ML20205K948
| ML20205K948 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/26/1999 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-482-98-05, 50-482-98-5, WM-99-0021, WM-99-21, NUDOCS 9904140065 | |
| Download: ML20205K948 (11) | |
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WQLF CREEK NUCLEAR OPERATING CORPORATION Otto L Maynard President and Chief Executive Officer March 26, 1999 g
WM 99-0021 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Mail Station P1-137 Washington, D. C.
20555 y
Reference 1: Letter WM 98-0080, dated August 5, 1998, from O.
L.
Maynard, WCNOC, to USNRC Reference 2: Letter WM 99-0012, dated February 11, 1999, from O. L. Maynard, WCNOC, to USNRC
Subject:
Docket No. 50-482: Change to Response to Notice of Violation 50-482/9805-05 Gentlemen:
This letter describes the actions taken to improve the Wolf Creek Nuclear Operating Corporation (WCNCC) Maintenance Rule Program, and the results
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achieved.
It also transmits a change to a commitment date made in the WCNOC August 5, 1998, response to NRC Notice of Violation (NOV) 9805-05.
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Nuclear Regulatory Commission (NRC) Inspection Report 50/482/98-05, issued July 6, 1998, documented four violations (NOV 9805-02, 9805-03, 9805-05, and 9805-06) that were issued as a result of the NRC Staff's " Maintenance Rule" baseline inspection.
WCNOC letter WM 98-0080, issued Augt.st 5,
- 1998, identified sixteen separate correct.ive action commitments associated with the resolution of the four violations.
A subsequent WCNOC letter, WM 99-l 0012, issued February 11, 1999, revised ene of the corrmitments associated
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with corrective action to NOV 9805-06.
The commitments identified in letters WM 98-0080 and WM 99-0012 were to be cortpleted by March 27, 1999.
WCNOC he completed corrective actions for three of the four violations and fifteen cf the sixteen corrective action commitments described in these two lettus.
Attachment I to tbio letter addresses each NOV and the associated ccmmitments made in WM 98-0000 and WM 99-0012, the status of each of the corrective actions described in the coinmitments, and the specific re sulty achieved.
Attachment II provides a list of commitments contained in :hir letter.
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9904140065 990326 PDR ADOCK 05000482 G
PDR PO. Box 411/ Burkngton, KS 66839 / Phone. (316) 364 8831 h Eqaal Oppurtundy Employer M T HCVET
. WM 99-0021 p g2 2 of 2 The completion date for one of the sixteen corrective action commitments is being extended.
WCNOC's original M1 98-0080 response to NOV 9805-05, on page 7, stated in part:
"A review of past SSC failures -will be performed to identify functional failures and any associated MPFFs that were not previously identified.
The review will include the most recent performance monitoring cycle associated with those functions within the scope of the Maintenance Rule.
This action will provide assurance that current performance data accurately indicates the effectiveness of the maintenance being applied to those SSCs."
In the WM 98-0080 letter, WCNOC committed to completing this review of historical documentation by March 27, 1999.
WCNOC is revising this date to June 30, 1999.
This extension is explained in detail in Attachment I.
If you have atri questions r,*garding this response change, please contact me at (316) 364-4000, or Mr. Michael J. Angus at (316) 364-4077.
Very truly yoars, bXP' Iaf Otto L. Maynard OLM/rlr Attachments cc:
W. D. Johnson (NRC), w/a E.
W.
Merschoff (NRC), w/a K. M. Thomas (NRC), w/a Senior Resident Tnspector (NRC), w/a
Attachment I to WM 99-0021
- Page.1 of 8 Corrective Actions for Notices of Violation 9805-02, 9805-03, 9805-05, & 9805-06 INTRODUCTION; This attachment provides the status of corrective actions resulting from NRC Notice of violation 9805-02, 9805-03, S805-05,
& 9805-06.
Each of the violations is listed below, along with the actions taken to correct the identified condition.
50-482/9805-02 --- Failure To Include Within The Scope Of In The Maintenance Rule Program Those Functions Associated With Essential Communications And Turbir.e Building Drain System Radioactive Release Mitigation l
In response to violation NOV 9805-02, WCNOC made three commitments.
