ML20052E500
| ML20052E500 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/21/1982 |
| From: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20052E496 | List: |
| References | |
| 50-482-81-12, NUDOCS 8205110164 | |
| Download: ML20052E500 (3) | |
Text
i APPENDIX A N01 ICE OF VIOLATION Kansas Gas and Electric Company Docket No. STN 50-482 Wolf Creek, Unit 1 As a result of the investigation conducted at the Wolf Creek, Unit 1, site in Burlington, Kansas, on June 8-9, June 17-18, and June 29-July 2, July 27-30, and August 13, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
A.
Failure to Follow Procedures Relative to the Installation of Safety-Related Duct Work and Supports 10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
Daniel International Corporation (DI) Work Procedure VIII-200, " Field Fabrication and Erection of Safety-Related Duct Work and Supports,"
issue date March 26, 1979, requires that safety-related Heating Ventilation and Air Conditioning (HVAC) hangers be erected in accor-dance with HVAC travelers and fabrication drawings.
Additionally, it states that QC inspection of the HVAC hangers would be performed in accordance with the traveler and Quality Control Procedure VIII-200.
Contrary to the above:
1.
Miscellaneous Structural Steel Weld Records (MSSWR) were used to document completion and QC inspection of attachment welds on HVAC hangers from June 25 to mid-August 1979, even though the Weld Control Record (WCR) form was issued on July 25, 1979, by DI j
Engineering Department for use as an HVAC traveler.
2.
DI Quality Control Procedure VIII-200, Revision 0, entitled " Field Fabrication and Erection of Safety-Related Duct Work and Supports" was not issued until September 24, 1979, indicating that there was no written procedure for QC inspection from March 26, 1979, until September 24, 1979.
This is a Severity Level IV violation.
(Supplement II-D)
B.
Failure to Maintain Sufficient Records Relative to Installation of Safety-Related HVAC Hangers 10 CFR 50, Appendix B, Criterion XVII states, in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality."
l 8205110164 820421 PDR ADOCK 05000482 l
G PDR L.
, Contrary to the above, records were identffied that did not furnish evidence of activities affecting quality in that they were fallacious.
Examples of fallacious records were:
1.
Data was transferred from the MSSWR form (which documents only attachment welds) to the WCR form (which documents the fabrication /QC inspection of the complete hanger) using hanger blueprints to identify the welds on each hanger with no visual confirmation that the welds had been completed.
2.
Data was subsequently transferred from the WCR form to form Weld r
Control Record Supplement Sheet (WCRSS) (which documents each individual weld on the respective hanger) with no valid record that the information on the WCR form correctly represented the fabrication and QC approval of a completed hanger.
3.
Numerous conflicts were identified in the Control Room HAVC hangers where the welder identification numbers on hanger welds and the welder identification numbers on the associated WCR form and/or j
WCRSS form did not correspond.
f This is a Severity Level IV violation.
(Supplement II-D)
C.
Failure to Establish Adequate Measures Relative to the Identification and Correction of Conditions Adverse to Quality 10 CFR 50, Appendix B, Criterion XVI states, in part, " Measures shall
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be established to assure that conditions adverse to quality, such as l
.,.. deviations... and nonconformances are promptly identified l
and corrected."
DI Deficiency Report 1SD5455M, dispositioned on November 18, 1980, states, in part, " Incorrect entries on WCRs and/or incorrect 'D' stamping to be corrected under direction of craft supervision...." The " Action Taken" portion of DR ISD5455M states, " Craft has been retrained and welding discrepancies corrected to reflect correct
'D' stamps and weld numbers with 3
corresponding traveler sheets."
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Contrary to the above, welding discrepancies had not been corrected to reflect correct "D" stamps and weld numbers with corresponding traveler sheets in that a re-examination of certain supports, i.e., R3349 on June 25, 1981, and R3240 on August 20, 1981, revealed that the welder "D" numbers did not correspond with the traveler sheets.
This is a Severity Level IV violation.
(Supplement II-D) l b
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. I D.
Failure to Establish Adequate Meass:res to Assure that Special Processes are Controlled and Accomplished by Qualified Personnel I
10 CFR 50, Appendix B, Criterion IX states, in part, " Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel...."
Contrary to the above, valid welder identification numbers were changed i
in September and October of 1979 to agree with erroneous Weld Control Records thus eliminating their authenticity.
l This is a Severity Level IV violation.
(Supplement II-D)
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t Pursuant to the provisions of 10 CFR 2.201, Kansas Gas and Electric Company is hereby required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply, including: (1) the corrective steps which will be taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Under the authority of Section 182 of the l
Atomic Energy Act of 1954, as ammended, this response shall be submitted i
under oath or affirmation.
Consideration may be given to extending your response time for good cause shown.
j Dated: April 21,1982 W. C. Seidlp, Chief Reactor PrVject Branch 2 l
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