ML19343D082

Forwards Revised Corrective Action Program to Be Carried Out by Daniel Const to Enhance Pipe Cleanliness Program.Also Forwards Summary of Changes from 801125 Program.Notification Will Be Submitted Prior to Lifting Work Hold Agreement 13

ML19343D082
Person / Time
Site:	Wolf Creek
Issue date:	12/16/1980
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
KMLNRC-047, KMLNRC-47, NUDOCS 8104090281
Download: ML19343D082 (6)

Text

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M ELECTAiC COMAANY KANSAS GAS AND ELECTRIC COA TIrv NSIC CENTRAL FILES OLENN L Rogsvgm v <1 ** t s.ct= r . mwcta == _, __

y ,, December 16, 1980 Emd / ,1000

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Mr. W.C. Seidle, Chief j Reactor Construction and Engineering Support Branch U.S. Nuclear Regulatory Cort nission -

~d Region IV -d .Q, 611 Ryan Plaza Drive 6)~ ,@

Suite 1000 No -

g Arlington, Texas 76011 3 V@,

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1 KMLNRC-047 4 -2 Re: Docket No. STN 50-482 Subj: Work Hold Agreement #13

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% y GLKeester letter dated 11/25/8C to WCSeidle p..

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Dear Mr. Seidle:

Attached is a revised Corrective Action Program to be carried out by Daniel Construction in order to enhance the pipe cleanliness program. Also attached is a summary that identifies the changes we request from the November 25, 1980 program and the reason for requesting these changes. I believe you will find the same end result will be achieved with the new revised program compared to the program that was submitted to your office on November 25, 1980.

As stated earlier, Kansas Gas and Electric Company will notify your office prior to our lifting of the Work Hold Agreement No. 13 in order for Mr. Thomas Vandel to assure you that the corrective action plan as outlined in the attached revised plan to this letter has been put in place.

Would you please call me as soon as you have received this information as we would like to get this program underway immediately.

l l Sincerely, I

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GLK:bb Attach cc: WCadman, w/a ECreel, w/a Tvandel, w/a 81u4090 $$l t

Attachment to IGILNRC-047 .12/18/80

SUMMARY

OF PPDFOSED PROGRAM CHANGES FROM WORK HOLD AGREEMENT #13 CORRECTIVE ACTION (Dated 11/25/80)

~ 1. Change - Under Corrective Action, Paragraph A &. B, the responsibility for pipe cleanliness has been assigned to craft personnel up to the stage of construction when tne pipe spool is ready for fit _ up.

- 1. Reason for Change'- The above change is made to ' focus responsibility on the-craft personnel and to make more Quility Centrol personnel available at -the time that asruring. a pipe spool is clean really ' counts, just prior to fit up and tacking in place for welding.

_ 2. Change - Under Corrective Action', Paragraph C, the only significant change is in Part 2 where a Construction Monitor who reports to the Construction Manager and independent from craft supervision has been set up in lieu of the independent group of craf t personnel who reported in line to consecutive levels of craf t foremen and craft supervision, i .

2. Reason for Change - The above change . is to provide a mechanism where a qualified non-manual person will' monitor the pipe elesnliness program prior to pipe fit up and be able to report any variations -to ' the program directly to Senior Management.

3. Change - Under Corrective Action, Paragraph D, the Construction Monitor has 2

been ~ added to the list of personnel to be retrained in requirements of the ~

new pipe cleanliness program and also the Foreman in lieu of the Independent Craft Monitors now will be required to go through an extensive training program to ensure they are fully cognizant of the cleaning requirements.

3. Reason for Change - The above change is made to concentrate the training on the piping foremen and craft persons that work with the pipe on a daily basis during all stages of piping ' construction and to emphasize to those persons their froat line responsibilities in the pipe cl,eanliness program to ensure the pipe cleanliness requirements are met. .The Construction Monitor will receive the same training as the piping foreman and craf t persons to ensure a uniform- complete understanding of the pipe cleanliness requirements.

