ML20198B682
| ML20198B682 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/14/1985 |
| From: | Emerson M, Herr R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198B650 | List: |
| References | |
| FOIA-85-101 Q4-84-052, Q4-84-52, NUDOCS 8511070155 | |
| Download: ML20198B682 (3) | |
Text
f UNITED ST ATES l
. ? }
NUCLEAR REGULATORY COMMISSION
,f OFFICE OF INVESTIGATIONS FIELD OFFICE. REGION IV L
- "INd$ON. TE" f5 REPORT OF INQU1RY Mr.
'a
SUBJECT:
WOLF CREEK GENERATING STATION:
ALLEGED FALSIFICATION OF A WELDING RECORn REPORT NUMBER: Q4-84-052 On November 19, 1984, NRC Region IV Regional Adr G
- e '*' s rt D. MARTIN e
requested an inquiry / investigation regarding thi -
s@*
.wo questionable weld inspection records at the Wolf Creek facility.
2 advised that during the inspection effort, documented in NRC Inspection Report No. 50-482/84-22, dated October 26, 1984 (Exhibit 1), Kansas Gas & Electric Co. (KG&E) informed the NRC that a previously inspected and accepted weld (524B2) was found, in actuality, not to exist.
MARTIN explained that further investigation by the licensee revealed a second weld (95B5), which reportedly had been inspected and accepted, was also found not to exist.
On February 27, 1985, a public meeting between NRC and KG&E was held in Bethesda, Maryland, to address the miscellaneous structural steel welding deficiencies discovered at the Wolf Creek facility.
A review of the meeting's transcript revealed a statement made by Bill RUDOLF, KG&E Quality Assurance (QA) Manager at Wolf Creek, in which RUDOLF states, "The missing welds, the missing material also represented a QA program breakdown" (Exhibit 2, transcript excerpt page 66).
This transcript also reports John C. BERRA, Daniel International Corporation (DIC) Vice President of Operations, stated that as a result of the two nonexistent welds, an extensive investigation was initiated and it was determined that the two incidents occurred due to unintentional human error (Exhibit 3, transcript excerpt page 105).
On March 15, 1985, Richard P. DENISE, Director, Division of Reactor Safety and Projects, Region IV, NRC, was interviewed (Exhibit 4) by NRC Investigators M. EMERSON and R. K. HERR.
DENISE was questioned regarding his knowledge of two reported cases in which welding inspection documentation (Miscellaneous / Structural Steel Weld Records [MSSWR]) existed for nonexistent c
welds as documented in KG&E Corrective Action Report No. 19 (CAR 19)
(Exhibit 5, transcript excerpt pages 27 and 28 of the CAR 19 Executive Summa ry).
DENISE explained that as a result of the discovered structural steel problems, including the missing welds (Exhibits 6 and 7), the NRC Task Force formed in July 1984 determined that a significant violation of NRC regulations had occurred as described in NRC Inspection Report No. 50-482/84-22. DENISE stated the NRC sent enforcement correspondence, a Notice of Violation, to KG&E on November 19, 1984.
DENISE said KG&E issued CAR 19 to obtain the necessary actions required to resolve structural steel problems.
DENISE related DIC personnel, in response to CAR 19, conducted a 100 percent reinspection of accessible structural steel welds and discovered the second instance in which a weld 95B5 previously reported as inspected and accepted (Exhibit 7) did not, in fact, exist.
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VARRICC85-101 PDR
q Q4-84-52 I
i DEt[ISEexplainedthefirstmissingweldwasdiscoveredbyDICduringtheweek of September 17, 1984, and involved the installation of beam no. 524B2 (joint no. AF) within the Auxiliary Building.
DENISE said the NRC became aware of this on September 20, 1984, by DIC personnel, and a review of the pertinent drawings, during KG&E CAR 19, revealed the beam configuration and floor layout in the area directly beneath the beam connection in question are very similar.
In addition, the beam below welded connection 524B2 connects at the same building coordinates.
DENISE said KG&E CAR 19 reported that the DIC inspector in question, Randy SMITH, possibly could have been one elevation beneath where he should have been when inspecting the welded connection.
DENISE said a detailed review by DIC verified SMITH had perfonned more than 800 structural steel welded joint inspections. DENISE said that DIC's detailed review and subsequent overviews by KG&E and the NRC of SMITH's work revealed this single inspection error.
DENIdE reported that DIC management personnel telephonically interviewed SMITH; however, SMITH was reportedly unable to recall this particular weld inspection.
DENISE stated DIC management concluded that human error was the root cause of this missing weld, which was concurred in by Region IV, NRC.
DENISE advised that a second similar incident v s discovered on October 8, 1984, by DIC and involved a joint connection identified as 95B5 (joint no.
C036) within the Control Building.
NRC was notified within several days of this finding by DIC.
The questioned joint connection was reportedly inspected and accepted when, in fact, a weld within the joint did not exist.
DENISE said a joint of this nature may contain up to twelve separate welds.
DENISE stated that the DIC review of the MSSWRs depicted the DIC inspector in question, Veryl BARB, as being confused when documenting the questioned welded connection on the MSSWRs.
BARB apparently incorrectly filled out a joint I
number, lined through and initialled his mistake, and subsequently entered l
another incorrect number on one of the MSSWRs in question.
DENISE identified two MSSWRs (Exhibit 7) documenting the questioned joint.
DENISE stated, after reviewing the two MSSWRs, "it is clear that BARB demonstrated his confusion as to the correct entry of infonnation on inspection documentation." DENISE related a DIC review of BARB's perfonnance revealed this inspector had completed 183 MSSWRs; however, only six MSSWRs related to structural steel weld inspections.
DENISE said all six inspections made by BARB were reinspected by DIC and no additional discrepancies were discovered.
DENISE i
stated DIC and the NRC Technical Review Team (TRT) believed BARB probably intended to document the welds attaching the beam clips to beam 95B5, since no retrievable MSSWR's are on file for these welds. DENISE said DIC concluded this missing weld was caused by the human error of an inexperienced inspector and documented the incident on Nonconfonnance Report No. ISN-20798CW. DENISE stated only the two described cases were identified in which inspection documentation existed for nonexistent welds.
Investigator's Note:
BARB's whereabouts are unknown; therefore, he was not interviewed.
In consideration of the following:
(1) the licensee's detailed reinspection of welds attributed to the two referenced QC inspectors revealed no additional discrepancies, (2) the admission of the KG&E QA manager that missing welds represent a QA program breakdown, (3) the acknowledgement of DIC that these two welds caused an immediate investigation to resolve the issues, and (4) the absence of evidence of willfulness or intent on the part of the concerned 1
2
Q4-84-52 parties regarding the issue of the missing two welds has been, in 01's view, appropriately addressed.
No further investigation of wrongdoing in this case is anticipated, and this inquiry is closed.
Investicator's Note:
Exhibits (1) and (5) discuss numerous nonconforming areas, including missing welds.
These welds include the following two categories:
(1) missing welds that are not documented by MSSWRs and (2) welds which were initially inspected and accepted (MSSWR's) and subsequently rejected as nonconforming. These two welding categories were addressed in NRC Inspection Reports numbered 50-482/85-12 and 85-13 (Exhibit 8), which depict technical evaluation / analysis resolving these t
issues. A review of these inspection reports did not indicate evidence of willfulness / intent of wrongdoing.
Neither this report nor exhibits may be released outside the NRC without the permission of the Director Office of Investigations.
Internal NRC access and dissemination must be on a need and right-to-know basis.
EXHIBITS:
(1) NRC Inspection Report No. 50-482/84-22/10-26-84 (2) Transcript Excerpt Page 66 of RUDOLF at Public KG&E/NRC Meeting /2-27-85 (3) Transcript Excerpt Page 105 of BERRA at Public KG&E/NRC Meeting /2-27-85 (4)
Report of Interview With Richard P. DENISE/3-15-85 (5) Executive Sunnary and Conclusions Sections of KG&E's CAR 19/-Undated-(6) MSSWR No. 524B2/3-14-79 (7) MSSWR Nos. 95B5/6-14-79 and C529/5-22-79 (8) NRC Inspection Report Nos. 50-482/85-12 and 85-13/2-25-85 REPORTED BY:
gat r PARTICIPATING PERSONNEL:
//
4-f _
Richard K. Herr' Direc r APPROVED BY:
4A, Richard K. Herr -
Director cc:
B.B. Hayes w/ exhibits E.J. Gilbert w/ exhibits R.D. Martin w/ exhibits i
T.F. Westerman w/o exhibits i!
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]n Reply Refer lo:
Docket:
Siri 50-482/64-22 Kanses Gas and Electric Company ATT ri:
Glenn L. Koester Vice President - tiuclear P.O. Eo> 208 Wichita, Kansas 67201 Gentlemen:
This refers to the inspection conducted by Mr. R. G. Taylor and other personnel, of this office during the period of June 3] through September 28, 3984, of activities authorized by tiRC Construction Perr.it CPPE-347 for the Wolf Creet Generating Station, and. to the discussion of our fir. dings with Mr. F. J.
Duddy and other nembers of your staff at the conclusior, of the inspection.
Areas examined during the inspection and our findings are discussed in the enclosed inspection report.
Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors.
As discussed with you and your staff on site, we have concluded that a significant violation of fiRC regulations has occurred in the area of structural steel welding in that the inspection program for safety-related structural steel welding was not executed in a manner to ensure conforr:.ance with the requirements of the Construction Procedures ant' the ISAR com itneents.
Details of the inspection findings which support this conclusion art discussed in the enclosed inspection report.
A writter. com;irehensivt prograt f or the reinspection of structural steel weldinc, alonc with appropriate corrective action is required to bE submit ted to Region ]V.
In accordance with our discussions, KGLE will discuss their corrective action plans, and establish a date for submittel of the documcr.ted correction actior, plans, at a sneeting with tiRC on October 29, 1984.
The enforcement correspondence and Notice of Violation pertaining to the matter will be sent to you under separate cover.
Certain aspects of these findings will be referred to the _ Office of Investications for possible investigation.
An enforcement meeting on this matter is scheduled for l
October 29, 1984.
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EXHIBIT (1) j d
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l.cn3rt 'bes ent t iet t t u (v; e t.s Onc new unresolved iten is ider.tified ir. perecraph 4 of the enclosee report.
In accordance with 30 CFR 2.790(a), e copy of this letter and thE enclosurt will be placed it. the NRC Public Document Room ur.less you notify this of fice, by itlephone, within 30 dtys of the delt of this letter, and subtit writter, applicatior to withhcid information contained therein withir. 30 days of the date of this letter.
Such applicatior. rnust be cor.sistent with the requirements of 2.793(t-)(2 ).
Should you have any questions concerning this inspectior, we will be pleased to discuss ther. vith you.
Si n'c e rely, 3
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NK R. P. Denise, Director Wolf Creet 'last Force Enclosure :
Appendia. A - NRC Jnspection Report 50-4E2/84-22 cc w/ enclosure:
Kansas Gas and Electric Company Forrest Rhodes, Flant Superintendent ATTN:
Gene P. Rethbur., Mer.eger Wolf Creet Genereting Stetior, of Licensing P.O. Box 309 P.O. Box 205 Burlingtor., Kenses 66839 Wichita, Kansas 6720)
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U. 5. Kl* t ! A5 R! Gtli AlOh C 0".".) 5 51 Oh RIG)ON )V NRC Jnspectior. Report:
50-452/64-22 Constructior. Percit:
CPPR-247 s
Docket:
50-452 Category:
A?
Licensee; P.a n s a s G a s a nd E l e c t r i c C omp a ny ( 6,G!.E )
P.
O.
Box 208 Vi c hi te, P.a nsas 67202 Facility Name.
Wolf Creek Generating Station Inspection At:
Wolf Creek Site, Cof f ey County, Burlington, Kansas 2nspection Conducted:
June II through Septem$er 26, 1984 Inspectors:
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Tay[Section A, or, (lean Leader) Reactor ]nspector D/t/
R. G.
Project Reactor Froject Eranch 2 r
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E 11 e rshaw, Reactor Jnspector Datl
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Freject Sectior. A Reactor Project Branch 2
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M )A.
R.
