ML20101C989
| ML20101C989 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/21/1983 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20101C978 | List: |
| References | |
| FOIA-84-244, FOIA-84-292 EA-83-018, EA-83-18, KLMNRC-83-045, KLMNRC-83-45, NUDOCS 8412210266 | |
| Download: ML20101C989 (29) | |
Text
{{#Wiki_filter:Y. %.Aa.h' n. i -{ f xansas cas ano stecraic courany Ta*E ELECT 8hC CCv8'ANY C L E se se L eOES7ER veCJ pos siosas t. a.uChaam April 21, 1983 Mr. Richard C. DeYoung, Director / Office of Inspection and Enforcement /' ~ U.S. Nuclear Regulatory Comr.J,ssion Washington, D.C. 20555 / 'L. Qs -x N N'N KMLNRC 83-045 Re Docket No. STN 50-482 Subj: Request for Mitigation of Civil Penalty and Response to Notice of Violation EA 83-18
Dear Mr. DeYoung:
By letter dated March 23, 1983, Mr. John T. Collins, Regional Adninistrator of Region IV, transmitted to Kansas Gas and Electric Company a Notice of Violation and Proposed Imposition of Civil Penalty. Two violations were identified. Both involved deficiencies that were detected by KG&E during a Quality Assurance Surveillance of the Borated Refueling Water Storage System. That problems existed in the process of turning over this system to our startup organization and that discrepancies existed in the " turnover exception list" for this system is not being disputed. However, what is important is that KG&E's Quality Assurance system found these problems and that KG&E furnished a copy of the surveillance report to the NRC's resident inspector the same day that the report was issued. KG&E has also taken prompt and vigorous actions to correct the problems which our QA program identified and to avoid future problems concerning proper clas-sification of reportable events under 10CFR50.55(e). We hope that as a result of your consideration of these facts, set forth in more detail in Attachment A to this letter, you will mitigate the civil penalty proposed on March 23, 1983. Pursuant to 10CFR2.205, we formally request such mitigation. Also provided as Attachment B to this letter is KG&E's response to the Notice of Vi.olation, as required by 10CFR2.201. We appreciate your consideration of these matters and would be pleased to r 8412210266 B40605 PDR FOIA BRDSEUS64-244 PDR \\ ~ 201 N. Market ~ Wictuta Kansa's - Mail Address: RO. Box 208 I w1chsta. Kansas 67201 - Telephone: Area Coce (316) 2616451
~ m +7 Mr. Richard C. DeYoung KMLNRC 83-045 April 21, 1983 7 discuss them in more detail with you and your staff. 4 Yours very truly, Y W Glenn L. Koester Vice President - Nuclear i GLK:bb Attachment A: Request for Mitigation of Proposed Civil Penalty Attachment B: Response to Notice of Violacion Attachment C: Letter of 3/2/83 from GLKoester, KG&E, to JTCollins, NRC Region IV 103 i CO? cc: J'ICollins, Region IV, w/a HRoberds/WSchum, w/a m e =
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- s CATH OF AFFIRMATION STATE OF KANSAS
) ) SS: COUNTY OF SEDGWICK ) I, Glenn L. Koester, of lawful age, being duly sworn upon oath, do depose, state and affirm that I am Vice President - Nucicar of Kansas Gas and Electric Company, Wichita, Kansas, that I have siJned the foregoing letter of transmittal, know the contents thereof, and tnat all statements contained therein are true. KANSAS GAS AND ELECTRIC COMPANY go:/ f it.//, By ,3 y Glenn L.:Koester ^~ Vice President - Nuclear W.B. Walker, Secretary STATE OF KANSAS ) ) SS: COUNTY OF SEDGWICK ) BE IT REMEMBERED that on this 21st day of April, 1983 , before me, Evelyn L. Fry, a Notary, personally appeared Glenn L. Koester, Vice P:.esident - Nuclear of Kansas Gas and Electric Company, Wichita, Kansas, who is personally Pnown to me and who executed the foregoing instrument, and he duly acknowledged the execution of the same for and on behalf of i and as the act and deed of said corporation. IN WITNESS WHEREOF, I have hereunto set my hand and affixed my seal the ,,,,,,,,,date and year above written. Is ', __(velyn /. Fry, Nota [ry dll 0-l j 4 \\ '.f. u a v.o. 15, 1984. \\ ., a ' f* Q 9E y. tommission expires on August M
o. 1 1 v ATTACHMENT A To 10iLNRC 83-045 REQUEST FOR MITIGATION OF PROPOSED CIVIL PENALTY s /\\ / .~ . '.'N i N. y N hh p. .gx /p Q Of r.
