IR 05000482/1988014

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/88-14.New Commitment Date of 891231 for Completion of Phase I of Plant Design Bases Program Acceptable

ML20247G563
Person / Time
Site:	Wolf Creek
Issue date:	03/27/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 8904040266
Download: ML20247G563 (2)

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MoR2785 In Reply Refer To: ,

Docket: STN 50-482/88-14 I

l Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839 Gentlemen:

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Thank you for your letter of February 22, 1989 (reference: WM89-0050),

informing us of a change in status of a comitment made in Section II.1, page 13 'of 19, paragraph 2, of your August 19, 1988, letter. This comitment stated that Phase I in the development of the Wolf Creek Nuclear Operating Corporation (WCNOC) Design Bases Program (DBP) would be completed by i December 31, 1988. Your February 22, 1989, letter informed us that this comitment could not be met until December 31, 198 We accept your new comitment date and request that, in the future, you inform i us of such significant slippages prior to the comitment expiratio Should you have any questions, we will be pleased to discuss them with yo l

Sincerely, Ottginal Signed By:

A. B. BEACH L. J. Callan, Director Division of Reactor Projects cc:

Wolf Creek Nuclear Operating Corpora +'on ATTN: Otto Maynard, Manager of Licensing P.O. Box 411 Burlington, Kansas 66839 Wolf Creek Nuclear Operating Corporation ATTN: Gary Boyer, Plant Manager P.O. Box 411 Burlington, Kansas 66839

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EJHoller;df JLMilhoan Cgnan 3/ /89 3/ /89 a3/27/89

• Previously concurred 8904040266 890327

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Wolf Creek Nuclear Operating -2-Corporation Kansas Corporation Comission ATTN: Robert D. Elliott, Chief Engineer

[ Fourth Floor. Docking State Office Buildin Topeka, Kansas 66612-1571 Kansas Radiation Control ' Program Director bectoDMB(IE01)

bec distrib. by RIV:

RRI R. D. Martin, RA SectionChief(DRP/D) DRP RPB-DRSS R. DeFayette. RIII RIV File SRI, Callaway, RIII MIS System RSTS Operator Project Engineer, DRP/D Lisa Shea, RM/ALF DRS D. V; Pickett, NRR Project Manager (MS: 13-D-18)

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W$LF CREEK' NUCLEAR OPERATING CORPORATION sen o. we.rs Preendent and CW Emme Oke' February 22, 1989 WM 89-0050 3 R@ EDW1HT

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R. D. Martin , Regional Administrator i U. S. Nuclear Regulatory Commission ' h, \

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M-lE Region IV J 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Reference: Letter dated August 19, 1988 from B. D. Withers, WCNOC, to R. D. Martin, NRC - Response to Systeratic Assessment of Licencee Performance Inspection Report 50-482/88-14 Subj ect : Docket No. 50-482: Change of Commitment Gentlemen:

The purpose of this letter is to advise you of a change in the status of a commitment made in Section II.I, page 13 of 19, paragraph 2 of the referenced lette The commitment concerns the development of the Wolf Creek Nuclear Operating Corporation (WCNOC) Design Bases Program (DBP).

Under the original design bases approach, the concept was to develop the Wolf Creek DBP in two phase The Phase I scope involved the turnover of the remaining design bases documents f rom the original A/E. The Phase II scope involved the review of project correspondence to extract design bases information and to develop Engineering Design Guides (EDGs) and Design Basis Documents (DBDs). The Phase II effort was expected to be performed over a 68 month time frame and result in providing Wolf Creek personnel with clearly defined design bases requirements and backgroun This work did not progress as quickly as expected because of additional assignment of responsibilities and a reprioritization of project In addition, after Phase I began, it was discovered that the work scope was greater than the original scoping study had indicate The organization implementing the Wolf Creek DBP has since formulated a somewhat different approach with the same goals in min The Wolf Creek DBP is currently being developed in '

three (3) parallel phase While the Phase I scope of work remains relatively unchanged, the Phase II scope now addresses the review of project correspondence and A/E calculations for loading into a computer data bas Phase III addresses the development of the EDGs and DBD C\r >

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.WM 89-0050 Page 2 of 2 February 22, 1989 Under the revised concept, each itese is worked in parallel as design documents become availabl This approach allows the program to be developed in a more natural sequence, as well as gradually putting the program into place so that it can be used while it is being complete As stated in the reference letter, Phase I of the original approach was scheduled to be completed by December 31, 1988. With the development of the new three phase program, the projected date for completion of Phase I is now December 31, 198 If you have any questions about this matter, please contact me or Mr. O. L. Maynard of my staf Very truly yours,

