ML20212A855

Provides Addl Detail Resulting from Audits of Records & Activities Performed at Pbnp Site & Home Office of Contracted Svc Supplier.Responses to 970805 Questions & Description of Elements of Evaluation,Encl

ML20212A855
Person / Time
Site:	Point Beach
Issue date:	10/16/1997
From:	Patulski S WISCONSIN ELECTRIC POWER CO.
To:	Grobe J NRC
References
NUDOCS 9710270031
Download: ML20212A855 (8)

Text

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Wisconsin Electnc Ab

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{s m PCWER COMPAW Q{ D i ._ , ,__$dOTT A. PATULSKI Point Beoch Nuclear Piont 661o Nuce A_. Two Revers wi s424i nPMA -

(920) 755-6214 October 16,1997 ,

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Mr. John A. Grobe Acting Director, Division of Reactor Safety U. S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532 1351 l

Dear Mr. Grobe:

EUPPLllMiltiTAldliSPONSE TO IlliQUEST FOR INFQiniATION PQlNT IlEACil NUCl. EAR l'LANT in our letter dated September 2,1997, Wisconsin Electric Power Company responded to an August 5,1997 request from P.egion til for information concerning activities at Point Beach Nuclear Plant. Ilecause we anticipated that certain activities of our evaluation would extend beyond the response date requested by the Nuclear Regulatory Commission, we committed to supplement our September 2,1997 letter as further detail became available.

This letter provides additional detail resulting from audits of records and activities performed at the Point Ileach Nuclear Plant site and at the home oflice of our contracted service supplier. The completed evaluation continues to support our initial conclusion that the afTected equipment remains operable. The answers to your August 5,1997 questions, and a description of the elements of our evaluation, are enclosed as Attachments A and B.

Sincerely, ud. db Scott A. Patutski Site Vice President Attachments 9710270031 971016 PDR ADOCK 05000301 P PDR

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Attachment A RESPONSE TO NRC QUESTIONS

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1. Describe whetlier Morrison Knudsen Corporation has informed you of this potential quality assurance issue, and if so, what was the extent of the information, and when did they inform you.

RESPONSE: hforrison Knudsen Corporation (hiK) had not informed Wisconsin Electric Power Company (WEPCO) of the subject quality assurance issue.

WEPCO vtas first made aware of the issue by the NRC Region til letter of August 5,1997 to which this response is addressed.

2. Describe to what extent the welding procedures utillred fall to meet relevant quality assurance standards and/or ASME Code requirements.

RESPONSE: A matrix of the procedures cited in QFR C 96 022 was prepared by hiK (and audited by WEPCO) to identify the corresponding welds performed using each procedure, the identified procedure deficiency and the disposition of the deficiency, in each case, either the procedure was not used, the procedure was used to fabricate erection aldes (i.e. no permanent plant welds were performad), or (in one case) the weld was subsequmy removed. All permanent plant welds met or were subsequently demonstrated to meet relevant quality assurcace standards and/or AShiE Code requirements. WEPCO's September 1997 audit of hiK's records searched for additional, generic examples of welding deficiencies and identified that weld specimens used to support three procedure qualification secords had been tested by a laboratory not on hfK's approved suppliers list.

Welds impacted by the results of these tests were acceptably dispositioned. The matrix of weld information and fmal audit report are available for NRC review onsite.

3. Identify all of the welds at your plant which are affected by welding procedures that do not meet these quality assurance standards and/or ASME Code requirements.

RESPONSE: Welds performed using the procedures cited in QFR C-96 022, and in the WEPCO audit, met or were subsequently demonstrated to meet applicable quality assurance standards and/or ash 1E Code requirements. The matrix of weld information and final audit repon are available for NRC review onsite.

4. Indicate whether a 10CFR Part 21 notification is required for this issue.

RESPONSE: The issues above were evaluated by WEPCO and hiK for reportability under 10CFR Part 21. It was determined ' hat the issues are not reportable.

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. l Attachment A e

5. Detail your inunediate and planned corrective actions to alleviate this problem.

RESPONSE: Our immediate and planned corrective actions are addressed in Attachment 13 to this letter.

