ML20217H349
| ML20217H349 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/31/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217H348 | List: |
| References | |
| NUDOCS 9804030278 | |
| Download: ML20217H349 (5) | |
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UNITED STATES '
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NUCLEAR REGULATORY COMMISSION l
' WASHINGTON, D.C. SeseHOO1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION CHANGE WOLF CREEK OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482
- 1,0 INTRODUCTION By letters dated June 24,1997, November 26,1997, February 17,1998, and March 20,1998, the Wolf Creek Nuclear Operating Corporation (WCNOC) submitted proposed revisions to the Wolf Creek Generating Station (WCGS) Operational Quality Assurance Program (OQAP) description presently contained in Chapter 17.2 of the WCGS Updated Safety Analyses Report
~ (USAR) in accordance with 10 CFR 50.54(a). The staff has reviewed the submittal in accordance with 10 CFR 50.54(a) and determined that the proposed changes to the OQAP affecting the control of nonconformances and trending are acceptable in that the quality -
assurance program continues to meet the requirements of Appendix B to 10 CFR Part 50 and meets the additional requirements of 10 CFR 50.34(b)(6)(ii) by discussing how the applicable requirements of Appendix B will be satisfied.
2.0 EVALUATION l
This safety evaluation contains a brief description of the staffs analysis of the proposed changes for the following activities:
1.
The proposed revision identifes a change to OQAP Section 17.2.4.5(5) that adds the following text for the control of certain nonconformances to procurement document requirements and conditions of their disposition.
" Procedures prescribe measures for the reporting, control, and disposition of purchased items which are identifed by suppliers as nonconforming.
Nonconformances dispositioned as "Use-as is" or " Repair" are reviewed per the design / configuration change process and, therefore, approved by the responsible design authority."
The staff considers this additional text acceptable because it further describes the processing of nonconformances identifed by the supplier and requires WCNOC design authority to approve nonconformances dispositioned by the supplier as "Use-as-is" or
" Repair."
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2.
The proposed revision identifies a change to OQAP Section 17.2.4.5(7)(c) that changes the term " Accept-as-is" to "Use-as-is." Further, in its November 26,1997, letter to the NRC, WCNOC proposed to delete the nonconformance disposition of " Redesign" that is presently contained in Section 17.2.4.5(7)(c) and identified that " Redesign" is not an acceptable supplier disposition because any deviation from the design specification and drawings included in the procurement documents supplied to a vendor is controlled in accordance with procurement document requirements and would be required to be submitted for acceptance by the WCNOC design authority. The staff considers this deletion acceptable based on existing procurement controls contained in USAR Section 17.2. -
3.
The proposed revision identifies a change to the fourth paragraph in USAR Section 17.2.15.2 that deletes the following text.
" Safety-related and special scope conditional releases are reviewed and approved by the operating Agent's Performance and improvement and Assessment division prior to impiamentation."
In its November 26,1997, letter to the NRC, WCNOC proposes to add additional text to the fourth paragraph in Section 17.2.15.2 to require that an engineering technical review and approval is required for the conditional release of nonconforming hardware.
Additionally, in its February 17,1998, letter WCNOC addressed QA involvement in the conditional release process by stating that the following provision would be added to the OOAP: " Conditional release evaluations are documented and the conditional release is closed by Supplier / Materia! Quality when the nonconforming condition is resolved."
Further, Section 17.3.15.2 requires " Nonconforming items required for Technical Specification Operability are only released for use through the design / configuration change process and, thus, cannot be conditionally released for operations." WCNOC's June 24,1997, letter also contains a commitment that the Performance improvement and Ass,essment (PIA) group will audit the corrective action process described in 17.2.16 every six months.
The staff finds that the proposed change is acceptable for the release of nonconforming hardware provided the PIA group continues to audit the corrective action process every six months and this audit scope includes an audit of the processing of safety-related and special scope conditional releases.
4.
Tne proposed OQAP revision deletes the discussion on the control of the various documents used to process nonconformances (e.g., the Commodity Discrepancy Report, the Nonconformance Report) presently contained in USAR Section 17.2.15.3
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and uses Sections 17.2.15.2 and 17.2.16.2 text to describe the control of j
nonconformances by using the Performance improvement Request (PIR) process. The staff finds this deletion acceptable because the proposed revised contiois described in Sections 17.2.15.2 and 17.2.16.2, as addressed in this safety evaluation, adequately describe how the requirements of Appendix B to 10 CFR Part 50 will be satisfied for controlling and reporting nonconformances.
- - 5.
I The proposed OQAP revision deletes the following (the last sentence) of existing USAR Section 17.2.15.4.