As indicated below, all three committed actions have been completed.
l 1.
"A review of non safety-related SSC functions, including radiation monitors, will be made to identify additional functions to be scoped into the Maintenance Rule Program.
This effort wil] include providing justification for those monitors that are determined not be included in the Maintenance Rule Program, sufficiently documenting that justification, and retaining the documentation. The portion of this review associated with radiatien monitors l
will be completed by September 5, 1998.
I WCNOC personnel reviewed the functions provided by the Radiation Monitoring System against the criteria for inclusion in t& e rule.
This system was 1
evaluated under thirteen discreet functions by the f4aintenance Rule Expert Panel (MREP) on August 26, 1998.
Of these thirteen functions, eight were considered i
not safety-related functions and ave been included within the scope of the rule.
One of the eight, function 1-06, the specific example cited in NOV 9805-02, was included in the rule at the time of its original identification.
Other non safety-related systems were also reviewed against the scoping criteria.
This review addreased approximately seven hundred structure, system, and component (SSC) functions.
Of this number, over five hundred reviewed functions were considered not safety-related.
Those functions that met the requirements for inclusion into the rule wer-incorporated into the Maintenance i
Rule Program.
Technical justification for exclusion from the rule was documented for those non safety-related structure, system, and component (SSC) functions not included in the Maintenance Rule scope and that warrented l
consideration by the Maintenance Rule Panel.
l This action is complete.
l 1
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Attachment I to LA 99-0021 Page.2 of 8 2.
"A review of Communication System historical performance to validate the established performance criteria will be completed by September 5,
1998.
Sub equent to this evaluation, the system will either be classified as (a) (2), or necessary goals and corrective actions will be developed to address identified performance issues."
Historical performance of the plant Gaitronics (plant paging), radio, and telephone systems was reviewed against the established performance criteria.
This review revealed no failures; that is, incidents where, during any mode of operation, the Control Room lost the complete ability to communicate to plant personnel.
Additionally, performance against the Condition Monitoring criteria of less than one failure for each communication group (Gaitronics, hand held radios, and telephones) in a thirty six (36) month period was also established.
This criteria was established for the communication " super-system" based upon the expectation that a complete loss of communication will not occur as a result j
of the redundancy of the identified communication groups.
Condition monitoring of the individual communication groups is considered predictive in nature because individual commurication groups may be placed into category (a) (1), when the condition monitoring criteria is exceeded, while still meeting the reliability criteria.
This ensures corrective actions are taken prior to the complete loss of all communication mechanisms.
A review of historical performance indicated random failures of individual communications components, but no instances where an entire group of communications equipment failed.
Based upon this review, the MREP returned the Communications " super-system" that addresses the above mentioned communications equipment groups to paragraph (a) (2) of the rule on August 5, 1998.
T. tis action is complete.
3.
" Scoping guidance relative to the inclusion of non safety-related SSCs will be revised to reflect current regulatory and industry guidance.
Appropriate training will be provided to system, component, and program engineers, as well as the Maintenanct Rule Program Expert Panel."
Admin:..rative
.rocedure AP 23M-001, Revision 2,
- WCGS Maintenance Rule Program," was completed and approved on February 2,
1999.
This revision provides guidance relative to including non safety-related equipment within the Maintenance Rule scope.
AP 23M-001 also provides reference to more detailed guidance provided in Engineering Desktop Instruction (EDI) 23M-010,
" Determination of Structures, Systems, and Components Within the Scope of the Maintenance Rule."
Instruction in the use of the procedure and the EDI was provided duria a comprehensive training effort for responsible engineers and several engineering supervisors.
The training also included an overview of scoping requirements.
Each attendee was required to successfully complete a written examination as part of this class.
In addition, a certification standard was created to document the qualification for each responsible engineer to manage Maintenance Rule responsibilities.
Each responsible engineer has completed this qualification standard.
Training was provided to the MREP members through the use of a contract individual experienced in Maintenance Rule programs.
