ML19225B478

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IE Insp Rept 50-482/79-09 on 790423-26.Noncompliance Noted: Failure to Follow Storage Procedures for Reactor Vessel Internals & Failure to Conduct QC Insp
ML19225B478
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 06/04/1979
From: Crossman W, Oberg C, Tomlinson D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19225B475 List:
References
50-482-79-09, 50-482-79-9, NUDOCS 7907250226
Download: ML19225B478 (13)


See also: IR 05000482/1979009

Text

U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF IflSPECTION AND ENFORCEMENT

REGION IV

-

Report No. STN 50-482/79-09

Docket No. STN 50-482

Category A2

Licensee:

Kansas Gas and Electric Company

P. O. Box 208

Wichita, Kansas

-

Facility Name: Wolf Creek, Unit No.1

.

Inspection at: Burlington, Coffey County, Kansas

Inspection conducted: April 23-26,1979

Inspectors:

Of4/ -

4-/-79

.

C. R. Oberg, RegcJor Inspector, Projects Section

Date

(Paragraphs 1, 2', 3, 4, 5, 6, 8, 9, 17 & 18)

,6 &

(o-04 79

0. P. fopfinson, Reactor Inspector, Engineering Support

Date

Section (Paragraphs 7 & 10)

$ k h /A L

6 - (/- 79

. F. Suermann, Bdactor Inspector (RIII)

Date

'

(Paragraphs 15 & 16)

~

. k.

%

g -p'ff

J. C. Mattia, Reactdr Inspector (RI)

Date

(Paragraphsll, 12, 13 & 14)

d 7!79

Approved:

=

W. A. Crossman, Chief, Projects Section

Date

'&

b

7f

R. E. ' Hall, Chief, Engineping Support Section

Date /

398

191

79072 5 on0

Inspection Sunmary:

,_

Inspection on April 23-26, 1979 (Report No. STN 50-482/79-09)

Areas Inspected:

Routine, unannounced inspection of safety related concrete;

.

reactor pressure vessel internals; Ultimate Heat Sink Dam; construction

deficiencies; QA audits; NDE activities; and licensee action on previously

identified inspection findings. The inspection involved ninety-two inspcetor-

hours on site by four flRC inspectors.

Resul ts: Of the seven areas inspected, no items of noncompliance or deviations

were found in five areas; two apparent items of noncompliance were found in

two areas (infraction - failure to follow storage procedures for reactor vessel

internals - paragraph 13 and infraction - failure to conduct quality control

inspection- paragraph 15).

--

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192

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DETAILS

1.

Persons Contacted

.

Principal Licensee Personnel

  • M. E. Clark, QA Manager, Site
  • D. W. Prigel, QA Engineer
  • G. W. Reeves, QA Engineer
  • T. Newman, QA Auditor

R. Seiple, Dames & Moore, Consultant

"

SNUPPS

  • R. D. Brown, SNUPPS Site Representative

Daniel International

  • W. E. Hitt, Project Manager
  • V. J. Turner, Project QA Manager
  • D. L. Jones, Project QC Manager
  • C. L. Phillips, Project Civil Engineer

J. Kerns, QC Inspector

T. Green, Civil OC Lead Engineer

C. Parry, QC Lead Receiving Inspector

S. E. Jinks, QC Civil Engineer

J. Ayres, QA Engineer

S. Kapp, Senior Aggregate Lab Technician

D. Davis, QC Civil Lead Inspector (Rebar)

K. Ebberly, QC Lead Inspector

G. Gukeisen, Area Eng'ineer, Storage and Maintenance

Clarkson

J. Carsen, Clarkson Project Manager

  • denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings

(Closed) Noncompliance (STN 50-482/78-11):

Failure to Follow Specifications

for Adjacent Cadweld Staggering.

The IE inspector confirmed through dis-

cussion and review of records that the nonconforming Cadwelds were replaced

with Cadwelds which were properly staggered.

