ML20136C100
| ML20136C100 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/20/1984 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Connelly S NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| Shared Package | |
| ML20136C034 | List: |
| References | |
| FOIA-85-101 NUDOCS 8511210022 | |
| Download: ML20136C100 (2) | |
Text
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UNITED ,ST ATEs
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REGION IV v[,. Ett RY AN PLAZ A DRIVE. SutTE 10@
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MEMORANDUM FOR: Director, Office of Inspector and Auditor s
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Robert D. Martin c -
Regional Administrator, Region IV
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SUBJECT:
NRCM 0702 NOTIFICATION <h,).-
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$J o f f qA Pursuant to NRC Manual Chapter 0702, I wish to inform you of two concerns O,,1#M$ >)
raised by OI with regards to RIV's handling of information pertaining to # e ,,
missing records and the falsification of other records at Kansas Gas and e Electric's Wolf Creek facility. Specifically, 01 has raised the following e,d two concerns: o 4 -
- 1. RIV failure to promptly notify 01 of the possibility of wrongdoing M, M
by KG&E at Wolf Creek. W v. .
- 2. RIV's reference to the fact that there may be an investigation of such wrongdoing in the inspection report, a copy of the final .y report having been given to KG&E on October 26, 1984.
p J' y I have attached a chronology of eve....: which may be of assistance to you in better understanding the background for Ol's concerns. Please let me 4.'
know if I can provide any additional information or answer any questions.
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[futobertD. Martin Regional Administrator 1
d Enclosure cc: W. J. Dircks, EDO .
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- Sequence of Eventso 10/4/84 A KG6E Quality First investigation report sent to 01/RIV.
This report was sent directly to R. Herr, 01 Director in RIV, by KG6E. The report stated that there had been falsification of some records.
Week of R. Martin, RIV Regional Administrator, brief ed on Wolf Crc.ek 10/15/84 enforcement issues by T. Westerman, R. Denise, L. Martin, and P. Check. R. Martin directed that inspection report state that there would be a possible investigation of certain issues. Since KG6E was already aware of the issues, having reported them to the NRC originally, he felt that the report should be "up front" in re the possibility of an investigation.
Same day or T. Westerman, RIV Enforcement Officer, briefed R. Herr that day after there had been a question of wrongdoing raised during a Wolf above meeting Creek inspection. T. Westerman emphasized the falsification of records issue.
10/23/84 D. Eisenhut briefed Commission on overall enforcement issues presumably including two issues of possible wrongdoing.
10/24 or The two possible issues of wrongdoing were discussed with 10/25/84 R. Herr in L. Martin's office.
10/26/84 Allegation Review Board meeting held. The two issues of possible wrongdoing were specifically discussed and R. Herr was informed that he would need to " follow-up on thec" and that a memorandum on the matter would be forthcoming.
Attendees at the meeting included: R. Herr, T. Westerman, R. Denise, L. Martin, C. Madsen, J. Jaudon, Eric Johnson, D. Hunter.
10/26/84 Final Inspection Report sent out--a copy sent to KG6E.
(Copy of transmittal attached.)
10/29/84 Enforcement Conference with KG6E. All enforcement issues were discussed.
11/13/84 Memorandum sent to R. Herr by R. Martin, Regional Administrator, cn this date formally informing him of the two possible issues of wrongdoing (copy attached). The issues had been discussed with R. Herr again by T. Westerman the week before this memorandum was sent. That same week, R. Herr pointed out the Inside NRC article on the Wolf Creek enforcement issues to T. Westerman. (Copy of Inside NRC issue attached.)
- Sequence dates are the best that recollection on records provide at this time. If dates can be refined, this Sequence will be updated.
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. Docket:
STN 50-482/84 //[l o ,, e 0
. 'EA 84-107 NOV 2 1 IB4 Kansas Gas and Electric Company ATTN: Glenn L. Koester Vice President - Nuclear P.O. Box 208 Wichita, Kansas 67201 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY This refers to the inspection conducted by Mr. R. G. Taylor and other Region IV ,
personnel during the period June 11 through September 28, 1984 of activities authorized by NRC 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 an Enforcement Conference held on October 29, 1984 at the NRC 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 staff.