This individual attended the MREP meetings, and provided oversight and instruction during meetings from July, 1998, to the present.
In addition, certification of each MHEP member to qualification standard ES9280468 " Maintenance Rule Expert Panel Member" is in progress.
WCNOC considers this approach to MREP training to exceed the intentions of the initial commitment.
This action is complete.
Corrective actions associated with NOV 9805-02 are complete.
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Attachment I to WM 99-0021
- Page.3 of 8 50-482/9805-03 --- Failure To Perform A 10 CFR 50.65 (A) (3)
Periodic Evaluation In response to violation NOV 9805-03, WCNOC made one commitment.
As indicated below, the commitnent's actions have been completed.
1.
" Expectations for timeliness of actions necessary for effective compliance l
with Maintenance Rule Program requirements will be incorporated into procedural guidance.
In addition to guidance requiring the timely completion of the periodic evaluation required by Paragraph (a) (3), these guidelines will include timeliness requirements for ongoing Maintenance Rule Program activities."
Administrative Procedure AP 23M-001, Revision 2,
"WCGS Maintenance Rule Program," includes requirements for the required (a) (3) periodic assessment of maintenance effectiveness. AP 23M-001, Section 6.1.10 now states in part:
"The periodic assessment should be performed within 90 days of the end of each refueling outage."
"The periodic assessment shall be completed within 24 months from the previous assessment regardless if the length of the outage is extended and completion of the assessment within 90 days of the outage is beyond this 24 month timeframe."
WCNOC has also included expectations for timeliners in the Engineering Desktop Instructions for
- scoping, determining safety significance, developing performance criteria, establishing goals and corrective actions, and on-going performance monitoring activities.
Corrective actions associated with NOV 9805-03 are complete.
50-482/9805-05 --- Failure To Iden?,ify MPFFs of Functions Associated With Containment Isolation And Main Steam Systems In response to violation NOV 9805-05, WCNOC made four commitments. As indicated below, three of the four committed actions have been completed.
The due date of commitment 3 below is being extended to June 30, 1999.
- 1. Administrative Instruction AI 23M-004,
" Maintenance Rule Performance Monitoring," and Administrative Procedure AP 23M-001, "WCGS Maintenance Rule Program," will be revised to incorporate improvements in the guidance for functional failure and repetitive MPFF determinations."
Administrative Instruction AI 23M-004,
" Maintenance Rule Performance Monitoring,"
has been replaced with comprehensive instractions within Engineering Desktop Instruction (EDI) 23M-050,
" Monitoring R*rformance to Criteria and Goals."
This EDI contains detailed guidance for d2termining if
Attachment I to WM 99-0021
- Page.4 of 8 events represent functional failures, and contains a logic process for the documentation of justifications for those events that are determined not to be Maintenance Preventable Functional Failures (MPFFs).
Each event screened to require a functional failure evaluation is reviewed by the Maintenance Rule Coordinator (MRC) in this process.
Administrative Procedure AP 23M-001, "WCGS Maintenance Rule Program," has been revised to incorporate responsibilities for timely review of equipment failures for functional failures and MPFFs, It also references EDI 23M-050 au the descriptive document for the performance of the review process.
This action is complete.
2.
- Engineers responsible for Maintenance Rule Program SSCs will receive training on the improved guidance for determining functional failures and I
repetitive MPFFs.
This will provide personnel with an adequate level of knowledge of the process to ensure accurate and consistent functional failure determinations are made."
Comprehensive training on the varivus aspects of Maintenance Rule processes has been provided for each responsible engineer and for several engineering supervisors.
The training included an overview of the MPFF review and determination process.
Each attendee was required to successfully complete a written examination as part of this class.
In addition, a certification standard ES9280460 was created to document the q 'lification for each responsible engineer to manage Maintenance Rule retoonsibilities.
Each l
l responsible engineer has completed this qualification stanaard.
l To assist the engineers in determining if events represent functional failures, l
guidance was created for each Maintenance Rule function, as applicable.
This guidance was documented within the database used in completing and documenting this process.
A process has been created to allow the engineers the capability to update and revise this guidance, as necessary.
