ML20198B760
| ML20198B760 | |
| 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 Q4-84-053, Q4-84-53, NUDOCS 8511070229 | |
| Download: ML20198B760 (33) | |
Text
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&VLC x UMTED ST ATES NUCLEAR REGULATORY COMMISSION
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p .g f OFFICE OF INVESTIG ATIONS FIELD OF FICE. REGION IV
'q * * *fc 611 RY AN PLAZA DRIVE. S'ilTE 1000
.,,,. ARLfNGTON TEXAS 76011 REPORT OF INQUIRY May 14, 1985
SUBJECT:
WOLF CREEK GENERATING STATION: ALLEGED MISSING WELD RECORDS REPORT NUMBER: Q4-84-053 On November 19, 1984, the NRC Region IV Regional Administrator, Robert D.
MARTIN, made a written request to the Region IV Office of Investigations (01) that appropriate inquiry / investigation be conducted, after NRC Region IV Inspection Report No. 50-482/84-22, dated October 26, 1984 (Exhibit 1),
disclosed that a substantial number of Wolf Creek safety-related weld records were missing. MARTIN advised that Region IV held an enforcement conference in October 1984 with Kansas Gas & Electric Co. (KG&E) and issued an escalated enforcement action, a Notice of Violation, to KG&E in November 1984. MARTIN also advised KG&E proceeded with a KG&E corrective action program, Corrective Action Request No. 19 (CAR 19), dated October 17, 1984, which resulted in an extensive review of structural steel welding and associated records.
On February 27, 1985, a public meeting between KG&E and the NRC was conducted at the NRC headquarters in Bethesda, Maryland. An NRC contract court reporter was present and recorded the testimony of all participants. The meeting allowed KG&E and its consultants to explain the issue of welding deficiencies discovered in the miscellaneous structural steel that also included the issue of missing records. During the meeting, KG&E Quality Assurance (QA) Manager Bill RUDOLPH, admitted the Wolf Creek QA program suffered a " breakdown associated with record retrievability" (Exhibit 2, transcript excerpt page 65). During the same meeting, John C. BERRA, Vice President-Operations, Daniei International Corporation (DIC), initially stated that the American Welding Society (AWS) Code makes no requirement to create or retain inspection records (Exhibit 3, transcript excerpt page 71). BERRA subsequently admitted that DIC's review of the weld record problems revealed " inadequate implementstion of our welding documentation procedures was a contributing factor to having less than 100 percent retrievability of Miscellaneous /
Structural Steel Welding Records" (MSSWR) (Exhibit 4, transcript excerpt page 86) (An MSSWR documents welding and inspections of safety-related welds).
On March 15, 1985, Richard P. DENISE, Director, Division of Reactor Safety and Projects Divisior, Region IV, NRC, was interviewed (Exhibit 5) by NRC Investigators R. K. HERR and M. EMEP,50N in Arlington, Texas. DENISE said the NRC Region IV Task Force (TF) was formed in July 1984 as a result of Region IV management's concern regarding the completion of the NRC inspection effort at Wolf Creek. DENISE stated that the TF, which was located on site, closely monitored KG&E's management efforts to ensure appropriate implementation of all corrective actions. DENISE stated that in July 1984, NRC's TF became g (LM aware of a substantial number of Wolf Creek safety-related structural steel weld inspection records which were unretrievable and/or missing. DENISE b f stated that on June 3C, 1983, DIC initiated NCR ISN-11957CW (Exhibit 6) which documents that missing wela records were discovered for the emergency service -
water system (ESWS) pump house structural steel. He stated that on August 10, 8511070229 851015 A RI biol PDR
r Q4-84-053 1 >
1983, DIC originated CAR 31 to address the missing weld records in question.
At this time, DIC conducted a review concerning a possible violation of 10 CFR 50.55(e) and decided this was not a reportable item to the NRC. CAR 31 was issued on August 16, 1983. DENISE said the NRC Region IV Inspection Report No. 50-482/84-22, supra, itemized the concerns of the NRC TF with respect to the Wolf Creek inspection program. DENISE said that as a result of the above NRC inspection report a Notice of Violation (Exhibit 7) was issued to KG&E, which identifies a significant breakdown in the KG&E QA program for the inspection and correction of defective safety-related structural steel welds.
DENISE said KG&E initiated a 100 percent reinspection of all' accessible structural steel welds as part of CAR 19, issued on October 17, 1984 The ,
executive summary and conclusions sections of KG&E's CAR 19 is included with >
this report as Exhibit (8). DENISE said this corrective action was approved, monitored, and continually evaluated by the NRC TF. DENISE described the CAR 19 reinspection as a well disciplined and structured plan utilizing absolute acceptance and rejection criteria. DENISE pointed out that 1,509 welding records were discovered missing between June 1983 and October 1984 by DIC, KG&E and NRC. DENISE explained that 91 percent of the joints which were identified as having missing documentation were. reinspected by NRC and/or KG&E personnel. DENISE advised that 6 percent of these welds were partially inspected because of accessibility problems, and only 3 percent were not inspected because they were inaccessible.
DENISE stated a civil penalty was subsequently imposed against KG&E in the amount of $75,000 for the failure to properly inspect, correct, and mairTtain records regarding safety-related structural steel welds. DENISE advised that KG&E management subsequently paid the civil penalty, documented by the December 31, 1984 letter (Exhibit 9) from Glen L. K0 ESTER, Vice President-Nuclear, KG&E.
On April 30, 1985, Lawrence E. ELLERSHAW, NRC Region IV Inspector, was interviewed (Exhibit 10) by NRC Investigators M. EMERSON and-R. K. HERR in Arlington, Texas. ELLERSHAW stated he had been, assigned to the NRC TF, formed in July 1984, to inspect the Wolf Creek facility. ELLERSHAW said he was responsible for the inspection of structural steel and associated records.
l ELLERSHAW said the NRC TF inspections revealed that procedures to generate
. MSSWRs existed, however, no adequate procedures existed for the maintenance l and/or retention of the MSSWRs. ELLERSHAW said the craf t personnel were told l
to initiate the MSSWRs, but were not instructed where to file / store the i
. completed MSSWR's. ELLERSHAW advised that as a result of the lack of specific i guidance, confusion existed with the welders and the QC inspectors, thereby t causing the MSSWRs to be stored in various locations. ELLERSHAW concluded by stating he uncovered no evidence of intentional wrongdoing on the part of anyone regarding the missing MSSWR's, and attributed the missing liSSWR's to
[ the absence of proper procedures on the part of DIC to ensure record maintenance, i
On March 6,1985, during a separate 01 investigation (4-84-026), Henry Frank K0ZLOWSKI, Jr. and Ronald MASTERS, both former DIC Quality Control (QC) inspectors, were interviewed by R. K. HERR and reporting investigator in the
! presence of an NRC contract-court reporter. K0ZLOWSKI stated he was employed l
by DIC from April 1981 until May 1984 as a civil QC inspector at the Wolf Creek facility. K0ZLOWSKI said that while working for DIC he became aware of a problem regarding the storage of safety-related welding inspection records.
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Q4-84-053 7 o K0ZLOWSKI revealed that some of the weld records in question were carelessly stored in a cardboard box on the DIC QC inspector's office floor. K0ZLOWSKI acknowledged these weld records were not safeguarded or treated as retrievable documents. K0ZLOWSKI added the weld records would sometimes overflow out of the cardboard box onto the floor where they stayed until they were discarded by janitorial personnel who were cleaning the area (Exhibit 11, transcript excerpt page 51 and Exhibit 12, page 58). MASTERS, who was also employed as a DIC Civil QC inspector at Wolf Creek from December 1980 until August 1984, confirmed K0ZLOWSKI's description of the " sloppy" record keeping (Exhibit 13, transcript excerpt pages 19 and 20).
Investigator's Note - K0ZLOWSKI also comented, when discussing ~ missing weld records, that the records in question could be stored in DIC's Document Review Group (DRG) office. On site inquiries by 01 disclosed an NRC inspector (ELLERSHAW [ supra]) had previously inspected these records and included them in the NRC Region IV overall review of documentation as reported in Exhibit (1).
Nine DIC QC inspectors and supervisors, including Stanley A. JOHNSON, were interviewed between April 17-24, 1985, during a separate investigation (4-84-026). These personnel, who had knowledge of the MSSWR situation, verified that the MSSWRs were carelessly maintained and explained that an organized filing system for the forms did not exist. The inspectors and supervisors stated that there was confusion with regard to retention of the MSSWRs between 1981- and 1982 and many of these documents were placed in -
various filing cabinets, boxes, and other on-site storage areas. The interviewees were not serprised that MSSWRs were missing and placed much of the blame on DIC's failure to provide adequate and clear guidance regarding the retention of these records. JOHNSON's statement is enclosed as Exhibit (14).
A chronology of the events relevant to the missing MSSWR's was developed from a review of the various documents identified in this report and testimony obtained during this investigation (Exhibit-15)$.~
In consideration of the following: (1) the NRC Task Force's reinspection effort, (2) the NRC-imposed civil penalty, (3) the licensee's 100 percent NRC-monitored reinspection effort, (4) the licensee's' subsequent admission of a QA program breakdown, (5) the construction contractor's admission of inadequate implementation of welding documentation procedures, (6) the witness' reported careless disregard of record maintenance on the part of DIC, and (7) the absence of evidence of wi]1 fulness or intent on the part of anyone to destroy or hide records or interfere with the NRC inspection effort, the issue of the missing records has been, in 01's view, appropriately addressed..
No further. investigation of wrongdoing in this case is anticipated, and this inquiry is closed.
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.
3 J
Q4-84-053 1
EXHIBITS:
(1) NRC Region IV Inspection Report No. 50-482-/84-22/10-26-84 (2) Transcript Excerpt Page 65 of the 2-27-85 Public KG&E/NRC Meeting
- 3) Transcript Excerpt Page 71 of the 2-27-85 Public KG&E/NRC Meeting
- 4) Transcript Excerpt Page 86 of the 2-27-95 Public KG&E/NRC Meeting
- 5) Report of Interview with Richard P. DENISE/3-15-85 (6) DIC NCR No. ISN-11957CW/6-30-83 (7) NRC Notice of Violation /11-21-84 (8) Executive Summary and Conclusions Sections of KG&E's CAR 19/-Undated-(9) KG&E Letter /12-31-84 .
(10) Report of Interview with Lawrence E. ELLERSHAW/4-30-85 (11) Transcript Excerpt Page 51 of Henry Frank K0ZLOWSKI's Testimony /3-06-85
. (12) Transcript Excerpt Page 58 of Henry Frank K0ZLOWSKI's Testimony /3-06-85 (13) Transcript Excerpt Pages 19 and 20 of Ronald MASTER's Testimony /3-06-85 ,
(14) Statement of Stanley A. JOHNSON /4-24-85 (15) Chronology /4-30-85 REPORTED BY: , m son .
Markg' Inves tigat r PAP,TICIPATING PERSONNEL: & /
~ ~ ~ -
Yicha'rd K.~ Herr '
Director APPROVED BY: N //f /,fd/I Richa'rd~K~ Herr Director cc: B.B. Hayes w/ exhibits l E.J. Gilbert w/ exhibits ,
i R.D. Martin w/ exhibits l T.F. Westerman w/o exhibits t '
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Q4-84-053 2240 05 06 65 1 WRBeb 1 MR. DENTON: Well, coming back to your findings 2 chart Where you made some significant findings in the ASW 3 area, why do you think, from your overview standpoint, that ,
4 they weren't found in other parts of the plant? Because the-5 other parts of the plant weren't controlled by NSME '
6 standards? .
7 MR. RUDOLPH: Yes. There are much more rigorous 8 controls applied to other types of welding activities, 9 specifically ASME we1 ding activities.
10 MR. DENTON: Is that the sole answer? I mean is 11 it the people who do the job?
12 MR. RUDOLPH: If you will permit us to continue 13 .with our presentation, these. root-cause factors will be 14 identifi*d e and explained in detail.-
15 MR. DENTON: So we can learn some lessons from a it, suppose ce htd to build Enother plant. '. Th a t would you 17 do differently to keep this from reoccurring?
18 MR. RUDOLPH: Ouite frankly, the record 19 retrievability program Which has been enhanced to prevent' 2D recurrence *r_2d be retdily Lcopted in itt current condition-21 cc it c::ir r right nc.. en the ci te . We had a quality 22 assurance program breakdown associated with record 23 retricrability which it one of the root caures which will be 24 explained. ,
25 other thcn_that program enhancen.ent which has EXHIBIT (2)
r ...
, Q4-84-003 2240.06 02 71 2 WRBeb 1 packages beginning in 1983 for turnover that occurred in
'2 1983. And as Mr. Rudolph pointed out, in that package 3 putting-together process the records were shovm to be less 4 than 100 percent retrievable.
5 (Slide.)
6 The' code used for structural steel at-Wolf Creek 7 is AWS D-1.1, 1975 edition. The major activities covered by 8 AWS were the design of welded connections, the workmanship, 9 the filler material requirements, weld procedure 10 qualification, welder qualifications and inspect. ion 11 criteria.