Johnson, Reactor ]nspector Date y
Project Section E, Reactor Project Eranch 3
/$ ff F.. ' P. Mullikin, Reactor ]nspector Date Project Section A, Reactor Project Branch 2 1
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- l. Bess, Reactor J nspec tor, Frcject Section E Reactor Project Eranch 2 Approved-
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t'. 1L. Martip( Chief, Freject Sectier. A D ae. e <
Re actor Project Eranch 2 Inspection Sum.ary Inspection Conducted June li throvoh September 26, 1984 (Report 50-482/64-22)
Areas Inspected:
Routine, unannounced inspection of electricel separation, electrical cable tray and conduit as-built installations, struttural steel as-built welding installations, electrical craf tsman qualifications, procedures for penetration fire seals, and f ollowup on previous NRC findings.
The inspection involved 246 inspector-hours onsite by five NRC inspectors.
Results:
k'ithin the areas inspected, two violations were identified (f ailure to assure conf ormance of saf ety-related structural steel welds with requirements, paragraph 3, and f ailure to r.aintain adequate electrical separation, paragraph 4).
]n medition, one new unresolved iter is icentified in paragraph 4.
4 I
DE1All5 2.
Persons Contacted Pr i nc ipa l L icensee Erricyees
- F. J. Duddy, Cons t ructior. Mar.ager
- v.
M.
Lindsay, Supervisor - Quality Systers
- P. Dyson, Field Engineering Supervisor
- R.
Grant, Director - Quality
- R.
L. Stright, Licensing
- N.
V.
Hoodley, Nuclear Plant Engineer Da ni e l International Contruction, Inc. (D2C)
"J.
Berra, Vice President
- J.
Fletcher, Construction QC Bechtel Corporation "C.
M.
He rbst, As sistant Project Engineer
- G.
D.
Erown, Engineer The NRC inspectors also interviewed other licensee D3C and Bechtel personnel.
" Denotes those attending the exit interview.
2.
Licensee Action on Previout Inspection Findinos (Closed) Unresolved 3 ten (5D-462/77-D5-D3) ibis iten invol ed the batchir.;
of concrete f or mud mats" underlying the nuclear saf ety-related buildir.-
Eased on an interview with the reporting NRC inspector, this NRC inspt et.-
determined that the major issue involved was a lack of desire on the pe-t of the applicant to utilize a certified batch plant for mixing the concrete.
The NRC inspector was provided a Certificate of Conf orn.ance Mc t Concrete Production Facilities" f or the Penny Ready Mis plant in New Strawn, Kansas signed by a licensed professional engineer on May 9, 2577.
The certificate is suf ficient to satisfy the requirements of the LWA-2, the NRC authori2ation f or tne work involved.
(Closed) Unresolved 3 tem (5D-482/76-D4-D5) Containment Base Mat Ninety-Day Cylinder Breaks.
This iten. was superceded by Notice of Violation, Iten E of Appendix A to Inspection Report 5D-482/78-13.
.t.
(Closed) J nf raction (50-4E2/76-04-E) F ailure to Meet Concrett A: c e pia nu Crite ria f or Containn.e nt Ease Mat.
This iten was trans f e rred it. NER for evaluation.
The NRR evaluation and conclusion is conteined in the Saf ety Evaluation Report for the Wolf Creek station (NUREG-OBE3) at paragraph 3.E.4 (Closed) Unresolved itet (50-462/76-35) Pre-Planning F or Concrete Flacement.
This unre selvec iten was superceded by Appendia E Notice of Deviation incluced with Inspection Report 79-03.
(Closed) Unresc1ved 3 tee (50-4E2/76-35) Plating Limitations for Concrete.
This unresolved iten was superceded by Appendix A Notice of Violation included with Inspection Report 79-032 (Closed) Unresolved 3ter (50-462/79-03) Concrete Practices.
This unresolved iter was superceded by Appendix A, Notice of Violation, included with 3nspection Report 50-452/79-03.
(Closed) Unresolved 3ter (50-482/79-03) CFR Weld Deficiency of Unistrut Material.
The 50.55(e) report was discussed in Inspection Report 79-07 which satisfied the unresolved item.
(Closed) Inf raction (50-462/79-03) Tailure to Adhere to Concrete Flacenent Lieitations.
This inf raction was issued f or record purposes with corrective action inolicit within the licensee's response to Inspection Report 78-15.
This conclusion is consistent with statements contained within paragraph 5, Report 50-462/79-03.
(Civsed) Unresolved 3 tee (50-462/79-07) Observation of Concrete lesting Procedures.
Although not specifically documented, the inspection ef tert described in Inspection Report 50-4E2/79-09, paragraph II, by the inspector of record in report 79-07 is considered as res&l,ving the K,atter.
(Closed) Unresolved Iter (50-482/80-13-03) Review of Work Hold Ap-een,ent Number 23.
The wor 6 hold involved a contlict betwee n the Daniel International Corporation procedure for coating application inspa rtier. anc the applicable Bechtel specificatiore.
Bechtel letter ELK! 60D cated r
August 27, 1980, provides inf ors.ation on the resolution of the c.atte r suf ficient to warrant cancellation of the Work Hold Agreement in September 1980.
(Closed) Unresolva.d 3 ter (482/E335-01) This item required the licensee to determine whether the Bechtel requirement that flexible electrical conduit j
not be greater tnan 5 feet includes total length where the conduit is s upported.
The re were five safety-related instrument transmitters f ound in this catecary.
The licensee furnished the Bechtel design drawings for these transmitters which showed that a support was allowed for each.
This item is considered closed.
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4 3.
kelcinc of Structural Steel Durinc a revie of 04/0 ane Quality First personr.cl outlifictiions and subsehuent interviews, the hRC inspector became awirt of poter.tial protlers with corrective actior, reports CAR 29 and 3].
The NR: inspector but sequer.tly ottiined copies of the two docurer.u.
CAE 3-W-0D?9 (ir.ititted on P.erch ??,19E3) stctes, in part, *5ubseover.ily to tht isst,ance of CAE 3-k-0D)S, quality has ir.stitutec' i randor rtir.spection of accessible structurel steel fillet welds ir. all 0 buildings.
31 bes been otternined by the results of this reinspectior. that an ur.Eccen_able percentece of these welds are deficient in the au>iliary, control, end f uel buildings.'
Attached documentation revealec' thti in the av>iliary buildinc, @ welds were inspected with 53 bcing. rejected.
in the control and fuel buildings, 50 welds were inspected with O rejected, and 53 inspectec with 35 rejections, respectively.
hevisior. 2 tc. CAR 3-W-0029 stated ir. the disposition that the defective welds wPUld be transferred tC a Nonconformance Report (NCR).
The NRC inspector obtained a copy of NCR 35N 103E)PV which was used as the vehicle to carry.out the direction provided by CAR 3-W-0329.
It appears that D)C Pro)ect Welding Engineerint personnel again reinspected the welds to mcre clearly define the nature and extent of the defects on a weld-by-wtid t. asis.
A mijority of the oefective welds were categorized es htving **cosr.,ctic" defects.
Tht D)C recomended disposition was use-es-is for welds ider.tified containino
c osne t i c de f ec ts.
The NCR states that '1 cosmetic defects include arc strikes, convexity, cold roll (understood to be synonymous with overlep),
porosity, and acceptable amounts of undercut.
ThE NRC inspector noted with respect to these defects that overlap is prohibited by the governinc AL'S D).)-75 Code and specific acceptance criteria f or the other defects are alsc. defined by this Code.
The engineer accepted the D]C recomendatior, stating, "This disposition is based or the understending that the costretic defects outlined... of this NCR dc not constitute violations of AWS D].)-75.
A written-in note labeled 5NU'PPS cornent
statet. that D)C had confirmed the engineer's understaric'inc.
NCR 35h 1030 F,. wts cor:pleted as ir.dicatec abovt or August SC., 39E3.
Dr. August 10,19E3, D]C personnel issued CAR 3-C-0D3) which indicut(d that approxir.ately 16.4 percent of tht miscelleneous st ructural steel we ldinc
_recoros for 'T weldinc couici not be located.
After corresponcinc b6ct and f orth, un and the engineer conclucec that it was accept eble for some arnount of these records to be missing, provided that the ovelity inspectior, prograr was acceptable.
Senior licensee QA managerrent expresseo to the
~NRC inspector that the program had obviously been fully successful since very few welds had been found to require repair af ter a substantial reinspection effort associated with CAR 29.
The NRC inspector expressed concerr, wi'th this approach to resolution and suggested that the licensee reevaluate their position.
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.g.
l Dr. September 2 3, 2 964, the licensee, ir. c or.j unc t ier, with se nior D3 C r.e na pme nt personnel, made a presentation to the NRC las6 Force Director and ct her NRC stef f pe rsonnel, including the NRC inipector.
T he pre sentation was eined at the D)C ef f ort te provide act Quate records of l
'nspection of the structural welds.
lhis effort involved the inspection I
i et that point in time of 339 weld joints in the reactor building for which there appeared to be no records.
Of these, 4E we re f ound te not meet c ode /de s ign original requirements.
Several hec beer, reenely2ed by the engineer and f ound to provice adequate structural s trength and we re deemed to be us e-a s-i s.
- The NRC Task Force Director and the NRC inspector riet with the KG&[
Froject Director on September 34, 1964.
The NRC personnel inf ormed the l
project director that the NRC position was that NCR ISN 303E3PW had not
~ beer. properly dispositioned and that, there f ore, the unoerlying pretist f or the closure of CAks pt end /(13vas f a ul ty.
The NRC personnel steted that it appeared that the quality status of the majority of all structural steel welds was (t_
The project director proposed tc best indeterrinete.
have the engineer identify a group of structurel members with the highest design loads or the lowest design strength saf ety c.argin and to have these jcints inspected.
The NRC personnel indicated that night be one possible approach to resolution of the matter.
i During the week of September 27, 1964, a reinspection of the icentified structural members with the highest design loads or the lowest design strength safety r.argin was initiated.
The reinspection identified a i
number of welds which do not meet drawing requirements.
This information was presented to the NRC staf f during a meeting conducted on September 25, 2964
]n an ef f ort to confire certain of the identified conditions, the NRC inspector accompanied D]C welding inspectors into tht reactor building to observe specific, identified weld joints.
This observatiori confirmed the welding inspectors ' findings ; e. g., welds that are un'dersized and of insuf ficient length, lack of fusion, and missing welds.
lhe riss ine welds a re T ror. the same location in eten of si> pressuri2er support connections.
Certain of the other welds ir. the pres s urizer support connections were undersi2ed and of insuf f ic ient length.
Drawing No. C-D5 2904 shows that various length 5/6-inct welds a re required in 34
[
specific locations.
Four locations required a 5/E-inch fillet weld of E inches in length.
Tht actual welds in twc of t ht locations measured between 3/E-inch and 1/2-inch by 5 inches in length, and 3/2-inch by 3 inches in length.
The missing welds and the undersized, insufficient length welds are _ clearly not in compliance with the requirements of the drawing or AWS D3.3-75.7CThe initial weld inspection records for these connections could not be located.
The NRC inspector accompanied two OlC welding inspectors f or reinspection of nine structural steel connections in the auxiliary building.
Drawing i
ht. K6720, applicable tc. thest c or.ne c t i or.5, sho,ts )? weld lotetions per connectior, with certeir. of the welci requirint returns.
Reinspection of the wClds creo returns ir.volved prCrioec thf f ollovling surn.hri2ed ditt :
Missing welds 2
Wtles with insufficient length 9
Undersized welds 6
Unde rsirt welds with insuf ficier.1 length 2
Overlencth returns 44 Undersize returns 25 Undersize returns with insufficient lencth 3
The NRC inspector requested the initial weld inspection records for these welds anc returns ir, the 9 reinspected connections.
As of September 2E, 1984, the only inspection racords thet were located pertained to 30 welds and 6 returns in one connectior., and E weles and 4 returns in each of 3 other connections.
These records did not indicate that the wcids were anything other than acceptable.
The licensee informed the NRC inspector of a situation where one inspectior, record for connection 524E2, clearly indicated by an atteched sketch, the existence of the a wGtFthat reinspection found not to exist.
This problem will be followed up in conjunction with tht other structurel steel problems.
The NRC inspector madt a comparison between tht existing i,nitial inspection records and the results of the reinspection eff6,rt in order to determine tht validity of the initial records.
1ht initiel' records show:
that the 30 welds with 6 returns in one connectior, were inspected end accepted on December )), 3576.
The re ir.spectior. iot ntifiec: one undersizec' weld, othe r undersized and overlength returr.s, and threE overlength returns.
The ir.itial records for thc other three connections show that eight welds with f our returns per connectior, were inspected and accepted or. September E,1979.
The reinspection of thest Welds (nd returns identified two returns which were overlength bnd unn sized ano two returns which were overlenoth per connectior..
