attachment II. In accordance with 10 CFR 50. 54 (a) (3) (iv) , WCNOC plans to implement these changes following receipt of an NRC letter indicating acceptance, or 60 days after the date of this submittal, whichever occurs first. If you have any questions concerning this matter, please contact me at (316)364-8831, extension 4485, or Mr. R. D. Flannigan at extension 4500.
Very truly yours, Clay C. Warren CCW/jad
?
Attadunents I
cc: E. W. Merschoff(NRC), w/a W. D. Johnson (NRC), w/a p f l
J. F. Ringwald (NRC), w/a '/
J. C. Stone (NRC), w/a "
p .7 q (i n r) " ^ " ~ "
- Burhngt n. KS 66839 / Phone. (316) 364 8831 9107'020539 970624 PDR ADOCK 05000482 lual opportunity Emtbyet M F HCVET P PDR
Attachment I to WO 97-0002 Page 1 of 3
, JUSTIFICATION FOR PROPOSED CHANGE CORRECTIVE ACTION REQUEST DELETION Updated Safety Analysis Report (USAR) Section 17.2.16 " Corrective Action" currently states that Corrective Action Requests (CARS) may be used to identify and correct significant conditions adverse to quality. USAR Section 17.2.16.3 further states that the CAR is used to correct significant conditions that could not be corrected by any other means. However, the Performance Improvement Request (PIR) process, as described in USAR Section 17.2.16.2, provides an acceptable means to identify and correct significant conditions adverse to quality, and has been used for identification of significant conditions adverse to quality since the PIR process was initiated.
Thus, Wolf Creek Nuclear Operating Corporation (WCNOC) proposes to revise this section and Section 17.2.17 to delete reference to the CAR. Also, USAR Section 17.2.16.2, " Performance Improvement Request" description will be enhanced to further clarify that PIRs are used not only to document conditions adverse to quality, but also to correct significant conditions adverse to quality.
10 CFR 50 Appendix B, Criterion XVI, " Corrective Action," requires:
- 1. Measures shall be established to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
- 2. In the cases of significant conditions adverse to quality, the measures shall ensure that the cause of the condition is determined and corrective action taken to preclude repetition.
- 3. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.
1 The current CAR process identified in USAR 17.2.16 allows the Performance Improvement and Assessment (PIA) group to initiate a CAR when significant conditions adverse to quality cannot be effectively corrected by other corrective action systems. Once the CAR was initiated, the root cause and corrective action for the condition would then be documented in a PIR by the responsible work group. Prior to closure of a CAR, PIA personnel would verify the implementation and effectiveness of the corrective action. ,
l I
The current PIR process, as described in USAR Section 17.2.16.2, is used to document corrective action for non-significant problems and to document and I identify to appropriate management the root cause evaluation, corrective action plan, and completed corrective actions for significant problems, including significant conditions adverse to quality.
The PIR process used today provides the same level of detail and level of I notification that the CAR process requires, with the following exceptions. i l
- PIRs do not require PIA supervision or manager approval for initiation, as CARS do, but can be initiated by any WCNOC personnel. l
- The PIA group does not initiate all PIRs and does not verify implementation effectiveness of all PIR corrective actions. The PIA group does, however, audit the corrective action process described in 17.2.16 every six months.
The CAR process is no longer needed since the current PIR process, as described in Chapter 17.2 of the USAR and implemented in procedure AP 28A-001,
" Performance Improvement Request," has been implemented. The PIR process requires that those PIRs identified as significant have a root cause identified, corrective actions determined and implemented, and effectiveness
Attachment I to WO 97-0002 Page 2 of 3 J
I i
, follow-ups performed to verify that corrective actions were effective. In l addition, the PIA group still has Stop Work authority for those activities I that could have adverse impact to the plant or the health and safety of the I public.
