IR 05000482/1984051
| ML20127C342 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, 05000000 |
| Issue date: | 12/11/1984 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20126H338 | List: |
| References | |
| FOIA-85-160 NUDOCS 8412190495 | |
| Download: ML20127C342 (6) | |
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* , . - 2 */ . /@ ' tog'o UNITED STATES E")m ;; (- ;E NUCLEAR REGULATORY COMMISSION WASHING TON, D. C. 20555 \'***** .o#
December 11, 1984 Docket No. 50-482 MEMORANDUM FOR: Richard P. Denise, Director
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Wolf Creek Task Force, Region IV i
. ? FROM: J. Nelson Grace, Director . Division of Quality Assurance, Safeguards, I and Inspection Programs j Office of Inspection and Enforcement
- SUBJECT: SPECIAL CONSTRUCTION VERIFICATION
: INSPECTION REPORT
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As requested in your memoranda to R. DeYoung dated September 24, 1984 and
. ; October 12, 1984, IE performed a special construction verification inspection j (SCVI) of the voluntary Construction Self Assessment (CSA) performed at the Wolf '
Creek Generating Station (WCGS). The SCVI was performed by members of IE/DQASIP .
; and consultants, most of whom had experience as members of an NRC Construction Appraisal Tea *
9] . q The SCVI report package is enclosed for your transmittal to the applicant. The h package includes the transmittal letter, Executive Summary, Potential Enforcement i Actions, and Unresolved Items for your use in the transmittal to Kansas Gas and
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Electric Company (KG&E).
The SCVI was performed primarily to achieve the requested assessment of the CSA h effort as defined in your memoranda. In the process of performing the requested assessment, the SCVI also identified other items which have been classified
, either as an item for potential enforcement action or as an unresolved ite J These are listea in Enclosures B and .C of the enclosed transmittal letter.
- j Closeout of all items relative to the potential enforcement action and unresolved j items identified during the NRC assessment of the CSA effort and of the specific j and generic concerns identified as a result of the CSA effort will be considered 1 a satisfactory resolution of the matters in this report.
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It is our recommendation that the potentia enforcementaction(PEA) detailed ij in Enclosure B to the enclosed transmittal letter be issued as a notice of j violation and be classified as Severity Level IV in accordance with 10 CFR , 2, Appendix C, Supplement II. It is recognized that the PEA is similar to a 1 violation issued in paragraph B of Appendix A, Notice of Violation, to the 7 Wolf Creek Inspection Report 50-482/84-22, but in our view relates to different j requirements.
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i 2 Richard P. Denis -2- December 11, 1984 If you have any questions, please contact Brian Grimes (492-4614) or fiark Peranich (492-9661).
N . c 7e J. Nelson Grace, Director Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement Enclosures: 1. SCVI Inspection Report 2. Transmittal Letter
, 3. A .- Executive Summary .
l 4. B - Potential Enforcement Action 5. C Unresolved Items i
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WASHINGTON, D. C. 20555
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Oscket No. 50-482
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i Kansas Gas and Electric Company
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ATTN: Mr. Glenn L. Koeste Vice President - Nuclear i P. O. Box 208
; Wichita, Kansas 67201 a
j Gentlemen:
4 Subject: Special Construction Verification Inspection j- 50-482/84-51 .
2 l' Enclosed is the report of the Special Construction Verification Inspection (SCVI) i conducted by the Office of Inspection and Enforcement (IE) from October 23
"- $ through November 2,1984 at the Wolf Creek Generating Station (WCGS) site. The SCVI team was composed of members of IE and a number of consultants. The SCVI :
was conducted to assess.the voluntary Construction Self Appraisal (CSA) effort .
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by the Delian Corporation and the followup corrective action The SCVI report identifies the areas examined during the inspection.- Within these areas, the effort consisted of an assessment of the independence, scope, a accuracy and completeness of the CSA effort and report, the categorization of deficiencies as to their level of seriousness, and the appropriateness and
- j justification of conclusions. A sample of installed hardware and associated records was inspected, including hardware and records inspected ouring the CS In addition, the corrective actions taken in response to the CSA findings were assessed.
} Enclosure A to this letter is an Executive Summary of the SCVI and of conclusions l( reached by this office. The SCVI team noted no pervasive breakdown in meeting i construction requirements in the samples of installed hardware or the procedures 4 inspected by the SCVI team. However, the SCVI identified certain limited areas $. . where the full objective of the CSA was not achieve a p Enclosure B contains a potential enforcement action based on SCVI findings 4 which is being reviewed by IE and the NRC Region IV Office for appropriate d action. Enclosure C contains a list of unresolved items based on SCVI i findings. Closeout of all items relative to the potential enforcement action and unresolved items identified during the NRC assessment of the CSA effort i and of the specific and generic concerns identified as a result of the CSA 3 effort will be considered a satisfactory resolution of the matters in this
,t report. With respect to the area of structural steel welding, followup will f be that required by the previously issued Notice of Violation. Please inform
: the NRC Region IV Office when your closecut of these matters is ready for NRC
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W o E 4 __ , Kansas Gas and Electric Company - 2- - In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures is being placed in the NRC Public Document P,oom. No reply to this letter is required at this time. You will be required to respond to these findings j after a decision is made regarding appropriate enforcement actio Should you have any questions concerning the SCVI or this report, please contact us or the SCVI team leader, Mark Peranich (301-492-9661).
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Sincerely, I l
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Richard P. Denise, Director l Division of Reactor Safety and Projects ' i Region IV
! Enclosures:
1. A - Executive Summary
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2. B - Potential Enforcement Actions 3. C - Unresolved Items ~
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4. Inspection Report 84-51
) } cc w/ enclosures:
1 See next page j (To be provided by Region IV) f i
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* . . f EXECUTIVE SUMMARY An announced special construction verification inspection (SCVI) was conducted at the Wolf Creek Generating Station (WCGS) during the period October 23 -
November 2,1984. The objective of the SCVI was to assess the extent to which the voluntary Construction Self Assessment (CSA) performed for the Kansas Gas
, and Electric Company (KG&E) by the Delian Corporation (Delian), and the followup , corrective actions, provide an additional measure of assurance of the quality of construction at WCGS. The objective of the CSA, as stated in the Delian report, was to " provide an independent evaluation of the construction at Wolf Creek "
with primary emphasis on hardware inspections similar to the Nuclear Regulatory Commission (NRC) Construction Appraisal Team (CAT) inspection."
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OVERALL CONCLUSIONS 1 It is the conclusion of the NRC SCVI team that the CSA effort met its stated 3 objective in most areas. In most areas the effort was adequately scoped, -
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inspections conducted were generally completed in an acceptable manner, results j were accurately reported, deficiencies were properly categorized as to their seriousness, and final conclusions were justified and appropriat l
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1 The NRC SCVI identified certain areas of the CSA effort where the full objective ; P stated for that effort was not achieved and where the additional measure of . l'I assurance of the quality of construction for the WCGS was marginal or not * achieved. These are:
! The CSA inspection sample for electrical terminations was limited in scope 1 and the NRC SCVI identified deficiencies in a broader, independent sampl l The Delian effort did not include inspection of specific cable sample , ' The CSA effort for the comparison of mechanical equipment nameplate data . -
with FSAR specifications was incomplete due to the absence of data being j collecte ]j The CSA effort for inspection of structural steel welding did not include a physical verification of structural steel welds. Acceptance by the CSA 1 was only based on documentation reviews of DIC inspection record a 1 The CSA effort for vendor welds did not uce a procedure or written criteria j for inspection of welds.
A j The CSA effort for reinforced concrete was limited in scope and did not
,, provide sufficient depth. The effort did not include an inspection of j anchor bolt ( The CSA effort in material traceability was limited to data verifications of certified material test reports, (CMTRs) and did not include physical verification of CMTR data to items installed in the plan . The CSA effort for verification of maintenance requirements was limited to equipment turned over to the licensee and did not include a similar verification for items still under the construction manager's (DIC's)
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g O 4 v8 It is noted that the NRC SCVI in these areas of limited CSA scope did not identify significant hardware deficiencies in the samples that were inspecte In general, where the concerns identified by the CSA team warranted a corrective action plan, the plan identified the requirements necessary to resolve the Concern In summary, the Delian CSA effort provides for an additional measure of assurance of the quality of construction at the Wolf Creek Generating Station except for the areas identified above and as further clarified in the following summary of . areas inspected and result AREAS INSPECTED AND RESULTS Electrical and Instrumentation Construction In general, the CSA effort was sufficient in scope, completeness, and independence, and adequately categorized the seriousness of findings. The
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effort provides an additional measure of quality of construction in the areas .
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of cable raceway, electrical equipment, and instrumentation. Only one area, cable and cable terminations, did not provide an additional measure of quality due to the limited scope of the CSA effort for this are In this area, the CSA scope did not include specific cable samples for inspection . and their sample for electrical terminations was limited to a specific plant *
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location. Independent SCVI findings were also identified in this are , .
, A review of selected CSA concerns indicates that CSA findings were categorized i based on their importance, and hardware deficiencies were linked to QA and QC I program weaknesses where appropriate. When the concern warranted a corrective i action plan, the CSA plan generally identified the requirements necessary to resolve the findings. The one exception was the lack of attention given the significant number of concerns regarding flexible conduit deficiencie , .
j During the assessment of the CSA effort, several additional items which required 4 resolution were identified by the NRC SCVI. These included: deficiencies in G cable rollout support and minimum bend radius found to be generic; several I deficiencies were found in a previously inspected, repaired and reinspected -
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tubing run; and several installations of nonsafety conduit based on the detail drawings are in conflict with the FSAR commitment for divisional separatio Mechanical Construction
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The CSA effort in the area of mechanical construction appeared sufficient in scope, completeness, and independence. The CSA team adequately categorized the
' importance of their findings. Due to absence or adequacy of data being collected
, and compared with specified requirements for equipment FSAR comparisons, the j additional measure of assurance of quality in this area was margina The CSA evaluation of the more significant individual findings is reflected in the identification of several generic concerns. A review of the generic concerns that developed in this area indicate that the CSA effort appropriately linked the collection of specific deficiencies to the need for corrective action on a broader sense as shown by their proposed action plan ' A-2
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{ .; , . Welding and NDE In general, the CSA effort was acceptable in terms of independence, scope, completeness, characterization of findings and the conclusions reached with a few exceptions. The effort provides an additional measure of quality of
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construction in the areas of welding and NDE. The exceptions were failure
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to physically inspect structural welds, lack of written inspection criteria and procedures for inspection of vendor welds, and failure to detect a discrepancy in the identification of material thicknes , A review of selected CSA concerns indicates that the CSA findings were categorized based on their importance, and hardware deficiencies were linked i to QA and QC program weaknesses where appropriate. When the concern warranted 1 a corrective action plan, the CSA plan generally identified the requirements 4 necessary to resolve the finding $ Reinforced Concrete and Structural Steel Construction
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Based on the NRC SCVI effort sufficient independence of the CSA effort in _ 1 this section was apparent. A limited additional measure of construction
' quality resulted from the CSA accomplishment as determined from the following:
l the CSA scope of effort was minimal for the assessment of reinforced concrete ] and structural steel; in general the CSA task in this area was somewhat lacking .
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in depth of review; and no concrete expansion anchor bolts were inspecte . j Independent samples inspected by the SCVI team did not reveal any hardware . I deficiencies except for insufficient minimum embedment for concrete anchor ij bolts around the perimeter of a safety injection accumulator tank.
1 Three of the.four CSA concerns in this section were appropriately categorized for level of seriousness'and were adequately dispositioned. The remaining
'. one is addressed in Enclosure ,
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; Material Traceability and Maintenance In general, the CSA inspection effort.in the area of material traceability, )j was limited to verification of documentation data requirements of sampled 1 CMTRs which were not compared to installed components. As such, the CSA effort
?! does little to assess the material traceability quality of construction d installations or support the CSA conclusion of adequacy for this area. Several d material traceability CSA concerns that were identified in other parts of the L CSA report should have been addressed in the conclusions of the Material y] Traceability section of the report. Each of these items indicated some M degree of a loss of material traceability and control. Independent NRC 3 SCVI inspections accomplished to further assess the CSA effort, revealed that, 2 in general, material traceability and control documentation was accurate and d agreed with hardware conditions except that a few deficiencies were found q regarding safety-related fastener ; In the area of maintenance, the CSA effort was limited to an examination of Newport News, Inc. (NNI) and did not result in any concerns. The CSA effort did not address the nature and quality of maintenance performed by DI ,
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Although the CSA report indicated that the maintenance effort (by NNI) was acceptable, many CSA concerns identified by other disciplines were found to be maintenance relate ' * A-a
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Quality Assurance The CSA effort in this area was found to be generally acceptable in terms of independence, scope, completeness, characterization of the concerns identified and conclusions reached. The one exception in this area was the CSA review of FCRs which was considered marginal based on the results of the KG&E audit TE:57062-K11 In general, the scope of current CSA Phase II corrective action plans for CSA generic concerns 159, 160, 161 and 170 and corrective action discussed in referenced CARS or other documents are considered adequate for achieving required corrective action, except for a few limited areas identified in Enclosure C, Unresolved Item Based on NRC observations of the CSA report effort in this area, an additional . measure of assurance of quality was achieved. Additionally, a significant ? additional measure of assurance of the quality of construction will be achieved with the effective implementation of the CSA/KG&E Phase II followup corrective y action for CSA concerns 159, 160, 161, and 17 .
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ENCLOSURE B p0TENTIAL ENFORCEMENT ACTION
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a As a result of the NRC special construction verification inspection of the Wolf Creek Generating Station, the following finding has been identified as
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subject to potential enforcement action: 10 CFR Part 50, Appendix B, Criterion III requires that applicable regulatcry
' . requirements and the design basis, as defined in 10 CFR 50.2 and as specified in the license application, are correctly translated into specifications, drawings, procedures and instruction t I 10 CFR 50.2 defines " design bases" as that information which identifies the -
specific functions to be performed by a structure, system, or component of a facility, and the specific values or ranges of values chosen for controlling j parameters as reference bounds for desig _ Section 8.3.1.4.1.1 of the license application specifies that cables from 4 different separation groups will, in accordance with IEEE Standard 384-1977 practice, be in steel conduit or enclosed raceway or separated by a fire barrier when the normal 5 foot and 3 foot horizontal separation cannot be * maintaine . Section 8.1.4.2 of the license application specifies that deviations from
the IEEE Standard 384-1977 practice which reduce the minimum spatial separation
] between circuits be supported by analysis and, in accordance with the specified Regulatory Guide 1.75-1974, be considered part of the licensee's applicatio t, Contrary to the ab'ove, a number of non-safety conduits to safety cable ,
trays and cables exiting the trays did not meet the spatial requirements e for cables from different separation groups, in accordance with Bechtel Drawing E-1R8900, nor was such deviation supported by an analysis, as specified I in the license applicatio Details of this finding are discussed in Section III.B.1.b.(2).(e) of this j repor I i
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ENCLOSURE C UNRESOLVED ITEMS As a result of the NRC special construction verification inspection of Wolf Creek Generating Station, a number of findings were made that require further action by Kansas Gas and Electric Company before the NRC can determine their significance. These findings, listed below, will be followed by NRC Region IV as unresolved items (section references are to the detailed portion of the Inspection Report).
' Two areas of minor deficiencies identified by the NRC SCVI were verified by DIC to be generic and require further action by them to correct
, existing deficiencies and prevent future deficiencies from developing: > the securing of cable at raceway rollouts, and minimum bend radius for '
cable transfering from tray to conduit. [Section III.B.1.b.(2).(a)] Three areas involving the incorporation of inspection criteria or the recording of inspection criteria were noted and require additional review .' by the licensee for resolution: -
! No requirement for consideration of concrete spalling in obtaining
' and verifyin expansion anchor minimum embeament. [Section III.B.1.b.(2 .(d)] Request for Clarification or Information 21D-7158 regarding Unistrut installation inspection provides an accer table condition for sidewall ; deflection which has not been incorporated into the inspection f criteria. [Section III.B.1.b.(2).(d)]
i Generic Resolution F-014 does not require documenting acceptance
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criteria drawing and specification numbers and revisions on the QC checklists although required to do so by the QC procedure [SectionIII.B.3.b.(2).(c)]
' The acceptability and generic implications of vendor termination lug bending, as found in panel RP-210, requires additional licensee evaluatio [Section III.B.2.b.(2).(b)] Two items found on the rack for battery NK-12 require additional evaluation '
to determine acceptability and generic implications: the actual torque values of the brace pad bolt assemblies, and quality of the rack plug weld [SectionIII.B.3.b(2).(c)] The reinspection of welds in accordance with the criteria referenced on Bechtel purchase orders, not used in the CSA, is required to provide a basis for implementation of corrective action. This should be done
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following the removal of paint from the welds or following an engineering evaluation of the acce)tability of the method of inspection of vendor welds through paint. :Section V.B.2.c] KG&E needs to contractually delegate responsibility for the use of written procedures and criteria that would alleviate organizational disagreements concerning implementation of corrective actio [Section V.B.2.c] - l As a result of the independent SCVI team review of the . Dravo film, 33 film packets were found to be marked with a material thickness different
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from that shown on the reader sheet. [Section V.B.3.c] A review of concrete batch ticket records identified a deviation from ] contractor ANSI N45.2.6 requirements in that a Level I rather than a Level II qualified inspector evaluated the results of inspections by a '
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Level I inspector. [SectionVI.B.1.b.(2).(c)] l The CSA evaluation and disposition for CSA concern #55 relative to the . ] attachment of non Q field routed tubing to a Q whip restraint did not
; consider loading from the tubing attachment and whether there was an ! adequate program for control, design evaluation and as-builts of tubing ! attached to Q supports. [SectionVI.B.2.b.(2)] ; 10. Bechtel Drawing C-1C2411, Revision 0. Detail I requires the projection * ; length of concrete anchor bolts to be 7" above the underside of the .
top flange of the safety injection accumulator tank (#TEP-01A) base J frame. According to DIC personnel present at the time of the SCVI, a
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z3/8" tolerance was allowed, permitting the total maximum projection l length to be 7-3/8". The inspector (s) found that six out of the twelve
- embedded concrete anchor bolts had projections above the top flange greater , than 7-3/8" which exceeds the maximum allowable. [SectionVI.B.3.b.(2)]
i 11. The material traceability for cabinet to cabinet fasteners for Motor
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i Control Centers NG01A, NG01B, NG03C, NG030 and NG04C could not be t established due to lack of required traceability markings and were y also either missing or were improperly installed. [SectionVII-2.b]
! 12. The material traceability of battery rack NK12 fastener assemblies could i not be established due to lack of required traceability markings or because
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J [Section VII-2.b.
a !! 13. High strength steel anchor bolts for main coolant pump and steam generator
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supports were made of indeterminate material. [Section VII.2.b]
~, 14. Safety Injection Accumulator Tanks TEP-01A and TEP-01B had anchor bolt
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nuts installations not in accordance with drawing requirements. [Section VII.2.b]
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15. An acceptable resolution of TE:57061-K111, Design Control audit findings
]ertaining to DIC implementation of Field Change Requests is neede .
:Section IX.B.2.b.(2)]
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16. The CSA evaluation of KG&E response to CSA concern #159 needs to address and resolve the differences in the KG&E and CSA count of audits not conducted, including any pertaining to audit of construction activities performed by other than DIC. The CSA evaluation should also review the adequacy of KG&E's response on the impact of not conducting audit ' TE:57061-K111 on schedule has on the assurance of quality of construction prior to plant operation. [Section IX.B.2.c] 17. The KG&E evaluation of SFR 1-88-147 for reportability to the NRC and of the relatec controls for the tighten of termination lugs during installation is identified for review. [SectionIX.B.3.b.(2)]
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18. The CAR #18 ano the CSA concern #160 action plan should be revised to ' incluoe additional clarification of intended corrective action require-ments involving SFRs for resolution of " design errors" or without
" identifiable or retrievable documentation". [Section IX.B.3.b.(2)]
19. Appropriate revision of procedure ADM 14-416, Rev. O is required to prevent recurrence of deficiencies in the use of NDCs of the type _ discussed in the KG&E report KQWLO 84-134 [Section IX.B.3.b.(4)] ,
: 20. KG&E should audit a sample of NCRs issued after the close out of NDCs !
for' compliance with procedure AP-V1-02, Section 3.30 provisions of .
" prior to and after N-stamping" of ASME systems / components. [Section IX.B.3.b.(4)] l , '
j 21. The KG&E/CSA corrective actions should ensure that the KG&E program for identification and review of deficiencies for reportability to the NRC is being implemented in a timely manner for: SFR or NCRs checked
, "potentially reportable"; and for deficiencies in construction which a
could have gone unoetected due to the breakdown in the SFR QA program, ds identified by the TE:50140-K003 Design Control audit. [Section IX.B.4.c.]
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT NRC Inspection Report: 50-482/84-51 Construction Permit: CPPR-147 Docket: 50-482 Category: A2 Licensee: Kansas Gas and Electric Company (KG&E) P. O. Box 208
: Wichita, Kansas 67201 '
Facility Name: Wolf Creek Generating Station
; Inspection At: Wolf Creek Site, Coffey County, Burlington, Kansas : ; Inspection Conducted: October 23 through November 2,1984 Inspectors: IIf /E t h '<
M. W. Peranich (Team Leader), Chief, Construction
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, Progr s/ CAT Secti
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' F. i , ~R tor Construction Engineer Date b , izio/fy : . ,r, r. Re ctor Construction Engineer Date '
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/Al/ol R. L. Cilimberg, Ne lurgical Engineer Date
}/$lb J T. K. McLellan, Reactor Construction Engineer
/2//ellY Date j
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- j R. L. Lloyd, Reactor Construction Engineer Date
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] J. <l. Nemoto, Reactor Construction Engineer Date
l' Contractor Consultant - M rmack, G. Black, J. Dever t h Approved by: . ,) 5> - Robsrt F. Heishman, Chief
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n Reactor Construction Programs Branch i l Inspection Sumary l[ Areas Inspected u Announced special construction verification inspection for an assessment of
, the Delian Corporation Construction Self Appraisal (CSA) and related followup l
corrective actions was conducted. The inspection involved 760 inspector-hours onsite by ten inspector '- 7-/ , g['f'
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Results l The results of the special construction inspection are discussed in each
- section of this report. The deficiencies and unresolved items identified
< during the inspection are summarized in enclosures to the transmittal letter of this repor r! > 4 ., *r p -
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TABLE OF CONTENTS TOPIC SECTION Inspection - Background, Objective and Scope .................. I
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The KG&E and Delian Relationship .............................. II , Electrical and Instrumentation Construction . . . . . . . . . . . . . . . . . . . III
Me chan i cal Cons tru cti on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV Welding and Nondestructive Examination (NDZ) . . . . . . . . . . . . . . . . . . V r:
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Rei nforced Concrete and St ructural Steel . . . . . . . . . . . . . . . . . . . . . . VI
. , . Material Traceabili ty and Mai ntenance . . . . . . . . . . . . . . . . . . . . . . . . . VII i
a Qual i ty Control Effectivenes s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VIII
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Quality Assurance ............................................. IX . i - i, * I Attachment A - Persons Contacted
] Attachment 8 - Glossary of Abbreviations :
Attachment C - CSA Status Summary
{ Attachment D - Status of CSA Generic Concerns
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I. BACKGROUND, OBJECTIVE AND SCOPE Background The Kansas Gas and Electric Company (KG&E), as lead applicant for the Wolf Creek Generating Station (WCGS) contracted with the Delian Corporation (Delian) for a Construction Self Assessment (CSA) of the WCGS. This assessment was performed from June through August 1984 and the Delian CSA report was transmitted to KG&E on August 28, ,; 1984. The objective of the CSA as stated in the report was to
" provide an independent evaluation of the construction at Wolf Creek ; with primary emphasis on hardware inspections similar to the Nuclear Regulatory Connission (NRC) Construction Appraisal Team (CAT)
inspection."
i The independent CSA effort was originally planned as preparation' for i an NRC CAT inspection which KG&E found later would not be conducted.
1 KG&E was aware that there was no requirement under NRC regulations 1 to conduct a CSA but decided to proceed on a voluntary basis with the . l} CSA initiative in the interest of providing additional verification of the quality of construction at the WCGS.
}
'
Following completion of the Delian CSA effort, KG&E provided the CSA . report and the KG&E pending corrective actions to the NRC Director,
. Wolf Creek Task Force, Region IV as further assurance of the quality *
r of construction for the plant. The NRC Director, Wolf Creek Task . j Force asked the Director, Office of Inspection and Enforcement (IE) i for assistance of NRC CAT personnel in assessing the adequacy of the
- ) Delian CSA effort and of related ongoing corrective actions.
J , 'i A team of IE staff and NRC consultants was formed to conduct the requested special construction verification inspection (SCVI). The
. NRC Director of the Wolf Creek Task Force requested that the scope of the SCVI address the following matters:
q An assessment of the Delian Corporation effort and report for independence, scope adequacy to achieve the stated objective, " accuracy of inspection .results, completeness of inspection and h report, appropriate categorization of deficiencies as to their " level of seriousness, and appropriateness and justification of conclusions. To the extent that it is practicable, the special
"
inspection should, by sample, verify the conditions identified by the Delian Corporation.
