ML20154E997

Responds to SALP Insp Rept 50-482/88-14.Response Reflects Discussion Held Between NRC & Util During 880720 SALP Conference.Mgt Support for Fire Protection Program Remains Strong

ML20154E997
Person / Time
Site:	Wolf Creek
Issue date:	08/19/1988
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20154E975	List: ML20154E972 ML20154E995 ML20154E997
References
WM-88-0207, WM-88-207, NUDOCS 8809190214
Download: ML20154E997 (21)

Text

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-W$LF CREEKy' nME NUCLEAR OPERATING CORPORATION 77g I

Bart D. Withers { h Presdens and 1 Cn.ef Enoctive OMcer August 19, 19$8 ' ~

WM 88-0207 R. D. Martin, Regional Adminiwtrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Reference:

Letter dated June 23, 1988 from R. D. Martin, NRC to B. D. Withers, WCNOC

Subject:

Docket No. 50-482: Response to Systematic '.asessment of Licensee Performance Inspection Report 50-482/88-14 Gentlemen:

Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) response to the Systematic Assessment of Licensee "erformance (SALP) Report transmitted in the Reference. This response reflects discussions held during the SALP conference between WCNOC and the NRC Staff on July 20, 1988, at Wolf Creek Generating Station Education Center.

If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staff.

Very truly yours,

. sJ Bart D. Withers President and l

1. f o. Chief Executive Officer  !

Attachment

$ cc: B. L. Bartlett (NRC), w/a cdg D. D. Chamberlain (NRC), w/a

$4 P. W. O'Connor (NRC), w/a (2) y Document Control Desk (NRC), w/a ,

0 0: Kansas Corporation Commission,

$$e ATTN Robert D. Elliott, Chief Engineer PO Dos 411/ Durtangtm, KS 66839 / Phone: (316) 364-8831 An Ewai Chor%rity EW uF HCATT

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Table of Contente

, i Pait Introduction 1 i

Section I. General Overview 2 Section II. Detailed Responses 3

A. Plant Operations 3 I

B. Radiological Controls . 4 C. Maintenance 5 ,

'k j D. Surveillance 6 l I

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i F. Energency Preparedness 7 I

G. Security 8 H. Outages 9 I. Quality Programs and Administrative Controls 10 Affecting Quality c 4

J. Licensing Activities 16

! K. Training and Qualification ectiveness 17 i

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Section III. Additional Comments on SA!.P Report 19 i

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INTRODUCTION Wolf Creek Nuclear Operating Corporation (WCNOC) has reviewed the Systematic Assessment of Licensee Performance (SALP) report and has prepared responses to address the ' Recommended Licensee Actions" for each of the functional areas evaluated.Section I provides a general overview of enhancements that have been made or initiated and Section II provides detailed responses to each of the areas evaluated. The detailed responses are presented in the same order in which they were presented in the SALP report. It should be noted that WCNOC did not address each example discussed in the report as the majority of these ,

examples have been addressed in previous correspondence. Instead, it responds to the Recommended Licensee Actions identified in each functional area and also responds to selected items that WCNOC feels need clarification.Section III provides editorial comments that address what WCNOC believes to be '

adm'.nistrative errors in the report.

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SECTION I GENERAL OVERVIEW

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The SALP report covered the period between March 1, 1987, and March 31, 1988 and identified the areas in which the NRC believed improvements could be made.

WCNOC's own assessment of performance during this period had also identified the need for improvements in several of the same areas. Therefore, many of the actions recommended in the SALP report had already been implemented or initiated even before the SALP Board met.

As discussed in more detail in Section II and in other previously docketed

. correspondence. WCNOC has made or is making enhancements in several areas. Some of the more significant changes made are outlined below:

- Re-organization of Maintenance to combine Maintenance and Modifications under a single manager and eitninate unnecessary levels of supervision in order to provide more direct management control of work activities.

- Changes in the Outage Management ora,anization to provide additional experienced personnel and to more clearly reflect the Outage Manager's function and authority.

- Restructuring of the daily planning meetings to focus more on problems and corrective actions than on work status. This provides significant improvement in cooperation and coordination among work groups and gets the technical support groups involved earlier when problems arise.

- Selected personnel have been trained in Root Cause Analysis and programmatic changes are being developed to provide a stronger program  :

for determination of root cause.  ;

- An independent assessment of the WCNOC organization has been 1 commissioned to identify and recommend enhancements to improve the '

overall effectiveness and efficiency of WCNOC.