The training specified for

Cadweld QC inspectors was conducted on Daniel Construction Procedure

QCP IV-102 and Bechtel Specification No.10466-Cll2(Q) as they pertain to

spacing of adjacent Cadwelds. This item is considered closed.

398

193

3

(Closed) Unresolved ! tem (STN 50-482/78-10):

Containment Spray Pump

Pedestals.

The IE inspector had quastioned the paint thickness on the

containment spray pump pedestals that were modified in the field. The

original QC coating inspector's repcrt couldn't be located. The assioned ~

QC inspector issued another survei,llance report dated April 23, 1979.

The report indicated that thc. painting was acceptable. Daniel QC also

issued an interoffice w.emo dated April 23, 1979, to explain the issuance

of the second serveillance report several months after the original

inspection was ccnducted.

In view of this, the IE inspector requested

that a paint thickness examination test be conducted during his presence.

This was done and the paint thickness was measured to be from 5-8 mils

in the modified areas. This thickness meets the specification require-

ments.

This item is considered resolved.

"

(0 pea) Noncompliance Item (STN 50-482/78-12):

Failure to Control Special

Processes.

RECO Corporation has agreed in writing to revise Welding

Procedure ES-106N. The revision is to include the requirements of ND-4412

of the ASME Code,Section III,1974 Edition through Winter 1975 Addenda for

removal of mill scale, grease, oil ano 91 deleter sus materials prior to

initiation of welding.

Spot radiography was performed on site of the

areas which . ';ared to have been welded without removal of the mill scale.

A total of s-

'n radiographs on two circumferential butt welds on Job 238

were evaluatt

and accepted by Peaboby Testing and KG&E. The procedure

revision will

o provide for spot radiography of the work of each

welder on each tu k as required by Appendix X, pccagraph X-3720(b) of the

ASME Code.

This item will remain open pending the issuance of the RECO procedure

revision containing the noted requirements.

3.

Site Tour

'

The IE inspectors conducted a walk-through of various areas of the con-

straction to observe construction activities in progress and to observe

the status of housekeeping. No items of noncompliance or deviations were

identified.

4.

Construction Deficiency - Damage to Essential Services Water System (ESWS)

Valve Operator

On February 14, 1979, KG&E reported to RIV a potential 10 CFR

.55(e)

matter involving damage to a Limitorgt.e valve operator (Valve No. C-03406,

Serial No. 260389).

Dui 79 the initial operational check, the valve

'

actuator was energized in the closed position instead of a mid-position.

The limit switches had been bypassed, and upon energization, the valve was

driven into the stops causing the actuator tc crack in five places. On

March 14,1979, KG&E reported that the incident did not appear to be

reportable under 10 CFR 50.55(e) for the following reasons: (1) the

electrician's error in wiring did not appear to be a breakdown in the QA

398

194

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program; (2) a deficiency in final design is not involved; (3) damaged

operator will be replaced; and (4) deviation from perfonnance is not

involved.

.

The IE Inspector determined that a change to Construction Work Procedure

WP-VI-200, " Installation of Rotating Equipment," is now in the process' of

approval.

This change will control energization of similar equipment in

the future.

After inspection of the valve operator, review of the NCR

(15N 0744-M), and discussion with responsible constructor and licensee

perscnnel, the IE inspector concluded that this event is not a Construction

Geficiency.

5.

Construction Deficiency - Pressurizer Supports

"

On March 23, 1979, SNUPPS (Gaithersburg) reported a Construction Deficiency

'

involving a design problem wit; 'he pressurizer supports. This deficiency

affects all SNUPPS units (work has not commenced at Wolf Creek).

Speci fi-

cally, the deficiency involves 2-1/2 inch diameter threaded studs of ASTM

AS40, Grade B23, Class-1 material which were to be welded, with a full

penetration groove weld, to girders of A36 material. The weld and/or

material may be inadequate.

A design fix is being prepared by the AE,

Bechtel.

A written report in accordance with 10 CFR 50.55(e) will be

submitted by SNUPPS (Gaithersburg). The IE inspector determined that KG&E

site personnel were aware of the deficiency.