There is no adverse impact of replacing the CAR with the PIR. A significant PIR will be initiated for conditions identified to be adverse to quality that have not been effectively corrected by any other means. In addition, the PIR can be initiated by any WCNOC personnel, not just the PIA group. The PIA j group will not verify the effectiveness of corrective actions for all I significant conditions adverse to quality. Rather, the verification of the effectiveness of corrective actions for all significant conditions adverse to quality will be performed by the assigned responsible organization. The PIA l group will continue to review identified significant conditions adverse to quality during their bi-annual audit of corrective actions, as required.
Therefore, the PIR program, as defined and controlled by procedure AP 28A-001, l
" Performance Improvement Request," envelops the aspects of the CAR process as l well as meeting the requirements of 10 CFR 50 Appendix B Section XVI. !
However, WCNOC has concluded that deletion of the CAR program represents a reduction of commitments in the QA program, as previously approved by the NRC.
This change requires NRC approval prior to implementation, per 10 CFR 50.54 (a) (3) .
NONCONFORMANCE REPORT PROCESS CHANGES Several revisions are proposed to Section 17.2.15 to eliminate redundant wording and enhance the description of how nonconformances are processed.
Most of the changes are minor, such as correcting typographical errors, eliminating redundant wording, and relocating some information to other locations in the USAR.
Specifically, the following changes are proposed:
- Section 17.2.15.2 was changed to eliminate redundant wording and add more descriptive wording.
- Section 17.2.15.3 (Reporting Methods) is being deleted. Nonconformance reporting methods are described in plant procedures and fully implement the program requirements described in Section 17.2.15.2. Section 17.2.15.3 is redundant.
- Section 17.2.15.4 will be renumbered as 17.2.15.3 and the requirement for independent review of nonconformance dispositions by Performance Improvement and Assessment will be deleted. The WCNOC design control program is utilized for all dispositions categorized as "Use-As-Is" or
" Repair." The WCNOC design control program requires engineering to perform independent reviews of all design changes. Rework disposition is the process by which a nonconforming item is made to conform to prior specified design requirements. These design requirements were previously established by the design authority and are contained in design documents. The WCNOC work control program addresses the implementation process for resolving nonconformances. This program allows the task planner to rework the item to pre-existing design or obtaining a " Repair" or "Use-as-is" disposition from the design authority. The WCNOC work control program also requires the task planner to use the Quality Control Inspection Manual (QCIM) to add inspections required by the manual to corrective maintenance work package instructions. This manual contains inspection and examination requirements for work activities that are required to be inspected by Quality Control.
The QCIM is reviewed, approved and controlled by the Quality Control organization and the inspections are based on design requirements. Quality ,
1 1
I l
. Attachment I to WO 97-0002 Page 3 of 3 Control performs inspections to the QCIM and design documents included in
. work control package. Items that are required to be reworked or repaired are inspected for acceptance prior to the component being returned to service.
- Section 17.2.15.5 (Procurement Controls) has been revised to eliminate redundant wording and clarify the process, and moved to Section 17.2.4.5.5.
- Section 17.2.15.6 will be renumbered as 17.2.15.4.
- Section 17.2.15.7 will be renumbered as 17.2.15.5. The first paragraph of current section 17.2.15.7 will be deleted. Maintenance Rule trending is being added to the second paragraph. The Maintenance Rule will be utilized as the tool to provide trending of nonconformances. References to the )
NPRDS have been removed. '
The Conditional Release procedures are required to prescribe the responsibilities for the processing of conditional releases that include I provisions for the review and approval of the conditional release.
No other USAR descriptions or conclusions would change or be rendered untrue due to the proposed change. Applicable procedures will be revised to reflect the program changes discussed above.
l l
~ . . . . .-. -- - . . . - . . - . - - - . -- -- -- _
Attachment II to WO 97-0002 Page 1 of 7 WOLF CREEK 17.2.4.3 Procedural Control Written procedures shall include, as applicable, controls for the preparation, content, review, approval, and processing of the following types of procurement documents:
- 1. Purchase Requisitions
- 2. Letters of Intent
- 3. Purchase Orders and Contracts 17.2.4.4 Quality Classification Each item to be procured is evaluated to determine whether or not it performs a safety-related function and to apprise the importance of this function to plant or public safety. For those cases where it is unclear if an individual piece (i.e., part of a safety-related structure, system, or component) is safety-related, an engineering evaluation is conducted. The evaluation classifies the safety relationship of the questionable component parts or items of safety-related structures, systems, or components. The evaluation is documented for future reference and receives an independent review. Procurements for safety-related items and services are reviewed by Supplier / Material Quality to ensure that quality requirements have been satisfied. Each service to be procured is evaluated to determine whether or not it involves activities that affect the function of safety-related materials, parts, or components and to apprise the.
importance of this function to plant or public safety.