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~ y Attachment A 6. REQUEST FOR MITIGATION OF PROPOSED CIVIL PENALTY F ~ .On March 23, 1983, the - Regional Administrator of. Region IV proposed the assessment of a civil penalty of $40,000 because " Kansas Gas and Electric Company f ailed to adequately contro1' activities affecting the quality of safety-related work." The specific allegation was that The Borated Refueling Water. Storage System and the Auxiliary Feedwater System were turned over from the construction contractor to the KG&E startup' organization on. October 28, 1982, and November 23, 1982, respectively following final quality assurance -checks with quality documentation and hardware dis-crepancies which were not on the turnover exception list. The. violation was categorized as a Severity Level III under 10CFR2, Appendix C, Supplement II. In addition to this violation, the NRC > notified - K0&E of a violation (with no' civil penalty proposed) for KG&E's failure to notify the Regional Office pursuant to 10CFR50.55(e) of the deficiencies noted in the system turnover pq'actices within 24 hours. Pursuant to 10CFR2.205(b) and Appendix C to 10CFR2, KG&E hereby requests mitigation of the proposed civil penalty. An analysis of the factors set forth in Section IV.B of Appendix C demonstrates that mitigation is appropriate in this case. I. PROMPT NOTIFICATION AND REPORTING The problems which underlie the two violations relate to hardware and doc-umentation discrepancies in the Borated Refueling Water Storage System and the Auxiliary Feedwater System-after these systems were turned over by the construction contractor to KGSE's Startup organization. The problems were first identified by KG&E's Quality Assurance organization when it issued a Surveillance Report, "BN01 System Walkdown", on January 13, 1983. The NRC's Resident Reactor Inspector, Mr.-W. S. Schum, received a copy of the Surveil-lance Report the sarae day. Indeed, the Report was providad even before the . organizations affected in the Report had been given the opportunity to address the Report's findings. The NRC was therefore promptly notified of the Surveillance Report findings. ~In accordance with KG&E's procedures, KG&E evaluated the Surveillance Report to determine whether it should be reported pursuant to 10CFR50.55(e). The ' initial evaluation, comp 1: ted on January 14, 1983, concluded that nons of the deficiencies identified in the Surveillance Report met the. criteria of 10CFR50.55(e). That is, no deficiencies in the design or construction were found which: 1 J
m c 7 Attachment A 1. Would have adversely affected the safety of Wolf Creek operation if gone uncorrected, and 2. Represented either A significant QA breakdown, a. b. Significant design deficiency, c. Significant construction deficiency or damage, or d. Significant deviation from performance specifications. Indeed, KG&E's evaluation to date of the findings in the Surveillance Report have identified no deficiency in design or construction which meets the reporting requirements of 10CFR50.55(e). Nonetheless, after the completion of the 10CFR50.55(e) evaluation on Jan-uary 14, 1983, discussions on the reportability of the findings of the Surveillance Report took place between KG&E, the Resident Inspector and Region IV. As a result of these discussions, KG&E reported the Surveillance Report findings as a potential 10CFR50.55(e) item on January 21, 1983. Notwithstanding the question of whether the f adings were properly reported, a matter discussed at greater length in the Response to the Notice of Viola-tion, there can be no question that the NRC was promptly notified of the existence of the Surveillance Report and its contents. Thic Report appears to be the primary basis for the Notice of Violation. The Raport was initiated and completed within a short time following turnover of the system especially considering the overall state of plant completion. KG&E respectfully submits that it has met the criteria of reduction of 50% of the base civil penalty for prompt identification and reporting. II. CORRECTIVE ACTION TO PREVENT RECURREMCE KG&E's corrective actions are set forth in its March 2,1983 letter to Mr. John T. Collins, Regional Administrator. In his March 10, 1983 letter to KG&E, Mr. Collins stated that "(t)he objectives and corrective actions identified in your letter (of March 2,1983) appear to be appropriate." The Surveillance Report was issued on January 13, 1983. KG&E recognized the importance of its findings and on the same day -- January 13 -- KG&E established a Quality Document Review Task Force to investigate the con-structor's quality documentation preparation and review process. 2
Attrchment A The objective of the Task Force was to make recommendations to ensure that the constructor had mechanisms which would properly document all unresolved quality discrepancies at the time of system turnover. The Task Force was composed of 12 members from KG&E Construction, KG&E Quality,- KG&E Startup, Daniel Corporate and Daniel Quality organizations. The members of the Task Force were senior level personnel each with an excellent knowledge of the requirements of the quality record review program. The Task Force commenced work on January 20, 1983, and was chartered to complete its evaluations within 30 days. The Task Force's conclusions and recommendations were reviewed internally with the constructor on February 16, 1983. The Task Force report was formally issued on February 24, 1983. The Task Force made 73 recommendations, all of which are being given full consideration. However, KG&E considered that twenty of the recommendations were of sufficient imoortance that their implementation was initiated without even awaiting issuance of the Task Force's report. ? By April 14, 1983, all twenty of these recommendations had been imple-mented. These recommendations are described in Table 1. 1 At the February 18, 1983 enforcement meeting between Region IV and KG&E, KG&E described (1) several ongoing actions to correct the deficiencies identified by the Surveillance Report and the Task Force, (2) the KG&E l surveillance of three previously turned over safety-related electrical systems which commenced on January 31,1983, and (3) the KG&E effort, completed on January' 31, 1983, to reverify the hanger status of all safety-related piping systems and subsystems which had already been turned over. Immediately after the February 18 meeting, KG&E decided to issue a self-l imposed stop work for the turnover of safety-related systems. On February 21, 1983, the next work day, the stop work on turnover was formalized and put in place by KG&E. KG&E's corrective action program was described in its March 2,1983 letter to Region IV. The program has these six major elements: 1. Self-Imposed Stop Work on Turnover of Safety-Related Systems; 2. Improved Constructor Activities; l 3. Task Force on Quality Documents: 4. Expanded Pre-Turnover Verification: 5. Reverification of Systems Already Turned Over; and 6. An Increased Quality Emphasis. The near-term actions of this comprehensive program are now nearing com-pletion and a release to begin turnover again is expected later in April 1983. The long-term corrective actions are planned to be completed by October 1, 1983. 3