6.

Construction Deficiency - Hold Down Bolts for Essential Services Water (ESW)

Pumps

On April 23, 1979, the licensee reported a potential 50.55(e) construt

.

deficiency involving the designed embedded length of the hold-down bolt

for

the ESW pumps. The AE (Bechtel) reported to KG&E that the embedded length

of the 2 inch diameter (3 foot 8 inch length) was inadequate for the

service required.

Presently 2 feet 10 inches of the bolts are embedded

in concrete. There are twenty bolts for each of the two ESW pumps. The

bolts have not been installed.

Bechtel is reviewing the design.

A KG&E

representative stated that a report will be submitted as required by 10 CFR 50.55(e).

7.

Construction Deficiency - G&W Pipe Assemblies

As a result of a potential 10 CFR 50.55(e) situation reported to RIV on

March 29, 1979, the IE inspector reviewed the radiographs for piping

assembly A-9-ll, welds #1 through #8.

This assembly was fabricated,

welded and accepted by Gulf and Western Energy Products.

The assembly

was accepted also by Daniel site receipt inspection, but at installation,

a Daniel QC inspector noted a possible nonconfonnance condition on the

inside surfaces of the two end joints.

An NCR was issued stating these

conditions.

A discussion involving representatives from Daniel, KG&E,

Bechtel, and Gulf und Western failed to resolve the differences of

opinion as to the acceptability of the welds.

Pending resolution of

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398

195

these differences, a stop-work has been issued by KG&E for the instal-

lation of all Gulf and Western ASME Class II piping pre-assemblies.

The IE inspector determined from review of the radiographs that the rough ,

surface condition of the welds and the quality of the radiographs are such

that no meaningful interpretation of the integrity of tne welds could be

made. The radiographs of these eight joints failed to meet the minimum

requirements of the ASME Code,1974 Edition with Addenda through Summer of

1975, in that none exhibited all elements of permanent identification on

the film, and some did not have the proper sensitivity or penetrameter

placement.

The density variations between the penetrameter and the

radiograph area of interest, in many cases, did not fall within the minus

15% - plus 30% requirement.

On some film the location markers were

..

masking possible defects that could be located in the heat affected zone.

In several cases the film-to-object contact was not maintained and badly

distorted images of both weld and penetrameter were produced.

Al though

not a code requirement, consecutive radiographs on the same welded joint

exhibited vast density variations indicating that the exposure technique

or procedure varialles were being altered, such as exposure duration or

source-to-film distance.

This item will be considered unresolved until such time as it is demon-

strated that all G&W piping pre-assemblies are acceptable to Code

requirements.

8.

Quality Assurance Audits,

The IE inspector reviewed KG&E site QA audit of Daniel o,. ' ations.

(Reference : KG&E letter to Daniel KQWLC-281 of April 18, b79) The audit

identified thirteen new open items and closed six.

flo items of noncF.pliance or deviations were identified.

9.

General QA Indoctrination and Training

The IE inspector reviewed a random sample of records of general QA training

conducted on site selected from the electrical and welding crafts,

The

training sample of records involved twelve personnei, including a superin-

tendent, foremen and journeymen.

Discussions were held with six craft

personnel regarding their training.

The IE inspector also reviewed con-

struction procedure AP-II-06, Rev. 3 (2/5/79), " Orientation and Indoctri-

nation of Personnel ." After consideration of AtlSI f145.2 requirements and

review of the degree of implementation, the IE inspector concluded that

the requirements of the Daniel procedure meets the minimum requiremer.ts of

the AtlSI Standard and that the Daniel procedure requirements are being

satisfied.

The IE inspector did observe that general retraining to

maintain an awareness of QA/QC program should be instituted.

A Constructor

representative stated that this was presently under consideration.

flo items of noncompliance or deviations were identified.

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398

190

10.

