ML20032C049
| ML20032C049 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/10/1981 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20032C043 | List: |
| References | |
| KMLNRC-81-111, NUDOCS 8111060649 | |
| Download: ML20032C049 (12) | |
Text
'
C KANSAS GAS AND ELECTRIC COMPANY TW ELECTsa.C COMPANY
'A
..T') Y{lG;((
/
GLENN L 4 0 E S T E st
[_
[
w'CE P4ESiOEpe? anvCatar
~
September 10, 1981 Mr. G.L. Madsen, Chief Reactor Projects Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 KMLNRC 81-111 Re:
Docket No. STN 50-482 Subj: Heating / Ventilating / Air Conditioning Duct Supports
Dear Mr. Madsen:
This letter documents the discussions and commitments made to NRC personnel during our September 3, 1981 meeting at the Region IV Office in Arlington, Texas.
The purpose of the meeting was to advise the NRC of our planned course of action to resolve our heating / ventilating / air conditioning duct support problem and our actions to determine if the causes of the problem may have adversely affected other items.
Information was presented in four areas: Changes Since Occurrence of Problem, Investigations and Plans, Program Enhancements, and the Heating / Ventilation / Air Conditioning Duct Support Corrective Action Plan. The information is summarized in the four attachments to this letter.
In accordance with requests made by Mr. Seyfrit during the meeting, the review of the safety-related heating / ventilating / air conditioning duct supports not already reviewed will be done in accordance wi h a l
sampling plan derived frca a recognized international standard for l
sampling plans including a prescribed acceptable quality level. Also, per Mr. Seyfrit's request, the presentations to be made to project personnel regarding quality documentation will address other aspects of quality such as correct application of welder stamps, use of qualified procedures and proper dispositioning of deficiencies.
In accordance wi th the agreement reached at the meeting, KG&E will file a report on this deficiency in accordance with 10CFR50.55(e) prior 8111060649 810923
/
PDR ADOCK 05000482 O
(
201 N. Market - Wichota, Kansas - Mail Address: PC. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code 1316) 261-6451
)
i l
Mr. G.L. Madsen KMLNRC 81-111 September 10, 1981 to October 3, 1981.
Each of the actions listed in the Attachments will be planned and a schedule for their completion established. These schedules will be available for NRC review by October 16, 1981.
Yours very truly, hk
.o'.
GLK:bb Attach cc: TVandel Resident NRC Inspector Attach L
J
ArrAcilMrfJT A to KML!JRC 81-111 CilA!JGES SI JCE OCCUIUM:f1CE OF PEOBLEM
]
7 I.
Since this problem occurred, signi ficant changes have occurred at
_==
j Wolf Crcek which contribute substantially to minimizing
-=
the likelihood of a similar occurrence today.
A new KG&E Construction Manager is in position and his
-7 a.
~
staff has increased tenfold.
M b.
The KG&E Site Q.A. Organization has increased in size by eleven people and the llome Of fice Q. A. Oroanization has M
doubled.
E The Daniel Project, Engineering, Services, Construction m
c.
M and Quality Managers have all been replaced.
d.
The On-Site Daniel Quality Opuation has been totally restructured and now has an independent reporting path to the Corporate Office in Greenville, The Daniel Quality Organization's cominunications with and e.
support from the Pro 4ect Manager have dramatically increased.
f.
The staf f of the Daniel Quality Organization has doubled in size.
M The Daniel Quality Organization has upgraded its training
-M g.
program and the qualifications of the Quality Personnel 6~z have increased.
_ -c W
II.
Many of the individuals who were directly involved in or had supervisory M
or managerial responsibilities associated with this problem are no longer m
at Wolf Creek.
6 III.
The procedural controls associated with the work activity causing
=
this problem have been irnproved.
MN
-.4 Page 1 of 2 M
m.
i
( *I
- C Attachment A to KMI,NRC 81-111 IV.
The programs to train Welders and Quality Control Welding Inspectors ha're been improved. This effort includes more ef fective use of audio /
visual equipment and the use of additional experienced instructors.
V.
KG&E Quality Assurance has recently completed a comprehensive audit of all visual weld inspection and an investigative audit of the heating, ventilating and air conditioning duct support installation process. The audits identified open items which are being addressed by Daniel and prampted several program enhancements cutlined in ATTACllMI:NT C.