17.2.4.5 Quality Requirements in Procurement Documents Procurement document control measures ensure that appropriate regulatory requirements, design bases, and other requirements are included in the procurement process. Originating and reviewing organization procedures require that the following be included or invoked by reference in procurement documents, as appropriate:
- 1. Requirements that the supplier provide a description of his quality assurance program which implements the applicable criteria of 10 CFR 50, Appendix B, or any other nationally recognized standard which meets the intent of 10 CFR 50 Appendix B and which is appropriate for the particular type of item or service which is to be supplied. The description of the Suppliero Oh program is reviewed by Supplier / Material Quality and resulting comments, if any, are resolved with the supplier prior to releasing the supplier to begin work in any area impacted by the comments. Comments resulting from the review that may require additional supplier control are identified. Certain items or services require extensive controls throughout all stages of manufacture or performance, while others may require only a limited control effort in selected phases. These requirements are not applicable to off-the-shelf or commercial-grade items which utilize a supplier's standard or proven design, or his procedures to meet given technical and quality requirements and whose fulfillment of the technical and quality requirements are accepted by receiving inspection.
17.2-12 Rev. 10
l l
Attachment II to WO 97-0002
[ Page 2 of 7 l WOLF CREEK i
- 2. Basic administrative and technical requirements,
! including' drawings, specifications, regulations, i special instructions, applicable codes and industrial
, _ standards, and procedural requirements identified by ,
l titles and revision levels; special process- )
instructions; test and examination requirements with !
corresponding acceptance criter4a; and special )
requirements for activities such as designing, '
identifying, fabricating, cleaning, erecting, packaging, handling, shipping, and storing.
l 3. Requirements for supplier surveillance, audit, and inspection, including provisions for providing the i Operating Agent or its agent access to facilities and l
! records and for identification of witness and hold -1 points.
[ 4. Requirements for extending applicable requirements of the Operating Agent's procurement documents to lower-tier suppliers and subcontractors. These requirements shall include right-of-access to subsupplier facilities )
and records by the Operating Agent.
- 5. Requirements for supplier reporting to the Operating Agent certain nonconformances to procurement document requirements and conditions of their disposition.
l Procedures prescribe measures for the reporting, control i and disposition of purchased items which are identified by suppliers as nonconforming. Nonconformances dispositioned as "Use-as-is" or " Repair" are reviewed per l the design / configuration change process and, therefore, l, approved by the responsible design authority.
- 6. Documentation requirements, including records to be prepared, maintained, submitted, or made available for i review, such as drawings, specifications, procedures, l procurement documents, inspection and test records, personnel and procedural qualifications,-chemical and physical test results, and instructions for the retention and disposition of records.
- 7. Requirements for supplier-furnished records, including:
- a. Documentation that identifies the purchased item l t and the specific procurement requirements (e.g.,
codes, standards, and specifications) met by the
' item,
- b. Documentation identifying any procurement requirements that have not been met.
- c. A description of those nonconformances from the procurement requirements dispositioned "Usccccept -as-is" ic" or "Reepair" or "Reedesign."
,8. Requirements for the reporting of defects -and l
[ noncompliances including 10 CFR 21.
i 1
! 17.2-13 Rev. 10
l Attachment II to WO 97-0002 Page 3 of 7 WOLF CREEK ;
procedural requirements which impact the quality of an item. Nonconforming activities which have not resulted in hardware nonconformances (i.e.,
programmaticpeegeamab&e or procedural deficiencies which do not impact the l quality of an item), are corrected in accordance with Chapter 17.2.16, Corrective Action.
