ML17333B050

Responds to NRC 970805 Ltr on Allegations Re 1988 SG Replacement Welding Project.Review of Applicable Codes Used During Unit 2 SG Replacement Refutes Allegations & No Corrective Actions Are Necessary

ML17333B050
Person / Time
Site:	Cook
Issue date:	09/18/1997
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
AEP:NRC:1273, NUDOCS 9710010324
Download: ML17333B050 (7)

Text

CATEGORY 1 REGULATOR INFORMATION DISTRIBUTION STEM (RIDS)

ACCESSION NBR:9710010324 DOC.DATE: 97/09/18 NOTARIZED: NO DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 5e-316.Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH. NAME AUTHOR AFFILIATION FITZPATRICK,E. Indiana Michigan power Co. (formerly Indiana a Michigan Ele RECIP.NAME RECIPIENT AFFILIATION GROBE,J.A. Region 3 (Post 820201)

SUBJECT:

Responds to NRC 970805 re notice of allegation re 1988 SG replacement welding project. Review of applicable codes used during Unit 2 SG replacement refutes allegations & no corrective actions're necessary.

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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response E NOTES:

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ID CODE/NAME LTTR ENCL CODE/NAME PD3-3 PD 1 1 HICKMANiJ 1 1 R

INTERNAL:. AEOD/SPD/RAB 1 1 AEON%~ 1 1 DEDRO 1 1 ILE CENTER 1 1 NRR/DISP/PIPB 1 1 R DRC HHFB 1 1 NRR/DRPM/PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1 RGN3 FILE 01 1 1 EXTERNAL: LITCO BRYCEiJ H 1 1 NOAC 1 1 D

NRC PDR 1 1 NUDOCS FULLTEXT 1 1 0

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September 18, 1997 AEP: NRC: 1273 Mr. J. A. Grobe U. S. Nuclear Regulatory Commission Region III 801,Warrenville Road Lisle, IL 60532-4351

Dear Mr. Grobe:

Donald C. Cook Nuclear Plant Units 1 and 2 RESPONSE TO NOTICE OF ALLEGATION 1988 STEAM GENERATOR REPLACEMENT PROJECT WELDING This is in response to your letter dated August 5, 1997, that forwarded a notice of an allegation regarding welding activities at Cook Nuclear Plant during the unit 2 steam generator replacement outage in 1988.

The attachment to this letter details our review and disposition of the allegations. The attachment contains no personal, private, proprietary, or safeguards information, and can be released to the public and placed in the NRC public document room.

Sincerely, E. E. Fitzpatrick Vice President vlb Attachment A. A. Blind A. B. Beach MDEQ - DW 6c RPD NRC Resident Inspector J. R. Padgett 97i00i0324 9709i8 llllllllllllllllllllllflllllllllllllllll PDR ADQCK 050003i5 8 PDR

ATTACHMENT TO AEP:NRC: 1273 RESPONSE TO NOTICE OF ALLEGATIONS 1988 STEAM GENERATOR REPLACEMENT PROJECT WELDING

Attachment to AEP:NRC:1273 Page 1 The investigation discussed below was prepared by'he current performance assurance, plant and supplier performance group manager and the current site cognizant engineer -, welding. To ensure independence, neither of these two personnel were involved in the unit 2 steam generator replacement (SGR) project. The cognizant engineer - welding was not an employee of any company within the American Electric Power System in 1988 at the time of the unit 2 SGR.

did experience difficulty with some welds during the SGR that were resolved with a NRC Region IZZ representative. project We We were not aware of later allegations regarding the potential quality assurance problems with the welds since completion of the unit 2 SGR prior to receipt of your letter. After receiving your letter, we contacted Morrison-Knudsen and Ferguson, hereinafter referred to as MKF, and determined that there had been some on-going internal communication regarding the welding procedures used at Cook Nuclear Plant during the unit 2 SGR. After reviewing the MKF documents, we conducted our own independent investigation of our records regarding the allegations you presented.