3 . An assessment of the KG&E response to the Delian Corporation report to determine if corrective measures are appropriat The NRC Director, Wolf Creek Task Force also provided IE with copies ,, of the Delian CSA report and current KG&E information on status of ^ corrective actions for use in preparation for the SCVI. KG&E also informed the NRC Director, Wolf Creek Task Force that all documenta-tion (specifications, procedures, drawings and other documents) used to conduct the CSA would be available in Delian files onsite for NRC review and use in conducting the SCV * I-1
.- . - . . . . . . , . . , , , . , ,.,.__m,,_,. y .. , .... _ , _., s . .,
. . _ - - - . . .= .- . __- - * .. l On October 23,.1984 the NRC SCVI team held an entrance meeting with the applicant and contractor representatives. Enclosure 1 of this section includes an attendance list. The entrance meeting was held
- to clarify in general terms the purpose and scope of the special NRC inspection and to obtain additional information for the inspectio The information presented by KG&E and Delian during the meeting included: Status Briefing on CSA and Associated Corrective Action Program; Statusing (and Table of Resolution) of CSA Concerns; for each CSA discipline team, a listing of the CSA team leader and KG&E and contractor support team members (Enclosure 2); the resumes of Delian CSA team leaders; and assigned DIC Contacts'. KG&E acknowledged the request that the NRC team be provided with periodic information on the status of the Delian Phase II CSA ni corrective actions for the 155 specific and 15 generic concerns ']; (Enclosure 3). Examples of status information received and used by
'
the SCVI team in the assessment of the Delian Phase II CSA corrective
,i action effort are attached to this report. This includes: Attachment a C, CSA Status Sumary of-Case Specific Concerns and Generic Concerns; Attachment D, Status of CSA Generic Concerns; Attachment E, Table
-
J j of Resolution of CSA Concerns, Rev. 8, dated 11/01/84, page 1-1 Primary KG&E contacts for the NRC inspection were R. Grant, Director
<
of Quality and C. Parry, Superintendent of Quality Systems Engineering.
.. -d Enclosure 4 of this section lists DIC contacts for the NRC review of . the CSA effort. A first day review of Delian CSA files found that o certain documents (specifications and procedures, in most part) had j been returned by Delian to KG&E or contractor organizations. Also, d the SCVI noted that " backup" documents (NCR's, CARS, audit reports, j etc.) needed for the SCVI (and Delian) to evaluate the adequacy of corrective action being taken by the reference " closeout document"
.; (see Attachment C) for each CSA concern was not included in the CSA
] files. KG&E took immediate action to provide the SCVI team with all 3 necessary documentation, including the requested duplicate set of ' Delian CSA file folders for each of the 155 specific and 15 generic d' concerns identified as a -re'sult of the CSA effort. KG&E also provided M Delian with a set of " backup" documents provided to the SCVI team.
3 Generally, all requested documentation needed during the SCVI to d complete the planned assessment was provided by KG8E during the j course of the inspection.
v
.. On November 2,1984 an NRC exit meeting was held with the applicant l and contractor representatives. Enclosure 5 of this section includes
- j the attendance lis n 1 The exit meeting was held primarily to inform the applicant of
'
deficiencies identified during the SCVI which may need imediate attention, to acknowledge applicant QA Manager comitments for 1 ensuring the effective control and implementation of the CSA corrective action program, and to note that the assessment of the e CSA effort and followup corrective actions and resulting conclusions would be based on a review of the findings of the SCVI and would be documentad in the inspection report. The applicant was also , , I-2 *
'
,
.
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* " . , , ' informed that the NRC viewed the CSA initiative as a positive action towards providing an additional measure of the quality of construction at Wolf Cree Inspection Objective and Scope
~ The objective of the special construction verification inspection was to assess for areas sampled the extent the CSA effort and followup s corrective actions provide an additional measure of assurance of the quality of construction at Wolf Cree The scope of the special construction verification inspection included a review of the CSA report; a reverification of a representative sample of hardware and associated records examined by the CSA effort and of similar or other items not included in the , CSA sample; and a discipline review of the ongoing corrective action i program for resolution of the 155 specific and 15 generic concerns j .. resulting from the CSA effort. Additionally, interviews were ! conducted with designated CSA discipline team leaders, KG&E Quality ~ l Assurance personnel and other support contractor personnel.
) The areas for which NRC selective examinations of the CSA effort and related corrective actions was conducted include: , ] _
* Electrical and Instrumentaticn Construction ;
.
.
1 Mechanical Construction i f * Welding and Nondestructive Examination s
'
* Civil and Structural Construction Material Traceability and Maintenance
-
* QC Inspection Effectiveness Quality Assurance i
.
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~ ENCLOSURE 1 ..
OCTOBER 23, 1984
. '
USNRC ENTRANCE MEETING L ATTENDANCE SHEET i
' ,
e Kansas Gas and Electric Company J
'
F. Duddy, Project Director P. Dyson, Supervisor Field Engineering
; G. Fouts, Construction Manager ?; R. Grant, Director - Quality i C. Hoch, Quality Assurance - Technical ,
j G. Koester, Vice President - Nuclear . L! W. Lindsay, Quality Systems Supervisor 1 0. Maynard, Licensing Supervisor C. Parry, Superintendent - Quality System Engineering
^
.
E. Peterson, Quality Assurance Technical Auditor W. Rudolph, II, Manager - Quality Assurance :
.
Kansas City Power and Light Company
-.
n- R. Flannigan, Site Representative .
.
l
;j Daniel International Corporation
j J. Berra, Vice President
'f P. E. Halstead, Project Manager ld -
Delian Corporation 3] 1 B. Carter, CSA Team D. Leaver, CSA Team 1]; B. Palmer, CSA Team is F. Pimentel, CSA Team El C. Thompson, CSA Team 'd H. Wong, CSA Team p G. Young, CSA Team n j Bechtel J II C. Herbst, Assistant Project Engineer G. Stanley, Assistant Project Manager
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. NRC and Consultants
.
G. Black R. Cilimberg
' ' G. Gower -
W. Gu ldemond
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R. Lloyd-
... . J. McCormack ' T. McLellan L . J. Nemoto .
i M. Peranich S. R. Stein R. Taylor-
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, Figure I-1. CSA Teani Drganizallonal Interfaces
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l ENCLOSURE 3 l CSA RESULTS OF INSPECTION j l l
* 155 SPECIFIC CONCERNS RESULTED FROM INSPECTIONS ?
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I + WELDING 24
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+ INSTRUMENTATION 9 f + CIVIL / STRUCTURAL STEEL 3 , + MECHANICAL EQUIPMENT 4 i
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[i 15-GENERIC CONCERNS RESULTED FROM SPECIFIC CONCERNS AND CONCLUSIONS.
d 0F CSA REPORT
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ENCLOSURE 4 DIC CONTACTS FOR NRC REVIEW 0F CSA o
'
DISCIPLINE NAME
:
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*Phillip Halstead
.i
.
] Civil Frank Raycher
':
j 1 Piping / Welding Johnny Hanvey Mechanical /HVAC Leon Payne
'
).i Electrical Shelton King
.I Pipe Supports Harold Kubasek
.j-Quality Lew Easterwood
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* Contact to arrange alternates if above listed people are not availabl .
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ENCLOSURE 5
.
NOVEMBER 2, 1984 USNRC EXIT MEETING ATTENDANCE SHEET <
. Kansas Gas and Electric Company
. P. Dyson,. Field Engineering Supervisor 3- R. Grant, Director - Quality
. C. Hoch, Quality Assurance - Technical W. Lindsay, Quality Systems Supervisor j C. Parry, Superintendent - Quality Systems Engineering .
i E. -Peterson, Quality Assurance Technical Auditor i W. Rudolph, II, Manager - Quality Assurance Daniel International Corporation .
* .
J. Berra, Vice President , j P.- Halstead, Management Consultant . Delian Corporation l * B. Palmer, Consultant f g H. Wong,' Consultant
'
G. Young, Consultant j NRC and Consultants f- G.' Black i R. Cilimberg j J. Devers-4- G. Gower i W. Guldemand
: R. L1oyd 4 J.' McCormack
- T. McLellan
-
J. Nemoto l M. Peranich S. Stein
. ,
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II. THE KG&E AND DELIAN RELATIONSHIP Objective The objective of the special construction verification inspection (SCVI) in this area was to assess if the work, authority, and independence delegated to Delian by KG8E were sufficient to achieve the objective and scope of work as stated by the Delian CSA report
, ,
and for the followup corrective action Discussion
'
The objective and scope for the Delian Phase I CSA effort are provided de on page I-1 and I-2 of the Delian CSA repor .; ij Delian presented information on the objective and scope for the Delian-l-M Phase II CSA followup corrective actions to the NRC SCVI team during the October 23, 1984 entrance meeting. - In general, these activities - 1 were characterized as a third party evaluator of corrective actions, _
- d including: the identification of appropriate corrective actions; a evaluation of the adequacy of corrective action responses; and the verification that corrective actions are complete and adequat ~'
The Delian Phase II CSA corrective action process would address most
! of the 155 specific concerns through the utilization of normal quality -
4 programs of the responsible organization. CSA forms would be used to e
;: document the CSA evaluation and verification of the closure of the CSA -
concer 'i q, For the 15 generic concerns and a few of the more significant specific 4 concerns, the Delian Phase II CSA corrective actions will be accomplished _N by the implementation of CSA established action plans and through the
;i corrective action programs of each responsible organization. The .3 results would also be documented on CSA Corrective. Action Verification and CSA Closure Fonn .x Delian Phase I CSA B
3 Inspection Scope
'$ ) The inspection in this area consisted of a review of KG&E/Delian contractual documents and of the objective and scope of work bj stated in Section I of the CSA report. Discussions were also held with the KG&E Director of Quality and Quality System
- fj4 Engineering Superintendent and Delian CSA personnel. A review 1p of observations and findings of the NRC SCVI for each area were also examine
- * Contract and related letter agreement documents reviewed y include:
,, ,j * KG&E Purchase Order (PO) No. 45606, including the referenced scope of work letter dated June 28, 1984 from Delian to o KG& *
*
11-1 ,
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'
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.
KG&E letter dated August 1,1964, KG8E to Delian (KQLO 84-015).
. Inspection Findings (1) Contractual Arrangements A review of KG8E/Delian contract documents found that generally adequate provisions did exist to provide Delian with sufficient authority, independence and scope of work to achieve the CSA objective and scope of work as stated in Section I of the Delian CSA repor f_ (2) CSA Implementation
,
The SCVI assessment of the 'CSA effort for independence, scope and completeness of work is discussed in Sections III through Section IX of this report for each area inspected. ~ _In general, NRC -inspector conclusions in this
;
regard reflect that the level of independence and authority delegated by KG&E to Delian for performance of the CSA l- was adequately implemente This conclusion is also based on NRC inspectors' observations . during the followup inspection of identified CSA concerns which
,
noted a general disagreement between DIC and Delian personnel regarding the merit of the concerns identified by the CSA and -
; also on the corrective action being directed by Delian. These i observations generally support a conclusion that the CSA concerns L were independently documented by CSA, regardless of the potential l for disagreement by a DIC CSA discipline team member, y '
Only a few SCVI observations raised some question on-the adequacy of the independence of the CSA effort. These generally related
' to inadequacies in the scope of the CSA inspection effort for areas P such as welding of structural steel connections (Section V.B.1.b),
F bolt torquing at the limited 80% design value-(Section IV.B.3.b), s
: and material traceability documentation (Section VII.B.1.c).
i1: - Conclusion l' Our overall assessment is that the CSA effort was generally conducted and reported in accordance with the independence, f authority, and work provisions established in contract document ; It is also our overall assessment that the CSA cbjective to evaluate the adequacy of construction was generally achieved i[ for the scope of the CSA review. In the following areas the
; CSA effort fell short of providing additional assurance of the , quality of construction to the degree indicate t noted below: ; (1) The CSA ins section sample for electrical terminations was marginal. :Section III .B. .2. c ]
II-2
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' . l (2) The CSA effort for the comparison of mechanical equipment nameplate data with FSAR specifications was margina [SectionIV.B.2.c.] (3) The CSA effort for inspection of structural steel welding was insufficient. [SectionV.B.1.c.]
. (4) The CSA effort for inspection of vendor welds was t insufficient. [SectionV.B.2.c.] l-
' (5) The CSA effort for reinforced concrete was margina [SectionVI.B.1.c.] (6) The CSA effort in material traceability was insufficien [Section VII.B.1.c.]
.
' (7) The CSA effort for verification of maintenance requirements
] was marginal. [SectionVII.B.3.c.] l Phase II - Corrective Action Followup j- Inspection Scope The inspection of this area consisted of a review of KG&E/Delian
; contract documents; a review of the information on the scope of .
the Delian Phase II corrective actions; NRC discussions with KG&E, a jl Delian and DIC personnel; NRC observations of Delian ongoing i Phase II activities, documentation and procedures; and a review of KG&E's QA program for monitoring ongoing Delian and DIC
.
corrective action activitie Contract and related letter agreement documents reviewed
include:
* KG&E P0 45606 and referenced Delian to KG&E j letter dated June 28, 198 * KG&E to Delian letter dated August 29, 1984
- (KQLO 84-016).
1 * Purchase Requisition No. 35983 dated October 31, il 1984, to add supplemental scope of work to .1 P0 45606.
ij ' CSA Concern Closure Fonn Instructions with Form, j Undated, and acquired on October 23, 1984.
- 3
- * Delian Corporation's Construction Self Assessment
} (CSA) Procedure, Rev. O, dated October 29, 198 * Delian Corporation Construction Self Assessment . (CSA) Procedure, Rev. 1, dated November 1, 198 ' ' KG&E QA Manual Procedures !
A l
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11-3
!
1, , - . . . . . . . r . ,
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-
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CSA Concern File Folders and Contents, including original and subsequently updated CSA Concern Closure Fonns and CSA Corrective Action / Verification Form Inspection Findings (1) Contractual Arrangements The initial NRC review of KG&E and Delian contract documents and related letter agreements and initial observations of
*
Delian implementation of delegated Phase II activities (as discussed under (2) below) found that the contract scope and other related instructions did not provide for sufficient clarification of Delian er KG&E responsibilities in this a rea. This finding was satisfactorily resolved by KG&E's issuance of purchase requisition No. 35983 to supplement the scope of work of P0 4560 (2) Delian Phase II CSA Implementation .
, Delian Phase II CSA activities are described as consisting of the control and management of corrective actions and the closure of CSA concerns. Delian initiated the pre- .
Ifminary onsite administrative aspects of the Phase II * effort during the first week of October 1984. The Delian CSA team members arrived on. site during the week of a i October 14, 1984 to start the technical reviews of the i Phase II effor ;
; As a result of NRC team member interviews with Delian CSA team' members and the review of Delian documentation relative to ongoing CSA team member technical evaluations, it was determined that current Delian instructions for CSA conduct of the Phase II effort were inadequate and there was insuf-ficient assurance that these activities would be adequately controlled and documented. NRC discussions with KG&E 3 and Delian in this regard resulted in the resolution of i this finding by the issuance of a comprehensive Delian ! Corporation procedure (Rev. 1, dated November 1, 1984) ! delineating how the Delian Phase II CSA corrective action i activities are to be conducted and documented. KG&E also acknowledged that their review of the procedure found the instructions acceptable as related to documentation . required : by KG&E as objective evidence that the CSA specific and '
generic concerns have been adequately addressed. Further, KG&E acknowledged that Delian would be required to perform l a reevaluation of all Phase II CSA technical activities
; conducted before November 1, 1984 to ensure that CSA individuals with appropriate expertise performed required technical reviews and that all such activities are
-; documented in accordance with the instructions of the November 1,1984 procedure.
.
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II-4 7-
- -- - - .- , - .. - .,s ..-,,-.,7
* ?. . (3) KG&E Participation, Audit or Surveillance of Corrective Action Activities Early during the NRC inspection, KG&E was not planning to conduct QA audits, or surveillance, of ongoing Delian Phase II " independent evaluation" of corrective actions. The initial KG&E involvement with the Delian Phase II effort was generally limited to support provided by the onsite QA Superintendent in arranging meetings between Delian and Contractor, in review of Delian/ Contractor action plans of proposed corrective action for CSA generic concerns, and in resolving any disputes resulting from such meeting NRC initial findings relative to matters listed below were presented to the KG&E Director of Quality as the basis for the NRC concern that currently planned KG&E surveillance '
of ongoing Delian or DIC corrective action activities were not sufficient, under existing conditions, to satisfy i KG&E's responsibilities for delegated activities. The - matters discussed were:
]
I (a) Procedures for control of Delian Phase II CSA activities 1 and KG&E assurances of CSA implementation in this are *
, (b) KG&E's near term schedule for fuel loa *
l j (c) NRC inspector observations of the prevalent difference of j opinion between Delian and DIC personnel regarding the j merit of Delian Phase I CSA concerns or the Delian Phase II proposed action plans for resolution of CSA generic
' ,
concern The following clarification by the KG&E Director of Quality of KG&E's commitments for ensuring that all Delian corrective action activities are established and implemented in an effective manner was provided.
] "KG&E QA is involved in determining appropriate 1- corrective actions for the " Generic" CSA concerns a because they represent program level problems.
lj *
"KG&E will approve the Delian procedure used to ; implement phase II of P.O. 45606 (i.e., verification l of Corrective Actions).
a
*
4 "KG&E Quality Evaluations group to perform an audit i * or surveillance to verify Delian compliance with the KG&E approved procedur ,
"KG&E Quality Systems will perform a review of all 3 Delian Corrective Action Packages'to ensure all
! required corrective actions have been completed, verified and documented by the CSA and the audited organization ,
'
.
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"KG&E Quality Systems will ensure all applicable documentation related to the CSA inspection, findings and corrective actions are retained in a useable form as QA Records in accordance with applicable site procedures."
In regard to the NRC question on how KG&E would ensure the'DIC. effective implementation of Delian corrective action plans, KG&E's commitment in this regard is generally summarized as follows:
*
KG&E will utilize its existing contractor surveillance program to ensure Delian action plans for the resolution of CSA generic concerns are effectively implemented by DIC, including v review or observation of the method DIC utilizes ? to select any expanded sample requested by the
-
Delian action plan'to assess the extent of a CSA generic concern.
l
, Conclusion
, The above KG&E commitments are considered an acceptable resolu-tion to NRC questions on the means that KG&E will utilized to * ensure the effective implementation of corrective action
~
] . ) activities delegated to either Delian or DI * n f i ) l I
. !
, t
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*
II-6
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* ' . .
III. ELECTRICAL AND INSTRUMENTATION CONSTRUCTION Objective The primary objective of the NRC special construction verification inspection (SCVI) was to assess the extent the Delian Corporation's Construction Self Assessment (CSA) effort and followup corrective
, action, for the area of electrical and instrumentation con:truction, .
provide an additional measure of assurance of the quality of
! construction at the Wolf Creek Generating Statio } Discussion i The report from the CSA inspectiun effort was reviewed to determine the scope of inspections for electrical raceway, cable and equipment, ,
instrumentation, and instrument tubing. A sample of the CSA effort, .s~ from Tables 11-1 and II-3 of the CSA report, was selected for examina-tion. The SCVI sample included some areas in which CSA identified .i specific and generic concerns and some areas in which no concerns were .
-
identified. In several' areas the examination also included samples
; outside the CSA effort to provide an additional basis for evaluation j of the overall Delian effor .
'
'
The CSA report and a selection of the 60 electrical and instrumentation
'
concerns were evaluated for the adequacy of scope, independence, ; completeness, the appropriateness of the CSA deficiency categorization . as to the level of seriousness, the overall conclusions and basis for the conclusions and adequacy of corrective actions. Discussions with onsite Delian, Kansas Gas and Electric Company (KG&E) and contractor personnel as well as the results of the SCVI inspections were taken into consideration for the overall evaluation of the CSA d- effort.
j ~ Electrical Raceway Inspection Scope Ten segments of cable tray totaling 300 feet were selected from the CSA sample of 720 feet. An additional 200 feet of 1 these same tray segments, which were adjacent to and not included 4 in the CSA inspection, were selected for examination. These 1 segments, previously inspected and accepted by the licensee, i were examined for compliance to licensee commitments relative to routing, location, support spacing, separation, bedding, l] identification, loading, physical condition, completeness, and y) protection, p 4 Five segments of conduit totaling 250 feet were selected for i examination from the CSA sample of 800 feet. These segments,
; previously inspected and accepted by the licensee, were examined *
for compliance to licensee commitments relative to routing, location, support spacing, separation, identification, complete-
:
ness, and physical conditio ,
*
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. _ _ _ - _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ . _ __ - __ ._ .
*
. l Thirteen raceway supports associated with the above electrical raceway, and four additional supports identified by CSA concern numbers 24 and 25, were examined for compliance to licensee commitments relative to location, spacing, material type and size, configuration, attachments, and where applicable, bolting and weld appearance and configuration. The four additional supports were also examined for the completeness of corrective action as identified by the CSA effor For a listing of the electrical raceway and supports examined, see Table III-1.
l The following documents provided the acceptance criteria for the NRC SCVI team examinations and revie , * Wolf Creek Generating Station Final Safety Analysis l- Report-(FSAR)
* Bechtel Power Corporation Specification E-01013, Rev.11, ; " Electrical Installation, Inspection and Testing"
, * Bechtel Power Corporation Drawing E-1R8900, Rev. 2,
" Raceway Notes, Symbols and Details" * Daniel International Corporation (DIC) Construction :
i Procedure QCP-X-300, Rev. 14 " Inspection of Electrical * Raceway" ! * DIC Construction Procedure QCP-X-302, Rev. 19, l " Inspection of Raceway Supports"
* DIC Construction Procedure QCP-X-304, Rev. 7,
- " Inspection of Cable Installation" Inspection Findings g In the area of electrical raceway and supports, the NRC SCVI ' inspectors observed that material and installation methods t used were generally as specified in the licensee commitments.
f However, several construction and inspection deficiencies were identified in both the CSA sample evaluated and the independent '
- . SCVI sample and are detailed in the following sections.
i (1) CSA Report Review
The scope for inspection of cable tray does not appear ' sufficient. A discrepancy between the CSA report text - and the listing of samples (CSA Table II-1) indicates i that their sample of tray may have been as little as 120 feet. The physical selection may have also been insufficient as a number of SCVI findings were in elbow sections imediately adjacent to the CSA samples which were predominantly the straight runs of the tray selecte , 4 4 III-2
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Excluding the limited scope of cable tray inspection the report was generally complete with respect to the items examined and findings recorded. Discussion with the Delian inspector and review of the CSA findings indicate that independence of the effort was maintaine Overall, the deficiencies identified were sufficiently categorized to identify their seriousness. One exception was the number of deficiencies identified with flexible
, conduit: 12 by CSA and one by the SCVI.. Even though outside of the scope of the selected sample, these many ' '
instances suggest a high level of significance and require further review by the license (2) NRC SCVI Sample
,
j (a) Cable Entering or Exiting Raceway
:
Several cables were observed to exit (rollout) cable tray into the top of equipment without being secured at a or near the rollout per the specified criteria. The a initial condition was observed in the independent SCVI i sample where cables exit tray 4J2A32 at box 1ZSE24 While the NRC inspectors observed that the specific instances *
.
3 themselves do not represent a significant deficiency in . 1 construction as there was no evidence of physical damage, ', subsequent investigation by the licensee representative indicated this condition to be generic throughout the
, facility and was subsequently recorded on Notification of J Discrepant Condition (NDC) E-111. Although the inspection criteria was available through a specification reference j, in the Quality Control Procedure, it was not readily
' 4 apparent from the QC checklist. As a result, QC personnel 1 did not identify these minor construction deficiencie '
. .' . The SCVI inspectors also observed one instance in the CSA sample and four instances in the independent sample where ~ .1 cable transferring between cable tray and conduit violated I the specified minimum bend radius or barely met the require-4 ment with no additional protection provided to prevent d- violation'due to subsequent construction activities. The 1.j; following is a list of the tray to conduit observations identified to the license e}
fj 4U2A32 to 4U2A2C
;
4J2A32 to 4J2 AIL j 4J2A31 to 4J2A2B ' 1 IJ1G60 to 1J1GSC
] 4J1C66 to 4J1C10 i It was noted that protection methods are detailed by the ! architect-engineer to be used where necessar .
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Discussions with the licensee representative indicated that if field personnel were suspicious of a bend radius measurement, they would make a temporary template for immeCiate verification only. No permanent templates exis The licensee representative verified .the specific violations and is evaluating additional protection to prevent future violation 'Again, the SCVI' inspectors observed that none of the instances identified exhibited a significant' deficiency in construction, but rather that minor construction " deficiencies had not been identified by QC personne Also, the NRC inspectors are concerned that the current method of verification may not identify bend radius , violations due to the configuration of the installed [ cable.
i>
(b) Cable Tray Barriers
'
In general, cable tray covers (fire barriers and dust covers) were found to be installed in accordance with the t specified criteria. However, several instances of missing and ' improperly sealed barriers and a loose barrier clamp, as listed below, were observed and identified to the licensee representative. The unsealed barrier was found : in the CSA inspected sample while the other two instances a f were found during independent inspection.
f IC8F58 - barrier not sealed IJ1H80 - loose barrier-clamp IC8K07 - barrier removed The licensee's representative documented these discrepancies * on Nonconformance Reports (NCRs) ISN-20890E, -20919E, and-20920E.
It The NRC inspectors observed that none of the specific L instances identified represented a significant deficiency in construction, but rather that minor construction p deficiencies had not been identified by QC personnel.
