IR 05000482/1980008
| ML19318C957 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/22/1980 |
| From: | Crossman W, Martin L, Oberg C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19318C952 | List: |
| References | |
| 50-482-80-08, 50-482-80-8, NUDOCS 8007070091 | |
| Download: ML19318C957 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No. STN 50-482/80-08 Docket No. STN 50-482 Category A2 Licensee: Kansas Gas and Electric Company Post Office Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek, Unit No 1 Inspection at:
Burlington, Coffey County, Kansas Inspection conducted: April 7-11 and 28-29, 1980 g/g///o Inspectors:
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3bh 480 T. E. Vande1[ Reactor Inspector, Region I Vate'
W (Paragraph 3r AWf MMd Reviewed:
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C. R. Oberg, Reac Inspector, Projects Section Date
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Approved:
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W. A. Crossman, Chief, Projects Section Date
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Inspection Summary:
Inspection on April 7-11 and 28-29,1980 (Report No. 50-482/80-08)
Areas Inspected:
Routine, unannounced inspection of safety-related construction activities pertaining to KG&E and Daniel QA program implementation and electrical installation including raceway and cables. The inspection involved fifty-six inspector-hours ona site by two NRC inspectors and twenty inspector-hours in-office (Region IV) by one inspector.
Results: Of the two areas inspected, no items of noncompliance were identified; one deviation was identified in one area (deviation - failure to identify Class IE raceway as safety-related as required by FSAR commitment to IEEE 336 -
paragraph 4.c).
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DETAILS 1.
Persons Contacted Principal Licensee Personnel
- D. W. Prigel, QA Engineer
- W. E. Hitt, Project Manager
- V. J. Turner, Project QA Manager
- D. L. Jones, Project QC Manager
- C. L. Phillips, Assistant Engineering Manager
- N. J. Criss, Audit Response Coordinator
- H. W. Curry, Project Electric QC Engineer
- J. F. Freeman, Project Electric Engineer
- J. E. Steely, Administrative Manager R. D. Scott, Construction Manager Other
- R.
C. Slovic, Site Liaison Bechtel
- R. D. Brown, Site Representative, SNUPPS D. Gasda, Electrical Engineer, Bechtel (Gaithersburg)
The IE inspectors also interviewed other licensee and contractor personnel during the course of the inspection.
- Denotes those attending the exit meeting.
2.
Site Tour The IE inspectors walked through the Reactor Building, Auxiliary Building, Spent Fuel areas, Control Complex area, and various outside storage areas to observe construction activities in progress.
Particular attention was given to housekeeping and storage of in plsce equipment.
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The overall housekeeping was adequate, but there were a few remote areas that needed increased attention, e.g., Auxiliary Feedwater Rooms and remote areas in Battery Room. The licensee representative took immediate action in these areas.
No items of noncompliance or deviations were identified.
3.
Quality Assurance Program Review The auditing, surveillance, and program assessment activities for the Wolf Creek facility were reviewed by the IE inspector with the following results.
a.
Program Procedures Review Applicable procedures of KG&E and Daniel were reviewed with no problem areas being identified.
The KG&E procedures reviewed were as follows.
KG&E Procadures Manual Section 1
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KP2-1, "QA Committee (KG&E)"
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KP4-1, "QA Requirements for Major Contracts"
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KP4-2, " Contractor Evaluation"
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KP4-3, " Specification Review by Quality Assurance"
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KP4-5, " Selective Review of Construction Procurements"
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KPS-1, " Control of Procedures, Instructions, and Forms"
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KPS-2, " Control of KG&E Procedures Manuals"
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KP5-3, " Review of Construction Procedures by Quality Assurance"
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KPS-4, " Document Control by Quality Assurance"
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KP7-1, "QA Personnel Indoctrination, Training, and Qualifications"
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KP9-1, " Processing of Nonconformance Reports by Quality Assurance"
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KP9-2, " Trend Analysis"
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KP10-2, " Reporting Significant Deficiencies and Defects"
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KP12-1, " Storage and Maintenance of QA Records"
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KP13-1, " Master Audit Plan"
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KP13-4, " Site Audit Procedure"
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KP13-5, " Site Surveillance"
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KP13-6, " Site Follow Up of Open Items "
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The Daniel Procedures reviewed were as follows.
