ML20211L389
| ML20211L389 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/10/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| GL-83-28, KMLNRC-86-231, NUDOCS 8612160009 | |
| Download: ML20211L389 (7) | |
Text
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i KANSAS GAS AND ELECT:lC C:MPANY T>E ELECTf4C COMPANY December 10, 1986 OLENN L MOESTER vatsPassiosmY mucLaan Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555 KMLNRC 86-231 Re:
Docket No. 50-482 Ref:
- 1) Letter KMLNRC 85-051 dated 2/6/85 from GLKoester, KG&E, to HRDenton, NRC.
- 2) Letter KMLNRC 84-023 dated 2/29/84 from GLKoester, KG&E, to HRDenton, NRC.
- 3) Letter KMLNRC 86-098 dated 5/21/86 from GLKoester, KG&E, to HRDenton, NRC 4)Leti:er KMLNRC 85-150 dated 6/6/85 from GLKoester, KG&E, to HRDenton, NRC Subj: License Condition 2.0.(13): Generic Letter 83-28
Dear Mr. Denton:
Wolf Creek Generating Station Unit 1 License Condition 2.C.(13) requires Kansas Gas and Electric Company (KG&B) to submit responses to and implement the requirements of Generic Letter 83-28 on a schedule consistent with Reference 1 and Reference 2.
In Reference 1, KG&E committed to sabmit a report describing the vendor interface prcgram, including an explanation of how the NUTAC report has been factored into the vendor interface program, prior to December 31, 1986 or prior to startup from the first refueling outage, whichever is later.
Attached is KG&E's report describing the programs in place implementing a vendor interface program and the implementation of the NUTAC report for the Wolf Creek Generating Station.
This submittal, in conjunction with Reference 2, Reference 3 and Reference 4,
satisfies the License Condition 2.C.(13).
KG&E has implemented the commitments made in responses to Generic Letter 83-28.
If you have any questions concerning this submittal, please contact me or Mr. O. L.
Maynard of my staff.
Yours very trul,
h
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Glenn L. Koester Vice President - Nuclear GLK:see Attachment
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oca P0'Connor JCummins 201 N. Ma:ket - Wichita, Kansas - Mail Address: PO. Box 208 I W1chta. Kansas 67201 - Telephone: Area Code (316) 261-6451
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Koester, of lawful age, being first duly sworn upon oath Officer of Kansas says that he is Vice President - Nuclear and an Gas and Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed that same for and on behalf of said Company with full power and authority to do to the and that the facts therein stated are true and correct so; best of his knowledge, information and belief.
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Glenn L. Koester
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Mr. H. R. Denton Decenb:r 10, 1986 Attachment to KMLNRC 86-231 Page 1 WOLP CREEK GENERATING STATION UNIT NO. 1 Vendor Interface Program 1.0 Introduction This report describes the vendor interface program which has aeen implemented at Wolf Creek Generating Station (WCGS).
The primary objective of the program is to ensure that lessons learned from industry technical experience is translated into corrective actians, if
- required, to improve safety and reliability of WCGS and to ensare that applicable vendor information is complete, current, contrilled and appropriately referenced or incorporated in plant instructions and procedures. The vendor interface program at WCGS applies to che review of industry technical information reports originating from external sources, and other vendor equipment technical information.
2.0 Program Description 2.1 Vendor Manuals Vendor manuals at WCGS are considered design documents.
Design changes to vendor manuals are generated as part of the Plant Modification Request (PMR) process.
When a vendor manual change associated with a design change is received at WCGS, the document is forwarded to the Engineering group where it undergoes a technical adequacy review.
If it is determined that the vendor manual change should be incorporated into the manual, the change is accomplished via the PMR process.
During the preliminary stages of PMR development, the PMR is forwarded to Operations, Maintenance, I&C, Training, and Results Engineering.
Each of these groups is responsible for identifying individual documents (i.e.,
Surveillance Procedure, Operating Procedure, Maintenance Procedure, etc.)
requiring changes and whether or not training is required.
Upon approval for implementation, the PMR is transmitted back to the affected groups for implementation of document changes.
The organization responsible for implementing the PMR will also verify the completeness of this process.
2.2 Vendor Documents (Other than Manuals)
The process for handling other vendor information (i.e.,
Westinghouse Technical Bulletins, INPO SOCRS, vendor letters identifying equipment problems) is discussed in Section 3 0.
Mr. H. R. Denton Dee:cb;r 10, 1986 Attachment to KMLNRC 86-231 Page 2 30 Implementation of NUTAC Position The following sections discuss how the Vendor Equipment Technical Information Program (VETIP) as defined in the March, 1984 Nuclear Utility Task Action Committee (NUTAC) response to the Generic Letter 83-28, Item 2.2.2. has been implementated at WCGS.
31 NSSS Vendor Contact The NUTAC position states that each utility should have a program in place with its NSSS supplier to obtain technical information.
This program is to consist of a technical bulletin system and necessary direct contact.
Westinghouse, the NSSS supplier for WCGS, has implemented a Technical Bulletin System which is covered under Westinghouse policies and procedures. Distribution of safety-related Technical Bulletins are accompanied by a return receipt.
The return receipts are pre-addressed to a central point in Westinghouse for recording all Technical Bulletins transmitted and their status.
Technical Bulletins for which receipt is not acknowledged within a reasonable time are retransmitted.