12 ' AWS does not specifically address qualifications 13 of inspectors nor the crestion and/or retention of 14 inspection r'ecdras. In general, the dodumentation 15 requirements of Wolf Creek are determined by Reg. Guide 1.2@
16 c n 6 A::5 I <5.2, cuc12ty arrurance prograr, rcquiren.cnts for 17 nuclear power plantr. And the inspectors' qualifications 16 are addressed g in ANSI 45.26, qualifications of inspection, 19 examination and testing personnel for nuclear power plants.
2C I repcat, the docurentitier for J.'s 60er not 21 rcquirc documcntction of inrpection ncr inspection reccrds 22 to be generated or kept. Its records that r.eed to be 23 gencrcted pertain to the steld procedure qualification and 24 the welder qualification.
. 25 The project construction and inspection S
EXHIBIT (3)
____.__.____..____________._-_______.________.__.___-____________m
.Q4-84-053 V
2240.07 04 86 1 WRBmpb 1 gentleman, in the time frame we had we couldn't document his
'2 background and we re-reinnpected his. And that's documented 3 in the CAR-19 report. .
4 Our documentation was in accordan'ce with AWS --
5 which only refers to procedures and welder qualification 6 records -- and ANSI, which I previously explained that that 7 governs our documentation.
8 In the programmatic review we als'o looked, as 9 Mr. Ruldolph mentioned, at the surveillance report; 'KGLE 10 surveillance report S3-72 which was in' question. And we 11 provided evidence that that had been addressed previously, 12 and there was documentation to demonstrate that.
13 Now the documentation review centered on the 14 retrievability of MSSWEs. As I stated b.efore, we could not 15 retrieve the records.
16 Our review concluded that ina6 equate 17 implementation of our welding documentation procedures was a 18 contributing factor to having less than 100 percent c, 19 retrievability. It was poor implementation of those 20 procedures.
21 Other programs have better procedures. The 22 procedures for AWS could have generated 100 percent 23 retrievability but poor implementation of them didn't.
24 Having established a root cause for those, e 1
25 looked at other programs for potentini similar problems.
I EXHIBIT (4) I
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Q4-84-053 REPORT OF INTERVIEW WITH Richard P. DENISE
, On March 15, 1985, Richard P. DENISE, Director, Division of Reactor Safety and Projects, Region IV, NRC, was interviewed by NRC Investigators M. EMERSON and R. K. HERR at the Office of Investigations, Region IV, NRC, in Arlington, Texas.
DENISE, who is also serving as the Director of the NRC Wolf Creek Task' Force (TF), was questioned regarding his' knowledge of the Wolf Creek missing ,
structural steel weld records. DENISE pointed out that the.NRC Region IV TF ,
was formed in JulyJ1984 as a result of Region IV management's concern over the completion of the NRC inspection effort at_ Wolf Creek. DENISE stated that the TF, which was located on site', closely monitored Kansas Gas & Electric Co.'s (KG&E's) management efforts to ensure appropriate implementation of all corrective actions. DENISE stated this included the monitoring of KG&E's
, corrective action programs which had been instituted after the discovery of s problems in the area of safety-related structural steel welding records at the Wolf Creek Generating Station (Wolf Creek). The TF activities also included independent inspection by NRC inspectors. DENISE provided the following ch.ronology of the major events that were involved in- the structural steel welding area. Between 1977 and 1981, the vast majority of structural steel welding was performed at Wolf Creek. DENISE stated there were approximately 11,000 field-made welds within the 6 safety-related buildings; i.e., -
auxiliary, reactor, control, emergency service water system, fuel, and diesel generator buildings. These welds were made and inspected by the KG&E construction contractor, Daniel International Corporation (DIC). DENISE said all of the welds and inspections were supposed to have been documented by craf t and inspectors on Miscellaneous / Structural Steel Welding Records (MSSWR); however,1,509 MSSWRs were found missing.
DENISE related that as a result of inspection by DIC in 1983 and 1984, deficient fillet weld conditions were identified on component supports. In respor.se to this discrepancy, DIC Quality Control (QC) initiated a' random reinspection of accessible structural steel fillet welds in safety-related buildings. This reinspection effort identified 148 rejectable welds in a sample of 241 that resulted in the issuance of DIC Corrective Action Request (CAR) No. 29 (CAR 1-W-0029). DIC subsequently concluded that only six of the welds would have to be reworked and the remaining 142 welds would be "used as is."-, DIC identified nearly all rejectable weld conditions as " cosmetic" in nature, notLjeopardizing the structural integrity of the buildings.
- l' DENISE stated that on June 30, 1983, DIC initiated NCR ISN-11957CW which l documented that weld records were discovered missing for the emergency service water system (ESWS) pump house structural steel. He stated that a DIC review
, of documentation in 1983, prior to building turnover-to KG&E, initially i revealed approximately 16 percent of the required PSSWR's were missing fromi
- the fuel building. Additionally, 24 percent of the required MSSWR's'were '
missing from the Reactor Building. DIC approved and issued Corrective Action Request ho. 31 (CAR 1-C-0031), dated August 16, 1983 (which was subsequently revised a number of times), which called for a review of all existing MSSWR's and the initiation of Nonconformance Reports (NCR) for each building having
- structural steel welds with missing PSSWR's. He stated that at that time DIC i
j EXHIBIT (5).
Q4-84-053 conducted a review regarding a possible violation of 10 CFR 50.55(e) and decided this was not a reportable item to the NRC. DENISE said each NCR was to be evaluated and each. weld was to be either reworked or "used as is,"
' depending upon circumstances after review of existing documentation for each ,
building. . DENISE explained that DIC and the KG&E project engineer concluded missing MSSWR's were acceptable provided the quality inspection program was '
acceptable. DENISE stated 1G&E, DIC, and Bechtel intended to close out this CAR on the basis of the relatively small (as seen by them) number of missing MSSWR's and the fact that the ,revious reinspection of a sample of structural
steel welds showed a small num'ber of welds (6) actually requiring rework.
Thus, DIC stated, and the other parties. agreed, that the fact that MSSWRs were ,
missing was deemed acceptable in this instance because of the weld quality .
established during the sainple reinspection. DENISE said the NRC first learned of the potential records ~ problem about' July 1984 during conversaticns between KG&E personnel (NFI) and an'NRC TF inspector (NFI). An NRC TF review of CAR 29 and CAR 31 was undertaken at this. time. DENISE explained that the major ;
cause of the missing MSSWR's was concluded by DIC to be a lack of procedural compliance with r spect to responsibility for maintenance of these records.
The MSSWRs were rt.portedly stored in various locations in the buildings being constructed and were under the control of various personnel, all of which contributed to the lack of control over the records in question. DENISE said that during August 1984 a document reconciliation effort was initiated by KG&E to determine which safety-related structural steel welds were lacking MSSWRs.
During September 1984, KG&E, DIC and Bechtel made a joint presentation to the NRC TF. This presentation identified the applicant's belief, at that time, that the missing MSSWR's were a problem of document retrieval, not a problem of quality installation / inspection of the structural steel. DENISE said the NRC TF did not agree with KG&E, Bechtel and DIC's evaluation that they had properly handled the disposition of CAP, 29 and CAR 31, and that the problem was only one of document retrieval. DENISE said that based on the NRC objections, KG&E agreed to perform a sample structural steel joint inspection of six randomly selected structurally significant joints. in each of the six safety-related buildings. This inspection effo}t resulted in the ~ discovery;of missing welds, missing structural members, and deficiencies with respect to weld size. DENISE said this information was formally reported to.the NRC, under 10 CFR, Part 50.55(e), on Septemberc18,'1984.- r On October 17, 1984, KG&E issued CAR 19 Ein order'to initiate the necessary
. actions ' required to resolve the identified' structural steel welding problems.
The specific issues covered under CAR 19 included missing MSSWR's for safety-; ,
related structural steel welds; deficiencies in previously accepted structural 3 steel welds; missing structural welds and/or material; and documentation that
-a weld was inspected.and accepted but, in fact, did not exist.
DENISE stated that in view of-the aforementioned' events it was determined that
. a violation of NRC regulations 'had occurred because of a significant, breakdown
'in KG&E's safety-related structuralnsteel quality assurance program.
' Supporting documentation of the violation is reported in NRC Region IV
~
Inspection Report No.z50-482/84-22. In October.1984, an enforcement meeting !
, was conducted with KG&E at the RIV offices in Arlington, Texas. .In November 1984, a Notice of Violation'was sent'to KG&E. KG_&E agreed to conduct a 100 percent reinspection of' accessible field welded structural steel joints,
~
as per CAR 19. KG&E subsequently paid the civil penalty. ,
, EXHIBIT s (5)
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Q4-84-053 DENISE stated the NRC TF had insisted on a comprehensive reinspection effort of structural steel welding, and that this was done by qualified DIC inspectors between October 1984 and February 1985. DENISE described this reinspection as a well disciplined and structured plan with absolute acceptance / rejection criteria. DENISE said the NRC TF app' roved the implementation of this' reinspection, continually monitored its implementation, and performed extensive independent inspections using NRC personnel.
DENISE said that 2,670-(100%) joints were targeted for the intensive -
reinspection effort. DENISE emphasized that 2,403 (91%) of the targeted joints were totally accessible,165 (6%) were partially accessible, and cr.ly 102 (3%) were totally inaccessible. ;
DENISE said by utilizing accepted engineering analysis only 66 (2%) of the total 2,670 targeted joints could not be, inspected or analyzed. DENISE added '
that of the 2,604 joints which were inspected and ' evaluated, 82 joints (3.14%)
were identified as exceeding the design allowable stresses. DENISE concluded that in view of the large percentage of evaluated joints and the small number of joints which exceeded design stress allowance, a confidence level of virtually 100 percent could be applied to the teinspection effort. DENISE ;'
pointed out that the missing 1,509 MSSWR's did not violate the AWS welding code; however, DIC's' failure to adequately maintain quality records did constitute a violation of NRC regulations, 10 CFR, Appendix B. .
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'Ibe ?old points winch ::oy have been bypassed, and justificaticn for the h7.abil.ity of each, are docnznanted belcw: - ,'
- l. Fit-::p - Fit-up is gtre_rned by the welding techniqJe which the weldcr s:tilized to install the weld. kb1ders are trained regarding tecimique paracetars.
- 2. Qualificatien of Wir% s - Welder gali*icatirn is mcnitored by the selder's swervisor, who is reggsible for ==cipng wirb s cnly to those joints for which they are em1f fied (Re.f. CWP-503, paragragt 4.1. 4. 2) . Ead of the cited wlac is a fillet weld, which any wirbe wtc has passed a:rf grocrac-welded test is gm14*ied to install. -
F 3. Fille- .Materir.l.s E7018 filler raMh are centrolled, issued and ret:.:rned in a h with CMP-503. Any deviations frcrn tins p.We sculd have resulted in a . N~R, which wculd have addressed /Acan the p =ble=.
- 4. Prcheat - Tach of the cited welds regairal 50 F m:tnim.n preheat. Ant 21ent tgmture in # e ESW *5 pu=pnouse is generally r.nintained at *repe atures greater than 50 F. Ranin qtutlity surveillances pzuvide additional assura:v:e of ccrpliance s-ith this requirurent.
- 5. Fi.~.al Vis2 1 In. W. - 20 of the cited welds were visimiay esomd_m=$by Walding En::=ncering. All of the 20 welds had been paa.nted, arxi fcur of the 20 welds were cnly par-ially e ssible; h w ever, the quality of wrk:anship was very cood. 'Ibe excr.ined w1a< were an a=ce;r.able size (equal to or greater thm 1/4 2nch), and were free of visible defects.
Based en the qmlity of the workranship obse.rved, it is premble that these welds were previously inspected and mpml by Cuality.
C74:SE CF NCTC2EPMT-N E AC JC'IC: "O PPEC.'T RErURPIN~E:
A conclusive datermL.ation as to whether or not the required k,e mtation -
was generated is rot ;cusible. e the prc=lem which necessitated the M x:eCAR-1 ~ g pb been generated ICR. Maitional to address action will not be required. -
,%,, . G f?7ki \
k SQQ g JAN 181985 L
, 9,g.y TIMF l,
s
, y y - rw
'b;$'_o77.1-2 n.muw
( (
e @EEJ!E: O7.g NCNCONFORM ANC E REDORT (NCR) CAR*"""**0031h PGr/ .
Pro:eet e- - s um sige sy onw
-*1 *
- CI.T CREZZ - 7158 s
ISN11957CW Ref. C-KS3OlQ R/4 E.S.W.S. Pumphouse Structural Steel.
El. 2000'. The following documents are missing.
AC3315 clips to beam welds records.
Clip to F3315 beam - both ends. .
Clip to E3315 beam - - w d S o T d P AI DS 4 412 9 26 ,
Clip to B3315 beam - both ends.
Clip to A3315 beam - both ends.
Clip te D3315 beam - both ends.