The failure to execute the required welding inspection program is a
)
violation of Criterion A of Appendix E to 30 CFR Part 50.
(482/8422-03)
)
4.
Observation of Electrical Separation (Class JE Cables)
M The NRC inspectors observed the completed electrical cable work for conformance to the separatior, criteria specified ir. the FSAR, IEEE standards and site procedures.
The specific areas inspected were the physical separation between redundant safety groups and between safety and r;arwvih t
.p.
horth [lectrical Fentiratior. Roor South Electrical Penetration Roon Control Roon Centrif ugal Chargin; Fump Rooms A and E Saf ety 2njection Pump Rooms A and B Lover Cable Spread Roon e
Upper Cable Spread Room Standby Diesel Generator Roor B Main Stean 1 solation Valve Room The f ollowing documents were examined during this inspection:
j Bechtel Drawing E-3R8900, Revision 3, detec July 13, 2984, " Raceway
=
Notes, Syr.bols & Details" Sechtel Drawing E-DID13(Q), Revision II, dated December 20, 1983, j
" Installation, 2nspectinn, and Testing Details f or Electrical Equipment and Cable" l
Bechtel Specification 3D46E-E-D(Q), Revision II, dated June 25, 1951,
" Electrical Design Criterie f or the Standardized Nuclear Unit Power Flant Syster (SNUPPS)"
Sechtel Drawing E-DIDDE, Revision E, deted December V, 3982, " Single Line anc Schematic Diagran Standards, hotes and Symbohs*
Daniel Frocedure WF-A-303, Revis ion 5, detec 5eptember 22, 1952, "Instellatior. of Cable" Daniel Procedurt WP-X- 3 04, Revision 34, dated F ebrua ry 9,1964, "lern.ination of Cable" Bechtel Drawing E-3R8900, Revision 3, states in paragraph 3.36.4 that:
"Minimun separation betweer, dif f erent Class 3E conduit syster.s and r.inimum separation between Class 3E conduit systems & non-3E conduit systems shall be 1"."
Separation shall be measured between the outside edges of the conduit."
9 Contrary to the above, the f ollowing observations were noted whe re the required r ininur separation was less than 3":
e Flex conduit 4J2035 (Class 3E) crosses within 3 inch of fles conduit 6J3175 (Non-Class 3E) in the Centrifugal Charging Pump Roon E.
Fle> conduit 403F37 (Class 3E) crosses within 3 inch of junction bc) 3U3203 (recondant Clas s 3E group) in Saf ety 2njection Pump Roor E.
l Flex conduit 4U3E7A (Class 3E) crosses within 2 inch of fles conduit e
IU3K45 (redundant Class 3E group) in the North Electrical Penetration K o on.
i e
Fles conduit 3U1285 (Class 30) crosses within 3 inch of flex conduit I
5J1224 (Non-Class 3E) in the Main Stean 3 solation Valve Room.
t Flex conduit 303282 (class 3E) crosses within 2 inch of flex conduit SJ2125 (Non-Class 3E) in the Main Stean. 3 solation Valve Room, Rigid conduit SC3009 (Class 3E) crosses within 3 inch of rigid e
conduit SCE51A (Non-Class 3E) in the Lover Cable Spread Room.
l Fle> conduit 4J3C55 (Class 3E) crosses within 3. inch of non-safety e
120 volt _A.C outlet QA1530 in Standby Diesel Generator Roon B.
Bechtel Drawing E p3013(Q), Revision 22, requires the f ollowing:
Par.agraph 5.E.3.b "Within the control boards and other panels a.
associated with protection systems, circuits and instruments of different separation groups shall be independent and physically I
separated horizontally and vertically by a distance,of 6 inches."
l i
b.
Faragraph 5.E.3 "Non-saf ety related circuits shall be separated f ror Class 3E circuits by the same distances applicable to Class 3E circuits of dif f erent groups."
i Contrary to the above, the following cables within cabinets or pancis in i
the control root were f ound to have less than the required 6-inch rinimu" l
spacing:
Cables 45B50 BAD and 45B508DD (Class IE) are within 6 inches of cable 55C301AE (Non-Class IE) at the floor penetration of cabinet RLO25/026.
t Cables 1EJG09CD and IEM313AD (Class 3E) are within 6 inches of separation group 4 vendor wiring at the base of cabinet RLO17/018.
Cable 25B508AC (Class 3E) is within 6 inches of non-class 3E cables 55BS508CC, 55FA16BB, 55F511BG, 55F511BF, 55FR16BA, and 55FY11AC in the main control board panel.
}
I
3 C'-
Cabit 45E506AC (Class 1[) is within 6 inthes of st ve ral bundled separation group 5 non-class ][ cables in the s.ain control board panel.
Two e marples are cables 55B207AJ and 55B207AA.
Cables 45E506AE, 45E50EBE, and 4EM317EA (Clas s 3[) are within E inches of c able s 35E505AE, 35E50BCE, and 3f M337AA (redundant Class 3[ group) in the sein control board panel.
Eechtel sent to the NRC inspector, Startup field Report ($F F) 3-Rt-33 which details additional separation violations in the control room.
1his SFR, along with the exampics noted by the NRC, show a widespread probler in internal panel and cabinet electrical separation.
The abeve examples are a violation of Criterion V of Appendix E to 30 CFR Fart 50.
(482/6422-02)
The NRC inspector also observed several installations of flexible electrical conduit which had the required 3 inch separation, but due to certain postulated events could violate the separation criteria.
T he f
installations noted were those where the flexible conduit dropped in air froe rigid conduit to safety-related equipment.
During events such as
[
equipment vibration, transnitted hydrodynan.ic loads, or seismic events, the flezible conduits could cor,e within 3 inch of redundant conduit.
1he Tc11oving cases were observed:
Fler condwit 3J3033 (Class JE) crosses flea conduit SU1378 (Non-Class 3E) at per >s DP-EM-01A in Centrif ugal Charging Pump Room A.
Flex conduit 3J3035 (Class 3E) crosses flex conduit 5J3255 (Non-Class 3E) at pump DP-EM-01A in Centrif ugal Charging Pump Room A.
Fles conduit 30:30 (Class 3E) crosses flex conduit 4'0)22E (Non-Class 3E) et pump DF-EM-02 A in Centrif ugal Charging Pun.p Room A.
Flex conduit 4U1297 (Clas 1E) crosses flea concuit 6J1339 (Non-Cies s 3[) at MilV AE-HV-033 in the u.ain steam isolation valve root.
Flex conduit 4U3295 (Class II) crosses rigid conduit 3U1333 (reduncant Class 1[ g roup) a t MS 3 v AE - KV- 014 i n t he e.a i n s t e am isolation valve room.
Cables f rom riser 3U3203 (Class 3E) air drop to cable bushings of BOP computer cabinet RJ159A and flex conduit 6J2055 (Non-Class 3E) at top entry to cabinet RJ359A in the north electrical penetration room.
These examples need to be evaluated by the licensee for safety significance and generic implications.
Pending this evaluation, this item is considered unresolved.
(4B2/8422-03) l i
___ 5.
As-Built Verificetion of Electrical Raceways ihr NRC inspectors selected several Class Il conduit and cable tray runt located in the reactor building, control building, and auxiliary building f or verification of actual installation against the latest approved design crawings.
i t.c inspection was linited to an exanination of the f ollowing-Location and routing Supports Separation Loading (cables physical and thermal) 3 dentificetion (conduit and tray)
Additional inspections will be performed by other NRC inspectors at a later time.
A total of 765 feet of cable tray and 335 f eet of conduit were inspected.
The f ollowing is a list of documents e xamined:
Bechtel Drawing E-3R3431, Revision 0, dated Aprli 26, 2964,
Raceway Plan - Auxiliary Building - Area 2, E1. 2026'-0" "
Bechtel Draving E-3R3423, Revision 2, dated June 25, 1984, " Raceway Plan - Auxiliary Building - Area 2. El. 2026'-0"
- Bechtel Drawing E-3R3&43, Revision 2, dated April 26, 3954, " Raceway Plan - Auxiliary Building - Area 4, fl. 2026'-0"
- Bechtel Drawing E-3R3431, Revision 0, dated June 35, 1954, " Raceway Plan - Auriliary Building - Area 3. E1. 202E'-O "
Bechtel Draving [-3R3433A, Revision 2, dated Junt 23, 1954, " Exposed Conduit - Auxiliary Building - Area 3 E1. 202E '-0" Bechtel Drawing E-2R3443C, Revision 2, dated July 13, 1964, " Exposed Conduit - Au>iliary Building - Area 4 E1. 2026'-0" "
Bechtel Drawing E-1R3712, Revision 1, dated June 28, 1964, " Raceway Plan - Control Building - Area 1 El. 2073'-6"
- Bechtel Drawing E-3R3512,, Revision 3, dated June 23, 1984, " Raceway Plan - Control Building - Area 1, El. 2032'-0"
- Bechtel Drawing E-OR3734, Revision 6, dated October 28, 1982,
" Exposed Conduit - Control Building - Area 2, E1. 2073'-6" "
- 3 ?-
Eec hte l Drawing E-3 R3534, Revision 4, cated October 4 3964, " Exposed
+
Conduit - Control Building - Area 2. E 1.
2032'-0"
- Bechtel Drawing E-3R2423, Revision 0, dated May 33, 1984, " Raceway Partial Flan - Reactor Building - Area 2, El. 2026'-0" "
Eechtel Drawing E-2R2423, Revision 2, dated August 4, 1954, " Raceway e
Flan - Re ac tor Building - Area 2, E 1. 2026'-D"
Bechtel Draving E-2R2432, Revision 2, dated May 3, 2964, " Raceway
+
Plan - Reettor Building - Are a 2 E1. 2026'-0" "
Sechtel Draving E-2RB900, Revision 2. dated July II,1954, " Raceway Notes, Symbols and Details" The f ollowing Bechtel typical cable tray ' support details were reviewed; C-0403, Revision 24, dated January 23, 1954 e
C-0402, Revision 25, dated March 6, 2984 e
C-0403, Revision 29, dated February 22, 1964 e
C-0404, Revision 2E, dated April 26, 2984 e
C-D405, Revision 9, dated April 24, 1984 e
C-040E, Revision 0, dated June 26, 1984 e
C-0409, Revision 23, dated April 26, 2954 e
C-0423, Revision E, dated November 4, lae3 C-0434, Revision 9, dated April 20, 29E3 e
C-0420, Revision 4, dated October 23, 19E3 e
2 n addition, the following Bechtel typical conduit support details were examined:
C-0602, Revision 18, dated February 22, 1984 e
C-0602, Revision 19, dated April 16, 1984 e
C-0603, Revision 13, dated February 7,1984 C-06D4, Revision 27, dated May 14, 1964 e
C-0605, Revision 27, dated March 6,1984
1
- 3 3-1 he NRC inspectors ntied the f ollowing disc repancies during the inspectior, et cable trays and conduit:
A loose bolt where the F306E angle clip attaches the F3003 horizontal brace to the F3003 vertical brate at tray support 142-005E at e le vat ion 202E '-0" in the auxiliary building.
T he angle clips f or trays 403B52 end 4J3E52 on support 343-0026 are 3 L, inches in length versus the required 4 inches.
These are located at elevation 2026'0" in the auxiliary building.
Tray 4C8FE7 has three out of four P-306E angle clips rissing on its two supports at elevation 2073'-$" in the control building.
Cable 3RPY20M is unterninated, coiled, and supported by cable ties instead of required supporting r.aterial.
This cable is located above tray 2C8F5E et elevation 2032'-D" in the control building.
The discrepancies were shown to Daniel QC personnel who confirmed the first two discrepan:ies.
A work order is being issued to correct ther.
Daniel showed the NRC inspector that tray 4C8FE7 was connected to the vertical support by c'irect bolting as allowed by an alternate support detail.
Cable 2RFY20AA was f ound to be a deleted cable.
These discrepancies represent isolated cases considering the large number of supports inspected.
No f urther action is required.
E.
As-Euilt Verification of Electrical Cables The NRC inspectors selected thirteen Class 2E electrical cables to verify that routing and separation confor1oed to design documents.
The f ollowing cables were inspected:
Cable 7 ray Syster 2AL]O3AA Jnstrumentation Aux. Feedwater IALG02CE Control Aux. Feedwater 3ALG04CE Control Aur. Feed.ater 2BBG39AC Control Reactor Coolant IBB538M 2nstrumentation Reactor Coolant 3GNG02CC Power Containment Cooling 3GN502CG Power Containment Cooling 3GN302AC Power Containment Cooling 3GN302AG Power Containment Cooling 2NGG01AJ Power 4BOV Syster INGG01BF Power 480V Systes 45E501DA 2nstrumentation Reactor Protection 45E504BA Control Reactor Protection There were no violations or deviations identified.
