IR 05000482/1981021
| ML20058B206 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/05/1982 |
| From: | Crossman W, Randy Hall, Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20058B195 | List: |
| References | |
| 50-482-81-21, NUDOCS 8207230189 | |
| Download: ML20058B206 (10) | |
Text
{{#Wiki_filter:. APPENDIX U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Report: STN 50-482/81-21 Docket: STN 50-482 Category A2 . Licensee: Kansas Gas and Electric Company Post Office Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek Generating Station Appraisal Period: July 1, 1980 - June 30, 1981 Appraisal Completion Date: September 18, 1981 Licensee Meeting: October 19, 1981 SALP Board Members: G. L. Madsen, Chief, Reactor Project Branch 1 J. Youngblood, Chief, Licensing Branch 1 W. A. Crossman, Chief, Reactor Project Section B R. E. Hall, Chief, Reactor Project Section C T. E. Vandel, Senior Resident Reactor Inspector L. E. Martin, Reactor Inspector Reviewed: I/[[81 W. A. Crossman, Chief, Reactor Project Section 8 Datfe ff f2 R. E. Hall, Chief, Reactor Project Section C Date 8/I/8V Approved:
G. L. Mads'en, Chief, Reactor Project Branch 1 Date (SALP Board Chairman) . 8207230189 820625 PDR ADOCK 05000482 G PDR __
I.
Introduction Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect available observations and data on an annual basis and evaluate licensee performance utilizing these data and observations as a basis.
The integrated systematic assessment i; intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensec management.
II. Criteria . The assessment of licensee performance is implemented through the use of seven evaluation criteria.
These criteria are applied to each functicnal area that is applicable to the facility activities (construc-tion, preoperation, or operation) for the categorization of licensee performance in these areas.
One or more of the following evaluation criteria are used to assess each applicable functional area.
1.
Management involvement in assuring quality 2.
Approach to resolution of technical issues from safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history 5.
Reporting and analysis of reportable events 6.
Staffing (including management) 7.
Training effectiveness and qualification Attributes associated with the above evaluation criteria form the guidance for the SALP Board for categorization of each functional area in one of three categories.
Performance categories are defined as follows: Category 1 - A combination of attributes which demonstrates achievement of superTo'r safety performance; i.e., licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of per-formance with respect to operational safety or construction is being achieved.
Reduced NRC attention may be appropriate.
Category 2 - A combination of attributes which demonstrates achievement of satisfactory safety performance; i.e., licensee management attention and involvement are evident and are concerned with nuclear safety; l licensee resources are adequate and are reasonably effective such that l satisfactory performance with respect to operational safety or construc-tion is being achieved.
NRC attention should be maintained at normal levels.
Category 3 - A combination of attributes which demonstrates achievement of only minimally satisfactory safety performance; i.e., licensee' manage-
ment attention or involvement acceptable and considers nuclear safety, l
but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.
Both NRC and licensee attention should be increased.
III. Summary of Results Functional Areas Category 1.
Soils and Foundations N/A 2.
Containment and other Safety-Related
Structures 3.
Piping Systems and Supports
4.
Safety-Related Components
5.
Support Systems
6.
Electrical Power Supply and Distribution
7.
Instrumentation and Control Systems N/A 8.
Licensing Activities
IV. Performance Analyses The SALP Board obtained assessment data applicable to the appraisal period of July 1, 1980, through June 30, 1981.
The data for the Wolf Creek facility was tabulated and analyzed, and a performance analysis was developed for each of six functional areas.
The SALP Board met on September 18, 1981, to review the performance analyses and supporting data and to develop the SALP Board Report.
Functional Area Analysis 1.
Soils and Foundations All activities in this area have been completed.
2.
Containment and Other Safety-Related Structures The Reactor Building Containment structure completion has been performed satisfactorily to date since resolution of the problems experienced early in the placement history.
Early concrete placement problems were identi-fied in construction deficiency reports provided to the Region IV office as follows: (1) basemate concrete low cylinder break deficiencies (these concerns became an item of review for NRR licensing personnel for which a letter was ultimately issued by NRR accepting the basemat for use at Wolf Creek); and (2) concrete voids found under the equipment hatch in Lift No. 6 of the containment wall.
These two deficiencies were the
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subject of a Region IV Immediate Action Letter and of a licensee Ad Hoc Committee review resulting in a licensee letter committing to 11 items of corrective action, dated December 19, 1978.