Clip to G3315 beam - west end.
. n Q..
AC3315 clips to embed (LtR) . . . N. * * " '
Removable beams
.~
" '.~ . '.,. ..
Clip to embed at beam A3316/1
- Clip to embed at beam A3316/2 Clip to embed at beam B3316/1 Clip to embed at beam B3316/2 Beam to clip and clip te embed (LER) f A3317/1 G3315 East End
,7 : - '-- -,75te,- r - .= g'g 2 a.24-E3 .
l* B2317/1 B3317/2 f.: - ' :. .y, ~'pg .3 ,.7,",. . a ,
-~
I
//-3 -d '5 The above represe.ts a total of 26 missing MSSWR's.
Ref C-KS301Q R/4 E.S.W.S. Pumphouse El. 4009'.
No MSSWR's available for this elevation.
required. A total of 16 MSSWR's El. 2000' 26 MSSWR's missing. -
El. 2009' 16 MSSWR's missing. V [# #O c f 42 Tesal
{ e g g DAN 181SES 8 ,
4
% .d* TIMr
- M.%.-
ter._
h~S%
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%.k .5 sse. 1 5
x--
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w -ec-u , _ _- _
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CNR303 PG V UEl
@GSEE C** *** ""* *a"* h** 5 "9
- NONCONFOR$4 f.NC E REscRT .tNCol *f _
__ m._
i SC* T CEZI - 71S8 t, - w , . s c -..m i A33I'"!ONAL D:sPcs:-ICN
- l. Results of reinspectict; (a ttach:nent 1) showed that two (2) Welds were rejected for incooplete weld (weld apprmv'mately 1/4" short on bottom of clip at end
- cf bean). C =me tic indications (porosity, crater, cold roll, lack of fusion)
', were noted oc four (4) welds;the cosmetic " defects" are of the type ,wiuch could '
be rer.:ve,i by g:2ng and would not reduce weld below required size. ,
82 76 // 63 j 'The to al n=cer of welds inspection was % % were found to ne acceptable.
t Six (6) welds wer e rejected for minor defects which will not be injurious to the serviceability of these welds. It is the opinion of welding engineerir.q that the resits of this reinspection have not shown that there is a significant problem in regards to these welds.
0 /O/py/g grm.;& Lam.e,na &~msA dWSshif wns 4/ (2rn 2occ'-o"cc'- a A /& m 2cc 9 '-o " 62. .
psi 74 cv' b W " b AEtce d as se & c t;u W s. , of G of' d!IE' i
MJM.
,f, b5 '.
s . . . - -
t ,
.ns ktRy u C, y c:2.m n 'o->
- c .
5 JAN 181985
.o" Tif *F-e
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Q4-84-053 t
}ULNSAS GAS AND ELECTRIC CO.MPANY FINAL REPORT -
CORRECTIVE ACTION REQUEST NO. 19 4
EXHIBIT (6) s.
b
FINAL REPORT KG&E CORRECTIVE ACTION REQUEST NO. 19 TABLE OF CONTENTS I. Executive Summary II. Introduction III. Objective ,
IV. Discussion of Findings and Corrective Actions V. Conclusions VI. Appendix A. KG&E Corrective Action Request No. 19 B. 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
- 1. Letter BLKES-1348, C. M. Herbst to G. L. Touts, $1/05/84
- 2. Letter KNPLKWC-84-065, J. A. Bailey to G. L. Touts, 11/13/84 F. Lehigh University Report - Structural Steel Welds at Wolf Creek 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).
~.
I of 33
. 1.' CAR-19 EXECUTIVE
SUMMARY
Because of deficiencies (i.e., undersize, undercut,...) previously found in fillet welds on ASME and Special Scope hangers, DIC performed a randot reinspection of structural steel fillet welds in February, 1983_in all "Q" designated buildings in the Powerblock. This reinspection indicated that an unacceptable percentage of structural steel fillet welds were deficient in the Auxiliary, Control and Fuel Buildings. A Corrective Action Report (CAR 1-W-0029) was initiated by DIC to implement reinspection, and nonconformance reports were generated to document and disposition deficiencies noted.
Subsequent to the issuance of CAR 1-W-0029 it was determined, during the course of document reviews in the Building turnover process, that Miscel-laneous Structural Steel Weld Records (MSSWR's) could not be located as procedurally required for all structural steel welds in "Q" designated buildings. These missing MSSWR's result,ed in DIC issuance of CAR 1-C-0031_.
The concerns addressed in CAR's 1-V-0029 and 1-C-0031 as well as other items listed in the " Introduction" section of this report caused KG&E Construction Quality Control to initiate a' limited inspection verification program. Through this inspection program additional concerns were raised as a result of the inspection verification results. These results identified instances of missing welds which had no inspection records, two missing welds which had inspection records, and welds with inspection records that did not co=pletely co= ply with project inspection and documentation criteria. The results of the verifications combined with the missing weld inspection records identified the need for a formalized action plan to fully investigate the concerns and formulate corrective action as necessary. To accomplish this KG&E QA initiated Corrective Action Request 19, describing the concerns and recommending corrective action on October 17, 1984. Based on the correc-tive actions recommended by CAR-19 and additional actions deemed warranted in support of the investigations, a Management Plan was developed to designate the nature and extent of the investigations.
The Management Plan covered three basic categories of investigation and evaluation. One category was a process of reinspection to identify and evaluate actual hardware conditions in the field. a second category addres-sed the programmatic aspects of Structural Steel erec~ tion through evaluation of both construction and quality program procedures. A _ third category addressed related considerations such as other AWS D1.1 applicat'iEis, evalua-tion of missing welds identified during the reinspections, evaluation of Scre m ble inspection _ records completed for velds found to be missing, and review and evaluation of surveillances , audits , and reports pertinent to AWS welding. 'Although not initially in the scope of KG&E CAR-19, non-welding related quality programs were reviewed for comparable programmatic deficien-cies. In accomplishing this KG&E and DIC conducted ,an extensive program assessment of the Piping , Hanger, Mechanical, Electrical and Civil disci-plines to ascertain the adequacy of the construction and quality programs instituted. This program assessment was conducted by KG&E and DIC Management representatives, and concluded that a satisfactory level of confidence exists to assure compliance of these to 10CFR50, the FSAR, ANSI N45.2, and design and procedural requirements.
The intent of the program evaluation was to evaluate the various construction and quality programs / procedures to determine their compliance to the AWS D1.1 Welding Code and FSAR commitments. This evaluation included
2 of 33
. relevant aspects of the various related programs from the initiation of purchase orders for procurement of structural steel and welding materials, to final installation and quality acceptance. The proced'res for receiving, storage and handling of materials were evaluated, as well as compliance of procedures for training and certification of inspectors to ANSI N45.2.6 and welder qualification to AWS requirements. The procedure reviews included a thorough evaluation from their origination through subsequent revisions, including an analysis to assure current conformance to design document requirements. No findings were noted that were determined to be contributing factors to inadequacies in AWS D1.1 applicchtions, although some procedural inadequacies were discovered and reconciled.
All other safety-related programs utilizing AWS welding were analyzed to ensure that the root cause identified as the reason for previous acceptance of deficient structural steel welds was not inherent, or impactivo, to these programs as well. The method of documenting weld inspections, control of this documentation, and cccountability to assure all required documentation was retrievable was resecrched for AWS D1.1 welding applications in raceway supports, electrical equipment, mechanical equipment, fire ' dampers , safety-related HVAC ductwork and supports, miscel'laneous steel and embed fabrica-tion, and pipe whip restraints for assurance that problems similar to those encountered in structural steel did not exist. Previous 1v compiled infor-mation Inciucing Constru . tion Self Assessment Reports, KG6E QA Reports and Surveillances, DIC QA Reports, DIC Project Monitoring Program Audits, and DIC Corrective Action Reports were reviewed to determine if the results of previous investigations indicated other potential problem areas relevant to AWS D1.1 welding. No findings were noted that could be considered to be contributing factors to inadequacies in AWS DI.1 programmatic applications.
An analysis of hardware installations for other project applications of AWS DI.1 welding identified one other area to be investigated for AWS welding problems. This is in the area of electrical equipment installations where the method of permanent insta11ction is by welding the equipment mounting frame to foundation embeds. DIC is addressing this potential problem on Corrective Action Report No. 1-EW-0046.
Reinspection of field welds was conducted utilizing, AWS Certified Welding Inspectors who were also certified to the DIC Quality Program requirements of ANSI N45.2.6. Inspections were performed in strict compliance to the Inspection Verification Plan which established inspection criteria and documentation requirements, and was incorporated into an existing DIC Quality Procedure, QCP-VII-200, and approved by DIC, Bechtel, and KG&E.
DIC and Bechtel research substantiated that all welders and welding procedures applicable to AWS D1.1-1975 welding of structural steel installations were qualified in accordance with AWS requirements. Research by DIC and Bechtel resulted in assurance that the programs and procedures for the purchase and control of weld filler materials used in AWS DI.1 applica-tions were in compliance with AWS requirements, and were properly implemented on site.
The retrievability and control of Miscellaneous Structural Steel Weld Records was thoroughly researched, and a determination made that inadequate
~ implementation of DIC Construction procedures was the primary contributing factor relative to retrievability and accountability problems in this area.
}
}f 9 ,j
(
3 of 33 s
An evaluation of the DIC Quality inspection training program demon-strated that this program and related procedures were in compliance to ANSI N45.2.6. Further investigation concluded that Quality inspection training was appropriate and adequate during the struct ural steel installation time frame.
An evaluation of DIC Quality inspection procedures and criteria applicable to the original structural steel installation /2nspection period revesled several procedural inadequacies. A thorough analysis of the emission of each inspection criterion of AWS D1.1 structural steel applica-tions was accomplished, with the conclusion that no adverse impact had resulted from these procedural inadequacies relative to AWS DI.1 welding inspection.
Inspection criteria to be used in the structural steel reinspection activities was procedurally defined and. training of all personnel completed prior to reinspection initiation. Sufficient technical justification was established by Bechtel to validate inspection of welds through a predeter-mined maximum thickness of paint. An analysis of reinspection results determined the root cause of the previous acceptance of deficient structural welds to be due to DIC inspection implementation differences relative to inspection vs. reinspection techniques, and inadequate impicmentation of applicable DIC procedures during original inspection efforts. These inspec-tion implementation differences are discussed elsewhere in this report, referencing the Reedy, Herbert, Gibbons documentary included in the Appendix, section VI.G.
Two joints (each missing one weld) of the two thousand six hundred sixty-nine (2,669) reinspected (representing more than 11,000 welds) had documentation reflecting the installation of these welds when in reality they were not installed.
Research revealed no evidence to indicate that either was a case of deliberate falsification. Additional investigations did indicate that human error was the cause of incorrectly documenting these nonexistent installa-
~
tions. .
Reinspection found that approximately two (2) percent of the inspected welds were not installed as required by design documents. These errors were primarily due to craft / engineering confusion relative to installation drawing details and requirements. Failure to install these welds and materials, although in some cases determined to be significant in impact to stress allowable calculations, would not have resulted in material or structural failure if left uncorrected.
The total number of joints subjected to the reinspection program was two thousand six hundred sixty-nine (2,669). These joints were selected by Bechtel _as structurally significant (See Appendix IV. D) with the distribution being: 693 in the Auxiliary Building, 1300 in the Reactor Building, 265 in the Control Building, 98 in the Diesel Generator Building, 36 in . the ESWS Pumphouse, and 277 , in the Fuel Building. The reinspection documented an as found condition regardless of the weld acceptability. All
\
results were forwarded to Bechtel in the form of inspection data sheets for evaluation. This evaluation was based upon Bechtel's review of reinspection data accumulated and nonconformance reports (NCR's) generated. The evalua-tion for structural adequacy was made based upon this cumulative data that
_ _ - _ . - _ _ _ _ _ _ - _ - _ . . _ _ - - - - - _ _ _ _ _ - - - - - _ _ _ _ _ _ _ _ _ _ _ . - . - - - - - - - _ _ _ - _ - - - , _ , _ _ - _ . - - _ _ - - - - . . _ _ - - - - . - - - - - - - - - - _ _ . _ - - _ - - - - -- - - - - - - - . - - - - -_----,-----._--_x-____.-----------_---._---__-a--__-- - - _ _ _ - - - - - . - - _ _ - - - - _ - - - - , . _ _
4 of 33
. reflected the as-built condition of the structurally significant joints prior to any rework or repairs. No deficiencies were identified, which if left uncorrected, would have adverselv affected the safe operation of the riant.
The results of this evaluation provides assurance that Safety Related Ak'S D1.1 structural steel welding complies with all Quality criteria as specified in the related design documents, and is within the tolerances of acceptable deviation as determined by the Architect / Engineer.
Joints that in the as-built condition were determined to exceed the design allowable stresses were all reworked. In addition joints in which the design allowable stresses were not exceeded in the as-built condition but were missing welds, were also reworked.
