IR 05000482/1987011

Insp Rept 50-482/87-11 on 870518-22 & 0602-05.No Violations or Deviations Noted.Three Unresolved Items Identified.Major Areas Inspected:Licensees Corrective Action Sys

ML20236U909
Person / Time
Site:	Wolf Creek
Issue date:	11/20/1987
From:	Boardman J, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236U901	List: IR 05000482/1987011 ML20236U899
References
50-482-87-11, NUDOCS 8712030444
Download: ML20236U909 (20)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-482/87-11 License: NPF-42 Docket: 50-482 Licensee: Wolf Creek Nuclear Operating Corporation (WCN00)

P. O. Box 411 Burlington, Kansas 66839 Facility Name: WolfCreekGeneratingStation(WCGS)

Inspection At: Wolf Creek Site, Coffey County, Burlington, Kansas Inspection Conducted: May 18-22 and June 2-5, 1987

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Inspector: - //[2c/6'/

J. R Boardman, Reactor Inspector, Operational Date 1 Pr grams Section, Division of Reactor Safety

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Approved By: %

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Date W. C. Seidle AJhief, Operational Programs Section, Division of Reactor Safety Inspection Summary Inspection Conducted May 18-22 and June 2-5, 1987 (Report 50-482/87-11)

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Areas Inspected: Routine, announced inspection of the licensees corrective action syste Results: Within the area inspected, no violations or deviations were identified. Three unresolved items are identified in paragraphs 2.a.(1)(b),

2.a.(4)(a), and 2.a.(4)(b). ,

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i e712030444 PDR ADOCK h o$ke2 PDR G

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i DETAILS l Persons Contacted

Principal Licensee Personnel l l

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+ D. Withers, President, WCNOC

+F. T. Rhodes, V.P., Nuclear Operations, WCNOC ,

• J. A. Bailey, V.P., Engineering and Technical Support, WCNOC R. M. Grant, V.P., Quality, WCNOC

• +G . ') . Boyer, Plant Manager l

• +W. J. Rudolph, Manager, QA 1

• +J. M. Pippin, Manager, NPE

• +0. L. Maynard, Manager, Licensing {

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+ Belote, Manager, Nuclear Safety Engineering

+J. A. Zell, Manger Nuclear Training

• +A. Freitag, Manager, NPE-WC l

• + G. Williams, Superintendent of Regulatory, Quality, and Administrative Services

+J. Stokes, Procurement and Materials Manager

+ L. Hoyt, Senior Engineering Specialist (0ps)

• + G. Williams, Superintendent of Regulatory, Quality and Administrative Services '

+M. Nichols, Plant f,upport Superintendent

+A. S. Mah, Superintendent, General Training

• W. M. Lindsay, Supervisor, Quality Systems

+K. Peterson, Supervisor, Licensing

+T. S. Morrill, Site Health Physicist

+ J. Moles, Manager, Emergency Planning

+J. C. Goode, Licensing Engineer

• +C. J. Hoch, QA

• S. Wideman, Licensing The NRC inspector also contacted other members of the licensee's staff during the inspection period to discuss areas being reviewe NRC Personnel

• +J. E. Cummins, Senior Resident Inspector

+P. W. O'Connor, Project Manager *

• +B. L. Bartlett, Resident Inspector

• Denotes persons at the exit meeting held on May 22, 198 + Denotes persons at the exit meeting held on June 5, 198 I

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1 Licensee Corrective Action System Licensee personnel stated that no formal management system review had been performed of the Wolf Creek corrective action system to:

Define the necessary elements of their corrective action system based on the licensee's management structure and methodology, Identify licensee corrective action system elemerits presently in place, or Determine the effectiveness of the elements of the corrective action syste The licensee's procedural. identification of corrective action subsystems was.by. organizational units (Licensing, Safety Engineering, Operations, Management Systems, Material Management, Nuclear Services, Nuclear Plant Engineering, and Quality). For clarity, this same concept has been used in this report by using separate report sections where appropriate. A listing of significant applicable procedures reviewed by the NRC inspector is given in Section 2.h of this repor All areas covered by the procedures listed in Section 2.h were considered to be satisfactory except those discussed herein. The corrective action system was defined by the licensee as those procedures referencing notes 1-8 in Section 2.h. Other procedures in Section 2.h were identified by the NRC inspector during the inspectio Overview of the Licensee Corrective Action System Sections 2.b through 2.f cover. the inspector's findings related to the corrective action subsystems for the following licensee organizational units:

Licensing Operations Branch Nuclear Plant Engineering Quality Branch Management Systems The following findings relate to more than one organizational unit:

(1) Evaluation of Conditions Adverse to Quality (Root-Cauf,e Determination)

The licensee indicated procedurally a commitment to the performance of root-cause determinations of identified problem The licensee, however, provided no training in root-cause

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determination, nor did he implement standardized " fault-tree" or other logic concepts for the performance of meaningful root-cause determinatio The NRC inspector reviewed three examples of corrective actions apparently performed without meaningful or effective root-cause determination. These examples illustrate the NRC inspector's concern about weaknesses in the licensee's corrective action system:

(a) Improperly Installed Cable l

The first example involved cables improperly installed in cable trays. Licensee Surveillance "TE 53359 S-1510, ESW Cable Replacement" identified an "as found" construction phase deficiency, in that twelve 600 volt power cables were found installed in an instrumentation cable tray. Licensee documentation states that the nonconforming cables were  ;

installed, inspected, and accepted during plant constructio The corrective action was to inspect 10 cable trays in Essential Service Water (ESW) Train A, and 3 trays in Train B. No logic was provided for sample selectio A significant element in root cause determination in this case related to the inspector, or inspectors, who accepted  ;

the nonconforming cable installation. The identified nonconforming cables may have been all that they inspected in the identified area, though they may have inspected other installations in the plan To look at adjacent cables without knowing who inspected them provides incomplete assurance that the identified problem does not exist elsewhere in the plan In addition, the sampling plan used did not provide a level of acceptability based on a valid statistical sampling pla Such a level would have required sampling plans based on the population of total cable runs in cable trays at Wolf Creek, consisting of lots that were homogeneous with respect to the attribute sampled. Without performing a statistically valid sample of all attributes (such as the inspector's work), a valid root cause determination could not be mad This is an open item (482/8711-01) to be further reviewed by the NRC inspector during a subsequent inspectio (b) ASME Bolting Material Certification The second example involved replacement ASME code bolting ]

(studs and nuts) for safety related Charging Pump Check j Valve BGV17 The certification for the bolting was q incorrect and they were subsequently replace No l

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determination was made as to whether the fastener manufacturer.(Cardinal Industries) or the ASME code certified supplier (Walworth-Aloyco) made the erro No verification was made that other. material supplied by either Walworth-Aloyco, or Cardinal as appropriate, was not-improperly certified, especially in sizes allowed by the ASME code to be certified by certificates of compliance or conformance. Bolting in the sizes so certified is used for pressure boundary joints of the size where failure could cause the most. safety-significant small-break-LOCA (SBLOCA).

Without determining the organization causing the problem, the root cause and adequate corrective action could not be accomplished. This is an unresolved item (482/8711-02)

pending further review by the NRC inspector during a subsequent inspectio (c) Failure of Main Steam Isolation Valve (MSIV) Accumulation for 4-Way Valves The third example involved the failure cf MSIV actuator accumulator 4-way valves, which was reported in LER 85-07 The redesigned 4-way valve assemblies (serial numbers 1012, 1028, 1132, and 1133) failed on December 4-5, 1986. The original root cause determination was not correct, and the corrective action was not effective in that the redesigned valves failed. This concern is discussed further in Section 2.a.(4)(b) of this repor (2) Review of Work Requests (WRs) and Corrective Work Requests (CWRs) for Conditions Adverse to Quality The NRC inspector found that licensee procedures contained no requirement to review WRs, and especially CWRs:

