ML20126H603

Const Self Assessment Corrective Action Evaluation

ML20126H603
Person / Time
Site:	Wolf Creek, 05000000
Issue date:	01/11/1985
From:	DELIAN CORP.
To:
Shared Package
ML20126H338	List: IA-85-160, Trip Rept of Site Visit During Wk of 831031 Re Physical Arrangement & Installation of Electrical,Instrumentation & Control Equipment.Compliance W/Nrc Design Criteria Confirmed IR 05000482/1984051 ML20126H335 ML20126H387 ML20126H439 ML20126H482 ML20126H603 ML20127B510
References
FOIA-85-160 NUDOCS 8506100367
Download: ML20126H603 (66)

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WOLF CREEK NUCLEAR GENERATING STATION CONSTRUCTION SELF ASSESSMENT CORRECTIVE ACTION EVALUATION PERFORMED BY DELIAN CORPORATION FOR KANSAS GAS & ELECTRIC DAVID E. LEAVER, DELIAN PROJECT MANAGER DELIAN CORPORATION >

1340 SARATOGA-SUNNYVALE ROAD 'i'd l SAN JOSE, 95129 I

, JANUARY 11, 1985 l

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8506100367 850415 PDR FOIA I STEPHEN 85-160 PDR l 2-R-85-015 L  ;

I. INTRODUCTION This reoort summa rizes the process and results of the corrective action evaluation program that was performed to address concerns defined in the Construction Self Assessment (CSA) of Wolf Creek Nuclear Generating Station.

The following sections of this report provide a brief discussion of the W background leading up to the corrective action program (Section I-A); discuss the scope of the corrective action performed by Delian (Section I-B); discuss the results of the corrective action evaluation program (Section- II); and review the conclusions reached in the original CSA report in light of the results obtained from the corrective action program (Section III).

A. Background The CSA was perfomed for Kansas Gas and Electric Company (KG&E) by Delian Corporation during the. period May through August, 1984 The objective of the CSA was to independently evaluate the adequacy of construction at Wolf Creek through installed hardware inspections and quality program reviews. The CSA results were documented in an August 28, 1984 report (See Reference 1). Table 1 identifies the 156 specific and 15 potential generic concerns that resulted from the CSA inspection. Subsequent to completing the CSA, KG&E requested Delian to evaluate the technical and programmatic adequacy of the corrective actions being performed by KG&E and its contractors in response to the findings of the CSA.

Delian perfomed these activities for KG&E during the period September 3 through December 6,1984. The subsequent sections of this report discuss the corrective action evaluation program and the results obtained therefrom.

B. Scope of Corrective Action Evaluation The basic objective of the corrective action evaluation was to assure that the corrective actions performed in response to the CSA findings fully addressed the technical and programmatic implications of the findings. To accomplish this objective the following was done:

o The original 156 specific concerns which were written up during the CSA were treated individually with a corrective action being perfomed 2-R-85-015

and documented for each concern by KG&E and its contractors. All corrective actions were carried out under the auspices of the existing Wolf Creek site quality program. Delian performed a separate tracking and technical review function to verify that the corrective action appropriately addressed the original CSA concern and was performed in accordance with appropriate Wolf Creek QA program requirements.

o Action plans were jointly developed by Delian and KG&E QA to address 15 potential generic concerns. The generic concerns were identified based on the conclusions of the CSA report regarding possiple generic problems and were largely extensions and/or combinations of certain of the specific concerns. In addition to preparing action plans for the potential generic concerns, action plans were also prepared for ten of the more significant specific concerns (see Table 1).

o The tracking and technical review function performed by Delian was controlled by the procedure entitled, " Description of CSA Corrective Action Process." This procedure was prepared by Delian and approved i

by KG&E-QA. Revision 2 of this procedure dated November 21, 1984 and approved by KG&E letter KQWLO 84-138 of December 4, 1984 was controlling at the completion of the project and is included as Attachment A to this report. This procedure described the steps

! followed by Delian in' processing and tracking closure of CSA concerns.

l o The specific activities performed by Delian as part of the corrective action evaluation program are highlighted below:

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+ For all of the generic concerns and for ten of the more significant specific concerns, prepare action plans (jointly with KG&E-QA) which defined the scope of the corrective action.

Typically, these action plans were oriented toward ascertaining the extent of a problem (i.e. , extent within a given discipline, common to several disciplines, or programmatic).

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+ Evaluate proposed corrective action and supporting documentation (including responses to those concerns for which action plans were prepared) to assure that the corrective action adequately addressed the CSA concern and that it was performed in accordance with program requirements.

+ Document acceptance or rejection of proposed corrective action

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and, where necessary, inform ' responsible organization. of need for _ W further action and/or information. -

+ Upon acceptance of a proposed corrective action, perform document review and if appropriate perform a physical inspection to verify satisfactory implementation of the corrective action.

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+ Document verification or rejection of the corrective action implementation and, where necessa ry , inform the responsible organization of need for further action.

o Unlike the CSA which was an independent, third party effort, the corrective action evaluation was a joint effort between Delian and KG&E QA. KG&E's involvement included:

+ Detemine approp'riate corrective actions for the generic concerns

+ Approve the Delian procedure for the corrective action evaluation and perform a surveillance to verify Delian compliance with the procedure.

+ Review all corrective action packages completed by Delian to ensure all required corrective actions have been performed, verified, and properly documented.

+

Perform final verification of those concerns which were closed out "in-process" by Delian (see KG&E letter XQWLO 84-138 of December 4,1984 in Attachment A).

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+ Provide for retention (as QA records) of all applicable documentation related to the CSA inspections and corrective action evaluation.

o As noted in the procedure, " Description of CSA Corrective Action Process," Delian was the final authority on the requirements for -

corrective actions and the type of verification. Two methods of verification were used for most of the corrective actions: (1) _9 physical review in which the corrected ha rdware was- actually inspected; and (2) complete document review in which all relevant documents were reviewed against the quality program requirements.

Physical review included a review of documentation against the quality program requirements. For both these methods, the verification was not performed until the corrective action was complete. Physical review was used where feasible except in a few cases which are noted in Table 1. Complete document review was used for documentation deficiencies, non-Q hardware problems, and in a few cases for hardware problems where the item was not accessible for inspection.

Near the end of the corrective action effort, it became apparent that a number of the corrective actions would require additional time to complete. Accordingly, KG&E directed Delian to close out those corrective action packeges by describing what actions had been verified to date and what additional verifications shall be performed -

by KG&E. Thus a third verification method, "in-process" document review, was used for these concerns for which corrective action had not been fully completed.

Table 1 lists the verification method for each concern.

As part of the 24 in-process verifications, Delian reviewed tha intended corrective action and the documentation in-place as of December 6, 1984. Also, Delian specified the steps which it considered necessary to complete the verification of the corrective action. Table 2 lists these required steps.

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II. CORRECTIVE ACTION RESULTS A. Format of Results As noted above, there were 171* concerns for which corrective action was performed. A separate file was maintained for each of these concerns including ,

the original CSA finding, an action plan (where appropriate) to guide the corrective action activity, corrective . action documents provided by the responsible organization, and a closure form for tracking the status of the corrective action and for documenting verification of the corrective action and final closure of the concern. These 171 files together with this letter report document the results of the corrective action effort.

B. Discussion of Results As is evident from Table 1, there were 90 concerns verified through physical inspections (which included a document review), 81 verified through complete document review, and 24 verified through in-process document review. (The total adds 195 since a number of the concerns had multiple parts). Of the 81 verified by complete document review, there were four safety-related items which could have been physically inspected (63, 76H, 125 and 144). As noted in the Table 1 footnote these were verified by complete document review on the basis of their minor significance. About 50 nonconformance reports were issued during the process of resolution of the 171 CSA findings as well as several corrective -

action reports and quality program violations.

t Generally, a physical inspection verification included a document review. The work documents and inspection documents are included in the file for each concern. The nature of the complete document review varied depending on the concern. Normally the documents reviewed consisted of those necessary to show that the quality program requirements had, in fact, been met or to show the l

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• Table 1 numbers the concerns only to 170. However, there are two separate l

l concerns with the number "76", 76H and 76P. Thus, the total is 171.

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nature of the deficiency when one existed. In a few cases (such as concerns 35,101,113,131 and 149) the field work has been completed and inspected by Delian but final closure of the documentation had not been performed at the time of the inspection. These concerns were footnoted on Table 1.

Out of the 171 concerns, there were 10 rejections. All 10 of :he rejected concerns were either minor hardware problems or minor documentation problems.

All of these rejections were subsequently reverified and accepted by Delian.

However, due to the delay associated with the rejection, six of the 10 were closed based on in-process document review. Table 3 lists these 10 concerns and the basis for rejection.

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III. CONCLUSI0f!S The purpose of this section is to discuss the original CSA report (Reference 1) conclusions in light of the additional information and insights obtained during the correction action evaluation. Only those original CSA conclusions which had potential generic or programmatic implications are discussed in detail here.

Regarding the 156 specific concerns, it is concluded that KG&E has resolved or is adequately addressing, all of the original findings. At the time of this report, resolution was fully complete on 136 of the 156 specific concerns. A number of these 136 were found upon investigation to not be deficient conditions and thus do not require corrective action. As noted in Section II above, the 20 specific concerns for which corrective action was only partially complete and which were closed in-process by Delian are being formally resolved by KG&E as part of its QA program. Details. regarding resolution of the specific concerns may be obtained from the appropriate files.

The original CSA conclusions which had potential generic or programmatic implications were of two types: (1) conclusions which strongly implied the existence of a generic problem and the action necessary to address it and (2) conclusions which were less explicit in that they were in the form of questions based on limited data, or were questions regarding whether a finding in one discipline extended into other disciplines. All of the first type of conclusion 'a's well as those of the second type which did turn out to be problems, have been or are being adequately resolved by the corrective action -

program. The remaining conclusions of the second type were demonstrated to be non problems which, therefore, required no corrective action.

The conclusions which had potential generic and programmatic implications are discussed below. Table 4 summarizes these conclusions and associated l resolutions along with the page numbers in the reference (1) report which

! discussed the conclusions and the related concern numbers which resulted from

-the original CSA inspections.

