ML20198J510
| ML20198J510 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/17/1997 |
| From: | Muench R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ET-97-0108, ET-97-108, NUDOCS 9710210087 | |
| Download: ML20198J510 (3) | |
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WFLF CREEK NUCLEAR OPERATING CORPORATION Rchard A. Muench Vice Ptesdent Engmeenng October 17, 1997 ET 97-0108 U.
S. Nuclear kegulatory Commission ATTN:
Document Control Desk Mall Station PI-137 Washington, D. C.
20$55 Reference Letter WM 96-0014, dated February 2, 1996, from N. S.
Subject:
Docket No. 50-402:
Change in Schedule for Completion of System Functional Assessments Gentlemen:
As a result of the Wolf Creek Icing Event (the Reference), Wolf Creek Nuclear Operating Corporation (WCNOC) committed to perform functional assessments on four risk significant systems; the Auxiliary Feedwater (AFW)
- System, the Essential Service Water (ESW) System, the Component Cooling Water (CCW) System, and the Residual Heat Removal (RHR) System.
The scheduled completion dates for the functional assessments of the safety-related eystems were originally selected to be December 31, 1996, for the AFW System, June 30, 1997, for the ESW System, December 31, 1997, for the CCW S ys t. em, and April 30, 1998, for the RHR System.
As stated in the Reference, WCNOC Indicated that we would continuously evaluate the scope of, and schedule for completing, these assessments and make adjustments, if warranted.
Based on the findings of tLe AFW System assessment completed on December 31, 1996, and the ESW System assessment completed on June 30, 1997, WCNOC has revised the schedules for completing the CCW System assessment to Fuel Cycle 11 and the RHR System assessment to Fuel Cycle 12.
The reasons and justification for these schedule changes are provided in the attachment.
If you have any questions concerning this matter, please contact me at (316) 364-8831, extension 4034, cr Mr. Richard D.
Flannigan, at extension 4500.
Very truly yours, 9710210007 971017
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Attachment to ET 97-0108 Page 1 of 2 Justification For Schedulo Ch ngs For Completion of Safety Functional Inspections For The CCW and RHR Systems As a result of the Wolf Creek Icing Event',
Wolf Creek.iuclear Operating Corporation (WCHOC) committed to perform 'unctional assessments on four risk significant systems; the Auxiliary Feedwater ( A FW) System, the Essential Service Water (ESW) System, the Component Cooling Water (cCW) System, and the Residual Heat Removal (RHR) System.
These functional assessments are designed to revied the adequacy of current design assumptions, adequacy of incorporation of lessons learned from industry experience, effectiveness of testing and surveillance programs, review of results to determine need to validate design input assumptions on other safety-related systems, and use of the Auxiliary Peedwater assessment to test new expectations and tools.
These asseesments evaluate both the Design Basis and License Basis of the systems.
These assessment plans were later expanded to include the corrective actions from Wolf Creek LER 96-006 on the steam generator feedwater regulating valve 8
roll pin failure, and LER 96-007' on a failure to perform require' post-modification testing.
The action added from LER 96-006 was to include in the risessments a review of design changes to determine if the design changes were cprectly reflected in the associated vendor manuals and drawir4gs, and if they ettectively addressed spare parts and procurement.
The correctivo action from LER 96-007 was to review a sampla of completed design modifications to ensure neceastry post-modification testing was completed on these changes.
The scheduled corapletion dates for the safety-related systems assesse'nts were originally selected to be December 31, 1996, for the Ard System, June 0,
- 1997, for the ESW System, December 31, 1997, for the CCW System, and April 30, 1998, for the RHR System.
As stated in the original commitment,
WCNOC indicated that we would 3
continuously evaluate the scope of, and schedule for completing, these assessments and make adjustments, if warranted.
Based on the findings of the AFW System assessment completed on Decenber 31, 1996, and the ESW System assessment completed on June 30, 1997, WCNOC has revised the schedules for completing the CCW assessment to Fuel Cycle 11 and the RHR System assessment to Fuel Cycle 12.
The reason behind this change in schedules is as follows:
WCNOC has instituted a comprehensive Design Basis / License Basis Program (DH/LB)'.
The knowledge and improvements that will be realized as a result of this program are important to the safe operstj on of the plant.
Elements of this initiative includes USAR Fidelity Review, Improved Technical Specification Implementation, Margin Management Program, Ganeric Letter 96-01 Review, DB/LB Process Review, System Functional Assessments, Engineering Information System, and the DH/LB Clearinghouse.
Completion of this program will provide information needed to complete the remaining system assessments, resulting in more efficient and more effective assessments.
The ESW System Functional Assessment ended approximately 6 months after the AFW System Functional Assessment and largely confirmed what was found during the first assessment.
_ WCNOC has implemented. corrective actions to cddress significe findings from those assessments.
Elements of our DB/LB program are part of ee corrective actions.
WCNOC is concerned that completing the s assessments on the ptesent schedule will likely only validate the remaining results o.
she first two assessments and would not assess the effectiveness of the DB/LB _ initiatives.
Rcscheduling the completion of the CCW and ESW System Functional Assessments would allow the use of these assessments to gauge the success of the WCHOC initiatives and corrective actions.
WCNOC has committed to implementing the Improved Technical Specifications.
The Improved Technical Specifications will result in changes to the surveillance
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Attcchment to ET 97-0108 Page 2 of i' Ju tification Far 8thedulo Change Far Completien of h fety Functional Inspections For The CCW and RHR Systems l
requirements and may impact values presently contained in the Technical Specifications.
WCNOC intends to use the future system functional eksessments to evaluate the effectiveness of implementation of the Improved Technical Specifications.
Several horizontal slice self-assessments and rovi3ws hnve beer completed or are currently in progress (e.g., Surveillance Procedures, Post-Ma;ntenance Testing, Procurement / Roll Pin, USAR Fidelity Review, Generic letter 36 01 Review) and more are being planned.
As these additional actions are completed, the results of these activities will provide input to the scope of the future assessments to help improve the effectiveness and efficiency of those assessments.
WCNOC is scheduled for an AE Inspection this Fall and an Engineering Inspection next Spring.
Because of the schedule of the two firs *. assessments, WCNOC was not able to take advantage of the NRC's 1996 Engineot ag inspection results in those assessments.
WCNOC intends to factor the inspection results from the AE and Engineering Inspections into the two remaining i'anctional assessments.
In summary, WCNOC's position it that the change in echedule for completion of the remaining two system functional assessments is warranted based on the scheduled completion of related activities needed to provide input to the assessments, the results of the first two assessments, time neaded to implement corrective actions resulting from the first two assessments, and the need to complete horizontal slice ascessments of issuen resulting from the completed functional assessments.
1.
Letter WM 96-0014, dated February 2, 1996, from N. S. Carns, WCNOC, to L. J. Callan, USNRC, " Wolf Creek Ictng Event Shutdown" 2.
Letter WO 96-0101, dated July 3, 1996, O. L. Maynard, WCNOC, to USNRC, " Licensee Event keport 96-006-00" 3.
Letter WO 96-0164, dated December 6, 1996, from L. Maynard, WCNOC, to USNRC, " License Event Report 96-007-01" 4.
Letter WM 96-0081, dated July 31, 1996
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