Two violations were identified during this inspection. They are described in the enclosed Notice 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 impicmented 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 ($75,000) for this violation. The violation has been categorized as a Severity Level 111 violation in accordance with the NRC Enforcement Policy,10 CFR Part 2, Appendix C, 49 FR 8583 (March 8,1984). The base civil penalty for a Severity Level Ill violation is $50,000. However, since you failed..to take adequate corrective actions for the problems identified by Corrective Action Requests CAR No. 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 11 has been categorized as a Severity Level IV violation for which no civil penalty is proposed.
You are required to respond to the enclosed Notice of Violation and Proposed Impositiet.. of Civil Penalty. In preparing your response you should follow the instructions specified in the Notice. Your reply to this letter and the results of future inspections will be considered in determining whether further enforcement action is warranted.
CERTIFIED MAIL RETURN RECEIPI REQUESTED IE:ES ELD Rly ES:D IE:DD zoom- 4 xm ._, own JAxelrad JTavine 11/ /84 11/ /84 11/ /84 11/ /84 11/ /84 ,
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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 Managenent and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely, Originar signed E.y Paul S. Ch;ch Robert D. Martin, Regional Administrator Region IV
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 Burlington, Kansas 66839 l
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I NOTICE OF VIOLATION AND PROPOSED IMPOSITION Of CIVIL PENALTY Ka nsas 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 pursuint 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:
I. 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 maintained to furnish evidence of activities affecting quality.
Daniel International Corporation (DIC) Construction Procedure No.
QCP-VII-200 describes the requiremen'ts 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 D1.1-75 Code nor were adequate records kept to document the quality of the welds. Furthermore, once deficient welds were identified, no actions were 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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- 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 weld 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., 2 1/4-inch and 2s1/2-inch lengths, respectively, versus a drawing required length of 3 inches. An additional nine welds were aise 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 2 1/8 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
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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 initia.1 ins'p ection was performed of either the pressu'rizer support cannect' ions 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 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-1R8900, Revision 1, " Raceway Notes, Symbols and Details" states in paragraph 3.36.4 that:
j "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 and.other panels associated with protection systems, circuits and instruments of different separation groups shall be independent and physically separated horizontally and vertically by a distance of 6 s 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).
[ _ .-
4 Notice of Violation 4 Pursuant to the provisions of 10 CFR 2.201, Kansas Gas and Electric Company is hereby required to submit to the Deputy Director, Office 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; an.d (5) the date when full compliance will be achieved. Consideration may be g'iven 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 Khnsas 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 in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may: (1) deny the violations listed in the Notice in whole or i'n 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
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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 f A v Robert D. Martin Regional Administrator Dated at clington, Texas this oay of November 1984 i
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The Honorable Nunzio Palladino Chairman Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Chairman:
Thank you for arranging for your staff to brief my colleagues in the Kansas Congressional delegation and me on the wolf Creek situation. I was disappointed, however, that neither Mr. Dircks nor Mr. Denton was present.
The meeting was helpful in providing us an understanding of the wolf Creek issues.
But some issues were not adequately addressed and other new questions were raised.
I listened carefully to descriptions of the NRC staff's efforts leadino it to conclude that questions concerning construction quality had been adequately resolved.
While there is no doubt as to the nature of the staf f's conclusions, it seemed to me that some gaps existed in the staff's explanation as to how it arrived at its conclusions.
Because of my continuing concerns, I would appreciate your providing an explanation, including a chronology, describino (A) the discovery of the problem of structural steel weld quality, (B) steps taken to assure its resolution by the licensee, and (C) actions taken by NRC staff to determine whether the licensee's resolution was in accord with applicable regulations.
Please provide, in addition, a similar explanation with respect to problems involving cable separation as described in Inspection Reports 50-R42/R4-22 and 50-842/84-51.