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l Instrument Tubing Cleanliness and Damage The original CSA conclusion derived from a number of instances in the field in 1

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which tubing was damaged and had foreign materials and residue on the surface.

Since the tubing is damage prone, particularly in high thoroughfare areas, there appeared to be a need for reinspection and correction of any damage during the period leading up to and immediately prior to operation. The corrective action investigation confirmed both the existence of the problem identified during the CSA inspection as well as management awareness of the problem and the existence -

of inspection and testing programs which provide reasonable assurance that such damage will be identified and corrected. Thus, it is concluded that while instrument tube damage has been occurring, sufficient programs are in place to correct the damage and no action beyond that al ready being performed is required.

Imorocer Imolementation of Vendor Instructions CSA had concluded that there were numerous deficiencies with fastener hardware used to perform on-site assembly of sections of electrical switchgear and motor control centers. The problem apparently stenned from a failure to fully implement vendor instructions. A complete reinspection. was conducted of all electrical equipment shipped in sections and assembled by DIC on-site, and all deficiencies were corrected. An investigation of mechanical equipment was conducted as part of the corrective action evaluation to assure that vendor ir.structions were adequately specified in the special instructions for on-site equipment as's'embly and installation. This investigation did not uncover any evidence that the vendor instruction problem extended into the mechanical -

l equipment area. Thus the results of the corrective action program have fully resolved the original CSA concern related to generic problems associated with l implementation of vendor instructions.

l l Screadino of Unistrut Walls CSA found a number of instances in which the walls of the unistrut used to support electrical conduit were somewhat bowed. This condition was not in accordance with the design and raised concerns regarding the seismic capability of the installation. However, as a result of the corrective action program, l these situations were reviewed by the A/E who concluded that the unistrut was acceptable on a use-as-is basis.

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Comoleteness of 0.C. Insoection Criteria The original CSA conclusion was based upon situations where Q.C. inspection criteria appeared either incomplete or more general than desirable. These situations involved HVAC hanger configuration, pipe support location, special pipe clamp configuration, and the electrical equipment fasteners. Each of these situations were investigated to determine if there was evidence that hardware problems existed due to the inspection" criteria problem.

For HVAC duct hanger configuration an extensive reinspection effort confimed that the hardware meets the latest design requirements. For special pipe clamps, a 100% reinspection identified a few hardware deficiencies which were resolved on a use-as-is basis. The pipe support location problem was determined to be an isolated one. The electrical equipment fastener prob.lem was resolved on the basis of a 100% reinspection. Furthermore, these fasteners were commercial grade hardware and did not require a Q.C. signoff.

Accordingly, the corrective action effort concluded that, although there were instances where more specific inspection criteria would have added assurance to quality, only the electrical equipment fastener problem was extensive and this problem was fully investigated and resolved. Thus, there does not appear to be any evidence of hardware problems resulting from a lack of specific Q.C.

inspection criteria.

Uodating of Special Instruction Sheets-The original CSA inspection identified three areas in which travelers failed to reflect the latest design requirements as a result of the "Special Instruction Sheets" not being updated. For snubbers, DIC initiated and completed two Corrective Action Reports (CAR 43 and 44) to define and resolve the problem.

For special pipe clamps, a 100% reinspec+. ion was performed, with a few deficiencies identified and resolved. For HVAC duct hanger; an extensive reinspection indicated that the installed hardware is acceptable despite the fact that the travelers did not explicitly identify and include the latest

- drawings used for construction or inspections. The corrective action evaluation also investigated and found no evidence of problems with incorporation of vendor 2-R-85-015

instructions into travelers for mechanical equipment. . Therefore, the corrective action program adequately addressed the original CSA concern in this area.

Quality of ANSI B31.1 Field Fabricated Pioino Welds The CSA inspections identified several DIC piping welds fabricated to ANSI B31.1 _

which, based on initial inspection, appeared to not meet requirements. The concern was whether this problem could be more widespread. For three of the welds, more detailed inspection during the corrective action evaluation indicated that the welds did meet requirements. A fourth weld was dye penetrant tested after blending. The test indicated that the weld was acceptable. Thus, there was no evidence of a generic problem with ANSI B31.1 field fabricated piping welds.

Control of Non-Conformino Conditions in Turned Over Eouipment CSA reviewed the system for identifying and resolving non-conforming conditions in turned over hardware and concluded that the Startup Field Report (SFR) system had been improperly used in some instances and that there cay be a need for improved procedures and training. This resulted in Corrective Action Report 18 and Work Hold Agreement 22 being issued by KG&E. Successful closecut of the CAR should resolve the orignal problem and provide adequate assurance that the SFR system is be'ing properly implemented. CSA also . tentatively concluded that the Notice of Descrepant Condition (NDC) system was being misused. Further -

investigation during the corrective action evaluation confirmed the existence of a problem with regard to closure of NDCs without issuance of a non-conformance vehicle as required. This investigation resulted in Quality Program Violation 12/84-01 being issued by KG&E. Once completed, this should correct the NDC problem.

,Pjpe Support Deficiencies The CSA inspection identified a number of pipe support ha rdware and documentation deficiencies. These deficiencies raised a concern as to whether a program problem existed in the fabrication and installation of pipe supports.

The deficiencies included mislocated supports, missing welds, incorrect pipe 2-R-85-015

clamps installed, incorrect snubber setting, and a number of minor deficiencies, investigation of the minor deficiencies indicated that they were not of a repetitive nature. Each of the more significant deficiencies was fully investigated during the corrective action evaluation and found to be isolated or limited in scope. Thus, based on the additional information obtained during the corrective action effort -there .does not appear to be evidence of a program problem with pipe supports.

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OA Audits Not Performed Per Schedule ._

The CSA inspection found that QA construction audits for the first two quarters of 1984 were not performed as specified in the KG&E QA schedule which was established at the beginning of 1984. Both the missing audits and concerns regarding the setting of priorities on topics for audits and the availability of resources to meet the schedule were addressed during the corrective action program. Investigation during the 'c orrective action phase indicated that the incomplete audits were performed later in 1984 Also, mechanisms have been put in place by KG&E to assure that the high priority activities are audited per applicable requirements. Finally, action has been taken by KG&E QA to assure availability of necessary resources to perform required audits on schedule.

Potential Problem with Control of Vendor Activities The CSA inspection noted several concerns with vendor activities including -

vendor weld problems, vendor radiograph problems, and some problems with fastener hardware supplied as part of a purchase order for some electrical switchgear and motor control centers. As a result, the CSA report raised a question as to whether vendor activities had been properly controlled.

Investigations during the corrective action evaluation indicated that the scope of the vendor weld problem is very limited and th'at there is only one vendor with a minor radiograph problem. Furthermore, the electrical equipment fastener problem turned out to be a problem with implementing vendor instructions rather than a problem controlling vendor activities. Thus, the original question as to whether vendor activities had been properly controlled is no longer relevant.

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HVAC Duct Hancer Overhead Attachment Welds CSA noted several examples of undersize welds on HVAC duct hanger overhead attachments. The undersize weld problem was restricted to joints connecting angle clips to embed plates and connecting vertical support plates to horizontal structural steel members, probably as a result of the tight geometry and resulting limited accessibility. To assess the extent of this problem, the corrective action evaluation included a reinspection of 13 additional duct hanger overhead joints with the one of the two configurations noted above. Two of the 13 duct hangers were found to have minor undersized welds. These two as well as the three hangers with undersize welds which were found in the CSA inspection were accepted on a use-as-is basis by the A/E. The reinspection and use-as-is acceptance by the A/E fully resolve this problem.

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-sr TABLE I

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTIDN VERIFICATION METHOD CSA CSA Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 1 Structural Steel, Missing GY DIC No Complete Document Review Documentation 2 Electrical, Rust on Conduit ilGW DIC No Physical Inspection 3 Electrical, Cable Min. IlGW DIC Yes Complete Document Re-Separation view (1) 4 Electrical, Conduit Marking HGW DIC No ' Physical Inspection 5 Electrical, Flex Out of Condulet HGW DIC No Physical Inspection 6 Electrical, Flex Connection HGW DIC No Physical Inspection Loose 7 Electrical, Fitting loose ilGW DIC No Physical Inspection 8 Electrical, Conduit Bends ilGW DIC No Complete' Document Review Greater than 360 9 Electrical, Min. Separation IIGW DIC No Physical Inspection

- 10 Electrical, lack of Cable llGW DIC No Compete Document Review.

Flex 4 11 Electrical, Flex Connector ilGW DIC flo Physical Inspection ' ' ' '

loose 12 Electrical, Missing Clamp On HGW DIC No Physical Inspection Support

TABLE 1

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METil0D CSA CSA Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 13 Welding, (Piping) Weld Paper CPT DIC No Complete Document Review Not Stamped Correctly 14 Welding, (Piping) Weld Loca- CPT DIC No Complete Document Review tion not shown on B/P 15 Mechanical (Piping) BDC a)KGAE a)No a) Complete Document Review a) Valves left Open b)DIC b)No b) Complete Document Review b) Nuts Not Fully Engaged 16 Mechanical (Piping) NDE CPT DIC No Complete Document Review Indication Not Addressed 17 Mechanical,(Supports) BDC DIC No Complete Document Review Traveler B.O.M. Not Correct 18 Mechanical,(Supports) SB DIC No Complete Document Review Not to Tolerance 19 Mechanical,(Supports) SB DIC No- Complete Document Review Obstruction 20 Mechanical,(Supports) SB DiC No Complete Document Review No QC Verification Noted 21 Electrical, Pull Box HGW DIC No Physical Inspection Cover Not Installed 22 Electrical, Cables Not HGW DIC No Complete Document Review Tied Down 23 Electrical, Flex Connector HGW DIC No Physical Inspection Loose TABLE I

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METIIOD CSA Concern CSA Action Method Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 24 Electrical, Unistrut Wall HGW Spread DIC No Physical Inspection 25 Electrical, Washer Rotated I!GW DIC No Complete Document Review on Unistrut 26 Electrical, Galvanize off IIGW DIC No In-Process Document Review Conduit 27 Electrical, Tray Support not HGW DIC No Physical Inspection Secured Properly 28 Electrical, No Fire Barrier HGW DIC No Physical Inspection 29 Electrical, Cable Tray Pene- HGW DIC No Physical Inspection tration Barrier 30 Electrical, Floor Penetration not as Required IIGW DIC No Physical Inspection 31 Electrical, Missing Cable llGW KG&E No Physical Inspection

, Softener 32 Electrical, Excess Tray Fill llGW DIC No Physical Inspection 33 Mechanical (Supports) In- BDC DIC a)No a) Physical Inspection sufficient Weld Length a)No b) Physical Inspection ,

34 Mechanical, (Supports) Not BDC DIC No Physical Inspection to Tolerance Incorrect Material I.D.

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TARLE 1 SUP9tARY OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Action Method Concern Responsible Responsible -

Plan Of Number Description ,

Individual (6) Organization Prepared Verification 35 Electrical, MCC Bolting Not HGW DIC No Physical Inspection (2) to Spec's.