9 9
31 of 33
, V.* Conclusions The technica) evaluation of WCGS structural steel significant joints, which was performed by Bechtel based upon reinspection data accumulated, established that safety related AWS DI.1 structural steel welding complies with all Quality criteria as specified in the related design documents, and is within the tolerances of acceptable deviation as determined by the Architect / Engineer. This evalt.ation for structural integrity was based upon this cumulative data that reflected the as-built condition of Bechtel identified structurally significant joints prior to any rework or repairs.
Two thousand six hundred sixty-nine (2,6o9) structurally significant joints were identified by Bechtel and were subsequently reinspected by DIC Certified Quality Inspectors who were all also AWS certified Velding Inspectors. Eighty one (81) of these significant jo; ats required rework due to design allowable stresses being exceeded in the as-built condition. Ke of the structurally significant joints "where discrepancies were identif2 .
would have failed if left uncorrected.
Research accomplished by DIC and Bechtel personnel substantiated that all DIC welders and welding procedures applicable to AWS D1.1-1975 welding of structural steel installations were qualified in accordance with AWS requirements. Additional research resulted in assurance that programs and procedures applicable to the purchase and control of weld filler materials used in AWS DI.1 applications were in compliance to AWS requirements.
7 Investigations into site implementation of these requirements and procedures provided assurance that implementation had been effective and properly controlled by DIC during project construction activities.
l The retrievability and control of Miscellaneous Structural Steel Veld Records (MSSWR's) was investigated, and a determination made that inadequate implementation of DIC construction procedures was a contributing factor to retrievability and accountability problems with MSSWR's relative to struc-tural . steel applications. Thorough analysis of each applicable program was undertaken by DIC Quality Engineerning to determine if similar programmatic or procedural requirements existed, and whether inadequate implementation had -
resulted in similar deficiencies. The results of these ass'essments deter-mined that no programmatic problems existed in any other AWS D1.1 application relative to inspection documentation required for weld inspections. Evalua-tions of each application identified that more efficient documentation methods were utilized, and in each case there was more effective control of the required documentation through its initiation and processing cycles.
Review of Quality Assurance historical audits and surveillances and an evaluation of procedural implementation adequacy further assured no problems existed in any other AWS DI.1 application similar to the MSSWR retrievability I problem on structural steel welding.
L -- .
Hardware applications of AWS D1.1-1975 requirements were also analyzed to determine if the root causes applicable to the previous acceptance of deficient structural steel welds were of potential impact in applications other than structural steel. Reinspection and Corrective Action reports existed in~every case to ensure the acceptability of installsd hardware where i
AWS DI.1 welding was utilized except in Electrical Equipment foundation k welds. DIC Management determined that a subsequent investigatory effort was necessary to provide data to ascertain the possible existence of deficiencies in welding and shimming in these installations. DIC Corrective Action Report 1-EW-0046 was initiated to document and accomplish these activities.
. ,+
-- a w~ ,,.
.ANSAS iG ELECTRIC COMPANY NO.2158 7 O BD 20h W6Cw1A A ANS A5 67201 VENDOE NO T011301 CONTROL NO rs gasvDegg meinsam 90 esuanBIa MM N SIIT 8 8V OI G SIREM C l
2184 CIVIL PENALTY IMPOSED BY U.S. NUCNEAR REGULATORY COMMISSION ON NOVEMBER 21, 1984, UNDER DOCKET NO. 50-482, CONSTRUCTION PERMIT NO. CPPR-147, EA84-107
. 75,000.00
'ECIAL HANDLING CHECK TOTAL c/o GLEN L. K0 ESTER l
KANSAS fe ELECTRIC COMPANY . (M - NO. 215 8 7 P.O box 205 WICHIT A. K ANSAS 67201 imi ,ossi- %.iiosa, say a tesst coy asi w<-:a i DATE VENDOR NO PAY EXACTLY
/ 122784 T0ll301
$***75,000.00
'^
oRD R TREASURER OF THE UNITED STATES .,
d rwe s<,~.10.is eiosp.. in a os o<i.
=' 0 0 0 215 8 7 8' i: 10 L LOOO L, Si: n*O 00 212 7 m' h
Q4-84-053
,.v REPORT OF INTERVIEW With Lawrence E. ELLERSHAW On April 30, 1985, Lawrence E. ELLERSHAW, NRC Region IV Inspector, was interviewed by NRC_ Investigators M. EMERSON and R. K. HERR in the Office of Investigations, Region IV, NRC, in Arlington, Texas. ELLERSHAW advised he had been assigned to the NRC Task Force which was formed in July 1984 to inspect the Wolf Creek facility. ELLERSHAW stated he was responsible for inspecting structural steel and associated records. ELLERSHAW said that during 1983, Daniel Internation Corporation (DIC) identified retrieval problems associated ,
with the Miscellaneous Structural Steel Weld Reports (MSSWRs) during'the ,
planned turnover of Wolf Creek buildings to Kansas Gas and Electric (KG&E).
ELLERSHAW said NRC Task Force inspections revealed procedures existed to generate MSSWRs, however, no adequate procedures existed for the maintenance and/or retention of the MSSWRs. ELLERSHAW said in other words, the craf t personnel / inspectors were told to initiate the MSSWRs but were not instructed where to file / store the completed MSSWR's. ELLERSHAW advised as a result of the lack of specific guidance, confusion existed with the welders and the QC inspectors, thereby causing the MSSWRs to be stored in various locations.
ELLERSHAW said that during his inspection, he had discussions with 10-15 DIC and KG&E QA records personnel, including supervisors regarding missing MSSWRs.
ELLERSHAW learned from his discussions that MSSWRs had been recovered from various locations including desks, wooden boxes, files and "gangboxes."
ELLERSHAW acknowledged DIC initially discovered the missing MSSWRs in August 1983 and issued DIC Corrective Action Request 31 (CAR 31) on August 16, 1983.
ELLERSHAW concluded by stating he uncovered no evidence of intentional wrongdoing on the part of anyone regarding the missing MSSWR's, and attributed the missing MSSWRs to the absence of proper procedures on the part of DIC to ensure record maintenance.
s h
EXHIBIT (10)
~
L Q4-84-053 l
"l ,, .
h
! . time," and nobody ever took the initiative, or 1
nobody was ever told, or, you know, to actually start working on the prints and get the prints l
l done and get these buildings done, so they t
qI
.1 wouldn't have such a rush in the end.
- N MR. HERR:
l So when you told Mr. Schum that they were falsifying 4
documents, you were talking about the prints? '
They were actually penciling in the prints?
A. Yes, right. The prints were our only means of
'i documentation.
i'
~
MR . HERR: The weld records that were missing -- was that 1
i because -- were they really missing'or never done l in the first place?
l A. That's the question. They used to not even file g
i weld records. They would throw them in a box.
1 on the floor -- just an ordinary cardboard box, it and some of them would fall out and get swept away by the laborers or 'whatever. They just didn'd have the documentation -- even when I was trying to trace the documentation in the end to turn
- 1 over the prints, they took what weld records they had and locked them up in a steel file cabinet up
%' ; \1ARIORIE D LARLET tsk AN L) A3M )CI A Th5 2g @' .:en.r..a u a, Aer,v.ng wr c kar 13 EXHIBIT (11) 1 2N2 La ndair Dme
' 'f A MP AIC.N ILLINOI4 e1871
r
_ pg3 l
, -5E-the items. Tarticularly, the auxillary building --
l t'
7 I did find weld records for t h e.T . As far as the f
h They p other builc..ings, I clan't find too many.
i l were just scattered.
i e MR . HERE: So they did exist at one time?
. .n . Yes, I don't know how many.
f MR. EEER: Okay, and the ones that were missing were usually the ones swept up when they threw them in a box j and they missed the bo>i and people would come by i:
and sweep them up?
A. Right.
l
!l MR. HEER: They were just careless in how they handled them?
r A. Eight. I guess they didn't consider it a major t
I i document or something because they didn't treat it like one. They never filed it or kept track f,
i of it. I imagine that's mechanicals fault for
- 1. .
that --
not keeping track of their welds, and that was the breakdown because they thought that we were keeping track of the hardware items that h
[ they were welding at the time. h'e - - I ' l l say j 1:
(l- we for the group -- not me personally because this was back .like in the late ~10's -- nobody I
MARJORIE D EARLE) CSE AND A550CI ATE 5 z# zu p.
<.,....m..-,s......
-C* ,I 261 La n61e Drne CH a MPAIGN lulNOls (18:1 EXHIBIT (
h
(----- - - - -.
Q4-84-053 was our responsibility per the procedure --
without that mark on the prints, we just couldn't make that determination, so, like I said, that whole thing come abocc just to
~
build the turnover or it wouldn't have never e 5
z been identified because there was a breakdown m n
It was our procedure, and $
in the procedure. 4 it was not in the welding procedure for them {
4 to check that, and all they really do is a c r:
g base metal inspection, and the craft personnel 5 E
f111ed out the MSSWR's, which is, as I told $
v:
g in a later interview with some gentlemen that * .
e g
come out here from Kansas, that that was not Y sufficient because it was a craft document, and 5 2
that cannot be tied into our documents in any -
3, C
C g
way for verification. ,
There appears to be some missing weld records?
HERR:
A. Correct. .
Did you ever find them, or did they keep them
. HERE:
kind of sloppy or keep thera -- I understand there was a box. Explain that situation a little bit to us.
MARJORIE cen.t.
D EARLEY. CSR. EXHIBIT (13) 4 coori iteporoes sr .c. AND ASSOCIATES 2612 Lawndale Dnve CH AMPAIGN. ILLINOl$ 61821 (21 7 156-1549
A. Well, it was just -- as I come on site and they
They could be in boxes. They were just d
enormous. No one felt like they were any kind of documentation that was going to be !
5 of concern because, as I stated, they were (
Ed m
3 filed by the craft, and anybody in quality m 5 d control knows that without a quality control ,
g
?
certified inspector's name on there and Q i
x C l verification of the fact that it's just -- g e-e it's not a very good legal document, so they g 4
m were just thrown all over the place, and they 5 e
H g
were shipped over finally over to mechanical -a x
because our lead got tired ~of kicking the box, N and I wasn't really certified at that time. [T a
I was just starting on the site, but I wasn't s
even quite sure what they were until later on when I got certified. Like I say, they changed i
procedures right after this happened with the fuel building. Our supervision, Tim ?!urphy, was a quality engineer before, and he had a
.b.; M ARJORIE Dc.,a.
EARLEY. CS R AND ASSOCI ATES a co,, ,,n,.. sm.u J 5Dr' 4 k ,$ jf 26 2 La.naaie onv.
04 AMPAIGN. ILLINOIS 6tth g% ._ ..#2fj pit) in.no
~ _ _ _ _ _ _ _
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4
'"i % NUCLEAR REGULATORY COMMISSION f
! OFFICE OF INVESTIG ATIONS FIELD OFFICE, REGION IV f 611 RY AN PLAZA DRIVE. SUITE 100C
_. f ARLINGTON, TEXAS 76011 j STATEMENT ;
l tinued)
\
sA l
'N :
N N
N N
N N
N N
N N
N N
N Nw-N I have read the foregoing statement consisting of Q handwritten /4ypes pages. I have mace anc initialec any necessary corrections and have signed my initials at the bottcm of each page. I fully understand anc have discussed the statement with Investigator /n. Gwa se,a - . This statement is the truth to the best of my knowiecge anc bei f.
Si gr.a tu re : Y 0 ubs // t3ms//
h J,u/>An l/ jf Subscribed and sworn to before me this QY day of ///d /ff6 ,
45&& a t o g G [pd _.
Investigator: _
d(/ D' Autnorit7 5ection 161c AEA 1954 as amended Witness:
i f.ame/Titl e '
Initials cf Person l'aking Statement EXHIBIT ( )
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V '.iT E C ST AT E S f
i 4' 'S NUCLEAR REGULATORY COMMISSION 5 '
j OFFICE OF 'NVESTIGATIONS FIELD OFFICE REGICN IV
<A ,
611 RY AN PLAZ A DRIVE. SUITE 1000
<s* *[ ARLINGTON. TEXAS 76011 a,,,.
STATEMENT Affiant Street h Bw State C/3 Zip
% dev1Ar?lon Vl> V S oA Citv Location !
~ La eveely KS 6G7/
y o/F Cee k 67~ # 6 N '~ Telephone ho'. : AC ( ) ,
1, /7M, asc4 JDwlu 4 , hereby make the following voluntary statement to /4. P-Nsea / , wbc has identified himself to me as an Investigatcr with tne U.S. Nuciear h. latory Comission. I make this statement freely with no threats or promises of reward havirg been mace to r.ie.
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,A, Initieis cf Person Making Statement __ EXHIBIT (14 )
Q4-84-053
. CHRONOLOGY 1977-1981 The majority of the structural steel welding was performed and inspected by Daniel International Corporation (DIC) in the six safety-related buildings. There were approximately 11,000 field made welds and the inspections were documented on Miscellaneous / Structural Steel Welding Records (MSSWR's).
