ML20236L221

Insp Rept 99901329/98-01 & 99901334/98-01 on 980520-22. Violations & Nonconformances Noted.Major Areas Inspected: Implementation of Selected Portions of Morrison Knudsen Corp & SG Team Quality Assurance Program

ML20236L221
Person / Time
Issue date:	07/08/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20236L157	List: ML20236L153 ML20236L179 ML20236L197 ML20236L221
References
REF-QA-99901329, REF-QA-99901334 99901329-98-01, 99901329-98-1, 99901334-98-01, 99901334-98-1, NUDOCS 9807100271
Download: ML20236L221 (13)

Text

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1 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Report No: 99901329/98-01 99901334/98-01 Organization: Morrison Knudsen Corporation (MK)

Engineering and Construction Group Power Division l 1500 West 3rd Street Cleveland, Ohio 44113-1406 The Steam Generating Team (SGT) 1500 West 3rd Street Cleveland, Ohio 44113-1406

Contact:

Michael F. Hendricks, Group Quality Director (216) 523-8193 Nuclear Industry: MK, Power Division, offers the nuclear industry services in construction, retrofit, maintenance and decommissioning of power plants.

SGT, a limited liability company owned by MK and Duke Engineering &

• Services offers the nue: ear industry steam generator replacement services.

Inspection Dates: May 20-22,1998 Inspectors: Joseph J. Petrosino, HOMB/NRR Katherine GreenBates, DRS/ Region Ill Je*ome J. Blake, DRS/ Region II Approved by: Robert A. Gramm, Chief Quality Assurance and Safety Assessment Section Quality Assurance, Vendor inspection and Maintenance Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation Enclosure 3 9907100271 98070s PDR GA999 EECMORRC 99901329 pog 'l c '(0 U / LU ' N k - - - - _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

1 INSPECTION

SUMMARY

During this inspection, the NRC inspectors reviewed the implementation of selected portions of the Morrison Knudsen Corporation (MK) and the Steam Generating Team (SGT), quality assurance (GA) program, and reviewed activities associated with its welding, maintenance, and steam generator replacement services to the nuclear industry.

The inspectica bases were:

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• I Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel j

Reprocessing Plants," to Part 50 of Title 10 of the C2;le of Federal Regulations i (Appendix B) e 10 CFR Part 21, " Reporting of Defects and Noncompliance" During this inspection, a violation of NRC requirements was identified and is discussed in I Section 3.1 of this report. Additionally, instances where MK/SGT fai!nd to conform to NRC and j American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code '

requirements contractually imposed upon them by NRC licensees were identified. These nonconformances are discussed herein.

l 2 STATUS OF PREVIOUS INSPECTION FINDINGS l 1

This was the first NRC inspection of the MK/SGT Cleveland, Ohio facility. ,

3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 10 CFR Part 21 Procram I

a. Insoection Scoce l i

The NRC inspectors reviewed records related to the identification 'and evaluation of deviations i to assess the overall effectiveness of MK/SGT's program that had been established to comply  :

with the requirements of 10 CFR Part 21.

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b. Observations and Findinos The NRC inspectors reviewed two MK "10 CFR Part 21 evaluation" packages and several -

project specific nonconformances that were dispositioned by SGT procedures that addressed 10 CFR Part 21 issue dispositions.

b.1 Part 21 Evaluations i 1

The Part 21 evaluations were documented on MK's Quality Asrurance Instruction (OAI) form l 1.1-1, " Determination Checklist for 10 CFR Part 21 Applicability," which is referenced in MK

! l procedure OAi 1.1," Reporting of Defects and Noncompliance," May 18,1993. Section 1.2.2 of j

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l OAl 1.1 stated that the form was applicable to the evaluation and reporting of defects and i

noncompliance discovered at the Cleveland office, cnd that defects and noncompliance

! i discovered at project sites shall be handled in accordance with project procedures.

l The evaluation packages regarded: (1) discrepancies in welding procedure specifications and

! procedure qualification records (PORs) at DC Cook and Point Beach initially evaluated on January 23,1997, closed on March 18,1997, and (2) Point Beach Welding Procedure Specifications (WPS') and PORs that were qualified throuqh testing performed by an ,

unapproved testing agency, initially evaluated on September 25,1997, closed on September 26,1997. {