for determination of conditior,s adverse to quality,

for root-cause determinations, and for actions to prevent recurrenc Nuclear Department Directive III.31.0, "Nonconformance Control,"

states in Section 31.5.2.b.3 that " Work requests shall be used to document nonconforming conditions identified after issue from the warehouse." Failure to review WRs and CWRs can preclude identification of significant conditions adverse to quality, and of adverse trends, in such areas as inadequate procedures, planning and work control; inadequate craft qualification and training; and excessive lost or damaged materia Based on Quality Program Deficiency (QPD) 12/86-202, reviewed by the NRC inspector, significant problems could exist with WRs/CWR This QPD is in QA Surveillance Report TE 53359 S-1510, dated January 5,1987, for Plant Modification Request (PMR)

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1828/WR 4245-86, " Essential Service Water (ESW) Cable replacement." QPD 12/86-202 documents that planning and work control were inadequate based on such identified factors as:

Sixteen revisions were required for the W The new cables were incorrectly labele Maximum cable pull tension was not given in the work packag Minimum (cable) bend radius (MBR) was not specified in the work package.

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Acceptable cable pulling equipment was not on site (pulling equipment which would violate the MBR was set up for use).

Cable pulling equipment was attached to safety-related structures without evaluation of the expected loadin No calibrated tension meter was available for cable pullin This will remain an open item (482/8711-03) pending further review by the NRC inspector during a subsequent inspectio (3) Integration of Corrective Action Subsystems The Wolf Creek corrective action program consists of several separate subsystems and separate documents used to identify conditions adverse to quality and to document licensee corrective actions related to such condition The NRC inspector was concerned that all subsystems were not routinely reviewed by the licensee's Quality Branch. Conditions adverse to quality in all systems were not integrated for overall trending of deficiencies. For example, during one trend period, an overall problem of inadequate (incomplete, not incorrect)

Nuclear Plant Engineering (NPE) technical direction could exist as different examples in such varied documents as:

a Defect / Deficiency Report (DDR)

a Nonconformance Report (NCR)

i an internal audit report a surveillance report a licensee inspection report a Quality Program Violation (QPV)  ;

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a Quality Program Deviation (QPD)

an NRC inspection report a Field Change Request (FCR)

documentation of conditions adverse to quality identified by NPE in accordance with Procedure KPN-B-303, " Corrective Action" revised WRs and CWRs Licensee procedures did not require the routine review of these (and other) corrective action documents to determine negative trends or significant programmatic conditions adverse to qualit In addition, as identified in licensee Audit Report TE: 50140-K147, forwarded by QA 87-0181, dated February 5,1987, all organizational units did not have corrective action programs to provide for the identification of conditions adverse to qualit The apparent fragmentation of the licensee corrective action program, and resulting lack of procedural requirements for overall analysis of all deficient program elements for the determination of significant conditions adverse to quality is considered to have a potentially adverse effect on the licensee's corrective action system and will remain an open item (482/8711-04) pending further review by the NRC inspector during a subsequent inspectio (4) Identification of Reportable Safety-Significant Defects and Deficiencies In sampling the licensee corrective action program for potentially reportable defects, the NRC inspector found two potentially generic failures of safety-related material that had been identified as potentially reportable, but af ter 6 months a point in the investigation had not been reached where it could be determined if they were reportabl The cases involved:

failure of a safety-related standby emergency diesel generator rocker arm (ball joint), and repetitive failures of MSIV actuator accumulator 4-way valves (briefly discussed in Section 2.a.(1)(c)).