36 Electrical, Box not Properly HGW DIC No Physical Inspection Secured 37 Electrical, Broken Flex in HGW DIC No Physical Inspection Conduit 38 Electrical, Flex 1.oose HGW DIC No Complete Document Review 39 Electrical, Lack of Edge HGW DIC No Physical Inspection Softener on table 40 Electrical, Broken Flex HGW DIC No Physical Inspection 41 Piping Flange Bolts not BDC DIC No Complete Document Review Fully Engaged 42 Mechanical, Snubber (Support) BDC DIC No Complete Document Review not Completely Wrapped 43 Mechanical,(Supports) BDC DIC No Complete Document Review Operational Interference 44 Mechanical (Piping) Clearance BDC DIC No j Complete Document Review Between Valve Handle 45 Mechanical, (Supports) Snubber BDC DIC No Physical Inspection Interference 46 Electrical, Missing Bolts on HGW DIC No Physical Inspection Cover

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TABLE 1

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 47 Electrical, Missing Bolts HGW DIC No Physical Inspection on Cover 48 Mechanical,(Supports) BDC DIC No Complete Document Review Hanger Clearance 49 Electrical, Flex Connector HGW DIC No Complete Document Review 1.cose 50 Mechanical, (Piping) Grind CPT DIC No Physical Inspection Spot 51 Electrical, Missing Strap for HGW DIC No Physical Inspection Unistrut 52 Electrical, Unistrut Strap not HGW DIC No Physical Inspection Engaged 53 Mechanical,(I&C. Valve) BDC DIC Complete Document Review a)No a) Incorrect Washers Installed b)No Complete Document Review b) incomplete Thread Engagement

- 54 Mechanical, (Supports) Temporary BDC DIC Yes In-Process Document Review Clamp 55 Mechanical, (Whip Restraint and BDC WESTINGHOUSE No In-Process Document Review Tubing Support-Civil / Structural)  ;

Clearance 56 Mechanical (Whip Restraint SB DIC No Complete Document Review Civil / Structural

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I TABLE 1

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Concern Action Method Responsible Responsible Plan Number Description Of Individual (6) Organization Prepared Verification 57 Mechanical, (Supports) Dperational SB DIC No Complete Document Review Interference 58 Mechanical, (Supports) Bushing SB , DIC No Complete Document Review not Properly Staked 1 59 Electrical, No I.D. Markers HGW DIC on MCC No Complete Document Review 60 Electrical, Flex not Properly HGW DIC No Physical Inspection Separated 61 Mechanical,(Piping) BDC alDIC a)No a)ln-Process Document a) Bolts Loose on Valve b)No White I.D. Tag Review b)DIC b)No b) Complete Document Review 62 Mechanical (Piping) BDC DIC a)No a)ln-Process Document a) Bolts loose on Valve b)No White I.D. Tag Review b)No b) Complete Document Review 63 Mechanical (Piping) BDC DIC No Complete Document

. Nuts Missing on Valve Review (3) 64 NDE, (R.T.) Film Quality CPT KGAE No Complete Document Review VENDOR 65 NDE, (R.T.) Film and Weld CPT KGAE Quality No Complete Document Review VENDOR ,

66 HDE, (R.T.) Film Quality CPT KGAE No Complete Document Review 67 Electrical Flex Disconnected HGW DIC No Physical Inspection

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TABLE 1

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 68 Welding, (Piping) Surface CPT 'KG&E Yes In-Process Document Review Defects VENDOR 69 Welding, (Piping) Surface CPT KGAE Yes In-Process Document Review Defects VENDOR 70 Welding, (Piping) Rust on BDC DIC Ho In-Process Document Review Stainless 71 Mechanical, (Piping) Valve BDC KG&E No In-Process Document Review Leaking 72 Welding,(Piping) CPT No a) Grinding Marks a)KGAE a) Physical Inspection b) Weld Reinforcement b)DIC b) Physical Inspection 73 Welding, (Piping) Undercut CPT DIC No Physical Inspection 74 Mechanical, (Piping) Hold BDC DIC No Physical Inspection Tag 75 Mechanical, (Equipment) Gouges CPT DIC No Physical Inspection and Arc Strikes 76P(7) Electrical, Conduit Interference HGW DIC No Complete Document Review 76H(7) Mechanical,(Supports) BDC DIC No Complete Document Angularity Review (3) -

77 Mechanical, (Supports) Special BDC DIC Yes Complete Document Review Scope MTDN's cvn

TABLE I

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METil0D CSA .

CSA .

Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 78 Mechanical, (Supports) Conflict SB DIC/ No Complete Document Review in Drawings BECitTEL 79 Mechanical,(Supports) a) Conflict in Drawings a)BDC a)RECllTEL a)No a) Complete Document Review b) Undersize Vendor Weld b)CPT b)DIC b)No b) Complete Document Review 80 Mechanical (Supports) BDC DIC No Complete Document Review B.O.M. Error 81 Mechanical,(Supports) BDC DIC/ No Complete Document Review Possible Clamp Rotation BECitTEL 82 Mechnical,(Supports) BDC DIC No Physical Inspection Cotter Pin 83 NDE, (R.T.) Slag CPT KGAE No Complete Document Review Indications 84 NDE, (R.T.) Weld CPT KGAE/ Yes Physical Inspection Quality WESTING-Il0USE 85 NDE, (R.T.) Film CPT KGAE/ Yes In-Process Document Review Density WESTING- ,

il00SE 86 Mechanical,(Piping) BDC DIC No Complete Document Review ECR Issued in lieu NCR 87 Welding, Weld Profile CPT DIC No Physical Inspection

TABLE 1 SilMMARY OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 88 Mechanical,(Piping) BDC DIC No Physical Inspection Base Mat'l Indication -

89 Mechanical,(Welding) CPT DIC No Complete Document Review In Process Inspection 90 Mechanical,(Piping) CPT DIC No Complete Document Review Pin Hole in B.M.

91 Mechanical (Piping) BDC DIC No In-Process Document Review Missing Nuts on Valve 92 Welding,(Piping) CPT KGAE/ No Physical Inspection Improper Prep for P.T. VEND 0R 93 Hechanical,(Support) SB DIC No Complete Document Review Rust on Hanger 94 NDE, (R.T.) Weld Quality CPT KGAE/ Yes Physical Inspectinn a)RT Discrepancies WEST-b) Lead ID in RT Area of Interest INGHOUSE 95 Mechanical, (Piping) Arc CPT DIC No Physical Inspection Gauges 96 Mechanical, (Piping) Paint BDC DIC/ No Complete Document Review Chipping KG5E 97 Mechanical (Piping) Valve, BDC KGAE No Physical Inspection .

Flow Direction Missing 98 Mechanical, (Piping) ASME BDC DIC/ No Complete Document Review Class Changes at Coupling BECHTEL N

TABLE 1

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 99 Mechanical,(Supports) BDC DIC No Physical Inspection Dimensional Error ,

100 Mechanical, BDC KG&E No allPhysical Inspection a) Maintenance Records Missing HGW DIC b? Physical Inspection b)No Danger Signs c) Physical Inspection c) Exhaust Fan 101 Electrical, Missing HGW DIC No Physical Inspection (2)

Nameplate 102 Mechanical, BDC DIC a) Maintenance Records HGW a)No a) Physical Inspection Missing b)No Danger Signs b) Physical Inspection b)No c) Exhaust Fan c)No c) Physical Inspection 103 Mechanical, BDC DIC a) Maintenance Records HGW a)No a) Physical Inspection Missing b)No Danger Signs b)No b) Physical Inspection c) Exhaust Fan c)No c) Physical Inspection 104 Mechanical, BDC DIC a) Maintenance Records HGW a)No a) Physical Inspection Missing b)No Danger Signs b)No b) Physical Inspection c) Exhaust Fan c)No c) Physical Inspection

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TABLE 1

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 105 Mechanical. (Supports) BDC DIC No Physical Inspection Minor Traveler Discrepancies and Minor Offset in Support 106 Mechanical, (Piping) U.T. CPT DIC No Complete Document Review Prep for wall thickness test 107 Welding, Linear Indication CPT DIC No Complete Document Review Weld 108 Welding, Linear Indication CPT DIC No Complete Document Review Weld 109 Welding, Weld Splatter CPT DIC No Complete Document Review 110 Welding, Questionable CPT DIC No Physical Inspection P.T. Prep 111 Welding, PSI /ISI U.T. CPT DIC/ Yes Physical Inspection Prep KG5E 112 Welding, Hoop Shrinkage CPT DIC/ No Complete Document Review BECHTEL 113 Electrical, Clamp Missing- HGW DIC No Physical Inspection (2) 114 Electrical, Separation HGW DIC No Physical Inspection 115 Mechanical, Equip, Bolts BDC DIC No Complete Document Review Missing on Valve Plates

TABLE 1

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METiiOD CSA CSA Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 116 Electrical, Loose Flex ilGW Dic No In-Process Document Review 117 Welding, rust on SST CPT WESTitlG- No Physical Inspection weidment 1100SE 118 Welding, Weld Profile CPT KG&E No Physical Inspection VEND 0R 119 Welding, Overlap CPT KG&E/ No In-Process Document Review WEST.

