ML20126H439
| ML20126H439 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, 05000000 |
| Issue date: | 01/21/1985 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20126H338 | List: |
| References | |
| FOIA-85-160 KMLNRC-85-036, KMLNRC-85-36, NUDOCS 8506100336 | |
| Download: ML20126H439 (22) | |
Text
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YANSAS GAS AND ELECTRIC COMPANY THE ELECT 8hc COMPANY oca== c mou ntr a v<ap.ssioast.mucLeae January 21, 1985 Mr. R.D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 KMLNRC 85-036 Re:
Docket No. STN 50-482 Ref:
Letter KMLNRC 84-175, dated 10/2/84 from GLKoester, KG&E, to RDMartin, NRC Subj: Special Construction Verification Inspection
Dear Mr. Martin:
Kansas Gas and Electric Company (KG&E) retained the Delian Corporation to perform an independent construction assessment of Wolf Creek Generating Station (WCGS).
This assessment was conducted during June through August, 1984 and the Assessment Report was transmitted by the. reference. Subsequent to completing the construction assessment, KG&E requested Delian to evaluate the t'echnical and programmatic adequacy of the corrective actions taken in response to the assessment findings.
Attachment A provides a copy of the Construction Self Assessment Corrective Action Evaluation Report prepared by the Delian Corporation which documents their final assessment.
During October 22 through November 2,
1984 a special Cons truction Verification Inspection (SCVI) was conducted by the Office of Inspection and Enforcement to assess the KG&E Construction Self Assessment effort described above.
As a result of the SCVI assessment one violation and twenty-one unresolved items were identified. Attachment B is a copy of KG&E's response to the Notice of Violation documented in Inspection Report STN 50-482/84-51 and Attachment C provides a summary of KG&E's actions taken to resolve the other issues. Attachment C addresses each of the 21 items in three parts:
o Finding o Action (s) taken to resolve the condition identified Date when required action (s) will be completed o
Supporting documentations packages for each of the 21 items are available for review on site.
8506100336 850415 POR FOIA STEPHEN 05-160 PDR J
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r Mr. RDMartin Page 2 Please contact me or Mr. Otto Maynard of my staff if you have any questions concerning this matter.
Yours very truly,
$/W Glenn L. Koester Vice President - Nuclear Attachments xc: P0'Connor (2)
HBundy WGuldemond
.:;q.-;
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Attach:nent A to KEVRC 85-036 4
ATTACHMENT A O
u
0 Attachment C to K.T.NRC 85-036 ATTACHMENT C
Page 1 INRESCLVED I'IH4 #1:
Finding:
'lwo areas of minor deficiencies identified by the NRC SCVI were verified by DIC to be generic and require further action by them to correct existing deficiencies and prevent future deficiencies frm developing:
the securing of cable at ra way rollouts, and minimum bend radius for cable transferring frm tray to conduit.
[Section III.B. l.b. ( 2 ). (a)].
In addition, the use of temporary teplates to verify minimum bend radius is an area of concern.
1 r=w.e:
a.
Actions taken to resolve the condition (s) identified The specific isolated instances of minimum bend radius violations identified by the NRC have been documented and resolved on ICR ISN 21165E.
The generic concern of potential bend radius violations due to construction activities where cable transfers between cable tray and conduit has been resolved through implerr.entation of EUR 1-5622-E and C t Tracking Form EU-318.
If potential damage exists due to on-going construction activity, edge guards are installed to preclude cable minimtra bend radius violations which would prevent any future occurrence.
The securing of cable at raceway rollouts was found to be a generic discrepancy throughout the power block.
Consequently, NCR's were generated to docu: rent the discrepancies and require a 100% re-inspection and rework of any identified violations.
Reference 1SN 20884E, IST 20885E,1S4 20886E,1S121172E,194 21173E, ISN 21174E, 1SN 21175E and 1SN 21176E. This walkdwn will assure all violations are resolved.
Electrical Quality inspection of minimtzu bend radius is performed in accordance with the requirements of procedure QCP-X-303,
" Inspection of Cable Installation". However, it is occasionally trore feasible to use a tmplate due to the configuration of the cable.
In such cases, a
template is prepared in office conditions with tools which ensure accuracy is maintained.
The tanplate is unique to a specific instal-
- lation, made en a case-by-case basis and verified by Quality prior to user thus it is considered to be temporary.