The corrective actions completed by the licensee, reviewed and closed out by the NRC inspector in Report No. STN 50-482/79-18, formed the basis for the placement procedures used for the remainder of the containment wall and dome, with the dome placements being com-pleted successfully in September and October 1980.
Although a few deficiency reports were generated by the contractor, no further problems have been encountered.
The post-tensioning system instal-lation to complete the Containment Building will start approximately October 1,1981.
, It is the opinion of the Resident Reactor Inspector that the construction activities since Lift No. 6 were performed well.
The Board recognizes the licensee action to institute controls that achieved proper performance of construction activities fu concrete placements.
The Board determined that the licensee performance in this area is equivalent to Category 1.
3.
Piping Systems and Supports Piping welding reject rate was recognized by the licensee and contrac-tor as an area of concern.
Corrective action was undertaken by Daniel International (Daniel) site welding personnel during the summer and fall of 1980.
In addition, a Daniel task force of corporate welding personnel was created to review the problem and provide corrective action recommendations.
Twenty identified problems and recommended changes were provided in the task force report.
Implementation of the changes and corrective actions resulted in a reject rate change from 48 to 79 percent down to the current experience of 8 to 12 percent.
The reactor coolant loop piping currently is nearing completion with this low repair experience.
Inspector-identified unresolved items are being resolved and removed based on current improved welding experience.
I The Board has no further concern regarding welding activities and con-siders the licensee performance to be Category 2 in this functional area.
4.
Safety-Related Components, Including Vessels, Internals, and Pumps Inspection activity conducted during the reporting period covered NSSS components and other safety-related mechanical and electrical equipment.
The equipment inspected was adequately stored and handled.
Personnel access control to internal areas of NSSS equipment, while adequate, has, at times, been somewhat inconsistent.
The safety-related components functional area performance is considered to be Category 2 by the Board.
.-. -- 5.
Support Systems, Including HVAC, Radwaste, and Fire Protection Allegations regarding heating / ventilating / air conditioning duct supports welding were provided to the Region IV office during the review period.
The allegations were concerned with the inadequacy of hanger welding and of inappropriate activities regarding transfer of information on safety-related records of the hangers.
Investigation of these concerns confirmed the allegations.
Corrective action by the licensee personnel included: (1) a complete audit of the problem and documentation of open items; (2) replacement of management personnel; (3) upgraded procedures for enhanced record . control; (4) a reinspection of all affected hangers welding for adequacy; (5) 122 nonconformance reports for rejected hanger welds; and (6) corrective repair in accordance with the A/E disposition instructions.
This ongoing program of actions and program enhancements included 17 discrete activity punch-list items.
Of these 17 major activities, a total of 109 milestones are included.
Current to this writing, 78 milestones and 6 major activities have been completed.
The Board believes that the inappropriate activities uncovered merited a Category 3 rating.
It is noted that the corrective action performance by the licensee is of the highly professional level that is customary for this licensee.
Therefore, an overall rating of Category 2 is extended for this functional area.
6.
Electrical Power Supply and Distribution The Region IV specialist inspector, during the last year, identified several concerns and has issued noncompliance and deviation citations regarding them as follows: a.
Failure to provide appropriate procedures.
Construction procedures made no provision for activities associated with II/I supports and raceway.
(Report STN 50-482/80-15) b.
Failure to designate cable tray as safety-related.
Nonsafety-related procured cable tray, later qualified for seismic use by testing, had not been designated as safety-related material on site even though the tray was in a safety-related application.
(Report STN 50-482/80-08) c.
Specification color coding for cable deviates from the FSAR commit-ment.
Class IE 4160 volt switchgear wiring, redundant separation color coding for one channel is of a different color (green) than committed to in the FSAR (yellow).
(Report STN 50-482/81-05) .
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. Two noncompliance items (Items a and b) have since been reviewed for corrective action and closed by the inspector.
The deviation is to be resolved by altering the FSAR wording to reference the specification or drawing (this having been concurred with by NRR licensing personnel).
Control Room main control panels and consoles were reported by the licensee for inadequate structural welding.
This problem, also generic with the Callaway facility, was reviewed by the Architect-Engin~eer who also provided disposition.
A mock-up test panel was fabricated with representative bad fillet welds and seismically tested to failure.
Acceptable welding was then established which became the acceptance criteria for reinspections of both the Callaway and Wolf Creek panels and consoles.
The Architect-Engineer's final report is expected soon.
The electrical installation functional area is considered to be a Category 2 performance by the Board.
7.
Instrumentation and Control Systems Work is this area was very limited during the assessment period.