WCHOC believes the above initiatives along with others discussed in Section II will result in more effective and efficient control of work activities. WCNOC >

will assess the effectiveness of the improvements discussed in this response and make adjustments as necessary to assure the safe, reliable, and efficient operation of Wolf Creek Generating Station.

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SEC'fION II DETAILED RESPONSE A. Plant Operations Recomrnded Licensee Actions Licensee management should ensure that there is an adequate and prompt QA, NSE, and Engineering involvement in operational events and in the technical resolution to safety issues.

Response to Recommended Licensee Actions WCNOC agrees that management should ensure that adequate and prompt technical support group involvement in operational events and in the technical resolution of safety issues takes place. The untimely resolution of the ESW pipe wall thinning issue was caused by management's failure to solicit a timely engineering evaluation which included the potential for generic implications. Discussion of the issue focused on peripheral matters, rather than on the fundamental concern, and thus created needless delay. The corrective actions which WCNOC has implemented to address these problems have been extensive. These corrective actions are simed at creating extensive interaction between operations and technical support groups and high visibility of problem areas to achieve timely resolution. The corrective actions include:

- Procedure requirements have been made ensuring that engineering is notified of technical concerns such as pipe wall thinning and that engineering evaluations are completed promptly to support operability determinations.

- Engineering has been included in work planning meetings to enhance communications between engineering and operations.

- Significant organizational restructuring has been implemented in the Haintenance and Modification areas to provide for close monitoring of engineering dispositions and their processing.

- More fundamentally, by restructuring the daily management meeting to include key managers for a review of work related issues, with an emphasis on the thorough airing of issues, WCNOC has created improved cooperation between Operations, Quality, Nuclear Safety Engineering, and other technical support groups for problem resolution.

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4 The NRC has also identified exam ^les of lack of attention to detail. Corrective actions taken or being taken to improve attention to detail includes i

- The need for continual attention to detail was emphasized to all -

station employees through group meetings and written consnunication.

- Procedures have been and are being prepared for equipaaent outages of a complex nature such as a vital electrical bus.

- Miscomunication between the Outage Control Work Authority (CWA) and the control Room, which resulted in the misuse of operator aids, I

resulted in the prompt relocation of the CWA into the Control Room.

- A review of operator aids was conducted to ensure they were being <

correctly utilized. It was also directed that such a review be done i periodically.

l j - The clearance order and the control of information tagging procedures l 4 have been revised to properly control and remove operator aids used l as a result of clearance orders.

The substantial corrective actions discussed above, coupled with close management attention, will result in improvement in the operations areas including significant and prompt Quality Assurance, Nuclear Safety Engineering, Engineering involvement in operational events and in the technical

! and resolution to safety issues.

B. Radiolonical Controls Recomended Licensee Actions Health Physics supervisory personnel should spend more time in the radiologically controlled areas evaluating and observing ongoing radiation ,

protection work activities to ensure compliance with station procedures.

Management should take action to provide training to technicians to enhance procedural compliance.

Response to Recomended Licensee Actions WCNOC agrees with the Recomended Licensee Actions. Unresolved concerne j j were noted in the areas of steam generator mockup training and supervisory  ;

! presence in the plant. Both of these issues are currently well underway  ;

t towards complete resolution. A steam generator mockup training program is

) , being fully implemented. The ongoing training program was initiated in 1 July, 1988, using the onsite steam generator mockup facility. A majority ,

j of the Health Physics staff and numero9s maintenance and contract l personnel are scheduled for training for the upcoming outage.  :

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• To improve supervisory presence in the plant, Health Physics supervisors are being placed on shift during major work outages. In addition, management staff meetings with Health Physics supervisors have emphasized the need for close field supervision. They have been instructed to provide first hand observation of work activities and provide appropriate log entries for management review. This will remain a high priority for the entire organization, not just the Health Physics organization.

Further action to ensure procedural compliance in Health Physics was also recommended. The emphasis on procedural compliance was made clear by direct management involvement during the outage for Health Physics as well as other organizations. In addition, examples of procedural noncompliances have been incorporated as examples in Health Physics training programs. This, together with high priority by management on Health Physics training will ensure improved procedure compliance.