L i One additional discrepancy found by the SCVI in the CSA ! ' sample involved the barrier for cable tray 4J2A31 at the junction'of conduit 4J2A1A. As installed, the barrier '
- _ partially obscured the tray identification. The licensee
} representative subsequently recorded this condition on NDC h E-097. This condition is considered to be minor,and an e, isolated cas (c) Cable Bedding and Training r With the exception of cable transfer and rollout deficiencies previously discussed, the SCVI inspectors observed that cable bedding and training had generally been maintained in the areas examined as per the specified criteri * III-4
._.7TETW_EEI ~
i $771 2IC 7.1_.11. El.-
_ _ __
; I However, one instance of two cables (1GEYl8CA and 1GEYl8AA) within the Delian raceway sample was found with one end not sealed and both coiled and laying on a lighting receptacle above tray IC8F58. Discussion with and investigation by the licensee representative indicated the cable had been deleted but not removed. This condition was subsequently documented on NDC-E-15 The NRC inspectors considered this instance an isolated Cas (d) Supports o Generally, raceway support assemblies, hold down clamps, -
bolted support braces, welds,_ and anchors were observed to > be in accordance with the specified criteria. An isolated
.; instance of a loose hold down clamp bolt on support ! 351F-75 was identified to the licensee representativ ~. The condition was subsequently documented on NCR ISN-20913-E for correctio .
- s i During the review and examination of the CSA concern
: number 24 regarding support 3710-24 (now identified as '
3710-1003), one anchor was observed to have concrete .
,
spalling behind the raceway support. The NRC inspectors * ,} expressed to the licensee representative that the extent of the spalling appeared to infringe upon the required . anchor minimum embedmen Subsequent discussion with the licensee representative and QC personnel revealed that minimum embedment is measured from the design surface of
, the concrete, regardless of the amount of spalling, per *
the project specifications. Further review of the project
requirements by the NRC inspectors did not find criteria j established to consider spalling when verifying minimum
~
anchor embedmen , Concurrently, the review and examination of concern .j number 24 and the related generic concern number 165 'j revealed a clarification of criteria for the sidewall A spread of raceway (Unistrut) supports on Request for Clarification or Information (RCI) 21D-7158. This ]i clarification indicates that a small deflection is acceptable provided no buckling (kinking) is presen j q Discussion with the project personnel indicated that the 1 RCI did not provide any accept / reject criteria as the j present procedure provided the criteria adequately. When
. asked what was the need for the RCI if the criteria existed, .} it was indicated the RCI was generated only for the ; condition identified by the CSA effort. Review of the
- 4 procedures by the NRC inspectors could not determine the i)' existence of acceptance criteria for Unistrut sidewall deflectio The lack of criteria established for the above conditions
': could allow for unacceptable installations to exis It is reconnended that licensee detailed attention be
,
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__ _ _ _ - _ _ _ _ - __. __ _-_. __ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _
"
* *
-
. .
..
given to these conditiuns to assure adequate corrective action by the CSA effort and an analysis to assure that these conditions do not allow for an unacceptable condition elsewhere.in the facility. These items remain unresolve (e) Raceway Separation The Wolf Creek Generating Station FSAR Section 8.3.1.4.1.1, Raceway and Cable Routing, provides the basic separation criteria between redundant Class IE circuits and between
,
Class 1E and non-Class 1E circuits. The criteria as stated is in consonance with IEEE Standard 384-1974 and NRC Regulatory Guide (RG) 1.75-1974. The requirements of RG 1.75 and IEEE-384 are discussed in the FSAR Section 8.1.4.3, Design Criteria, Regulatory Guides and IEEE Standards, and although several items are supplemented
; or clarified, no exceptions to either document are taken.
i In summary, FSAR Section 8.3.1.4.1.1 requires cables from different separation groups to be in steel conduit or enclosed [T wireways or separated by a fire barrier when the nonnal s 5-foot vertical and 3-foot horizontal separation cannot l be maintaine A conflict was noted by the SCVI inspectors between the * FSAR commitments and raceway installations as permitted by Drawing E-1R8900. Paragraph 3.36.5 of the drawing permits a non-class 1E conduit to be run within one inch of open Class 1E cable tray. The SCVI inspectors noted several non-Class 1E conduit to Class 1E cable tray installations A that met the drawing requirement but did not meet the FSAR commitment for either 3-foot 5-foot separation, enclosed raceway or separation by barriers. These are: a , Non-Class IE Conduit Class 1E Tray tl 3 6U3H1A, 6U3H1B to 4G1C12, 4U1858-
(and free air cable k exiting tray)
t i 5J3030 to 101E01 i i 3U3090 to 1J1001, 1C8C01, 101E01 ,
'
5U5010, 5U5011, to 4U1C72 t 603E3M, 6U3E3N
,
j IEEE-384 permits lesser separation distances to be established i' by analysis based on flame retardancy testing of the installation. RG 1.75 requires this analysis to be part of the FSAR. Discussions held with representatives of Bechtel Power Corporation indicated that analyses for the Wolf Creek Generating Station installations have not been performed. This item remains unresolve * III-6 . i g emeny=4 er e e- # 71 # -' 7 +e9 ** yt* -4- g ., g g** j f 4NSW7* t' f 29f 99,*e e CV f**> ;' g **=ia+
; I Conclusion Several instances of minor construction deficiencies identified by the SCVI were found to be generic by the licensee. A conflict between the FSAR commitment for divisional se3aration and several installations of non-safety conduit permitted by the detail drawing requires resolutio While some of the NRC inspection observations were made in the same areas previously' examined by the CSA effort, the.overall CSA effort resulted in conclusions appropriate for the basis
provided, and identified specific and generic deficiencies which
. require detailed licensee attention to provide correction and I
assure the quality of construction. Within the scope of the CSA raceway inspection, the effort was complete, independent, 2 properly concluded and does provide an additional measure of
"
assurance of quality of constructio l Cable and Terminations .
j Inspection Scope
'
Since the NRC Region IV task force inspected cable and cable - routing, no independent sample was evaluated by the SCVI tea , However, cable was reviewed during the SCVI inspection of . 1 racewa The NRC SCVI inspectors inspected approximately 50 field termina-tions in two of the four control room panels inspected by the CSA effort. These were panels SA036A and SA066 .
: In addition, approximately 30 field terminations fron various .
i areas of the plant were independently inspected. These were:
.i Panel Cable t RP-210 4GSY02AD 4BMY02AD t 4BMK06BC
4 NN-11 INNYO1AA .S INNY01AB 1 INNY01AG 1 INNY01AH i j NE-106 4NER11AC 4 4 NEB 02AP
14 '
.
The terminations were inspected for identification, proper
! landing of conductors, wire or insulation damage, evidence . of proper crimping, lug bending and general workmanship. The termination inspection records were also reviewe The following documents provided the acceptance criteria for the inspection of terminations:
]
* [ III-7 q .., .,m.. y...,... .,. ..,. , . ,, .m;.,~,..... . .g-..,,. .:
_ _ _ _ _ _ _ _ _ _ _ _ ._ __ _ _ ____ _ _ _ _ _ _ _
* *
.
* DIC Construction Procedure QCP-X-304, Rev.10
" Cable Termination"
* Bechtel Drawing E-17000, " Electrical Temination List" b. Inspection Findings (1) CSA Report Review the Delian Although the number team appeared adequate, of terminations their singular inspected location by(control room panels) was not sufficiently representative of the plant. The CSA report conclusion recognizes this limitatio The in-process inspection of terminations by Delian provided the review of characteristics not available in final inspections. However, the CSA report does not identify any acceptance criteria used for inspection of termination No specific sample of cable was inspected by the CSA effort.
( (2) NRC SCVI Sample (a) Cable . During the NRC SCVI inspection of raceway, several problems . were identified with cable exiting cable tray. These are discussed in Section III B.1.b.2.(a), above. Cable bedding c ' and training observed during raceway inspection is also discussed in Section III.B.1.b.2.(c), abov (b) Terminations No deficiencies were noted in the evaluation of the CSA sample of terminations. However, one field deficiency and a potential problem with vendor terminations was found in f the independent sample that was inspected. Both of these i occurred in panel RP-210.
h One conductor from cable 4BMK06BC in panel RP-210 had its insulation deformed and cut through to the wire. Although ( this apparently occurred during installation of the terminal lug, the DIC inspection records accepted the installatio However, the DIC field termination was made using nylon screws with the licensee performing the final change-out to the current metal terminal screws and a review of the i licensee's documentation for this process was not mad This deficiency was documented by DIC on a Notice of Discrepant Condition which had not yet been serialize A number of vendor installed terminal lugs in the same panel were found to be bent a full 90 degrees. The DIC Lead Electrical Engineer indicated that the requirement L
'
III-8 m. ._ - ~ . , . ._ ,..-. ,. m . ... .,. . ~ . - . . 7 ..
* '. .
for field terminations is one bend not to exceed 45 degree When the SCVI inspector questioned the vendor requirement, DIC reviewed the purchase specification for the panel and reported that the specification contained no requirement for terminal lug bending. DIC has requested a determination of acceptability of this condition from Bechtel Power Corporation via RCI 1-1361-E. This item remains unresolve No other deficiencies were found in the other panels
,
inspecte Conclusion b 1 Only one deficiency in vendor tenninations was identified by the q SCVI effort. However, the acceptability of vendor termination lug bending requires licensee attention.
Due to the limited scope of the CSA terminations sample, the i SCVI findings for terminations and tht, lack of a specific cable j inspection by Delian, the CSA effort does not provide an additional j measure of assurance of quality in this are . Equipment
~ Inspection Scope ,
t . 5 Three items of electrical equipment inspected by the CSA team i were chosen for evaluation by the SCVI inspectors. These were:- I High Pressure Safety Injection (HPSI) Pump Motor DPEM01A i Motor Control Center (MCC) NG02B ] 125 V d.c. Battery NK-12 a i In addition to location, mounting details, identification and
'
general workmanship, the HPSI pump motor was inspected for 1 nameplate data verification; the MCC was inspected for attachment welds (length, location,generalcontour),nameplatedata
'
i verification and breaker size; and the 125 V battery was l inspected for cell electrolyte level, rack configuration and
- j battery room environment.
'l ' The following documents provided the acceptance criteria for
.j the inspections: '
,, i * DIC Construction Procedure, QCP-XI-300, Rev. 10, j " Inspection of Electrical Equipment" d
* DIC Construction Procedure WP-XI-300, Rev. 8,
]1 " Installation of Electrical Equipment" u j * Manufacturers' equipment manuals
:
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*
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- . _ _ . _ _ _ _ - -
*
, l Inspection Findings (1) CSA Report Review The size of the CSA sample for equipment appeared adequate to determine the quality of construction in this are Discussions with Delian representatives revealed that the inspection of motor operated valves (MOVs) was hindered by
! the inspector's inability to open the MOV covers for a thorough inspection. The CSA' inspection.was comprehensive, complete and independent for the equipment that was fully accessible to the inspector.
! The significant hardware deficiency found by the CSA effort was properly identified as such and properly extended to j inadequate inspection criteria and inspection reports.
l (2) NRC SCVI Sample
{>
(a) HPSI Pump Motor DDEM01A t
No discrepancies were noted with the installation of the , pump motor which is in consonance with the CSA inspectio * .
(b) MCC NG028 .
.
No deficiencies were noted in the location, identification and mounting of the MCC. Breaker size, workmanship and identification of the several cubicles inspected met the specified requirement The bolting discrepancies identified by the CSA effort and .
<
recorded under their concern numbers 35 and 164 are discussed in Section VII, Material Traceability and Maintenance, of
'
this repor (c) 125 V d.c. Battery NK-1Q
! The battery cell electrolyte levels, battery rack configuration and battery room housekeeping were found to be generally ' . acceptable. However, the SCVI inspector noted an inconsist-ency in the deformation of the battery rack brace pads
' ! between the two racks; deformation being caused by torquing I of the brace pad bolting assemblies. The inconsistent i deflection puts the actual torque values in doubt. DIC l recorded this condition on NDC E-103 for resolution by the
;
licensee. This item remains unresolve l The plug welds attaching the battery racks to the floor
; embed channels exhibited considerable variation in contou The concern was documented by DIC on Electrical Rework Assignment RA-EI.341-22 which requires two welds to be \'I cleaned and reinspected. This unresolved item will require
followup by Regional weld inspector r
'
III-10
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A review of the QC inspection checklists revealed an incorrect drawing reference on the latest checklis When this was identified to DIC, Generic Resolution F-014 dated September 7,1984, was produced. F-014 states that, although required by the QC procedure, drawing or specification numbers and revisions need not be recorded on the QC checklists as this information is available from other documents. Althougn no adverse affect on the hardware in this particular case was noted by the SCVI
-
inspector, the Generic Resolution indica.tes a program , i weakness. It is now not certain how the specific documents
#
and revisions used as the acceptance criteria for an i inspection can be verified. The licensee needs to more
-
fully address this are ; A review of the CSA concerns for battery NK12 (concern l numbers 100, 101 and 155) showed'that CSA's requirement for
; corrective action plans and their evalution of responses ( was comensurate with the categorization of the finding .
i J The one significant finding on battery rack bolting, concern - i number 155, was properly incorporated into generic concern
! number 164 ano is discussed in Section VII, Material > Traceability and Maintenance, of this repor , Conclusions :
4 .
.
No deficiencies in addition to the CSA findings were noted during _- 2' the SCVI inspection of the MCC and HPSI pump moto l
, Two items with the 125 V d.c. battery rack require additional i licensee attention: brace pad torquing and plug weld qualit The scope and depth of the CSA effort in this area provides an
' additional measure of assurance of quality for electrical equipment with one exception: the inspection of MOV operators.
j Instrumentation Inspection -
! } .I1spection Scope Several items inspected by the CSA effort were evaluated by the y SCVI team. These consisted of one tubing run (approximately 100 f
i feet in length), one pressure indicator and the accessories for l one air operated valve, and are identified below:
} Isometric drawing J-14BB13 (tubing run) - PI-402 (pressure indicator) *
EM 8823 (air operated valve) Two additional tubing runs for an approximate total of 70 feet were independently inspected. These were detailed on isometric drawings J-048G02 and J-148G1 * III-11
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In addition to the tubing itself, the tubing supports, instrument mounting details and mounting structure configurations were verifie Inspection records were also reviewe The following documents provided the acceptance criteria for the inspectio * Bechtel Specification 10466-M-204 Appendix X, Rev.16, " Field Fabrication and Installation of
'
t Instrument Tubing, Tubing Supports and Instrument
' . . Sypports". - ,
Westinghouse Nuclear Operations Division (WN00) Procedure G-SAP-A-005, Rev. 4. " Engineering Job Instruction for Field Instrumentation Installations".
.
' Inspection Findings
, (1) CSA Report Review j The samples chosen by the CSA inspector were of sufficient
! size and variety to make an adequate determination of . i *
construction quality. The only omission noted in the CSA
. effort for instrumentation was the lack of inspection : / documentation revie . ,
i The concerns evaluated by the SCVI were properly categorized
) by CSA and represented the results of an effective, inde-1- pendent inspectio ; (2) NRC SCVI Sample J
No deficiencies were noted with the CSA inspected pressure indicator and air operated valve accessories, and only one minor deficiency was noted on one of the independently j . inspected tubing runs. This deficicacy was a tubing clamp on j isometric J-048G02 located over the specification tolerance
} for the designed spacing. This condition was being documented f on an NCR at the close of the inspection and an NCR number j had not yet been assigned.
} The CSA inspection of isometric J-148813 resulted in concern 3 number 143 for a loose tubing clamp and bent and sagging i tubing. At the time of the SCVI, Westinghouse N00 had A repaired and reinspected the items identified by the CSA j although Delian had not yet verified the corrective action.
,. The SCVI inspector identified three separate deficiencies
in the tubing run, one of which was located immediately
- adjacent to the repaired section of the tubing.
A The three deficiencies included an area of sagging tubing and two instances of physical interference. The sagging tubing
'
s was located approximately 10 feet from the area identified by the CSA concern. The tubing was also in contact with a tube
* .
III-12 '
.
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* ' . l steel support immediately adjacent to the repaired section and was apparently caused by the repair, and the second interference occured where the tubing passes through a wall penetration shared with an insulated pipe. The Bechtel specification M-204 Appendix X and Westinghouse procedure G-SAP-A-005 require sufficient clearance from all steel and concrete surfaces of building member The sagging tubing and the area of contact with the tube steel were documented on NCR ISN55413-J. The . interference with the -
pipe insulation and wall penetration sleeve requires coordination
-
wi.th the insulation contractor and was documented on the Open
, *
Items Status Report. Although relatively minor in natur deficiencies in tubing which has been inspected, repaired and reinspected may indicate that the licensee does not have sufficient control over inspected and accepted tubing run ! In addition to reviewing concern number 143, the SCVI - 1 reviewed CSA's generic concern number 156 issued as a . result of foreign material on instrument tubing and tubing j damage caused by subsequent construction activitie I Although the CSA corrective action plan is not specific, 1 it identifies the key elements the licensee should meet: , ' identification of damage, prevention of damage, determina-tion of corrective action effectiveness, and tubing ". a verification prior to operation. CSA was still reviewing . j the licensee's proposed actions relative to this concern H at the end of the SCVI.
l J Conclusions j j Four deficiencies, which were not considered to be significant j construction deficiencies, were noted by the SCVI and documented
- by the construction organization. However, the presence of three of these on one tubing run that had been inspected twice, repaired j
. and reinspected indicates that the licensee's corrective action 1 program in this area needs improvement.
A 1 The CSA effort in instrumentation was acceptable in scope, independence, and categorization of findings. Although it j,1 would have benefited from a review of documentation, the X effort does provide an additional measure of assurance of quality.
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, TABLE 111-1 RACEWAY AND SUPPORT INSTALLATION Raceway 1C8F IJ1G 6J2A 4J2A IJ3F6A IC8G IJ1H 6J2B 4J1C58 3J6002 r
IC8J IJ1J 4U2A IU3M10 3U6002
, , Supports 3710-1002 351F-71 251F-74 241-03 252FR-29 , 3710-1003 351F-72 351F-75 241-04 ,
3710-1004 351F-73 241-02 241-05-1 l h-
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i i IV. MECHANICAL CONSTRUCTION A. Objective The objective of the special construction verification inspection (SCVI) was to assess the extent the Construction Self Assessment (CSA) effort and followup corrective actions, in the area of mechanical construction, provide an additional measure of assurance of the quality of construction at Wolf Creek Generating Statio , B. Discussion The scope and description of the CSA effort in the area of mechanical
'
construction are provided on page III-1 and III-2 of the Delian Construction Assessment Report. The more significant inspection 3 findings are discussed on page III-3 of the report and the specific details of the individual concerns resulting from the CSA effort
, in this area are contained in 50 separate concern packages maintained
by Delian Corporation at the Wolf Creek sit . j During the course of the NRC inspection, the individual concern packages i were examined to more fully assess the nature of the concern, corrective
[ action taken or the action plan proposed to resolve the concer Acceptance criteria for the NRC inspections were essentially the same ,
as used by CSA and referenced in the Delian report. Copies of the j appropriate standards, specifications, drawings, manuals and procedures - l were provided by KG&E or DIC as needed. Also, interviews were conducted i
'
with Delian, KG&E and DIC personnel involved in the mechanical construction area as needed to assess the CSA effort. Factors considered in the assessment of the CSA were: independence, adequacy of thsir scope for the stated objectives, completeness, appropriateness of CSA identified deficiencies, their categorization 1 and the conclusions reached in their repor " Specifics of the NRC verification inspections are provided belo , Pipe Supports / Restraints j Inspection Scopje i
The Delian report lists a total of 50 large bore and 20 small bore supports / restraints as those inspected by the CSA tea I Page III-3 of the report prcvides the details of what was i inspected and Tables III-3 and -4 give the individual systems j involved, hanger numbers and other pertinent information y relative to the support / restraint.
The NRC team inspected a sample of 13 large and small bore pipe supports / restraints that the CSA team had also inspected. Two additional support / restraints not inspected by the CSA team were also inspected. The 15 are identified below:
'
IV-1
'
.
. _ . . . . . _ _ - , . - . ,,; .,, , ,.-,m- ., - - - -
. , - . - - -
__ _ _ _ _ _ _
'
. :
EG01-C012 AE05-R014 AB01-R032 AE05-R001* AE05-H005 EJ02-C002 EG10-A001 EJ02-R023 EG13-R008* AB01-R515 EP02-R021 EM12-H005 EP02-R011 EP02-H005 EP02-R010 Prior to NRC inspection of the above supports / restraints, data packages used by the CSA team for the inspection items were reviewed along with the concern packages for those that had - generated a concern. Similar data was used for the SCVI of the two restraints not included in the CSA sample. These data packages contained design sketches, bill of materials, any . special instruction sheets involved, QC inspection forms and
,
other quality related documentation. For the 13 supports, specific design / construction attributes noted to have been *
} inspected by CSA were reviewe ! During the NRC team inspection the same attributes were examined j and verified and on some supports additional attributes beyond those inspected by CSA were examined for conformance to design / - ,
construction specification . b. Inspection Findings I NRC inspections of the supports / restraints noted above, including the two not in the CSA sample, did not result in the identifica-
-
tion of significant deficiencies beyond those identified by the
, CSA effor . .
On several supports the specific concerns identified by CSA a were observed to have been corrected or reworked; other concerns l were noted te have been accepted "as is". It is noted that j several specific concerns in this area resulted in generic j concern 166. This matter dealt primarily with the possibility
! that Special Instruction Sheets (SIS) may not have been updated i following drawing changes, etc. Resolution of this relatively significant concern involved review of a considerable number i; of SISs and the eventual issuance of two Corrective Action Reports (CAR). The NRC team reviewed the particulars of this finding and the proposed resolution including the two CARS.
1 The finding is considered valid and the proposed corrective action is a reasonable method of resolution.
. It is noted that the CSA effort by Delian did not include J inspection of the expansion anchor bolts used to fasten surface mounted base plates for the support / restraints in their sample or as a separate area of inspection. In view of this, the NRC team selected a sample of expansion anchor
* Support Restraint not in CSA Sample
'
IV-2 o
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1 bolts used in supports / restraints both within the CSA sample
and outside. A total of 8 surface mounted base plates which included a total of 32 expansion anchor bolts were inspected for proper torque. The details and results of the inspection
.
of anchor bolts are discussed in Section V of this repor ^ Conclusion t- The CSA effort in this area was found to be generally acceptable i in terms of independence, scope, completeness, characterization 1; of findings and the conclusions reached. The action plan developed in connection with generic concerns 157 and 166 are appropriate
. in view of the specific findings which led to their preparation.
The fact that the CSA effort did not include the verification
, of torque values and inspection of a sample of expansion anchor ,
1 bolts detracts somewhat from the overall CSA conclusions about '
pipe supports / restraints, with this exception, the CSA effort -
~j provides an additional measure of assurance of quality in the -
l area of pipe supports and restraint I Equipment Data FSAR Comparisons
. . Inspection Scope .
II - 1 The Delian report discusses this area of inspection on page * III-7. Of the seven items listed on Table III-6 of the Delian report, four were examined by the NRC team for verification.
, , It was noted that a total of 19 parameter values - Nameplate 3 Data or FSAR Data - were missing from Table III-6 and presumed
indeterminate by Delian for comparison purpose ,
. Inspection Findings q].
F During the NRC team coverage of this area 13 of the 19 missing comparison values were located with the help of KG&E personnel j] . e and evaluated. Several comparison values remain indeterminate j for some CSA sample items. Discussions with Delian personnel 1 on this matter indicate that an attempt to obtain some of the missing data from KG&E had failed. The matter was not pursued ?j by Delian.
d i Conclusions i i The CSA effort in this area was determined to have been generally .j acceptable with respect to independence and scope. The NRC j review of this effort indicates that most of the items listed j for comparison purposes were verified by CSA, however, a signi-ficant number of values that were not verified as shown by blanks '
.
s in table III-6. Seven pieces of equipment were involved in the
-
CSA sample. From one to four items of comparative data was left
'
blank on each of the seven items. This raises a question about the completeness of this effort and therefore the additional measure of assurance of the quality provided by the CSA effort
,
in this area is considered, margina . IV-3 1 . 9*
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". . Bolt Torquing for Mechanical Equipment Inspection Scope A description of the Delian effort in this area is provided on page III-7 of their report and Table III-7 lists the specifics of the items checked. During discussions with the CSA team members associated with this effort an attempt was made to determine the bases for using test-torque values 80% of the specified design valaes. It was learned that. the 80% torque limit was essentially established to avoid breaking any torque seals that had been previously applied following final QC torquin Inspection Findings The NRC team coulo not verify or establish the validity of using an 80% test limit in terms of quality verification or other quality stanoards. A discrepancy is noted between the statement on page III-7 about an 80% limit and the data in table III- Apparently some of the bolts in the CSA sample were torqued to -
100% of the specified values despite the statement on page III- No independent SCVI examinations were conducted in this are * Conclusion
.
