ML20133P241
| ML20133P241 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/22/1985 |
| From: | Ellershaw L, Madsen G, Martin L NRC - WOLF CREEK TASK FORCE, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20133P232 | List: |
| References | |
| 50-482-85-22, NUDOCS 8508140228 | |
| Download: ML20133P241 (10) | |
See also: IR 05000482/1985022
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APPENDIX
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
STN 50-482/85-22
Construction Permit:
CPPR-147
Docket:
50-482
, Category:
81
Licensee:
Kansas Gas and Electric Company (KG&E)
P. O. Box 208
Wichita, Kansas
67201
Facility Name: Wo1f Creek Generating Station
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Inspection At: Wolf Creek Site, Coffey County, Burlington, Kansas
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Inspection Conducted: April 23-25, 1985
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Inspectors:
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L."E. Ellershaw, Reactor Inspector
Date
Project Section A, Reactor Project Branch 2
h W&
j-/8-SS
G. L. Madsen, Reactor Inspector
Date
Project Section A, Reactor Project Branch 2
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Approved:
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L.~ET Martin,
ief, Wolf Creek Task Force
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Inspection Summary
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Inspection Conducted April 23-25, 1985 (Report STN 50-482/85-22)
Areas Inspected:
Routine, announced inspection of the followup on
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allegations. The inspection involved 50 inspector-hours onsite by two NRC
inspectors.
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Results: Within the areas inspected, no violations or deviations were
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identified.
8508140228 850802
ADOCK 05000482
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DETAILS
1.
Persons Contacted
Kansas Gas and Electric Company (KG&E)
W. J. Rudolph II, Manager, Quality Assurance (QA)
R. M. Grant, Director, QA
C. A. Snyder, Manager, Quality First
H. Curry, Supervisor, Quality Control Inspections
D. Madsen, Quality Control Engineer
Thc NRC inspectors also interviewed other site personnel during the
course of the inspection.
2.
Followup on Allegations
a.
(Closed) Allegation 4-84-A-019:
The alleger indicated several items
of concern principally relating to structural construction.
Findings relating to these items follows:
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(1) The alleger indicated that material traceability of structural
steel shims was not verified during installation"and shim plate
sizes may be questionable.
Material traceability (in terms of heat numbers) is not
generally considered important since shims are always com-
pressively loaded.
Any traceability required would relate to
providing a degree of assurance that shims are of a weldable
material, since shims are usually welded to assure they will
remain in place.
The resolution of the structural _ welding
issue has provided adequate-assurance that shims are' weldable
and therefore no further action is warranted.
Shim material
was a subject included in CAR (Corrective Action Report) 46
which was reviewed by the NRC.
This allegation was considered substantiated, however, there
is no safety significance.
The licensee's corrective actions
to resolve this issue were satisfactory.
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(2) It was alleged that structural steel inspections were not
accomplished because of a breakdown in assignment of
responsibilities, and QC supervision attempted to cover-up the
situation by coloring in control status drawings to show that
work had been done.
The above information precipitated an extensive NRC inspection
which subsequently substantiated that the inspection program
for safety-related structural steel welds was not adequately
executed to assure conformance to the requirements, nor were
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adequate records kept to document the quality of the welds.
The attempted cover-up was investigated by the Office of
Investigations and will be documented in a subsequent inspection
report.
As a result, the NRC issued a-Notice of Violation and an
Imposition of Civil Penalty.
KG&E's corrective action included a 100% reinspection of all
accessible safety-related structural steel welds. All of the
actions required to be taken by KG&E in order to provide
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adequate resolution to the structural steel welding issue, were
performed and are documented in their Final Report Corrective
Action Request No. 19, dated January 21, 1985.
The NRC
performed verification of KG&E corrective actions and
documented this activity in NRC Inspection Reports 50-482/85-12
and 50-482/85-13.
This allegation was substantiated, however, appropriate
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corrective action was taken.
This item is considered closed.
(3) It was alleged that KG&E's surveillance report S-372 did not
adequately address the failure to inspect and/or document the
results of structural steel inspections.
Surveillance report S-372 was a precursor to Daniel
International Company's (DIC) Corrective Action Reports (CAR)
29 and 31, and subsequently to KG&E's CAR 19.
The major
findings identified in the surveillance report dealt with
electrical support weld inspection documentation. The resolution
of the structural' steel welding problems has satisfied the
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technical elements of this item.
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This item is considered closed.
(4)- It was alleged that pipe whip restraints were inspected / signed
off in a manner'similar to structural steel.
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CAR-19 was written primarily to address weld deficiencies and
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missing inspection documentation relative to the structural
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steel welding program. To assure that problems similar to
those identified in structural steel did not exist in other
safety-related programs using AWS D1.1 welding, CAR-19 was
expanded to require an analysis of those programs, including
. pipe whip restraints.
