ML20133B686
| ML20133B686 | |
| Person / Time | |
|---|---|
| Issue date: | 06/07/1984 |
| From: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Koester G KANSAS GAS & ELECTRIC CO. |
| Shared Package | |
| ML20132C642 | List: |
| References | |
| FOIA-85-161 NUDOCS 8507200352 | |
| Download: ML20133B686 (4) | |
Text
{{#Wiki_filter:- - g _.T d -[ o / 49Cd. n.1 June 7. 1984 ,
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1 i W. Glenn L. Roester Vice President - Nuclear Kansas Gas and Electric Compaq l
- p. O. Box 208
*l Wichita. Kansas 67201 I
Dear W . Ebester. ,
By letter dated April 18. 1984. you sent as a copy of the report en l RE&E's investigation into an alleged intimidation of a Daniel Inter-nattamal Corporation inspector by a supervisory employee. You stated in the letter that the investigation into the matter.did not reveal an informatles to support the alleged intimidation. You also stated that the transmittal letter was confidential and asked that the report attached to the letter be ensupt from disclosure in accordance with the provisions of 10 CFR 2.7g0 so that the conf 1-dentiality of the individuals involved could be protected. Stace I em unable to assure that such information can be protected in the manner you regnested. I am returning the report and its transmittal letter to you. - I appreciate the fact that you are keeping full details of the investi-gation available for our further review at the Wolf Creek jobsite. Sincerely'. V POriginal Signed trft J. T. COLLINS" John T. Collins Regional Adelaistrator Enclosures bec: / R. Herr, O!:RIV J. Liebennan, OELD E. Shanahan, 0:1.0 l' 4 8507200352 850510 h., PDR FOIA STEPHENR5-1A1 PDR D,RRP&E:R V :
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- 2. Functional Area (s) Involved: i (Check apprennets boxte ) : operations onsite health and safety construction offsite health and safety safeguards emergency preparednssa other (specifyl ,
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- 6. N me of Individual (First two initials and last namel D D* kb b R:cciving Allegation:
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- 13. All:gation Number: , ,
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fg bad.)L ALLEGATION REVIEW CASE NUMBER 4-84-A-094 DATE OPENED 09/11/84 FACILITY NAME Wolf Creek 50-482 SUBJECT (Sensitive) SOURCE OF ALLEGATION Former contractor employee NUM8ER OF ALLEG. 1 ASSIGNED TO DI CROSS REF. NO. Q4-84-042 ACTION SCHEDULED Initial inquiry FIRST/LAST NAME R. Herr DATE ASSIGNED 09/11/84 REPORT NUMBER 1st: 2nd: Lst: FTS NUMBER 8-492-8110 DUE DATE ALLEGATION SUBSTANT SORT CODE O DATE CLOSED ACTION OFFICE OIRIV MAN HOURS REPORT PREPARATION ASSIST DETAILS: (Sensitive) Ref: Q4-84-042. sy ,,, , ou - y- EV A ' "
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O', i ALLEGATION REVIEW CASE NUMBER 4-84-A-098 DATE OPENED 10/01/84 FACILITY NAME Wolf Creek 50-482 SUBJECT DOL complaint containing QA/QC program allegations SOURCE OF ALLEGATION Former contractor employee NUMBER OF ALLEG. 6 ASSIGNED TO Task Force CROSS REF. NO. ACTION SCHEDULED Inspection i 1 FIRST/LAST NAME R. Denise I DATE ASSIGNED 10/01/84 REPORT NUMBER 1st: 2nd: Lst: FTS NUMBER 8-728-8100 DUE DATE ALLEGATION SUBSTANT SORT CODE C DATE CLOSED ACTION OFFICE RIV MAN HOURS REPORT PREPARATION ASSIST DETAILS: Complaint made to DOL (210) by Brent L. Rowlands which contains QA/QC program allegations. These are as follows: (1) material verification contrary to Daniel Policy; (2) " Post-0K Reviews" by engineers; (3) insufficient material verification; (4) disagreements over incorporation of NCRs into drawings; (5) improper verification of snubber transaction assemblies; and (6) problems in use of system deficiency list. , l i i l il l e l n d l'h0
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UNITED STATES X% %3 r #
!" o NUCLEAR REGULATORY COMMISSION
{ ,I WASHINGTON. D. C. 20555
*s.,*****/ December 11, 1984 D:cket No. 50-482
[ MEMORANDUM FOR: Richard P. Denise, Director
. Wolf Creek Task Force, Region IV . FROM: J. Nelson Grace, Director Division of Quality Assurance, Safeguards, a
and Inspection Programs Office of Inspection and Enforcement
SUBJECT:
SPECIAL CONSTRUCTION VERIFICATION INSvECTION REPORT i 1 - As requested in your memoranda to R. DeYoung dated September 24, 1984 and October 12, 1984, IE performed a special construction verification inspection (SCVI) of the voluntary Construction Self Assessment (CSA) perfomed at the Wolf Creek Generating Station (WCGS). The SCVI was performed by members of IE/DQASIP and consultants, most of whom had experience as members of an NRC Construction
- Appraisal Team. :
. The SCVI report package is enclosed for your transmittal to the applicant. The package includes the transmittal letter, Executive Sumary, Potential Enforcement Actions, and Unresolved Items for your use in the transmittal to Kansas Gas and Electric Company (KG&E).
The SCVI was performed primarily to achieve the requested assessment of the CSA effort as defined in your memoranda. In the process of performing the requested { assessment, the SCVI also identified other items which have been classified either as an item for potential enforcement action or as an unresolved item. l These are listeo in Enclosures B and .C of the enclosed transmittal letter. Closecut of all items relative to the potential enforcement action ano unresolved items ioentified during the NRC assessment of the CSA effort and of the specific and generic concerns identified as a result of the CSA effort will be considered a satisfactory resolution of the matters in this report. It is our recomendation that the potential enforcement action (PEA) detailed '. in Enclosure B to the enclosed transmittal letter be issued as a notice of violation and be classified as Severity Level IV in accordance with 10 CFR 2, Appendix C, Supplement II. It is recognized that the PEA is similar to a 1,i violation issued in paragraph 8 of Appendix A, Notice of Violation, to the
- Wolf Creek Inspection Report 50-482/84-22, but in our view relates to different
. requirements. i' D b 4
3 +. l Richard P. Denis December 11, 1984 If you have any questions, please contact Brian Grimes (492-4614) or Mark Peranich (492-9661). . N , c M 4N J. Nelson Grace, Director Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement
Enclosures:
- 1. SCVI Inspection Report
- 2. Transmittal Letter
- 3. A - Executive Summary -
- 4. B - Potential Enforcement Action
- 5. C - Unresolved Items e
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! o NUCLEAR REGULATORY COMMISSION i I WASHINGTON. D. C. 20665
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Docket No. 50-482
, Kansas Gas and Electric Company ATTN: Mr. Glenn L. Koester " Vice President - Nuclear P. O. Box 208 Wichita, Kansas 67201 Gentlemen:
J
Subject:
Special Construction Verification Inspection j 50-482/84-51 . 1 i~ Enclosed is the report of the Special Construction Verification Inspection (SCVI) conducted by the Office of Inspection and Enforcement (IE) from October 23 l through flovember 2,1984 at the Wolf Creek Generating Station (WCGS) site. The SCVI team was composed of members of IE and a number of consultants. The SCVI
/ was conducted to assess the voluntary Construction Self Appraisal (CSA) effort .
4 by the Delian Corporation and the followup corrective actions.
.l
} The SCVI report identifies the areas examined during the inspection. Within I these areas, the effort consisted of an assessment of the independence, scope, ,
accuracy and completeness of the CSA effort and report, the categorization ' of deficiencies as to their level of seriousness, and the appropriateness and
; justification of conclusions. A sample of installed hardware and associated
- records was inspected, including hardware and records inspected curing the
, CSA. In addition, the corrective actions taken in response to the CSA findings g were assessed.
Enclosure A to this letter is an Executive Summary of the SCVI and of conclusions reached by this office. The SCVI team noted no pervasive breakdown in meeting construction requirements in the samples of installed hardware or the procedures inspected by the SCVI team. However, the SCVI identified certain limitea areas
- i. where the full objective of the CSA was not achieved.
- {
P Enclosure B contains a potential enforcement action based on SCVI findings 5 which is being reviewed by IE and the NRC Region IV Office for appropriate i action. Enclosure C contains a list of unresolved items based on SCVI j findings. Closeout of all items relative to the potential enforcement action
., and unresolved items identified during the NRC assessment of the CSA effort and of the specific and generic concerns identified as a result of the CSA
- effort will be considered a satisfactory resolution of the matters in this
'i report. With respect to the area of structural steel welding, followup will 3 be that required by the previously issued Notice of Violation. Please inform
- the NRC Region IV Office when your closeout of these matters is ready for NRC review.
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1 8 Kansas Gas and Electric Company - In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures is being placed in the NRC Public Document Room. No reply to this letter is required at this time. You will be required to respond to these findings 3 after a decision is made regarding appropriate enforcement action. Should you have any questions concerning the SCVI or this report, please contact us or the SCVI team leader, Mark Peranich (301-492-9661). - Sincerely, 4 Richard P. Denise, Director Division of Reactor Safety and Projects ~ Region IV "i
Enclosures:
- 1. A - Executive Sunnary
- 2. B - Potential Enforcement Actions
- 3. C - Unresolved Items
- 4. Inspection Report 84-51 .
4 t CC W/ enclosures: 1 See next page 3 (To be provided by Region IV) l- .i 4 '. g q .4. . 4 o
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e e .- EXECUTIVE
SUMMARY
An announced special construction verification inspection (SCVI) was conducted at the Wolf Creek Gencrating Station (WCGS) during the period October 23 - November 2,1984. The objective of the SCVI was to assess the extent to which the voluntary Construction Self Assessment (CSA) performed for the Kansas Gas and Electric Company (KG&E) by the Delian Corporation (Delian), and the followup corrective actions, provide an additional measure of assurance of the quality of construction at WCGS. The objective of the CSA, as stated in the Delian report, was to " provide an independent evaluation of the construction at Wolf Creek with primary emphasis on hardware inspections similar to the Nuclear Regulatory Comission (NRC) Construction Appraisal Team (CAT) inspection." OVERALL CONCLUSIONS It is the conclusion of the NRC SCVI team that the CSA effort met its stated objective in most areas. In most areas the effort was adequately scoped, - _. inspections conducted were generally completed in an acceptable manner, results a were accurately reported, deficiencies were properly categorized as to their seriousness, and final conclusions were justified and appropriate.
^
The NRC SCVI identified certain areas of the CSA effort where the full objective ,
~
stated for that effort was not achieved and where the additional measure of - assurance of the quality of construction for the WCGS was marginal or not
- I achieved. These are:
't
- 1. The CSA inspection sample for electrical terminations was limited in scope and the NRC SCVI identified deficiencies in a broader, independent sample.
The Delian effort did not include inspection of specific cable samples.
; 2. The CSA effort for the comparison of mechanical equipment nameplate data j with FSAR specifications was incomplete due to the absence of data being i collected.
i
- 3. The CSA effort for inspection of structural steel welding did not include a physical verification of structural steel welds. Acceptance by tne CSA was only based on documentation reviews of DIC inspection records.
- 4. The CSA effort for vendor welds did not use a procedure or written criteria for inspection of welds.
i
- 5. The CSA effort for reinforced concrete was limited in scope and did not provide sufficient depth. The effort did not include an inspection of i anchor bolts.
1
', 6. The CSA effort in material traceability was limited to data verifications of certified material test reports, (CMTRs) and did not include physical ; verification of CMTR data to items installed in the plant.
The CSA effort for verification of maintenance requirements was limited 7. to equipment turned over to the licensee and did not include a similar verification for items still under the construction manager's (DIC's) cognizance. A-1
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It is noted that the NRC SCVI in these areas of limited CSA scope did not identify significant hardware deficiencies in the samples that were inspected. In general, where the concerns identified by the CSA team warranted a corrective action plan, the plan identified the requirements necessary to resolve the concerns. In summary, the Delian CSA effort provides for an additional measure of assurance of the quality of construction at the Wolf Creek Generating Station except for the areas identified above and as further clarified in the f.ollowing summary of . areas inspected and results. AREAS INSPECTED AND RESULTS Electrical and Instrumentation Construction In general, the CSA effort was sufficient in scope, completeness, and independence, and adequately categorized the seriousness of findings. The effort provides an additional measure of quality of construction in the areas . of cable raceway, electrical equipment, and instrumentation. Only one area, cable and cable teminations, did not provide an additional measure of quality due to the limited scope of the CSA effort for this area. In this area, the CSA scope did not include specific cable samples for inspection - and their sample for electrical teminations was limited to a specific plant location. Independent SCVI findings were also identified in this area. : A review of selected CSA concerns indicates that CSA findings were categorized based on their importance, and hardware deficiencies were linked to QA and QC program weaknesses where appropriate. When the concern warranted a currective '
. action plan, the CSA plan generally identified the requirements necessary to resolve the findings. The one exception was the lack of attention given the significant number of concerns regarding flexible conduit deficiencies.
During the assessment of the CSA effort, several additional items which required resolution were identified by the NRC SCVI. These included: deficiencies in cabie rollout support and minimum bend radius found to be generic; several deficiencies were found in a previously inspected, repaired and reinspected tubing run; and several installations of nonsafety conduit based on the cetail orawings are in conflict with the FSAR commitment for divisional separation. Mechanical Construction The CSA effort in the area of mechanical construction appeared sufficient in scope, completeness, and independence. The CSA team adequately categorized the importance of their findings. Due to absence or adequacy of data being collected ., and compared with specified requirements for equipment FSAR comparisons, the additional measure of assurance of quality in this area was marginal. The CSA evaluation of the more significant individual findings is reflected in the identification of several generic concerns. A review of the generic concerns that developed in this area indicate that the CSA effort appropriately linked the collection of specific deficiencies to the need for corrective action on a broader sense as shown by their proposed action plans. A-2
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8 o Welding and NDE In general, the CSA effort was acceptable in terms of independence, scope, completeness, characterization of findings and the conclusions reached with a few exceptions. The effort provides an additional measure of quality of construction in the areas of welding and NDE. The exceptions were failure to physically inspect structural welds, lack of written inspection criteria and procedures for inspection of vendor welds, and failure to detect a discrepancy in the identification of material thickness. A review of selected CSA concerns indicates that the CSA findings were categorized based on their importance, and hardware deficiencies were linked i to QA and QC program weaknesses where appropriate. When the concern warranted a corrective action plan, the CSA plan generally identified the requirements necessary to resolve the findings. Reinforced Concrete and Structural Steel Construction
, Based on the NRC SCVI effort sufficient independence of the CSA effort in . ? this section was apparent. A limited additional measure of construction j quality resulted from the CSA accomplishment as detennined from the following:
e the CSA scope of effort was minimal for the assessment of reinforced concrete and structural steel; in general the CSA task in this area was somewhat lacking in depth of review; and no concrete expansion anchor bolts were inspected. , j Independent samples inspected by the SCVI team did not reveal any hardware I deficiencies except for insufficient minimum embedment for concrete anchor ] bolts around the perimeter of a safety injection accumulator tank. Three.of the four CSA concerns in this set: tion were appropriately categorized for level of seriousness ~and were adequately dispositioned. The remaining one is addressed in Enclosure C. .j Material Traceability and Maintenance .} In general, the CSA inspection effort.in the area of material traceability, was limited to verification of documentation data requirements of sampled CMTRs which were not compared to installed components. As such, the CSA effort
! does little to assess the material traceability quality of construction installations or support the CSA conclusion of adequacy for this area. Several e material traceability CSA concerns that were identified in other parts of the CSA report should have been addressed in the conclusions of the Material N] Traceability section of the report. Each of these items indicated some 4 degree of a loss of material traceability and control. Independent NRC ] SCVI inspections accomplished to further assess the CSA effort, revealed that, in general, material traceability and control documentation was accurate and 3
8 agreed with hardware conditions except that a few deficiencies were found d regarding safety-related fasteners.
- In the area of maintenance, the CSA effort was limited to an examination of Newport News, Inc. (NNI) and did not result in any concerns. The CSA effort did not address the nature and quality of maintenance performed by DIC.
Although the CSA report indicated that the maintenance effort (by NNI) was acceptable, many CSA concerns identified by other disciplines were found to be maintenance related. , A-3
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Quality Assurance The CSA effort in this area was found to be generally acceptable in terms of independence, scope, completeness, characterization of the concerns identified { and conclusions reached. The one exception in this area was the CSA review of FCRs which was considered marginal based on the results of the KG&E audit TE:57062-K111. In general, the scope of current CSA Phase II corrective action plans for CSA generic concerns 159, 160, 161 and 170 and corrective action discussed in referenced CARS or other documents are considered adequate for achieving required corrective action, except for a few limited areas identified in l Enclosure C, Unresolved Items. Based on NRC observations of the CSA report effort in this area, an additional measure of assurance of quality was achieved. Additionally, a significant additional measure of assurance of the quality of construction '4111 be achieved with the effective implementation of the CSA/KG&E Phase II followup corrective action for CSA concerns 159, 160, 161, and 170. . h l r l f, 4 A-4
- _-_:_-__ . - ~ . - - .- - ~ ~ - - - -
e . ENCLOSURE B l POTENTIAL ENFORCEMENT ACTION As a result of the NRC special construction verification inspection of the Wolf Creek Generating Station, the following finding has been identified as subject to potential enforcement action:
~
10 CFR Part 50, Appendix B, Criterion III requires that app'icable l regulatory
; requirements and the design basis, as defined in 10 CFR 50.2 and as specified in i
, the license application, are correctly translated into specifications, drawings, procedures and instructions.
10 CFR 50.2 defines " design bases" as that information which identifies the specific functions to be performed by a structure, system, or component of a facility, and the specific values or ranges of values chosen for controlling l parameters as reference bounds for design. . i
; Section 8.3.1.4.1.1 of the license application specifies that cables from different separation groups will, in accordance with IEEE Standard 384-1977 practice, be in steel conduit or enclosed raceway or separated by a fire -
barrier when the normal 5 foot and 3 foot horizontal separation cannot be -
; maintained.
- Section 8.1.4.2 of the license application specifies that deviations from the IEEE Standard 384-1977 practice which reduce the minimum spatial separation between circuits be supported by analysis and, in accordance with the specified i
, Regulatory Guide 1.75-1974, be considered part of the licensee's application, Contrary to the above, a number of non-safety conduits to safety cable trays and cables exiting the trays did not meet the spatial requirements i for cables from different separation groups, in accordance with Bechtel Drawing J E-1R8900, nor was such deviation supported by an analysis, as specified in the license application.
Details of this finding are discussed in Section III.B.1.b.(2).(e) of this
. report.
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l I ENCLOSURE C I UNRESOLVED ITEMS As a result of the NRC special construction verification inspection of Wolf Creek Generating Station, a number of findings were made that require further action by Kansas Gas and Electric Company before the NRC can determine their significance. These findings, listed below, will be followed by NRC Region IV as unresolved items (section references are to the detailed portion of the Inspection Report). i 1. Two areas of minor deficiencies identified by the NRC SCVI were verified by DIC to be generic and require further action by them to correct . existing deficiencies and prevent future deficiencies from developing: the securing of cable at raceway rollouts, and minimum bend radius for cable transfering from tray to conduit. [Section III.B.1.b.(2).(a)]
- 2. Three areas involving the incorporation of inspection criteria or the
- l
) recording of inspection criteria were noted and require additional review i by the licensee for resolution: - i
- a. No requirement for consideration of concrete spalling in obtaining and verifying expansion anchor minimum embedrent. [Section i III.B.1.b.(2),(d)]
- b. Request for Clarification or Information 210-7158 regarding Unistrut installation inspection provides an acceptable condition for sidewall deflection which has not been incorporated into the inspection
! criteria. [SectionIII.B.1.b.(2).(d)]
- c. Generic Resolution F-014 does not require cocumenting acceptance criteria drawing and specification numbers and revisions on the QC checklists although required to do so by the QC procedures.
[Section III.B.3.b.(2).(c)]
- 3. The acceptability and generic implications of vendor termination lug bending, as found in panel RP-210, requires additional licensee evaluation.
[SectionIII.B.2.b.(2).(b)]
- 4. Two items found on the rack for battery NK-12 require additional evaluation to determine acceptability and generic implications: the actual torque i values of the brace pad bolt assemblies, and quality of the rack plug welds.
[SectionIII.B.3.b(2)(c)]
- 5. The reinspection of welds in accordance with the criteria referenced on Bechtel purchase orders, not used in the CSA, is required to provide a basis for implementation of corrective action. This should be done
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following the removal of paint from the welds or following an engineering evaluation of the acce)tability of the method of inspection of vendor welds through paint. :Section V.B.2.c]
- 6. KG&E needs to contractually delegate responsibility for the use of written procedures and criteria that would alleviate organizational disagreements concerning implementation of corrective action. [Section V.B.2.c]
- 7. As a result of the independent SCVI team review of the . Dravo film, 33 film packets were found to be marked with a material thickness different from that shown on the reader sheet. [SectionV.B.3.c]
! 8. A review of concrete batch ticket records identified a deviation from , contractor ANSI N45.2.6 requirements in that a Level I rather than a Level II qualified inspector evaluated the results of inspections by a Level I inspector. [Section VI.B.1.b.(2).(c)]
.i 9. The CSA evaluation and disposition for CSA concern #55 relative to the
} attachment of non Q field routed tubing to a Q whip restraint did not ; consider loading from the tubing attachment and whether there was an i . adequate program for control, design evaluation and as-builts of tubing . attached to Q supports. [Section VI.B.2.b.(2)]
j 10. Bechtel Drawing C-1C2411, Revision 0, Detail 1 requires the projection length of concrete anchor bolts to be 7" above the underside of the j - i top flange of the safety injection accumulator tank (#TEP-01A) base
! frame. According to DIC personnel present at the time of the SCVI, a 1 :3/8" tolerance was allowed, permitting the total maximum projection j length to be 7-3/8". The inspector (s) found that six out of the twelve i embedded concrete anchor bolts had projections above the top flange greater than 7-3/8" which exceeds the maximum allowable. [SectionVI.B.3.b.(2)]
2 J 11. The material traceability for cabinet to cabinet fasteners for Motor 3 Control Centers NG01A, NG01B, NG03C, NG03D and NG04C could not be ~j established due to lack of required traceability markings and were also either missing or were improperly installed. [SectionVII-2.b]
- 12. The material traceability of battery rack NK12 fastener assemblies could
- not be established due to lack of required traceability markings or because they were missing.
9 [Section VII-2.b a
) 13. High strength steel anchor bolts for main coolant pump and steam generator
- supports were made of indetenninate material. [Section VII.2.b]
7, 14 Safety Injection Accumulator Tanks TEP-01A and TEP-O1B had anchor bolt
" nuts installations not in accordance with drawing requirements. [Section VII.2.b]
- 15. An acceptable resolution of TE:57061-K111, Design Control audit findings 3ertaining to DIC imp]lementation of Field Change Requests is needed.
Section IX.B.2.b.(2) C-2
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- 16. The CSA evaluation of KG&E response to CSA concern #159 needs to address and resolve the differences in the KG&E and CSA count of audits not conducted, including any pertaining to audit of construction activities performed by other than DIC. The CSA evaluation should also review the adequacy of KG8E's response on the impact of not conducting audit TE:57061-K111 on schedule has on the assurance of quality of construction prior to plant operation. [SectionIX.B.2.c]
- 17. The KG&E evaluation of SFR 1-B8-147 for reportability to the NRC and of the related controls for the tighten of termination lugs during installation is identified for review. [Section IX.B.3.b.(2)]
- 18. The CAR #18 and the CSA concern #160 action plan should be revised to include additional clarification of intended corrective action require-ments involving SFRs for resolution of " design errors" or without
" identifiable or retrievable documentation". [SectionIX.B.3.b.(2)]
- 19. Appropriate revision of procedure ADM 14-416, Rev. O is required to prevent recurrence of deficiencies in the use of NDCs of the type .
discussed in the KG&E report KQWLO 84-134. [SectionIX.B.3.b.(4)]
- 20. KG&E should audit a sample of NCRs issued after the close out of NDCs for compliance with procedure AP-V1-02, Section 3.30 provisions of
" prior to and after N-stamping" of ASME systems / components. [Section IX.B.3.b.(4)] :
- 21. The KG&E/CSA corrective actions should ensure that the KG&E program for identification and review of deficiencies for reportability to the NRC
'3 is being implemented in a timely manner for: SFR or NCRs checked "potentially reportable"; and for deficiencies in construction which could have gone unoetected due to the breakdown in the SFR QA program, as identified by the TE:50140-K003 Design Control audit. [Section IX.B.4.c.] i 6 4-
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i U. S. NUCLEAR REGULATORY COP 9tISSION OFFICE OF INSPECTION AND ENFORCEMENT NRC Inspection Report: 50-482/84-51 Construction Pennit: CPPR-147 Docket: 50-482 Category: A2 Licensee: Kansas Gas and Electric Company (KG&E) P. O. Box 208 i h
- Wichita, Kansas 67201 Facility Name: Wolf Creek Generating Station Inspection At: Wolf Creek Site, Coffey County, Burlington, Kansas
. Inspection Conducted: October 23 through November 2,1984 Inspectors: #If 8 /fdW M. W. Peranich (Team Leader), Chief, Construction
/N/If Date Progr s/ CAT Secti 1 /Z//o/8Y
' E. R. i , ~R tar Construction Engineer Date izin/fy G. . ,r , r. Re ctor Construction Engineer Date
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. R. L. Cilimberg, Me lurgical Engineer Date 52dM:EL /
., T. K. McLellan, Reactor Construction Engineer aMr Date s -
$6' k R. L. Lloyd, Reactor Construction Engineer
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] Date
/ /D '
- / L ? /Z//c/?y J. <l. Nemoto, Reactor Construction Engineer Date
; Contractor Consultant : M rmack, G. Black, J. Devers.
