ML20111C555
| ML20111C555 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/31/1984 |
| From: | Kaester G, Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-84-107, EA-84-107-238, KMLNRC-84-238, NUDOCS 8501090340 | |
| Download: ML20111C555 (5) | |
Text
D c-J KANSAS GAS AND ELECTRIC COMPANY TP41 ELECTRC COMPANY December 31, 1984 CLENN L.NOESTER mcsPatssotmt Nuctaan Mr. Richard C. DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 KMLNRC 84-238 Re:
Docket No. STN 50-482 Ref: 1) Letter dated 11/21/84 from RDMartin, NRC to GLKoester, KG&E
- 2) Letter KMLNRC 84-234 dated 12/21/84 from GLKoester, KGLE, to RCDeYoung, NRC.
Subj:
Enforcement Action 84-107
Dear Mr. DeYoung:
Enclosed is Kansas Gas and Electric Company's (KG&E) response to Violation I (Violation Assessed Civil Penalty) as doctnented in Reference 1.
Pursuant to 10CFR2.201, the following five items are addressed in the Enclosure for the alleged violation:
1.
Admission or denial of the alleged violation; 2.
The reasons for the violation, if admitted; 3
The corrective steps that have been taken and the results achieved; 4.
The corrective steps that will be taken to avoid further violations; and 5.
The date when full compliance will be achieved.
KG&E's response to Violation II (Violation Not Assessed Civil Penalty) was transmitted by Reference 2 which also doctmented the agreed upon extension for the response to Violation I.
Please contact me or Mr. Otto Maynard of my staff if you have any questions concerning KG&E's response to the alleged violation.
Yours very truly, s,
Lc'ta 8501090340 841231 (er Glenn L. Koester hDRADOCK05000h Vice President - Nuclear GLK:ke
- lk xc: RDMartin w/o l
RPDenise w/a P0'Connor w/a p
a HBundy w/a 1
j 201 N. Market - WcN:a, Kansas - Man Address: RO. Box 208 ( Nchits, Kansas 67201 - Telephone: Area Code (316) 261-6451
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Enclosure to KMLNRC 84-238 VIOLATION ASSESSED CIVIL PENALTY i
FINDING-Criterion X. T 10CFR Part 50, Appendix B, requires that a program for inspection of activities affecting quality be estabished and executed by or
' for-the organization performing the activity to verify conformance with the
- documented instructions, procedures, and drawings for accomplishing the
^ activity.,
Criterion XVI of Appendix B' further requires that measures be estabished to
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assure that nonconformances are promptly identified and corected.
Criterion XVII requires that sufficient records be maintained to furnish evidence of activities affecting quality.
Daniel-International Corporation (DIC) Construction Procedure No. QCP-VII-200. describes the requirements for performance and inspection of safety-
= related structural steel welds with respect to committed conformance to the American Welding Society ( AWS) D1.1-75.
Appendix I in Revision 4 of this procedore invokes _ a prohibition with respect to lack of fusion, overlap,
. slag, are. strikes, and weld splatter.
Paragraph 6.5.1 of AWS D1.1-75 :
requires inspector verification that the size and length of welds conform to the drawing requirements-and that no specified welds are omitted.
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~ Contrary to the above, the inspection program for safety-related structural p
steel welds -was not adequately ~ executed to assure conformance to the requirements of Construction Procedure QCP-VII-200 Revision 4 and the AWS D1.1-75 Code nor* were adequate-records kept to document the quality of the
-welds. Furthermore, once deficient welds were identified, no actions were
. taken to correct the deficiencies. - -This inadequate inspection program and
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4 the-failure to take corrective actions is evidenced by the followings t
L1. _' A random reinspection of 241 structural steel -safety-related welds, which was made 'in accordance with Revision 4 of. QCP-VII-200, was performed
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- by 'DIC and documented in Corrective Action Report (CAR) No.1-W-0029 dated March 22,1983. Sixty-two percent of the inspected holds were found by the 4
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- DIC inspectors to not conform to the requirements of Revision 4 of ~ QCP-VII-
- 200. _ The reported defects that resulted in rejection by the DIC inspectors included arc strikes, slag, lack of fusion, overlap, and weld splatter. -
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- 2.
Another. reinspection of a sample of structural members with lowest 1 design. safety margins was initiated on September 14, 1984._ The results of ~
the licensee. reinspection activities (verified by NRC-inspectors) as of September-28 1984, were as : follows :
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- a.. - A missing weld was found at the same location in each of six l.
pressurizer support connections.