This effort revealed no similar con-
- ditions or causes generic to the pipe whip restraint program.
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Programmatic elements utilized in the inspection and
documentation of the various applications of AWS D1.1 welding
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differed depending upon the Quality discipline responsible for
inspection activities.
Nondestructive examination (NDE) was
identified as a differing element of the pipe whip restraint
program.
It was determined that pipe whip restraint welds were
100% nondestructively examined and accepted.
There were no
identified instances of missing NDE reports.
This item is considered closed.
(5) The alleger indicated that inspection of structural steel
bolting was neglected in the radwaste and turbine buildings.
Originally these buildings were a part of CAR 26; however, both
buildings were subsequently deleted from the scope of CAR 26.
A review of records revealed that the radwaste and turbine
buildings were deleted from the scope of CAR-26 in that the
purpose of the reinspection program was to determine the status
of high strength bolting connections in safety-related
structures.
The turbine and radwaste buildings (Non Category I
structures) were deleted from the scope of CAR 26 based on DIC
engineering disposition of deficiency report ISD-7844C.
(6) The alleger alludes to the improper torquing of the bolts for
the rail clips on the Polar Crane or the possible falsification
of the inspection records by the day shift inspector who got
sick the one time he did go up on the Polar Crane to inspect
these bolts.
The alleger also said that the second shift QC
inspector worked very hard on inspecting these connections,
while the day shift inspector did nothing.
A review of the time and attendance records and site first aid
records of the individual that allegedly did not perform the
above inspections or possibly falsified the inspection records
confirms that the inspector did get sick while working on the
Polar Crane rail and was subsequently helped down and taken to
first aid on site.
The inspector did not return to the site
for approximately three weeks.
A review of the inspection documentation for the Polar Crane
indicates that this inspector had inspected torquing of the rail
clip bolting on the one day in question.
Structural drawing
E-122 also provides positive indication that the other
inspections were performed by two other inspectors.
A subsequent interview of this inspector, by 01, confirmed that
this inspector had only inspected the torquing of these bolts on
the one occasion.
Structural drawing E-122 and its attachments
also indicates that the bolted connections, after initial
alignment were to be welded, which was accomplished.
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The allusion to improper inspection or possible falsification
of the inspection records for the torquing of the bolts in the
clips for the Polar Crane rail was not substantiated.
(7)
It was alleged that bolting holding down fuel rod storage
containers had no inspection documentation and the prints were
marked up wrong.
Installation of the New Fuel Storage Rack assemblies was con-
trolled and documented on Westinghouse Installation /Fabrica-
tion Traveler SAP-WC-018, revisions 0 and 1.
Pages 4 and 5 of
revision 1 to the traveler document the installation and
inspection of bolting and torquing requirements as evidenced by
the initials of the operator and the Quality Assurance Engineer,
with dates.
The installation of the Spent Fuel Storage Rack assemblies was
controlled and documented on Westinghouse Installation /Fabrica-
tion Traveler G-SAP-WC-030, revision 0.
Pages 10, 11, 14, and
15 of the traveler document the installation and inspection of
~ bolting and torquing requirements as evidenced by the initials
of the operator and Quality Assurance personnel, with dates.
This item is considered closed.
b.
(Closed) Allegation 4-85-A-44:
The alleger stated that there had
been a failure to conduct routine audits of onsite contractors at
the required frequency.
The FSAR for Wolf Creek states that the
management of each SNUPPS' utility is to assess the scope of imple-
mentation and effectiveness of the QA program to assure adequate
compliance with the utilities' policies and with 10 CFR 50,
Appendix B.
This assessment will be conducted every six months
during the first two years that the program is implemented.
Thereafter the evaluation process will be performed on an annual
basis.
This evaluation process may include audits performed by the
utility personnel or outside consultants.
KG&E Quality First received a similar concern from the alleger;
however, the concern was focused on procedures in the KG&E con-
struction procedure manual.
Quality First investigations disclosed
that construction procedures govern activities which are a dupli-
cation of quality related functions which are subject to QA audits or
in the case of Procedure KP-4503, do not control a quality related
function.
Quality First determined that a QA audit of the KG&E
construction procedure manual is not required.
The alleger was
contacted by Quality First on January 18, 1985, at which time he
acknowledged the receipt of a written summary regarding this concern
and he indicated no problem with the findings regarding this item.
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During the period 1977-1985, KG&E corporate and onsite QA conducted
some 190 onsite audits and 1040 surveillances of Wolf Creek con-
struction activities.
In addition to the audits performed by KG&E,
the site constructors performed some 545 audits of their own
activities.
On the basis of the above, the audit and surveillance of onsite
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construction is considered adequate.
c.