In addition, the following actions are being taken:
e DIC has performed a review of their construction ccmpletion pro-oedures and construction services procedures and has determined that these procedures prcnide adequate guidelines / criteria to prevent future deficiencies frm developing. This action is emplete.
e ITRE QA has performed a review to verify that the DIC procedural l
evaluation was adequate. This action is otrnplete.
1
Page 2 An evaluaticn was perfomed by IqmE Startup and Operations of their e
procedures to verify that the programatic controls included would preclude the identified deficiencies frm developing.
No corrective actions were identified. This action is emplete.
e IEEE Constructim Procedure I<P-550 is being revised to require all Safety Related and Special Scope Werk Requests assigned to mntractors to be routed to IqEE Quality Engineering to verify that awwriate inspection criteria has been included prior to the initiation of work.
This action is scheduled for cmpletion by January 25, 1985.
b.
Date when required action (s) will be empleted The re aining actions described in bullet four (4) above are scheduled for car.pletion by January 25, 1985.
tERESOLVED TID 4 92A:
Finding:
No requirement for consideration of concrete spalling in obtaining and veri-fying expansion anchor bolt minimum embedment.
Respcnses a.
Actions taken to resolve the condition identified RCI-1-0597-C was initiated to obtain the A/E's engineering evaluation on this subject. For small spalls of the type described by the BCI, it is acceptable to measure the ad;udnent fran the surface of the concrete.
It is not necessary to reduce the ad;edirent depth by the depth of the spall.
The basis for the A/E position is that a minor spall, as described, could ret be detrimental to any expansion anchor failure node.
It should be noted that there is a factor of safety of four between failure and allowable working load.
b.
Date when required acticn(s) will be empleted Based cn the description of the condition and the A/E evaluation, no further action should be required for this unresolved item.
INRESCLVED TITM $2B Pinding:
Request for clarification of information, RCI #1-1357-E, regarding unistrut installation inspection prcuides an acceptable condition for sidewall deflection which has not been incorporated into the inspection criteria.
I Paga 3 Respmse:
Actions taken to resolve the condition (s) identified a.
The fundamental responsibility of Quality inspection is to verify conformance to approved design documents.
A " Request for Clarification of Informaticn" establishes guidelines which, in accordance with DIC procedure AP-III-03,
" facilitate the recording of inquiries concerning the interpretation of design documents and the designer's response thereto." Use of an RCI "is limited to requesting and recording inter-pretation which in no way would change or supercede the authorized design docunents."
Procedure OCP-X-302, Rev.
19, requires verification of raceway support installation per... details, and the latest approved for omstruc-tion drawings...(Reference.. 2.6...)".
Reference 2.6 identifies "Bechtel Civil Structural Conduit Support Drawings
'C-0600 Series'".
The particular detail that lends itself to Unistrut sidewall spreading is found on drawing 10466-C-1602, Detail 3 ard 3A.
In accordance with procedural requirments, Quality inspection verifies empliance with the design drawing; i.e.,
the drawing shows contact between the P1064 fitting and the crown of the Unistrut, expansion anchors are required to meet specificaticn C103A and drawing C-0003, torque is stipulated, proper attachment of the conduit strap is shown.
The purpose of RCI 1-1357-E was not to establish accept / reject criteria for the installaticn; criteria is as shown on the drawing.
RCI 1-1357-E ackrowledges instal-lation to design requirments; the sidewall deflection is a' result of design.
The RCI interprets guidelines that may be considered in good practice, but, as stated on the RCI, "Under no circumstances may this PCI be construed to nodify,
- change, or supercede controlled documents used for construction."
To further substantiate that installations were inspected to design criteria and are acceptable, DIC Engineering, in conjunction with CSA, inspected approximately 80 supports that were installed to C-1602 detail 3/3A. The quantity was selected based cn MIL S'ID 105D.
All were found to be installed to design requirements, with additional assurance verified through PCI 1-1357-E.
b.
Date when full corrective action will be achieved Based on the above activities, no further action should be required for this unresolved item.
,th_ PES %VED I'ITM $2C:
F.inding:
Generic Resolution E-014 does not require docurunting acceptance criteria drawing and specification numbers and revisions on the QC checklists although required to do so_ by the QC procedures.
Pagm 4 Responses a.
Actions taken to resolve the condition (s) identified Generic Resolution E-014 was approved and issued 09/07/84. This resolu-tion was initiated based cm repetitive software discrepancies noted during
+v'==nt reviews concerning the cxsupletion of the Work / Rework Assignment, P.O. Specification and Drawing sections of the Electrical Equipnent Quality Checklist and the Electrical Instrinnent Quality Check-list.
