ML20129A045
| ML20129A045 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/11/1985 |
| From: | NRC |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20128R100 | List: |
| References | |
| FOIA-85-161 NUDOCS 8507270154 | |
| Download: ML20129A045 (2) | |
Text
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MARCH 11, 1985 2/i NOTE T0 y pa FROM:
SANDY
SUBJECT:
WOLF CREEK LETTERS THE FOLLOWING LIST OF TABS IDENTIFY THE WOLF CREEK LETTERS THAT MR. DIRCKS SIGNED TODAY ALONG WITH THE INCOMING CORRESPONDENCE.
A.
LETTER TO CONGRESSMAN DINGELL FROM DIRCKS DTD 3/11/85 IN RESPONSE TO TO CONGRESSMAN DINGELL'S 1/9/85 LETTER.
B.
LETTER TO GOVERNOR CARLIN DTD 3/11/85 IN RESPONSE TO GOVERNOR CARLIN'S 3/5/85 LETTER.
C.
LETTER TO DARRELL EISENHUT FROM THE KANSAS CORPORATION COMMISSION DTD 11/5/84 (EISENHUT SENT A RESPONSE TO THE COMMISSION TODAY AND WE WILL GET A COPY TOMORROW).
D.
LETTER TO CONGRESSMAN GLICKMAN FROM DIRCKS DTD 3/11/85 IN RESPONSE TO CONGRESSMAN GLICKMAN'S 2/1/85 LETTER.
E.
LETTER TO CONGRESSMAN SLATTERY FROM DIRCKS DTD 3/11/85 IN RESPONSE TO CONGRESSMAN SLATTERY'S 2/8/85 LETTER.
F.
LETTER TO CONGRESSMAN MILLER FROM DIRCKS DTD 3/11/85 IN RESPONSE TO CONGRESSMAN MILLER'S 2/14/85 LETTER.
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G.
LETTER TO REPRESENTATIVE POTTORFF FROM DIRCKS DTD 3/11/85 IN RESPONSE TO REPRESENTATIVE POTTORF0FF 2/18/85 LETTER.
H.
LETTER TO REPRESENTATIVE WUNSCH FROM DIRCKS DTD 3/11/85 IN RESPONSE TO REPRESENTATIVE WUNSCH 2/18/85 LETTER.
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UNITED STATES 8
NUCLEAR GEGULATORY COMMISSION P
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MAR 1111185 The Honorable John D. Dingell United States House of Representatives Washington, D.C. 20515
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Dear Congressman Dinge11:
This is in continued response to your letter of January 9,1985, and the NRC cosuitment in Chairman Palladino's letter of January 23,1985,to provide you with a copy of MRC inspection reports relating to our followup on the reinspection of structural steel welding at the Wolf Creek Generating Station. The NRC inspections have been completed and NRC Inspection Reports 50-482/85-12 and 50-482/85-13 are provided for you in Enclosure I (Reference 6).
Enclosure I provides a comprehensive sunnary description of the activities of both Kansas Gas and Electric Company (KG4E) and the NRC related to the structural
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steel issue. Enclosure I describes a significant program of corrective action by the KG&E which addressed not only the structural steel welding issue, but also included inspections and evaluations to determine that the aspects involved in the structural steel welding issue did not occur in other areas of construction. Enclosure I also describes the extensive NRC program of verification and independent inspection on all these issues to assure the adequacy of the structural steel welding and the implementation of the Quality Assurance (QA) program meets Cosnission requirements. Based on the completed efforts of KG&E, which have been verified t;y NRC inspections, the NRC has concluded that these issues are resolved.
We have also prepared additional information regarding problems involving cable separation. This information is provided in Enclosure II of this letter. Based on KG4E corrective action and independent NRC inspections, we have concluded that adequate cable separation exists at Wolf Creek Generating Station and this issue is resolved.
As you may recall, the Office of Investigations (01) has recently initiated a number of investigations regarding alleged erroneous or falsified records.
Some investigations are presently underway. At this time O! has no firs estimated completion date. One OI report regarding this subject has been recently completed. If you desire, we will be. pleased to brief you on s>ecific aspects of the investigations.
In order to protect the integrity of tie investigative process, we suggest such briefings >e oral.
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The Honorable John D. Dingell i l
The NRC technical staff has evaluated the safety aspects of missing and potentially falsified welding records, and has resolved the safety aspects I
The NRC staff has evaluated the of these issues, as indicated in Enclosure I.
safety-related aspects of the other issues being reviewed by 01. At this time.
we are not awam of any infomation from the Office of Investigations that l
constitutes a basis for withholding the issuance of a low power license for I
I Wolf Creek. Therefore, the staff is proceeding with its review in support of the license issuance. Matters pertaining to all continuing investinations will be reviewed by the Comission prior to issuance of a full power l' cense.
Because of your interest in being infomed about NRC activities at the Wolf Creek plant, we are also advising you that NRC review of preoperational test activities indicated that some deficiencies had occurred in these activities.
These deficiencies included instances of incormet test conditions, incomplete 1
verification of systems operation, and incomplete recording of test data.
l These matters were identified to KG4E and cormctive actions, including any l
repeating of preoperational tests, were perfomed by the applicant and were reviewed by NRC inspectors. Actions taken by KGAE to 3revent recurrence are responsive to the NRC concerns. The technical issues eve been resolved, and actions necessary to support issuance of a license pemitting fuel load and low power testing have I>een completed. The NRC is also reviewing the need for possible enforcement action relative to the deficiencies identified in the preoperational testing program. A copy of inspection reports and any enforcement correspondence related to this subject will be provided to you when they are issued to KG&E.
Based upon the NRC staff review and inspection program, we conclude that the l
facility has been constructed in confomance with the requirements of the Comission and its operation will not represent any undue risk to the health and safety of the pu >1ic.
f Sincerely, i
M Weism 1. tests William J. Dircks Executive Director for Operations j
Enclosures:
1 1.
Structural Steel Issue i
2.
Electrical Separation Issue
- SEE PREVIOUS CONCURRENCE i
RevisedinED0 Office (3/11/85)
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DATED:
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g Enclosure I STRUCTURAL STEEL ISSUE INTRODUCTION AND BACKGROUND The purpose of this document is to provide a description of the issues involving field-welded structural steel at the Wolf Creek Generating Station (WCGS). There is substantial documentation associated with the matter. The documentation of primary importance is referenced throughout this document, and is listed in attachment A.
The referenced documentation is also attached.
The vas.t majority of the structural steel at WCGS was erected during the period 1977 to 1981. Approximately 11,150 structural steel joints were fabricated during the erection period to support safety-related components or structures at the WCGS. The majority of these joints were bolted or shop-welded together.
About a quarter of these structural steel joints were welded in the field in accordance with the design requirements and the American Velding Society code, AWS D 1.1.
Between 1978 and 1982, a small sample (less than 1%) of these structural ioints were selected by the NRC inspectors and inspected for compl;ance with the applicable code and NRC requirements.
No significant deviations or violations were observed in these samples.
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In July 1984, the NRC established a task force to complete the NRC inspection program at the WCGS. The inspection program calls for, among other activities, a review of the applicant's corrective action programs required by their QA program.
During these inspection activities, the NRC inspectors raised concerns regarding the applicant's handling of certain corrective action requests associated with the field welding of structural steel joints. A review of one corrective action report indicated that a reinspection of a
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sample of field welded structural steel joints by the applicant showed tht a relatively high percentage of the welds failed to meet one or more of the quality requirements of the applicable code; these results were at variance with the initial inspections which accepted the welds as meeting code requirements.
In addition, another corrective action request indicated that the original inspection records for many of the field welded structural steel joints were not available.
The applicant's evaluation of these particular matters resulted in acceptance of field welded structural steel joints on the basis that the defects identified during the reinspected sample were cosmetic, and his conclusion that the unavailability of the original inspection records did not undermine confidence that the field welded joints were properly installed. The NRC task force did not agree that the applicant had properly handled the disposition of these corrective action requests.
The NRC task force requested that the applicant select, inspect, and evaluate additional field weled joints. These additional inspections revealed missing welds, missing structural material, an inspection record for welds which did not exist, and some welds not in conformance with the applicable code and design documents. The NRC task force consequently concluded that in view of
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inappropriate disposition of the corrective action requests, the results of reinspections, and the unavailability of original weld inspection records, the quality of the field welded structural steel joints would have to be reevaluated. This became the central issue, but not the only issue, to be resolved.
As a result of the inspection findings, the NRC took enforcement action which required, among other things, the development and implementation of a corrective action plan which would provide adequate assurance that the field,
welded structural steel was appropriately installed and would perform the required safety function. The applicant developed and implemented a program which included a reinspection of all accessible structurally significant field welded joints. The program was reviewed and accepted by the NRC. Throughout the implementation of the program, the NRC monitored its conduct, witnessed inspections by the applicant, reviewed inspection results, and conducted independent inspections. These activities were completed in early March 1985.
The remainder of this document provides a general chronology of events, identifies the appropriate codes and their application, elaborates on the unavailable weld inspection records, describes the appifcant's reinspection program scope and results, describes the NRC independent inspection activities and results, and sets forth the NRC conclusions.
CHRON0 LOGY OF EVENTS The following is a chronology of major events that were involved in the structural steel welding area.
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1977 - 1981 Structural steel welding was initiated approximately during the last quarter of 1977, with approximate completion occurring during the last quarter of 1981. As discussed later, there are 2,670 safety-related structural steel connections consisting of approximately 11,000 welds identified in the six safety-related buildings; i.e., auxiliary, reactor, control, emergency service water system, fuel, and diesel generator buildings. These welds were made and inspected by Kansas Gas and Electric Company s (KG8E) construction contractor, Daniel International Company (DIC). The results of the weld inspections were to be documented in Miscellaneous / Structural Steel Welding Records (MSSWRs).
March 1983 As a result of previously identified deficient fillet weld conditions on component supports; e.g., pipe hangers DIC Quality Control (QC) initiated a random reinspection of accessible structural steel fillet welds in the safety-related buildings.
This activity identified 148 rejectable welds in a sample of 241, and resulted in the issuance of corrective action report No. CAR 1-W-0029 (Reference 1). This CAR directed that all of the
'% rejected welds be incorporated into a noncnnformance report (NCR) so that an evaluation and disposition could be made by the DIC Project Welding Engineer on each discrepancy. NCR ISN 10381PW was written and an evaluation of each rejected weld was performed.
The NCR was dispositioned as follows:
Rework - 6 welds Use As Is - 142 welds Nearly all of the rejectable conditions were considered cosmetic in nature in that structural integrity was not jeopardized.. Based on the above
-figures, DIC concluded that as a result of the very small percentage of welds requiring rework, "no sacrifice to structural integrity would have resulted... if they had not been reinspected and reworked." The NCR was closed with subsequent closure of the CAR on October 22, 1983.
August 1983
.A DIC review of documentation prior to building turnover to KG8E revealed approximately 16% and 24% of the required MSSWRs were missing for Fuel Building and Reactor Building welds, respectively. This resulted in the issuance of CAR 1-C-0031 (Reference 2), dated August 10, 1983, through Revision 7 dated October 20, 1984. The suggested corrective action included a review of all existing MSSWRs prior to building turnovers and the generation of NCRs for each building identified as having missing MSSWRs. Each NCR was to be evaluated and dispositinned as rework or use-as-is, depending upon the circumstances revealed after the existing documentation for each building had been reviewed.
This CAR was intended to be closed out on the basis of the relatively small number of missing MSSWRs and the fact that the previous reinspection of a sample of structural steel welds showed an even smaller number of welds requiring rework. Thus, the fact that MSSWRs were missing was accepted because of the weld quality established during the sample reinspection.
This CAR was not formally closed until January 16, 1985, as a result of the continuing chronology of events.
The major cause of the missing MSSWRs was concluded to be the result of a lack of procedural compliance with respect tn responsibility for origination, completion, and maintenance of these records. The MSSWR$
were stored in various locations and by varinus personnel within the individual buildings from the time they were originally initiated; thus precluding any assurance of control.
June - August 1984 NRC first learned nf the potential records problem in conversations wl.th applicant personnel.
In addition to personnel interviews, a review of l
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% CARS was undertaken and the specifics of CARS 1-W-0029 and 1-W-0031 became known to the NRC.
August 1984 A document reconciliation effort was initiated by KG&E to determine which safety-related structural steel welds were lacking MSSWRs.
In addition, an inspection verification effort was initiated to provide an accurate assessment of the as-built conditions of safety-related structural steel welded connections which were lacking available MSSWRs.
September 1984 KG8E, DIC, and Bechtel made a joint presentation to the NRC task force which identified the belief at that time, that the problem was one of-document retrieval, and not a hardware problem. This was not an acceptable premise to the NRC task force and as a result, KG&E agreed to perform a sample structural steel joint inspection of six randomly selected structurally significant joints in each of the six safety-related buildings. This inspection resulted in the discovery of missing welds,
' missing structural members, and deficiencies with respect to weld size.
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This information was formally reported to the NRC under 10 CFR Part 50.55(e) on September 18, 1984.
Subsequent meetings were held between KG&E and the NRC task force for further information updates.
October 1984
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KG8E Quality Assurance issued CAR No.19 (Reference 3) on October 17, 1984, to obtain the necessary actions required to resolve the issues i
associated with structural steel welding. The specific issues included:
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missing MSSWRs for safety-related structural steel welds; deficiencies being identified in previously accepted structural steel welds; missing structural welds and/or material; and documentation that a weld was inspected and accepted, but in fact, the inspected welds did not exist.
October 26, 1984 As a result of the above events, it was determined that a significant violation of NRC regulations had occurred and NRC's Region IV office issued Inspection Report No. 50-482/84-22 (Reference 4), which provided the details of the inspection findings and also stated that enforcement correspondence and Notice of Violation pertaining to this matter would be sent to KG8E under separate cover.
It further addressed a scheduled enforcement meeting to be conducted on October 29, 1984.
October 29, 1984 Enforcement Conference at RIV offices in Arlington, Texas. KGAE issues plan for corrective actions, including CAR No. 19 (Reference 3).
W November 15, 1984 NRC-RIV Issued Confirmation of Action Lettar (CAL) confirming understandings reached at Enforcemert Conference on October 29, 1984, and providing additional guidance on conduct of corrective action program (Reference 7).
November 21. 1984 The Notice of Violation and Proposed Imposition of Civil Penalty was issued to KG8E as Enforcement Action No.84-107 (Reference 5).
November 1984 - February 1985 NRC personnel ennducted independent visual and nondestructive examinations, and verified and evaluated KG8E's committed corrective actions. This information is documented in NRC Inspection Report Nos. 50-482/85-12 and 85-13 (Reference 6).
' December 31, 1984 KG8E issues final report on CAR No. 19 corrective action in response to Notice of Violation (Reference 9).
January 21, 1985 KG8E issues supplement to final report on Notice of Violation (Reference 10).
February 27, 1985 A public meeting was held at the NRC in Bethesda, Maryland, between the NRC and the Kansas Gas and Electric Company to fully discuss the structural steel welding issue. A transcript of this meeting was made (Reference 8).
February - March 1985 KG&E provided supplemental information regarding results of additional inspection, and in response to NRC requests for additional information (References 11-14).
APPLICABLE CODES, STANDARDS, AND COMMITMENTS The applicable codes and standards as conunf tted to in the WCGS Final Safety Analysis Report (FSAR) with respect to building construction, are as follows:
American Institute of Steel Construction (AISC) Specification for the Desigr., Fabrication and Erection of Structural Steel for Buildings
. American Welding Society's Structural Welding Code, AWS D 1.1-75.
The identified deficient welds were contrary to the acceptance criteria of AWS D 1.1-75.
At the time KG&E initiated CAR No. 19, construction was basically complete.
This resulted in approximately 56% of the safety-related joints being in a painted condition. Due to KG8E's commitment to perform a 100% reinspection of all accessible structurally significant joints, criteria had to be established with respect to inspecting through paint. The inspection requirements, acceptance criteria, and method of documenting the results of the reinspection were proceduralized in procedure No. QCP-VII-200, Revision 20 dated November 2, 1984 (Reference 9). The procedure recognized that paint and fireproofing material would exist on most of the welds to be inspected; however, the inspectors were directed to inspect in accordance with the design drawings and AWS D 1.1-75 criteria.
The procedure further stated that if the fireproofing material precluded the ability to reinspect, then the welds were to be reeleaned. Additional information and results of the reinspection are addressed later.
MISCELLANE0US/ STRUCTURAL STEEL WELD RECORDS The appifcant's approved Quality Assurance /Ouality Control (QA/QC) program required that a document referred to as a Miscellaneous / Structural Steel Weld Record (MSSWR) be prepared and retained for welds made on field-welded structural steel joints. The individual weld and joint records are not a requirement of AWS D 1.1.
The MSSWR required the following principal items to be entered:
Drawing reference and joint number Material type Weld procedure utilized weld Filler material identification Symbol identification of the welder Date of welding and inspection Identification of inspector Weld acceptance Remarks and/or sketches required for clarity The QA/QC program provided that each Bechtel structural steel drawing be annotated to reflect the generation of acceptance MSSWRs on a connection-by-
i connection basis. When all of the connections were annotated, that pagkage of work was considered complete.
Following completion of the structural steel welding activities, the MSSWRs were retained at the construction site by the construction crews (field engineers and inspectors) at various locations referred to as " headache shacks" and " gang boxes." The great majority of the MSSWRs were single-part forms, so that copies were not provided at the time to records keeping organizations.
The storage of MSSWRs in this manner in the field went on for a considerable period of time. The constructor, Daniels International Corporation, did not maintain adequate control or provide adherence to procedures, to ensure that the MSSWRs were fully retained (References 8 and 9).
It was not until the KG&E and DIC Combined Review Group (a document review group) began a review of the acceptance documentation in 1983 to accomplish building turnover, that they found that the acceptance of all welds in all connections could not be accomplished with the existing records. At that time, the effect of the above factors was identified and documented in CAR 1-C-0031.
The final report for KG8E CAR 19 (Reference 9) indicates that 1,509 of 6,816 MSSWRs for safety-related structural steel welds are missing. The detailed records of the reinspection of the structural steel welds are being retainedasplantrecords(Reference 8).
REINSPECTION OF PAINTED WELDS The KG&E corrective action plan to perform a 100% reinspection of all accessible safety-related structural steel welds necessitated the need for 8echtel to identify the applicable joints. This was accomplished by review of the erection drawings prepared by the structural and miscellaneous steel fabricators, field change request, nonconformance reports, construction variance requests, and structural steel fabrication requests.
Bechtel identified 2,670 structurally significant safety-related field-welded joints which required reinspection.
As stated previously, approximately 56%, or 1,484 welded joints, were reinspected in a painted condition which consisted of either a primer coat, topcoat, or both. Approximately 58%, or 859 of the painted weld joints, had existing MSSWRs from the original inspection which showed the welds to be acceptable.
Bechtel provided a technical justification for inspection through paint as an attachment to a letter to XG&E identified as BLKES-1348 dated November 5,1984 (Reference 9). Bechtel's position is that fillet welds which have been coated with up to 4 mils of primer and up to an additional 10 mils of topcoat can be visually examined to the AWS D 1.1-75 acceptance criteria.
Paint thickness was measured using a standard dry film thickness gauge.
Bechtel identified the following attributes as being those which could be fully evaluated:
T 1 l Weld presence and location Weld length Weld size, both leg length and throat thickness i
2 Weld profile, including convexity and concavity Fusion between weld and base metal Overlap Cross-section of weld craters Coarse undercut i
l Large porosity 1
They,further identified the following attributes as being more difficult to evaluate and measure in a painted condition, and in some cases may not be visible at all:
Cracks l
Fine porosity Tight undercut However, these three attributes were addressed as being largely dependent on.
the metallurgical characteristics of the base metal being joined, the welding material being used, and the ability of the welders performing the work.
The base material used for all structural steel at WCGS is ASTM A36, which is a low carbon, highly weldable steel. The welding materials used were Type E7018 r
electrodes, which are highly compatible with A36 material. This compatibility
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results in sound crack-and porosity-free welds provided basic precautions are taken. These precautions are all addressed in the welding procedure specifications used for the structural steel welding. The presence or absence of undercut is dependent on materials used, welding parameters, and welder ability. The first two factors were addressed earlier, leaving welder ability, which to a large degree is the major cause of undercut. The training and qualification tests are in accordance with AWS D 1.1, which is designed to provide the welders with the ability to control these attributes.
The NRC evaluated Bechtel's basis for joint selection and their justification for reinspection of painted welds.
The NRC concluded that:
Bechtel's basis for the selection / identification of joints for reinspection was proper
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Bechtel's justification for inspection through paint was valid with respect to identifying those defects which would affect the structural integrity of the welds.
The NRC was not completely satisfied that visual examination of painted welds would reveal lack of fusion.
Independent NRC visual inspection (VT) of painted welds was conducted to confirm that significant attributes could be detected.
In addition, painted welds were magnetic particle tested (MT) to determine if l
the paint was masking surface discontinuities; no surface discontinuities were found in the sample examined.
In addition, the NRC selected a statistically significant sample of painted joints which were reinspected by the NRC using VT and MT after the paint was removed.
No defects were found in the sample selected. This provided additional confidence in the ability to inspect painted welds for significant defects, and confidence that the welds had been properly made (Reference 6).
It is important to note that the applicable code, AWS D 1.1, requires that welded joints not be painted until after the work has been completed and accepted. The AWS has suggested that paint will generally mask surface l
discontinuities. The DIC corresponded with the AWS regarding reinspection of l
structural steel welds.
The AWS replied that reinspection is not covered l
(addressed) by AWS 01.1, and that such reinspection should be in accordance l
with acceptance criteria agreed upon by the engineer and the contractor (Reference 8).
RESULTS OF REINSPECTION h
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The KG&E reinspection effort was performed by AWS-certified welding inspectors (CWis) who were also certified as quality inspectors by DIC in accordance with I
the requirements of ANSI N45.2.6-78. As previously discussed, inspection l
criteria, acceptance standards, and method of documenting inspection results was procedurally defined. The reinspection data was recorded in Weld Data Sheets which documented the inspected as-built conditions of all accessible structural steel welds. All identified deficiencies were documented in NCRs
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which, together with the Weld Data Sheets, were presented to Bechtel in order that a case-by-case evaluation of each deficient welded joint could be per formed.