The OAl 1,1-1 form had four parts: A. Description of deviation or Noncompliance, B. Initial Evaluation, C. Final Evaluation, and D. Deportability Evaluation. The NRC inspectors noted that the initial evaluation (Section B) requires a determination of whether a violation o' the J

Atomic Energy Act of 1954 or any applicab!e rule or regulation relating to suo' stantial safety i hazards, or whether the activity or component dogs contain defects wnich could create a substantial safety hazard, The chcices (blocks that may be checked) were "yes " "no," or

" unknown by MK." Both of the Part 21 evaluations performed by MK/SGT were checked as unknown by MK. However, in the final evaluation section of the OAl 1.1-1 forms, similar questions are asked regarding whether, on the basis of an evaluation, the issue could create a substantial safety hazard and, therefore be a defect, and whether the deviation could contribute 'j to the exceeding of a safety limit. The inspectors noted that the reviewers checked "no"in the final evaluation boxes, even though they had previously checked " unknown"in Section D, that  !

is, the initial evaluation section.

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In the subject evaluation packages MK/SGT staff identified the deviation of its services as

" basic components," as oefined in $21.3 of Part 21, and also identified in the initial evaluation section that it was " unknown" to them whether the questionable activities had violated any rule, {

regulation or license of the NRC. It was also identified by the MK/SGT staff that it was unknown l to the evaluators whether " defects" existed which could cause a substantial safety hazard. i However, in the final evaluation section of form QAl 1.1-1 the evaluator determined that defects did not exist, and also concluded that the deviation could not contribute to the exceeding of a safety limit. The NRC Inspectors discussed the evaluation process with one of the evaluators and found that the MK/SGT was not familiar with the failure mechanisms or consequences to other components in the area of the steam generator weldments, and was not aware of all of the interactions and consequences for a design basis event accident. The NRC Inspectors determined that MK/SGT did not have adequate capability to perform the required evaluation as defined in Part 21.

Therefore, the NRC Inspectors concluded that MK/SGT did not have adequate plant specific knowledge to determine whether the matter could have caused a substantial safety hazard or exceeded technical specification parameters; therefore, MK/SGT was required to evaluate the matter in accordance with 6 21.21 of Part 21, The issue contained in evaluation package 2, appeared to be an issue that could have been completely dispositioned in accordance with the MK/SGT QA program instead of the Part 21 program.

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i b.2 Proiect Soecific Nonconformances A review of several MK/SGT nonconformances identified that all had been appropriately dispositioned with one exception. One of the several potential Part 21 issues that were i

dispositioned in accordance with the MK/SGT QA program was determined to be a deviation, as defined in @21.3 of Part 21, and should have been processed in accordance with the vendor's Part 21 program, and is discussed in Section 3.2 below.

C. Conclusions The NRC inspectors conclude that the MK/SGT Part 21 program and the procedures that it has adopted to implement the provisions of 10 CFR Part 21 does not ensure effective implementation of the Part 21 provisions. Violation 99901329/98-01-01, and 99901334/98-01-L 1 was identified in this area.

3.2 Evaluation of St. Lucie NPS Welding insoqction Issue

a. Insoection Scopa

• The NRC inspectors reviewed several vendor Nonconformance Reports (NCR's) to verify that MK/SGT staff had appropriately evaluated and dispositioned reported problems or deficiencies 3, l

had taken adequate corrective actions to preclude recurrence, and had evaluated potential deviations in accordance with Part 21.

b. Observations and Findinas The NRC inspectors reviewed selected NCR's and identified one instance on the Florida Power '

and Light company, St. Lucie NPS Steam Generator Replacement Project where SGT did not  !

perform an adequate evaluation of an identified deviation. A review of SGT Nonconformance

, Report (NCR) 254, issued October 28,1997, identified that two undersize fillet welds had been s

found by the licensee's OA inspectors and brought to SGT's attention. The welds had previously been inspected and accepted by a qualified SGT quality control (OC) weld inspector.

A second QC weld inspector was sent out to reinspect a sample of nine welds previously inspected and found to be acceptable by the first inspector. All nine welds were found acceptable by.the second QC !nspector.