.M.
7.
Review of Procedures (Penetration Fire Seals)
The NRC inspector reviewec thE B&E insulation, Inc., procedures for thE installation of Redflex (flexible fire-radiation barrier) and High Density t
Lead [lastomer (solid fire and radiation barrier).
These documents were examined to assure compliantt with NRC requirements and licensee co mitmer15.
The folicwing B&E procedures were examined:
1030.312,
- Installation Procedures - B&E Insulation, Inc. -
Radflex Seal, Issue F, dated February 16, 1954
~
103C.))4, Installation of B&B Insulation Radflex Sealant Material Using a' Mono-Pump Dispensing System, Issue 0, dated May 2,1984 103D.232, Proprietary - Proportioning, Pre-Batching and Blending B&E Radflex Components ALB for Mono-Pump Application
- 370?.10), Instellation of Hi-Density Leaded Matrix *, E Issue, dated
~
Februa ry 36, 1954 1703.302,
- Repair, of High Density Leaded Elestomer Penetration',
D Issue, dated February 16, 1984 3703.123, ]nstallation of Hi-Density Leaded Matrix Annulus Reducing Se a l s
3703.20),
- Proportioning & Pre-Blending of B&B Hi-Density Leaded
~
Matrix Components A&B", E 1ssue, dated February 27, 1984 ho viola tions or deviations were identified.
L.
- Levie, t' honconfomante Reports, Desion Chance Notices and Field Chance heouests (Safety-Relatec Conduits and Cable Trays)
ThE NRC inspector reviewed eight Daniel Construction Inc., Field Change Requtsis, three nonconformance reports and five design change notices relative to the installation of safety-related conduits and cable trays.
The documents were reviewed to detemine whether the records were lecible,
~
complete, reviewed by QC personnel, readily retrievatile and reflect "as-built" conditions of safety-related conduit and cable trays.
In additior., the records were examined to detemine whether nonconformances i
and changes were adequately described and included in the status of the corrective action or resolution.
l l
I
35-l The f ollowing records were exar.ined:
NCR's DCN's F C F. ' s 35N27957E C-0404(Q)35 3-53E7-E 25N373?3E C-04 04 (Q)34 3-5246-E 25N4986E C-0404(Q)30 3-5133-E C-0404(Q)9 3-5?63-t C-D4 04 (Q)E 3 - 5370- E 3-523E-E 3-5466-E 3 - 544 3 - E No violations or deviations were identified.
9.
]nterviews with flectrical Terr.inatior. Personnel The NRC inspectors interviewed two D3C personnel who performed actual terr.inations of Class 2E electrical cable.
The two employees' training records were reviewed also.
Both exhibited adequate technical knowledge as well as the understanding of procedure requirements.
No violations or deviations were identified.
20.
Unresolved items Unresolved iters are r.atters which require more inf orn.ation to ascertain whether they are acceptable items, violations, or deviations.
One unresolved iten is identified in paragraph 4.
II.
Management Interview 1he NRC personnel met with licensee and D3C management pe ' onnel as noted s
in earlier paragraphs of this report.
The NRC personnel met with the licensee personnel noted in paoraph 2 to express the f ull results anc conclusions pertaining to this inspection.
l l
1 Q4-84-052
\\
2240 05 07
. 0'3 se 1
KRBab 1'. cirOCdy b2cn comp 10ted, I think it is readily apparent fron 2
some of the other presentations that the causal effects of 3
record retrievability were there and did need to be enhanco 4
and have been enhanced.
5 The missing welds, the missing material.also 6
represented a OA program breakdown.
7 From a quality perspective, all the controls 8
incumbent in the program to prevent these things are in :fac 9
there, and I think again in our presentation if will be 10 stated why, in my opinion, I don't believe we need any 11 additional corrective action, either corrective action 12 immediately or corrective action to prevent recurrence.
13 MR. EISENHUT:
If I could ask ancther general b'ould yo 14 qu,e s ti on, not just in CA'R-19 but in previous ones, 15 answer Harold's question the same way?
That,i s, the lesson 16 l etrr.e6 f rom the other or.es tht go back to the carlier 17 issues all the way through 31, are there timilar kinds of 18 findings there?
Or how do they relate to these kinds of 19 findings?
20 "R.
P.UDOLFH:
As part of our less ons-learned
'2 r r r.:: r s, : ev;1 I t c-5 rr haf cv;2ut cd c.-ry :crrc-etivc a
22 action request initiated by my organization.
In the same 23 manner we also had evaluated for sicilar rect-cause effects 24 every corrective action request generated by the Daniel 25 Corporation.
And there were no adverse findings upon the EXHIBIT (2)
Q4-84-052 2240 08'07 1
WRBagb 1
k 105 We did an inspection of the structurally 2
significant joints.
3 We did an investigation of ndssing welds with 4
primary records.
During the secondary inspection plan, we 5
looked at over 11,000 structurally significant welds.
We 6
found two welds on separate joints in, separate buildings 7
that inspected by two different inspectors -- we fotnd 8
those two welds missing and we found a record that said the 9
weld was there.
10 Now we did an extensive investigation into that, 11 including interview of one of the inspectors -- both 12 inspectors were no longer at the site at the time of the 13 secondary inspection and neither were employed by Daniel at 14 the time of the secondary inspection.
We,did a hardware 15 review and a documentation review and found the occurrence 16 lini;r.d sc these two cases cut cf the in c::ce ss of 11,000 17 welds locked at.
18 Our conclusion $s that this was an error, an 19 unintentional human error.
I could 9 into more detail but 20 there vas an extensive review of that that becked that up 21 and it is included in CA.R-19 in the rummary.
22 During our inspection -- our re-inspection, we 23 dccumented the construction configuration of the joints.
24 Previously I stated in the primary inspection you went out 25 and inspected the weld -- maybe all the welds in a joint, i
EXHIBIT (3) i
Q4-84-052 REPORT OF INTERVIEW WITH j
Richard P. DENISE l
On March 15, 1985, Richard P. DENISE, Director, Reactor Safety and Projects i
Division, Region IV, NRC, was interviewed by NRC Investigators M. EMERSON and i
R. K. HERR at the Office of Investigations, Region IV, NRC, in Arlington, Texas.
DENISE advised he was also serving a collateral duty as Director of the NRC Wolf Creek Task Force, formed in July 1984, which monitored the safety-related structural steel problems at the Wolf Creek Generating Station (Wolf Creek).
DENISE was questioned regarding his knowledge of the Wolf Creek Quality Assurance (QA) program and, in particular, NRC Inspection Report No. 50-482/84-22, which identified a welded connection inspection record for
)
which the individual weld did not exist.
DENISE explained that the missing weld was identified by DIC Quality inspectors during a sample reinspection and that a similar condition was found at another welded connection during the subsequent 100 percent reinspection of all safety-related structural steel at Wolf Creek. DENISE acknowledged that these reinspection programs had been instituted at the request of the NRC Task Force after numerous deficiencies were discovered in the fabrication and erection, inspection, and records i
retention activities, j
DENISE explained the first missing weld was discovered by DIC during the week of September 17, 1984, and involved the installation of beam no. 524B2 (joint no. AF) within the Auxiliary Building.
DENISE said that the NRC became aware of this on September 20, 1984, and a review of this record clearly indicated the weld was inspected and accepted but in fact did not exist.
DENISE explained that as a result of the discovered structural steel problems the NRC Task Force determined that a significant violation of NRC regulations had occurred, as described in NRC Inspection Report No. 50-482/84-22.
The matters in question were aodressed in an enforcement meeting conducted during October 1984. DENISE stated the NRC sent enforcement correspondence, a Notice of Violation, to KG&E during November 1984.
DENISE'said that on October 17, 1985, KG&E issued KG&E Corrective Action Request No. 19 (CAR 19) to obtain the necessary actions required to resolve structural steel problems which included the discovery of the second nonexistent weld.
DENISE related that in response to KG&E CAR 19, DIC personnel researched all documentation pertinent to the I
missing weld. Miscellaneous / Structural Steel Weld Records (MSSWR) were reviewed in order to determine if any trend of missing welds existed.
DENISE related, as a result of these inquiries, only the two cases were identified in which inspection documentation existed for nonexistent welds.
DENISE explained the first instance involved the installation of beam no. 524B2 within the Auxiliary Building.
DENISE said a review of the pertinent drawings, during KG&E CAR 19, revealed the beam configuration and floor layout in the area directly beneath the beam connection in question are very similar.
In addition, the beam below connection 524B2 connects at the same building coordinates.
DENISE said KG&E CAR 19 reportad that the DIC inspector in question, Randy SMITH, possibly could have been one elevation beneath where he should have been when inspecting the connection.
DENISE said a detailed review by DIC> verified SMITH had performed more than 800 structural steel welded joint inspections. DENISE said that the DIC detailed review and EXHIBIT-(4)
_ _ =.
Q4-84-052 overviews by KG&E and NRC of SMITH's work revealed this single inspection error. DENISE reported that DIC management personnel telephonically interviewed SMITH; however, SMITH was reportedly unable to recall this particular weld inspection. DIC management and NRC Region IV concluded that human error was the root cause of this missing weld.
DENISE advised that a second similar incident was discovered by DIC on October 8, 1984, and involved a beam connection identified as 95B5 (joint no.
C036) within the Control Building. NRC was notified within several days of this finding.
The questioned joint connection was reportedly inspected and accepted when, in fact, a weld within the joint did not exist.
DENISE said a joint of this nature may contain up to twelve separate welds. DENISE stated that the DIC review of the MSSWRs depicted the DIC inspector in question, Veryl BARB, as being confused when documenting the questioned welded connection on the MSSWRs.
BARB incorrectly filled out a joint number, lined through and initialled his mistake, and subsequently entered another incorrect number on one of the MSSWRs in question.
DENISE identified two MSSWRs
]
documenting the questioned joint.
DENISE stated, after reviewing the two MSSWRs, "It is clear that BARB demonstrated his confusion as to the correct entry of information on inspection documentation." DENISE related a DIC review of BARB's performance revealed this inspector had completed 183 MSSWRs; however, only six MSSWRs related to structural steel weld inspections.
DENISE said all six inspections made by BARB were reinspected by DIC and no additional discrepancies were discovered.
DENISE stated DIC and the NRC Task Force believed BARB probably intended to document the welds attaching the beam clips to beam 95B5, since no retrievable MSSWR's are on file for these welds.
DIC concluded this missing weld was caused by the human error of an inexperienced inspector and documented the incident on Nonconformance Report No. ISN-20798CW.
4
)
EXHIBIT (4)
Q4-84-052 h
9 g
h w' \\,
l i
i KANSAS GAS AND EI2CTRIC COMPAhT FINAL REPORT-CORRECTIVEACi10NREQUESTNO. 19 e
4
\\
\\.
EXHIBIT (5)
/
FINAL REPORT l
KG&E CORRECTIVE ACTION REQLT,ST NO.19 s
TABLE OF CONTENTS 5
s e
-l. Executive Summary
'II. Introduction
,r III. Objective IV. Discussion of Findings and Corrective Actions t
i V. Conclusions VI. Appendix A.
KG&E Corrective Action Request No. 19 E.
KG&E Management Plan C.
Procedure Change Notice No. 14 to QCP-VII-200 D.
Bechtel Analysis of Structurally Significant Joints / Welds E.
Reports on Inspection of Welds through Paint 3-1.
Letter PLKES-1348, C. M. Herbst to G. L. Fouts, l'1/05/84 2.
Letter KNPLKWC-84-065, J. A. Bailey to G. L. Fouts, 11/13/84 F.
Lehigh University Report Structural Steel Welds at Wolf Creek
.L Generating Station G.
White Paper on Veld Evaluations by Reedy, Herbert, Gibbons &
Associates, Inc. of August 11, 1983.
H.
DIC Program Assessment I.
Referenced documentation and filed location (separated by Correc-tive Action).
N t
?Ir r_
e.
27 of 33 The missing welds identified for installations involving other miscellaneous materials and welds missing are of a smaller quantity.
Thorough investigation revealed the root cause of these missing welds to be due to a lack of formal follow-up and inadequate statuses of completed work and the subsequent completion of unfinished work.