J (a) Failure of Standby Emergency Diesel Generator Rocker Arm j Ball Joint

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i As reported on licensee DDR Form No.86-101, on November 11, 1986, it was discovered during the performance of i maintenance on Colt Standby Diesel Engine KKJ01B that the

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ball joint had sheared from the rocker arm on No. 4 cylinder and was seated in the push rod. The logic for continued operation was that with No. 4 cylinder inoperable, the diesel engine "would still~be capable of fulfilling its intended function." There was no analysis to support this statemen This is considered an unresolved item (482/8711-05) pending further review by the NRC inspector during a subsequent inspectio (b) Repetitive Failure of MSIV Accumulator 4-way Valves As previously discussed in Section 2.a.(1)(c), MSIV accumulator 4-way valves failed in 1985 and were reported by LER 85-075. Four redesigned replacement valves failed on December 4 and 5, 1986. The licensee apparently used the following logic to justify that these failures were not safety-significant at Wolf Creek:

The valves which failed were those functioning during opening of the MSIVs, which see a higher pressure than the 4-way valves which function to close the MSIVs Valve failure occurs after relatively few cycles Test existing valves at Wolf Creek, including previously replaced valves of the original design, to opening pressure for numerous cycle If they did not fail, they would not fail pending vendor resolution and may be used When asked by the NRC inspector, the licensee stated that there were no empirical data to substantiate that valve failure could not occur at the lower pressures used for MSIV closure after some greater number of cycles. This is considered an unresolved item (482/8711-06) pending further review by the NRC inspector during a subsequent inspectio The NRC inspector observed that while licensee procedures require prompt reporting of defect / deficiencies once they were determined to be reportable, there was no procedural requirement, or tracking, to assure a prompt determination of deportabilit b. Licensing Corrective Action Program The following corrective action activities were prescribed in approved procedures:

Identification, evaluation, and reporting (as appropriate) of potentially reportable defects, noncompliance and events as defined and required by 10 CFR Part 21 and the Wolf Creek Technical Specification

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1 Tracking of licensee commitments f The NRC inspector had the following concerns relating to the licensing procedures and corrective action program:

(1) There was no requirement for documented verification of p accomplishment of all commitment j (2) There was no subsequent audit of commitments to assure that they were effectiv (3) There was no requirement to provide assurance against recurrence in all cases, such as NRC Bulletins where identified components were not used at the time of the Bulletin, but no controls were instituted to prevent their subsequent us (4) There was no requirement for root-cause determinatio ,

(5) There was no requirement for items determined as not reportable to be included in another corrective action subsystem for resolutio These concerns will remain an open item (482/8711-07) pending further review by the NRC inspector during a subsequent inspectio .

c. Operations Branch Corrective Action Program The NRC inspector's findings relating to the licensee Operations Branch corrective action program were as follows:

(1) Licensee Procedure ADM 01-033, " Instructions Describing Deportability, Review, and Documentation of Licensee Event Reports (LERs), and Defect Deficiencies," was reviewed and the following concerns were identified:

(a) There was no requirement for the performance of root-cause determinatio (b) For defects (or deficiencies) that were potentially reportable as required by 10 CFR Part 21, the licensee used a "DDR" For If a defect / deficiency was subsequently determined to be not reportable, the DDR form was closed without initiating an NCR, CWR, or other document to control accomplishment of necessary corrective actions to prevent recurrenc (2) The NRC inspector's concerns about corrective action analysis of Work Requests is contained in Section 2.a.(2) of this repor ..

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10 Nuclear Plant Engineering (NPE) Corrective Action Program The following were the findings of the NRC inspector concerning the NPE corrective action program:

(1) Licensee Procedure KPN-B-303, " Corrective Action," covers the (

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corrective action program for NPE. This procedure details the requirements and responsibilities for affected personnel relative to reporting, tracking, and closure of conditions adverse to ,

quality. The NRC inspector's concerns were:  ;

(a) The procedure specifies only verbal reporting of conditions -

adverse to quality by NPE personnel below the level of section manager. Only if a section manager considers the concern valid is it documented and corrective action {