A list of current Technical Bulletins is transmitted to all Westinghouse customers periodically but not less frequently than once per year.
KG&E's program for processing Westinghouse Technical Bulletins is discussed in Section 3.4.
32 NPRDS/SEE-IN The NUTAC position states that each utility should reaffirm its active participation in the NPRDS/SEE-IN programs.
The utility is to supply the basic information and should report failure / problems on a timely basis.
Adequate internal controls should be in place to ensure that this activity is timely, consistent and controlled and should include incorporation of future revisions to these programs.
SEE-IN is managed by INPO for the purpose of screening nuclear plant events and disseminating information on those events considered to be significant to safety and reliability.
Section 34 discusses the established mechanism for handling the outputs from the SEE-IN program.
Mr. H. R. Denton December 10, 1986 Attachment to KMLNRC 86-231 Page 3 Administrative procedures identify the scope and responsibilities of NPRDS at WCGS. NPRDS failure reports are normally submitted to INPO within one month from the end of the month in which the failure occurred.
33 Contact with Safety-Related Equipment Vendors The NUTAC position states that each utility should seek assistance and equipment technical information (ETI) from other safety-related equipment vendors when the utility's evaluation of equipment or ETI problem concludes that such direct interaction is beneficial or necessary.
WCGS supports an active approach for obtaining vendor assistance and information when equipment problems indicate that vendor information is necessary.
Administrative procedures define the responsibilities when interfacing with outside organizations performing maintenance on station structures, systems and components.
34 Internal Handling of Equipment Technical Information The NUTAC position states that the utility should have administrative procedures that provide control of incoming equipment technical information (ETI) whether it arrives directly from the vendor or from other industry or regulatory sources so that it receives the appropriate engineering / technical review, evaluation and distribution for the following:
1) prompt warnings to key personnel 2) timely incorporation into maintenance or operating procedures, equipment data / purchasing records, and training programs 3) future procedure reviews and revision cycles 4) notification on INPO Nuclear Network of significant ETI The NUTAC position also states that the administrative system shoald require that maintenance or operating procedures cite appropriate ETI in the reference section of the procedure; and within the performar.ce section, the appropriate ETI should be incorporated and approved in the engineering, technical, and quality review of safety-related procedures.
Mr. H. R. Denten Decsrber 10, 1986 Attachment to KMLNRC 86-231 Page 4 WCGS administrative procedures have been implemented to establish the guidelines for the review and analysis of industry. technical information.
The program, called the Industry Technical Information Program (ITIP),
applies to the review of industry technical information from the NRC, INPO, NSSS vendor and other vendors or industry sources as appropriate.
Specific documents under this program include, but are not limited to, NRC Information
- Notices, INPO Significant Operating Experience Reports, INPO Significant Event Reports, INPO Operations and Maintenance Reminders, Westinghouse Technical Bulletins and other unsolicited vendor information.
The objective of the program is to ensure that lessons learned from industry technical experiences are translated into corrective actions, if required, to improve the safety and reliability of WCGS.
Upon receipt of an industry technical information report, an initial review is conducted to determine its applicability to WCGS. As determined by the initial review, if the report requires a more detailed evaluation, it is transmitted to the appropriate organization for further evaluation. The evaluation addresses the followings applicability to WCGS, potential consequences to WCG3, any similiar problems that have occurred at WCGS, and primary lessons learned by WCGS.
The evaluation identifies corrective-actions that are required to be implemented.
Corrective actions could include the following:
changes to operating, maintenance, surveillance and emergency response procedures; changes to the emergency plan and its implementing procedures; changes to training, radiation protection, inspection and adminictration control programs and procedures; changes to plant or equipment design; and changes to controlled vendor manuals.
The evaluation and any required corrective actions are documented.
This documentstion is reviewed and concurred with by the responsible branch / division manager / superintendent.
This is verified by a program coordinator.
35 Internal Handling of Vendor Services The NUTAC position states that the vendor, contractor, or technical representative who will perform safety-related services should be a QA approved / qualified supplier of such services.
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2 Mr. H. R. Denton Dec;;ber 10, 1986 Attachment to KMLNRC 86-231 Page 5 Additionally, the services should be specified in the procurement documentation so that a combination of procedural and QA/QC controls are established. The position then addresses controls on ptcoedures used by contractors to perform safety-related services, addressing the need for assurance that such procedures, provided by the utility or the contractor, have received proper review and approval.
The position also addresses the QA/QC program to be used for vendor-supplied safety-related services, stressing the assurance that if the vendor's QA program is utilized, that it has been reviewed and approved in accordance with the utility's QA program.
WCGS administrative procedures which control vendor services contain the following provisions:
Outside organizations shall either work under the WCGS Quality Assurance Program or if the services are performed under the vendor QA Program the program shall be approved by WCGS.
When a vendor QA Program is implemented, the documentation will include a Vendor Work Plan.
The Vendor l
Work Plan specifies vendor and KG&E responsibilities and reflects the contractual and quality assurance requirements of the approved procurement documents.
Vendors supplying services must work under the site work request program and follow the administrative procedurec set forth to control l
that program.
When vendor procedures or instructions are required by the procurement documents, the procedures are reviewed by the Plant Safety Review Committee and approved by the Plant Manager.
The performance of these procedures remains under the control of the site work request program.
Upon completion of vendor services, KG&E is responsible for accepting the service and assuring procurement document requirements and site work program requirements have been met.
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