In accordance with QCP-I-05, these " minor" r uculure violations were documented on a Resolution of Repetitive and/or Generic Discrepancy Sheet.
'Ibe justification for resolution of this discrepancy identified that these entries were informational and not deemed as Quality characteristics since the subject information can be obtained frcn other source documents (i.e.,
Work / Rework Assignments).
This conclusion is supported by the fact that Quality procedures require the Quality Inspector to inspect / verify activities in accordance with Work Assignments.
The specific information required for the Quality Inspector to perform the required inspections are contained in the Work Assignment.
'Iherefore, discrepancies noted during docurrent review are informational in nature and appropriately resolved per the Generic Resolution E-014.
The Repetitive and/or Generic Discrepancy Sheet is a vehicle to document a minor program violation affecting software related itces.
In the specific case of the checklist for equipment NK12, the incorrect drawing reference was informational in nature and had no hardware impact. Based on this specific item and the information above, it is concluded that the Repetitive and/or Generic Discrepancy Sheet has been properly utilized in resolving the subject discrepancies.
b.
Date when required action (s) will be cx2rpleted Based on the above explanation, no further action should be rt. quired for this unresolved item.
UNRESCLVED ITEM 43:
Finding:
The acceptability and generic implications of vendor termination lug bending, as found in panel RP-210, requires additional licensee evaluation.
Responses a.
Actions taken to resolved the condition (s) identified The Terminal Lug Vendor (Thcmas t. Detta) performed formal testing of the lugs and found no detrimental effects to the hardware.
Bechtel performed an evaluation of the Vendor Test Report and found the results acceptable.
_k Page 5 l
b.
Date when required acticn(s) will be empleted Based on the above infonnation, no further action should be required for this unresolved item.
tactPMrWVED T11!M $4:
Finding:
%c items found on the battery rack NK-12 required additional evaluation to determine acceptability and generic implications:
the actual torque valves of the brace pad bolt asserblies, and quality of the rack plug welds.
Response
a.
Actions taken to resolve the condition (s) identified o NCR lEN-21202E was initiated to resolve discrepancies on battery rack tE-12 brace pads.
o CWP NK-172E was initiated to re-inspect plug welds cn battery rack tK-12.
o To address the generic implications of the brace pad bolt assernbly concern a re-inspection of the brace pads for the safety related battery racks (tE-ll, tK-13, and NK-14) has been performed.
No discrepant conditions were identified.
The generic implication of the plug weld discrepancies was addressed o
in a re-inspection conducted in December,1984.
All plug welds for battery racks tE-ll, IE-12, NK-13, and NK-14 were inspected for ccmpliance to AWS Dl.1-75 and design criteria.
This inspecticn was documented in accordance with the requirements of QCP-XI-300, Appendix I and all plug welds were found to be acceptable.
b.
Date when required action (s) will be empleted Based on the results of the re-inspection activities performed on the battery rack plug welds and brace pads, no further action should be required for this unresolved itan.
tastynr1VED ITEM $5:
Pinding:
The re-inspection of welds in accordance with the criteria referenced on Bechtel purchase orders, not used in the CSA, is required to provide a basis for implementation of corrective action.
This should be done following the twnoval of paint frcm the welds or folicwing an ergineering evaluation of the acceptability of the method of inspection of vendor welds through paint.
Pags 6
Response
a.
Actions taken to correct the condition (s) identified Per page IV-3 and 4 of the CSA Executive Surrmary Report relative to Phase I CSA activity, ASME weld inspections were based on the following Codes, Specifications, ard Procedures:
ASME Sections III, V, and IX Bechtel Spec. 10466-M-204,
" Specification for the Field Installation and Fabrication of Piping and Pipe Supports to ASME Section III DIC Procedure OCP-VII-200, " Inspection of Welding Process" DIC Procedure OCP-VII-201,
" Inspection and Docmentation of Fabrica-tion and Installation of ASME, B31.1 Critical, and Special Scope Piping, Valves, and Canponents The initial CSA inspection cancerns were documented on a "GA Field Inspection Concern Form". A concern was documented to:
Require additional research of procedures and design documents rela-tive to concern and
- Respond to concern.
Corrective actions were implemented in accordance with the contractor's quality program which required the use of the applicable procedure /
procedures for re-inspection and verification of the corrected item (s).
DIC OCP-VII-200, " Inspection of Welding Process", was the procedure used for weld inspection.