.. ; z Approved by: Robert F. Heishman, Chief
/Yh/f/
Date Reactor Construction Programs Branch i .] Inspection Summary J
- Areas Inspected Announced special construction verification inspection for an assessment of
, the Delian Corporation Construction Self Appraisal (CSA) and related followup corrective actions was conducted. The inspection involved 760 inspector-hours onsite by ten inspectors.
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Results The results of the special construction inspection are discussed in each section of this report. The deficiencies and unresolved items identified during the inspection are sumarized in enclosures to the transmittal letter of this report. e S s e 0 9 e s 's I ~
. . .. . . .- , ,. . . . . - - . . . . . _ . . . . , . . . . - , . . .-. , :--,.: ,-. .,~. - n--; , .
l TABLE OF CONTENTS , l l TOPIC SECTION Inspection - Background, Objective and Scope .................. I The KG&E and Delian~ Relationship .............................. . II Electrical and Instrumentation Construction . . . . . . . . . . . . . . . . . . . III i
. Mechanical Constructi on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV
-j Welding and Nondestructive Examination (NDE) . . . . . . . . . . . . . . . . . . V i
. Reinforced Concrete and Structu ral Steel . . . . . . . . . . . . . . . . . . . . . . VI
; Materi al Traceabili ty and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . VII i Quality Control Effectiveness ................................. VIII
,i Quality Assurance ............................................. IX .
Attachment A - Persons Contacted I
- Attachment B - Glossary of Abbreviations Attachment C - CSA Status Summary
, Attachment D - Status of CSA Generic Concerns 4
ej Attachment E - Table of Resolution of CSA Concerns
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I. BACKGROUND, OBJECTIVE AND SCOPE A. Background The Kansas Gas and Electric Company (KG&E), as lead applicant for the Wolf Creek Generating Station (WCGS) contracted with the Delian Corporation (Delian) for a Construction Self Assessment (CSA) of the WCGS. This assessment was performed from June through August 1984 and the Delian CSA report was transmitted to KG&E on August 28, 1984. The objective of the CSA as stated in the report was to
" provide an independent evaluation of the construction at Wolf' Creek with primary emphasis on hardware inspections similar to the Nuclear Regulatory Comission (hRC) Construction Appraisal Team (CAT) inspection."
The independent CSA effort was originally planned as preparation for an NRC CAT inspection which KG&E found later would not be conducted. KG&E was aware that there was no requirement under NRC regulations to conduct a CSA but decided to proceed on a voluntary basis with the .
? CSA initiative in the interest of providing additional verification of the quality of construction at the WCGS.
Following completion of the Delian CSA effort, KG&E provided the CSA report and the KG&E pending corrective actions to the NRC Director, Wolf Creek Task Force, Region IV as further assurance of the quality of construction for the plant. The NRC Director, Wolf Creek Task . Force asked the Director, Office of Inspection and Enforcement (IE) for assistance of NRC CAT personnel in assessing the adequacy of the Delian CSA effort and of related ongoing corrective actions. A team of IE staff and NRC consultants was formed to conduct the requested special construction verification inspection (SCVI). The NRC Director of the Wolf Creek Task Force requested that the scope of the SCVI adoress the following matters:
- 1. An assessment of the Delian Corporation effort and report for independence, scope-adequacy to achieve the stated objective, accuracy of inspection results, completeness of inspection and report, apprcpriate categorization of deficiencies as to their level of seriousness, and appropriateness and justification of conclusions. To the extent that it is practicable, the special inspection should, by sample, verify the conditions identified by the Delian Corporation.
- 2. An assessment of the KG&E response to the Delian Corporation report to determine if corrective measures are appropriate.
The NRC Director, Wolf Creek Task Force also provided IE with copies of the Delian CSA report and current KG&E infonnation on status of corrective actions for use in preparation for the SCVI. KG&E also informed the NRC Director, Wolf Creek Task Force that all documenta-
. tion (specifications, procedures, drawings and other documents) used !
to conduct the CSA would be available in Delian files onsite for NRC : review and use in conducting the SCVI. ) i I-1
. , . , , , . , , , . . . . . .n , . . - - - ,.
j
e , On October 23, 1984 the NRC SCVI team held an entrance meeting with the applicant and contractor representatives. Enclosure 1 of this s(ction includes an attendance list. The entrance meeting was held to clarify in general terms the purpose and scope of the special NRC inspection and to obtain additional infonnation for the inspection. The information presented by KG&E and Delian during the meeting included: Status Briefing on CSA and Associated Corrective Action Program; Statusing (and Table of Resolution) of CSA Concerns; for each CSA discipline team, a listing of the CSA team leader and KG&E and contractor support team members (Enclosure 2); the resumes of Delian CSA team leaders; and assigned DIC Contacts'.
- KG&E acknowledged the request that the NRC team be provided with periodic information on the status of the Delian Phase II CSA corrective actions for the 155 specific and 15 generic concerns i (Enclosure 3). Examples of status information received and used by
- the SCVI team in the assessment of the Delian Phase II CSA corrective action effort are attached to this report. This includes: Attachment i C, CSA Status Sumary of Case Specific Concerns and Generic Concerns; i- Attachment D, Status of CSA Generic Concerns; Attachment E. Table
. of Resolution of CSA Concerns, Rev. 8, dated 11/01/84, page 1-17.
$ Primary KG&E contacts for the NRC inspection were R. Grant, Director of Quality and C. Parry, Superintendent of Quality Systems Engineering. l, Enclosure 4 of this section lists DIC contacts for the NRC review of , i the CSA effort. A first day review of Delian CSA files found that j certain documents (specifications and procedures, in most part) had been returned by Delian to KG&E or contractor organizations. Also, 1
- the SCVI noted that " backup" documents (NCR's, CARS, audit reports,
' etc.) needed for the SCVI (and Delian) to evaluate the adequacy of corrective action being taken by the reference " closeout document" ;
(see Attachment C) for each CSA concern was not included in the CSA ' files. KG&E took immediate action to provide the SCVI team with all ; necessary documentation, including the requested duplicate set of
. Delian CSA file folders for.each of the 155 specific and 15 generic 2 concerns identified as a result of the CSA effort. KG&E also provided Deltan with a set of " backup" documents provided to the SCVI team.
Generally, all requested documentation needed during tne SCVI to complete the planned assessment was provided by KG&E during the course of the inspection, y 1 On November 2,1984 an NRC exit meeting was held with the applicant
.and contractor representatives. Enclosure 5 of this section includes
? the attendance list.
- i. The exit meeting was held primarily to inform the applicant of deficiencies identified during the SCVI which may need imediate attention, to acknowledge applicant QA Manager comitments for
- ensuring the effective control and implementation of the CSA corrective action program, and to note that the assessment of the CSA effort and followup corrective actions and resulting conclusions would be based on a review of the findings of the SCVI and would be documented in the inspection report. The applicant was also I-2
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informed that the NRC viewed the CSA initiative as a positive action towards providing an additional measure of the quality of construction at Wolf Creek. B. Inspection Objective and Scope The objective of the special construction verification inspection was to assess for areas sampled the extent the CSA effort and followup corrective actions provide an additional measure of assurance of the quality of construction at Wolf Creek. The scope of the special construction verification inspection included a review of the CSA report; a reverification of a representative sample of hardware and associated records examined by the CSA effort and of similar or other items not included in the CSA sample; and a discipline review of the ongoing corrective action - program for resolution of the 155 specific and 15 generic concerns resulting from the CSA effort. Additionally, interviews were conducted with designated CSA discipline team leaders, KG&E Quality ' . Assurance personnel and other support contractor personnel. The areas for which NRC selective examinations of the CSA effort and related corrective actions was conducted include:
- Electrical and Instrumentation Construction ~
j " Mechanical Construction i
- Welding and Noncestructive Examination
- Civil and Structural Construction Material Traceability and Maintenance
- QC Inspection Effectiveness 1
- Quality Assurance i
d 1-3
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ENCLOSURE 1 OCTOBER 23, 1984 USNRC ENTRANCE MEETING ATTENDANCE SHEET L
- Kansas Gas and Electric Company F. Duddy, Project Director P. Dyson, Supervisor Field Engineering G. Fouts, Construction Manager R. Grant, Director - Quality -
.i C. Hoch, Quality Assurance - Technical . 1 G. Koester, Vice President - Nuclear i W. Lindsay, Quality Systems Supervisor
- 0. Maynard, Licensing Supervisor C. Parry, Superintendent - Quality System Engineering .
E. Peterson, Quality Assurance Technical Auditor - W. Rudolph, II, Manager - Quality Assurance :
! Kansas City Power and Light Company 1
R. Flannigan, Site Representative j Daniel International Corporation J. Berre, Vice President P. E. Halstead, Project Manager j Delian Corporation -b B. Carter, CSA Team
,; D. Leaver, CSA Team U B. Palmer, CSA Team F. Pimentel, CSA Team C. Thompson, CSA Team H. Wong, CSA Team
- G. Young, CSA Team 5 Bechtel C. Herbst, Assistant Project Engineer G. Stanley, Assistant Project Manager e
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NRC and Consultants G. Black R. Cilimberg G. Gower W. Guldemond R. Lloyd J. McCormack T. McLellan J. Nemoto M. Peranich S. R. Stein R. Taylor i I L I I 4 I-5
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. IIC&E Construction .IEC&E Const.
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EcsE Const. - RC&E Cortst.
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. NCEE Cemst.
; - DEC 01 ICivil) - plc 03 Dic 08 M*stingh<mse O.C. - Dic 0.A.
l (Elect rical) DEC 01 Ince;hanical & t ntC Crnstruction (Hrs:hanical uridiruj)
* - E e.t Isufuuso n stlewfornow 0.A.
(Civil) DIC Const. & Wolellr.3) Inst itum9st at iost
# (ElecttIcal) DEC Const. ConsttectIon
- IIC&E 0.A. . - DEC Const . (Piping and , >
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. MGEC 0.A. - MG&E Q.A.
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,8 i ,Fitysre I-l. CSA Trane Dryanizatlosut Interfaces 9 <.s* e
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a. ENCLOSURE 3 CSA RESULTS OF INSPECTION 155 SPECIFIC CONCERNS RESULTED FROM INSPECTIONS t N' l
+ ELECTRICAL 48 ; , + PIPE 26 -
- + WELDING 24 h + NDE 7
+ ' PIPE SUPPORTS 29
+ HVAC 5 .
+ INSTRUMENTATION 9 3
+ CIVIL / STRUCTURAL STEEL 3
+ MECHANICAL EQUIPMENT 4 15 GENERIC CONCERNS RESULTED FROM SPECIFIC CONCERNS AND CONCLUSIONS 0F CSA REPORT e
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ENCLOSURE 4 i DIC CONTACTS FOR NRC REVIEW 0F CSA DISCIPLINE NAME
*Phillip Halstead i
3 Civil Frank Raycher Piping / Welding Johnny Hanvey 1 Mechanical /HVAC Leon Payne
~
Electrical Shelton King s I Pipe Supports Harold Kubasek + Quality Lew Easterwood
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- Contact to arrange alternates if above listed people are not available.
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ENCLOSURE 5 NOVEMBER 2, 1984 USNRC EXIT MEETING ATTENDANCE SHEET Kansas Gas and Electric Company P. Dyson, Field Engineering Supervisor R. Grant, Director - Quality C. Hoch, Quality Assurance - Technical W. Lindsay, Quality Systems Supervisor C. Parry, Superintendent - Quality Systems Engineering
- E. Peterson, Quality Assurance Technical Auditor W. Rudolph, II, Manager - Quality Assurance Daniel International Corporation J. Berra, Vice President 1 P. Halstead, Management Consultant .
1 l Delian Corporation 2 B. Palmer, Consultant
. H. Wong, Consultant G. Young, Consultant NRC and Consultants G. Black R. Cilimberg J. Devers G. Gower W. Guldemand R. Lloyd
- J. McCormack
- T. McLellan J. Nemoto . M. Peranich
.. S. Stein
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II. THE KG&E AND DELIAN RELATIONSHIP , I A. Objective The objective of the special construction verification inspection (SCVI) in this area was to assess if the work, authority, and independence delegated to Delian by KG&E were sufficient to achieve the objective and scope of work as stated by the Delian CSA report and for the followup corrective actions. B. Discussion
- The objective and scope for the Delian Phase I CSA effort are provided t- on page I-1 and I-2 of the Delian CSA report.
$- Delian presented information on the objective and scope for the Delian
.; Phase II CSA followup corrective actions to the NRC SCVI team during i the October 23, 1984 entrance meeting. In general, these activities i were characterized as a third party evaluator of corrective actions, .
' including: the identification of appropriate corrective actions; evaluation of the adequacy of corrective action responses; and the !
- verification that corrective actions are complete and adequate.
The Delian Phase II CSA corrective action process would address most ~
- of the 155 specific concerns through the utilization of nomal quality 1 programs of the responsible organization. CSA foms would be used to .
document the CSA evaluation and verification of the closure of the CSA concern. i For the 15 generic concerns and a few of the more significant specific 3 concerns, the Delian Phase 11 CSA corrective actions will be accomplished by the implementation of CSA established action plans and through the corrective action programs of each responsible organization. The i results would also be documented on CSA Corrective Action Verification
} and CSA Closure Foms.
I
! 1. Delian Phase I CSA
- a. Inspection Scope The inspection in this area consisted of a review of KG&E/Delian i
contractual documents and of the objective and scope of work i stated in Section I of the CSA report. Discussions were also held with the KG&E Director of Quality and Quality System
}
1 Engineering Superintendent and Delian CSA personnel. A review J of observations and findings of the NRC SCVI for each area
} were also examined.
Contract and related letter agreement documents reviewed 1 include: l
. \
- KG&E Purchase Order (P0) No. 45606, including the referenced i i scope of work letter dated June 28, 1984 from Delian to l KG&E.
II-1 N
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- KG&E letter dated August 1,1984, KG&E to Delian (KQLO 84-015).
- b. Inspection Findings (1) Contractual Arrangements A review of KG&E/Delian contract documents found that generally adequate provisions did .axist to provide Delian !
with sufficient authority, independence and scope of work to achieve the CSA objective and scope of work as stated ; in Section I of the Delian CSA report. ' (2) CSA Implementation The SCVI assessment of the CSA effort for independence, scope and completeness of work is discussed in Sections III through Section IX of this re~ port for each area inspected. In general, NRC inspector conclusions in this regard reflect that the level of independence and authority delegated by KG&E to Delian for perfomance of the CSA was adequately implemented. This conclusion is also based on NRC inspectors' observations during the followup inspection of identified CSA concerns which noted a general disagreement between DIC and Delian personnel : regarding the merit of the concerns identified by the CSA and - also on the corrective action being directed by Delian. These observations generally support a conclusion that the CSA concerns were independently documented by CSA, regardless of the potential for disagreement by a DIC CSA discipline team member. Only a few SCVI observations raised some question on the adequacy of the independence of the CSA effort. These generally related to inadequacies in the scope of the CSA inspection effort for areas such as welding of structural steel connections (Section V.B.1.b), bolt torquing at the limited 80% design value (Section IV.B.3.b), and material traceability documentation (Section VII.B.1.c).
c. Conclusion
Our overall assessment is that the CSA effort was generally conducted and reported in accordance with the independence, authority, and work provisions established in contract documents. , It is also our overall assessment that the CSA objective to evaluate the adequacy of construction was generally achieved for the scope of the CSA review. In the following areas the CSA effort fell short of providing additional assurance of the quality of construction to the degree indicated. noted below: (1) The CSA ins]ection sample for electrical teminations was marginal. :SectionIII.B.2.c.] II-2
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(2) The CSA effort for the comparison of mechanical equipment i nameplate data with FSAR specifications was marginal. [SectionIV.B.2.c.] . (3) The CSA effort for inspection of structural steel welding was insufficient. [SectionV.B.1.c.] (4) The CSA effort for inspection of vendor welds was . insufficient. [SectionV.B.2.c.] l (5) The CSA effort for reinforced concrete was marginal. [SectionVI.B.1.c.] l (6) The CSA effort in material traceability was insufficient. ; [SectionVII.B.1.c.] ! (7) The CSA effort for verification of maintenance requirements j. was marginal. [SectionVII.B.3.c.]
) 2. Phase II - Corrective Action Followup i a. Inspection Scope The inspection of this area consisted of a review of KG&E/Delian , contract documents; a review of the information on the scope of , the Delian Phase II corrective actions; NRC discussions with KG&E, -
j Delian and DIC personnel; NRC observations of Delian ongoing i Phase II activities, documentation and procedures; and a review of KG&E's QA program for monitoring ongoing Delian and DIC corrective action activities. Contract and related letter agreement documents reviewed include:
- KG&E P0 45606 and referenced Delian to KG&E j letter dated June 28, 1984.
i
- KG&E to Delian letter dated August 29, 1984 (KQL084-016).
- Purchase Requisition No. 35983 dated October 31,
'.! 1984, to add supplemental scope of work to
; P0 45606.
- i
- CSA Concern Closure Fonn Instructions with Form, fj Undated, and acquired on October 23, 1984.
a j
- Delian Corporation's Construction Self Assessment
{. (CSA) Procedure, Rev. O, dated October 29, 1984. .
- Delian Corporation Construction Self Assessment (CSA) Procedure, Rev. 1, dated November 1, 1984.
"h
- KG&E QA Manual Procedures i
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- CSA Concern File Folders and Contents, including original and subsequently updated CSA Concern Closure Forms and CSA Corrective Action / Verification. Foms.
- b. Inspection Findings (1) Contractual Arrangements The initial NRC review of KG&E and Delian contract documents and related letter agreements and initial observations of Delian implementation of delegated Phase II activities (as discussed under (2) below) found that the contract scope and other related instructions did not provide for sufficient clarification of Delian or KG&E responsibilities in this area. This finding was satisfactorily resolved by KG&E's issuance of purchase requisition No. 35983 to supplement the scope of work of PO 45606.
(2) Delian Phase II CSA Implementation
} Delian Phase II CSA activities are described as consisting i of the control and maragement of corrective actions and the closure of CSA concerns. Delian initiated the pre-liminary onsite administrative aspects of the Phase II '
effort during the first week of October 1984. The Delian CSA team members arrived on. site during the week of
- October 14, 1984 to start the technical reviews of the
' Phase II effort.
l As a result of NRC team member interviews with Delian CSA team members and the review of Delian documentation relative to ongoing CSA team member technical evaluations, it was determined that current Delian instructions for CSA conduct of the Phase II effort were inadequate and there was insuf-ficient assurance that these activities would be adequately controlled and documented. NRC discussions with KG&E and Delian in this regard resulted in the resolution of this finding by the issuance of a comprehensive Delian Corporation procedure (Rev.1, dated November 1,1984) delineating how the Delian Phase II CSA corrective action activities are to be conducted and documented. KG&E also acknowledged that their review of the procedure found the instructions acceptable as related to documentation , required
- by KG&E as objective evidence that the CSA specific and generic concerns have been adequately addressed. Further, KG&E acknowledged that Delian would be required to perform a reevaluation of all Phase II CSA technical activities conducted before November 1, 1984 to ensure that CSA individuals with appropriate expertise perfomed required technical reviews and that all such activities are
? documented in accordance with the instructions of the November 1, 1984 procedure. II-4
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d (3) KG&E Participation Audit or Surveillance of Corrective ' Action Activities Early during the NRC inspection, KG&E was not planning to conduct QA audits, or surveillance, of ongoing Delian Phase
- II~" independent evaluation" of corrective actions. The initial KG&E involvement with the Delian Phase II effort i was generally limited to support provided by the onsite QA ,
Superintendent in arranging meetings between Delian and ; Contractor, in review of Delian/ Contractor action plans of proposed corrective action for CSA generic concerns, and in resolving any disputes resulting from such meetings.
'. NRC initial findings relative to matters listed below were i presented to the KG&E Director of Quality as the basis for i the NRC concern that currently planned K0&E surveillance of ongoing Delian or DIC corrective actico activities were not sufficient, under existing conditions, to satisfy ' KG&E's responsibilities for delegated activities. The - ] matters discussed were: )- (a) Procedures for control of Delian Phase II CSA activities
>; and KG8E assurances of CSA implementation in this area. (b) KG&E's near tenn schedule for fuel load.
- 11 i
(c) NRC inspector observations of the prevalent difference of
, opinion between Delian and DIC personnel regarding the merit of Delian Phase I CSA concerns or the Delian Phase II proposed action plans for resolution of CSA generic concerns.
i The following clarification by the KG&E Director of 4 Quality of KG&E's commitments for ensuring that all l Delian corrective action activities are established and s implemented in an effective manner was provided.
. "KG&E QA is involved in determining appropriate
"} corrective actions for the " Generic" CSA concerns
, because they represent program level problems.
- 1 9 *
"KG&E will approve the Delian procedure used to implement phase II of P.O. 45606 (i.e., verification i
j of Corrective Actions). f.j "KG&E Quality Evaluations group to perform an audit
% or surveillance to verify Delian compliance with
! the KG&E approved procedure.
"KG&E Quality Systems will perform a review of all Delian Corrective Action Packages to enture all M required corrective actions have been completed,
. verified and documented by the CSA and the audited i organizations. II-5 w ** * % 5
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* "KG8E Quality Systems will ensure all applicable documentation related to the CSA inspection, findings and corrective actions are retained in a useable form as QA Records in accordance with applicable site procedures."
In regard tn the NRC question on how KG&E would ensure the DIC effective implementation of Delian corrective action plans, KG&E's commitment in this regard is generally summarized as follows:
- KG&E will utilize its existing contractor surveillance program to ensure Delian action plans for the resolution of CSA generic concerns are effectively implemented by DIC, including
, review or observation of the method DIC utilizes to select any expanded sample requested by the Delian action plan to assess the extent of a CSA generic concern.
- c. Conclusion The above KG&E commitments are considered an acceptable resolu-tion to NRC questions on the means that KG&E will utilized to ensure the effective implementation of corrective action .
activities delegated to either Delian or DIC. - a L b s II-6
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III. ELECTRICAL AND INSTRUMENTATION CONSTRUCTION A. Objective The primary objective of the NRC special construction verification inspection (SCVI) was to assess the extent the Delian Corporation's Construction Self Assessment (CSA) effort and followup corrective action, for the area of electrical and instrumentation construction, provide an additional measure of assurance of the quality of construction at the Wolf Creek Generating Station., B. Discussion 1 The report from the CSA inspection effort was reviewed to determine the scope of inspections for electrical raceway, cable and equipment, instrumentation, and instrument tubing. A sample of the CSA effort, from Tables 11-1 and II-3 of the CSA report, was selected for examina-tion. The SCVI sample included some areas in which CSA identified
- .! specific and generic concerns and some areas in which no concerns were identified. In several areas the examination also included samples outside the CSA effort to provide an additional basis for evaluation j of the overall Delian effort.
The CSA report and a selection of the 60 electrical and instrumentation concerns were evaluated for the adequacy of scope, independence, : completeness, the appropriateness of the CSA deficiency categorization . i as to the level of seriousness, the overall conclusions and basis
- for the conclusions and adequacy of corrective actions. Discussions
! with onsite Delian, Kansas Gas and Electric Company (KG&E) and contractor personnel as well as the results of the SCVI inspections were taken into consideration for the overall evaluation of the CSA effort.
- 1. Electrical Raceway
. a. Inspection Scope Ten segments of cable tray totaling 300 feet were selected i from the CSA sample of 720 feet. An additional 200 feet of 1 these same tray segments, which were adjacent to and not included in the CSA inspection, were selected for examination. These i segments, previously inspected and accepted by the licensee, , ; were examined for compliance to licensee commitments relative l ': to routing, location, support spacing, separation, bedding, ! . identification, loading, physical condition, completeness, and l J' protection. +'
Five segments of conduit totaling 250 feet were selected for ! I
- examination from the CSA sample of 800 feet. These segments, previously inspected and accepted by the licensee, were examined
- for compliance to licensee commitments relative to routing, l' location, support spacing, separation, identification, complete-i nest, and physical condition.
III-1 ! _.y..- . , . . . .,
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O o Thirteen raceway supports associated with the above electrical raceway, and four additional supports identified by CSA concern numbers 24 and 25, were examined for compliance to licensee connitments relative to location, spacing, material type and size, configuration, attachments, and where applicable, bolting and weld appearance and configuration. The four additional supports were also examined for the completeness of corrective action as identified by the CSA effort. For a listing of the electrical raceway and supports examined, see Table III-1. The following documents provided the acceptance criteria for the NRC SCVI team examinations and review. Wolf Creek Generating Station Final Safety Analysis Report (FSAR)
- Bechtel Power Corporation Specification E-01013, Rev.11,
" Electrical Installation, Inspection and Testing"
- Bechtel Power Corporation Drawing E-1R8900, Rev. 2,
" Raceway Notes, Symbols and Details"
- Daniel International Corporation (DIC) Construction Procedure QCP-X-300, Rev.14, " Inspection of Electrical
- Raceway" DIC Construction Procedure QCP-X-302, Rev.19,
" Inspection of Raceway Supports"
- DIC Construction Procedure QCP-X-304, Rev. 7,
" Inspection of Cable Installation"
- b. Inspection Findings In the area of electrical raceway and supports, the NRC SCVI inspectors observea that material ano installation methods used were generally as specified in the licensee connitments.
