IR 05000301/1998005

Insp Rept 50-301/98-05 on 971216-980309.Violations Noted. Major Areas Inspected:Maint

ML20247D695
Person / Time
Site:	Point Beach
Issue date:	05/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247D666	List: IR 05000301/1998005 ML20247D660 ML20247D668
References
50-301-98-05, 50-301-98-5, NUDOCS 9805180025
Download: ML20247D695 (12)

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l U.S. NUCLEAR REGULATORY COMMISSION J

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REGIONlli Docket No.: 50-301 License No.: DPR-27 I

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Report No.: 50-301/98005(DRS)

Licensee: Wisconsin Electric Power Company

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Facility: Point Beach Nuclear Plant

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Location: 6612 Nuclear Road l Two Rivers, WI 54241-9516 Dates: December 16,1997 - March 9,1998 Inspector: K. S. GreenBates, Reactor Engineer Approved by: J. A. Gavula, Chief Engineering Specialist Branch 1 l

9005180025 990505 PDR ADOCK 05000301 G PDR ,

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EXECUTIVE SUMMARY Point Beach Nuclear Plant, Unit 2 NRC Inspection Report 50-301/98005(DRS)

Because of potential problems relating to a Morrison Knudsen Corporation (MK), Quality Finding Report, the NRC requested Point Beach to evaluate the adequacy of the weld procedures used during the recent Steam Generator Replacement Project (SGRP). The MK Quality Finding Report, C-96-022, dated January 15,1997, indicated that certain welding procedures, used during the SGRP, failed to meet relevant quality assurance standards. The NRC requested that Point Beach evaluate the Unit 2 SGRP welding procedures and associated welds to verify that American Society of Mechanical Engineers Code (Code) requirements were met. A special inspection was initiated to evaluate the weld procedure concerns associated j with these weld procedures. Reviews of documentation and interviews with licensee and contractor staff were conducted on-site and at the Region lli NRC office during the inspection period. The results of this inspection are discussed belo Maintenance j

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The inspector identified two violations of 10 CFR 50, Appendix B, Criterion IX pertaining to main steam and feedwater welding procedures which did not meet Code heat input

. requirements. Additionally, the inspector identified a violation of 10 CFR 50, Appendix B, Criterion V, pertaining to a weld procedure which lacked instructions to perform a post weld heat treatment which had been performed on a main steam piping weld. The inspector concluded that the affected welds did not pose an immediate safety concern due to the extensive margin available to the minimum allowable Code impact strengt The inspector identified three examples of a violation of 10 CFR 50, Appendix B, Criterion XVil pertaining to errors in documentation of welds made during the Unit 2 steam generator replacement. These errors in documentation hampered licensee and inspector efforts to verify that the Code requirements had been met for the affected welds.

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The inspector identified that the welding contractor and licensee audits of welding performed during the Unit 2 steam generator replacement lacked rigor and were ineffective. Specifically, the audits did not identify that welding procedures did not meet the Code requirements and that weld documentation records were inaccurate. Also, the licensee had established a weak basis for operability of the Unit 2 steam generators with respect to the use of non-Code qualified welding procedure ,

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Report Details Backaround Information I Because of potential problems relating to a Morrison Knudsen Corporation (MK), Quality Finding Report, the NRC requested Point Beach to evaluate the adequacy of the weld i procedures used during the recent Steam Generator Replacement Project (SGRP). The MK Quality Finding Report, C-96-022, dated January 15,1997, indicated that 14 of 18 welding procedures used during the SGRP failed to meet relevant quality assurance standards. In a letter dated August 5,1997, the NRC requested that Point Beach evaluate the Unit 2 SGRP j welding procedures and associated welds to verify that American Society of Mechanical Engineers (ASME) Code requirements were me II. Maintenance M3 Maintenance Procedures and Documentation l

M31 Unit 2 Steam Generator Replacement Proiect Weldina Procedures Insoection Scooe (IP 50001. IP 55050)

