ML19254D292

Responds to NRC 790607 Ltr Re Violations Noted in IE Insp Rept 50-482/79-09.Corrective Actions:All Excavation & Const Work on Ultimate Heat Sink Reservation & Dam Considered to Be safety-related Activity

ML19254D292
Person / Time
Site:	Wolf Creek
Issue date:	07/06/1979
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19254D289	List: ML19254D292 ML19254D295
References
NUDOCS 7910230297
Download: ML19254D292 (4)

Text

KANSAS GAS AND ELECTRIC COMPANY GLENN L. dOESTE R veCt PetsC,Essf optmaisO4S July 6, 1979 Mr. W.C. Seidlj, Chief Reactor Construction and Engineering Support Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012 Subj: Response to Inspection Report 50-482/79-09

Dear Mr. Seidle:

This letter is written in response to your letter of June 7, 1979, which transmitted Inspection Report 50-482/79-09. As requested, each finding is being addressed in three parts:

a) Corrective steps which have been taken and the results achieved, b) Corrective steps which will be taken to avoid further non-compliance, and c) The dates when full compliance will be achieved.

Finding Daniel Procedure QCP-I-01, Revision 5, paragraph 4.2 requires Lliat deficiencies found during storage and maintenance inspections shall be handled by the issue of a Deficiency Report (DR) in ac-cordance with Daniel Procedure AP-VI-02.

Contrary tc the above:

Five defici .scies noted on upper and lower internals storage in QC Inspection Report No. 052 conducted February 17, 1979, were not documented in a Deficiency Repc 't (DR).

Response

a. To assure that all problens noted on old surveillance reports have been properly dispositioned the following steps are 3

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201 N. Market - Wichita, Kansas - Mall Address: P.O. Box 208 / Wichita, Kansas 67201 - Telephone: Area Code (316) 264-1111

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Mr. W.C. Seidle July 6, 1979 being taken:

1. Storage Surveillance Reports initiated prior to May 79 are being reviewed.

2. If a storage problem was noted on a report, a check is being made to determine if a Deficiency Report was processed; if not,

3. The equipment / material, if still in storage, is being checked to verify that the problem has been corrected.

Deficiency Reports ISD1471M and J SDl657?t have been initiated for the conditions noted in the above finding.

Revision 6 to QCP-I-01 has been issued to clearly define when Deficiency Reports are to be initiated for failure to provide and maintain a proper storage environment.

b. A training class was conducted for the responsible Quality Control Inspectors on May 3, 1979 relative to the requirements of QCP-I-Ol Revision 6.

c. Full compliance will be achieved when the review of storage surveillance repo, is completed. (Estimated completion date is August 1, 1979, Finding Paragraph 6, ANSI Standard N45.2-1971 states in part, " Activities affecting quality shall be prescribed by documented instructions

... and shall be accomplished in accordance with these instructions

. . . :' Paragraph 6 further states in part, "The activity may be pre-scribed in job specifications, work instructions ... test procedures, or any other type of written form, provided that the activity is adequately described. Quantitative criteria ... and qualitative criteria . . . shall be specified . . . ."

Paragraph 17.1.5 of the SNUPPS PSAR states in part, "Each major SNUPPS contractor is responsible for controlling its activities affecting quality in accordance with documented procedures ...."

Daniel Supplier Qualification Certificatet dated March 30, 1978. and April 25, 1977, require that work perdo.med by Clarkson Constr uction Company on the Ultimate Heat Sink (UHS) be monitored by Daniel Quality Control personnel using existing Daniel QC procedures.

Contrary to the above:

The ~ constructor, Daniel international, has not conducted quality control inspections or surveillance on the UHS work since its beginning on

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.. s Mr. W.C. Seidle July 6, 1979 or about October 16, 1978. In addition, the applicable Daniel quality control procedares have not been identified for the UHS work nor have qualitative and quantative acceptance criteria been specified for the blarzing work.

Response

a) 10 CFR 50, Appendix B, Criterion X states that examinati ens, measurements, or tests of material or products processed shall be performed for each work operation where necessary to assure quality. To date, UHS work has been limited to blasting and excavation related activities. On June 18, 1979 the Site Geotechnical Engineer (hams & !*corc) conclude? an evaluation which reaffirmed that pre-shot inspection of UHS structural excavation blasts, as well as the inspection of other UHS and UHS dam excavations, are not necessary for current UHS activities, b) Inspection and surveillance procedures will be implemented later in the construction phase of the UHS and UHS dam to assure compliance with applicable drawings, specifications and procedures.

c) Construction of the UHS and UHS dam is expected to begin November, 1979. Inspection and surveillance (monitoring) of this work will be performed in accordance with approved procedures by Dames & Moore, and Daniel International at that time.

Please advise if you need additional information.

Yours very truly, 1 I , -

'fNY /

GLK:bb ii"/ 207