ML20247R469
| ML20247R469 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/01/1989 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-89-0160, WM-89-160, NUDOCS 8906070236 | |
| Download: ML20247R469 (4) | |
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W$LF CREEK
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NUCLEAR OPERATING CORPORATION Bart D. Withers pr ni.no Chief Execuuvo offeer June 1,1989 WM 89-0160 U. S. Nuclear' Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555' l
Reference:
Letter dated May 2, 1989 from R. D. Martin, NRC to B. D. Withers, WCNOC
Subject:
Docket No. 50-482: Response to Request'for Additional Information on Violations 482/88200-03 and 04 Gentlemen:
.This letter provides Wolf. Creek Nuclear Operating-Corporation's (WCNOC)-
response to.the request for additional information. documented in the Reference.
The request for additional information was in conjunction with violation 482/88200-03 involving an inadequate procedure' and violation
'482/88200-04 involving a failure to establish procedures.
If you have any questions concerning this matter, please contact me or
-Mr. O. L. Maynard of my staff.
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Very truly yours, l
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Bart D. Withers President and Chief Executive Officer BDW/jad Attachment cc:
B. L. Bartlett (NRC), w/a E. J. Holler (NRC), w/a R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a 89'06070236 890601 PDR ADOCK 05000482
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Q FDC P.O. Box 411 / Burlington, KS 66839 / Phone: (316) 364-8831 An Equal opportunity Employer Mf HC' VET g
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.t Attachment to WM 89-0160 Page 1 of 3.
Violation B (482/88200-03): Inadeauste Procedure Reauest:
We request that you provide additional information regarding the training and qualifications standards which define " skill of the craft." We further request that you provide information on how planners, engineers or others drafting work instructions are knowledgeable of what is encompassed in
" skill of the craft" for the various maintenance disciplines.
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Response
The On the Job Training (0JT) program developed from craft involved Job Task Analysis serves as a standard for acquired skills.
This program requires both satisfactory training attendance and the demonstration of ability to perform to the standard.
This program did not specifically address the heating of couplings for removal and re-installation.
OJT module MH1327408 " Coupling Removal and Installation", has since been developed and is presently being incorporated into the ongoing training program.
Engineers, Planners, and others drafting work instructions are aware of and have access to the information contained within the OJT program to become knowledgeable of what is encompassed.
However, a requirement of the work assignments for individuals to perform work in the field requires a check of the individuals qualification attainment be made at the time of assignment.
0 It is known by the work instruction. preparer that the craft worker's supervisor will review the instruction for necessary details and will match the skill of'the individuals to the task being performed.
While all the previous criteria was generally met, both in generating the work instructions and in assigning personnel to perform this activity, the concern raised is recognized as an improvement to present practices.
Violation C (482/88200-04): Failure to Establish Procedure Reouest:
The violation was written to state that you had f ail ed to obtain three Service Information Letters (SILs) affecting your Emergency Diesel Generator (EDG) and that you had failed to review or evaluate five other SILs affecting your EDGs.
In your response, you state that your only commitment is to review vendor information, not to obtain vendor information.
We reject this argument, for the intent of Generic Letter (GL) 83-28 was to assure that pertinent information related to maintaining safety-related equipment operable was identified and used.
Your position indicated that you may not have grasped the safety significance of GL 83-28.
We request that your provide us with a fuller description of your corrective action with regard to the review and use of vendor information for safety related equipment.
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Attachment to WM 89-0160 Page 2 of 3
Response
WCNOC fully recognizes the safety significance of Generic Letter 83-28 and, as indicated during the telephone discussion, is doing more than what is currently required.
The statements made during the April 14, 1989 discussion which may have resulted in some misunderstandings were relative to the differences between what WCNOC is doing and what WCNOC is required to do.
As stated earlier, WCNOC fully recognizes the need to obtain and evaluate vendor information to the maximum extent practical and we agree with the NRC that pertinent information relating to maintaining safety related equipment operable should be identified and used. WCNOC has initiated actions to obtain information from vendors in order to evaluate any problems or changes relative to the application of their products at Wolf Creek Generating Station (WCGS).
Procedure KGP-1311
" Industry Technical Information Program" establishes the guidelines for the review and analysis of industry technical information (including unsolicited vendor letters identifying potential problems) to ensure that vendor information is translated into corrective actions, if
- required, to improve the safety and reliability of WCGS.
Upon receipt of industry technical information, an initial review is conducted to determine its applicability to WCGS.
As determined by the initial review, if the information requires a more detailed evaluation, it is transmitted to the appropriate organization for further evaluation. This evaluation involves a review of WCGS programs, procedures and design information for the purpose of resolving concerns and identifying corrective actions such as changes to procedures, training and plant or equipment design.
In November 1987 WCNOC determined that it was not receiving emergency diesel generator (EDG) Service Information Letters (SILs) from the vendor.
At that point, which was prior to the NRC inspection, actions were taken to obtain previous SILc that pertained to the WCGS EDGs. At the time, WCGS was relying on the vendor to identify those SILs applicable to WCGS, which resulted in WCGS receiving five SILs that were potentially applicable.
The evaluation of the SILs did not identify any substantial safety concerns.
In letter dated November 30, 1988 from 3. D. Withers, WCNOC to the NRC, WCNOC discussed its plans to develop a program to enhance the technical information program.
Supplier Quality procedure SMQP 7.10
" Supplier l
Problem / Service Information Bulletins", was initiated in December 1988 to l
provide a method for periodically contacting equipment vendors on the WCNOC Supplier Information List to determine if they have issued letters / bulletins which could impact components or systems at WCGS.
Upon receipt of a supplier letter / bulletin, a copy is forwarded to the Industry Technical Information Program (ITIP) Coordinator for inclusion into the ITIP.
As of May 8, 1989, letters have been transmitted to 71 vendors requesting a
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Attachment to WM 89-0160 Page' -3 of.3 technical contact and to identify if any letters / bulletins have been issued which affect WCGS.
Twenty responses have been received with only one (1) bulletin being. transmitted to WCGS as' a result of this effort.
The infonnation provided 'in this bulletin was the subject of a previously received NRC Information Notice and was already being evaluated.
The statements made during the April 14, 1989 discussion relative to requirements which may have contributed to some confusion, were that WCNOC considers the commitments made in its response to Generic Letter 83-28 to be the applicable regulatory positions as defined in NRC Manual Chapter 0514, Section 053.
The NRC Staff review of the Generic Letter 83-28 vendor interface issue is i
g ongoing and WCNOC fully recognizes that changes in the applicable regulatory position may occur through the provisions of 10 CFR 50.109.
However, until the Staff review is complete,. WCNOC considers the commitments made in the
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December 10, 1966 letter to be the applicable regulatory position for WCGS.
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