Atttchment A KG&E respectfully submits that it has met the criteria of reduction cf 50% of the base civil penalty for corrective action to prevent recurrence. III. EUFORCEMENT HISTORY KG&E has had, we believe, a very favorable enforcement history. This is reflected in the NRC's most recent Systematic Assessment of Licencee PorfOr=ance (SALP) Board Report of the Wolf Creek Generating Station. Two very important functional areas evaluated (Quality Assurance Program and Management Control) were considered to be Category 1 areas. Category 1 was defined in the report as Category 1 Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or con-struction is being achieved. The report provided the following analyses in support of the Category 1 classification: Management Control Several times during this report, management activity has been considered to be a significant contributing factor toward achieving resolution of identified problem areas as well as having placed heavy emphasis on quality and safety in both the resolution of problems and the conduct of construction activities.... Improvement in the overall SALP appraisal for the current period as compared to the 1981 SALP appraisal is, in large part, attributed to that management effort and attitude. Intimate involvement with site activities and problems, by the licensee management, is very evident. Furthermore, the licensee management has demonstrated a willingness and desire to meet with NRC regional super-vision in an ef fort to inform and provide a candid discussion forum. The licensee pursues a contiauing effort to reduce enforcement history, to provide additional staffing and/ or organization changes when the needs dictate and to provide training perceived to be necessary for all con-struction activity. 4
kk l i Attrchment A -){ \\ Quality Assurance Program The 1981 SALP Report '(STN 50-482/81-21) stated in the ~ conclusion on page 6 that " Quality Assurance was heavily influenced.by investigation results that indicated a breakdown of Quality Assurance program control." H During this assessment period an NRC special team inspec-l tion was conducted during the week of ' September 28, 1981, covering Quality Assurance program' control on site. Although, _ two unresolved matters were identified, no ' real concerns were identified as a result of this inspection. The licensee Quality Assurance organization, however, was modified during the assessment period to add a surveillance group to the on-site staff. This group provides construc-tion activities monitoring and surveillance as well as monitoring of tests and startup and operations activities. e Early identification of problem areas in construction activities and prompt. resolution of the concerns has resulted. The problems in the turnover process were identified as a direct result of the activities conducted by the KG&E Quality Assurance Surveillance section and the prompt extensive corrective actions were implemented at the direction of KG&E management. Therefore, these two functional areas performed effectively in identifying a concern and implementing corrective action. Furthermore, during the appraisal period for the latest SALP Board Report of Wolf Creek the NRC identified no major problems and only three Severity l Level IV violations. Under " Inspection Activities" on page 12 of the report the following analysis was provided: During August 1, 1981, to July 31, 1982, appraisal l period, a total fo 1,141 inspection hours were performed-l on inspection and investigations as follows: (1) eight l periodic inspections were reported by the assigned resident l reactor inspectors (2) eight on-site inspections were l conducted and reported by regional inspectors; and (3) a major team inspection was conducted during the week begin-r I ning September 28, 1981, covering Quality Assurance program control. No major problems were identified. Three Severity Level IV violations were identified during the ( -assessment pericd. l l Further evidence of favorable enforcement history is the fac: that prior to the March 23, 1983 proposed civil penalty, no civil penalties have been proposed against the Wolf Creek project. 5 l
Attachment A n IV. PRIOR NOTICE OF SIMILAR EVENTS KG&E had no prior notice of the types of croblems hichlichted by the l Surveillance Report. Indeed, the surveillance was undertaken, at least in part, to determine whether problems did in fact exist. At an October 14, 1982 meeting between KG&E and NRC Staff to discuss the SALP Board Report, the NRC noted that. other projects had problems with system turnovers in that the startup organizations typically found more deficiencies than the con-structors. As a result of this information and because BN was the first major safety-related system with most welding to ASME requirements to be turned over, KG&E had the surveillance performed. KG&E was alerted to the potential for problems in this area, promptly looked for them, and found them. This history clearly supports mitigation. V. MULTIPLE OCCURRENCES This factor only applies "where the NRC identifies the viclation or where the violation is associated with a "self-disclosing incident." Neither of these are present here. VI. OTHER CONSIDERATIONS A. Severity Level ( KG&E recognizes that a substantial amount of judgment goes into the NRC's choice of a Severity Level when it identifies a violation. In this case, we believe that the choice of Severity Level III is at least subject to question. Appendix C to 10CFR2 defines a Severity III violation as a "significant violation" involving 1. A deficiency in a licensee quality assurance program for construction related to a single work activity (e.g., structural, piping, electrical or foundations). Such significant deficiency normally involves the licensee's failure to conduct adequate audits or to take prompt corrective action on the basis of such audits, and normally involves multiple examples L of deficient construction or construction of unknown quality due to inadequate program implementation; 2. Failure to confirm the design safety requirements of a structure or system as a result of inadequate preoperational test program implementations or 3. Failure to make a required 10CFR50.55(e) report. 6