17.2.15.2 Nonconformance Controls Nonconformances identified under the Operating % gent'c Operating Ouclity Program-are identified, documented, controlled, dispositioned and corrected in l accordance with approved procedures. These measures provide for the I notification of affected parties and controls to prevent the inadvertent use of I
nonconforming items.
l
) Nonconformances are controlled by report documentation, tagging, marking, l logging, or physical segregation. Nonconformances are documented on records I
! which identify the nonconforming condition, record the disposition, and l register the signature of an appropriate approval authority. Nonconformances are reworked, rejected, repaired, or accepted. Repaired and reworked items are reinspected / tested in accordance with applicable procedures to ensure that critical attributes possibly affected by the nonconforming condition remain acceptable. These procedures are based on original inspection and test requirements or approved alternatives. Reinspection results and operational data, gathered subsequent to repair or rework, are documented or referenced on nonconformance, test or inspection documentation.
The design /configurationconfiguraten change process is used in the
. Nonconformance Program to carry out dispositions of "Uuse-as-is" or "Reepair."
l This process ensures that all aspects of plant operation are considered in light of the fact that the dispositioned item is now not exactly per original design. These considerations include revision of applicable drawings, possible revisions to operation, test, maintenance and inspection procedures; training
, of affected personnel, changes to spare parts inventory; unreviewed safety questions; and review of licensing documents. .
1 Measures have been established to control the conditional release of nonconforming items from the warehouse,ncaccaformanccc for which correction is l pending and a technical evaluation indicates that installation and/or testing will not adversely affect nor preclude identification and correction of the nonconformance. A conditional release to proceed with installation and/or w+th l l testing of a system or subsystem with outstanding nonconformances considers the nature of the nonconformance, its effect on installation and/or testing and the need for supplemental tests or inspections after correction of the l nonconformance. Conditional release evaluations are documented. Safety related and cpecial ccepc conditicnal relecccc are reviewed and approved by-bhe Operating 7. gent'c Performance Icprovement and 5cccccment divicicn pric t-te implementaticar
- Nonconforming items required for Technical Specification Operability are only l released for use through the design / configuration change process and, thus, cannot be conditionally released for operations.
l 17.2-39 Rev. 10 l
l
1
. I Attachment II to WO 97-0002 Page 4 of 7 l J
WOLF CREEK l 1
17.2.15.3 'cperting Methoda Ncaconformance repert: 'c.g., : r Re qu e c t c , "cnacnformance Report, .;c r k 1 S S' SS_ S S _
i 1
"enconfermance reports are used to document nonconforming materie4er-P+rtc, or l componente after iccue frem the .:a rchcu c c . j i
l Ccmmedity Dicerepancy Reperto are uced to document nonconforming aterialc, partc cr compcncnto under archcuce centrol and dccument minor dccumentatica related ncnccaformanccc at the ti=c cf rcccipt nd after receipt incpecticar Nonconformance report; and Ccrmodity Dicercpancy "cpert requiring ""cc ".c-Ic" cr " Repair" dispccition; arc revicued and dicpecitioned by the recpcacible dccigr cuthority.
Occumentation dicerepancica identified after rcccipt incpecticr " hat render Ehe quality cf hardware indeterminctc arc dccumented ucing cr CDP 17.2.15.34 Disposition i
Procedures prescribe the individuals or groups assigned the responsibility and authority to approve the disposition of nonconformances. Nonconformance l disposition categories are: )
i
- 1. " Reject" - the process by which a nonconforming item is j rejected for use and either scrapped, returned to vendor, or downgraded to allow for use in a Non-Q System.
- 2. " Rework" - the process by which a nonconforming item is made to conform to a prior specified requirement by completion, remachining, reassembling or other corrective means.
- 3. " Repair" - the process of restoring a nonconforming characteristic to a condition such that the capability of an item to function reliably and safely is unimpaired, even though that item still may not conform to the original requirement.