Review of f1DE Activities - Peabody' Testing

The IE inspector reviewed the f1DE procedures in use by Peabody Testing for

the performance of radiographic, ultrasemc, magnetic particle and liquid

penetrant examination.

Also reviewed were the qualification and certification

records for all on-site Peabody Testing personnel, including evidence of

current vision tests in accordance with NTC-1A.

Calibration records and

certifications for inspection equipment and materials approved for use on

site were also checked against equipment stickers and materials batch numbers.

The IE inspector revicued approximately forty randomly selected inspection

reports generated by Peabody Testing in all four flDE methods since January 1, "

1979.

Several minor errors in data recording "ere noted and reported to the

on-site Level III supervisor who made the appropr' ate corrections and verbally

committed to reinstruct his personnel in the need for accurate reports.

fio

further action is required as these errors were detemined to be nonsignifi-

cant and were isolated cases,

fio items of noncompliance or deviations were identified.

11.

Observation of Concrete Work Activities

Three concrete placements (considered difficult) were made during this

inspection period. The following specific activities ancciated with place-

ments fio. OC 133WO5, OC 133W14 and OC 135Wl; Were inspar.ted to verify compliance

with Daniel Procedures and Bechtel Specifications:

Pre-placement Inspection

Concrete Delivery and Placement

Concrete Field Testing

Concrete Consolidation

The IE inspector also verified that civil testing lah did perfom the testing

as specified in QCP-I-04, Revisi.)n 3, Appendix A for concrete produced on

April 24, 1979.

fio items of noncompliance er deviations were identified.

12.

Review of Reactor Vessel Internals Procedures

The IE inspector reviewed procedures to detemine that activities associated

with react 9r internals are controlled and performed in accordance with f1RC

requirements and PSAR cormiitments.

The following are the specific procedures

reviewed for receipt inspection, storage, handling and lifting of reactor

internals:

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398

197

Receiving Maintenance Instruction PNI-W-042, Revision 2

Work Procedure WP-IV-110, Revision 2

Quality Control Procedure QCP-I-01 Revision 5

-

Quality Control Procedure QCP-I-05, Revision 5

Westinghouse Equipment Specification No. 953080, Revision 2

The IE inspector informed the licensee that the procedure PHI-W-042 did not

specify the frequency for the " standard surveillance" that is to be preformed.

The licensee stated that an audit conducted in February 1979 indicated that

"

this was a generic item, and that Daniel is currently revising QCP-I-01,

which will correct this.

The IE inspector informed the licensee that this item is considered

unresolved pending review by NRC of the corrective action taken.

13.

Protection and Storage of Vessel Internals

The IE inspector observed the storage, protection and preservation of specific

reactor vessel internals (listed below) to ascertain that the requirements of

specifications and procedures are being adhered to:

Name of Item

Dwg. No.

Serial No.

Lower Internals

6123E59-H01

36190

Upper Internals

6121 E72-G01

42780

Upper Tie Plate

'

6120E10-H01

R204A02

Lower Tie Plate

6120 Ell-H01

R204A03

Holddown Spring

1050F37-H01

R958A01

The lower and upper internals were stored in accordance with NSSS requirements.

However, the IE inspector found the upper and lower tie plates and the hold-

down spring improperly stored. The enclosure used to store these items was

not weather proof. Water was found on all three items and the desicant bags

were all saturated "d some had mold growth on the outside of the bag.

Caniel

informed the IE inspector 'that their surveillance ( Audit Log #057) identified,

on February 12, 1979, that the Kelley Closure was not weather tight (water

and snow were found inside of enclosure).

The IE inspector infonned Daniel

that a deficiency report was not issued for this deficiency as required by

Daniel Procedure QCP-I-01 (Revision 5).

They stated that a follow-up surveil-

lance report #230 performed on April 25, 1979, with engineering, stated that

a weather tight enclosure is not a problem.

The IE inspector stated that level

C storage is indoors or equivalent.

Daniel stated that corrective action would

be taken.

_g.

398

198

The IE inspector also noted that for another storage inspection (Report flo.