The missing welds on the Incore tubing supports revealed that all investigatory information supports the hypothesis that these missing welds were not installed due to oversite.
The four lateral support brackets, two at each of the vertical angle supports (Incore tubing supports) located 32' 2 3/4" north of the Reactor Center Line and 4' 10" east and west (one each direction) of Reactor Center Line on Drawing GOS2919 were added by revision to drawing GOS2924 after the supports had been presumed completed.
Nonconformance report ISN 21273CW documents missing welds on channel i
clips to beam attachments.
The channels that American Bridge Drawing
- C121-10675 shows welded to a beam web along A2 at Elevation 2042' are bolted instead. The channel clips are bolted to the web using the same bolts as removable beams on the opposite side of the web.
Research found that the installation of the channel and removable beam was late in the construction sequence of this area, also. Since the channel clips and removable beam clips are bolttd through a beam web with the same bolts, the channel, clip l
attachment welds were probably assumed to be unnecessary by the construction personnel responsible for installation.
If the removable beams had been disconnected for the purpose of i
(
construction, it would have become necessary to weld the channel clips to the
(
beam web at that time. The beams and channel in question were installed late in the construction sequence of the area, removal of the beams never became e
mandatory, the welds were not a recognized priority and were never installed
[
as required.
The root cause of these missing welds is due to DIC error in
)
assuming the bolted connections were acceptable rather than the required I
In the miscellaneous group, investigations revealed that welds or material found missing were those welds or materials that would not impede construction progress related to that connection.
Finding #4 to CAR-19 stated, "One (1) weld was documented as having been k
inspected when in reality the weld was not made.
(Ref. NCR ISN 20495CW)."
j Corrective Action 4a) i
" Investigate the concern to determine the root cause of the error.
Immediately notify KG&E Quality Assurance if any other problems of this nature are identified. Document I'ae investigative actions. The notification i
of KG&E QA shall not preclude % issuance of an NCR."
t i
6 The results of the !A. ;Tr 2spection effort were tracked and each case i
where a missina weld oi" Inis di.2 material was identified was researched thoroughly by DIC Engineerina to determine whether. documentation-existed
?artinent to the installation of the missing weld / material.
Miscellaneous 3tructural Steel Weld Records (MSSWR's) were reviewed to determine if a trend l
or pattern existed.
Nonconformance reports identifying missing welds were compared to MSSWR's to determine if there were repetitive occurrences.
(,
--.-.---.-..-.a
28 of 33 Applicable drawings were reviewed for similarities in beam numbers, floor layout and beams at similar locations in an attempt to further identify possible sources of confusion. As a result of the investigations conducted k
only two (2) cases were identified where inspection documentation existed for welds not installed.
The first case is the installation of beam No. 524E2 and its connection to an e= bed in the Auxiliary Building.
All available information indicates that DIC Quality Inspector W made a human error when documenting the inspection of this beas connection. A review of the drawings shows that the beam configuration and floor layout in the area (elevator shaft and equipment hatch) directly beneath the beam connection in question are very similar.
In cddition, the beam below beam 524E2 connects at the same building coordi-nates.
It is possible that Inspector W could have been one elevation beneath where he should have been when inspecting the connection.
Out of the multiple welds inspected by Inspector W this problem occurred only once.
If actions which would result in other conclusions had occurred, it would be reasonable to assume that they would have occurred repeatedly.
Inspector W's signature. appears on over eight hundred (800) MSSWR's.
Each MSSWR could document multiple weld inspections, therefore, Inspector W very likely inspected over one thousand (1,000) structural steel welds, with the result that this type of problem occurred once.
A telephone conversation between Inspector W and DIC management personnel concerning this incident revealed no
[
information that Inspector W could offer, since he could not recall the
(
specific connection from the more than eight hundred (800) he inspected. The root cause conclusion in this case is human error.
The second case is the installation of beam No. 95B5 to an embed in the Control Building.
All available information suggests that DIC Quality Inspector X made a human error when documenting the inspection of this beam connection.
The MSSWR documenting this connection shows Inspector X's confusion in that he entered the joint number incorrectly when filling out this portion of the MSSVR, then lined through, initialed and dated his error, and entered what he thought was a correct entry.
Drawing K6711-XI-I-E13 details this connection, but is unclear in that it does not designate the connection number for the beam clip to embed weld, and only lists the beam seat number (91MI).
yurther research revealed that Inspector X completed one hundred eighty-three (183) MSSVR's during his tenure on site, but only six (6) of these MSSWR's were related to structural steel weld inspections.
This is indicative that Inspector X was possibly confused by the details on the erection drawing.
It is probable that Inspector X attempted to document the welds attaching the beam clips to beam 95BS, since no retrievable MSSWR is on file for these welds. These circumstances are documented on nonconformance report ISN 20798CW for disposition and resolution. The root cause conclusion in this case is human error.
Finding #5 of CAR-19 stated, " Objective evidence that the mechanical and structural inspection / documentation problems identified in KG&E QA Surveil-i
(
lance Report S-372 were rectified has not been provided."
Q4-84-052 f
"A~II0CYh%bT A
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g BASE M ATERIAL PIECE OR HEAT NO.~
j^;> pg g AREA / LOCATION s
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Q4-84-052 In Reply Refer To:
0'M Docket:
STN 50-482/85-12 ef STN 50-482/85-13
(
Kansas Gas and Electric Company ATTN:
Glenn L. Koester Vice President - Nuclear P. O. Box 208 Wichita, Kansas 67201 Gentlemen:
This refers to the inspection conducted by Mr. L. E. Ellershaw of this office and Mr. H. W. Kerch and other nondestructive examination (NDE) personnel of the NRC Region I office during the period Januar.y 2 through February 22, 1985, of activities authorized by NRC Construct, ion Permit CPPR-147 for the Wolf Creek Generating Station, and to the discussion of our findings with Mr. C.
Mason, and other members of your staff at the conclusion of the inspection.
The enclosed NRC Inspection Reports 50-482/85-12 and 50-482/85-13 respectively document NRC Region I independent NDE activities with respect to AWS structural steel welding performed as a result of a Region IV request, and the Region IV followup inspection of your corrective action taken in response to the civil penalty violation identified in NRC Enforcement Package EA-84-107.
Your initial response to the civil penalty violation, dated December 31, 1984, and subsequent data submittals, have been extensively reviewed.
We have also followed up your corrective actions through onsite verification activities, including independent inspection, witnessing of your reinspection activities, and evaluating your inspection results.
To further confirm the validity of your results with respect to reinspection through paint, Region IV requested the Region I office to perform independent confirmatory testing utilizing an appropriate NDE method.
In addition, Region IV requested the Office of Nuclear Reactor Regulation (NRR) to perform a technical review of your corrective actions with respect to engineering activities.
The activities performed by NRR, Region I, and Region IV, have resulted in the conclusion that your corrective actions have been implemented and are complete.
As a result, this item is considered closed.
s f Q. Fl RPB2 WC/T' WC/T q
RA IV LEghshaw:jc LEM ra n RPDenise TFh RD d
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Kansas Gas and Electric Company Should you have any questions concerning this inspection, we will be pleased i
to discuss them with you.
Sincerely.
Original cigned by Robert D. Etrtin Robert D. Martin i
Regional Administrator l
t
Enclosure:
i Appendix - NRC Inspection Report 50-482/85-12 e
50-482/85-13 cc w/ enclosures:
i Kansas Gas and Electric Company l
ATTN:
Gene P. Rathbun, Manager i
of Licensing P. O. Box 208 Wichita, Kansas 67201 Forrest Rhodes, Plant Superintendent Wolf Creek Generating Station P. O. Box 309 Burlington, Kansas 66839 bec to DMB (IE01) bec distrib. by RIV:
H. W. Kerch, RI P. O'Connor, NRR
- RPB2
- Resident Inspector R. D. Martin, RA
- EP&RPB L*5ection Chief (RPB2/A)
C. Wisner, PA0
- RIV File R. Denise, DRS&P
- MIS System Myron Karman, ELD, MNBB (2)
J. Harrison, RIII i
KANSAS STATE DEPT. HEALTH
- RSTS Operator
- D. Weiss, LFMB ( AR-2015)
T. F. Westerman, EO L. E. Ellershaw l
l
i U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No~
50-482/85-12 Docket No.
50-482 License No.
CPPR-147 Priority Category C
Licensee:
Kansas Gas and Electric F.O. Box 208 Wichita, Kansas 67201 Facility Name:
Wolf Creek Inspection At:
Burlincton, Kansas Inspection Conduc d:
February 6-9, 1985 Inspectors:
~
> // f/9 (
riar W. Aerch, Le44 Reactor Engineer date b9/dS' che H.r1 r) gingering Technician
/
'date l
I daf A//WW
" Randy / Campbell,F,4gineeringTechnician date O ),ah)
WJs VW Approved by:
,u 2,,,u y acqg9 Durr, Chief date Materials and Processes Section, DRS Inspection Summary:
Inspection February 6-9, 1985 Areas Inspected:
A special announced NRC independent measurements inspection was conducted at the utilities construction site using NRC nondestructive ex-amination (NDE) personnel. American Welding Society (AWS) Code D1.1 structural field weldments were re-examined by the NRC Nondestructive Examination Team.
The three region based inspection personnel were assisted by two NRC contract NDE personnel.
The inspection involved 225 on site hours and 72 off site hours.
Results:
No violations were identified.
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A DETAILS l
1.0 Persons Contacted 2.0 Purpose The purpose of this special inspection was to provide technical assistance to Region IV using the NRC Mobile Nondestructive Examination Van resources.
In 1984, the licensee initiated a reinspection program for field welded structural steel connections.
These reinspections indicated that there were deficiencies in the original inspection program. Because of the late stages of construction, some of the welds were reinspected through the paint coating.
There was a question by the NRC staff regarding the ade-quacy of the inspections through paint. The paint coatings were generally 5 mils in thickness, but a small percentage ranged as high as 8 to 13 mils.
During development of the licensee's reinspection program, there was
. recognition that certain weld attributes could be determined even though the welds were painted.
These attributes included size, length, configura-tion and location.
It was also recognized that surface expressions such as porosity, tight cracks, and lack of fusion might be masked by the coat-ing. Kansas Gas and Electric has taken the position that effective rein-spection of painted welds has been accon:plished for all attributes which could reasonably affect structural integrity.
This inspection, using the NDE Van Personnel and equipmer.t. was designed to:
(1)' determine whether magnetic-Particle examination (MT) can be re-lied upon to detect rejectable indications through painted coatings; (2) determine whether visual inspection of coated welds is reliable for de-tecting critical structural weld flaws; and (3) Perform a sampling inspec-tion to verify the adequacy of the previous licensee reinspection.
This inspection consisted of the following phases:
Phase I - Qualification Test Blocks The first phase was an effort to determine the acceptability of the previous licensee inspections and any subsequent NRC inspections through coatings.
This was accomplished by performing a series of examinations t
on known flawed samples with and without the protective coatings applied.
i Four structural carbon steel weld samples were fabricated with known flaws such as tight cracks and porosity in the welds.
The sar:ples were 3/4" X 6" X 8" in dimension.
These were examined visually, with magnetic par-titles, a r.d then photographed ' before painting.
The samples were then coated with Carboline CZ-11 Primer and the coating tnickness measured.
The previous visual and magnetic particle examinations were repeated
{
through the coating and the results photographed again. The samples were i
then coated with Carboline 191 HB epoxy, representative of field con-ditions, and the examinations performed again and photographed.
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2 The results of these tests proved that meaningful magnetic particle ex-aminations can be performed through the paint coatings.
The test results are presented in Table 1.
The NRC team that performed the VT and MT examinations are AWS certified t
weld inspectors.
Based on their experience, the types of indications noted within these test blocks represented the types of indications that would be encountered with structural welding.
The team also indicated that the tight indications in the test blocks were difficult to visually detect and if all the welds were in the' as welded condition, a small per-centage of the indications would have been detected visually.
Indications wider than the samples would be detected by visual inspection.
O
TABLE 1 TEST BLOCK INSPECTION RESULTS Visual M.T.
Visual M.T.
Visual M.T.
Visual M.T.
Brushed Brushed Bare Metal Bare Metal Primer Primer Epoxy Epoxy Ecoxy Epoxy Weld 1 Rej Rej Ace Rej Acc Rej Ace Acc (Ground)
Weld 2 Rej Rej Acc Rej Acc Rej Ace Rej (Ground)
Weld 3 Rej Rej Ace Rej Acc Rej Ace Rej (Ground)
Weld 4 Acc Rej Acc Rej Acc Acc Ace Act (As Welded)
REJ = Rejected ACC = Accepted e
3 phase II - Field Trial Examinations A small sample size of ten epoxy coated welds were to be selected from the auxiliary building and the diesel generator rooms.