- 4. "Use-as-is" - A disposition which may be imposed for (i.e., a nonconformance when it can be estab-Accept) lished that the discrepancy will result in no adverse conditions and that the item under consideration will continue to meet all engineering functional requirements including performance, maintainability, fit and safety.
17.2-40 Rev.10
)
i l
i 1
I
I Attachment II to WO 97-0002 Page 5 of 7 WOLF CREEK
" Repair" and "Use-as-is" dispositions are approved by the responsible design authority as prescribed in procedures. This authority is an organization which has demonstrated competence in the specific area, has an adequate understanding of the requirements and has access to pertinent background information.
n:__
. .. m. :_.i____.,:
....y_ . ..
.~ ...m, ., .a.: _.,y--.
. ., _ : ,. tem.. .,. . s..,__, .... u ~ s_ y _...a_.a.
m . ~ s. . .i m
, ...:.s.
. . -.a, , u, . . n.__.c_.__.~,.,_
. . .~.
c _ ._ u.s . c .n. , _ .- a~ .c.. _ ,:
,_a r
m..y m ._m . . m _ _- ~ ~ . . .. ..~ n___._____.
~. -... . .~ y 7 . _ . ~_.,f.u ,.__ _:.. n . . -.
, 3,.:. , . . . .c _ ._ c_n n. m,. .
i 17 .9.it..t_
. . .mm mmmm.
n._mmm._____.. e m _.__. ...1_
i Plant and other Opcrating .Sgent crgani;c;4cn precederec prcccribe mcacurcc for the acntrol and dicpociticr of Operating ". gent'c purchaced items hich are
.am. : c:_a u.. __.:,.._.,.v.av auw.u.. **ww u, m
vw.w.uw. .. : a v.sju...u
_ wv ..v_ M.' v_ _. .c v.m..3 n._.m.,... v v u ~w m w m. . a vmv
~w. _ m .s. .~ . . ,
___m,e_... !c, .L..m,..-
. _ .~__..-~_.,cm_ ,_.- . .L. _:,,L. __,, ..
_ . L ..:.._m.J .m .- .L..... nme n_..!., __
. M.~,m... . ~ .
c m ,.
...~__..~..mm m y y . m ., . _1. m.c . L.m _.~_~.~s~
__ _a_A
-a -v _m_!, - . .
n, __ . :m.~ ._,L,~__
m__ _ _mmm
... . s~ r m . ~ m___ .- .L.._m_m m
. .s s. . .
nonconfermanccc require documentatier and arc for;arded to the Operating ^. gent along .:ith t+.c hart:are and acccmpanying quclity verification documentation The Operating .^. gent'c organicatica recponcible for correcting the problem approvec the recommended dicpecition of nonconfermanecc relating to the Operating ?. gent'c initiated procurement requiremente. *he cupplicr/"_aterial
%..t .:. , .. . __,c.c : _ __._.s._.,
. _ . _ym.
- utm
.s p- ._ _m . a.. : . : ., , .u.~_ y.__..,
_ _ _ _ _ :_, _c
- m. .v.._.__ .m.~ey. _
. s ecc.mmended __...: _ dicpecitienc.
- m. _., : ,., .v.._.~,_.,
~
.s._.._a The dicpociticr of a noncenictmanac . hic'_irvclvcc
_ . u. ~m ,~u, . ,. ,i,_ c.:_ _, _, _: _.. _u~_._
1 _ _ _ __
. . y,.. . ~... , . .., e.,-._
and, therefore, cpproved by the responcible dccigr authcrity.
1 17.2.15.46 Reportable Nonconformances l l Nonconformances are evaluated for reportability to the NRC under 10 CFR 21.
All nonconformances identified as reportable are reviewed by the PSRC and NSRC.
17.2.15.54 Trend Analysis l um _ ___
~..,.~..c...~.~- ,_,_a.~__m.___.. . ~ . . _u.,
- _.. _ _.._..a_u_.,.
, n._ _. ..c___
...y_...~...