052, performed on 2/17/79) five deficiencies were found for the storage con-

ditions for the upper and lower internals and a deficiency report for all

these deficiencies was not issued.

.

The IE inspector informed the licensee that the Daniel QC Procedure QCP I-01,

Revision 5 requires that deficiencies found during storage and maintenance

shall be handled in accordance with Daniel's Construction Procedure AP-VI-02.

This procedure requires the issue of a Deficiency Report (DR) for deficient

i tems .

The licensee was informed that this item is contrary to the requirements of

10 CFR 50, Appendix B, Criterion V, a failure to follow procedures, aad is

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en infraction.

14.

, Reactor' Pressure Vessel Internals Record Review

The IE inspector reviewed the following records relative to reactor pressure

vessel internals storage, protection and receipt inspection to ascertain

whether these records are in confonnance with established procedures:

QC Receiving Inspection Report, dated 2/10/79

Material Receiving Report No. 24888

Receiving and Storage Inspection Checklist, dated 2/10/79

Westinghouse quality Release No. ?2259

Westinghouse Shipment Notice, dated 11/2/78

Westinghouse Form hCS-1 (N Certificate holders)

Data Report for Internals (National Board No. W-18529)

ASME Data Report (National Board No. 18530)

Westinghouse Deviation Notices No. 13635,13650,13669 and 18277

The IE inspector noted that the Westinghouse Shipment Notice, dated November 2,

1978, had a statement as follows, "This is to certify that Item No. 1 of

P.O. No. 011471 is incomplete within this shipment." Daniel could not identify

to the IE inspector what was incomplete nor could they state what " Item 1" was

since a copy of the Purchase Order (No. 211471) was not available. On May 7,

1979, the licensee informed the IE inspector by phone that the incomplete item

(No. 1) was a device which will be used as a construction aide during the

installation of the internals. This device is called a " Roto Lock" and is not

considered to be safety related.

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398

199

The IE inspector informed the licensee that this item is considered unresolved

pending review by IE inspector of Westinghouse information (purchase order and

drawing of Roto Lock) and the verification that Daniel has a procedure for -

handling safety related incomplete items that have been received on site.

15.

Lakes, Dams and Canals - Procedures Review

a.

The IE inspector completed the review of the Clarkson Construction Co.

Blasting Procedure, Specification A-3854, which was initiated during

the NRC inspection of April 16-19, 1979 (Inspection Report No. STN

50-482/79-D8).

During discussions held with the Clarkson Project

Engineer, the Dames & Moore Resident Geotechnical Engineer (RGTE),

"

Daniel QA Department and KG&E Quality Assurance Department, it was

ascertained that the blasting procedure did not accurately reflect

the procedure employed by Clarkson in performbg blasting work on the

Ultimate Heat Sink (UHS).

Furthermore, Dames & Moore was not signing

the blast plans as required by the procedures, although the plans were

being reviewed by the Dames & Moore staff as required. The blasting

practice used by Clarkson was determined to be producing acceptable

results, but it did not conform to the written procedure.

The possi-

bility existed that a required check on obtaining blast approval from

Dames & Moore could be violated.

The Clar'Ksen Project Engineer agreed

with the IE inspector that the actual practice differed from the written

procedure. The Dames & Moore RGTE also agreed that the requirement for

written approval of the blast plan was not being met. Both individuals

voluntarily agreed to review the procedures and make revisions as re-

quired to ensure the actual practice of safe ty related blasting conformed

to the written procedures.

Pending acceptable revision of the blasting procedure, the matter is

considered unresolved.

b.

Daniel does not require that Clarkson Construction Co. have a separate

quality assurance program due to th 2 nature of the work being performed.

Daniel, however, does require that Clarkson's work be monitored by

Daniel Quality Control personnel operating to existing approved QC pro-

cedures. This position is stated in Daniel Supplier Qualification

Certificates, dated March 30, 1973, and April 25,1979, and in 3 Daniel

interoffice communication, dated May 10, 1976.