Attrchment A Neither paragraphs 2 or 3 are applicable in our judgment. Nor would Paragraph 1 seem to apply in this case since the charged violation does not involve KG&E's " failure to ' conduct adequate audits", nor a failure to "take prompt corrective action", nor " multiple examples of deficient construction or con-struction of unknown quality." B. KG&E Organization The allocation of responsibilities at Wolf Creek between the Construction, Startup and Operations organizations differs from that at many other nuclear construction prcjects. KG&E decided early in the project to per-form many post-construction activities usually assumed by the constructor to allow plant operators to become more proficient in the operation of plant equipment through earlier exposure to the equipment. As a result of this arrangement, systems are turned over from the constructor to KG&E at an earlier state than may be experienced on other projects. Functions such as the flushing and hydrostatic testing of piping systems by KG&E can occur with many exceptions on ' he turnover exception list. Turnover can occur t with many unresolved items. Resolution of these items can occur in parallel with initial system testing. VII. CONCLUSION The NRC's General Policy and Procedure for Enforcement Actions, Appendix C to 10CFR2, puts great emphasis on self-detection, self-correcting, and prompt notification of the NRC. The General Policy goes so far as to indicate that no penalty may be assessed where the licensee has responded appropriately. NRC attaches great importance to comprehensive licensee programs for detection, correction, and reporting of problems that may constitute, or lead to, violation of regulatory requirements. This is emphasized by giving credit for effective licensee audit programs when. licensees find, correct, and report problems expeditiously and effectively. To encourage licensee self-identification and correction of violations and to avoid potential con-cealment of problems of safety significance, application of the adjustment factors set forth below may result in no civil penalty being assessed for violations which are identified, reported (if required), and effectively corrected by the licensee, provided that such violations were not disclosed as a result of overexposure or un-planned releaaes of radioactivity or other specific, self-disclosing incidents. KG&E respectfully submits that its actions fall within the conduct described in this passage. 7
1. 'f *' ' Atttchment A 'On October 14, 1982, at a meeting on the SALP Board Report, NRC alerted ) KG&E to the potential for problems'in the system turnover area. KGGE promptly followed up on the NRC's suggestion, and conducted a surveillance of.the first appropriate system subsequently turned over. The Surveillance Report which resulted.became the basis for the Notice of Violation. This is not to claim that no problems existed.. Problems did exist in the turnover process and discrepancies did exist in the " turnover exception list" for the BN system. However, KG&E detected the problems itself. It undertook major corrective actions itself. It informed the NRC promptly of the problems by supplying the Resident Inspector with the Surveillance . Report itself. The honest differences of interpretation of 10CFR50.55(e) should not cloud the fact that NRC was promptly notified of the findings. Based on all of the above, Kansas Gas and Electric Company respectfully requests.that the NRC mitigate the proposed civil penalty. O =* 8
e TAh!.E 1 Conclusions and Recommendations Requiring Immediate Action Item 5 Conc 1usion Hecommendation Pipe and Welding Records 1 The training given to the traveler preparation A training outline should be prepared for clerks consists of informal on-the-job training, the training of piping and hanger traveler The scope, duration and amount of training is preparation clerks to assure consistency determined by the trainer assigned to the of training, resgensibility for training the individual. It was noted, however, that the clerks interviewed had adequate knowledge for the performunce of their jobs. e 2 Traveler pseparation clerks have individual Consolidate and control preparation aids preparation osds which consist of requiresnents and provide each clerk with a comiplete set. extracted from various specifications, codes, Develop new aids as required to enhance procedures and s.emoranda. These preparation traveler preparation and review. aids vary f rom one clerk to another and could result in non-uniform traveler preparation. 7 The QDS technicians have established procedural All instructions that provide direction ta guidelines that are worked to,.but there are a the technical functions of the review should number of instructions tlwt are provided by be proceduralized or some other aneans of memorandam and verbal instruction that are positive control used to assure all techni-noted by the technician, cians have the same instsuctions. This control is presently in the makisig. 9 There are no-instructions for routing of the The routing should be speci fied by Procedure Discrepancy 1.ist after issuance to the Piping QCP-I-5. The type af review and basis of Completion Group for resolution. The current acceptance by QE of the Piping Completion routing of this document after issuance to Group's disposition, and Quality Inspection the Piping Completion Group or QI Group is Group disposition, should be specified by the (1) back to QDS, (2) review and acceptance by grocedure. The review presently being per-technician identifying discrepancy,-(3) review fornied by the QuS Technician should be and acceptance by QE and (4) ODS file. stopped, and the procedure revised accordingly. s
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TAl1IE 1 (Continued) s. Item 8 Conclusion Recosasnenda t iosa 13 The timing for the walkdown is not tied Pre-turnover piping hanger walkdown six>uld directly to any activity or completion statina be scheduled to take place at an optimum that would key these walkdown groups on when time, taking into consideration a naudier of to do the walkdown. Construction performed factors ~ including: percent. of cosapletion after walkdown is not covered on walkdown. of subscope ant; Category'I exception items, size of systesa, nd turnover schedule. Pre-ferably, the walktw n.would take place as near as possible to cosapletion of sulascope and Category I exception items. The status of construction at time of walkdown should be retrievable so that the N-5 walkdown would not have to duplicate the pre-turnover walk-down. The timing for walkdown should be scheduled with input from the Tursu>ver Coordinator (see Recomn.endation No. 1). Mechanical Diuipnent Installation 1 At present no training program exists for the Establish a training program for the persosmol Quality Services group technician who reviews involved with the review of mechanical install-the mechanical installation traveler packages. ation documentation. I'ormal training program is being developed. 2 No checklist exists for the Quality Services Provide a detailed checklist. Checklist is group technician to review the mechanical being developed. installation travelers. Dpaipnesit Maintenance 1 Hevisions to lett's are keyed to vendor manual To preclude possible oversight and to take revisions although this is not proceduralized. credit for an existing process, Win-I-01 should be revised to require review of vendor punual and specification revisions when issued for lossible HMI ulxlate.
