ML20199L974
| ML20199L974 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/26/1997 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-97-0141, WM-97-141, NUDOCS 9712020159 | |
| Download: ML20199L974 (10) | |
Text
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i i
s LF CREEK E
W@) NUCLEAR OPERATING Otto L Maynard Presdent and Chef Execut#ve Officer i
N0vember 26, 1997 i
WM 97-0141 U. S. Iluelear Regulatory Commission i
ATTN:
Document Control Desk l
Mail Station F1-137
]
Washington, D. C.
20555 i
Roference:
1)
Letter WO 97-0002, dated June 24, 1997, from C. C. Warren, WCNOC, to USNRC 2)
Letter dated September 3, 1997, from 4
l J. C. Stonc, USNRC, to O. L Maynard, WCNOC Subjects Docket No 50-492:
Response to Roquest for Additional Information - Changes to Operational Quality Assurance Program, Wolf Creek Generating Station Gentlement l
Reference 1 transmitted a request for approval of changes to the Wolf Creek Generating Station Operating Quality Assurance Program. Reference 2 requested additional information to support review of Reference 1.
This letter transmits the Wolf Creek Nuclear Operating Corporation (WCNOC) response to Reference 2.
The Attachment contains the details of WCNOC's response.
In addition to providing responses to the specific comments, WCNOC ts also providing supporting background information to address both the general comments and an underlying question throughout all of the specific comments.
If you have any questions regarding this response, please contact me at (316) 364-8831, extension 4000, or Mr. W.
B. Norton at extension 4553.
Very truly yours, 1
(
/,'r/Lar Otto L. Maynard '
OLM/jad Attachment cc W.
D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a L a l
J.
F. Ringwald (NRC), w/a
()h a K. M. Thomas (NRC), w/a h'h.
- g. !
9712020159 971126 4
PDR ADOCK 05000482 P
POR PO Dos 411/ Barkrrgton. KS 66839 > Phone-(3t6) 364 BLO1 An Equat Onnetung Eqtyw M f HCTET
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Attechmont to WM 97-0141 Page 1 of 9 Response to Request for Additional Information Concerning Operational Quality Assurance Program Changes Pursuant to 10 CFR 50.54 (a) (3)
Supporting Background Information Operating Quality Program Format The operating Quality Assurance Program (OQAP) for Wolf Creek Generating Station (WCGS) is formatted to reflect the major sections of 10 CFR 50 Appendix B.
This format is intended to allow the reader to understand how Wolf Creek Nuclear Operating Corporation (WCNOC) satisfies the requirements of 10 CFR 50 Appendix B.
The OQAP was reviewed and approved as part of the Final Safety Analysis Report during the licensing process.
Although these have been changes to the OOAP since the Operating License was issued, they have not been signifJeant.
Changes to the OQAP, subsequent to licensing, have been evaluated using 10 CFR 50.54 (a) (3). They have either been implemented as allowed or have receive-prior NRC review and approval.
Therefore, WCNOC believes the OQAP continues to satisfy the requirements of content established in 10 CFR 50 Appendix B.
Application of the Standard Review Plan 10 CFR 50.34 (g) requires licensees docketed after May 17, 1982 to conform to the Standard Review Plan (NUREG 0800).
However, the application for the WCGS Operating License was docketed August 1980.
Therefore, 10 CFR 50.34 (g) was not applied to licensing criteria for WCGS.
And, although The Standard Review Plan was consulted during the licensing phase for both license submittals and for NRC review, WCNOC did not, in general terms, commit to NUREG 0800.
Since receipt of the licensa, WCNOC may consider the SRP when developing a change, however, since there is no general commitment nor regulatory requirement to NUBEG 0000, other acceptable methods of meeting regulation should be considered.
Types of Nonconformance Documents WCNOC utilizes two programs to identify and document nonconformances:
Hardware nonconformances are identified and processed in accordance with procedures as described in Section 17.2.15.
Documents used to identify hardware nonconformances are titled " Commodity Discrepancy Reports" (CDR) and "Nonconformance Report (NCR).
