ML19350B483
| ML19350B483 | |
| 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 | |
| 810216, NUDOCS 8103200640 | |
| Download: ML19350B483 (6) | |
Text
{{#Wiki_filter:hY KANSAS GAS AND ELE -e e.s:-=c ::> wv f llgQ,, M, lO ,I W )g '4 %,f' p'y8tr h 4, t) su==unocerc= / ce...,,,... m.. _+ e .27i %e 2: >g, . i, Dece m j16 FI9hD B 24,,0 d ,.b Mr. W.C. Seidle, C11ef Reacter Construction and e = - - - Engineering Support Branch
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U.S. Nuclear Regulatory Commission aegica IV Director, RCI, OIE 611 ayan Plaza Drive Director, AE00 Suite 1000 Chief, OE3, MPA. 9 IE FILES Arlington, Texas 76011 ICCIBC-047 Re: Docket No. STN 50-482 Subj: Work Hold Agreement 413 GLKoester letter dated 11/25/B0 to WCSeidle
Dear Mr. Seidle:
Attached is a revised Corrective Action Program to be carried out by Daniel Construction in order to enhance the pipe cleanliness progrm:1. Also attached is a s-7 that identifies the changes we request from the November 25, 1980 program cud 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 Co=pany 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 infor=atien 'as we would like to e,et this program underway immer.iately. O/ Sincerely, _s /f ,. ga..u %v.% uu // ~.. GLx:hb Attach cc: WCad=an, w/a ECreel, w/a Tvandel, w/a -8108200 W A w u -., - -,, n,,... - - -... o - m, -. ~.. m n, . ~..,,..,....
i l Attachment to KMLMRC-047 - 12/16/80 o
SUMMARY
CF PROPOSED PROGPAM CHANGES FROM '<CPX HCLD 1 AGREEMENT 413 CORRECTIVE ACTICN (Dated 11/25/S0) 1. Change - Under Corrective Action, Paragraph A & 3, the responsibility for pipe cleanliness has been assigned to craft personnel up to the stage of construction when the pipe spool is ready for fit up. 1. Reason for Change - The above change is made to focus responsibility en the craft personnel and to =ake more Quality 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 Mcnitor who reports to the Construction Manacer and independent from craft supervisien has been set up in lieu of the independent group.of craft personnel who reported in line to censecutive levels of craf t foremen and craft supervision. 2. Reason for Change - The above change is to provide a rechanism where a qualified non-manual person will monitor the pipe cleanliness 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 Ccnstruction Monitor has been added to. the list of personnel to be retrained in recuirements 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 traininq on the piping foremen and craft persons that work with the pipe on a daily, basis during all stages of piping ccnstruction and to emphasize to those persons their front line responsibilitics in the pipe ci,eanliness program to ensure the pipe cleanliness requirements are met. The Constructicn 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 i.ist of the foreman's resycnsiblities has. been added to this change. Foreman responsibilities with regard to pipe cleanliness are delineated to clearly define the -foreman 's responsibilities. J p' 4. Reason for Chance
- he above addition 'is made to improve the pipe cicanliness program by clearly stating the' foremn's responsibilities and is to ensure there can be no misunderstanding ameng, the foreman, craf ts persons, supervision, Quality Control and the construction Monitor en the foreman's responsibilities.
P00R FEL
1 Work Hold. Agreement #13 Attachment to Page Two of Two KMLNRC-047 - 12/16/80 5. Change Deviations from CAR 45 and #6 Commitments This list of the Deviations frem CAR 45 and 45 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. 4 V 4 w = r
Mtnchmett t to KMLNRC-047 - 12/15/80 WCRK HOLD AGREBIENT #13 In response to Work Hold Agreement (13 (issued November 20, 1980), Danici Interna-ticnal proposes the folicwing corrective action to modify and upgrade the existing pipe cicanliness program as initially outlined in CAR f6. CAUSE OF NCNCCNF041ING CCNDITICN In evaluating the spools identified in Kansas Gas and Electric Surveillance Report No. S-280, it has been determined that: A) Pipe being processed through the Pipe Cleanliness Station (Hydrolaser Building) is effectively being cleaned, inspected, and capped. .B) C1 caned 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 en the pipe once it has been brought into the buildings; hcwever, the Quality Control Seals en the caps are not being maintained. D) Field personnel are not fully aware or cognitant of the existing requirement for having Quality 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 at i printer errors, they are difficult to mad and therefore have not been issued to all involved personnel. F) Although placement of dams prior to end prep grinding or dirt-prcducing activi-ties is being performed, 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 -ASB) The ccnstruction craft will have all responsibility for cleaning the pipe in the Pipe Cleaning Station, capping after cleaning, and maintain pipe cleanliness in the staging areas. Quality Centrol will not be required to verify cleanliness after cleaning, nor seal the caps in the Pipe Cleaning Station. C) Responsibility of maintaining pipe cleanliness ence the pips leaves the staging area and is brought into de building will be shifted directly to the construc-tien craft responsible for installing the pipe as fo11cws: 1. He craft foreman installing the pipe will have the ultimate responsibility 'for insuring pipe cicanliness is maintained frem the time he has it brcught into the building until it is ccmpletely installed. 2. A Construction Monitor, reporting to the Constmction Manauer independent frem Craft Supervision will be set up. Specific responsibility will be to . perform surveillance of craft responsibility of in-process cleanliness and cicanliness centrol. The Constmetion Manager will take corrective acticr. on any reported deviation to the in-process cicanliness criteria. P00R ORGINAL