In view of the NRC team's problems in establishing the basis 4 upon which bolt torquing was accomplished there appears to be 1 a limit on the additional measure of quality achieved from this
'
effor The bolts (8 of 18) that were torqued to full specified values were of one type and size and located on the same type of f equipment (auxiliary feedvater pump). To this extent there is ' an additional measure of assurance of quality of bolt torquin . Heating, Ventilation and Air Conditioning (HVAC)
,
l Inspection Scope i The CSA scope and description of the CSA inspections in this area i are provided on pages III-8 and -9; the list of specific items making up the CSA sample is provided in Table III-8. The CSA 4 concerns resulting from their inspections are provided in
'
j Table III- I The NRC team inspected four of the 24 HVAC hangers in the CSA sample including the adjacent sections of duct, flanges and equipment in the general area. Prior to performing the inspections
'
both the CSA data package and the CSA concern file were obtained and reviewed for each hanger to ensure recognition of the , sttributes inspested by CSA and resulting findings / concern ' - IV-4
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Generally, the concerns identified by CSA were of a welding nature (undersized welds - generic concern 168) and inconsistencies between various documents which specified fabrication and inspection requirements (specific concern 153 and generic concern 158).
The NRC inspection confirmed the CSA findings; no significant additional deficiencies were identifie The CSA effort, as far as the NRC team could determine, did not include a sample of fire dampers. The NRC team inspected a sample of 6 fire dampers. The appropriate.Bechtel drawings were used during those inspections. Also, Bechtel Specification ~
'
10466-M-6278 " Technical Specification for Dampers for SNUPPS", DIC Document QCP-VIII-200 " Inspection Documentation of Field Fabrication and Erection of Safety Related Ductwork and Supports" and DIC Document AP-VI-13 "Special Programs - Fire Protection
,
Verification" were reviewed by the NRC team in connection with their inspections in this arec. The following fire dampers were -. ; inspected:
! GKFD-030 GKFD-163Q d -041 -296 1 -1600 -297
,1 Inspection Findings i No discrepancies from design and specification requirements were .
- I observed during the inspection; however, a flow direction vane
, assembly was observed to have minor damage. Appropriate
. documentation of this damage was prepared by DIC personne I The CSA e'ffort, as noted above, also did not include a sample of expansion anchor bolts in their inspections of HVAC hangers / supports. This prompted the NRC team to select a random sample
.i of 31 expansion anchor bolts for inspection and verification of torque setting. Several discrepancies were observed and documented as a result of this effort. Specific details and ; on this matter are contained in Section V of this repor ;i
.l Conclusion y
: The CSA effort in this area was found to be generally acceptable d in terms of independence, scope, completeness, characterization d of the concerns identified and the conclusions reached. The-l generic concern (158) that stemed from the overall CSA evaluation j of specific findings was reviewed and the NRC team concludes j- that the proposed action plan is a reasonable method for resolving 4 the stated concern (conflict or lack of uniform inspection j criteria) .
The CSA effort would have been more complete had it included 1 a sample of fire dampers and expansion anchor bolts. While this
- does detract somewhat from the overall CSA effort in the HVAC area and limits their conclusions correspondingly, those areas that were covered provide an additional measure of assurance of ~
the quality of constructio ' IV-5 i
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. l WELDING AND NONDESTRUCTIVE EXAMINATION (NDE) Objective The objective of the special construction verification inspection (SCVI) was to assess the extent the Delian Corporation Construction Self Assessment (CSA) effort and followup corrective actions in the area of welding and NDE provide an additional measure of assurance
' of the quality of construction at Wolf Creek.
- Discussion The scope and description of the CSA effort in the area of welding for mechanical, electrical and structural activities and NDE are provided in the Delian CSA report. The more significant inspection findings are discussed on pages IV-4 and IV-5 of the report. Specific details pertaining to individual concerns resulting from the CSA 3 effort, in this area, are contained in 44 separate concern packages retained by Delian at the Wolf Creek site, i
- During the course of the NRC inspection all of the individual concern
',
packages were examined to assess the nature of the concern, and the corrective action taken on the action plan proposed to resolve the concern. The vendor data packages for supplier welds selected for examination during the inspection were acquired, after some delay, : and reviewed prior to the actual inspection of welds. Interviews .
- and discussions were also conducted with Delian, KG&E and DIC l personnel involved in the welding and NDE area as a part of this
7 inspection. Factors considered were: independence of CSA, adequacy I of their scope for the stated objectives, completeness, appropriate-
'
ness of CSA identified deficiencies, their categorization and the conclusions reached in their repor : Specifics of the SCVI are provided below: Structural Steel Welding a ] Inspection Scope
? The SCVI team inspected weld connections C81, C82, C83, C84, and ; C85. These welds were made by field welding structural floor beams to embed plates above the Control Room per Bechtel drawing number 10466-C-121-1420-02 which is listed in Table V-4 of the j Delian repor * Inspection Findings !
The SCVI team was informed by KG&E during the entrance meeting that KG&E was performing a 100% reinspection of all structural welds as a result of the NRC Region IV finding that some
,
structural welds were missing and various other welds did not
'
meet requirements. The CSA of structural steel welds is covered in Sections IV and V of the Delian report. Structural welds in the Control, Auxiliary, and Reactor Buildings that were
'
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_ visually inspected by the CSA are listed in Table V- The report also stated that "No hardware welding problems were noted in structural steel and electrical support areas." The SCVI team interviewed the CSA Civil / Structural discipline leader of Delian who indicated that structural welds were not physically reinspected. The discipline leader stated that "the structural welds were judged to be acceptable on the basis of visual observation and review of weld records only." It was also
' clarified that the review of existing DIC weld records was performed by the DIC member of the CSA tea The SCVI inspection of a selected weld sample revealed that some of the inspected structural welds did not meet the Bechtel . specifications. The weld deficiencies found were identified as weld underrun, undersized welds, lack of fusion between beads and excessive overlap. These welds were previously visually inspected and accepted by CS Conclusions 1 The CSA effort was not effective in discovering the structural 1 welding problems because the CSA inspectors did not physically '
inspect structural welds, therefore the objective of the CSA
; was not effectively implemented in this area. The CSA did not . '
provide an additional measure of assurance of the quality of construction in this are * Welding of Piping and Components i j Inspection Scope ,i The CSA inspection of the welding of piping and components is covered in Section III of the Delian report. The CSA inspection resulted in 37 concerns based on visual inspection of piping and component welds. The CSA team physically reinspected some of the J welds on which the concerns were based. The SCVI team selec'ted concern numbers 68, 69, 72, 119, 120 and 137 which involved vendor } s welds and reviewed the data packages in order to identify the acceptance criteria used for the physical inspection of the welds.
;
The inspection in this area was delayed by the inability of the DIC contacts to supply vendor data packages. KG&E resolved this
; problem by providing the data packages in response to requests by i the SCVI team leader.
J
$ Inspection Findings d
1 The CSA team has accepted the corrective action for 22 of the f 37 concerns. Nine of the remaining 15 concerns requiring y corrective action were related to vendor welos.
q-q The SCVI team inspection of the selected weld sample resulted y in the following observations:
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* Welds were inspected through paint without engineering evaluation of the acceptability of that method of inspectio * The CSA inspectors did not use a written procedure or criteria for the inspection of vendor weld The SCVI team inspection did not identify any significant deficiencies beyond those identified by the CSA effor However, the DIC personnel' stated that "they were not responsible for welds made by vendors", and in a number of cases expressed their view that CSA findings were not valid. The SCVI team questions the adequacy of imple-mentation of corrective action by DIC when DIC does not believe that they are responsible for corrective actio Conclusions The CSA effort in this area was found to be generally acceptable in terms of independence, scope, completeness, characterization of findings and the conclusions reached with the following excep-tion The reinspection of vendor welds in accordance with the criteria ,
referenced on Bechtel purchase orders, not used in the CSA, is -
! required to provide a basis for implementation of corrective -
4 action. This should follow the removal of paint from the vendor welds or an engineering evaluation on the acceptability of , inspecting welds through paint. This item remains unresolve KG&E needs to contractually delegate responsibility for the
'
use of written procedures and criteria that would alleviate
< organizational disagreements concerning implementation of . corrective action in accordance with the generally acceptable '
action plan for resolution of CSA generic concern 169. This item remains unresolved.
- The CSA effort did not provide an additional measure of assurance of quality in the area of vendor welds.
[ Welding of Piping and Components - Radiographic Inspection Inspection Scope y The scope of the CSA review of radiographic film for vendors 1 is discussed on page IV-2 of the Delian report. The findings
'
of the CSA effort for this area is given on pages IV-6 through j IV-11. Table IV-6 lists film reviewed by the CS The objective of the radiographic inspection was to determine
-
if the CSA effort was adequate in scope and implementation to
. be capable of determining if the work, both completed and in prugress, and quality control (QC) work related to welding and NDE activities, were and are, controlled ano performed
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in accordance with design requirements and applicable codes and specification To acccmplish the above objectives, the SCVI reviewed 703 radiographs, which cover approximately 377 feet of weld (32 welds made by 15 contractors and vendors). 148 of these films related to field welds completed on the sit The SCVI sample included NDE for welds performed by two onsite
! contractors (DIC and GE0 Testing) and 12 of the 13 piping and ; component vendors in the CSA sample and of one vendor not in t
the CSA sample. Some of the SCVI sample was the same as the CSA sample while others as noted in b.(1), (2), (3), (8), (10) and (13) below were independent of the CSA sample review of NDE for weldin Three quality control certification / qualification packages for ] QC inspectors were also reviewed.
{, Inspection Findings q ] (1) Daniel International Company (DIC) ? The SCVI. team reviewed 16 welds which were reviewed by ~ the CSA team and one.that was not reviewed by Delian. This b involved the review of 140 film covering 143 feet of piping - i or component welds for eleven system The CSA found no unresolved problems. SCVI examinations
,
confirmed this findin / J (2) Geo Construction Testing ] A total of 8 film, covering 4 feet of weld associated with
l the Feedwater System (AE) was reviewed. This item was not i reviewed by CSA. No problems were identified as a result of this revie (3) DRAVO 1 The SCVI team reviewed film for 5 welds which were reviewed by CSA and 3 welds which were not reviewed by Delian. This y:
.
effort involved the review of 36 film covering 30 feet of i; weld on the Main Steam System (AB) and Reactor Coolant System (BB).
> j No problems were found by CSA. The SCVI team noted 33
'i film packages which had a different material thickness than those recorded on the reader sheets. In 31 film ,
packages, the thickness difference was 1/10 of an inch and
~
in two packages the difference was 11/100 of an inch. In order to resolve this item, the applicant should detennine 7 the actual thickness of the weld and verify that the correct penetrameter was used based on the confirmed thickness.
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(4) Sargent Industries /Airite Division This effort involved the review of 36 film covering 9 feet of. weld on flued heads by both CSA and the SCVI team.
- ' CSA concern #64 - penetrameter material did not . conform to the inspection report and the film showed poor radio-- graphic technique and film scratches. Further investigation and review verified that a proper penny was used and that the film scratches were not indications.of. bad welds but of poor film handling technique. The concern was resolved L by CSA and KG&E and the SCVI team concur (5) Atlas
!
This involved the review of 72 film covering 36 feet of weld on the Excess Let Down Heat Exchanger by both CSA and the SCVI team. No. problems were found by CSA or the SCVI team.-
(6) Pullman-Kellogg l ' The. SCVI' team reviewed the film for six welds which were -
reviewed by CSA. This involved the review of 48 film ' covering 15 feet of weld on the Feedwater System. No . .
'
problems found by CSA or the SCVI tea *
!
l (7) Westinghouse The CSA team reviewed film from 17 welds. The SCVI team reviewed film for five welds which were reviewed by CS , This involved review of 59 film covering 6 feet of weld on p; the Inlet Nozzle Safe End and Control. Rod Housing, y'
! CSA concern #83 - the vendor's radiograph showed a linear l indication about 7/8 inch long in an area where the maximum t length would be 3/4 inch. This slag indication on closer !. examination proved to be two slag inclusions both of which L are acceptable under the code.. The SCVI team agrees with ! the second interpretation. The concern was resolved by CSA and KG& (8) Richmond Engineering Company (RECO) -
CSA reviewed film from 6 welds. The SCVI team reviewed
:: the film for these six welds and 4 other welds. This.
, involved the review of 38 film covering 50 feet of weld t on the Let Down Heat Exchanger System and the Gas
. Accumulator.
T i For CSA concern #94, the vendor's shooting sketch shows that a 22 inch diameter pipe was radiographed. The actual
- welds radiographed were 3.635 inches in diameter. In addition, film placement does not agree with sketch and
, lead I.D. markers were located within the area of interest.
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: . * 'As a result of the CSA, all film in connection with the concern will be reexamined and film from other RECO contracts will be examined up to 100% depending on further finding The SCVI team concurred with the film analysis and the recommendation for review of additional RECO contract (9) Applied Engineering Company This involved review of 57 film covering 25 feet of weld on the Seal Water and the Let Down Reheat Exchangers~ by both CSA and the SCVI tea CSA concerns #84 and #85 - Vendor films show indications , of incomplete penetration, lack of fusion, undercut and unacceptable densities. The areas of concern were re-radio- ) '
graphed and the concerns were confirmed. An~ NCR is to be written, a 100% review of this vendor's film is to be done
{ and possibly the internals of the vessel concerned will be
; removed to allow further visual examination and possibly repai The SCVI team agrees with the findings and with the indicated additional review and corrective actio .
'
l (10) Struthers Wells t This film review was by the SCVI team. CSA did no reviews of this vendor. This involved review of 9 film covering l 16 feet of weld on Heat Exchangers. No problems found by
- these independent examination ( (11) Anchor / Darling Valve Company The SCVI team reviewed film for 6 welds which were reviewed by CSA. This involved review of 48 film covering 6 feet of weld on three 600# valve bodie i j CSA concern #66 - unacceptable film density in thin sections
; of the welds and in the penetrameter. Further review j determined that film densities were within code limits
.; and the concern was resolved by CSA and KG8E. The SCVI
) team concurs with the final raiew result ? (12)Walworth
]; The SCVI team reviewed film for eight welds which were reviewed by CSA. This involved the review of 24 film covering 13 feet of weld on 3 inch valve bodies- No
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.
',. problems were found by CSA or the SCVI tea *
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(13) Velan Valve The SCVI team reviewed film of 4 welds repairs, three of
' which were reviewed by CSA. This involved review of 42 film covering 3 feet of weld on 3 inch 900# valve bodie No problems were found by CSA or the SCVI tea (14) G&W Energy (Taylor Forge)
'The SCVI team reviewed film for 6 welds .which were reviewed by CSA. This involved review of 47 film covering 21 feet of weld. No problems were found by CSA or the SCVI tea (15) Chicago Bridge & Iron
' CSA reviewed film from 31 welds. The SCVI team did not review any CBI fil CSA concern #65 - inspection showed no shooting procedure,
,
station markers distorted, incomplete fusion, and possible '
'
incomplete fusion (noted on the film as a surface condition).
Further review determined that the referenced procedure
-
was a shooting procedure, film indications were surface conditions.as noteo and the radiographs met ASME Section V requirement '
: .
g- The concern was resolved by CSA and KG&E (KG&E sign-off
; missing).
l (16) Summary Review of CSA Concerns t The CSA delineated 7 areas of concern in the NDE area of the welding /NDE discipline. Of these 7, 4 were resolved by further review of film and hardware by Delian and KG& l These are concerns No. 64, No. 65, No. 66 and No. 83. For f three concerns, No. 84, No. 85, and No. 94, the CSA team 1 required further investigation and/or documentation before a resolution can be accomplishe .{ g Conclusions
; The CSA effort on film review was found to be generally acceptable
, with respect to independence and scope for interpreting the 1 film and instituting corrective action. In a few cases more
. effort to institute review of further samples when welding defects -
were detected would have been appropriat i As a result of the independent SCVI team review of the Dravo . film, 33 film packets were found to be marked with a material ] thickness different from that shown on the reader sheet. This f item remains unresolved.
.
'
The SCVI found the CSA corrective action for CSA concerns
#84, #85 and #94, including the resolution of CSA identified
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4 ..8 deficiencies in welding by Allied Engineering Company and RECO and the 100% review of all other welding performed by
. those.two suppliers, acceptabl ,
The CSA provided an additional measure of assurance of quality
"
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' VI. REINFORCED CONCRETE AND STRUCTURAL STEEL ; Ob.iective The objective of the special construction verification inspection (SCVI) was to assess the extent the Construction Self Assessment
.(CSA) effort and follow up corrective actions, in the areas of reinforced concrete and structural steel, provide an additional measure of quality of construction at Wolf Creek Generating
. Statio i
' Discussion i
; The scope and description of the CSA civil and structural construction
, inspection effort are covered on pages V-1 through V-3 of their report
. and consist of two areas, namely, reinforced concrete and structural f
.
steel construction. The CSA report had no significant findings for i review by the NRC inspection team. However, to assess the adequacy of i the CSA conclusions, both areas of the.CSA effort and report were
}. inspected by the SCVI team excluding structural welds which were [ covered by the Welding and NDE effort (Section V). In addition, the . ; SCVI team inspected concrete expansion anchor bolts for torque, embedment, concrete spalling and bolt spacin Interviews were conducted with onsite CSA KG8E and DIC personnel :
prior to, during, and after the SCVI team examinations. . Other - factors considered for the CSA effort and report evaluation were:
.independency of the CSA effort; adequacy of the CSA scope for the stated objective; appropriateness of CSA deficiency categorization; dnd the Conclusion of their repor s - Reinforced Concrete i
Inspection Scope-
~
a.
' The CSA report (pages V-4 and V-5) lists a total of 24 j- concrete pour pdckages examined by CSA. The CSA team F assembled a file of the concrete placement documentation j that they reviewe .
The SCVI team inspected records of five in-place pours (0C241W20;
) OC361WO2; OC251S01; OC252501 and OC142WO6) and reviewed the
{ associated documentation previously sampled by CSA. The five k .. concrete placements consisted of three concrete placements in I: the Reactor Building and one each in the Auxiliary Building and 1 - Control Building. The SCVI team visually inspected the surface h of these five in-place concrete pours for cracks, misalignment, concrete repairs and installation of embeds. The SCVI team
-
selected at random from the five concrete placement packages,
! nine inspectors who performed QC inspections to verify, though J a review of the certified inspector computer listing, if they were certified in the duties that they performed. The SCVI team also reviewed the qualification records of five of the ,
nine inspectors to determine if they were qualified to perform their dutie ' j VI-l b- . c, . c
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The SCVI team reviewed the associated documentation of the concrete placements to determine the overall odequacy of the CSA review of DIC performance of the following:
- Concrete and Material Testing Laboratory Air, Slump, Temperature Unit Weight & Cylinders Batch Adjustment Form - Pre-Placement Inspection Reinforcement Cadwelding Embedments - Placement Inspection
.: 4 In accordance with standards, specifications, and procedure ; - Post-Placement Inspection Curing , ii The associated documentation was reviewed for conformance to
'
the following procedures: J QCP-IV-106, Rev. 12. " Concrete Pre-Placement, Placement, .; and Post-Placement"
: .; QCP-IV-102, Rev. 7, " Mechanical Splicing of Rebar"
, QCP-IV-105, Rev. 4, " Concrete Batching, Mixing, and j
. .
Delivery" a q Inspection Findings (1) CSA Report Review j No concerns were identified by the walkdown and document review by the CSA inspectors regarding the concrete in-place ( or the documentation.
j The CSA inspector stated to the SCVI team that he did not
; review any other documents, such as the Daily Cadweld j Inspection Report, As-Built Cadwe'id Location Drawings, -
Cadweld Test Splice Results, Concrete Materials Test Results
+ or any inspector's qualifications and certifications, to '
substantiate the acceptance by DIC of the different items-e- on the Pre-Placement Checklist.
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?' The following observations were made regarding the documentation review and the concrete in-place inspection:
(a) The SCVI team visually observed no cracks, misalignment, embedments or faulty. concrete repairs during the inspection
, of the five in-place concrete pours selecte (b) Concrete and Material Testing requirements and frequency were found to be in accordance with approved procedure (c) The review of the qualifications and certifications of
, DIC inspectors revealed that one Level I Batch Plant '
Inspector.had signed off for the evaluation of batch , tickets instead of the required Level II. This was found to be inconsistent with Table 1 " Minimum Levels of j' Capability for Project Functions" of ANSI N45.2.6 which
'
states that.only a Level II or Level III can evaluate the validity and acceptability of inspection, examination, and testing results. A KG&E surveillance report (S-395) was presented to the SCVI team for the resolution. It -
investigated a similar problem in the electrical discipline ,
, onl Further action was not taken to consider adequately 3 the civil discir.line. Therefore, the surveillance report *
c was considered insufficient for this issue. This item , remained unresolve
(d) The KG8E response documentation to'CSA concern #162 was F undeitevaluation by CSA and remained open pending '
completion of CSA review and followup corrective action, F if necessary. With respect to the reinforced concrete
; aspects of concern #162, KG8E was found to have an acceptable response based on the SCVI team's review of the KG&E documentatio !
{ Conclusion ([.. The SCVI team concludes that there was sufficient independence of the CSA effort, but that the depth of the CSA investigation
? was marginal. The one deficiency identified in the reinforced
!: concrete area was brought to the attention of DIC and KG&E for adequate dispositio The conclusion that the depth of the CSA investigation was
-
marginal was based on the information that the CSA inspector i relied on the acceptance signature of the DIC inspector instead
!' of substantiating the acceptance of the inspection item by review of supporting documentation. The CSA sample size of concrete placerents was marginal because the total concrete L volume of the selected placements appeared to be somewhat lo Based on the marginal depth of the CSA review of concrete pour documentation and marginal CSA sample size, the additional * '
VI-3
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assurance provided by the CSA effort in this area was also o marginal. However, the SCVI team's examinations conducted to assess the CSA effort, did not identify'any significant deficiencies in concrete pour documentation that would indicate
. physical deficiencies in the concrete structure > Structural Steel ~i Inspection Scope l
a The CSA report (pages V-7 to V-11) lists their structural l
! steel inspection sample.
.
' .The SCVI team visually' inspected the structural steel installa-
< tions associated with beam members: 362B1; 34081; 39183; -; 346B1; 339B1 and 324B1 previously sampled by CSA. The structural steel configurations listed above were at elevation 2068'-8". They were located in 3 different areas of the Reactor a Building. Pertinent documents were reviewed. Fireproofing of W the structural steel hardware in the Auxiliary and Control 1 Buildings preempted a visual inspection by the SCVI team of CSA J' samples in those areas. The SCVI review of structural welding is addressed in Section V of this report.
_' ~ Inspection Findings , ,
.
5 (1) CSA Report Review
- ,3 The CSA report concluded that the 54 structural steel y members and 10 associated bolted and welded connections 1 comp' lied with the design drawings, installation drawings,
. '
and field installation procedures. The " Table of a Resolution of CSA Concerns" listed three concerns (#1, 4 -55, and 56) related to this are qr (2) SCVI Sample d'd The SCVI team visually inspected the sampled structural steel, listed in Part 2a above, installed by DIC and p3 indicated to have been sampled by CSA. The assessment of Q the samples was based on the observations discussed below.
h An effective assessment of the CSA effort and basis for CSA conclusions in this area was not possible due to lack of CSA retention of' inspector's records or documentation a f;} showing the visual inspections and document review stated d' to have been performed. However, the NRC physical verifica-
;] tion of a limited sample of structural ' steel configurations y 1n the Reactor Building did not identify any deficiencies in
design and found the hardware to be in accordance with the design drawings. There were three concerns (#1, 55, and 56)
, identified by the CSA effort. Concern #'s 1 and 56 were
,j determined to be of no significanc ' ,i.
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i VI-4 d . 1 - - 3_ -
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For concern #55 the original concern was that a non-safety relateo tubing support had been attached to a safety related
-
whip restraint and out-of-plane vibration of the whip restraint would damage the tubing. This issue was considered minor to the SCVI team. However, the proposed written resolution indicated that the whip restraint design did not include loading from the tubing suppor This should have been done despite the small loaos the tubing support may cause, and in addition, the as-built design drawing should have been reviewed to see if the location of the tubing support on the whip restraint is shown. The whip restraint also should have been checked
. to see if the location of the tubing interferes in any way in the intended design and with the functioning of the whip restraint. The SCVI team discussed this with appropriate , CSA team members who indicated that the NRC question would be considered in the resolution of the concern. Subsequent . review of this matter by SCVI resulted in another open question on the resolution of this CSA concern. The resolution also needs to address the DIC program for control, ; documentation and design review of such cases of " field routed" tubing or piping which is attached to safety related supports. This item is unresolve : Conclusion .
1 There appeared to be adequate independence of the CSA effort.
( With respect to the CSA scope, the depth of the inspection was l only marginal . Three concerns were identified by the CSA team
; in the structural steel area. The level of seriousness for '
concern #'s 1 and 56 were appropriate. Concern #55 requires further stud It is concluded that the CSA effort, although
'
lacking supporting records, does result in an additional measure
; of quality of construction at WCG j Concrete Expansion Anchor Bolts
I a. Inspection Scope
' The SCVI team inspected the concrete expansion anchor bolts
, for pipe supports and HVAC ouct hangers. This was done to : provide added basis for evaluation of the CSA report on pipe ; supports and HVAC duct hangers. The hanger numbers identified t with the pipe support related anchor bolts were: EJ03-R508; '
EJ03-R507; EG01-C012; AB01-R511; SJ01-C526; EJ04-H008; EM12-H005;
! and EM03-R020. The hanger numbers connected with the HVAC duct : hanger anchor bolts were: C1460; 1541GK3410H1383; 11541GL0025NL192; 11541GF0010H1359; and 11541GF0530H1360.
q
.