C. Maintenance Recommended Licensee Actions The licensee should follow through and assesses the effectiveness of their corrective actions. The licensee should continue the increased emphasis on procedural compliance.

Response to Recommended Licensee Actions The outage problems associated with the Maintenance organization included several examples of procedural noncompliance. It became apparent, however, that more was needed than a strong re-emphasis of procedural compliance philosophies. As a result, VCHOC undertook a major restructuring of the Maintenance organization to ensure strong supervisory support for not only procedural compliance, but for correction of other weaknesses as well.

As recognized in the SALP report, the organizational changes made during and since the outage have significantly strengthened the Maintenance organization. The current management team has emphasized procedural adherence, pre-job briefings, and identification of areas in need of improvement. This has resulted in improvement actions in the following areas

- Staffing has been proiided to address needed procedure improvements.

- Easier-to-use work packages with additional detail in the work instructions have been developed by using an enhanced desk-top publishing system.

- Regular meetings of supervisors, schedulers, and work groups are scheduled to improve communication and coordination of all involved personnel.

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- Improvements in trending of maintenance indicators have been made.

- Administrative steps have been implemented to more effectively hold personnel accountable for their actions.

VCNOC will continue to emphasize management attention and support in the Maintenance and Modifications areas. Problems that are identified will receive prompt attention and corrective actions will continue to be assessed to verify effectiveness.

D. Surveillance Recommended Licensee Actions The licensee is encouraged to perform an in-depth review of the Technical Specification surveillance requirements and ensure that the surveillance procedures address these requirements. Also, additional management involvement with the surveillance activities is encouraged.

Response to Recommended Licensee Actions As noted in the SALP report, WCNOC had several Licensee Event Reports associated with surveillance procedurer. Those instances have been addressed through a number of mechanisms including:

- procedure revision

- review of infrequently performed surveillances

- review of Technical Specification bases and procedures to ensure consistency

- enhancement of programmatic controls of surveillance procedure revisions While each of these resulted in some Onprovement in the program, the NRC has encouraged VCNOC to undertake an in-depth review of the entire Technical Specification surveillance requirements to ensure that they are procedurally addressed. WCNOC has recently initiated that effort through the Operations organization. This effort and the ongoing performance of the surveillance program will receive close management attention to ensure the correction of identified weaknesses.

E. Fire Protection Recommended Licensee Actions The licensee should assure that the recent organizational changes that have the fire protection engineer reporting to a different group and at a lower managerent lecel does not result in a reduction of management support.

Attachment to WM 88-0207 Page 7 of 19 Response to Recommended Licensee Actions The recent organizational changes are anticipated to improve communication and coordination between the fire protection specialist and Operations organizations. This will enhance the response of the Operations department to the Fire Protection Specialist's input regarding housekeeping and surveillances. Management support for the fire protection program remains strong.

F. Emergency Preparedness Recommended Licensee Actions The level of management attention to the implementition of the emergency preparedness program should be increased to ensure proper response to NRC identified concerns relating to cali-out drill response and shift augmentation response times. The licensee should expedite correction of the call-out drill response and shift augmentation concern. Management should review the distribution of on-site and off-site emergency program areas of authority and responsibilities.

Resoonse to Recommended Licensee Actions WCNOC has taken and is taking actions regarding the NRC's recommendations to provide a Radiological Emergency Response Plan and an Emergency Response Organization which are both effective and responsive to NRC concerns. In regard to call-out drill response and shift augmentation response times WCNOC has significantly revised the call-out procedures and methodology. As a s. salt of these changes, WCNOC has successfully a completed the last two quarterly call-out drills. However, the different methodologies are being continually assessed to improve the call-out response times.

l In regard to shift augmentation, health physics training of additional project personnel is being conducted to increase the number of qualified personnel to respond to the call-out.

The distribution of authority and responsibilities between the on-site and off-site portions of the emergency response plan are currently under review. WCNOC has recognized that there may not be a clear understanding of the responsibilities of the Emergency Planning Coordinator and the Emergency Planning Administrator by all project personnel, although the i division of responsibility and authority are defined in the Emergency Plan i Implementing Procedures.

In an effort to improve accountability for the actions of the Emergency l Planning Administrator in the performance of his duties, he now reports to l a 'ine manager in order to assure that his actions are monitored more closely and additional guidance and attention to detail is provided by management.