120 Welding, Porosity CPT KG&E No Physical Inspection VENDOR 121 Welding, Excessive CPT DIC No Physical Inspection Reinforcement 122 Welding, Linear Indication CPT DIC No Physical Inspection 123 Mechanical,(Supports) BDC DIC No Physical Inspection Code Data & Documentation 124 Mechanical,(Supports) BDC DIC No Physical Inspection Loose Jam Nut 125 Mechanical,(Supports) BDC DIC No Complete Document Clamp Angle Off Review (3) 126 Mechanical,(Supports) BDC DIC a) Snubber Tension in Lieu a)No a) Complete Document Review of Comp.

b)0bstructions b)flo b) Complete Document Review-

TABLE 1

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METh00 CSA CSA Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 127 Mechanical,(Supports) BDC DIC No Complete Document Review BOM Calls for Snubber to be in Comp. Conflict with Traveler 128 Mechanical,(Supports) BDC DIC No Complete Document Review (Same as 127) 129 Electrical, No 0.C. HGW DIC No In-Process Document Review Documentation on Bus Bar Torquing 130 Electrical, Bolting of HGW DIC No In-Process Document Review Switchgear 131 Electrical, Bolting of HGW DIC No Physical Inspection (2)

Switchgear 132 Electrical, Conduit Touching HGW DIC No Complete Document Review Support

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133 Mechanical,(Supports) BDC DIC a) Wrong Size Washers a)No a)ln-Process Document Review b) CAR 25 b)Yes b) Complete Document Review c)2 instead of 4 Hole Clamp c)Yes c) Complete Document Review 134 Mechanical,(Supports) SB DIC No -

a) Loose Nuts a) Complete Document Review b) Hangers not Shimmed b) Complete Document Review

1 TABLE I

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 135 Mechanical,(IAC) BDC KGAE No Residue on Tubing In-Process Document Review 136 Mechanical,(I&C) SB WESTING- No Complete Document Review Holes in Concrete HOUSE 137 Welding, Underfill CPT KGAE No Physical Inspection VENDOR 138 Welding, Porosity CPT KGAE No Physical Inspection VEND 0R 139 Welding, Undercut CPT KG&E No Physical Inspection VEND 0R 140 Electrical, Flex Pulled HGW DIC No Physical Inspection from Connector 141 Mechanical,(I&C) SB WESTING- No Complete Document Review Anchor Spacing 1100SE 142 Mechanical,(I&C) BDC WESTING- No Complete Document Review Damaged Tubing & Gage 110USE 143 Mechanical,(I&C) BDC WESTING- No In-Process Document Review Loose Clamp 110VSE 144 Mechanical,(IAC) BDC WESTING- No Complete Document Missing / Loose Nuts on 110VSE Review (3)

Terminal Box

TABLE 1

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Action Method Concern Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 145 Mechanical,(Supports) BDC DIC No Physical Inspection Standing Water in Stanchions 146 Mechanical,(ISC) BDC WESTING- No In-Process Document Review Damaged Tubing and HOUSE Clamp Missing 147 Mechanical,(I&C) BDC WESTING-a) Damaged Tubing fl0VSE a)No a) Physical Inspection b) Hanger Not Installed

• b)No b) Physical Inspection 148 Mechanical,(ISC) BDC WESTING- No Physical Inspection Missing Valve Handle IIOUSE and Missing Clamp 149 Mechanical,(HVAC) CPT DIC No Physical Inspection (2)

Undersize Welds 150 Mechanical,(HVAC) CPT a) Welds Undersize a)KGAE a)No a) Physical Inspection VEND 0R .

. b) Dimensions b)DIC b)No b) Complete Document Review 151 Mechanical,(HVAC) a) Welds Undersize CPT DIC a)No a) Complete Document Review b) Grinding Embeds CPT DIC b) Physical Inspection b)No c) Documentation BDC DIC c)No c) Complete Document Review ,

152 Mechanical,(HVAC) BDC DIC No Complete Document Review -

Post Applied Plates 153 Mechanical,(HVAC) BDC DIC No Complete Document Review Welding on Gusset Plate OO

TABLE I

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Action Method Concern Responsible Responsible Plan Of-Number Description Individual (6) Organization Prepared Verification 154 Welding, Excessive CPT KG&E/ No Physical Inspection Weld Width VENDOR 155 Electrical. HGW a)No Inspection Record of a)KG&E/ a)No a) Complete Document Review Battery Rack DIC b) Nuts Missing from Battery b)KG5E b)No b)In-Process Document Rack Assemblies Review Potential Generic / Program Concerns 156 I&C, Tubing Damage FP KGAE Yes Complete Document Review OPS.

157 Supports, Hardware / BDC DIC Yes Physical Inspection Documentation Problems 158 HVAC, Conflict or Lack of FP DIC Yes Complete Document Uniform inspection Criteria Review (4) 159 Quality Assurance / Construction BP KGAE 0A Yes Complete Document Review Audits not to Schedule for 1st/2nd qtr. 1984 ,

160 Startup. SFR's not Being BP KGAE Yes In-Process Document Review Properly Utilized or Dis-positioned ,

161 Quality Assurance, SDL's not BP DIC Yes Complete Document Review

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Being Properly Utilized or Dispositioned

TABLE 1 St!MMARY OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Concern Action Method Responsible Responsible Plan Of Number Description Individual (6) Organization Prepared Verification 162 Implementation of Vendor FP DIC Yes Complete Document Review Instructions for Assembly and Installation of Mech-anical Equipment 163 Potential concern regarding FP KGAE Yes Complete Document Review the Completeness of QC DIC Inspection Criteria.

164 A Generic Problem with Regard HGW DIC Yes Physical Inspection (5) to the Fasteners (e.g., Nuts, In-Process Document Review Bolts, Washers) Used for On-Site Assembly and Installation -

of Electrical Equipment.

165 A Problem with Unistrut Wall HGW DIC Spreading and Possible loss Yes Physical Inspection BECHTEL of Capability to Support Electrical Conduits.

166 A Problem with the Established BDC DIC Yes Physical Inspection Construction Contractor Drawing Change Control Procedures in the Area of Special Instruction Sheets ,

167 Welding, Concern with the CPT Quality of Field Fabricated Yes Physical Inspection DIC -

ANSI B31.1 Piping Welds -

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TABLE I

SUMMARY

OF CSA CONCERNS AND CORRECTIVE ACTION VERIFICATION METHOD CSA CSA Action Method Concern Responsible Responsible' Plan Of Number Description Individual (6) Organization Prepared Verification 168 Welding, Concern with HVAC CPT DIC Yes Physical Inspection Support Attachment Welds 169 Welding, Concern with Visual CPT KG&E Yes Physical Inspection (5)

Acceptance of Vendor Fabri- In-Process Document Review cated Piping Welds 170 Startup Improper Use of BP KG&E Yes In-Process Document Review the System for Controlling DIC Nonconforming Conditions for Equipment Turned over to KGaE.

FOOTNOTES TO TA2LE 1

1) The verification was based in part on the extent of the original CSA inspection. No additional field inspection was perfnrmed as part of corrective action since disposition of NCR condition was use-as-is.

2) Though the work was verified complete, the associated NCRs or other documents had not yet been closed out.

3) Item was judged by Delian to be of minor significance so although field verification was feasible, only a document review was warranted.

, 4) As part of the corrective action, a reinspection of 56 duct hangers was performed by DIC at Delia'n request.

Q.C. Checklists were prepared and signed off as part of this inspection and are included in the file.

5) A portion of the work associated with Generic Concerns 164 and 169 remains to be performed. That which had been completed was inspected.

6) Initials are for following Delian personnel: GY-George Young, HGW-Henry Wong, BDC-Brian Carter, SB-Steve Baron, CPT-Pat Thompson, BP-Brien Palmer, FP-Frank Pimentel.

7) Two number "76" were inadvertently assigned during the original CSA inspections. The letter designator was '

assigned to distinguish these tw3

TABLE 2 KG&E QA VERIFICATIONS REQUIRED FOR CSA CORRECTIVE ACTIONS Concern Required KG&E Action 26 Verify implementation and closure of NCR ISN 21268 E 54 Perform surveillance to determine how unauthorized temporary supports are being installed and removed and take appropriate corrective action.

55 Verify closure of NCR ISN 55503-J including follow up of W ,

sample of tube supports.

61 Verify implementation and closure of NCR ISN 17199 E

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62 Verify implementation and closure of NCR ISN 17199 E 68 Verify disposition, implementation, and closure of NCR ISN 21241 PW 69 Verify disposition, implementation, and closure of NCR ISN 21241 PW 70 Revise CWP EG-854-M to require leaking valve to be repaired, verify fix, and verify closure of CWP.

71 Verify disposition, implementation, and c1'sure o of RIR RCME 3041 GN1 85 Verify disposition, implementation, and closure of FDR 11083 -

91 Verify disposition, implementation, and closure of RIRs RCME 2623 EM and RCHE 2624 EM.

116 Verify implementation and closure of CWP AL 464 E and closure of NCR ISN 20301 E.

119 Verify disposition, implementation, and closure of FDR SAPN 11081.

129 Verify implementation and closure of NCR ISN 20674 E.

130 Verify implementation and closure of NCR ISN 20682 E.

133(a) Verify disposition, implementation, and closure of NCR ISN 21331H.

-31 . .

2-R-85-015

TABLE 2 (CONT.)

KG&E QA VERIFICATIONS REQUIRED FOR CSA CORRECTIVE ACTIONS Concern Required KG&E Action 135 Verify closure of NDC I-0035-W; verify resolution of deficient condition (i.e., issuance and closure of proper resolution documentation).

143 Verify disposition, implementation, and closure of NCR ISN 55488 J.

146 Verify closure of NDC I-0034-W; verify resolution of deficient condition (i.e., issuance and closure of proper resolution documentation.)

155(b) Verify closure of RIR RCME 3032 NK and implementation and closure of CWP NK 177.

160 Complete and close CAR 18 and Work Hold Agreement 22.

164 Verify implementation and closure of NCRs ISN 20674E, 1SN 20681 E, and ISN 20682 E.

169 Verify disposition, implementation, and closure of NCR ISN 21241 and FDR SAPH 11081; may require additional inspection if a problem exists.

170 Complete and close QPV 12/84-01. .

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2-R-85-015

1 TABLE 3

SUMMARY

OF REJECTED VERIFICATIONS Concern Basis for Rejection Number Description of Concern of Corrective Action 34 Pipe supports - incorrect piece BOM not annotated with numbers on parts number of SDL used to document deficiency.