table 1 (Continued) l ~ Item 8 Conc 1usIon Recommeralation 3 The "pendir.g file" system for tracking reject WP-I-01 needs to be revised to formalize tlIe. maintenance activities appears to tuve potential notification method, reference the NCN' for slippage of problem correction or inapprop-procedure and provide guidelines for NCh riate resolution. Notification methods are issuance, and clarify the satisfactory com-i informul. These are no guidelines for issuing pletion or closing of pending activities. l NCR's or definition for satisfactorily completing or closing pending activities. l 6 Past documentation discrepancy resolution The discreiuncy resolution process should be associated with turnover review through CAH IGOOll, revised to increase A/E, vendor, and Quality. has minimal A/E and vendor involvement and no Engineering involvement. This needs to be Quality Engineering involvement. There is concern factored into the staf fing level evaluation. that resolutions of discrepancies as cosmetic may actually tuve lurdware impact. 10 Maintenance record transmittals included as part When equianent numbers ar" not identified on t of the turnover package records sometimes do not . maintenance recond transmittals, an equipment list equi eent numbers, list needs to be attached. The turnover t procedure should be revised accordingly. FJ Electrical Records 6 The QOS personnel interviewed, expressed concern The training prmjram associated with QDS l because of the discontinuation of the intensive personnel should be monitored to insure Llut training psogram. During the task force it was an adequate prmJram is in place. learned that this training would be started again soon. H Items are 1,eing turned over to ICG&E by component The Project Quality Engineer should review release without a coa.plete documentation review, procedure AP-XIV-02 and revise the " General" contrary to' procedure AP-XIV-02, paragraph 3.2.3. section to reflect the procedure's sequirenents. There apgears to be a conflict between paragraphs 3.2.3 and 3.4.1 regarding the extent of the documentation review associated with component
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TAbl.E I (Continued) 2 Item 3 Conc 1 usion Recouumenda t ion 9 4 Procusement Records S There is anot a central or coanplete list available There needs to be a list developed and muin-that identifies all MkR packages perta.ining to a tained by the QDS group that identifies all given turssover system. MkR's per taining to a given systesa. This list could be kept in a segurate file or in the turnover package itself. 6 The decision that the DIC QDS review of MHH A final decision should be made by KG&E packages where the hechtel G321D form is used management. concerning the type of review ter-be only for the veritying that the dacumentatiori . formed on MHH documentation packages where identified on the G321D as sent is still question-the Bechtel G321D form is used. able based on continuing discussions with QA. KG&E Records Review 4 There is an inconsistency between planned practices Clunge of KG&E Procedure KI-11-502.1 to and procedural requirements in the area of quality reflect planned practice. Quanti ty the suuuber e" document luckage acceptance by the KG&E Construction (percentage wise) of hardware and paperwork Completion Digineer. The procedure as presently deficiencies that can be identified by the written does not differentiate between a hardware KG&E Construction Completion Engineer betore ^ deficiency and a paperwrk deficiency. Presently, an additional los saanple is required, only one lurdware or paperwork deficiency should trigger another los sample. 10 The KG&E Operations Maintenance review and The present practices should be proceduralized approval of maintenance records for turnover is to assure consistency of application and assure an informul review. 14o procedural requireux:nts prompt closure of deficiencies. exist to detine how discrepancies and or acceptance is documented and how discrepancies are tracked to closure. 12 Startup is not determining that appropriate KG&E evaluate present practices against FSAR documentation is available at turnover but is commitments and resolve any deviation. relying on reviews being performed by KG&E Construction Completion. This appears to con-f1ict with FSAR comunitments. I i
ATTACHMENT B 'Ib IOfLNRC 83-045 PESPONSE 'IO NOTICE OF VIOLATION ) i \\ ..e ~ l ,w. I , j', T f i [J i \\ j sy .v ~.... / \\ April 21, 1983
l .s Att chment B RESPONSE TO NOTICE OF VIOLATION PURSUANT TO 10CFR2.201(b) The Notice of Violation and Proposed Imposition of Civil Penalty, dated March 23, 1983, requires that Kansas Gas and Electric Company pursuant to 10CFR2.201(b) submit a written statement or explanation including for each of the two charged violations the following five items. 1. Admission or denial of the alleged violation; 2. The reasons for the violation if admitted; 3 The corrective steps which have been taken and the results achieved; i 4. The corrective steps which will be taken to avoid further violations; and l 5. The date when full compliance will be achieved. l In addition, the March 23, 1983, letter from Mr. John T. Collins, Regional Administrator of Region IV which transmitted the Morice of Violation requested that KG&E's response j should address actions planned or taken which would ensure that work completed prior to the identification of this breakdown was properly accomplished. This should include a complete review of safety-related systems which have been turned over from construction to startup. These actions should include verification of as-built plant configuration and review of related quality documentation. Your response should also address measures taken or planned to ensure that your quality assurance procedures are adequate and that as-built verification requirements are clearly stated. Our response first addresses each of the two charged violations and then responds to the matters raised in Mr. Collins' letter. I. VIOLATION ASSESSED CIVIL PENALTY The first violaticn charged by the NRC states: 10CFR50 Appendix B, Criterion II, required that, "The quality assurance program shall provide control over activities affecting the quality of the identified structures, systems, and components to an extent consistent with their importance to safety. Activities affecting quality shall be accomplished under suitably controlled conditions." l l 1 L.