However, several construction and inspection deficiencies were identified in both the CSA sample evaluated and the indepenaent SCVI sample and are detailed in the following sections. (1) CSA Report Review I The scope for inspection of cable tray does not appear sufficient. A discrepancy between the CSA report text and the listing of samples (CSA Table Il-1) indicates that their sample of tray may have been as little as 120 feet. The physical selection may have also been insufficient as a number of SCVI findings were in elbow sections innediately adjacent to the CSA samples which were predominantly the straight runs of the tray selected. III-2
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l Excluding the limited scope of cable tray inspection the l report was generally complete with respect to the items examined and findings recorded. Discussion with the Delian inspector and review of the CSA findings indicate that independence of the effort was maintained. Overall, the deficiencies identified were sufficiently categorized to identify their seriousness. One exception was the number of deficiencies identified with flexible
- conduit: 12 by CSA and one by the SCVI., Even though outside of the scope of the' selected sample, these many
!~
instances suggest a high level of significance and require i further review by the licensee. (2) NRC SCVI Sample
}' (a) Cable Entering or Exiting Raceway j Several cables were observed to exit (rollout) cable q tray into the top of equipment without being secured at t or near the rollout per the specified criteria. The initial condition was observed in the independent SCVI 1 sample where cables exit tray 4J2A32 at box 1ZSE249.
While the NRC inspectors observed that the specific instances :
, themselves do not represent.a significant deficiency in .
. construction as there was no evidence of physical damage, l subsequent investigation by the licensee representative l Indicated this condition to be generic throughout the facility and was subsequently recorded on Notification of Discrepant Condition (NOC) E-111. Although the inspection criteria was available through a specification reference in the Quality Control Procedure, it was not readily 4
apparent from the QC checklist. As a result, QC personnel did not identify these minor construction deficiencies. 1 j The SCVI inspectors also observed one instance in the CSA
! sample and four instances in the independent sample where i cable transferring between cable tray and conduit violatec the specified minimum bend radius or barely met the require-4 ment with no additional protection provided to prevent 4 violation due to subsequent construction activities. The following is a list of the tray to conduit observations
- g. identified to the licensee.
'i 4U2A32 to 4U2A2C 4J2A32 to 4J2 AIL ^!, 4J2A31 to 4J2A2B 1J1G60 to 1J1G5C
.i 4J1C66 to 4J1C10 i It was noted that protection methods are detailed by the architect-engineer to be used where necessary. III-3 ag**** v e m * ** s *
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- W
Discussions with the licensee representative indicated that if field personnel were suspicious of a bend radius measurement, they would make a temporary template for immediate verification only. No permanent templates exist. The licensee representative verified the specific violations and is evaluating additional protection to prevent future violations. Again, the SCVI inspectors observed that none of the instances identified exhibited a significant deficiency in construction, but rather that minor construction deficiencies had not been identified by QC personnel. Also, the NRC inspectors are concerned that the current method of verification may not identify bend radius violations due to the configuration of the installed cable. (b) Cable Tray Barriers ' In general, cable tray covers (fire barriers and dust covers) were found to be installed in accordance with the - specified criteria. However, several instances of missing and improperly sealed barriers and a loose barrier clamp, as listed below, were observed and identified to the
- licensee representative. The unsealed barrier was found .
in the CSA inspected sample while the other two instances - were found during independent inspection. IC8F58 - barrier not sealed 1J1H80 - loose barrier clamp IC8K07 - barrier removed The licensee's representative documented these discrepancies on Nonconformance Reports (NCRs) ISN-20890E, -20919E, and
-20920E.
The NRC inspectors observed that none of the specific instances identifiec representec a significant deficiency in construction, but rather that minor construction
' deficiencies had not been identified by QC perscnnel. ' l One additional discrepancy found by the SCVI in the CSA ; sample involved the barrier for cable tray 4J2A31 at the junction of conduit 4J2A1A. As installed, the barrier partially obscured the tray identification. The licensee representative subsequently recorded this condition on NDC E-097. This condition is considered to be minor.and an isolated case.
(c) Cable Bedding and Training With the exception of cable transfer and rollout deficiencies previously discussed, the SCVI inspectors observed that cable bedding and training had generally been maintained in the areas examined as per the specified criteria. III-4
, . - _ . - . . . , m_, , . . 3, .. , ,... . m --, . w .- m . . . .
However, one instance of two cables (1GEYl8CA and 1GEYl8AA) within the Delian raceway sample was found with one end not sealed and both coiled and laying on a lighting receptacle above tray IC8F58. Discussion with and investigation by the licensee representative indicated the cable had been deleted but not removed. This condition was subsequently documented on NDC-E-152. The NRC inspectors considered this instance an isolated case. (d) Supports 3 Generally, raceway support assemblies, hold down clamps, bolted support braces, welds,. and anchors were observed to be in accordance with the specified criteria. An isolated instance of a loose hold down clamp bolt on support ', 351F-75 was identified to the licensee representative.
- The condition was subsequently documented on NCR
( ISN-20913-E for correction. 4
' During the review and examination of the CSA concern J- number 24 regarding support 371D-24 (now identified as 3710-1003), one anchor was observed to have concrete - - spalling behind the raceway support. The NRC inspectors expressed to the licensee representative that the extent : ; of the spalling appeared to infringe upon the required .
t anchor minimum embedment. Subsequent discussion with the
}. licensee representative and QC personnel revealed that ; minimum embedment is measured from the design surface of 4 the concrete, regardless of the amount of spalling, per '
the project specifications. Further review of the project requirements by the NRC inspectors did not find criteria established to consider spalling when verifying minimum j anchor embedment. ( Concurrently, the review and examination of concern
' number 24 and the related generic concern number 165 revealed a clarification of criteria for the sidewall
- spread of raceway (Unistrut) supports on Request for
' Clarification or Information (RCI) 210-7158. This a clarification indicates that a small deflection is j acceptable provided no buckling (kinking) is present. 1 Discussion with the project personnel indicated that the 3 RCI did not provide any accept / reject criteria as the 3 present procedure provided the criteria adequately. When
; asked what was the need for the RCI if the criteria existed, < .l it was indicated the RCI was generated only for the condition identified by the CSA effort. Review of the
- procedures by the NRC inspectors could not determine the
.i existence of acceptance criteria for Unistrut sidewall deflection.
L .The lack of criteria established for the above conditions
- could allow for unacceptable installations to exist. l It is recomended that licensee detailed attention be j i
i III-5 'l 1 I w , v , -. . - . . . , .. . m m, w.. .9 3py ,-w--~ xr,g v w , p -,m .. .
given to these conditions to assure adequate corrective action by the CSA effort and an analysis to assure that these conditions do not allow for an unacceptable condition ! elsewhere in the facility. These items remain unresolved. (e) Raceway Separation The Wolf Creek Generating Station FSAR Section 8.3.1.4.1.1, Raceway and Cable Routing, provides the basic separation criteria between redundant Class IE circuits and between Class IE and non-Class IE circuits. The criteria as stated is in consonance with IEEE Standard 384-1974 and NRC Regulatory Guide (RG) 1.75-1974. The requirements of RG 1.75 and IEEE-384 are discussed in the FSAR Section 8.1.4.3, Design Criteria, Regulatory Guides and IEEE Standards, and although several items are supplemented or clarified, no exceptions to either document are taken. , In sumary, FSAR Section 8.3.1.4.1.1 requires cables from different separation groups to be in steel conduit or enclosed . wireways or separated by a fire barrier when the normal 5-foot vertical and 3-foot horizontal separation cannot be maintained. A conflict was noted by the SCVI inspectors between the FSAR comitments and raceway installations as permitted : by Drawing E-1R8900. Paragraph 3.36.5 of the drawing permits
- non-class 1E conduit to be run within one inch of open Class 1E cable tray. The SCVI inspectors noted several non-Class 1E conduit to Class 1E cable tray installations that met the drawing requirement but did not meet the FSAR commitment for either 3-foot 5-foot separation, enclosed raceway or separation by barriers. These are:
Non-Class IE Conduit Class 1E Tray 6U3H1A, 6U3H1B to 4G1C12, 4U1858 (and free air cable exiting tray) P , 5J3030 to 1U1E01 SU3090 to 1J1001, IC8C01, 1U1E01 5U5010, SU5011, to 4U1C72 6U3E3M, 6U3E3N IEEE-384 permits lesser separation distances to be established by analysis based on flame retardancy testing of the installation. RG 1.75 requires this analysis to be part of the FSAR. Discussions held with representatives of Bechtel Power Corporation indicated that analyses for the Wolf Creek Generating Station installations have not been performed. This item remains unresolved. i III-6
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l
)
- c. Conclusion l
Several instances of minor construction deficiencies identified by the SCVI were found to be generic by the licensee. A conflict ' between the FSAR comitment for divisional separation and several installations of non-safety conduit permitted by the detail drawing requires resolution. f l [ While some of the NRC inspection observations were made in the same areas previously examined by the CSA effort, the overall 1 CSA effort resulted in conclusions appropriate for the basis ; provided, and identified specific and generic deficiencies which f j require detailed licensee attention to provide correction and I assure the quality of construction. Within the scope of the CSA raceway inspection, the effort was complete, independent, properly concluded and does provide an additional measure of assurance of quality of construction. l
- 2. Cable and Terminations .i i
j a. Inspection Scope
; Since the NRC Region IV task force inspected cable and cable routing, no independent sample was evaluated by the SCVI team. ,
However, cable was reviewed during the SCVI inspection of . j raceway. *
,' The NRC SCVI inspectors inspected approximately 50 field termina-4 tions in two of the four control room panels inspected by the CSA effort. These were panels SA036A and SA066C.
In addition, approximately 30 field terminations from various areas of the plant were independently inspected. These were: Panel Cable $; RP-210 4GSY02AD 4BMYO2AD 4BMK06BC NN-11 INNY01AA INNY01AB
! 1NNY01AG ! 1NNY01AH . NE-106 4NER11AC , 4 NEB 02AP ; The terminations were inspected for identification, proper landing of conductors, wire or insulation damage, evidence of proper crimping, lug bending and general workmanship. The tennination inspection records were also reviewed.
The following documents provided the acceptance criteria for the inspection of tenninations: III-7
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- DIC Construction Procedure QCP-X-304, Rev. 10
" Cable Termination"
- Bechtel Drawing E-17000 " Electrical Termination List"
- b. Inspection Findings (1) CSA Report Review Although the number of terminations inspected by the Delian team appeared adequate, their singular location (control room panels) was not sufficiently representative of the plant. The CSA report conclusion recognizes this limitation.
The in-process inspection of terminations by Delian provided the review of characteristics not available in final inspections. However, the CSA report does not identify any acceptance criteria used for inspection of tenninations. No specific sample of cable was inspected by the CSA effort. l l (2) NRC SCVI Sample (a) Cable , During the NRC SCVI inspection of raceway, several problems I were identified with cable exiting cable tray. These are discussed in Section III B.1.b.2.(a), above. Cable bedding and training observed during raceway inspection is also discussed in Section III.B.1.b.2.(c), above. (b) Terminations No deficiencies were noted in the evaluation of the CSA sample of terminations. However, one field deficiency and a potential problem with vendor teminations was found in the independent sample that was inspected. Both of these occurred in panel RP-210. One conductor from cable 4BMK06BC in panel Rp-210 had its insulation deformed and cut through to the wire. Althcugh this apparently occurred during installation of the terminal - lug, the DIC inspection records accepted the installation. However, the DIC field termination was made using nylon screws with the licensee performing the final change-out to the current metal terminal screws and a review of the - licensee's documentation for this process was not made. This deficiency was documented by DIC on a Notice of Discrepant Condition which had not yet been serialized. A number of vendor installed tenninal lugs in the same panel were found to be bent a full 90 degrees. The DIC Lead Electrical Engineer indicated that the requirement III-8
. . . .. -. . . . . .,, . , . -,, ,. . . w . - - g . , . ,
for field terminations is one bend not to exceed 45 degrees. When the SCVI inspector questioned the vendor requirement, DIC reviewed the purchase specification for the panel and reported that the specification contained no requirement for terminal lug bending. DIC has requested a determination of acceptability of this condition from Bechtel Power Corporation via RCI 1-1361-E. This item remains unresolved. No other deficiencies were found in the other panels inspected.
- c. Conclusion
-r i
Only one deficiency in vendor terminations was identified by the 3 SCVI effort. However, the acceptability of vendor termination lug bending requires licensee attention.
~
Due to the limited scope of the CSA terminations sample, the SCVI findings for terminations and the lack of a specific cable .
.j inspection by Delian, the CSA effort does not provide an additional j measure of assurance of quality in this area.
- 3. Equipment
- a. Inspection Scope :
; Three items of electrical equipment inspected by the CSA team were chosen for evaluation by the SCVI inspectors. These were:
1 High Pressure Safety Injection (HPSI) Pump Motor DPEM01A Motor Control Center (MCC) NG02B 125 V d.c. Battery NK-12 In addition to location, mounting details, identification and general workmanship, the HPSI pump motor was inspected for nameplate data verification; the MCC was inspected for attachment welds (length, location, general contour), nameplate data verification and breaker size; and the 125 V battery was inspected for cell electrolyte level, rack configuration and j battery room environment.
.'] The following documents provided the acceptance criteria for .. the inspections:
d i
- DIC Construction Procedure, QCP-XI-300, Rev. 10,
'1
" Inspection of Electrical Equipment"
.y
- DIC Construction Procedure WP-XI-300, Rev. 8, i;l " Installation of Electrical Equipment" o
[j
- Manufacturers' equipment manuals j
e III-9 3
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- b. Inspection Findings (1) CSA Report Review The size of the CSA sample for equipment appeared adequate '
to determine the quality of construction in this area. Discussions with Delian representatives revealed that the inspection of motor operated valves (M0Vs) was hindered by the inspector's inability to open the MOV covers for a thorough inspection. The CSA inspectiort was comprehensive, complete and independent for the equipment that was fully accessible to the inspector. The significant hardware deficiency found by the CSA effort was properly identifieo as such and properly extended to inadequate inspection criteria and inspection reports. (2) NRC SCVI Sample (a) HpSI Pump Motor DPEM01A No discrepancies were noted with the installation of the pump motor which is in consonance with the CSA inspection. - (b) MCC NG02B No deficiencies were noted in the location, identification and mounting of the MCC. Breaker size, workmanship and identification of the several cubicles inspected met the specified requirements. The bolting discrepancies identified by the CSA effort and recorded under their concern numbers 35 and 164 are discussed in Section VII, Material Traceability and Maintenance, of y this report, (c) 125 V d.c. Battery NK-12 The battery cell electrolyte levels, battery rack configuration and battery room housekeeping were found to be generally acceptable. However, the SCVI inspector noted an inconsist- : ency in the deformation of the battery rack brace pads i between the two racks; deformation being caused by torquing of the brace pad bolting assemblies. The inconsistent deflection puts the actual torque values in doubt. DIC 3 recorded this condition on NDC E-103 for resolution by the licensee. This item remains unresolved. l The plug welds attaching the battery racks to the floor l embed channels exhibited considerable variation in contour. l The concern was documented by DIC on Electrical Rework i Assignment RA-EI.341-22 which requires two welds to be cleaned and reinspected. This unresolved item will require followup by Regional weld inspectors. III-10
._,- 7. .. v . -- ..; . . _. . , . . . - . . . .
3-
A review of the QC inspection checklists revealed an incorrect drawing reference on the latest checklist. When this was identified to DIC, Generic Resolution F-014 dated September 7,1984, was produced. F-014 states that, although required by the QC procedure, drawing or specification numbers and revisions need not be recorded on the QC checklists as this information is available from other documents. Although no adverse affect on the hardware in this particular case was noted by the SCVI inspector, the Generic Resolution indica.tes a program weakness. It is now not certain how the specific documents and revisions used as the acceptance criteria for an 4 inspection can be verified. The licensee needs to more fully address this area. A review of the CSA concerns for battery NK12 (concern _, numbers 100,101 and 155) showed that CSA's requirement for
; corrective action plans and their evalution of responses - was connensurate with the categorization of the findings.
- d. The one significant finding on battery rack bolting, concern
. number 155, was properly incorporated into generic concern rumber 164 ano is discussed in Section VII, Material l Traceability and Maintenance, of this report.
- c. Conclusions :
No deficiencies in addition to the CSA findings were noted during the SCVI inspection of the MCC and HPSI pump motor. Two items with the 125 V d.c. battery rack require additional licensee attention: brace pad torquing and plug weld quality.
; The scope and depth of the CSA effort in this area provides an
, additional measure of assurance of quality for electrical
.j equipment with one exception: the inspection of MOV operators. l 4. Instrumentation Inspection
- a. Inspection Scope Several items inspected by the CSA effort were evaluated by the j SCVI team. These consisted of one tubing run (approximately 100 4- feet in length), one pressure indicator and the accessories for one air operated valve, and are identified below:
f{ . :. Isometric drawing J-14BB13 (tubing run)
- PI-402 (pressure indicator) l EM 8823 (air operated valve)
Two additional tubing runs for an approximate total of 70 feet were independently inspected. These were detailed on isometric
- drawings J-04BG02 and J-148G16.
III-11 l, - . 7 - -, . ., in r,,~ p r 7- ---
- n. ,
- - r :. -
In addition to the tubing itself, the tubing supports, instrument mounting details and mounting structure configurations were verified. Inspection records were also reviewed. The following documents provided the acceptance criteria for the inspection.
- Bechtel Specification 10466-M-204 Appendix X, Rev. 16. " Field Fabrication and Installation of Instrument Tubing, Tubing Supports and, Instrument Supports".
- Westinghouse Nuclear Operations Division (WN00)
Procedure G-SAP-A-005, Rev. 4, " Engineering Job Instruction for Field Instrumentation Installations".
- b. Inspection Findings (1) CSA Report Review The samples chosen by the CSA inspector were of sufficient size and variety to make an adequate determination of construction quality. The only omission noted in the CSA effort for instrumentation was the lack of inspection documentation review. .
The concerns evaluated by the SCVI were properly categorized by CSA and represented the results of an effective, inde-pendent inspection. (2) NRC SCVI Sample No deficiencies were noted with the CSA inspected pressure indicator and air operated valve accessories, and only one minor deficiency was noted on one of the independently inspected tubing runs. This deficiency was a tubing clamp on isometric J-04BG02 located over the specification tolerance for the designed spacing. This condition was being documented on an hCR at the close of the inspection and an NCR number had not yet been assigned.
. The CSA inspection of isometric J-14BB13 resulted in concern number 143 for a loose tubing clamp and bent and sagging tubing. At the time of the SCVI, Westinghouse N0D had repaired and reinspected the items identified by the CSA although Delian had not yet verified the corrective action.
The SCVI inspector identified three separate deficiencies in the tubing run, one of which was located immediately adjacent to the repaired section of the tubing. The three deficiencies included an area of sagging tubing and two instances of physical interference. The sagging tubing was located approximately 10 feet from the area identified by the CSA concern. The tubing was also in contact with a tube III-12
, , . . , ,, _py.;. p: y, y m-~ . . ~~
l steel support immediately adjacent to the repaired section and was apparently caused by the repair, and the second interference occured where the tubing passes through a wall penetration shared with an insulated pipe. The Bechtel specification M-204
' Appendix X and Westinghouse procedure G-SAP-A-005 require sufficient clearance from all steel and concrete surfaces of building members.
The sagging tubing and the area of contact with the tube steel f were documented on NCR ISN55413-J. The . interference with the pipe insulation and wall penetration sleeve requires coordination wj,th the insulation contractor and was documented on the Open Items Status Report. Although relatively minor in nature, deficiencies in tubing which has been inspected, repaired and reinspected may indicate that the licensee does not have sufficient control over inspected and accepted tubing runs. e i-In addition to reviewing concern number 143, the SCVI -
) reviewed CSA's generic concern number 156 issued as a .
result of foreign material on instrument tubing and tubing i damage caused by subsequent construction activities. Although the CSA corrective action plan is not specific, it identifies the key elements the licensee should meet: . , identification of damage, prevention of damage, determina-tion of corrective action effectiveness, and tubing
- verification prior to operation. CSA was still reviewing .
.. the licensee's proposed actions relative to this concern
.} at the end of the SCVI. ; c. Conclusions 4
Four deficiencies, which were not considered to be significant
. construction deficiencies, were noted by the SCVI and documented a' by the construction organization. However, the presence of three of these on one tubing run that had been inspected twice, repaired j and reinspected indicates that the licensee's corrective action program in this area needs improvement.
3 The CSA effort in instrumentation was acceptable in scope, j independence, and categorization of findings. Although it ,1 would have benefited from a review of documentation, the effort does provide an additional measure of assurance of quality. F q l.
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e III-13 ' m s. . .; . . . . . . . ...m c.,--, g ,v,79 7--, .- -- q.; 7.- , ,- .- , .
TABLE III-1 RACEWAY AND SUPPORT INSTALLATION Raceway IC8F IJ1G 6J2A 4J2A IJ3F6A IC8G IJ1H 6J26 4J1C5B 3J6002 1C8J IJ1J 4U2A IU3MID 3U6002 Supports 3710-1002 351F-71 251F-74 241-03 252FR-29 3710-1003 351F-72 351F-75 241-04 3710-1004 351F-73 241-02 241-05 ? L h i o
+ 0 III-14
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IV. MECHANICAL CONSTRUCTION l A.. Ob.iective , r The objective of the special construction verification inspection l (SCVI) was to assess the extent the Construction Self Assessment (CSA) effort and followup corrective actions, in the area of , mechanical construction, provide an additional measure of assurance t of the quality of construction at Wolf Creek Generating Station. B. Discussion The scope and description of the CSA effort in the area of mechanical construction are provided on page III-1 and III-2 of the Delian
,' Construction Assessment Report. The more significant inspection . . findings are discussed on page III-3 of the report and the specific details of the individual concerns resulting from the CSA effort in this area are contained in 50 separate concern packages maintained j by Delian Corporation at the Wolf Creek site. -
j During the course of the NRC inspection, the individual concern packages i were examined to more fully assess the nature of the concern, corrective action taken or the action plan proposed to resolve the concern. Acceptance criteria for the NRC inspections were essentially the same as used by CSA and referenced in the Delian report. Copies of the .
; appropriate standards, specifications, drawings, manuals and procedures
- I were provided by KG8E or DIC as needed. Also, interviews were conducted I with Delian, KG&E and DIC personnel involved in the mechanical 1 construction area as needed to assess the CSA effort. Factors i considered in the assessment of the CSA were: independence,
, adequacy of their scope for the stated objectives, completeness, appropriateness of CSA identified deficiencies, their categorization and the conclusions reached in their report.
Specifics of the NRC verification inspections are provided below.
- 1. Pipe Supports / Restraints
- a. Inspection Scope f
The Delian report lists a total of 50 large bore and 20 small i: bore supports / restraints as those inspected by the CSA team. Page III-3 of the report provides the details of what was inspected and Tables III-3 and -4 give the individual systems %j involved, hanger numbers and other pertinent information relative to the support / restraint.
, The NRC team inspected a sample of 13 large and small bore pipe supports / restraints that the CSA team had also inspected. Two additional support / restraints not inspected by the CSA team were i also inspected. The 15 are identified below:
1 5 IV-1 O
. %#'
- N#D YOY T*[ } # Y $
- 6 l ,y g ,.
d k, f *h # N ' # h F ',
r L h l EG01-C012 AE05-R014 AB01-R032 AE05-R001* l AE05-H005 EJ02-C002 l EG10-A001 EJ02-R023 i EG13-R008* AB01-R515 EP02-R021 EM12-H005 EP02-R011 EP02-H005
- EP02-R010 Prior to NRC inspection of the above supports / restraints, data packages used by the CSA team for the inspection items were reviewed along with the concern packages for those that had generated a concern. Similar data was used for the SCVI of the two restraints not included in the CSA sample. These data packages contained design sketches, bill of materials, any L special instruction sheets involved, QC inspection fonns and other quality related documentation. For the 13 supports, specific design / construction attributes noted to have been j inspected by CSA were reviewed.
During the NRC team inspection the same attributes were examined and verified and on some supports additional attributes beyond i those inspected by CSA were examined for conformance to design / construction specifications,
- b. Inspection Findings
- l l NRC. inspections of the supports / restraints noted above, including l the two not in the CSA sample, did not result in the identifica-tion of significant deficiencies beyond those identified by the CSA effort.
On several supports the specific concerns identified by CSA were observed to have been corrected or reworked; other concerns were noted to have been accepted "as is". It is noted that several specific concerns in this area resulted in generic concern 166. This matter dealt primarily with the possibility that Special Instruction Sheets (SIS) may not have been updated following drawing changes, etc. Resolution of this relatively significant concern involved review of a considerable number l of SISs and the eventual issuance of two Corrective Action Reports (CAR). The NRC team reviewed the particulars of this finding and the proposed resolution including the two CARS. The finding is considered valid and the proposed corrective action is a reasonable method of resolution. It is noted that the CSA effort by Delian did not include inspection of the expansion anchor bolts used to fasten surface mounted base plates for the support / restraints in their sample or as a separate area of inspection. In view of this, the NRC team selected a sample of expansion anchor
- ' Support Restraint not in CSA Sample IV-2
- . - . . . . . ..r., c .,.,~.s....... m , w , .. r .4.
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o . bolts used in supports / restraints both within the CSA sample and outside. A total of 8 surface mounted base plates which ! included a total of 32 expansion anchor bolts were inspected for proper torque. The details and results of the inspection l of anchor bolts are discussed in Section V of this report.
c. Conclusion
The CSA effort in this area was found to be generally acceptable
) in terms of independence, scope, completeness, characterization of findings and the conclusions reached. The action plan developed in connection with generic concerns 157 and 166 are appropriate in view of the specific findings which led to their preparation.
The fact that the CSA effort did not include the verification
. of torque values and inspection of a sample of expansion anchor
.. bolts detracts somewhat from the overall CSA conclusions about j i pipe supports / restraints, with this exception, the CSA effort provides an additional measure of assurance of quality in the - area of pipe supports and restraint::.
- 2. Equipment Data FSAR Comparisons
- a. Inspection Scope .