'he NRC correspondence requests that we evaluate an allegation that the welding procedures used on the unit 2 SGR were not in compliance with regulations at the time of construction.

Furthermore, it was concluded in the allegation that these non-compliant welding procedures raise safety concerns regarding our SGR in 1988.

In 1988, MKF was awarded the contract to perform services related to the welding activities for the unit 2 SGR. Several MKF welding procedures were used, including the welding procedures to join the main feedwater and main steam systems to each steam generator.

The allegation suggests the welding procedure specifications (WPS) and the qualifying procedure qualification records (PQR) were not appropriate for the service intended. This was apparently based on the assumption that, the WPS that was used specified a welding material of a specific ASME Section II American Welding Society (AWS) classification different from that actually used in the PQR test for the WPS.

Znveeti ation The table below summarizes the variables in question from MKF's WPSs and PQRs used for the unit 2 SGR main steam and feedwater connections. The table also references the associated ASME Section ZX paragraphs.

The PQRs in question were qualified with a weld filler material, AWS classification (E7018A1, SFA-5.5), that is different from that specified in the WPSs (E7018, SFA-5.1). ASME Section IX, 1986 Edition, "Welding and Brazing Qualification", states in table for the shielded metal-arc welding (SMAW) process that a change QW-'53 in the AWS classification is a supplementary essential variable.

Zt appears to us that the allegation is founded in the presumption that we used ASME Section IIZ for our construction code where impact properties are mandatory. Under ASME Section IZZ, a change in the weld material classification, an essential variable, would indeed have constituted a change in the welding procedure

Attachment to AEP:NRC:1273 Page 2 specification, or a requalification of a procedure qualification test.

However, the unit ASME 2 SGR Section III was not the construction code used for welding of the main feedwater and main steam piping systems. The welds for both the main steam and feedwater piping systems were made at pipe to elbow (main steam) and pipe to reducer (main feedwater) joints for each steam generator. The forged nozzle to elbow welds were left intact, and no welding was performed on the vessel for these connections. The original construction code for piping welds is ANSI B31.1, 1967 Edition, and we maintained the ANSI B31.1 code requirements during the steam generator replacement for the applicable pipe to pipe and pipe to fitting welds.

Our engineering specification, DCC-AE-100-QCN, was used to procure materials and services for the unit 2 SGR, and was used by MKF during the replacement. DCC-AE-100-QCN references DCC-PV-109-QCN, revision 3, "Installation and Erection of Nuclear Piping Systems for the Cook Nuclear Plant", that specifically takes exception to impact properties for piping welds for the unit 2 SGR.

therefore, concluded that the welding for these piping welds need It is, only meet the requirements of ASME Section IX, and ANSI B31.1.

Because the AWS classification is not an essential variable for welding applications where impact property performance is not required, we find both the WPSs and PQRs acceptable, and in compliance with the governing codes as they were applied during

. the SGR.

Summary WPS and PQR Data for Unit 2 SGR Piller MKP Piller Piller UTS+

Metal PQR¹ Metal Metal (PSI)

Class- SMAW Classi- AWS ification Only fication No. On On WPS On PQR PQR M-1-1-AB SFA-5.1 1" 117 SFA-5.5 E-7018 A1 67900 or (E-7018)

M-1-1"BA M-1-1-AB SFA-5.1 1-124 SFA-5.5 E-7018 A1 78100 or (E-7018)

M-1-1-BA ASME QW-404 QW-2253 QW-404.12 65000 Section IX 1986 Ed.

• U timate tensile strengt reporte on PQR.

Conclusion Our review of the applicable codes used during the unit 2 SGR refutes the allegations as stated in your letter dated August 5, 1997. We are confident that the WPSs used were relevant and met quality assurance standards and ASME code requirements.

There is no 10 CFR Part 21 issue, nor are any corrective actions necessary.