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Insp Rept 50-482/97-13 on 970624-27 & 0708.No Violations Noted.Major Areas Inspected:Followup on licensee-identified Welding Work Control Issues by Observation of Welding & Welding Matl Control Activities
	ML20141J956
Person / Time
Site:	Wolf Creek
Issue date:	08/17/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20141J953	List: ML20141J948; ML20141J956;
References
	50-482-97-13, NUDOCS 9708210435
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EfLQ_1.OSURE

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-482

1.19ense No,: it?F 42

Hoport No.: 50 4812,97 13

Licentce; W'alf Creek Nuclear Operatine Corporation-

Facility: Wolf-Creek Generating S.ation

Location: 1550 Oxen Lane, NE

Burlington, Kansas '

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Detew: June 24 27, with in-office inspection continuing until July 8,1997-

Inspector: Lawrence E. Ellershaw, Reactor inspector, Maintenance Branch

Approved By: Dr. Dale A. Powers, Chief, Maintenance Branch

I '- !/ision of Reactor Safety

ATTACHMENT: Supplemental information

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9708210435 470317

PDR ADOCK 05000482

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EXECUTIVE SUMMARY

Wolf Creek Generating Station

NRC Inspection Report 50-482/97-13

This inspection consiste of a followup on licensee identified welding work control issues

by observation of welding and welding material control activities, and review of corre tive i

actions for adequacy and completeness.

Maintenanen

Licensee personnel identified an apparent falsification of a field welding material

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requisition form (Section MB.1).

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Licensee personnel identified four examples of undocumented and unauthorized

work performed by the mechanical maintenance organization (Section M8.1.b).

Licensee personnel identified a lack of control over welding materials

(Section M8.1.b).

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The licensee's actions in response to each of the welding work control failures were

appropriate (Section M8.1.b).

The licensee implemented a thorough training plan to assure that the identified

welding work control f ailures would not recur (Section M8.1.b).

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REPORT DETAlLE

- Eymmarv of Plant Status

The plant operated at 100 percent power throughout the inspection period.

11. Maintenance !

M8 Miscellaneous Maintenance issues

M8.1 Followuo on Weldina lesues (55050)

During December 1996, the licensee terminated a mechanical maintenance welder 4

for apparently falsifying a field welding material requisition slip. On December 13,

,_ 1996, licensee personnel Initiated Performance improvement Request 96 3277 to

[ document, evaluate, and implement corrective actions to minimize the potential for

recurrence. Licensee personnel also notified the NRC of the incident.

-The licensee's investigation determined that uron completion of his assigned work, >

the welder attempted to return unused weld filler material to the weld rod room

attendant. The welder, however, had apparently lost his copy of the field welding

material requisition slip. He obtained and completed a new weld filler material

requisition form, and apparontly signed the welding engineer's name to the approval

block on the form, He then used the falsified requisition form to return the unused

weld filler material to the weld rod room attendant. The attendant noted that the

welding engineer's approval signature was different from the way it was normally

signed. The attendant contacted a welding engineering department supervisor, who

took the slip to the welding engineer who had purportedly signed it.- The welding

engineer determined that the signature was not his. Subsequently, the welder's

ernployment at the Wolf Creek Generating Station was terminated.

The inspector noted during review of Section 4.2 in Procedure FMC 1, " Filler

Material Control," Revision 6, that the welding engineer is responsible for verifying

that the welder is qualified to weld to the welding procedure specification listed on

- the field welding material requisition and the applicable weld data sheet prior to

authorizing issuance of weld filler material. Section 5.5 states that a welder shall

return unused weld filler materials, containers, and the welder's copy of the field

- welding material requisition form to the point of issue.

This licensee-identified issue of an apparently falsified field welding material

requisition form, and the welder's failure to return his copy of the requisition to the

point of issue, is an unresolved item pending further NRC review (50-482/9713-01).

