ML20004B328
| ML20004B328 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/25/1980 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| KMLNRC-041, KMLNRC-41, NUDOCS 8105280038 | |
| Download: ML20004B328 (4) | |
Text
'/ /b KANSAS GAS AN? ELECTRIC COMPANY tw museme c=wea~v TELECOPIED TO MR. SEIDLE with original placed in mail.
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N vember 25, 1980 h" w4 naua nourr:cs:Iip /
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Mr. W. r. Seidle, Chie f
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4 U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 KMLNRC-041 Subj: Work Hold Agreement #13
Dear Mr. Seidle:
Work Hold Agreement No.13 was issued November 20, 1980 at the Wolf Creek Generating Station for further corrective action to be taken by Daniel International for pipe cleanliness.
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Attached is the response by Daniel International outlining the "Cause of Nonconforming Condition" and the " Corrective Action" that l
is recommended to enhance the pipe cleanliness program.
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As discussed with you by telephone today, 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 t?.at the corrective action plan as outlined in the attachment to this letter has been put in place.
If you have any further questions c7ncernin9 this mat.ter, please call me.
Yours very truly,
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n.ut. smmlMC GLK:bb Attach cc: WCadman, w/a ECreel, w/a TVandel, w/a 8105280038 201 N. Market - Mchtta, Kansas - Mad Address: PO. Box 208 I Wehrta. Kansas 67201 - Teleonone: Area Code (3161 261-6451
Attcchment to KMLNRC-041 - 11/25/80 WORK HOLD AGREEMENT #13 In response to Work Hold Agreement #13 (issued November 20, 1980), Daniel International proposes the following corrective action to upgrade the existing pipe cleanliness program as originally outlined in CAR #6.
CAUSE OF NONCONFORMING CONDITION In evaluating the spools identified in Kansas Gas and Electric Surveillance Report S-282, it has been determined that (a)
Pipe being processed through the Pipe Cleanliness Station (Hydrolaser Building) is effectively being cleaned, inspected, and capped.
'.(b)
Cleaned pipe being stored in the staging areas is adequately being stored and cleanliness including the integrity of end caps is being maintained in these areas.
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(c)
The integrity of the pipe and 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.
J' (d)
Field personnel are not fully aware or cognizant 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 listin'gs of cleanliness requirements (as committed 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 inssued to all involved personnel.
( f)
Although placement of dams prior to end prep grinding or dirt producing activities 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 cleanli-ness program.
CORRECTIVE ACTION (a)
No further corrective action is required at the pipe cleanliness station. Pipe will continue to be processed through this station with Quality Control vertification of cleanliness and placement of Quality Control accept seals.
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Attachment to e
KMLNRC-041 - 11/25/80 Work Hold Agreement #12 Page Two of Three (b)
No further corrective action is necessary at the pipe staging areas. Controlled access into these areas will continue to be maintained.
(c)
Responsibility of maintaining pipe cleanliness once the pipe leaves the staging area and is brought into the building will be shifted directly. to the construction craft responsible for installing the pipe as follows:
(1)
The craft foreman will have the ultimate respon-sibility for ineuring pipe cleanliness until just prior to fitup.
It will be his responsibility to insure that dams are placed and. adequately sealed prior to performing and prep or other dirt producing activities.
The foreman is also responsible for verifying pipe cleanliness prior to requesting cleanliness inspection.
(2)
An independent group of craft personnel will be set up to monitor in-process cleanliness. Specific responsibilities will be witnessing all removal of end caps, installation of dams, verification of cleanliness prior to removal of dams, witnessing removal of dams, reverification of cleanliness after the dam is removed, and witnessing the replacement of end caps.
(3)
Quality Control will be required to inspect the pipe for cleanliness just prior to fitup and release acceptable pipe for fitup by indicating such on the appropriate weld control record in the traveler. This inspection will be performed after the pipe. has been moved into approximate installation po.cition with sufficient accessibility for the Quality Control Inspector to adequately inspect internals of the pipe.
(4) IAfter the pipe is erected and installed (at least one end welded), Quality Control will verify cleanliness and seal all open ends of the pipe.
(5)
If it is necessary to delay fitup and reinstall the cap (s) after the pipe is released fo_ fitup, Qualit/
Control will be required to apply a seal to the cap (s).
Removal and/or replacement of sealed cap (s) will require Quality Control witnessing.
(6)
If it is necessary to do additional '.<ork on the pipe prior to fitup, control of the pipe can be returned to the craft by having Quality Control Inspector void
Attachm:nt to KMLNRC-041 - 11/25/80 Work Hold Agreement #13 Page Three of Three his release for fitup on the weld control record.
Quality Control will be required to again inspect and re. ease the pipe prior to fitup.
(d)
All Craft, Engineering, and Quality Control Personnel involved witn installation of piping will be retrained in the requirements of the new pipe cleanliness program. (Procedure revisions are addressed in (g) below). The craft cleanliness monitors will be required to go through an extensive training program to insure they are fully cognizant of cleanliness requirements and emphasizing the independence and control over the work activity. This training shall be completed prior to starting work.
(e)
"Hard Card" portable listings will be re-ordered and issued to Craft, Quality Control, and' Engineering Personnel. The cards will be revised listing key information and shall be printed on a size sufficient to insure legibility.
(f)
Addressed in (c) above.
(g)
All appropriate Work Procedures and Quality Control Procedures will be revised implementing the above program.
IC?3 shall be issued prior to starting work.
Effectiveness of the above program will be monitored through Quality Control surveillance of the activities and our existing Quality Assurance Program.
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