A subsequent inspection of the same nine sample welds by licensee QA staff determined that two of the nine welds inspected by the second SGT QC inspector were undersized. As a result, SGT generated NCR 262, issued October 31,1997, and instituted an inspection program to re-inspect 100% of the welds accepted by the two QC inspectors and a 10% random sampling of all St. Lucie NPS welds accepted by all of the other SGT QC weld inspection personnel. As a result of the re-inspection effort, SGT identified a total c,f nine unacceptable welds that had been accepted by the first QC weld inspector; two of which were erroneously found as acceptable by the second QC inspector. The first inspector was subsequently removed from weld inspection duties, whereas, the second QC weld inspector was retrained and returned to

l duty. Since the systems that contained the unacceptable (undersized) welds had been tumed over to the licensee, and the condition was a deviation, as C; fined in $21.3 of 10 CFR Part 21, SGT was required to evaluate the deviation to determine whether a substantial safety hazard could exist.

The NRC inspectors determined that SGT processed the two nonconformances in accordance with its procedure adopted to implement the provisions of 10 CFR Part 21, SGT Quality Execution Procedure (OEP) 1.R1, " identification and Control of Deviations," St. Lucie NPS

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Project, Revised October 7,1%7. Discussions with the cognizant St. Lucie NPS Project  !

Quality Manager (POM) and a review of the procedure determined that QEP 15.1 did not contain adequate criteria to allow the PQM to determine how the deviation should be dispositioned in accordance with 10 CFR Part 21, including whether SGT would have the capability to perform the required evaluation, as discussed in @21.21(b). j 1

The inspectors met with the MK Engineering and Construction Group Quality Director (GUD) to discuss how the generic view of this situation had been handled and whether the possibility that undersized fillet welds existed at other MK/SGT nuclear work sites had been addressed. Since two SGT vielding inspectors had failed to identify the undersize welds, this did not appear to be an isolated case. The NRC inspector questioned whether a root cause for why the qualified  !

welders and two Q.C. inspectors had failed to identify the unacceptable fillet welds (e.g., poor training, inappropriate measuring tools, insufficient knowledge of the applicable ASME code), l had been considered.

Additionally, there appeared to be an overalllack of MK/SGT guidance on how to perform and document a thorough evaluation in OEP-15.1, that is, quality records were not present in the NCR packages to show what generic applicability activities had been completed. After the NRC inspectors questioned the inadequate information that was contained in the packages, the MK staff contacted its Personnel department to determine if either of the QC inspectors had worked at other MK work sites, it was noted that MK/SGT satisfactorily identified the extent of the questionable welding inspections at the St. Lucie project and had taken appropriate corrective action regarding the J two suspect inspectors. However, as a result of the lack of adequate procedural criteria to ensure that effective evaluations were performed, MK/SGT staff did not consider the generic implications of the identified deviation. That is, MK/SGT did not determine whether either of the 3

suspect QC inspectors had performed welding inspections for MK/SGT on any of its other 1 nuclear power station projects. The lack of evaluation criteria guidance contained within SGT 1 quality assurance procedure QEP 15.1 resulted in an inadequate evaluation of a deviation. '

Violation 99901329/98-01-01 and 99901335/98-01-01 was identified in this area.

Before the NRC inspector's oxit meeting the GOD identified to the NRC Inspectors that the first inspector had not bean employed by MK/SGT on any other projects. Subsequent to the inspection, MK informed the NRC inspectors that the second weld inspector worked for MK/SGT at both D.C. Cook and Point Beach projects. However, the second inspector did not  ;

perform any weldment inspection at the D.C. Cook project, only the St. Lucie NPS and Point Beach steam generator replacements. MK staff informed the lead inspector that no welding anomalies had been identified during the Point Beach steam generator replacement. Howes 9r, I

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the lead inspector pointed out that lack of negative weld inspection results at Point Beach did not necessarily indicate that the second inspector had not accepted undersize welds at Point Beach. As a result of the discussion between the GOD and the Lead Inspector, MK committed to review the circumstances of the issue and inform the licensee of those circumstances on or before July 17,1998, if applicable I

c. Conclusions The MK/SGT procedures lacked adequate guidance to perform a proper Part 21 evaluation. As l

a result, a deviation relating to potentially unacceptable welds at other MK/SGT sites was not '

taken into consideration.