(Closed) Allegation 4-85-A-45:
The alleger indicated several items
relating principally to electrical activities.
Findings regarding
these items follows:
(1) The alleger indicated that equipment was moved from the
warehouse to the field without proper handling and installation
procedures.
A review of warehouse maintenance and QC
inspection records revealed damage to Power Supply Inverter
NN13 which had been identified and corrected.
However, Quality
Inspection personnel failed to initiate the appropriate
corrective action documents.
In spite of the oversight, the
Quality Program identified, resolved, and inspected the
deficiency.
In order to substantiate the acceptability of the
equipment, KG&E QC and QA personnel performed a visual
inspection of Inverter NN13 on May 1, 1985.
No evidence of
damage associated with this allegation was found.
(2) The alleger indicated concern about the turnover of the
procurement program to KG&E as .related to the KG&E Vendor
Control and spare parts program.
The alleger indicated a
concern that the KG&E QA group was performing inadequate
reviews of Bechtel and Westinghouse procurement.
The concern relating to vendor program control is believed to
be related to the control of vendor. instructions manuals which
were shipped with the equipment and were taken to the field
without benefit of proper approval or control. This concern
was identified on November 14, 1984.
QC investigations, to
determine if procedural control was in place for transmitting
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vendor generated documents from WCGS Receiving to Document
Control for processing, revealed that QCP 7.1, Revision 1,
failed to provide instructions for transmittal of Vendor
generated documents.
QCP 7.1, Revisi)n 2 was initiated on
December 17, 1984, to correct this condition.
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(3) The alleger is concerned over the use of a ground bar used
for instrument ground where other grounds are terminated.
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Isolated Grounding for Instrumentation is governed by the
following documents:
. P-XI-300, " Installation of Electrical Equipment and
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Instrumentation," Revision 9
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WP-X-301, " Grounding," Revision 3
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Bechtel Drawing E-0G8900, " Grounding Notes, Symbols and
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Details," Revision 13
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IEEE Standard 446, "IEEE Recommended Practice for Grounding
of Industrial and Commercial Power Systems"
-The Inspection of Isolated Grounding for Instrumentation is
governed by:
QCP-XI-300, " Inspection of Electrical Equipment,"
Revision 12
The NRC inspector reviewed the above documents and determined
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that they were satisfactory.
The isolated grounding system at WCGS is primarily for the
purpose of providing a noise free insulated isolated grounding
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method for instrumentation through a very low impedance path to
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station ground.
The inspector could not identify within the
above documents any prohibition against other grounds being
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terminated on the same ground bar that is used for instrument
ground.
The technical merits of this concern would only be
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relevant if it could be identified.that a specific non-
instrument ground, in fact, resulted in noise being induced
into the ground circuit of such a magnitude that the low
impedance cable connecting the ground bus to the station ground
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mat was not properly sized.
This would result in a spike being
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induced into the instrument ground.
This spike in and of it
self would be highly attenuated due to parallel paths.
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This allegation lacks specificity sufficient to pursue in
depth, and the grounding practices are typical of those
utilized elsewhere in the power industry.
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(4) It was alleged that cables were generally routed over sharp
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edges at all elevations in the cable spreading rooms,
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The NRC inspector conducted an inspection of the two cable
spreading rooms in the control building in order to assess the
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validity of the allegation.
Forty cable trays in both the
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lower spreading room at elevation 2032' and the upper spreading
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room at elevation 2073' 6" were observed.
There were no
instances identified where either cables were routed over sharp
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edges or that the minimum bend radii had been exceeded. . Where
cables either entered or exited a cable tray from the side, a
cable tray edge guard had been installed.
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This item was not substantiated and is considered closed.
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(5) It was alleged that a cable tray in the reactor building had
not been cleaned before the covers were put in place.
The
cable tray location was described as being at floor level to
the left of the main personnel hatch two or three levels down,
and passing through a wall separating two large tanks.
Reactor building drawings were reviewed to determine the
specific cable tray. involved and location.
A cable tray was
located that passed through a wall separating the accumulator
tanks. The cable tray was identified as IU2A, and located at
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the 2009' elevation of the reactor building.
The NRC inspector
requested that the covers be removed from the four segments of
the cable tray in order to observe the internal cleanliness
condition.
Covers were removed from segments IU 2A-39, -40,
-41, and -42.
With the exception of some dust, there was no
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debris observed.
This item is not substantiated and is considered closed.
(6) The alleger indicated that the inspectors inspecting anchor
bolts had neither the proper training nor procedures.
It was
indicated that a QC inspector had resigned on March 21, 1983,
prior to submitting an NCR relating to this matter.
He
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questioned KG&E's corrective action and whether a CAR was
issued.