The documented results of the KG&E reinspection effort can be tabulated as follows:
. No. of Joints Identified for Reinspection -
2.670 No. of Joints Completely Reinspected -
2,403 No. of Painted Joints -
1,484 No. of Unpainted Joints -
919 No. of Acceptable Joints -
1,305 No. of Rejected Joints -
1,098 No. of Partially Inaccessible Joints -
165 No. of Totally Inaccessible Joints -
102 A question arose as to the causes of the obvious differences in inspection results with respect to the original inspections between 1977 and 1982, and the reinspection effort between October 1984 and February 1985.
The existing MSSWRs documenting the results of the original inspections show that the welding was acceptable, while the reinspection identified 1,098 rejectable welded joints. This disparity was probably caused by a less intense inspection discipline during the original inspections. Considerable more latitude and judgement was the norm for structural steel welding inspection during the
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earlier time frame. As a result of the subsequent identification of defective welds during the sample inspection, a very disciplined and structured plan with absolute acceptance / rejection criteria was established for use during the reinspection activities. As a result, those attributes originally identified as being acceptable, were now being rejected.
In addition, inspection to the established rigid and absolute criteria would allow Bechtel to perform complete and thorough evaluations of the as-built conditions.
Bechtel's evaluation of the 1,098 rejectable welded joints identified 82 joints requiring repairs due to defective conditions which caused the design allowable stresses to be exceeded in the as-built condition, and 81 additional joints were identified as requiring repairs due to KG8E's commitment to install missing material and missing and underlength welds (unless prohibited by field conditions) even though the design allowable stresses had not been exceeded.
It was determined that field conditions did preclude the repair of 14 of the 81 joints. Thus, a total of 149 welded joints' were repaired, and all others were dispositioned as "use-as-is."
With respect to the 102 joints identified as being totally inaccessible due to their being embedded in concrete or having physical interferences, 62 were acceptable as-is because evaluation showed that the concrete was capable of supporting the design load, thus eliminating any concerns with respect to defective welds.
It was also noted that 165 joints were partially inaccessible; however, sufficient inspection data was available on 139 of the joints to allow an evaluation to be performed.
This leaves a total of 66 joints out of 2,670 which could not be evaluated. The basis by which Bechtel accepted these joints was through statistical analysis, and is considered
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l proper logic.
If the 2,604 fully evaluated joints are considered a sample of the 2,670 total population of joints, then the sample size represents such a i
large percentage of the total population that statistics associated with the l
sample may be applied to the total population with virtually 100% confidence.
This implies that if a percentage of inspected joints were determined to exceed design allowable stresses, then statistically this percentage may be applied to l
the total population.
1 Of the 2,604 joints which were evaluated, 82 joints (3.14%) were identified in which the design allowable stresses were exceeded. Analysis has shown that j
those joints would not have failed under the design loading conditions.
However, 60 of the 82 joints were polar crane radial stops in which the same
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l welds were missing in each joint and the design allowable stresses were exceeded.
In addition, 6 pressurizer support joints had the same welds missing in each joint, three of which exceeded the design allowable stresses. Thus, a total of 19 joints in the remaining population of 2,541 joints (0.75%),
exceeded the design allowable stresses.
It should be pointed out that the cause of the missing identical welds in the 60 polar crane radial stops and the b
6 pressurizer supports is attributable to the failure of the detail drawings to 1
provide a clear understanding of the weld details. This is considered an isolated condition and was substantiated by the NRC Region IV inspector's review of the applicable structural steel detail drawings delineating the welded joint configurations. That is, by reviewing typical drawings of the f
66 joint details, the NRC staff concluded that they are more representative of the larger population; in other words, joint welding details are clear, not j
0 iike the so poiar craae ston Joiati. Therefore. the aac staff coaciudes it i
appropriate to include these 66 joints in the larger population group, j
j The 0.75% statistically applied to the group of 66 joints which could not be Q<
evaluated, results in less than 1 joint in which the design allowable stresses could be expected to be exceeded.
It would also be expected that none of these joints would fail under the design loading conditions as a result of defective welds.
j NRC reviewed Bechtel's methodology with respect to evaluating and i
dispositioning the identified welding defects, and their approach with respect r
to inaccessible welded joints embedded in concrete. NRC concluded that:
j Bechtel's approach of individually calculating stress levels to
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determine the structural adequacy of the identified as-built
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conditions is acceptable.
i There is no deficiency in Bechtel's approach with respect tn inaccessible welded joints embedded in concrete, in that the use of statistical analysis and acceptable alternative load path evaluation l
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is proper.
In order to assess the adequacy and implementation of KG&E's comitted i
corrective actions, NRC's Region IV staff accompanied CWis on several occasions to observe and verify their inspection activities and to assure that the i
results of the inspections were being accurately recorded, in addition. NRC's j
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, i l
l Region IV staff conducted independent inspections on selected joints'with subsequent comparison to the CW!s inspection data sheets. There were no discernible differences in inspection results obtained by NRC's Region IV staff and the CWis during either the accompanied or independent inspection activities. This created a very high level of confidence in the data being documented by the CWis during the reinspection program.
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The NRC Region IV staff reviewed weld data sheets and applicable NCRs for approximately 1,750 welded joints, including 149 data sheets and 34 NCRs associated with the joints that were repaired.
In addition, and subsequent to i
the completion of the reinspection effort, the NRC Region IV staff performed an j
inspection on 42 of the 149 repaired joints, with acceptable results.
It was noted that magnetic particle examination (MT) was also performed on 24 of the 149 repaired joints with acceptable results by KG8E.
1 Of potential concern was the reconciliation of the as-built conditions to the 4
design drawinos. This was resolved by Bechtel in that they are identifying all i
NCRs applicabIe to field-welded / structural steel joints on Drawing No. C-1045.
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Note,46 in Revision 1 to Drawing No. C-1003, " Civil-Structural Steel and Concrete General Notes," states, in part, "... See the shop detail drawings
(
and appropriate noaconformance reports identified on Drawing C-1045 for connection details."
I As stated earlier the NRC performed an independent NDE program at WCGS. The j
particular NDE disciplines used were VT and MT. The NRC specifically recognized that fine lack of fusion, tight cracks or porosity, might be masked by coatings and that the use of MT might be of significant assistance in f
i helping to determine its existence. One of the goals of the MT was to help establish the validity of the VT of painted welds.
l The results of the NRC inspection are documented in NRC Inspection a
O Report 50-482/85-12; however, a sumary of those results are presented here.
f Four structural carbon steel weld samples were fabricated with known flaws such j
as tight cracks and porosity in the welds.
The samples were 3/4" X 6" X 8" in dimension. These were examined by VT and MT, and then photographed before 1
painting. The samples were then coated with Carboline CZ-11 primer and the l
coating thickness measured. The VT and MT examinations were repeated through the coating and the results photographed. The samples were then coated with j
Carboline 191 HB epoxy, representative of field conditions, and the examinatinns performed again and photographed.
The types of indications noted within these test blocks represented the types of indications that could be i
encountered with structural welding.
The NRC inspection team also indicated that the tight indications in the test blocks were difficult to visually detect and if all the welds were in the as-welded condition, a small percentage of the 1
indications would have been detected visually.
Indications wider than the samples would be detected by visual inspection.
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The results of these tests proved that meaningful MT can be performed through i
paint coatings.
3 i
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. The NRC inspectors randomly selected safety-related structural welds in the essential service water system pumphouse (ESWS) and reactor building. The l
welds were subjected to VT and MT with either the primer or the epoxy coatings applied.
The coatings were then removed and the welds were reexamined by VT and MT.
In the ESWS, welds on six clip angles were visually examined with Carboline CZ-ll primer coat applied.
The dry film thickness for the primer ranged from 1.0 to 3.0 mils. After the primer was removed, the welds were reinspected by VT and MT using the NRC-approved procedure NDE-6, Revision 0, and Addendum WC-1-6-1.
The examinations disclosed that three of the clip angle welds were undersized; P-7, P-8, and P-10.
Review of KG&E records showed that these welds had been identified as being undersize and were recorded on a nonconformance report.
Otherwise, no other deficiencies were noted.
Similar examinations were conducted in the reactor building wherein five structural steel weld joints were VT'd and MT'd for AWS D 1.1 acceptability and overall workmanship.
The welds had Carboline 191 HB epoxy coating on them.
The welds were found to be acceptable.
A sample of 55 welded connections was selected in the reactor building for VT with primer and epoxy coatings applied.
The samples were selected from different elevations in order to provide a sample that had been welded by different welders and at different times. The VT was performed to design requirements and AWS D 1.1 acceptance criteria.
Five of the joints had their coatings removed and were reinspected by YT and MT. No indications were found on the welds with coatings or on those that had the coatings removed.
It was concluded that certain characteristics involved in VT can be evaluated effectively on coated welds. There were no characteristics identified during this inspection that could affect the integrity of the welded joints inspected.
A statistical sample of welded structural joints was selected from the reactor butiding for reinspection and evaluation to provide a level of confidence as to the quality of existing welded joints.
The selected sample consisted of 53 welded joints that were inspected for size, surface condition and overall workmanship, then MT'd for discontinuities. On those welded joints selected, all primer and epoxy coatings were removed prior to inspection. The inspection was performed and evaluations made in accordance with the design requirements and AWS D 1.1 acceptance criteria. No rejectable welds were identified.
The NRC staff concluded that the above VT and NT exaninations provided adequate assurance that welds can be HT'd through the coatings and that the previous reinspections give reasonable confidence that the inspection program was capable of identifying detrimental structural weld flaws.
There have been three other major activities involving AWS welding.
These activities involved different inspection methods and record retention requirements than those used in structural steel welding.
These activities
i
, P and supports for heating, ventilation, and air conditioning (HVAC)p restrai involved the installation of electrical raceway supports, pipe whi ductwork.
KG8E had discovered problems in two of these areas as documented in a 10 CFR 50.55(e) report to the NRC relative to the HVAC supports, ard was resolved by a 100% reinspection and rework program culminating in early 1983.
An NRC inspection was performed on the HVAC system, including welded supports, which concluded that the rework program had been satisfactory. The other area of AWS welding problems involved electrical raceway supports. KGSE had identified problems with these welds in 1982, but Bechtel had resolved the issue through engineering analysis and revision to the engineering criteria which had the effect of allowing the welds to meet AWS Code criteria. This resolution was satisfactory, based on inspections performed by NRC. With respect to the pipe whip restraints, NDE (liquid penetrant or MT) was required on 100% of the welds. This was an original specification requirement for this category of hardware. MSSWRs were used as described earlier, however, each weld was also documented on a separate NDE report. A review of these documents provided no indication of problems.
The methods of documenting inspection results differed depending upon the quality discipline responsible for inspection of the different AWS welding activities. The inspections of electrical raceway supports and HVAC supports were documented on Raceway Support Checklists and Mechanical Travelers, respectively. These methods provided a closed loop system where individual accountability for a weld was required and controlled, and the documentation was verified accurate and complete by QC/QA personnel.
Welding of piping systems and supports for the piping systems was accomplished in accordance with Section !!! of the American Society of Mechanical Engineers (ASME) Code. The examination and documentation requirements with respect to ASME Code Section !!! welding, are considerably more detailed and controlled.
Further, nearly all Class 1, 2, and 3 welds in pressure retaining materials receive some fom of NDEt i.e., radiography, ultrasonic, liquid penetrant, or MT. With one exception, there have been no significant problems in this area identified during many inspections, the most recent of which were accomplished after initial development of the structural welding issue by NRC personnel.
The exception noted was a KGAE 10 CFR 50.55(e) report which related a finding that there were undersized fillet welds in small diameter piping systems.
These welds were reworked to achieve compliance and verified by the ASME Authorized Nuclear Inspector and by the NRC.
The inspections of nonwelding areas documented in NRC inspection Report 50 482/84-51 (Reference 15), were wide ranging in nature and involved nearly every principal aspect of construction. These inspections were conducted at a time and by personnel fully cognizant of the structural welding issue. As noted in the letter of transmittal for NRC Inspection Report 50 482/84 51, no pervasive breakdowns were identified.
. CONCt.USIONS Based on the comprehensive corrective action by KGSE and the NRC's extensive independent inspection and verification program, the structural steel welding issue is considered resolved.
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Attachment A REFERENCES I
Reference No.
Description 1
CAR 1-W-0029 dated March 22, 1983 2
CAR 1-C-0031 dated August 10, 1983 3
G. L. Koester to R. D. Martin letter dated October 29, 1984 -
KML NRC 84-191 4
R. P. Denise to G. L. Koester letter dated October 26, 1984 Transmits inspection report 50-482/84-22.
5 Robert D. Martin to G. L. Koester letter dated November 21, 1984 EA 84-107. Transmits Notice of
)
Violation and Proposed Imposition of Civil Penalty.
6 Robert D. Martin to G. L. Koester letter dated March 7, 1985.
Transmits inspection reports 50-482/85-12 and 50-482/85-13.
7 Robert D. Martin to G. L. Koester letter dated November 15, 1985.
(ConfirmationofActionLetter.)
8 Transcript of Meeting 8etween Kansas Gas and Electric Company and the Nuclear Regulatory Comission -
Wednesday, February 27, 1985 9
G. L. Koester to R. C. DeYoung letter dated December 31, 1984, KML NRC-report.)(TransmitsCAR19 final 84 238.
?.
Reference No.
Description 10 G. L. Koester to R. C. Detoung letter dated January 21, 1985 -
KML NRC 85 037 firansmits supplemental response to NOV.J 11 G. L. Koester to R. P. Denise letter dated February 14, 1985 -
KML NRC 85-054.
12 G. L. Koester to R. P. Denise letter dated February 15, 1985 -
KML NRC 85 057.
13 G. L. Koester to R. P. Denise letter dated February 22, 1985 -
KML NRC 85 065.
14 G. L. Koester to R. P. Denise letter dated March 4,1985 -
KML NRC 85-073.
15 R. P. Denise to G. L. Koester letter dated January 3, 1985.
(Transmitted inspection report 50482/84-51.)
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Attachment A e
REFERENCES Reference No.
Descrietion 1
CAR 1-W-0029 dated March 22,1983 I
2 CAR 1-C-0031 dated August 10,1983 i
3
- 8. L. Rooster to R. D. ertin letter dated October 29, 1984 -
NML NRC 84-191 4
R. p. Denise to 8. L. Rooster letter dated October 28,1984. Transmits inspection report 50-442/M-12.
j l
5 Robert D. Martin to 8. L. Rooster 1etter dated November 21,1984 l
EA 84-107. TransmitsNoticeof Violation and proposed Imposition of Civil penalty.
8 Robert D. Martin to 8. L. Rooster letter dated March 7, 1985.
Transmits inspection reports l
50-482/85-12 and 50-442/85-13.
l 7
Robert D. Martin to 8. L. Rooster letter dated November 15,1988.
(ConftenationofActionLetter.)
f 8
Transcript of Meeting Setween Kansas Ses and Electric ny and the Nuclear Re9ulatory esmission -
l Wednesday, February 27, 1M8 I
i 9
- 8. L. Rooster to R. C. DeVoung letter dated December 31,1984 Nf8.NRC-I report.)(TransaitsCAR19 final 84 !M.
i i
i i
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Neference No.
DescriDtion 10
- 8. L. Koester to R. C. DeYoung letter 1M5_
dated January 21, Transmits supplemental NML NRC 85-037 i response to NOV.J 11
- 8. L. Koester to R. P. Denise letter dated February 14, I M 5 -
NML NRC 85-054.
12
- 8. L. Rooster to R. P. Denise letter dated February 15, I N 5 -
NML NRC 85 067.
i 13
- 8. L. Rooster to R. P. Denise letter dated February 22,1W85 -
NHL NRC 85 M5.
14
- 8. L. Rooster to p. P. Denise letter dated March 4. IN5 -
NML NRC 85-073.
15 R. P. Denise to 8. L. Koester letter dated January 3, 1985. (Transmitted inspection report 50-412/M 51.)
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Enclosure II l
ELECTRICAL SEPARATION ISSUE A.
Introducticn The purpose of this document is to provide information relative to the findings of electrical cable separation deficiencies and cable separation procedural inadequacies at the Wolf Creek Generating Station (WCGS) identified in NRC Inspection Reports 50-482/84-22 and 50-482/84-51, I
respectively.
8.
Scope 1
1.
The deficiencies in the area of electrical cable separation were discovered by the NRC during two different inspections at the WCGS.
These resulted in the issuance of two violations.
The inspection conducted during the period of June 11 through September 28, 1984 l
(documentedinNRCInspectionReport 50482/84-22), detailed several I
examples of the following:
Violations of the criteria where safety related electrical conduits must be separated by 1-inch or more from redundant l
l safety related and nonsafety-related conduits.
Violations of the criteria where safety related electrical l
cables must be separated by 6 inches or more from redundant safety related and nonsafety related cables within cabinets or panels.
2.
NRC Inspection Report 50-482/84 51 documented the findings of an NRC inspection conducted during the period of October 23 through November 2, 1984 This inspection discovered that site procedures do not include the same separation criteria for nonsafety related conduits to safety-related cable trays as is required for safety related conduits to nonsafety-related cable trays. This is in violation of FSAR comitments to NRC Regulatory Guide 1.75 and IEEE-384, since no evaluation of safety significance was perfomed.
C.
Sense of KCAC's Corrective Action I
KG8E instituted a walkdown inspection of all safety related buildings for violations of the 1-inch separation criterf a, and all control room cabinets and panels for violations of the 6 inch internal separation l
criteria.
KGAE stated that the deficiencies discovered during these l
walkdowns were documented on nonconformance reports and were corrected.
In addition to the physical work performed Kr.AE required retraining of the construction craf t, engineering, and inspection personnel in the importance of assuring proper conduit separation. Also, a memo was issued to site organitations alerting them to the separation requirements, and the care that must be taken when routing cables within cabinets and l
panels.
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I A proposed change to the Wolf Creek FSAR was submitted to the NRC's i
Office of Nuclear Reactor Regulation (NRR) on January 14, 1985..to incorporate site procedural requirements into the FSAR. The change would accept the existing physical separation of nonsafety-related conduits to safety-related cable trays, based upon a KG&E evaluation. This change was accepted by NRR on February 15, 1985.
D.
NRC Verification of KG&E's Corrective Actions NRC Region IV performed an inspection of the areas where corrective action nn the NRC-identified violation was to have been completed. All of the examples cited in NRC Inspection Report 50 482/84-22 were found to have been adequately resolved and no additional violations were discovered.
The scope of KGSE's inspection of cabinets and panels in the control l
room was judged broad enough since several previous NRC inspections of cabinets and panels in other plant tress found no separation violations.
It was determined that adequate corrective action has been performed to resolve existing deficiencies, alleviate future concerns, and satisfy NRC Regulatory Guide 1.75 and IEEE-384.
The NRC closure of this violation is documented in NRC Inspection Report 50 482/85 03, which is attached.
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.m U. S. NUCLEAR REGULATORY CopMI5510N REGION IV MRC Inspection Report:
STN 50-442/85-03 Construction Pomit:
CPPR-147 Docket:
50-442 Category:
81 Licensee Mansas Gas and Electric Company (NG&E)
P. O. Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek Generating Station Inspection Att Wolf Creek Site, Ceffey County, Burlington, Kansas i'
Inspection Conducted: January 7-24, 1985 J33&f' Inspectorst M
- 7. Nu111 kin /Rescur Inspector, Project Dy I
SectionA,ItacterProjectBranch2 (pers. 1, 2, 3, 4, 5, and 6) 6 Yhu W
.Yb. N I
- f. I. Bes6,Reacter Ino)6Cter. Project Date
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Section B Reacter Project Branch 2 (pars. 1, 2, 3, 4, 5, and 6) hi,<s)
.5/tl0$
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'5. L. Madsen, Reacter Inspector, Project Mte Section A Reacter Project Branch 2 l
(par. 3)
I/ WA 4-4,,rev.d
- 6. i. n.run, i.r, v.ir Cre.n T.on rorc.
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Insoection Summary Inssection Conducted January 7-24. 1985 (Rgrort STN 50-482/85-03)
Areas Inspected:
Routine, announced inspection for the followup on previous NRC inspection findings and, allegations.
The inspection involved 76 inspector-hours onsite and 8 inspector-hours in-office by three NRC inspectors.
Results: Within the areas inspected, no violations or deviations were identified.
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Persons Contacted i
Kansas Gas and Electric Pa)
N. J. Sudd1ph II, Manager Quality Assurance (QA) 4 N. M. Lindsay, Superviser, Quality Systems i
i
- N. Headley, Nuclear plant Engineering
- 88. L. Stright, Licensing j
- T. D. Fay, Licensing i
aC. J. Noch QA Technician J.L.Blackwe1I,LicensingFire Protection Specialist N. E. Chernoff
)
)-
E. Peterson, Licensing j
.S M. F1, etcher Licensing The NRC ins ters alte interviewed other site personnel during the l.
l seurse of inspection.
- Denotes these attending the exit interview.
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2.
Licensee Action en Previous Insmettien Findinas l
l (Closed) Violation (482/8422-02):
Failure to maintain electrical separation.
The issue of 1-inch senduit-to-senduit separation i
J deficiencies was satisfied by the completion of M Corrective Action I
i Request (CAR) 15.
Under CAR 18. Daniel International Construction (OIC) i was to identify a11 violettens of the 1 inch separation eriteria in all i
2 "q' areas,andeerrectthemusingnonsenfermancereports(NCRs). After.
i
, DIC sempleted its work on CAR ll M Q4 perfereed a surveillance of the '
l l
inspectedareasandfoundsevereIunidentifiedseparationvietations, j
M rejected the DIC serrective action as ineffective, and subsequently, t
a joint DIC and M weltdown was initiated. ' This wellidown identified l
i
' only four additional violettens of the 1 inch criteria.
All vietations '
i were secrected as denoted by the closure of the CAR, Corrective action was t,aken to avoid further violations of this type.
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StartupFieldReport(SFR)1RL31wasinitiatedtoidentifyall i
i violations of the 6 inch internal sabinet separation criteria.