3/22/83 Corrective Action Request (CAR 29) was initiated by DIC to implement a random inspection of accessible structural steel ;
welds in all safety-related buildings. DIC determined that 148 (62 percent) of the 241 reinspected welds did not conform to revision (REV) 4 of Quality Control Procedure (QCP) - VII-200.
Nonconformance Reports (NCR's) were generated to document and disposition the deficiencies. REV 2 to CAR 29 reported that the disposition of the defective welds would be transferred to NCR ISN-10381PW.
The 148 defective welds were reinspected by DIC under NCR ISN-10381PW and the majority of them were categorized as having
" cosmetic" defects which could be "used as is." DIC concluded that only six of the 148 welds required rework. The NCR was completed with this disposition on August 30, 1983. -
6/30/83 NCR ISN-11957CW was initiated by DIC to document a total of 41 MSSWR's which were missing from the Emergency Service Water System Pump House.
8/16/83 Subsequent to the issuance of CAR 29, during the document review process prior to building turnovers to Kansas Gas and Electric (KG&E), DIC discovered that approximately 16.4 percent of the MSSWRs could not be locatbd for welds in safety-related buildings as procedurally required. Therefore, on August 16, 1983, CAR 31 was issued by DIC to initiatt a review of all existing MSSWR's and to originate NCRs for each building with missing MSSWR's.
DIC concluded that it was acceptable for a portion.of these records to be missing if the quality inspection program was acceptable. In this regard, senior licensee Quality Assurance (QA) management told an NRC inspector that the program had been successful since very few unacceptable welds had been discovered during the substantial reinspection effort associated with CAR 29 (see disposition of NCR.ISN-10381PW, supra)
At the time of CAR 31 being approved, DIC determined the condition did not require reporting to the NRC pursuant to 10 CFR 50.55(e).
6/11-9/28/84 An NRC Region IV inspection team and Task Force monitored KG&E EXHIBIT (15) 4-30 1
Q4-84-053 management corrective action programs which had been instituted after the discovery of problems regarding the MSSWRs to ensure appropriate implementation. This included an independent inspection by the NRC. During this period (approximately July 1984), an NRC inspector was apprised of the missing weld records during conversations with KG&E personnel. The Task Force also reviewed CAR's 29 and 31.
9/11/84 KG&E, Bechtel, and DIC made a joint presentation to the NRC concerning DIC's efforts to provide adequate records of the inspection of.the welds. 319 weld joints with missing MSSWR's ,
were inspected, and 48 did not meet original code / design <
requirements. Several were reanalyzed by the engineer and determined to be "use as is." At this time, KG&E was of the opinion the missing MSSWR's were a document retrieval problem rather than a problem with quality installation and/or inspection.
The NRC told KG&E that NCR ISN-10381PW had not been properly dispositioned; therefore, the closures of CAR's 29 and 31 were faulty. The NRC noted that the quality status of the majority of all structural steel welds was indeterminate. At the NRC's suggestion, KG&E agreed to perform a sample inspection of structural steel joints in each of the six safety-related buildings.
- This reinspection, conducted during the week of September 17, 1984, disclosed one missing weld in each of the six connections, five of fourteen welds were undersized, and two of these welds were also under the required length. Additionally, an NRC inspector accompanied two DIC inspectors for a reinspection of nine connections in the Auxiliary 8uilding.
This revealed numerous inadequate welds and two missing welds.
The NRC inspector requested the briginal weld inspection records for the bad and missing welds. As of September 28, 1984, only a few MSSWR's had been located. The NRG inspector made a comparison of the existing original inspection records with the results of the reinspection to deiermine the validity of the initial records. Several bad welds had been inspected
, and accepted on December 11, 1978 and~ September 8, 1979.
Approximately 80 percent of the MSSWRs were missing for these deficiencies, and records were not available to confirm that an initial inspection had been conducted.
9/18/84 The results of the reinspection were formally reported to the NRC under 10 CFR 50.55(e).
9/25/84 A meeting was held between KG&E and the NRC to discuss the findings of the reinspection; i.e., inadequate welds, missing welds, and the inability to locate MSSWRs.
9/28/84 The reinspection results were formally provided to the NRC.
10/17/84 CAR 19 was initiated by KG&E to resolve the various proolems EXHIBIT (15) 4-30 . _ _ _ _ - - _ _ _ _ _ _ _ _ _ - _ - - _ - _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ . _ _ _ _ - . _ _ - - _ _ _ _ _
.Q4-84-053 t .
associated with structural steel welding. Issues addressed were (1) missing MSSWR's, (2) deficiencies in previously accepted welds, (3) missing welds and/or material, and (4) documentation indicating that a weld was inspected and accepted, which did not exist. CAR 19 consisted of an extensive review of welding and welding records, and resulted in a 100 percent reinspection of structural steel welding between October 1984 and February 1985. The NRC Task Force approved, monitored, and evaluated the reinspection; and also performed an independent inspection with NRC personnel.
The reinspection disclosed that 1,509 MSSWRs were misiing. Of ;
the 2,604 joints which were reinspected, 82 (3.14%) were determined to exceed design allowable stresses. The Task Force Director concluded that a confidence level of virtually i 100 percent could be applied for the inspection effort in view of the large percentage of welds which were evaluated and the small number which exceeded design stress allowances.
1 DIC and KG&E determined that the major reason for the missing MSSWR's was the inadequate implementation of DIC construction procedures / lack of procedural compliance regarding the maintenance of records. They also established that the root cause of the previous acceptance of deficient welds was due to the DIC-inspection implementation differences relative to inspection v.s. reinspection techniques and the inadequate implementation of applicable DIC procedures during the original inspection efforts. No deficiencies were identified which if left uncorrected would have adversely affected the safe 1
operation of the plant.
10/26/84 RIV Inspection Report 50-482/84-22 was issued. It concluded that a significant violation of NRC regulations had occurred in the area of structural steel welding since the inspection I
program for safety-related welding was not executed in a manner to ensure conformance with the requirements of the. Construction Procedures and the FSAR commitments. It required the licensee
} to prepare a written program for'the reinspection of structural steel welding,'along with appropriate corrective action.
10/29/84 An enforcement meeting was held between KG&E and the NRC to
, discuss corrective action plans resulting from the findings of
- the NRC Inspection Report.
11/19/84 NRC, Region IV, requested an investigation by 01 regarding the i missing MSSWR's.
11/21/84 NRC, Region IV, issued a' Notice of Violation (N0V) to KG&E.
1 The NOV was based on the results of NRC Inspection Report 50-482/84-22 which identified a significant breakdown in KGSE's QA program regarding structural steel welds. The NRC concluded that since DIC failed'to take adequate corrective
- action for the problems identified in CAR's 29 and 31, the base EXHIBIT (15) 4-30-85
Q4-84-053 penalty was escalated 50 percent. A Civil Penalty of $75,000 was imposed.
12/31/84 KG&E paid the $75,000 Civil Penalty required by the NOV.
3/07/85 The NRC Region IV Inspection Report 50-482/85-13 reflects concurrence in CAR 19's corrective action.
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EXHIBIT (15) 4-30-85
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- ARLINGTON. TE A A5 76C11 001 %f, B64 In Reply Refer To:
Docket: STN 50-482/84-22 Kansas Gas and Electric Company ATTh: Glenn L. Koester Vice President - Nuclear P.O. Box 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 11 through September 28, 1984, of activities authorized by NRC Construction Permit CPPR-147 for the Wolf Creek Generating Station, and to the discussion of our findings with Mr. f. J.
Duddy and other members of your staff at the conclusion 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 NRC regulations has occurred in the area of structural steel welding in that the inspection program for safdty-related structural steel welding was not executed in a manner to ensure conformance with the requirements of the Construction Procedures anc' tht FSAR commitments. Details of the inspection findings which support this conclusion arc discussed in the enclosed inspection report. A written comprehensive program for the reinspection of structural steel weldinc, along with appropriate corrective action is required to be submitted to Region IV.
In accordance with our discussions, KG&E will discuss their corrective action plans, and establish a date for submittal of the documented correction action plans, at a meeting with NRC 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 October 29, 1984.
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EXilIBIT (1)
t i ADPf NN) F U. 5. NUCLE AR REGUL A10RY COMMISSION REGION IV NRC Inspection Report: 50-482/84-22 Construction Permit: CPPR-147 Docket: 50-482 Category: A2 Licensee: Kansas Gas and Electric Company (KG&E)
P. O. Box 208 Wichita, Kansas 6720' Facility Name: Wolf Creek Generating Station Inspection At: Wolf Creek Site, Cof f ey County, Burlington, Kansas Inspection Conducted: June 11 through September 28, 1984 Inspectors: /4 [ fY R. G. Tay[or, (Team Leader) Reactor Inspector D/te/
Project Section A, Reactor Project Branch 2
/
aad L. E. E11ersha'w, Reactor Inspector
/b lMld Dat/ /
Project Section A, Reactor Project Branch 2
$1 M' k' ' hY M A. Project R. Johnson, Reactor Inspector Date ,
p Section B, Reactor Project Branch 1 R.'P.
4 P.7L & L:
Mullikin, Reactor Inspector
%/er Date '
Project Section A. Reactor Project Branch 2 Whl_ j 'W -
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t i Kenses Les anc' Llectric Corpary One new unresolved item is identified in paragraph 4 of the enclosed report. .
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written application to withhold information contained therein within 30 days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sin'ce rely,
- f
%b < Wg R. P. Denise, Director Wolf Creek Task Force
Enclosure:
Appendix A - NRC Inspection Rcport 50-482/84-22 cc w/ enclosure:
Kansas Gas and Electric Company Forrest Rhodes, Plant Superintendent' ATTN: Gene P. Rathbun, Manager Wolf Creet Generating Station of Licensing P.O. Box 309 P.O. Box 208 Burlington, Kansas 66839 Wichita, Kansas 67201 s
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[. Bess, Reactor Inspector, Project Section B Reactor Project Branch 2 i Approved: Ir /r//
L'. 'E. Martipf Chief , Project Section A Dat e /
Reactor Project Branch 2 Inspection summary Inspection Conducted June 11 through September 28, 1984 (Report 50-482/64-22) i Areas Inspected: Routine, unannounced inspection of electrical separation, electrical cable tray and conduit as-built installations, structural steel as-built welding installations, electrical craftsman qualifications, procedures for penetration fire seals, and followup on previous NRC findings. The inspection involved 246 inspector-hours onsite by five NRC inspectors.
Results: Within the areas inspected, two violations were identified (f ailure to assure conformance of safety-related structural steel welds with requirements, paragraph 3, and f ailure to maintain adequate electrical separation, paragraph 4). In addition, one new unresolved iter: .is identified in paragraph 4.
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DETAILS
- 1. Persons Contacted Principal Licensee Employees
- F. J. Duddy, Construction Manager
- W. M. Lindsay, Supervisor - Quality Systems
- P. Dyson, Field Engineering Supervisor
- R. Grant, Director - Quality
- R. L. Stright, Licensing
- N. W. Hoodley, Nuclear Plant Engineer Daniel International Contruction, Inc. (DIC)
- J. Berra, Vice President
- J. Fletcher, Construction QC Bechtel Corporation
- C. M. Herbst, Assistant Project Engineer .
- G. D. Brown, Engineer The NRC inspectors also interviewed other licensee, DIC and Bechtel personnel.
- Denotes those attending the exit interview.
- 2. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (50-482/77-05-01) This item invol ed the batchine of concrete for " mud matt" underlying the nuclear safety-related buildirr.
Based on an interview with the reporting NRC inspector, this NRC insptet:r determined that the major issue involved was a lack of desire on the part of the applicant to utilize a certified batch plant for mixing the concrete. The NRC inspector was provided a Certificate of Conformance fcr Concrete Production Facilities" for the Penny Ready Mix plant in New Strawn, Kansas signed by a licensed professional engineer on May 9, 1977.
The certificate is sufficient to satisfy the requirements of the LWA-2, the NRC authorization f or the work involved.
(Closed) Unresolved Item (50~482/78-04-05) Containment Base Mat Ninety-Day Cylinder Breaks. This item was superceded by Notice of Violation, Iten B of Appendix A to Inspection Report 50-482/78-13.
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(Closed) Inf raction (50-482/78-04-B) Failure to Meet Concrett Acceptance Criteria f or Containment Base Mat. This item was transferred to NRR for
. evaluation. The NRR evaluation and conclusion is contained in the Safety Evaluation Report for the Wolf Creek station (NUREG-OSSI) at paragraph 3.8.4.
(Closed) Unresolved Itee (50-482/78-15) Pre-Planning For Concrete Placement. This unresolved item was superceded by Appendi> E Notice of Deviation included with Inspection Report 79-03.
(Closed) Unresolved Itee (50-482/78-15) Placing Limitations for Concrete.
This unresolved iter was superceded by Appendix A Notice of Violation included with Inspection Report 79-03.
(Closed) Unresolved Iter (50-482/79-01) Concrete Practices. This unresolved. iter was superceded by Appendix A, Notice of Violation, included with inspection Report 50-482/79-03.