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Attachment to WM 88-0207 Page 8 of 19 p G. Security Recommended Licensee Actions The licensee should continue to probe the causative factors of security events for broader implications and adjust programs, training, disciplinary actions, maintenance, and engineering responses appropriately. The organizational adjustments made in the QA area should be closely monitored to ensure that the high quality of the security oversight program continues.

Resoonse to Recommended Licensee Actions WCNOC will continue in-depth evaluation of security events to determine causative factors and to identify broader implications which require changes to programs, training, disciplinary actions, maintenance, and engineering responses, as suggested.

It is important to note that the Quality Department was reorganized in February, 1968. The objective of this change was to more effectively group functional responsibilities. No changes were made with regard to the personnel or methods previously used to perform security program evaluations. The auditors who had been previously involved are still involved in the performance of QA audits and surveillances of security.

Additional Response Two security related issues discussed in the SALP report deserve some additional discussion from WCNOC's perspective. These two issues are Control Room access and the closed circuit television (CCTV) system.

The Control Room access issue is still open pending the issuance of an NRC position on two items. A meeting was held between WCNOC (then KG&E) personnel and NRC Region IV personnel in Arlington, Texas on October 27, 1986. In that meeting Region IV agreed to obtain and relay to Wolf Creek the NRC's position on the two items. It was understood that Wolf Creek would make no significant changes until Region IV provided the NRC's position on these two items. Although recent discussions indicate that this information is forthcoming, it had not been received at the time of the issuance of the SALP report. Therefore. WCNOC believes it was inappropriate and incorrect to identify this as a long standing regulatory issue attributable to the Licensee.

The second issue that was identified as a long standing regulatory issue attributable to the Licensee was relative to the CCTV system. When the inspector identified this as a potential violation in his exit meeting, he stated that hir concerns were with both the design and maintenance of l

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the system. WCNOC's initial response challenged the design concerns and acknowledge the maintenance concerns. After several discussions it was ,

discovered that the NRC was not challenging the design. Therefore, WCNOC completed the maintenance enhancements needed to keep the CCTV system in good working condition. The time between the receipt of the violation and completion of the enhancements was less than six months. Again, WCNOC believes it is inappropriate to identify this as a long standing regulatory issue attributable to the Licensee.

H. Outare Recommended Licensee Actions I The licensee should ensure that lessons learned from the previous outages  ;

are identified and reviewed for program improvements. The results of this i

review should be incorporated into outage planning and control.

Resoonse to Recommended Licensee Action _s In general WCNOC agrees with the evaluation and Recoounended Licensee Actions, recognizing that the events do not lend themselves to grouping.

For example, the Haintenance area, the Operations area and the Outage area all have interconnecting concerns as a result of the events of last fall.

There was a major ' lesson learned' in this outage. A traumatic event such as a death manifests itself throughout the organization, causing a preoccupation with the event and a potential to lose track of plant and job status. The loss of effective management oversight of the outage activities was one of the more obvious effects, and necessitated a self initiated work halt to regain control of the project activities.

In order to ensure that events such as these do not repeat themselves, i WCNOC looked at organizational relationships and at personnel assignments. WCNOC recognized that accountability of personnel for their actions during the outage was not adequate. WCNOC also recognized that the Outage organization's activities in controlling the outage were not ,

totally effective. Also, the Outage organization was not perceived by the  !

i line organizations to be an acccuntable function.

l During the outage, a Shift Supervisor was temporarily added to the Outage I j

group for the remaining part of the outage. This provided operational knowledge to the group and contributed to the outage recovery. As a permanent change, two senior supervisors have been added to the group as permanent members of the Outage organization, one Maintenance Superintendent a r.d one Shift Supervisor. To give the group the '

1 accountability they require, the Outage group was transferred to the Plant

Manager's organization, with the Outage Manager now reporting to the Plant '

Manager. In additior. the scheduling personnel now get their direction i l directly from the outage group. I i

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t The Outage Group is strengthened during a major outage also, by adding Containment Outage Coordinators to the group. In this manner, there will be an Outage group representative on each shift working in containment during a major outage period.

WCNOC has also strengthened the cooperation between organizations by i structuring a periodic meeting, chaired by the Outage Manager, to develop  ;

q minor and major outage plans. All affected working groups attend these r meetings including Engineering, Procurement, and Operations.

i These changes, plus the changes in the plant organisation combining (

Maintenance with the Modifications Group provide a vertical integration of ,

the work function with proper line authority for direction and approval of f outage activities. These changes are strong improvements to the total organization.