As part of the Performance impronment Request 96 3277 evaluation, a review of

field welding material requisition slip's for the previous 2 years was undertaken to

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determine if other improprieties had occurred. The reviewers de' ermined that this l

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was an isolated case, and that there was no evidence to suggest that the welding

l material control program was not effective. Thus, Performance improvement

Request 96 3277 was closed on January 2,1997, i

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However, during the licensee's investigation, additional welding program / work

control concerns were identified, including:

Failure to control welding filler material

Performance of unauthorized and undocumented work activities

Conduct of non licensee work in the mechanical maintenance welding shop

These concerns prompted the licensea to initiate a self assessment effort to further

evaluate the adequacy of the implementation of the welding program and associated

work activities. A self assessment team was created and on January 28,1997,

Self Assessment Plan SEL 97-003, " Welding and Associated Work Controls," was

approved for their activities. On February 13,1997, during the self assessment

team interviews with welding personnel, it was learned that unauthorized and

undocumented work had been performed on safety related equipment (i.e., weld

repair to a normal charging pump room pipe support base plate, and grinding of

vendor supplied welds on essential service water piping). The self assessment team

identified a total of eight issues of concern.

At that time, the plant manager instituted an iremediate stop of alllicensee

employee welding activities. Additionally, alllicensee issued welder

certifications were revoked. This included licensee employed welders and

contractor welders. Based on the new information, the licensee formed incident

Investigation Team 97-01 to investigate the welding issues developed by the self-

assessment team. The incident investigation team was chartered to investigate,

determine the root cause, and recommend corrective actions. During the incident

investigation team's effort, an additional three issues of concern were identified.

Therefore, the licensee's investigative efforts developed a total of 11 issues of

concern from all sources. The licensee initiated performance improvement requests

to investigate and evaluate all of the identified issues for technical and safety

concerns. The licensee's investigation and evaluation effort determined that there

was some degree of validity for 8 of the 11 issues of concern,

a. insocction Scone

The scope of this inspection was to evaluate each of the issues of concern to

assure that technical or safety concerns did not exist, and to determine whether

licensee corrective actions were comprehensive and appropriate.

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Further, tne inspector reviewed the following procedures:

AP 29F 002, " Control of Welding Operations," Revision 2

CWD 1, " Control of Welding Documentation," Revision 6

AP 16C-002, " Work Controls," Revision 5

AP 15C-002, " Procedure Use And Adherence," Revision 8

AP 16-001, " Control of Maintenance," Revision 1

, The inspector also reviewed all of the applicable performance improvement requests

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l In addition, the inspector observed shielded metal arc welding. The welding l

l was performad on the third stage extraction to heater piping (Group PSA

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material, Line AC-005 GAD 16) that was being fabricated under Work

Package WPT 118876 1. The alloy piping was being fabricated to replace

carbon steel piping that had been degraded by flow accelerated erosion.

Tha inspector also observed and evaluated welding filler material control (i.e.,

storage, identification, issuance, welder's control, and return to storage).

b. Observations and Findinns

Each of the licensee validated eight issues of concern documented in the

performance improvement requests is discussed below. The inspector determined

that the licensee's actions in followup to these issues of concern were appropriate.

b.1 Performance Imorovement Reauest 97-0453: Initiated on February 13,1997, to

address a welding issue in which a welder may have performed a weld fitup and

seat weld while water was weeping from a valve's weld joint. This activity was

scheduled to have been performed on March 23,1996, during Refueling Outage

Vill.

During the licensee's investigation of this matter, no definitive substantiation could

be reached. However, the licensee investigators were able to determine that the

weld had not been made under the described conditions that resulted in the

initiation of the performance improvement request. Documentation existed which

showed that a task had been developed to disassemble the valve, evacuate the

water, and clean it to f acilitate making the seal weld, and records showed that the

seal weld was made on March 24,1996, and was accepted by a quality control

inspector.

Subsequent to completion of the weld, the valve was tested and it was found that

the valve would not seat. The valve was cut out of the line and replaced with a

new valve that was tested and accepted.

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b.2 Performance Imorovement Reouest 97-0454: Initiated on February 13,1997, to

address an issue where a nonsafety related conduit support in the turbine building

had been shortened with a band saw without appropriate work authorization. This

activity occurred during October 1995.

The support had been shortened to facilitate freeing a suspended rigging load that

had become hung up on the support. The workers considered this to be a

personnel safety threat and they acted on their own initiative to eliminate the threat.

Later, the workers notified their supervisor. The supervisor requested that the

j support be inspected and evaluated against the design specification. It was

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determined that !be support was acceptable and met design specification criteria.