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Bart D. Withers President and Chief Executive Officer BDW/j ad cc: B. L. Bartlett (NRC)

E. J. Holler (NRC)

D. V. Pickett (NRC)

Document Control Desk (NRC)

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W4LF CREEK ?m

NUCLEAR OPERATING CORPORATION

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n- , cri.e ti. cum, omw " W-' ' Augst 19, 1988

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R. D. Martin, Regional Administrator '

l U. S. Nuclear Regulatory Conunission i

Region IV >

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Arlington, Texas 76011 .: ,

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Reference: Letter dated June 23, 1988 from R. D. Martin, NRC to  ;

B. D. Withers, WCNOC Subject: Docket No. 50-482: Response to f'ystematic Assecament E of Licensee Performance InspectO . Report 50-482/88-14

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Gentlemen:

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Atteched is Wolf Creek Nuclear Optratin( Corporation's (WCNOC) response to the Systematic Assessment of Licensee ."erformance (SALP) Report transmitted in the ,

Referenc This response reflects discussions held during the SALP conference 4 l

between WCNOC and the NRC Staff on July 20, 1988, at Wolf Creek Generating '

Station Education Cente ;. .

If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staf Very truly yours, u

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p Y_ D l Bart D. Withers >

Presidut and Chief Executive Offiter Attachment ,

ec: B. L. Bartlett (NkC), w/a a D. D. Chamberlai,n (NRC), w/a L P. W. O'Connor (NRC), w/a (2)

Document Cont rol Desk (NRC), w/a Kansas Corporation Commission, h i ATTN: Robeer t D. Elliott, Chief Engineer

L PO fus dit Hurhrstew KS f4639 Ptone (316) 364 8a31 An f quai Gr, wine, i ma>ya M t' HC VI T

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Att4 chm:nt to WM 88 0207 .

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Pare 10 of 19 The Outage Group is strengthened during a major outage also, by adding Containment Outage Coordinators to the group. In this manner, there will be an 0.tage group representative on eacn shift working in containment during a major outage perio WCNOC has also strengthened the cooperation between orga11:ations by structuring a periodic meeting, chaired by the Outage Manager, to develop minor and major outage plans. All affected working groups attend these meetings including Engineering, Procurement, and Operation These changes, plus the : hanges in the plant organization combining Maintenance with the Modifications Group provide a vertical integration of the work function with proper line authority for direction and approval of outage activitie These changes are strong improvements to the total organizatio In the overall improvement area WCNOC has looked closely at five specific items, Management Effectiveness, Communications Problems. Work Planning, Procedure Problems and Quality Problem In each of these, the concerns wvre identified, the corrective action identified and the individual responsible recognize In a similar manner the concerns and the areas for improvement resulting from a review of Refueling Outage II were examined and specitic >

assignments made to ensure the identified areas of concern were not overlooked in any f uture outag Quality Programs and Administrative Controls Affecting Ouality Recommended Licensee Actions Increased corporate management involvement in site activities is recommende In particule.r. additional corporate management involvement is needed to ensure that proper engineering tnd QA involvement is maintained in all activitie [

Response to Recommended Licensee Actions f

f Although the activities in this area are very much interrelated, this I section of the report is divided into three functionni areas which are [

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Engineering Group 1.have.become a major priority at Wolf. Creek.J... Experiences

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support organization . Engineering and 0,4 cations'Departmest% management j have'assessedotheir.currentmeansofcommunication,Qands are, implementing, major . improvements which are discussed below.J c nx :An 'a@. Qcm w q pph:;;.1;Fr %pw:% >' r;. 'g - '

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of engineering dispositions are more visible to all' orgsnisations witbin

Operations, ' engineering personnel .have : teen' instructed to discuss any

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special. requirements of dispecitions..during' the daily management meeting. In addition,r engineering procedures used for the disposition of

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nonconforming : conditions have been revised to requira the-engineers to

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describe the affected design basis cin . addition tc Ltheir.. technical resolution when ' resolving . problems.." :This: . change ,will, improve conununication of design basis information :. to : the plant staff so that design considerations can routinely ~ be factored into plant operating decision ~

