ML20063A108
| ML20063A108 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/16/1982 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, KMLNRC-82-236, NUDOCS 8208240196 | |
| Download: ML20063A108 (8) | |
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KANSAS GAS AND ELECTRIC COMPANY TH ELECT 2C COMPANY QLENN L MOESTER veta possios=? sauc6sse August 16, 1982 Mr. W.C. Seidle, Chief U.S. Nuclear Regulatory Commission
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Reactor Projects Branch 2
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.l Region IV i
I 611 Ryan Plaza Drive, Suite 1000 ggg Arlington, Texas 76011
't KMLNRC 82-236 Re:
Docket No. STN 50-482 Subj: Final 10CFR50.55(e) Report HVAC Duct Supports
Dear Mr. Seidle :
Attached is the final report submitted pursuant to 10CFR50.55(e) regarding documentation and installation deficiencies in the safety
- elated Heating / Ventilating / Air Conditioning duct supports.
Documentation concerning the corrective action for this matter is available for review.
If you require additional information, please contact me or Mr. Otto Maynard of my staf f.
Yours very truly,
//fff GLK:bb Attach cc: Mr. Thomas Vandel Resident NRC Inspector P.O. Box 311 Burlington, Kansas 66839 Attach 8208%401 % 3 201 N. Market - Woctura, Kansas - Mail Address: RO. Box 208 f Wchsta, Kansas 67201 - Telephone: Area Code (316) 261-6451
10 CFR50.55 (e ) FINAL REPORT Cn Heating / Ventilating / Air Conditioning Duct Supports For WOLF CREEK GENERATING STATION, UNIT NO.1 KANSAS GAS AND ELECTRIC COMPANY Augus t 16, 1982
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TABLE OF CONTENTS I.
Introduction II.
Description of Deficiency III.
Analysis of Safety Implications IV.
Corrective Action i
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' Introduction During the spring of 1981 anonymous individuals made allegations regarding improprieties in the construction, and associated documentation, of safety-related Heating / Ventilating / Air Conditioning (HVAC) ducts and duct supports installed in the Wolf Creek Generating Station.
This led to a through investigation of safety-related HVAC duct support installation and documentation by the Nuclear Regulatory Commission, Kansas Gas and Electric (KG&E) and Daniel International Corporation (DIC). KG&E is the construction permit holder and DIC is the constructor for Wolf Creek Generating Station.
The investigation of this matter revealed several discrepancies in the documentation and installation of HVAC duct supports installed during 1979 It was further determined that the discrepancies were reportable under 10CFR50.55(e).
The following sections of this report describe the deficiencies, analyze the safety implications, and state the corrective actions taken to resolve the documented discrepancies and preclude similar problems in the future.
II.
Description g Deficiency During the investigation of the installation and documentation of safety-related HVAC duct supports, several deficiencies were identified. These der-iciencies and their descriptions were as follows:
A.
Procedure relative to the installation of safety-related duct work and supports had not been followed.
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Miscellaneous Structural Steel Weld Records (MSSWR) were issued to document completion and QC inspection of attachment welds on HVAC hangers from June 25 to mid-
- August, 1979, even though the Weld Control Record (WCR)
I form was issued on July 25, 1979, by DIC Dngineering Department for use as an HVAC traveler.
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2.
DI Quality Control Procedure QCP-VIII-200, Revioicn 0, entitled
" Field Fabrication and Erection of Safety-Related Duct Work and Supports" was not issued until September 24, 1979, indicating that there was no written procedure for QC inspection from March 26, 1979, until September 24, 1979.
B.
Sufficient records relative to the installation of safety-related HVAC hangers were not maintained.
1.
Records were identified that did not furnish evidence of
. activities affecting quality in that they were fallacious. Examples of fallacious records were:
a.
Data was transferred from the MSSWR form (which documents only attachment welds) to the WCR form (which documents the installation /QC inspection of the complete hanger) using hanger blueprints to identify tho' welds on each hanger with no visual confirmation that the welds had been completed.
b.
Data was subsequently transferred from the WCR form to the Wold Control Record supplement Sheet (WCRSS), which documents each individual weld on the respective hanger, with no valid record that the information on the WCR form correctly represented the fabrication and QC approval of a completed hanger.
c.
Numerous conflicts were identified in the Control Room HVAC hangers where the welder identification numbers on the associated WCR form and/or WCRSS form did not corrrespond.
2.
'Ihe record shown below was identified that did not furnish evidence of activities affecting quality in that it was, in part, a falsified document and no QC inspection was conducted.