In the overall improvement area WCNOC has looked closely at five specific  ;

items, Management Effectiveness, Connunications Problems. Work Planning, ,

! Procedure Problems and Quality Problems. In each of these, the concerns  !

1 were identified, the corrective action identified and the individual

responsible recognized.

In a similar manner the concerns and the areas for improvement resulting l from a review of Refueling Outage II were examined and specific assignments made to ensure the identified areas of concern were not l overlooked in any future outage.

i I. Quality Pronrams and Administrative Controls Affectina Quality Recommended Licensee Actions r l Increased corporate management involvement in site activities is  ;

recommended. In particular, additional corporate management involvement i

is needed to ensure that proper engineering and s involvement is (

, maintained in all activities.

r Resoonse to Recommended Licensee Actions

) Although the activities in this area are very much interrelated, this

section of the report is divided into three functional areas which are j discussed below. I i

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a) Engineering Cooperation and coordination between the plant staff and various technical support groups such as Engineering, Quality and Safety Engineering Group have become a major priority at Wolf Creek. Experiences like those cited in the SALP report have taught the importance of improving communications between the plant operating staff and technical support organizations. Engineering and Operations Department management have assessed their current means of communication, and are implementing major improvements which are discussed below.

In the Operations group, plant management has been instructed to maintain '

daily contact with Engineering and Quality to ensure the plant issues are

• j promptly addressed with consideration to design conformity, and quality j program compliance as well as operability.

l The Engineering organizations normally communicate limiting conditions and required operator actions to the plant staff through their disposition / safety evaluation packages. To ensure that the requirements of engineering dispositions are more visible to all organizations within Operations, engineering personnel have been instructed to discuss any special requirements of dispositions during the daily management

. meeting. In addition, engineering procedures used for the disposition of

, nonconforming conditions have been revised to require the engineers to

describe the affected design basis in addition to their t4chnical resolution when resolving problems. This change will improve communication of design basis information to the plant staff so that i

, design considerations can routinely be factored into plant operating l decisions.

l Huch of the communication between the Operating staff and Engineering is i formalized in written work documents. WCNOC understands the need for i formal documentation of technical requirements and design changes.

However, WCNOC also recognizes that formal work document processes j somstimes tend to inhibit interaction between departments because of the

various approvals required before these documents can be transmitted across organizational lines and simply because of the time inherent in

preparation of formal documents. The Engineering and Operations departments are committed to a new policy of optnness whereby all groups verbally exchange preliminary information and actively participate in the J resolution of problems. Of course those technical issues which have )

i safety significance will continue to be documented through the formal '

methods: but face to face coordination prior to initiation of the j i documents will expedite needed information exchange. For nonsafety.

! related activities, engineering will document this technical information l through memos to operating personnel, with a copy to the Control Room.

This will provide an expedited means to convey design information to the Operating staff.

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These measures will enhance Engineering's input, Operation's responsiveness, and improve cooperation and coordination between all organizations.

WCNOC has assembled an experienced engineering staff with technical i expertise, however, partially as a result of the NRC's Safety Systems 5 Outage Modification Inspection (SSOHI) at Wolf Creek last fall, WCNOC has r become aware that the engineering organizatione do not consistently evaluate the effects of modifications on original design. The need to ensure that the engineering staff firmly understands the Wolf Creek - l specific design basis is being stressed. Two major projects have been undertaken to address this, a design transition training program and a design basis turnover project. -

4 A design transition training plan was developed for technical personnel in the Nuclear Plant Engineering Division. This training is taught by experienced engineers from the original design A/E firm and consists of twenty-eight (28) courses - each 8 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in length for the civil, electrical, instrument / control, and mechanical engineering disciplines. ,

In addition to Engineering, members of the plant staff from Maintenance.

I&C, and Results Engineering also attend. The planned objectives for each course include training in the requirements and intent of the original Wolf Creek design, an understanding of the analytical methods employed for i the original Wolf Creek design, and a feniliarization with the design input documents which define the original design. The design-transition training program began in mid-1987 and will be complete by Spring, 1988.