,a
..~
Acccccment percc ncl for identification of petential uncaticfactccy
_ . . , :. , .... i .: ., .. .___a.,. ..a~ u
.,. _c yy ..a . ,i u. ~ ,. _ ._ _:,1 .n..,,n... :
.c _ _ ..~u._m..
y.~ .~. ,.~ . ,. . ., ~. . . .
v,. u . . - ~ . , - . .c y.c..<~.._.
. ~_ __. .~ .. .u.
. . ._ . . _: s
. . ~ . .,~ _ ~ , . _y. -
..,_~a . , ~ - _ , ~r._...
. . ~ . --__.
Significant adverce quality program trendo are handled i cccordance :ith e -.:.m_
~~m .. ,. .,. q . n. c . -
Hardware failures are reviewed within the Operating Agent by the Performance Improvement Reques t ( PIR) program. This program determines and evaluates the causes of hardware malfunctions / failures. The Nbintenance Rule provides for trending of safety-significant SSCs. A review and evaluation of previous experiences (trending) for the system, structurccquipment or component is made to determine whether the item is functionally reliable. The "uclear Pland "cliability Data System ( DPSS )
_a _.m a _..:
w y. _ . . .. .c,.,.__ : _ "a. _._.
..~ .,
_.. program.u.capturec
.__a._._.
. _ . ~ ., ~ u. n. n_n pertinent
- y. e ,.m _ _,_ informatier
,, _ y . . 1for
__ .. &, au.
__~:.~
s.~.._m . . . . . , _.y
_m__ _m__ .sm _ m _
~.. &__ _.
~L1.c e_mm
_t. , .L.._,.
. ,_.m.. .c :.. _1:.~.,..
.m,.._ , _ L. .i m 3.~L m .L.~..
cxpericrced ir the remainder Of tFc inductry. T'ic Maintenance Rule data may then be used to determine needed. corrective measures based on the identified root cause and severity of the component problems. This data may also be utilized to evaluate the potential need for equipment replacement. 4+r44HS n.._.__._.~, .,:_._. _ a. sm u, : _ : c__ _ :__
n, i , __ . . . .~mu a .: .c .: _m .... , . , .:_ u n. -n. n.~e a s.~, ,. s, , , ,~ms.~.,.,,, em .s...~..,
s . 7 ,.m. . .s.,.
component dispccitirns.
17.2-41 Rev.10
Attachment II to WO 97-0002 Page 6 af 7 WOLF CREEK 17.2.16 CORRECTIVE ACTION 17.2.16.1 Scope l
l Corrective action control measures have been established to assure that
! conditions adverse to quality are promptly identified, reported, and corrected.
! When necessary, corrective action includes actions to preclude recurrence and
- followup verification. Corrective actions associated with the resolution of l hardware related nonconformance reports and audits /surveillances are processed in accordance with Sections 17.2.15 and 17.2.18, respectively.
Significant conditions adverse to quality which impede the implementation or reduce the effectiveness of the QA program are identified and documented in accordance with approved procedures. Procedures provide instructions for identifying, reporting, documenting, and initiating corrective action to preclude recurrence of significant adverse conditions. These conditions are reported to apprcpriate management, evaluated, documented, and corrected. The PSRC reviews all significant conditions adverse to quality identified at the plant and recommends corrective action on significant conditions adverse to safety regarding operating procedures. Significant adverse conditions are documented by measures described herein. These conditions may include a gross noncompliance to procedural requirements, a recurring condition where past I corrective action have been ineffective, significant adverse nonconformance or l noncompliance trends, or significant Operating Quality Program deficiencies.