These i
l vielettens were corrected via the NCR process and closed out.
Corrective action was taken to preclude recurrence of this noncompliance,.
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The MC inspector visually inspected all MC identified separation violations to confire that corrective action had been performed.
It appears that M has adequately addressed the problems delineated in the violation.
This violetten is considered closed.
t (Closed) Unresolved Ites (482/M22-03):
potential flexible electrical j
conduit separations violations due to equipment vibration, transmitted hydre&namic. leads, or setseis events.
During the walkdowns associated with CAR ll, as described above, inspectors pliysically attempted to violate the 1 inch criteria by moving the senduits tot' ether and everlapping if possible. When released by the inspectors,rall senduits were observed to have maintained the required separation.
This action i
appears to satisfy this concern. This unresolved item is, considered slesed.
(Closed) Open Item (482/M18-02):
This item senserned the correct torquing of mounting belts for safety-related instrueentation.
SFR (50-72) had been issued to track and document the sempletten of the belt terguing concerns.
Construction Work permits (CWps) were issued and,.
work sempleted as required by 80-72.
The MC inspector verified that the work was sempleted and documented.
This itse is sensidered slesed.
(Closgd) Open Item (442/M 19 01):
Incorporation of revisions and issuance of fire protectioniprecedures and fire peoplans. The MC inspector confirood that all MC identified changes to procedures had been made and that the procedures and fire peoplans were issued..This open ites is sensidered closed.
(Closed) Open Itas (482/M 19 02):
Fire deepers operability during flou senditions, and maintenance procedure.
M procedure STS NT 026 was.
approved which will require periodis visual inspection of fire deepers.
ThetestIngofthefiredeepersduringflowcondittenshaspetbeen I
perfereed einse the required actions to be taken during a fire would be to Isolate the fire by shutting doun all ventilation fans to the effected j,
area. This appears adequate to resolve this sensern.
This open ites is-sensidered closed.
(Closed)'Open Itse (482/M 19 03), Test of portable radies' needed to support the safe shutdown function.
The licensee supplied the MC.
inspector with the results of a test that showed that communicettens b.two.n,i.nt insti.no nu.ss.u t. shut M.n the,i.nt free.vtsin the control room and the auntliary swtdown panel were feend settsfactory.
l Also checked were traffic restes between locations.
This open itse is sensidered sieted.
r (Closed) Open Itse (442/M 19 04):
Inadeewate esereency light.ing.
The MC inspector verified that the previeve1y identified lighting deficiencies l
were secreep. However, a new precedure for evetuating the centrol roen j
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due to a fire was developed after the previous inspection..This procedure i
was walked down in its entirety to assess the emergency lighting in areas
)
i not previously inspected by the MC. The MC inspector identified three i
areas to the licensee where existing lights needed to be realigned.
h se l
lights were subsequently redirected, and a followup inspection by the MC inspector showed them to be acceptable. This open item is considered i
closed.
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(Closed) Open Item (482/8419-05):
Caspletion of all preoperational fire protection tests and the completion of an acceptab1d set of fire pump i
{
operation curves.
The itsensee confirmed that all fire protection preoperational tests had been performed.
In addition the licensee
{
performedfirepumpperformancetestsontheirelectrIcanddieselfire 3
pumps. Curves were shown to the MC inspector and'these will became their base curves. This open item is considered closed.
(Closed)OpenItem(482/8419-06):
Installation of all fire barrier penetration seals. The MC inspector was informed by K845 that the i
. insta11ation of all penetration seals required for safe shutdown was completed on January 12 1g85. However, due to modifications requiring i
maybesea13ofsomeoftheseseals,notallsafeshutdownpenet the breachi en a certain day. This concern is siieviated by the site Technical Specifications which will require a fire watch for each breached l
seal. This open item is considered closed inthecontrolroom(ventilation) ducting. Adequacy of fire protection detect (Closed)Openitem 442/8419 07 :
N MC inspector reviewed an i
1 analysis of the fire detection arrangement in the control reen, which-l included the insta11atten of two additional detectors in the centrol room.
l This appears to satisfy the concern. This open item is considered closed.
l (Closed)O Ceapletten of identifted fire barrier wrapping.penitem(442/841908):M&E confirmed to the MC inspector i been completed. A visual inspection was made of a sample of the completed '
l
, wraps in the sumiliary building by the MC inspector. These wraps appeared to satisfy separation requirements. This open item is considered' cle~ sed.
[
(Closed Open Item Isolation of diesel generators from the control)roomandthe(442/8419091: analysis s the spurious signal concern. The MC o
inspector reviewed and walked down procedure OfN 00 017 for the evacuation of the control reem due to a fire.
This procedure, along with physical modificationsfallowsfortheisolationofthedieselgeneratorsandtheThis open elimination o spurious signals to selected equipment.
considered closed.
(Closed)O Issuanceofanacceptablehetshutdown precedure,penitem(442/641910): training of operators and demons 0
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6 MC. The MC inspector reviewed and welhed down Procedure OFN 00-017 for the evacuation of the control room due to a fire. The licenseesaise provided records of the training of personnel in this procedure. This appears adequate to resolve this concern. This open item is considered closed.
(Closed)Openitem 482/8413-11):
Alternate searce of power inde of the control reen(, for the pressuriser reitef isolation vaIves (pendent PRIV).
The MC inspector reviewed procedure 0FN-00-017 which demonstrates how the PRIVs can be iselsted from the control room and still have power. This 3
open item is considered closed.
3.
Fellowes en Alleestions a.
(Closed)A11egation.(4-84A-71): This allegation concerned a number of items in the startup program.
Included are several Met SFAs dealing with the fire protection program that the allegers felt were incorrectly dispositioned..The following are the investigations of each,allegatten ites:
A11eestioni part 1: SFR 1-RC M." stated that site specifications require snet halen piping be rigidly supported to prevent swaying.
.The SFR liste(Sechtel's response was that the ters 'rigidlyseveral fire requirement.
supported
- does not mean " supported with no movement." They stated that additional restraints would be added if found necessary due to preoperational, tests.
i part.1:
The National Fire protection' Associshon fMFPA)
.itA states, in part. 'The piping system (halen) shal' be securely supported with due allowances for agent thrust forces, thermal espensten and contraction and shall not be subjected te mechanical, chemical, vibretten er other damage."
The Rut startup engineer who originated SFR 1-RC N was interviewed e.
by the MC inspector. The startup engineer stated that this SFR was written before the piping wa11 penetration seals were installed. At that time, unacceptable sevement was observed.
However, he stated that the proeperational halen teste performed on the systems at the time of the interview showed no adverse problems with pipe sway.
i Part 1: After en investigation of this allegation, it that although the werd ' rigidly
- ma be inappropriate as the present halen pi system does not usedinthevenderdrawingforpipe'eevementerF violate the NFPA standard taunitments.-
part 1 of this allegation could not be substantiated.
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- part 2: SFR 1-KC-41 stated that the infra-red view in the diesel generator teens are severely obscured by pemenent HVAC ductuerk, catwalks and the diesel generator silencer. These detectors are line-of-sight devices and must see a fire to operate. This, acderding to the SFR. is a vielstion of NFPA-7tt. Bechtel responded that the reens have the required detector coverage and that the obstructions noted in the SFR were temporary due to sonstruction activities.
i Part 2: The NRC inspector toured both diesel generator seuld find me pemenent structure that appeared to obscure the detectors' view. A review of the prosperational tests for these reens($U4-EC03)showedthatthedetectorsperfernedasrequiredby site requirements for a staulated fire.
s Port 2: Based upon the above findings it is concluded
- natalled infra red fire detectors in the diesel generator reens are adequate in mus6er and location. Part i of this allegation,
seuld not be substantiated.
Port 3: SFR l-RC-45 stated that the F8A'R E'RMe: tecti..nd aia. in safetereisted areas Mtres that issa A circuits. Newever. according to the 5FR, Bechtel Drawings 10444-N 6SI-0074 through 0075 shou S4 out ef 103 senes,in safety related areas as Class g strsvits. The SFR recommended revision of design documents and the PSAR. Sechtel rejected tho' proposed resolution and accepted the design 'as is' stating that FSAR soumittaents were set.
Find < nes Part 3: The FSAR. Section 3.5.1 requires, in part. "In sareyr related areas, the fire detettien an$ alem system meets NFPA-720 Class A.*
NFPA-720 states, in part. 'll be casable ofA smoke detec ses41natIenofaC16;sAProprietary tem sha operating for a sache alors signal du a single break or a single',
eround feelt sendition of the circuit wi ins senductors (a) between,
the sentral supervising station and the smote alors signal transettler and the smoke detector sentrol unit...*
AnNRCfirepr6testionengineerinfotoodtheNRCinspectorthatthe NRC interpretation of NFPA 720 is that the actval fire detettien circuit (fromthedetectortothecontrolunit)doesnothave'tobe Class A as is the sentention in the SFA.
Part 3:
It is sentivded that the present design of Part 3 of this a11egation seuld not be substantiated.quirements.
testion circuits satisfies FSAR and NFPA re p
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I A11esattent part 4: SFR 1-NC-46 stated that, for fire protection system KE-ol KC-06. KC-07, and KC-Og each main and reserve bank of j
halen cylinders has parallel solenoid actuators where the tochtel drawings show only one. Also, the SFR stated that this arrangement does not allow for the required solenoid coil supervision. Sechtel's I
response to the SFR was to initiate a design change to show the para 11e1 coil arrangement en the site draw < nos.
They further stated l
that the parallel solenoids are supervised and, thus, no additional changes were made to design.
part 4: Bechtel Drawings N-458-0035-03 and M-458-0038-03 viewed by the NRC inspector. The inspector verified that a change was made to these drawings to show the parallel solenoid actuators. The redundant solenoids are installed in areas required
, for the safe shutdown requirements of 10 CFR SO Appendia R. This arrangementprovidesanentremeasureofreliabIlity.butisnot required by the NRC. The NRC inspector determined that electrical supervision of the redundant solenoids is available under the present arrangement.
- part 4:
It is concluded that the present arrangement of parallel solenoids actuators satisfies both FSAR and NFPA rAquirements., part 4 of this allegation seuld not be substantiated.
A11eestions part 5: SFR 1 kC-47 dealt with the r supply to the fire precoction control cabinets. The SFR had the 11 ewing three concerns:
1)
The de power supply is rated for 130 to 170 volts de' but the required input range is 108 to 140 volts de per Sechte)
Specification No. 10464-N-ele.
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The power supply is oeunted flush against the well but the annefacturer recommends a 1/2 inch stand off for ventilation.
3)
There is no indication that the power supply is listed er approved for fire protection service.
'l Sechtel's response was that the power supply is acceptable for.its intended service.
Findinant part 5: The halen centrol panels require a reevleted r supply. The plant dc power can very from 106 le 140 volts.
ver the regulated power suppIy in the control panel is listed for a II0 to 170 volt es input range. The vender has supplied inforestion from the manufacturer of the centrol panels that the regulated power supp1r will operate satisfactory at the different input rpnge. Also, t w asnufacturer stated that flush mounting of I
4 g
g 4
9 g
I g
y
,,m-_,-._
- l I
j.,
i t
i the supply would have no adverse effect en its operation. Although the r supply is not UL listed the sentrol pene), with the power supp y is approved and Itsted by Fastery Mutual for fire protection j
serv se which satisfies FSAR and NFPA requirements.
t j.
Conclusient part 8:' Based upon the above findings it is sensleded snes sne malen sentrol panel will operate satisfactory with the installed power supply. part 5 of this allegation seuld not be substantiated.
i
- part 6:
SFR 1-RC S! stated that en improper ertup on a l
to pressure switch RC-pSM143 required the replacement of a ring type lug with a split type Ive. The SFR questioned this replacement. Sechtel's response was that the installation was I
i asseptable due to the fast that the conneetten was fast 11tated in a 1
craftsmanline asaner and the pressure switch is a sempenent of a
' supervised circuit. A fatture mode such as en open er short circuit
{
would alare in the sentrol reen.
part 4: techtel Specification M-og0-04 does not address of Ive required. An inspection by the NRC inseester of local panel IH, where switch terminetten is lesated, showed that no
>enesual stress would be put on the connection.
It appears hiehl un1thely that the split type lug soulil lose electrical sentact. y.
i f
part 4:
Itissensleded,basedopentheabovefindi1s e
of this allegation seuld not be substantiated. quirements.
termination satisfies FSAR and NFPA re part t
part 7: SFR l EC 47 stated that a flew was dissevered lesheeting and thesteut of the RC.00g fire slave panel in sentrol room. An incoming alors signal caused 1 a printout.
l a blinking LED annenstetten, and L3 audible ann (en) station. I l-ating LES went solid and the audth e) stepped when the alors was 4
t i
acknowledged. The problem osevered, asserding to the SPR. when en l
input signal went through several shenges of state rapidly, Itke the,
bouesteg of a sentact. The annuntater windou would sleer after l
l beine schnewledged but the audible signal sentinued to sound until it i'
i had been acknowledged twice as eeny times as the centset bounced.
The result was having a seemingly clear board with an audible alarm, that would eet step, techtel responded to the lfR by statin that the operetten of the control panel was neraal as described. g'he T
l l
nuisance alares were to be espected during inspection and testing. -
l Subsequently,startu lechtel's response. p initiated a second SFR dissereeing with In addition, the stated that retors were observed estne=1 edging RCoog a hented eierm by key ng $n m A v
(return).AAA(return).AAA(retsen),a etc., unt 1 the ruy w e i
I i
l l
i
30-went away. They did not have to in the specified sequence of acknowledge).(senenumber),
er 1 (for ale m er tre ele). The 1 (ible alarm was noticed by sta tT cease, based on the right aud number of acknowledgements, regardless of which sone entry was inputted.
- Part 7: The Quality First organisation at Wolf Creek aise ted this matter.
Subsequently. SFR 1-KC-Itg was'tasued to resolve the prob 1 m., Coordination among the manufacturer. K468 resolutionthattheoperationofandBechtelresultedinthethe panel is as in Nuclear Plant Ensincering (NPt) requires. Quality first did not substantiate this all,ogation.
part 7: The above finding's a rto'adebatelyresolve part 7 of this allegatten seu d not be sestantiated.
1
- port 8: SFR 1.RC-lg stated, in part, that the halen system seuld be put inte en inhibit mode which would not allow automatic or manual electric eushbutten actuation of the system. The alleger slaimed that the only way to discharge halen in en emergency, while the system is in the inhttit sede would be to eperate the annual lever at the tanks. This operatier would discharge he into the protected area but would not slese venttistion er shut off the MAC system. ' This, according to the alleger, wou d aske the halen system ineffective due to the helen sencontratten being dissipated through the MAC.systs. The remaining halen seuld decompose, due to the heating of the halen.
into taals gases and a ad inte other areas of the plant. The SFR recomended a design a to permit the annual electric discharge pushbutten to everride inhibit switch. Sechtelrejectedthe.
!as osed resolutten to the SFR and esse y the present designSubseque rep '
ts.
5868 NPt agreed with tochtet s evaluetten.
needed to resolve the proble(1 RC 78) which depicted the desten c startup tesued another SFR stated in SFR l-8C 09. Seshtel and NPE
. j.
rejectedthisresoluttenelse.
i part 4: The use of the inhibit switch is to allow for of the protected area during pertede of estatenance. The MC nopector dissevered that the SFR was serrett in stating that menval estustion of the helen would not shut down the M AC system er close despers. Newever, there are sov. oral design and administrative sentroleineffectthatwouldeliminsteamejorprob1m.
In the event of the helen system being put into the inhibit mode, site Technical Specificellent will require a continuous fire watch in the aree.
If a firt essvered ehtte the system is in the inhibit mode, e detettien signal would be received in the sentrol room even though halen would not discherge. The approved site fire peoplans require the togtre) roen operators to iselste the fire by snutting down the MAC fens and despers to the effected area.
B 9
- ~
A
- r...
?
1
- part St Based upon the above findings it is concluded resent design could allow halen discharge without dampers closine and the NVAC system shutting down, but administrative controls in effect will eliminate any concern, part 8 of this allegation is partially substantiated but appears to have ne safe shutdown significance.
11 part g: 5FR 1-KC-40 stated that five fuel building fire s and fifteen turbine hvilding horns failed to operate during tests due to corresten en electrical contacts. Also,some turbine building horne were indistinguishable from background noise.
Bechtel's response was that once the plant is operational a surveillance procedure will pertedically verify that the horns,
function. Also they stated that the background noise.in the turbine building will diminish during neraal plant operation.
i part 3:
NFPA-7tA requires that audible alares be from the environment sad that they be heard clearly regardless of the monimum noise level obtained from machinery or ether equipment under permal conditions of occupancy.
RS&E has a sveveillance procedure which will require periodic testing of the audible alares. The Quality First ernanisation aise investigated this allegatten and determined that the back round noise level'sheeld be tested durine power ascensten to adequate r determine whether horns seuld be heard. Quality First stated ut this will be added to the open items work list and will be tracked through the closure process,for Quality First File QCl-84 24W.
Conclus'est part 3:
It is concluded that serveillance tests will be aseguaso se detect faulty horns,ls in the turbine building, and that further tests will be -
needed for backaround nette leve part 3 of this allegatlen is partially substantiated but appears to have no safe shutdown significance.
part l'0: SFR l RC 64 stated that the smoke detection he south electrical penetration reen does not meet NFPA 7 t Ig78 sriterte. This requires more detectors in en area when structural beams are more than eighteen inches deep.
In additten,in the SFR described two cross sened detectors (197 006 and the north electrical penetratten roen ehtsh are separated by a fu height well.
Sechtel responded by adding addittenal smoke detectors Newever Bethle) stated that the structural beams only where needed.
enceed eighteen inches,in' depth when fireproofing material is added which they sensidered to be the terrect interpretation of the NFPA,
standard.
R848 startup initiated another SFR which stated o to attepting Sechtel's interpretation of the NFPA standard. ppositten g
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1 u,
33 Findinast part 10: The NRC inspector conferred with an NRC fire protection engineer who aereed that Sechtel's interpretation of the NFPA standard concerning 6eam depth with fireproofine added is acceptable. Bechtel Drawing E-1F1401 was reviewed which showed the location of additional smoke detectors in the subject areas. The NRC inspector verified that these detectors were actually installed.
The north electrical penetration room was inspected by th' NiC and a
found that two cross sened detectors were separated by a full height wall. However, both detectors are located within the protected area oftwoothercrossseneddetectors(114-007and107-003).
- part 10: Based upon the above findi l
resentsystemofdetectorssatisfiesbe3's1.tisconc,luded I
F A and n,A j
p, requirements. Part 10 of this, allegation could not be substantiated.
{
A11eestion: Part 11: SFR 1-EC-68 stated that, contra to NFPA pendentheadswhenusedindroptileceilingareas.SeNels requirements, return bends'were not installed for wet p s rinkler
)
responses was that the NFPA standard does not require return bonds in
[,
the subject area.
Pai$ 11: NFPA-13 states, in part "when piping on wet areconcealed,withsprinklersinstaIIedinpendentposition leu a ceiling, return bonds shall be used when the sprinkler system is from a raw water source...* The use of return bends is reevired l
to minimise sediment build up in the sprinkler heads. The Quality j
First organisation aise investigated this allegatten and found it te l
be substantiated. Thecorrectiveactionisbeinghandledthrough l
Ovality First File OCI-84 t4W. The area in question is not an area l
l required,for safe shutdown.
l~',
a Part 11:
It is concluded that the use of return bonds sprinkler heads are required to satisfy PSAR and NFPA requirements.
Port 11 of this allegation is substantiated but l
l appears to have ne safe shutdown significance.
Part 11:
SFR 1 RC-4g state'l that the FSAR and site '
i ions require that visual and audible local alares and
'j i
l trouble indicaters be installed on field deluge valve panels. The panels de not have the'se alarms and indicators. Bechtel's response
}.
was to accept the system *as is.*
i Part 11: Section g.lt of the FSAR requires the fire i
system to alare 1eca11y and in the control room. the NRC i spector elscussed with an NRC fire protettien engineer the
(
definition of " local." The engineer stated that the NRC, interprets a
e
y_,
i local indication and alarming to be at the multiplexer and not at the field deluge valve panels as alleged
==
Conclusion:==
part 11:
Based on the above findings it is concluded snat sne present design for' local indication and alarming satisfies F5AR and NFPA requirements.
Part 11 of this allegation could not be substantiated.
Allossuion part 12:
SFR 1-KC-70 stated that NFPA-12A requires the for ow< ag for the halon discharge system:
- 1)
- Design nozzle pressures shall be not less than 200 psig.
- 2)
- The agent discharge shall be substantially complete in a nominal 10 seconds.
The SFR said that Bechtel Drawing M-658-0046-01 allowed variations to these requirements in violation of FSAR commitments. Bechtel accepted the system "as-is" since they stated that NFPA allows longer discharge times, and the discharge nosale pressure requirements has been removed from the NFPA standard.
F<ndines Part 12: Section 3.5.1 of the FSAR requires that halon r<re protection systems be designed in accordance with NFPA-12A-1973..
NFPA-12A-1973 required that design nostle pressure be not less than 200 P5IS. Subsequent issues have this requirement removed. Also-required in the NFPA standard is that the halen discharge shall be setstantially completed in a nominal 10 seconds or a shorter time if rectical, unless a longer discherge time is specifically permitted the authort having urisdiction, prosperational tests have several scharse ines greater than 10 seconds. The American Nuclear Insurer, which is the authority having jurisdiction for inserence pu ses. has accepted,1enger discharge times based on the larger capac halen tanks used over what the design specifies. An variations from nosale pressu.has informed the NRC inspector that the NRC fire protection engineer re and discharge time requirements are acceptable.
Part 12:
Based on the above findines it is concluded '
chtel response to this SFR is accepta61e.
Part It'of this allegation could not be substantiated.
A11eaation:
Part 13: SFR 1 tC 73 sta'ted that halen discharge pressure switches were not wired to shut down the WAC system once halen discharged as r6 quired by the PSAR. gechtel's response was that the MAC system needed to be shut down prior to halen discharge 4
1.,
to eliminate loss of halon due to the fans coasting down. Bechtel subsequently revised the FSAR to reflect their design intent.