Wald Control Record Supplement Sheet No. H-10C, traveler for safety-related HVAC Hanger No.
R3349, did not furnish evidence of activity affecting quality in that there was:
a.
Nonexistence of a valid traveler; b.
No record of actual QC inspection of safety-related hanger No. R3349.
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C.
Adequcto meccuroo relativs to tha idIntifiestion and correction of conditions adverse to quality had not been established.
DI Deficiency Report 1 SE5455M, dispositioned on November 18, 1980, states in part, " Incorrect entries on WCRs and/or incorrect "D" stamping to be corrected under The " Action Taken"
' rection of craf t supervision.
portion of' DR 1SE5455M states, "Craf t has been retrained and welding discrepancies corrected to reflect correct "D"
stamps and weld number with corresponding traveler sheets."
Welding discrepancies had not been corrected to reflect correct "D"
stamps and weld numbers with corresponding traveler sheets in that a reexamination of certain supports, i.e.,
R3349 on June 25,1981, and R3240 on August 20, 1981, revealed that the welder "D" numbers did not correspond with the traveler sheets.
D.
Adequate measures to assure that special processes are controlled and accomplished by qualified personnel had not been established.
In particular, it was discovered that valid welder identification numbers were changed in September and October of 1979 to agree with erroneous Weld Control Records, thus eliminating their authenticity.
E.
Several welds were determined to be slightly undersized.
%e majority of these welds were considered undersized due to a slight amount of taper at the end of the weld.
We main body of tne weld was satisfactory.
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III. An91yain of,S faty Implic tionc As discussed in Section II of this report, a large number of supports were found to have documentation or installation deficiencies.
Therfore, an engineering evaluation and/or test program to determine the adequacy of each:
support was not feasible. After a thorough evaluation of this matter,.the conservative assumption was made that any of the safety-related HVAC duct supports with installation or documentation discrepancies which could not be reconciled could fail.
Therefore, it was determined that this matter is reportable under 10CFR50.55(e) because the deficiencies represent a significant breakdown in the quality assurance program and could have adversely affected the safety of operations of Wolf Creek Generating Station.
IV.
Corrective Action Several acticns have been taken to correct deficiencies associated with the safety-related HVAC duct supports.
These actions were designed to correct the originally identified deficiencies, identify and correct any additional deficiencies, and preclude similar problems in the future.
Nonconformance Report (NCR) 1SN-3558-M was generated and dispositioned to provide 100% reinspection and required rework of supports in question in accordance with Procedures QCP-VII-200 and WP-VIII-200.
These actions will ensure adequate Quality records and that welder identification on supports is authentic and agrees with the travel records. In addition, per-sonnel involved with the installation and inspection of HVAC duct supports have been and will continue to be appropriately trained in the following procedures:
WP-VIII-200, CWP-504, QCP-VII-200, QCP-VII-204, QCP VII-504, and QCP-VIII-200.
In addition several procedures have also developed or revised as part of the corrective action. Procedure WP-VIII-200 has been revised to clarify and better define support installation and documentation requirements.
Construction Procedure AP-VI-02, (4)
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"Nonconformance Control and Reporting " has been revised to include the review of all NCR/DR dispositions for adequacy by Quality Engineering.
Procedure AP-II-02 has been developed for the preparation of policy state-ements, issuance of a policy sta tement, issuance of a policy statement concerning the transfer of data, issuance of a policy statement concerning the transfer of Documentation, and development of a Quality Presentation on this subject which is presented to incoming Craf t and Quality personnel. Craft and Quality personnel already onsite have also received a presentation on this subject.
In coordination with the aforementioned corrective action, seventeen
" Program Enhancement Actiivities " were initiated to identify, correct and preclude problems with installation and documentation of safety-related HVAC duct supports.
%ese activities were described in interim report KMLNRC 82-173 dated March 11, 1982. All seventeen activities have been completed.
Within the scope of the original investigation, 122 supports were identified as having some type of documentation or installation deficiency.
All corrective action described above has now been completed and the documentation / installation of these 122 supports are in full compliance.
It should be noted that enhancement activity seventeen developed a sampling plan to review the other safety-related HVAC duct supports which wel not included in the original investigation.
Activity seventeen has been closed, however, several deficiencies were identified as a result of the sampling process.
- Werefore, 100% of the additional safety-related HVAC supports are being inspected.
Deficiencies identified on the additional supports are being documented and corrected separate from the supports included within the scope of this report.
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