The Delian report discusses this area of inspection on page *l ' [ t III-7. Of the seven items listed on Table III-6 of the Delian l report, four were examined by the NRC team for verification. It was noted that a total of 19 parameter values - Nameplate
- Data or FSAR Data - were missing from Table III-6 and presumed indeterminate by Delian for comparison purposes,
- b. Inspection Findings During the NRC team coverage of this area 13 of the 19 missing
.j comparison values were located with the help of KG&E personnel
' and evaluated. Several comparison values remain indeterminate for some CSA sample items. Discussions with Delian personnel on this matter indicate that an attempt to obtain some of the missing data from KG&E had failed. The matter was not pursued - by Delian. ; c. Conclusions i The CSA effort in this area was determined to have been generally
.: acceptable with respect to independence and scope. The NRC review of this effort indicates that most of the items listed 4 for comparison purposes were verified by CSA, however, a signi-R ficant number of values that were not verified as shown by blanks
, in table III-6. Seven pieces of equipment were involved in the CSA sample. From one to four items of comparative data was left blank on each of the seven items. This raises a question about the completeness of this effort and therefore the additional measure of assurance of the quality provided by the CSA effort in this area is considered marginal.
IV-3 [_... . . - . . , . , . ,
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- 3. Bolt Torquing for Mechanical Equipment
- a. Inspection Scope A description of the Delian effort in this area is provided on page III-7 of their report and Table III-7 lists the specifics of the items checked. During discussions with the CSA team members associated with this effort an attempt was made to detemine the bases for using test-torque values 80% of the specified design values. It was learned that.the 80% torque limit was essentially established to avoid breaking any torque seals that had been previously applied following final QC torquing.
- b. Inspection Findings The NRC team coula not verify or establish the validity of using an 80% test limit in terms of quality verifi,:ation or other quality stanoards. A discrepancy is noted between the statement on page III-7 about an 80% limit and the data in table III-7.
Apparently some of the bolts in the CSA sample were torqued to 100% of the specified values despite the statement on page III-7. No independent SCVI examinations were conducted in this area.
- c. Conclusion In view of the NRC team's problems in establishing the basis upon which bolt torquing was accomplished there appears to be a limit on the ddditional measure of quality achieved from this effort.
The bolts (8 of 18) that were torqued to full specified values were of one type and size and located on the same type of equipment (auxiliary feedwater pump). To this extent there is dn additional measure of assurance of quality of bolt torquing.
- 4. Heating, Ventilation and Air Conditioning (HVAC)
- a. Inspection Scope The CSA scope and description of the CSA inspections in this area are provided on pages III-8 and -9; the list of specific items making up the CSA sample is provided in Table III-8. The CSA concerns resulting from their inspections are provided in Table III-9.
The NRC team inspected four of the 24 HVAC hangers in the CSA sample including the adjacent sections of duct, flanges and equipment in the general area. Prior to performing the inspections both the CSA data package and the CSA concern file were obtained and reviewed for each hanger to ensure recognition of the attributes inspected by CSA and resulting findings / concerns. l IV-4
. 7. ,p,.p.py,-e - r c -~ t 7 .
i Generally, the concerns identified by CSA were of a welding nature (undersized welds - generic concern 168) and inconsistencies between various documents which specified fabrication and inspection
- requirements (specific concern 153 and generic concern 158).
The NRC inspection confirmed the CSA findings; no significant additional-deficiencies were identified. The CSA effort, as far as the NRC team could determine, did a ' not include a sample of fire dampers. The NRC team inspected i' a sample of 6 fire dampers. The appropriate.Bechtel drawings were used during those inspections. Also, Bechtel Specification
- 10466-M-6278 " Technical Specification for Dampers for SNUPPS",
DIC Document QCP-VIII-200 " Inspection Documentation of Field Fabrication and Erection of Safety Related Ductwork and Supports" and DIC Document AP-VI-13 "Special Programs - Fire Protection Verification" were reviewed by the NRC team in connection with their inspections in this area. The following fire dampers were g inspected: h! GKFD-030 GKFD-163Q
. -041 -296 3l, -160Q -297 i ,
j b. Inspection Findings 9 f
, No discrepancies from design and specification requirements were
- observed during the inspection; however, a flow direction vane
' .i assembly was observed to have minor damage. Appropriate j documentation of this damage was prepared by DIC personnel.
';i The CSA e'ffort, as noted above, also did not include a sample of expansion anchor bolts in their inspections of HVAC hangers /
- supports. This prompced the NRC team to select a random sample 4
of 31 expansion anchor bolts for inspection and verification L of torque setting. Several discrepancies were observed and documented as a result of this effort. Specific details and I on this matter are contained in Section V of this report.
c. Conclusion
. The CSA effort in this area was found to be generally acceptable !- in terms of independence, scope, completeness, characterization I of the concerns identified and the conclusions reached. The ^c! generic concern (158) that stemmed from the'overall CSA evaluation , of specific findings was reviewed and the NRC team concludes
) that the proposed action plan is a reasonable method for resolving !i the stated concern (conflict or lack of unifonn inspection criteria).
C The CSA effort would have been more complete had it included a sample of fire dampers and expansion anchor bolts. While this ,
'~
does detract somewhat from the overall CSA effort in the HVAC area and limits their conclusions correspondingly, those areas
'} that were covered provide an additional seasure of assurance of the quality of construction.
I r IV-5 N Z E E 1 7 E'S f 7E7 % ~ W E W '7 ,1_ I C C..l_L i i __i,_ _
V. WELDING AND NONDESTRUCTIVE EXAMINATION (NDE) A. Ob.iective The objective of the special construction verification inspection (SCVI) was to assess the extent the Delian Corporation Construction Self Assessment (CSA) effort and followup corrective actions in the area of welding and NDE provide an additional measure of assurance of the quality of construction at Wolf Creek. B. Discussion The scope and description of the CSA effort in the area of welding for mechanical, electrical and structural activities and NDE are provided in the Delian CSA report. The more significant inspection findings are discussed on pages IV-4 and IV-5 of the report. Specific details pertaining to individual concerns resulting from the CSA effort, in this area, are contained in 44 separate concern packages retained by Delian at the Wolf Creek site. During the course of the NRC inspection all of the individual concern packages were examined to assess the nature of the concern, and the corrective action taken on tha action plan proposed to resolve the concern. The vendor data packages for supplier welds selected for examination during the inspection were acquired, after some delay, '. and reviewed prior to the actual inspection of welds. Interviews . and discussions were also conducted with Delian, KG&E and DIC
! personnel involved in the welding and NDE area as a part of this inspection. Factors considered were: independence of CSA, adequacy of tneir scope for the stated objectives, completeness, appropriate-ness of CSA identified deficiencies, their categorization and the conclusions reached in their report.
Specifics of the SCVI are provided below:
- 1. Structural Steel Welding
- a. Inspection Scope The SCVI team inspected weld connections CS1, C82, C83, C84, and C85. These welds were made by field welcing structural floor beams to embed plates above the Control Room per Bechtel drawing number 10466-C-121-1420-02 which is listed in Table V-4 of the Delian report.
- b. Inspection Findings The SCVI team was informed by KG&E during the entrance meeting that KG&E was performing a 100% reinspection of all structural welds as a result of the NRC Region IV finding that some structural welds were missing and various other welds did not meet requirements. The CSA of structural steel welds is covered in Sections IV and V of the Delian report. Structural welds in the Control, Auxiliary, and Reactor Buildings that were V-1
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visually inspected by the CSA are listed in Table V-4. The report also stated that "No hardware welding problems were noted in structural steel and electrical support areas." The SCVI team interviewed the CSA Civil / Structural discipline leader of Delian who indicated that structural welds were not physically reinspected. The discipline leader stated that "the structural welds were judged to be acceptable on the basis of visual observation and review of weld records only." It was also clarified that the review of existing DIC weld records was perfonned by the DIC member of the CSA team. . The SCVI inspection of a selected weld sample revealed that
, some of the inspected structural welds did not meet the Bechtel specifications. The weld deficiencies found were identified as weld underrun, undersized welds, lack of fusion between beads and excessive overlap. These welds were previously visually inspected and accepted by CSA.
- c. Conclusions l
The CSA effort was not effective in discovering the structural welding problems because the CSA inspectors did not physically inspect structural welds, therefore the objective of the CSA was not effectively implemented in this area. The CSA did not provide an additional measure of assurance of the quality of construction in this area.
- i l 2. Welding of Piping and Components i'
- a. Inspection Scope The CSA inspection of the welding of piping and components is covered in Section III of the Delian report. The CSA inspection resulted in 37 concerns based on visual inspection of piping and j component welds. The CSA team physically reinspected some of the a
welds on which the concerns were based. The SCVI team selected concern numbers 68, 69, 72, 119, 120 and 137 which involved vendor welds and reviewed the data packages in order to ioentify the acceptance criteria used for the physical inspection of the welds. The inspection in this area was delayed by the inability of the DIC contacts to supply vendor data packages. KG&E resolved this 'j problem by providing the data packages in response to requests by 71 the SCVI team leader. 4
- b. Inspection Findings i The CSA team has accepted the corrective action for 22 of the i 37 concerns. Nine of the remaining 15 concerns requiring
; corrective action were related to vendor welas.
I The SCVI te m inspection of the selected weld sample resulted l in the following observations:
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- Welds were inspected through paint without engineering evaluation of the acceptability of that method of inspection.
- The CSA inspectors did not use a written procedure or criteria for the inspection of vendor welds.
- The SCVI team inspection did not identify any significant deficiencies beyond those identified by the CSA effort.
However, the DIC personnel
- stated that "they were.not responsible for welds made by vendors", and in a number of cases expressed their view that CSA findings were not valid. The SCVI team questions the adequacy of imple-mentation of corrective action by DIC when DIC does not believe that they are responsible for corrective action,
- c. Conclusions The CSA effort in this area was found to be generally acceptable in terms of independence, scope, completeness, characterization of findings and the conclusions reached with the following excep-tions.
The reinspection of vendor welds in accordance with the criteria referenced on Bechtel purchase orders, not used in the CSA, is required to provide a basis for implementation of corrective
- action. This should follow the removal of paint from the vendor welds or an engineering evaluation on the acceptability of inspecting welds-through paint. This item remains unresolved.
KG&E needs to contractually delegate responsibility for the
. use of written procedures and criteria that would alleviate organizational disagreements concerning implementation of corrective action in accordance with the generally acceptable action plan for resolution of CSA generic concern 169. This item remains unresolved.
The CSA effort dio not provide an additional measure of assurance of quality in the area of vendor welds.
- 3. Welding of Piping and Components - Radiographic Inspection
[ a. Inspection Scope The scope of the CSA review of radiographic film for vendors is discussed on page IV-2 of the Delian report. The findings of the CSA effort for this area is given on pages IV-6 through IV-11. Table IV-6 lists film reviewed by the CSA. The objective of the radiographic inspection was to determine if the CSA effort was adequate in scope and implementation to be capable of determining if the work, both completed and in i progress, and quality control (QC) work related to welding and NDE activities, were and are, controlled and perfomed V-3
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i in accordance with design requirements and applicable codes and specifications. To accomplish the above objectives, the SCVI reviewed 703 radiographs, which cover approximately 377 feet of weld (32 welds made by 15 contractors and vendars). 148 of these films related to field welds completed on the site. The SCVI sample included NDE for welds performed by two onsite contractors (DIC and GEO Testing) and 12 of the 13 piping and
., component vendors in the CSA sample and of one vendor not in the CSA sample. Some of the SCVI sample was the same as the CSA sample while others as noted in b.(1), (2), (3), (8), (10) and (13) below were independent of the CSA sample review of NDE for welding.
Three quality control certification / qualification packages for
, QC inspectors were also reviewed.
L! i b. Inspection Findings (1) Daniel International Company (DIC) l The SCVI team _ reviewed 16 welds which were reviewed by , the CSA team and one that was not reviewed by Delian. This involved the review of 140 film covering 143 feet of piping - l or component welds for eleven systems. The CSA found no unresolved problems. SCVI examinations confirmed this finding. (2) Geo Construction Testing A total of 8 film, covering 4 feet of weld associated with the Feedwater System (AE) was reviewed. This item was not
, reviewed by CSA. No problems were identified as a result of this review.
J (3) DRAVO The SCVI team reviewed film for 5 welds which were reviewed 3 by CSA and 3 welds which were not revieweo by Delian. This
; effort involved the review of 36 film covering 30 feet of ; weld on the Main Steam System (AB) and Reactor Coolant i System (88).
No problems were found by CSA. The SCVI team noted 33
; film packages which had a different material thickness than those recorded on the reader sheets. In 31 film
,, packages, the thickness difference was 1/10 of an inch and in two packages the difference was 11/100 of an inch. In order to resolve this item, the applicant should detennine
.: the actual thickness of the weld and verify that the correct j' penetrameter was used based on the confinned thickness.
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(4) Sargent Industries /Airite Division This effort involved the review of 36 film covering 9 feet of weld on flued heads by both CSA and the SCVI team. CSA concern #64 - penetrameter material did not conform to the inspection report and the film showed poor radio-graphic technique and film scratches. Further investigation and review verified that a proper penny was used and that the film scratches were not indications.of bad welds but of poor film handling technique. The concern was resolved by CSA and KG&E and the SCVI team concurs. (5) Atlas This involved the review of 72 film covering 36 feet of weld on the Excess Let Down Heat Exchanger by both CSA and the SCVI team. No problems were found by CSA or the SCVI team. J (6) Pullman-Kellogg The SCVI team reviewed the film for six welds which were reviewed by CSA. This involved the. review of 48 film covering 15 feet of weld on the Feedwater System. No problems found by CSA or the SCVI team. - (7) Westinghouse The CSA team reviewed film from 17 welds. The SCVI team reviewed film for five welds which were reviewed by CSA. This involved review of 59 film covering 6 feet of weld on the Inlet Nozzle Safe End and Control Rod Housing. CSA concern #83 - the vendor's radiograph showed a linear indication about 7/8 inch long in an area where the maximum length would be 3/4 inch. This slag indication on closer examination proved to be two slag inclusions both of which are acceptable under the code. The SCVI team agrees with the second interpretation. The concern was resolved by CSA and KG&E. (8) Richmond Engineering Company (RECO) CSA reviewed film from 6 welds. The SCVI team reviewed the film for these six welds and 4 other welds, This involved the review of 38 film covering 50 feet of weld on the Let Down Heat Exchanger System and the Gas Accumulator. For CSA concern #94, the vendor's shooting sketch shows that a 22 inch diameter pipe was radiographed. The actual welds radiographed were 3.635 inches in diameter. In addition, film placement does not agree with sketch and lead I.D. markers were located within the area of interest. V-5 w - . - -,- ,, - n -- -
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'As a result of the CSA, all film in connection with the concern will be reexamined and film from other RECO contracts will be examined up to 100% depending on further findings.
l The SCVI team concurred with the film analysis and the recommendation for review of additional RECO contracts. (9) Applied Engineering Company l This involved review of 57 film covering 25 feet of weld on the Seal Water and the Let Down Reheat Exchangers by j both CSA and the SCVI team. CSA concerns #84 and #85 - Vendor films show indications
, of incomplete penetration, lack of fusion, undercut and unacceptable densities. The areas of concern were re-radio-graphed and the concerns were confirmed. An NCR is to be j written, a 100% review of this vendor's film is to be done and possibly the internals of the vessel concerned will be removed to allow further visual examination and possibly repai r.
The SCVI team agrees with the findings and with the indicated " additional review and corrective action. l (10) Struthers Wells This film review was by the SCVI team. CSA did no reviews of this vendor. This involved review of 9 film covering 16 feet of weld on Heat Exchangers. No problems found by these independent examinations. (11) Anchor / Darling Valve Company i The SCVI team reviewed film for 6 welds which were reviewed ]f by CSA. This involved review of 48 film covering 6 feet of weld on three 600# valve bodies. 2'
, CSA concern #66 - unacceptable film density in thin sections of the welds and in the penetrameter. Further review ; detennined that film densities were within code limits
[ and the concern was resolved by CSA and KG&E. The SCVI q team concurs with the final review results. (12)Walworth ( The SCVI team reviewed film for eight welds which were reviewed by CSA. This involved the review of 24 film
- 1 covering 13 feet of weld on 3 inch valve bodies. No problems were found by CSA or the SCVI team.
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(13)VelanValve The SCVI team reviewed film of 4 welds repairs, three of which were reviewed by CSA. This involved review of 42 film covering 3 feet of weld on 3 inch 900# valve bodies. No problems were found by CSA or the SCVI team. (14) G6W Energy (Taylor Forge) The SCVI team reviewed film for 6 welds which were reviewed by CSA. This involved review of 47 film covering 21 feet-
- of weld. No problems were found by CSA or the SCVI team.
(15) Chicago Bridge & Iron CSA reviewed film from 31 welds. The SCVI team did not - review any CBI film. CSA concern #65 - inspection showed no shooting procedure,
- , station markers distorted, incomplete fusion, and possible incomplete fusion (noted on the film as a surface condition).
4 Further review determined that the referenced procedure was a shooting procedure, film indications were surface conditions as noteo and the radiographs met ASME Section V requirements. The concern was resolved by CSA and KG&E (KG&E sign-off
; missing).
(16) Summary Review of CSA Concerns The CSA delineated 7 areas of concern in the NDE area of the welding /NDE discipline. Of these 7, 4 were resolved by further review of film and hardware by Delian and KG&E. These are concerns No. 64, No. 65, No. 66 and No. 83. For
; three concerns, No. 84, No. 85, and No. 94, the CSA team , required further investigation and/or documentation before a resolution can be acccmplished.
- c. Conclusions
, The CSA effort on film review was found to be generally acceptable s with respect to independence and scope for interpreting the .: film and instituting corrective acticn. In a few cases more
- effort to institute review of further samples when welding defects were detected would have been appropriate.
As a result of the independent SCVI team review of the Dravo film, 33 film packets were found to be marked with a material thickness different from that shown on the reader sheet. This item remains unresolved. j The SCVI found the CSA corrective action for CSA concerns i' #84, #85 and #94, including the resolution of CSA identified V-7
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-RECO and the 100% review of all other welding performed by those two suppliers, acceptable.
The CSA provided an additional measure of assurance of quality in the area of welding. J 4 9 'k 1 . 1 li ' ,i. 'ie i 4 3 s
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VI. REINFORCED CONCRETE AND STRUCTURAL STEEL A. Objective The objective of the special construction verification inspection (SCVI) was to assess the extent the Construction Self Assessment (CSA) effort and follow up corrective actions, in the areas of reinforced concrete and structural steel, provide an additional f measure of quality of construction at Wolf Creek Generating ' Station. j 1 B. Discussion The scope and description of the CSA civil and structural construction ; inspection effort are covered on pages V-1 through V-3 of their report and consist of two areas, namely, reinforced concrete and structural i steel construction. The CSA report had no significant findings for j review by the NRC inspection team. However, to assess the adequacy of
- the CSA conclusions, both areas of the CSA effort and report were i inspected by the SCVI team excluding structural welds which were '
covered by the Welding and NDE effort (Section V). In addition, the s SCVI team inspected concrete expansion anchor bolts for torque, ! embedment, concrete.spalling and bolt spacing. Interviews were conducted with cnsite CSA, KG&E and DIC personnel . , prior to, during, and after the SCVI team examinations. Other a factors considered for the CSA effort and report evaluation were: independency of the CSA effort; acequacy of the CSA scope.for the stated objective; appropriateness of CSA deficiency categorization; end the conclusion of their report.
- 1. Reinforced Concrete
, a. Inspection Scope $ The CSA report (pages V-4 and V-5) lists a total of 24 concrete pour packages examined by CSA. The CSA team assembled a file of the concrete placement documentation that they reviewed. The SCVI team inspected records of five in-place pours (0C241W20; OC361WO2; OC251S01; G:252501 and OC142WO6) and reviewed the
- associated documentation previously sampled by CSA. The five concrete placements consisted of three concrete placements in
, the Reactor Building and one each in the Auxiliary Building and Control Building. The SCVI team visually inspected the surface . of these five in-place concrete pours for cracks, misalignment, concrete reptirs an( installation of embeds. The SCVI team .
selected at randor.. from the five concrete placement packages, l nine inspectors who performed QC inspections to verify, though a review of the certified inspector computer listing, if they were certified in the duties that they performed. The SCVI team also reviewed the qualification records of five of the nine inspectors to determine if they were qualified to perform their duties. VI-1 9 e,-g* ,e w._ e-y
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The SCVI team reviewed the associated documentation of the concrete placements to determine the overall edequacy of the CSA review of DIC performance of the following:
- Concrete and Material Testing
- a. Laboratory
- b. Air, Slump, Temperature, Unit Weight & Cylinders
, c. Batch Adjustment Form
- Pre-Placement Inspection
- a. Reinforcement
- b. Cadwelding
- c. Embedments
- Placement Inspection In accordance with standards, specifications, and procedures. . - Post-Placement Inspection Curing The associated documentation was reviewed for conformance to * , the following procedures:
I 1
, QCP-IV-106, Rev.12, " Concrete Pre-Placement, Placement, and Post-Placement" QCP-IV-102, Rev. 7, " Mechanical Splicing of Rebar" QCP-IV-105, Rev. 4, " Concrete Batching, Mixing, and Delive ry" l
- b. Inspection Findings
, (1) CSA Report Review No concerns were identified by the walkdown and document review by the CSA inspectors regarding the concrete in-place ; or the documentation.
- The CSA inspector stated to the SCVI team that he did not j review any other documents, such as the Daily Cadweld Inspection Report, As-Built Caaweld Location Drawings, Cadweld Test Splice Results, Concrete Materials Test Results or any inspector's qualifications and certifications, to substantiate the acceptance by DIC of the different items on the Pre-Placement Checklist.
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O * (2) SCVI Sample The following observations were made regarding the documentation review and the concrete in-place inspection: (a) The SCVI team visually observed no cracks, misalignment, embedments or faulty concrete repairs during the inspection of the five in-place concrete pours selected. (b) Concrete and Material Testing requirements and frequency were found to be in accordance with approved procedures. (c) The review of the qualifications and certifications of DIC inspectors revealed that one Level I Batch Plant Inspector had signed off for the evaluation of batch tickets instead of the required Level II. This was found to be inconsistent with Table 1 " Minimum Levels of Capability for Project Functions" of ANSI N45.2.6 which states that only a Level II or Level III can evaluate the , validity and acceptability of inspection, examination, and testing results. A KG&E surveillance report (S-395) was presented to the SCVI team for the resolution. It investigated a similar problem in the electrical discipline only. Further action was not taken to consider adequately the civil discipline. Therefore, the surveillance report was considered insufficient for this issue. This item remained unresolved. (d) The KG&E response documentation to CSA concern #162 was under evaluation by CSA and remained open pending completion of CSA review and followup corrective action, if necessary. With respect to the reinforced concrete aspects of concern #162, KG&E was found to have an acceptable response based on the SCVI team's review of the KG&E documentation.
- c. Conclusion The SCVI team concludes that there was sufficient independence of the CSA effort, but that the depth of the CSA investigation was marginal. The one deficiency identified in the reinforced concrete area was brought to the attention of DIC and KG&E for adequate disposition.
The conclusion that the depth of the CSA investigation was marginal was based on the infortnation that the CSA inspector relied on the acceptance signature of the DIC inspector instead of substantiating the acceptance of the inspection item by review of suppcrting documentation. The CSA sample size of concrete placements was marginal because the total concrete volume of the selected placements appeared to be somewhat low. Based on the marginal depth of the CSA review of concrete pour documentation and marginal CSA sample size, the additional
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assurance provided by the CSA effort in this area was also marginal. However, the SCVI team's examinations conducted to assess the CSA effort, did not identify any significant _ deficiencies in concrete pour documentation that would indicate physical deficiencies in the concrete structures.
- 2. Structural Steel
- a. Inspection Scope The CSA report (pages V-7 to V-L') lists their structural steel inspection sample.
The SCVI team visually inspected the structural steel installa-tions associated with beam members: 362B1; 340B1; 391B3; 346B1; 33981 and 32481 previously sampled by CSA. The structural steel configurations listed above were at elevation 2068'-8". They were located in 3 different areas of the Reactor
.i Building. Pertinent documents were reviewed. Fireproofing of the structural steel hardware in the Auxiliary and Control ~
Buildings preempted a visual inspection by the SCVI team of CSA samples in those areas. The SCVI review of structural welding is addressed in Section V of this report.
- b. Inspection Findings .
,- (1) CSA Report Review
.} The CSA report concluded that the 54 structural steel members and 10 associated bolted and welded connections complied with the design drawings, installation drawings, and field installation procedures. The " Table of Resolution of CSA Concerns" listed three concerns (#1,
. 55, and 56) related to this area.
(2) SCVI Sample The SCVI team visually inspectea the sampled structural steel, listed in Part 2a above, installed by DIC and indicated to have been sampled by CSA. The assessment of the samples was based on the observations discussed below. An effective assessment of the CSA effort and basis for j CSA conclusions in this area was not possible due to lack .j _ of CSA retention of inspector's records or documentation i showing the visual inspections and document review stated 1 to have been performed. However, the NRC physical verifica-tion of a limited sample of structural steel configurations in the Reactor Building did not identify any deficiencies in design and found the hardware to be in accordance with the l' design drawings. There were three concerns (#1, 55, and 56) identified by the CSA effort. Concern #'s 1 and 56 were determined to be of no significance. 1, I % e VI-4 {.
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For concern #55 the original concern was that a non-safety relateo tubing support had been attached to a safety related I whip restraint and out-of-plane vibration of the whip l restraint would damage the tubing. This issue was ! considered minor to the SCVI team. However, the proposed 1 written resolution indicated that the whip restraint design did not include loading from the tubing support. This should have been done despite the small loads the tubing support may cause, and in addition, the as-built design drawing should have been reviewed to see if the location of the tubing support on the whip restraint is shown. The whip restraint also should have been checked to see if the location of the tubing interferes in any way in the intended design and with the functioning of the whip restraint. The SCVI team discussed this with appropriate CSA team members who indicated that the NRC question would be considered in the resolution of the concern. Subsequent review of this matter by SCVI resulted in another open question on the resolution of this CSA concern. The resolution also needs to address the DIC program for control, documentation and design review of such cases of " field routed" tubing or piping which is attached to safety related supports. This item is unresolved.