(Closed) Unresolved Iter (50-482/79-01) 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 (50-482/79-03) Failure to Adhere to Concrete Placement Limitations. This inf raction was issued for record purposes with corrective action ie.plicit within the licensee's response to Inspection Report 78-15. This conclusion is consistent with statements contained within paragraph 5, Report 50-482/79-03.
(Closed) Unresolved Ites (50-482/79-07) Observation of Concrete Testing Procedures. Although not specifically documented, the inspection ef f ort described in Inspection Report 50-482/79-09, paragraph 11, by the inspector of record in report 79-07 15 considered as resol,ving the matter.
(Closed) Unreso]ved Iter (50-482/B0-13-01) Review of Work Hold Acreement Number II. < The work hold involved a conflict between the Daniel International Corporation procedure for coating application inspection and the applicable, Bechtel specification. Bechtel letter BLKE 600 dated August 27, 1980, provides information on the resolution of the matter suf ficient to warrant cancellation of the Work Hold Agreement in Septembcr 1980.
(Closed) Unresolved Iter (482/8335-01) This item required the licenset to determine whether the Bechtel requirement that flexible electrical conduit l not be greater than 5 feet includes total length where the conduit is I supported. There were five safety-related instrument transmittert found l in this category. The licensee furnished the Bechtel design drawings f or these transmit %ers which showed that a support was allowed for each. This !
item is considered closed. i Y.\ ; 1 t
- 3. Welcino of Structural Steel During a review of QA/QC and Quality first personnti quelifications and subsequent interviews, the NRC inspector became aw6rc of potential problers with corrective action reports CAR 29 and 31. The NRC inspector subsequently obtained copies of the two documents. CAR 1-K-0029 (initiated on March 22,1953) states, in part, *5ubsequently to thc issuance of CAP 1-W-0019, quality has instituted a rendor. rcinspection of accessible structural steel fillet welds in all 0 buildines. It has been dcternined by the results of this reinspection that an,unacccptable_
percentace of these welds are deficient in the auxiliery, control, and
~
~ fuel buildings." Attached documentation revealed that in the auxiliary building, @ welds were inspected with 53 bcing rejected. In the control and fuel buildings, 50 welds were inspected c with 43 rejected, and 53 inspected with 35 rejections, respectively. Levision 2 to CAR 1-W-0029 stated in the disposition that the defective welds would be transferred to a Nonconformance Report (NCR). The NRC inspector obtained a copy of NCR ISN 10381PW which was used as the whicle to carry out the direction provided by CAR 1-W-0029. It appears that DIC Project Welding Engineering personnel again reinspected the welds to more clearly define the nature and extent of the defects on a weld-by-weld basis. A mEjority of the defective welds were categorized as having *cosmctic" defects. The Dlc recomended disposition was use-as-is for welds identified containino
" cosmetic" defects. The NCR states that ". cosmetic" defects include arc strikes, convexity, cold roll (understood to be synonymous with overlap),
porosity, and acceptable amounts of undercut. The NRC inspector noted with respect to these defects that overlap is prohibited by the governing AWS D1.1-75 Code and specific acceptance criteria for the other defects are also defined by this Code. The engineer accepted the DIC recomendation stating, "This disposition is based on the understanding that the cosmetic defects outlined . . . of this NCR dc not, constitute violations of AWS D1.1-75." A written-in note labeled *5NUPPS coment" states that DIC had confimed the engineer's understanding. NCR ISN 10381P',, was completed as indicatec abovc on August 30, 1963.
On August 16, 1983, DIC personnc1 issued CAR 1-C-0031 which indicatcd that approxit.atcly 16.4 percent of the miscellaneous structur61 steel wt1 din _o
. records for "Q" welding could not be located. After corresponding back and f orth, vn, and the engineer concluced that it was acceptable for some amount of these records to be missing, provided that tne cuelity inspection prograr was acceptable. Senior licensee QA management expressed to the NRC inspector that the program had obviously been fully successful since very few welds had been found to require repair af ter a substantial reinspection effort associated with CAR 29. The NRC inspector expressed concern wi'th this approach to resolution and suggested that the licensee '
reevaluate their position.
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, -E-On September 11, 1984, the licensee, in conjunction with senior D1C managment personnel, made a presentation to the NRC Task Force Director ~~~
and other NRC staff personnel, including the NRC inspector. The presentation was aimed at the D]C ef f ort to provide adequate records of inspection of the structural welds. This ef fort involved the inspection at that point in tine of 319 weld joints in the reactor building for which there appeared to be no records. Of these, 48 were found to not meet code / design original requirements. Several had been reenalyzed by the engineer and found to providt adequate structural strength and were deemed to be "use-as-is."
The NRC Task Force Director and the NRC inspector met with the KG&E Froject Director on September 14, 1964. The NRC personnel informed the project director that the NRC position was that NCR ISN 10381PW had not been properly dispositioned and that, therefore,~ the underlying premise
'f or the closure of CARS &!t and (Il3was f aulty. The NRC personnel stated that it appeared that the quality status of the majority of all structural steel welds was at best indeterminate _. The project director proposed to have the engineer identify a group of structural members with the highest design loads or the lowest design strength safety margin and to have these joints inspected. The NRC personnel indicated that might be one possible approach to resolution of the matter.
During the week of September 17, 1984, a reinspection of the identified structural members with the highest design loads or the lowest design strength safety margin was initiated. The reinspection identified a number of welds which do not meet drawing requirements. This information was presented to the NRC staff during a meeting conducted on September 25, 1964. In an ef fort to confirm certain of the identified conditions, the HRC inspector accompanied D]C welding inspectors into the reactor building to observe specific, identified weld joints. This observation confirmed the welding inspectors' findings; e.g., welds that are undersi2ed and of insuf ficient length, lack of fusion, and missing welds.
The rjssing welds are f rom the same location in etch of six pressurizer
~
support connections. Certain of the other welds in the pressurizer support connections were undersized and of insufficient length. Drawing No. C-05 2904 shows that various length 5/8-inch welds are required in 14 specific locations. Four locations required a 5/E-inch fillet weld of 6 inches in length. The actual welds in two of the locations measured between 3/8-inch and 1/2-inch by 5 inches in length, and 1/2-inch by 3 inches in length. The missing welds and the undersized, insufficient length welds are_ clearly not in compliance with the requirements of the drawing or AWS D1.1-75 :PCThe initial weld inspection records for these connections could not be located. --
The NRC inspector accompanied two D]C welding inspectors for reinspection of nine structural steel connections in the auxiliary building. Drawing I
t 0
7 he. K6720, applicable to these connections, shows 12 weld locations per connection with certain of the welds requiring returns. Reinspection of thc welds and returns involved proviced the following sumarized data:
Missing welds 2 i WeldY with insufficient icngth 9 Undersized welds 6 Undersize welds with insufficient length 2 Overlength returns 44 Undersize returns . 25 Undersize returns with insufficient length I The NRC inspector requested the initial weld inspection records for these welds and returns in the 9 reinspected connections. As of September 28, 1984, the only inspection records that were located pertained to 10 welds and 6 returns in one connection, and 6 welds and 4 returns in each of 3 other connections. These records did not indicate that the welds were anything other than acceptable. The licensee infomed the NRC inspector of a situation where one inspection record for connection 524B2, clearly indicated by an attached sketch, the existence of the a w(TTThat reinspection found not to exist. This problem will be followed up in conjunction with the other structural steel problems.
The NRC inspector madt a comparison between thc existing initial inspection records and the results of the reinspection effort in order to determine thc validity of the initial records. The initial
- records show that the 10 welds with 6 returns in one connection were inspected and accepted on December 13, 1978. The reir.spection identified one undersized weld, other undersized and overlength returns, and three overlength re turns . The initial records for the other three connections show that eight welds with four returns per connection were inspected and accepted on September 8,1979. The reinspection of these welds and returns identified two returns which were overlength and undersized and two returns which were overlength per connection. ,
The failure to execute the required welding inspection program is a ,F violation of Criterion X of Appendix B to 10 CFR Part 50. (482/8422-01)
- 4. Observation of Electrical Separation (Class IE Cables)
The NRC inspectors observed the completed electrical cable work for confomance to the separation 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 non-safety groups. The plant areas inspected were the following:
- E-
- North Electrical Penetration Room
- South Electrical Penetration Room
- Control Room
- Centrifugal Charging Pump Rooms A and B
- Safety Injection Pump Rooms A and B
+ Lower Cable Spread Room
- Upper Cable Spread Room
- Standby Diesel Generator Room B
- Main Steam Isolation valve Room The following documents were examined during this inspection:
- Bechtel Drawing E-]R8900, Revision 1, dated July II, 1984, " Raceway Notes, Symbols & Details"
- Bechtel Drawing E-01013(Q), Revision 11, dated December 20, 1983,
" Installation, Inspection, and Testing Details for Electrical Equipment and Cable"
- Bechtel Specification ID466-E-O(Q), Revision II, dated June 25, 1981,
" Electrical Design Criteria for the Standardized Nuclear Unit Power Plant System (SNUPPS)"
- Bechtel Drawing E-OlOD6, Revision 8, dated December 7, 1982, " Single Line and Schematic Diagram Standards, Notes and Symbohs"
- Daniel Procedure WP-X-303, Revision 9, dated September 22, 1982,
" Installation of Cable"
- Daniel Procedure WP-X-304, Revision 14, dated February 9,1984,
" Termination of Cable" Bechtel Drawing E-IR8900, Revision 1, states in paragraph 3.36.4 that:
" Minimum separation between different Class IE conduit systems and minimum separation between Class 3E conduit systems & non-IE conduit systems shall be 1"." Separation shall be measured between the outside edges of the conduit."
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. Contrary to the above, the f ollowing observations were noted where the required minimum separation was less than 1":
- Flex conduit 4J1039 (Class IE) crosses within 1 inch of flex conduit 6J1175 (Non-Class IE) in the Centrifugal Charging Pump Room B.
- Flex conduit 4U3 FIT (Class IE) crosses within 1 inch of junction box IU1201 (redundant Class IE group) in Safety Injection Pump Room B.
- Flex conduit 4U3E7A (Class IE) crosses within 1 inch of flex conduit IU3K4B (redundant Class IE group) in the North Electrical Penetration Room.
- Flex conduit IU1288 (Class IE) crosses within 1 inch of flex conduit 5J1124 (Non-Class IE) in the Main Steam Isolation Valve Room.
- Flex conduit IU1281 (Class IE) crosses within 1 inch of flex conduit 5J1125 (Non-Class IE) in the Main Steam Isolation Valve Room.
- Rigid conduit 3C3009 (Class IE) crosses within 1 inch of rigid conduit SC851A (Non-Class IE) in the Lower Cable Spread Room.
- Flex conduit 4J1C5B (Class IE) crosses within 1 inch of non-safety 120 volt _AC outlet QA1530 in Standby Diesel Generator Room B.
Bechtel Drawing E-01013(Q), Revision 11, requires the following:
- a. Paragraph 5.8.1.b "Within the control boards and other panels associated with protection systems, circuits and instruments of dif ferent separation groups shall be independent and physically separated horizontally and vertically by a distance of 6 inches."
- b. Paragraph 5.8.3 " Hon-safety related circuits shall be separated fror. Cless IE circuits by the same distances applicable to Class IE circuits of different groups."
Contrary to the above, the f ollowing cables within cabinets or panels in the control room were found to have less than the required 6-inch minimun spacing:
- Cables 45B508AD and 45B508DD (Class IE) are within 6 inches of cable 55CIO1AE (Non-Class IE) at the floor penetration of cabinet RLO25/026.
- Cables 1EJG09CD and IEMG13AD (Class IE) are within 6 inches of separation group 4 vendor wiring at the base of cabinet RLO17/018.
- Cable 15B508AC (Class IE) is within 6 inches of non-class IE cables 55BS508CC, $5FR16BB, 55F511BG, 55F511BF, 55FR16BA, and 55FY11AC in the main control board panel.
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- Cable 45B508AC (Class IE) is within 6 inches of several bundled separation group 5 non-class 3E cables in the main control board panel. Two e>arples are cables 55BZ07AJ and 55BZO7AA.
- Cables 45B508AB, 45B508BB, and 4EM117BA (Class IE) are within 6 inches of cables 15B50BAB,15B508CB, and IEM117AA (redundant Class ]E group) in the main control board panel.
Bechtel sent to the NRC inspector, Startup Field Report (SFR) 1-RL-31 which details additional separation violations in the control room. This SFR, along with the examples noted by the NRC, show a widespread problem in internal panel and cabinet electrical
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separation.
The above examples are a violation of Criterion V of Appendix B to 10 CFR Part 50. (482/6422-02)
The NRC inspector also observed several installations of flexible electrical conduit which had the required 1 inch separation, but due to certain postulated events could violate the separation criteria. The installations noted were those where the flexible conduit dropped in air from rigid conduit to safety-related equipment. During events such as equipment vibration, transmitted hydrodynamic loads , or seismic events ,
the flexible conduits could come within 1 inch of redundant conduit. The following cases were observed:
- Flex conduit IJ1033 (Class IE) crosses flex conduit SU1378 (Non-Class IE) at pumps DP-EM-01A in Centrifugal Charging Pump Room A.