Corrective ;ction documento ticF may bc Performance Improvement Requests (PIRs) are used to identify significant conditions adverse to quality, a+e i Performance Improvement Requectc 'PIRc and Corrective Scticr Ecqucct: 'CARc) 1 Corrective Action for significant conditions adverse to quality ensures the elimination of the cause of the conditions and includes provisions for ensuring j that corrective actions are not inadvertently nullified by subsequent actions. ;
1 17.2.16.2 Performance Improvement Request (PIR) i PIRs are used to document conditions adverse to quality and correct I significant conditions adverse to quality, including nonhardware problems )
(programmatic, procedural, or personnel), radiological occurrenceocccurencca, and requests for analysis of plant equipment failures. These conditions are evaluated for potential reportability, potential applicability to other organizations, significant recurring trends and the potential impact to plant operability. The Responsible Manager ensures that corrective actions addressing ,
NRC violations, LERs or other significant conditions adverse to quality include I root cause determination; a plan of action based on root cause, which includes l action to preclude recurrence, and a scheduled completion date; an independent review of the action plan to ensure that the corrective action will be adequate; and an independent follow-up to determine if the corrective action was effective. Independent reviews and follow-up are performed by individuals assigned by the Responsible Manager but who were not responsible for the corrective action plan or corrective action implementation, respectively.
Prior to closing a PIR which required corrective action, the Responsible Manager ensures that corrective action was completed and accepted.
PIRs are processed to Performance Improvement and Assessment, Trend Analysis for analysis to identify trends in quality performance. These trends are reported to appropriate level of management and the Chairman of the NSRC.
17.2-42 Rev. 10
. .-~ .. _ . - - -. . .- . _ . , _ . . -
I
\ .
,* Attachment II to WO 97-0002
' ' Page 7 of 7 W'OLF CREEK
( 17 2 16.3 Crrrective *ction ".c qu e s t - ( C? " )
l ,
I Canc are n;tiated tc correct cignificant conditienc adverce-tc quality wh4eh cculd not be corrected by cther corrective actier meanc. Claa a re Iri+iated by Performance Improvement and Scccccmcr' and C^Rc are trancmitted to the Recpancibic "anager hc :dentifice the cauce'c) c f the de ficiency and, based-en the rect caucc, cpecifico the actien(c) cccccary to carrect the condition (c) l ar" prevent recurrence. The Recponcible "; ager encurcc that the corrective action ic implemented. " PlS ic uccd by the Respencible Manager to document l the rect caucc determinabien, the corrective actica plar and impl-emenbation and
! the fcile up-aetivitico.
G4cccout of C?Rc by Performance Impretamcr' and Aaccccment ic accomplichef ac promptly as practicable but Occurc only after the imp 4cmentaticr effectivenecc of the corrective acticr 'ac beer verified. Performance !mprovement and Acccccment periodically preparec cummarice of C"Rc and cubmit thecc cummarico to the MSRC and apprcpriate levcic cf managenc-t, 17.2.16.34 10 CFR 21 Reports Significant adverse conditions involving a defect or noncompliance in a delivered component or service which could create a substantial safety hazard are reported to the Nuclear Regulatory Commission pursuant to the requirements of 10 CFR 21. The PSRC reviews potentially reportable defects or noncompliance evaluations performed by the plant staff.
17.2.16.46 Trend Analysis l PIRs are processed to Performance Improvement and Assessment to identify trends. These trends are reported to appropriate management and the Chairman of the NSRC.
17.2.17 QUALITY ASSURANCE RECORDS 17.2.17.1 Scope A records system governing the collection, storage, and maintenance of records was established by the Operating Agent and is in compliance with the standards and Regulatory Guides identified in Table 17.2-3. At a minimum, the records system applies to operating phase records associated with Operating Quality Program governed activities when records are required to either demonstrate compliance with licensing commitment or finished documentary evidence of the goality of items and activities affecting quality. All such records are considered QA records and are legible, complete, adequat~ly identifiable to the item or activity involved and readily retrievable.
Quality Assurance records include but are not limited to operating logs; maintenance and modification procedures and inspection results; reportable occurrences; results of monitoring and reviews; inspections, tests, audits, and material analyses; qualification of personnel, procedures, and equipment; records required by Technical Specifications; and other documentation including drawings, specifications, procurement documents, nonconformance documentation, corrective action requcctc, procedures, and calibration procedures and reports l required to demonstrate compliance with license commitments.
17.2-43 Rev. 10 1
i r -e -