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(b) Section 6.2.2 (and subsections thereto) state that conditions adverse, or significantly adverse, to quality that may be identified in an organization outside of NPE shall be reported to a section manager. The section manager shall determine if the condition is vali If so, it shall be reported in writing to the manager of NPE. The manager NPE or his designee shall contact the management of the organization involved. If the organization does not occur with the observation, the manager NPE or his designee may notify the Quality Branch. (If the identified condition is a potentially reportable defect, it will be sent to licensing for review and determination.) This section indicated that conditions adverse, or significantly adverse, to quality were not reported to the licensee's quality organization unless the organization outside NPE did not concur with NP Even when there was a lack of agreement, NPE may notify the Quality Branch, but was not required to do so. As a result, significant conditions adverse to quality were not required to be identified to the Quality Branch, or to senior management, for determination of safety-significance, for root-cause determination, or for prevention of recurrenc (2) Licensee Procedure KPN-E-314, " Disposition of Nonconformance <

Reports, Engineering Evaluation Reports, Field Change Requests and Corrective Work Requests," prescribed the methods and NPE responsibilities for processing Nonconformance Reports (NCRs),

Engineering Evaluation Requests (EERs), Field Change Requests (FCRs) and Corrective Work Requests (CWRs), and for providing technical evaluation using Procurement Evaluation Requests (PERs). The NRC inspector's concerns were:

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(a) There was no requirement for root-cause determinatio (b) Based on Section 6.4.5.3.2.1 and discussions with licensee personnel, failure of NPE to provide sufficient technical

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information (as opposed to providing incorrect information)

was not considered to be a deficiency, or a condition adverse to qualit (c) FCRs (requests for change to Plant Modification Requests, or PMRs) were not considered documents to be evaluated for conditions adver.se to quality and corrective actio ;

(d) As a result of (a) through (c) above, there was no apparent corrective action subsystem for evaluation of NPE activities and decisions for conditions adverse to qualit (3) Other NRC inspection concerns were with NPE procedures, such as KPN-D-300, " Engineering Activities," and KPN-D-302, " Engineering Study," which did not address the performance of root-cause-determination of conditions adverse to quality when such conditions were identified by, or to, NP Identified concerns with the NPE corrective action program will remain an open item (482/8711-08) pending further review by the NRC inspector during a subsequent inspectio e. Quality Branch Corrective Action Program The following were the concerns of the NRC inspector which relate to the Quality Branch corrective action program:

(1) Procedural Weaknesses Quality Branch procedures such as QAP 16.1, " Corrective Action for QA Program Breakdowns" (Section 7.2), and QCP 16.1,

" Identification of Program Noncompliance" (Sections 6.5 and 7.1.2), prevent the issuance of the documentation of conditions {

adverse to quality without supervisory approval. QCP 16.1,  !

Section 6.5 prohibits the issuance of a QC Report of Procedure Violation (QRPV) against the QC Division without the approval signature of the superintendent, quality contro As a result, a quality program noncompliance or violation would not be documented if supervision did not agree. This situation prevents the unrestrained identification of noncompliance and violations and is considered a weakness in the licensee's corrective action system. Similar weaknesses are identified in Sections 2.d and 2.f of this repor __ _ _- __ __- . _ -

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12 (2) Use of MIL-STD-1050 for Sampling in Corrective Action i

Licensee Document QA 87-0466, dated April 29, 1987, contained Corrective Action Request (CAR) No. 24. In CAR No. 24 under-finding No. 1, " Recommended Corrective Action 1.b," specified the utilization of MIL-STD-105 with a sampling plan having an acceptable quality level (AQL) of 96 percent. MIL-STD-105 gives AQLs in percent defective. Apparently the intent was to provide an AQL of 4 percent defective. No discussion was given as to the homogeneity of the sample to permit the statistically meaningful use of MIL-STD-105. This standard is structured for use in sampling automated processes under a quality program meeting MIL-Q-985 Where AQLs as high as 4 percent defective (as opposed to 0.1 percent defective) are used, the licensee should o document that higher AQLs can not violate their FSAR, or otherwise adversely affect reactor safet The NRC inspector's concerns with the Quality Branch corrective action program will remain an open item (482/8711-09) pending further review by the NRC inspector during a subsequent inspectio f. Management Systems Corrective Action System The NRC inspector had several concerns regarding the licensee Management Systems organizatio Procedure KP-1010, " Corrective Action Program," Sections 6.1, 6.2, and subsections thereto, required:

(1) Section manager, or manager, approval for an employee to report an identified nonconformance to quality control (6.1.1).

l l (2) Section manager approval before an employee could document i (report in writing) a condition adverse to quality (6.2.1. and 6.2.1.1.2).

(3) No reporting to the Quality Department of conditions adverse to i quality which were fcund by Management Systems employees, but existed in other organizational units, unless it was a

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"potentially reportable defect" (6.2.1.2.3 and 6.2.1.2.4).

Identified concerns with the Management System's corrective action program will remain an open item (482/8711-10) pending further review by the NRC inspector during a subsequent inspectio g. Licensee Audit Findings Relating to the Corrective Action Program During the last two licensee audits of the corrective action system in June 1986 and January 1987 the following were the findings which are considered significant concerns by the NRC inspector:

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Type / Serial Number of Finding Description of Finding QPD 6/86-081 Contrary to ADM 01-025, paragraph 3.4.3, the (Closed - responsible superintendents did not take the Prompt appropriate actions within the allowed timeframe to Corrective resolve NRC' finding Action Taken)

QPD 6/86-082 Contrary to QAP C16.5, paragraph 7.7 and 7.9, Report Information Folders for NRC findings did not contain evidence of completion of corrective actions. (Note 1)

QPD 6/86-084 Contrary to NDPM, paragraph 26.5.2, no tracking (Closed - mechanism was in place to assure corrective action for Prompt findings identified during the corrective action Corrective process for I.0.P.D. 85-11, which was close Action Taken)

QPD 6/86-085 Contrary to FSAR Addendum, Section 17.2.16 and NDPM, (Closed - paragraph 26.5.2, no objective evidence was found to Prompt identify I.0.P.D. 85-06 task force findings and their Corrective corrective action resolution Action Taken)

QPV 1/87-011 Contrary to Nuclear Department Directive III.26, procedures implementing a corrective action program have not been established for each site organizatio (Note 1)

QPD 1/87-012 Contrary to QPM 16 (Rev. 2), " Corrective Actinn,"

quality procedures do not address the actions to be taken when conditions adverse to quality are reported to the Quality Branch by an outside organization.

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(Note 1)

QPD 1/87-013 Contrary to Nuclear Department Directive III.17, procedures governing the processing of NCRs do not address deportability reviews for NCRs dispositioned

" Rework" or " Reject." (Note 1)

QPV 1/87-014 Contrary to Nuclear Department Directive 111.17, methods to ensure that potentially reportable conditions are identified and evaluated have not been proceduralized for each site organization. (Note 1)

In addition to the above, it was identified that reviews for potential 10 CFR 21 deportability for L_-_-____-__________ --- _ _ _ _ _ - _ _ _ __ _ . _ _ _ - _ __ _ _ _ _ . _ _

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conditions identified on NCRs are proceduralized only '

for those NCR3 dispositioned " Repair" or "Use-As-Is."

(Note 1)

QPD 1/87-015 Contrary to Nuclear Department Directive III.31 (Rev. 2), "Nonconformance Control," Management Systems Procedure KP-1010 (Revision 0), " Corrective Action Program," requires that nonconformances be reported to the Quality Branch rather than to quality contro When conditions are determined to be reportable, they are reported to the NRC within the required time limits. It was noted, however, that not all site organizations have proceduralized methods to ensure that organizations responsible for evaluating potentially reportable conditions are promptly notified when such a condition is discovere This condition is partially addressed in finding (QPV 1/87-011) and in violation (QPV 1/87-014).