The inspector reviewed seven of the Point Beach Unit 2 SGRP weld procedures, in conjunction with the supporting Procedure Qualification Records (POR), for conformance with ASME Code and regulatory requirement Observations and Findinas Weld Procedures Do Not Meet Code Heat lnout Requirements Heat inputs traceable to weld material contained in the Charpy impact specimens are the heat inputs that support ASME Code,Section IX, QW 409.1, weld procedure qualification requirements. This ensures that the more limiting weld material properties, l created by higher heat inputs, are measured and tested as part of the qualification wel Paragraph QW-409.1 of the ASME Code states, in part, that an increase in heat input, or an increase in volume of weld metal deposited per unit length of weld, [is not allowed)

over that qualifie The inspector identified that weld procedure specifications (WPS), used in fabrication of the following welds, allowed heat inputs in excess of that used in the qualification weld b.1.1 Main Steam and Main Feedwater Field Welds FW-2.3.4.7 and 10

Main steam field welds FW-2 and 3, and feedwater field welds FW-4 and 10 on steam I generator (SG) A, and main steam field welds FW-2 and 3, and feedwater field welds

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l FW-4 and 7 on SG B, were fabricated using gas tungsten arc welding (GTAW)in accordance with WPS GT-SM/1.1-1PB, Revision 4. These welds had a base material

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l thickness range between 5/8 and 1.5 inches. The weld procedure allowed these welds to be fabricated with heat inputs of up to 47.4 kilo-Joule per inch (kJ/in). However, the qualification welds documented in the supporting POR GT-SM/1.1-Q4, were welded with a maximum heat input of 29.5 kJ/in for material thicknesses between 5/8 end 1.5 inche Therefore, the heat inputs authorized in WPS GT-SM/1.1-1PB, Revision 4, exceeded the heat inputs in the supporting qualification welds, which was contrary to ASME Code paragraph QW 409.1 requirements. Failure to use an ASME Code qualified welding procedure for the affected welds is a violation of 10 CFR 50, Appendix B, Criterion IX (VIO 50-301/98005-01(DRS)) .

Exceeding the omlified heat input for these welds has a potential consequence of lowering of the .aesired impact strength of the weldment. ASME Code, Section ill, NB/NC 233;, required a minimum Charpy V-notch Test impact strength of 25/30 mils of lateral expansion. inspectors noted that the average measured Charpy V-notch Test value for the qua!ification welds using lower weld heat inputs, was 65.3 mils lateral

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expansion. Based on the extensive margin to the minimum acceptable values, the l inspector concluded that there was no immediate safety concern for the affected weld b.1.2 Feedwater Nozzle-to-Pioe Weld A feedwater nozzle-to-pipe weld was fabricated using GTAW and shielded metal arc l

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welding (SMAW) processes in accordance with Revision 1 of GT-SM-BU/1.3-1PB. The WPS allowed heat input values of 73.3 kJ/in for GTAW, and 83.7 kJ/in for SMA These values exceeded heat inputs of 43.3 kJ/in for GTAW and 54.3 kJ/in for SMAW in the supporting PQR, GT-SM-BU/1.3Q1. Therefore, the heat inputs authorized in WPS GT-SM-BU/1.3-1PB exceeded the heat input limitations of the qualified weld, which is contrary to ASME Code paragraph QW 409.1 requirements. Failure to use an ASME Code qualified welding procedure for the affected welds is a violation of 10 CFR 50, Appendix B, Criterion IX (VIO 50-301/98005-02(DRS)) .

This weld was later removed in order to Install a different weld joint configuration, and therefore, there was no safety concern. However, the use of an unqualified WPS was not recognized at the time and violated Code requirement Main Steam Weld Procedure Lacked Instructions Main steam field weld FW-6 on SGs A and B was fabricated in accordance with weld procedure WPS GT-SM/1.1-1PB, Revision 4. Although, this weld procedure had instructions to perform a post weld heat treatment (PWHT) for base materials exceeding 1.5 inches, no instructions existed to perform a PWHT on weldments with a thickness below 1.5 inche On December 9 and 10,1996, the licensee performed a PWHT on these main steam welds with a base metal thickness of 1.35 inches. Specifically, for FW-6, heat treatment records HTR-3081-A-10 and HTR-3081-B-1 documented that a PWHT had been applied l

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to the field weld FW-6. Performance of a PWHT on two main steam piping welds that was not prescribed by the weld procedure is a violation of 10 CFR 50 Appendix B, Criterion V (50-301/98005-03(DRS)).