/
Findinos: part 13: Section 3.5.1.2.3 of the FSAR was; revised to colete any reference to the initiation of the shutdown of associated equipment by the halon dische pressure switch. This design was found to be acceptable to the C
==
Conclusion:==
part 13:
It is concluded that the present design for nunc system shutdown satisfies FSAR and NFPA requirements. Part 13 of this allegation could not be substantiated.
A11eestion: part 14:
SFR 1-EC-74 stated that the. water flow
. pressure switches for fire protection control panel 322 and 323 in the north and south electrical penetration areas fail to' provide Class A function as described by NFPA-720 and required by the FSAR i
. the system "as-is."
BechteI'sresponsewastoaccept for flow monitor device circuits.
Findi'nes part 14: The FSAR. Section 3.5.1 states, in part. "In NFPA y-related areas, the fire detection and alem system meets safet 720. Class A."
NFPA-720 states in part. " Class A system provides emerge operation for fire alam, waterflow alam and l
guard's tour si 1s during a single break.or a single ground fault of the signa 11 line circuit."
The alleger interpreted the signaling line circuit to mean from the detector to the transmitter and beyond. Bechtel's interpretation was
)
that a signaling line circuit runs from the transmitter and 'beyond.
Thiscircuitisalres(yClassA. A discussion between the NRC inspector and an NRC fire protection engineer revealed that techtel's,
interpretation of a signaling line circuit is correct.
I Part 14:
It is concluded, based on the above e
that circuit design for the water flew pressure switches satisfies FIAR and NFPA requirements. part 14 of this allegation could not be substantiated.
Alleeso,1ons part it:
SFR 1 RC-H stated that in the cable choses aeJeIn' ng electrical equipment rooms, a water sprinkler system has replaced the originally designed halon system. The concern in the SFR was that consideration had not been siven to possible water damage to the electrical equipment and electrical penetration seals.
Sechtel's response was that fleer penetration seals in the table chases could withstand the pressure of water buildup and drains could handle the overflow from the chases.
l 3
8 a
8 i
r
?
Findinfis:
Part 15: The NRC inspector reviewed the data suppiied by Bechte' and inspected the electrical equipment rooms. There is no indication that the drains would not be able to eliminate water buildup in these rooms and the penetration seals would be breached.
==
Conclusion:==
Part.15~: Based on the above findings, it is concluded that the present fire suppression system in the cable chases satisfies FSAR and NFPA requirements.
Allegation:
Part 16: SFR 1-SU40 stated that the penetration seslant being used between the north and south electrical penetration room walls and the outer containment wall is a combustible type material. Also of concern was that flannable caulking was being used around numerous fire doors throughout the powerblock. A handwritten connent on the SFR said that Bechtel pigeonholed this $FR until a new one(SFR1-SU-94)waswrittenonthesamesubjectwiththe"yes" box checkedfor10CFR50.55(e)reportability.
Findinfis:
Part 16: The Quality First organization also investigated thisa' legation (QCI-84-24W)anddeterminedittob substantiated.
This allegation subsequently became a 10 CFR 50.55(g) reportable item e
(53564-K140).
==
Conclusion:==
Part 16: Part 16 of this allegation was substantiated.
The safety significance and generic 1'mplications of this~ deficiency are discussed in NRC Inspection Report STN 50-482/85-04 for the i closure of this reportable item.
Allegation:
Part 17: The alleger stated that construction had landed many electrical cables using nylon screws and washers to allow for construction completion, but at the same time not allow the
~
- 3-circuit to o wrate. The alleger believed that there was no control over where ttis was done and that testing was being relied on exclusively to find and change the screws / washers.
Findings:
Part 17: The subject of the use of mylon fasteners was previously found to be a violation of 10 CFR 50. Appendix B.
requirements, and documented in NRC Inspection Report STN 50-482/84-05,;
i dated February 29, 1984. This violation was subsequently c1(sed out in NRC Inspection Report STN 50-482/84-15 dated September 6, 1984.
==
Conclusion:==
Part 17:
Part 17 of this allegation is substantiated based on the NRC's issuance of a violation.
Allegation:
Part 18: The alleger stated that many systems were turned over from construction so incomplete that test procedure i
sequences had to be altered by test change notices (TCNs) in a gr.oss manner and that'startup testing was not well sequenced or integrated.
9
~
Finding:
part 18:
During the initial phases of startup testing, the NRC Inspectors observed a lack of comunication between test engineers. Additionally, the lack of good sequencing procedures resulted in the need for TCNs. Most of the required TCNs resulted from the impact of integration of different tests which were being performed on similar systems plus word and gramatical corrections.
Issued TCNs were not associated with the incompleteness of systems.
==
Conclusion:==
Part 18:
Most TCNs were administrative in nature rather than a. technical system change. The large number of TCNs did not invalidate the acceptability of the systems or the acceptability of.the
. preoperational test program..
~
b.
(Closedh Allegation (4-84-A-114): This allega' tion concerned several safety 1 ssues on the fire penetration seals, and of reprisals mode against the a11eger for identifying them. The following technical issues were identified:
1)
Due to pressure exerted by the production department of 888
~
construction to install penetration seals at a fast pace, some in-process and post installation QC inspections were not performed.
~
2)
QC was told to write only a limited number.of NCRs.
3)
NCRs were not processed in a timely manner.'
4)' Quality of penetration seals was suspect.
Findings: The Quality First organization investigated this allegation also under file number QCI-84-93W. They performed an in-depth investigation into each concern. Quality First was able to substantiate the allegation that in-process and final inspections for fire penetration seals were not performed.
It was found that during a period from March to June 1984 some inspection hold points had been bypassed. Quality First issued Quality Program Violation 8/84-24 to determine how many hold points were bypassed. inspect them, and develop measures to prevent recurrence of the problem. This has subsequently been accomplished.
The NRC inspector discovered that a random reinspection of foam penetration seals was conducted during March 198a at the request of KG&E. This reinspection was initiated due to concerns raised at.
i. : '..
i.
Callaway on the quali of seals there, and covered approximat'ely 55 percent of the tota population. No significant problems were identified. The NRC inspector also randomly inspected penetration seals in the control and auxiliary buildings and found those to be acceptable, based on,B&B inspection and' manufacturer criteria.
j The allegation into the reprisals against the alleger for identifying j
safety issues was investigated by the NRC Office of Investigations i
and documented in report Q4-84-048.
1
==
Conclusion:==
~
i
' Based on the above findings. It is concluded'thqt some required:QC inspections of fire penetration seals were ssed. This allegation was partially ~ substantiated, and appears to ve had safe shutdown significance. However, corrective action is considered istisfactory to resolve this concern.
c.
(Closed 1 Allegation (4-85-A-045: The alleger stated that 'the resolut1on to KEEE GAR 15 was <nadequate due to the use of unqualified DIC QC inspectors. CAR 15 dealt with the corrective action required for NRC Violation 50-482/8422-02 concerning violations of the 1 inch separation criteria for electrical conduits.
In addition, the alleger stated that NCRs 19715E and 20443E i
identified minimum bend radius probleins in small terminal enclosures 2
but many more exist.
The NRC inspectors identified the four DIC QC inspecths Findings:
that participated in the walkdown associated with CAR 15. The j
qualifications and training for these inspectors were reviewed.
Although the NRC inspectors were unable to determine how much actual.
inspection experience each person had relative to electrical separation, each QC inspecter was trained and certified for that disci line. Also it was datarained that each inspecto' was given a r
refre her course in separation requirements prior to the walkdown.
After DIC completed its walkdown and performed corrective action.
1 KG&E QA did twir own walkdown and found other separation deficiencies.
KG&E rejected the corrective action as being-i inadequate and instituted a joint DIC-KG&E walkdown of all areas (Details are given in paragraph 2 of this report for the closure of'
)
NRC Violation 482/8422-02.)
thetwoNCRsnotedabovewerereviewedbytheNRCinspector. These.
NCRs dealt with the separation problems associated with CAR 15 and not with minimum bend radius problems as alleged. The area of conformance to minimum bend' radius requirements has been the subject of sever 61 MRC inspections as documented in the follcwing NRC
~
Inspection Reports: 50-482/82-08. 82-17. 83-03, 83-31, d3-3S. 84'-02.
i l
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and 84-05. These inspections discovered no adverse minimum bend radius problems.
1
==
Conclusions:==
Based on the above findings it is concluded that there is no evidence to suggest a significant problem in adherence to
)
minimum bend radius requirements within enclosure. 'Even though the qualifications and training of the DIC QC inspectors appe.ar adequate, the separation walkdown was inadequate as supported by the KG&E rejection of CAR 15's corrective action. However, KG&E's prompt action in this matter appears to have eliminated any concern. This allegation is partially substantiated.
d.
LClosed) Allegation (4-84-A-76): The concerns of this. allegation
~. tnvolve a wide range of technical and procedural questions in the areas of instrumentation and control (ISC) calibration methods.
~
These concerns are the results'of decisions made on technical and procedural issues that the, alleger did not agree with. The NRC inspector reviewed and investigated the concerns of the alleger which could have an impact on plant safety. The following is a susmary of each item:
i Allegation:.Part 1: The a11eger stated that component ratesting was
~
performedusingastartupprocedure(SU6-CSO4)ratherthan i
Operational Procedure ADM 08-806.
Investigation: Part 1: The NRC inspector reviewed the referenced procedure (AUM 08-806) to ascertain whether procedural instructions were being followed during component testing. ADM 08-806 applies to the operational recalibration program. This procedure is implemented after Operations has jurisdiction over components turned over from
~
the startup groups. Until the operation groups receive turnovers fromthestartupgroups,startupprocedure(SU6C504)isusedfor l
initial tests. Any ratests requested are by CWPs. The NRC inspector reviewedamemo(RJG-084)fromthestart-upmanagerreferencing F
initial component calibration and recalibration. This meno was l
written to system engineers to clear up apparent confusions, concerning component calibration and recalibration program for instrumentation. The meno stated that all initial component testing wouldbeperformedunderthestartup(SU6-C504)testprogram.
==
Conclusion:==
Part 1: 'Because there was a possible misinterpretation of the applicable procedures, KG&E issued Administrative Procedure Change Notice ADM 14-003 Rev. 9.
This amendment was written to i
delete the requirement for entering component into the site i
calibration program a.fter testing, thus eliminating the possibility ofconfusingwhenstartupprocedures(SU6CSO4)orOperation l
Procedures ADM 08-806 are to be implemented. The investigation l
.c
~
r.,
19-4 l
findings concluded that correct procedures.were being followed. On l
this basis. Part 1 of this allegation could not be substantiated.
4 i
Allegation: Part,la: The alleger stated that data on' switch test records was ir. consistent with the Wolf Creek Generating Station Total PlantSetpointDocument(TPSD)andtheTPSDisinconsistentwith Vendor Prints.
i l
Investigation: Part la:
The NRC inspector reviewed cal'ibration test records of several switches to ascertain if inconsistencies existed 4
i between the TPSD or if the TPSD was inconsistent with Vendor Prints.
The NRC inspector reviewed the test records for G-DSL-106A. This l
instrument had been identified as having incorrect or inconsistent i
documentation. Also reviewed was the TPSD to verify if there was a 1
difference in setpoints. After reviewing both the tes't records a~nd TPSD the NRC inspector noted that there was a difference in
+
setpoints. The test record listed the tolerance of the instrument as being 2 12 psig. The TPSD listed the tolerance as +10,-0 psig.
According to drawing MD 18274-5 the TPSD is correct. However, the test records showed the actual error to he +3 psig. Since this was within the +10 -0 psig tolerance, the component test was acceptable.
The NRC inspector also reviewed the test records for instrument.
G-TSL-163. The test record had an accuracy of 215 per vendor print The licensee stated the accuracy of (*.15)y was' stated aswas a t According to the TPSD. 'this accurac i
- MD 18-271-4.
2.15.
error. A recent revision to the vendor print (M0 18-271-5) has -
t l
revised the setpcints to read 25'F at 40*F. gl.25'F at 225'F. With the new revised setpoints, the allowable error should have been 22*F i
per the setpoint tolerance in the TPSD. The test record shows the actual errors to be *1.2*F.
Since the actual error is within the H -
2*F tolerance, the component test.was acceptable. The TPSD typographical error has been corrected. The licensee stated that Procedure ADM 14-103 clarifies what steps are taken to correct inconsistencies between the TPSD and etter documents.
l Paragraph 4.3.2 states in part. "If a conflict occurs between the TPSD and another design document, testing may proceed using the TPSD as the le6d document.
In this case, results engineering shall be notified and a startup field report (SFR) written to correct the conflict.' The NRC inspector was advised that a SFR is not required to be written if the TPSD is to be. revised to agree with a design
'ocument. A SFR would only be written if design document revisions.
d i
are required or. if there are discrepancies between design documents.
Since the TPSD only needed to be revised to raficct the latest vendor l
prints, no SFR had been written to correct the discrepancies. The NRC inspector verified that all documents had been corrected.
{
l
(
i
[
m 1
4
Conclusion:
Part: la: After an investigation of other documentation j
.to verify if inconsistencies existed, the NRC inspector noticed that another instrument (G-TSL-163) had a discrepancy in documentation.
j The discrepancy was caused by a drawing change which also resulted in the TPSD requiring changes. For all cases identified, where the wrong allowable error was used, the actual error was within the setpoint tolerance.
In view of the inconsistencies found, there is no impact on any preoperational test results. This portion of the allegation is substantiated; however it was found to be without i
technical merit.
~
i-Allegation:
Part Ib:
It was alleged that data sheets generated by 15C using Procedure SU6-CS04 did not provide sufficient detailed actions necessary for unique testing of individua1' components. Also.
calibration data sheets for level indicators LI 0031 and LI-00131 were found not to have been corrected for using water in the calibration media instead of lube oil, as requ' red by startup. field report (SFR) U 13.
I Investination:
Part Ib:
Data sheets for several instroents were reviewed to ascertain if sufficient information was available to insure that individual components are correctly calibrated. The
.Qvestigation revealed that indicators LI-0031 and LI-0131 were originally calibrated with no specific gravity compensation. The test equipment indicator used to perform the test was " inches < f water." Since there is a specific gravity difference between oil and water, retesting of all instruments was done p'r SFR (G-13). This SFR corrected all level type devices to show inches of oil" for actual level. Due to a technician error. LI-0031 was tes'ted without this correction.
CWP U -4051 retested and corrected this device..
The technician was notified of his error. The level III personnel l#
had been reinstructed to review tests for proper conditions.
==
Conclusion:==
.Part Ib: Based on the investigation above, it appears that Inc procedures did provide sufficient detail to assure objective evidence of acceptable testing. This was clearly stated in Section 2.0 of Procedure SU6-C504. There appeared to be confusion by the !&C technician concerning compensation of the difference in specific gravity of water and oil. The investigation also conclude:I that the allowable instrument error would have been in its
);
uncorrected state, within the acceptance criteria. Since ISC i
identified, corrected, arid documented the errors comitted by ISC technicians this portion of the allegation cannot be substantiated.
Allegation: Part 2: This allegation states the G system component-retest data sheets did not contain the 'as found" condition or i
corrective action performed.
i e
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m __ m m _..,.
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/
Investication:
Part 2: Administration Procedure ADM 14-102 w'as reviewed to setermine if instrument data sheets were required to list as found conditions during startup.
For a typical startup tes't procedure, the " prerequisites" section provides the "as found" condition, and the " restoration" section provides the "as left" condition. While the "as found" and "as left" are not specifically listed, the signoffs for the prerequisites and restoration are made.
In place of recording this data, visual checks were made of the instrument condition denoting the "as found" condition. The calibrated device test data is recorded. The Operational Calibration Program (ANSI N18.7) does record "as found" and "as left" data.
For startup purpose, the initial calibration as "left data" is all that is appropriate. The NRC inspector was informed that ADM-102 will be revised to clarify this issue.
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Conclusion:==
Part 2:
Based on the review of ADM-102,it is apparent that misinterpretation of this procedure is possible. However, this portion of the allegation could neither be substantiated nor found to l
have any technical merit.
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l Allegation: Part 3:
It was alleged that I&C was not documenting rejection of out of calibration instruments.
i Investigation:
Part 3: An investigation into the allegation revealed that G-P1-0193. G-LI-0131.' and PT-0126 did not appear to note exception documented by RCIC-2067-G. RCIC-2066-G and i
RCIC-2068-U.
Procedure SU6-C504 was reviewed and found to contain j
steps 7.2.1.4 and 7.2.2.6 instructing that for unsatisfactory tests
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utilize the guidance in ADM 14-103. Section 4.5. on procedure ADM 14-103 Rev.19. Section 4.5.1.1 Part b, states in exception.
part. "or if as a resuit of the exception (e.g., component will be rejected out of startup jurisdiction) the test record will not be completed and no credit taken for the test wrtion performed, the test data sheet may be discarded." Since tto three items listed above were not reworkable, they were discarded, as well as their data sheets. The new instruments were calibrated using new data sheets.
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Conclusion:==
Part 3:
Based on the objective evidence examined and l
procedures reviewed. IAC were following administrative procedures and appropriate actions were followed. This portion of the allegation '
could not be substantiated and did not appear to have any technical merit.
A11ecation: Part 4: This allegation stated that I&C Level III personnel signed preoperational steps stating that necessary i
retesting recalibration is currer3t and data sheets are available.
The level III technicians indicated that 9nly ratesting/recalibrations contained in Appendix 8 were current and available and not other '
i instruments used in the preoperational % sting.
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i Investigation:
Part 4: SU3-KJ-01 was reviewed to determine if the l
procedure required Level III personnel to sign data sheet stating that all necessary retesting /recalibration was current and data sheets were available. The NRC inspector contacted the Level III personnel involvet' to try and get their interpretation of this procedure.
It was stated that steps 6.1.23 and 6.2i23 of the data sheets are signed by Level III personnel to assure that all components covered by the preoperational test have been tested, and that data sheets are available. This was consistent with RJG-084. After conversation with the Level III personnel it appears that mis-communication, or answers to specific questions. Were given j
without understanding the entire concept. The alleger had a listing of plant instruments used as test equipse,nt for preoperational test SU3-KJ-01 Rev. 1.
The list contained forty instruments which was.
. alleged to not have been reviewed by I&C Level III personnel prior to signing steps 6.1.23 and 6.2.23. This list of instruments was reviewed and verified as calibrated except:
PT-107 and TSH-53, which did not exist; LG 170 and LG 70, which are sight gipsses and were marked N/A, since they are non-calibratable, and LS-11g. which the vendor instructed the startup engineer and ISC not to calibrate for,
contamination reasons.
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Conclusion:
Part 4: Based upon the above investigat1on finding. it appears that a connunication problem existed as to what was recuired of the Level III personnel. All ratesting/recalibration signet by the Level III personnel appeared to be complete.and data sheets were, available. This portion of the allegation coul.d not be substantiated.
Allegation: 'Part 5:
It was alleged that Bechtel had lost control of design change process in relation to the Diesel Generators!
Investination:
Part 5: Several Colt drawings were reviewed to
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determine if discrepancies existed between current design drawings and the current TPSD. This allegation concerned the setpoints for -
instruments TS-50 T5-150. PSL-106A. 1068. 6A. and 68 as being
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different from the current TPSD. A review of the latest TP50 listed l
the setpoint for TS-50 and 75-150 to be 150*F. The setpoint for PSL 106A. PL5-1068. PSL-6A. and PSL-68 was listed as 435 psig. A review of the Colt latest Drawing 118734g3(10466-M-018-0140-08)and.vi earlier submittal (10466-M-018-0140-07). indicated the setpoints -
approved by Bechte' were 145'F (for 75-50 and T5-150). The setpoints for TS-50 and T5-150 were unchanged from the original Colt Drawing l
118734g3(10466-M-018-0140-01). The setpoints of 435'psig for i '
PSL-106A. PSL-1068. PSL-6A and P5Le68 were changed from 485 psig ty Bechtel on Drawing 10466-M-018-0140-07. This revision was l
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23-accomplished after Colt submitted Drawing 10466-M-018-100-03 showing the corrected setpoints to be 435 psig.
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Conclusion:==
Part 5:
Based on the investigation above, it was acknowledged that there was a discrepancy in the setpoints for T5-50 and T5-150, between' Colt Drawing 10466-M-018-0272-06 and Colt 1
Drawing 10466-M-018-0140-07.
This oversight was. corrected with the issuance of Drawing 10466-N-018-0272-WO7.
Also, it is the responsibility of KG&E to update and maintain setpoints changes to the TPSD when changes are made to a design drawinn. This was not a Bechtel responsibility.
A review of current draw'ngs and the curren't TPSD appears to resolve the discrepancies for T5-150 and TS-150.
It has been established that portions of this allegation are substantiated but the concerns. wore identified and corrected.
Therefore, the technical merits of tMs allegation could not be proven.
A11eastion:
Part 5: The a11eger stated that the acceptance.
criteria, which states the performance characteristics of the diesel j
generators and associated auxiliaries are within design
. specification, were not incorporated'into preoperational test $U3-KJ01, Revision 1, Section 2.1, entitled " Acceptance Criteria."
Investication:
Part 5:
TCN 24 was issued to delete this entry from Section 5.8 of the preoperational test and re-enter in Section 2.8.
i The following actions have been completed by TCN-24.
Section 5.8 has been deleted.
Section 2.8 states, "The acceptance criteria to ensure performance characteristics of the diesel generator and associated auxiliaries are within design specification is performed as escorded in SU3-NE01 :
and SU3-NF02. All data is recorded under loaded conditions. The reason for this change was to clarify traceability of acceptance criteria.
==
Conclusion:==
Part 5: Based on the investigation of the changes i
above, the TCN was issued for clarification and not because of a technical or procedural concern. Also,' prior to.this investigation, the alleger was quoted by Quality First Investigators as saying that l
the preoperational test was in good shape and he was no longer concerned with the contents.
Titis portion of the allegation could
'not be substantiated.
Allegation:
Part 7:
It was alleged that instruments were being calibrated individually ins'tead of in a loop. Problems were encountered when " loop.was operated.