7_ ]< c Atttch3:nt B ' Contrary to the above, the Kansas Gas and Electric Company failed to adequately control activities affecting the _ quality of safety-related work. Specifically, the Borated Refueling Water Storage System and the Auxiliary-Feedwater System were i turned over from the construction contractor to the KG&E Startup organization on October 28, 1982, and November 23,'1982, respectively, following H final quality. assurance checks with quality documentation'and hardware discrepancies which were not listed on the turnover exception-list. A. Admission or Denial The Borated Refueling Water Storage System and the' Auxiliary Feedwater j System were turned over by the constructor to KG&E with documentation l and hardware discrepancies which were not listed on the turnover exception list. l B. Reasons for Violation The constructor's quality review process was not ef fectively identifying all exceptions for the turnover exception list. System walkdowns were not effective in verifying the accuracy of the turnover-exceotion list. C. Corrective Steps Taken KG&E's corrective actions are set forth in its March 2, 1983, letter. I to Mr. John T. Collins, Regional Administrator. Those corrective actions which have been completed are: 1. Self-Imposed Stop Work on Turnover of Safety-Related l Systems ' Complete the implementation of the Daniel procedural, training, and organizational changes and the key recommendations of the Task Force on quality documentation - Complete. l
- Establish a schedule for the reverification of safety-related systems already turned over - Complete.
- Issue a letter to all Wolf' Creek personnel and conduct follow-up quality emphasis meetings by senior management personnel - Complete.
I 2 ?
7 Attcchment B
- Establish a schedul<a for completion of the Daniel and KG&E Management assessment audits - Complete.
" Implement the revised 10CFR50.55(e) policy - Complete. 2. Improved Constructor Activities 'Proceduralization of several processes and modification of procedures to eliminate inconsistencies - Complete. ' Additional training for personnel involved with system turnover inspection and documentation - Complete. ' Reemphasis through meetings and training sessions of the importance of craft, engineering, and inspection personnel to produce a quality product - Cc=plete. ' Implementation of organizational and personnel changes that should improve quality - Complete. 3 Task Force on Quality Documents 'On January 13, 1983, KG&E appointed a Quality Document Review Task Force to investigate the constructor's quality documentation preparation and review process. The objective of the Task Force was to make recommendations to ensure that the constructor had mechanis m to properly document all unresolved quality discrepancies at the time of system turnover. The Task Force report was formally issued on February 24, 1983. Twenty of the recommendations were of sufficient importance that thcir implementation was initiated without awaiting issuance of the Task Force report. These items are described in Table 1 of Attachment A - Complete. 4. An Increased Quality Emphasis ' Meetings for, and a letter to, all 'dolf Creek personnel will emphasize the importance of achieving quality objectives and the dedication of both KG&E and Daniel to quality work - Complete. 'An individual from SNUPPS Staff has been assigned to assist the Vice President - Nuclear in ensuring that the entire action plan is implemented - Complete.
- The KG&E policy for reporting 10CFR50.55(e) deficiencies will be revised to clarify responsibilities - Complete.
D. Corrective Steps to be Taken The KG&E corrective actiens net yet complete on the balance of those actions described in the March 2, 1983, letter to Mr. John T. Collins, Regional Administrator. Specifically, these actions are: a
m Attachm:nt B 1. Self-Imposed Stop Work on Turnover of Safety-Related Systems i ' Complete the revised turnover and verification process on a trial basis for a safety-related system. ' Complete the BN01 Surveillance Report evaluation and implement corrective action. 2. Expanded Pre-turnover Verification 1 To assure that KG&E obtains an accurate status of systems to be turned over, an expanded pre-turnover verification effort will be implemented as follows: ' Teams of KG&E Construction and Startup personnel will conduct a complete walkdown of all future safety-related systems. These complete walkdowns will continue until we have enough confidence that reduced verifications will be satisfactory. Documentation review will be expanded to include additional detailed review in those areas where documentation deficiencies have been experienced.
- As a tool to monitor the effectiveness of the Daniel and KG&E turnover verifications and reviews, KG&E Quality Assurance will perform a surveillance of each safety-related system after the formal system turnover.
3 Reverification of Systems Already Turned Over
- Several safety-related systems have been turned over from Construction to KG8E Startup.
For these systems or portions of systems which are safety-related KG&E Construction and Startup personnel will perform complete system walkdowns and documentation reviews. In addition, KG&E Quality Assurance will perform a surveillance of each system after the joint Construction-Startup walkdown is complete. 4. An Increased Quality Emphasis 'An~ evaluation of the BN01 Surveillance Report which first pointed out the turnover process deficiencies 'is in process. Cause and corrective actions to prevent recurrence will be addressed in the evaluation. 'A canagement assessment au'dit by-an outside firm will be performed of both the Daniel Quality and the KG&E Quality Assurance organizations. This audit is intended to give KG&E additional confidence in the Wolf Creek quality programs and to seek areas of possible enhancements. E. Date for Full Comoliance Tha majority of_the corrective actions have already been completed. .Mowever, several months will be required to complete all the actions 7 4 i i
~ ' .Attechment B identified. Full compliance will be achieved by October 1, 1983 II. VIOLATION NOT ASSESSED A CIVIL PENALTY The second violation charged by the NRC states: 10CFR50.55(e) requires that the holder of a construction permit shall notify the Commicsion of each deficiency found in design and con-struction which, if uncorrected, could adversely affect the safety of plant operations. The regulation further requires that the holder of the construction permit shall notify ~the appropriate NRC Regional Office within 24 hours after the deficiency was found. Contrary to this requirement, Kansas Gas and Electric failed to provide notification within 24 hours of the deficiencies noted in the system turnover practices that were discovered during
- Quality Assurance Audit completed on January 13, 1983 Preliminary notificatien to the Regional Office was not provided until January 21, 1983 A.