This procedure contains all the weld criteria required by Bechtel Specification M-204.
All vendor supplied pipe sub asserrblies were purchased to Bechtel Specifications 10466-M-201 a, b,
and c,
" Shop Fab Piping".
A review of the two Bechtel Specifications, M-204 vs.
M-201 series, establishes the same requirements for weld acceptability.
In surtmation, the use of DIC Procedure OCP-VII-200 assured that the verification of welds were in ocupliance with Bechtel Purchase Order Specifications.
DIC Procedure OCP-VII-200 was the procedure used for the verification and acceptance of both original inspections and subsequent re-inspections, if required.
Arpendix III of OCP-VII-200 is the appendix relative to the inspection of ASME Section III weld.
Section III.A.a, Page 4 of Appendix III, establishes the first requirement for visual inspection of cartpleted welds as follows:
" Welds shall be cleaned to rernove slag, spatter,
- rust, and other foreign matter".
Definition of foreign matter would include paint, grease, or any material which could potentially mask an indication.
Paga 7 In conclusicn, the use of DIC Procedure OCP-VII-200 assured that:
1.
The acceptance criteria of Bechtel Purchase Order specification has been impleented, and 2.
The implementation of corrective action requiring weld re-inspection was not performed through foreign matter (paint, etc.).
b.
Date when required action (s) will be :rrnpleted Based on the above explanaticn, no further action should be required for this unresolved item.
[NRESOLVED I'IB4 96:
Finding:
E&E needs to contractually delegate responsibility for the use of written procedures and criteria that would alleviate organization disagrements concerning implementation of corrective action.
Respcnses a.
Actions taken to resolve the condition (s) identified If during field activities (such as the CSA) nonconforming conditions are identified by/to the Constructor (DIC),
they are documented and controlled in accordance with their Construction Procedure AP-VI-02.
Section 3.10 of this procedure states, " Client personnel may initiate an NCR by providing a written request to the Project Quality manager".
The concern expressed by see of the SCVI team inspectors was that corrective actions performed by DIC may not be adequate because DIC did not believe that they were responsible for the corrective action (s).
This concern was ccumunicated to the M&E Director - Quality and Super-intendent Quality Systems Engineering shortly before the SCVI team left the WCGS site. In response to this concern, m &E inmediately initiated a OA surveillance (S-1217) to assess the effectiveness and timeliness of corrective actions assigned to DIC. The surveillance indicated that all corrective actions assigned to DIC were being implemented as required.
Total verification of all corrective actions regardless of the imple-menting organization was acccznplished by both Delian and M&E through the CSA Phase II program.
b.
Date when required action (s) will be ocrnpleted Based on the acceptable corrective actions resultirg frcm the CSA effort as described above, m&E is confident that the Corrective Action elments of the WGS Quality Assurance Program are being effectively implemented by the constructor.
No further action should be required l
for this unresolved ite.
Page 8 LNRESOLVED I'IB4 $7:
Finding:
As a result of the independent SCVI team review of the Dravo film, 33 film packets were found to be marked with a material thickness different frcm that shown on the reader sheet.
Respcase:
Actions taken to resolve the condition (s) identified a.
J This is a generic condition with Dravo film packages and reader sheets.
The thickness recorded on the film package is the actual material thickness.
Dravo Corp. was contacted and the follcwing clarification was provided:
"When there is weld reinforcement, the shim thickness is matched to the thickness of the weld reinforcement and added to the material thickness radiographed.
When there is no weld reinforcement, the actual material thickness is recorded in the material thickness block."
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b.
Date when required action (s) will be ccrnpleted Based on the above referenced letter, no further action should be required for this unresolved item.
UNRESOLVED ITEN $8:
Pinding:
Review of concrete batch ticket records identified that a Level I rather than a Level II Quality Inspector evaluated inspection results, which is contrary to ANSI N45.2.6 requirements.
"._g.se Actions taken to resolve the condition (s) ide'ntified a.
DIC NCR 194-11639C and Generic Resolution C006 ard C007 address the concern of Civil Inspectors signing Inspection Reports prior to their date of certificaticn.
The NCR was appropriately dispositioned as
" rework" and corrective actions were taken.
b.
Date when required action (s) will be ccrnpleted Based on the above referenced documents, no further action should be requiral for this unresolved itan.