Neither the workers nor the supervisor initiated a performance improvement request.

While this work was nonsafety related, it was an example of personnel working

outside the scope of their authorized work activity,

b.3 Performance Imnrovement Reauest 97-0469: Initiated on February 13,1997, to

address vendor installed welds that had been altered (ground) without authorization

or documentation. These welds were on a safety related essential service water

J system elbow on the Train A component cooling water room cooler, it was

identified that a welder had been instructed to grind the weld crowns to avoid

interference with an existing box support. This incident occurred on March 28,

1996, during Refueling Outage Vill.

The interference resulted from implementing a design change package. The

package required the f abrication of a new spool piece, removal of the existing pipe,

and installation of the new pipe spool piece. The large weld crowns created an

interference (i.e., the pipe would not pass through the support) with the box

support.

Licensee personnel, upon learning of this issue, immediately initiated actions to

identify the specific welds that had been altered. The shift supervisor declared

Train A of the component cooling water system inoperable and entered the 72-hour

limiting condition for operation. Licensee personnel located and identified the

specific wolds, and performed magnetic particle and ultrasonic examinations on

them. The examined welds were accepted (there were no surface indications and

the design-specified minimum wall thicknesses had not been violated). The limiting

condition for operation was exited and the Train A component cooling water system

was declared operable,

Section 5.7 in Procedere AP 16C-002, states,in part, that work group supervisors

are responsible for:

Ensuring the shop / field work is performed in accordance with the

requirements of the work package task and applicable procedures.

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Section 5.9 states, in part, that workers are responsible for:

Ensuring the work is performed in accordance with the requirements of the

work package task and applicable procedures.

Notifying the supervisor if work cannot be performed in accordance with the

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which change the scope of the work to be performed.

Documenting in the work completion / history sections c the task package:

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i Summary of work performed (as found condition, corrective action, as left

j condition, parts used, man-hours, etc.).

The licensee's investigation revealed that there was no documentation showing that

grinding of the welds was authorized or performed.

This issue of unauthorized and undocumented work is an .nr tolved item pending

further NRC review (50 482/9713-02).

b.4 Performance Imorovement Reauest 97-0470: Initiated on February 13,1997,to

address an anauthorized base metal weld repair (plug weld). The repair had been

made on a safety related normal charging pump pipe support baseplate. The

support was identified as one of six within the normal charging pump suction and

discharge isolation boundaries.

Licensee personnel determined that an unauthorized and undocumented plug weld

had been performed around August 29,1996, to repair a mis-drilled baseplate hole.

The hole had been drilled during a modification to the normal charging pump.

Licensee personnel learned that a welder had made a series of mistakes with the

support baseplate, and that he performed weld repairs to the baseplate without

revising or creating new documentation to reflect the weld repair.

Licensee personnel remcved paint and examined each of the six support baseplates

within the normal charging pump suction and discharge isolation boundaries using

an acid etch. They identified weld filler material on one of the support baseplates

(BG01-H012/112(Q)) located on the discharge side of the pump. Examination of

the repair showed that it was structurally sound and exhibited good workmanship.

On March 14,1997, design engineering provided a "use-as-is" disposition for the

unauthorized and undocumented condition.

This issue of unauthorized and undocumented work is a secor.d example of an

unresol'ed item pending further NRC review (50-482/9713-02).

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b.5 brformance Imorovement Reauest 97-0481: Initiated on February 14,1997, to

address the concern that field welding material requisitions had been pre signed by I

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During the licensee investigators' interviews, it was learned that a welding

supervisor may have improperly pre-signed approximately 10 field welding material

requisitions for use on a day that the supervisor was not going to be at work. The

j pre signing was apparently done to facilitate welding activities scheduled to be

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performed on nonsafety related chiller equipment.

Licensee personnel investigated this issue and identified 5 field welding material

requisitions, dated May 28,1996, that were signed by the welding supervisor,

f They appeared to have been dated by the lead welder (determined by apparent

differences in handwriting and date writing style). Licenseo security records

showed that the welding supervisor passed through security at 6:05 a.m. on

May 28,1996. This was just 3 minutes before the first apparently presigned

requisition was used.

