ML20072P138
| ML20072P138 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/24/1983 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20072P104 | List: |
| References | |
| KMLNRC-83-080, KMLNRC-83-80, NUDOCS 8307180278 | |
| Download: ML20072P138 (3) | |
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KANSAS GAS AND ELECTRIC COMPANY THE ELECTf%C COMPANY GLENN L MOESTER vRs Paassoreev.s vetrae e
June 24, 1983 Mr. W.C. Seidle, Chief Reactor Projects Branch 2 hhbb U.S. Nuclear Regulatory Commission lt Region IV d
611 Ryan Plaza Drive, Suite 1000 h'
Arlington, Texas 76011
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KMLNRC 83-080 Re:
Docket No. STN 50-482 Subj: Response to Inspection Report STN 50-482/83-10
Dear Mr. Seidle:
This letter is written in response to your letter of May 6,1983, which transmitted Inspection Report STN 50-482/83-10. As requested, the violation identified in the Inspection Report is being addressed in three parts:
a) The corrective steps which have been taken and the results achieved 1 b) Corrective steps which will be taken tc avoid further violations 1 and c) The date when full compliance will be achieved.
Violation Finding: Failure to Prescribe Activities Affecting Quality by Procedure 10CFR50, Appendix B, Criterion V, requires in part that activities affecting quality shall be prescribed by instructions, procedures, or drawings and shall be ac-complished in accordance with these instructions, procedures or drawings.
Paragraph 17.1.10 of the Wolf Creek Site Addendum to the Quality Assurance Programs For Design and Construction Manual states, in part, "The major contractors are 8307180278 830713 PDR ADOCK 05000482 FDR 201 N. Market -Wichita, Kansas - 9!an Address: RO. Box 208 i W1chita, Kansas 67201 - Telephone: Area Code (316) 261-6451
Mr. W.C.~ Seidle KMLNRC 83-080 June 24,1993 Finding (Continued) :
responsible to establish inspection programs which provide measures for:
. Controlled inspection procedures, instructions and/or checklists being provided and contain-ing the following.
. Accept and reject criteria.
Contrary to the above, the major contractor, Daniel International Corporation (DIC), did not provide measures for controlled inspection procedures in that DIC Procedure No. QCP-X-302, " Installation of Electrical Raceway Supports" did not contain the intermittent weld configuration accept and reject criteria as required.
Response
The NRC's Notice of Violation cites that DIC procedure QCP-X-302, " Installation of Electrical Raceway Supports" did not contain accept / reject criteria for intermittent fillet welds. QCP-X-302 is not intended to contain weld acceptance. criteria. Intermittent fillet welds are inspected under DIC procedure QCP-VII-200, " Inspect $on of Welding Process." QCP-VII-200 does contain welding accept / reject criteria.
Electrical raceway uupport welding is to be performed at Wolf Creek to the requirements of AWS Dl.1-75.
The Architect / Engineer's installation specifications and the DIC inspection procedure (QCP-VII-200) both reference the
' AWS code for intermittent fillet weld requirements.
QCP-VII-200 references the AWS code for weld acceptance criteria. However, due to code interpretation differences, electrical raceway supports were installed and quality accepted with intermittent fillet welds which did not start or terminate at the end of the support's dimensioned
- length, a) Corrective steps which have been taken and results achieved:
The Architect / Engineer performed a design review of the non-conforming supports identified'in. the Notice of Violation. (Nonconformance Report ISN9130EW), as well as those identified'on Nonconformance Raports 1SN10419EF, ISN10543EW, and ISN10350CW in dispositioning Field Change Request (FCR)' 1-0060-W.
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The review indicated that all of the affected supports were acceptable as reported. These details comprise all affected electrical supports shown on the C-0400 and C-0600 series
- drawings.
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Mr. W.C. Seidle KMLNRC 83-080 June 24, 1983 A design review of all other conditions where inter-mittent welding was specified, which may have been affected by the conditions described in the FCR, has also been completed by the Architect / Engineer. The results of this design review indicate that no safety implications exist as a result of the reported condition.
The reported e ndition does not, therefore, represent a safety conce:;n and is acceptable on a technical basis.
All intermittent fillet welding previously performed on the Wolf Creek site is acceptable with regards to weld increment.
b) Corrective steps which will be taken to avoid further violations:
The FCR was dispositioned on June 15, 1983, to require that for all future intermittmt fillet welding a weld increment shall be located at the ends of the dimensioned length. DIC personnel involved in welding and inspection of intermittent fillet welding will te informed of the disposition of the FCR so that all such welding performed after June 15, 1983, will not be quality accepted without welds on the ends of the piece or appropriate disposition by the Architect / Engineer. All affected personnel will be so informed by June 28, 1983.
c) Date when full compliance will be achieved:
Full compliance will be achieved by June 28, 1983.
KG&E Quality Assurance personnel will conduct a surveillance of intermit-tent fillet welding activities during calendar year 1983 to evaluate the effectiveness of the above corrective steps.
Supporting documentation for the responses provided above is available for review at the Wolf Creek job site. If you have any further questions concerning this response, please contact me or Mr. Otto Maynard of my
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staff.
Yours very truly, 4
% Glenn L. Koester Vice President - Nuclear GLK:bb cc: HRoberds/WSchum E
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