/0 Valve EGV144 has rust contami- Rust contamination nation on stainless steel weld- existed at time of ments. Delian reinspection; valve was leaking.

71 Valve GNV004 leaking onto in- Valve was leaking at sulation. the time of Delian re-inspection.

/2 Grinding marks 3/32" deep adjacent Insulation prevented re-to weld. inspection.

123 Improper attachment of code data BOM not annotated with tag. number of NCR used to document deficiency.

124 Loose lock nut on pipe clamp. Lock nut loose at time of Delian reinspection.

. 133 1/4" rather than 3/8" washers 1/4" washers installed in on pipe clamp. parallel with NCR approving use-as-is dis-position for 3/8" washers. -

2-R-85-015

TABLE 3 (CONTINUED)

SUMMARY

OF REJECTED VERIFICATIONS Concern Basis for Rejection Number Description of Concern of Corrective Action 135 Foreign material on instrument Small tenporary mark left on tubing. at one location on tubing after QC inspection of the tube cleaning.

143 Damaged instrument tubing. Tubing damage existed at time of Delian reinspec-tion.

146 Damaged instrument tube hardware. Hardware damage existed at time of Delian rein-spection.

2-R-85-015

TABLE 4

SUMMARY

OF N0ST IMPORTAfiT CSA CONCLUSI0t!S AND ASSOCIATED RESOLUTI0tl CSA Concern Conclusion Reference U) flo(s) Resolution Cleanliness problems and continuing Pages 2, 135, 142, Program for testing and reinspec-minor damage to instrument tubing and 11-8 143, 146, tion leading up to operation hardware suggesting need for reinspec- 156 investigated and found to be tion prior to operation. adequate.

Improper implementation of vendor in- Pages 2, 35, 129, Complete reinspection and cor-structions and fastener hardware for on- II-6 130, 131, rection of all electrical equipment site assembly and installation of elec- 155, 164 shipped in sections.

trical equipment shipped in sections.

' Possible generic problem with spre6*ing Pages 2, 24, 165 Designer accepted general condition (not in accordance with design) of the 11-2 use-as-is.

walls of unistrut used to support elec-trical conduit.

Potential generic problem with regard to Pages 3, 5, 157, 158, Investigation indicated only one completeness of Q.C. inspection criteria. VII-2, VII-3 163, 164 area in which lack of more specific Q.C. inspection criteria may have affected the hardware (electrical equipment fasteners) and this problem was corrected.

Potential failure of the Special Instruc- Pages 6, 126, 127, For areas in which problems were tion Sheet portion of travelers to incor- III-6 128, 133, identified, corrective actions porate the latest design requirements. 158, 166 were taken and the problems re-solved.

Concern with quality of a number of field Pages 4, 87, 121, Further field inspection, testing, I

fabricated piping welds to ANSI B31.1. IV-4, IV-5 122, 167 and blending revealed that the -

welds in question were acceptable.

E mtB

TABLE 4 (CONTINUED)

SUMMARY

OF MOST IMPORTANT CSA CONCLUSIONS AND ASSOCIATED RESOLUTION CSA Concern Conclusion Reference No(s) Resolution Problems with the system for controlling Pages 6, 160, 170 Corrective action to resolve these non-conforming conditions for turned over VIII-5 problems has either been taken or equipment. is under way.

Multiple deficiencies with hardware and Pages 3, 18, 33 The minor deficiencies were found documentation for pipe supports sug- III-4, III-5, 79, 123, to be non-repetitive; the more gesting possible program problem. III-6 133, 157 important deficiencies were each investigated, corrected, and found to be isolated problems.

QA audits not performed in accordance Pages 5, 159 Further investigation of QA audit with audit schedule. VIII-2 program confirmed that mechanisms are in place to assure that highest priority activities are audited and to assure that resources exist to perform these audits; no violation of Appendix B, ANSI, or FSAR re-quirements occurred.

Potential problem with control of Page 6 111, 84, The individual concerns with vendor quality of vendor activities. 85, 162, welds and vendor radiographs were 164, 169 determined to either not violate requirements or to be isolated problems; the electrical fastener problem was determined to be un-related to management of quality of vendor activities.

TABLE 4 (CONTINUED)

SUMMARY

OF MOST IMPORTANT CSA CONCtUSIONS AND ASSOCIATED RESOLUTION CSA Concern Conclusion Reference No(s) Resolution Potential problem with HVAC hanger Page 4, 149, 150, Extensive reinspection was per-overhead attachment weld quality. IV-5 151, 168 formed on hangers with that over-

' head geometry which created a potential for unacceptable welds; minor undersize conditions were found which the A/E accepted on a use-as-is basis.

NOTES:

(1)The pages in this column are from the Reference (1) report.

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REFERENCES

1. Wolf Creek Nuclear Generating Station Construction Self Assessment.

Performed by Delian Corporation for Kansas Gas and Electric Company.

August 28, 1984.

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e 2-R-85-015

ATTACHMENT A DESCRIPTION OF CSA CORRECTION ACTION PROCESS 4 h 2-R-85-0IS

KANSAS GAS AND ELECTRIC COMPANY m mm WOLF CREEK GENERATING STATION December 4,1984 Mr. David E. Leaver CSA Project Manager Delian Corp.

1340 Saratoga - Sunnyvale Road Suite 206 San Jose, CA 95129 KQWLO 84-138

Subject:

KG&E Procedure Approval Ref: KG&E P.O. 45606 Supp. No.1

Dear David:

~

KG&E Quality has reviewed and found acceptable for use Delian's procedure

" Description of Construction Self Assessment (CSA) Corrective Action Process", Revision 2.

Additionally, because of the amount of time necessary to closeout certain

, findings, it has beccxne obvious that Delian will not be able to perform final verification for all of the concerns. Therefore, upon concurrence of KG&E, Delian shall closecut those verification packages be describing what actions they have verified to date 'and what additional corrective / verification actions will be taken by KG&E. KG&E Quality Assuranc'e shall then assume resonsibility for those packages. Details of this transfer shall be coordinated by Mr. Carl Parry, Superintendent--Quality Systems Engineering.

This letter will also serve as KG&E's formal approval of the addition of Mr.

James A. (A1) Johnson to Delian's CSA team.

Sincerely, KANSAS GAS & ELECTRIC CO.

Q l / $1&Y R.M. Grant Director - Quality ec: C.E. Parry J. Wesbrooks .

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DELIAN CORPORATION i

! 1340 Saratoga-Sunnyvale Road-Suite 206 San Jose, California 95129 November 21, 1984 f Richard Grant ~ ---

l Quality Assurance Corporate Manager

• Kansas Gas and Electric Wolf Creek Generating Station New Strawn, Kansas

Dear' Dick:

Attached is Revision 2 of Delian Corporation's Construction Self Assessment (CSA) Procedure for control.and management of corrective actions and closure of CSA concerns. This revision was made to include Al Johnson as a qualified verifier and to document a proceas for CSA people to inform KG&E on nonconform-ing conditions outside the scope of CSA. Should you have any questions, please feel free to call me at extension 1262.

Sincerely, l

J, l

David E. Leaver Delian Corp. CSA Project Manager l DEL /dh l

l l

cc: Carl Parry, KG&E Q.A.

l Brian Carter,- CSA Brien Palmer CSA l Frank Pimentel, CSA l Pat Thompson, CSA Henry Wong, CSA Al Johnson, CSA I

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nev 1310![ 4, ( ; 1/ ,* l / 64 )

Page 1 of 3

. And Exhibits A and B; as Appendix I DESCRIPTION OF CSA CORRECTIVE ACTION PROCESS 1.0 SCOPE Delian's Procedure " Description of Construction Self Assessment (CSA) Corrective Action Process" delineates the implementation and responsibilities, Phase II, related to management and resolutions of concerns resulting from Delian's CSA Inspection.

2.0 OBJECTIVE The objective of this procedure is 'to assure adequate i

CSA technical review, management and closure of corrective actions and to assure that KG&E, contractor (s), and other agencies understand the actions requrired by CSA to resolve CSA concerns.

3.0 DEFINITIONS Definitions relative to this procedure and CSA activities are as follows:

3.1 PHASE I CSA activities commencing with initial documentation preparation and field inspections and terminating with transmittal of CSA final inspection (August 29, 1984) report to KG&E.

3.2 PHASE II CSA activities commencing after transmittal of ' final report to KG&E (August 29, 1984), preparation of case specific and generic action plans, evaluation of corrective action (s), and verification of corrective action (s) ,

terminating with transmittal of final corrective action report to KG&E.

3.3 CSA Case Specific Concerns: CSA Findings as a direct result of Phase I inspection activities.

3.4 CSA Generic Concerns: A CSA concern indicating a possible programmatic deviation / noncompliance or a widespread hardware noncomplimice. Generic Concerns are typically based on a group of common Case Specific and/or Generic Concerns relating to hardware and/or software. .

3.5 All CSA concerns shall be documented on the Exhibit A form. The Exhibit B form shall be used in addition for the Generic Concerns and the Case Specific Concerns requiring a detailed written action plan.

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Page 2 of 3 4.0 EXHIBITS AND APPENDICES j 4.1 Exhibit A - CSA Concern Closure Form 4.2 Exhibit B - CSA Corrective Action / Verification Form 4.3 Appendix I - Flow chart describing the Delian Process for Evaluation, Verification, and Closure of Corrective Actions.

l 5.9 PROCEDURE i

The Delian interface with KG&E QA during the corrective action /verifica;~

tion process is twofold. First, the existing KG&E (as well as contractor) quality program corrective action mechanisms are being used as appropriate.

Thus, the Delian role is not being performed under a formal QA program, but rather, relies on existing on-site programs and this procedure.

Second, KG&E QA is directing contractors to perform corrective actions in accordance with Delian requirements. Delian shall be the final author-ity on the requirements for corrective actions and the type of verifica-tion, i.e., physical inspection or document review.

Nonconforming conditions which are noticed by CSA personnel during the course of corrective action acceptance or verification but which are l outside the scope of the original CSA inspection shall be documented in j a memorandum to KG&E QA but shall not be included in the CSA process.