The licensee's investigation established that the welding supervisor denied signing

blank field welding material requisitions. The licensee's investigation confirmed that

the supervisor and lead welder were both at work on the date of the subject work

performance, and the style of the written date on the five requisition forms was

different from that normally used by the supervisor.

Licenseo personnel evaluated the five field welding material requisitions and verified

that the specified welding material was appropriate for the job description annotated

on each requisition. No adverse conditions to plant systems or components were

ic'intified. Additional ly, licensee personnel found no similar anomalies with respect

to field welding material requisitions.

Procedure FMC 1, Section 5.4.1, Revision 6, states that the welding engineer (or

authorized designee) shall authorire the issue of filler material only to qualified

welders, by approving the field welding material requisition form. While the

procedure does not specifically prohibit pre signing a requisition form, signing a

blank requisition form would not provide the level of control intended by the

procedure. Such advance signing would preclude assuring that appropriate filler

material would be issued only to a qualified welder for a specified job,

b.6 brformance Imorovement Reouest 97 0481: Initiated on February 14,1997, to

address unauthorized and undocumented work (cutting, moving, and rewelding a

welded beam attachment) during modification to the nonsafety related auxiliary

boiler system piping.

During the initial self assessment team interviews, licensee personnel learned that a

welder had cut, moved, and rewelded a welded beam attachment. The welded

beam attachment was identified as being part of a pipe support for a 2-inch drain

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line on the auxiliary boiler. The incident Investigation Team conducted a field

verification and confirmed that the welded beam attachrr.ent had been cut, moved,

and rewelded. The licensee's engineering organization performed an evaluation and

determined that the new welds and location of the attachment were within design

limits and were subsequently dispositioned acceptable.

While this work was nonsafety related, it was another example of personnel

working outside the scope of their authorized work activity.

h.7 Performance Improvement Renuest 97 0652: Initiated on February 28,1997, to

, address the discovery of unattended weld filler material found in the weld shop

area.

The licensee's investigation determined that the material may have besn

inadvertently left on a welder's work table upon completion of a welding job in

which the same weld filler material had been used. The welder's stub bucket,

containing used weld rod, had been returned to the weld materialissue room. It

appeared however, that two pieces of ER 309L weld rod did not get placed in the

stub bucket.

Licensee personnel conducted a search on the next day of the weld shop area. The

search located several pieces of filler material, most of which were minor pieces,

some of which had been fashioned into various simple tools or shop aids (i.e.,

hooks, spacers, etc.). Licensee personnel considered this to be insignificant even

though it was characterized as improper use of weld filler material. Additional

information traelved by the welding supervisor prompted a more thorough search on

March 3,1997. This search located 3 pieces of stainless weld rod and 10 pieces of

E7018 covered electrodes.

Section 4.4 in Procedure FMC-1 states that the welder is responsible for controlling

the materials issued, and for returning unused materials, containers, and the field

welding material requisition form to the point of issue. Section 5.4.11 states that

filler material stubs and damaged filler material shall be placed in stub buckets by

the welder. The stub buckets shall be returned daily to the rod room where the

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filler material was issued. Any coated electrodes that the welder removes from

portable rod warmers or exposes to the atmosphere in excess of the maximum

allowed times shall be returned in the stub bucket and scrapped.

This issue of not returning weld filler material upon completion of the welding

activity is an unresolved item pending further NRC review (50-482/9713-03),

b.8 Performance Imorovement Reauest 97 0739: Initiated on March 7,1997, to

address the identification of an undocuenented weld repair (plug welds) to a

nonsafety related plate of the stator water cooling system that had been mis-orilled.

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This occurred during a modification (Design Change Package 07091) to the stator

water cooling system, in which a 16-inch x 16 inch x 3/8-inch plate _was required to

be drilled for attachment to an existing support. _ The plate was used for supporting

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a pressure regulator and - flow meter.- Apparently during fabrication in the weld

shop, the holes were incorrectly drilled.

Licensee personnel confirmed that two plue welds had been made in the plate

without proper authorization and documentation. Tne licensee's engineering

organization evaluated the plate and determined that the stator water cooling

system was operable, but the' plate should be replaced at a later date to be

scheduled by the integrated Planning and Scheduling group.