The specific actiom to the original commitment are complete.
However, the training in this prr cess is open ended and continuing.
The effectiveness of this process is beini closely monitored by the Maintenance Rule Coordinator and support staff experienced in Maintenance Rule programs.
Assistance to the 4
responsible engineers is available and is provided during the implementation of this process.
The effectiveness of these changes will be validated through the normal WCNOC process of Performance Improvement Request (PIR) effectiveness follow-up and Maintenance Rule (a) (3) assessment.
This action is complete.
3.
"A review of past SSC failures will be performed to identify functional failures and any associated MPFFs that were not previously identified.
The review will include the most recent performance monitoring cycle associated with those functions within tle scope of the Maintenance Rule.
This action will provide assurance that current performance data accurately indicates the effectiveness of the maintenance being applied to those SSCs."
During the Maintenance Rule improvement process, each plant system with functions included in the scope of the rule, and systems that were considered neading additional review and documentation of the considerations for exclusion from the rule, were reviewed by the responsible engineers and contract staff experienced in Maintenance Rule programs.
This review resulted in considerable
Attachment I to WM 99-0021
'Paga.5 of 8 improvement in the documentation of Maintenance Rule considerations, and revisions to the performance criteria, bases, and guidance in determinatica of functional _ f ailures.
This information was necessary to ensure the review of historical performance reflected the revised criteria and monitord ;g guidelines resulting from this process.
To ensure the proper classification of the structures, systems, and components 'SSCs) at the time of the Maintenance Rule Expert Panel (MREP) review and approval of these revisions, the responsible engineer was interviewed by the MREP to verify the proper classification of the system SSCs under paragraph (a) (1) or (a) (2) of the rule. When either MREP members or the responsible engineers felt that the SSCs' performance history did not meet the requirements for classification under paragraph (a) (2), the SSCs were classified under paragraph (a) (1) of the rule.
A review of Performance Improvement Requests (PIRs) and corrective maintenance work requests written between January 1, 1997 and March 1,
1999*,
(over 11,500 documents) was undertaken to verify the classifications made during these MREP reviews.
This review was scheduled to begin in the later stages of the overall Maintenance Rule improvement process to ensure the review process included all revisions to the criteria.
Each of the documents was screened to eliminate those items that presented no potential for representing a functional failure of Maintenance Rule SSCs.
The remaining documents were processed through the revised functional failure evaluation process by personnel experienced in determining functional failure applicability.
The review of PIRs and Work Requests is near completion.
The responsible engineers and contract staff are evaluating the results of this review to identify any instances where this review indicates affected SSCs have exceeded reliability performance
- criteria, and the need to further review the effectiveness of maintenance for Maintenance Rule SSCs.
This review will complete the commitment to ensure the performance data accurately indicates the effectiveness of the maintenance being applied to those SSCs.
Because the scope of the review is much larger than initially anticipated, WCNOC is extending the completion date for this commitment to June 30, 1999.
This extension will allow completion of this validation following Refueling Outage 10, currently scheduled for April 3, 1999, to May 8, 1999.
The additional time is needed to ensure an effective review and evaluation is performed on the PIRs and CWRs.
The extension of the review of historical documents allows for continued progress to be made without distracting engineering personnel from the immediate safety-related activities associated with Refuel Outage 10.
Contract staff and responsible engineers will continue efforts to complete this effort during the outage with final (a) (1) or (a) (2) determinations and goal setting being complete by June 30, 1999.
- Potential functional failure events occurring after March 1, 1999, are being processed though the new Maintenance Rule functional failure process.
This process requires generation of a PIR and a functional failure evaluation for each potential event per WCGS Administrative Procedure AP 23M-001 and Engineering Desktop Instruction EDI 23M-050.
This process requires timely resolution of these events.
" Timely" is defined as completion within 30 days of the identification of the condition.
Therefore, events occurring after March 1,
1999, are not considered historical, and are not included in this commitment.
This action will be completed June 30, 1999.
4.
" Administrative Procedure AP 28A-001, " Performance Improvement Request," will be revised to provide guidance for PIR initiation for potential functional failures.