A total of 63 anchor bolts were inspected for the pipe supports
, and HVAC duct hangers. For the pipe supports 12 anchor bolts were pre-selected and 20 were randomly chosen. These 32 anchor bolts were in either the Reactor or Auxiliary Buildings. There
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VI-5 l
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were 31 anchor bolts ranoomly selected for the HVAC duct hangers and were located in either the Auxiliary or Control Building The anchor bolts were inspected for conformance to the following specifications and drawings: Bechtel Specification 10466-C-103A, Rev. 6 " Technical Specifications for Installation of Concrete Expansion Anchor Bolts"
.
Bechtel Drawing C-1003, Rev. O, " Structural Steel and 3 Concrete. General Notes" Bechtel Drawing C-1037, Rev. 0, " Standard Details Sheet
-
No. 34" i For a review of certifications of qualifications of the DIC
: QC inspectors assigned to the SCVI inspectors see Section
+ VII !
. Inspection Findings l (1) CSA Report Review
'
j The inspection of surface mounted base plates and anchor
' bolts was not included in the scope of the CSA effor l j (2) SCVI Inspection Sample t '
For the anchor bolts associated with the pipe supports, only one out of 32 turned. One of the nuts associated .. with hanger number EM12-H005 rotated about 1/8 of a full
! turn. This was considered an isolateo case and of no significance. DIC QC inspectors present at the time of inspection generated the necessary follow-up documentation .
since the torque seal on the bolt was broken.
& j Of the 31 anchor bolts sampled for the HVAC duct hangers, f a total of 6 nuts turned from 1/16 to one and a half full 1 rotations. Hanger number 11541GF0010H1359 had the only
! nut needing 1-1/2 turns before reaching the required torque.
I Again DIC QC inspectors followed up with the required 1 documentation. For hanger number 11541GF0530H1360 the i lower two anchor bolts were installed.with a slope greater j than 1 in 20 with respect to a plane perpendicular to the surface of the bolted material. The DIC QC inspectors 3; drafted the required documentation for the misaligned bolts and broken torque seals.
., [ An cbservation by the SCVI of Material Traceability,
: noticed questionable minimum embedment lengths with six of the twelve anchor bolts supporting safety injection accumulator tank number TEP-01A in the Reactor Buildin , : .
Those six anchor bolts did no.t meet minimum embedment
.
- VI-6
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lengths required by Bechtel drawing #'s C-0X2902 and C-1C2411 and exceeded maximum tolerances by as much as 3/8".
Bechtel Drawing C-1C2411, Revision 0, Detail 1 requires the projection length of concrete anchor bolts to be 7" above the underside of the top flange of the safety injection accumulator tank (#TEP-01A) base fram According to DIC personnel present at the time of the SCVI, a 23/8" tolerance was allowed, permitting the projection length to be up to 7-3/8". Contrary to the above, six out of the twelve embedded concrete anchor bolts had projections above the top flange greater than 7-3/ This item remained unresolved and requires an engineering evaluation report to determine if the design requirements are met by existing embedment lengths. Also, further action may be prudent to determine the scope of this proble Another separate effort addressed in Section III of this report noted spalling of the concrete around an anchor bolt supporting a raceway unistru In summary, the SCVI samples were generally found to be in accordance with the drawings and specifications. There were : no significant deficiencies identified except for the - I lack of anchor bolt embedment. Adequate measures in accordance with KG&E QA program requirements were being taken by appropriate personnel to disposition the noted . discrepancies, t Conclusion , ' As the CSA effort did not investigate the concrete expansion anchor bolts, no assessment of the CSA effort in this area was mad The SCVI identified no significant findings in this area, , except for embedment of anchorage bolts, as discussed above.
, f
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VI-7
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* . l VII. MATERIAL TRACEABILITY AND MAINTENANCE Objective , The objective of the special construction verification inspection (SCVI) was to assess the extent that the Construction Self Assessment (CSA) efforts in the area of material traceability and maintenance, provides an additional measure of assurance of the quality of
, construction for the Wolf Creek plan Discussion
-
The scope and description of the CSA coverage in the area of material traceability and maintenance are provided on pages VI-1 through VI-5 of the CSA report. The CSA material traceability and maintenance
,
inspection team did not identify any concerns in either the material traceability or maintenance areas. Some material and traceability
, concerns, however, were identified by other CSA disciplines.
n 1 In addition to reviewing the CSA report in its entirety to determine l the scope of examinations and findings regarding the material j' traceability and maintenance areas, each applicable individual concern package was reviewed to assess the nature of the concern, - corrective action taken or the action plan proposed to resolve the , concern. Interviews with key CSA, Daniel International Corporation .
(DIC), and Newport News Incorporated (NNI) rersonnel were conducted
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*
"
to better assess the CSA effort. Throughout the NRC inspection, attention was given to general areas of the CSA such as independence,
. . .
adequacy of inspection scope for stated objectives, completeness,
i appropriateness of CSA identified deficiencies and their categori-zation, and of' conclusions reache ..
-j NRC inspection samples were taken which included some CSA samples 1 '
and similar types of items not inspected by the CSA team. This was done as an additional method of assessing the CSA report ano effor j CSA Material Traceability Review q 1- Inspection Scope i Each of the individual CSA discipline inspection scopes and
- relevant CSA team inspection packages were reviewed for
- l applicability to material traceability ano maintenanc j The following CSA concerns resulting from the CSA effort in k areas of the CSA report other than the material traceability 2 section, but which involved material traceability, were reviewed to detemine their relative importance and the manner in which j the concerns were to be resolved
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*
#34; Mechanical, (Supports) Not to Tolerance, 3 Incorrect Material t t
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#35; Electrical, MCC Bolting Not to Specs
*#53; Mechanical,(I&CValve)
* #63; Mechanical, (Piping) Nuts Missing on Valve
* #86; Mechanical, (Piping) ECR Issued in Lieu NCR
* #91; Mechanical, (Piping) Missing Nuts on Valve
#100; Mechanical, Maintenance Records Missing
#102,103 and 104; No Danger Signs, Exhaust Fan
* #115; Mechanical, Equipment, Bolts Missing on Valve
*
Plates g
; * #123; Mechanical, (Supports) Code Data and Documentation ' * #130 and 131; Electrical, Bolting of Switchgear o * #144; Mechanical, (I&C) Missing / Loose Nuts on Terminal Box , * #148; Mechanical, (I&C) Missing Valve Handle, Missing .
Clamp
} ! * #155; Electrical, No Inspection Record of Battery Rack l Fasteners, Nuts Missing from Battery Rack Assemblies t #157; Supports, Minor Hardware / Documentation Problems i . * #162; An Apparent Deficiency in Management Control of Vendor Activities. Inadequacies in Vendor Supplied l Hardware and Documentation in Several Disciplines j * #164; A Generic Problem with Regard to the Fasteners ' (e.g., Nuts, Bolts, Washers) Used for On-Site Assembly 1 and Installation of Electrical Equipment. Generic concern #164 (inclusive of specific concerns #35, 130, 131 and 155) was thoroughly investigated via records ; review and on-site inspection.
'
,
The SCVI inspection samples were selected from installed safety-6 related material and equipment. A total of 59 individual samples i- were examined to varying extent. Items included in the inspection
, were categorized into four general groups as indicated on Table VII-1 of this repor ,' Acceptance criteria for material traceability used in conducting these inspections were:
* Section 17 of SNUPPS Preliminary Safety Analysis Report VII-2
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DIC Procedure AP-VI-08, " Identification and Status of Material, Parts, and Components" DIC Procedure AP-VIII-03, " Identification, Marking and Inspection" Inspection Findings
. (1) CSA Report Review The general conclusion made by the CSA report regarding material traceability was that filler material and base , materials appear to meet applicable material specification i This is based on their review of Certified Material Test - Reports (CMTRs). However, none of the material checked for
traceability listed on Table VI-1 (Material Certification)
- of the CSA report can be directly traced to a specific installed component. The Objective and Discussion sections j of the CSA report (page VI-1) indicate that samples were to Ii be selected from field-installed components, however, this lj relationship was not establishe Several QA items that were covered in other parts of the
!i CSA report should have addressed the Material Traceability "
-
aspects of the problems. These included CSA concern
'
numbers 34, 35, 53, 63, 86,.91, 115, 144, 148, 155, 162 - and 164. Each of these concerns indicate some' degree of . a loss of material traceability and control.
I (2) .NRC SCVI Sample In general, the documentation and control of material a traceability for the SCVI sample of piping and fittings, 4 field and vendor weld joints, and equipment was acceptabl However, deficiencies involving material traceability and control of fasteners were noted by CSA and the SCV These included: 3 * Motor Control Centers NG01A, NG01B, NG03C, NG03D and i NG04C had cabinet to cabinet fasteners that were made 1.; of indeterminate material; were missing or improperly 1 installed. The CSA inspection effort also included j the Motor Control Centers, resulting in similar findings, 3 however, the CSA report did not address the lack of d traceability. Pennanent markings on the fasteners are j required by the material specificatio d i * Battery rack NK12 had fastener assemblies that were
; made of indeterminate material or were missing. The CSA inspection effort in other areas also included the
,z battery racks resulting in similar findings. However, the CSA report did not address the lack of traceabilit $ * Two of four anchor bolts for main coolant pump support
.,
(Lamco Industries #1533) were judged to be made of
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indeterminate material since no traceability markings were visible. Permanent markings are required by the material specificatio * Two of four anchor bolts for the "B" steam generator northeast suppurt leg were judged to be made of indeterminate material since no traceability markings were visible. Permanent markings are required by the material specification * One of three anchor bolts for the "B" steam generator
- southeast support leg was judged to be made of indeterminate material since no traceability markings were visible. Permanent markings are required by the material specificatio * Safety Injection Accumulator Tanks TEP-01A and TEP-01B had anchor bolt nuts which were not in accordance with
' drawing requirements. Some anchor bolt assemblies had ! two heavy hex nuts installed while others had a single L heavy hex nut and a jam nut. Detailed placement drawings for the accumulator tanks indicate a single heavy hex nut for embedded anchor bolts and double heavy hex nuts for - through type anchor bolts. Deficiencies were also noted , involving placement of embedded anchor bolts for TEP-01A . while inspecting the anchor bolt assemblies for material * j traceability. See Section VI for further discussions concerning anchor bolt embedment concern A review of the installation documentation by the NRC-SCVI inspector' revealed no evidence of material verification during installation. All of the above deficiencies remain unresolved.
} Conclusions CMTRs reviewed by CSA meet the documentation data requirements in accordance with applicable material specification require- . ments. The NRC inspector believes the independence of the CSA
material traceability inspection effort was adequate. However, , the conclusions of the CSA material traceability section were incomplete in that the material traceability findings by other ' - ' CSA disciplines were not considered. The CSA effort does not " provide an additional measure of assurance of quality in this area.
! Based on the limited independent inspection scope accomplished ?- by the NRC, material traceability and control documentation, in general, was accurate and agreed with actual inspected hardware conditions except for the following:
* Review of safety-related hardware or equipment revealed some material traceability and control concerns involving fasteners. Fastener assemblies were found missing or partially missing, indeter-
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VII-4
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minate bolting materials were installed or improperly installed and embedded anchor bolt assemblies not installed per drawing requirement . CSA Maintenance Review Inspection Scope
- '
A review of the CSA effort in the area of maintenance including personal interviews with CSA and NNI personnel - was conducted to determine the scope of the examination and maintenance work accomplished by NNI.
' Inspection Findings ',7' Many CSA concerns were found to be maintenance related. For
'
example, CSA concern numbers 2, 5, 6, 7, 11, 12, 15, 21, 23, 35, 36, 37, 38, 40, 41, 42, 46, 47, 49, 53, 61, 62, 63, 67, 70, <i, 71, 91, 93, 96, 97, 102, 103, 104, 113, 115, 124, 134, 142, 144, d 146, 147, 148, 155, 156 and 164 were all related to maintenar.ce j to some degree. The majority of these concerns involved broken, i damaged, missing or loose component parts or basic cleanliness problems. Each item associated with the above concerns should have been maintained by either Daniel for items not yet turned
<
over to KG&E or NNI for those items under KG&E cognizanc Determination of the base cause and corrective action for * .I these deficiencies is an unresolved item.
- [ The CSA effort did not include inspections into Daniel's
*
- }
; preventive maintenance program for installed items or for the 1 adequacy of DIC turnover reviews with respect to damaged item i Only those items / components / systems turned over to KG&E and j
subsequently contracted to NNI were covered by the CSA inspectio Conclusions ,
- ,
q The CSA effort in the area of maintenance was found to be
; generally acceptable in terms of independence. The inspection g scope, however, was limited to a review of NNI and did not n include an examination and evaluation of DICs preventive .
maintenance program. It appears that the maintenance effort j supplied by NNI was satisfactory based on the review of the CSA inspection.
l{
$ Numerous maintenance related concerns reported by other CSA j disciplines as noted in Section VII.B.2.b. above, were not *
addressed in the Maintenance Sections of the CSA repor i The number of these concerns indicate that the scope of the CSA effort for preventive maintenance should have addressed
*
the reasons and implications of these concerns as associated with the DIC and NNI maintenance programs. The additional measure of assurance of quality provided by this CSA effort is margina 't 4 9
[ VII-5 ,
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, TABLE VII-1 SUMMARY OF SAMPLES , No. of Samples Piping Including Associated Fittings 7.(L)* Field and Vendor Weld J,oints 16 Equipment 8
,
Fasteners 28 (L) TOTAL 59
-
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VIII. QUALITY CONTROL EFFECTIVENESS Objective The objective of the special construction verification inspection (SCVI) in the area of QC effectiveness for qualification and per-formance of QC inspectors was to determine the extent the CSA effort provides an additional measure of assurance of the quality of constructio Discussion The scope and description of the CSA coverage in this area is provided on pages VII-1 through -3 and Table VII-1 of the CSA ', repor Primarily, the effort dealt with a confirmation of QC inspector qualifications through record review and an assessment of QC inspector performance as determined from the various j inspection findings.
? During the course of the SCVI in four areas of construction, samples 4 of QC inspector certifications were examined for conformance to l established criteria and discussions were held with the QC inspectors
*
in the various disciplines involved. These activities provided a ' basis for assessing the CSA effort in terms of the stated objective . Specifics of the SCVI team observations in this area are provided - belo * Mechanical Construction
!
The SCVI team reviewed the following documents in connection
; with this are *
} ANSI N45.2.6-1978, " Qualifications of Inspection, i Examination and Testing Personnel for Nuclear j Power Plants" a j DIC Procedure AP-VI-01 " Indoctrination Training } and Certification of Quality Personnel" ! The qualification records for eight Level II QC inspectors were e, examined for conformance to the above criteria. Six quali-i " fications records were selected from Table VII-1 of the CSA report. Disciplines involvea were Weld (Mechanical), Equipment p
[ (Mechanical), NF (Mechanical), Piping, and Hangers. No ~
discrepancies were observed.
! ( Discussions were held with DIC Quality Training personnel regarding the testing of inspectors for pipe supports / restraints, hangers and expansion anchor bolts. The current DIC data
; banks of test questions were examined for Hangers (mechanical) , and a special set developed for anchor bolt inspection The NRC team found the questions to be comprehensive and to ., reflect both technical depth and past experienc .
VIII-1
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During the SCVI the team members came in contact with several Dlc personnel that were presently engaged in quality inspection work or had been QC inspectors in the past and had advanced into a more senior position. They assisted the team in locating sone of the items being inspected, provided clarification on inspection attributes as needed, assisted in providing quality documentation on components under inspection and generally answered questions about their training, experience, inspection and documentation practices. These contacts provided information to help assess the effectiveness of the DIC QC performanc Overall the DIC personnel contacted appeared knowledgeable and capable in their respective discipline , With respect to the CSA conclusion (page VII-3) that a possible
. generic concern exists with regard to the completeness of .
QC inspection requirements (based upon several findings, some l of which involved mechanical construction), the SCVI team - reviewed concern 163 and the proposed action plan. The CSA concern appears to be valid and the CSA proposed resolution ? (pending adequate resolution of concerns 157, 162 and 164) is ] a reasonable course of actio f Electrical and Instrumentation The qualifications for one instrumentation inspector and . two electrical inspectors were. reviewed to the requirements a j of ANSI N45.2.6-1978 and were found to meet those requirements.
3 One electrical inspector was interviewed and was knowledgeable .t of procedures and requirements. A program weakness identified ] by the CSA report in one area (inspection of fasteners) was
'
found to exist in several others. It was noted by the SCVI that the identification and documentation of inspection and j acceptance criteria was not adequate in several cases. Although
, not identified by the CSA team, the QC program was also found 1 not to be effective in identifying repetitious minor hardware i discrepancies identified by the SCVI in two areas (cable j rollout and cable bend radius). These items are discussed in i Section III of this report.
l1 Welding and NDE I J ihe NRC SCVI team reviewed certification and qualification j files for 3 DIC quality control personnel. No discrepancies j . were observed.
i- During the NRC inspections the NRC team came in contact with
- .] personnel from KG&E, Bechtel and DIC engaged in quality 4- inspection wor They also assisted the team in locating y items to be inspected, provided clarification on inspection i parameters as needed, provided quality documentation on 4 piping and components under inspection and answered ouestions
'
about their training, experience, inspection and detmtr.nta-
+
tion practices. Overall, with one exception discusstd in Section V.B.2.a of this report relative to the ability of the
'
VIII-2
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assigned DIC contact in providing requested documentation, the personnel contacted appeared knowledgeable and capable in their respective discipline . Reinforced Concrete and Structural Steel The evaluation of QC effectiveness in this area was performed in connection with samples from concrete pour packages and
. '
concrete expansion. anchor bolts. For the concrete pour packages the NRC' team randomly checked nine insp.ectors to .
, see if they were certified in the duties they performe From those nine inspectors, five were reviewed to determine if they were qualified in accordance with the requirements of ANSI N45.2.6-1978. The NRC team found that generally the qualification and certification records were adequate. During this review, the NRC team identified a Level I inspector performing the duties of a level II inspector for the evaluation of batch tickets. This is discussed in further ,
detail in Section VI of this repor i The qualification and certification records of two inspectors i for concrete expansion anchor bolts were reviewed. No discrepancies were observe ~ Conclusions j
.
The CSA effort in the verification of QC inspector qualifications
- ) and assessment of QC inspector performance was found to be acceptable
! in terms of independence, scope and completeness. The CSA findings
-' were, for the most part, verified by the NRC team's review. The-conclusions reached by the CSA team with respect to the possible generic concern about the completeness of QC inspection requirements a
'
appears valid in view of the NRC team's independent findings. The proposed CSA action plan for generic concern 163, which bears upon i this matter is reasonabl The CSA effort in this area provides an additional measure of j 4 assurance of the quality of constructio i r ') - i
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1 . IX. QUALITY ASSURANCE
. Objective The objective of the special construction verification inspection (SCVI) in the area of quality assurance was to assess the extent to which the Construction Self Assessment (CSA) effort and followup corrective actions provide an additional measure of assurance of the quality of construction at the Wolf Creek Generating Station (WCGS). Discussion Section VIII of the CSA report was reviewed to assess the scope of CSA inspections for the area of quality. assurance (QA). These inspections covered: Kansas Gas and Electric (KG&E) QA effectiveness, KG&E audits, corrective action systems, and design change contro A sample of the CSA effort and findings for the area of KG&E audits and corrective action systems was selected for examinatio i As related to the SCVI sample, a review of CSA generic concerns 159, 160, 161 and 170 was also conducted. The generic concerns were i reviewed for the scope of the concern and status of the Delian CSA-Phase II corrective action, and supporting KG&E or DIC documentatio Also, the involvement of KG&E in assuring that required corrective ,
actions are effectively implemented was reviewed. The review of the CSA QA finding for design change control, generic concern 166 (snubber - stroke problem), is covered in Section IV.B.1.b of this repor I J Other factors considered in the SCVI assessment of the CSA effort J were: independence; adequacy of scope for the stated objective,
'
completeness; appropriateness of CSA deficiency categorization as to level of seriousness; and the overall conclusions of the report
'
and adequacy of corrective action. Discussions with onsite Delian,
.; KG&E and contractor personnel and the results of the NRC SCVI were q
. included in the overall evaluation of the CSA effort.
k Documents examined in the text which, in addition to specific
- documents referenced, provide the basic acceptance criteria for j the SCVI in the area of quality assurance, include
o
* 10 CFR 50, Appendix B
'l
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WCGS PSAR, Section 17, QA Program KG&E/Delian Contract and' Letter Agreements
! * KG&E QA Manual / Audit Procedures I * Delian Corporation Construction Self Assessment (CSA) Procedures, Rev. O, dated October 29, 1984 and Revision 1 dateo November 1, 1984 and prior CSA Fonns J
' CSA Phase I documentation for selected samples / areas inspected CSA Phase II concern file folders
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+
,
% Involvement of KG&E - CSA Phase II Inspection Scope The CSA Phase II effort for control and management of corrective actions and closure of CSA concerns was reviewed to assess KG&E involvement in assuring that activities associated with establishing and implementing corrective actions are effectively implemented, Inspection Findings
- The SCVI review of CSA evaluations and corrective action plans for the 155 specific and 15 generic concerns confirmed the
'
quality-affecting nature of these activities and that adequate procedural controls subject to KG&E QA program surveillance were . required. SCVI observations of CSA corrective actions determined I that current Delian forms for documenting the CSA effort were l+ inadequate. There was insufficient assurance that CSA technical evaluations would be performed by individuals with required i expertise and be adequately documente I During the SCVI, team observations also noted the general
. disagreement between DIC and CSA personriel on the various concerns identified by CSA as well as the proposed CSA action
- plans. SCVI team discussions in this regard resulted in the -
question of whether DIC would be objective in implementing CSA action plans for additional sampling of DIC work to determine the scope of the CSA generic concern and required corrective .. action. Based on these observations, a meeting was held by j the SCVI team leader with the KG&E Director of Quality and the
KG&E Superintendent, Quality System Engineering to obtain a ] further clarification of the involvement of KG&E in ensuring i effective implementation of CSA action plans and corrective j action by DIC.
} A summary of NRC discussions with KG&E and the quality assurance a commitments made for KG&E involvement in assuring effective j implementation of corrective actions for CSA concerns are j discussed in further detail in Section II of this repor i j
o Conclusions j With the KG&E commitments noted in Section II of this report -
*
and the followup action by KG&E to ensure that all past and I current CSA Phase II activities will be performed in
- t accordance with the November 1,1984 Delian CSA procedure, 4 the KG&E involvement in assuring the effectiveness of CSA
} and DIC corrective actions is considered acceptabl t * * ,
,
*
IX-2
.
f te ==K %** * P .p -y *7 j "- V T 'h * C*rp.,t P * g **T ng**-6_ 19y P ff **'f U' * * *W f T,**' [ * T*"I * ~7" $[' ' '" A . y' * * *' ~ '
_ - _ _ _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___--_ _ _ - . . _ _ _ _ - _ - _ _ _ _ _ _ - _ - _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ . _
. : - KG&E Audits Inspection Scope The KG&E construction audits discussed on page VIII-2 and Table VIII-1 of the CSA report and related CSA inspection findings in this area were selected for the SCVI sample. Specific discussions were conducted with the CSA team leader and KG&E personnel i including: Manager, Quali*y Assurance; Superintendent, Quality Evaluations; and Supervisor of Audit Specific documents reviewed during the SCVI of the CSA of KG&E audits include:
- ' QAP W18.1, Rev. 1 "WCGS Audit Scheduling and Surveillance Information Reporting" i , QAP W18.2, "WCGS Audit Procedure" !- * QAP C16.1, " Corrective Action for QA Program Breakdowns"
.
CSA Concern Closure and Corrective Action / Verification - Forms for documentation of CSA Phase II actions, including: [ - CSA Action Plan, Rev. O, dated 9/17/84 ., 4 - CSA Action Plan, Rev. 1, dated 11/1/84 l - KG&E Corrective Action Documentation - CSA #159, including letter KQWLO84-126, W. Rudolph to F. Pimentel, dated 9/25/84 i Supplement to CSA Finding No. 159, no date KG&E File No. TE:57061 audit reports for audit of DIC,
- including series nos.: K71, K106, K107, K109, K111, K112, K113.
1 Inspection Findings C i (1) CSA Report Review \ [' The CSA review of KG&E auoits was as represented by the CSA report. The CSA included a review of existing KG&E QA i procedures for scheduling and conducting audits and records j for audits conducted in 198 The SCVI review of KG&E audit plans and reports for audits
, of DIC generally confirmed the first CSA finding that KG&E
. audits are well planned, thorough (for planned scope) and consistent with Tactice; 1.e., with KG&E QA program for planning, cs g, reporting and documenting audit .
*
IX-3
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The CSA finding that Lead Auditor qualifications were acceptable was confirmed through the SCVI review of the above referenced 'K' series report .The SCVI of audit reports and of dates the audits were conducted confirmed the CSA finding (generic concern #159)
-that certain KG&E construction audits scheduled for the ,
first and second quarter of 1984 were not conducte However, the SCVI noted differences in the count of audits i not conducted as recorded on CSA forms a.nd the CSA repor *
~ NRC discussions with the KG&E Superintendent, Quality Evaluations resulted in a KG&E-prepared Supplement to CSA ' Finding #159 and the following clarification. The count for KG&E (TE:57061) construction audits of DIC not conducted as scheduled was changed to seven. This included 'K' audit Nos. K106, K109, Kill, K112, K113, K119 and K122. All i seven of these audits were shown as rescheduled for -
i~ completion during 1984. - Also five of the seven rescheduled
-; audits had been completed. The two (K119 and K122) not-p completed were both scheduled to be completed by 11/5/8 i , 'The above status for the seven audits was confinned by the SCVI for the above referenced audit reports, except it was '
noted that audit K122 and the related report were completed on September 17, 198 .