Currently, the CDRs are used to dccument hardware nonconformances identified with items that are under warehouse control.
NCRs are used to document hardware nonconformances identified with items that have been issued from the warehouse to the plant.
Both nonconformance documents implement the elements of the nonconformance controls that are currently described in Section 17.2.15, specifically the first and second paragraph of Section 17.2.15.2.
Non-hardware nonconformance (training issues, design deficiencies, personnel performance problems,)
are identified and processed in accordance with procedures as described in Section 17.2.16.
The current document used to identify non-hardware nonconformances is the " Performance Improvement Request" (PIR).
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Attachment to tfM 97-0161 Page 2 of 9 i
i The.following responses are specific to the Request for Additional Information.
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Comment 1
[
t The proposed additional text (regarding the dispositioning of supplier i
nonconformances) to Item 5 on page 17.2-13 contains the text from the fourth paragraph from Section 17.2.15.3 (Note Section 17.2.15.3 is being deleted in its entirety).
With this deletion and relocated text, it is unclear as to I
what type of reports will now be used to document nonconforming materials, parts or components under warehouse control and to doeur..ent trinor documentation related nonconfntmances at the time of receipt and after receipt inspection.
Further, what Ja the document to be used to document and accept nonconformances identified by the supplier of an item before it is shipped to Wolf Creuk? If the document is the Performance Improvement Requests (PIRs) or some other nonconformance document, the document and jts controls need to be described in the Operational Quality Assurance Program (OQAP).
Additional OQAP text appears to be needed to describe the controls for the various types of nonconformances.
Replacing the proposed deleted Section 17.2.15.3 with the proposed text on page 17.2-13 does not appear to adequately describe the nonconformance
?
controls for items that are identified by the suppliers as nonconforming.
Further, where has the other deleted text from existing Section 17.2.15.3 been captured in the OQAP text?
For example, is the Commodity Discrepancy Report
'CDR) used or has it been replaced by the PIR? Are ncnconformance reports and CDRu no longer used and have they been replaced by the PIR? The OOAP needs to describe (on a high level as it does now) ths nonconformance controls for these activities and not just refer to implementing procedures.
}g40C Response to Comment 1, Paragraph 1, Sentences 1 and 2 WCNOC Procedure AP 24H-002, Rev.
4,
" Commodity Discrepancies", describes the use of the Commodity Discrepancy Report (CDR) to document nonconforman.:es identified during receipt inspection or during storage under warehouse control.
Chapter 17.2.15 of the WCNOC USAR describes the controls used for nonconformances at WCGS, both in the warehouse and in the plant. As described in 17.2.15.2, second paragraph, "Nonconformances are controlled by report documentation,
- tagging, marking,
- logging, or physical segregation.
Nonconformances are documented on records which identify the nonconforming condition, record the disposition, and register the signature of an appropriate approval."
By deleting the section 17.2.15.3, WCNOC is only deleting the titles of the nonconformance reports.
WCNOC Response to Comment 1, Paragraph 1, Sentences 3 and 4 The change to 17. 2. 4. 5 ( 5), submitted with the initial submittal, indicates that nonconformances dispositioned as "use-as-is" or " repair" are reviewed and approved per the design / configuration change process and therefore, approved by the responsible design authority.
The specific vehicle used by WCNOC to assure that thase supplier nonconformances are sent to design engineering for review and acceptance has never been specifically described in the USAR other than reference to the procedures used.
The current document used to transmit this information to the design authority is called a supplier deviation request.
The important element of review and acceptance is described and satisfieu in the UGAR submittal.
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Attachment to Wi4 97-0141 Page 3 of 9 WCNOC Responso to Comment 1,
Paragraph 1, Sentence 5 I
WCNOC does not implement various types of hardware nonconformance controls.
The controls described in Section 17.2.15 are applicable to hardware nonconformances identified at Wolf Creek.
However, Wolf Creek does currently use two types of doeurents to implement the controls described in Section 17.2.15.