Work F.old Agreemenc *13 Attachment to i -. Page Two of three K24.I2iRC-047 - 1 /15/30 iv 3. The craft foremwt will be required t.o have the pipe inspected for cleanli-ness and released for fit::p by Qnlity Centrol. This inspectica will be performed after the pipe has been moved into approximate installatien posi-tien, with sufficient accessibility fcr the Quality Centrol Inspector to adequately inspect the internals of the pipe. 4. As part of de release for fitup, de installed pipe will also require inspection by Quality Centrol. Quality Centrol will have to witness the removal of the cap frcm the installed piece. 5. If both $e installed pipe and de pipe being installed are clean. de Quality Cchtrol-Inspector will release the joint for fitup by indic:_ ing such en the apprer-iate fem in de Traveler. If the piece being installed is not acceptable, it will be returned to de craft for cleaning. If the installed piece is not acceptable, :s Deficiency Report will be initiated. 6. After release for fitup, all cpen ends of the pipe not required for fitup will be capped and~ sealed by the Qmlity Centrol Inspec:cr. 7. If it is necessary to delay fitup snd re-install the cap (s) after de pipe is released for fitup, Quality Centrol will be recuired to apply a seal to the cap (s). Removal and/or replacement of de sealed cap (s) will require witness by Quality Control. 3. If it is necessary to do additienal work en the pipe being installed' prior to fitup, centrol of the pipe can be returned to the craft by having de Quality Centrol Inspector void his release for fitup en tw Neld.C:ntrol Record. - Quality Control will be recuired to again inspect and release de pipe prior to fitup. 9. All installed pipe and pipe released for fitup will be under centrol of Quality Centrol. ' A Qualir/ Centrol Inspec:ct will.be required to witness removal of caps, installatien and removal of dams, and replacement of caps, with de Quality Centrol Inspector verifying cleanliness at these times.
- 10. ; For Non-Q pipe, Mechanical Engineering will perfom the Quality Centrol
- unc:: ens specirled in Mmbers 2 through 3.
~ D)'. All Craft, Engineering, Quality Centrol, and Ccnstmetien Mcnitoring persennel 4 . involved with installatien of piping will be re-trained in require::ents of de new pipe cleanliness program.' (Precedure revisiens are addressed in (G)~, belcw.) ' Foremen will be recuired to go through an extensive : raining pregram to ensure - they are fully ccgnizant of the cleanliness requirements. These training sessiens -snall be cm.pleted prior to starting work. ~ E) "Hard' Card" portabic listings will be recorded and issued to Craft.- Quali:v Con-tr:1, and Engineering personnel. The cards will be revised, listing key infoma-tien and shall be printed en a size sufficient-to ensure Icgibili:/. t F) hidressed in -{C), 'above. GL Apptcpriate Work Precedures and Qaality Centrol Precedures will be revised to - ' ' reflect de aboveLprogram. EICP's'shall be issued prior to startit.g wcrk. - To , supplement precedure requirements, Work Instmetiens shall be issued to craft foremen by the.CcnstructionSunage6 utlining'the; fellcwing specific respcnsi-bilitics ofithcL foreman to assure expliance with de precedure.- These Work lInstructiens shall'be emphasized during L: raining.: y t 'n 1 ~ T 4 9 d v- = 4 r es,=y , t y yw y - + +
work Hold Acreement #13 Attachment to ... Paga Thrso of Three K EIRC-047 - 12/15/B0 FORE %4 RESPONSIBILITIES: 1. To insure that.integritf of caps is maintained and that caps are not re-moved from the pipe unless recuired to perform work. 2. To insure that dams are placed and adecuately sealed:
- 1) prior to per-forming end props 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. 4. To assure caps are replaced after c:mpletien of work. 5. To assure pipe is clean prior to requesting cleanliness inspection by Quality Centrol prior to fitup. Effectiveness of the above program will be menitored through cur existing Quality Assurance Program. DEVIATICNS FFG1 CAR f 5 AND #6 CC6NI3 TENTS As stated in the cpening paragraph, the preceeding was a proposal to modify and up-grade the existing pipe cleanliness program. The cemitments made in response to - CAR #5 and #6 are to remain in effect, with the follcwing deviaticns: A) Piping will not be inspected by Quality Centrol after cleaning in the Pipe Cleaning Statica. B) QC Accept" seals denoting clesnliness will nc~t be applied to end caps until .after the pipe is released for fitup. C) Quality Centrol will not be required to witness remeval of caps, installaticn and removal of dams, or replacunent of caps until after the pipe is released for fitup. D) Quality Control Inspectors will perform surveillance of pipe for conditlen of czyping and sealing only en installed pipe or pipe released for fitup. 4. 9 4 .}}