In addition to this transition training, Engineering has methods in place to systematically evaluate the experience of individual engineers to  ;

detennine developmental needs and to provide proficiency training in specific technical areas.

i j Proficies.cy training is normally provided through university continuing  !

education, industry-sponsored programs, on-the-job training with more [

experienced enbineering personnel, and through contracted, on-site course work. <

l WCNOC is confident that these training programs will channel efforts to improve the depth of engineering expertise relative to the Wolf Creek j specific design basis. This increased expertise will strengthen WCNOC's .

i engineers' consideration of the original design basis for safety 1 1

evaluations and modifications. It will also promote more timely technical support of the operating staff.

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In addition to the engineering transition training mentioned previously, WCNOC management has initiated a design basis turnover project. This project will result in the incorporation of the Wolf Creek design basis into our configuration control program and will provide more expedient retrieval of technical information by engineering and operations personnel.

This project will involve turnover of remaining design basis documents from the original A/E. Phase I of this project began in January, 1988 and is scheduled to be completed in December, 1988. This project will result in a clearly defined methodology for engineers to assemble pertinent design basis requirements during the design change process and will improve the ability to retrieve design intent information quickly. WCNOC is confident that this project will strengthen the Engineering staff's understanding of the original design basis.

Senior management in both the Engineering and Operations Departments recognize that they need to focus more attention on job prioritization so that significant safety werk is completed in a timely manner. Each department has been directed to implement methods to screen work activities as needs are recognized. Safety significant work is assigned a high priority, then scheduled and monitored by upper management through completion. Operations and Engineering departments routinely meet to assess work load and coordinate shared work scopes to ensure compatability. This will allow management to focus attention on completing significant safety work to that follow-up actions, like those mentioned in the SALP report, are identified and monitored through timely completion.

Improved coordination of significant jobs between the Engineering and the Operating staff is also paramount. WCNOC is currently in the process of completing an extensive project which will result in a more structured planning process for major modifications. At the start of each major modification, a formal scoping session is held to develop a modification plan for all phases of the job. The scopias session includes a field walkdown and results in a clear definition of the problem, cause of the problem, scope of work, assigned organizational responsibilities, relative priority and schedule. These sessions are attended by ' worker

• 1evel personnel from the appropriate organizations in Engineering and Operations  ;

who have detailed hands-on knowledge of the problems, operational l considerations, and design requirements. Proposed modification plans are reviewed and approved by all levels including senior management in the Engineering, Operations, and Quality departments. This modification I

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planning process is supported by a performanc6 monitoring program which allows our management to ensure that significant jobs proceed according to plan and remain well coordinated. Development of this refined planning process began in 1987 and will be fully functional by December, 1988.

When this process la fully functional, it will provide a mechanism to focus Engineering's and Operation's talent on specific problem areas in the plant and will improve the sharing of information between both departments, b) Ouality Assurance The Quality Department has been reorganized to more effectively group similar functions. These changes included the consolidation of all QA activities relating to suppliers, procurement and materials into one division to ensure effective management oversight. This change improved. communications and resulted in the ability to batter coordinate vendor specific quality requirements with the Purchasing department.

This can decrease the probability of problems such as the noncede part being procured for use as a code boundary. It also provided for direct involvement and supervision by senior Quality staff members in the receiving and inspection process. This will reduce problems such as the improperly documented receipt inspection of the reactor vessel 0-ring seals.

Quality Department procedures have been reviewed and revised where necessary to ensure they clearly commanicate specific performance methods and criteria to the people doing the job. Personnel are receiving training on these procedures. Specific job details are reviewed prior to the start of activities to ensure all requirements are understood. This will help eliminate problems such as the incomplete inspection performed at the installation of the reactor vessel 0-rings and the problems identified with veld control inspections during the outage.

WCNOC recognizes the importance of ' performance-based' assessments and i had previously arranged for training of our QA audit and su:veillance personnel. This training was conducted July 19-21, 1988. WCNOC is confident that this performance-based approach will result in QA audits and surveillances that focus on plant safety and reliability rather than procedure and record reviews.

The Quality Department is currently performing research to develop a 1 corporate program for root cause analysis (RCA). RCA programs have been requested from several other utilities and consulting firms. After careful review of these programs a corporate policy will be issued. This RCA program will be factored into the procedures used to resolve nonconforming hardware conditions. These procedures will also consider the need to evaluate the cause of the nonconformance for potential generic implications, as well as methods to implement and track generic corrective actions for hardware nonconformances. This program will ensure that problems like the generic implications in the pipe wall thinning issue are

/ s' Attachment to WM 88-0207 Page 15 of 19 eliminated in the future. Training in RCA methods will be provided to user groups. This program will ensure that root cause analysis is comprehensive and consistent throughout the company.

