ML20247D827
| ML20247D827 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/29/1998 |
| From: | Muench R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-482-98-08, 50-482-98-8, ET-98-0040, ET-98-40, NUDOCS 9805180116 | |
| Download: ML20247D827 (3) | |
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L LF CREEK W4)NUCLEAROPERATING C Richard A. Muench Vice President Engineering April 29, 1998 ET 98-0040 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station: Pl-137 Washington, D. C.
20555
Subject:
Docket Nc. 50-482:
Unresolved Item 9808-01 from Inspection Report 98-08 Gentlemen:
Wolf Creek Nuclear Operating Corporation (WCNOC) has reviewed NRC Inspection Report 98-008 pertaining to the Safety Assessment / Quality Verification Inspection conducted at our facility from March 2 - 6, 1998.
The inspection report identified an unresolved item (URI 9808-01) regarding implementation of the WCNOC Updated Safety Analysis Report (USAR) Fidelity Review Project Plan.
This letter provides our response to the issues discussed in URI 9808-01.
The inspection. report cover letter, executive summary, and report details section state that there was a failure to initiate Performance Improvement Requests (PIRS) for some discrepancies that were characterized as "significant" by the WCNOC USAR Fidelity review team.
The report stated that this item requires further review to determine whether conditions existed that may violate or be in conflict with the operating license.
WCNOC firmly believes neither the USAR Fidelity E9 view Project Plan nor the. identified items conflict with WCNOC's operating license.
The observation made by the inspectors was due to a lack of timeliness by WCGS engineering personnel with respect to resolving potential USAR discrepancies which required further review. WCNOC is in the process of revising the USAR Fidelity Project Plan to include criteria for resolving potential discrepancies in a ~ timely manner.
The revised plan will establish a 15 day target for a potential identified discrepancy to be resolved or a PIR initiated.
In addition, WCNOC has
-restructured the Fidelity Review team to include a group dedicated to the resolution of identified discrepancies.
These actions will ensure more timely resolution of potential discrepancies.
With respect to the 12 "significant" discrepancies discussed in NRC IR 98-08, l
WCNOC has taken action on each of the discrepancies and issued PIRs, all of which were determined to be non-significant, or determined that the item was minor in nature.
Nine of the 12 discrepancies noted in URI 9808-01 were less l
than one month old.
The USAR Fidelity Review personnel had characterized the items as~ "significant" to reflect that they involved technical questions.
This designation is not-equivalent to a similar "significant" characterization used in the WCNOC corrective action process.
None of these discrepancies resulted in issues which affected venerability of plant systems, structures, or
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components, nor did they affect plant safety.
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9 ET 98-0040
- Pega 2 of 3 The executive summary and section El.1 of the inspection. report details section, state that the USAR Fidelity Review Project ' Plan did not provide guidance, discussion, or training in order to ensure proper implementation of the corrective action program.
The USAR Fidelity Review Project Plan (SEL 97-044) does provide-guidance and reference to WCNOC's corrective action process.
The Plan states, "All corrective actions associated with the WCGS USAR Fidelity Review will be conducted in accordance with procedure AP 28A-001, Performance Improvement Requests."
The Plan. also states that the overall corrective action methodology for the review program consists of an initial screening of identified discrepancies, a detailed review' of identified discrepancies, and resolution of discrepancies through the normal corrective
. action process.
The initial screening is performed to ensure that prompt corrective action is initiated on identified USAR discrepancies which may have an impact on safety or operability or that require immediate attention for any other reason.
The USAR Fidelity Review Plan also provides direction to individuals performing reviews of the USAR to enter the WCGS corrective action program for any identified discrepancy.
Procedure AP 28A-001 implements WCNOC's corrective action program, and provides detailed guidance related to
. initiation of PIRs, the thresholds for initiating PIRs, and all information necessary to generate the document.
Repeating this information in the Plan-was not considered-necessary to assure its implementation.
However, the Plan does provide detailed information concerning the identification of discrepancies, initial screening of these discrepancies, and the review process used to evaluate the discrepancies.
As with procedures governing any other activity performed at WCNOC (e.g.,
design, operations, maintenance, testing), individuals are required to enter into the corrective action program to. address a. concern through a reference to AP 28A-001.
A PIR. can be initiated in accordance with procedure AP 28A-001 by individuals performing USAR reviews at. any time during the review process when a discrepancy is identified.
Individuals performing these reviews have always been aware of this process, and WCGS has re-emphasized this fact with team members.
1 The inspection report notes, on page 13 of the report details.section,'that contractors serving as team members, with the exception of initial general employee
- training, had not received specific training regarding the performance improvement request / corrective action process.
The inspection
- report further notes that the inspectors considered this to be important since the primary mission of the team members was to review and identify discrepancies and initiate the' steps necessary to effect corrective action, j
The USAR Fidelity Review team. members participated in discussion sessions
' during-July / August 1997 discussing the USAR Fidelity Review Methodology for discrepancies and how they will be documented in the corrective action process.
The lesson materials used during the discussions clearly state that if at any time information is identified which is believed to impact the operability of a structure, system, or component or has a high likelihood of impacting an SSC operability the Duty Shift Supervisor shall be promptly j
notified in association with procedure AP 28A-001.
The team members are aware and have always understood that pursuant to WCNOC's Corrective Action program anyone can write a PIR at any time.
In relation to URI 9808-01, it has come to our attention that the Safety System Engineering Inspection (SSEI) team is considering adding another example to the URI and characterizing the URI as a violation.
It is WCNOC's position-that the SSEI item and the URI,are not related.
The SSEI item is that a non-conformance report was not issued for pressurizer code safety valve test failures in 1996.
This item was identified by WCNOC personnel prior to commencement of the SSEI and is historical in nature. The item is not related to the-USAR Fidelity Review, and the procirammatic aspects that existed in the past have been corrected.
Therefore, these items should not be combined.
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AET 98-0040-Page 3 of 3 h.
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-The Engineering section of Inspection Report 98-08,.section El on page 10, is specifically identified as " Problem Identification and Resolution for the I
USAR."
The SSEI item is not related to the USAR Fidelity Review.
A separate section, El.2 on page 16, discusses-whether Engineering department personnel are' appropriately identifying problems and. implementing timely corrective actions.
Section El.2 concluded that th's licensee's program for identifying and resolving problems in engineering was good, and stated that in general engineering department personnel were-properly implementing the program.
WCNOC agrees-with this ~ assessment that Engineering personnel understand and correctly utilize the corrective action process.
In addition, the inspection report noted that-of the PIRs initiated from the USAR Fidelity Review Team, the inspectors were satisfied with the timeliness of the resolution in all but one case.
If you have any questions.concerning this matter, please contact me at (316) 364-8831, extension 4034, or Mr. Michael J. Angus at extension 4077
-i Very truly yours, e
J 'l n eA Richard Muench j
RAM /rir cc:
W. D. Johnson'(NBC)
.E.
W.' Merschoff (NRC)
J. F. Ringwald (NRC)
K. M. Thomas (NRC) l 1
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