AP-II-08, "QA Surveillance and Audit"
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AP-II-09, "QA Stop Work Action"
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AP-II-10, "QA Review of Project Procedures and Instructions"
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AP-II-11, "QA Audit Planning and Scheduling"
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AP-II-12, " Project Audit Response"
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AP-II-07, "QA Personnel, Selection, Indoctrination, and Training"
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No items of noncompliance or deviations were identified.
b.
Program Activities Review (1) Certification of KG&E Personne_1 The IE inspector discussed certification of KG&E QA personnel l
and learned that three QA personnel have been certified for auditor and/or lead auditor functions.
The three auditors are:
M. E. Clark, QA Manager, Site D. W. Prigel, Assistant QA Manager, Site G. W. Reeves, QA Engineer In addition, the IE inspector was informed that three additional QA personnel are currently in training for certification. Those trainees are:
R. G. Haines, QA Engineer R. M. Stambaugh, QA Engineer S. J. Walmsley, QA Technician
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A seventh member of the KG&E QA staff has recently been added, Mr. S. D. Boston, who is currently listed as a QA Technician.
The training and qualification for one certified auditor was reviewed for adequacy.
The IE inspector observed that the file contained the following:
March 1978 certifications provided by the employees previous
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employer, which listed his Professional Engineer in Quality Engineering certifications from the State of California as part of his qualification.
KG&E training session attendance lists for QA, concrete,
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tendon sheaths, expansion anchors, and welding among others.
Certification by the KG&E Corporate QA Director as a
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qualified lead auditor.
Another notation that training sessions are continuing.
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(2) Review of KG&E Audit Reports The IE inspector selected reports of three separate audits per-formed by the certified auditors during the last nine months.
The audits were performed relative to the following subjects:
Completed on September 21, 1979, Audit of Daniel site
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Quality Assurance.
Completed on October 11, 1979, Audit of Receipt, Storage,
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Handling, and Preservation of Safety-Related Equipment.
Completed on January 17, 1980, Audit of Specification
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and Drawing Revision Control.
The information available for review established that in each case a checklist was used by the auditors and the results of the audit were provided to the audited organization.
Follow up of the audit findings is in progress.
No itema of noncompliance or deviations were identified.
c.
Audit Planning and Scheduling Upon request, a copy of a three month QA Audit Schedule for the months of April, May, and June 1980 was provided by the Daniel QA Manager.
This schedule provided the Daniel scheduled audits for these three months and separately provided the KG&E audits and surveillances scheduled for the same period.
The Daniel audit schedule includes a listing of ten separate audits that have been scheduled for each month and are identifiable to specific parts of
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the QA program. During discussions with the Daniel QA Manager, it was learned that for assurance all aspects of the program, in terms of all Appendix B Criteria, have been audited during the year, a Criteria Matrix is maintained.
This matrix reflects all audits (both scheduled and unscheduled) as well as all surveillance activity against the appropriate criterion.
No items of noncompliance or deviations were identified.
d.
Daniel Personnel Oualifications and Audit Reports Review Discussions were held with both the Daniel QA Manager and the QC Manager and review was undertaken of the qualification of personnel, preparation for audits, audit reports, and of records maintained of the status of audit results and findings.
A sampling review was undertaken for the following items:
personnel qualification folder
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two audit reports
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Quality Assurance Audit Findings (QAAF) sheets related to the
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two reports audit planning check sheets
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The IE inspector learned that, in addition to the auditors located on site, other qualified additors are available from the corporate office who can provide added expertise when needed.
In response to questioning, the IE inspector learned that Daniel conducts a management program assessment activity of the site on a l
quarterly basis, termed the Project Monitoring Program. The most recent audit was reviewed.