A walk down inspection was conducted to select the ten welds; however, this walk down revealed that the epoxy coated welds were also sprayed with DURA for fire protection making access to these welds extremely difficult.
It was decided not to inspect these welds at this time.
Next, the NRC inspectors randomly selected safety related structural welds in the essential service water and reactor buildings.
The welds were visually inspected and magnetic particle examined with either the primer or the epoxy coatings applied.
The coatings were then removed and the welds were re-examined visually and with magnetic particles.
In the ESV building, eleven (11) welds on sia clip angels were visually examined with Carboline CZ-11 primer coat applied. The dry film thickness for the primer ranged from 1.0 to 3.0 mils. After the primer was removed, the welds were reinspected visually and with magnetic particles usir.g the NRC approved procedure NDE-6, Revision 0, and addendum WC-1-6-1.
l The examinations disclosed that three of the clip angle welds were ur. der-sized; p-7, P-8, and P-10.
Review of the licensee's records showed that i
these welds had been identified as undersize by the licensee and were recorded on a nonconformance report.
Otherwise, no other deficiencies were noted in the thirty six (36) linear inches of weld metal examined.
Similar examinations were conducted in the reactor building whereir. five (5) structural steel weld joints were visually and magnetic particle ex-l amined for AWS D1.1 acceptability and overall workmanship.
The welds had Carboline 191 HB epoxy coating on them.
The welds were found to be acceptable.
Phase III - Visual Inspection, With Primer And Epoxy Coating Fifty-five weldments were visually examined with primer and epoxy ccating applied.
A total of 3017 linear inches of fillet welds were inspecte:: for the following characteristics that could be evaluated with ceasings applied.
1.
Fillet size 2.
Location (per DWG) 3.
Leg 'ength and throat 4.
Concavity and convexity 5.
Overlap 6.
Length of weld 7.
Gross undercut and large porosity 8.
Overall workmanship 9.
Craters
4 This inspection was performed to design requirements and AWS DI.] accep-tance criteria. Of the weldments visually inspected five had the coating removed to bare metal and were reinspected visually and by magnetic par-ticle.
Although two fillet welds were found to be rejectable for weld t
undersize, (R736, R737) no indications were found on the welds with primer or epoxy coating; nor were any indication found on those that had primer and epoxy coating removed.
It was also concluded that various types of induced discontinuities are not visually inspectable through primer or epoxy coating, such as the following:
1.
Cracks 2.
Fine porosity 3.
Tight undercut 4.
Fusion type discontinuities (tight)
Weld joints sampled during this inspection were selected in the Reactor Building and selections were made at all levels (elevations).
This pro-vided a sample that was welded at different time periods and by different welders.
Recognizing that certain characteristics involved in visual inspection can be evaluated effectively with primer and coating.
It is determined that there were no characteristics involved during this inspection that could affect the integrity of those welded joints inspected. This was confirmed by the above sample reinspection and or the removal of paint coatings on certain selected welded joints, phase IV - Statistical Sample of Structural Welds A statistical sample of structural weld joints was selected from the re-actor building for inspection and evaluation to provide a level of confi-dence as to the quality of existing welded joints.
The selected sample consisted of fif ty-three welded joints that were visually inspected for size, surface condition and overall workmanship, then magnetic particle inspected for discontinuities.
On those welded joints selected all primer and epoxy coating was removed prior to inspection. The inspection was performed and evaluations made in accordance with the design require-ments and AWS DI.1 Structural Code acceptance criteria.
A total of fifty-three welded joints, 2413 linear inches, were inspected and accepted. No rejectable welds were found.
The foregoing inspections and examinations provide adequate assurance that welds can be magnetically examined through the coatings and that the pre-vious reinspections give reasonable confidence that the inspection program was capable of identifying detrimental structural weld flaws.
5 Attachments Attachment No. I is a tabulation of structural steel weld joints examined during Phase II of the special inspection.
Attachment No. 2 is a list of welds inspected during Phase III of this inspection.
Attachment No.
3 is a list of specific welds examined during the statistical sampling inspection (Phase IV).
Attachment No. 4 contains summary statements of Welding and nondestructive testing experience for NRC and contractor personnel involved with this inspection.
Copies of AWS Certified Welding Inspector certificates are also included.
Exit Interview An exit interview was held on February 9,1985, with members of the licensee's staff. The inspector summarized the scope and findings of this inspection.
No written information was given to the licensee by the inspector during the course of this inspection.
i
AWS Strisct ral Weld in pection Wntr Creek Station Bierlangton, Mansas 50-4M2 85-12 Plin e.n 11 Alenrhonett #1 Page 1 nr 1 Type Type Inspection Detail and Total Li nea r I nche s ident i rica tio3 Location Held ylsual Mr O rewi no__
or Weld inspected _
P-3 ESW-Ridg.
Clip Anglo Acc Acc Cl31-5381-05, Rev. D 12 Inches Fillet Wald P-4 ESW-Ridg.
Acc Acc 1A inches P-7 ESW-Bldg.
Ace Acc 12 Inches P-8 ESW-Bldg.
Ace Acc 12 Inches P-9 ESW-Bldg.
Acc Acc 6 inches P-10 ESW-ntdg.
Acc Acc C131-5381-05, Rev. D 6 Inches R110 29181 Reactor Ridg.
Clip Angle Acc Acc C121-8577-06 106 inches rittet Wold 31 AZ91tl2R Reactor Ridg.
Acc Ace 4% I nche s R154 A215R2 Reactor aldg.
Ace Ace 20 inches R159 26052 Reactor Bldg.
Ace Acc los Inches R160 26062 Reactor Bldg.
Ace Ace C121-8577-06 10s Inches
l
?
AWS Structural Weld Inspection Wolf Creek Station Burlin9 ton, Ransas 50-482 85-12 Phase ill Attachment #2 Page 1 of 4:
Type Type inspection Detall total Linear Inches IdcutR ication Location Weld Yl_sua l M_L Drawing
.p O Jld lnspecteel.,
A111M6 #PC 1 Reactor Ridg.
Fillets Acc N/A C121-8543-09 89 inches A111M1 #PC 2 Pressurizer Acc 89 inches Supports l
A111M8 #PC 3 Pressurize r Acc 89 Inches Supports A111M2 #PC 4 Pressurizer Acc 89 inches Supports A11tM9 #PC 5 Pressurlie r Acc 89 inches l
Supports A111M7 #PC 6 Pressurizer Acc C121-8543-09 89 Inches supports t
Q1C2 Angle Supports Ace 6714-1-E103, Rev 7 12 Inches Q131 Angle Supports Ace 6714-1-E103, Rev 7 8 Inches D716 Angle Supports Reject" C121-8772-01 16 Inches QT37 Angle Supports Reject
- C121-8772-01 16 Inches t
4 Support Clips Clips Ace C121-8772-01 64 Inches vnr 136, 137 C271R2 Remus Ace C121-8753-02 16 I nc he s 27293 Rene Ace C121-8753-02 16 Inches
607R2 Ream Ace CIS2311, Rev 0 72 inches 60684 Ream Acc C152311, Rev 0 72 inches I
r r-AWS Structural Weld Inspection Wot r Creek Stat ion Burlington, kansas 50-482 85-12 phase les Attachment g2 Page 2 of 4; Type Type Inspection Detall and Total L inee r I nches identirtentlog Locatlog We l_d Visual Mi As)tfng_,
Or_ye t.d Inspected _
r 606M3 Reactor Bldg.
Fillets Acc N/A C121-8549-04 72 Inches 606R4 Beams Acc C121-8549-04 72 Inches 60684 Seems Acc C121-8549-04 72 Inches 956 Renas Acc C121-8577-06 26 Inches 957 Beams Acc C121-8577-06 16 Inches 321n2 Beams Acc C121-8625-06 20 Inches C121-8302-07 27782 Beems Acc C121-8577-06 20 Inches C121-6621-04 777R3 Seems Acc C121-8577-06 19 inches C121-8621-04 32nni peams Ace C121-8675-06 14 inches C121-8302-07 321n1 Beams Acc C121-8625-06 20 Inches C121-8302-0T 326R2 Meems Acc C121-13093-02 24 inches 326R3 Beams Acc C121-13093-02 4R Inches 32683 Beams Acc C121-13093-02 4R enches 340M1 Beems Acc C121-8625-06 130 inches
[119 36?nt penas Acc C121-86?5-06 42 Inches
_a
I AWS Strucutral Weld inspection Wnt r Creek Station
(
Mierllngton, Kansas
[
50-402 84-12 l
Phase Ill l
Attachment #2 Page 3 nr 4 Type Type inspection Detall and Total L i nea r i nc he s identifl cat lng I,ocation Wo.i d ylsesa l Mi
_ Drawing _,
_Of We ld J n s pec t ed, 25783 Roactor Ridg.
Fillets Ace N/A C121-8576-05 E118 20 inches 251R2 Beams Acc C121-8576-05 E118 18 inches 32(R2 Reams Acc C121-8523-09 E119 20 i nche s 32RB2 Beams Acc C121-8523-09 E119 20 Inches F10251 Beams Acc C121-13001-02 Detalt 4 20 Inches A21281 Reams Acc C121-8912-04 FW 200 144 inches A21182 Beans Acc C121-8912-04 FW 200 144 inches A27282 Reams Acc C121-8912-04 FW 200 144 inches 2915-C9 Channel Acc COX-2912 R/0 Detalt 4 19 inches 2913-586/2916 2915-C8 Channel Acc COX-2912 R/0 Detalt 5 19 Inches 2913-5804/2916 2915-C3 Channel Acc COM-2913 R/0 Detall 1 19 Inches 2913-5813/2916 2915-C36 Channot Acc C0X-2913 R/0 Detall 1 19 i nc he s 2913-5813/2916 2915-C36 Channel Aec COX-2912 R/0 Detail 2 19 inches 2913-584/2916 2915-C3 Channel Acc Cox-2912 R/0 Detall 2 19 inches 2913-5810/2916 Q113 Beam Acc COX-2912 R/O Detall 2 28 Inches l
2913-5810/2916 1
l l
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AWS Structural Wald inspection Wolf Creek Station Ste r l i ng ton, Kansas 50-487 85-12 Phase ill Attachment #2 Page 4 or 4 Type Type inspection Detail and Total Linea r inches identiricatips tocauen Held ylsuel M1
_oraving Or_yeld_Lnspec_ted__
Q114 Reactor Bldg.
Fillets Acc N/A C121-8577-06 108 inches DET E196, E108, E118 Q117 Renas Acc C121-8577-06 178 Inches Dtf Ein6, [108, E118 C115 Deams Acc C121-8577-06 128 Inches DET E106, E108, E116 C119 Reams Acc C121-8577-06 128 inches Dff E1D6, E108, E118 C149 Beans Acc C121-8577-06 178 inches DET E106, E108, [118 Q151 Beams Acc C121-8577-06 178 i nches DET E106, E108 E118 C153 Reactor Bldg.
Acc C121-8577-06 178 inches DET E106, [108, E118 1
e
AWS Weld Inspection Wolf Creek Station 85-12 Phase IV Page 1 of 3 Attachment #3 50-482 Total' Inches No.