As previously stated, hardware nonconformances identified for items unde; warehouse control are documented on the CDR and hardware nonconformances identified for items that have been released from the warehouse are documented on the NCR.
WCNOC Response to Comment 1, Paragraph 2 and 3, All Sentences It is not the it. tent to replace the proposed deleted Section 17.2.15. 3 with the proposed text on page 17.2-13.
The proposed text on page 17.2-13 was intended to partially replace the proposed deleted section 17.2.15.5.
Supplier nonconformances dispositioned repair or use-as-is are required to be submitted to WCNOC from the suppliers of goods or services for approval of the disposition.
These provisions are stipulated in the procurement document as required by WCNOC procedures and Section 17.2.4.5.5 (Page 17.2-13).
The NCR and CDR controls are described in section 17.2.15.2.
Comment 2 Section 7c on page 17.2-13 identifies a disposition of " redesign." Neither the third par graph of proposed Section 17.2.15.2 nor any other paragraph in this section andresses the " redesign" disposition.
Is this an oversight?
- Also, the disposition of " redesign" is not addressed in existing Section 17.2.12.4 (proposed Section 17.2.12.3), hgain, is this an oversight?
WCNOC Response to Comment 2, Paragraph 1, All Sentences The disposition " redesign" in Section 7c on page 17.2-13 is an oversight.
" Redesign" is not a
recognized disposition category for a
hardware nonconic"mance.
It is a historicc term.
The original intent of the redesign requirement was to assure the supplier would understand the need to notify WCNOC of any design changes made to a component that did not meet the requirements of the design specification. Houwer, purchase documents require the supplier to satisfy the technicil requiremene of a procutement document for the goods that they are supplying.
A part of the technical requirements are the design specifications listed in the procurement oocument as well is any drawings.
If the supplier has redesigned an item then they would 1ot neccesarily satisfy the technical requirements of the purchase document and e
would be required to submit the revised item for acceptance by the design authority.
Therefore, the redesign process is captured this way, This is further supported by section 17.2.4 of the USAR.
The reference to this term will be removed from Section 17.2.15.4.5.7.c (page 17.2-13). This chenge will
-e implemented in - conjunction witn the changes requested in the original submittal.
Comment 3 The proposed fourth paragraph of Section 17.2.15.2 deletes the OQAP description for the review and approval process for conditions 1 relecses prior to implementation by the Performance Irnprovement and Assessment division.
Has this review and approval process changed? The basis for this deletion is not clear.
Please discuss the controls for review and approval of conditional releases and describe these controls in the OQAP.
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Attachment to WM 97-0141 Page 4 of 9 WCNOC kesponse to Comment 3, Paragraph 1, All Sentences The conoitional release of a hardware nonconforming item is initiated by the individual nr group that intends to install the item prior to resolving the nonconforming condition.
As indicated in the fourth paragraph of 17.2.15.2 a technical evaluation (review and approval of the requested conditional release) is performed to ensure that the installation and/or testing will not adversely affect nor preclude identification and correction of the hardware nonconformance.
During the early years of cperation, QA (now Performance Improvement and Assessment (PIA)) was the organization responsible for this review and approval.
- However, procedures were changed to require an additional review and approval f rom the engineering organization.
Currently both PIA and Engineering perform review and approvals of conditional releases.
WCNOC proposes removing PIA from this review and approval process for the same reasons that WCN00 plans to remove the PIA organization from the nonconformance disposition review and approval.
Engineering is the more appropriate organization to perform the review.
Requiring both organizations to perform the review and approval is considered redundant.
WCNOC will clarify in the USAR change that an engineering technical review and approval is requi red for the conditional release of a hardware nonconforming item.
This change will be implemented in conjunction with the changes requested in the original submittal.
Comment 4 The last sentence, Prior to implementation, dispositions are independently reviewed by Performance
_ Improvement and_
Assessment for NCRs and Sypplier/ Material for CDRS.
The existing Section 17.2.15.4 on page 17.2-41 is being deleted.
What group is now responsible for performing these activities?