In addition, five of 14 fillet welds in one pressurizer support connection were undersized by 1/8-inch to 1/4 inch with respect to the drawing-required size of 5/8-inch, and two of these welds were also under the required length; i.e. 3-inch and 5-inch lengths, respectively, versus drawing-required length of 8 inches. The weld dimensions of the remaining five pressurizer support connections were not included in the NRC-verification activity.
b.
Beinspection.of nine structural steel connections in the auxiliary building identified two missing welds in one connection.
In addition, weld size and length discrepancies were identified in each of the nine connections.
Of the total of 106 welds in the connections, eight were found to be undersized by:1/16-inch to 3/16-inch with respect to drawing-required width. Two of;the undersized welds were also under the required length; i.e., 21/4-inch and 2 1/2-inch lengths, respectively, versus a drawing required length.of 3 inches. An additional nine welds were also.under the drawing-required flength of 3 inches by 1/2-inch to 1-inch.
Examination of 54 weld returns in'the nine connections found 26 to be undersized by 1/16-inch to 3/16-inch with respect to drawing-required widths. One of the undersized weld returns was also under the required length; i.e.,
2 inches versus a drawing-required size of 3 inches. - L1 addition, 36 weld returns exceeded the drawing-required maximum length of 5/8-inch by.15/8-inches to 3 5/8-inches. An additional eight weld returns exceeded the drawing-required maximum length of 3/4-inch by 1/2-inch to 2 1/8-inches.
3.
The absence of required.Miscellanious structural Steel Weld Records (MSSWRs) ' for documenting welding and inspection of safety-related structural
, steel welded connections was identified by KG&E in CAR No.1-C-0031.. As a result of this identification it has been ~ established that approximately percent of MSSWRs could not be located, which precludes positive verification of control of welding and performance of required inspections.
Approximately 80 percent of the MSSWRs applicable to the activities described in paragraph 2 above could not be located.
Records were not available to indicate that an initial inspection was performed of either the
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pressurizer support connections or the auxiliary building strutural connection which was identified to be missing two welds.
MSSWRs were located for certain welds in four structural connections which g
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-indicated acceptable welds. However, reinspection of these four connections showed one undersized weld in one connection and undersized and overlength weld returns in the four connections.
RESPONSE
1.
Admission or denial of alleged violation; Kansas Gas and Electric Canpany (KG&E) does not dispute that problems existed in the inspection and documentation of safety-related structural steel welds. However, KG&E does take exception with one of the statements fdocumented in the NRC's Notice of Violation and Proposed Laposition of Civil Penalty.
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- The statement: with which KG&E takes exception is:
"Furthermore, once deficient welds were identified, no actions were taken to correct the deficiencies."
All' identified weld deficiencies were docueented on Nonconformance Reports and either. reworked to correct the deficiency or evaluated by the Architect / Engineer for a use-as-is-disposition.
~ 2.
The reasons for the violation, if admitted; The reasons for the violation are discussed in the attached final report.
' 3.
The corrective steps that have been taken and the results achieved:
The corrective steps'that have been taken and the results achieved are documented in the attached final report.
4.
The corrective steps that will be taken to avoid further violations:
' The corrective steps taken to avoid further violations are discussed in the
. attached final report.
5.
The date when full compliance will be achieved:
Corrective steps to.. resolve. the safety-related structural steel welding
' concern will be completed by January 15, 1985.
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0A_UI 0F AFFIRMATION STATE OF KANSAS
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COUNTY OF SEDGWICK )
I, Kent R. Brown, of lawful age, being duly sworn upon oath, do depose, state and. affirm that I am Group Vice President - Technical Services of Kansas Gas and Electric Company, Wichita, Kansas, that I have signed the foregoing letter of transmittal for Glenn L. Koester, Vice President -
Nuclear of Kansas Gas and Electric Company, know the contents thereof, and that all statements contained therein are true..
KANSAS GAS AND ELECTRIC COMPANY ATTEST:
d By C(Ad mu r Kent R. Brown Group Vice President-Technical Services' E. D. Prothro, Assistant Secretary STATE OF KANSAS
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COUNTY OF SEDGWICK )
BE IT REMEMBERED that on this 31st day of December,1984 before me, Evelyn L. Fry, a Notary, personally appeared Kent R. Brown, Group Vice President - Technical Services of Kansas Gas and Electric Company, Wichita, Kansas, who is-personally known to me and who executed the foregoing-instru-ment, and he duly acknowledged the execution of the same for and on behalf of and as the act and deed of said Corporation.
,,.......,T,N WITNESS WilEREOF, I have hereunto set my hand and affixed my seal the
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te and year above written.
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EgelynL.Fy, Notary i :-
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..C mmis81 n eXP res on August 15, 1985.
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