The IE inspector also was able to review the scheduling notice of the next glanned audit to be conducted in
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April 1980.
i No items of noncompliance or deviations were identified.
4.
Electrical Systems (Raceway and Cables)
a.
Follow Up on Potential Construction Deficiency The IE inspector followed up on potential 50.55(e), electrical cable manufacturing defects.
The supplier, Rockbestos, was at the site and had examined the defects identified by the licensee. The licensee representative told the IE inspector that the supplier, upon examination of the seven defective reels of cable, had determined
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that the problem was confined to the outer jacket and filler material and that the individual conductor insulation was satisfactory. The suspected splice reported to the NRC on April 3, 1980, was a bulge in the outer jacket caused by an improper lay of the filler material. The licensee is returning all defective cable to the supplier. To date all of the defects have been in the black (non-IE) cable.
On April 18, 1980, the licensee began a program to inspect enough cable to allow a continued pulling program for 60 days and was planning to inspect additional Class IE cable reels to determine the scope of the manufactur-ing defects. The licensee plans to issue a 30 day report.
b.
Procedure Review The IE inspector reviewed the following procedures for compliance with 10 CFR 50, FSAR commitments and applicable industry standards:
QCP-X-300, Rev. 4, " Installation of Electrical Raceway" WP-X-300, " Installation of Electrical Raceway" QCP-X-302, Rev. 7, " Installation of Electrical Raceway Supports" WP-X-302, Rev. 2, " Installation of Electrical Raceway Supports" QCP-X-303, Rev. O, " Installation of Cable" WP-X-303, Rev. 1, " Installation of Cable" The IE inspector noted that some attempt had been made to address the open item from NRC Report No. 79-07 with regards to II/I, or non-Class IE cables and raceway systems that might influence or damage Class IE equipment ia the area. The WPs (Work Procedures) have been revised to cover II/I for areas of rework, but not the original instal-lation. The QCPs (Quality Control Procedures) still do not address II/I. There have been no final QC inspections of installed tray and supports. The IE inspector informed the licensee of this inconsis-tency. This will remain as an open item.
No items of noncompliance' cr deviations were identified.
c.
Observation of Work i
The IE inspector made a tour through the cable spreading rooms with a QC inspector and randomly picked supports in the process of instal-lation and raceway sections to determine what in process icspections were being accomplished.
The IE inspector reviewed the following documents for the in process work observed:
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In-Process Inspection Reports for Raceway Supports 371-A-11, 371-A-12, 371-04, and 351-E-39.
Bechtel Drawings:
10466 C-0404(Q), Rev. 8, " Typical Details, Cable Tray Supports" 10466 C-0403(Q), Rev. 9, " Typical Details, Cable Tray Supports" 10466 C-0413(Q), Rev. 9, " Typical Details, Cable Tray Supports" E-OR3511(Q), Rev. 10, " Raceway Plan Control Bldg, Area 1"
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E-OR8900(Q), Rev. 9, " Raceway Notes, Symbols, and Details" Daniels Drawings:
FSK-E-351-E, Rev. 4 FSK-E-500-S, SHT 628, Rev. O Bechtel Specification 10466-E-034, Rev. 3, " Technical Specification for Purchase of Ele:trical Cable Trays for the Standarized Nuclear Unit Power Plant (SNUPPS)"
The IE inspector, during review of Specification 10466-E-034 noted that the specification was not designated as safety-related. The IE inspector determined, through discussions with Bechtel and Daniel personnel on site, that the cable tray is not only purchased not safety-related, but remains as nonsafety.
On April 28, 1980, the IE inspector was informed via telephone, by Mr. Gasda from Bechtel Gaithersburg Power Division, that the tray was purchased nonsafety under 10 CFR 21 as a " commercial grade item" and was qualified for its intended use by testing and analysis.
Mr. Gasda stated that the cable tray stiffness character-istic is used in the seismic calculations and analysis of the Class IE and II/I cable support system.