Note 1: Findings referencing this note are considered by the NRC as significant programmatic weaknesse h. Significant Licensee Procedures Related to Corrective Action Programs Reviewed During the Inspection Approval l (1) Policy Title Revision Date II.1 Nuclear Safety Review 02 02/24/87 Committee (2) Nuclear Department Approval Directions Title Revision Date III.1 KG&E Resolution and 19 07/01/86 Tracking of NRC and Industry Concerns

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III.1 Reporting of Defects and 02 12/06/85 Noncompliance (10 CFR 21)

and other Reportable Events III.2 Nuclear Plant 02 03/05/86 Reliability Data System III.2 Corrective Action Program 03 09/25/86 III.3 Nonconformance Control 02 01/10/85 III.3 Audits 01 09/13/85 l

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I (3) General Operating Department Instruction Letter No. 022, dated-January 10, 1986, Subject: Quality First Program )

(4) KCPL letter to J. M. Evans from F. D. Cranford dated October.11, 1984, Subject: KCPL procedure for reporting of defects and noncompliance regarding Wolf Creek (5) Nuclear Department Procedure Title Revision Date KGP-1311 Industry Technical 0 07/02/86 Information Program KP-C2227 Reportings Defects and 0 11/24/86 Noncompliance and other Reportable Events KP-2145 Control of Nonconforming 0 08/06/86 (Note 2) Material Parts and PCN 1 Components KP-2147 Material Verification 0 07/22/86 (Note 2) Testing KP-C225 Corrective Action 2 09/04/86 (Note 3)

KPN-B-303 Corrective Action 0 11/04/86 (Note 4)

(6) KG&E Approval Procedure Title Revision Date KP-LZ11 Licensee Commitment 01 (Note 1) Tracking System PCN 1 04/25/85 KP-SE203 Surveillance of WCGS 03 07/12/85 (Note 5) Activities by the Safety Engineering Group KP-SE204 Safety Engineering Group 03 07/12/85 (Note 5) Technical Review Program KP-SE205 Reporting of Unsafe, 03 12/16/85 (Note 5) Hazardous or Potentially Damaging Activities by the Safety Engineering Group KPN-0-300 Engineering Activities 01 02/07/86 l

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KPN-D-302 Engineering Study 04 PCN 1 04/16/87

KPN-D-303 Determination of Safety 02

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Classification PCN2 04/16/87 KPN-D-304 Licensing Review and 01 Safety Evaluation PCN1 03/05/86 KPN-D-307 Commitment Tracking 01 PCN1 11/01/84 KPN-D-308 Review of NRC Bulletins, 01 02/07/86 NRC Information Notices and Other Information Documents KPN-D-310 Engineering Document 01 03/04/86 Change Notice KPN-D-311 Q-List 02 i PCN 2 04/16/87 KPN-D-315 Reporting of 10 CFR 21 (lote 4) Deficiencies and Noncompliance 01 03/10/86 KPN-C-300 Plant Modification Process 04 PCN1 01/16/87 KPN-C-307 Revising the Plant 03 03/06/86 Modification Request KPN-C-308 Closecut of Completed 02 09/27/85 Plant Modifications (7) Wolf Creek Operating Corporation Procedures Admi Approval Procedures Title Revision Date ADM 01-025 Corrective Action 08 07/08/86 (Note 6) Response ADM 01-031 Operating Experience 09 05/19/87 Review Program

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17-ADM 01-033 Instructions Describing 15 02/25/86 (Note 6) Deportability, Review, and Documentation o Licensee Event Reports (LERs), and Defect Deficiencies ,

ADM 01-057 Work Request 11 08/22/86-(Note 6)

ADM 07-100 Preparation, Review 30 01/26/87-(Note 6) Approval and~ Distribution of WCGS Procedures ADM 01-086 Material Replacement 00 .05/12/87 Selection ADM 01-120 NPRDS 00 09/04/87 i