3.3 QA Procram Review for Control and Qualification of Welding Activities

a. Insoection Scoce The inspectors reviewed welding documentation for the Point Beach and St. Lucie NPS steam ,

generator replacement projects to verify that ASME Code and MK/SGT quality assurance l

program requirements were met. The inspectors review includec' procedure qualification l records, weld procedure specifications, weld data cards, and r ;ociated quality assurance  !

manual chapters.

b. Observations and Findings i Inspector review identified examples where MK/SGT activities, or the procedures used for activities, did not meet ASME Code requirements and/or were not in compliance with written MK/SGT quality assurance program requirements. Examples of these instances are provided in the following sections:

I b.1 WPS GT-SM/1.1-1 PB Revision 4 Comoliance with ASME Code The NRC inspectors identified that in November and December of 1996, MK/SGT weld i procedure WPS GT-SM/1.1-1 PB Revision 4, used to fabricate steam generator replacement Main Steam and Main Feedwater weldments at Point Beach, did not meet certain requirements )

of ASME QW-409.1. The ASME requirement, as implemented by OW-253 and QW-256, does {

not allow changes in current or polarity, increases in heat input, or increases in deposited weld metal over that r hich was qualified.

However, tne inspectors noted that this weld procedure allowed welding to be performed with an increase in heat input over that which had been qualified. Exceeding the qualified heat input for these welds has a potential consequence of lowering of the desired impact strength of the weldment.

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The NRC Inspectors reviewed MK correspondence No. M-QM-97-045, June 3,1997, concerning the re-evaluation of Point Beach WPS's and PQR's at Point Beach's request. After the review, the NRC inspectors were concerned about the capability of the MK quality l assurance program that is used to evaluate ASME Code weld procedures. The MK letter states at the conclusion of the MK re-evaluation that "SSW [ Point Beach Site Specific WPS) heat input allowable were at, or below, that allowed by the POR."

The re-evaluation failed to identify that the Main Steam and Feedwater welds fabricated using gas tungsten arc welding (GTAW)in accordance with this WPS were fabricated using an unqualified weld procedure. These welds had a material thickness range between 5/8 and 1.5 inches and were not post weld heat treated (PWHT). 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/1.104, were welded with a maximum heat input of 29.5 kJ/in for material thicknesses between 5/8 and 1.5 inches that did not receive a PWHT. Therefore, the heat inputs authorized in WPS GT-SM/1.1-1PB Revision 4, exceeded the hea; inputs in the supporting qualification welds, which was contrary to ASME paragraph QW 409.1 requirements. {

l Increased heat input has the potential consequence of lowering the desired impact strength of '

the weld which bounds the materials ability to resist crack propagation. Nonconformance 99901334/98-01-02 was identified in thie area.

b.2 Eoint Beach Weld and Procedure Qualification Records The inspectors reviewed SGT Quality Execution Procedure (OEP) 20.2, " Welding Procedure Qualification," October 25,1996, for Wisconsin Electric's Point Beach station. The procedure required that the new site PORs must be approved by the MK Engineering and Construction Group Welding Engineer (GWE), or delegated to the Project Welding Engineer (PWE).

The inspector identified that PQR GT-SM/1.1-05 was signed and approved by an SGT staff member on November 27,1996, without a previously issued delegation, and therefore was not in compliance with the vendor's written quality assurance program requirements. The POR was for use in qualifying a weld procedure to fabricate Point Beach Unit 2 safety related Main Steam and Feedwater welds. Since the same SGT staff member had reviewed and approved the applicable SGT quality assurance program requirement chapter (OEP 20.2) for Wisconsin Electric on October 25,1996, the inspector concluded that the individual was aware of this quality assurance requirement when he signed POR GT-SM/1.1-05 on November 27,1996.

The inspector identified that the control of weld procedures (review and approval) for welding on safety related components / systems did not appear to be in compliance with the vendor's quauty assurance program requirements, inspector review of a sample of weld procedures listed below, found 13 that were approved by an individual who had not been directly delegated authority by the GWE as required by the quality assurance program. Because the GWE did not specifically delegate authority to the individual the inspectors concluded that the following steam generator replacement project WPS's signed by that individual were not in compliance with MK/SGT requirements, including (a) Section 9.2.1 of the MK Quality Assurance Manual,

6 i August 20,1996, " Welding and Heat Treating - Weld Procedure Qualifications", (b) Section 9.2.6 ;

of the MK QAM, and (c) Quality Assurance Instruction (OAI) 11.2, September 23,1996,

" Control of Welding Procedure Specifications." Nonconformance 99901329/98-01-03 was i identified in this area.