Wolf Creek Final Safety Analysis Report, Chapter 8, Section 8.1.4.3 commits in total to IEEE Std. 336, 1971 (ANSI N45.2.6) and NRC Regu-latory Guide 1.30.
This section also commits all electrical systems to the control requirements of the Quality Assurance Program in Chapter 17 of the FSAR.
Wolf Creek Final Safety Analysis Report, Chapter 3, Table 3.2-1 indi-cates that the installation of raceway for Class IE cables is safety-related.
IEEE Std. 336, 1971 (ANSI N45.2.6) "IEEE Standard Installation, Inspec-tion, and Testing for Instrumentation and Electric Equipment During
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the Construction of Nuclear Power Generating Stations," paragraph 1.1.1
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states that,."the requirements of this standard cover the Class IE-systems and equipment, and the auxiliaries such as the following (1)
connecting cables and raccways."
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IEEE Std. 336, 1971, paragraph 1.1.4 requires that activities within the scope of this standard be accomplished in accordance with ANSI N45.2-1971, " Quality Assurance Requirements for Nuclear Power Plants."
10 CFR 21 Section 21.3(k) states that,,"a ' commercial grade item' is not a part of a basic component until after ' Dedication'." Section 21.3(C-1) of 10 CFR 21 states that, "' dedication of a commercial grade ites' occurs after receipt when that item is designated for use as a basic component."
IEEE STD 279, 1971, " Criteria for Protection Systems for Nuclear Power Plants," and IEEE 323-1974, " Qualifying Class IE Equipment for Nuclear Power Generating Stations," both require that equipment be qualifici for its intended use.
IEEE 323, 1974 specifically defines the qualifi-cations of interface equipment, e.g.,
cable tray.
Contrary to the above:
The IE inspector was informed by Bechtel site personnel and Mr. Gasda
of Bechtel Power Division that the cable tray being installed at Wolf l
Creek and the other SNUPPS sites is not safety-related, because the
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qualification of the tray by testing and analysis has proven its ability to perform and, therefore, it does not have to be designated as safety-related or Class IE.
The IE inspector also reviewed a letter dated August 20, 1979, from Mr. J. H. Smith, Project Engineering Manager, Bechtel Power Corporation to Mr. Nicholas A. Petrick, Executive Director, SNUPPS which was Bechtel's response to SNUPPS on NRC IE Information Notice 79-14.
IE Information Notice 79-14 was the application of pertinent QA requirements of 10 CFR 50, Appendix B to design, procure-ment and installation of cable trays for Class IE electrical systems.
This letter indicates that the testing of off the shelf cable tray and conduit precludes the Q classification of this material.
i As indicated in 10 CFR 21, IEEE Stds. 336, 279, 323, the qualification testing does not preclude the requirement of equipment as safety-related, but justifies it.
The IE inspector is concerned whether or not the cable tray at Wolf Creek is in fact "off the shelf" or " commercial grade item" as there has been a coeliderable amount of additional brazing accomplished
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at spot weld joints (pregalvanized) to strengthen either inadequate or failed spot welds.
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The IE inspector could not review the cable tray test to determine if the tray tested had this type of welding.
These tests were not on site at the time of this inspection.
The failure to designate this tray as safety-related exempts the material from future 10 CFR 21 or 10 CFR 50.55(e) reporting. This has generic implications with all of the SNUPPS sites and any other sites where Bechtel is the architect engineer.
This material can be ordered as " commercial grade" and subsequently qualified for its intended use, but upon receipt at site, including inspection prior-to installation and defect reportability, should be designated as "Q" or safety-related material as required by the above listed FSAR commitments.
This is a deviation.
5.
Exit Interview The IE inspectors met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on April 10, 1980. The IE inspectors summarized the p';. pose, scope and findings of the inspection.
The licensee representatives acknowledged the statements by the inspectors with regard to the item of deviation.
Mr. Vandel met with Mr. Clark on April 11, 1980, to cover additional inspection.
A phone call was made to Mr. Clark on May 1, 1980, to inform him of the findings of the in-office inspection.
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