Where is this now described in the OQAP? The justification provided for this deletion includes a lot of discussion, however none of the discussion is described in the OCAP.
Also, the justification provided does not discuss the controls associated with non-hardware related nonconformances (e.g.,
a design package was prepared and the independent design verification was not performed or an operator was performing activities for which he had not received training).
WCNOC Response to Comment 4, Paragraph 1, Sentences 1-5 The responsible design authority is required to approve "Use-As-Is" and
" Repair" type dispositions.
Section 17.2.3.6, third paragraph, states in part:
" Design verification is performed by qualified veri fiers who are not
.directly responsiblo for the design or the design change...."
For this reason, WCNOC proposes to eliminate the redundant PIA review and approval of "Use-As-Is" and " Repair" type dispositions.
With respect to the " Rework" type disposition, WCNOC agrees that the detail in the justification for the initial submittal should be included in the USAR.
The following paragraph will be added as the last paragraph of Section
.17.2.15.4 (proposed):
" 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.
Items which are required to be reworked are inspected, as required, for icceptance prior to the component being returned to cervice." This change will be implemented in conjunction with the changes requested in the original submittal.
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Attechment to MM 97-0141 Pags 5 of 9 WCtJOC, Respo.nse to Comment 4, Paragr_aph 1, Sentence 6 fion-hardware nonconformances are documented on PIPS as described in Section 17.2.16.2.
Comment 5 Existing Section 17.2.15.5. " Procurement Controls," is being deleted.
This section describes among other things the control of nonconformances identified by outside organizations, and requires that Supplier / Material Quality staff is responsible for auditing and pcocessing of these supplier recommended nonconformance dispositions.
Where is this now described in the OQAP and who now performs this activity? Note:
in the justification provided by WCtJOC, it is stated that Section 17.2.15.5 (Procurement Controls) has been revised to eliminate redundant wording and clarify the process, and moved to Sectien 17.2.4.5.5."
Section 17. 2.15. 5 has been d<tleted in its entirety.
Proposed Section 17.2.4.5.5 does not appe to have incorporated any of the discussion from Section 17.2.15.5, but nev refers to procedures that are not discussed or described in the OQAP, Please provide the sections of the proposed revision to the OQAP that describe and clarify the process that was described in existing Section 17.2.15.5.
WCtJOC Pesponse to Comment 5, Paragraph i All Sentences t
Deleted Section 17.2.15.5 is described in the following sections of the USAR:
Sentenc-one of proposed deleted section 17.2.15.5 is described in Section 17.2.4.5 (5).
Sentence two of proposed deleted section 17.2.15.5 is described in Section 17.2.4.5 (5) and 17.2.4.5 (7).
Sentence three of proposed deleted section 17.2.15.5 is described in Section 17.2.4.5 (7),
Sentence four of proposed deleted section 17.2.15.5 is described in Section 17.2.4.5 (5).
+ Sentence five of proposed deleted section 17.2.15.5 is described in Section l'.2.7.1 (4),
17.2.7.2, and 17.2.7.7 (notet responsibilities are described on page 17.2-23).
Sentence six of proposed deleted section 17.2.15.5 is described in Section 17.2.4.5 (5).
The addition to Section 17.2.4.5.5 (pago 17.2-13) enhances the level of descrit ed detail relating to the identification of hardware nonconformance controls in the procurement documents.
Attachment to WM 97-0141 Page 6 of 9 l
1 Comment %,
Existing Section 17.2.15.7 (Proposed Section 17.2.15.5) Trend Analyses.
The first paragraph has been deleted.
It is unclear as how the Maantenance Rule trending data will capture and trend the data that is presently being trended by Performance and Improvement and Assessment and the Supplier / Material Quality group. Further, the proposed revision does not appear to have considered the processing and trending of non-hardware related nonconformances.
As discussed in the statements of consideration for the Maintenance Rule, where failures are likely to cause loss of an intended function, monitoring should be predictive in nature, providing early warning of degradation.
Monitoring activities for specific systems, structures, and components (SSCs) can be performance oriented, condition oriented (parameter trending), or both.