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WPS GTM/1.1-2PB Revision 1 December 21996, WPS GTM/1.1-3PB Revision 0 November 27,1996  !

WPS GT-SM/1.1-1PB Revision 4 November 28,1996 WPS GT-SM/1.1-1PB Revision 3 November 23,1996 1

WPS GT-SM/1.8-1PB )

Revision 1 November 23,1996  !

WPS GT-SM/43.43PB Revision 1 November 23,1996 WPS GT-SM/8.8-1PB Revision 2 November 23,1996 WPS GT-SM/8.8-1PB Revision 1 November 5,1996 WPS GTM/1.1-2 PB Revision 0 November 27,1996 WPS GTM/1.1-3 PB Revision 1 December 3,1996 l

WPS POWPS-04PB Revision 0 October 24,1996 WPS WP-2-1PB Revision 0 December 4,1996 l WPS GT-SM-BU/1.3-1PB Revision 1 November 23,1996 in an associated area, the inspectors determined through discussions with SGT and MK staff that some ambiguity existed between the SGT and MK QA program control in the different welding procedure specifications. MK management expectations were made clear to the j

inspector in that the control of welding procedure specifications for the safety related steam I generator replacement welding activities at Point Beach and other licensee sites, should be closely monitored and approved by the MK GWE. The MK quality assurance documentation reviewed by the inspector supported that practice. However, the inspector's review of the SGT quality assurance documents and discussions with SGT personnel, determined that the i MK quality assurance requirements may not have been carried through to the site quality j assurance requirements in this area. That is, the quality assurance requirements for the control of weld procedures for welding on safety related components and systems appeared to be inconsistent, with differing review and approval requirements. Thn area appeared to have some weaknesses. l l

b.3 East Weld Heat Treatment Regarding ASME Cocle The NRC inspectors reviewed the steam generator replacement, Main Steam ard Main Feedwater weld procedure WPS GT-SM/1.1-1 PB Revision 4, and found that it did not prescribe a post weld heat treatment on weldments with a thickness of 1.5 inches and below.

The inspectors identified that on December 9,1996, and December 10,1996, post weld heat l treatments were applied to two Main Steam welds with a material thickness of 1.34 inches.

However, the QA program controls that MK/SGT used in this area had not identified the deviation from ASME Code requirements.

The ASME requirements, ASME Section IX,1995 Edition, QW-409.1, as implemented by requirements QW-253 and QW-256, required that "A change in the type of current or polarity, an increase in heat input, or an increase in volume of weld metal deposited per unit length of weld, [is not allowed] over that qualified."

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l inspectors identified that in November and December of 1996, MK/SGT weld procedure WPS GT-SM/1.1-1 PB Revisica 4, used to fabricate steam generator replacement Main Steam and  ;

Main Feedwater weldments at Point Beach, did not meet the requirements of the above stated I ASME requirement OW-409.1. This weld procedure allowed welding to be performed with an increase in heat input over that which had been qualified.

Inspectors reviewed MK correspondence No. M-QM-97-045 dated June 3,1997 conceming the re-evaluation of Point Beach WPS's and POR's at Point Beach's request. After review, i inspectors became concerned about the capability of the MK quality assurance to evaluate ASME Code weld procedures. The MK letter states at the conclusion of the MK re-evaluation that "SSW [PB Site Specific WPS) heat input allowables were at, or below, that allowed by the PQR." The re-evaluation apparently missed the fact that the Main Steam and Feedwater welds fabricated using gas tungsten arc welding (GTAW) in accordance with this WPS were fabricated using an unqualified weld procedure. These welds had a material thickness range I between 5/8 and 1.E inches and were not post weld heat treated (PWHT). 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/1.104, were welded with a maximum heat input of 29.5 kJ/in for material thicknesses between 5/8 and 1.5 inches that did not receive a PWHT. 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 paragraph QW 409.1 re.quirements. Using weld procedures not in compliance with ASME Code is considered a nonconformance. This is identified as an example of Nonconformance 99901334/98-01-03.

b.4 WPS GT-SM-BU/1.311 PB Revision 1 Comoliance witL ASME Code The NRC inspectors reviewed weld procedure WPS GT-SM BU/1.3-1 PB Revision 1, that was used at Point Beach in November 1996. The ing.pectors determined that the procedure did not meet the requirements of ASME QW-409.1. The weld procedure allowed welding to be performed wnh an increase in heat input over that which had been qualified. Although this weld was later removed for other reasons at the request of Westinghouse, complete weld fabrication using this WPS took place without MK/SGT quality assurance program identification that an unqualified weld procedure was in use.