Although the licensee had applied a PWHT in accordance with instructions applicable to thicker base materials, the POR supporting WPS GT-SM/1.1-1PB bounded the use of a PWHT. Therefore, the inspector considered the weld procedure and affected welds in conformance with Code requirements.

i c Conclusions l

i The inspector identified two violations of 10 CFR 50, Appendix B, Criterion IX pertaining l to main steam and feedwater welding procedures which did not meet Code heat input ( requirements. Additionally, the inspector identified a violation of 10 CFR 50, Appendix B, Criterion V pertaining to a weld procedure which lacked instructions to

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perform a PWHT that was performed on a main steam piping weld. The inspector concluded that the affected welds did not pose an immediate safety concern due to the extensive margin available to the minimum allowable Code impact strengt M7 Quality Assurance in Maintenance Activities M7.1 SGRP Weld Data Records I

l Insoection Scoce (IP 55050)

The inspector reviewed 14 Weld Data Cards (WDCs), which had been reviewed by the Point Beach SGRP Quality Assurance Audit Team, to evaluate the effectiveness of licensee's audit. The WDCs are considered to be the permanent plant records for the 1996 Unit 2 SGRP by the licensee, Observations and Findinos Of the 14 WDC welds reviewed by inspectors,4 contained inaccurate information as discussed below, Feedwater Nozzle Permanent Plant Records WDC 3042-A-2 and WDC 3042-B-2 documented the feedwater nozzle extension welds on SG A and B respectively. Poth WDC's listed a weld procedure, WPS GTM3.3-1, that was not used in the actual fat.1 cation of that weld, as stated in MK letter No. M-QM-97-045. As a consequence, licensee quality assurance audit staff erroneously believed this procedure was used for the non-root portion of the weld and performed a quality assurance review on this unused WPS. The failure to maintain accurate permanent plant records for these welds is an example of a violation of 10 CFR 50, Appendix B,

, Criterion XVil (VIO 50-301/98005-04a(DRS)).

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. Main Feedwater Weld FW-7 Permanent Plant Record WDC 3081-B-7 documented the 16-inch feedwater weld FW-7 on the B SG. This WDC recorded the initial "Fitup and Tack" weld as complete on November 28,1996 and the visual inspection of the completed weld on November 30,1996. The inspector observed that the weld procedure in use at that tirne for weld fabrication was WPS GT-SM/1.1-1PB, Revision 4, dated November 28,1996. However, the revision listed on this WDC l was Revision 3. When questioned by the inspector, the licensee provided a table which stated that Revision 4 shou!d have been used. Thus, this WDC listed the incorrect revision of the WPS used for this welding. As a consequence of this inaccuracy, the licensee mistakenly used Revision 3 in validating the Code qualification of the affected WPS and did not identify an unqualified weld. Failure to maintain an accurate permanent plant record for this weld is an example of a violation of 10 CFR 50, Appendix B, Criterion XVil (VIO 50-301/98005-04b(DRS)). Main Steam Weld FW-2 Permanent Plant Record WDC 3081-A-2 for the 30-inch main steam line weld FW-2 on the A SG, recorded the initial preheat to prepare the base metal for welding on November 23 and 24,1996 and the visualinspection of the completed weld on December 7,1996. The inspector observed that weld procedure WPS GT-SM/1.1-1PB, Revision 3 was dated November 23,1996, and Revision 4 was dated November 28,1996. Therefore Revision 3 and/or 4 should have been in effect during weld fabrication. However, the revision of the WPS recorded on this WDC was Revision The inspector questioned the licensee on whether Revision 2,3 or 4 was used for the fabrication of this weld. The licensee provided a table which stated that " Dates imply that Revision 3 was likely in effect during welding. WFMCS's [ Weld Filler Metal Control Slips]

not available to validate which one was used." As a consequence of this inaccuracy, the licensee could not have completed an accurate validation of the Code requirements for the affected weld procedures. Failure to maintain an accurate permanent plant record for this weld is an example of a violation of 10 CFR 50 Appendix B, Criterion XVil (VIO 50-301/98005-04c(DRS)). Conclusions The inspector identified three examples of a violation of 10 CFR 50, Appendix B, Criterion XVil pertaining to errors in documentation of welds made during the Unit 2 SGRP. These errors in documentation hampered licensee and inspector efforts to verify that the ASME Code requirements had been met for the affected weld M7.2 Weldina Quality Assurance Audits Insoection Scoce (IP 40500)