This revision will also ensure the necessary level of evaluations
8 Attachment I to WM 99-0021 Page.6 of 8 and root cause determinations is performed for potential and confirmed functional failures, commensurate with the level of safety significance of the*affected SSC."
The identification and capture of potential functional failures has been enhanced through revisions to AP 28A-001, ' Performance Improvement Requests."
During the initial screening of PIRs, personnel are required to identify whether the identified corrective action issue relates to a potential Maintenance Rule Functional Failure.
If the
'yes' block is marked, additional instructions within the body of the procedure refer to the Maintenance Rule requirements of procedure AP 23M-001, *WCGS Maintenance Rule Program."
In addition to the revisions made to AP 23M-001 and AP 28A-001, Engineering Desktop Instruction EDI 23M-050 requires review of work orders initiated to reveal any potential functional failures where a PIR was not initiated concurrent with the work order.
This action is complete.
Corrective actions associated with NOV 9805-05 are complete.
50-482/9805-06 --- Failure To Establish An Appropriate System Of Train Level Performance Measures To Demonstrate That Preventive Maintenance Effectively Ensured That Functions Associated With Emergency Diesel Generator, Excore Neutron Monitoring, And Process Radiation's Monitoring Systems Would Perforin As Required In response to violation NOV 9805-06, WCNOC made four commitments. As indicated below, all four committed actions have been completed.
1.
" Wolf Creek personnel will review all scoped SSC functions, and those proposed functions yet to be approved, to ensure adequate performance monitoring requirements are in place.
This review will include a comparison of the function's operating classification against the definition of
' standby' in Regulatory Guide 1.160, Revision 2.
The Wolf Creek Maintenance Rule Expert Panel (MREP) will evaluate those SSCs they identify as not having adequate performance criteria and will either immediately place trem (a) (1) until proper performance measures can be established, or will assign a date for the responsible engineer to present acceptable performance criteria to the MREP.
This date will be established based upon the safety significance of the SSCs in question and the resources necessary to complete the process.
This option will only be utilized
- situations where the MREP considers the necesr.ary revisions to the mon 4' ng program to be minor, and the MREP expects the criteria t t.
be met.
in ca wa where the MREP considers the revisions to the criteria and efforts to validate performance significant, or the MREP questions the performance of the subject SSCs, the SSCs will be placed into (a) (1) until performance is validated against the revised i
performance criteria."
Procedural guidance was revised for the determination of standby status of structures, systems, and components (SSCs) wichin the scope of the rule.
The definition of " standby" in Section 4.17.1 of Administrative Procedure AP 23M-
Attachment I to WM 99-0021
' Pace.7 of 8 001, Revision 2,
"WCGS Maintenance Rule Program" was revised to read " Standby SSCs are those whose failures would not become apparent un til the next demand, actua t*f on, or surveillance. "
This definition is consistent with that provided in NRC Regulatory Guide 1.160, Revision 2.
In addition, Engineering Desktop t
Instruction EDI 23M-010 provides more detailed guidance for this determination.
Maintenance Rule personnel have reviewed the scoping, safety significance classifications, and performance criteria for each SSC included within the scope of the Maintenance Rule.
The MREP reviewed each scoped function to ensure the proper standby or normal operating classification was applied.
The MREP reviewed the applicability of plant level monitoring for each function classified as normal operating.
In addition to those SSC f uncti ons considered standby, SSC specific performance monitoring criteria were established for normal operating SSC functions where plant level monitoring did not provide adequate performance monitoring measures.
As the MREP reviewed and approved revised performance criteria, che historical performance of the SSCs was discussed.
When the MREP and the responsible engineers questioned the applicability of (a) (2) classification, the SSC was either placed into (a) (1), or the responsible engineer was assigned an action item to validate the performance and return to the MREP.
If the MREP or the responsible engineer were not confident that the historical performance review would indicate adequate performance, the SSCs were placed into (a) (1).
This action is complete.
2.
