ML20198B673

Forwards Rept of Inquiry Q4-84-048.Case Closed.Related Info Encl

ML20198B673
Person / Time
Site:	Wolf Creek
Issue date:	01/29/1985
From:	Herr R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hayes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20198B650	List: ML20198B645 ML20198B658 ML20198B665 ML20198B673 ML20198B682 ML20198B760 ML20198B775 ML20198B781 ML20198B794 ML20198B806 ML20198B818 ML20198B832 ML20198D229
References
FOIA-85-101 NUDOCS 8511070149
Download: ML20198B673 (4)

Text

I li e' de, UNITED STATE S

.p - ; NUCLEAR REGULATORY COMMISSION \

5 orrict or isvr Stic4TioNS ritto orrect. Ricios ivi,$, tt?.C '.

<w

<,,9,, ,,

g $11 RYAN PL AZA ORIVE. SUif t 1000 ARLINGTON. TE X AS 76011 , g }'/

)h / - r January 29, 1985 '.,' Oci s'

\

MEMORANDUM T0: Ben B. Hayes Director. 01 o 2OkJLt ynRichard K. Herr FROM:

Director. 01 Field Office

SUBJECT:

REPORT OF INQUIRY (Q4-84-048)

Attached is Report of Inquiry Q4-84-048. This case is CLOSED.

Attachrent:

As stated g 10 g y e51015 VARRICC85-101 PDR

'.d ~

a

r-- . ,

u s. e.uctac.a enutavonv cowissio=

c eon see INVESTIGATION STATUS RECORD sr uci.o~s t - e... *. .,.. 4. . . .... ..... .,. . . ,ao<...ie .*. ,,.. . . . ,s.

me....-.-. .4..woi.- cm.. ~ ...,..%. .,...........e.,......,,.....

oao.......

c.se mv-.e . c.esoo , o. . .c s o o,....... ...c.o. . .. o...ov.i .c.. .. 0! flELD Off!CE REGION IV Q4-84-048 x c

....c..i.o.

co. .cu,o o. . _

= -. ....ts.. vet W %fenoO. . of g.

ai .. , o su. .ci DRISKILt. b'0LF CREEK GEtiERAllflG STA110N. UNIT 1:

,,,,,, ALLEGED REPRISALS AGAINST A FOPHER EMPLOYFE FOR ID[f4TifYING SAFETY ISSUES DATE: October 31 1984 -

This investigation is in progress.

I a n t i c i p .i t e completion of investigation during the December 1984/ January 1985 time frame. ECD: Unknown DATE: November 30 198'. - This investigation in in progress. I anticipate completion of investigation during the Spring 1985 t ime frame. ECD: Unknown Y

\ #

n'g /,$y . , . Y-

\ e

\n .

,. b, *

<', y? . P / l' r x y;

,,,y"~p- ;. +A p ' '

v'yp . p '" ' , p. u., u e ,', ;(;% ,3 .-

f7 y 'p . ,A 7 ) f ,

%s f', .\)V W p

~' \

6 4 .<

y2 t'

T v

ds y f ' ' , j, ' e } .

4 q'

,) .

.; E x/ i  %

.e, \

\ L ,v

-b v>

s.a p[_ s, 4*, n g, Af ,f

- \ ,

.w-.

L' '

r v',y\}s -

ye p

f h_._______________

b

_y%

e 9

4 I '

1

\

\ \

i 6

\

\ '

\

\ ,

\\

,--s, sen , w - 2.vs t N

~

\

1

,e

}i ~ )

r m

,o*

g e e

/ 7 A c e A/ -

T.ta 9Vy afdye di we 5: /Om l/l6.cr-<~#~

e F

]~.4 n n y M / W - G l u Olsdbut (7feesy '

Yo .zdx an we 78cessen -ppn ///jg&t -

WY C dtY t W $^.} h & ,

/

l l

l l

m__-.-_--- -_---------__--_-.-______--__----______________..---___________.._-__.-a

n m

KANSAS GAS AND ELECTRIC COMPANY

• • 18 EJCtnC Cos epa w **v O k a se se L aosatsa N .etteet=' mwchaam December 31, 1984 M . Richard C. DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Cocraission hY.r->

Washington , D.C. 20555 ,}lM , gg ,

KMLNRC 84-237 .