Admission or Denial KG&E did not report the Quality Assurance Surveillance Report findings pursuant to 10CFR50.55(e) within the time period set by that regulation. B. Reason for Violation In accordance with KG&E's procedures, the Surveillance Report for the Borated Refueling Water Storage System was reviewed to determine whether any of the deficiencies noted in the report met the reporting criteria of 10CFR50.55(e). That review, completed on January 14',
- 1983, concluded that none of the deficiencies in the report met the tests set forth in 50.55(e).
As a result of subsequent discussions between KG&E, the NRC Resident Inspector and Region IV, KG&E cn January 21,--1983, reported the Surveillance Report findings as a potential 50.55(e) item. C. Corrective Steps Taken KG&E has issued a new policy for the reporting of 10CFR50.55(e) deficiencies.which clarifies responsibilities. A significant aspect of the new policy is the addition of an independent review by KG&E's Safety Engineering Section of potentially significant deficiencies which have been evaluated as "not reportable". This has resulted in a more conservative approach in determining the reportability of identified deficiencies, i 5 J
' * * ' f( Attachment.B KG&E had a meeting with NRC Revion IV representatives on April 4, 1983, to discuss interpretation of. reporting requirements under 10CFR50.55(e). The meeting included discussions of several questions concerning general interpretation of the regulation as well as specific examples to provide a better understanding of the NRC's interpretation of the regulations. Region'IV also provided copies of the guidance they use in evaluating reportability in order to give KG&E additional information concerning the NRC's interpretation of tha regulations. D. Corrective Steps to be Taken Not applicable. E. Date for Full Comoliance i Full compliance was achieved on April 4, 1983. ) III. PROPER ACCOMPLISHMENT OF PRIOR WORK l The March 23, 1983 letter from John T. Collins, Regional Administrator, Region IV, requested that KG&E's response to the Notice of Violation address actions which are planned or taken to ensure that work completed prior to the Surveillonce Report was properly accomplished. Prior to the issuance of the Surveillance Report, several safety-related systems had been turned over by the Construction Organization to the KG&E startup organization. As discussed in Section II.D.3 above, KG&E construction and startup personnel will perform complete system walkdowns and documentation reviews for each l system or portion of a system which is safety-related and had already undergone l formal turnover. In addition, KG&E Cuality Assurance will perform a surveillance of each system after the joint construction-startup walkdown is complete. IV. QUALITY ASSURANCE PROCEDURES I l The March 23, 1983, letter also requested that KG&E address the measures taken or planned to ensure that qualit.y assurance procedures are adequate and that as-built verification requirements are clearly stated. The entire program described in this Attachment was developed with the intent to establish or reverify that measures were in place ~or would be developed to-I ensure that quality assurance procedures are adequate and that as-built verification requirements are clearly stated. O 6 w
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o 1 APPENDIX EVALUATION AND CONCLUSION -For the violation and associated civil penalty identified in the Notice of Violation and Proposed Imposition of Civil Penalty for Kansas Gas and Electric Company (KG&E), dated March 23, 1983, the original violation is restated, the i licensee's response, dated April 21, 1983, is summarized and the NRC's evaluation and conclusions regarding this response are presented. Statement of Violation Assessed a Civil Penalty 10 CFR 50, Spendix B, Criterion II, requires that, "The quality assurance program shall provide control over activities affecting the quality of the identified structures, systems,' and components to an extent consistent with their importance to safety. Activities affecting quality shall be t accomplished under suitably controlled conditions." i Contrary to the above, the KG&E failed to adequately control activities affer. ting the quality of safety-reJated work. Specifically, the Borated Refueling Water Storage System and the Auxiliary Feedwater System were turned over from the construction contractor to the KG&E startup organization on October 28, 1982, and November 23, 1982, respectively, following final quality assurance checks with quality documentation and hardware discrepancies which were not listed on the turnover exception list, This is a Severity Level III Violation (Supplement II) Civil Penalty - $40,000 i 4 Summary of Licensee's Response The licensee's response admitted'the violation and acknowledged the existence of problems in the process of safety-related system turnover from the construction contractor to the KG&E startup organization and the existence of discrepancies ' in the system turnover exception list. KG&E emphasized that the problems were identified by the KG&E Quality Assurance (QA) organization; that a copy of the QA surveillance report was promptly given to the NRC resident inspector; and that KG&E has taken prompt and vigorous actions to correct the problems. Specific points made in the licensee's response are summarized below with an NRC evaluation for each point. A. Prompt Notification and Reporting Summary of Licensee's Response ~ ~ The licensee's response noted that the primary basis for the severity l Level III violation'was a surveillance report entitled ",BN01 System f i