A conference call among the IE inspector, KG&E, Daniel Engineering

Department, Dames & Moore, and Sargent & Lundy (Site AE) confirmed that

the rock excavation for the Ultimate Heat Sink is a safety related

a ctivity.

Daniel is required, therefore, to apply QC inspection functions

to the blasting work to supplement the monitoring activities provided

by Dames & Moore.

Discussions with the Daniel QC Manager ascertained

that Daniel has not been performing any QC inspections or surveillance

on Clarkson's blasting work and that Daniel QC is not clear on what

quantitative or qualitative criteria would be applied in perfonning

the QC work.

)N

g

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.

These items are considered to be in noncompliance with the requirements

of 10 CFR 50, Appendix B, Criteria V and applicable specifications and -

procedures.

16.

Lakes, Dams and Canals - Ouality Records

Paragraph 302.9e, Specification A-3854 requires a blasting specialist to

a.

be present during blasting in progress and that his qualifications be

approved by the purchaser. The IE inspector verified that a full-time

blasting specialist was present during blasting work on the UHS and also

reviewed the blaster's qualifications. The qualifications appeared to

be in order.

Daniel approved the blastcr's qualifications on April 15,

-

1977.

Sarg,et & Lundy also approved the blaster's qualifications in a

letter, dated April 12, 1977, addressed to Daniel.

b.

Dames & Moore uses either of two seismographs to monitor the blasting

effects on safety related structures.

The IE inspector verified the

calibration status of both instruments and reviewed field calibration

sheets as follows:

(1)

Sprengnether Instrument Co. Model flo. VS-1100

Recorder #4690

Seismometer #4790

Certificate of Calibration, dated June 9, 1976, was signed by the

Sprengnether chief engineer and notarized. The certificate

indicated traceability to the flational Bureau of Standards (t;BS)

Calibration Services and also indicated the instrument was within

specification recording limits.

Field Calibration Check Sheet #4690/4790

Date

Instrument Within Limits

3-<

79

Yes

3-15-79

Yes

12-21-78

Yes

12-19-78

Yes

12-18-78

Yes

12-14-78

Yes

398

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33

(2)

Sprengnether Instrument Co. Model No. VS-1100

Recorder #4681

Seismometer #4781

-

Certificate of Calibration, dated August 11, 1978, indicated

traceability to the National Bureau of Standards and that the

instrument was within specification recording limits.

Field Calibration Check Sheet #4681/4781

Date

Instrument Within Limits

,,

4-17-79

Yes

4-16-79

Yes

4-14-79

Yes

4-10-79

Yes

4-03-79

Yes

4-02-79

Yes

3-28-79

Yes

c.

The IE inspector reviewed a sampling of the Dames & Moore blast review

forms.

A total of sixty-nine forms were reviewed covering work on the

UHS from December 13, 1978, to April 17, 1979. All of the fonas reviewed

indicated whether or not blast monitoring was required and indicated

that the allowable peak particle velocity was not exceeded by any of the

blasts.

d.

The IE inspector reviewed twenty-five of the Clarkson Construction Co.

blasting plans covering the period March 16, 1979, to April 17, 1979.

All the plans reviewed indicated the depth of the drill hole, the quantity

of explosive used per hole, the stemming length, the pattern, and the hole

size as required by procedures.

No items of noncompliance or deviations were identified.

17.

Unresolved Item

Unresolved items are matters about which more information is required in order

to ascertain whether they are acceptable items, items of noncompliance, cr

398

20A.

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.

deviations. Unresolved items disclosed during the inspection are discussed

in the following paragraphs:

7

-

G&W Pipe Assemblies

-

12

-

Reactor Vessel Internals Procedures

14

Reactor Vessel Internals Record Review

-

15

-

UHS Blasting Procedure Review

18.

Ex't Interview

'

..

The IE inspector met with licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on April 26, 1979.

The IE inspectors

summarized the scope and findings of the inspection.

The unresolved items

and items of noncompliance were acknowledged by the licensee representatives.

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