4. Change - A list of the ' foreman's resconsiblities has been added to this chan ge . Foreman responsibilities with regard to pipe - cleanliness are -

delineated to clearly define . the foreman 's responsibilities.

4 Reason for Change - The above addition is made to improve the pipe cleanliness

- program by clearly stating the foreman's responsibilities and is to ensure there can be no misunderstanding among, the foreman , craf ts pecsv.m.

supervision, Quality Control and the Construction Monitor on the foreman's res ponsibilities .

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Work Hold Agreement #13 Attachment to Page Two.of Two KMLNRC-047 - 12/16/80 a

5. Change - Deviations from _ CAR #5 and #6 Commitments

- This list of the Deviations from CAR #5 and #5 Commitments had been attached to this change, however, they have been previously discussed

, in the Corrective Action paragraphs and are listed for ready -reference.

. 5. Reason for Ghange - The above addition is 'made to readily identify the changes from the program that existed prior to November 25, 1980.

. At tmchterit to

. KMLNRC-047 - 12/15/80 WORK HOLD AGREINENT #13 In response to Work Hold Agreement #13 (issued November 20,1980), Danici Interna-tional proposes the following corrective action to modify and upgrade-the existing pipe cleanliness program as initially outlined in CAR #6.

CAUSE OF NONCONFOINING CONDITICN In evaluating the spools identified in Kansas Gas and Electric Surveillance Report No. S-280, it has been detemined that:

A) Pipe being processed through the Pipe Cleanliness Station (Hydrolaser Building) is effectively being c1 caned, inspected, and capped. i B) Cleaned pipe being stored in the staging area is adequately being stored and cleanliness including integrity of end caps is being maintained in these areas.

C) The integrity of the pipe end caps is being maintained on the ' pipe once it has been brought into the buildings; however, the Quality Control Seals on the caps are not being maintained.

D) Field personnel are not fully aware or cogni:: ant of the existing requirement for having Quclity Control witness the removal and replacement of end caps while the pipe is being worked in the buildings.

E) Hard card portable listings of cleanliness requirements (as comitted to in CAR #6) have been made, but due to the amount 'of information printed on the card and printer errors, they are difficult to read and therefore have not been issued to all involved personnel.

F) Although placement of dams prior to end prep grinding or dirt-producing activi-ties is being perfomed, there is evidence that the dams are not being used for 100% of the time or the sealing integrity of the dam is not always adequate.

G) Work Procedures do not clearly explain the existing pipe cleanliness program.

CORRECTIVE ACTION t ASB) The constmction craft will have all respensibility for cleaning the pipe in the Pipe Cleaning Station, capping after cleaning, and maintain pipe cleanliness in

, the staging areas. Quality Control will not be required to verify cleanliness i after cleaning, nor seal the caps in the Pipe Cleaning Station.

L C) Responsibility of maintaining pipe cleanliness once the pipe Icaves the staging area and is brought into the building will be shifted directly to the constmc-j tien craft responsibic for installing the pipe as follows:

l 1. The craft foreman installing the pipe will have the ultimate responsibility l for insuring pipe cicanliness is maintained from the time he has it brought l into the building until it is completely installed.

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! 2. A Construction Moniter, reporting to the Constmctica Manauer independent l from Craft Supetvision will be set up. Specific responsibility will be to l perfom surveillance of craft responsibility of in-process cleanliness and cicanliness centrol. The Constmction Manager will take corrective action on any reported deviation to the in-process cleanliness criteria.

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> Work-!!old Agreement #13 Attachment to l < Paga Two of Thrsa KMLNRc-047 - 12/15/80

3. %c= craft foreman will be required to have the pipe inspected for cleanli-ness and released for fitup by Quality Control. H is inspection will be-perfomed after the pipe has been moved into approximate installation posi-tion, with sufficient accessibility for the Quality Control Inspector to adequately inspect. the internals of the pipe.