He felt that corrective action should include a random
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audit with pull tests and a review of anchor bolt certifi-
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cations.
He. stated that there had been two companies furnishing
anchor bolts (one safety-related and one nonsafety-related).
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questioned whether or not KG&E maintained proper segregation.
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DIC NCR ISN-9711E, dated March 26, 1983, was initiated to
address the issue of " improper training and procedures" to
govern inspection of expansion anchor bolt installation.
This
NCR was voided with the following justification:
It is the
employer's responsibility to qualify the inspectors in each
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discipline for certification.
DIC Quality inspection
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management reviewed the program in question and determined that
the electrical support certiiication program was adequate for
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the required anchor bolt inspection criteria established at the
beginning of the program.
All inspectors were trained and
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tested prior to being certified and performing any inspections.
The approved Architect Engineer disposition of DIC NCR #ISN
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3476C, dated July 30, 1981, provided additional installation and
inspection criteria to governing documents in effect at that
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time.
As specified in the approved disposition of DIC NCR #ISN
9711E ". . . All inspectors participating in the program were
trained and tested to this criteria prior to being certified
and performing any inspections."
A review of DIC Purchasing and Warehouse records revealed that
concrete expansion anchor bolts were purchased as safety and
nonsafety-related.
The primary manufacturer was RAMSET.
Some
safety related bolting was purchased from Robert Isray Co.
These expansion anchors were "Hilti Cinch Anchors." These
expansion anchors were subsequently found to be incompatible
with site installation procedures and were returned for
salvage.
Warehouse storage maintenance practices for segregation of
safety and nonsafety-related bolting material is accomplished
by storing nonsafety-related bolting material in the area
designated as " Tool Room".
This area is located on the south
end of the warehouse.
The safety-related bolting material is
stored in the north end of the warehouse.
All safety-related
expansion anchor bolts are "Trubolt" as manufactured by RAMSET.
Visual inspection of the safety-related storage area would
readily identify nonsafety-related material inadvertently placed
in this area.
In addition, all nonsafety-related expansion
anchor bolts purchased from RAMSET are "Dynabolts".
Though
similar in appearance to the RAMSET "Trubolt," the difference.is
also readily apparent.
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Based on the information noted above, it was determined that no
corrective action is deemed necessary.
(7) The alleger stated that there were splices inside of cabinets
that were not being properly documented.
The cabinets described
appear to be located in the vital instrument power rooms.
The
cabinets were described as being located in a series of small
rooms.
The NRC inspector visually inspected cabinets NN01, NK51, NK51A,
NK41, NK43, NN03, NK03, NK44 and NK54 in the battery equipment
rooms.
Splices were observed on cables IRPK09DA and IRPK0908 in cabinet
NK41 and on cables 4RPK090A and 4RPK0908 in cabinet NK44.
A
review of electrical termination document E-17000A revealed
that pigtail splices were authorized for the subject cables in
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that the conductor wire size was too large to terminate on
equipment terminal blocks or other connection means.
(8) The alleger related concerns reletive to the routing and
termination of electrical cables within cabinets.
He recalled
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blue Honeywell cabinets located halfway into the auxiliary
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building on the main level as good examples.
He indicated that
cables in the cabinets were in thick bundles and were laying
over the troughs.
He stated that some terminations broke on
moving cable during a walkdown inspection and indicated the
details were in the walkdown notes.
He indicated that hairline
cracks in lugs were noted and that terminations in the upper
level of the pool area were the best examples.
The NRC inspector visually inspected Honeywell Cabinets RJ
160A, B, C and D and RJ 159 A, B, C and D in the south and
north penetration rooms on elevation 2026 feet.
The inspection
revealed no evidence of cable laying over troughs or hairline
cracks in lugs.
The inspector noticed the presence of a tag
within cabinet RJ-159A which indicated lug bends greater than 45
degrees on six cables and referenced Work Request 16654-84
dated December 21, 1984.
A review of the allegers walkdown record dated September 26,
1983, included identification of discrepancies similar to the
subject allegations.
Records indicate that a reinspection was
performed on October 24, 1984, and the conditions were found to
be acceptable.
However, upon correction of cable training,
construction lugs were found bent past 45 degrees. WR 16654-84
was issued for six cables within cabinet RJ 159A.
Reinspections
of cabinets revealed eight additional lugs bent beyond 45
degrees.
These additional damaged lugs were added to
WR 16654-84. WR 16654-84 was closed on January 27, 1985.
Inspections of cabinets on the upper levels of the fuel pool
building failed to reveal cracking of termination lugs as
indicated by the alleger.
3.
Exit Interview
The NRC inspectors discussed the scope and findings of the inspection,
with Messrs. R. M. Grant and W. J. Rudolph on April 25, 1985.
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