4 Appendix Walkdown," issued on January 13, 1983, by the KG&E QA organization, and that a copy of this report was given to the NRC resident inspector on the day of issuance. The licensee's evaluation of this report, completed on January 14, 1983, and subsequent evaluations concluded that the defi-ciencies identified in the report did not meet the reporting requirements of 10 CFR 50.55(e). NRC Evaluation The licensee is not entitled to mitigation for self-identification and reporting because the licensee only initiated the surveillance audits' which gave rise to the report after being advised by the NRC during the October 14, 1982 Systematic Assessment of Licensee Performance meeting and prior discussions with NRC inspectors, that other utilities had been having problems With system turnovers and that KG&E should be especially careful in these same areas. Furthermore, twenty-five systems had already been turned over from construction to start-up before KG&E initiated these audits. KG&E was also cited for failure to submit a prompt 50.55(e) report. This violation was not assessed a civil penalty although it could have been. Thus, the possible penalty was actually mitigated in this way. The licensee deserves no additional credit for promptly reporting the violation. B. Corrective Action to Prevent Recurrence Summary of Licensee's Response The licensee's response discussed various actions taken or planned to prevent recurrence of the violation. These included the establishment, on January 13, 1983, of a Quality Document Review Task Force; the actions discussed at the enforcement conference on February 18, 1983; the stop work order for the turnover of safety-related systems effective on Februa ry 21, 1983; and the corrective action program described in the licensee's letter to NRC, Region IV, dated March 2, 1983. NRC Evaluation While the corrective action plan established by the licensee appears to be appropriate, the NRC staff does not consider the licensee's actions in-this regard to be unusually prompt and extensive as would be required for a reduction of the civil penalty proposed for the. violation. For example, the licensee's imposition of a stop work order for the turnover of safety-related systems on February 21, 1983, in response to problems identified on January 13, 1983, was not considered to be an unusually prompt corrective action. l ?>
Appendix C. Enforcement History Summary of Licensee's Response The licensee's reponse discussed the favorable enforcement history at Wolf ' Creek and the favorable Systematic Assessment of Licensee Performance (SALP) ratings in the areas of Management Control and Quality Assurance Program. NRC Evaluation The NRC Enforcement Policy of 10 CFR 2, Appendix C, does not specifically provide for a reduction of proposed civil penalties based upon favorable enforcement history or SALP ratings. v D. Prior Notice Summary of Licensee's Response The licensee's response points out that at the October 14, 1982, SALP meeting, the NRC staff noted that other projects had problems in the area of system turnover. In response, KG&E looked for problems in this area and found the problems which formed the basis for the Severity Level III violation. NRC Evaluation Thc NRC Enforcement Policy provides for consideration of increasing a civil penalty based on prior notice of similar events, but not for reducing a civil penalty on such a basis. Furthermore, KG&E's actions in response to the notice were not particularly prompt. E. Severity Level Summary of Licensee's Response The licensee's response questioned the assignment of Severity Level III to this violation since the violation did not involve: failure to conduct adequate' audits, or failure to take prompt corrective action, or . multiple examples of deficient construction or construction of unknown quality.
M.. Appendix NRC Evaluation The staff recognizes that def'iciencies in the BN01 system were discovered through a KG&E QA surveillance audit. The staff believes that an adequate turnover review with timely audits, as described in the Wolf Creek FSAR, would have identified deficiencies in the BN01 system during the turnover process. Thus, KG8E's audit program was not adequate. Furthennore, the audit of the BN01 system occurred after 25 systems had been turned over and was not a routine part of the QA program. Therefore, KG&E had no actual knowledge of the quality of the 25 systems which were turned over before it initiated the audit program. Therefore, this violation,vas appropriately classified as a Severity Level III violation. Statement of Violation Not Assessed a Civil Penalty I 10 CFR 50.55(e) requires that the holder of a consturction permit shall notify the Commission of each deficiency found in design and construction, which, if uncorrected, could adversely affect the safety of plant operations. The regulation further requirer that the holder of the construction pennit shall notify the appropriate NRC regional office within 24 hours after the deficiency was found. Contrary to this requirement, KG&E failed to provide notification within 24 hours of the deficiencies noted in the system turnover practices that were discovered during a Quality Assurance Audit completed on January 13, 1983. Preliminary notification to the regional office was not prov4ed until January 21, 1983. This is a Severity Level IV Violation (Supplement II). At the conclusion of the QA surveillance audit, XG&E was aware of numerous deficiencies involved with the BNOI system. KG&E was also aware that the deficiencies were the result of a significant QA breakdown. however, infonna-tion was not available as to the negative safety effect on the system. The available information was sufficient to warrant the reporting to the NRC of. a reportable event under the requirements of 50:55(e). Giving a copy of a report to the NRC resident inspector does not fulfill the licensee's respon-sibilities for reporting in accordance with 10 CFR 50.55(e). Conclusion The licensee's letter of April 21, 1983, contains no information r.egarding the violations that was not previously known by the NRC during the enforcement conference or prior to the issuance of the proposed civil penalty, and presented l no arguments for mitigation of the civil penalty which had not been considered in the preparation of the Notice of Violation and Proposed Imposition of Civil Penalty dated March 23, 1983. Accordingly, the NRC staff concludes that mitiga-tion of the civil penalty is not warranted. l
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