IR 05000482/1980005

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IE Insp Rept 50-482/80-05 on 800317-20.Noncompliance Noted: Failure to Provide Prompt & Adequate Corrective Action
ML19317H420
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 04/08/1980
From: Crossman W, Martin L, Oberg C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19317H415 List:
References
50-482-80-05, 50-482-80-5, NUDOCS 8006050528
Download: ML19317H420 (6)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Report No. STN 50-482/80-05 Docket No. STN 50-482 Category A2 Licensee: Kansas Gas & Electric Company Post Office Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek, Unit No. 1 Inspection at:

Burlington, Coffey County, Kansas Inspectior conducted:

March 17-20, 1980 Inspecto

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L. E. Martin, Reactor Inspector, Projects Section Date Reviewed-N

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h C. R. Oberg, Reactor Inspector, Projects Section Date Approved:

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u W. A. Crossman, Chief, Projects Section Date x - -

R. E. Hall, Chief, Engineering Support Section Date l

l Inspect;on Summary:

Inspection on Marct 17-20, 1980 (Report No. STN 50-482/80-05)

Areas Inspected: Routine, unannounced inspection of construction activities including review of Daniel's QA Program and QA audit reports; reactor vessel internals storage and maintenance; and observation of work and review of pro-cedures for concrete expansion anchor installation.

The inspection involved twenty-eight inspector-hours by one NRC inspector.

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Results:

Of the three areas, no items of noncompliance were identified in one area.

One item of noncompliance was identified in one area (infraction-failure to provide prompt and adequate corrective action paragraph 4).

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DETAILS 1.

Persons Contacted Principal Licensee Personnel

  • M. E. Clark, Msnager, QA-Site
  • G. W. Reeves, LA Engineer
  • D. W. Prigel, QA Engineer
  • J. Stokes, KG&E Construction Daniel International (Daniel) Personnel
  • W. E. Hitt, Project Manager
  • V. J. Turner, Project QA Manager
  • D. L. Jones, Project QC Manager
  • C. L. Phillips, Assistant Engineering Manager
  • N. Criss, Audit Response Coordinator The IE inspector also contacted other construction personnel including members of the technical and engineering staffs.
  • Denotes those present at the exit interview.

2.

Site Tour The IE inspector made a tour of the Reactor Building, Auxiliary Building, and other general plant areas, including warehouse areas to observe con-struction activities in progress and to inspect housekeeping.

No items of noncompliance or deviations were identified.

3.

Review of Daniel QA Audit Program The IE inspector reviewed the following sections from the Daniel Quality Assurance Manual for compliance with Chapter 17 of the FSAR and 10 CFR 50 Appendix B:

AP-II-04, Revision 3, " Start /Stop Work Authority" AP-II-06, Revision 0, " Corporate Monitoring" AP-II-07, Revision 2, " Quality Assurance Personnel Selection, Indoctrination, and Training" AP-II-08, Revision 3, " Quality Assurance Surveillance and Audit" AP-II-09, Revision 0, " Quality Assurance Stop Work

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AP-II-11, Revision 1, " Quality Assurance Audit Planning and Scheduling" AP-II-12, Revision 2, " Project Audit Response" The IE inspector reviewed five audit reports for tie period from July 1979 to February 1980. The IE inspector also reviewed the audit responses and reaudits where applicable.

No items of noncompliance or deviations were identified.

4.

Reactor Vessel Internals On March 19, 1980, the IE inspector, during an inspection of the reactor internals storage area (Kelly Building) found approximately one inch of water standing on the concrete floor of the building. The water covered about twenty percent of the fl.oor area. The reactor head and upper and lower internals are stored in this building. The licensee representative informed the IE inspector that they had previously been having problems with rain and melting snow getting into the building and water accumulating on the floor of thi.

Iding.

A subsequent review of the maintenance records and QC surveillance reports revealed that this problem had been identified and documented by inspection and surveillance reports as early as February 1979. The IE inspector reviewed seven Storage Surveillance Reports (052, 475, 674, 885, 949,1057, and 1189), two Deficiency Reports (ISD2807 and ISD1471), and a Corrective Action Report (1-G-003) that had identified a problem with water and moisture ingress of the storage area for the reactor vessel internals.

These documents identified this problem as a failure to comply with QCP-I-01, ANSI N45.2.2 and 3, and 10 CFR 50, Appendix B.

This problem had been recognized and documented almost continuously for more than a year (13 mos.).