Pags 9 UNRESOLVED ITD4 49:
Pinding:
The CSA Evaluation and disposition for CSA cancern #55 relative to the attachment of Ncn-O field routed tubing to a O whip restraint did not consider loading frcm the tubing attachment and whether there was an adequate program for control, design evaluaticn, and as-builts of tubing attached to O supports.
Response
Actions taken to resolve the condition (s) identified a.
l It should be noted that the ncn-safety related tubirx3 support was 1
installed by Westinghouse and the whip restraints were installed by l
DIC. Westinghouse NCR 191 55503J was initiated.
The NCR documents the use-as-is condition of the hardware identified and the approval of the disposition by the A/E.
The NCR also documents the results of an additional examination to determine if welding of similiar tube supports (J17G03) was a generic concern.
'IVenty-nine (29) additional supports were examined and no similiar conditions were found.
j l
Date when required acticn(s) will be ccmpleted b.
further actions should be required for this Based cn the above, to unresolved item.
INRESOLVED I'ITN #10:
Finding:
Bechtel Drawing C-lC2411, Revision 0,
Detail I requires the projection the underside of the top length of concrete anchor bolts to be 7" above flange of the safety injection accunulator tank (#TEP-01A) based frame.
According to DIC personnel present at the time of the SCVI, a + 3/8" toler-allowed, permitting the total maximum projection length to be 7-ance wasThe inspector (s) found that six out of the twelve embedded concrete 3/8".
bolts had projections above the top flange greater than 7-3/8" which anchor exceeds the maximum allowable.
i i
l Resocnse:
Actions taken to resolve the condition (s) identified a.
A Construction Engineering investigation of the noted condition revealed that both accumulator tanks TEP-OlA and TEP-OlB have embedded anchor bolts with excessive projections.
Field Engineering ccmpleted an as-built survey docunenting existing tx)lt projections.
NDC-023-C was generated, as required by site procedures.
This was NCR 19121150C resolved by the generation of a Ncnconformance Report.
was initiated arri sutmitted to Dechtel for Engineering evaluation and was found to be acceptabic to use-as-is.
Page 10 Construction Engineerirg found this occurance to be an isolated case.
8 inches thick The subject bolts were installed in a very thin slab, with a 2 inch ridged steel decking.
By design review, no other slabs exist which the bolt erbedment (including head thickness) equals the slab thickness.
b.
Date when required action (s) will be ccripleted Based on the above, no further action should be required for this unresolved item.
UNRESOLVED I'IDt ill:
Finding:
b The rnateria'l traceability for cabinet to cabinet fasteners for Motor Control Centers IUOlA, t001B, IUO3C, IE03D and 1004C could not be established due to lack of required traceability markings and were also either missing or were improperly installed.
i
Response
Actions taken to correct the condition (s) identified a.
A ccmplete review of ' vendor drawings, data, test results, procedures and l
instruction manuals was performed to establish if material specification l
(i.e. ASTM A-307, A-325, etc.) markings were required.
The review and evaluation has determined that no material specification markings are l
required per vendor drawings,
- data, etc.
RCI l-1365-E has been initiated and subnitted to the A/E to confirm material traceability requirements..
DIC All missing or improperly installed fasteners have been adressed on NCR ISN 20682E. The NCR has been closed.
b.
Date when required action (s) will be ocrnpleted A/E response to RCI-1-1365-E is in progress.
The proposed ccrapletion date is scheduled for January 22, 1985.
i UNRESOLVED ITD4 #12:
4
-Finding:
The material traceability of battery rack IE12 fastener assenblies could not be established due to lack of required traceability markirgs or because they were missing.
5-
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t i.
1
Page 11
Response
a.
Actions taken to resolve the condition (s) identified A cxrplete review of vendor data applicable to the ICX-900 battery racks was performed to establish if material specification (i.e. ASIM A-307,A-325, etc.) markirgs were required. An evaluation has detennined that no material traceability is required per vendor drawings.
The bolting material supplied by the vendor was procured to specificaticn SAE-J429, GR 2.
Per the vendors purchase requirements, no markings are required on the bolt heads.
Assurance that the vendor received the correct material fran his supplier was provided by certificate of conformance.
Confinnation of the information noted above has been received fran the material supplier via telecon record sheet dated 1/16/85 and 1/18/85.
The missing fastener for battery rack NK-12 has been addressed on NDC-E-065 and CWP-tE-177-M.
b.
Date when required action (s) will be conpleted:
Based on the above, no further action should be required for this unresolved item.
UNRESOLVED I'ID4 413:
Finding:
High strength steel anchor bolts for main coolant pump and steam generator supports were made of indeterminate material.