8.
Licensing Activities Kansas Gas & Electric, with the assistance of the SNUPPS organization, provided very good quality responses in a timely manner to requests for information.
Due to shortened review schedules, the timeliness and quality indicate a significant effort with a good understanding of NRR licensing requirements by the licensee.
The above-average rating for this reporting period is based upon SNUPPS being an integral portion of the licensee's organization.
The Board evaluated the licensee's performance, with the assistance of SNUPPS, to be Category 1.
l Conclusion
The SALP Board concludes that the licensee ranks on a par with most other nuclear facilities under construction, and that an overall Category 2 rating is considered appropriate.
Quality Assurance was heavily influenced by investigation results that indicated a breakdown of Quality Assurance program control.
Board Recommendations The SALP Board did not recommend any change in the level of inspection for the next appraisal period.
However, programmatic changes for construction inspection have been made that will effectively reduce inspection activities l ' for all construction sites.
. l l
_ _. .
V. Supporting Data and Summaries 1.
Report Data a.
LER Numbers Reviewed (not applicable) b.
Construction Deficiency Reports (CDRs) Listed below is a summary of results of the NRC inspector's review of previously unreviewed CDRs.
The results were - included in six different inspection reports issued during the appraisal period (80-13, 80-15, 80-18, 80-24, 81-02, and 81-05).
Determined to be not reportable items and closed
Report items closed out
Report items continued in open status
The following listed deficiencies were reported by the licensee or through the SNUPPS reporting system, during the appraisal period as a Part 50, Section 50.55(e) report: Structural members, improper heat . Piping system analysis . Anchor bolt forces with horizontal steam line break . Application of structural steel fireproofing . Nonconforming Rockbestos cable . Undersize socket welds in piping . GE sticky overcurrent relays . Corner and Lada sway struts . Chargirg pump operation following secondary side high . energy line rupture 3-inch isolation valve (Westinghouse) . Pipe whip restraints . l Nuclear coatings, Specification A125 (Q) . Main control room panels and consoles nonconforming welds i . Fisher controls, manually operated valves . GE HFA relays . GE AKR 30 and 50 circuit breaker . Dravo piping spools . Bergen-Paterson sway struts . c.
Part 21 Reports Limitorque actuator motor pinion . . Bergen-Paterson shock arrestor interference problem
-_ ________ - ______ _____ ______ ________ ___ _ _ _ _ _ _ _ _ _ _ _ _.
Significant CDRs and Part 21's reported during the appraisal period, although not necessarily reviewed and closed by the inspector, are summarized below: Inadequate socket welds have been identified on small bore . piping 2 inches and under.
These were fabricated by field construction forces throughout a large number of systems in the plant.
Rejection rate experience has been nearly 10 percent of all welds.
Reinspection of all welds, repair of deficient welds, and a retraining program for field personnel are currently in progress.
However, completion is not expected until the end of 1981.
Control Room main control panels, consoles, and auxiliary . rel;y racks supplied by Comsip Customline Corporation were reported to have nonconforming fillet welds on the structural members.
The Architect-Engineer developed a generic program for both Callaway and Wolf Creek sites to assess the impact on the structural integrity of the panels and racks.
To date, a mock-up panel has been prepared with representative inadequate welds and has been seismically tested to failure.
The results of the test provided the basis for new acceptance criteria of the welds in question which were then reinspected.
ThefinalreportingisexpectedNovember30,199 Gould Nema 3 electric motor starters potential defect was . reported to the NRC on September 11, 1979, as a Part 21 type report.
This information was subsequently provided to the licensee as an IE Circular No. 79-23, dated November 26, 1979.
This significant deficiency, although initially reported prior to the current appraisal period, continues to remain in an open status at this writing.
IE Inspection Report 81-05 reported the most recent inspector's concerns as follows: (1) Daniel NCRs identified 70 size-3 starters requiring replacement; (2) Gould added 3 more, for a total of 73; and (3) a Gould letter to Bechtel (the Architect-Engineer) stated that a total of 74 starter replacement kits had been installed.
This item remains open until a determination can be made as to how many starters were involved.
SNUPPS informed the NRC of a significant construction deficiency . involving failure to close of valves identical to isolation valves used at the SNUPPS plants.
The original reports singled out 3-inch gate valves, supplied by Westinghouse Electro-Mechanical Division, 1500 pounds class, that failed to close under preoperational testing conditions.
Information provided later expanded that deficiency to include 4-inch valves.