- c. Conclusion :
There appeared to be adequate independence of the CSA effort. With respect to the CSA scope, the depth of the inspection was only marginal . Three concerns were identified by the CSA team in the structural steel area. The level of seriousness for concern #'s 1 and 56 were appropriate. Concern #55 requires further study. It is concluded that the CSA effort, although lacking supporting records, does result in an additional measure of quality of construction at WCGS.
- 3. Concrete Expansion Anchor Bolts
- a. Inspection Scope The SCVI team inspected the concrete expansion anchor bolts
, for pipe supports and HVAC ouct hangers. This was done to provide added basis for evaluation of the CSA report on pipe
, supports and HVAC duct hangers. The hanger numbers identified with the pipe support related anchor bolts were: EJ03-R508; EJ03-R507; EG01-C012; AB01-R511; SJ01-C526; EJ04-H008; EM12-H005; and EM03-R020. The hanger numbers connected with the HVAC duct hanger anchor bolts were: C1460; 1541GK3410H1383; 11541GL0025NL192; 11541GF0010H1359; and 11541GF0530H1360. )
. A total of 63 anchor bolts were inspected for the pipe supports and HVAC duct hangers. For the pipe supports 12 anchor bolts were pre-selected and 20 were randomly chosen. These 32 anchor bolts were in either the Reactor or Auxiliary Buildings. There VI-5
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l were 31 anchor bolts randomly selected for the HVAC duct hangers and were located in either the Auxiliary or Control Buildings. The anchor bolts were inspected for conformance to the following j specifications and drawings: Bechtel Specification 10466-C-103A, Rev. 6, " Technical Specifications for Installation nf Concrete Expansion Anchor Bolts" Bechtel Drawing C-1003, Rev. O, " Structural Steel and i
, Concrete General Notes"
- Bechtel Drawing C-1037, Rev. O, " Standard Details Sheet No. 34" For a review of certifications of qualifications of the DIC QC inspectors assigned to the SCVI inspectors see Section
; VIII. , b. Inspection Findings l (1) CSA Report Review ; The inspection of surface mounted base plates and anchor bolts was not included in the scope of the CSA effort.
(2) SCVI Inspection Sample For the anchor bolts associated with the pipe supports, only one out of 32 turned. One of the nuts associated with hanger number EH12-H005 rotated about 1/8 of a full turn. This was considered an isolatec case and of no j significance. DIC QC inspectors present at the time of
; inspection generated the necessary follow-up documentation since the torque seal on the bolt was broken.
Of the 31 anchor bolts sampled for the HVAC auct hangers, a total of 6 nuts turned from 1/16 to one and a half full i rotations. Hanger number 11541GF0010H1359 had the only
, nut needing 1-1/2 turns before reaching the required torque.
Again DIC QC inspectors followed up with the required 4 documentation. For hanger number 11541GF0530H1360 the .j lower two anchor bolts were installed with a slope greater than 1 in 20 with respect to a plane perpendicular to the I surface of the bolted material. The DIC QC inspectors
- i- drafted the required documentation for the misaligned bolts and broken torque seals.
<, An observation by the SCVI of Material Traceability, a noticed questionable minimum embedment lengths with six of the twelve anchor bolts supporting safety injection
.; accumulator tank number TEP-01A in the Reactor Building.
1 Those six anchor bolts did not meet minimum embedment VI-6 , i I
.t.
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lengths required by Bechtel drawing #'s C-0X2902 and C-1C2411 and exceeded maximum tolerances by as much as 3/8". Bechtel Drawing C-1C2411, Revision 0, Detail 1 requires the projection length of concrete anchor bolts to be 7" above the underside of the top flange of the safety injection accumulator tank (#TEP-01A) base frane. According to DIC personnel present at the time of the SCVI, a 23/8" tolerance was allowed, permitting the projection length to be up to 7-3/8". Contrary to the above, six out of the twelve embedded concrete anchor bolts had projections above the top flange greater than 7-3/8. This item remained unresolved and requires an engineering evaluation report to determine if the design requirements are met by existing embedment lengths. Also, further action may be prudent to determine the scope of this problem. Another separate effort addressed in Section III of this report noted spalling of the concrete around an anchor bolt supporting a raceway unistrut. In summary, the SCVI samples were generally found to be in , accordance with the drawings and sr,ecifications. There were no significant deficiencies identified except for the - lack of anchor bolt embedment. Adequate measures in accordance with KG&E QA program requirements were being taken by appropriate personnel to aisposition the noted discrepancies.
- c. Conclusion As the CSA effort did not investigate the concrete expansion
, anchor bolts, no assessment of the CSA effort in this area was made.
The SCVI identified no significant fincings in this area, except for embedment of anchorage bolts, as discussed above. 4 4 VI-7
- .- .. . . - . , , . ~.m ,., 7.,
VII. MATERIAL TRACEABILITY AND MAINTENANCE A. Ob.iective i The objective of the special construction verification inspection (SCVI) was to assess the extent that the Construction Self Assessment (CSA) efforts in the area of material traceability and maintenance, provides an additional measure of assurance of the quality of construction for the Wolf Creek plant. B. Discussion The scope and description of the CSA coverage in the area of material traceability and maintenance are provided on pages VI-1 through VI-5 of the CSA report. The CSA material traceability and maintenance inspection team did not identify any concerns in either the material traceability or maintenance areas. Some material and traceability concerns, however, were identified by other CSA disciplines. In addition to reviewing the CSA report in its entirety to determine j the scope of examinations and findings regarding the material traceability and maintenance areas, each applicable individual concern package was reviewed to assess the nature of the concern, corrective action taken or the action plan proposed to resolve the concern. Interviews with key CSA, Daniel International Corporation (DIC), and Newport News Incorporated (NNI) personnel were conducted - i. to better assess the CSA effort. Throughout the NRC inspection, attention was given to general areas of the CSA such as independence, adequacy of inspection sccpe for stated objectives, completeness,
- 1. ' appropriateness of CSA identified deficiencies and their categori-zation, and of' conclusions reached.
[ NRC inspection samples were taken which included some CSA samples
. and similar types of items not inspected by the CSA team. This was done as an additional method of assessing the CSA report ana effort.
~
q
- 1. CSA Material Traceability Review
- a. Inspection Scope Each of the individual CSA discipline inspection scop'es and 3 ~
relevant CSA team inspection packages were reviewed for applicability to material traceability ana maintenance. The following CSA concerns resulting from the CSA effort in
, areas of the CSA report other than the material traceability i
section, but which involved material traceability, were reviewed to detemine their relative importance and the manner in which the concerns were to be resolved:
* #34; Mechanical, (Supports) Not to Tolerance, a Incorrect Material I.D.
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* #35; Electrical, MCC Bolting Not to Specs
* #53; Mechanical, (!&C Valve)
* #63; Mechanical, (Piping) Nuts Missing on Valve
* #86; Mechanical, (Piping) ECR Issued in Lieu NCR
* #91; Mechanical, (Piping) Missing Nuts on Valve
* #100; Mechanical, Maintenance Records Missing
* #102, 103 and 104; No Danger Signs, Exhaust Fan
* #115; Mechanical, Equipment, Bolts Missing on Valve Plates
* #123; Mechanical, (Supports) Code Data and a Documentation
's
* #130 and 131; Electrical, Bolting of Switchgear
* #144; Mechanical, (I&C) Missing / Loose Nuts on Terminal Box
* #148; Mechanical, (I&C) Missing Valve Handle, Missing .
; Clamp
.' * #155; Electrical, No Inspection Record of Battery Rack Fasteners, Nuts Missing from Battery Rack Assemblies
* #157; Supports, Minor Hardware / Documentation Problems
* #162; An Apparent Deficiency in Management Control of Vendor Activities. Inadequacies in Vendor Supplied Hardware and Documentation in Several Disciplines
* *164; A Generic Problem with Regard to the Fasteners (e.g., Nuts, Bolts, Washers) Used for On-Site Assembly and Installation of Electrical Equipment. Generic concern #164 (inclusive of specific concerns #35, 130, 131 and 155) was thoroughly investigated via records review and on-site inspection.
The SCVI inspection samples were selected from installed safety-related material and equipment. A total of 59 individual samples were examined to varying extent. Items included in the inspection were categorized into four general groups as indicated on Table VII-1 of this report. Acceptance criteria for material traceability used in conducting these inspections were:
- Section 17 of SNUPPS Preliminary Safety Analysis
- Report VII-2
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- DIC Procedure AP-VI-08, " Identification and Status of Material, Parts, and Components"
- DIC Procedure AP-VIII-03, " Identification, Marking and Inspection"
- b. Inspection Findings (1) CSA Report Review The general conclusion made by the CSA report regarding material traceability was that filler material and base 3' materials appear to meet applicable material specifications.
This is based on their review of Certified Material Test Reports (CMTRs). However, none of the material checked for traceability listed on Table VI-1 (Material Certification) of the CSA report can be directly traced to a specific installed component. The Objective and Discussion sections 1 of the CSA report (page VI-1) indicate that samples were to i be selected from field-installed components, however, this j relationship was not established. j Several QA items that were covered in other parts of the -
- CSA report should have addressed the Material Traceability ,
aspects of the problems. These included CSA concern numbers 34, 35, 53, 63, 86,.91, 115, 144, 148, 155, 162 - l and 164. Each of these concerns indicate some degree of a loss of material traceability and control.
! (2) NRC SCVI Sample . In general, the documentation and control of material traceability for the SCVI sample of piping and fittings, field and vendor weld joints, and equipment was acceptable.
However, deficiencies involving material traceability and control of fasteners were noted by CSA and the SCVI. 't These included:
- Motor Control Centers NG01A, NG01B, NG03C, NG03D and NG04C had cabinet to cabinet fasteners that were made of indeterminate material; were missing or improperly installed. The CSA inspection effort also included
! the Motor Control Centers, resulting in similar findings, e
~ however, the CSA report did not address the lack of traceability. Permanent markings on the fasteners are
- e required by the material specification.
- Battery rack NK12 had fastener assemblies that were
'4
- made of indeterminate material or were missing. The CSA inspection effort in other areas also included the
- battery racks resulting in similar findings. However, the CSA report did not address the lack of traceability.
- Two of four anchor bolts for main coolant pump support
- , (Lamco Industries #1533) were judged to be made of VII-3
l
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O O i indeterminate material since no traceability markings j were visible. Permanent markings are required by the j material specification. i
- Two of four anchor bolts for the "B" steam generator northeast support leg were judged to be made of l' indeterminate material since no traceability markings were visible. . Permanent markings are required by the i material specifications. '
- One of three anchor bolts for the "B" steam generator southeast support leg was judged to be made of indeterminate material since no traceability markings were visible. Permanent markings are required by the material specification.
- Safety Injection Accumulator Tanks TEP-01A and TEP-01B had anchor bolt nuts which were not in accordance with drawing requirements. Some anchor bolt assemblies had two heavy hex nuts installed while others had a single heavy hex nut and a jam nut. Detailed placement drawings for the accumulator tanks indicate a single heavy hex nut for embedded anchor bolts and double heavy hex nuts for -
through type anchor bolts. Deficiencies were also noted , involving placement of embedded anchor bolts for TEP-01A - while inspecting the anchor bolt assemblies for material
- traceability. See Section VI for further discussions concerning anchor bolt embedment concerns.
A review of the installation documentation by the NRC SCVI inspector' revealed no evidence of material verification during installation. All of the above deficiencies remain unresolved.
- c. Conclusions CMTRs reviewed by CSA meet the documentation data requirements in accordance with applicable material specification require-ments. The NRC-inspector believes the independence of the CSA material traceability inspection effort was acequate. However, the conclusions of the CSA material traceability section were incomplete in that the material traceability findings by other ;
CSA disciplines were not considered. The CSA effort does not l provide an additional measure of assurance of quality in this area. l , Based on the limited independent inspection scope accomplished l by the NRC, material traceability and control documentation, in ' general, was accurate and agreed with actual inspected hardware conditions except for the following*
- Review of safety-related hardware or equipment l revealed some material traceability and control concerns involving fasteners. Fastener assemblies were found missing or partially missing, indeter-VII-4
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minate bolting materials were installed or improperly installed and embedoed anchor bolt assemblies not installed per drawing requirements.
- 2. CSA Maintenance Review
- a. Inspection Scope A review of the CSA effort in the area of maintenance including personal interviews with CSA and NNI personnel -
a was conducted to detennine the scope of the examination and maintenance work accomplished by NNI.
- b. Inspection Findings Many CSA concerns were found to be maintenance related. For example, CSA concern numbers 2, 5, 6, 7, 11, 12, 15, 21, 23, 35, 36, 37, 38, 40, 41, 42, 46, 47, 49, 53, 61, 62, 63, 67, 70, 71, 91, 93, 96, 97, 102, 103, 104, 113, 115, 124, 134, 142, 144, 146, 147, 148, 155, 156 and 164 were all related to maintenance j to some degree.- The majority of these concerns involved broken,
; damaged, missing or loose component parts or basic cleanliness problems. Each item associated with the above concerns should have been maintained by either Daniel for items not yet turned over to KG&E or NNI for those items under KG&E cognizance.
Determination.of the base cause and corrective action for
- these deficiencies is an unresolved item.
The CSA effort did not include inspections into Daniel's preventive maintenance program for installed items or for the adequacy of DIC turnover reviews with respect to damaged items. Only those items / components / systems turned over to KG&E and subsequently contracted to NNI were covered by the CSA inspection.
- c. Conclusions The CSA effort in the area of maintenance was found to be generally acceptable in terms of independence. The inspection scope, however, was limited to a review of NNI and did not include an examination ano evaluation of DICs preventive-maintenance program. It appears that the maintenance effort i supplied by NNI was satisfactory based on the review of the CSA inspection.
Numerous maintenance related concerns reported by other CSA
; disciplines as noted in Section VII.B.2.b. above, were not ; addressed in the Maintenance Sections of the CSA report.
The number of these concerns indicate that the scope of the CSA effort for preventive maintenance should have addressed
- the reasons and implications of these concerns as associated with the DIC and NNI maintenance programs. The additional u measure of assurance of quality provided by this CSA effort
- is marginal.
- VII-5
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TABLE VII-1
SUMMARY
OF SAMPLES No. of Samples Piping Including Associ'ated Fittings 7.(L)* Field and Vendor Weld Joints 16 Equipment 8 Fasteners 28 (L) TOTAL 59
*(L) = Lots 9
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VIII. QUALITY CONTROL EFFECTIVENESS A. Ob.iective The objective of the special construction verification inspection (SCVI) in the area of QC effectiveness for qualification and per- l formance of QC inspectors was to determine the extent the CSA effort provides an additional measure of assurance of the quality of 1 construction. l i
, B. Discussion The scope and description of the CSA coverage in this area is provided on pages VII-1 through -3 and Table VII-1 of the CSA report. Primarily, the effort dealt with a confirmation of QC , inspector qualifications through record review and an assessment of QC inspector performance as detennined from the various 3
inspection findings.
! During the course of the SCVI in four areas of construction, samples i of QC inspector certifications were examined for conformance to established criteria and discussions were held with the QC inspectors ! in the various disciplines involved. These activities provided a '
I basis for assessing the CSA effort in terms of the stated objectives. . '; Specifics of the SCVI team observations in this area are provided -
; below. * $ 1. Mechanical Construction
.l
! The SCVI team reviewed the following documents in connection I with this area, a
j
- ANSI N45.2.6-1978, " Qualifications of Inspection,
; Examination and Testing Personnel for Nuclear 1 Power Plants" i
i
- DIC Procedure AP-VI-01 " Indoctrination Training and Certification of Quality Personnel" l The qualification records for eight Level II QC inspectors were 3 examined for conformance to the above criteria. Six quali-
' .? fications records were selected from Table VII-1 of the CSA j report. Disciplines involveo were Weld (Mechanical), Equipment 1 (Mechanical), NF (Mechanical), Piping, and Hangers. No j 1 discrepancies were observed. Discussions were held with DIC Quality Training personnel regarding the testing of inspectors for pipe supports / restraints, hangers and expansion anchor bolts. The current DIC data
, banks of test questions were examined for Hangers (mechanical) and a special set developed for anchor bolt inspections.
[ The NRC team found the questions to be comprehensive and to j reflect both technical depth and past experience. L VIII-1 i y y . . . . . ,; ., - , . . . , e . g.y n,n, a y, z , ry - -= * - - - - - -w- ? y G pr
During the SCVI the team members came in contact with several Dlc personnel that were presently engaged in quality inspection work or had been QC inspectors in the past and had advanced into a more senior position. They assisted the team in locatin some of the items being inspected, provided clarification on ' g inspection attributes as needed, assisted in providing quality i documentation on components under inspection and generally answered questions about their training, experience, inspection , and documentation practices. These contacts provided information I to help assess the effectiveness of the DIC QC performance. ' Overall the DIC personnel contacted appeared knowledgeable and . capable in their respective disciplines. With respect to the CSA conclusion (page VII-3) that a possible generic concern exists with regard to the completeness of QC inspection requirements (based upon several findings, some of which involved mechanical construction), the SCVI team reviewed concern 163 and the proposed action plan. The CSA concern appears to be valid and the CSA proposed resolution (pending adequate resolution of concerns 157, 162 and 164) is ;
- a reasonable course of action. l
- 2. Electrical and Instrumentation ,
4
~
The qualifications for one instrumentation inspector and . two electrical inspectors were. reviewed to the requirements - I of ANSI N45.2.6-1978 and were found to meet those requirements. One electrical inspector was interviewed and was knowledgeable of procedures and requirements. A program weakness identified I by the CSA report in one area (inspection of fasteners) was found to exist in several others. It was noted by the SCVI that the identification and documentation of inspection and acceptance criteria was not adequate in several cases. Although not identified by the CSA team, the QC program was also found , not to be effective in identifying repetitious minor hardware ' discrepancies identified by the SCVI in two areas (cable rollout and cable bend radius). These items are discussed in Section III of this report. o 3. Welding and NDE j ~ The NRC SCVI team reviewed certification and qualification files for 3 DIC quality control personnel. No discrepa.ncies were observed. During the NRC inspections the NRC team came in contact with
. personnel from KG&E, Bechtel and DIC engaged in quality i inspection work. They also assisted the team in locating l p items to be inspected, provided clarification on inspection ~
parameters as needed, provided quality documentation on piping and components under inspection and answered questions l about their training, experience, inspection and documenta- . tion practices. Overall, with one exception discussed in
, Section V.B.2.a of this report relative to the ability of the VIII-2
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assigned DIC contact in providing requested documentation, the personnel contacted appeared knowledgeable and capable in their respective disciplines.
, 4 Reinforced Concrete and Structural Steel The evaluation of QC effectiveness in this area was performed in connection with samples from concrete pour packages and concrete expansion anchor bolts. For the concrete pour .', packages the NRC team randomly checked nine inspectors to see .if they were certified in the duties they perfonned.
From those nine inspectors, five were reviewed to determine if they were qualified in accordance with the requirements of ANSI N45.2.6-1978. The NRC team found that generally the-qualification and certification records were adequate. During this review, the NRC team identified a Level I inspector perfonning the duties of a Level II inspector for the evaluation of batch tickets. This is discussed in further
', detail in Section VI of this report.
The qualification and certificatiod records of two inspectors 1
.'., for concrete expansion anchor bolts were reviewed. No discrepancies were observed.
C. Conclusions The CSA effort in the verification of QC inspector qualifications and assessment of QC inspector performance was found to be acceptable ~ in terms of independence, scope and completeness. The CSA findings
.were, for the most part, verified by .the NRC team's review. The conclusions reached by the CSA team with respect to the possible generic concern about the completeness of QC inspection requirements appears valid in view of the NRC team's independent findings. The proposed CSA action plan for generic concern 163, which bears upon this matter is reasonable.
The CSA effort in this area provides an additional measure of assurance of the quality of construction. 4 L a i 5 i l
- 1 1
1 l VIII-3 l
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IX. QUALITY ASSURANCE A. Ob.iective The objective of the special construction verification inspection (SCVI) in the area of quality assurance was to assess the extent to which the Construction Self Assessment (CSA) effort and followup corrective actions provide an additional measure of assurance of the quality of construction at the Wolf Creek Generating Station (WCGS). B. Discussion Section VIII of the CSA report was reviewed to asse:s the ;; ope of CSA inspections for the area of quality assurance (QA). These inspections covered: Kansas Gas and Electric (KG&E) QA effectiveness, KG&E audits, corrective action systems, and design change control. A sample of the CSA effort and findings for the area of KG&E audits and corrective action systems was selected for examination. As related to the SCVI sample, a review of CSA generic concerns 159, 160, 161 and 170 was also conducted. The generic concerns were reviewed for the scope of the concern and status of the Delian CSA-Phase II corrective action, and supporting KG&E or DIC documentation. Also, the involvement of KG&E in assuring that required corrective , actions are effectively implemented was reviewed. The review of the CSA QA finding for design change control, generic concern 166 (snubber - stroke problem), is covered in Section IV.B.1.b of this report. Other factors considered in the SCVI assessment of the CSA effort were: independence; adequacy of scope for the stated objective, completeness; appropriateness of CSA deficiency categorization as to level of seriousness; and the overall conclusions of the report and adequacy of corrective action. Discussions with onsite Delian, KG&E and contractor personnel and the results of the NRC SCVI were included in the overall evaluation of the CSA effort. Documents examined in the text which, in addition to specific documents referenced, proviae the basic acceptance criteria for the SCVI in the area of quality assurance, include:
- 10 CFR 50, Appendix B
!
- WCGS PSAR, Section 17, QA Program
- KG&E/Delian Contract and Letter Agreements
- KG&E QA Manual / Audit Procedures
- Delian Corporation Construction Self Assessment (CSA) Procedures, Rev. O, dated October 29, 1984 and Revision 1 dated November 1, 1984 and prior CSA Foms
.
- CSA Phase I documentation for selected samples / areas inspected
- CSA Phase II concern file folders IX-1 v ... - ,.., w g y.
v..,-,--.c. . -- -, - ----
- 1. Involvement of KG8E - CSA Phase II
- a. Inspection Scope The CSA Phase II effort for control and management of corrective actions and closure of CSA concerns was reviewed to assess
, KG8E involvement in assuring that activities associated with establishing and implementing corrective actions are effectively ,
implemented. l 1
. b. Inspection Findings
- 1 The SCVI review of CSA evaluations and corrective action plans for the 155 specific and 15 generic concerns confimed the quality-affecting nature of these activities and that adequate Y procedural controls subject to KG&E QA program surveillance were N required. SCVI observations of CSA corrective actions determined H that current Delian forms for documenting the CSA effort were
,! inadequate. There was insufficient assurance that CSA technical
' evaluations would be perfomed by individuals with required j- expertise and be adequately documented.
), During the SCVI, team observations also noted the general disagreement between DIC and CSA personnel on the various
- concerns identified by CSA as well as the proposed CSA action plans. SCVI team discussions in this regard resulted in the -
l3 question of whether DIC would be objective in implementing
- j CSA action plans for additional sampling of DIC work to determine
'l the scope of the CSA generic concern and required corrective ci- action. Based on these observations, a meeting was held by .. the SCVI team leader with the KG&E Director of Quality and the U, KG&E Superintendent, Quality System Engineering to obtain a 21 further clarification of the involvement of KG&E in ensuring >i ' effective implementation of CSA action plans and corrective action by DIC. "' A summary of NRC discussions with KG&E and the quality assurance commitments made for KG&E involvement in assuring effective t implementation of corrective actions for CSA concerns are () discussed in further detail in Section II of this report. q j c. Conclusions z.s
'1 . With the KG&E commitments noted in Section II of this report ? and the followup action by KG&E to ensure that all past and H current CSA Phase II activities will be performed in 3A accordance with the November 1, 1984 Delian CSA procedure, -
the KG&E involvement in assuring the effectiveness of CSA and DIC corrective actions is considered acceptable. C cy ,t - IX-2
' # ** 9"**** *? *'*'
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- 2. KG8E Audits
- a. Inspection Scope The KG&E construction audits discussed on page VIII-2 and Table VIII-1 of the CSA report and related CSA inspection findings in this area were selected for the SCVI sample. Specific discussions were conducted with the CSA team leader and KG&E personnel including: Manager, Quality Assurance; Superintendent, Quality Evaluations; and Supervisor of Audits.
Specific. documents reviewed during the SCVI of the CSA of KG&E audits include:
- QAP W18.1, Rev. 1, "WCGS Audit Scheduling and Surveillance Information Reporting" QAP W18.2, "WCGS Audit Procedure" 5
- QAP C16.1, " Corrective Action for QA Program Breakdowns"
- CSA Concern Closure and Corrective Action / Verification Forms for documentation of CSA Phase II actions, including:
- CSA Action Plan, Rev. O, dated 9/17/84
- CSA Action Plan, Rev. 1, dated 11/1/84 KG&E Corrective Action Documentation - CSA #159, including letter KQWLO84-126, W. Rudolph to F. Pimentel, dated 9/25/84
, Supplement to CSA Finding No. 159, no date
.l
- KG&E File No. TE:57061 audit reports for audit of DIC, including series nos.: K71, K106, K107, K109, K111, K112, K113.
- b. Inspection Findings (1) CSA Report Review The CSA review of KG&E audits was as represented by the CSA report. The CSA included a review of existing KG&E QA procedures for scheduling and conducting audits and records ,
; for audits conducted in 1984.