Wolf Creek management has become more aware of the need for manngement involvement in the corrective action procets. On July 6, 1988, an escalation policy was issued by the President /CEO which will ensure senior management involvement in corrective actions which are untimely or inadequate. In addition, every effort is being made to ensure that open communications are maintained between line organizations such as Operations Engineering and the Quality department. Several groups in our Quality department are physically located with their line counterparts to promote ongoing communication. The office of the QA Hanager is located adjacent to the Plant Kanager's office to ensure there is an open and ongoing exchange of information on issues regarding plant safety and reliability.

These actions are fully supported by the corporate commitment to excellence. VCNOC is confident that these collective actions will serve to strengthen the Quality program.

c) Management and Administrative Controls WCNOC agrees that the response to the safety-related pipe wall thinning issue was not timely and lacked consideration for long-term design integrity and ASME Code compliance. Our plant management failed to solicit and consider Engineering input in the early stages, including the possibility of generic implications.

One of the most effective changes in improving teamwork and cooperation has been the significant restructuring of the daily management meeting.

The attendance of key management personnel from the plant staff, Engineering, Quality and other support groups is now required. This meeting is also routinely attended by the NRC resident inspectors. The meeting includes a review of current plant conditions, new work requests and current work schedule. At this meeting, there is an emphasis on a [

thorough airing of issues in a non-threatening environment. Opportunities  :

are available to express design concerns and present any problems that might relate to compliance with the Quality program.

The problems w'th the chlorine monitors started in April of 1985 and have resulted in numerous Licensee Event Reports (LERs). It became obvious early that there may be inherent design flaws in these instruments. VCNOC is in the process of qualifying different type of monitor and will be installing them during the next refueling outage.

The end result here is the acknowledgment by WCNOC management that the resolution of these problems was not timely. WCNOC has learned its lessons and problems like the ESW pipe issue and the chlorine monitors will ne pursued aggressively. Primarily, this improvement will be a result of teamwork, with all departments involved in plant activities.

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The emphasis is now on teamwork to ensure effective cooperation and coordination. The ability to get to the bottom line and permanently resolve problems through a comprehensive corporate approach to root cause analysis is being required. The goal at Wolf Creek is aggressive management involvement to ensure that issues are resolved correctly and in a timely manner and to ensure that all necessary resources are brought to bear in the operation of Wolf Creek Generating Station.

J. Licensing Recommended Licensee Actions The licensee should improve the quality of the safety evaluation summaries submitted pursuant to 10 CFR 50.59 and should improve the content of '

licensing submittals to preclude the need for staff requests for additional information that could have been forseen by the licensee.

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Resconse to Recommended Licensee Actions j I i The SALP evaluation of the Licensing area has been reviewed and while t WCNOC has a slightly different perspective than the NRC on three of the items discussed in the report, actions are being taken to implement the

' Recommended Licensee Actions.'

WCNOC is obtaining examples of what the NRC Project Manager considered acceptable 50.59 annual reports. These will be evaluated and the necessary adjustments made in the next annual report so that the requested level of detail can be provided.

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4 Although these actions are being taken, WCNOC is somewhat disappointed L that this issue was cited in the SALP report. The regulations require a i j summary and do not provide guidance on the level of detail. A number of f i annual reports have been reviewed which revealed a wide variety of depth .

! of information in the reports. For several of these reports that WCNOC l i considers similar to WCNOC's annual report, nothing was found in their f

, SALP reports or the inspection reports of those utilities to indicate that l the level of detail was insufficient. When the NRC Project Manager first  :

questioned WCNOC's annual report. WCNOC requested the NRC's guidance l relative to this item that was applicable to all plants. The Licensing

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< division was informed that the guidance did not exist. WCNOC believes it ,

. is inappropriate to cite this issue in the SALP report since WCNOC was i

I attempting to get generic NRC guidance on the acceptable level of detail

{ and since there appears to be a large variance in what NRC Project 1 Managers find acceptable.

1 i WCNOC will strive to provida the necessary information in all NRC submittals. Internally. WCNOC will be more critical in the review of

draft NRC submittals and assure that the submittals provide the

] information necessary for a thorough regulatory review.