I am also confused about the status of items assigned to the NRC Office of Investigations (OI). Your letter to Chairman Dingell indicated that several investigations were underway with respect to missing, falsified, or erroneous records. I inferred from your staff, however, that little or no investigative work had actually been conducted on the records-deficiences. ;
Please inform me as to the status of each inquiry including the date on which l
the inquiry began, the amount of effort applied since that date, and its estimated completion date. I I would appreciate this information as quickly as poss e. i W reg ,
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WASHINGTON OFFICE 1431 LobeGWORT,4 Houst OFFact BUILDING ' CANSAS OFFICE l WASHINGTON, DC 20515 ' 7 SUlft 280 '
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JIM SLATTERY 2ND DisinscT, KANSAS February 8, 1985 The Honorable Nunzio Palladino Chairman Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Chairman,
Thank you for arranging for members of your staf f to brief the Kansas congressional delegation concerning NRC oversight of the Wolf Creek project.
The meeting was helpful in furthering The presentation, however, left meofwith my understanding of the progress the Wolf Creek project.
several questions that I wish to have resolved.
I would appreciate your providing an explanation, including a chronology, describing the discovery of the problem of structural steel weld quality, steps taken to assure its resolution by the licensee, and actions taken by the NRC staff to determine whether the licensee's resolution was in accord with the applicable regulations.
With regard to the problem welds, I am particularly interested in receiving an explanation of how the inspection was carried out upon welds that were covered with paint, and upon welds that were imbedded in concrete, and I would like to know if those inspections were carried out in accord with the applicable regulations.
It your staff, is mu understanding, based upon the meeting I attended with to missing, that several investigations are underway with respect falsified, or erroneous records.
as to the status of Please inform me each inquiry, including the date on which the inquiry began, the activities and its estimated completion date. that have taken place since that date, I look forward to your prompt response.
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Howard Bauleke. Washington office JS/hb 0 ri , j,. '
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REQUEST INF0 PI WOLF CREEK ISSUES e=ctosuars
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TO:
CHAIRMAN PALLADINO FOR SIONATURE OF: ** PRIORITY ** SECY NO: 85-106 EXECUTIVE DIRECTOR DESC: ROUTING:
REQUEST INFO RE WOLF CREEK ISSUES DIRCKS ROE DATE: 02/12/85 REHM ASSIONED TO: RIV CONTACT: RMARTIN STELLO TAYLOR DENTON SPECIAL INSTRUCTIONS OR REMARKS: GCUNNINGHAM QI PROVIDE INPUT TO REGION IV. -
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Rep Jim Slattery CORRESPONDENCE CONTROL TICKET SECY NUMBER: 85-106 LOGGING DATE: 2/11/85
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OFFICE OF THE SECRETARY ACTION OFFICE: E00 AllTHOR: Rep Jim Slattery -
AFFILIATION: U.S. House of Representatives '
LETTER DATE: 2/8/83
) FILE CODE:
g ADDRESSEE: Palladino
SUBJECT:
Ques concerning Wolf Creek Proj ACTION: ED0's Sign ....Date due: Feb 21 DISTRIBUTION: OCA to Ack, RF SPECIAL HANDLING: None SIGNATURE DATE: 8AC FOR THE COMMISSION:
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MEMORANDUM FOR: Commissioner Asselstine ,
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FROM: Samuel J. Chilk, Secret h '
SUBJECT:
OIREQUESTFORCOMMISSIONdUIDANCE ON INITIATING INVESTIGATYONS OF SENIOR MANAGERS AT THE WOLF CREEK GENERATING STATION A majority of the Commission has not supported your suggestion regarding the initiation of an investigation by OI on the matters contained in Ben Hayes' December 24, 1984 memorandum for the reasons indicated in their responses which were provided to you. Commissioner Roberts requested additional information from OI and received.it on January 15, 1985. He has made no further comment.
Attached is a copy of a memorandum to Mr. Hayes on this subject. ~
This completes action on your memorandum of January 2, 1985.
Attachments:
As Stated cc: Chairman Palladino Commissioner Roberts Commissioner Bernthal Commissioner Zech OGC OPE-EDO OI l
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