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O Attachment B EVALUATION On August 5,1997, Wisconsin Electric Power Company (WEPCO) received notice that information described in hiorrison Knudsen Corporation Quality Finding Report (QFR)

C 96 022 may callinto question the ability of welding procedures, and consequently the associated welds fabricated with these procedures, to meet AShiE Code Criteria. These procedures were used in support of the Point Beach Unit 2 Steam Generator Replacement Project (SGRP).

On August 12,1997, WEPCO received a copy of QFR C-96 022 from hiorrison Knudsen. Upon receipt, the Point Beach hianager's Supervisory Stafr(onsite safety revi:w committee) conducted an immediate, independent review of the QFR findings and responses. The results of this item by item detailed review are contained in the minutes cf hianager's Supervisoiy Stafr(hiss) meeting #9712. The QFR was transmitted to WEPCO via facsimile cover sheet which contained a signed statement from hiorrison Knudsen's Executive Vice President, Power Division, that "If'e (hiorrison Knudsen) found that there were no ducrepancies that in anyum a(fected the quality of u chts at Pt.

l Beach. " As a result of the htSS review and the position statement from hiorrison Knudsen, WEPCO concluded that Point Beach Unit 2 startup,in progress at the time, could be safely continued I

Although WEPCO cor'cluded that the issues presented in QFR C 96 022 were not safety significant, it was funher concluded that they were significant from a regulatory perspective since there appeared to be potential programmatic deficiencies in the control of procedures, code compatibility, and vendor communication aspects of the quality program. A Condition Report was generated on August 13,1997 to it'itiate additional evaluation and corrective '

action. The resulting action plan steps and outcomes are presented on the following pages.

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Attachment B ACTION PLAN TO ADDRESS A10RRISON KNUDSEN CORPORATION QUALITY FINDING REPORT QFR C.96 022 A. Immediate Action

1. Convene a hianager's Supervisory Stafr(onsite safety review committee) l meeting to perform a detailed review of h1K QFR C 96 022 to assess l potential impact on the Unit 2 scheduled approach to criticality.

l l COh1PLETE. An h1SS meeting (9712)was held on August 12,1997. This I

is the same date WEPCO received a Facsimile copy of the subject QFR and WEPCO's first knowledge ofits content. The details are contained in the minutes of h1SS meeting #97-12 and conclude that Unit 2 startup may be ,

safely continued.

2. Request that hiK provide a statement of their position regarding the quality of the weld:: performed on the Point Beach SGRP in view of QFR C 96 022.

COh1PLETE The Facsimile cover memo transmitting the subject QFR contained a signed statement by hiorrison Knudsen's Executive Vice President, Power Division, that "II'efound that there were no discwpancies that in an)voy a((ected the quality ofwehh at Pt. Heach."

3. Initiate a Condition Report to assure the QFR is entered into the corrective action system and that operability and reportability are addressed.

COh1PLETE. A Condition Report was initiated on August 13,1997.

B. Follow-up Action

1. hiorrison Knudsen (hiK) will be requested to supplement the disposition of each fmding of QFR C-96 022 to specifically address the implications to the welding activities performed on the Point Beach project. The current response (attached to the QFR as three pages, originated by hiorrison Knudsen's project welding engineer, dated January 22,1997), appears to address how the QFR fmdings will be resolved for future projects rather than address the implications of their past use in the welding activities at Point Beach Unit 2. This confusion is generated by several of the fmdirig responses which contain the statement: "7his li'PSis no longn being used. " (It is unclear as to whether this statement means the procedure is ao Page 2 of 5

Attachment B

, longer in use by hiK and therefore is not a concern for future projects, or whether use was discontinued prior to the Point Beach project).

NOTE: In a phone conversation between Point Beach senior managers and hiorrison Knudsen's Executive Vice President on August 14,1997, h1K committed to create a matrix containing each weld performed at Point Beach, the corresponding welding procedure used to perform the weld, the QFR finding related to that procedure, and the implications of the finding to the gur.lity and code conformance of the weld. This matrix would appear to address the above request.

COhlPLETE. This request was communicated to hiorrison Knudsen in l

WEPCO letter NPL 97 0501 dated August 14,1997. h1K responded by letter dated August 21,1997 and subsequently held a meeting at the Point Beach site on August 26,1997, to review the matrix of welds performed as mentioned in the NOTE above. The matrix of weld information provided by h1K at the August 26,1997 meeting, clarified that all responses therein were specific to the Point Beach Unit 2 SGRP. This review did not change the conclusion reached by WEPCO discussed in item A.1 above.