(2) CSA Phase II i The status of the CSA corrective action effort at the
end of the SCVI for CSA ~ concern #159 was: I! j Initial CSA Action Plan issued on 9/18/8 p j * CSA review of KG&E response (KQWLO 84-126), noted by CSA as Incomplete. CSA Rev. 1 Action Plan issued on s ..! 11/1/8 'l i The statements included in the current CSA action plan Ji are:
y " PROBLEM STATEMENT: A . 't "CSA notes that the KG&E response states that the ii root cause of the audit concern was a need to q reallocate four lead auditors to another program.
k The indicated corrective action is to subsequently ]' perfonn the' audits not perfonned." [during 1984] q-N "It is noted that this corrective action does not Q address how this problem will be prevented in the
,; future for startup testing and operations audits.
'! -
)
<i
'
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.
!
"KG&E is requested to provide the following l additional information:
l
" ACTION PLAN:
:
"1) The basis for audit schedules, (i.e. , how ,
the activities to be audited are defined 1 and how the schedule is decided upon).
"2) The plan to insure that adequate resources are available to meet the schedul "3) The procedures, program requirements, et which document the above basis and plan."
= " The KG&E corrective action response and implementation appears to have adequately resolved the immediate concern and potential'for a violation of KG&E's annual ANSI N45.2.12 audit commitments for audits of DIC. The CSA concern that KG&E address how this problem will be prevented in the future for startup and operations audits is
appropriate.
I The SCVI noted that the findings of a rescheduled and ,
,
conducted audit TE:57061-K111 did result in four Quality l Program Violations (QPV) and two Quality Program Deviations * Ti (QPD). Also, the audit ' report stated that several findings
; of this audit had been identified by previous audit * TE:57061-K52. The scope of these audits pertained to implementation of the DIC Field Change Request (FCR)
portion of the design control program.
j As a result of the KG&E significance attached to QPV
: findings (QAP W18.2, paragraph 4.1), acceptable KG&E resolution of TE:57061-K111, Design Control audit findings is needed. This item remains unresolve Conclusions j The CSA report effort in the area of KG&E audits is generally j considered acceptable in terms of independence, scope, complete- ! ness and characterization of concerns identified and conclusions reached.
] For CSA Phase II, the current CSA concern 159 action plan is considered an acceptable method of resolving the CSA concern and
; preventing recurrence of a similar problem during operations.
'
,
The CSA evaluation of KG&E response to CSA concern 159 will also need to address and resolve the differences in the KG&E
! and CSA count of audits not conducted, including any pertaining 4 to audit of construction activities other than performed by DI '
The CSA evaluation should also review the adecuacy of KG&E's response on the impact of not conducting audit TE:57061-K111 on schedule has on the assurance of quality of construction prior
,
to plant operatio . .
-
IX-5
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- * ' . .
Based on the NRC observations of the CSA effort in this area, an additional measure of assurance of the quality and effectiveness of the KG&E audit program was achieved. An additional measure of assurance of the quality of the DIC construction quality assurance program will be achieved with the effective imple-mentation of the CSA/KG&E Phase II followup corrective actions for CSA concern 15 . Corrective Action Systems
-
a Inspection Scope The CSA scope, findings and conclusions in this area are discussed on pages VIII-2 through VIII-5 of the CSA repor The objective of the CSA review of certain corrective action systems was to determine if deficiencies were being properly
identified and dispositioned. The CSA sample of corrective
- 4 action system documents as described in the CSA report included:
! 20-30 DIC Nonconformance Reports (NCRs), several hundred DIC ; System Discrepancy Lists (SDLs), 20-30 DIC Notice of Discrepant l' Conditions (NDCs), 20-30 DIC Field Change Requests (FCRs) and i 1 20 KG&E Startup Field Reports (SFRs).
' The scope of the SCVI in this area included: the CSA report ,
'
findings and conclusions, a sample of DIC and KG&E corrective
*
j action system documents reviewed by CSA, and followup corrective I actions for CSA generic concerns 160, 161 and 17 . Inspection Findings i
; (1) CSA Report Review :
1 CSA findings of examples of improper use of corrective j action system documents include: 2 NCRs, 2 SDLs, 5 NDCs
:ad 7 SFRs. No misuse of FCRs was noted in this sample s
i" or by the CSA review in the area of design change control (Tables VIII-2 and Table VIII-3), where 22 FCRs were j reviewed to verify appropriate revisions to drawings.
a J-i CSA conclusions relative to the above findings are i sumarized in (a) and (b) and restated in (c) below: a 1 (a) The 2 NCR and 2 SDL examples of misuse were an d isolated case of generally acceptable DIC use of
- } those system f Q (b) The use of NDC's by DIC for closecut of NCR's at
; transfer of a system to KG&E should be reviewed and "
such use of NDCs should be controlled on a case by d case basis. Further, DIC personnel should be informed
? that NDCs should not be used to close out NCRs for systems not transferred to KG&E and which are best
, resolved by DI ' (c) "KG&E should insure that the SFR system is well under-stood by those who use it. It may be advisable to
.
" IX-6 i ' q - < .- - - -
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*
. :
include more guidance in Administrative Procedure 14-402 regarding classification of the type of SFR, use-as-is disposition, purpose of the various signoffs, etc. Also, training could be provided for those using the SFR system. Since four out of the approximately 20 SFRs reviewed were not correctly classified as NCR type, it would be prudent to perform an audit of SFRs starting with the first ones issued to determine if this mistake is widespread. This is important since SFRs which are not processed as NCRs are not lifetime records and do not receive trending reviews."
The NRC review of the Executive Summary of the CSA report, noted that the CSA findings in this area were
- appropriately addressed.
' As a result of the CSA Phase I effort, it was noted that CSA generic concerns 160 for SFRs,161 for SDLs
; and 170 for NDCs were established for followup corrective ! action. The need for CSA generic concern 161 was not , '-
apparent at this time, based on the CSA report " isolated case" conclusion for SDL (2) CSA phase II Corrective Actions - Generic Concern 160 CSA generic concern 160 was described as improper use *
, and processing of Startup Field Reports (SFRs). The :
concern was based on the seven CSA findings of misuse of
! SFRs. These included 4 SFRs not properly classified as - '
an NCR,1 SFR not having Bechtel concurrence for use-as-is disposition and the review of 2 SFRs being perfonned by the originator of the SFR. In summary,
,
the conclusions of the CSA report in this area indicate that significant corrective action should be initiated,
, relative to procedural revision, training and the audit i
,
of all SFRs issued to determine the magnitude of the j problem with use of SFRs.
$ Specific documents reviewed relative to CSA resolution
; of this concern are:
~
* CSA Corrective Action / Verification Form,
, including Action Plan, dated 9/18/84 4 CSA Concern Closure Form, with CSA Evaluation l Acceptance and proposed CSA Action Plan, i dated 10/31/84 r
* KGaE Correspondence, KQWLKWSU 84-164, W. Rudolph to R. J. Glover, DIC, dated October 9, 1984, Subject: Corrective Action Request (CAR) No. 18
'
IX-7 _ . , ,. , : --- -
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.
.
-
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* KG&E Correspondence, KQWLKQW 84-387, R. Stambaugh/M. W. Shannon/C. A. Daley to C. G. Patrick, dated October 10, 1984, Subject: CAR No. 18-TE:50140-K003-Startup Field Reports
* KG&E Correspondence, KQWLK0W 84-407, C. Patrick to R. M. Stambaugh, dated 10/24/84, Subject: Response to Quality Concern
'
7 * KG&E Correspondence, KQWLKSLU 84-177, dated October 18, 1984, Subject: KG&E QA Audit 9 Report TE:50140-K003
; * Startup Administrative Procedure, Startup , Field Report, ADM 14-402, Revision 11, ', dated 3/21/84 and Revision 12, dated i 10/9/84
l Corrective Action Request (CAR) No. 18,
!
dated 10/9/84 ,
:i : * CSA package of SFRs '
A general sumary of parts of the information contained
~
in the above referenced documents germane to the SCVI . assessment in this area follows'. The information on the CSA forms was found to include the CSA acceptance of the KG&E response including: l CAR #18 on Nonconformance Control and r Correction
j
' * Work Hold Agreement #22 on Nonconforming Condition The CSA evaluation remarks stated: " Verification should include the following:
0*
" KG&E Quality should have verified corrective action a for CAR #18 and closed the CA i j " A sample of several Non-Q SFR's should be reviewed I by CSA to confirm they are, in fact, Non-Q.
j " A sample of several Q SFR's requiring work on a
. hardware item should be reviewed by CSA to confirm 'i that implementation documentation is identified , in accordance with procedures.
" KG&E Quality should have verified corrective actions called for in Work Hold Agreement #2 I
*
IX-8
'
.
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. s " Revisions to ADM 14-402 and ADM 14-407 to insure sufficient programmatic controls for nonconforming conditions should be verifie " Documentation of 'nonconformance identification'
and ' administrative procedure' training should be verifie " Existence of an approved and controlled Q-list should be verifie " Revisions to supporting ADM 14 series procedures related to the SFR and RIR programs should be verified."
, In the October 9,1984 document KG&E directed that DIC take
, necessary remedial action under CAR #18. This document, in j part, stated:
.i "The problem was initially. identified while P performing Audit TE:50140-K003 'Startup Field Reports' and resulted in Work Hold Agreement
#22." .
~
The October 10, 1984 document was found to express the auditor's concerns on CAR #18 requirements. The October 24, .
,
1984 document provided the managers response to each of five
- auditor concern [ '
The attachment to the October 18, 1984 document included audit report, TE:50140-K003. The scope of the audit was stated as follows:
. 'm "This audit was conducted to evaluate the adequacy and effectiveness of the Startup . Program for processing of nonconforming and j other conditions utilizing Startup Field j Reports."
i The findings of audit TE:50140-K003 include the following
-
statemen i
"8ased on the auditor samples, it was , determineo that major discrepancies . existed in the Startup Field Report Program, from both a program content and 0( - implementation aspect."
. The audit report lists three Quality Programs Violations '.' (QPVs): 9/84-53, 9/84-69 and 10/84-1) and found additional noncompliances. The QPVs were noted as being contrary to the requirements of FSAR, Section 17 and ADM 14-40 The audit report, Section IV, Evaluation states:
*
IX-9
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- _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _
i .- i !
"The program for utilization of Startup Field i Reports was found to be poorly defined, with significant discrepancies relative to implementation of program requirements. The extent and nature "
of the program and implementation deficiencies were such that compliance to the regulatory and standard requirements for identification, control, processing and closeout of nonconforming conditions was not being obtained. This lack
! of program control and noncompliances relative *
to implementation of program requirements has caused extensive indeterminancies relative to
. hardware conditions resolved by the use of Startup Field Report , " Corrective action measures as specified by ; Work Hold Agreement #22, when fully implemented 1 and complied with by the Startup organization, I will provide an adequate program for the 1 utilization of Startup Field Report :: ! " Remedial actions as specified by CAR #18, I when completed, will provide WCGS Management -
i with a measure of assurance that previously J
'
processed and closed Startup Field Reports : have been properly evaluated and closed in - accordance with established requirements."
The audit report was signed by the Audit Team Leader j and participating auditor and initialed by the Auditor Supervisor, all dated 10/18/8 a i
"
In general, the SCVI found the CSA evaluation of KG&E response to CSA concern 160, and action plan relative to CAR #18 and Work Hold Agreement #22 as an adequate resolution. A SCVI general review of CAR #18'found it adequately represented audit TE:50140-K003 findings and 1 the requested corrective action appeared complete, except j as discussed belo > Corrective action required under CAR #18 should be clarified j in the following areas. The guidance on discontinuing the i review of a design error was found to be incomplete. The
guidance should be revised to ensure that appropriate program requirements of design control are satisfied for
)l -
each change in design. Additionally, where Reject Item Reports (RIRs) are issued for SFRs without identifiable or retrievable documentation, all QA/QC documentation as j
..
required to ensure the quality of the items should be j established in accordance with applicable quality program i requirements and be subject to KG&E audit. Other methods used to verify the quality of work or an item should a receive KG8E QA review and approva i
.
*
j IX-10 1 - . - , _ _ m _ ..~.,, ,m,,, m.- -- --
,.g7 7 7.s, .,. - .,- . .
. 8 The CSA package of SFRs for the CSA sample was obtained from Delian. The SCVI review of the package found it contained 46 SFRs associated with 13 different safety systems. The CSA report did not list the CSA sample of 20 SFRs and therefore no direct review those SFRs could be performed. The CSA finding of failure to check NCR for three of the four CSA identified SFRs: 1-GN-14, 1-GM-12, and 1-HB-41 was confirmed. It was noted that fourth SFR 1-MA-42, was not, as appropriate, stamped "Q". SFRs ,
1-KA-56 and 1-KA-55 relating to the other CSA findings were not included in the CSA package and these findings could not be confirmed. The SCVI review identified a number of other SFRs not checked as an NCR when required; 4 SFRs not initially checked NCR in block 6 were subse-quently checked NCR in block 17. There were also a number of "Q" SFRs not stamped "Q", as required. The above SCVI assessment generally confirms the CSA and KG&E audit t findings in this area, i
*
Included in the CSA inspection sample was SFR 1-B8-14 . This SFR was identified in block 6 and block 11 as a
'.
potential 10 CFR 50.55(e)/Part 21 but was not identified as NCR type or addressed in the CSA report. It is readily apparent from the description of the probable cause and the problem that the ioentified problem is subject to a 10 CFR 50.55(e)/Part 21 evaluation. The SFR identified - i the affected items as: Component DPBB01, A, B, C, and D, 1 manufactured by Westinghouse for the Reactor Coolant System i* (88). The initiated RIR described the problem as a broken high voltage termination lug at the surge suppressor on i phase C. The apparent cause was that the component is made
; of cast brass and may have been overtightened. The SCVI in - *
this area was performed after the onsite inspection and therefore no NRC review of the KG&E review of controls for j , lug terminations or evaluation for reportability was
; performe '
The review of KG&E evaluation of SFR 1-B8-147 for reporta-bility to the NRC and of the related controls for the
: tightening of termination lugs during installation remains r unresolve ; (3) CSA Phase II Corrective Actions - Generic Concern 161 , ; , CSA generic concern 161 was oescribed as SDLs not being ; properly utilized or dispositione I Specific documents reviewed relative to the resolution ; of this concern include: * CSA Corrective Action / Verification Form, 1 Rev. O, 9/17/84, including the CSA finding ano proposed CSA action pla )
' I ' IX-11 -
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_
*
1 .
* CSA Concern Closure Form, with CSA Evaluation Acceptance, dated 10/15/8 * DIC Response Report, dated 10/11/8 I Stop Work Action No. G-003, dated 8/27/8 Corrective Action Report (CAR) No. 1-G0045, ; dated 8/27/8 ! * DIC Response Report, dateo 9/13/8 The review of the specific documents listed above found that generally acceptable CSA and DIC corrective action was established to resolve CSA concern 161. Confirmation of corrective action is currently pending CSA verificatio It was noted in the Response Report; dated 10/11/84 that the problem with SDLs had been previously identified by ! NRC audit 482/84-08. A review of the NRC transmittal i of report 482/84-08 to KG&E found that a Notice of Violation i had been issued for two deviations from procedures for '
use of SOL (4) CSA Phase II Corrective Actions - Generic Concern 170 ,
! CSA generic concern 170 was described as improper use of the system (NOCs) for controlling nonconforming g conditions for equipment turned over to KG& ,
Specific documents reviewed during the SCVI of this S concern include:
*
'j * CSA Corrective Action / Verification Form, dated
, 9/18/84, including the CSA finding and action j plans, Rev. O, dated 9/17/84 and Rev. 1, dated
10/11/84, i R * KG&E letter, KQWLO 84-134, W. J. Rudolph to d F. Pimentel, Subject: KG&E QA Response to CSA Finding 17 l } * KG8E Procedure for Control and Resolution of i Discrepant Conditions Reports, ADM 14-416 j Rev. O, dated 7/18/8 The current CSA action plan lists seven steps generally directing that a major audit of a sufficient sample
, (95% level of confidence) of NOC's be conducted to examine l and clarify the scope of the problem. A note on the CSA ! action plan requests that " Final KG&E submittal, subsequent to CSA review, shall be submitted by KG&E QA utilizing
_ appropriate QA vehicle (s) 1.e. CARS, NCRs, 10 CFR 50.55(e)."
' k IX-12
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i
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. I The KG&E letter KQWLO 84-134 responding to the CSA action plan provides a report on the results of a 100% (not sample)
review of all closed NDCs. The review is based on verification of compliance with the procedural requirements of ADM 14-416, Rev. The KG8E review of the number of NDCs for each discipline area included: Electrical - 31, Piping - 42, Hangers - 26, Mechanical - 5, Civil - 12, Welding - 3, for a total of 119 NOCs reviewed. Of the 119, the KG&E review identified 43 NDCs with deficiencies, 40 of the 43 deficiencies were resolved leaving 3 of the 119 NDC deficiencies unresolve Based on the KG&E review and total number of deficiencies identified, it appears that some revision to procedure ADM 14-416, Rev. O. would be appropriate to clearly indicate criteria for the selection of "the appropriate resolution" document and to provide for a more timely issuance of these documents. Also, currently it is ' indeterminant whether the " lateness" in the issuance of
-
NCRs to correct a problem had any affect on compliance with certain requirements of NCR procedure AP-VI-02, i.e., , for ASME system / components " prior to stamping" or "after stamping", under Section 3.30.1 and 3.30.2. Thus an audit of a sample of the corrective action taken by these NCRs appears appropriat . The status of CSA concern 170 at the close of the SCVI was
still pending completion of CSA's evaluation of KG&E's report response. . Conclusions
; The CSA effort in this area was found to be generally acceptable j in terms of independence, scope, completeness, characterization of the concerns identified and conclusions reached. The one
!e exception is that the CSA scope for review of FCRs is considered
* marginal based on the results of the KG&E audit TE:57062-K111
{
.. discussed in B.2.b.(2) above.
In general, the scope of current CSA Phase II corrective action
plans for CSA generic concerns 160, 161 and 170 and corrective action discussed in referenced CARS or other documents are .1 considered' adequate for achieving the required corrective action, with the following clarification:
' (1) For CSA concern 160 and as discussed above, CAR #18 and i the CSA concern 160 action plan should be revised to include '
additional clarification of intenced corrective action
! requirements involving SFRs for resolution of " design errors" or without " identifiable or retrievable documentation".
(2) For CSA concern 170 and document KQWLO 84-134 as discussed above, appropriate revision of procedure ADM 14-416, Rev. O is required to prevent recurrence of deficiencies in the use of NDCs of the type discussed in the KG&E repor ' IX-13
, , * . m .. ..- - - . . . , ,. ,m, g , _ , ,,. ..,__g.my, ., . ._ ., 7 7 _ r .
1 /- KG8E should audit a sample of NCRs issued late due to the deficiencies in processing NDCs for compliance with procedure AP-V1-02, Section 3.30 provisions for ASME systems / components prior to and after N-stampin : Based on NRC observations of the CSA report effort in this
'
area, an additional measure of assurance of the quality of the corrective action system programs reviewed by CSA, except for SDLs, was achieved. Additionally, a significant additional j measure of assurance of the quality of construction will be t achieved with the effective implementation of the CSA/KG&E Phase l II followup corrective action for CSA concerns 160, 161, and 17 .
, KG8E 10 CFR 50.55(e) Evaluation Inspection Scope i "
KG&E TE:50140-K003 audit findings of Quality Program Violations (QPV) in the area of Startup Field Reports were selected for 3 SCVI review of KG&E evaluation for reportability of the
:j identified QA program breakdown to the NRC. This area was .[ also selected to assess the adequacy of CSA Phase II followup j corrective actions, t . Specific documents reviewed during the SCVI in this area :
include: .
'l , *
III. Project Policies, 17 Reporting Significant Deficiencies and Defects, Revision 1, dated 2/84
* . KG&E QA Procedure, QAP 18.2, Revision 1, dated .' 10/10/84, Parts 7.4.2.0 through 7.4.2.0 for j action to be taken when there is identification-l of a condition adverse to qualit ,
! 4-
*
4 KG&E Correspondence, KQWLK0W 84-380, W.- M. Lindsay j to W. J. Rudolph, dated October 4, 1984, Subject, i 50.55(e) for Startup Field Reports i * n WCGS Request for Reportability Evaluation, by G Auditors C. A. Daley/M. Shannon and Supervisor, A R. M. Stambaugh, dated 9/18/84 '! * g Telephone Call Record, dated 10/4/84 from L H. . Chernoff/W. Rudolph, M. Lindsay/C. Patrick / M. Shannon/C. Daley, KG&E to B. Taylor, NRC, d. . Region IV R * File Note, by R. M. Stambaugh, dated 10/25/84, [ w/cc to M. Shannon and C. Daley, Subject, s Telephone Call Record J 9 T
* ~
IX-14 a , s W ~Y[C .* *'7 9 "' * * *ren n '.'f 4%' W1 . ** r J.QM**[.L'1'{;,*"JR "? * ** + C ';' ~" * '" ' ' ' ' '
______
. t *
Interviews with KG&E Auditors (contractor), M. Shannon and C. Daley and Supervisor R. M. Stambaugh General Discussions with KG&E QA Manager, WCGS
*
List of KG&E auditor identified sample of types of deficiencies in hardware / design
,
being resolved through use of SFRs Inspection Findings Based on the SCVI observations of the above referenced documents, interviews and discussions, the SCVI found that KG&E policy and procedural requirements applicable to KG&E QA program personnel (auditors and managers) for evaluation of a condition adverse to quality, as noted by audit report TE:50140-K003, were satisfied, to the extent that current i information was available for evaluatio It was noted that the auditors evaluation under the WCGS Request for Reportability Form, dated 9/18/84 found that two of the criteria required for reportin were satisfied (i.e., relative to (1)g under 10 CFRwhich a deficiency, 50.55(e)were it to have remained uncorrected could have affected adversely - i the safety of operation of the nuclear power plant, and (2) j a deficiency which represents a significant QA program i breakdown). This input to the review process was then evaluated by the assigned QA organization Significant Deficiency Coordinator (SDC) who' determined that the auditor conclusions for item I had not been demon!trated and concluded based on information available that the matter was not reportabl The KG&E QA Significant Deficiency Coordinator (SDC) indicated ]l' that the KG&E QA Manager (WCGS) agreed with his conclusio The SDC also stated that he had not received any new information subsequent to his evaluation. Based on further discussions the
SDC stated that he was aware of the list of typical SFR problem descriptions / discrepancies prepared by the auditing function of
. '
KG&E. Further, that until such time that it is demonstrated that identified startup problems of the type on the reference list (e.g., leak during calibration, running clearances out of tolerance,
'
terminal blocks not installed per design, drawings do not reflect , correct information) are deficiencies which, if not corrected, ] could have affected adversely the safety of operations, the
: identified QA program breakdown is not viewed as reportable, or
' potentially reportable. The SDC also indicated that his respon-sibilities as the V E QA SDC did not require him to seek out
: this information, i.e., the procedures in effect require that this information be brought to his attentio The SCVI imediate concern regarding KG&E's current position on the reportability of this item to the NRC was generally resolved upon being informed by KG&E of the documentation of two telephone
*
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calls informing the NRC Region IV of the general problem with the SFR program and of the Work Hold #22. The first notification to NRC was on 10/4/84. The second notification was on 10/25/84, during the SCVI of this area. The second call resulted in KG&E
. licensing informing the NRC that the 10/4/84 telephone record statement that " hardware inspections are being conducted to determine if any nonconforming materials exist in the plant",
as highlighted on the record, was an incorrect statement and needed to be correcte Conclusion
' ! Based on the above, KG&E should continue to review this matter i
for reportability to the NRC as new infonnation becomes available on either the significance of the QA program breakdown or resulting hardware deficiencies.
u .! ' The KG&E/CSA corrective actions should ensure that the KG&E program for identification and review of deficiencies for reportability to the NRC is being implemented in a timely i manner for SFR or NCRs checked "potentially reportable"; and ]1 for deficiencies in construction which could have gone undetected due to the breakdown in the SFR QA program, as identified by the TE:50140-K003 Design Control audi '
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ATTACHMENT A PERSONS CONTACTED The following people were contacted by the NRC inspectors during the special construction verification inspectio Kansas Gas and Electric Company R. Bird W. Lindsay H. Chernoff 0. Naynard C. Daley C. Parry 0. Dominguez C. Patrick P. Dyson E. Peterson ' D. Felix W. Rudolph G. Fouts M. Shannon R. Grant R. Stambaugh T. Halecki J. Wesbrooks G. Koester Daniel International Corporation
,
D. Bach S. King -
- J. Berra S. Koenig
'. ' R. Booth H. Kubasek L. Boss V. McBride P. Early R. McCraney L. Easterwood R. McGriff D. Garrett J. Maine > R. Gesling G. New D. Gillespie L. Payne L. Gourley G. Riley i ' P. Halstead B. Robinson J. Hanvey H. Shields - J. Hightower L. Smith J. Hooks K. Steiner , J. Lewis L. Weeks Delian Corporation S. Baron F. Pimentel '
, B. Carter C. Thompson D. Leaver H. Wong B. Palmer G. Young Bechtel K. Anderson J. Purdy J. Fletcher D. Quattrociocchi G. Hoffman G. Stanley W. Jenkins S. Wood C. Mathews
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. G. Barber .
