ML20069L107

Advises NRC of Rev to Commitment Made Re Response to Violation 50-482/9031-01

ML20069L107
Person / Time
Site:	Wolf Creek
Issue date:	06/13/1994
From:	Carns N WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
WM-94-0082, WM-94-82, NUDOCS 9406170201
Download: ML20069L107 (2)

Text

.

,e W$LF CREEK

~

NUCLEAR OPERATING CORPORATION Ned S

• Buzz" Carns cn.rman. ere oeni.""

h m 13* 1 m chief En.cutnie onicer WM 94-0082 U. S. Nuclear Regulatory Commissica ATTN: Document Control Desk Mail Station P1-137 Washington, D.

C.

20555

Reference:

Letter NO 90-0287, dated November 16, 1990, from J. A. Bailey, WCNOC, to NRC Subject.

Docket No. 50-482:

Revision to NRC Commitment i

Made in WCNOC's Response to Violation 482/9031-01 Gentlemen:

The purpose of this letter is to advise the NRC of a revision to a commitment made in the Reference.

The Reference provided Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Violation 482/9031-01.

This response addressed a violation of Technical Specification 6.8.1, which requires approved written procedures for activities affecting safety.

Specifically, the violation documented the performance of a test of the main generator voltage regulator without a procedure that had been approved by the Plant Safety Review Committee or the plant manager.

In response to the violation, WCNOC committed to require the use of procedures when performing preventative and corrective maintenance work activities on equipment that is in service.

Procedure ADM 08-201, " Control of Maintenance and Modifications," was revised to state that " Procedures shall be developed and used for both Preventive and Corrective Work Act ivities on systems / components which are in service."

This commitment has been changed, in part, to implement the " Minor Maintenance" philosophy.

This change allows the performance of " Minor Maintenance" utilizing a more streamlined process than the normal Work Request process.

" Minor Maintenance" is defined, in part, as corrective work actions for deficiencies on components or parts, without the use of a written procedure, where the component or part does not perform or affect:

a safety-related function, an environmental qualification function, a seismic function, or quality assurance programs for the ASME NPT or National Board NR and R Certificates of Authorization.

Therefore, the use of the " Minor Maintenance" philosophy could allow preventive and corrective work activities on systems / components which are in service without the use of a procedure.

9406170201 940613 PDR ADDCK 05000482 g

PDb.~.,s 1/ Burhngtor. KS 66839 / Phone (316) 364-8831 An E oual opportunity Employer MJ/HC-YET

~--

WM 94-0082 Page 2 of 2 The NRC Violation was issued based on the fact that testing was being conducted on safety-related equipment without a properly reviewed and approved procedure.

Administrative controls are in place which address the fact that " Minor Maintenance" can not be performed on any component or part that performs or affects any safety-related function, or affects the ability of safety-related components to operate as designed.

Also, the Shift Supervisor / Control Room is required to be notified prior to the performance of work if the work activity could change control board indications or cause an unexpected alarm. Therefore, there are adequate administrative controls in place to ensure that " Minor Maintenance" is not performed on components or parts that could affect safety-related components.

If you have any questions concerning this matter, please contact me at (316) 364-8831, extension 4000, or Mr. Richard D. Flannigan at extension 4500.

Very truly yours, Neil S. Carns NSC/jra cc:

L. J. Callan (NRC)

G.

A.

Pick (NRC)

W.

D. Reckley (NRC)

T, Reis (NRC) m

-