- Flex conduit IJ1035 (Class IE) crosses flex conduit 5J1258 (Non-Class IE) at pump DP-EM-01A in Centrifugal Charging Pump Room A.
- Flex conduit IUCIU (Class IE) crosses flex conduit 4UJ228 (Non-Class IE) at pump DP-EM-01A in Centrif ugal Charging Pump Room A.
- Flex conduit 4U1297 (Class IE) crosses flex conduit 6J1139 (Non-Class JE) at MSIV AB-HV-011 in the main steam isolation valve room.
- Flex conduit 4U1295 (Class IE) crosses rigid conduit 1U1113 (redundant Class 1E group) at MSIV AB-HV-014 in the main steam isolation valve room. -
- Cables from riser IU3201 (Class IE) air drop to' cable bushings of BOP computer cabinet RJ159A and flex conduit 6J1055 (Non-Class IE) at top entry to cabinet RJ159A 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. (482/8422-03)
. j
33
- 5. As-Built verification of Electrical Racewavs The NRC inspectors selected several Class IE conduit and cable tray runs located in the reactor building, control building, and auxiliary building for verification of actual installation against the latest approved design drawings. The inspection was lin.ited to an examination of the following:
- Location and routing
- Supports
- Separation
- Loading (cables physical and thermal)
- Identification (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 feet of conduit were inspected.
The following is a list of documents examined:
- Bechtel Drawing E-IR1411, Revision 0, dated Aprli 16, 1984,
" Raceway Plan - Auxiliary Building - Area 1, El. 2026'-0" "
- Bechtel Drawing E-IR1421, Revision 2, dated June 15, 1984, " Raceway Plan - Auxiliary Building - Area 2 E1. 2026'-0" "
- Bechtel Drawing E-IR1441 Revision 2, dated April 26, 1984, " Raceway Plan - Auxiliary Building - Area 4, E1. 2026'-0" "
i
- Bechtel Drawing E-IR1431, Revision 0, dated June 15, 1984, " Raceway Plan - Aux.iliary Building - Area 3, E1. 2026'-0" "
- Bechtel Drawing E-IR3433A, Revision 2, dated June 23, 1984, " Exposed Conduit - Auxiliary Building - Area 3 El. 2026'-0" "
- Bechtel Drawing E-IR1443C, Revision 2, dated July 11, 1984, " Exposed Conduit - Auxiliary Building - Area 4, E1. 2026'-0" "
- Bechtel Drawing E-1R3711, Revision 1, dated June 28, 1984, " Raceway Plan - Control Building - Area 1, E1. 2073'-6" "
- Bechtel Drawing E-IR3512 , Revision 3, dated June 23, 1984, " Raceway Plan - Control Building - Area 1, E1. 2032'-0" "
- Bechtel Drawing E-OR3714, Revision 6, dated October 18, 1982,
" Exposed Conduit - Control Building - Area 1, E1. 2073'-6" "
I 1
l
- Bechtel Drawing E-1'<3514, Revision 4, dated October 4,1984, " Exposed Conduit - Control fuilding - Area 1. E1. 2032'-0" "
- Bechtel Drawing E-1R2423, Revision 0, dated May 31, 1984, " Raceway Partial Plan - Reactor Building - Area 2, E1. 2026'-0" "
- Bechtel Drawing E-1R2421, Revision 2, dated August 4,1984, " Raceway Plan - Reactor Building - Area 2, E1. 2026'-0" "
- Bechtel Drawing E-IR2411, Revision 1, dated May 3,1984, " Raceway Plan - Reactor Building - Area 2, E1. 2026'-0" "
- Bechtel Drawing E-IR8900, Revision 1, dated July ll,1984, " Raceway Notes, Symbols and Details"
- The following Bechtel typical cable tray ' support details were reviewed
- C-0401, Revision 14, dated January 13, 1984
- C-0402, Revision 15, dated March 6,1984
- C-0403, Revision 19, dated February 22, 1984
- C-0404, Revision 18, dated April 26, 1984
- C-0405, Revision 9, dated April 24, 1984
- C-0408 Revision 0, dated June 28, 1984
- C-0409, Revision 13, dated April 26, 1984 C-0411, Revision 8, dated November 4,1983 .,
- C-0434, Revision 9, dated April 20, 1983
- C-0420, Revision 4, dated October 13, 1983 In addition, the following Bechtel typical conduit support details were examined:
- C-0601, Revision 18, dated February 22, 1984
- C-0602, Revision 19, dated April 16, 1984
- C-0603, Revision 13, dated February 7,1984
- C-06D4, Revision 17, dated May 14, 1984
- C-0605, Revision 17, dated March 6, 1984
l t
- The NRC inspectors noted the following discrepancies during the inspection of cable trays and conduit:
- A loose bolt where the P1068 angle clip attaches the P1001 horizontal brace to the P1001 vertical brace at tray support 142-0056 at elevation 2026'-O" in the auxiliary building.
. The angle clips for trays 4U3B52 and 4J3B52 on support 143-0026 are 3\ inches in length versus the required 4 inches. These are located at elevation 2026'0" in the auxiliary building.
- Tray 4C8F87 bas three out of four P-1068 angle clips missing on its two supports at elevation 2073'-6" in the control building.
- Cable IRPY10AA is unterminated, coiled, and supported by cable ties instead of required supporting material. This cable is located above tray IC8F58 at elevation 2032'-0" in the control building.
The discrepancies were shown to Daniel QC personnel who confirmed the first two discrepancies. A work order is being issued to correct them.
Daniel showed the NRC inspector that tray 4C8F87 was connected to the vertical support by direct bolting as allowed by an alternate support detail. Cable IRPY10AA was f ound to be a deleted cable. These discrepancies represent isolated cases considering the large number of supports inspected. No further action is required.
- 6. As-Built Verification of Electrical Cables The NRC inspectors selected thirteen Class IE electrical cables to verify that routing and separation conformed to design documents. The following cables were inspected:
Cable Tray System IALIO3AA Instrumentation Aux. Feedwate r IALG02CB Control Aux. Feedwater IALG04CE Control Aux. Feedwater IBBG39AC Control Reactor Coolant IBB538AA Instrumentation Reactor Coolant IGNG02CC Power Containment Cooling IGNG02CG Power Containment Cooling IGNG02AC Power Containment Cooling IGNG02AG Power Containment Cooling INGG01AJ Power 480V Syster INGG01BF Power 480V Systes 4SB501DA Instrumentation Reactor Protection 4SBSO4BA Control Reactor Protection There were no violations or deviations identified.
m 1
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- 7. Review of Procedures (Penetration fire Seals)
The NRC inspector reviewed the B&B Insulation, Inc., procedures for the installation of Radflex (flexible fire-radiation barrier) and High Density Lead Elastomer (solid fire and radiation barrier). These documents were examined to assure compliance with NRC requirements and licensee conr.itner ts .
The folicwing B&B procedures were examined:
1030.112, " Installation Procedures - B&B Insulation, Inc. -
Radflex Seal", Issue F, dated February 16, 1984 103G.114, " Installation of B&B Insulation Radflex Sealant Material Using a Mono-Pump Dispensing System" Issue 0, dated May 2,1984 1030.212, " Proprietary - Proportioning, Pre-Batching and Blending B&B Radflex Components A&B for Mono-Pump Application" 1700.101, " Installation of Hi-Density Leaded Matrix", B Issue, dated February 16, 1984 1703.102, " Repair, of High Density Leaded Elastomer Penetration *,
D Issue, dated February 16, 1984 1703.121, " Installation of Hi-Density Leaded Matrix Annulus Reducing Seals" 1703.201, " Proportioning & Pre-Blending of B&B Hi-Density Leaded Matrix Components A&B", B Issue, dated February 27, 1984 No violations or deviations were identified. .
E. Reviet c' Nonconformance Reports, Design Change Notices and Field Change Requests (Saf ety-Related Conduits and Cable Trays)
The NRC inspector reviewed eight Daniel Construction Inc., Field Change Requests, three nonconfonnance reports and five design change notices relative to the installation of safety-related conduits and cable trays.
The documents were reviewed to detennine whether the records were legible, complete, reviewed by QC personnel, readily retrievatile and reflect "as-built" conditions of safety-related conduit and cable trays. In addition, the records were examined to determine whether nonconformances and changes were adequately described and included in the status of the corrective action or resolution.
t ,
. The following records were examined:
NCR's DCN's FCR's 15N17957E C-0404(Q)15 3-5187-E 15N17323E C-0404(Q)14 1-5246-E 15N4986E C-0404(Q)10 1-5133-E C-0404(Q)9 1-5261-E C-0404(Q)8 1-5370-E 1-5236-E 1-5466-E 1- 5441- E No violations or deviations were identified.
- 9. Interviews with Electrical Termination Personnel The NRC inspectors interviewed two DIC personnel who performed actual terminations of Class IE 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.
- 10. Unresolved Items Unresolved items are matters which require more information to ascertain whether they are acceptable items, violations, or deviations. One unresolved item is identified in paragraph 4.
- 11. Management Interview The NRC personnel met with licensee and D]C management pe sonnel as noted in earlier paragraphs of this report. The NRC personnel met with the licensee personnel noted in pagraph I to express the full results and conclusions pertaining to this inspection.
, Docket:
" 9 EA 64-107 STfi 50-4S2/84 /[,,,,,-04-053
~
NOV 2 1 WM Kansas Gas and Electric Company ATTN: Glenn L. Koester Vice President - Nuclear P.O. Box 20S Wichita, Kansas 67201 Gentlemen:
SUBJECT:
NOTICE OF VIOLAT10ti AND PROPOSED IMPOSITION OF CIVIL PEtiALTY This refers to the inspection conducted by Mr. R. G. Taylor and other Region IV .
personnel during the period June 31 through September 28, 1984 of activities authorized by tiRC Construction Permit CPPR-147 for the Wolf Creek Generating Station. The results of the inspection were discussed with Mr. F. J. Duddy and other members of your staff at the conclusion of the inspection and during on Enforcement Conference held on October 29, 1954 at the fiRC Region IV office in Arlington, Texas with you and other members of the Kansas Gas and Electric staff and myself and other members of the Region IV staf f.
Two violations were identified during this inspection. They are described in the enclosed hotice of Violation and Proposed Imposition of Civil Penalty.
Violation I represents a significant breakdown in your program for the inspection and correction of defective safety-related structural steel welds.
To emphasize the need for Kansas Gas and Electric Company management- to ensure an effective quality assurance program has been implemented that both identifies and corrects construction deficiencies, I have been authorized, af ter consultation with the Deputy Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Seventy-five Thousand Dollars (575,000) for this violation. The violation has been categorized as a Severity Level III violation in accordance with the tiRC Enforcement Policy, 30 CFR Part 2, Appendix C, 49 FR E583 (March 6,1984). The base civil penalty for a Severity Level III violation is 150,000. However, since you failed to take adequate corrective actions for the problems identified by Corrective Action Requests CAR ido. 1-W-0029 (initiated on March 22,1983) and CAR No. 1-W-0031 (issued August 16,1983), the base civil penalty is being escalated by 50%.
Violation II has been categorized as a Severity Level IV violation for which no civil penalty is proposed. -
You are required to respond to the ent,losed fictice of Violation and Proposed Imposition of Civil Penalty. In preparing your response you should follow the instructions specified in the fictice. Your reply to this letter and the results of future inspections will be considered in determining whether further enforcement action is warranted.
CERTIFIED 7%IL RfiURt. RECEIPT REQUESTED.
EXHIBIT W gn r 1 ~W QP
l Kansas gas and Electric Company 2 i
In accordance with 10 CFR 2.790, of the NRC's " Rules of Practice, Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedure of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely, Origina: Signer Ef Faul S C h.c.h Robert D. Martin, Regional Administrator Region IV e
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc: w/ enclosure Kansas Gas and Electric Company ATTN: Gene P. Rathbun, Manager of Licensing P.O. Box 208 \
Wichita, Kansas 67201 Forrest Rhodes, Plant Superintendent Wolf Creek Generating Station P.O. Box 309 Bur.ington, Kansas 66839
I Kan'sas Gas and Electric Company Distribution "
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Enforcement Coordinators RI, RII, RIII, RIV, RV BHayes, 01 SConnelly, 01A JCrooks, AEOD EA File
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NOTICE Of VIOLATION AND PROPOSED IMP 051110N Of CIVIL PENALTY Kansas Gas and Electric Company Docket: 50-482/84-22 Wolf Creek Generating Station Permit: CPPR-147 EA 84-107 As a result of an NRC inspection conducted during the period of June 11, 1984 through September 28, 1984, two violations were identified one of which represents a significant breakdown in the licensee's program for the inspection and correction of defective safety-related structural steel welds. To emphasize the need for Kansas Gas and Electric Company management to ensure an effective quality inspection program has been implemented that both identifies and corrects construction deficiencies, the Nuclear Regulatory Commission proposes to impose a civil penalty in the amount of Seventy-five Thousand Dollars (575,000) for this violation.