"The performance criteria for EDGs will be revised to ref;
. failure rates consistent with the assumptions in the WCNOC probabilistic safety assessment, clearly stating that potential functional
- failures, regardless of classification relative to NUMARC 87-00
- guidance, are considered.
Additionally, unavailability monitoring methodology for the EDGs will be revised to ensure instances of unavailability, consistent with the definitions provided in NUMARC 93-01 and Regulatory Guide 1.160, are captured.
As stated above, the EDGs have been administratively reclassified as (a) (1) pending the review of historical data against these revised criteria."
Emergency Diesel Generator (EDG) function KJ-01,
" Provide emergeacy 4160 VAC power to the respective 4160 VAC bus, within 12 seconds of a demand, for up to seven days, in the event of a loss of off-site power to that bus," was approved by the MREP on January 20, 1999.
Reliability criteria for function KJ-01 is now, 'No more than 2 functional failures in the most recent 25 demands on that engine," and unavailability criteria is now "< =
200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> unavailability p.r train per 18 months monitored on a 'per engine' basis."
The functional failure guidance, alc,19 sith the basis for the performance criteria, will ensure potential functional failures for the EDG are evaluated independent of the NUMARC 87-00 criteria.
The functional failure guidance and performance criteria basis is now detailed in EDG function KJ-01.
This action is complete.
3.
"The practice of discounting surveillance and testing times from other SSCs where availability is monitored is currently under investigation to determine if other SSCs are affected."
Performance criteria were reviewed and modified as necessary for each SSC in the scope of the Maintenance Rule.
This effort included a review of the data sources used for determining unavailability.
As describeu in WCNOC letter WM i
.a o
Attachment I to WM 99-0021
" Page.8 of 6 98-0080, WCNOC used the INPO definition of unavailability for the EDGs.
As part of the review of each SSC function, specific unavailability data sources were i dent i'fied.' The INPO definition of unavailability was not identified in the performance criteria for any other SSCs.
This action is coe.plete.
l 4.
" Wolf Creek Maintenance Rule Program procedures will be revised to clearly state rules for unavailability monitoring consistent with the definitions of Regulatory Guide 1.160."
There is no definitive definition for " unavailability" in Regulatory Guide 1.160.
This was discussed with NRC. personnel at NRC headquarters in White Flint, Maryland.
Based upon the discussion with the NRC, it was decided an acceptable approach would be to incorporate the guidance contained in the NRC Maintenance Rule Internet Home
- Page,
" Maintenance Rule Frequently Asked Questions".
Procedure AP 23M-001, "WCGS Maintenance Rule Program" implements the Maintenance Rule Program at WCNOC.
This procedure also contains the definitions of the terms used in the Maintenance Rule.
Paragraph 4.19 contains the definition for unavailability.
This definition was revised on February 16, 19.19, with the issuance of AP 23M-001, Revision 2, to be consistent with the definition given NRC Maintenance Rule Internet Home Page, " Maintenance Rule Frequently Asked Questions."
This action is complete.
Corrective actions associated with NOV 9805-06 are complete.
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- Attachment II to WM 99-0021
.. ' ~
Page 1 of 1 LIST OF COMMITMENTS The following table identifies those actions committed to by Wolf Creek Nuclear Operating Corporation (WCNOC) in this document.
Any other statements in this submittal are provided for information purposes and are not considered to be commitments.
Please direct questions regarding these commitments to Mr.
Michael J.
Angus, Manager Licensing and Corrective Action, at Wolf Creek Generating Station, (316) 364-4077.
COMMITMENT Due Date/ Event "A review of past SSC failures will be performed Jun' 30, 1999.*
to identify functional failures and any associated MPFFs that were not previously identified.
The review will include the most recent performance monitoring cycle associated i
with those functions within the scope of the Maintenance Rule.
This action will provide assurance that current performance data accurately indicates the effectiveness of the maintenance being applied to these SSCs.'
In the WM 98-0080 letter, WCNOC committed to completing this review of historical documentation by March 27, 1999.
WCNOC is revising this date to June 30, 1999.
l l
- Note: Commitment remains unchanged from the August 5, 1998, letter (WM 98-0080).
Only the date has changed.
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