The results of monitoring are required to be evaluated against the licensee established goals.
Goals should be established commensurate with a SSCs safety significance.
Further, where failures are likely to cause loss of an intended function, monitoring under Maintenance Rule should be predictive, giving early warning of degradation.
Maintenance Rule trend data is normally associated with identifying maintenance preventable failures.
Does the Maintenance Rule Trend Data at WCNOC include trending areas, items, and issues (other than predictive warnings of degraded SSCs) such as the following?
a.
Design deficiencies b.
Procurement deficiencies c.
Vendor performance d.
Receiving inspection results (documentation and hardware) e.
Personnel training deficiencies (operations, engineering) f.
OA Program implementation trends Please identify areas that are presently within the scope of WCNOC trend prograr that would not continue to be trended when using the WCNOC Maintenance Rule trending data and provide discussion and justification for the elimination of any area that will no longer be trended.
Also, it is unclear how the Maintenance Rule data will be incorporated into the trending system that is presently being used.
Please provide discussion on why the - trending addressed in the proposed revision to Section 17.2.15.5 has a statement that implies that the Maintenance Rule trend data is limited and "provides for trending safety significant SSCs,"
The staff's initial thoughts are that Maintenance Rule trending is a subset of the plant's traditional trending program and as such the Maintenance Rule trend data would only provide a limited scope of trend data for the activities and areas presently being trended at WCNOC.
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Attachment to WM 97-0141 1
Page 7 of 9 j
The use of.the Maintenance Rule trend data in lieu of traditional trend data, as described -in the proposed revision to existing Section 17.2.lf,.7, appears l
to be a significant reduction in cormait. ment.. Additional. diFcussion is nceded in order to understand this proposed chJ.nge.
r WCNOC Response to Comment 6, Paragraph 1, All Sentence _s,-
WCNOC currently utilizes two programs for trending.
(
The first program is described in proposed Section 17.2.15.5 and is
[
specifically related to hardware nonconformance. Tt.e change's discussed in-the su'>mittal are for the hardware nonconformance trending program. The purpose of r
this change is to allow WCNOC to' strategically focus the hardware nonconformance trending on systems, structures, and components identified in p
the Maintenance Rule.
- The second progrt.ti is -dos::ribed in re-numberod Section 17.2.16.4 and - is specifically related to non-hardware nonconformances.
No changes are planned or discussed in the submittal relative to the non-hardware nonconformance trending program (Re-r.amberad Section 17.2.16.4).
l WCNOC Response to Comment 6, Paragraphr, 2 and 3, All Sentences i
Non-hardware nonconforrr.ances are trended as described in re-numbered 17.2.16.4.
t WCNOC Response to Comment 6, Paragraph 4, All Sentences Hardware nonconformances identified for items (i.e.,
systems, structures, f
components) that 4.re not in the Maint6 nance Rule scope would not be trended.
See discussion below for justification associated to hardware nonconformance I
trending.
WCNOC Response to Commsnt 6, Paragraph 5, All Sentences As per 10 CFR Sec. - 50. 65, the WCNO(. Maintenance Rule scope includes safety related and non-safety related structures, systems, and components as follows:
{
I
- 1. Safety related structures, systems, or components that are relied upon to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, and the capability to prevent or Initigate the consequences of accidents trat could result -in potential off-site exposure comparable to the 10 CFR part 100 guidelines.
- 2. Non-safety related structures, systems, or components:
a) That are. relied upon_to mitigate accidents or transients or are used in plant emergency operating procedures (EOPs); or b).Whose failure could prevent safety-related. structures, systems, and components from fulfilling their safety-related functions or y
c) Whoso f ailure could cause a reactor. scram or actuation of a safety-related system.
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I Attachment to WM 97-0141 Page 8 of 9 WCN,00. Response to Comment 6, Paragraphs 6 and 7, All Sentences As previously statet WCHOC performs Trend Analysis of non-hardware nonconformances as described in the re-numbered 17.2.16.4.