The following steps are required for the processing of CSA Concerns:

5.1 Processing of CSA' Case Specific and Generic Concerns on Exhibit A.

5.1.1 Review corrective action and supporting documentation for technical adequacy.

5.1.2 Document acceptance or rejection.

l 5.1.3 Inform responsible organization of need for further action /

information if response is inadequate. -

5.1.4 Upon acceptance response, conduct review and/or inspection to verify satisfactory implementation or corrective action.

5.1.5 If implementation is unsatisfactory, inform responsible l organization of need for further action.

5.1.6 When implementation is satisfactory, complete verification and closure blocks.

5.1.7 Transmit completed package to KG&E QA Manager for review to ensure all required corrective actions have been completed, verified, and documented by Delian and the responsible i organizations.

Page 3 of 3 5.2 Processing of CSA Generic Concerns; Specific Concerns requiring a detailed and Case written action plan. (Processing shall be on Exhibits A &

B.)

5.2.1 Review corrective action and supporting documentation for technical adequacy.

5.2.2 Document acceptance of response on Exhibits A & B; document rejection on Exhibit A.

5.2.3 If response inform is rejected,~

responsible organization of need for further action /information on Exhibit A.

5.2.4 Upon acceptable response, conduct review and/or inspection to verify satisfactory implementation of corrective action.

5.2.5 Document acceptance of implementation on

- Exhibit A & B; document rejection on Exhibit A.

5.2.6 If implementation is rejected, inform responsible organization of need for further action on Exhibit A.

• 5.2.7 When implementation is acceptable, document acceptance in accordance with paragraph 5.2.5.

5.2.8 Transmit completed package to KG&E QA Manager for review to ensure all required corrective actions have been completed, verified, and documented by Delian and the l responsible organizations.

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l PREPARED BY: b -_ APPROVED BY:

l David Leaver David Leaver l

.j, 3; A

'P$ae 1 of 3 CSA CCNCERN CLOSt.dr TCPy, Concern No. Response Rev.

Responsible Org.

Concern Sunnary: '

Response: -

(Attach and reference supporting docu=ents)

RESPONSE

TO CSA CONCERN l

Ore. Title Prepared by: Print Name Signature /Date ooNeutr&Ete"By: Ext. -

Accept l Further. Action / Info Req'd Remarks: .

(Include requests for further action /infor=ation, if applicabl )

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CSA EVALUA-TION Print Name Signa ture/Da te Ext,

! Accept s___

Reject Remarks:

1 1

1 CSA

UERIFI-CATION 1

l Print Name Signature /Date Ext.

CSA ,

} CLOSURE Approved by:

Print Name Signature /Date Ext.

Page 2 of 3 EXHIBIT A DELIAN CORPORATION CSA CONCERN CLOSURE FOPM INSTRUCTIONS HFADING ,

CSA will record the concern no., revision of response, and responsible organization. Responses for which further action or information is requested will result in issuance of the next subsequent revision number. -

CSA will briefly sunnarize the concern. Soeci.fic detail is found on the applicable "CSA Field Inspection Concern Form" and in the body of the Construction Self Assessment Report.

, RESPONSE 'IO CSA CONCERN

' The respondent will provide the response, either directly or by reference to attachment doctruents. All documents referenced in the response should be

provided and attached.

The respondent will identify his- or herself in the space provided.

Occasionally, CSA will request concurrence from a specific source. In these cases CSA will fill in the appropriate "Org." and " Title" blocks. Note that concurrence may be requested frcm scmeone outside the preparer's organization.

CSA EVALUATION The response will either be judged acceptable, or further information or action will be requested. In the latter case, the remainder of the form will be left blank, and closure.will be acccuplished on a new revision of the form. CSA will distribute copies of both the evaluated response and of the new revision to be used. See note below regarding signatures.

CSA VERIFICATION CSA will verify implenentation of an acceptable response as appropriate.

The basis of the verification (e.g., physical inspection, doctrnent review, etc.) will be documented by the CSA individual. Disapproved verifications will be processed as described for disapproved CSA Evaluations. See note below regarding signatures.

CSA CLOSURE CSA concerns will be closed by a CSA Project Manager.

NCTTE: CSA signatures denoting acceptance of response and acceptance of verification will be signed (or if currently signed, will be counter-signed before closure) by a CSA individual with qualifications in the appropriate area. Page 3 of this exhibit lists CSA individuals and their areas of expertise.

.....,-.r.n,- -,n-.,,-,,.----,n.,.--,. , ,

Page 3 of 3 EXHIBIT A Area of Expertise Qualified CSA Individual Mechanical Brian Carter Steve Baron Al Johnson Electrical Henry Wong Brian Carter Brien Palmer (cable, cable tray, and conduit only).

Civil / Structural George Young Brien Palmer Instru=entation Steve Baron (Mechanical only)

Frank Pimentel (Mechanical only)

- Brian Carter (Mechanical / Electrical)

Al Johnson (Mechanical only)

Welding /NDE Pat Thompscn Frank Pimentel Brian Carter (Visual only)

Quality Program Brien Palmer Frank Pimentel Brian Carter CSA Project Managers Frank Pimentel David Leaver

EXHZBIT B Page 3 of 3

' DELIAN CORPORATION CSA CORRECTIVE ACTION / VERIFICATION FORM INSTRUCTIONS CSA Corrective. Action / Verification (CAV) forms are to be used in conjunction with all generic CSA concerns. In addition, these forms may be used for case-specific CSA concerns where the required corrective action is felt to be extensive or detailed enough to warrant its use.

All CSA concerns, generic and specific, will also be tracked by the CSA Closure Forms (refer to Closure Form Instructions).

All entries on the CAV form shall be completed (including "N/A" entries) prior.to However, closure by CSA. scrne entries will remain blank pending in-process investigation and corrective action.

HEADI?G Enter appropriate date, including CSA concern revision status.

PART I: REQUIREMENT

_ Enter the appropriate requirement.

PART II: FINDI?G Provide a brief description of the concern.

PART III: RECOtt'INDATIONS Provide the required corrective action (" action plan") in the expected chronological order. Where corrective action is required for specific items of hardware or doctrnentation, provide sufficient reference thereto. Cm.plete Page 2 (Continuation Sheet) of the CSA Corrective Action / Verification Form if additional space is required.

Indicate in the space provided "See Attachment".

PART IV: CORRIETIVE ACTION TAKEN Describe corrective action taken, either directly or by reference to appropriate file documentation received. Indicate CSA acceptance * (pending verification) by signature and date in the blocks provided. Signature should be by a CSA individual qualified in the appropriate area.

i PART V: VERIFICATION Provide description of verification steps taken.

PART VI: ACCEPTANCE Indicate CSA acceptance

• by signature of the assigned CSA individual and date in the prcper space provided. The basis of the verification (e.g., physical inspection, document review, etc.) will be documented by the CSA individual. Signature should be by a CSA individual qualified in the appropriate area.

PART VII: CCEPTANCE AND r rnSURE The CSA Project Manager shall signify closure of the concern by signature,in the appropriate space.

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Rav.0 7/1 -

DELIAN # "" '"**'l CSA ACTION / VERIFICATION FORM CORPORATION DESCRIPTION OF CONCERN - '

DATE PAGE _ 0F ,

ACTION P W C -

VERIFICATION PLAN ]

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, CSA ACTION PIAN PREPARER -

CSA VERIFIER _

DATE 4

CSA TEAM p n _

DATE

ExHISIT S

?*ge ' vf 3 DELIAN CSA CORRECTIVE ACTION / FIV.0 9/Ij' CORPORATION VERIFICATION FORM CSA NUMEF.R _

DATE PAGE -

_ 0F CONTROLLING LOCLT..NT _

CSA SUBJECT LOCATION / ORGANIZATION ISITIAICR APPROV?.D BY I. .EQUIREhi.NI II. FINDING d

III.

FICO.ENDATIONS/ PROPOSED CORRECTIVE ACIION -

SCFDULE.D/ COMPLETION DATF.

RESPONSIBILIIY EOR CORRECTIVE ACTION IV. CORRECTIVE ACIION TAUM DATE COMPLETED -

APPROVED (RESPONSIBLE AUTdORIIT)

V. VEU FICATION OF CORRECTIVE ACTION:

VI. CORRECTIVE ACTION STATEMEh7 ACCEPTED ATL

• DATE VII.

ATLCORRECTIVI. ACTION ACCEPTED DATE DISTRIBUTION: -

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I f DELIAN PROCESS FOR EVAL,UATION AND VERIFICATION AttrIONS OF CORREcr VE 4

Review corrective action '

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cnd aunporting documenta- Inform respons.ihte tion for technical adequacy.

> Is it adequate? No - -> organization of neve Step (1) l for further act lon. '

Yes Step (2) b --

Signature accepting G -

written response. -+ londuct review an.1/

or inspection to Inform re-Step (3) verify satisfactory _.

Implemented sponsibic r arganizatior implementation of satisfactorily? H J of need for corrective actfon.

further Step (4) action.

Yes Step (".) ,.

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Sinnature verifying

corrective action

_ complete.

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CSA management review and signature for clokure.

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Attachment B to KMLNRC 85-036 ATTACHMENT B -- --

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Identified by NRC

/.jin Tracy Black (Inapsetor)

(1) Problem: Lower spreader room,'lJ1G5C/lJ1G60, minimum bend radius c~oncern.

J1P cable has. l.75" allowable. Cables are: lJEIO2NC, lLEI12AB, ILFIllBB, ILFIllCB, and lLFIllLB. E-lR3514 Revision 4. First addressed by NRC on 10-27-84. NRC questioned how the actual bend radius measurement was calculated.

Response: 2" bend radius actually found. The-bend radius was verified by the use of a template.

(2) Problem: Diesel Generator, West room, East wall South end, adequate fire' barrier cover concern. Tray 4UlC72/74 with conduits 5U5010, SU5011, SU3E3N, 6U3E3E, and 6U3E3M. First addressed by NRC on 10-27-84.

Response: Installation is presently within the guidelines of Paragraph 3.36.5 E-lR8900.

(2a) Problem: NRC is concerned that E-lR8900 paragraph 3.36.5 does not adequately address requirements of FSAR 8.3.1.4.1.1 and Reg. guide #175.

Response: Bechtel to evaluate and respond.

