ML20077F895
| ML20077F895 | |
| 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 | |
| ML20077F890 | List: |
| References | |
| KMLNRC-83-080, KMLNRC-83-80, NUDOCS 8308030169 | |
| Download: ML20077F895 (3) | |
Text
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VANSAS GAS AND ELECTRIC COMPANY THE EL.ECTAC COPMANY OLENN L MOESTER w*CE Patt*0E4 r - asuCL.sae June 24, 1983 Mr. W.C. Seidle, Chief Reactor Projects Branch 2 U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 y i,,
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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; b) Corrective steps which will be taken to avoid further violations; 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 cf the Wolf Creek Site Addendum to the Quality Assurance Programs For Design and Construction Manual states, in part, "The major contractors are DFSE:iATED ORIGINAL 8308030169 830727 cutified By 88 PDR ADOCK 05000482 v
G PDR 201 N. Market - WicNta, Kansas - Mad Address:RO, Box 208 l WIcMa, Kansas 67201 - Telephone: Area Code (3*6) 261-6451
Mr. W.C. Seidle KMLNRC 83-080 June 24, 1903 l
Finding (Continued) reeponsibla to establish inspeccion programs which provide measures for:
. Controlled inspection procedures, instructions and/or checklists being provided and contain-ing the folJowing.
Accept and reject criteria.
Contrary to the above, the majer 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 tha intermittent weld configuration accept and reject criteria as required.
Response
i The NRC's Notice of Violation cites that DIC procedure QCP-X-302, " Installation of Electrical Raceway Supports" did no'c 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, " Inspection of Welding Proceas." QCP-VII-200 does contain welding accept / reject criteria.
l Electrical raceway support welding is to be performed at Wolf Creet to the requirements cf AWS Dl.1-75.
The Architect / Engineer's installation specifications and the DIC inspection procedure 'QCP-VII-200) Loth reference the i
AWS code for intermittent fillet weld requirernents.
QCP-VII-200 references the AWS ccde for weld acceptance criteria. However, due to code interpretation differences, electrical raceway supports were installed and quality accepted with intermittent fillet welds wnich did not I-start or terminate at the end of the support's dimensioned length.
a) Correciivs steps which h oe been taken and resulte achieved:
The Architect / Engineer performed a design review of the i
non-conforming supports identified in the Notice of Violation (Nonconformance Report ISN9130EW), as well as those identified cn Nonconformance Reperts 1SN10419EW, 1SN10543EW, and 1SN10350CW in dispositioning Field Change Request (FCR) 1-0060-W.
The review indicsted that all of the affected supports were acceptable as reported. These details coteprise 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 24i 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 air,o 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 condition does not, therefore, represent a safety concern and is acceptable on a technical basis.
All intermittent fillet welding previca:1y 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 intermitixnt 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 be informed of the disposition of the FCR so that all such welding performed after June 15, 1983, will nc be quality accepted without welds on the ends of the piece or appropriate dispositien 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 rersonnel will conduct a surveillance of intermit-tent fillet welding activities during calendar year 1983 to evaluate the effectiveness of the above corrective steps.
Supporting documer.tation 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 staff.
Yours very truly, d2
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w W Glenn L. Koester Vice President - Nuclear GLK:bb cc: HRoberds/WSchum