The inspector reviewed: the Point Beach letters dated September 2,1997 and October 16,1997 which responded to the August 5,1997 NRC letter requesting that the

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licensee evaluato SGRP weld procedures and describe to what extent the procedures failed to meet the ASME Code requirement The inspector also reviewed the following documents: the Point Beach Quality Assurance Audit 97-130 of MK, the MK initial and clarified issues of Assessment C-96-022, Weld Data Cards and Daily inspection Reports used to validate conclusions for the Quality Assurance Audi Observations and Findinas Ineffective Weldina Audits The licensee's welding contractor MK completed intemal audits and evaluations and documented the results in letter No M-QM-97-045 dated June 6,1997 and in a weld .

! matrix on August 26,199 I In the June 6,1997 letter, MK stated that all site specific WPS heat input allowables l were at or below that allowed by their associated PQR's. However, as documented in l Section M3.1 above, the MK staff had failed to identify that WPS GT-SM/1.1-1PB, Revision 4, allowed higher heat inputs than the supporting PQR The MK audit weld matrix corne.sted August 26,1997 identified: the welds performed at Point Beach during the SGRP, the corresponding weld procedure used to perform the

, weld, the specific concem applicable to the procedure, and the Code compliance of the l weld. The findings listed in this weld matrix did not identify any deviations from Code requirements for the affected welds and weld procedures. However, as documented in Section M3.1 above, the weld procedure WPS GT-SM/1.1-1PB and WPS GT-SM-BU/1.3-1PB did not meet Cod For the MK audit weld matrix completed August 26,1997, the inspectors identified that a large bore main feedwater weld (FW 10) had not been included in the matrix of welds l evaluated. Other inaccuracies in this weld matrix included references to weld procedures not used for the welds listed and incorrect information pertaining to the ,

application of a PWHT on main steam and feedwater line i The licensee performed a Quality Assurance Audit 97-130 of MK to address the concerns pertaining to welding procedures used on the SGRP which were identified in the NRC letter dated August 5,1997. This audit did not identify that welding procedures ;

used during the SGRP did not meet the ASME Code requirements and did not identify !

the inaccuracies in the documentation provided in the we! ding contractor audits and evaluation Weak Basis For Operability in Condition Reoorts (CR) 98-0339 and CR 97-2493 The licensee issued CR 98-0339 to document and disposition the integrity of SGRP ,

. welds considered by the licensee to be unqualified due to the use of an unqualified weld

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procedure. In this CR, the licensee stated that " Review of the SGT [ Steam Generator

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Team) QC (Quality Control] surveillance showed that the heat inputs for welds that were i not PWHT*d, were within the lower heat input ranges." This statement pertained to eight welds (Section M3.1) fabricated in accordance with WPS GT-SM/1.1-1PB, Revision The inspector identified that this statement was based on only one measured heat input data point. The eight main steam and main feedwater welds were fabricated over a period of several days with multiple shifts of welders. A single measurement provided a weak basis for concluding that the heat input used for these welds remained within the lower heat input limitations of the qualified wel CR 97-2493 documented the licensee's basis for operability of the Unit 2 SGs with respect to the use of unqualified welding procedures on Unit 2 during the SGR Finding 5.2 in the operability determination for this CR stated "A final PWHT was j performed on the feedwater and main steam lines. Therefore this is not considered an j operability issue." However, actual heat treatment records showed thet only two of the j ten welds received a PWHT. Further, the inspector did not consider the use of a PWHT {

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as an adequate technical basis to establish operability. The inspector considered that a more appropriate basis would be the margin available in the Charpy impact Test samples as discussed in Section M3.1. The inspector considered this issue to represent 1 a significant weakness in the licensee's basis for operability of the Unit 2 SG l Conclusions The inspector identified that the welding contractor and licensee audits of welding performed during the Unit 2 SGRP lacked rigor and were ineffective. Specifically, the audits did not identify that welding procedures did not meet the Code requirements and that weld documentation records were inaccurate. Also, the licer'see had established a weak basis for operability of the Unit 2 SGs with respect to the use of non-Code qualified welding procedure !