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Huch of the consnunication between the Operating staff and Engineering is formalized in written work documents. 'VCNOC understands the need for formal documentation of technical requirements and design change However, VCNDC also recognizes that formal work document processes sometimes tend to inhibit interaction between departments because of the various approvals required before these documents can be transmitted across organizational lines and simply because of the time itherent in preparation of~ formal document The Engineering and Operations departments are coasnitted to a new policy of openness whereby all groups verbally exchange preliminary information and actively participate in the resolution of. problem Of course those technical issues which have safety significance will continue to be documented through the formal methods: but' face Sto face coordination- prior to initiation of the documchts will . expedite ~~ needed information exchang For nonsafet related activities, engineering will document this techt.ical information through memos to operating personnel, with a copy to the Control Roo This will provide an expedited means to convey design information to the Operating staf ,

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WCNOC has assembled an . experienced engineering staff with ~ technical

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expert;se, however,' partially as a result of the NRC's safety Systems Outage Modification Inspection (SSOMI) at Wolf Creek last fall, WCMOC has

. become awaro that the engineering organizations do not consistently evaluate the eff6 cts of modifications on original desig The ner to . - :.

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ensure that the engineering. staff firmly understands the Wolf Creek -

specific design basis is being stresse Two major projects have been .

Y undertaken to address this, a design transition training program and a- .

s , design basis turnover projec ,

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A design transition training plan was developed for technical personnel in I de Nuclear Plant Engineering Divisio .This training is taught,by g, experienced engineers from the original design A/E firm and consists of .

twenty-eight (28) courses - each 8 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in length for the civil, electrical, instrument / control, and mechanical engineering discipline In addition to Engineering, members of the plant staff from Maintenance, IEC, and Results Engineering also attend. The planned objectives for each course includo training in the requirements and intent of the original

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Wolf Creek design, an understanding of the analytical c.ethods employed for the original Wolf Creek design, and a familiarization with the design input documents which define the original design. The design-transition training program began in mid-1987 and will be complete by Spring, 198 In addition to this transitior. raining, Engineering has methods in place to systematically evaluate the experience of individus1 engineers to determine developmental needs and to provide proficiency training in specific technical area Proficiency training is normally provided through university continuing education, industry-sponsored pregrams, on-the-job training with more experienced engineering personnel, and through contracted, on-site course wor WCNOC is confident that these training proc, rams will channel efforts to improve the depth of engineering expertise relative to the Wolf Creek specific design basi This increased expertise will strengthen WCNOC's engineers' consideration of the original design basis for safety evaluations and modification It will also promote mare timely technical support of the operating staf r ,

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-WCNOC management ,has . initiated a design basis turnover project.3. This project will result lin the incorporation of the Wolf icreek design ibasis -

into our configuration ' control program and will provide more expedient estrieval of technical linformation by s engineering nand : operations i k

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This project will'iinvolve turnover of remaining design basis documentsP n; from the original A/E.. Phase I of this project began in January, :1980'end ' J 'i is scheduled to be. completed le M ember, 198 This project will result '

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in a clearly defined methodo Q y for engineers ,to assemblea.,pertiment -  : .% -

design . basis requirements _during the, design change -process and will - 6

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is confident that . thisa project will strengthen the Engineering : staff's > L > "

understanding of the original design basis., % e brq; &, t 4, :.U. i M, 6 6 4 C

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recogrize that they need t'o focus more attention on job prioritisation so " i ,

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that significant. safety work is completed in a timely manne Each A department has been directed to implement methods to screen work '"

activities as needs are recognize Safety significant work is assigned a high priority, then scheduled and monitored by upper menagement through  !

completio Operations and Engineering departments routinely seet to assess work load .and coordinate shared work scopes to ensure e apatabilit This will allow management to focus attention on completing significant safety work so that follow-up actions, like those mentioned in the SA1,P report, are identified and monitored through timely t completio Improved coordination of significant jobs between tne Engineering and the Operating staff is also paramoun WCNOC is currently in the process of completing an extensive project which will result in a more structured planning process for major modification At the start of each major ,

modification, a formal scoping session is held to develop a modification plan for all phases of the jo The scoping session includes a field walkdown and results in a clear definition of the problem,- cause of the problem, scope of work, assigned organizational responsibilitice, relative priority and schedul These sessions are attended by 'w rke r * 1evel 2 personnel from the appropriate organizations in Engineering and Operations who have detailed hands-on knowledge of the problem operational considerations. and design requirement Proposed modification plans are reviewed and approved by all levels including senior management in the 6 Engineering. Operations, and Quality department This modification 9 Is P

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