J. Lytle
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In addition to the above personnel, numerous other inspectors, engineers, g and supervisory personnel were also contacte .
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. o ATTACHMENT B GLOSSARY OF ABBREVIATIONS AE Architect Engineer
- ANSI American National Standards Institute ASME American Society of Mechanical Engineers AWS American Welding Society CAT Construction Appraisal Team CAR Corrective Action Request CBI Chicago Bridge and Iron CFR Code of Federal Regulations CMTR Certified Material Test Report CSA Construction Self Assessment by the Delian Corporation
. Delian Delian Corporation DIC Daniel International Corporation ECR Engineering Change Request FCR Field Change Request FSAR Final Safety Analysis Report *
HPSI High Pressure Safety Injection , HVAC Heating, Ventilation, and Air Conditioning . I&C Instrumentation and Control -
. IE Office of Inspection and Enforcement r IEEE Institute of Electrical and Electronics Engineers Kansas Gas & Electric Company -
KG&E KCPL Kansas City Power and Light Company MCC Motor Control Center f10V Motor Operated Valve NCR Nonconformance Report [ NDC Notice of Discrepant Condition NDE Nondestructive Examination
, NRC Nuclear Regulatory Comission NNI Newport News Incorporated '
NOD Nuclear Operations Division
'
NRC Nuclear Regulatory Commission PSAR Preliminary Safety Analysis Report Q Safety Related QA Quality Assurance QC Quality Control p QPV Quality Programs Violation RCI Request for Clarification or Information REC 0 Richmond Engineering Company RG Regulatory Guide
,
RIR Reject Item Report
; SCVI Special Construction Verification Inspection by NRC '
SDC Significant Deficiency Coordinator
,
SDL System Discrepancy List
; SFR Startup Field Report SNUPPS Standardized Nuclear Unit Power Plant System WCGS Wolf Creek Generating Station WN00 Westinghouse Nuclear Operations Division
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s - 6 ATTACHMENT C CSA STATUS SUMARY -
,
Case-Specific Concerns Amount and Date Code Code Description of Status
'
10/26/84 10/30/84 -
, ,' A No response received 2 1 B CSA is evaluating response 9 12
1 C CSA requires further action /information 20 25 a j D CSA accepts written response, pending 33 60
-
verification j
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E CSA rejects verification 0 0 - . I F CSA accepts verification 2 14
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G Closure by CSA Manager 0 0
- * Requires CSA administrative processing 89 43 T!I!i T9i
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3 Generic Concerns a li
< Amount and Date j Code Code Description of Status
3 10/26/84 10/30/84 1'
!! A CSA Action Plan issued *
4 4 . i.
f B Corrective Action Complete (per writte j response by actionee)
1 C Response determined incomplete by CSA 0 0 4;. t D Response accepted by CSA 2 2
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j y E CSA rejects verification 0 0
.
F CSA accepts verification 0 0 G Closure by CSA manager 0 0 e
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ATTACHMENT 0 STATUS OF CSA GENERIC CONCERNS (Per Table of Resolution of CSA Concerns) 10/25/84 11/01/84 Code Description CSA # Total CSA # Total A Action Plan Complete, CSA 156, 157 4 156, 157 4 Awaiting Complete Response 163, 169 163, 169 B Response Received, CSA 158, 159 9 158, 162, 7 Evaluation in Process 160, 162 164, 166 164, 166 167, 168 167, 168 '170 170 C Response Incomplete, per 0 159 1 i CSA Review i D CSA has Approved Response, 161, 165 2 160, 161 3 Closure Pending CSA 165 Verificatio *
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j ' ATTACHHENT E TABLE OF RESOLifflON OF CSA CONCERNS 1> . Hea 8 11/08/84 , [l CSA RES (A)
* ITEM CON OR ITEM STATUS BY ACTION / RESP. REV/ CSA REP. DUE DATE CIOSE OUT CSA , li MlatBER DESCRIPTION N DIS RESP, ORGANIZATION ACTION PLAN CSA STATUS DOCUMENT VENIFICATION ,a.-
CONC. REF. SCHJAC j l Structural Steel, Misssag I Dic Documentation None Required 0-F Yes V-3 CSA Con-Documentation Located /Ites Closed V-Il cern Form A- i
2 Electrical, Rust on 2 DIC NCR Prepared / None Required 0-D Yes
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Table NDC-E-Oli L . rf Conduit Ites Closed 1 11-2,16 WN-IlO65-84 Q .A 3 Electrical, Cable Hi WN-M469-84
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3 DIC NCR Prepared / None Required 0-D Yes 11-16 NCR-ISN-
,
Separation Item Closed I 19387E 4 Electrical, ConJust 4 DIC NDC Prepared / Required I-C No 18-18 NDC-E-018
] Marking Item Open I (Voaded Copy)
5 Electrical, Fles Out 5 DIC NDC Prepared / None Required 0-D Yes 11-16 NDC-E-010
.j of Condulet item Closed 1 J
q 6 Electrical, Flex 6 DIC NDC Prepared / Mone Required 0-D Yes 11-16 NDC-E-026 _ Connection Loose Ites Closed I CWP CS-39-E .i 7 Electrical, Fatting Loose 7 DIC NDC Prepared / None Required 0-D Yes 11-16 NDC-E-013 Item Closed I
'. 8 Electrical, Conduit Rends 8 DIC Hemo Prepsred) Required d-C No 11-2 He'm2 of [/U84
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- Greater than 360* Item Open i 11-16 , on Hecord
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) 9 Electrical, Mi DIC NDC Prepared / None Required 0-D Yes 11-2 NDC-E-015 -
Separation Item Closed i 11-16
] ID Electrical, Lack of DIC
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10 Memo Prepared / None Required I-F Yes 11-16 Hemo of 6/29/84
-
Cable Flex Item Open 2 * 10/9/84 on Record 11 Electrical, Flex 11 DEC NDC Prepared / None Required 0-D Yes 11-16 NDC-E-OI2
.
Connector Loose item closed 8
.
! K1y for (A) CSA Conc. = CSA Concurrence CSA Status Codes: (A) No resp. received i
(1) Italated or Limited Frequency (2) Potential Generic or Programatic CSA Concern (3) Generic or Programatic (B) Hequires CSA evaluation (C) Furtlier Yze. Indicates CSA's Concurrence with Response Provided lay Close Out Document act ion /anic required (l)) Hesponse OK pen.lang
, j Co. Indicates that Additional Isiformation or Actioss is kequired to Close Out the Concern veritir.stion (E) Heject verstaration j Rep. Ref. = Page Number in CSA Report keierence Concern (F) Ver s t a rat ion OK pesailing closure
*
(G) Closed lay CSA ANcquires
; AE-1 Administr. steve Pa uress ang oss Closus e Fose
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TABLE OF RESOLUTION OF CSA CONCERNS y Rev. 8 11/01/84 CSA
] CSA RES (A)
4 ITEN CON ON ITEM STATUS BY ACTION / -RESP. REV/ CSA RE DUE DATE CIDSE OUT CSA-tj IRSWEll DESCRIPTION N DIS RESP. ORGANIZATION ACTION PLAN CSA STATUS CONC. RE SCH./AC IM)CIDIENT VENI FI C_Atl,0N
.y s 12 Electrical, Missing Clamp 12 DIC NDC Prepared / None Required 0-D Yes 11-28 NDC-E-Oll
-; on Support item Closed i 13 * Welding, (Piping) Weld Paper 13 DIC Nemo Prepared / None Required 0-D Yes Ill-20
'
Hemo 7/5/84
,;,
Not Stamped Correctly item Closed I on Record 14 Welding, (Piping) Weld Loca- 14 DIC Memo Prepared / Required 0-C No 111-20
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Hemo 7/5/84 - tion not shown on B/P Item Open I on Record d, 15 Nechanical. (Piping) 15 a)ECE Item Open a) Required a)N'[A III-20
~
a)A Memo 7/5/84 j a) Valves Left Open b)DIC Memo Prepare.1/ b)None Required b)o-D b)Yes on Herord 4 b) Nuts Not Fully Ensaged Item Closed 2
?
' 1:5 Mechanical. (Piping) NDE 16 DIC NCR + Menos Prepared / None Required Yes
~ ' " ~
I-D 111'-20 Menos 7/lif/84 ladication not Addressed item Closed
j e I on Necord NCH ISN-12-132PW a
! 17 Nechanical, (Supports) 17 DIC SDL Prepared / None Required 0-0 Yes
~~
J Ill-31 S'DI512-237 Traveler a.O.M. Not Correct Item Closed I
-:1 NIS Nechanical. (Supports) IS DIC NCH Prepared / None Required 0-F Yes III-4 ISN-19F15H~
Not to Tolerance Item Closed (See Item 157) 1 111-38 . l 19 Mechanical, (Supports) 19 DIC NCH Prepared / None Required 0-F Yes 118-38 ISN-19271H
,j Obstruction Item Closed I
j23 Mechanical (Supports) 20 DIC Item kesolved on CSA Mone Required * Yes 111-33 CSA Yorm
~ ~
No QC Verilication Noted Form / Item C?used I
*i . 21 Electrical, Pull Box 28 DIC Nemo Prepared / None Required ' I-F Yes I I - I f> Memo 6/10/84 Cover act Installed Item Clos on Herord WA-NC-300-09 QHC 8324 : 22 Electrical, Cables not 22 DIC Memo Prepared / Noac kequired 3-F #
Yes 11-16 Memu 6/30/84 Tied Down item Closed I C on Hecord E-olol3 E-IN8900 , AE-2
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! . i, TABl.E OF RESOLUTION OF CSA CONCERNS Rev. 8 11/01/84 4h CSA i CSA RES (A)
ITEN CONC. OR ITEM STATUS BY ACTION / RESP. REV/ CSA NE DUE DATE CLOSE OUT CSA MISIAER DESCRIPTION N DIS RESP. ORGANIZATION ACTION PLAN CSA STATUS CONC. REF. SCH.]AC DOCUMENT VERIFil;ATION a'.j 23 Electrical, Flex 23 DIC Inspection Report Required 0-C No 11-17 Inspect Report ', j Comaector Loose Verified / Item Open I 7/3/84 on Record m..) . 1 Electrical, Unistrut Wall Q 24 24 DIC NCR Prepared / None Required 0-D Yes 11-2 ISN-19274E H. .y Sprsed Ites Closed (See.165 Also) * I 11-17-j ~;y 25 Electrical, Washer 25 DIC NDC Prepared / None Required 0-D Yes 11-2 ISN-19320E _. . . .
?q Rotated on Unistrut Item Closed I ,18-17 NDC E-Ol4
:1
) 25 Electrical, Calvanize 26 DIC NDC Prepared / None Required 0-D Yes 11-17 NDC-E-016
~~
q off Conduit Ites Closed I WR 10757-84
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Electrical Tray Support 27 DIC NCR Prepared / None Required 0-b Yes 11-3
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not Secured Properly Ites Closed I 11-17 28 Electrical. No Fire 28 DIC Memo Prepared / Mone Required 0- D Yes 11-17 Hemo 7/5/84
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Barrier Item Closed I on Record
. ' .1 j 29 Electrical, Cable Tray 29 DIC NDC Prepared / None Required 0-D Yes II-il NDC-E-027 a
Penetration Barrier Item closed I l 30 Electrical, Floor Penetra- 30 DEC Memo Prepared / Required 0-C No 11-17 Memo 7/6/84 on
;.j tion not as Required item Open i Hecord, .
Breach ol Seal
, . )i Notifiration J 31 Electrical, Missing 31 DIC Memo Prepared / None Required I-F Yes 11-3 Memo 7/5/84 } Cable Soltener Item closed I Il-17 on Herord WA-RC-300-01 ,
QCIC WA-RC-300-01 E-0103 32 Electrical, Fire Barrier 32 DIC Hemo Prepared / None Required I-F Yes 11-3 I Full Memo 1/2/84 stem Closed I 11-17 on kccord E-15000 E-IRH900
: 33 Mechanical, (Supports) 33 DIC a)NCH Prepared / Required a)l-B* a)No Ill-5~ 4)lSN-19277tlW Insufficient Weld Length Item Open (See Item 157) b)O-D I Ill-11 FCH I-0181-11 b)NCR Prepared / b)Yes Hesponse to CSA 15?A Item Closed I b)NCH ISNI9277HW AE-3 * .
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4 f s e TABLE OF RESOLbi!ON OF CSA CONCERNS
. ;?-' key. 8 11/01/84 $ CSA CSA RES ,~i ITEM (A)
CONC. OR ITEM STATUS RY ACTION /
:i IRBIRER DESCRIPTION RESP. REV/ CSA kEP. DUE DATE CIDSE OUT CSA N DIS RESP. ORGANIZATION ACTION Pl.AN CSA STATUS
' I CONC. RE SCH./AC DOCIMNT VER I F.I CA. .T I.ON :
.
i 34 Mechanical. (Supports) 34 DIC NCR Prepared / . None Required *
.cx Not to Tolerance Yes 118-31 ISN-19285HW items Closed i , Incorrect Material SDL-AR-t-075 35 Electrical, NCC Bolting 35 DIC NDC Prepared / None Required .y L
not to Spec' Item Open (See item 164) I-D Yes
11-6 11-17 NCI-1352E and NDC-E-048
]y NCR ISN2068tE NCR ISN20682E 1-D ' j 36 -
Electrical, Boa not 36 DIC TOE Prepared / Required 0-C No 11-17
~ ~ ~
j -Properly secured TOE 123 &
.,e n Ites Open I 124 .-j 37 Electrical, Broken Fles 37 DIC NRC Prepared / None Required 0-D y in Conduit Yes 11-17 ISN-193I1-E r
Item Closed I Yj 34 Electrical, Flex Loose 38 DIC NRC Prepared / None Required 0-D Yes 11-18 INN-19332E
'; Ites Closed 1 39 Electrical, l.ath of Edge 39 DIC NDC Prepared / None Required 0-D Yes j Softener on Cable Item closed (See Item 170) I
!!-18 NDC-E-021 i' 40 Electrical, Broken Flex 40 DIC NDC Prepared / None Required 0-D Yes 11-18 ISN-19310-E
<S Item Closed
! I .
741 Pipias, Flange Bolts not 41 DIC Memo Prepared) None Required 0-D
~
Fully Eagaged Yes 111-20 Mcmo T[5/84' 3 item closed 1 s Mechanical, Snubber (Support) 42 DIC lten Resolved on None Required * r)42 act Completely Wrapped Yes 111-32 CSA Form CSA Form / Item j Closed I 43 Mechanical, (Supports) 43 DIC Item Resolved by None Required 0-D NCl2~
~~
Operational Interference Yes !!!-31 8 0054H RCI/Ites Closed I '
:44 Mechanical. (Paping) 44 DlC Item Resolved by None Required I-D Yes III-32 CSA Form +
Clearance Retween valve CSA Fors/ Item i
,
Mandle Hemo Open 10-20-84
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:4 Rev. 8 II/01/84 CSA i CSA RES .I ITEM (A)
CON Ok ITEM STATUS RY ACTIOel/ NESP. REV/ CSA REP. IMJE DATE
, IANGER Cl.OSE Otfr CSA DESCRIPTION N DIS RESP. ORGANIZATION ACTION PLAN CSA STATUS :3 ,.
CONC. REF. SCH./AC DOCUMENT VEN I F I CAT. .I. O. N f 45 Mechanical, (Supports) 45 DIC NDC Prepared / ,None Required * Yes III-12 ISN-19538N ' ] Seesbber later f erence Itee Closed I 46 ' Electrical, Missing Rolts 46 DIC NDC Prepared / None Required 0-D
~
Yes 11-19 NDC-E-023 W on Cover Itee Closed i J$ .;4 47 Electrical, Missing Rotta 47 DIC NDC Prepared / Nome Required 0-D Yes 11-19
~ ~ '-
NDC-E-022 em Cover Ites Closed I
[ 44 Mechanical, (Supports) 48 . Dic Itee Resolved on None Required 0-D Yes III-33 CSA Form Hanger Clearance CSA Fors/ Item I
@f Closed d
'. 49 Electrical, Fles Connector 49 DIC NDC Prepared / None Required 0-0 Yes 11-18 ISN-19313E
~
j Loose Item Closed I
*
50 Mechanical, (Piping) 50 DIC Memo Prepared / None Required 0-D Yes III-20
~
Grind Spot Memo 7/14/84 Q Ites Closed I on Necord
, ,j QSk SR-1093-M UT-2416 q
j51 Electrical 51 DIC lten Resolved None Required 0-D Yes 11-19
~ ~' RUk'CM42-94 Missing Strap for Unistrut ou CSA Form x, , Memo 1/3/84 .1 a> . j 52 Electrical, 52 DIC Item Resolved on None Required 0-D Yes 11-19 RA-HC-242-95 * liaistrut Strap not CSA Foam / Item (See Ites 165) 3 Memo 7/1/84 ] Eagaged Closed QHC e,628tJ .
W
. 53 Mechanical. (IEC Valve) 53 DIC lten Resolved by a)None Required a)0-D a)Yes III-20 Memo 1/5/ 5 ~&
~
a)lacorrect Washers Installed Memo & Special Instruc- 1 1/11/84 b) Incomplete Thread Engagement Lion /Ites Closed b)None Required b)l-D b)Yes III-20 Work Pkg In. lex 385 d' I SIS IM03EPU6(Q)02 Spec. M204, ', WP-Vil R. 19, p.25
< 54 Mechanical, (Supports) 54 DIC lien Resolved by Action Plan 54 4-C No Ill-20 Memo 7/10/84
._
Temporary Clamp Memo / Item Open 3
.? 55 Mechanical, (Whip Restraint 55 KC&E Itce Resolved on 0-C Required No V-3 CSA Fura } and Tubing Support-Civil / Dic CSA Form / Item Open I l
Structural) Clearante AE-5
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TABLE OF RESOLIITION OF CSA CONCERNS
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'j ' CSA Rev. 8 18/01/84 CSA kES __ ITEM COIIC. OR (A) ITEM STATUS BY ]'s NISSES . DESCRil" TION N DIS NESP. ONCANIZATION ACTION / ACTION PIAN kESP. REV/ CSA STATUS CSA CONC. RE RE DUE DATE CIDSE OUT CSA SCN./AC DOC 1 MENT V_ER.-I
- - F.I-- CA.T I ON j 56 Mechanical (Whiip Restraint- 56 DIC lten Resolved by None Required 0-F Yes V-3 FCR-l-140lC, q Civil / Structural) FCR/Ites Closed i Item 6
.1 5 Mechanical, (supports) 57 DIC Item Resolved on None Required 0-F Yes III-31
'
q Operational Interference CSA Form CSA Fore / Item I SDt. AE-243 Closed j SS Mechanical (Supports) 58 Dic SDL Prepared / None Required 0-F Yes
~ " -j Bushing mot Properly item Closed Ill-31 SDI.-EG-871 ; Staked i '1 '3 59 Electrical, No DIC lten Resolved on Required 0-C No 11-18 .i Markers on MCC CSA Fors/ Item CSA Form ", Open
Menu 7/20/84 IMJG E-IING20/R1
$60 Electrical, Flex not 60 DIC NDC Prepared / Required .? 0-C No 11-18 NDC-E-O'15 Properly Separated Item OPen I QHC 101153-i ' 61 Mechanical, (Piping) 61 4)DIC NCH Prepared /
1 None Required a)0-D Yes 111-20 m) NCR ISN-17199E c) Loose Solts on Valve Ites Closed d b) No White I.D. Tag b)DIC b) Item Closed i Memo 7/Il&l0/8/84 on tile
~1 b)D-F Yes b) Hemo 9/4/84 on lite , 1
,. 62 Mechanical, (Piping) 62 DIC NDC Prepased/ Nosse Required a)0-D Yes 111-23 a) NCR ISN-17199E
'.
c) Bolts Loose on Valve item Closed i 4 b) No 14aite I.D. Tag Memo 7/Il&l0/8/84 on Isle b)0-F Yes b) Memo 9/4/84 on Inic
.] I 63 Mechanical. (Paping) 63 DIC NDC Prepared / .
Mets Missing on Valve Item Closed None Required 0-D Yes li t -ft Nd-~P70E7
~"~
I
, 64 NDE, (R.T.) Film Quality 64 KG&E Item Resolved on VENDOR CSA Fore / Item None Required 0-F Yes IV-18 ~ 'Al CS orm
~
I Closed
.
C5 NDE, (R.T.) Fala and 65 KC&E Item Resolved on None Required 0-F Yes IV-19 CSA Fosm
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ideld Quality VENih* CSA Fore / Item I Closed ~ AE-6 '
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CSA Nev. 8 18/0l/84
') CSA kES (A)
4 ITEN COIIC. Oft ITEM STATUS RY ACTION / RESP. KEV / CSA REP. IAIE DATE
.2 m DESCRIPTION ag DIS RESP. ORGANIZATl001 ACT1001 PLAN CSA STATUS CONC. NE SCN./AC CLOSE OUT DOCUPENT CSA' 'i VEk l F i t'AT ION )
i 66 IRIE, (R.T.) File Quality 66 EGEE Itee Resolved on None kequired 0-F Yes y CSA Fore /Itee Closed I IV-18 CSA Fore
:q rp 67' Electrical, Fles 67 DIC IIDC Prepared / .None Required ~~~
0-D Yes 11-19 N Disconnected Itee Closed I ISN-19359E a , ;. " 63 tielding, (Piping) 68 .- EG&E NDC Prepared / None Required 0 gD Yes
--
-
3 Surface Defects VENDCet Item closed til-21 ISN-19513 IW (See Ites 169) 3 Memo 7/9 & 7/16/84 iQ on record 69 tielding, (Piping) 69 KG&E Memo Prepared / Required
I-C No Ill-21 M-mo 7/9/84 T4 Serface Defects VEllDOR Ites Open (See Ites 169) -U) ^ 3 -n Record
] 7) tielding (Piping) 70 DIC Memo Prepared / lione Required .--
0-D Yes 111-25 Memo 7/16/84,
-J Reset es Stainless ites Closed -
' *
: 1 on Record QSR 5094-M , j 71 plechasical. (Piping) 71 Dic NDC Prepared / None Required * ~ $ Valve Leaking Yes 111-23 NDC-P026 Ites Closed I qt tielding, (Piping)- 72 EG&E a) Memo Prepared / Required ]j 72 a) Grinding Marks b) tield a)o-C a)No 111-21 a) Memo 7/l6/84 on recond VENDoet Item Opesi (See Item 169) b)o-C 3 , . .s Reinforcement b) Memo Prepared / QSR SR 8090M b)Mo b) Memo 7/b/84 on retoed )}
e1 Item Open 3
,
4 73 tielding (Piping) 73 EC&E NDC Prepared / None Required ~ ' Hadercut I-D Yes III-22 ISN-19494MW 1j VENDOR Item open ' 3
.. j j Mechaatcal, (Piping) 74 DIC Memo Prepared / None Required * ' "
Mold Tag Yes Ill-22 Memo 7/10/84
. .
Itce Closed I on Record
~; 75 Mechanical (Equipment) 75 DIC NCR Prepared /
Gouges and Arc Strikes None Required * Yes 111-22 ISN-19436MW ites Closed I 76P Electrical, 76P DIC Memo Prepared / Conduit laterlerence item Closed lione Reepaired 0-F Yes l l- li 1.eticI i I2/10/82, on Hetord
'
76M Mechanical, (Supports) RCI l-0205-E 76H DIC SDB. Psepared/ None Required * Yes i f Angularity I l l-~ll SDB.-EG-879 ltre Closed I , 1 . AE-7 -
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TABl.E OF RESOLITTIOli OF CSA CONCERNS i i Nev. 8 II/01/84 CSA
'd CSA RES A ITEN (A)
CONC. 00t ITEM STATUS BY ACTIOll/
,
j amatBER DEScitlPTioti RESP. REV/ CSA REP. DUE DATE CLOSE OITT CSA N DIS RESP. ORGANIZATIOtl ACTIoll PLAN CSA STATUS 9 CONC. kEF. SCH./AC IM)CletENT VEN I F I CA.T. l_HN ' [ 77 Nechanical, (Supports) 77 DIC Resolution on CSA See Action Plan 77 l-B No 111-5
.; Special Scope NTDel's Fore / Item Open CSA Fore /Dic 10M * 3 Ill-33 dated 9/26/84 , ,
Typed pg "CSA 77" dated 10/9/84 78 leechanical, (Supports) 78 DIC/ RCI Prepared / None Required * Yes III-38 NCI-t-0012H i4 Conflict in Drauinas BECNTEL Item closed I 79 Itechanical, (Supports) 79 a)BPC (a) NCR Prepared / Required a)o-C (a)No Ill-5 (a)lSN-19356N
'
' (a) Conflict in Drauinas Item Open n (b) Undersize Vendor Weld b)DIC (b) SDL Prepared / (See Itee 161) b)o-D j (Is)Yes Ill-33 (I,)SDL-EG-880
,lten Closed (See Also Ites 157) 1 80 Itechanical, (Supports) 80 DEC SDL Prepared /Itee Required 0-C No III-38
~
SDEEG-881
~' '
B.O.N. Error Open I 1 Si leechaaical, (Supports) SI DIC/ RCI Prepared / Nene Required * Yes Possible Clamp Rotation Ill-5 RCl-1-0083H
.