The SCVI review of KG&E audit plans and reports for audits of DIC generally confirmed the first CSA finding that KG&E audits are well planned, thorough (for planned scope) and consistent with good practice; i.e., with KG&E QA program for planning, conducting, reporting and documenting audits. t IX-3
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The CSA finding that Lead Auditor qualifications were acceptable was confirmed through the SCVI review of the above referenced 'K' series reports. The SCVI of audit reports and of dates the audits were conducted confirmed the CSA finding (generic concern #159) that certain KG&E construction audits scheduled for the first and second quarter of 1984 were not conducted. However, the SCVI noted differences in the count of audits not conducted as recorded on CSA foms a.nd the CSA report. NRC discussions with the KG&E Superintendent, Quality Evaluations resulted in a KG8E-prepared Supplement to CSA Finding #159 and the following clarification. The count for KG&E (TE:57061) construction audits of DIC not conducted as scheduled was changed to seven. This included 'K' audit Nos. K106, K109, Kill, K112, K113, K119 and K122. All seven of these audits were shown as rescheduled for completion during 1984. Also five of the seven rescheduled audits had been completed. The two (K119 and K122) not completed were both scheduled to be completed by 11/5/84. The above status for the seven audits was confirmed by the SCVI for the above referenced audit reports, except it was noted that audit K122 and the related report were completed
- on September 17, 1984. .
(2) CSA Phase II The status of the CSA corrective action effort at the end of the SCVI for CSA concern #159 was:
- Initial CSA Action Plan issued on 9/18/84 CSA review of KG&E response (KQWLO 84-126), noted by CSA as incomplete. CSA Rev. 1 Action Plan issued on 11/1/84.
The statements included in the current CSA action plan are: a " PROBLEM ST.\TEMENT: ? I "CSA notes that the KG&E response states that t'he '! root cause of the audit concern was a need to l reallocate four lead auditors to another program. The indicated corrective action is to subsequently (! . perform the audits not perfomed." [during1984]
- i "It is noted that this corrective action does not address how this problem will be prevented in the future for startup testing and operations audits.
9 IX-4
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o O "KG&E is requested to provide the following additional information:
" ACTION PLAN:
"1) The basis for audit schedules, (i.e., how the activities to be audited are defined and how the schedule is decided upon).
"2) The plan to insure that adequate resources are available to meet the schedule.
"3) The procedures, program requirements, etc.
which document the above basis and plan." The KG&E corrective action response and implementation appears to have adequately resolved the immediate concern and potential for a violation of KG&E's annual ANSI N45.2.12 audit comitments for audits of DIC. The CSA l concern that KG&E address how this problem will be prevented in the future for startup and operations audits is l. ll appropriate. 1 The SCVI noted that the findings of a rescheduled and l: conducted audit TE:57061-K111 did result in four Quality Program Violations (QPV) and two Quality Program Deviations *
- , (QPD). Also, the audit report stated that several findings of this audit had been identified by previous audit TE:57061-K52. The scopo of these audits pertained to implementation of the DIC Field Change Request (FCR) l portion of the design control program.
! As a result of the KG&E significance attached to QPV
- l. findings (QAP W18.2, paragraph 4.1), acceptable KG&E resolution of TE:57061-K111, Design Control audit findings is needed. This item remains unresolved.
- c. Conclusions (i
l' The CSA report effort 'e ie area of KG&E audits is generally P. considered acceptah'9 f t * :rms of independence, scope, complete-ness and charactui @ af concerns identified and conclusions !- reached. l- For CSA Phase II, the current CSA concern 159 action plan is L: considered an acceptable method of resolving the CSA concern and preventing recurrence of a similar problem during operations. The CSA evaluation of KG&E response to CSA concern 159 will also need to address and resolve the differences in the KG&E
- and CSA count of audits not conducted, includng any pertaining
+
to audit of construction L ,tivities other than performed by DIC. The CSA evaluation should also review the adequacy of KG&E's response on the impact of not conducting audit TE:57061-K111 on schedule has on the assurance of quality of construction prior to plant operation. IX-5 e n ., , v- . . .. . . - .
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Based on the NRC observations of the CSA effort in this area, an
-additional measure of assurance of the quality and effectiveness of the KG8E audit program was achieved. An additional measure of assurance of the quality of the DIC construction quality assurance program will be achieved with the effective imple-mentation of the CSA/KG&E Phase II followup corrective actions for CSA concern 159.
- 3. Corrective Action Systems
- a. Inspection Scope The CSA scope,-findings and conclusions in this area are discussed on pages VIII-2 through VIII-5 of the CSA report.
. The objective of the CSA review of certain corrective action systems was to determine if deficiencies were being properly identified and dispositioned. The CSA sample of corrective l action system documents as described in the CSA report included: ! 20-30 DIC Nonconfomance Reports (NCRs), several hundred DIC System Discrepancy Lists (SDLs), 20-30 DIC Notice of Discrepant Conditions (NDCs), 20-30 DIC Field Change Requests (FCP.s) and 20 KG&E Startup Field Reports (SFRs).
The scope of the SCVI in this area included: the CSA report , findings and conclusions, a sample of DIC and KG8E corrective
, action system documents reviewed by CSA, and followup corrective
- actions for CSA generic concerns 160, 161 and 170.
- b. Inspection Findings ,
o (1) CSA Report Review CSA findings of examples of improper use of corrective action system documents include: 2 NCRs, 2 SDLs, 5 NDCs i and 7 SFRs. No misuse of FCRs was noted in this sample or by the CSA review in the area of design change control (Tables VIII-2 and Table VIII-3), where 22 FCRs were reviewed to verify appropriate revisions to drawings. l l' CSA conclusions relative to the above findings are {
- sununarized in (a) and (b) and restated in (c) below
1 (a) The 2 NCR and 2 SDL examples of misuse were an , isolated case of generally acceptable DIC use of those systems. $ (b) The use of NDC's by DIC for closeout of NCR's at transfer of a system to KG&E should be reviewed and such use of NDCs should be controlled on a case by case basis. Further, DIC personnel should be informed that NDC's should not be used to close out NCRs for systems not transferred to KG&E and which are best a resolved by DIC. (c) "KGAE should insure that the SFR system is well under- i stood by those who use it. It may be advisable to IX-6
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- include more guidance in Administrative Procedure 14-402 regarding classification of the type of SFR, use-as-is disposition, purpose of the various signoffs, etc. Also, training could be provided for those using the SFR system. Since four out of the approximately 20 SFRs reviewed were not correctly classified as NCR type, it would be prudent to perform an audit of SFRs starting with the first ones issued to determine if this mistake is widespread. This is important since SFRs which are not processed as NCRs are not lifetime records and do not receive trending reviews."
The NRC review of the Executive Summary of the CSA report, noted that the CSA findings in this area were appropriately addressed. As a result of the CSA Phase I effort, it was noted that CSA generic concerns 160 for SFRs,161 for SDLs and 170 for NDCs were established for followup corrective action. The need for CSA generic concern 161 was not apparent at this time, based on the CSA report " isolated case" conclusion for SDLs. (2) CSA Phase II Corrective Actions - Generic Concern 160 CSA generic concern 160 was described as improper use - and processing of Startup Field Reports (SFRs). The concern was based on the seven CSA findings of misuse of SFRs. These included 4 SFRs not properly classified as an NCR,1 SFR not having Bechtel concurrence for use-as-is disposition and the review of 2 SFRs being performed by the originator of the SFR. In sumary, the conclusions of the CSA report in this area indicate that significant er rective action should be initiated, relative to proct Mal revision, training and the audit of all SFRs issueo to determine the magnitude of the problem with use of SFRs. Specific documents reviewed relative to CSA resolution of this concern are:
- CSA Corrective Action / Verification Form, including Action Plan, dated 9/18/84 CSA Concern Closure Form, with C5a Evaluation Acceptance and proposed CSA Action Plan, dated 10/31/84
- KG&E Correspondence, KQWLKWSU 84-164, W. J.
Rudolph to R. J. Glover, DIC, dated October 9, 1984,
Subject:
Corrective Action Request ).. (CAR) No. 18 i 6 IX-7
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- KG8E Correspondence, KQWLKQW 84-387, R. M.
Stambaugh/M. W. Shannon/C. A. Daley to C. G. Patrick, dated October 10, 1984,
Subject:
CAR No. 18-TE:50140-K003-Startup Field Reports
- KG&E Correspondence, KQWLK0W 84-407, C. G.
Patrick to R. M. Stambaugh, dated 10/24/84,
Subject:
Response to_ Quality Concern
- KG8E Correspondence, KQWLKSL(J S4-177, dated October 18, 1984,
Subject:
KG&E QA Audit
. Report TE:50140-K003 Startup Administrative Procedure, Startup
. Field Report, ADM 14-402, Revision 11, dated 3/21/84 and Revision 12, dated i 10/9/84 i
- Corrective Action Request (CAR) No. 18,
. dated 10/9/84 ,
1 7
- CSA package of SFRs A general sumary of parts of the information contained in the above referenced documents germane to the SCVI .
J; assessment in this area follows. iI The information on the CSA forms was found to include the CSA acceptance of the KG&E response including: CAR #18 on Nonconformance Control and Correction
- Work Hold Agreement #22 on Nonconforming
, Conditions.
The CSA evaluation remarks stated:
" Verification should include the following:
-" "1. KG&E Quality should have verified corrective action
? for CAR #18 and closed the CAR.
"2. A sample of several Non-Q SFR's should be reviewed
_! by CSA to confirm they are, in fact, Non-Q. 4
'I "3. A sample of several Q SFR's requiring work on a l hardware item should be reviewed by CSA to confirm !
that implementation documentation is identified i
/ in accordance with procedures. l - "4. KG&E Quality should have verified corrective actions called for in Work Hold Agreement #22.
IX-8 44 % **N IMI OY 5O' D'Dk k *I M & "* 4
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"S. Revisions to ADM 14-402 and ADM 14-407 to insure sufficient programmatic controls for nonconforming conditions should be verified.
"6. Documentation of 'nonconformance identification' and ' administrative procedure' training should be verified.
"7. Existence of an approved and controlled Q-list should be verified.
"8. Revisions to supporting ADM 14 series procedures related to the SFR and RIR programs should be verified."
In the October 9,1984 document KG&E directed that DIC take necessary remedial action under CAR #18. This document, in
; part, stated:
4 "The problem was initially identified while performing Audit TE:50140-K003 'Startup Field Reports' and resulted in Work Hold Agreement
#22."
The October 10, 1984 document was found to express the auditor's concerns on CAR #18 requirements. The October 24, - 1984 document provided the managers response to each of five auditor concerns. I The attachment to the October 18, 1984 document included audit report, TE:50140-K003. The scope of the audit was stated as follows:
"This audit was Londucted to evaluate the adequacy and effectiveness of the Stertup Program for processing of nonconforming and other conditions utilizing Startup Field Reports."
$ The findings of audit TE:50140-K003 include the following statement.
" Based on the auditor samples, it was i determineo that major discrepancies existed in the Startup Field Report Program, from both a program content and i;'
implementation aspect."
< The audit report lists three Quality Programs Violations (QPVs): 9/84-53, 9/84-69 and 10/84-1) and found additional noncompliances. The QPVs were noted as being contrary to 2 the requirements of FSAR, Section 17 and ADM 14-402.
The audit report, Section IV, Evaluation states: IX-9
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"The program for utilization of Startup Field Reports was found to be poorly defined, with significant discrepancies relative to implementation of program requirements. The extent and nature of the program and implementation deficiencies were such that compliance to the regulatory and standard requirements for identification, control, processing and closeout of nonconforming conditions was not being obtained. This lack of program control and noncompliances relative
~
to implementation of program requirements has caused extensive indeterminancies relative to hardware conditions resolved by the use of Startup Field Reports.
" Corrective action measures as specified by Work Hold Agreement #22, when fully implemented and complied with by the Startup organization,
- will provide an adequate program for the
- utilization of Startup Field Reports.
" Remedial actions as specified by CAR #18, when completed, will provide WCGS Management with a measure of assurance that previously processed and closed Startup Field Reports have been properly evaluated and closed in -
accordance with established requirements." , i
,; The audit report was signed by the Audit Team Leader i and participating auditor and initialed by the Auditor Supervisor, all dated 10/18/84.
In general, the SCVI found the CSA evaluation of KG&E
; response to CSA concern 160, and action plan relative to ! CAR #18 and Work Hold Agreement #22 as an adequate
- resolution. A SCVI general review of CAR #18 found it
] adequately represented audit TE:50140-K003 findings and the requested corrective action appeared complete, except j as discussed below.
, Corrective action required under CAR #18 should be clarified
, in the following areas. The guidance on discontinuing the
. review of a design error was found to be incomplete. The i guidance should be revised to ensure that appropriate j program requirements of design control are satisfied for each change in design. Additionally, where Reject Item
,j Reports (RIRs) are issued for SFRs without identifiable er retrievable documentation, all QA/QC documentation as dl.1 required to ensure the quality of the items should be
! established in accordance with applicable quality program a requirements and be subject to KG&E audit. Other methods used to verify the quality of work or an item should a
receive KG&E QA review and approval. Li i t IX-10
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The CSA' package of SFRs for the CSA sample was obtained from Delian. The SCVI review of the package found it contained 46 SFRs associated with 13 different safety systems. The CSA report did not list the CSA sample of 20 SFRs and therefore no direct review those SFRs could be performed. The CSA finding of failure to check NCR for three of the four CSA identified SFRs: 1-GN-14, 1-GM-12, and 1-HB-41 was confirmed. It was noted that fourth SFR 1-MA-42, was not, as appropriate, stamped "Q". SFRs 1-KA-56 and 1-KA-55 relating to the other CSA findings were not included in the CSA package and these findings could not be confimed. The SCVI review identified a number of other SFRs not checked as an NCR when required; 4 SFRs not initially checked NCR in block 6 were subse-quently checked NCR in block 17. There were also a number of "Q" SFRs not stamped "Q", as required. The above SCVI assessment generally confirms the CSA and KG&E audit findings in this area. Included in the CSA inspection sample was SFR 1-BB-147. This SFR was identified in block 6 and block 11 as a potential 10 CFR 50.55(e)/Part 21 but was not identified l as NCR type or addressed in the CSA report. It is readily I apparent from the description of the probable cause and the problem that the iaentified problem is subject to a 10 CFR 50.55(e)/Part 21 evaluation. The SFR identified the affected items as: Component DPBB01, A, B, C, and D, manufactured by Westinghouse for the Reactor Coolant System (BB). The initiated RIR described the problem as a broken
- high voltage termination lug at the surge suppressor on phase C. The apparent cause was that the component is made of cast brass and may have been overtightened. The SCVI in this area was performed after the onsite inspection and therefore no NRC review of the KG&E review of controls for lug terminations or evaluation for reportability was performed.
The review of KG&E evaluation of SFR 1-88-147 for reporta-bility to the NRC and of the related controls for the tightening of termination lugs during installation remains unresolved. (3) CSA Phase II Corrective Actions - Generic Concern 161 CSA generic concern 161 was described as SDLs not being properly utilized or dispositioned. i I Specific documents reviewed relative to the resolution of this concern include:
- CSA Corrective Action / Verification Form, Rev. O, 9/17/84, including the CSA finding and proposed CSA action plan.
IX-11
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CSA Concern Closure Form, with CSA Evaluation Acceptance, dated 10/15/84. DIC Response Report, dated 10/11/84. Stop Work Action No. G-003, dated 8/27/84. Corrective Action Report (CAR) No. 1-G0045,
; dated 8/27/84.
DIC Response Report, dateo 9/13/84. The review of the specific documents listed above found that generally acceptable CSA and DIC corrective action was established to resolve CSA concern 161. Confirmation of corrective action is currently pending CSA verification.
. It was noted in the Response Report, dated 10/11/84 that the problem with SDLs had been previously identified by M NRC audit 482/84-08. A review of the NRC transmittal
,l of report 482/84-08 to KG&E found that a Notice of Violation had been issued for two deviations from procedures for use of SDLs. (4) CSA Phase II Corrective Actions - Generic Concern 170 i CSA generic concern 170 was described as improper use
- I of the system (NDCs) for controlling nonconforming conditions for equipment turned over to KG&E.
Specific documents reviewed during the SCVI of this
. concern include:
- , CSA Corrective Action / Verification Fonn, dated
. 9/18/84, including the CSA finding and action i plans, Rev. O, dated 9/17/84 and Rev. 1, dated
'! 10/11/84.
- , KG8E letter, KQWLO 84-134, W. J. Rudolph to I i F. Pimentel,
Subject:
KG&E QA Response to I j CSA Finding 170. j ,$ KG&E Procedure for Control and Resolution of
- l' Discrepant Conditions Reports, ADM 14-416, Rev. O, dated 7/18/84.
.{ ] The current CSA action plan lists seven steps generally I directing that a major audit of a sufficient sample (95% level of confidence) of NDC's be conducted to examine j and clarify the scope of the problem. A note on the CSA action plan requests that " Final KG&E submittal, subsequent to CSA review, shall be submitted by KG&E QA utilizing appropriate QA vehicle (s) 1.e. CARS, NCRs, 10 CFR 50.55(e)." IX-12
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- The KG&E letter KQWLO 84-134 responding to the CSA action plan provides a report on the results of a 100% (not sample) review of all closed NDCs. The review is based on verification of compliance with the procedural requirements of ACM 14-416, Rev. O. The KG&E review of the number of NDCs for each discipline area included: Electrical - 31, Piping - 42 Hangers - 26, Mechanical - 5, Civil - 12, Welding - 3, for a total of 119 NDCs reviewed. Of the 119, tne KG&E review identified 43 NDCs with deficiencies, 40 of the 43 deficiencies were resolved leaving 3 of the 119 NDC deficiencies unresolved.
Based on the KG&E review and total number of deficiencies identified, it appears that some revision to procedure ADM 14-416, Rev. O. would be appropriate to clearly indicate criteria for the selection of "the appropriate resolution" document and to provide for a more timely issuance of these documents. Also, currently it is indetertninant whether the " lateness" in the issuance of - NCRs to correct a problem had any affect on compliance with certain requirements of NCR procedure AP-VI-02, i.e., for ASME system / components " prior to stamping" or "after stamping", under Section 3.30.1 and 3.30.2. Thus an audit - of a sample of the corrective action taken by these NCRs , appears appropriate. - The status of CSA concern 170 at the close of the SCVI was still pending completion of CSA's evaluation of KG&E's report response.
- c. Conclusions The CSA effort in this area was found to be generally acceptable
. in terms of independence, scope, completeness, characterization 3 of the concerns identified and conclusions reached. The one exception is that the CSA scope for review of FCRs is considered marginal based on the results of the KG&E audit TE:57062-K111 ciscussed in B.2.b.(2) above.
~
In general, the scope of current CSA Phase II corrective action plans for CSA generic concerns 160, 161 and 170 and corrective action discussed in referenced CARS or other documents are considered adequate for achieving the required corrective action, with the following clarification: (1) For CSA concern 160 and as discussed above, CAR #18 and the CSA concern 160 action plan should be revised to include additional clarification of intended corrective action requirements involving SFRs for resolution of " design errors" or without " identifiable or retrievable documentation". (2) For CSA concern 170 and document KQWLO 84-134 as discussed . above, appropriate revision of procedure ADM 14-416, Rev. 0 is required to prevent recurrence of deficiencies in the use of NDCs of the type discussed in the KG&E report. IX-13
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KG&E should audit a sample of NCRs issued late due to the , deficiencies in processing NDCs for compliance with procedure , AP-V1-02, Section 3.30 provisions for ASME systems / components l prior to and after N-stamping. Based on NRC observations of the CSA report effort in this , area, an additional measure of assurance of the quality of the corrective action system programs reviewed by CSA, except for SDLs, was achieved. Additionally, a significant additional , measure of assurance of the quality of construction will be - achieved with the effective' implementation of the CSA/KG8E Phase II followup corrective action for CSA concerns 160, 161, and 170.
- 4. KG&E 10 CFR 50.55(e) Evaluation f
- a. Inspection Scope .
KG&E TE:50140-K003 audit' findings of Quality Program Violations ! (QPV) in the area of Startup Field Reports were selected for -' SCVI review of KG&E evaluation for reportability of the
. identified QA program breakdown to the NRC. This area was 1 also selected to assess the adequacy of CSA Phase II followup a corrective actions. !
1 Specific documents reviewed during the SCVI in this area include: . 1 III. Project Policies, 17 Reporting Significant Deficiencies and Defects, Revision 1, dated 2/84 l KG&E QA Procedure, QAP 18.2, Revision 1, dated 10/10/84, Parts 7.4.2.D through 7.4.2.0 for
; action to be taken when there is identification 1 of a condition adverse to quality.
KG&E Correspondence, KQWLK0W 84-380, W. M. Lindsay to W. J. Rudolph, dated October 4, 1984, Subject, 50.55(e) for Startup Field Reports WCGS Request for Reportability Evaluation, by Auditors C. A. Daley/M. Shannon and Supervisor,
; R. M. Stambaugh, dated 9/18/84 Telephone Call Record, dated 10/4/84 from j H. Chernoff/W. Rudolph, M. Lindsay/C. Patrick /
i ' M. Shannon/C. Daley, KG&E to B. Taylor, NRC, Region IV File Note, by R. M. Stambaugh, dated 10/25/84, w/cc to M. Shannon and C. Daley, Subject, Telephone Call Record ; i IX-14
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- Interviews with KG8E Auditors (contractor),
M. Shannon and C. Daley and Supervisor R. M. Stambaugh
- General Discussions with KG&E QA Manager, WCGS
- List of KG&E auditor identified sample of types of deficiencies in hardware / design being resolved through use of SFRs
- b. Inspection Findings Based on the SCVI observations of the above referenced documents, interviews and discussions, the SCVI found that KG&E policy and procedural requirements applicable to KG&E QA program personnel (auditors and managers) for evaluation of a condition adverse to quality, as noted by ' audit report TE:50140-K003, were satisfied, to the extent that current information was available for evaluation.
It was noted that the auditors evaluation under the WCGS Request for Reportability Form, dated 9/18/84 found that two of the criteria required for reporting under 10 CFR 50.55(e) were satisfied (i.e., relative to (1) a deficiency, which were it to have remained uncorrected could have affected adversely *- the safety of operation of the nuclear power plant, and (2)
, a deficiency which represents a significant QA program breakdown). This input to the review process was then evaluated by the assigned QA organization Significant Deficiency Coordinator (SDC) who' determined that the auditor conclusions for item I had not been demonstrated and concluded based on information available that the matter was not reportable.
The KG&E QA Significant Deficiency Coordinator (SDC) indicated that the KG&E QA Manager (WCGS) agreed with his conclusion. The SDC also stated that he had not received any new information subsequent to his evaluation. Based on further discussions the SDC stated that he was aware of the list of typical SFR problem descriptions / discrepancies prepared by the auditing function of KG&E. Further, that until such time that it. is demonstrated that ioentified startup problems of the type on the reference list 4 (e.g., leak during calibration, running clearances out of tolerance, terminal blocks not installed per design, drawings do not reflect correct information) are deficiencies which, if not corrected, L could have affected adversely _ the safety of operations, the identified QA program breakdown is not viewed as reportable, or potentially reportable. The SDC also indicated that his respon-sibilities as the KG&E QA SDC did not require him to seek-out this information, i.e., the procedures in effect require that this information be brought to his attention. The SCVI immediate concern regarding KG&E's current position on the reportability of this item to the NRC was generally resolved upon being infomed by KG&E of the documentation of two telephone
^
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o s calls informing the NRC Region IV of the general problem with the SFR program and of the Work Hold #22. The first notification to NRC was on 10/4/84. The second notification was on 10/25/84, during the SCVI of this area. The second call resulted in KG&E licensing informing the NRC that the 10/4/84 telephone record statement that " hardware inspections are being conducted to determine if any nonconforming materials exist in the plant", as highlighted on the record, was an incorrect statement and needed to be corrected. i
- c. Conclusion
- Based on the above, KG&E should continue to review this matter for reportability to the NRC as new information becomes available on either the significance of the QA program breakdown or resulting hardware deficiencies.