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t a Attachment to WM 88-0207 Page 17 of 19 As for the coments relative to the IST program meeting and subsequent submittal of Rev. 6 of the IST program. WCNOC has a slightly different recollection of the agreements. WCNOC understood the individual reviewer's position relative to his interpretation of the code requirements. WCNOC believed at that time, as WCNOC still believes, that the proposed testing met the require'nants. Therefore. WCNOC exercised its Regulatory rights and submitted the program the way WCNOC thought was best. The NRC exercised its authority and formally rejected the proposal. This was simply a case of exercising the regulatory process.

Since the regulatory process was followed. WCNOC believes it is inappropriate to downgrade the WCNOC project in the SALP report for using the Regulatory process.

K. Traininn Recommended Licensee Action The licensee should further emphasize the need for oversight of operator requalification training and the need for the training staff to be more attentive to details in the performance of their activities. Licensee management should continue their oversight and support of the training of the nonlicensed staff.

Resoonse to Recommended Licensee Actions In training. WCNOC is comitted to a positive program of dealing with the Training needs of the entire organization. Training is continuing, for example to emphasize advanced college programs for personnel through the involvement with Kansas State and Emporia State Universities. The successful program of obtaining college credit for selected training courses in the Training Programs by virtue of the academic accreditation program has given the programs a better acceptance by the individual trainees.

WCNOC does recognize the NRC's concerns for increased management attention to the proper level of detail and is striving to accomplish that.

Additional Response While WCHOC basically agrees with and is implementin5 the NRC's recommendations, some of the items discussed in the evaluations deserve further discussion from WCNOC's perspective.

The SALP report for Training seemed to stem from one NRC inspection report (50-482/87-19). The overall effect is that the Training category rating at Volf Creek was reduced even though there were significant positive accomplishments during the reporting period. These accomplishments include achievement of full corporation membership in the National Academy for Nuclear Training and a recommendation for credit equivalency of 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> of college and votech credit by the American Council on Education.

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'f Attachment to WH 88-0207 Page 18 of 19 .-

To address the NRC comment in the SALP report about en informal method of tracking licensed operator records. WCNOC has a slightly different interpretation of the event. A formal mechanism did exist to track required reactivity manipulations and is included in station records. The Training Coordinator was using prudent judgment by maintaining his own parallel tracking mechanism in a checklist format to ensure required performance. The checklist was for planning purposes and was not intended to replace our formal tracking mechanism. As was mentioned in the NRC inspection report, the instructors efforts were beneficial. The report does not state that the formal mechanism was either missing or insufficient. The correction of the cause of the missed manipulations was management emphasis that the Training Coordinator would have the personal respons!.bility to overview this activity. As verified by your inspector in the inspection report the emphasis agneared to be effective in accomplishing its desired results.

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Attechmsnt.doWM 88-0207 Page 19 of 19 SECTION III ADDITIONAL CCt0 Q QQ, This section list rinor errors in the SALP report which have been identified by WCNOC. There is no discussion of these errors, only a clarification of the facts as reflected in WCNOC's records. The errors are identified by Page. Table or Section number in the SALP report.

EAlf_19.

The last outage listed is not correct. WCNOC had 242.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> in January plus 379.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> in February for a total of 621.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. No mention was made of the exciter / generator out ye that followed.

Pare 19 The Reactor vessel 0-ring outage was followed by a generator / exciter outage which lasted a total of 10 days in January and 16 days in February for a total of 25 days, 21.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. The report states 16 days.

Table 3 & Pane 24 Correction 10 LERs 13 LERs 8 CRVIS 11 CRVIS 6 from C1' monitors 9 from Cl* monitors table 1

1. Quality Progrens 11 Correction 9 7 Total 25 23 Table 2 page 4 The last three violations were actually one violation with three examples.

Violation 50/482-8815.

Trainint page 27 License Exams . The reported statistics of 5/7 Ros and 6/7 /s passing their examinations is in error. Wolf Creek statietics indicate tha. 4/6 Ros and 7/7 SR0s passed their exams. It should be noted that one RO candidate was withdrawn from the examination process by Wolf Creek. Also. Wolf Creek presently has 34

$Ros and 17 Ros verse the 36 SRO: and 15 Ros mentioned in the SALP report.

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