Response
a.
Actions taken to resolve the condition (s) identified The Bechtel Procurement Specification 10466-C-134-A (Section 6.3) i indicates that threaded rod (anchor bolt) material shall be as specified on the drawings.
Drawing 10466-C-OC2321(Q) indicates that these l
threaded rods (Mark No.
TR-1) shall be of A540 GR B23, Class 4 (Alloy steel bolting material for special application). ASIM A540 requires the heat nunber to be stamped on one surface.
The Bechtel Spec.
requires that each type of bolt (e.g.
TR-1s) be made fran one mill heat of material.
i The subject bolts were received at Wolf Creek in Iknenber, 1977 and receipt inspected by DIC Quality Control.
The material was verified as being AS40 GR B23 Class 4 by conparing the stamped heat nunber against the acca:panying material test report.
Identification (Piece Mark) was also verified per DIC RMI 10466-C-134A (Q) and all inspection results i
were documented on the QC Inspection Report (MRR 9198).
The bolts were QC accepted on Novmber 22, 1977.
l
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Page 12 Acceptable anchor bolts (threaded rods) are controlled by the warehouse until being issued for installation.
At the point of installaticn, prior to concrete placement, Civil QC Inspectors verify that anchor balts and other embedded items are in accordance with applicable drawings.
This is documented on the Pre-Placement Checklist.
When installing the rods scne of the stamped ends were placed cbwn in the concrete and are therefore no longer visible.
In su:miary the DIC material cx>ntrol program provides verifications to ensure the specified threaded rods were of the proper material and were installed in accordance with design drawings.
This program meets the requirements of ANSI N45.2, Section 9 which states in part:
"... Identification may be either on the item or on records traceable to the iten, as appropriate."
b.
Date when required action will be ccmpleted:
Based on the above, no further actions should be required for this unresolved item.
INRESOLVED ITEM #14:
Finding:
Safety Injection Accumulator Tanks TEP-OlA and TEP-OlD had anchor bolt nuts installation not in accordance with drawing requirements.
Response
a.
Actions taken to correct the condition (s) identified l
Field As-Builts were taken of the anchor bolts installed for the ao::umu-(
lator tanks. An Engineering evaluation determined that the installation l
fully meets the design intent.
Per Bechtel disposition of RCI l-0598-C, the cited condition at accunu-lator tanks TEP-01A (Q) and TEP-OlD (Q) is not a deficient conditicn, based on the following:
e The deficiency of the bolt er.t)edment was addressed on NCR ISN-21150C and approved for "use-as-is" by the A/E. This approval satisfies the bolt errbedment qualification imp > sed by the A/E in their response to l
RCI-1-0598-C.
l e The " Bolted Connection Control Record" for travelers TEP-OlA (0) and l
TEP-OlD (0) have always required torque verification of nuts for these accumulator tanks and thus also satisfy the requirements of i
RCI-1-0598-c.
l The A/E response to RCI-1-0598-C establishes that the presence of the additional nut is acceptable.
O h
Page 13 b.
Date when required action (s) will be c:rpleted Based cn the above, no further actions should be required for this unresolved iten.
UNRESOLVED ITEM #15:
Finding:
An acceptable resolution of 'IE:
57061-K111, Design Control Audit Findings pertaining to DIC implenentation of Field Change Requests is needed.
Resconse:
Actions taken to resolve the condition (s) identified a.
All corrective actions associated with TE: 57061-Klll audit findings have been satisfactorily implemented and verifed.
All audit-findings are closed.
b.
Date when required action (s) will be aanpleted Based on the above, no further actions should be required for this unresolved item.
UNRESOLVED ITEN #16:
Finding:
The CSA evaluation of KG&E response to CSA concern #159 needs to address and resolve the differences in the KG&E and CSA count of audits not conducted, including any pertaining to audits of construction activities performed by other than DIC.
The CSA evaluation should also review the adequacy of KG&E's response cn the impact of not conducting audit TE:
57061-Kill on schedule has on 'the assurance of quality of construction prior to plant operation.
Response
Actions taken to resolve the condition (s) identified a.
- CSA, in their finding, apparently made an error in counting the number of scheduled audits for the 1st and 2nd quarter of 1984 due to the fact that several construction organizations were listed to be audited for the same criterion ccanpliance.
CSA apparently counted multiple entries as one audit.
- However, KG&E QA audits each organization separately.