The purpose of the proposed change to the Trend Analysis of hardware nonconformances is to allow WCNOC to specifically focus on the systems, structures, and components that are identified in the Maintenance Rule.
This trending program is separate from the non-hardware nonconformance trend analysis program.
p Comment 7 Section 17.2.16.1 Scope (CORRE.CTIVE ACTION).
Describe the processing (review, approval, followup, closeout, _etc.) of a PIR categorized as a significant condit' s adverse to quality.
The proposed deletion of Section 17.2.16.3 has eliminated soveral of the essential elements described in the OQAP concerning the process of escalating or categorizing a PIR to a significant condition adverse to quality, i
Purther, existing OOAP Section 17.2.16.3.
" CARS" is being deleted.
This section describes how the requirements of Appendix B will be satisfied when a significant cond' tion adverse to quality exists and it describes the processing of such conditions.
Again, with its deletion, it is unclear how the PIR process will control this activity.
Perhaps it was an oversight, but the details deleted need to be described in the proposed revision to Section 17.2.16.2.
WCNOC Response to Comment 7, All Sentences t
As dectribed in USAR section 17.2.16.2, PIRs are used to document conditions adverse to quality and correct significant conditions adverse to quality, including non-hardware problems, radiological occurrences, and requests for analysis of plant equipment failures.
The responsible manager ensures that corrective actions-addressing significant conditions adverse to quality include action to preclude recurrence and a scheduled enmpletion date, an independent review of the action plan to ensure that the corrective action will be adequate, and s i independent follow-up to determine if the corrective action w;s ef f ect ive.
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.
Prior to closing a PIR which required corrective action, the responsible manager i
ensures that corrective action was completed and accepted.
Significant conditions adverse to quality are describad and defined in 17.2.16,1, second paragraph.
Significant conditions adverse to quality are defined as issues which impede the implementation or reduce the effectiveness of the OA program.
Additional conditions may.e a gross noncompliance to procedural requirements, a recurring condition where past corrective actions were-ineffective,-significant adverse nonconformance or noncompliance-trends, or significant operating quality program deficiencies.
fhe deletion of 17.2.16.3 shifts the reporting vehicle that would be used by Performance Improvement and Assessment to report significtnt conditions adverse to quality from the CAR to the PIR.
If PIA identifies a significant condition adverse.to quality, a PIR would be initiated.
This significant PIR would then be assigned to the responsible manager for root cause analysis, a detailed corrective action plan and a follow-up review of the actions taken to ensure the corrective actions were effective.
If this PIR was initiated during the audit procese (17.2.18), Performance Improvement and Assessment personnel would also follow-up the issue to ensure that corrective actions were adequate to prevent recurrence.
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l At t achre ent to WM 97-0141 i
i e,',,
1%ge 9 of 9 l
i Comment 8 Existing Section 17.2.16.5 (new 17.2.16.4) has not been revised.
esevet, t*x
)
Proposed revisions to existing Section 17.2.1$.7 (new Secti
,1. ) '. 0 )
t?.i.
6,4 appears to have deleted *.he provisions contained in existing Sec by deleting trending activities by the OA organization and su'2. atdiH ine Maintenance Rule for trending.
It is unclear as to what is t e paren et each of these two sections (as used in the proposed change) at
% t :-
are I
related (if at all).
l l
l WCllOC Re_sponse to Comment 8 j
WCtJOC currer.tly utilf res two programs for trending.
I 2.15.5 and is The first program is descrit,ed in re-numbered Section tiscussed in the specifically related to hardware nonconformances. The char v,
submittal are for the hardware nonconforrrance trending pr n =i. The purpose of this change is to allow WCtJOC to strategically s.
- s the hardwara nonconformance trending on systems, structures, and cor on* nts identified in the Maintenance Rule.
The second program is described in proposed Sen'i' 17.2.16.4 and is changes are planned specifically related to non-hardware nonconiormances.
e l
or discussed in the submittal relative to the nr rdware nonconformance trending program (Re-numbered Section 17.2.16.41