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=24-l Investination:
Part 7: Administrative Procedure ADH 14-140 was reviewed to verify if procedures had been develo p to ensure that instruments were being correctly calibrated and loop tested.
l Piping and Instrumentation Diagrams (P&ID's) were reviewed to identify which instruments should be loop tested. The NRC inspector reviewed the list of instruments generated by the a11eger as not l
being loop calibrated. The allegers list contained such instruments as Pressure Indicators (PIs) Pressure Transmitters (pts) and Hand Indicating Switches (HI$s), etc. h NRC inspector randomly selected several CS 12 data sheets from the vault to ascertain if. loop testing i
was required for these types of instruments.
Data sheet revealed that component test had been perfomed.
These instruments are not of i
the analog type and, therefore, no loop testing were, required.
Further investigation revealed.that the gliegers list contained instruments such as Temperature Elements (TEs) and Temperature Indicators (tis) which were embedded in component structures and could not be removed for loop testing.
However..the NRC inspector verified by reviewing data. sheets that scheme and element tests were completed.
Also, it was alleged that instruments LSH-27, LSH-127,
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LSH-36, LSH-136, LSH-32, and LSH-132 had not been loop checked. An investigation of this concern renaled that vendor instructions suggested these instruments not be tested to avoid possible o
contamination. h se instruments were checked during preoperational l.
'insting.
==
Conclusion:==
Part 7: Based on the investigatio.n above, all instruments that had been identified as requiring loop checks, had these checks completed, and documentation verified their acceptability. This portion of the allegation.could not'be-substantiated.
Allocation:
Part 8: The al. leger stated that Resistance Temperature l Detectors (RTDs) are not calibrated in a loop..I&C calibrates the elements but does not account for loop resistance.
i Investination:
Part 8: The NRC inspector investigated these concerns using the same approach as listed above in Part 7.
The list of instruments identified by.the alleger was reviewed. As stated in the investigation above, the instruments (RTDs) were embedded in i-j component structure and were not removed because they were not considered as part of loops.
Data sheets reviewed indicated that all l
RTDs had a scheme or point check.
==
Conclusion:==
Part 8: All pertinent documents (data sheet, drawing etc) were reviewed; there were no indications of a programmatic.
breakdown in the areas of 1.nstrument calibration. This portion of l
the allegation could not be substantiated.
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A11ecation:
Part 9:
Following completion of acceptable comp'nent o
testing, the Status Indicator was not completed in accordance with Procedure ADM 08-806..
Investination:
Part 9: The supervisor of the IE Startup program was interviewed by the NRC inspector to verify if there was, in fact,.
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a problem with the calibration program as defined by Procedure ADM 08-806.
The I E supervisor stated that steps 4.8.1 of Procedure ADM 14-103 applies to the " Operational" program for the compilation of a Matter Schedule in accordance with ADM 08-806. This schedule is being refined and updated using data sheets, the Status Index, P& ids, and the instrument index. The IE supervisor also indicated that the Master Schedule is a document which is updated on a daily basis.
It'is not a controlled or design document.
It was further stated that the Master Schedule is in the preoperational stage for " Operational use." This master schedule was not to be used to determine operability of a v system in startup, the status index performs this function. A review of Procedures ADM 08-806 and i
ADM 14-103 did not reveal any discrepancies in the purpose and functions of the Status Indicator.
Conclusion:
Part 9:
Following the review of the above referenced procedures and the interview with the I&C supervisor, the NRC inspector did not find discrepancies as alleged.
It appears that there was confusion as to how and when Procedure ADM 08-806 was to be used by the site IE personnel. This portion of the allegation pould not be substantiated.
Allocation:
Part 10:
It was alleged that the " yellow dot" system used.by the IE startup group is confusing.
Investination:
Part 10:' The " yellow dot" system was researched to get an understanding of what this systes meant in relation to '
instrumentation.
The IE supervisor referenced IE-IP-001 which clarified the usage of the " yellow dot" systas.
IP-001 states, in i
part "After an instrument is checked by the IE group, a yellow paper dot will be placed on the instrument to indicate that it has been calibrated.
This dot is to be used only as an I E in-shop tool to identify av instrument that any not be calibrated." IE personnel further stated the " yellow dot" was not apart of an i
l official procedure and did not necessarily imply that an instrument was in present caTibration.
It was also stated by I E startup
' personnel that the " yellow dot" system was a method used to " flag" or 1et the electrician know that the I E group should be contacted prior to working on that particular instrument.
==
Conclusion:==
Part 10:' Based on the investigation above, it appears that the " yellow dot" system was only used for "in-shop"! purposes.
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It appears that I&C had complete control of the system, and the confusion by the alleger was the results of not understanqing how the
' system works.
This portion of the allegation could not be substantiated.
4.
Unresolved items
.. - Unresolved items are matters which require more information to ascertain 4
whether they are acceptable items, violations, or deviations.
5.
Ooen Items Open items are matters which have been discussed with the.Iicensee, which will be reviewed further by the NRC, and which will inv'olve'some action on the part of the NRC or licensee or both.
i 5..
Exit Interview The Region IV inspectors met wit:h Mr. W. J. Rudolph and other licensee personnel on January 24, 1985, to discuss the scope and findings of this inspection.
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UNITED STATES g'
NUCLEAR REGULATCRY COMMISSION pgg nasMiwoYow, p. c. sosse o
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Janua ry 23, 1985 CHAIRMAN The Honorable John D. Dingell United States House of Representatives Washington, D. C.
20515
Dear Congressman Dingell:
This is in response to your letter of January 9, 1985 which requested information related to structural steel welding at the Wolf Creek Generating Station located near Burlington, Kansas.
The NRC is concerned when a utility does not discover and take appropriate corrective action regarding deficiencies.
However, the NRC inspection activity identified the deficiencies and required corrective action before the plant was ready for operation.
I have enclosed for your information copies of inspection reports, the enforce-ment action, and the Confirmation of Action Letter from NRC requiring action by the applicant in this matter.
By letter dated December 31, 1984, the Kansas Gas & Electric Company (KGSE) has submitted their final report providing the results of their reinspection of the Wolf Creek structural steel welding and identified the corrective ections that they had taken in response to the NRC staff's Confirmation of Action Letter (See Enclosure 3) on this issue. We have included this report (See Enclosure 5) for your information.
The staff is reviewing the KGSE
, report and we will provide a copy of our inspection report as soon as it is available.
Also enclosed for your informatfo.n is additional detailed background related to this issue and specific answers to each of your questions.
Sincerely,
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Nunzio J. Palladino Chairman
Enclosures:
See next page cc:
Rep. James T. Broyhill 9
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2-The Honorable John D. Dingell
Enclosures:
1.
Background Statemert and Answers to Questions 2.
Enforcement Action EA 84-107 3.
Confirmatcry Action Letter, dated 11/15/84 4.
KG4E letter, dated 12/7/84 - Supplemental Information - Structural Steel Welding 5.
KG4E letter, dated 12/31/84 - Enforcement Action 84-107 Response 6.
Inspection Report 50-482/84-51 7.
Inspection Report 50-462/84-22 8.
SNUPP5 Letter dated December 3. 1984 FSAR Requirements for Structural Steel Weldirg 9.- Structural and Geotechnical Engineering 8, ranch SSER Input (Draft) 9 e
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r ENCLOSURE 1
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Background===
During the period between 1978 and 1981, approximately 11,150 structural steel joints were fabricated to support safety related components or structures at Wolf Creek.
The majority of these joints were bolted or shop welded together.
About a cuarter (2669 joints) of these structural steel welds were welded in the field in accordance with the provisions of American Welding Society (AWS)
Code D.1.1.
Between 1978 and 1982, a small sample (less than 1%) of these structural joints were selected by the NRC inspectors and inspected for com-pliance with the code and NRC requirements.
No significant deviations or violations were observed in this sample.
The 1978-1982 version of the NRC inspection program for structural steel welds specified a relatively small percentage of welds to be physically inspected.
In 1983, as part of a revision to the Office of Inspection & Enforcement (!&E)
Construction Inspection Program, greater emphasis was placed on the direct inspection of hardware and a sample size of 30 to 60 structural steel welds for each weld contractor was established for direct inspection by NRC inspectors.
Additionally, the 1983 program provides more explicit inspection requirements for the conduct of the physical inspection of welds.
In July 1984, the NRC established a task force to assure the overall inspection program at the Wolf Creek Station would be completed on a schedule consistent with the utility's projected fuel load date.
As part of this inspection activ-ity, a concern regarding the applicant's handling of certain Corrective Action Reports was raised.
It was found from a review of applicant's corrective ac-tion reports that a sample of structural steel welds had shown that a high per-centage of the welds failed to meet one or more of the weld quality requirements of AWS D1.1-75.
As a result; the enforcement action (EA 84-107 See Enclosure 2 - Applicant's Response See Enclosures 4 and 5) was sent to the applicant requiring the imple-mentation of a corrective action plan.
The applicant reinspected 100% of the structurally significant structural steel welds associated with the field welded joints in order to provide the NRC staff with adequate assurance that all of the field welded structural steel was properly installed.
In. response to the above reinspection, about 1466 joints were accepted without deviation,1039 joints had deviatiens that were accepted in accordance with the provisions of AWS D.1.1 and the FSAR Revision (see Enclosures 8 and 9),
and 164 joints were reworked.
Of these, 81 were reworked to assure that design allowable stresses would not be exceeded, and 84 were reworked to install missing and correct underlength welds.
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QUESTION 1 WHAT ACTIONS ARE UNDERWAY TO DETERMINE WHETHER A QUALITY ASSURANCE BREAKDOWN, SUCH AS THAT WHICH OCCURRED IN THE STRUCTURAL WELDING PROGRAM, DID NOT EXTEND TO OTHER ASPECTS OF DESIGN AND CONSTRUCTION OF WOLF CREEK?
ANSWER 1 IN JULY 1984, THE NRC ESTABLISHED A TASK FORCE TO ASSURE THE OVER-ALL INSPECTION PROGRAM AT THE WOLF CREEK STATION WOULD BE COMPLETED ON A SCHEDULE CONSIST,ENT WITH THE UTILITIES PROJECTED FUEL LOAD DATE.
THIS EFFORT EXTENDED ACROSS MANY IMPORTANT ASPECTS OF THE DESIGN AND CONSTRUCTION OF WOLF CREEK AND WAS AN IN-DEPTH INSPE'C-TION OF THE PLANT AS-BUILT CONDITIONS, AS DOCUMENTED IN QA RECORDS.
THE INSPECTION 0F AS-BUILT STRUCTURAL STEEL, INCLUDING WELDING, WAS INCLUDED WITHIN THIS PROGRAM, WITH THE RECOGNITION OF THE IDENTIFIED BREAKDOWN IN THE STRUCTURAL STEEL PROGRAM, THE NRC INSPECTORS WERE SENSITIVE TO ANY INDICATION OF SIGNIFICANT PRO-GRAMMATIC BREAKDOWN IN OTHER AREAS BE,1NG INSPECTED, THE NRC INSPECTIONS REVEALED ONLY A SMALL NUMBER OF ADVERSE FINDINGS THAT REPRESENTED A SMALL NUMBER OF ISOLATED FAILURES AS OPPOSED TO A BREAKDOWN, THE. INSPECTIONS DID NOT IDENTIFY ANY OTHER AREAS 0F PROGRAM BREAKDOWN IN THE CONSTRUCTION OF WOLF CREEK.
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AS PART OF THE TASK FORCE EFFORT, THE NRC STAFF CONDUCTED A SPECIAL CONSTRUCTION VERIFICATION INSPECTION AT WOLF CREEK.
AS STATED IN THE INSPECTION REPORT (50-082/84-51, SEE EN-CLOSURE 6) THERE WERE NO PEP.VASIVE BREAVDCWNS IN QA IDENTIFIED, IN ADDITION, WE NOTE THAT THE NRC's 0FFICE OF INVESTIGATION HAS SEVERAL INVESTIGATIONS UNDERWAY WHOSE CONCLUSIONS WOULD PROVIDE' INSIGHTS INTO THIS PROBLEM.
THOSE INVESTIGATIONS RELATE TO A NUMBER OF ISSUES INCLUDING MISSING, FALSIFIED, OR ERR 0NEOUS QA
- RECORDS, l
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OllESTION 2 HAS THE NRC STAFF ENUMERATED THE SPECIFIC CAUSES OF THE FAILURE TO ADHERE TO THE REQUIREMENTS 0F AMERICAN WELDING SOCIETY (AWS)
DI.1-75?
IF SO, PLEASE PROVIDE THE PERTINENT DOCUMENTS, ANSWER 2 NRCISSPECTION' REPORT 84-22(SEEENCLOSURE7)ANDENFORCEMENT ACTION LETTER 84-107 (SEE ENCLOSURE 2) IDENTIFIED THE PRIMARY CAUSES FOR THIS BREAKDOWN AS THE APPLICANT'S FAILURE TO PROPERLY INSPECT THE WELDING AND TO APPROPRI ATELY PERFORM THE NECESSARY STRUCTURAL STEEL WELDING CORRECTIVE ACTIONS IN RESPONSE TO DEVIATIONS IDENTIFIED IN CORRECTIVE ACTION REQUESTS, G
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00EST10N 3 i
HAVE OTHER UTILITIES WITH PLANTS UNDER CONSTRUCTION BEEN GRANTED EXEMPTIONS FROM CONFORMANCE TO AFS DI.]?
FOR THOSE INSTANCES 0F PLANTS UNDER CONSTRUCTION VPERE EXEMPTIONS WERE GF. ANTED TO PERMIT CONFORMANCES TO LESS STRINGENT REQUIREMENTS THAN THOSE t
IMPLICIT IN AWS D1,1, PLEASE PROVIDE ALL DOCUMENTS PERTAINING TO TPE REQUEST AND GRANT OF SUCH EXEMPTIONS.
ANSWER 3 r
THE NRC HAS NOT " GRANTED" EXEMPTIONS FROM CONFORMANCE TO AWS DI.).
UNLIKE SECTION XI 0F THE ASME CODE, AVS DI ! IS NOT INCORFORATED i
BY REFERENCE IN 10 CFR PART 50.
THEREF0PE, THERE IS NO PROCEDURAL i
RECU!REMENT FOR THE COMMISSION TO GRANT EXEMPTION FROM THE DI.1 CODE.
HOWEVER, THE STAFF R,ECEIVED A REQUEST (ENCLOSURE 8) BY THE WOLF CREEK APPLICANT TO AMEKD THEIR FSAR SECTION 3.8.3.6.3.3 RE-GARDING THE USE OF AWS DI.1.
THE STAFF ACCEP,TED THE CHANGES, WHICH ARE TO BE DOCUMENTED IN AN UPCOMING SER SUPPLEMENT #5.
(SEE ENCLOSURE 9).
WHEN THERE M.AY PE SOME OVESTION WITH F.EGARD TO A DEVIATION TAKEN TO ACCEPTANCE CRITERIA, AN AMENDMENT TO THE FSAR l
IS A COMKONLY USED PROCESS TO ASSURE THAT THE CONSTRUCTION OF THE PLANT AND THE FSAR ARE IN CONFORMANCE WITH EACH OTHER.
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7 THE PROVISIONS OF APS DI.1 ALLOW FANY DEVIATIONS, SUBJECT TO THE APPROVAL OF THE ENGINEER, WHO IS DEFINED IN AWS DI.1 AS THE DULY DESIGNATED PERSON WHO ACTS FOR AND IN BEHALF 0F THE OWNER ON ALL MATTERS VITHIN THE SCOPE OF THIS CODE.
AWS Dl.1 IS USUALLY INVOKED THROUGH A GENERAL STRUCTURAL BUILDING CODE THAT IS COMMITTED TO BY AN APPLICANT IN HIS FSAR.
FOR EXAMPLE, THE MOST COMMON STRUCTURAL CODE USED AT NUCLEAP POWER PLM'Ts IS THE AMERICAN INSTITUTE OF STEEL CONSTRUCTION'S (AISC's)
" SPECIFICATION F0P THE DESIGN, FABRICATION AND EPECTION OF STPUCTURAL STEEL F0P BUILDINGS."
THE AISC SPECIFICATION PROVIDES SOME RULES PEGARDING WELDING, BUT REFERS TO THE AWS DI.] CODE FOR WELDING PROCEDURES, QUAllFICATIONS AND OTHER REQUIREMENTS.
AFS D] 1 DEFINES WORKMANSHIP STANDARDS FOR THE WELDERS, PROVIDES INSTRUCTIONS TO WELDING SUPERVISORS AND ACCEPTANCE CRITERIA FOR THE FINAL WELDS WHICH ARE CHECKED BY IN a
SPECTORS.
FUPTHER, THE AISC QUALITY CR!TERIA DOCUMENT, "CUALITY CPITERIA AND INSPECTION STANDARDS" IS OFTEN USED AS A SUPPLEMENT TO THE,AISC SPECIFICATION TO PROVIDE PRACTICAL AND ACCEPTABLE GUIDANCE ON THE USE OF THE AISC SPECIFICATION AND AWS DI.1.
IT l
ALLOWSEXCEPTiONSTOSOMEOFTHEPPOV!SIONSOFAWSDI.1;E.G.,
THE QUAllTY CRI.TERIA DOCUMENT STATES:
l
l "THE HUMAN ELEMENT IS INVOLVED IN ALL PHASES OF STRUCTURAL DESIGN AND FABRICATION: THEREFORE, IT I
IS NOT SURPRISING THAT AN UNINTENTIONAL DEVIATION FROM A DRAWING OR SPECIFICATION CAN OCCUR.
NOT ALL ERRORS OR DEVIATIONS NEED TO BE ALTERED OR REPAIRED; MANY COULD BE ACCEPTED WITHOUT CHANGE, WITH NO PENALTY TO THE STRUCTURE OR ITS END USE.
THERE ARE TIMES WHEN REPAIR WORK, CREATES HIGHER RESIDUAL STRESSES AND DOES MORE HARM THAN GOOD.
IN GENERAL, IT SHOULD BE THE ENGINEER'S DECISION WHETHER OR NOT THE DEVIATION IS HARMFUL TO THE END USE OF THE PRODUCT."
THEREFORE, WHEN DESIGNING AND CONSTRUCTING STRUCTURES TO THE AISC
. SPECIFICATION, IT IS NECESSARY FOR THE ENGINEER AND THE OWNER TO DEFINE THE APPROPRIATE WELD,1NG ACCEPTANCE CRITERIA FOR THE WORK TO BE PERFORMED.
THERE ARE"SOME INSTANCES WHERE IT IS NECESSARY l
TO N0DIFY THE AWS DI.1 ACCEPTANCE CRITERIA IN, ORDER TO BE PRACTICAL AND MEANINGFUL FOR USE IN INSPECTING STRUCTURES DESIGNED IN ACCORD-l t.NCE WITH THE AISC SPECIFICATION.
MODIFICATION TO ACCEPTANCE i
l' CRITERI A 0F AWS D1.1 IS PERMITTED WITHIN THE PROVISIONS OF BOTH AISC SPEC'IFICATION AND AWS (0DE, AND NRC APPROVAL IS NOT REQUIRED.
i THE APPLICANT IS, HOWEVER, REQUIRED TO DOCUMENT AND MAINTAIN ON FILE ALL DEVIATIONS TAKEN TO WS DI ! ACCEPTANCE CRITERIA.
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SUMMARY
, THE NRC DOES NOT NEED TO GRANT AN EXEMPTION TO MEET ITS REGULATIONS TO WOLF CREEK OR ANY OTHER PLANT UNDER CONSTRUCTION BECAUSE OF THEIR FAILURE TO MEET AWS D.I.l.
INSTEAD, AS PERMITTED BY THE CODE, THE ENGINEER IS AUTHORIZED TO GRANT DEVIATIONS TO THE
- CODE, HOWEVER, FOR WOLF CREEK, THE APPLICANT DID PROPOSE AN AMENDMENT TO THE FSAR DESCRIBING A DEVIATION TO AWS D l.1 WHICH WAS ACCEPTED BY THE NRC STAFF, e
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F Congreff si tb WNitet Ctates masse at Representat(tes casman a ensey an commen assa stas agens seem one comme quantasen 3.c. sosts sunc0MMITTEE 3 DVERSIGRT M D INVESTIGATIQhts January 9, 1985 The Bonorable Nunzio Falladino Chairman Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Chairman:
In the course of fulfilling its legislative oversight responsibilities, the subcommittee on oversight and Investigations has been informed that Nuclear Regulatory Commission (NRC) inspections conducted in 1984 uncovered significant cases of noncompliance with requirements pertaining to structural welding at the Wolf Creek Generating station.
It is of concern to us that these problems were not found until construction of the Wolf Creek plant had been virtually completed.
There are aspects of this matter which require further explanation.
Accordingly, we would appreciate a prompt response to the following questions:
l 1.
What actions are underway to determine whether a quality assurance breakdown, such as that which occurred in the attuctural welding program, did not extend to other' aspects of design and construction of Wolf Creek?
2.
Mas NRC staff enumerated the specific causes of the f ailure to adhere to the requirements of American Welding society (ANS) D1.1-757 If so, please provide the pertinent documents.
3.
Have other utilities with plants under construction been granted exemptions from conformance to AWS D1.17 For those instances of plants under construction where esemptions were granted to permit conformance to less stringent requirements.than those implicit in AWs D1.1, please provide all documents pertaining to the request and grant of such exemptions.
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The Monorable Nunzio Palladino January 9,1985 Page 2 If the unavailability of documents pertaining to any element of this request prevents a full response prior to Tuesday, January 22, 1985, please provide by this date whatever documents are available along with an explanation as to why the other documents cannot be readily ret leved f rom the NRC files.
Sin r ely, ohn D.
ngell Chairman subcommittee on oversight and Investigations JDD PScm O
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uenTaostavas NUCLEAR REGULATORY C004W8880N
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namasseren,o.a. asses MAR 11 M.
The Honorable John Carlin Governor. State of Kansas Office of the Governor State Capitel Topeks. Kansas $4412-1530
Dear Governor Carlin:
Your letter of March 5 Igel to Chairman Palladino, requested a full and complete examination of all safety metters relating to the Wolf Creek Generatine Station. Your letter referred to safety concerns raised in the November 5. Ige 4 letter from the Kansas State Corporation Commission (KSCC). the Fehrwary 1. Igel letter from Congressmen sItchmen, the February S. Igel letter from Congressmen Slattery, and the February 14 and February 18. Igel letters from the Kansas State Legislators.