The scheduled audit count provided by KG&E QA was therefore the correct count. tKfrE:
QA's count included all construction organizations, not just DIC.
Page 14 With regard to the timeliness of the TE:
57061-K111 DIC Design Control audit and the quality impact, the OA audit pmgram established for the Construction Phase required that each of the Appendix B criterion be audited on an annual basis.
Although the DIC Design Control audit was scheduled for the 2nd quarter of 1984, the last audit of this criterion was conducted in Novernber,1983.
In accordance with the established audit program the actual date required for initiating this audit would then have been Noverrber,1984.
TE:
57061-Kill was actually conducted fran August 16, 1984 to September 10, 1984, with the report issued October 1, 1984. Therefore, no quality impact could be assumed since no violations of the audit program or standards existed.
b.
Ihte when required action (s) will be canpleted Based on the above explanation, no further action should be required for this unresolved item.
UNRESOLVED ITEM #17:
Finding:
The KG&E evaluation of SFR l-BB-147 for reportability to the NRC and of the related controls for the tightening of tennination lugs during installation is identified for review.
Response
a.
Actions taken to resolve the condition (s) identified VCGS Request for Reportability, 84-33, was initiated and evaluated during June, 1984. The request was evaluated by KG&E and was determined not to be a potentially reportable 50.55(e) conditicn.
A review was performed of DIC procedures to verify that adequate prc>-
granmatic controls exist for the tightening of termination lugs during installation.
This review verified that these controls are in place in WP-X-304 (Para. 3.16) and OCP-X-304 (Para. 4.8.8).
b.
Date when required action (s) will be acrtpleted Based on the above informaticn, no further action should be required for this unresolved item.
UNRESOLVED ITEM #18:
Finding:
The CAR #18 and the CSA Concern #160 action plan should be revised to include additional clarification of intended corrective action requirenents involving SFRs for resolution of " design errors" or without " identifiable or retrievable documentation".
Page 15
Response
a.
Actions taken to resolve the condition (s) identified e SFR Desian Errors:
Audit TE:
50140-K003 (Startup Field Reports) identified a generic problem with the SFR form and procedures in defining the type of problem to be checked in Block 6.
The audit identified mainly that nonconforming conditions were not always marked as "NCR", but as "Other",
" Design Info Inadequate",
" Drawing Error" and " System Design Problem".
Hoaever, no evidence was identified to conclude that a design control problem existed for SFRs checked " Design Problem".
Since the audit did identify numerous program breakckwns, it was felt that the Startup program for tracking design changes should be evaluated further, though not necessarily included in CAR #18. Therefore, this evaluation was included in the scope of audit TE:
50140-KU12 (Design Control). This audit indicated that no conditions adverse to quality were identified relative to design changes dispositioned via SFRs.
In sumnary, due to the fact that (1) no problems were noted in the SFR audit in identifying design errors and (2) ro problems were noted in the subsequent audit for the tracking of design error reso-lutions, no further action was deemed necessary.
e Identifiable or Retrievable Documentation:
Finding #2 of CAR #18 addresses the necessity for the implementing work documents to be traceable to the SFR. The reccmnended corrective actions [ Items 3(d) through 5 (1)] of CAR #18, were verified to assure traceability /
retrievability of work documentation.
In response, Startup prepared a cross reference table relating SFRs to the associated work documents. IG&E OA verified, through surveillances TE:
53359-S-1219 and TE:
53359-S-1230, that the information contained in the cross reference table was accurate.
Where RIRs were generated for SFRs without identifiable or retrievable documentation, this was so noted in the tables.
Related activities with regard to other Responsible Work Organizations (IMOs) were reviewed for ocupliance to their QA programs for handling the SFR resolution work. This review indicated that the SFR resolutions were properly implemented by the applicable work documents generated by Westinghouse and 10&E Maintenznce (the IUO's).
b.
Date when required action (s) will be ccmpleted Based on the above informaticn, no further action should be required for this unresolved item.
UNRESOLVID ITIN 419:
Finding:
Appropriate revision of procedure ADM 14-416, Rev. O is required to prevent recurrence of deficiencies in the use of NDCs of the type discussed in the KG&E report }ORD 84-134.
Page 16 Resnonse:
a.
Actions taken to resolve the condition (s) identified IG&E OA initiated Surveillance Report S-1225 concernire the use and dis-position of Notice of Discrepant Conditions (NDC's).