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/I 3.36 111ni=u= separation required between redundant conduit A.' .

between redundant tray / conduit systems.

systems and

/

/ 3.36.1 The minimum separation distance between conduit systems and e'

/ between tray / conduit systems must be naintained between all dif f erent Class IE separatien groupe and between Class IE separation groups and Ecn-li separation P.roups. It does not ~

g* apply to separation between BOP separation r.roups 5 & 6 nor to g{ separation distances within a, separation group.

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3.36.2 Installation tolerances shall not be used to violate the 1 inch 2I minimum separation distance as defined in 3.36.3, 3.36.5 &

3.36.6.

} 3.36.3 Minimum separation berusen different Class IE conduit systems and

.I.

[;] minimum separation between Class IE conduit systems i Non IE conduit systems shall be 1". Separation shall he measured

.g ~ between the outside edges of the conduit.

)

$h 3.36.4 Minimum separation between 1) Class IE conduit and Class II yj-}* tray of different separation groups and 2) Class IE conduit and Kon-IE tray shall be as follows: Separation shall be measured g; fro = the tray siderail to the outside edge of the conduit.

.y9 a) All areas except the cable spreading areas.

,9 x 1) Minimum separation of 3 ft. horizontal.

gj 2) Minimum separation of 5 ft. vertical. _

• ", j b) Cable spreading areas (including Main Control Room)

1. 1) Minimum separation of 1 f t. horizontal.

g (1}~.j,1 5 g {-

2) Minimum separation of 3 ft. vertical.

3.36.5 Minimum separation between Non-It conduit and Class IE tray shall be 1". Separation shall be measured from the tray siderail to 5 y ~j the outside edge of the conduit.

5V' 3.36.6 Mini =u= separation of 1 inch in 3.36.3 & 3.36.5 must be maintained

'g I w No barriers will be added. In cases where the minimum separation

{[h Kjz distances outlined in 3.36.4 can not be maintained a Tray Cover

( y" must be installed with a minimum of 1 inch separation between the Tray Cover and the conduit.

jb 3.36.7 Typically, Covers shall be noted on the raceway drawings.

r-[ Cuidelines to enable the constructor to establish the required I ; in barrier lengths and the quantity of trays in a stack to be

%f5 covered are given in the fire barrier section of E-lR8900 starting

{j[ on Sheet 49. Only one set of covers need be installed on a giver, iE ,

• tray even though covers may be shown for the same tray on more thas

%fl E.j one drawing. The cover shall be installed so as to satisfy the 3 combined separation requirements of the raceway shown on all the drawines.

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(43) Problem: Cubicle NG02BDR2 Cable # 4EFG08BB white wire / black tracer, has no temp. mod. tag. Is it required?

Response: .No mod. tag is required. The conductor is a spare conductor per the latest revision of E-017000.

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(44) Problem: In Control Room troughs 2JR002 and 4JR004 - Free aired cable be-

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tween conduits and floor. troughs. Also, same conduits up above going into 5" trays. .

Response: DIC investigation has confirmed that the conduits 2J3009 and 4J3010 as shown on E-IR 3910 Revision 0 are installed per current design. .

Separation for the free aired cables between the conduits and troughs are acceptable based on the l'-0" horizontal and 3'-0" vertical sepa-ration dictated by E-IR 8900. Actual measurement between the conduits is 17".

(45) Problem: Separation violation between 4J1ClZ and a communication conduit in Diesel Generator Building.

Response: NDC written by Engineering and is at Quality for processing.

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WC-AP-077.6 NOTIFICATION OF DISCREPANT CONDITION Rev. 5-14-84  ;

TO: KG&E STARTUP NCR/NDC COORDINATOR NDC #

DATE:  !

IDENTIFICATION OF AREA AND ITEM: hC[ A fA-7f'd3/ F/'o/g 7e'd / AdNNA/

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2 - # eo'u SYSTEM DESIGNATIQN: -

TURNOVER DATE:

THE FOLLOWING CONDITION WAS OBSERVED BY DIC. THIS NDC SERVES AS FORMAL NOTIFICATION TO THE APPROPRIATE KG&E PERSONNEL FOR EVALUATION AND RESOLUTION AS DEEMED APPLICABLE.

DISCREPANCT: h k $ f A A f k 7/os/ $//dl#7t'os/ ext's XT J$f7Wes/

N $_f C 1 R AA/D A C o m s t k y o'e n ro o* d g C cx//J u r' 7 NT N' FA s 7 of A A o n/ TA s Sea 7A FAc e oP C8 A7 [L 30/V' A/EC- Ccutta rW' A

ORIGINATOR: [

SUPERVISOR:

[

RESOLUTION:

I STARTUP ENGINEER:

STARTUP QC ENGINEER:

cc: KG&E Project Quality Supervisor KG&E Manager Quality Assurance (WCGS)

KG&E Constructica Manager - Staff Assistant

.0

CERCRS IDENTIFIER 38400119 -~, ,

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CASE TITLE: FIELD-RUN CABLES USED IN BECHTEL DESIGN ARE ( d' . A . '

DEFICIENT (* / a <. s . . ,

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NRC REGION NUMBER: 0 --NRC HEADQUARTERS REPORT TYPE: 4 --

10 CFR 21 RESULTING FROM A 10 CFR 50.55(E)

FIRST REPORT DATE: 3/19/1984 SYSTEM: EC --LOW VOLTAGE AC (LESS THAN 600V)

PRIMARY COMPONENT: CBL --CABLE / WIRE SECONDARY COMPONENT: ZVZ --VALVE. UNKNOWN TYPE, UNKNOWN MATERIAL HOW DISCOVERED: P --

PERIODIC SURVEILLANCE AND INSPECTION WHO DISCOVERED: CO -- CONSTRUCTOR (SITE CONSTRUCTION CONTRACTOR)

CAUSE STAGE: D --

DESIGN PURPOSE: T --

THERNAL REASON: S --

WRONG STANDARD OR SPECIFICATION MANUFACTURER: VO29--VALCO DEFICIENCY 901 FIELD-RUN CABLES TO VALCOR SOLENOID VALVES (50 VALVES EACH AT THE CALLAWAY AND WOLF CREEK SITES) ARE SPECIFIED FOR 90 C USE BUT ARE SUBJECTED TO 150 C SERVICE.

CAUSE: 901 CABLE WAS INCORRECTLY SPECIFIED.

OTHER INFORMATION: 001 AFFECTS VALVES IN SEVERAL SYSTEMS. MAY AFFECT ALL OTHER BECHTEL NUCLEAR PROJECTS.

BECHTEL IS CURRENTLY PROCURING OUALIFIED HIGH TEMPERATURE CABLE FROM VALCOR.

ASSIGNED NRC STAFF 4

4 REPORT ITEM 3 q

REPORT DATE: 3/19/1984

REPORT CLAOS: I ACCESSION NUMBER: 0003230108 DATE FORM WAS CODED: 4/19/1984 CODER INITIALS: JT SUBMITTOR'S !.D. CODE: B130 REPORT SEQUENCE # 00000119 FACILITIES AFFECTED: O 482 --WOLF CREEK 1 3 483 --CALLAWAY 1 2 486 --CALLAWAY 2 CERCRS IDENTIFIER 28400231 CASE TITLE: LOAD SHEDDER EMERGENCY LOAD SEQUENCER MISSING WIRES SUBMITTOR'S FORM ID: 84-52 NRC REGION NUMBER: 4 --MID-WESTERN STATES REPORT TYPE: 2 --

10 CFR SO.55(E)

FIRST REPORT DATE: 3/30/1984 SYSTEM: EB --MEDIUM VOLTAGE AC (35KV TO 600V)

PRIMARY COMPONENT: CBL --CABLE / WIRE SECONDARY COMPONENT: SEQ --SEQUENCER HOW DISCOVERED I --

INITIAL /PREOPERATIONAL TESTING WHO DISCOVERED: LI -- LICENSEE CAUSE STAGE: F --

FABRICATION / MANUFACTURE PURPOSE: Y --

NOT APPLICABLE REASON: T --

IMPROPER TURNOVER MANUFACTURER: C560--CONSOLIDATED CONTROLS CORP.

DEFICIENCY 001 DURING COMPONENT TESTING, IT WAS DISCOVERED THAT VENDOR WIRES WERE MISSING FROM 2 LOGIC RACK ASSEMBLIES (NF173-1 &-2) OF THE LSELS. WIRES ARE TO CONNECT SEQUENCER AND RELAY DRIVER. RELAYS NIGHT NOT HAVE WORKED IN UNDER VOLTAGE CONDITION.

. CAUSE: 001 FABRICATION ERROR.

OTHER INFORMATION: eOI REPAIRS WERE MADE BY VENDOR

ASSIGNED NRC STAFF REPORT ITEMS REPORT DATE: 3/30/1984 REPORT CLASS: FO ACCESSION NUMBER: 8404090343 DATE FORM WAS CODED: 5/ 1/1984

• CODER INITIALS: JH SUBMITTOR'S I.D. CODE: KGE --KANSAS GAS & ELECTRIC CO.

REPORT SEQUENCE # 00000231 FACILITIES AFFECTED: 482 --WOLF CREEK 1 CERCRS IDENTIFIER 28400912 CASE TITLE: MECHANICAL CABLE TERMINATION LUGS NRC REGION NUMBER: 4 --MID-WESTERN STATES REFORT TYPE: 2 --

10 CFR 50.55(E)

FIRST REPORT DATE: 12/16/1983 SYSTEM: ZZ --UNKNOWN PRIMARY COMPONENT: CBL --CABLE / WIRE SECONDARY COMPONENT: CON --CONNECTOR HOW DISCOVERED: Z --

UNKNOWN WHO DISCOVERED: LI -- LICENSEE CAUSE STAGE: Z --

UNKNOWN PURPOSE: Z --

UNKNOWN REASON: Z --

UNKNOWN q

4 DEFICIENCY 901 CONCERNS MECHANICAL CABLE TERMINATION LUGS.

4 CAUSE 801 NOT STATED.

OTHER INFORMATION: 001 NO DAMAGED MECHANICAL TYPE LUGS WERE I FOUND DURING INSPECTION OF SAFETY-RELATED

, LOAD CENTERS. CONDITION IS NO LONGER

CONSIDERED REPORTABLE.