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While this work was nonsafety-related, it was another example of personnel

working outside the scope of their authorized work activity,

b.9 Licensee Identified Root Causes

Licensee personnel used change and STORM (Stimulus Team Operation Response

and Management) analyses as the_ major techniques to identify the root cause and

contributing causes of the welding problems. These analyses, and the corrective

actions, were addressed in Performance Improvement Request 97-0481. The

licensee also used a consultant from Performance improvement International to-

assist in developing the causes using the Performance improvement International

process.

l Briefly, the contributing causes were identified as follows:

Ineffective changing work scope management, (i.e., there had been an

elimination of contractor welding personnel during 1995, without providing ;

appropriate training to licensee welders who were now tasked to perform

work previousiv performed by contractors)-

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Pressures brought on by greatly emphasized adherence to schedule that

caused workers to take short cuts

Less than adequate communications _and reporting of problems within the

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mechanical maintenance organization

Work processes were determined to be burdensome and cumbersome

- Supervision of maintenance welding field activities was less than adequate

The root cause was determined to be a willingness on the part of the welding

personnel to perform work outside the scope of the work control process. The

reasons for this attitude were not conclusively established; however, less than

adequate supervision was considered a key element.

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I b.10 Corrective Actions '

Besides making immediate evaluations for each of the identified failures, licensee

personnel reviewed all performance improvement requests for the preceding

2 years. Additionally, they evaluated quality engineering audits, surveillances, plant

evaluations, and self assessments, and determined that these conditions (i.e.,

performance of unauthorized and undocumented work, and a failure to follow

established program / procedure requirements), were limited to the mechanical

maintenance organization.

Licensee personnel also performed a sample inspection of safety and nonsafety-

related equipment that the welding group had worked on between January 1995

and February 1997. A plant walk down was conducted on March 18,1997, during

which a sample of 110 work package tasks (i.e., component installation or

modifications) performed by welding personnel were inspected and compared with

the actual documentation packages. The walkdown teams found no evidence of -

undocumented or unauthorized work activities.

The licensee established three action items specifically related to the welding / work

control failures. Action item 1 pertained to disciplinary action and was not

reviewed by the inspector. Action item 2 pertained to whether proper training had

been provided to the mechanical maintenance organization for installation and

modification work that had previously been performed by contractor personnel.

Action item 3 pertained to the work philosophy and dealt with reinforcement of

management expectations regarding procedural complia. ice, problem identification

and solving, quality and production performance of day-to-day work activities,

communications regarding problems or concerns, and safety priorities.

Action items 2 and 3 were addressed by the establishment of a weld recovery plan.

The plan was a comprehensive training program designed to assure that all i

personnel associated with welding activities (contractor and licensee) received

appropriate technical and general work-related training. This included welding

engineers, planners, fitters, firewatch personnel, and welders. With the exception

of welder qualifications, most of the training was designed to be follow-on or

enhancement to existing training. Nearly all of the scheduled training had been

completed by the end of the onsite portion of this inspection.

In addition, field welding oversight was being performed on a daily basis and was

intended to be continued through Refueling Outage IX (near the end of 1997).

This was being accomplished with the use of a comprehensive document called a

" Welding Oversight Checklist," Revision 1. Further, a self assessment of the weld

program was scheduled to be performed and completed by November 8,1997, with

a report issued by November 15,1997.

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Additional actions were established under Performence improvement

Requests 97-1385, -1386, -1387, and -1388. Each of these dealt with evaluation

- and possible improvement to programs / processes; work control process; welding

engineering dispositions; process indicators and problem reporting reinforcement;

and work schedule process. Performance Improvement Request 97-1388, " Work

Scheduling Process," was completed on June 10,1997; however, the other three

were not scheduled for completion untillater during 1997 and 1998.

b.11 Observation of Weldino and Tour of Storaae Area

The inspector observed shielded metal arc welding performed by two licensee

welders, both of whom were documented in the current welder qualification log as

qualified to perform the shielded metal arc welding process. The welding was

performed on chrome-molybdenum alloy replacement piping for third-stage

extraction to Heaters 7A and 78 piping under Work Package WPT 118876-1. The

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package designated use of Welding Procedure Specification 1-0105T02, Revision 0, i

The inspector verified that the welders used the welding procedure specification and

that electrical characteristics, preheat maintenance, and travel speed were complied

with. The inspector also verified that each welder had a copy of the field welding

, material requisition slips for the issued welding material. The inspector also noted

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that the E901883 welding electrodes were properly maintained in a portable,

heated, caddy.