The surveillance resulted in issuance of Quality Program Violation (OW) 12/84-01 which addressed the procedural implementation deficiencies. The violation was verified and closed cn 01/12/85.
No revisions to procedure ADM 14-416 are required as a result of the evaluaticn/ verification of CSA concern #170 and the verification and closure of QW 12/84-01.
b.
Date when required acticn(s) will be achieved PAsed on the above information, no further action should be required for this unresolved item.
UNRESOLVED ITEM #20:
Finding:
KG&E should audit a sample of NCRs issued after the close out of NDCs for coupliance with procedure AP-VI-02, Section 3.30 provisions of " prior to and after N-stamping" of ASME systems /ccrnponents.
Response
a.
Actions taken to resolve the condition (s) identified OA Letter, Patrick to Rudolph,
Subject:
CSA Concern 84/51-20, dated 01/14/85, was issued assessing the need to perform an audit or surveillance to verify that the proper ASME Section (III and XI) is being utilized.
The letter states that due to the multiple levels of programnatic controls established, it is very unlikely for an error to remain undetected and uncorrected. Furthermore, since the program will be ccrupletely revised in a matter of days, an audit of the "old" program would be inappropriate.
The present audit schedule does,
- however, require an audit to be performed on the "new" DIC Construction Services program in the first quarter of 1985.
b.
Date when full required action (s) will be ccrupleted Based on the above information, no further actions should be required for this unresolved iten.
Pags 17 UNRESOLVED ITEN $21:
Finding:
The KG&E/CSA corrective actions should ensure that the M&E program for identifica~ tion and review of deficiencies for reportability to the NRC is being implemented in a timely manner for:
SFR or NCRs checked "potentially reportable";
arri for deficiencies in constructicn which muld have gone undetected due to the breakdown in the SFR OA program, as identified by the TE: 50140-K003 Design Control audit.
Response
a.
Actions taken to resolve the condition (s) identified As a result of independent action by the Quality First organization, the SFR Reportability issue was examined by Quality First Action Request (OFAR) 9/84-005 (initiated 09/28/84 and closed cn 11/05/84).
The OFAR precipitated a review by KG&E Startup of all previously written SFR's up to October 1, 1984 for ccrnpliance to the requirements of ADM 01-033, " Instructions Describing Reportability,
- Review, and Documenta-tion of. Licensee Event Reports (LERs), and Defect Deficiencies".
SFR's were evaluated and reviewed in five (5) categories including those marked as "Yes" for potential reportability and those SFR's that were dom 3raded frcrn "Yes" to "No" potential reportability.
As a result of the examinaticn, fourteen (14) SFR's were reviewed for reportability.
The evaluation for reportability revealed no reportable conditions were identified that had not been previously reported.
A KG&E OA Surveillance (S-1234) was initiated to evaluate the 50.55(e) reportability discussed in this unresolved item.
The surveillaa.ce concluded that the actions associated with the request for reportability relative to the SER problens were proper,
- correct, and in accordance with established procedures.
b.
Date when required action (s) will be achieved Based on the above, no further actions should be required for this unre-solved iten.
y j,2
,N 2-T-14-002 CORPORATION January 11, 1985 Mr. Richard M. Grant Director - Quality Kansas Gas and Electric Company
-Wolf Creek Generating Station P. O. Box 309 Burlington, KS 66839
Dear Dick,
This letter forwards the report, " Construction Self Assessment Corrective Action Evaluation," prepared by Delian Corporation to document the joint Delian - KG&E effort to address concerns defined in last sumer's Construction Self Assessment (CSA) of Wolf Creek.
The report briefly outlines the objectives and scope of the corrective action evaluation effort, sumarizes the results, and discusses the key, original CSA conclusions in light of the corrective action results.
Based on the completed corrective actions and those few which are still in-process, it is Delian's judgment that all of the concerns of the CSA have been or are being satisfactorily resolved, either through corrective action pPrformed by KG&E and/or its contractors or through investigations which demonstrated that the original concern is not a problem.
It has been a pleasure working with KG&E on the corrective action evaluation and I wish you the best in your efforts toward making Wolf Creek operational.
Ver truly yours, W, 'S &
1
\\
W l-David E. Leaver Vice-President Delian Project Manager i
cc: Marvin Fertel Carl Parry Enclosure t
l 1340 Saratoga-Sunnyvale Road Suite 206 San Jose, California 95129 408/446-4242 l
Idaho Falls, llaho
- Del Mar, California
- Monrorvdic, Pennsyhunia
- Washington, D.C.
.