The KG&E/CSA corrective actions should ensure that the KG&E ! program for identification and review of deficiencies for L reportability to the NRC is being implemented in a timely i manner for SFR or NCRs checked "potentially reportable"; and for deficiencies in construction which could have gone undetected due to the breakdown in the SFR QA program, as identified by the TE:50140-K003_ Design Control audit. ? s ? a 5 l 1 I IX-16 , t
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ATTACHMENT A PERSONS CONTACTED The following people were contacted by the NRC inspectors during the special construttion verification inspection. Kansas Gas and Electric Company R. Bird W. Lindsay H. Chernoff 0. Maynard C. Daley C. Parry
- 0. Dominguez C. Patrick P. Dyson E. Peterson D. Felix W. Rudolph G. Fouts M. Shannon R. Grant R. Stambaugh T. Halecki J. Wesbrooks G. Koester Daniel International Corporation _
D. Bach S. King J. Berra S. Koenig R. Booth H. Kubasek L. Boss V. McBride P. Early R. McCraney L. Easterwood R. McGriff l D. Garrett J. Maine R. Gesling G. New D. Gillespie L. Payne L. Gourley G. Riley P. Halstead B. Robinson J. Hanvey H. Shields J. Hightower L. Smith J. Hooks K. Steiner J. Lewis L. Weeks Delian Corporation S. Baron F. Pimentel B. Carter C. Thompson D. Leaver H. Wong i B. Palmer G. Young Bechtel K. Anderson ! J. Purdy ' J. Fletcher D. Quattrociocchi G. Hoffman G. Stanley W. Jenkins S. Wood C. Mathews AA-1 ' p..,.,
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Westinghouse Nuclear Operations Division L. Mosier R. Sunderland Newport News Incorporated G. Barber J. Lytle In addition to the above personnel, numerous other inspectors, engineers, and supervisory personnel were also contacted. i I i I 1 L I i i AA-2 1
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ATTACHMENT B GLOSSARY OF ABBREVIATIONS AE Architect Engineer ANSI American National Standards Institute ASME American Society of Mechanical Engineers AWS American Welding Society CAT Construction Appraisal Team CAR Corrective Action Request CBI Chicago Bridge and Iron CFR Code of Federal Regulations CMTR Certified Material Test Report CSA Construction Self Assessment by the Delian Corporation Delian Delian Corporation DIC Daniel International Corporation ECR Engineering Change Request FCR Field Change Request FSAR Final Safety Analysis Report HPSI High Pressure Safety Injection HVAC Heating, Ventilation, and Air Conditioning I&C Instrumentation and Control - IE Office of Inspection and Enforcement IEEE Institute of Electrical and Electronics Engineers KG&E Kansas Gas & Electric Company KCPL Kansas City Power and Light Company MCC Motor Control Center M0V Motor Operated Valve NCR Nonconformance Report NDC Notice of Discrepant Condition NDE Nondestructive Examination NRC Nuclear Regulatory Comission NNI Newport News Incorporated NOD Nuclear Operations Division NRC Nuclear Regulatory Commission PSAR Preliminary Safety Analysis Report Q Safety Related QA Quality Assurance QC Quality Control . QPV Quality Programs Violation I RCI Request for Clarification or Information REC 0 Richmond Engineering Company ,i RG Regulatory Guide RIR Reject Item Report SCVI Special Construction Verification Inspection by NRC SDC Significant Deficiency Coordinator SDL System Discrepancy List
, SFR Startup Field Report
- SNUPPS Standardized Nuclear Unit Power Plant System
~ WCGS Wolf Creek Generating Station WN00 Westinghouse Nuclear Operations Division AB-1 4
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ATTACHMENT C CSA STATUS SUWARY Case-Specific Concerns Amount and Date Code Code Description of Status l 10/26/84 10/30/84 .
- A No response received 2 1 B CSA is evaluating response 9 12 i
- C CSA requires further action /information 20 25 l D CSA accepts written response, pending 33 60 verification 1
i E CSA rejects verification 0 0 F CSA accepts verification - 2 14 G Closure by CSA Manager 0 0 ( Requires CSA administrative processing 89 43 T!i!i T!ili Generic Concerns Amount and Date Code Code Description of Status l 10/26/84 10/30/84 l l A CSA Action, Plan issued 4 4 B Corrective Action Complete (per written. 9 9 c
. response by actionee) p C Response determined incomplete by CSA 0 0 4
( D Response accepted by CSA 2 2 E CSA rejects verification 0 0 2 F CSA accepts verification 0 0 ' G Closure by CSA manager 0 'O T!i T!i e AC-1
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ATTACHMENT D STATUS OF CSA GENERIC CONCERNS (Per Table of Resolution of CSA Concerns) 10/25/84 11/01/84 Code Description CSA # Total CSA # Total A Action Plan Complete, CSA 156, 157 4 156, 157 4 Awaiting Complete Response 163, 169 163, 169 B Response Received, CSA 156, 159 9 158, 162 7 Evaluation in Process 160, 162 164, 166 164, 166 167, 168 167, 168 170 170 C Response Incomplete, per 0 159 1 .' CSA Review D CSA has Approved Response, 161, 165 2 160, 161 3 Closure Pending CSA 165 Verification
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.I j ' ATTACHt1ENT E TABl.E OF RESOLifflON OF CSA CONCERNS
.] ; CSA ke- it 11/01/34
~j CSA RESP. (A)
ITEM CONC. ORG. ITEN STATUS BY ACTION / RESP. REV/ CSA REP. DUE*DATE CIDSE Olff CSA
.].sMOSER DESCRIPTION NO. DISC. RESP. ORGANIZATION ACTION PLAN CSA STATUS CONC. REF. SCN./ACT. DOCUIENT VERIFICATisses
{;3 1 Structenral Steel, Hlasing I DIC Documentation None Required 0-F Yes V-3 CSA Coa-Documentation Located / Item Closed cern Form - Y]*: 1 V-Il 2 Electrical,, Rust on 2 DIC NCR PerpareJ/ None Required 0-D Yes Table NDC-E-0IF
- Conduit Item Closed i Il-2,16 Wit-I IO65-84
-S WM-10469-84
< 3 Electrical, Cable flin. 3 DIC NCH Prepared / None Required 0-D Yes II-I6 NCR-ISal-jj Separation Item Closed I 19317E
.+
4 ~
~
.- 4 Electrical, Conduit 4 DIC NUC Prepared / Required I-C No II-18 NDC-E-Olt Narking Item Open I (Voided Copy)
.J _... ._. . - .
', 5 Electrical, Fles Out 5 DIC NDC Prepared / None Required 0-D Yes Il-16 NDC-E-Ol0 j af Coodelet item CInsed I
- t 6 Electrical, Fles 6 DIC NDC Prepared / None Required 0-D Yes 11-16 NDC-E-026 Comaection Loose Ites Closed I CWP CS-39-E 7 Electrical, Fitting Loose 7 DIC NDC Prepared / None Required 0-D Yes II-16 NDC-E-013 Item Closed I hC
~
E Electrical, Conduit Bends 8 DIC Nemo Parpared/ Required No ll-2 Hemo of 7/3/84 Creater than 360* Item Open i II-16 , osa Record
~
~
9 Electrical, Nin. 9 DIC NDC Nrpareil/ None Required 0-D Yes 11-2 NDCI E-Ol5 Separation item Closed I II-16 1.) Electrical, Lack of 10 DIC Nemo Psepared/ None Required I-F Yes II-16 Nemo of 6/29/84 i Cable Fles Item open 2 + 10/c/34 on Necord II Electrical, Flex Il DIC NIM' Prepared / None Required 0-D Yes Il-16 NDC-E-Ol2 Connector Loose item Closed i
'" ' "- ~ - '
Key far (A) CSA Conc. = CSA Concurrence CSA St'4Tu s Codes'i '( A)'lio7e~sp~. received t i (1) Istated or Limited Frequenry (2) Potential Gesner as or Psogramats: CSA Concern (3) Generic or Programatic (B) Nequires CSA evaluation (C) Further s Yes, Indicates CSA's Concurrence with Response Provsded 1.y Close out Document act ioss/issf o required (D) Itesponse OK pesadesist No, Indicates that Additional Informatson or Artsons as kcagussed to Close Out the Concern veriistation (IC ) Neject versiscation
- l Rep. Ref. = Page Number in CSA Report Neference Coestern (F) Versticatson OK pending closure (G) Closed by CSA ANequires t Ag.y Adesseint rat ave Prorcuming on Closesre Fose
. .. . . w ... w. w - . .x- - . ~ - - ~ -
4 i i
; TABLE OF RESOLUTION OF CSA CONCERNS 'j Rev. 8 II/01/84 CSA CSA RESP. (A) 3 ITEM CONC. ORG. ITEM STATUS BY ACTION / RESP. REV/ CSA REP. DUE DATE CI.OSE OUT CSA IRaeER DESCRIPTION 10 0 . DISC. RESP. ORGANIZATION ACTION PIAN CSA STATUS CONC. REF. SCN./ACT. DOC 15ENT VERIFICATitNI .s
- j,s 12 Electrical, Missing Claap 12 DIC NDC Prepared / None Required 0-D Yes II-21 NDC-E-Olt on Support Ites Closed I y 13 ' Welding, (Piping) Weld Paper 13 DIC Memo Prepared / None Required 0-D Yes Ill-20 Memo 7/5/84 a Mot Stamped Correctly Ites Closed I on Record I4 Welding, (Piping) Weld Loca- 14 DIC Memo Prepared / Required 0-C No III-20 Memo F/5/84
~'
tion mot shown os B/P Item Open I on Record 15 Mechanical, (Piping) 15 a)KCE Item Open a) Required a)A a)N/A III-20 Memo F/5/84 c) Valves Istt Open b)DIC Memo Prepared / b)None Required b)O-D b)Yes on Record 1,3 b) Ifuts Not Fully Engaged Item Closed 2
- )
NIJ Mechanical (Piping) NDE I6 DIC NCR + Mears Prepared / None Required I-D Yes III-20 Menos 1/12/84
~ ~ ~ ; Indicattoe not Addressed Item Closed I on Record .] NCR ISN-12-132PW t
,117 Mechanical (Supports) 17 DIC SDL Prepared / Mone Required 0-D Yes III-31 SDL-AE-237
,4 Traveler B.O.M. Not Correct Item closed I 1
IS
~~
- ' IS Mechanical, (Supports) DIC NCR Prepared / Mone Required 0-F Yes III-4 ISN-1923EN ci Not to Tolerance Item Closed (See Item 157) I III-35 I . j 19 Mechanical (Supports) 19 DIC NCR Prepared / Mone Required 0-F Yes Ill-31 ISN-192 FIN
, Obstruction Ites Closed I
} 20 Mechanical (Supports) 20 DIC Itee Resolved on CSA None Required
- Yes III-31 CSA Form i No QC Verification Noted Form / Item Closed I
.21 Electrical, Pull Box 21 DIC Memo Prepared / None Required I-F Yes II-16 Menu 6/30/84 Cover act Installed Item Closed 2 on Nerord WA-NC-300-09 QNC 8324
~
12 Electrical, Cables not 22 DIC Memo P r ep3 r~c~d/ None Required 1-F Yes II-16 "Meeul[3I/84 Tied Down Itce Closed I on Netoed I E-UloI3 E-INN 900 , AE-2
V
- . . ;_ . . .s . , . .~...:..s....
e D I TAHl.E OF RESOLUTION OF CSA CONCERNS 2 Rev. 8 II/05/84
'?.
'CSA CSA RESP. (A)
ITan CONC. orc. ITEM STATUS BY ACTION / RESP. REV/ CSA REP. DUE DATE CIASE OUT CSA DESCRIPTION No. DISC. RESP. UltGANIZATION ACTION Pl.AN CSA STATUS CollC. REF. SCN.]ACT. DOClNEllT VERIFICATiest t MAGER
) DIC Required 0-C No 15-17 Inspect Report
.,e 23 Electrical, Fles 23 Inspertion Report i$ Comaector Loose Verified / Item open 1 7/3/84 on Record
~
~
24 DIC NCR Ecp~ared/ Mone Required 0-D Yes Il-2 ISN-19274E 24 Electrical, liaistrut Wall Spread Ites Closed (See 165 Also) 1 Il-17 j,:q _ . _ . Le 0-D Yes II-2 ISN-19320E q 25 Electrical. Washer 25 DIC NDC Prepared / None Required Item Closed i 11-17 NUC E-Ol4 y'j Rotated os liaistrut
~~
26 DIC WDC Prepared / None Required 0-D Yes II-17 NDC-E-016 26 Electrical, Galvaatze I WR 10757-84 y 2 cff Condisit ites Closed NCH Prepared / None Required 0-D Yes II-3 ISN-19312E c.c.; 27 Electrical Tray Support 27 Dlc Il-17 (.J act Secured Properly Item Clased 1 4
- 28 Electrical Ito Fire 28 DIC Memo Prepared / Mone itequire. I 0-D Yes II-IF Memo 7/5/84 Ites Closed I on Record l Barrier 1
j _ _ . NDC Prepared / 0-D Yes II-17 NDC-E-027 i 29 Electrical, Cable Tray 29 DIC None Required I
?j Penetration Barrier Item Closed 30 DIC Memo Preparc.1/ Required 0-C No 11-37 Memo 7/6/84 on 30 Electrical, Floor Penetra- Nerord, tion not as Required item Open I jj Breach of Sea!
. . 'a Notifiration DIC Memo Psepared/ None Required 1-F Yes II-3 Memo 7/5/84
. 31 Electrical, Missing 31 on Necord 11-17
t
] Cable Softener Item closed 1 WA-RC-300-01 QCIC WA-NC-300-08 5 E-0103 32 DEC Memo Prepared / None Required I-F Yes 11-3 Memo 7/2/84 3 32 Electrical, Fire Barrier oss aterord E-IS000 item Closed i 11-17
. Full E-IM8900 33 DIC a)NCR Prepared / Required a)l-B* a)No Ill-5 allSN-89217NW
_ ,; 33 Nechasical, (Supports) I FCR l-0ISI-N lasufficient Weld Lenstle Item Open (See Itee 157) b)O-D Ill-31 le)NCH Prepare.f/ b)Ves Nesponse to CSA 1578
. le.m t' Bused i I.)NCR ISN192771Rt Ar-3
. . . . a. ~. ~ ~
d A 21 s TABLE OF RESOLUTION OF CSA CONCERNS Rev. 8 II/01/84 CSA RESP. (A) ITEN CONC. ORG. ITEtt STATUS BY ACTION / MSMER RESP. REV/ CSA kEP. DUL DATE CLOSE OUT CSA
- DESCRIPTION NO. DISC. RESP. ORCANIZATION ACTION PIAN CSA STATUS CONC. REF. SCN. /A_ CT. DOctaENT VERIFlt'ATitNe
,', 34 Nechanical, (Supports) 34 DIC NCR Prepared / *
,None Required Yes Ill-38 ISN-192SSNW y Not to Tolerance Items Closed i y Incorrect Material I.D. SDL-AB-I-075 d 35 Electrical, NCC Solting 35 DIC NDC Prepared / None Required I-D Yes II-6 RCI-8352E and
~
gj mot to Spec's. Item Open (See Item 164) 3 II-17 NDC-E-048 NCR ISN2068IE
} NCR ISN20682E 4 36 Electrical, Boa not 36 DIC TOE Prepared / Required 0-C No 11-17
~ '
j Properly Secured TOE 123 & Item Open I I24
';37 f Electrical, Broken Fles 37 DIC NRC Prepared / None Required 0-D Yes 11-17 ISN-193II-E ;, in Conduit Ites Closed I j 38 Electrical, Flex Loose 34 DIC NRC Prepared / Mone Required 0-D Yes 11-18 INN-19332E Item Closed 3 ".A 39 Electrical, Lack of Edge 39 DIC NDC Prepared / None Required 0-D Yes 11-18~ N'DC-E-021 ai Softener ce Cable , Ites Closed (See Ites 170) I
'.h
- 40 Electrical, Broken Fles 40 DIC NDC Prepared / Wone Required 0-D Yes 11-18 ISN-89310-E
*j Ites Closed I .
01 Piping, Flange Bolts not 41 DIC Memo Prepared / None Required 0-D Yes Fully Engaged III-20 Memo 7/5/84
, Item Closed I 's J42 Nechanical, Snubber (Support) 42 DIC Ites ResolS d on None Required
- Yes III-32 CSA Form
-1 not Completely tirapped CSA Fore /Iten I
}
Closed
'43 Nechanical, (Supports)
~
43 DIC Item RcsIIve.1 by None Required 0-D Yes III-31 NCI-T~00i4N
~
Operational Interference RCI/ Item Closed I
,44 Nechanical (Piping) 44 DIC Item Resolved by None Required I-D Yes til-32 CSA Form +
Clearance Between Valve CSA Form / Item I Memo Nandle open 10-20-84 AE-4 O
. .-. . . . .>. . . ~ . . . . . . . . . . . . . .
u 4 4 J ! f 9 h i' TABl.E OF RESOLUTION OF CSA CONCERNS
.' Rev. 8 11/01/84 CSA
[]
~d CSA RESP. (A)
ITEM CONC. ORG. ITEN STATUS BY ACTION / NESP. REV/ CSA REP. DUE DATE Cl.OSE Otfr CSA I IR8SER DESCRIPTION NO. DISC. RESP.,(*GANIZATION ACTION Pl.AN CSA STATUS CONC. REF. SCH./ACT. DOCINENT VEllIFICATityl d 45 Mechanical (Supports) 45 DIC NDC Prepared / .None Required
- Yes III-32 ISN-1953811
;d Snubber laterference
'. Item closed I
- . 46 ~ Electrical, Missing Bolts 46 DIC NDC Prepared / None Required 0-D Yes
~
M II-19 NDC-E-023 on Cover Ites Closed I
; 47 Electrical, Missing Bolts 47 DIC NDC Prepared / None Required 0-D Yes 11-19 % NDC-E-022 on Cover Ites Closed I l]48 l Mechanical. (Supports)
Konger Clearance 48 DIC Item Relalved on None Required 0-D Yes III-33 CSA Fore
~
CSA Fose/ Item I
;} Closed j 49 Electrical, Fles Connector 49 DIC NDC Prep.ared/ None Required 0-D Yes II-18 ISN-19313E i Loose Item Closed I HMe ie rpEl7 50 Nechanical, (Piping) 50 DIC None Required ~ '
[f 0-D Yes Ill-20 Nel 7/94/84 Grind Spot Item Closed I on Record QSR Sk-1093-M UT-2486
- 4
..i 51 Electrical 51 DIC Item Resolved None Requsred 0-D Yes 11-19 NA-RC-242-94
; tissing Strap for Unistrut on CSA Form I , Memo 7/3/84 52 Electrical, 52 DIC Item Resolve.I un None Required 0-D Yes 11-19 RA-NC-242-95
.I IInistrut Strap not CSA Form / Item (See item 165) 3 Memo 7/1/84 "I Engaged Close.1 QNC 682BIJ
$ W q 53 Merhanical, (I&C valve) 53 DIC it em Resolve.1 ley a)None Required a)O-D a)Yes III-20 Memo 7/5/84 &
. e) Incorrect Washers Installed Mesme & Special Instruc- I 7/17/84 i b) Incomplete ThreaJ Engagement tion / lice Closed b)None Required b)l-D b)Yes Ill-20 Work Pks Indes 385 I SIS IN03EPO6(Q)02 Sper. M204, p.8 WP-Vil R. 19, p . 25_
54 Nechanical, (Supports) 54 DIC Item Resolved by No At-tion Plan 54 I-C III-20 Memo 7/10/84 Temporary Clamp Nemun/ I t em thwn 3 55 Mechanical, (Wtiip Restran.t 55 KC&E Item Resolved oen Required 0-C No V-1 4:SA Form
, and TuSing Support-CiviI/ Dir r...io.m/giem open i St ru t ral) CIcaraus e p
, _y, s,
f e 4 TABLE OF RESOLtTTION OF CSA CONCERNS j Nev. 8 11/01/84 CSA CSA ItESP. ( A') j ITEM CONC. ORG. ITEtt STATUS BY ACTION / NESP. REV/ CSA REP. DUE DATE CLOSE OUT 4 m DESCRIPTIOll 10 0 . DISC. NESP. ORGANIZATION ACTION PIJul CSA STATUS CONC. kEF. SCH./ACT. 00CIDElfT CSA WERIFICATitNI 1
- 56 llechanical (lanip Restraint- 56 DIC Item Resolved by None Required 0-F Yes V-3 FCN-t-1401C,
,s Civil / Structural) FCR/ Item Closed i Item 6 4 )57.
?
Mechanical, (supports) Operational Interference 57 DIC Item licsolved on ~None Required 0-F Ye's III-31 CSA Form CSA Form / Item I SDL AE-243 Closed
' 58 leechaatcal (Supports) 58 DIC
~
SDI. Prcpased/ Nos.e Required 0-F Yes III-38 SDL-EG-8 7 8 Bushing not Properly Item closed I '-{ Staked
~
59 Electrical,Ito I.D. 59 DIC Item Resolved on Required 0-C No 11-18 CSA Fore Q Markers em MCC CSA Foam / Item I '- Memo 7/20/84 Open DWG E-IlllG20/Rt 6e Electrical, Fles not 60 DIC NIF P% ased/ Required 0-C No Il-18
~
NUC-E-035 Properly Separated item Open I QltC 101351 61 llechanical, (Piping) 65 a)DIC NCH Psepared/ None itequered a)O-D Yes Ill-20 a) NCR ISN-87199E
; c) Loose Belts on Valve Item closed I Memo 7/II&l0/8/84 on late j b) No latite I.D. Tag b)DIC b) lien closed b)0-F Yes b) Memo 9/4/84 on tale
- I
- j. 62 Mechanical (Piping) 62 DIC NDC Prepascel/ None Required a)O-D Yes ill-21 a) NCR ISN-87199E 1 c) Bolts Loose on Valve Isra Close.1 1 Memo 7/Il&l0/8/84 on tele b) No lAkite I.D. Tag b)0-F l1 Yes b) Memo 9/4/84 on file j I e
- C3 Mechanical, (Piping) 63 DIC NDC Psepared/ Nonc itequired 0-D Yes III-21 NOC-P-027 Nuts Missing on Valve Item CInsed I
, 64 IIDE, (R.T.) Film Quality 64 KC&E Iten kesolved on None Required 0-F Yes IV-18 CSA Form VENDON CSA Fusm/I em I Close.1 65 NDE, (R.T.) Film and 65 KGEE lies'liesol vMa~ ~~None Required 0-F Yes IV-19 ~CSA E m
~
Wld Quality VENIN
- CSA Foam /tten I Closed AE-6
-~ ~ - _ . -.-e% - m -
. . . . a a a .u _< .. . .- . ..--- * * ~' ' -
~
l i i
- P TABl.E OF resol.UTION OF CSA COIICERNS i New. 8 II/Ol/84 CSA
; CSA RESP. ,'; ITEM * (A)
COIIC. OkG. ITtH STATUS SY ACTIOti/ RESP. REV/ CSA REP. DUE DATE CLOSE OUT CSA
] amasmen DESCRIPTIOsl 10 0 . DISC. RESP. ORCANIZATION ACTION PIJul CSA STATUS CoelC. REF. SCN./ACT. DocimENT VERIFICATIfC
.2
- 66 IIDE, (R.T.) Film Qisality 66 EGE Itco Resolved on None Required 0-F Yes IV-18 fj CSA Fosm/Itee Closed i CSA Fore 1
+ 3 C7
- Electrical, Fles 67 DIC NDC Ple'pi~rE / None Required 0-D Yes II-89 ISN-19359E y Dascomaected Item Closed I g
+
Q 64 WIding, (Pipang) 68 KG&E NDC Prepared /
] Surface Defects VENDOR Item Closed None Required (See Item 169) 0 hD Yes 3
III-28 ISN-19513 MW Memo 7/9 & 7/96/84
.g on record 69 tielding (Piping) 69 KGEE Memo Prepared / Required I-C No III-25 Memo 7/9/84
+] Surface Defecta VElsDOR Itco Open (See Itee 169) 3 on Record 4 ~ A 70 tielding, (Piping) 70 DIC Memo 5repared/ None Required 0-D Yes III-23 Meen 7/16/84,
.i Rest es Stataless Itco Closed I on Record 3
.) QSR 1094-M 71 Mechanical. (Piping) FI DIC NDC' Pr epa 7eill. None Requared *
~~
- Yes Ill-28 NDC-P026 Valve Eeaking Itce Closed I
! 72 tieldisg, (Paping) 72 KG&E a)tsceo Psepased/ Required a)D-C a)No III-21 j a)Crisding Marks b) nield .s) Memo 7/16/84 on resor.1 VENDolt item open (See Itco 169) b)0-C 3 QSR SR 1090M Relaforcseest b) Memo Prepared /
,j b)No 3
' ,. b) Memo 7/6/84 on recond ltre Open 3 3
~
1 73 tielding, (Piping) 73 KG&E NDE Ps'rphrM / None Required I-D Yes III-22 ISN-19494MW
'~'
(j landercut VENDOR Itce Opeu 3
-1 __ _ _ - _ -e 74 Meckaatcal (Piping) 74 DIC Memo Psepared/ None Required
- Yes
' Ill-22 Memo 7/10/84 Hold Tag Item Closed I oss Record
=
~
; 75 Mechanical (Equipeemt) 75 DIC NE'R l5cp.sNe'l/ None Required
- Yes III-22 ISNTI9T36MW
_q Gouges and Arc Strakes Itce Close.1 1
.: 76F Electrical, 76P DIC Memo Prepared / None Required 0-F Yes Il-19 f.et t e r Conduit laterference Itco Closed .} I 82/10/82, -4 On Record RCI l-0205-E 765 Mech nical, (Supports) 76H DIC SIlf. Perpared/
- Yes P%ne Peeluared lit-le Sul.-EG-879 Aagwi e r i t y , ( I nse.1 I
AE-7 . . .
m - . -. 1 s TABLE OF RESOLitrION OF CSA CONCERNS
' Rev. S 11/01/84 CSA
.; CSA RESP. (A)
.* ITRN CONC. tJtG. ITEPI STATUS SY ACTION / RESP. REV/ CSA REP. DUE DATE CIASE OllT CSA M BESCRIPTIOtt NO. DISC. RESP. ORGANIZATION ACTIod PLAN CSA STATUS CONC. REF. SCN./ACT. DOCINENT WERIFit ATitIII '
)77 Nechanical. (Supports) 77 DIC Resolution on CSA See Action Plan 77 l-B No III-5 CSA Fore /DIC 1998 i Special Scape fffDel's Fors/ Item Open 3 Ill-33 dated 9/26/84 O
Typed pg "CSA ??" i
- - dated 10/9/84 78 Nechanical. (Supports) 78 DIC/ RCI' Prepared / None Required
- Yes Ill-38 BCI-3-0012N
'~
l Coeflict la Drawings BECNTEL Item Closed 1 1
] 79 flechanical (Supports) 79 a)BPC (a) MCle Prepared / Required a)O-C (a)Mo Ill-5 (allSN-1935681 3,a (a) Caaflict in Drawings Item Open I (b) Undersize Vendor ndeld b)DIC (bl SIIL Prepared / (See Item 168) b)o-D (b)Yes III-31 (b)SDL-EG-SSO I
i Item Closed (See Also Item 157) I to SS flechanical. (Supports) 80 DIC SDL Psepared/ Item Required 0-C No III-31 SDL-EG-SSI B.O.M. Errar Open I
~ ~
; SI Ill-5 '
~
flechaaical. (Supports) St DIC/ RCI' Prepared / None Required
- Yes RCI-I-0013N
, Poseable Clamp Rotation BECNTEL Item Closed 1 III-32
$ S2 SDI~ Pr7pa~r d/
Necheatcal, (Supports) 82 DIC None Required
- Yes III-3T ~ ~ SDL-AB-t-234 Cotter Pia Ites Clemed 3
~'
- 83 IDE, (R.T.) Sla8 83 DIC ReToE c.I on CSA None Required 0-D Yes IV-9 , CSA Form
, Indications , Form / Item closed 3
! , S4 ISE, (R.T.) nield 84 KG&E/ Item Open Action Plan 84 0-C No IV-10 CSA Fore Quality Applied 3 IV-21 SAP EG 1993 Eng. i
- 85 ISE, (R.T.) Film 85 KC&E/ I t em Oswn Action Plan 85 0-C No IV-10 CSA Form
- Density Applied 3 IV-21 QSR-Sit- IO95-M Eng.