The inspector also toured the welding material storage and issue room. All holding

ovens were appropriately identified and maintained at the proper temperature range.

The inspector verified that the weld rods inside each oven corresponded to the weld

rod identification noted on the ovens. The tool room attendants had current copies '

of the filler material control procedure, a list of qualified welders, and the authorized

signature list, which identified those personnel who could authorize the issuance of

welding material. The inspector also verified that the field welding material

requisition slips were properly completed, and that those associated with the two

welders previously observed, matched those in the welders' possession.

c. Conclusions

The licensee had taken the appropriate steps to reconcile and correct the identified

welding work control failures.

Observation of in-process welding and the control of welding materials revealed that

the observed personnel were properly performing their assigned work activities (i.e.,

welding was performed by qualified welders in accordance with the welding

procedure specification, and welding material was properly controlled).

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V. Manaaement Meetinas

X1 - Exit Meeting Summary

,The inspector presented the inspection results to members of licensee management

at the_ conclusion of the onsite portion of the inspection on June 27,1997. The

licensee personnel' acknowledged the findings presented.

On July 8 and August'12,1997, supplemental exits were held via telephone with

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Mr. C. Reekie and Ms. C. Redding, respectively. l The purpose of the first followup -

was to inform the licensee of a change to information provided at the onsite exit.

At the onsite exit, two of the findings were characterized as potential violations.

After in office review of additio al information, these items were reclassified as -

unresolved items pending further NRC review. The purpose of the second followup

was to inform the licensee of the identification of a third unresolved item pending

further NRC review.

The inspector asked the licensee personnel whether any materials examined during~

the inspection should be considered proprietary. No proprietary information was--

identified.

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ATTACHMENT

SUPPLEMENTAL INFORMATION

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. PARTIAL LIST OF PERSONS CONTACTED '

Licensee

B. Bergstrom, Supervisor, Maintenance

-- G. Boyer, Chief Administrative _ Officer

. B. Dale, Supervisor,- Maintenance-

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R. Denton, Quality Assurance Specialist

C. Fowler, Manager, Integrated Plant Scheduling

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D. Gillespie, Supervisor, Modifications

l .K. Hughes, Supervisor, Training Development

!- 'J. Johnson,-Superintendent, Security

G. Lawson, Superintendent,- Maintenance Planning

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l - W. Lindsay, Manager, Hot License

R. Miller, Superintendent, Mechanical Maintenance

D. Moore, Manager, Maintenance -

T. Morrill, Assistant to the Vice President, Engineering

W. Norton, Manager, Performance Improvement and Assessments

_ C. Redding, Engineering Specialist, Licensing

C. Reekie, Engineering Specialist, Licensing

R. Sims, Manager, System Engineering

S. Sprague, Maintenance Welding Engineer

J. Weeks, Manager, Emergency Planning

S. Wideman, Engineering Specialist, Licensing

C. Younie, Manager, Operations J

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F. Ringwald, Senior Resident inspector

INSPECTION PROCEDURES USED -

IP 55050. Nuclear Welding GeneralInspection Procedure

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ITEMS OPENED

Qpened

50-482/9713-01 URI welder failed to return copy of field welding

material requisition, and a field welding

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material requisition was apparently falsified

(Section M8.1)

50-482/9713-02, URI unauthorized and undocumented work was

two examples performed (Section M8.1.b.3 and M8.1.b.4)

50-482/9713-03 URI welding material was not returned to the point

of issuance (Section M8.1.b 7)

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DOCUMENTS REVIEWED

Procedurqa

Number Revision Title

FMC-1 6 Filler Material Control

CWD-1 6 Control Of Welding Documentation

AP 29F-002 2 Control Of Welding Operations

AP 16C-002 5 Work Controls

AP 1 BC-002 8 Procedure Use and Adherence

AP 16-001 1 Control of Maintenance

ML20141J956

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