2. hiK will be requested to render a position regarding the applicability of 10CFR21 concerning the generic implications of the subject QFR findings to have resulted in nonconformances on other projects than Point Beach Unit 2.

COhlPLETE. hiK responded in a letter dated August 21,1997 that they had performed an evaluation in response to WEPCO letter NPL 97 0501 dated August 1a, l997, and "it was determined there were no other a(fected plants. " WEPCO Audit Report 97140, dated October 8,1997, also reaches a conclusion that items were not identified that have 10CFR21 reponing implications.

3. A QA audit team will be assembled to perform a supplier audit of h1K's quality records and welding program used in support of the Point Beach SGRP. This audit should address the following points:

(a) Although QFR C 96-022 was originated in January,1997, hiK did not inform WEPCO of this potential quality assurance issue. WEPCO's first notice of the existence of this report was provided by the NRC letter dated August 5,1997.

(1) The audit team should determine why h1K did not inform WEPCO of the subject QFR findings and disposition in January, 1997.

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Attachment B

• , COMPLETE: MK responded directly to this question in their August 27,1997 letter stating that "...AIK haddeterruined that all of the conditions reported (in the QFR) concernedissues ,

internal to A fK and that none of the reported conditions afected uvrk turned over to Point Beach. " The WEPCO audit team (Report 97 140) reached a similar conclusion.

l (2) The audit team should identify whether or not there are any other i

relevant QFRs or quality records at the MK of11ces, that have not been shared with WEPCO, that may hnpact the quality or acceptability of the steam generators.

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COMPLETE: MK responded directly to this question in thelt August 21,1997, letter stating that, based on internal conversations, "...there are no other known SGTiAfK.'oint Beach SGRP related QFRs or quality issues:" Tbe Whi'CO audit team reviewed the quality records on file at MK's corporate ofilce for the Polnt Beach Unit 2 SGRP. A sample of the Point Beach Unit I and St. Lucie Unit I steam generator replacement project records were also reviewed for potentialimpact. The WEPCO audit team noted an observation in one of MK's management audits that some weld specimens may have been tested by a laboratory that was not on MK's approved suppliers list. When researching this Onding for application to the Point Beach project, it was found that three procedure qualification records (PQR's) had been qualified using an unapproved testing agency (Ebasco. Savannah River), but that none had been used to support permanent plant welds.

(b) Outside welding code expertise should be included on the audit team to review appropriate welding procedures, weld data cards, procedure qualification records, and other information as necessary to render an opinion regarding the conformance and acceptability of the processes used to assure the continued safety, quality, and operability of the Point Beach Unit 2 steam generators.

COMPLETE: The Manager of Welding and Materials, Duke Engineering Sersices, assisted the WEPCO audit team. He reviewed the welding program to ensure that the procedures met ASME requirements and were properly used in fabricating welds for the SGRP at Point Beach Unit 2, Ilis fmdings agreed with WEPCO's previous conclusions regarding the welding procedures used on the Point Beach SGRP and found that none of the essential or supplementary welding variables were violated in making the welds.

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Attachment B

, , (c) The audit team should render their independent opinion as to whether any fmdings of their audit have 10CFR21 reporting implications.

COMPLETE: The audit team did not identify issues requiring reporting under 10CFR21.

(d) The audit team should identify any specific welds performed which were affected by welding procedures that did not meet quality assurance standards and/or ASME code requirements.

COMPLETE: The audit team confirmed that the welds, welding procedure deficiencies, and their respective dispositions are as described and documented by MK during the August 26,1997 meeting at the Point Beach site (see response to item 1 above) and met quality assurance standards and ASME Code requirements.

(c) The audit team should verify and validate the accuracy of the MK statements in the attachment to QFR C 96 022 (titled "As3c3sment C 96-022 OFR-ol", .. 3 pages), by review of appropriate records regarding use of post weld heat treatment, range of weld sizes to which specific procedures were applied, heat inputs, etc.

COMPLETE: The audit team completed a review of the Weld Data Cards for the Point Beach SGRP and reached similar conclusions to those presented by Morrison Knudsen in tiie initial and clarified issues of Assessment C-96 022, i.e. "there were no discretumcles that in any way affected the quality of wehls at Pt. Beach."

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