lil. Enaineerina E8 Miscellaneous Engineering issues l

E (Closed) IFl 50-301/96014-03(DRSk Sensitization of SG 1000 weld and POR validitv The inspector reviewed the licensee's internal action item IR-96-014, regarding recirculation loop piping to SG nozzle weld " sensitization" (precipitation of carbides at the grain boundaries of austenitic stainless steel) of existing weld material caused by the

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deposition of a new weld metal. The inspector also evaluated the July 18,1997 MK Site !

Steam Generating Team letter No. 97-MK-31 which dispositioned the ASME Code compliance of this issue. After review of the validity of the associated POR for this condition, the inspector concluded that all regulatory requirements appear to have been met and this inspection follow up item is considered close l l

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i V. Management Meetings

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X1 Exit Meeting Summary

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The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on March 9,1997. The licensee acknowledged the findings l

presented and did not identify any of the potential report input as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED  !

Wisconsin Electric G. Boldt, Special Assistant to Site Vice President K. Crowley, Senior Engineering, SGRP Welding F. Flentje, Regulation & Compliance Specialist D. Johnson, Manager, SGRP Regulatory Services & Licensing J. Knorr, Manager, Regulation & Compliance T. Mielke, Senior Engineer, SGRP J. Polacek, Senior Engineer, Quality Assurance, SGRP M. Reddemann, Plant Manager, PBNP J. Thorgersen, Senior Project Eng - Quality Verification j Duke Engineering S. Forsha, Welding Engineer NB_G F. Brown, Senior Resident Inspector, DRP l

INSPECTION PROCEDURES USED IP 40500: Effectiveness of License Controls in Identifying, Resolving and Preventing Problems IP 50001: Steam Generator Replacement inspection IP 55050: Weld Inspection of Nuclear Welds ITEMS OPENED, CLOSED, AND DISCUSSED

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50-301/98005-01(DRS) ViO WPS GT-SM/1.1-1PB, Revision 4, incorrect heat input 50-301/98005-02(DRS) VIO WPS GT-SM-BU/1.3-1PB, incorrect heat input 50-301/98005-03(DRS) VIO WPS GT-SM/1.1-1PB, Revision 4, PWHT not specified l

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50-301/98005-04a(DRS) VIO Failure to maintain accurate permanent plant records '

50-301/98005-04b(DRS) VIO Failure to maintain accurate permanent plant records 50-301/98005-04c(DRS) VIO Failure to maintain accurate permanent plant records i

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, 50-301/96014-03(DRS) IFl Sensitization of steam generator to recirc loop weld l

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PARTIAL LIST OF DOCUMENTS REVIEWED

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Weld Procedure Specifications (WPS)

• WPS GT-SM/1.1-1PB, Revisions 3 and 4, main steam, feedwater and small bore welds on the Unit 2 steam generator *WPS FC/3.3-1PB, Revision 0, girth welds on the Unit 2 steam generators

• WPS GTM/3.3-1PB, Revision 0, Point Beach audit and weld data cards indicated that this procedure was used to perform the non-root portion of the feedwater nozzle extension welds on the Unit 2 SG *WPS GT-SM/3.3-2PB, Revisions 1 and 2, used to perform the girth welds and feedwater extension welds on the Unit 2 SG .WPS GT-SM/1.3-1PB, Revision 2, used to perform the nozzle-to-pipe welds for the Main Steam and Main Feedwater connections on the Unit 2 steam generator *WPS GT-SM-BU/1.3-1PB, Revision 1, originally used to butter the Feedwater nozzle extension welds on the Unit 2 steam generator . Procedure Qualification Records (POR)

• PQR GT-SM/1.1-Q1, Revision 0, (supporting WPS GT-SM/1.1-1PB).

PQR GT-SM/1.1-Q2, Revision 0, (supporting WPS GT-SM/1.1-1PB).

POR GT-SM/1.1-Q4, Revision 1, (supporting WPS GT-SM/1.1-1PB).

