ML20077J470
| ML20077J470 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/22/1983 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20077J464 | List: |
| References | |
| KMLNRC-83-096, KMLNRC-83-96, NUDOCS 8308160434 | |
| Download: ML20077J470 (4) | |
Text
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KANSAS GAS AND ELECTRIC COMPANY THE ELECTnC COMPAt9Y eLENN L F3 ESTER WCE PREtsOENT-NUCLE AR July 22, 1983 Mr. W.C. Seidle, Chief 3
~
Reactor Projects Branch 2 U.S. Nuclear Regulatory Commission Region IV AI. 2 5123 L
611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 b'
KMLNRC 83-096 Re:
Docket No. STN 50-482 Subj: Response to Inspection Report STN 50-482/83-18
Dear Mr. Seidle:
This letter is written in response to your letter of June 23, 1983, which transmitted Inspection Report STN 50-482/83-18. As requested, the violation identified in the Inspection Repcrt is being addressed in four (4) parts:
a) The corrective steps which have been taken and the results achieved; b) Corrective steps which will be taken to avoid further violations; c) The date when full compliance will be achieved; and d) Response to specific questions.
Violation: Improper Substitution of Material in Safety-Related Pipe Hanger Finding:
10CFR50, Appendix B, Criterion VIII requires that, " Measures shall be established for the identification and control of materials, parts, and components, including partially fabricated assemblies. These measures shall assure that identification of the item is maintained by heat number, part number, serial number, or other appropriate means, either on the item or on records traceable to the item, as required throughout fabrication, 8308160434 030802 PDR ADOCK 05000482 G
PDR 201 N. Market - Wichita, Kansas - Mall Addrsss: RO. Box 208 I Nchita, Kansas 67201 - Telephone: Area Code (316) 261-6451
l Mr. W.C. Seidle KMLNRC 83-096 July 22, 1983 Finding (continued) :
erection, installation, and use of the item. These identification and control measures shall be designed to prevent the use of in-correct or defective material, parts, and components."
Contrary to the above, Piece 2 of Hanger BG04-CO33 was removed on March 16-17, 1981, and replaced with scrap material which had been stamped with a heat number and hanger number to duplicate the numbers on the original piece.
Response :
a) Corrective steps which have been taken and results achieved.
Suspect material (i.e., Piece 2 of support BG04-C033) was removed during the investigation and turned over to the NRC Investigator. The remainder of the support has been removed and refabricated to assure that all pieces are traceable.
b) Corrective steps which will be taken to avoid further violations.
The subject support was one (1) of 129 identified and re-inspected as part of the Corrective Action in response to the original identification of material substitutions in an allegation to the NRC in the spring of 1981 (see NRC Report No. 81-08). This reinspection included the following elements:
- 1. Verification that the welder identification was stamped on the support and that the welder identified was qualified for the weld procedure prescribed.
- 2. Verification that the material heat number was stamped on the support and that the heat number identified was traceable (i.e., a valid number in the safety-related heat log).
- 3. Identification of any weld or material defects.
Reinspection of all 129 supports has been completed and all deficiencies identified have been resolved using 16 Deficiency Reports (DR's). In addition, the foreman involved was terminated.
Mr. W.C. Seidle KMLNRC 83-096
-3 July 22, 1983 Response (continued) :
c) Date when full compliance will be achieved.
Support BG04-CO33 was refabricated and final QC installation inspection was performed on July 15, 1983.
Reinspection and any necessary rework on the 129 supports installed by the foreman in question was completed November 12, 1982.
d) Response to specific questions.
- 1. Has hanger BG04-C033 been reworxed with traceable material?
Yes. SupportBG04-C033 has been totally removed and
-refabricated to assure all pieces are traceable.
This was completed July 15, 1983.
- 2. Was hanger BG04-CO33 reinspected in the summer of 1981 following identification of another counterfeit hanger? If it was, please explainwhy its degraded condition was not ~ identified by that inspection.
Support BG04-C033 underwent the reinspection described above on April 21, 1981 (36 days after the alleged material substitution and heat number transfer took place). The reinspection checklist indicates that Piece 2 was die-stamped with 1/4" punch lettering indicating a material heat number of 170C961. This heat number appears in the safety-related heat log as acceptable for W4X13 Beam Stock, Grade A36 from Bethlehem Steel purchased on Daniel P.O. 7158-SR15007.
As a result of the heat number in question being on the steel and indicated as being acceptable in the heat log, the Inspector performing the reinspection had no reason to doubt its validity. The reinspection of this support did, however,. identify 6 weld defects wh'ch were addressed on DR ISD6646M (closed September 28, 1981).
- 3. Has KG&E ' assured that no other hangers in safety-related systems have been degraded by improper material substitution?
-1
Mr. W.C. Seidle KMLNRC 83-096 July 22, 1983 KG&E performed an extensive investigation in response to this concern when originally identified in the spring of 1981. All supports installed by the foreman in question have been reinspected and reworked when discrepancies were identified. The NRC's review of this reinspection activity was summarized in NRC Report 81-08 (Vandel and Gagliardo) dated July 21, 1981, which states in part,
. The inspections of these hangers were performed by DI QC inspectors. The inspectors were provided with special checklists to document the heat numbers of each piece (for material traceability), the welder ID numbers, and dimensions of the weld (actual and as indicated on the drawings).
"The NRC inspector's independent review essentially verified the results of the QC inspection. The differences were not significant and will be resolved in the corrective action committed to by the licensee."
" Interviews with the QC inspectors, who performed the inspections, substantiated the stated scope and depth of the inspection effort. The results of the interviews added credence to the licensee's contention that the improperly fabricated hanger was an isolated case In summary, KG&E has taken necessary corrective actions, including extensive reinspection, required rework and removal of personnel identified as directing these improper material substitutions. No subsequent allegations, interviews, or hardware and documentation examinations have identified this problem to any other supports nor implicated any other crew.
Please contact me or Mr. Otto Maynard of my staff if you have any questions concerning this response.
Yours very truly,
.(or Glenn L. Koester Vice president - Nuclear GLK:bb cc: HRoberds/WSchum
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