The MC staff has completed eer evaluation of the safety aspects of these metters. This information is provided as teclosure I of this letter.
including all references, and inclosure II. Inclosure I describes a sig-nificant program of corrective action by the Kansas Ses and Electric Company (Keet)whichaddressednotonlythestructuralsteelweldingissue,butalso included inspections and evaluations to determine that the aspects involved in the structural steel welding issue did not ocese in other areas of
. construction. Inclosure I aise describes the entensive MC program of verification and in t x t t inspection on all these issues to assure the adequacyofstructuralsteelweldingandthatthe04programhasbeen rly implemented. Gesed on the completed efforts of R$4t. which have verified by MC inspections, the NRC het concluded that these issues are resolved. Inclosure II describes inforestion regarding problems involving cable separation and Ke&E corrective action. Based on independent MC inspec-tiens. we have concluded that adequate cable separation exists at Wolf Creek and this issue is resolved.
In some instances in addition to assuring that all safety related aspects of each issue has been resolved the MC staff has referred certain items to the MCOfficeofInvestigationforadditionalinvestigationifrequired. At this time, we are not aware of any information from the Office of Investigations that constitutes a basis for withholding the issvence of a law ps.or license for Wolf Creek. Therefore, the staff is proceedine with its review in support Matters pertaining to all continui
,theCes.issi.n,ri.,toissuance.fafuif,investitc'.tiens of the Itcense is
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The Honorable John Carlin -
Based upon the NRC staff review and ir.spection program we conclude that the facility has been constructed in conformance with the requirements of the Comission and its operation will not represent any undue risk to the health and safety of the public.
I believe that these findings represent a full and complete examination of all matters which relate to the plant's safety. The Congressional Delegation, the Kansas State Legislators and the Kansas Corporation Comission are being informed by separate letter.
Thank you for your interest with these matters.
Sincerely, Mggem).DW William J. Dircks Executive Director for Operations Enclosurest (see letter to Rep. Dingell for Encls., EDO 275) 1.
Structural Steel Issue 2.
Electrical Separation Issue cc: Attorney General, State of Kansas o
- stE PREVIOUS PAGE FOR CONCURRENCES (RETYPED 3/9/85kab)
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=Asm=orom, o, c. som MAR 111985 Mr. Michael Lennin, Chairman State Corporation Commission Fourth Floor, State Office Building Topeka, Kansas 66612-1571
Dear Mr. Lennin:
Your letter of November 5,1984 concerns the structural steel welding and electrical separation issues at Wolf Creek Generating Station. Shortly after receipt of your letter, the NRC Project Manager for Wolf Creek, Mr. Paul O'Connor, spoke to Mr. Robert Fillmore of your staff about the proposed schedule for reports resolving this issue and the impact of this issue on the construction completion date for Wolf Creek. This letter is a followup to that discussion.
The NRC staff has completed our evaluation of the safety aspects of these matters. This information is provided as Enclosure I of this letter,
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including all references, and Enclosure !!. Enclosure I describes a sig-I nificant program of corrective action by the Kansas Gas and Electric Company (KG8E) which addressed not only the structural steel welding issue, but also included inspections and evaluations to determine that the aspects involved in the structural steel welding issue did not occur in other areas of construction. Enclosure I also describes the extensive NRC program of verification and independent inspection on all these issues to assure the adequacy of structural steel welding and that the QA program has been properly implemented.
Based on the completed efforts of KG8E. which have been verified by MRC inspections, the NRC has concluded that these issues are resolved. Enclosure !! describes information regarding problems involving cable separation and KG4E corrective action. Based on independent NRC inspec-tions, we have concluded that adequate cable separation exists at Wolf Creek and this issue is resolved, in some instances, in additten to assuring that all safety related aspects of each issue has been resolved, the NRC staff has referred certain items to the NRC Office of Investigation for additional investigation if required. At this time, we are not aware of any information from the Office of Investigations that constitutes a basis for withholding the issuance of a low power license j
for Wolf Creek. Therefore, the staff is proceeding with its review in support of the license issuance. Matters pertaining to al' continuing investigations will be reviewed by the Comission prior to issuance of a full power license.
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Mr. Michael Lennin, Chaiman b Based upon the NRC staff review and inspection program we conclude that the facility has been constructed in conformance with the requirements of the Comission and its operation will not represent any undue risk to the health and safety of the public.
Thank you for your interest with these matters.
Sincerely, i
Alt' Hu b L. Thompso rector Division of Licensin Office of Nuclear Re ctor Regulation
Enclosures:
1.
Structural Steel Issue 2.
Electrical Separation Issue 4
e I
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1 Enclosure I STRUCTURAL STEEL ISSUE i
INTRODUCTION AND BACKGROUND The purpose of this document is to provide a description of the issues involving field-welded structural steel at the Wolf Creek Generating Station (WCGS). There is' substantial documentation associated with the matter. The documentation of primary importance is referenced throughout this document, and is listed in attachment A.
The referenced documentation is also attached.
The vast majority of the structural steel at WCGS was erected during the period 1977 to 1981. Approximately 11,150 structural steel joints were fabricated during the erection period to support safety-related components or structures at the WCGS. The majority of these joints were bolted or shop-welded together.
About a quarter of these structural steel joints were welded in the field in accordance with the design requirements and the American Welding Society code, AWS D 1.1.
Between 1978 and 1982, a small sample (less than 15) of these structural joints were selected by the NRC inspectors and inspected for compliance with the applicable code and NRC requirements. No significant deviations or violations were observed in these samples..
.In July 1984, the NRC established a task force to complete the NRC inspection program at the WCGS. The inspection program calls for, among other activities, a review of the applicant's corrective action programs required by their QA program. During these inspection activities, the NRC inspectors raised concerns regarding the applicant's handling of certain corrective action requests associated with the field welding of structural steel joints. A review of one corrective action report indicated that a reinspection of a sample of field welded structural steel joints by the applicant showed that a relatively high percentage of the welds failed to meet one or more of the-quality requirements of the ap>11 cable code; these results were at variance with the initial inspections witch accepted the welds as meeting code requirements. In addition, another corrective action request indicated that the original inspection records for many of the field welded structural steel joints were not available.
The applicant's evaluation of these particular matters resulted in acceptance of field welded structural steel joints on the basis that the defects identified during the reinspected sample were cosmetic, and his conclusion that the unavailability of the original inspection records did not undermine confidence that the field welded joints were properly installed. The NRC task l
force did not agree that the applicant had properly handled the disposition of i
these corrective action requests.
The NRC task force requested that the applicant select, inspect, and evaluate additional field welded joints. These additional inspections revealed missing welds, missing structural material, an inspection record for welds which did not exist, and some welds not in confonnance with the applicable code and design documents. The NRC task force consequently concluded that in view of s
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A s.
. inappropriate disposition of the corrective action requests, the results of reinspections, and the unavailability of original weld inspection records, the quality of the field welded structural steel joints would have to be reevaluated. This became the central issue, but not the only issue, to be resolved.
As a result of the inspection findings, the NRC took enforcement action which required, among other things, the development and implementation of a corrective action plan which would provide adequate assurance that the field
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welded structural steel was appropriately installed and would perform the required safety function. The applicant developed and implemented a program which included a reinspection of all accessible structurally significant field welded joints. The program was reviewed and accepted by the NRC. Throughout the implementation of the program, the NRC monitored its conduct, witnessed inspections by the applicant, reviewed inspection results, and conducted independent inspections. These activities were completed in early March 1985.
The remainder of this document provides a general chronology of events, identifies the appropriate codes and their application, elaborates on the unavailable weld inspection records, describes the applicant's reinspection program scope and results, describes the NRC independent inspection activities and results, and sets forth the NRC conclusions.
CMDOELUGYOLEJENTS The following is a chronolegy of mjor events that tare involved in the.
structural steel welding crec.
1977 - 1981 Structural steal widing was initisted approximately during the last quarter of 1977. with approximate completion occurring during the last quarter of 1981. As discussed later, there are 2.670 safety-related structural steel ecanections consisting of approximately 11.000 welds identified in the six safety-related buildings: 1.e., auxiliary, reactor.
control, emergency tervice water system, fuel, and diesel generator buildings. These welds were made and inspected by Kansas Gas and Electric construction contractor. Daniel International Company Company s (KG8E)lts of the weld inspections were to be documented in (DIC). The resu Miscellaneous / Structural,SteelWeldingRecords(MSSWRs).
March 1983 As a result of prevkuzly identified deficient fillet weld conditions on component supports; e.g., pipe hangers. DIC Quality Control (QC) initiated a random rainspection of accessible structural steel fillet welds in the safety-related buildings. This activity identified 148 rejectable welds in a sample of 241, tr.d resulted in the issuance of corrective action report No. CAR 1-W-0029 (Referer.ce 1). This CAR directed that all of the 4
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rejected welds be incorporated into a nonconformance report (NCR) so that en evaluation and disposition could be made by the DIC Project Welding l
Engineer on each discrepancy. NCR ISN 10381PW was written and an i
evaluation of each rejected weld was performed. The NCR was dispositioned as follows:
Rework - 6 welds l
Use As Is - 142 welds Nearly all of the rejectable conditions were considered cosmetic in nature j
in that structural integrity was not jeopardized. Based on the above i
figures. DIC concluded that as a result of the very small percentage of welds requiring rework. "no sacrifice to structural integrity would have resu'Ited... if they had not been reinspected and reworked." The NCR was closed vith subsequent closure of the CAR on October 22,1983.
August 1983 A DIC review of documentation arior to building turnover to KGSE revealed j
approximately 165 and 245 of tw required MSSWRs were missing for Fuel Building and Reactor Building welds, respectively. This resulted in the issuanceofCAR1-C-0031(Reference 2),datedAugust 10, 1983, through Revision 7 dated October 20, 1984. The suggested corrective action included a review of all existing MSSWRs prior to building turnovers and the generation of NCRs for each building identified as having missing MSSWRs. Each NCR was to be evaluated and dispositioned as rework or use-as-is, depending upon the circumstances revealed after the existing documentation for each building had been reviewed.
4 This CAR was intended to be closed out on the basis of the relatively small number of missing MSSWRs and the fact that the previous reinspection
,of a sample of structural steel welds showed an even smaller number of welds requiring rework. Thus, the fact that MSSWRs were missing was 4
accepted because of the weld quality estab1Ished during the sample reinspection.
This CAR was not formally closed until Joh ary 16,1985, as a result of the continuing chronology of events.
The major cause of the missing MSSWRs was concluded to be the result of a lack of procedural compliance with respect to responsibility for 4
origination, completion, and maintenance of these records. The MSSWRs i
were stored in various locations and by various personnel within the individual buildings frem the time they were originally initiated; thus j
precluding any assurance of control.
June - August 1984 i
NRC first learned of the potential records problem in conversa'tions with applicant personnel. In addition to personnel interviews, a review of i
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A e.
,,. CARS was undertaken and the specifics of CARS 1-W-0029 and 1-W-0031 became known to the NRC.
August 1984 4
A document reconciliation effort was initiated by K6&E to detemine which safety-related structural steel welds were lacking MSSWRs.
In addition, an inspection verification effort was initiated to provide an accurate assessment of the as-butit conditions of safety-related structural steel welded connections which were lacking available MSSWRs.
September 1984 KG4E, DIC, and Bechtel made a joint presentation to the NRC task force which identified the belisf at that time, that the problem was one of document retrieval, and not a hardware problem. This was not an acceptable premise to the NRC task force and as a result KG&E agreed to i
perform a sample structural steel joint inspection of six randomly l,
selected structurally significant joints in each of the six safety-related buildings. This inspection resulted in the discovery of missing welds, missing structural members, and deficiencies with respect to weld size.
This infomation was formally reported to the NRC under 10 CFR Part50.55(e)onSeptember 18, 1984. Subsequent meetings were held between K6&E and the NRC task force for further infomation updates.
October 1984 i
KG4E Ouality Assurance issued CAR No.19 (Reference 3) on October 17, 1984, to obtain the necessary actions required to resolve the issues associated with structural steel welding. The specific issues included:
missing MSSWRs for safety-related structural steel welds; deficiencies being identified in previously accepted structural steel welds; missing structural welds and/or material; and documentation that a weld was l
inspected and accepted, but in fact, the inspected welds did not exist.
I l
October 26, 1984 As a result of the above events, it was determined that a significant violation of NRC regulations had occurred and NRC's Region IV office issued Inspection Report No. 50-482/84-22(Reference 4),whichprovided the details of the inspection findings and also stated that enforcement correspondence and Notice of Violation pertaining to this matter would be j
sent to KG&E under separate cover.
It further addressed a scheduled enforcement meeting to be conducted on October 29, 1984.
October 29, 1984 Enforcement Conference at'RIV offices in Arlington, Texas. KGAE issues plan for corrective actions, including CAR No.19 (Reference 3).
t l
me.
November 15. 1984 NRC-RIV Issued Confimation of Action Letter (CAL) confiming understandings reached at Enforcement Conference on October 29, 1984, and providing additional guidance on conduct of corrective action program (Reference 7).
November 21, 1984 The Notice of Violation and Prnposed Imposition of Civil penalty was issuedtoKG&EasEnforcementActionNo.84-107(Reference 5).
November 1984 - February 1985 NRC personnel conducted independent visual and nondestructive examinations, and verified and evaluated KG&E's comitted corrective actions. This infomation is documented in NRC Inspection Report Nos.50-482/85-12and85-13(Raference6).
December 31,1984 KG&E issues final re rt on CAR No. 19 corrective action in response to Notice of Violation Reference 9).
January 21, 1985 KG&E issues supplement to final report on Notice of Violation (Reference 10).
February 27. 1985 A public meeting was held at the NRC in Bethesda, Maryland, between the NRC and the Kansas Gas and Electric Company to fully discuss the structural steel welding issue. A transcript of this meeting was made (Reference 8).
February - March 1985 KSSE provided supplemental infomation regarding results of additional inspection, and in response to NRC requests for additional information (References 11-14).
APPLICABLE CODES. STANDARDS. AND C0004ITNENTS The applicable codes and standards as comitted to in the WCSS Final Safety Analysis Report (FSAR) with respect to building construction, are as follows:
American Institute of Steel Construction (AISC) Specification for the Design. Fabrication and Erection of Structural Steel for Buildings 6
i i '
American Welding Society's Structural Welding Code AWS D 1.1-75.
The identified deficient welds were contrary to the acceptance criteria of AWS D 1.1-75.
I At the time KGAE initiated CAR No. 19, construction was basically complete.
This resulted in approximately 56% of the safety-related joints being in a painted condition. Due to KG&E's comunitment to perform a 100% reinspection of all accessible structurally significant joints, criteria had to be established with respect to inspecting through paint. The inspection requirements, acceptance criteria, and method of documenting the results of the reinspection roceduralized in procedure No. QCP-VII-200, Revision 20 dated November 2, were p(Reference 9). The procedure recognized that paint and fireproofing 1984 material would exist on most of the welds to be inspected; however, the 1
inspectors were directed to inspect in accordance with the design drawings and AWS D 1.1-75 criteria. The procedure further stated that if the fireproofing i
material precluded the ability ~to reinspect, then the welds were to be recleaned. Additional information and results of the reinspection are addressed later.
MISCELLANE0US/ STRUCTURAL STEEL WELD RECORDS Theapplicant'sapprovedQualityAssurance/QualityControl(QA/QC) program required that a document referred to as a Miscellaneous / Structural Steel Weld Record (MSSWR) be prepared and retained for welds made on field-welded structural steel joints. The individual weld and joint records are not a requirement of AWS D 1.1.
The MSSWR required the following principal items to be entered:
Drawing reference and joint number Material type Weld procedure utilized weld Filler material identification Symbol identification of the welder Date of welding and inspection Identification of inspector Weld acceptance Remarks and/or sketches required for clarity The QA/QC program provided that each Bechtel structural steel drawing be annotated to reflect the generation of acceptance MSSWRs on a connection-by-
i E
connection basis. When all of the connections were annotated, that package of work was considered complete.
Following completion of the structural steel welding activities, the MS$WRs were retained at the construction site by the construction crews (field engineers and inspectors) at various locations referred to as " headache shacks" and " gang boxes." The great majority of the MSSWRs were single-part forms, so that copies were not provided at the time to records keeping organizations.
The storage of MSSWRs in this manner in the field went on for a considerable period of time. The constructor. Daniels International Corporation, did not maintain adequate control or provide adherence to procedures, to ensure that the MSSWRs were fully retained (References 8 and 9).
l It was not until the KS&E and DIC Combined Review Group (a document review group) began a review of the acceptance documentation in 1983 to accomplish l
building turnover, that they found that the acceptance of all welds in all connections could not be accomplished with the existing records. At that time.
the effect of the above factors was identified and documented in CAR 1-C-0031.
indicates that 1.509 of The final report for KS&E CAR 19 (Reference 9) l welds are miss'ing.
6.816 MSSWRs for safety-related structural stee The i
detailed records of the reinspection of the structural steel welds are being
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retained as plant records (Reference 8).
REINSPECTION 0F PAINTED WELDS a
l The KG&E corrective action plan to perform a 1005 reinspection of all accessible safety-related structural steel welds necessitated the need for Bechtel to identify the applicable joints. This was accomplished by review of the erection drawings prepared by the structural and miscellaneous steel l
fabricators, field change request nonconformance reports, construction variance requests, and structural steel fabrication requests. Sechtel identified 2.670 structurally significant safety-related field-welded joints which required reinspection.
As stated previously, approximately 565, or 1.484 welded joints, were reinspected in a painted condition which consisted of either a primer coat, topcoat, or both. Approximately 585, or 859 of the NifRted weld joints, had existing MSSWRs from the original inspection which sunsed the welds to be acceptable.
Bechtel provided a technical justification for inspection through paint as an attachment to a letter to KG8E identified as BLKES-1348 dated November 5, 1984 (Reference 9). Sechtel's position is that fillet welds which have been coated with up to 4 mils of primer and up to an additional 10 mils of topcoat can be visually examined to the AWS D 1.1-75 acceptance criteria. Paint thickness was measured using a standard dry film thickness gauge. Bechtel identified the following attributes as being those which could be fully evaluated:
- l.
-8 Weld presence and location Weld length j
Weld size, both leg length and throat thickness Weld profile, including convexity and concavity Fusion between weld and base metal Overlap Cross-section of weld craters Coarse undercut Large porosity by further identified the following attributes as being more difficult to evaluate and measure in a painted condition, and in some cases may not be visible at all:
Cracks Fine porosity Tight undercut However, these three attributes were addressed as being largely dependent on the metallurgical characteristics of the base metal being joined, the welding material being used, and the ability of the welders perfoming the work.
The base material used for all structural steel at WCGS is ASTM A36, which is a low carbon, highly weldable steel. h welding materials used were Type E7018 electrodes, which are highly compatible with A36 material. This compatibility results in sound crack-and porosity-free welds provided basic precautions are taken. These precautions are all addressed in t w welding procedure specifications used for the structural steel welding. h presence or absence of undercut is dependent on materials used, welding parameters, and welder ability. h first two factors were addressed earlier, leaving welder ability, which to a large degree is the major cause of undercut. The training and qualification tests are in accordance with AWS 0 1.1, which is designed to provide the welders with the ability to control these attributes.
The NRC evaluated Bechtel's basis for joint selection and their justification for reinspection of painted welds.
The NRC concluded that:
8echtel's basis for the selection / identification of joints for reinspection was proper 0
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.g-i Sechtel's justification for inspection through paint was valid with 4
respect to identifying those defects which would affect the i
structural integrity of the welds.
The NRC was not completely satisfied that visual examination of p(ainted welds would reveal lack of fusion.
Independent NRC visual inspection VT) of painted i
welds was conducted to confirm that significant attributes could be detected.
In addition, painted welds were magnetic particle tested (MT) to determine if the paint was masking surface discontinuities; no surface discontinuities were found in the sample examined. In addition, the NRC selected a statistically significant sample of painted joints which were reinspected by the NRC using VT and MT after the paint was removed. No defects were found in the sample selected. This provided additional confidence in the ability to inspect painted welds for significant defects, 'and confidence that the welds had been properly made (Reference 6).
It is important to note that the applicable code. AWS 01.1. requires that welded joints not be painted until after the' work has been completed and accepted. The AWS has suggested that paint will generally mask surface discontinuities. The DIC corresponded with the AWS regarding reinspection of structural steel welds. The AWS replied that reinspection is not covered (addressed) by AWS D 1.1, and that such reinspection should be in accordance with acceptance criteria agreed upon by the engineer and the contractor (Reference 8).
3 I
RESULTS OF REINSPECTION I
The KGAE reinspection effort was performed by AWS-certified welding inspectors (CW!s) who were also certified as quality inspectors by DIC in accordance with 1
the requirements of ANSI M45.2.6-78. As previously discussed, inspection criteria, acceptance standards, ano method of documenting inspection results
~
was procedurally defined. The reinspection data was recorded in Weld Data Sheets which documented the inspected as-built conditions of all accessible structural steel welds. All identified deficiencies were documented in NCRs which, together with the Weld Data Sheets, were presented to Bechtel in order that a case-by-case evaluation of each deficient welded joint could be performed.
The documented results of the KGAE reinspection effort can be tabulated as follows:
No. of Joints Identified for Reinspection -
2.670 No. of Joints Completely R'ainspected -
2.403 No. of Painted Joints -
1.484 No. of Unpainted Joints -
gig l
No. of Acceptable Joints -
1.305 l
No. of Rejected Joints -
1.098 No. of Partially Inaccessible Joints -
165 f
No. of Totally Inaccessible Joints -
102 A question arose as to the causes of the obvious differences in inspection l
results with respect to the original inspections between 1977 and 1982, and the reinspection effort between October 1984 and February 1985. The existing It$$WRs documenting the results of the original inspections show that the welding was acceptable, while the reinspection identified 1.098 rejectable weldedjoints. This disparity was probably caused by a less intense inspection discipline during the original inspections. Considerable more latitude and Judy sent was the norm for structural steel welding inspection during the ear 1er time frame. As a result of the subsequent identification of defective welds during the sample inspection, a very disciplined and structured plan with absolute acceptance / rejection criteria was established for use during the t
reinspection activities. As a result, those attributes originally identified as being acceptable, were now being rejected. In addition inspection to the established rigid and absolute criteria would allow Bechtel to perform complete and thorough evaluations of the as-built conditions.