In accordance with the NRC Enforcement Policy, 10 CFR Part 2, Appendix C, as revised, 49 FR 8583 (March 8, 1984), and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended ("Act"), 42 U.S.C. 2282, PL 96-295 and 10 CFR 2.205, the particular violations and the associated civil penalty is set forth in Section I below:
- 1. Civil Penalty Violation Criterion X of 10 CFR Part 50, Appendix B, requires that a program for inspection of activities affecting quality be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.
Criterion XVI of Appendix B further requires that measures be established to assure that nonconformances are promptly identified and corrected.
Criterion XVII requires that sufficient records be maintaihed to furnish evidence of activities affecting quality.
Daniel International Corporation (DIC) Construction Procedure No.
QCP-VII-200 describes the requirements for performance and inspection of safety-related structural steel welds with respect to committed conformance to the American Welding Society (AWS) D1.1.-75. Appendix I in Revision 4 of this procedure invokes a prohibition with respect to lack of fusion, overlap, slag, arc strikes, and weld splatter. Paragraph 6.5.1 of AWS D1.1-75 requires inspector verification that the size and length of welds conform to the drawing requirements and that no specified welds are .
omitted.
Contrary to the above, the inspection program for safety-related structural steel welds was not adequately executed to assure conformance to the requirements of Construction Procedure QCP-VII-200 Revision 4 and the AWS DI.1-75 Code nor were adequate records kept to document the quality of the welds. Furthermore, once deficient welds were identified, no actions were taken to correct the deficiencies. This inadequate inspection program and the failure to take corrective actions is evidenced by the following:
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Notice of Violation 2
- 1. A random reinspection of 241 structural steel safety-related welds, which were made in accordance with Revision 4 of QCP-VII-200, was performed by DIC and documented in Corrective Action Report (CAR)
No. 1-W-0029 dated March 22, 1983. Sixty-two percent of the inspected welds were found by the DIC inspectors to not conform to the requirements of Revision 4 of QCP-VII-200. The reported defects that resulted in rejection by the DIC inspectors included arc strikes, slag, lack of fusion, overlap, and wel.d splatter.
- 2. Another reinspection of a sample of structural members with the lowest design safety margins was initiated on September 14, 1984.
The results of the licensee reinspection activities (verified by NRC inspectors) as of September 28, 1984, were as follows:
- a. A missing weld was found at the same location in each of six pressurizer support connections. In addition, five of 14 fillet welds in one pressurizer' support connection were undersized by 1/8-inch to 1/4-inch with respect to the drawing-required size of 5/8-inch, and two of these welds were also under the required length; i.e., 3-inch and 5-inch lengths, respectively, versus a drawing required length of 8 inches.
The weld dimensions of the remaining five pressurizer support connections were not included in the NRC verification activity.
- b. Reinspection of nine structural steel connections in the auxiliary building identified two missing welds in one connection. In addition, weld size and length discrepancies were identified in each of the nine connections. Of the total of 106 welds in the connections, eight were found to be undersized by 1/16-inch to 3/16-inch with respect to drawing-required width. Two of the undersized welds were also under the required length; i.e. , 21/4-inch and 2*,1/2-inch lengths, respectively, versus a drawing required length of 3 inches. An additional nine welds were also under the drawing required length of 3 inches by 1/2-inch to 1-inch.
Examination of 54 weld returns in the nine connections found 26 to be undersized by 1/16-inch to 3/16-inch with respect to drawing-required widths. One of the undersized weld returns was also under the required length; i.e. , 2 inches versus a drawing-required size of 3 inches. In addition, 36 weld returns exceeded the drawing required maximum length of 5/8-inch by 1 5/8 inches to 3 5/8 inches. An additional eight weld returns exceeded the drawing-required maximum length of 3/4-inch by 1/2-inch to 21/8 inches.
- 3. The absence of required Miscellaneous Structural Steel Weld Records (MSSWRs) for documenting welding and inspection of safety-related structural steel welded connections was identified by KG&E in CAR No.
1-C-0031. As a result of this identification, it has been established that approximately 16 percent of MSSWRs could not be located, which precludes positive verification of control of welding and performance
Notice of Violation 3
of required inspections. Approximately 80 percent of the MSSWRs applicable to the activities described in paragraph 2 above could not be located. Records were not available to indicate that an initial inspection was performed of either the pressurizer support connections or the auxiliary building structural connection which was identified to be missing two welds.
MSSWRs were located for certain welds in four structural connections which indicated acceptable welds. However, reinspection of these four connections showed one undersized weld in one connection and undersized and overlength weld returns in the four connections.
This is a Severity Level III Violation. (Supplement II.C)
Civil Penalty $75,000 II. Violation Not Assessed a Civil Penalty I
Criterion V of 10 CFR 50, Appendix B, requires that activities affecting quality shall be accomplished in accordance with appropriate instructions, procedures, and drawings, and that these instructions, procedures, and drawings contain appropriate quantitative acceptance criteria.
Bechtel Drawing E-IR8900, Revision 1, " Raceway Notes, Symbols and Details" states in paragraph 3.36.4 that:
"Mininum separation between different Class IE conduit systems and minimum separation between Class IE conduit systems and non IE conduit systems shall be 1". Separation shall be measured between the outside edges of the conduit".
Bechtel Drawing E-01013(q), Revision 11, requires the following:
- 1. Paragraph 5.8.1.6 "Within the control boards andi.other panels '
associated with protecticn systems, circuits and instruments of different separation groups shall be independent and physically separated horizontally and vertically by a distance of 6 inches".
- 2. Paragraph 5.8.3 "Non-safety related circuits shall be separated from Class IE circuits by the same distances applicable to Class IE circuits of different groups".
Contrary to the above, the following activities affecting quality were not accomplished in accordance with appropriate drawings:
1.
There were seven cases noted where conduit-to-conduit separation was less than one inch.
- 2. There were five areas in the control panels and cabinets where electrical cable separation was less than six inches. !
This is a Severity Level IV Violation (Supplement II). !
l
Notice,of Violation 4 Pursuant to the provisions of 10 CFR 2.201, Kansas Gas and Electric Company is hereby required to submit to tne Deputy Director, Of fice of Inspection and Enforcement, USNRC, Washington, D.C. 20555, with a copy to this office, within 30 days of the date of this Notice, a written statement or explanation in reply, including for each alleged violation: (1) admission or denial of the alleged violation; (2) the reasons for the violation, if admitted; (3) the corrective steps that will be taken and the results achieved; (4) the corrective steps that will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, Kansas Gas and Electric Company may pay the civil penalty in the amount of $75,000 or may protest imposition,of the civil penalty in whole or in part by a written answer. Should Kinsas Gas and Electric Company fail to answer within the time specified, the Deputy Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalty in the amount proposed above. Should Kansas Gas and Electric Company elect to file an answer answer may:
in accordance with 10 CFR 2.205 protesting the civil penalty, such (1) deny the violations listed in the Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty. In requesting mitigation of the proposed penalty, the five factors contained in section V.B of 10 CFR Part 2, should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of Kansas Gas and Electric Company is directed to the other provisions of 10 CFR 2.205 regarding the procedure for imposing a civil penalty. '
Upon failure to pay any civil penalty due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.
FOR THE NUCLEAR REGULATORY COMMISSION
< /
.h) Regional v Robert D. Martin Administrator Dated at lington, Texas this g ay of November 1984
Q4-84-053 KANSAS GAS AND EUCmc COMPANY
,- . t eme em.e GLEhk L ROgSTEm 948 se t t'es e.* motsa..
December 31, 1984 W . Richard C. De Yo ung . Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Comission Washington , D.C. 20555 KMLNRC 84-237 Re: Docket }h. STN 50-482 Ref: Letter KMLNRC 84-238 from GLKoester, KG& E, To RCD = Young , NRC Subj : Enforcement Action 84-107 '
De r W . DeYoung :
The Reference provided Kansas Gas and Electric Company's (KG&E) response to the " Notice of Violation and Imposition of Civil Penalty" relative to Enforcement Action 84-107. In that response, KG&E doctnented the extensive corrective actions taken to resolve the concern and provide assurance that the quality of construction meets or exceeds applicable requff ements. Based upon the actions taker., KGiE believes the aucunt of the Civil Penalty is excessive and should not have been escalated oy 50%.
Notwithstanding our right to request miti5ation of the Civil Penalty, we are enclosing a check in the amount of $75,000 made payable to the Treasurer of the United States. Further debate over the issues which gave rise to the Civil Penalty is not likely to be productive. In this case or resorces i
will be better spent in working cooperatively with the NRC to complete the quality construction and licensing of Wolf C eek Generating Station.
Yours very truly, J gt
'. ~.} e t t.- P m
[# Glenn L. Koester Vice President-Nuclear GLK:ke Attach CERTIFIED MAIL xc: RDMartin, Reg.IV RPDenise P0'Connor (2)
HBundy g M_ d7y a rf, Q
'r EXHIBIT (9)
KANSAS GAS AND ELECTRIC COMPANY To G E6.ECTfhC NANYl 6 L E es se L aOESTER v.cs u . . . u.
December 31, 1984 W. Richard C. DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Comission Washington , D.C. 20555 KMLNRC 84-237 Re: Docket th. STN 50-482 Ref: Letter KMLNRC 84-238 from GLKoester, KG&E, To RCDeYotzig , NRC Subj : Enforcement Action 84-107
Dear W. DeYotrig:
The Reference provided Kansas Gas and Electric Company's (KG&E) response to the " Notice of Violation and Imposition of Civil Penalty" relative to Enforcement Action'84-107. In that response KG&E doctanented the extensive corrective actions taken to resolve the concern and provide assurance that the quality of construction meets or exceeds applicable requff ements. Based upon the actions taken, KG&E believes the anount of the Civil Penalty is excessive and should not have been escalated by 50%.
Notwithstanding our right to request mitigation of the Civil Penalty, we are enclosing a check in the amount of $75,000 made payable to the Treasurer of the United States. Further debate over the issues which gave rise to the Civil Penalty is not likely to be productive. In this case, our resou-ces will be better spent in working cooperatively with the NRC to complete the quality construction and licensirig of Wolf &eek Generating Station.
Yours very truly, g gtq
- ._) 'l et e- W m
[# Glenn L. Koester Vice President-Nuclear GLK:ke -
Attach l CERTIFIED MAIL Ic: RDMartin, Reg.IV M }.-
RPDenise (
P0'Connor (2)
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it BILL FOR COLLECTION 3,ii x ,.....-......
U.S. Nuclear Regulatory Comission ...
WashinatdE,"Y$"'7b55'"' "'" " "~ Daie ..Janua ry,,7, 1985 Address)
PMER.
Kansas Gas and Electric Company P.O. Box 208 Wichita, KS 67201 7 4, , 4 n , s . ;< ,, ,,, , ,,,, e , ,,
p=>re a u4 4u r nueu,.
SEE INSTRI CTIO.\S BEL 0ss'.
p ie DSCRIPTION Quantity ,"" py '
Amount 1/7/85 Received full payment for EA 84-107, dated 11/21/84, Docket No. STN 50-482
$75,000.00 l
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I l A.uCU.\T DCE THIS BILL. ,l 5 75,00C .00 This is not a receipt INSTRUCTIONS Tsader of rasment of the abose bill mas ss th2 smce incicated Such tender, when in ans other form than cash. should be drawn to end Bs:reau or Omcc incacated abose nt l
Receipis mill be issued in all cases where
- cash"is receised, and only upon request when remittance sf pas msnt of this bill as other than cash or United States postal monew order. them.receips Ifrender sha!! no
- enfer h;s been cleared and the amount receased bs the Departrnent or Establishment and Bureau or Omce ind ,
such surema Ftiltre is, menisoned or agenes recesseabose.
a receipt for a cash pasment should be prompelv reported by the paver to the c r s ca.twierNT PABrT9sc OFFICE 1994 0 a SIS.See
KANS'AS fG ELECTRIC COMPf. 4Y NO.21587 P O BOk 206 WiCH11 A, K ANSAS 67201 VENDOR NO T011301 CONTROL NO
' " Nif SNVO8CE AasOUNT
'"EYa eNv0ect NuatsYe PO NuatBER g
.22184 CIVIL PENALTY IMPOSED SY U.S. NUCIEAR REGULATORY COM ISSION ON NOVEMBER 21, 1984, UNDER DOCKET N0. 50-482, CONSTRUCTION PERMIT NO. CPPR-147, EA84-107 75,000.00 i I
I CHECK TOTAL SPECIAL HANDLING c/o GLEN L. K0 ESTER i KANSAS f3WICHITA, ELECTRIC COMPANY M-NO. 21587 i P.O. box 208 KANSAS 67201 tat sovata watoNA sana a Taust couPANv w c<ta a DATE VENDOR NO. PAY EXACTLY
/ 122784 T011301 $***75,000.00
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