The most recent SNUPPS report (June 19,1981) indicated that larger sizes (i.e., 6, 8, 10, 12, 14, 16, and 18-inch) can also be anticipated to have closure problems.
_ _ _ _ _
-. Further information is to be provided by SNUPPS in the future.
Bergen-Paterson identified a Part 21 reportable inter- . ference problem by letter, dated June 20, 1980, that will hinder full function of their pipe clamp strut assembly when used with a Pacific Scientific mechanical shock arrestor.
This report was specific to sizes No. 2541.35 and.65 only and did not include larger sizes (i.e., 2541-1.5, -6, -15, -50, and -120).
Subsequently, the licensee incorporated this Part 21 report . into their 50.55(e) reporting system to a final report letter, dated August 4, 1980, KG&E to the NRC Region IV office.
Bergen-Paterson later issued another Part 21 report letter, dated October 29, 1980, that expanded the pipe clamp strut and shock arrestor assemblies involved to include sizes __- ~2541-6, -15, and -120 as also having interference problems.
SNUPPS provided final reports for each of the above Part 21 reports by letter to the NRC (i.e., SLNRC 80-53, dated November 26, 1980, and SLNRC 81-37, dated June 1, 1981).
The June 1, 1981, report indicated that all clamps affected will be returned to the supplier for modifications, and that all assemblies supplied after March 4, 1981, will include the modified clamp.
Other corrective action-type commit-ments were provided by the supplier and reviewed by Becthel.
Separately, an unrelated matter was reported by the licensee to the RIV office on May 29, 1980, regarding loose sway strut bushings on Bergen-Paterson manufactured struts as well as other manufacturers' sway struts.
Interim reports were pro-vided on August 29, 1980, November 12, 1980, and February 26, 1981.
The most recent letter noted that the Bergen-Paterson portion will be completed by SNUPPS reporting on a generic basis.
The Senior Resident Reactor Inspector was informally apprised that the Architect-Engineer determined that even a complete loss of bushings on the struts would have no safety l function of the struts.
The final report from SNUPPS is expected soon.
' It is noted that the other manufacturers of sway struts (i.e., Corner and Lada and ITT Grinnell), having the loose bushings , problem, have been reported per 50.55(e) requirements and are ' being pursued by the licensee.
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i r .
. 2.
Licensee Activities Construction activities continued routinely during the appraisal period with the investigation of allegations mentioned earlier in this report being the only major unusual effort by the licensee.
The licensee has devoted t.onsiderable effort to the problem determination, scope, and to corrective action planning which is now complete.
3.
Inspection Activities During the July 1, 1980, to June 30, 1981, appraisal period, a total of 1,033 inspector-hours were performed on inspections and investi- - gations as follows: (1) eleven periodic inspections reported by the assigned Resident Reactor Inspector; (2) nine inspections were con-ducted by regional inspectors onsite; (3) two investigations were conducted by a regional investigator of allegations regarding construction practices; and (4) one inspection was conducted of the SNUPPS and Bechtel activities.
No major team inspection was conducted during the appraisal period.
4.
Investigations and Allegations Review A concern regarding Quality Assurance program breakdown resulted from a recent investigation of allegations regarding: (1) fabrication of a fake pipe hanger (confirmed); (2) forging of QC inspector's signa-ture on weld control record cards (confirmed); and (3) falsification of weld control and supplemental sheet records (determined to be an inadvertent result of records transfer activities).
These allegations were received during April and May 1981.
A Notice of Violation was issued regarding lack of program control for the fabrication of a pseudo hanger replacing a safety-related hanger (Inspection Report STN 50-482/81-06). Investigation Reports 81-07, 81-10, and 81-12 were issued.
5.
Escalated Enforcement Actions Utilization of Immediate Action Letters (IALs) occurred during the appraisal period to emphasize the NRC's concern regarding the pipe cleanliness problem identified by the licensee.
The licensee identi-fied, for the second time, inadequate control by the contractor of piping cleanliness (November 21,1980).
IALs were issued on November 26, 1980, and December 22, 1980, regarding corrective actions by the licensee and followup by the Senior Resident Reactor Inspector.
The licensee resumed piping work on December 31, 1980.
No further problems have developed.
6.
Management Conference Held During Appraisal Period . Meetings were held with licensee representatives on August 21, 1981, at their corporate office and on September 3, 1981, at the Region IV office to discuss hanger concerns, their resolution, and corrective action. (See 4 above) The licensee outlined those corrective actions in a report to the NRC on September 10, 1981.
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