" Prior'to implementation, dispositions are independently reviewed by Performance Improvement and Assessment for NCRs and Supplier / Material Quality for_CDRs."
in its November 26,1998, letter to the NRC, WCNOC stated that the following.
paragraph would 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. The design requirements were previously established by 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 acceptance prior to the component being retumed to service."
The staff finds the above deletion acceptable provided that the PIA group continues to audit the corrective action program every 6 months and this audit scope includes an audit of the implementation, disposition, and closeout of rumconformances.
6.
The proposed OQAP revision deletes the procurement controls in existing OQAP Section 17.2.15.5. The staff finds this deletion acceptable based on the fact that the deleted sentences are described in the following OQAP sections:
Sentences one, two, three and four of the proposed deleted Section 17.2.15.5 are described in Sect!on 17.2.4.5.
Sentence five of the proposed deleted Section 17.2.15.5 is described in Sections 17.2.7.1(4),17.2.7.2,17.2.7.7, and responsibilities la Section 17.2.4.5(5).
Sentence six of the proposed deleted Section 17.2.15.5 is described in Section 17.2.4.5(5).
. 7, The proposed OQAP revision deletes the provisions contained in existing Section 17.2.15.7 for the Performance improvement and Assessment (PIA) group to analyze
' hardware nonconfonnance documentation for the identification of potential unsatisfactory quality trends. The revision proposes that hardware nonconformances be
- reviewed by Engineering to identify potential unsatisfactory trends and that these trends be documented and evaluated using the PIR process in accordance with the provisions of Section 17.2.6,
- Corrective Action," of the OQAP. It is noted that when such PIRs are generated by Engineering, they are forwarded to the PIA Group for processing as provided for in prepcd OQAP Sections 17.2.16.2 and 17.2.16.4. The PIR process determines and evaluates the causes of unsatisfactory trends when they are classified as a significant PIR. In its November 26,1997, letter WCNOC stated that the trending
' of programmatic, design, and other non-hardware nonconformances would continue to w
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4 be performed by the PIA Group. For the trending 'of vendor performance, WCNOC has committed to Regulatory Guide 1.144, which requires an evaluation of veador
. performance. Further, existing Section 17.2.16.5 (new 17.2.16.4) remains unchanged and requires that "PIRs are processed to Performance improvement and Assessment to identify trends. These trends are reported to appropriate management and the Chairman of the NSRC."
WCNOC is committed to audit the corrective action program every 6 months and this audit scope includes. an audit of the trending activities. The audit of the proposed trending program, along with the OQAP corrective action provisions and the PlR process appear to provide adequate controls for the WCNOC trending program. The staff finds that the above proposed changes are acceptable because they continue to _
meet Section 4.1(4) of ANSI N18.7 which requires that the trend program be established to detect trends that may not be apparent to a day-to-day observer.
8.
WCNOC proposes to eliminate its Corrective Action Request (CAR), a document used to process significant conditions adverse to quality, and to incorporate the CAR process into its Performance improvement Request (PIR) process. To facilitate this change, WCNOC proposes to delete OQAP Section 17.2.16.3 in its entirety and to revise Sections 17.2.16.1 and 17.2.16.2 to address how significant conditions adverse to quality are processed using PIRs. By deleting existing Section 17.2.16.3, WCNOC is deleting the provision for the PIA Group to close out all PIRs that document significant conditions adverse to quality. WCNOC is proposing that the verification of the i
effectiveness of the corrective actions fur all significant conditions adverse to quality be performed by the assigned responsible organization, and the PIA Group will continue to review the identified significant conditions adverse to quality during their bi-annual audit of corrective actions, in its March 20,1998, letter to the NRC, WCNOC proposed to add the following provisions to Section 17.2.16.2:
"PIRs are processed to Licensing and Corrective Action personnel for analysis to identify trends in quality performance. These trends and a summary of significant PIRs are reported to appropriate levels of management and the Chairman of the NSRC."
Further, proposed Section 17.2.16.4 contains similar text.
The staff finds that the changes, as discussed above, are acceptable because they continue to meet the applicable requirements for processing nonconformances and implementing corrective actions contained in Appendix B to 10 CFR Part 50.
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CONCLUSION i
The staff has determined that the proposed OQAP changes to the existing trending
.- program and changes to the nonconformance and corrective action practices represent i
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. acceptable attematives to exist lng QA program provisions as provided for in the.
applicable review criteria contained in Section 17.2 of NUREG4800. Further, the proposed changes, as discussed in this safety evaluation, continue to meet the applicable requirements for processing nonconformances and implementing corrective actions contained in Appendix B to 10 CFR Part 50.
Principal Contributor: L Campbell Date: March 31, 1998 5