ASSIGNED NRC STAFF REPORT ITEMS REPORT DATE: 6/15/1984 REPORT CLASS: FO ACCESSION NUMBER: 8406210088 DATE FORM WAS CODED: 7/24/1984 CODER INITIALS: JT SUBMITTOR'S I.D. CODE: KGE --KANSAS GAS & ELECTRIC CO.

REPORT SEOUENCE #3 00000912 FACILITIES AFFECTED: 482 --WOLF CREEK 1 CERCRS IDENTIFIER *:8401499 CASE TITLE: IN-CORE THERMOCOUPLE ADAPTOR CABLE CONNECTORS NRC REGION NUMBER: 4 --MID-WESTERN STATES REPORT TYPE: 2 --

10 CFR 50.55(E)

FIRST REPORT DATE: 9/ 5/1984 SYSTEM: AA --REACTOR CORE PRIMARY COMPONENT: CBL --CABLE / WIRE SECONDARY COMPONENT: CON --CONNECTOR HOW DISCOVERED: S --

SPECIAL TEST AND INSPECTION WHO DISCOVERED: LI -- LICENSEE CAUSE STAGE: O --

ON-SITE CONSTRUCTION PURPOSE: I --

INSTRUMENTATION / ELECTRONICS / CONTROLS REASON: R --

MISHANDLING DEFICIENCY: e01 MORE THAN HALF OF THE CLASS 1E THERMOCOUPLE CONNECTORS FOR THE IN-CORE THERMOCOUPLE ADAPTOR CABLES WERE FOUND TO ____

HAVE CRACKED OR BROKEN INSULATION INSERTS.

CAUSE: 001 MISHANDLING IN THE FIELD MAY BE THE CAUSE OF THE DAMAGE.

OTHER INFORMATION: 901 KG&E HAS ELECTED TO REPLACE ALL OF THE IN-CORE THERMOCOUPLE ADAPTOR CABLE CONNECTORS WITH NEW CONNECTORS OF A DIFFERNET DESIGN.

ASSIGNED NRC STAFF REPORT ITEMS REPORT DATE: 9/ 5/1984 REPORT CLASS: FO ACCESSION NUMBER: 8409210011 DATE FORM WAS CODED: 10/19/1984 CODER INITIALS: MW SUBMITTOR'S I.D. CODE: KGE --KANSAS GAS & ELECTRIC CO.

REPORT SEQUENCE #: 00001499 FACILITIES AFFECTED: 482 --W9LF CREEK 1 CERCRS IDENTIFIER **8401830 CASE TITLE: VULKENE SUPREME CABLE TERMINATIONS NRC REGION NUMBER: 4 --MID-WESTERN STATES REPORT TYPE: 2 --

10 CFR 50.55(E)

FIRST REPORT DATE: 7/20/1983 SYSTEM: EZ PRIMARY COMPONENT: CBL --CABLE / WIRE SECONDARY COMPONENT: FAS --FASTENER HOW DISCOVERED: Z --

UNKNOWN WHO DISCOVERED: LI -- LICENSEE CAUSE

~

STAGE: O --

ON-SITE CONSTRUCTION PURPOSE: E --

ELECTRICAL (POWER)

REASON: P --

PROCESSING OR FABRICATION ERROR

VENDOR: XXXX--other vendor DEFICIENCY: 801 THE TIGHT. NEARLY-INVISIBLE WRAPPING ON THE CABLE WAS NOT ADEQUATELY REMOVED WHEN MAKING CABLE TERMINATIONS. CONSEQUENTLY. SOME EQUIPMENT WAS NOT PASSING CONTINUITY, NEGGER. OR OPERATIONAL CHECKS.

CAUSE 801 WRAPPING WAS NOT ADEQUATELY REMOVED BECAUSE OF BEING NEARLY INVISIBLE.

OTHER INFORMATION: 801 CABLE HAS BEEN REPLACED WITH A CABLE THAT DOES NOT HAVE THE INVISIBLE WRAPPING. THE VENDOR OF THE VULKENE SUPREME CABLE IS NOT KNOWN.

ASSIGNED NRC STAFF REPORT ITEMS REPORT DATE: 10/17/1984 REPORT CLASS: FO ACCESSION NUMBER: 8411050280 DATE FORM WAS CODED: 12/ 6/1984 CODER INITIALS: FH SUBMITTOR'S I.D. CODE: KGE --KANSAS GAS & ELECTRIC CO.

REPORT SEQUENCE #: 00001830 FACILITIES AFFECTED: 482 --WOLF CREEK 1 CERCRS IDENTIFIER::8400375 CASE TITLE: TEMPERATURE RATING OF FIELD WIRING TO SOLENOID VALVE IS TOO LOW SUBMITTOR'S FORM ID: 84-065 NRC REGION NUMBER: 3 --NORTH CENTRAL STATES REPORT TYPE: 3 --

BOTH 10 CFR 21 AND CFR 50.55(E)

FIRST REPORT DATE: 4/13/1984 SYSTEM: BF --RESIDUAL HEAT REMOVAL (PWR) 3IMARY COMPONENT: VOE --VALVE OPERATOR. SOLENOID SECONDARY COMPONENT: CBL --CABLE / WIRE

- ... ~.

HOW DISCOVERED: M -

MAINTENANCE / MODIFICATION

~

WHO DISCOVERED: LI -- LICENSEE CAUSE STAGE: D --

DESIGN PURPOSE: E --

ELECTRICAL (POWER)

REASON: M --

MISAPPLICATION / IMPROPER USE DEFICIENCY e01 FIELD WIRING THAT CONNECTS INSIDE THE SOLENOID VALVE COULD EXPERIENCE TEMPERATURES THAT EXCEED THE WIRE INSULATION MAXIMUM TEMPERATURE RATING.

CAUSE 901 INTERNAL OPERATING TEMP OF VALCOR SOLENOID VALVE HIGHER THAN EXPECTED.

OTHER INFORMATION: 901 THIS REPORT WAS WRITTEN BY SNUPPS. 37 VALVES ARE AFFECTED IN SIX DIFFERENT SYSTEMS.

HIGH TEMPERATURE RATED WIRE WILL BE OSED TO MAKE THE INTERNAL VALVE CONNECTION THAT WIL6 THEN RUN OUT CF THE VALVE TO A SPLICE BOX 5 TO to FEET REMOTE FROM THE VALVE.

ASSIGNED NRC STAFF REPORT ITEMS REPORT DATE: 4/13/1984 REPORT CLASS: FO ACCESSION NUMBER: 8404260230 DATE FORM WAS CODED: 5/17/1984

' CODER INITIALS: FH SUBMITTOR'S !.D. CODE: XXX --OTHER GUBMITTOR

! REPORT SEQUENCE #: 00000375 FACILITIES AFFECTED: O 482 --WOLF CREEK 1

483 --CALLAWAY 1 CERCRS IDENTIFIER: 304v0366 CASE TITLE: FIELD RUN CABLES FOR SOLENOID VALVES

SUBMITTOR'S FORM ID: 80-02 NRC REGION NUMBER: 3 --NORTH CENTRAL STATES REPORT TYPE: 5 --

10 CFR 50.55(E) RESULTING FROM A 10 CFR 21 FIRST REPORT DATE: 4/13/1984 SYSTEM: EZ PRIMARY COMPONENT: VOE --VALVE OPERATOR. SOLENOID SECONDARY COMPONENT: CBL --CABLE / WIRE HOW DISCOVERED M --

MAINTENANCE'/ MODIFICATION WHO DISCOVERED: LI -- LICENSEE CAUSE STAGE D --

DESIGN PURPOSE: E --

ELECTRICAL (POWER)

REASON: I --

RECORDS INCOMPLETE MANUFACTURER: A499--ASCO VALVES

TO20--TARGET ROCK CORP.

VENDOR: VO30--VALCOR ENGINEERING CORP.

DEFICIENCY 901 THE INCOMING FIELD CABLES ARE TERMINATED INSIDE A TOTALLY ENCLOSED VALVE BODY HOUSING A LARGE ENERGIZED SOLENOID. TEMPERATURES GENERATED BY THE SOLENOID ARE TOO HIGH FOR THE FIELD WIRING INSULATION.

CAUSE 801 VALCOR. SOLENOID SUPPLIER. SUPPLIED DRAWINGS DEPICTING VALVE AND WIRING DETAILS.

BUT PROVIDED NO TEMPERATURE INFORMATION. THE AE DID NOT RECOGNIZE THAT HIGH AMBIENT TEMPERATURES WOULD BE ENCOUNTERED. SO HIGH TEMPERATURE INSULATION WAS NOT SPECIFIED.

OTHER INFORMATION: 901 DESIGN CHANGES HAVE BEEN IMPLEMENTED TO REPLACE THE FIELD WIRING WITH QUALIFIED HIGH TEMPERATURE WIRING. IF OTHER SUCH DEFICIENCIES ARE DISCOVERED, A SUPPLEMENTAL REPORT WILL BE ISSUED. THE ' DEFICIENCY WAS FIRST SEEN IN THE COURSE OF UNRELATED REWORK ON ONE OF THE AFFECTED VALVES. REPORT SUBMITTED BY SNUPPS 802 OTHER EQUIPMENT WAS EXAMINED FOR POSSIBLE EXCESSIVE HEAT RISE AT FIELD TERMINATIONS. FOUND 20 TARGET ROCK SOLENOIDS AND 2 ASCO SOLENOIDS. CABLES WILL BE REPLACED.

ASSIGNED NRC STAFF

. .>.n REPORT-ITEMS REPORT DATE: 4/13/1984 REPORT CLASSI FO ACCESSION NUMBER 8 8404260045 DATE FORM WAS CODED: 5/16/1984 CODER INITIALS MW SUBMITTOR'S I.D. CODE XXX --OTHER SUBMITTOR REPORT SEQUENCE #8 00000386

• REPORT DATE: 5/10/1984 REPORT CLASS: F1 ACCESSION NUMBER 8405210105 DATE FORM WAS CODED 11/13/1984 CODER INITIALS: RO REPORT SEQUENCE # 00000583 FACILITIES AFFECTED: O 482 --WOLF CREEK 1 3 483 --CALLAWAY 1 e

i