Identification / Location Inspected Orawing and Detail 1
321B2 AZ293* Beam 20 Inches C121-8625-06 and C121-8302-07 2
277B2 AZ286* Beam 20 Inches C121-8577-06 and C121-8621-04 3
27783 AZ296' Beam 19 Inches C121-8577-06 and C121-8621-04 4
320B1 AZ285' Beam 14 Inches C121-8625-06 and C121-8302-07 5
321B1 AZ296* Beam 20 Inches C121-8625-06 and C121-8302-07 6
326B2 R45 Beam 24 Inches C121-13093-02 7
326B3 R44 Beam 48 Inches
( AZ-245') C121-13093-02 8
326B3 R43 Beam 48 Inches (AZ-240*) C121-13093-02 9
34081 R165 Beam 130 Inches (AZ-296*) C121-8625-06 Detail 10 (E119) 10 362B1 AZ296* Beam 42 Inches C121-8625-06 E119 11 257B3 AZ53' Beam 20 Inches C121-8576-05 E118 12 25782 AZ62*
Beam 18 Inches C121-8576-05 E118 13 32782 AZ62*
Beam 20 Inches C121-8523-09 E119 14 328B2 AZ53' Beam 20 Inches C121-8523-09 E119 15 F102B1 R101 Beam 20 Inches C121-13001-02 Detail 4 E115 (AZ110')
16 A212B1 RC Beam 144 Inches C121-8912-04 FW200 ( AZ132*)
17 A211B2 R126 Beam 144 Inches
( AZ 140') C121-8912-04 Detail FW200 18 A272B2 R127 Beam 144 Inches (AZ140*) C121-8912-04 Detail FW200 19 271B3 R129 Beam 36 Inches (AZ160') C121-8912-04 Detail FW200 20 27183 R130 Beam 36 Inches (AZ160*) C121-8912-04 Detail FW 200 21 27183 R131 Beam 36 Inches (AZ160*) C121-8912-04 Detail FW 200 22 27183 R132 Beam 36 Inches (AZ160') C121-8912-04 Detail FW 200 23 271B1 R133 Beam 80 Inches
( AZ170*) C121-8912-04 Detail FW 200 24 271B1 R106 Beam 40 Inches (AZ180*) C121-8909-04 25 2915-C9 R398 Channel 19 Inches COX-2912 R/0 Detail 1/2913 5811/2916
l 3
AWS Weld Inspection Wolf Creek Station 85-12 Phase IV Page 2 of 3 i
Attachment #3
.50-482-Total Inches No.
Identification / Location Inspected Drawing and Detail 26 2915-C8 R399 Channel 19 Inches COX-2912 R/0 Detail 1/2913 583/2816 27 2915-C9 R406
-Channel 19 Inches COX-2912 R/0 Detail 4/2913-586/2916 28 2915-C8 R404 Channel 19 Inches COX-2912 R/0 Detail 5/2913-5804/2916 29 2915-C3 R372 Channel 19 Inches COX-2912 R/0 Detail 1/2913-5813/2916 30 2915-C36 R373 Channel 19 Inches COX-2912 R/0 Detail 1/2913-582/2916 31 2915-C36 R300 Channel 19 Inches COX-2912 R/0 Detail 2/2913-584/2916 32 2915-C3 R379 Channel 19 Inches COX-2912 R/0 Detail 5810/2916 33 659B1 R69 Beam 80 Inches C121-8787-03 Detail 1 34 65982 R70 Beam-80 Inches C121-8787-03 Detail 3 r
35 65882 R71 Beam 80 Inches C121-8787-03 Detail 3 36 658B1 R72 Beam 80 Inches C121-8787-03 Detail 2 37 272B1 R128 Beam 180 Inches C121-8912-04 Detail FW 200 38 606B3 RA Beam 72 Inches C121-8549-04 Detail 1 f
(AZ 270*)
39 603B1 A2253' Beam 20 Inches C121-8549-04 40 606B4 A2270* Beam 24 Inches C121-8549-04 1A 2920-C27'R340 Channel 18 Inches 004-2912 Detail.15/2913 -
MI/2916 2A 2911-C11 R334 Channel 18 Inches 004-2912 Detail 2/2913 -
589/2916 3A C17 R336 Channel 13 Inches 004-2912 Detail 1/2913 -
588/2916 4A 2915-C11 R337 Channel 8 Inches 004-2912 Detail 1/2913 -
5820/2916 5A' C20 R359 Channel 13 Inches 004-2912 Detail 1/2913 -
587/2916 l
i AWS Weld Inspection Wolf Creek Station 85-12 Phase IV Page 3 of 3 j'
Attachment #3 50-482 Total Inches j
No.
Identification / Location Inspected Drawing and Detail 6A 2915-C13 R360 Channel 8 Inches 004-2912 Detail 1/2913 -
4 1/2913 -
/2916 7A 2920-C28 R364 Channel 10 Inches 004-2917~ Detail 3/2913-MI/2916 8A C20 R361 Channel 6 Inches 004-2912 Detail on Drawing 9A 144B4 A262* Beam 10 Inches C121-8510-04 Detail E115 i
10A 174B1 R77 Beam 74 Inches C121-8504-03 Detail 16 E115 11A 142B2 A2288* Beam 74 Inches C121-8506-05 Detail 115 12A 296B2 R113 Beam 98 Inches C121-8577-06 Detail 27 E115 13A A214B1 R153 Beam 116 Inches C121-8576-05 Detail 18 E115 4
i Ambridge Drawings:
l FW 200 = C121-8896-01 E115 = C121-8081-08 i
E118 = C121-8621-04 E119 = C121-8302-07
~
Bechtel Details COX-2913 - COX-2916 i
i, 9
j l
i I
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1 I
6 4
ATTACHMENT 4 PERSONNEL CERTIFICATION 6
t Harry W. Kerch Education:
B.S. in Industrial Engineering Experience:
Over twenty years of nondestructive examination experience in the air craf t and nuclear industry.
I have served the Past 2h years as lead reactor engineer in charge of the NRC Kobile Nondestructive Examination Van.
In this capacity, I have been responsible for reviewing nondestructive ex-amination programs for reactors under construction and operations for Regions I, III, IV and V.
I am a Certified Nondestructive Level III Examiner ( ASNT Cert. FI646) in the methods of radiography, liquid penetrant, magnetic particle, and ultrasonic examinations.
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Richard H. Harris NRC NDE, Technician Region I Welding Inspection / Nondestructive Test Experience I ha've over twenty years experience in Nondestructive testing and ten years in Weld inspection.
I am currently a Certified level II in accordance with SNT-TC-1A for magnetic particle, liquid penetrant, radiography and ultrasonic inspection.
I was certified (CWI) in accordance with the requirements of section 6.1 of (AWS) American Welding Society 1980.
I have been involved with structural steel inspection since 1974.
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k Randy M. Campbell NRC NDE Technician Region I Welding Inspection / Nondestructive Testing Experience:
I have approximately ten years. of welding inspection and nondestructive testing experience in the nuclear industry.
I am currently a Level II under ASNT-TC-1A guidelines for nondestructive examination methods.
I have been a certified welding Inspector (CWI) in accordance with the requirements of Section 6.1 of American Welding Society since 1980. I was recertified again in November 1983.
(Certificate Number 80111121)
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Subject:
NDE Certification 4
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has complied with, and successfully passed, all of the applicable requirements of the referenced standard, which is in accordance.
aith the American Society for Nondestructive Testing Recommended Practice No.
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I certify that the above statement is correct and bertiti
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This individual is hereby certified in the ipdi ated NDE Method and Level.
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has complied with, and successfully passed, all of the applicable req 61rements of the referenced standard, which is in accordance with the American Society for Nondestructive Testing Recommended Practice No.
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I certify that the above statement is correct and
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Certified by:
i J /h SDE Level'Ill Exhminer ASNT Certificate #F1646 Composite Grade 2.
General 97X.3 = M Specific 93X.2 = 1Tr l
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December 10, 19833 Certification of David F. Payne to SNT-TC-1A Level 111 Nondestructive Examination Technician (Cert. No. R-1008).
This is to advise that The American Society for Nondestructive Testing recognizes David F. Payne as NDT Level lli certified and as such he has been designated Corporate Level lit for Thompson Engineering Testing, Inc. This appointment has been made in view of Mr. Payne's background knowledge, practical and technical experience and his capabilities.
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THOMPSON ENGINEERING TESTING, INC.
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.. a NAME DAVID C. VIGCINS SOCIAL SECURITY NUMEER 423-74-9966 DATE HIRED 11-24-75 DATE OF BIRTE 10-25-53 TEST METHOD KT LEVEL II A.
EDUCATION:
School Name Date Attended Yrs. At School Degree In Graemer School High School Shav 1967 - 1971 4
DIPLOMA College Univ. of South Alaba=a 1971 - 1972 2
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EXAMINATION:
(Copy in File)
Test Crade Percentile Weight Composite Grade G:neral / Basic 93.33 0.3 28.0 Pra ctical/ Method 95.0 0.2 19.0 Specific 100.0 0.5 50.0 Tetal 96.11 1.0 97.0 E.
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Results NORMAL Dated ON FILE T.
Imployers written Practice Available for Review:
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APPENDIX A U. S. NUCLEAR REGULATORY COMMISSION REGION IV t
NRC Inspection Report:
STN 50-482/85-13 Construction Permit:
CPPR-147 Docket STN 50-482 Licensee:
Kansas Gas and Electric Conpany P. O. Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek Generating Station Inspection At: Wolf Creek Site, Coffee County, Burlington, Kansas Inspection Cond cted:
January 2 through February 23, 1985 Inspector:
GL C d I/ f K E. E. Ellershaw, Reactor Inspector Date' Project Section A, Reactor Project Branch 2 h/
5 Approved:
r T.C. Martin, ief, Project Sectior. A at,V t
Reactor Proj t Branch 2 Inspection Sunrnary Inspe-tion Conducted January 2 throuch February 23, 198_5 (Report STN 50 te2/85-13) l Areas Inspected:
Routine, announced, ir,spection of licensee's corrective action on AW5 structural steel welding.
The inspection involved 63 inspector-hours onsite, and 64 inspector-hours offsite by one NRC inspector.
Results:. Within the one area inspected, no violations or deviations were identified.
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f' DETAILS 1.
Persons Contacted Principal Licensee Emplovees
- P. Dyson, Field Engineering Supervisor
- J. Fletcher, Supervisor, Quality Control
- R. Grant, Director, Quality
- H. Chernoff, Licensing Bechtel Power Corporation C. M. Herbst, Assistant Project Engineer The NRC inspector also interviewed other licensee and Bechtel personnel.
- Denotes those attending the exit interview.
2.
Licensee Action on Previous Inspection Findincs (Closed) Violation (482/8422-01) This item dealt with an inspection program for safety-related structural steel field welds not being adequately executed to assure conformance to requirements, nor were adequate records kept to document the quality of the welds.
KG&E's corrective action comitments included a 100 percent visual reinspection of all accessible structurally significant safety-related structural steel field welds.
Accessible is defined as those joints which are not embedded in concrete.
The structurally significant welded joints were identified and defined by Bechtel as being those field welded joints which support or potentially support safety-related equipment and building components.
Reinspection was to be perfomed by AWS (American Welding Society) certified welding inspectors (CWIs), who were also certified as Quality Inspectors by Daniel International Corporation (DIC), the constructor.
Inspection criteria to be used were procedurally defined and any supplemental training required would be completed prior to initiation of the reinspection activity.
Adequate technical justification was to be provided by Bechtel to validate the result of visual examination (VT) of painted welds.
The reinspection results were to be documented in inspection data sheets which were to delineate the design requirements with respect to joint geometry and individual weld characteristics.
The CWIs were instructed to record the inspected as-built condition of all i
accessible welds, with signature and date of inspection.
All identified deficienci,. were to be documented in nonconfomance reports (hCRs) which, together with the inspection data sheets, were to be provided to Bechtel l
so that a case-by-case evaluation of each structurally significant joint could be perfomed.
The evaluations were to detemine whether each weided l
. joint's as-built condition met design allowable stresses at maximum loading condition, or represented a significant deficiency as defined by 10 CFR Part 50.55(e), or rework / repair was required.
i KG&E's final report addressing the violation, dated January 21, 1985, includes Revision 1 to Bechtel's " Final Report on the Evaluation of AWS Field Welding on Structural and Miscellaneous Steel at the Wolf Creek Generating Station," dated January 19, 1985.
Bechtel's report identified 2670 structurally significant and safety-related field welded joints which required reinspection.
The joint inspectability data shows:
2403 joints were completely inspected 165 joints were partially inaccessible 102 joints were totally inaccessible The results of the CWIs inspection efforts showed that of the 2403 joints that were ccmpletely inspected, they accepted 1305 joints and rejected 1098 joints for various material and weld deviations.
The report further shows that of the 2670 total joints, 82 joints required rework / repair due to defective conditions which caused the design allowable stresses to be exceeded in the as-built condition, and 81 additional joints were identified as requiring rework / repair due to KG&E's commitment to install missing material and missing and underlength welds (unless prohibited by field conditions) even though the design allowable stresses had not been exceeded. It was determined that field conditions did preclude the rework of 14 of the 81 joints, therefore, Bechtel dispositioned the applicable NCRs as "Use-As-Is."
l In order to assess the adequacy and implementation of KG&E's committed corrective actions, the NRC Region IV inspector accompanied CWIs on several occasions to observe and verify their inspection activities and to assure that the results of the inspections were being accurately recorded.