I Page 2 of 2
ATTACHME!!T B to KMLNRC 81-111 I!NESTIGATIONS AND PLANS 1)
Investigate to determine if the following conditions which adversely affected construction and inspection work associated with the heating /
ventilation / air conditioning duct supports adversely affect ed any other work:
~
a)
The transfer of information from one record to another where the original was superseded, b)
The performance of construction or inspection activities without benefit of procedural control cr where changes to construction and inspection procedures were not coordinated.
c)
The disposi tioning of DR's which provide no specific direction to the craft /QC personr.el as to how the deficiency was to be resolved.
d)
The lack of recognition by the project of the safety-related a
status or the special program requirements of a system prior to the start of ccnstruction activities on that system.
A plan for these investigations will be developed. The plan will establish priorities for the syr,tems involved and a schedule for completion of the effort.
2)
Inspect the in-place safety related heating / ventilating / air conditioning duct work to verify that it con forms to the drawings and specifications.
- 3) The open items identified in the recent audits of visual weld inspec-tion and heating, ventilating and air conditioning duct s uppo rt instal-l 1ation, file numbers 57061-K51 and 57061-K53, shall be investigated and responded to by DIC.
l l
l Page 1 of I l
t
O
_A E Agilig4T C to KMLNRC 81-111 PROGRAM ENilANCEMENTS 1)
Increase control of quality documentation:
a)
Travelers will be controlled in a central project location by Engineering. The Craf t and Quality Supervision will generate need lists of travelers on a daily basis and input requests to the supervi or of the traveler group prior to the end of the f
shift. The traveler group will assemble the docaments for withdrawal. The Craft or Quality Supervisor will sign out the documents and turn the documents back in during the same shift.
The traveler group will log out and in the traveler documents.
At check in, the traveler group will verify document count and check the documents for inclusion of appropriate information, obvious errors, omissions and unauthorized additions, changes or deletions of information.
b)
Identify the additional documentation which should be controlled.
c)
Evaluate the need for Craf t involvement in the flow of controlled documentation.
d)
Where the Craft involvement is not required, revise procedures to remove Craft from document flow.
e)
Where the documents provide information needed by the Craf t, the procedural controls will be revised to restrict the Cra f t cont rol of documents to an as-needed basis.
2)
Improve coordination between the Work Procedures
(' P's) and the Quality W
Control Procedures (QCD's):
l Page 1 of 4 l
At tachmen t C to XMLMRC 81-111 a)
Revise Procedure AP-I-02 so that proposed revisions to Work or QC Procedures are reviewed for impact upon the mating procedure.
Where impact is identified, the change shall be held until both resised Procedures can be issued simultaneously.
3)
Improve processing of completed records from the field to the vault:
~
a)
Evaluate the flow of ccmpleted documents and establish when they sbauld be processed to the vault for retention.
b)
Revise Procedures as appropriate to reflect when the documents should be processed to the vault for retention.
c)
Evaluate reducing size of existing travelers to cover smaller portions of work so that paperwork will be available for pro-cessing into the vault in a more timely manner.
d) Future travelers will be limited to the smallest practical work size.
4)
Develop controls for transfer of data / signatures from one record to ano th e r.-
a) The ceneral work instructions provided to project personnel will be reviewed and, as appropriate, instructions will be provided prohibiting the transfer of data / signatures from one record to another unless such transfer is conducted in accordance with approved Procedures.
b)
Procedures requiring transfer of information will specify that the superseded documentation will be retained.
- 5) Verify that the inspection process requires adequate in-process inspection Page 2 of 4
Attachment C to XMLNRC 81-111 by Quality Inspection personnel.
Improve continuity of inspection effort by assigning welds / hangers, etc. to a specific Inspector:
a)
Evaluate the processes controlled by the following list of procedures te assure that adequate in-process inspection is provided. Where additional in-proce;s inspection in deemed desirabic,,the QC and work Procedures will be revised to include appropriate in-process inspections.
1)
Receipt, storage and preservation of safety-related materials and items.
2)
Miscellaneous steel and imbedment fabrication.
3)
Fireproofing of st.ructural steel.
4)
Special field coatings and surfaces.
5)
Installation of rotating equipt'ent.
6)
Inspection of welding process.
7)
Installation fabrication of piping, components and supports.
8)
Inspection of coating and wrapping of pipe.
9)
Hydrostatic / pneumatic testing.
10)
Weld repair.
11)
Field fabrication and erection of safety-related duct-work and supports.
12)
Installation of electrical raceway 13)
Installation of electrical raceway supports.
14)
Installation of cabic.
15)
Cabic termination.
16)
Installation of electrical equipment.
17)
Electrical instrumentation installation.
