ML20094F511
| ML20094F511 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/01/1984 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20094F502 | List: |
| References | |
| KMLNRC-84-084, KMLNRC-84-84, NUDOCS 8408100075 | |
| Download: ML20094F511 (5) | |
Text
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KANSAS GAS AND ELECTRIC COAtPANY CL8NN L st 0 t t ? 8 m
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Juno 1, 1984 Mr. E.ll. Johnson, Acting Chief Reactor Project 11 ranch 2
{q U.S. Nucicar Regulatory Comminaion Region IV 1,. i,
611 Ryan Plaza Drivo, Suito 1000 g-d@
Arlington, Texas 76011
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U KMLNRC 04-004
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Ron Dockot No. 50-482 Subj: Responno to Inspection Report 50-402/64-00 Doar Mr. Johnnon:
This lottor providos tho Kansan Gas and 1:1cctric Company (KG&E) runponso to your lotter of May 4,1984, which trannmittod Inspection Report STN 50-402/04-00. An requented, the violationn identified in the Inspection Report, aro being addrounod in throo parta a) Correctivo stopa which havo boon taken and the results achieved b) Correctivo ator.n which will bo taken to avoid further violations and c) The dato when fall compliance will be achioved.
VIO!ATION 4H2/0400-01:
PA!!.URI: TO PROPI:RLY REVIIM RECORDS r_i nd i n3:
Critorion V of Appendix li to 10 CPR Part 50 requiron, in part, "Activition af fecting quality.
. shall bo accomplinhed in accordanco with... Instructionn, proceduron, or drawings Paragraph 3.14 of Proceduro No. QCP-I-05, Revision 17, " Quality Proconning of Qt. Records," ntaten, in part, in rogard to the Combined Itoview Croup (CRa), " Documentation rocoived by CR0 will bo reviewed to onnuro complianco to applicablo proceduron, codon, ntandardn, and npocificationn 0400100075 040731 PDH ADUCK OD000402 0
PDH
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s Mr. E.H. Johnson KMLNRC 84-084 June 1, 1984 Finding - (continued) :
Contrary to the above, the review by CRG did not ensure compliance to applicable specifications in that a code form (NPP-1) for Spool EJ-04-S016, one of the three spools sampled, identified the piping to be Material Specification SA 312; however, the certified material test reports idantified the same piping to be SA 376.
Responses a) Corrective steps which have been taken and results achieved:
Daniel International Corporation (DIC) has written Nonconformance Report (NCR) ISN17097P to require a corrected Code Data, Report for spool EJ-044-5016 be obtained from the manufacturer. The corrected Code Data report has been obtained and placed in the file.
In the period from August 8,1983 through September 14, 1983, KG&E. Construction Quality Control reviewed 13 of 139 pipe spool document packages. The review was done in accordance with procedure KPil-504 (sampling per-MIL std. 105 D). No hardware deficiencies were detected. Although the Code Data Report for spool EJ-04-5016 was incoriact, the specified material was t
received and used. Therefore the error was administrative and did not affect hardware.
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m b) Corrective steps which will be taken to avoid further violations :
The detailed review of the CMTR in question was a " source inspection" responsibility. The Combined Review Group (CRG) verifies that the required CMTRs are received but the accuracy. of the information is reviewed by the " source inspectors". The organization responsible for the source inspection will be made aware of the discrepancy identified in this violation and directed to be more alert to administrative errors when reviewing CMTRs.
c) Date.when full compliance will be achieved:
Full compliance will be achieved by June 15, 1984.
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Mr. E.H. Johnson KMLNRC 84-084 June 1, 1984 VIOLATION 482/840R-02: FAILURE 'IO IDENTIFY NONCONFORMANCES AT TURNOVER Finding:
Criterion V of Appendix B to 10 CFR Part 50 requires, in part,
" Activities affecting quality... shall be accomplished in accordance with.
instructions, procedures, or drawings Paragraph 3.12 of procedure No. AP-XIV-01, Revision 11,
" System Turnover" states, in part, "... all open documentation items shall be listed on the Turnover Exception List prior to the system / subsystem turnover.
Contrary to the above, an open documentation item on System Discrepancy List No. EJ-151 for Spool EJ-04-S028 was found that was not listed on the Turnover Exception List prior to turnover.
Response
a) Corrective steps which have been taken and results achieved:
System Discrepancy List (SDL) No. EJ-151 has been listed on the Turnover Exception List.
b) Corrective steps which will be taken to avoid further violations :
Daniel International Corporation (DIC) will reinstruct
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SDL processors to provide SDL's upon origination to the Discipline Construction Completion Engineer for entry on the Turnover Exception List.
l' c) Date when full compliance will be achieved:
Reinstruction of SDL processors by DIC will be completed by June 29, 1984.
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VIOLATION 482/8408-03: FAILURE TO UPDATE THE SYSTEM DISCREPANCY LIST l
LOG FOLLOWING CLOSEOUT OF NONCONFORMANCES i
Finding:
l Critorion V of Appendix B to 10 CFR Part 50 requires, in part, l
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4, Mr. E.H. Johnson KMLNRC 84-084 June 1, 1984 Finding (continued) :
" Activities affecting quality.
. shall be accomplished in accordance with.
. instructions, procedures, or drawings t
Appendix V of Procedure No. AP-VI-02, Revision 21, "Nonconformance Control and Reporting" states, in part, in regard to system discrepancy lists (SDLs), "After verification of completed resolution (s) for each item delineated on the SDL.
. notify the PQSE of SDL closure in order that the SDL log will be updated accordingly."
i Contrary to the above, a review of five SDLs with completed resolution found that the SDL log was not updated accordingly.
i The SDLs in question are EJ-109, BB-019, BB-061, BBil-007 and BBil-002.
Response.
f a) Corrective steps which have been taken and results achieved:
i System Discrepancy Lists (SDLs) EJ-109, BB-019, BB-061, BBil-007'and BBil-002 have been entered in the SDL log.
i b) Corrective steps which will be taken to avoid further violations:
l Daniel International Corporation (DIC) is revising Construction Procedure AP-VI-02 to give the responsibility p
for maintaining the SDL log to the Project Quality Engineer (PGE). The procedure revision will require, that after-verification of completed resolution (s), the original SDL will be sent to the PQE for entry on the l
SDL log.
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c) Date when full compliance will be achieved:
Entry of the omitted SDLs on the SDL log has' been completed (see paragraph a of this response).
Revision of Construction Procedure AP-VI-02 by DIC (see paragraph b of this response) will be completed by July 2, 1984.
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- s-Mr. E.H. Johnson KMLNRC 84-084 June 1, 1984 Supporting documentation for the responses provided is available for review at the Wolf Creek job site. If you have any further questions concerning these responses, please contact me or Mr. Otto Maynard of my staff.
Yours very truly, M Glenn L. Koester Vice President - Nuclear GLK:bb xc: PO'Connor HBundy d