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4. As part of the release for fitup, the installed pipe will also require inspection by Quality Control. Quality Control will have to witness the removal of the cap from the installed piece.

5. If both the installed pipe and the pipe being ' installed are clean,. the Quality Cohtrol Inspector will release the joint for. fitup by indicating such on the appropriate fom in the Traveler. !If the piece being installed is not acceptabic, it will be returned to the craft for cleaning. If the installed piece is not acceptable, a Deficiency Report will be initiated.

6. After release for fitup, all open ends of the pipe not required for fitup will be capped and scaled by the Quality Control Inspector.

7. If it is necessary to delay fitup and re-install the cap (s) after the pipe is released for fitup, Quality Control will be required to apply a seal to the cap (s). Removal and/or replacement of the sealed cap (s) will require witness by Quality Control.

8. If it is necessary to do additional work on the pipe being insta11ed' prior to fitup, control of the pipe can b'e returned to the craft by having the Quality Centrol Inspector void his release for fitup on the Weld Control Record. Quality Control will be required to again inspect and release the -

pipe prior to fitup.

9. All installed pipe and pipe released for fitup will be under control of Quality Control. A Quality Control Inspector will be required to witness removal of caps, installation and removal of dams, and replacement of caps, with the Quality Control Inspector verifying cleanliness at these times.

10. For Non-Q pipe, Mechanical Engineering will perfom the Quality Control functions specified in Numbers 2 through 8.

D) All Craft. Engineering, Quality Control, and Construction Monitoring personnel involved with installation of new pipe cleanliness program. (Procedure piping will be re-trained revisions in requirements are addressed in (G),ofbelow.)

the Foremen will be required to go through an extensive training program to ensure they are fully cognizant of the cleanliness requirements. Rese training sessions shall be completed prior to starting work.

E) "Hard Card" portable listings will be recorded and issued to Craft. Quality Con-trol, and Engineering personnel. He cards will be revised, listing key infoma-tien and shall be printed on a size sufficient to ensure legibility.

F) Addressed in (C), above.

G) Appropriate Work Procedures and Quality Control Precedures will be revised to reflect the above program. ICP's shall be issued prior to starting work. To supplement procedure requirements, Work Instmctions shall be issued to craft foremen by the Construction Manager, outlining the following specific responsi-bilities of the foreman to assure compliance with the procedure. R ese Work Instmctions shall be emphasized during training.

, Wofk lloid Agreement #13 Att.achment to

. , , ' Paga Threa of Thraa KMLNRC-047 12/15/80

' FORE EN RESPONSIBILITIES:

1. To insure that . integrity. of caps is maintained and th.at caps are not re-moved from the pipe unless required to perform work.

2. To insure that dams are placed and adequately scaled: 1) prior to per-fonning end preps or other dirt-producing activities; or 2) at any time caps will be left off for long periods of time.

3. To assure pipe is clean prior to removal of. dams or replacement of caps.

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4. To assure caps are replaced after empletion of work.

5. To assure pipe is clean prior to requesting cleanliness inspection by Quality Control prior to fitup.

Effectiveness of the above program will be monitored through our existing Quality Assurance Program.

DEVIATICNS FRCt1 CAR f 5 AND #6 CCt41ITMENTS As stated in the opening paragraph, the preceeding was a proposal to modify and up-grade the existing pipe cleanliness program. The. commitments.made in response to CAR #5-and #6 are to remain in effect, with the following deviations:

A) Piping will not be inspected by Quality Control after cleaning in the Pipe Cleaning Station.

B) "QC Accept" seals denoting cleanliness will no't be applied to end caps until after the ~ pipe is released for fitup.

C) Quality Control will not be required to witness removal of caps, installation and removal of dams, or replacement of caps until after the pipe is released for fitup.

D) Quality Control Inspectors will perfom surveillance of pipe for condition of capping and sealing only on installed pipe or pipe released for fitup.