ENG 01-500 Operating Assessment  :

Review Tracking System 04 08/11/86 ADM 08-206 Corrective Maintenance 02 11/11/86 (8) Procedure Approval Designation Title Revision Date I ICP-1010 Corrective Action 01 03/13/87 (Note 7) Program KPN-E-314 Disposition of Non- 05 04/21/87 conformance Reports, Engineering Evaluation Requests, Field Change Requests, and Corrective Work Requests

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QPM-15 Nonconformances 04 12/04/86 (Note 8)

QPM-16 Corrective Action 02 12/04/86 (Note 8)

QPM-18 Audits 02 12/04/86 (Note 8)

QP Processing of Work 02 12/04/86 ,

Requests QP 1 Inspection Planning 02 04/30/87 for Work Activities

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QP'1 Quality Branch 00 12/04/86 (Note 8) Followup of NRC Findings .

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QP 1 QA/QC Review for 00 02/06/87 (Note 8) Deportability QAP 15.1 Processing of Non- 00 12/05/87 (Note 8) conformance Reports QAP 15.2 Processing of Con- 00 12/05/86 (Note 8) ditional Releases QAP 16.1 Corrective Action QA 00 12/05/86 QAP 16.2 Stop Work 00 12/05/86 (Note 8)

QAP 16.3 Quality Trend Analysis 00 12/05/86 (Note 8) ,

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QAP 16.5 QA Review of 00 12/05/86 (Note 8) Industrial & NRC Concerns QAP 17.1 QA Processing of 00 12/05/86 (Note 8) Quality Records QAP 17.2 Review of Encoding 00 01/15/87 (Note 8) Data Guides PCN1 QAP 18.1 Audit Surveillance 00 12/05/86 (Note 8) Scheduling QAP 18.2 Audit Procedure 00 12/18/86 (Note 8)

QAP 18.3 Audit System 00 01/18/87 (Note 8) PCN1 QAP 18.6 Quality Unresolved 00 12/05/86 (Note 8) Items

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QAP 18.7 Instant Quality 00 12/05/86 (Note 8) Program Deviations

, QCP 15.1 Nonconformance 05 02/27/87 (Note 8) Reports QCP 15.3 Deficient Document 02 02/27/87 !

(Note 8) Control

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QCP 1 Work Request 02 03/03/87 (Note 8) "

QCP 1 Identification of 02 02/23/87 (Note 8) Program Noncompliance SQP Supplier Performance 00 12/17/86 Feedback System SQP Supplier Evaluation 00 05/22/87 PCN1

SQP Supplier Performance 00 12/17/86 Trending System SQP 1 Evaluation of Supplier 00 12/17/86 l (Note 8) Defects / Deviations j for Deportability j SQP 1 Audit and Conduct 00 12/17/86 (Note 8) of Reporting Notes: These procedures were identified as those corrective action procedures applicable to the licensing organizatio . These procedures'were identified as those corrective action procedures applicable to Materials Management.

i . This procedure was identified as the applicable corrective action !

procedure for Nuclear Service . These procedures were identified as those corrective action procedures applicable to Nuclear Plant Engineerin . These procedures were identified as those corrective action procedures applicable to Safety Engineerin . These procedures were identified as those .orrective action procedures applicable to the Operations Organization.

l These procedures were identified as those corrective action j procedures applicable to the Management Systems Organizatio . These procedures were identified as those corrective action procedures applicable to Quality Organization I I

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- - _ _ - , _ _ _ _ _ _ . - _ _ _ = _ - _ - - _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _- . - . - - _ _ - _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ .

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20 Unresolved Items-Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Three unresolved items disclosed during the inspection are discussed in paragraphs 2.a.(1)(b), 2.a.(4)(a), and 2.a.(4)(b). Exit Meeting The NRC inspector met with licensee personnel to discuss the scope and findings of this inspection on May 22 and June 5, 1987. The resident inspectors were present at the exit interviews.

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