P.: : kc ke t L . 3T;i 50-L '

Reft Letter KMLNRC 84-233 from GLKoester, KGLE, To RCDe Yo ung , NRC Subj : Enforcement Action 84-107

Dear Hr . De Yo ung :

The Reference provided Kansas Gas and Electric Company's (KG&E) response to the " Notice of Violation and Imposition of Civil Penalty" relative to Enforcement Action 84-107. In that response, KG&E doctraented the extensive corrective actions taken to resolve the concern and provide assurance that the quality of construction meets or exceeds applicable requirements. Baried upon the actions taken, KGLE believes the amount of the Civil Penalty is excessive and should not have been escalated by 50%.

Notwithstanding our right to request mitigation of the Civil Penalty, we are enclosing a check in the amount of 175,000 made payable to the Treasurer of the United States. Further debate over the issues which gave rise to the Civil Penalty is not likely to be productive. In this case, our resources will be batter spent in working cooperatively with the NRC to complete the quality construction and licensing of Wolf Creek Generating Station.

Ya e se g ,,* y t e nl y 4N A } f etan ~ m f(7 Glenn L. Koester Vice President-Nuclear GLK ke Attach CERTIFIED MAIt g,, qp',.y; n. qp jf.l p,* ,jj xc : RDMartin, Reg.IV (M\ N 1"'k RPDenise 01 8 l'V G- mf C.D s

P0'Connor (2)

HBundy 21!1. 'G*O n-i+; ,7: .m 209 N Market - Wctuta, Kansas - Mad Address: P0. Bos 200 i Wctwte, Kansas 67209 .- Telephone: Area Code (3 t6) 26I.645I

~

r q

.v KANSAS GAS AND ELECTRIC CDAfPANY

% ea:=c cwe, December 31, 1934 oLEN= L motstaa vet 8 8et.ete=* enesC6sae Mr. Richard C. DeYoung Director Office of Inspection and Enforcement U.S. Hu: lear Regulatory Cocrnission Washington , D.C. 20555 KMLNRC S4-238 Re: Docket No. STN 50-482 ,

Ref: 1) Letter dated 11/21/84 from RDMartin, NRC to GLKoester , KG&E g.4g

' '; , j

2) Letter KMLNRC 84-234 dated 12/21/84 from ,,

GLKoester, KG5E, to RCDeYoung, NRC. l~

Subj: Enforcement Action 84-107

Dear Mr. DeYoung:

Enclosed is Kansas Gas and Electric Company's (KG&E) response to Violation I (Violation Assessed Civil Penalty) as doctnented in Reference 1. Pursuant to 10CFR2.201, the following five items are addressed in the Enclosure for the alleged violation:

1. Admission or denial of the alleged violation;

2. The reasons for the violation, if admitted; 3 ne corrective steps that have been taken and the results achieved;

4. The corrective steps that will be taken to avoid further violations; and

5. We date wnen full compliance will be achieved.

KG&E's response to Violation II (Violation Not Assessed Civil Penalty) was transmitted by Reference 2 which also doctnented the agreed upon extension for the response to Violation I.

Please contact me or Mr. Otto Maynard of my staff if you have any questions concerning KGLE's response to the alleged violation.

Yours very truly, L et.J%

(cr - Glenn L. Koester ,)

Vice President - Nuclear GLK ke xc: RDMartin w/o ,_

RPDenise w/a P0'Connor w/a

, j/(

HBundy w/a # '

/L 201 N Market -Wictete Mensas - Mad Address. PO Bos 208 I Wicture. Kansas 67201 - Telephone Area Coce (3t6) 26t-045 t /

o jhs Enclosure to KMLNRC 84-238 VIOLATION ASSESSED CIVIL PENALTY FINDING Criterion X f 10CFR Part 50, Appendix B, requires that a program for inspection of activities affecting quality be estabished and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.

, ,. Criterion XVI of Appendix B further requires that measures be estabished to assure that nonconformances are pranptly identified and corected.

Criterion XVII requires that sufficient records be maintained to furnish

,;~ evidence of activities affecting quality.

Daniel International Corporation (DIC) Construction Procedure No. QCP-VII-j

• _' 200 describes the requirements for performance and inspection of safety-

]

related structural steel welds with respect to committed conformance to the American Welding Society (K4S) D1.1-75. Appendix I in Revision 4 of this procedure invokes a prohibition with respect to lack of fusion, overlap, l' slag, are strikes, and weld splatter. Paragraph 6.5.1 of AWS D1.1-75

s requires inspector verification that the size and length of welds conform to the drawing requirements and that no specified welds are omitted.