Bechtel's evaluation of the 1.098 rejectable welded joints identified 82 joints '
requiring repairs due to defective conditions which caused the design allowable stresses to be exceeded in the as-built condition, and 81 additiona joints l
were identified as requiring repairs due to KG&E's commitment to install missing material and missing and underlength welds (unless prohibited by field conditions)eventhoughthedesignallowablestresseshadnotbeenexceeded.
i l
It was detemined that field conditions did preclude the repair of 14 of the 81 joints. Thus, a total of 149 welded joints were repaired, and all others were dispositioned as "use-as-is."
4 With respect to the 102 joints identified as being totally inaccessible due to their being embedded in concrete or having physical interferences. 62 were i
acceptable as-is because evaluation showed that the concrete was capable of thus eliminating any concerns with respect to supporting the design load Itwasalsonotedthat165jointswerepartially defective welds.
inaccessible; however, sufficient inspection data was available on i39 of the j
l Joints to allow an evaluation to be perfomed. This leaves a total of 66
)
joints out of 2.670 which could not be evaluated. The basis by which Bechtel accepted these joints was through statistical analysis, and is considered 1
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proper logic. If the 2.604 fully evaluated joints are considered's sample of the 2.670 total population of joints. then the sample size represents such a large percentage of the total population that statistics associated with the sample may be applied to the total population with virtually 1005 confidence, This implies that if a percentage of inspected joints were detemined to exceed i
design alloweble stresses, then statistically this percentage may be applied to 1
the total population.
Of the 2.604 joints which were evaluated. 82 joints (3.145) were identified in which the design alloweble stresses were exceeded. Analysis has shown that those joints would not have failed under the design loading conditions.
However. 60 of the 82 joints were polar crane rad'al stops in which the same welds were missing in each joint and the design allowable stresses were exceeded. In addition. 6 pressurizer support joints had the same welds missing in each joint, three of which exceeded the design alloweble stresses. Thus, a i
total of 19 joints in the remaining population of 2.541 joints (0.755).
exceeded the design allowable stresses. It should be pointed out that the cause of the miss<ng identical welds in the 60 polar crane radial stops and the 6 pressurizer supports is attributable to the failure of the detail drawings to provide a clear understanding of the weld details. This is considered an isolated condition and was substantiated by the NRC Region IV inspector's review of the applicable structural steel detail drawings delineating the l
welded joint configurations. ht is, by reviewing typical drawings of the 66 joint details, the NRC staff concluded that they are more representative of the larger population; in other words, joint welding details are clear, not like the 60 polar crane stop joints. Wrefore, the NRC staff concludes it appropriate to include these 66 joints in the larger population group.
The 0.755 statistically applied to the group of 66 joints which could not be evaluated, results in less than 1 joint in which the design allowable stresses could be expected to be exceeded.
It would also be expected that none of these Joints would fati under the design loading conditions as a result of defective welds.
RE reviend Gechtel's methodology with respect to evaluating and dispositioning the identified we ding defects, and their approach with respect
- o intecessibie tvelded joints embedded in concrete. NRC concluded that:
ScchM1's a >proach of individually calculating stress levels to datmrine tw structural adequacy of the identified as-built con:lltions is acceptable.
Yhere is no deficiency in Bechtel's approach with res pect to i
fesecessible welded joints embedded in concrete, in tsat the use of statistical analysis and acceptable alternative load path evaluation l
1s proper.
In order to assess the adequacy and implementation of KG&E's commit'ted corrective actions. NRC's Region IV staff accompanied CW!s on several occasions to observe and verify their inspection activities and to assure that the results of the inspections were being accurately recorded. In addition. NRC's l
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l Region IV staff conducted independent inspections on selected joints with subsequent comparison to the CW!s inspection data sheets. There were no discernible differences in inspection results obtained by NRC's Region IV staff and the CW!s during either the accompanied or independent inspection activities. This created a very higi level of confidence in the data being documented by the CW!s during the reinspection program.
The NRC Region IV staff reviewed weld data sheets and applicable NCRs for i
approximately 1.750 welded joints, including 149 data sheets and 34 NCRs associated with the joints that were repaired. In addition, and subsequent to the completion of the reinspection effort the NRC Region IV staff performed an inspection on 42 of the 14g repaired joints, with acceptable results.
It was noted that magnetic particle examination (MT) was also performed on 24 of the 14g repaired joints with acceptable results by KGAE.
i I
Of potential concern was the reconciliation of the as-built conditions to the design drawinps. This was resolved by Bechtel in that they are identifying 611 NCRs applicab e to field-welded / structural steel joints on Drawing No. C-1045.
Note 46 in Revision 1 to Drawing No. C-1003. " Civil-Structural Steel and Concrete General Notes." states in part. "... See the shop detail drawings 4
and appropriate nonconformance reports identified on Drawing C-1045 for connection details."
l As stated earlier the NRC performed an independent NDE program at WCSS. The particular NDE disciplir.;s used were VT and NT. The NRC specifically recognized that fine lack of fusion, tight cracks or porosity, might be masked by coatings and that the use of NT might be of significant assistance in helping to determine its existence. One of the goals of the MT was to help l
establish the validity of the VT of painted welds.
The results of the NRC inspection sre documented in NRC Inspection
~
Neport 50-482/85-12s however, a summary of those results are presented here.
Four structural carbon steel weld samples were fabricated with known flaws such j
as tight cracks and porosity in the welds. h san >1es were 3/4" X 6" X 8" in dimension. These were examined by VT and NT, and tten photographed before painting. The samples were then coated with Carbo 11ne CZ-11 primer and the coating thickness measured. The VT and NT examinations were repeated through the coating and the results photographed. h samples were then coated with Carbo 11ne 191 HB epoxy representative of field conditions, and the examinations performed again and photographed. The types of indications noted within these test blocks represented the types of indications that could be i
encountered with structural welding. N Ntc inspection team also indicated that the tight indications in the test blocks were difficult to visually detect and if all the welds were in the as-welded condition, a small percentage of the l
indications would have been detected visually. Indications wider than the samples would be detected by visual inspection.
W results of these tests proved that meaningful MT can be perfors$d through l
paint coatings.
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The flRC inspectors randomly selected safety-related structural welds in the f
essentialservicewatersystempumphouse(ESWS)andreactorbuilding. W welds were subjected to VT and M with either the primer or the epoxy coatings applied. The coatings were then removed and the welds were reexamined by VT i
and M.
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In the ESWS, welds on six clip angles were visually examined with Carboline CZ-11 primer coat applied, h dry film thickness for the primer ranged from 1.0 to 3.0 mils. After the primer was removed, the welds were reinspected by VT and HT using the llRC-approved procedure IIDE-6. Revision 0 i
and Addendum WC-1-6-1.
l h examinations disclosed that three of the clip angle welds were undersized; i
p-7, p-8, and p-10. Review of ESSE records showed that these welds had been identified as being undersize and were recorded on a nonconformance report.
Otherwise,no other deficiencies were noted.
Similar examinations were conducted in the reactor building wherein five structural steel weld joints were VT'd and MT'd for AWS 0 1.1 acceptability and overall workmanship. The welds had Carbo 11ne Ig1 W epoxy coating on them.
The welds were found to be acceptable.
1 A sample of 55 welded connections was selected in the reactor building for VT i
with primer and epoxy coatings applied. The samples were selected from different elevations in order to provide a sample that had been welded by I
different welders and at different times. The VT was performed to design requirements and AWS D 1.1 acceptance criteria. Five of the joints had their coatings removed and were reinspected by VT and MT. Ilo indications were found on the welds with coatings or on those that had the coatings removed.
It was concluded that certain characteristics involved in VT can be evaluated effectively on coated welds. There were no characteristics identified during this inspection that could affect the integrity of the welded joints inspected.
L i
A statistical sample of welded structural joints was selected from the reactor building for reinspection and evaluation to provide a level of confidence as to the quality of existing welded joints. The selected sample consisted of 53 welded joints that were inspected for size surface condition and overall j
workmanship, then MT'd for discontinuities. En those welded joints selected.
i all primer and epoxy coatings were removed prior to ins metion. The inspection i
was performed and evaluations made in accordance with tu design requirements l
and AWS 0 1.1 acceptance criteria. Ilo rejectable welds were identified.
The NRC staff concluded that the above VT and NT examinations provided adequate assurance that welds can be MT'd through the coatings and that the previous reinspections give reasonable confidence that the inspection program was j
capable of identifying detrimental structural weld flaws.
There have been three other major activities involving AWS welding.' These j
activities involved different inspection methods and record retention j
requirements than those used in structural steel welding. These activities i
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involved the installation of electrical raceway supports, pipe whi and supports for heating, ventilation, and air conditioning (HVAC)p res
- ductwork, KG8E had discovered problems in two of these areas as documented in a i
10 CFR 50.55(e) report to the NRC relative to the HVAC supports, and was resolved by a 1005 reinspection and rework program culminating in early 1983.
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An NRC inspection was 1erfomed on the HVAC system, including welded supports, J
which concluded that tte rework program had been satisfactory. The other area of AWS welding problems involved electrical raceway supports. KSSE had j
identified problems with these welds in 1982, but Bechtel had resolved the issue through engineering analysis and revision to the engineering criteria which had the effect of allowing the welds to meet AWS Code criteria. This 4
With resolution was satisfactory, based on insp(ections performed by NRC.liquidpene i
respect to the pipe whip restraints. NDE on 100% of the welds. This was an original specification requirement for this i
category of hardware. MS$WRs were used as described earlier, however, each weld was also documented on a separata NDE report. A review of these documents i
,i provided no indication of problems.
l The methods of do:umenting inspection results diffemd depending upon the quality discipline responsible for inspection of the different AWS welding 4
activities. The inspections of electrical raceway supports and HVAC supports i
were documented on Raceway Support Checklists and Mechanical Travelers, respectively. These methods provided a closed loop system where individual
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accountability for a weld was required and controlled, and the documentation i
j was verified accurate and complete by QC/QA personnel.
i Welding of piping systems and supports for the piping systems was accomplished in accordance with Section III of the American Society of Mechanical Engineers i
(ASME) Code. The examination and documentation requirements with respect to ASME Code Section III welding, are considerably more detailed and controlled.
I l
Further, nearly all Class 1, 2, and 3 welds in pressure retaining materials receive some fom of NDE; 1.e., radiography, ultrasonic, liquid penetrant, or l
MT. With one exception, there have been no significant 3roblems in this area identified during many inspections, the most recent of wtich were accomplished after initial development of the structural welding issue by NRC personnel.
i TheexceptionnotedwasaKGAE10CFR50.55(e)reportwhichrelatedafinding i
ti.at there were undersized fillet welds in smell diameter piping systems.
These welds were reworked to achieve compliance and verified by the ASME Authorized Nuclear Inspector and by the NRC.
The inspections of nonwalding areas documented in NRC inspection i
Report 50-482/84-51 (Reference 15), were wide ranging in nature and involved nearly every principal aspect of construction. These inspections were conducted at a time and by personnel fully cognizant of the structural welding issue. As noted in the letter of transmittal for NRC Inspection Report 50-482/84-51,no pervasive breakdowns were identified.
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Based on the comprehensive corrective action by KG&E. and the NRC's er. tensive independent inspection and verification program, the structural steel welding issue is considered resolved.
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'.C Enclosure II ELECTRICAL SEPARATION ISSUE A.
Introduction The purpose of this document is to provide information relative to the findings of electrical cable separation deficiencies and cable separation procedural inadequacies at the Wolf Creek Generating Station (WCGS) identified in NRC Inspection Reports 50-482/84-22 and 50-482/84-51, respective 1y'.
B.
Scope 1.
The deficiencies in the area of electrical cable separation were discovered by the NRC during two different inspections'at the WCGS.
' These resulted in the issuance of two violations. The inspection conducted during the period of June 11 through September 28, 1984 (documentedinNRCInspectionReport 50-482/84-22), detailed several examples of the following:
Violations of the criteria where safety-related electrical conduits must be separated by 1-inch or more from redundant
~
safety-related and nonsafety-related conduits.
Violations of the criteria where safety-related electrical cables must be separated by 6 inches or more from redundant ;
safety-related and nonsafety-related cables within cabinets or panels.
2.
NRC Inspection Report 50-482/84-51 documented the findings of an NRC inspection conducted during the period of October 23 through November 2 '
1984. This inspection discovered that site procedures do not include the same separation criteria for nonsafety-related conduits to safety-related cable trays as is required for safety-related conduits to nonsafety-related cable trays. This is in violation of FSAR commitments to NRC Regulatory Guide 1.75 and IEEE-384, since no -
evaluation of safety significance was performed.
C.
Scope of KG8E's Corrective Action KG&E instituted a walkdown inspection of all safety-related buildings for violations of the 1-inch separation criteria, and all control room cabinets and panels for violations of the 6-inch internal separation criteria. KG4E stated that the deficiencies discovered during these walkdowns were documented on nonconformance reports and were corrected.
In addition to the physical work performed. KG8E required retraining of the construction craft, engineering, and inspection personnel in the importance of assuring proper conduit separation. Also, a meino was issued to site organizations alerting them to the separation fequirements, and the care that must be taken when routing cables within cabinets and panels.
o; A proposed change to the Wolf Creek FSAR was submitted to the NRC's office of Nuclear Reactor Regulation (NRR) on January 14, 1985 sto incorporate site procedural requirements into the FSAR. The change would accept the existing physical separation of nonsafety-related conduits *.o safety-related cable trays, based upon a KG&E evaluation. This. change was accepted by NRR on February 15, 1985.
D.
NRC Verification of KG&E's Corrective Actions NRC Region Ih performed an inspection of the areas where corrective action on the NRC-identified violation was to have been completed. All of the examples cited in NRC Inspection Report 50-482/84-22 were found to have been adequately resolved and no additional violations were discovered.
The scope of KG&E's inspection of cabinets and panels iri the' control room was judged broad enough since several previous NRC inspections of cabinets and panels in other plant steas found no separation violations.
It was determined that adequate corrective action has been performed to resolve existing deficiencies. alleviate future concerns, and satisfy NRC Regulatory Guide 1.75 and IEEE-384. The NRC closure of this violation is documented in NRC Inspection Report 50-482/85-03, which is attached.
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In Reply Refer To:
Docket: STN 50-442/85-03 aga si 55 Kansas Gas and Electric Company i
ATTH:
Glenn L. Koester Vice President - Nuclear P. O. hx 2M j
Wichita, Kansas 87201 Gentlemen:
This refers to the inspection conducted by Messrs. R. P. Mu111 kin, J. E. Bess and G. L. Madsen of this office during the period January 7-24,1985, of :
activities authorized by NRC Construction Permit CPPR-147 for the Wolf Creek i
Generating station, and to the discussion of our findings with
- Mr. W. J. Rudolph, and other members of your staff at the conclusion of the inspectiers.
Areas examined during the inspection included followup on previously identified ins'ection findings and allegations. Within these areas, the inspection p
consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors. These findings
~
are documented in the enclosed inspection report.
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Within the scope of the inspection, no violations or deviations were identified.
Should you have any questions concerning this inspection, we will be pleased to
. discuss them with you.
Sincerely, o,wnet sened W y,.. '* * * *f.
R. P. Denise, Director Wolf Creek Task Force
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Enclosure:
Appendix - NRC Inspection Report 50-482/85-03 cc:
(see'page 2)
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Kansas Gas and Electric Ceapany ATTN:
Gene P. Rathbun, Manager l
of Licensing P. 0. Box 208 Wichita, Kansas 67201 Forrest Rhodes, Plant Superintendent Wolf Creek Generating Station P. O. Box 309 Surlington, Kansas 56839 bec to DM (IE01) bec distrib. by RIV:
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- Resident Inspector R. D. Martin, RA
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C. Wisner, PA0
- RIV File R. Denise, DRS&P AMIS System ftyron Karman, ELD, M88 (2)
J. Harrison, RIII KANSAS STATE DEPT. HEALTH
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g amme A.moceseA samme a===r om omssaans TOPEXA KANSAS 444121571 November 5, 1984 D - 4 f2 Mr. Darrell Eisenhut Diraator cf R= actor Licengin9-07 Unir.ed States Nucle &r Regulatory w..uu.. Aon Washington, D.C.
20555 Dear Mr. Eisenhuts We have recently received from Kansas Gas & Electric Company a copy of NRC Inspection Report No. 50-482/84-22 in Docket No.
50-482 (Wolf Creek Generating Station).
The report was generated following an inspection conducted between June 11, 1984 and September 28, 1984.
Generally, the report concludes that two violations were identified:
(1) failure to assure conformance of i
safety-related structural steel welds with requirements; and (2) failure to maintain adequate electrical separation.
l Specifically, the report cites a variety of problems which appear to be substantial:
During a review of QA/QC and Quality First personnel qualifications and subsequent interviews, the NRC inspector became aware of potential prroblems with corrective action reports CAR 29 and 31.
The NRC inspector subsequently obtained copies of the two documents.
CAR 1-W-0029 (initiated on March 22, 1983) states, in part, ' Subsequently to the issuance of CAR 1-W-0019, quality has instituted a random reinspection of accessible structural steel fillet welds in all 0 buildings.
It has been determined by the results of this reinspection that an unacceptable percentage of i
these welds are~ deficient in the auxiliary, control, and fuel buildings.'
Attached documentation revealed that in the auxiliary building, 60 welds were inspected, with 53 being rejected.
In the.. control and i
fuel buildings, 50 welds were inspected with 43 rejected, and 53 inspected with 35 rejections, respectively.
Revision 2 to CAR 1-W-0029 stated in the disposition that the defective welds would be transferred to a Nonconformance Report (NCR).
The NRC inspector obtained a copy of NCR ISN 10381PW which was used as the vehicle to carry out the direction provided by CAR 1-W-0029.
It appears that DIC Project Welding Engineering personnel again reinspected the welds to
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Letter Mr. DarreI['Eisenhut Page 2 more clearly define the nature and e'ttent of the i
defects en a weld-by-weld basis.
A majorit of the defective welds were categorized as having { cosmetic
- The DIC recommended disposition was use-as-is defects.
for welds identified containing " cosmetic" defects.
The NCR states that " cosmetic" defects include arc strikes, convexity, cold roll (understood to be synonymous with overlap), porosity, and acceptable amounts of undercut.
The NRC inspector noted with respect to these defects that overlap is prohibited by i
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- M governing AWS c' 1-?S Code, and specific acceptance criteria for the other defects *are also defined by this-Code.
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e on August 16, 1983, DIC personnel issued CAR 1-C-0031 which indicated that approximatley 16.4 percent of the miscellaneous structural steel welding records for "O" welding could not be located.
Af ter corresponding back it was and forth, DIC and the engineer concluded that acceptable for some amount of these records to be missing,'provided that the quality inspection program Senior licensee QA management was acceptable.
expressed to the NRC inspector that the program had obviously been fully successful since very few welds had been found to require repair af ter a substantial The NRC reinspection effort associated with CAR 29.
inspector expressed concern with this approach to resolution and suggested that the licensee reevaluate their position, e
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f During the week of September 17, 1984, a reinspection of the identified structural members with the highest design loads or the lowest design strength safety margin was initiated.
The reinspection identified a number of welds which do not meet drawing This information was presented to the requirements.
NRC staf f during a meeting conducted on September 25, 1984.
In an effort to confirm certain of the identified conditions, the NRC inspector accompanied DIC welding inspectors into the reactor building to l
This observe specific, identified weld joints.
observation confirmed the welding inspectors' findings; e.g., welds that are undersized and of insufficient length, lack of fusion, and missing welds.
The missing welds are from the same location in each of Certain of the six pressurizer support connections.
other welds in the pressurizer support connections were i
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i Letter Nr. Darrell Eisenhut Page 3 undersized and of insufficient length.
Drawing No.
C-05 2904 shows that various length 5/8-inch welds are required in 14 specific locations.
Four locations required a 5/8-inch fillet weld of 8 inches in length.
The actual welds in two of the locations measured between 3/8-inch and 1/2-inch by 5 inches in length, and 1/2-inch by 3 inches in length.
The missing welds and the undersized, insufficient length welds are i
clearly not in compliance with the requirements of the drawing or AWS D1.1-75.
The initial weld inspection record-r % hose connections cout....ot... 1:ex u d.
The NRC inspector accompanied two DIC welding inspectors for reinspection of nine structural steel connections in the auxiliary building.
Drawing No.
K6720, applicable to these connections, shows 12 weld locations per connection with certain of the welds requiring returns.
Reinspection of the welds and returns involved provided the following summarized data
- Missing welds 2
- Welds with insufficient length 9
- Undersized welds 6
- Undersize welds with insufficient length 2
i
- Overlength returns 44
- Undersize returns 25 Undersize returns with insufficient length 1
The NRC inspector requested the initial weld inspection records for these welds and returns in the 9 reinspected connections.
As of September 28, 1984, the only inspection records that were located pertained to 10 welds and 6 returns in one connection, and 8 welds and 4 returns in each of 3 other connections.
These records did not indicate that the welds were anything other than acceptable.
The licensee informed the NRC inspector of a situation where one inspection record for connection 524B2 clearly indicated by an ateched sketch the existence of the a weld that reinspection found not to exist.
This problem will be followed up in conjunction with the other structural steel problems.
The NRC inspector made a comparison between the existing initial inspection records and the results of
l i
Let'ter Mr. DarreT tisenhut p..
4 the reinspection effort in order to determine the validity of the initial records.
The initial records show that the 10 welds with 6 returns in one connection were inspected and accepted on December 11, 1978.
The reinspection identified one undersized weld, other undersized and overlength returns, and three overlength The initial records for the other three returns.
connections show that eight welds with four returns per connection were inspected and accepted on September 8, 1979.
The reinspection of these welds and returns v intified two returns.;...o s.'9f,9 overleng;b and undersized and two returns which were overis.4,cu pec connection.
The failure to esecute the required welding inspection program is a violation of Criterion X of Appendix 5 to 10 CFR Part 50.