The IE inspector found Deficiency Report ISD2807 and Corrective Action Report 1-G-003 had been closed out and signed-off.

Deficiency Report 1471 was still open.

This report not only required correction of water ingress, but also the removal of rust from the reactor vessel head. The licensee representative advised the IE inspector that this required repair was the reason that this Deficiency Report was still open.

The reactor internals are required by procedure to be in a Level "C" storage with temperature and humidity controls.

Daniel's procedure AP-VIII-05, Revision 2 requires a weathertight, well drained area not subject to flooding.

Daniel's procedure QCP-I-01 commits to the require-ments of AP-VIII-05 and ANSI N45.2.2 and 3 as does the FSAR.

Daniel has replaced the roof on this building and foamed the seams in the building in an attempt to stop the water ingress, but it was apparent by the water present on March 19, 1980, that the corrective

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actions taken over the past thirteen months have not prevented water ingress into the building. This same problem had occurred in another building of this type where the reactor head "0" rings, tie plates, and alignment pins had been stored.

When this problem was identified, these materials were relocated to the "B" and "A" storage areas to preclude recurrence.

Although Daniel and the licensee had documented the failure to comply with the storage requirements for the reactor vessel head and internals and had made several attempts ta correct this problem over the last thirteen months, water is con;1Luing to ingress the building and all of the reports identifying the problem have been signed-off indicating that the corrective action was implemented and adequate.

A subsequent inspec-tion by the KG&E Site QA Manager during a shower on March 20, 1980, indicated that if a rain was accompanied by a moderate breeze, the walls of the building would flex opening the seams and water would ingress into the building.

10 CFR 50, Appendix B, Criterion XVI requires that conditions adverse to quality be promptly identified and corrected.

The thirteen month period during which the failure to comply with storage requirements and possible continued degradation of the reactor vessel head and internals due to the lack of prompt and adequate corrective action is a failure to meet the requirements of 10 CFR 50, Appendix B, Criterion XVI.

This is an infraction.

The IE inspector reviewed the following documents and instructions associated with the reactor internals for compliance with 10 CFR 50,

"~oR, ANSI N45.2, and applicable standards and procedures:

Purchase Order 207952 MRR 24889 - Reactor Closure Head and "0" Rings MRR 16782 - Closure Hardware MRR 2954 - Nuts and Studs Purchase Order 211471 MRR 24888 - Tie Plates and Hold Down Springs MRR 27352 - Internals Hardware Nonconformance Reports ISD 1115M, ISD 1119M, ISD 1479M, ISD 1377M,

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ISN 11373, ISN 0844M, ISN 1188M, l

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Maintenance Instructions RMI-W-042, Revision 3; RMI-W-090, Revision 1; and RMI-W-105, Revision 3.

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No items of noncompliance or deviations were identified.

5.

Concrete Expansion Anchors The IE inspector, during a walk through the reactor building, noticed that concrete expansion anchors were being installed immediately adjacent to abandoned holes and abandoned anchors that had been cut-off and driven in.

Bechtel Specification 10466-C-103A, Appendix C addresses the load values, minimum imbedment depth, and minimum spacing between anchors (assumed loaded), but does not address spacing between anchors and aban-doned holes or abandoned anchors.

Specification 10466-C-103A, Appendix D also requires qualification testing of concrete expansion anchors.

Bechtel Specification 10466-C-103A addresses the repair of concrete anamolies greater than one inch in depth or one square foot in area and thus abandoned holes are being repaired with drypack.

Bechtel Drawing 10466-C-0003, Revision 9, Note #28 addresses the removal of abandoned anchors and repair of abandoned holes or leaving partial anchor in the hole and repairing over after partial anchor is driven to the bottom of the hole.

The results of the qualification test required by Specification 10466-C-103A were not available on site. This item wi?.'. be considered as an unre-solved item pending the IE inspector's review of the concrete expansion anchor qualification and supporting analysis.

This documentation should reflect the methods of repair of abandoned holes and abandoned anc: ors as prescribed by the specifications, drawings and procedures being implemented during the period of this inspection.

6.

Unresolved Item Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. One unresolved item disclosed during the inspection is discussed in paragraph 5, Concrete Expansion Anchors.

7.

Exit Interview The IE inspector met with licensee representatives (denoted in para-graph 1) at the conclusion of the inspection on March 20, 1980.

The IE inspector summarized the purpose, scope and findings of the inspection.

The licensee representatives acknowledged the statements by the IE inspector with regard to the item of noncompliance and the unresolved item.

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