Contrary to the above, the inspection program for safety-related structural steel welds was not adequately executed to assure conformance to the requirements of Construction Procedure QCP-VII-200 Revision 4 and the AWS D1.1-75 Code nor were adequate records kept to document the quality of the welds. Furthermore, once deficient welds were identified, no actions were i

taken to correct the deficiencies. This inadequate inspection program and .

the failure to take corrective actions is evidenced by the following:

1. A random reinspection of 241 structural steel safety-related welds, t which was made in accordance with Revision 4 of QCP-VII-200, was performed by DIC and documented in Corrective Action Report (CAR) No.1 'd-0029 dated March 22, 1983 Sixty-two percent of the inspected welds were found by the r DIC inspectors to not conform to the requirements of Revision 4 of QCP-VII-zn 200. The reported defects that resulted in rejection by the DIC inspectors included are strikes, slag, lack of fusion, overlap, .and weld splatter.

2. Another reinspection of a sample of structural members with lowest

/ design safety margins was initiated on September 14, 1984 The results of the licensee reinspection activities (verified by NRC inspectors) as of September 28, 1984, were as follows:

s

r e v

a. A missing weld was found at the same location in each of six pressurizer support connections. In addition, five of 14 fillet welds in one pressurizer support connection were undersized by 1/S-inch to 1/4 inch with respect to the drawing-required size of 5/S-inch, and two of these welds were also under the required length; i.e. 3-inch and 5-inch lengths, respectively, versus drawing-required length of 8 inches. The weld dimensions of the remaining five pressurizer support connections were not included in the NRC verification activity.

b. Reinspection of nine structural steel connections in the auxiliary building identified two missing welds in one connection. In addition, weld size and length discrepancies were identified in each of the nine connections. Of the total of 106 welds in the connections, eight were found to be undersized by 1/16-inch to 3/16-  !

inch with respect to drawing-required width. Two of the undersized welds were also under the required length; i.e., 21/4-inch and 2 1/2-inch lengths, respectively, versus a drawing required length of 3 inches. An additional nine welds were also under the drawing-required length of 3 inches by 1/2-inch to 1-inch. Examination of 54 weld returns in the nine connections found 26 to be undersized by 1/16-inch to 3/16-inch with respect to drawing-required widths. One of the undersized weld returns was also under the required length; i.e., 2 inches versus a drawing-required size of 3 inches. In addition, 36 weld returns exceeded the drawing-required maximum length of 5/8-inch by 15/8-inches to 3 5/B-inches. An additional eight weld returns exceeded the drawing-required maximum length of 3/4-inch by 1/2-inch to 2 1/8-inches.

3 The absence of required Miscellanious Structural Steel Weld Records (HSSWRs) for documenting welding and inspection of safety-related structural steel welded connections was identified by KG&E in CAR No.1-C-0031. As a result of this identification it has been established that approximately 16 percent of MSSWRs could not be located, which precludes positive verification of control of welding and performance of required inspections.

Approximately 80 percent of the MSSWRs applicable to the activities described in paragraph 2 above could not be located. Records were not available to indicate that an initial inspection was performed of either the pressurizer support connections or the auxiliary building strutural connection which was identified to be missing two welds.

MSSWRs were located for certain welds in four structural connections which indicated acceptable welds. How2ver, reinspection of these four connections showed one undersized weld in one connection and undersized and overlength weld returns in the four connections.

RESPONSE

1. Admission or denial of alleged violation; Kansas Gas and Electric Company (KG&E) does not dispute that problems existed in the inspection and documentation of safety-related structural steel welds. However, KG&E does take exception with one of the statements documented in the NRC's Notice of Violation and Proposed Imposition of Civil Penalty.

,- W y g k ,5v(1 JAN 0 81F Docket No. 50-482 Permit No. CPPR-147 EA 84-107 Kansas Gas and Electric Company ATTN: Glenn L. Koester Vice President - Nuclear P.O. Box 208 Wichita, Kansas 67201 Gentlemen:

This will acknowledge receipt of your letter dated December 31, 1984 and your check for $75,000 in payment for the civil penalty proposed by the NRC in a letter dated November 21, 1984. The corrective actions described in your letter will be examined during future inspections.

Sincerely, OrigM sgned gy M L 4xekad Jane A. Axelrad, Director -

Enforcement Staff Office of Inspection and Enforcement Distribution PDR SECY CA ACRS JTaylor, IE RMartin, RIV JAxelrad IE BBeach, IE Enforcement Coordinators RI, RII, RIII, RIV, RV JLieberman, ELD VStello,DED/ROGR BHayes, 01 Sconnelly. 01A JCrooks, AE0D HDenton, NRR EA File ES File e g ,LL.0Z /-

DCS l -- \$

IE:EM b BBeach 1 rad 1/$/85 /85 L=