(442/8422-01).
We note that you have recently been quoted by the press as indicating that these welding problems could portend extensive We assume that you now question the most recent NRC case delays.
load forecast panel estimate for the date of fuel load.
Due to.
the ratemaking impact of project delay, it is necessary that we inquire as to your best estimate at this time of the length of project delay occasioned by the defects identified in the acove-referenced inspection report.
Thank you for'your cooperation.
Sincerely, KANSAS CORPORATION COMMISSION f<
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Y The Honorable Dan 811ckman United States House of Representatives Washington. 0.C. 20515 Dear Congressman 411ckment
.f This is in response to your letter of February 1, IM5. to Chairmen palladino requesting additional information on structural steel welding at the Wolf Creek Generating Station. This information is provided as inclosure I of i
this letter, including all references. Inclosure I describes a significant program of corrective action by the Kansas Ses and Electric Company (Rattl which addressed not only the structural steel welding issue, but aise inctoded inspections and evaluations to determine that the aspects involved in the structural steel weldine issue did not occur in other areas of construction.
Enclosure I also describes the entensive NRC program of verification and Independent inspection on all these issues to assure the ade structuralsteelweldingandthattheQualityAssurance(44)quacyofthe program has been properly implemented. Based on the coseleted efforts of R88E, which have been verified by HRC inspections, the NRC has concluded that these issues are resolved.
Your letter requested additional information regarding problems involving cable separation. This information is provided in Enclosure !! of this i
letter. Based on R44E corrective action and independent NRC inspections, we have concluded that adequate cable separation exists at Wolf Creek Generating Station and this issue is m selved.
i You also asked about the status of items assigned to the Office of Inves-I tigations(01). 0! has recently initiated a nos6er of investigations regarding alleged erroneous or falsified records. Some investigations are presently underway. At this time 0! has no firm estimated completion date.
I One 0! report regarding this subject has been recently completed.
If you desire we will be pleased to brief you on specific aspects of the investIgettons.
In order to protect the integrity of the investigative l
process, we suggest such briefings be oral.
The NRC technical staff has evaluated the safety aspects of missing and l
l potentially falsified welding records, and has resolved the safety aspects i
of these issues, as indicated in Enclosure I.
The NRC staff has evaluated the safety related aspects of the other issues being reviewed by 01. At this
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time, we are not aware of any information from the Office of Investigations that constitutes a basis for withholding the issuance of a low power license i
j for Wolf Creek. Therefore, the staff is proceeding with its review in support l
t of the license issuance. Metters pertaining to all continuins invettfoetions I
will be reviewed by the Commission prior to issuance of a full power l'conse.
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-t-Secesse of your interest in being informed about MC activities et the Wolf Creek plant, we are else advising yev that MC review of rational test activities indicated that sese deficiencies had occurred in t activities.
These deficiencies included instances of incorrect test condittens, incomplete verification of systems operation, and incomplete recording of test date.
These setters som identified to set eM corrective actions, including any repeating of eroeperational tests, wem perfereed by the applicent and were reviewed by MC inspectors. Actions taken by Ret to erovent returmace are responsive to the MC concerns. The technical issues Imve been resolved, and actions necesse to a et issuance of a license permitting fuel lead and law power testi have completed. The MC is else revteufng the need for possible en orcement action relative to the deficiencies identified in the proeperational testing program. A copy of inspection reports and any enforcement correspondence relates to this subject will be provided to yev when they are issued to Ret.
Sesed open the MC staff review and inspection program, es conclude that the facility has been constructed in conformence with the requirements of the Casudesten and its operation will not represent ey endue risk to the health and safety of the pub 11c.
Sincerely.
MM William J. Dirchs taecutive Director for Operations teclosures 1.
Structural Steel leste t.
tiectrical Seperetten Issue (See letter to Rep. Dinpell for EncIs.. [00 275) stVISt0 SY E00 0FFICE (3/11/06)
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The Honorable Jim Slattery United States House of Representatives Washington. 0.C. 20615
Dear Congressman Slattery:
This is in response to your letter of February 8,1985, to Chaiman palladino requesting additional information on structural steel ws1 ding at the Wolf Creek Generating Station. This information is provided as inclosure I of this letter including all references. Enclosure I describes a significant program of corrective action by the Mansas 8ss and Electric Company (Rett) which addressed not only the structural steel welding issue, but also included inspections and evaluations to determine that the aspects involved in the strwetural steel welding issue did not occur in other areas of construction.
teclosure I also describes the entensive MC program of verification and independent inspection on all these issues to as'.uie the ade structural steel welding and that the Quality Assurance (QA)quacy of the program has been properly fuplemented. Based on the completed efforts of R48t. which have toen verified by MC inspections, the nac has concluded that these issues are resolved.
We have also prepared additional information regarding problems involving cable separation. This information is provided in Enclosure !! ef this letter. Based on K8&E corrective action and independent MC inspections, we have concluded that adequate cable separation exists at Wolf Creek Generating Stetten and this issue is resolved.
You also asked about the status of items assigned to the Office of Inves-l tisattens(01). 01 has recently initiated a nus6er of investigations regarding r
alleged erroneous or falsified records. Some investigations are presently underway. At this time OI has no fire estimated completion date. One 0!
report recording this subject has been recently coupleted.
we i
will be pleased to brief you on specific aspects of the investigations.IfyoudesireIn l
order to protect the integrity of the investigative process, we suggest such briefings be oral.
The MC technical staff has evaluated the safety aspects of missing and potentially falsified welding records, and has resolved the safety aspects of these issues, as indicated in inclosure I.
The MC staff has evaluated the safety-related aspects of the other issues being reviewed by 01. At this time, we are not aware of any information from the Office of Investigations that constitutes a basis for withholdine the issuance of a low power license for Wolf Creek. Therefore, the staff is proceeding with its review in support of the Itcense issuance. Matters pertaining to aII continuins investigations will be reviewed by the Cosmission prior to issuance of a full power license.
dSitL3BMJl 3 JlY
The Honorable Jim Slattery i Because of your interest in being infomed about NRC activities at the Wolf Creek plant, we are also advising you that NRC review of preoperational test activities indicated that some deficiencies had occurred in these activities.
These deficiencies included instances of incorrect test conditions, incomplete verification of systems operation, and incomplete recording of test data.
These matters were identified to KG&E and cormctive cetions, including any 3
repeating of preoperational tests, were performed by the applicant and were reviewed by NRC inspectors. Actions taken by KG&E to prevent recurrence' are responsive to the NRC concerns. The technical issues have been resolved, and actions necessary to support issuance of a license permitting fuel load and low power testing have been completed. The NRC is also reviewing the need for possible enforcement action relative to the deficiencies identified in the preoperational testing program. A copy of inspection reports and any enforcement correspondence related to this subject will be pmvided to you when they are issued to KG&E.
s Based upon the NRC staff review and inspection program, we conclude that the facility has been constructed in conformance with the requirements of the Cosmiission and its operation will not represent any undue risk to the health and safety of the public.
Sincerely, MSI N.
William J. Dircks Executive Director for Operations
Enclosures:
1.
Structural Steel Issue 2.
Electrical Separation Issue (See letter to, ep. 'Dingel.1 for.Encis., EDO 275)
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l REVISEDINEDO0FFICE(3/11/85)
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HAR 11885 The Honorable Robert H. Miller Kansas. House of Representatives Topeka, Kansas 66612 l
Dear Mr. Miller:
This is in response to your letter dated February 14, 1985, which was co-signed by other members of the Kansas Senate and House of Representatives. Your letter expressed concern regarding the issuance of an operating license for the Wolf Creek Generating Station before investigations involving alleged construction deficiencies and quality assurance defects are completed, and that because these investigations are as yet incomplete that the safety of the facility may be questioned.
The NRC staff has completed our evaluation of the safety aspects of these matters. This information is provided as Enclosure I of this letter.
including all references, and Enclosure II. Enclosure I describes a sig-nificant program of corrective action by the Kansas Gas and Electric Company l
(KG&E) which addressed not only the structural steel welding issue, but also l
included inspections and evaluations to determine that the aspects involved in the structural steel welding issue did not occur in other areas of construction. Enclosure I also describes the extensive NRC program of verification and independent inspection on all these issues to assure the adequacy of structural steel welding and that the QA program has been properly implemented. Based on the completed efforts of KG&E, which have been verified by NRC inspections, the NRC has concluded that these issues are resolved. Enclosure II describes information regarding problems involving cable separation and KG&E corrective action. Based on independent NRC inspec-tions, we have concluded that adequate cable separation exists at Wolf Creek and this issue is resolved.
In some instances, in addition to assuring that all ' safety related aspects of each issue has been resolved, the NRC staff has referred certain items to the NRC Office of Investigation for additional investigation. At this time, we are not aware of any information from the Office of Investigations that constitutes a basis for withholding the issuance of a low power license for Wolf Creek. Therefore, the staff is proceeding with its review in support of the license issuance. Matters pertaining to all continuing investigations will be reviewed by the Cossnission prior to issuance of a full power license.
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- V-The Honorable Robert H. Miller 1 Based upon the NRC staff review and inspection program we conclude that the facility has been constructed in conforinance with the requirements of the Comission and its operation will not represent any undue risk to the health and safety bf the public.
Sincerely.
M WEhp @
William J. Dircks Executive Director for Operations
Enclosures:
1.
Structural Steel Issue 2.
Electrical Separation Issue (See letter to Rep. Dingell for Enc 1s., EDO 275)
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HOUSE OF REPRESENTATIVES February 14, 1985 The Honorable Nunzio Palladino Chairman Nuelear Regulatory Commission
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Dear Mr. Chairman:
We, the undersigned, members of the Kansas Senate and House of Representatives, are deeply concerned with the approach-ing conditional licensure of the Wolf Creek electrical generating station.
It is our understanding that this licensure may occur in spite of the fact that open investigations exist into matters such as alleged construction defects and quality assurance de-ficiencies.
Since such matters are directly relevant to the issue of plant safety, we ask for your assistance.
Correspondence between your office and the offices of Congressman Dan Glickman and Congressman John D. Dingell has been made available for our review.
It is clear from our review of the Congressmen's questions and your response that:
- 1) A substantial number of structural steel welds have 1
been found to be below accepted standards;
- 2) Investigations into the weld deficiencies are underway, i
including such issues as missing, falsified or erroneous i
quality assurance records; and
- 3) Unanswered safety questions remain, including problems relating to the safe separation of electrical cables.
We have, for several years, expressed our concerns and our citizen's concerns relating to the safe and economical pro-duction of nuclear-generated electricity.
The Wolf Creek project has been the object of scrutiny from this Legislature and from other agencies of state government.
We have attempted to maximize the ability of our utility commission to review the project and determine the extent to which the ratepayers will assume construction related costs.
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Honorcblo Nunzio Pallcdino 4
Fobruary 14, 95 Pcgo Two However, Congress has established that your commission is the review mechanism for all matters relating to the safe construction and operation of nuclear plants.
It is in that capacity that we seek your assistance.
We ask that all investigations, including any pre-invest-igation matters pending in the office of Investigation and of Inspection and Enforcement, be concluded in a comprehensive and thorough manner.
We ask that your findings be made available to us, to the Kansas Congressional delegation, our Governor and Attorney General, and to the Kansas Corporation Commission.
We ask that these things be done prior to the issuance of a conditional, low-power operating license.
When the power is turned on at Wolf Creek, it is essential that all questions have been answered and all safety standards met.
Only these conditions will provide the needed assurances to Kansas to validate the operational integrity of the Wolf Creek plant.
We ask for your prompt response, and express our appre-ciation for your consideration of this matter.
Sincerely,
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IlAR 11585 The Honorable Jo Ann Pottorff Kansas. House of Representatives Topeka, Kansas 66612 Dear Ms. Pottorff.
This is in response to your letter dated February 18, 1985. Your letter expressed concern regarding the issuance of an operating license for the Wolf Creek Generating Station before investigations involving alleged construction deficiencies and quality assurance defects are completed, and that because these investigations are as yet incomplete that the safety of the facility may be questioned.
i The NRC staff has completed our evaluation of the safety aspects of these matters. This infomation is provided as Enclosure I of this letter.
including all references, and Enclosure II. Enclosure I describes a sig-nificant program of corrective action by the Kansas Gas and Electric Company (KGSE) which addressed not only the structural steel welding issue, but also included inspections.and evaluations to detemine that the aspects involved in the structural steel welding issue did not occur in other areas of construction. Enclosure I also describes the extensive NRC program of verification and independent inspection on all these issues to assure the adequacy of structural steel welding and that the QA program has been properly implemented. Based on the completed efforts of K6&E, which have men verified by NRC inspections, the NRC has concluded that these issues are resolved. Enclosure II describes infomation regarding problems involving cable separation and KG&E corrective action. Based on independent NRC inspec-tions, we have concluded that adequate cable separation exists at Wolf Creek and this issue is resolved.
In some instances, in addition to assuring that all safety related aspects of each issue has been resolved, the NRC staff has referred certain items to the NRC Office of Investigation for additional investigation. At this time, we are not aware of any information from the Office of Investigations that constitutes a basis for withholding the issuance of a low power license for Wolf Creek. Therefore, the staff is proceeding with its review in support of the license issuance. Matters pertaining to all continuing investigations will be reviewed by the Comission prior to 1'ssuance of a full power license.
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'1y The Honorable Jo Ann Pottorff 2-Based upon the NRC staff review and inspection program we conclude that the facility has been constructed in conformance with the requirements of the Commission and its operation will not represent any undue risk to the health and safety of the public.
Sincerely, WHAM William J. Dircks Executive Director for Operations
Enclosures:
1.
Structural Steel Issue 2.
Electrical Separation Issue (See letter to Rep. Dingell for Encis., EDO 275)
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HOGSE Or 4 EPR ES ENT ATW ES g
February 18, 1985 0
r.,D FER 2 51985 The Honorable Nunzio Falladino Chairman 25 i gto
Dear Mr. Chairman:
h As a member of the Kansas Legislature I am deeply concerned witlk Creek the approaching conditional licensure of the WoIt is my understanding th into generating station.
that open investigations exist may occur in spite of the fact lity assurance matters such as alleged construction defects and quaSince such deficiencies.
of plant safety. I ask for your assistance.
Correspondence between your office and the offices l
It is clear from a review of the Congressmen's for our review.
questions and your response that:
A substantial number of structural steel welds have 1) been found to be below accepted standards; Investigations into the weld' deficiencies are underway.
including such issues as missing, falsified or erroneous 2) quality assurance records; and Unanswered safety questions remain, including problems relating to the safe separation of electrical cables.
3)
Kansans I would like to express my concern and the concern of many other d
relating to the safe and economical production of nuclea
e from this Legislature and from other agencies of state government.
electricity.
have attempted to maximize the ability of our utility will assume construction related costs.
l
j a.
is::.2:
Pego 2 1
However Congress has established that your commission is the review mechanism for all matters relating to the safe construction and operation of nuclear plants.
It is in that capacity that I seek your assistance.
I ask that all investigations, including any pre-investment matters pending be in the Office of Investigation and of Inspection and Enforcement,I ask that your findings concluded in a comprehensive and chorough manner.
be made available to me, tc the Kansas Congressional delegation, our Governor and Attorney General, and to the Kansas Corporation Commission.
rb-tssuance of a conditional, j
I ask tha r'
se things be done prior en les-power operating license.
It is essential that all questions When the power is. turned on at Wolf Creek.
Only these conditions have been answered and all safety standards met.
will provide the needed assurances to Kansas to validate the operational integrity of the Wolf Creek plant.
I express my appreciation for your consideration of this matter.
Very truly yours.
"~12 LM ChL w I,,
l bert S. Wunsch Representative 101st District RSW:1sf t
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION 5
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IlAR.11 BBS The Honorable Robert S. Wunsch Kansas. House of Representatives Topeka, Kansas 66612
Dear Mr. Wunsch:
This is in response to your letter dated February 18, 1985. Your letter expressed concern regarding the issuance of an operating license for the Wolf
' Creek Generating. Station before investigations involving alleged construction deficiencies and quality assurance defects are completed, and that because these investigations are as yet incomplete that the safety of the facility may be questioned.
The NRC staff has completed our evaluation of the safety aspects of these matters. This information is provided as Enclosure I of this letter.
including all references, and Enclosure II. Enclosure I describes a sig-nificant program of corrective action by the Kansas Gas and Electric Company (KGAE) which addressed not only the structural steel welding issue, but also included irspections and evaluations to detenmine that the aspects involved in the structural steel welding issue did not occur in other areas of construction. Enclosure I also describes the extensive NRC program of verification and independent inspection on all these issues to assure the adequacy of structural steel welding and that the QA program has been i
properly implemented. Based on the completed efforts of KG&E, which have been verified by NRC inspections, the NRC has concluded that these issues are resolved. Enclosure II describes information regarding problems involving cable separation and KGAE corrective action. Based on independent NRC inspec-i tions, we have concluded that adequate cable separation exists at Wolf Creek and this issue is resolved.
In'some instances, in addition to assuring that all safety related aspects of each issue has been resolved, the NRC staff has referred certain items to the NRC Office of Investigation for additional investigation. At this time, we are not aware of any infonsation from the Office of Investigations that constitutes a basis for withholding the issuance of a low power license for Wolf Cree::. Therefore, the staff is proceeding with its review in support of the license issuance. Matters pertaining to all continuing investigations will be reviewed by the Connission prior to issuance of a full power license.
~
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The Honorable Robert S. Wunsch.
Based upon the NRC staff review and inspection program we conclude that the facility has been constructed in conformance with the requirements of the Consnission and its operation will not represent any undue risk to the health and safety of the public.
Sincerely.
M551seJ.Embe William J. Dircks Executive Director for Operations
Enclosures:
1.
Structural Steel Issue 2.
Electrfcal Separation Issue (See letter to Dingell for.Encis., EDO 275)
. )
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NO R EPR ES ENT ATIV ES February 18, 1985
$iEC kb5 bb The *.onnrable Nunzio palladino, Chairman Nuc2eaz
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D.C.
20555 PROC.si' m F 4
Dear Mr. Chairman:
I am deeply concerned As a member of the Kansas Legislature, with the approaching conditional licensure of the Wolf Creek elec-It is my understanding that this licen-trical generating station.
sure may occur in spite of the fact that open investigations exist into matters such as alleged construction defects and quality as-Since such matters are directly relevant to surance deficiencies.
the issue of plant safety, I ask for your assistance.
Correspondence between your office and the offices of Congress-man Dan Glickman and Congressman John D. Dingell has been made avail-It is clear from a review of the Congress =eh's able for our review.
questions and your response that:
A substantial number of structural steel welds have 1) been found to be below accepted standards:
Investigations into the weld deficiencies are under-2) including su:h issues as missing, falsified or
- way, erroneous quality assurance records; and Unarewered safety questions remain, including problems 3) relating to the safe separation of electrical cables.
I wogid like to express my concern and the concerns of many other Kansans relating to ne safe and economical production of nuclear-The Wolf Creek project has been the object generated electrie:ty.of scrutiny from this Legislature and from other agencies of sta We have attempted to maximize the ability of our util-government.
ity commission to review the project and determine the extent to which the ratepayers will assume construction related costs.
i However, Congress has established that your commission is the review mechanism for all matters relating to the safe construction It is in that capacity that I and operation of nuclear plants.
seek your assistance.
WP
F F
t r
Page 2 Honorable Nunzio Palladino February 18, 1985 I ask that all investigations, including any pre-invest-igation matters pending in the Office of Investigation and of Inspection and Enforcement, be concluded in a comprehensive and thorough manner.
I ask that your findings be made available to me, to the Kansas Congressional delegation, our Governor and
' Attorney General, and to the Kansas Corporation Commission.
I ask that these things be done prior to the issuance of a condi-tional, low-power operating license.
When the pcwer is turned on at Wol f creek. it is essential tnat all que.;p.... '.ea ve a : e:6 ma r e n..
.a--
. afetp's tandarc.
met.
Only these conditions will provide the needed assurances to Kansas to validate the operational integrity of the Wolf Creek plant.
I express my appreciation for your consideration of this matter and ask that my name be added to the list of other Kansas Legislators that was sent to you in a letter dated February 14, 1985.
Sincerely, d)
^
o Ann Pottorff Representative' 83rd District JAP:jw l
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i EUBCOMMITTEE ID] MERSIGHT AED INVESTIGATIONS January 9,1985 The Bonorable Nunzio Palladino Chairman Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr'. Chairman:
In the course of fulfilling its legislative oversight responsibilities, the Subcommittee on oversight and Investigations has been informed that Nuclear Regulatory Commission (NRC) inspections conducted in 1984 uncovered significant cases of noncompliance with requirements pertaining to structural welding at the Wolf Creek Generating Station.
It is of concern to us that these problems were not found until construction of the Wolf Creek plant had been virtually completed.
There are aspects of this matter which require further explanation.
Accordingly, we would appreciate a prompt response to the following questions:
1.
What actions are underway to determine whether a quality assurance breakdown, such as that which occurred in the structural welding program, did not extend to other aspects of design and const'ruction of Wolf Creek?
2.
Bas NRC staff enumerated the specific'.causes of the failure to adhere to the requirements 'of American welding society (AWS) Dl.1-757 If so,
- please provide the pertinent documents.
~
3.
Bave ;other utilities with plants under '
construction been granted exemptions. f Eoin conforaance to. AWS DI.l?
For those instances of plants.under. construction where exemptions were granted to. permit conformance to less stringent requirements than those implicit in AWS D1.1, please provide all documents pertaining to. the request and grant of such' exemptions.
2P 9
1/15,..To EDO to Prepare response.for Commission review and Ch, airman's signature.* Date due Comm:
1/98f...Cpys to: Chm, Cars, RF OCA to Ackn(90lodgWm o.a.
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e The Honorable Nunzio Palladino January 9, 1985
. Page 2 If the unavailability of documents pertaining to any element of this request prevents a full response prior to Tuesday, January 22, 1985, please provide by this date whatever documents '
are available along with an explanation as to why the other documents cannot be readily retrieved f rom the NRC files.
Sin erely, ohn D.
ngell
/
Chairman Subcommittee on oversight and Investigations JDD PScm e
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