86 Nechanical. (Piping) 86 DIC Mem.. Immurd/ None Required I-D Yes III-22 Memo 7/16/84, ECR Issued in lies IICR Item Closed 2 on sterord i ECM 22,ll,.O J. 87 ndelding, Ideld Pro (11e 87 DIC Memo Issued / Required I-5 No 111-22 Memo 7/25/84, Item olwn (See Item 167) 3 ou leccord/ECR Ino'lEn04(y)ECIti8 ,
, AF-8 PT ll574;UT 2455 i
.. . .u . . c a . . a ..: . * . . ~ - . . .. .
4 i .
-)
i P 5 TABLE OF RESOLUTION OF CSA CONCERNS
? Rev. 8 II/01/84 CSA
) CSA RESP.
(A) 4 ITSM CossC. ORC. ITEtt STATUS BY ACTION / RESP. REV/ CSA REP. DUE DATE CIASE OUT CSA d IReeER DESCRIPTIOII No. DISC. RESP. ORGANIZATION ACTIost PIJul CSA STATUS CONC. kEF. SCH./ACT. DOCtBENT VERIFICAT1008 g j SS Mechanical. (Piping) 88 DIC Memo Issued / None Required j Base Mat'l Indication Item Closed I-F Yes 2 III-22 Memo 7/I7/84, on Record
} QSR SR-1092-M PT Il550;IJT 2434 j$9 Mechanical (Welding) 89 DIC Menos P'separed/ None Required 0-D Yes
~ ~
g In Process Inspection Item closed I III-22 Memo F/10/84, on Record 90 Mechanical (Piping) 90 DIC Memo Prepared / None Required 0-D Yes llIY-23 Memo 7/16/84 i Pin Note la R.M. Item Closed ~
.J 2 on Record QSR SR-8093-M 95 Mechanical (Piping) 91 DIC NDC Prepared / None Required * ~ ~
Yes III-2) NDC-P-028 f Missing Iluts om Valve Item Closed I [. 92 Weldias (Piping) 92 hG&E/ Memo Prepared / Mone Required 0-F Yes III-23 Memo 73 [84
.: Improper Prep, for P.T. VENDOR Itc. Closed (See Item 169) I on Record
- ~
j 93 Mechanical, (Seapport) 93 W NCR Prepared / None Required
- Yes III-23 ISNT5265-J
,} Rust on Reager Item closed I a
j94 NDE, (R.T.) Weld Quality 94 KC&E U.T 3 sfo Inc~d/ Action Plan 94 0-C No i'TT VI If.f.-2431,
~ .:4 c)RT Daserepancies (RECO) Item Open 3 IV-28 SAP EC 1994 1 b) Lead ID in RT Area of Interest ,
1 195 Mechanical, (Piping) 95 DIC None Required j Crc Couges Surve II.nce Report Preparc.1/ltre Closed I-F Yes 2 III-23 Memo 7/I6/84, on Record QsR-3097-M NCR ISN20075PW i 96 Mechanical (Piping) 96 DIC/ M M PseparEl None Required 0-D
^^
Yes III-23 Memo 1/I4/84, Paint Chipping KCEE Itco Closed I
.,, on Record 17 Mechanical (Piping) 97 KG&E Meo~ ~Er egia rEI/ None Required 0-D Yes III-23 M E 7/I9/84, "'
Valve, Flow Direction Item Clumed I on Necord Cissing 98 Mechanical (Piping) 98 DIC/ Mrma Pe rp4 c.1/ None Required I-D Yes Ill-25 Memo 1/20/84
- CSME Class Changes RECitTEL I s r* Cl..mc.1 2 on kerord at C.,upling NCI l-OF49-P AE-9
t I TAbli of RESOLUTION OF CSA CONCERNS Rev. 8 II/01/84 CSA
? CSA RESP. ( A')
] ITEM .C080C. ORG. ITEM STATUS BY ACTION / RESP. REV/ CSA REP. DUE DATE ClJOSE Olff CSA
- MAGER DESCRIPTIost 31 0 . DISC. RESP. (*GANIZATION ACTION PLAN CSA STATUS CONC. REF. SCN./ACT. DocurENT WER I F I C..A..T 14W
- 99 Mechaalcal, (Supports) 99 DIC SDL Prepared / , Required I-B No Ill-32 SDL-EJ-406
'I Cinematonal Error Item Open I AP-VI-02,R.25 -lO , (partial)
~
100 Mechanical, 100 EG&E Memo Pscpared/ None Required
- Yes 11-18 Memo 7/I4/84, 5 (a) Maintenance Records Itco closed I on Record j (b) Danger Signs
] (c) Eshaust Fan
~'
301 Electrical, Missing 101 DIC Prepasch'NDC/ None Required 0-D Yes Il- 18 ' NdC E039 ,j Nameplate ltce Clumed I A Mechaatcal, 102 Dlc Memo Prepared / None Required
- Yes 11-18 Memo 7/I4/84, l102 (a) Maintenance Records Itee Closed I on Record 1 Missing j (b) Ifo Dnager Signs
.,, (c) Eshaust Fan
~ ~
103 Mechaatcal, 103 DIC Memo Preli$ red / None Required
- Yes II-18 d )[84/84, (Same am 102) Itce Closed I on Record
~~
'1 104 ^ - Mechanical, 104 DIC Mc E Prce de7/ None Requared
- Yes 11-18 Aceo 7/l4/84,
. (Same as 102) Itce Close.1 I . + 7//18/84 i
On Record
, 105 Mechanical. (Supports) 105 DIC NCR & hcl Prepared / None Required
- Yes III-12 ISN 19583N (a) Loads on Can do not Item Closed 2 RCI-t-0016H
'! Agree with Boe (b) No NTDli I (c) No CAR 25 in Traveler (d) Can Binding 106 Mechanical, (Piping) U.T. 106 DIC SR Prepaeed/ None Required 0-F Yes III-24 SN 1098tl
! Prep for W.T. Inca clumed I CWP E6 602P 107 Welding, Linear Indication 107 DIC Memo Prreared/ Fone Required I-D Yes Ill-24 Memo 1/17/84
- Weld Itce Closed I on Nerord PT-II584 AE-10 ,
~. .
. . . , . .. ,. .. n . - .
4
'i .
I s g 4 TABLE fW RF.SOLiff!ON OF CSA CONCERNS I Rev. 8 11/03/84 j _ CSA 3 RESP. CSA (A)
- ITEM CONC. ORG. ITEtt STATUS BY ACTION / RESP. REV/ CSA REP. DUE DATE' CI.DSE OUT CSA BROGER DESCRIPTIOld 11 0 . DISC. RESP. _ ORGANIZATION ACTION PIJJi CSA STATUS CONC. REF. SCH./ACT. DOC M NT VERIFICATIpts
~l 108 Weldies, Linear Indication 108 DIC Memo Prepare 4f None Required I-D Yes III-24 Memo //17/84, i Weld Iten Closed I on Recort
- j PT-Il584
, 109 Welding, Weld Splatter 109 DIC SR Prepared / None Required 0-D Yes III-24 SR-lidOM
- N Item Closed 3 NCh ISN20lI0F H
Welding, Queestionable 110 DIC Memo Prepared / None Required 0-D Yes III-24 Memo 7/11/84, {J110 P.T. Prep item closed 3 on Record PT-Il583
~
Ill Weldin8, PSI /ISI U.T. lll DIC/ Hemo Prepared / Action Plan lil I-C No 111-24 Memo 7/lF/84, 3 Prep KG&E Item Open 3 on Record } LP 4863 PT P87-PT-4613 '.}112 Welding,Iloop Shrinkage 112 DIC/ Hemo Psepared/ None Required 0-D Yes Ill-24 Memo 7/16/84,
.l,s BECHTEL Item Closed I on Record
[, 113 Electrical, Clamp Missing 113 DIC NDC Prepare.1/ None Req.s a r cif O-D Yes 11-18 NDC-E041 Item Closed I
,'d II4 Electrical, Separatior. ' 114 DIC NDC Prepared / None Required 0-D Yes MDC-E042 ;:1 Item Closed (See Item IFO) I ,
d 115 Mechanical, Equip, Bolts 115 DIC NDC Preposed/ None Required
- Yes ill-24 NDC-P-041 Kissing osa Valve Plates Item closed I
~
f'll6 Electrical Loose Fles 186 DIC NId Prepared /~~ Nor.e Required 0-D Yes NDC-E043, Ismo 'i Item Closed I
-117 Welding, Steel on SS II7 W NDC Prepared / Required O-C No III-24 ISN-55260J Item Open I
;118 Welding, Weld Profile II8 KC&E Hemo Perpareil/ Required I-B No III-24 Memo 7/89/84 VENDOR Item Open (See Item 169) 3 on Nerord
~ icquired
^
l319 Weldsng, Overlap 819 KGN/~ N?lt sirep .cjf ~~ I 0-C No Ill-25 ~ ~ ~~iSN-l M~2'Mbi ~ " W.ST . yen (:.cc I a s~m I. 3
, no i- .
I 1 } i j lq TABl.E OF RESOLIITION OF CSA CONCERNS l New. 8 11/01/84 CSA '3 - CSA RESP. (A) '!} ITIJE CONC. ORG. ITEM STATilS BY ACTION / RESP. REV/ CSA REP. DUE DATE CIDSE OUT CSA MSWER DESCRIPTION NO. DISC. RESP _. ORCAMlZATION ACTION PIAN CSA STATUS CONC. ItEF. _ SCN. /ACT. DoctsEstT VERIFICATIUII 120 Welding, Porosity 120 NG&E Memo Prepared / Required 0-C No III-25 Memo 7/19/84, ,..- VENDolt Iten Open (See Itco 169) 3 on itecord I :<j 1,
~
Welding Escessive 121 DIC Memo Prepared / None Required 0-D Yes III-25 Memo 7/19/84,
~
d[123 Reinforceerst Itee Closed (See Ites 167) I on Record H( p 122 Weldios, Linear 122 DIC SR Prep 4eed/ None Required I-F Yes III-25 QSR SR-IO99-M 'g ladication Itee Closed (See Itee 167) 3 PT-Il586 123 Mechanical (Supports) 123 DIC NCR Pieglared/ Nane Required
- Yes III-32~ ISH 19607N
~~~
Code Data & Documentation Ites Closed (See Itco 157) 3 M* 124 Mechanical. (Supports) 124 DIC SDL Prepared / None Required
- Yes III-32 SDL-EP-288 Imose Jan Hut Itc. Closed i I2%
Mechanical, (Supports) 125 DIC SD'L'EcparId/ Mone Required
- Yes Ill-32 SDL-EP-287 Claap Angle Off Itco Closed I
326 Mechanical, (Supports) 126 DEC (a) NCR Prepased/ a) None Required a)* a)Yes Ill-5 (a) ISNI9609N g (a) Saebber Tension in Item Closed (See Item 166) 3 (b) SDL-EP-284
'. Lieu nf Comp, (b) SDI. Prepared b) Required b)l-B No Ill-32
,{ (b) Obstructions Isce Closed I
~
$ 127 Mechanical, (Supports) 127 DIC ' SUI.PIerar5/~~' Mone Required C Yes IIIE SDL IP E'l 8's See Calls for Snubber to i t em C lo:.ed (See Itc 166) 3 111-32 be in Comp. Conflict
; with Traveler
^t
. 123 Mechanical, (Supports) 128 DIC SDI. Prepared / None Required
- Yes III-5 SDl.-EP-286 j (Same as 127) Item Closed (See Item 166) 3 III-12
' 129 Electrical, No Q.C. 129 DIC Resolutson on CSA None Required I-D Yes II-6 CSA Form Documentation on Bus Bar Fore /itre Closed (See Items 162 & 163) 3 II-18 NCR ISN20674E Tarquing QC Checklist Seeples 4
AE-12 ,
...:.." . . . . .;. - ... - n. .- .. ..
v.. . . . .. . . . . . . . . 4 I . I J j TABLE OF RESul.UTION OF CSA CONCEftNS j Nev. 8 II/01/84 CSA i CSA RESP. (A) ,j ITDI CONC. ORG. ITEM STATUS BY ACTION / RESP. REV/ CSA REP. DUE DATE CIDSE Otif CSA ' t NISISER DESCRIPTION No. DISC. NESP. OHGANIZATION_ ACTION Pl.AN CSA STATUS CONC. REF. _SCN./ACT. DOC 19ENT VERI Fit'AT isNt 'I
- j 130 Electrical, 130 DIC NDC Prepared / None Required 0-D Yes 11-18 NDC-E-049 Solting of Switchgear Item closed (See Item 164) I
~
131- Electrical, 131 DIC NDC~ Prelared/ l None Required 0-D Ye's Il-18 NDC-E-049 'j (Same as 130) Item Closed (See Item 164) I 132 Electrical, Conduct 132 Dic NDC Prepared / None Required 0-D Yes 11-18 NDC-E-047 Lf Touching Support Item Closed i Bechtel SLSE 11,338
' 133 Mechanical, (Supports) 133 DIC a*b)NDC Prepared / a) & b)Mone Required
- a&b) yes Ill-5 ISN 1963011 id (c) Wrong Size Washers Items Closed (See Item 157) 3 4 (S) CAR 25 c) Item Open c)See Action Plan 133 c) No Ill-32 Memo CSA No.
4 (c) 2 insteed 4 Hole Clamp (See also Item 166)l-C 3 133" '? 134 Mechanicals (Supports) 134 DIC SR Prepared / None Required
- Yes ill-33 NSIR's 2t?7N,
.I (s) 1.oose duts Item Closed I 217818, d >
(b) Naegers not Shimmed 2179N
~
NCH and IItter yea 135 Mechanical. (IEC) 135 KG&E None Required 2-D II-8~~ ~lSNS526tJ
]
, d, Residue on Tubing Pre pa t ed/ I t em 3 ll-25 SAP-EG-1885 Closed . SAP-EG-1708
- SAP-EG-1866
. ISN $53905 3 SAP-EG-2004 ?
1 836 Mechanical. (I&C) 136 W Hema Prepared / Required I-8 No 11-28 PCN 84-3
.j Notes in Concrete Item open 2 FCR I-Il96-C
*4 SAP-EG-2004 137 Welding, Underfill. 137 KC&E Memo Perpared/ Required 0-C No Ill-25 Meme 7/23/84 VENDOR It em Open (See item 169) 3 on Necord
,138 Welding, Porosity 138 NG&E Memw. Prepared / Required 0-C No III-25 Memo 1/21/84
, VENDOR Item Open (See Item 169) 3 on Necord
- 139
~
. Welding, Undercut 139 KC&E Memo e SH None Required 0-D Yes til-25 Memo 1-23-84 VENDON Prepared / Item Closed (See Item 169) 3 SN WIR-84-278 h
i Al-13
' l. , ,
i y TABLE OF RESOLUTION OF CSA CONCERNS Rev. 8 II/01/84 'i , CSA
! CSA RESP. (A)
ITDI CONC. ORG. ITDI STATUS HY ACTION / RESP. REV/ CSA REP. DUE DATE Cl.0SE OUT CSA lAIllte8ER DESCRIPTION NO. DISC. RESP. ORGANIZATION ACTION Pl.AN CSA STATUS CONC. REF. DOCl# RENT VICAIFICATiuN SCN. LACT. 3, 140 Electrical, Flex Pulled 140 DIC NCR Prepared / None Required 0-D Yes 11-18 ISN-19716E
*j from Connector item Closed I UT'I
^
141- Mechanical (l&C) 141 W Memo Prepared / None Requared I-F Yes 2 W Memo 2/24/82, Aachor Spacing Ites Closed 2 NCR 19A1 51224-J SAP-EG-2004 142 Mechanical. (l&C) 142 W CWP Prepared / None Required I-D Yes 11-21 (Cancelled) y Damaged Tubing & Gage Item Open (See item 156) 2 CWP SG 873I SAP-EG-1998 143 Mechanical, (l&C) 143 W CWP Prepared / Mone Required
- Yes 11-21 CWP-88-6731
, ,1 loose Clamp Item Closed (See Item 156) I KWCLWW-84-127
~
144 Mechanical (l&C) 344 W Memo Prepired/ None Required
- Yes li-U W Memo 772W 84, j Missing / Loose Nuts on Item Closed (See Item 156) i SAP-EG-18%
Tarminal Bom , t h 145 Mechanical, (Supports) 145 DIC RCI Prepared / Required 0-C Mu RCI-lO434-P j Standin8 Water in Stanchions item Open (See item 156), I f14 Mechanical (I&C) 846 W CWP Prepased/ Required 0-C No 11-21 CWP E.1-4591
*- Damaged Tubing and Item Open (See item 156) 3 , G-SAP-EJ-003-Clamp Missing CSA QII/I CWA-EJ-G03-CSA 1847 Mechanical, (l&C) 147 W a) CWP Prepared / a) kequared a)O-C (a)No ll-8 a) SAP EG-18 %
4 (c) Damaged Tubing item open I CWP HB-239-3 (b) Hanger not Installed b) NCR Prreared/ Generic b) None Required b)O-D (b)Yes 11-21 NCR ISN55355J 1 Implicatsons Evaluated / (See item 156) I b)ECWP-382 Item Closed FCR W-t-0432-J SAP EGl945+EGISM CWA-Nb-G03-CSA-I 148 Mechanical, (I&C) 148 W CVP Prepared / None Required
- Yes 11-21 CWP EJ-4591 (s) Missing Valve Handle Item Clo.cl .
(See item 156) I S AP-EG- I SM g (b) Missing Clamp 149 Mechanical (HVAC) 149 DIC NDC Pr ep.e s e.8/ None Required 0-D Yes Ill-39 NDC MWO68 I lindessaze Welds I t ce. C l u mr.I ISee am 168) l ' g Al. I # e *
, . . .u. z ; . . . . , m . s --. . x A .x. - -.- - ., . . . ! 6 ?
f l TABLE OF RESOLUTION OF CSA CONCERNS 3 kev. 8 11/01/84 ( CSA l CSA RESP. (A) ,1 ITEM CONC. ORG. ITEM STATUS BY ACTION / RESP. REV/ CSA REP. DUE DATE CthSE OUT CSA jIR8mER DESCRIPTIoll No. DISC. RESP. pkGANIZATION ACTION PLAN CSA STATUS CONC. kEF. SCN./ACT. DOCUPENT VERIFICA_ TION t ,4 1 150 Mechanical, (HVAC) 150 (a)KG&E(a) NDC Prepared (a) Required a) l-8 (a)Mo 181-19 (a) NDC-MWO60 (a) Welds Undersize VENDOR Item open (See Item 162) 3 NCR ISN-20104-MW (b) Dimensions (b)Dic (b) RCI and NDC (b) None Required b) * (b)Yes (b) RCI-t-244-M i Prepared / Item I and NCR d Closed ISN-20003-M
~~
151 Mechanical, (HVAC) 151 DIC (a) NDC Prepared / (a) Required a) 3-8 No lil-39 (a) 'IDC MW 062
- (c) Welde Undersize Item open (See Itce 168) 3 ISM 20104MW (b) Grinding Embeds DIC (b) Memo Prepared / (b) None Required b)
- Yes (b) Memo 8/l/84,
)[ Ites Closed I on Record
.-, (c) Documentation DIC (r) NDC Prepared / (c) None Required c) 0-D Yes (c) ISM 19938N Item Closed I
.{
1
*152 Mechanical, (NVAC) 152 DIC Meino Psepared/ Mone Required 0-G Yes 181-39 Memo F/26/84,
.I Post Applied Plates Itce closed (See also Item 158) I on Record i Dwas. C-1037,R.0 3 C-0C2323 R. 19 7f153 Mechanical (HVAC) 153 DIC Memo Prepared / Required I-C No III-39 Memo 8/4/54 Welding on Cusset Plate Item open 3 on Record
~ ~ -
, 154 Welding, Escessive 154 KC&E/ Re'solutinsi on C5A None Required 0-D Yes I11-25~~ CS ' Fore Weld Width VENDOR Fore / Item Closed I ,
' i,
' ~~
a)Yes 11-6~
-~ .f155 Electrical, (a) No Inspec- 155 a)KCE/ ajlten CloJ d a)None Required 0-D 'l tion Record of Battery Rack Dlc (See Item 164) 3 ll-19 'j F(steners (b) Nuts Missing b)KG&E b)NDC Preparrd/ b) Required b) l" b)Mo b)MDC E-065 '1 from Sattery Rack Assemblies Itco open 3 1 ..
2 i
.1 e
AE-15
E l 2 b
- TABLE OF kESOLlifl0W OF CSA CONCERNS
- Rev. 8 II/01/84 CSA
, CSA RESP. (A) sITEM CONC. ORC. ITEM STATUS HY ACTION / RESP. REV/ CSA REP. DUE DATE CIDSE Oltr CSA
.NiagSER DESCRIPTION NO. DISC. RESP. ONGANIZATION___, ACTION P!AN CSA STATUS CONC. NEF._ SCH./ACT. DOCt4ENT VERIFICAfttWe
= Generic / Program Concerns f - 'I54 IEC Tubins Damese KG&E See Action Plan 156 l-A No ! OPS. VSAP-EG-1932 3 i 157 Supports, Minor Hardware / KC&E ~ 'eI S ction Plan 157 a)l-B No 3 Documentation Problema DIC b)l-B 3 g c)l-A ISS NVAC, Conflict or Lack of DIC See Action Plan 158 0-8 No Uniform Inspection Criteria 3 1 159 Qu21 sty Assurance /Construc- KGEE See Action Plan 159 0-C No Vill-2 Currective Action tio2 Audits not to Schedule 3 Document 159,9/25/84 , far Ist/2nd qtr. 1984 KyWID " Supplement to CSA 157" ,I60 Startup, SFR's not Being See Actson Plan 160 0-D Yes Vill-5 CAR IS Properly Utilized or 3 Work Hold [tepositioned Agrecaent 22 161 Qu286ty Assurance, SDL's not DEC See Action Plan 161 0-D Yes Beirs Properly Utilized or 3 , Cirpositioned 162 An Apparent Deficiency in KG&E See Action Plan 162 1-B No Max sement Control of Vendor 3 Activities. Inadequacies in Vindor Supplied Hardware and
! Documentation in Several Disciplines.
Jtctn3 Riference for Generic Conterne: (X) - _(Y) i Action Plan Hev. _ _ _ . Status Code itctus Codes: (A) Action Plan Complete (B) Corsectase Asason Complete (C) Hesponse incomplete per CSA Nevaew (D) Response OK per CSA Neview ) (E) CSA Verification - Reject (F) CSA Ver s i se at ion - Art ept (G) CSA Closure t
! 40-16 '
i
~ - - - - - _ - - - - - -
. .i s ..: $ a . s.J G r . . .. .
_. .. -. -..s, w. .. . ( J 4 TABLE OF RESOLUTION OF CSA CONCERNS kev. 8 II/01/34 CSA ~~ i CSA RESP. (A) l ITEM CONC. ORG. ITDI STATUS BY ACTION / RESP. REV/ CSA k t' P . IMIE 11 ATE CIASE Oltr CSA
! MSEBER DESCRIPTION NO. DISC. RESP. ORGANIZATION ACTION PLAN CSA STATUS CONC. REF. SCN./ACT. DOCupe.WT VENIFICAflu h 163 A Potential Generic Problem KG&E See Action Plan I63 0-A No trith Regard to the Complete- DIC (Pending 3
}q ness of QC Inspection 157, 162 r Criteria. + 164)
~
164 A Generic Problem with Regard KG&E See Action Plan 164 l-B No Vendor Site to the Fasteners (e.g., Nuts, DIC 3 Visit Report Bolts, Washers) Used for On- B-274 ~~, , Site Assembly and lastella-
, tion of Electrical Equipment.
{ . _ . . . j165 A Problem with Unistrut Walt DIC See Action Plan 165 3-D Yes 15-2 Spreading and Possible Loss BECHTEL Ref. 24, 52 3. cf Capability to Support j Electrical Conduits.
~
166 A Problem with the Estab- Dic See Action Plan 166 2-B No CAR-43
}' lished Construction Contrac- (Also, Su Action 3 CAN-44 f, ter Drawing Change Control Plan 153)
Procedures in the Area of
. Special Instruction Sheets.
167 Welding, Concern with the KC&E See Action Plan 167 I-B No ,
.[ Quality of Field Fabricated DIC Hef. Il2, 123, 122 3
, Welding Including ANSI B31.1
- Piping Welds.
~
- 163 Welding, Concern with NVAC DIC See Action Plan 163 1-B No Support Attachneet Welds Ref. 149 3
~
169 Welding, Concern with Visual DIC See Action Plan 169 l-A No Acceptance of Vendor Fabri- 3 cated Piping Welds
^
170 Startup, leproper Use KG&E See Action Plan 170 l-B No Vill-5 si the System for Con- 3 e trollies Nonconforming Conditions for Equipment
, Turned over to KG&E. .l __ . .
_ - _ _ _ _ - -_}}