BECitTEL ltee Closed i III-32 l 4 82 Nechaatcal (Supports) 82 DIC SDL Prepared / None Required * Cotter Pia Yes 111-38 SDL-AB-t-238
, Ites Closed 3
)
.q $3 NDE, (R.T.) Slag $3 DIC Resolved on CSA None Required ~
~'
; Indications 0-D Yes IV-9~ , CSA Fuse i
Fore /ttee Clemed 3 S4 IEIE, (R.T.) Wld 84 KG&E/ Item Open ~ Action Plan 84 0-C No IV-RO CSA Fore
~ , quality Applied i
3 IV-25 SAP EG 1993 En '$
$ L5 IEEE, (R.T.) File 85 KG&E/ Item Open Demaity Action Plan 85 0-C No IV-T0
-
C5A Form t
~
Applied IV-28
,
3 QSR-Sk-IP95-M
,
En ; S's leechanical, (Piping) 86 DIC Memo Issued / None Required ~ ECE Issued in lieu NCR I-D Yes III-22 Memo 7/iU84, ltre Closed 2 on Record
, f t87 Welding, WId Profile 87 DIC ECR_22, H_dbH, Memo Issued / Required I-B No Ill-22__ Meeu 7/25/84, Item Open (See Itse 167) 3
,
,
on Nerord/ECH , IMO3EM04(Q)ECHIS e
, AE-8 PT ll574;ui 2455 I
s -
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. z. : . c. . .s - . . - .:; m .x um m.w r .WE LL : m.a.u a - s - .- :. .a- 2 . .. . :.a : . ... . . ., _ '4-e - ]' .i s ~!
a 1
. $
:
i i
TABI.E OF RESOLUTION OF CSA CONCERNS
, #
Nev. 8 11/01/84
.l CSA CSA RES ITEM (A)
CONC. OR ITEM STATUS BY ACT1001/ y naaseen DESCRIPTIOIl RESP. REV/ CSA REP. DUE DATE CIASE OUT CSA 11 0 . DIS RESP. ORGANIZATION ACTICII PLAN CSA STATUS CONC. kEF. SCH./AC DOCittENT VEklFICATp* 88 Mechanical (Piping) SS DIC
-$ Memo Issued / None Required I-F Yes III-22 Memo 7/I7/84, "F Rose Mat *1 Indicataos Item Closed t} ,
2 on Record
* QSk SR-1092-M
:} PT ll550;UT 2434
.: 89 Mechanica!. (Welding) 89 DIC Menos Prepared / None Required 0-0 Yes 111-22 Memo 7/10/84, O m la Process Inspection Ites Closed I on Record 94 IIechanical. (Piping) 90 DIC Memo Prepared / None Required 0-D Yes 111-23
~
. Pia llele in Item closed' Menu 7/16/84 2 on Record QSR SR-1091-M h 91 Itechanical (Piping) 91 DIC NDC Prepared / None Required * Yes 111-23 Missing Nuts on Valve WDC-P-028
..!: Item Closed I 92 Welding, (Pipang) 92 KG&E/ Memo Prepared / None Required Improper Prep. for F Yes 111-23 Memo 73 [84 .
VEllD00t Ites Closed (See Item 169) I on Necord Q 93 Mechaaical, (Support) 93 W NCR Prepared / Nong Required * Yes Rust on Manger 111-23 ISN55265-J d* Item Closed $94 NDE, (R.T.) Weld Quality 94 KG&E U.T. Perlormed/ Action Plan 94 0-C U'.T.-2431,
~
No IV-Il c3 e)RT Discrepancies (kECO) Item Open 3 IV-21 SAP EG 1994 t;.! h) Lead ID in NT Area of Interest , '
(95 leechanical. (Paping) 95 DIC Surveillance Report None Required
Arc Gouges I-F Yes III-23 Memo f/3 /84, 3 PrepareJ/ Item Closed 2 on kerord
,- ( . ,.
QSR-1097-M NCH ISN20075PW 496 Mechanical, (Piping) 96 DIC/ Memo Pacpared/ Mone Required 0-D New 7/II.'84,
~
Yes III-23
, Paint Chipping KGAE Item Closed /
I on Record
--[97 Mechanical, (Piping) 97 KG&E Memo Prepared / ' None Required 0-D Yes Valve, Flow Darection ill-23 Meau 7/19/84, Item Closed 1 on kccord Missing 94 Mechanical (Pipsag) 98 DIC/ Memo Psepared/ None Required
'
'
I-D Yes 188"-23 ~MA mo 7/E0/84 ASPE Class Changes BECIITEl. Item Closed 2 on kccord
; at Coupling l hcl 1-0749-P t ,
AE-9
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,
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. ; TABLE OF NESOLUTION OF CSA CONCEkNS key. 8 II/OI/84 $ CSA J CSA RES (A) 'j ITF4 CONC. OR ITEM STATUS RY ACTION / RESP. REV/ CSA REP. DUE DATE CLOSE OUT CSA T
F. DER DESCRIPTION B0 DIS RESP. OkCANIZATION ACTIoti PLAN CSA STATUS CONC. NE SCN./AC DOCUMENT VENIFICArloN
.: 99 Itechanical. (Supports) 99 DIC SDL Prepared / .kequired I-8 No 111-32 SDL-EJ-406 j ]R Dimemaional Error Item Open 1 AP-VI-02,R.25 (partial) -
308 Nechanica KG&E Memo Prepared / None Required * 11-18 (4 Yes Memo 7/14/84,
-
(a) lentatenance Records Ites Closed . I on Record d (b) Danger Signs
'] (c) Eshaust Fan 121 Electrical, Missing 101 DIC Prepared NDC/ None Required 0-D 11-18 Y'em NDC E039
.j Hameplate Item Closed
*
102 Mechanical, 102 DIC Memo Prepared / e None Required * Yes 11-18 Memo 7/14/84,
-
(a) Maintenance Records item Closed I on Record Missing-j (b) He Danger Signs s (c) Enhaust Fan
' 1 *.3 Nechanica Dic Memo Prepared / Name Required * Yes 11-88- Memo 7/i4/54,
~~
{ (Same as 102) Ites Closed I on Hecord 104 Nechanical, 104 DIC Memo Prepared / None Required * ~
Yes 11-18 Memo 7/I4/84, i (Same as 102) Item Closed
.
I . + 7//l8/84 4 On Hecord 105 Itechaaical, (Supports) 105 DIC NCR & NCI PrepareJ/ None Required * Yes 181 '12
~
liN 19583H
- (a) Imade on can do not Item Closed 2 kCI-t-0016H '! Agree with Bom (b) No IfTDel 'j (c) No CAR 25 in , Traveler (d) Can Sinding .
106 leechanical. (Pipang) DIC SR Prepared / None Required 0-F Yes Ill-24
~
-SN Td'i8M
~ ~
Prep for Item Closed 1 CWP EG t.02P 137 Welding, Linear Indication 107 DIC Memo Piepared/ None Required I-D Yes Ill-24~~ H.W1/117154,
~ ~ ; Weld Ince Closed j I on Record t*T-II584 .
AE-10 .
,
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' , ' [, TABI.E OF RES01.UTION OF CSA CONCERNS
j Rev. 8 11/05/84 CSA
-{ CSA RES (A)
,; j ITEN COIIC. OR ITEM STATUS SY ACT10el/ RESP. REV/
Jt IRAGER DESCRIPTIoll CSA REP. DUE DATE Cl.0SE OUT CSA 10 0 . DIS RESP. ORGANIZATION ACT1001 FIAN CSA STATUS '
CONC. REF. SCH./AC DOCUMENT VER I FICA, Tit He j 108 Welding, Linear Indication IOS DIC Memo Prepared / Mone Required I-D Yes a Weld III-24 . Memo 7/17/84,
'Ites Closed ') -,
I on Hecord PT-Il584 109 Welding, Weld Splatter 109 DIC SR Prepared / None Required ~ ~' 0-D Yes III-24 SR-Il00M 3 Itce Closed 3
,$ NCH ISN20ll0P *
3 Ile Weldang, Questionable 110 DIC Memo Prepared / None Required . _ . _ _ . 0-D Yes 111-24 Memo 7/I1/84,
'l P.T. Prep Item closed 3 on Herord PT-II583 III Welding, PSI /ISI Ill DIC/ Memo Prepared / Action Plan lil
~
I-C No Ill-24 Memo 7/11/84,
' Prep EC&E Item open .
3 on Record LP 4863,64 PR7-PT-46 8 3
-
1 112 Welding Hoop Shrinkage 182 DIC/ Hemo Prepared / None Required 0-D
, " Yes 111-24 Memo 7/16/84, .
BECMTEL Itce Closed I on Necord j 113 Electrical, Claany Massing 113 Dlc NDC Prepared / None Required 0-D Yes 11-18 NDC-E041
,
Item Closed I N 114 Electrical, Separation !!4 DIC NDC Prepared / None Required 0-D Yes _ . _ . _ . . . i NDC-E042
} Item Closed (See Ites 170). 1
- { 115 Mechanical Equip, Solta 115 DIC NDC' Prepared / None Required * !!i!^4 ND EPT048
Yes 2 y} . Cissing on Valve Plates Itco Closed I
' ! !!6 Electrical I.cose Fles 116 DIC NDC Prepared / None Required 0-D Yes NiiCTE043, McEs
'l Itee Closed I
?
-%
:!!7 Welding, Steel on SS 117 W NDC Prepared / Required 0-C No III-24 ISN-552603 Item Open I
.
;118 Welding, Weld Prefale 118 EC&E Memo Prepared / Required I-B No Ill-24 Memo 7/19/84,
} VENDOR ltee Open (See Ites 169) 3 on Herord
,313 Weldang, Overlap II9 EG&t./ NCR Prepared / Nequired 0-C No Ill-25 ISN- 196ts2PtW 1,T.ST . Itre Open (See Item ,
' Ar.11 .
-, - , - -- . . - ~ . - - --;. - ,-..
,
-. . n - -
*
.
'
t TABLE OF RESOLITTION OF CSA CONCERNS 5 Rev. 8 II/01/84 CSA CSA RES T ITEN (A)
CONC. Ott ITEM STATUS RY ACTION / RESP. KEV / CSA kE IRAGER DUE DATE CLOSE OUT CSA DESCRIPTION 10 0 . DIS RESP. ORCANIZATIoli ACT1001 PLAN CSA STATUS CONC. kEF. Scil . / AC DOCUMENT VENIFICATION;
. 120 idelding, Porosity 120 KC&E Nemo Prepared / Itequired 0-C No !!!-25 Memo 7/19/84, d VENDOR lten Open (See Ites 169) 3 on Record "3 # 121 leelding, Escessive 121 DIC Nemo Prepared / None Required 0-D Yes 111-25 Memo 7/19/84,
.r Reinforcescat Ites Closed (See Item 167) I on kccord h 122 leelding, Linear 122 DIC SR Prepared / None Required I-F Yes 138-25 QSH SH-1099-M Indication Item Closed g
,
(See Ites 167) 3 PT-Il586 M 123 IIechanical. (Supports) 123 DIC NCR Prepared / Nome Required * Yes III-32 ISN 19607H
~~~ ~
~} Code Data & Documentation Item closed (See Ites 157) 3
'
124 stechaatcal. (Supports) 124 DIC SDL Prepared / Ilone Required * Yes 111-32 SDL-EP-281 4 Imose Jan Nut Item Closed I
; 125 Nechanical. (Supports) 125 DIC SDL Prepared / None Requsred * Yes -< Clamp Angle Off til-32 SDELP-287 Item Closed I ' 126 Ilechaatcal. (E ;;crts) 126 DIC (a) NCR Prepared / 4) None Required a)* a)Yes Ill-5 (a) ISN19609H ; (a) Saubber Tension an Itce Closed (See Ites 166) 3 5 Lieu of Comp, (13) SDL-EP-284 (b) SDL Prepared b) Required b)l-R No Ill-32 j (b) Obstructions Itco Closed 1 127 Nechanical, (Supports) 127 DIC S'DL Prepared / None Required " '* T EE-285 ^
Yes IIl-5 SDL See Calls for Snubber to Ites Closed (See Item 166) 3 118-32 be in Comp. Conflict
: with Traveler ' 'I t128 Nechanical. (Supports) 125 DIC SDL Prepared / None Required * Yes !!I-5 SDL-EP-286 ,- ',* (Same as 127) Item closed (See Item 166) 3 III-32 . ' 129 Electrical. No DIC Resolutson on CSA Ilone Required I-D Yes II-b CSA Fore Documentation om Rus Bar Fore /Ites Closed (See Items 162 & 863) 3 11-18 NCR ISN20674E Torquing QC Checklist Samples
. *
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-
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.
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.
h TABl.E OF RESULUTION OF CSA CONCERNS
,
j CSA key. 8 II/01/84 i CSA RES (A) l ITEM ColeC. Olt ITEM STATUS BY ACTION / RESP. REV/ CSA kE lAlE DATE CIDSE Olff CSA i MSIER DESCRIPTIosi 11 0 . DIS RESP. ORGANIZATIOIl ACTIoti PLAN CSA STATUS CONC. RE I SCN./AC DOCUNENT VENIFICATION q 130 Electrical, 130 DIC NDC Pregared/ None Required 0-D Bolting of Switchgear Yes 11-18 NDC-E-049 u; Ites closed (See Itco 164) I d131- Electrical, 131 DIC NDC Prepared / None Required 0-D Yes 11-18~ NDC-E-049 J (Same as 130) Item Closed (See Item 164) A lQ 132 Electrical, Conduct 132 DIC NDC Prepared / None Required 0-D
~~ '
Yes 11-18 NDC-E-047 M Touching Support Ites Closed I A 8cclitel BLSE 11,338 1 133 luchaaical. (Supports) 133 DIC a*b)MDC Prepared / a) & b)llone kequired * 4&b) yes lil-5
.- - --
-
(a) Wrong Size Washers ISM 19630K i
Items closed (See Item 157) 3 4 (b) CAR 25 c) Item Opera c)See Action Plao 133 c) No Ill-32 (c) 2 instead 4 Note Claap Memo "CSA N [. (See also Ites 166)l-C 3 133
134 Mechaaical, (Supports) 134 Dlc SR Prepared / None Required * Yes (a) Loose Nuts Ill-33 NSik's 2377H, Item Closed 1 2tJ8M,
'I (b) Mengers not Slasamed 2179N '
135 llechanical. (I&C) 135 EC&E NCR and I.etter None Required 2-D Yes 11-8 ISN5526lJ Besideae on Tubing Prepared / Item 3 11-25 SAP-EG-1815 j Closed SAP-EG-1708
. SAP-EG-1866 ISN 553905 ) ,
SAP-EG-2004
:
-836 Mechanical, (I&C) 136 W Memo Prepared / Required I-B No 11-21 PCN 84-3 38eles in Concrete Item Open 2 FCR l-II96-C j SAP-EG-2004
,'137 Welding, Underfill 137 EG&E Memo Prepared / Required 0-C No III-25 Memo 7/23/84 VENDuN Item Opca .
(See Item 169) 3 on ketoril 334 Welding, Perosaty 134 EU Nemo Picpared/ Required 0-C No
~
I l l! I5 ' ' Memo ~1/2O84~ VENDok Item Opra (See Item 169) 3 on Record 139 Weldang. Undercut 139 EG&E Memo e SR None Required
~ '
0-D Yes lit-25~ ~ ~ ~ N M E~23-84~
. VENDOR Prepared / Item Closed (See Item 169) 3 SN WIN-84-278 AE-13 - - .
, ., _ _ _ _ _ . ,, __ _ _ . - - __ _
_ _ _ _ _ ._-
). ^ , , TABLE OF RES01.trTION OF CSA CONCERNS .
Ncv. 8 11/0l/84
.
CSA
$ CSA RES (A) ,l ITEll *
COIIC. 00 ITEM STATUS BY ACTIcel/ RESP. REV/ CSA NEP. DUE DATE CLOSE OUT CSA
- M4WER DESCRIPTIDW 10 0 . DIS RESP. ORGANIZATIOtt ACTIott PIAN CSA STATUS CONC. NE SCH _. /,A_CT . DOCBMENT VERIFICATluN , 140 Electrical, Fles Pulled 140 Dic NCR Prepared / None Requised 0-D Yes Il-18 ISN-19716E '
from Comaectar ites Closed I 141 Stechanical (ILC) 144 W Meen Prepared / None Required I-F Yes ~~7l1 28
~ '
'W Nemo 2/ s/82,
'
-
Anchor Specing Item Closed 2 NCR IN88 51224-J
..
SAP-EG-2004 f *142 IIechaatcal, (I&C) 142 W CWP Prepared / Nome Required I-D Yes II-21 (Cancelled) Damaged Tubing & Gage Item Open (See Ites 156) 2 CWP BG 8731 d
: SAP-EG-1998
) 143 Itechanical, (l&C) 143 W CWP Prepared / None Required * Yes Il-28 CWP-B8-6731
) Laese Clamp Ites Closed (See Item 156) 1 EWCLWW-84-127
:144 Itechanical, (l&C) I44 W Memo Prepared / Nome llequired * Yes 11-28 W Meno 7/20/84,
! Nisaing/ Loose Nuts on item CloseJ (See Item 156) I SAP-EG-1866
~[ Terminal Boa
, 145 Itechanical (Supports) 145 DIC NCI Prepared / Required 0-C No kcl-IO434-P
! Standing Water in Stanchions Iten Open
.
(See Item 156) !
pI46 feechanical (IEC) 146 W CWE Prepared / Required 0-C No
~
18-11
~
C5P E1-^4 U I
; Damaged Tubing and Item Open (See Item 156) 3 G-SAP-EJ-G03-Clamp Missing
,
CSA Qll/l
.
CWA-EJ-GO3-CSA Nechanical, (l&C) W a) ~ ~ Npared/ a) Required
~
{l07 147 CWI (a)No- Il28
~
P a)O-C a') SAP EG-18Ae q (a) Damaged Tubing item Open I CWP HB-239-I (b) Naager not lastalled b) NCR Prepared / Generic b) None Required b)O-D (b)Yes 11-21 NCR ISN55355J l i Implications Evaluated / (See Item 156) I b)ECWP-382 Ites Closed FCR W-B-0432-J SAP EGl945eEGl866 CWA-HB-G03-CSA-B
~
144 Nechanical (IEC) 148 W CWP Prepared / Nome Required * Yes I I - 2'I' ~CWP'U d El
~
(a) Massing Valve Maadte Ites Closed (See Ites 156) 1 SAP-EG- 1866 (b) Massing Clamp f 109 Mechanical, (HVAC) I49 DiC~ ~ ~N fPNpar~cd ~ None Requared 0-D Yemlil-N ' '~NDC P100tal
'
) Undessaze Welds item Clused (See Item 168) 1 4
, /sE-14
* .
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.
I TABLE OF resol.IrrION OF CSA CONCERNS
; key. 8 II/03/84 i CSA ; CSA RES (A) 't ITEll Cosec. OR ITEM STATUS RY ACTIOll/ kESP. REV/ CSA REP. DUE DATE CLOSE Otfr CSA Imm DESCRIPTION N DIS kESP. OttCANIZATION ACTION Pl.All CSA STATUS CONC. kEF. SCN./AC DOCUMENT VEkiFICATION - 154
feechanical, (IEVAC) 150 (a)KCLE(a) MDC Prepared (a) Required a) I-8 (4)No Ill-39 (a) NDC-MWO60
' ; (c) Welds Undersize VEND 08t Itce open (See Item I62) 3 NCR ISN-20104-MW
't (b) Dimensions (b)DIC (b) RCI and IIDC (b) None Required b) * (b)Yes (b) RCI-t-244-M
*
>j Prepared / Item I and NCR 1 Closed ISN-20003-M t l i 151 Itechaeacal, (MVAC) ISI DIC (a) NDC Prepared / (a) Required a) 1-R No III-39 (4) NDC MW 062 ~j (a) Welds Undersize Itce open (See Ites 168) 3 ISN 20104MW 3 (b) Crinding Embeds DIC (b) Memo Prepared / (b) lione Required b) * Yes (b) Nemo 8/8/84, ld.; item Closed (c) Ilone Required I on Record (c) Doc mentation DIC (c) MDC Prepared / c) 0-D Yes (c) ISN 19938M '3 Itce Closed i 152 Itechaaical (IIVAC) 152 DIC Memo Prepared / None Required 0-G Yes Ill-39 Memo 1/26/84, j Post Applied Plates Ites Closed (See also Item 158) I on kecord 1 INgs. C-1037, C-0C2323 R. 19
, _ .. . . ,
1 153 Mechanical (NVAC) 153 DIC Memo Prepared / Required I-C No Ill-39 Memo 8/4/84, , Welding on Casset Plate item Open 3 on Record
-
---- -- _ -
- 154 Welding, Escessive 154 KC&E/ Resolution on CSA None Required 0-D Yes Ill-25. - . _ CSA Form Weld Width VENDuk Fora / Item Closed I ,
~ '
l 155 Electrical, (a) No laspec- 155 a)KCE/ a)lten Closed a)None Required a) 0-D a)Yes Il-6 1 tion Record el Rattery Rark DIC (See Item 164) 3 Il-19 i Fasteners (b) liuts Missing b)KC&E b)MDC Prepared / b) Required b) 1-C b)No b)hDC E-065 i free Rattery Rack Assemblies Item open 3 _ e e = = + b e M-15
< , * e
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TAtl.E OF kESOIUTION OF CSA CONCEluts
- Rev. 8 18/03/84 CSA
_
.
CSA RES (A)
} ITEM CONC. Ok ITEN STATUS BY ACTION / RESP. KEV / CSA REP. IAJE DATE CIDSE Otfr CSA IAASER DESCRIPTION N DIS kESP. ORGANIZATION ACTION PIAN CSA STATUS CONC. kEF. SCN./AC IN GIMENT VF.RI FICATitHi
, Generic / Program Concerns 156 I&C, Tubang Damage KGLE See Action Plaa 156 1-A No
~ ~ ~
W 5AP-EG-1932
, -
OP Supports, Manor Marduare/ KG&E See Action Plan 157 a)l-R
'
No Documentation Probicos DIC b)l-B 3
,
c)l-A ISS IfvAC, Conflact or Lack of DIC See Action Plan 158 0-8 No t linifera laspect aos Crateria 3 159 Onsality Assurance /Construc- KGEE See Action Plan 159 0-C 5e
~
Vill-2 Currect swe Act son tion Audits act to Schedule 3 Ikwument 159,9/25/84 for ist/2nd qtr. 1954 EtJWlh "Supplesment to CSA 157" 160 Stcrtup, SFR's not Scang See Action Plan It,0 0-D Yes
'
Vill-5 CAR 88 Properly Utalized or 3 Work Nold Cispositioned Agrecaeut 22 168 Quality Assurance, SDI's not DIC See Action Plaa 165 O-D Yes
--
Seing Properly Utilized or 3 , Cispositioned
~
162 An Apparent Deficiency in KCU See Action Plan 162' l-R No
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lemmagement Control of Vendor 3 Actavities. leadequacies na Vendor Supplied llarJuare and Documentation an Several Ctscipline . _ status Reference for Generac Concerns: (X) - _ _(Y) i Action Plan Re Status Code itetus Codes: (A) Action Plan Complete (R) Corrective Action Complete (C) Response Incomplete per CSA kewaew (D) kespouse OK per CSA kevaew g (E) CSA Verificataca - Reject (F) CSA Versfasation - Accept (G) CSA Closure
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TABLE OF RESOLUTION OF CSA CONCEkNS New. 8 !!/08/34 CSA (i)
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CSA RES ' 17t38 CONC. OR ITEM STATUS BY ACTION / RESP. REV/ CSA REP. IA8E 11 ATE CIDSE OITT CSA MBGER DESCkiPTION M DISC. kESP. ORGANIZATIOel ACTION PLAN CSA STATUS CONC. kEF. SCN./AC DOCl#IENT VEN I F I CA'f, ite i 163 O Potential Generic Problem KG&E See Action Plan 163 0-A No I with Regard to the Complete- DIC (Peading 3 j mess of QC Inspection 157. 162 ~
- Criteri e 164)
164 a Generic Problem with Begard KG&E See Action Plam 164 l-B No Vendor Site
to the Festeners (e.g.. IIut DIC 3 Visit Report Bolts. Washers) Used for On- B-274 J Site Assembly and Installa-
-{ tion of Electrical Egesipaca j 165 O Problem with Unistrut Well DIC See Action Plam 165 l-D Yes !!-2
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Spreading and Possible Lase SECNTEL Ref. 24, 52 . cf Capability to Support j Electrical Condanit .
, 166 o Prohtee with the Estah- DIC See Action Plan 166 2-3 No
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CAR-43
; Iished Construction Contrac- (Also See Action 3 CAM-44 ter Brawing Change Control Plaa ISS) ? Procedures in the Area of Special lastraction Sheet Welding. Concern with the KC6E See Action Plan 167 l-B No . } Qanality of Field Fabricated DIC Ref. 112. 121. 122 3 , *
Welding lecteding AIISI S3 Piping Weld !
; 164 Welding Concern with IIVAC DIC See Action Plam 164 1-B
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No Support Attaclament Welds Ref. 149 3
~ 869 Weldlag. Concern with Visual DIC See Action Plan 369 l-A No
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Acceptsace of Vendor Fabri- 3 cated Piping Welda l 170 Starteap leproper Use EC&E See Action Plaa IFO l-B No Vill-5 g cf the System for Coa- 3 l e trolling Noaconfessing
,' Conditions ter Equipment Turn e d ov e r t o KGLE .
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