18)
M/W system turnover procedure quality.
Page 3 of 4
Attachment C to KMLNRC 81-111 6)
Improve control of welder ID stamping:
a)
Review present controls and revise Procedures to include quality verification of the welder identification on both the weld and associated documentation.
b)
Evaluate the need for tighter controls on welder identification stamps.
c) Evaluate the practicality of having unique welder identification stamps manufactured.
7)
Inject the new Quality Engineering function into the review of DR/NCR dispositions:
a)
Revice Procedure AP-VI-02, Nonconformance Control and Reporting, to include the Quality Engineering concurrence of DR and NCR dispositions prior to effecting the disposition. Procedure AP-VI-02 shall delineate the items to be evaluated as part of the Quality Engineering review.
I 8)
Increase Craf t and Quality personnel awareness of the importance of complete, accurate quality documentation:
a)
The general work instructions provided to Project personnel will be reviewed and, as appropriate, inst:
ions will be provided l
l stressing the importance of complete, accurate quality documentation.
b)
The importance of complete accurate documentation will be the topic of presentations by the Project Quality Manager and the Project
\\'
Manager to Site personnel.
Page 4 of 4
Ud
/',*
ATTACHMENT D
'f to KMLMRC B1-111 HEATING / VENTILATING / AIR CONDITIONING DUCT SUPPORT CORRECTIVE ACTION PLAN This Plan focuses on the lack of accurate installation documentation for 122 heating, ventilating, and air conditioning duct supports. Ninety-five are in the Control Room and twenty-seven are located e'lsewhere in the Control Building.
Actions taken prior to 9/3/81 include:
The documentation for the material supplied by Robert Irsay Co.
from which the hangers were fabricated has been reviewed and was found to be acceptable.
The documentation for the weld filler material on Site, which could have been used in the installation of the subject supports, has been reviewed and was found to be acceptable.
The Welder qualification records for the 620 welders who have worked on the Site since the start of construction have been reviewed, and it has been determined that 606 welders were qualified to perform the welding process required for installing the subject supports.
Twelve welders were qualified to only automatic welding techniques.
Two welders, D-328 and D-387, 5. re not qualified in any of the welding processes which would qualify them for welding on the subject supports.
The welding procedures which were available for field installation of the subject supports were verified as qualified and containing the necessary parameters and controls for making acceptable weldn.
Page 1 of 3
'o Attachment D to KMLURC 81-111 Non-Conformance Report (NCR) ISN3558M was generated documenting the indeterminate acceptability of the welds on the subject supports.
Included in the NCR is a list of the supports and detailed steps to be taken to assure that reinspection and corrective action on the subject supports is controlled.
Protective coati ~ngs (i.e. fireproofing, paint, etc.) were removed from all accessible welds to expose them for inspection. The welds were then prepared for inspection by wire brushing to remove any elements which could mask.tv3 weld.
A specific training course was developed to provide selected Inspectors with instructions relative to inspection requirements established for NCR ISN3558M.
Thirtcen inspection personnel attended the training course. Upon completion of the training course, the personnel completed both a
" closed book" written examination and a practical test using test coupons. A passing grade of 90% was required for the written exam-ination and consisted of 38 questions.
A passing grade of 100% was required for the practical test and consisted of six coupons with 39 known defects. Based on the results of the training course, eight Inspectors and two Lead Inspectors were selected to perform the inspection.
Mechanical Engineering prepared a drawing and a weld inspection sheet for each support to be inspected. Engineering, craft and quality t
i l
Page 2 of 3 l
l k
'm e
T.
.A Attachment D
,S. '
to KMLNRC 81-111 personnel were briefed on the specific requirements. The inspection activities were begun September 1, 1981 using two-man teams (i.e.
one inspecting and one recording the information).
Actions initiated since 9/3/81 include:
Inaccessible welds (i.e. behind block or sheet rock walls) vill be exposed and prepared for inspection. All field welds will be inspected.
The inspectors shall also determine that the supports are properly identified and are located per drawing dimensions.
All field welds on the 122 supports will be ground out and rewelded or will be supplemented by the addition of a new weld, using certified welders and qualified Procedures. Use of supplemental welds shall be approved by Bechtel, and shown on as-built drawings. The new welds will be inspected in accordance wid1 approved Procedures. The required documentation of the welding and inspection shall be completed.
Safety-related heating / ventilating / air conditioning duct supports, other than the 122 already discussed, will be subjected to documentation and hardware review based on a sampling plan to determine if similar problems exist.
Page 3 of 3