In addition, the NRC Region IV inspector conducted independent inspections
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on selected joints with subsequent comparison to the CWIs inspection data sheets.
There were no discernible differences in inspection results i
l obtained by the NRC Region IV inspector and the CWIs during either the accompanied or independent inspection activities.
This created a very high level of confidence in the data being documented by the CWIs during the reinspection program.
The NRC Region IV inspector reviewed inspection data sheets and applicable NCRs for approximately 1750 welded joints, including 149 data sheets ano 34 NCRs associated with the joints that were repaired.
In addition, and subsequent to the completion of the reinspection effort, the NRC Region IV inspector performed an inspection on 42 of the 149 repaired joints, with acceptable results.
It was noted that magnetic particle examination (MT) l
. was also performed on 24 of the 149 repaired joints with acceptable results.
Of potential concern was the reconciliation of the as-built conditions to the design drawings.
This was resolved by Bechtel in that they are identifying all NCRs applicable to field welded / structural steel joints on Drawing No. C-1045.
Note 46 in Revision I to Drawing No. C-1003,
" Civil-Structural Steel and Concrete General Notes," states in part, "... See the shop detail drawings and appropriate nonconformance reports identified on Drawing C-1045 for conneci. ion details."
With respect to the 102 joints identified as being totally inaccessible due to their being embedded in concrete, 62 were acceptable as is because evaluation showed that the concrete was capable of supporting the design load, thus eliminating any concerns with respect to defective welds.
It was also noted that 165 joints were partially inaccessible; however, sufficient inspection data was available on-139 of the joints to allow an evaluation to be performed.
This leaves a total of 66 joints out of 2670 which could not be evaluated.
The basis by which Bechtel accepted these joints was through statistical analysis, and is considered proper logic.
If the 2604 fully evaluated joints are considered a sample of the 2670 total population of joints, then the sample size represents such a large percentage of the total population that statistics associated with the sample may be applied to the total population with virtually 100 percent confidence.
This implies that if a percentage of inspected joints were determined to exceed design allowable stresses, then statistically this percentage may be applied to the total population.
Of the 2604 joints which were evaluated, E2 joints (3.14%) were identified in which the design allowable stresses were exceeded.
Analysis has shown that those joints would not have failed unoer the design loading conditions.
However, 60 of the 82 joints were polar crane radial stops in which the same welds were missing in each joint and the design allowable stresses were exceeded.
In addition, six pressurizer support joints had the same welds missing in each joint, three of which exceeded the design allowable stresses.
Thus, a total of 19 joints in the remaining population of 2541 joints (0.75%), exceedeo the design allowable stresses.
It should be pointed out that the cause of the missing identical welds in the 60 polar crane radial stops and the 6 pressurizer supports is attributable to the failure of the detail drawings to provide a clear understanding of the weld details.
This is considered an isolated condition and was substantiated by the hR~ Region IV inspector's review of the applicable structural steel detail drawings delineating the welded joint configurations.
The 0.75% statistically applied to the group of 66 joints which could not be evaluated, results in less than 1 joint in which the design allowable stresses could be expected to be exceedec.
It would also be expected that m
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F none of these joints would fail under the design loading conditions as a result of defective welds.
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Incorporated into the KG&E report is Bechtel's engineering position for VT, in accordance with AWS DI.1, of painted welds.
In summary, their i
t position states that " fillet welds which have been coated with up to 4 mils of primer and, in some cases, up to an additional 10 mils of topcoat can be visually inspected to the AWS D1.1 acceptance criteria.
Those attributes which cannot be fully evaluated are of little concern on the structural steel at WCGS." Those attributes identified as being capable of being fully evaluated to the design requirements and AWS D1.1 acceptance criteria are: weld presence and location; weld length; weld size; weld profile; fusion; overlap; cross-section of weld craters; coarse undercut, and large porosity.
The attributes identified as being more difficult to inspect, or not being visible at all, include:
tight weld cracks; fine porosity, and tight undercut.
A discussion followed in which these attributes were identified as being largely dependent on the metallurgical characteristics of the base metal, welding filler materials, and the ability of the welders.
With respect to the metallurgical characteristics of the base metal (ASTM A-36) and the welding filler material (Type E7018 electrodes), compatibility results in sound, crack and porosity-free welds provided certain precautions are taken. The 4
precautions are incluoed in the approved welding procedure specifications used for structural steel welding.
A DIC and Bechtel review substantiated that DIC welders involved with structural steel welding were satisfactorily qualified in accordance with AWS requirements.
l It should be noted that paragraph 3.10.1, in Section 3 of AWS DI.1-75, states in part, "... Welded joints shall not be painted until after the work has been completed and accepted...."
With the exception of one attribute, i.e., lack of fusion, the logic of the Eechtel engineering position regarding inspection through paint appeared sound.
The NRC Region IV office requested technical assistance from the Office of Nuclear Reactor Regulation (NRR) in order to arrive at a technically acceptable position.
Specifically, NRR was requested to:
a.
Review the process by which Sechtel identified the structurally significant safety-related field welded joints.
b.
Review calculations, evaluations, and dispositions as they relate to identified deficient welds.
c.
Review the adequacy of Bechtel's position regarding the acceptance of inaccessible welded connections embedded in concrete.
. d.
Review the adequacy of Bechtel's engineering position with respect to VT of painted welds.
NRR staff visited Bechtel's Gaithersburg, Maryland, offices on November 6, 13, and 27,1984, to acquire and review information pertaining to the above items.
The NRR staff evaluation concluded that:
a.
There is little likelihood of any structurally significant safety-related field welded joint not being identified for reinspection.
b.
Bechtel's approach of individually calculating stress levels to determine the structural acequacy of the identified as-built conditions is acceptable.
c.
There is no deficiency in Bechtel's approach with respect to inaccessible welded joints embedded in concrete, in that the use of statistical analysis and acceptable alternative load path evaluation is proper.
d.
With respect to VT of painted welds, the defects which could significantly affect structural integrity, i.e., lack of fusion, undersize and underlength welds, heavy undercut, and missing welds, are all visually detectable and measurable through coatings, except for lack of fusion.
NRR further stated that reinspection of welds with coatings for these types of defects, other than lack of fusion, would be acceptable.
It was recommended that alternate methods for detection of lack of fusion be addressed.
As a result of NRR's recommendation, the NRC Region IV office requested NRC Region I assistance in performing an independent nondestructive examination (NDE) program at the WCGS.
The particular NDE disciplines to be utilized were MT and VT.
The NRC Region IV specifically recognized that fine lack of fusion, tight cracks or porosity, might be masked by coatings and that the use of MT might be of significant assistance in helping to determine its existence.
One of the goals of the MT was to help establish the validity of the VT of painted welds.
The results of the NRC Region I inspection are documented in NRC Inspection Report 50-482/85-12; however, a summary of those results are presented here.
NRC Region I staff, in conjunction with NRC contract NDE personnel, conducted an inspection at the WCGS on February 6-9, 1985, in order to:
(a) determine whether MT can be relied upon to detect rejectable indications through painted coatings; (b) determine whether VT of coated welds is reliable for detecting critical structural weld flaws; and 4
7 (c) perform a sample inspection to verify the adequacy of the previous licensee reinspection.
Four structural carbon steel weld samples were fabricated with known flaws such as tight cracks and porosity in the welds.
The samples were 3/4" X 6" X 8" in dimension.
These were examined by VT and MT, and then photographed before painting.
The samples were then coated with Carboline CZ-11 Primer and the coating thickness measured.
The VT and MT examinations were repeated through the coating and the results photographed.
The samples were then coated with Carboline 191 HB epoxy, representative of field conditions, and the examinations performed again and photographed.
The types of indications noted within these test blocks represented the types of indications that would be encountered with structural welding.
The team also indicated that the tight indications in the test blocks were difficult to visually detect and if all the welds were in the as-welded condition, a small percentage of the indications would have been detected visually.
Indications wider than the samples would be detected by visual inspection.
The results of these tests proved that meaningful MT can be performed through paint coatings.
The NRC inspectors randomly selected safety-related structural welds in the essential service water system pumphouse (ESWS) and reactor building.
The welds were subjected to VT and MT with either the primer or the epoxy coatings applied.
The coatings were then removed and the welos were reexamined by VT and MT.
In the ESWS, welds on 6 clip angles were visually examined with Carboline CZ-11 primer coat applied.
The dry film thickness for the primer ranged f rom 1.0 to 3.0 mils.
Af ter the primer was removed, the welds were reinspected by VT and MT using the NRC-approved procedure NDE-6, Revision 0, and addendum WC-1-6-1.
The examinations disclosed that three of the clip angle welds were undersized; P-7, P-8, and P-10.
Review of KG&E records showed that these welds had been identified as being undersize and were recorded on a nonconformance report.
Otherwise, no other deficiencies were noted.
Similar examinations were conducted in the reactor building wherein five structural steel weld joints were VT'd and MT'd for AWS D1.1 acceptability and overall workmanship.
The welds had Carboline 191 HB epoxy coating oo them.
The welds were found to be acceptable.
A sample of 55 welded connnections were selected in the reactor building for VT with primer and epoxy coatings applied.
The samples were selected from different elevations in order to provide a sample that had been welded by different welders and at different times.
The VT was performed to design requirements and AWS D1.1 acceptance criteria.
Five of the
. joints had their coatings removed and were reinspected by VT and MT.
No indications were found on the welds with coatings or on those that had the coatings removed.
It was concluded that certain characteristics involved in VT can be evaluated effectively on coated welds.
There were no characteristics identified during this inspection that could affect the integrity of the welded joints inspected.
A statistical sample of welded structural joints was selected from the reactor building for reinspection and evaluation to provide a level of confidence as to the quality of existing welded joints.
The selected sample consisted of 53 welded joints that were inspected for size, surface condition and overall workmanship, then tR'd for discontinuities.
On those welded joints selected, all primer and epoxy coating was removed prior to inspection.
The inspection was performed and evaluations made in accordance with the design requirements and-AWS DI.1 acceptance criteria.
No rejectable welds were identified.
The NRC Region I staff concluded that the above VT and MT examinations provided adequate assurance that welds can be MT'd through the coatings and that the previous reinspections give reasonable confidence that the inspection program was capable of identifying detrimental structural weld flaws.
Based on the NRR technical review, the Region I NDE effort, the independent Region IV inspections, the Region IV witnessing of the KG&E reinspection activities, and the Region IV evaluation of the KG&E reinspection results, it is determined that the corrective actions have been implemented and are complete; therefore, this item is closed.
3.
KG&E Significant Construction Deficiency No. 53564-K152, Structural Weldino (Closec)
As a result of the activities described above, this item is closed.
4.
Exit Interview Exit interviews were held periodically with licensee management personnel during the course of this inspection.
Those attending the final Region IV meeting on January 22, 1985, are denoted in paragraph I.
Other personnel attended the Region I meeting on February 9,1985.
At these meetings, the scope and findings of the inspection were presented.
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May 14, 1985 i
PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE PNO-II-85-52 This preliminary notification constitutes EARLY notice of events of POSSIBLE safety or public interest significance.
The infomation is as initially received without verif t-cation or evaluation, and is basically all that is known by the Region II staff on this dat2.
FACILITY: Mississippi Power & Light Company Licensee Emergency Classification:
Grand Gulf Unit 1 Notification of Unusual Event Docket No. 50-416 Alert Port Gibson, Mississippi Site Area Emergency General Emergency i
X Not Applicable
SUBJECT:
UNIT REACHES 100 PERCENT POWER LEVEL Grand Gulf Unit 1, which is undergoing power ascension testing, reached 100 percent power 4
- for the first time at 9:07 a.m. (EDT) on May 12. The unit remained at this power level for approximately an hour. The unit is operating at 98 percent power today.
Grand Gulf is now in the final phase of power ascension testing which has been under way sinca a full-power operating license was issued on August 31, 1984.
Mississippi Power and Light has responded to a media inquiry concerning this event.
Tha State of Mississippt has been infomed.
This PN is issued for infomation only.
Contact:
R. Carroll, 242-5543 V. Brownlee, 242-5583 DISTRIBUTION:
H. Street MNB8 Phillips E/W W111ste MAIL:
Chairman Pal 1adino F NRR TF NM55 ERIDtB Cosa. Roberts PA OIA RES DOT: Trans Only Comm. Asselstine MPA AE00 Applicable State Conn. Bernthat ELD Coss. Zech Air Rights INPO SECY SP NSAC ACAS CA PDR Regions:
Licensee:
(Reactor Licensees)
Applicable Resident Site l
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