PQR GT-SM/1.1-Q5, Revision 0, (supporting WPS GT-SM/1.1-1PB).

• PQR FC/3.3-Q1, Revision 1 (supporting WPS FC/3.3-1PB).

PQR GTM/3.3-Q1, Revision 0, (supporting WPS GTM/3.3-1PB).

PQR GT-SM/3.3-Q2, Revision 0, (supporting WPS GT-SM/3.3PB).

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POR GT-SM/1.3 Q1, Revision 0, (supporting WPS GT-SM/1.3-1PB).

POR GT-SM-BU/1.3-Q1, Revision 1 (supporting WPS GT-SM-BU/1.3PB).

PQR GT-SM-BU/1.3-Q1, Revision 0, (supporting WPS GT-SM-BU/1.3-1 PBNP).

Morrison Knudsen Corporation Documents

.MK Letter No. L-QM-97-017 from A. Walcutt (Morrison Knudsen Corporation) to D. Johnson (Wisconsin Electric) dated May 5,1997, which provided additional qualification information related to POR GT-SM/3.3-Q2.

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.MK Inter-office Correspondence No. M-QM-97-045, from A. Walcutt (MK) to Distribution dated June 6,1997, which provided qualification information related to MK PQR GT-3.3-Q2, Point Beach Site Specific WPSs: GT-SM/3.-2PB, GT-SM/1.3-1PB, GT-SM/1.3-Q1, GTM/3.3-iPB, GT-SM-BU1.3-1PB, GT-SM/1.1-1PB and POR GTHW/3.3-Q +Morrison Knudsen Corporation Quality Finding Report C-96-022, dated January 15,199 SGT Letter No. 97-MK-31 (Morrison Knudsen Corporation Site Steam Generating Team) to D.

. Johnson (Wisconsin Electric) dated July 18,1997, which provided additional information

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Wisconsin Electric (PBNP) Documents PBNP Inter-office Correspondence, Letter No. NPM 97-0877, PBNP Audit No.97-130, PBNP Audit of Morrison Knudsen SGRP Welds, dated October 15,199 PBNP Condition Report No. CR 97-2493 dated August 13,1997, PBNP Work Package 3081-A Change No. O, Figures 9 & 10, Schematic SGRP Weld Point Beach letter to the NRC " Response to Request for Information Point Beach Nuclear Power Plant" dated September 2,1997, Point Beach letter to the NRC " Supplemental Response to Request for information Point Beach Nuclear Power Plant" dated October 16,1997, PBNP Intemal Action item No. IR 96-014 dated March 5,1997 regarding the sensitization of existing weld materialin the RCS piping.,

PBNP Condition Report No. CR 96-1462 dated November 20,1996 PBNP Nonconformance Report No. NCR 159 and supporting documentation dated December l

4,1996, PBNP weld data cards for the SGRP the feedwater extension weld and SGRP field welds FW-1, 2, 3, 4, 6, 7, 8 and 1 ,

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PBNP Condition Report No. CR 97-0230 dated October 9,1997 PBNP Condition Report No. CR 98-0339 dated January 29,1998 PBNP Condition Report No. CR 98-0149 dated January 15,1998 Point Beach Unit 2 Steam Generator Replacement Report, Revision 1, September 17,1996 Point Beach Unit 2 Replacement Steam Generator Modification, Design Package MR-95-058*0, Revision 1 dated February 6,1997 Point Beach Quality Assurance Surveillance Report No. S-P-%-07, dated February 7,1997 LIST OF ACRONYMS USED ASME American Society of Mechanical Engineers CFR Code of Federal Regulations ,

CR Condition Report j GTAW Gas Tungsten Arc Welding IFl Inspection Follow up Item IP Inspection Procedure kJ/in kilo-Joule per inch MK Morrison Knudsen Corporation NRC Nuclear Regulatory Commission  ;

PBNP Point Beach Nuclear Plant POR Procedure Qualification Records j PWHT Post Weld Heat Treatment

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SGRP Steam Generator Replacement Project SG Steam Generator ,

SMAW Shielded Metal Arc Welding VIO Violation WDC Weld Data Cards WFMCS Weld Filler Metal Control Slip WPS Weld Procedure Specification

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