b.5 St. Lucie NPS & Point Beach Permanent Plant Records (Weld Data Card);

The NRC inspectors record review identified that as of March 9,1998, MK/SGT had not provided accurate permanent plant records for certain welding processes used to assure ti a continued safety, quality, and operability of the Point Beach Unit 2 steam generators, for example:

(a) The NRC Inspector found permanent plant welder records for the St. Lucie NPS steam generator replacement project that did not meet SGT QEP 20.1 " Control of Welding,"

October 31,1997, and SGT QEM 20.5, " Control of Filler Metal," October 24,1997, quality assurance requirements. Of the 36 welders entered on an SGT weld data card

quality document only six actually perform welding on the weldment. The licensee's steam generator project QA identified and brought the matter to SGT's attention (St.

Lucie NPS OR No. 97-6637) during a routine review of welding documentation.

(b) The NRC Inspector determined that an SGT Point Beach Weld Data Card, WDC 3081-A-2, and WDC 3081-B-7 did not have the applicable revision recorded for the weld procedure used to fabricate the steam generator replacement main steam weld.

Consequently, when Revision 4 of the welding procedure was determined to be an unqualified procedure, the licensee could not identify that these welds required requalification.

The quality documents for steam generator replacement welds did not contain sufficient records l for the details of the welding that had been performed as required by 10 CFR Part 50, Appendix B requirements. The MK/SGT QA/QC programs had not identified the inconsistencies in accordance with its OEP 20.1 and 20.5 quality assurance requirements. This matter is identified as an example of Nonconformance 99901334/98-01-04. )

l B.6 ASME Reauired Droo Weiaht Testina l

a. Insoection Scoce The inspectors reviewed documentation of drop weight tests conducted to qualify ASME welding procedure specifications (WPSs) for D. C. Cook and the Point Beach steam generator replacement projects.

b. Observations and Findings The procedure qualification requirements for ASME WPSs involved Charpy V-notch (Cv) impact testing where the WPSs were to be used on materials for which ASME Section ll1 specified fracture toughness as a design requirement.

The testing of the Cyspecimens required that an appropriate test temperature be established through consideration of the Lowest Service Temperature (LST) and/or Tno7, as defined by ASME.

LST is the minimum temperature of the fluid retained by the component or, the calculated minimum metal temperature whenever the pressure within the component exceeds 20% of the preoperational system hydrostatic test pressure.

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Tsor is the temperature at or above the nil-ductility transition temperature NDT (ASTM E l 208-81); Tsar is 10 F below the temperature at which two specimens show nu-break I performance.

The selected test temperature for the Cv specimens, Tev, in turn established the reference l temperature (RTnor) for the qualified WPSs. RTuor is defir,ed by ASME as the higher of Tnor j and (Tev - 60 F) and establishes LST for materials welded using the WPSs.

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The Procedure Qualification Record (POR) for the D. C. Cook WPS was POR No. 3-8 f Shielded Metal Arc Welding (SMAW) of A-302 Grade B bne material to itself, (P3 Group 3 to P3 Group 3). For this PQR, a series of drop weight test was conducted which established the Tnm as -100*F for the weld metal zone and -60*F for the base material. The C specimens for y

POR No. 3-8 were tested at Tev = +50 F which established the RTnm as -10*F for the qualified WPS. These tests met the requirements of the applicable ASME Section IX, and Section lit, 1980 Edition, Summer 1983 Addenda.

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The POR for the Point Beach WPS was POR No. FC/3.3-Q1 for the Flux Core Arc Welding (FCAW) of SA-533 Grade B Class 1 to SA-533 Grade B Class 2, (P3 Group 3 to P3 Group 3).

For this POR, two drop weight specimens were tested at a test temperature of +5*F. After both specimens met the "no-break" requirement, the POR No. FC/3.3-Q1 Cv specimens were tested at Tcv = +55 F which established the RTum as -5'F for the qualified WPS. These tests met the requirements of the applicable ASME Section IX,1995 Edition, and Section lil,1986 Edition.

c. Graclusions Although the Point Beach, POR No. FC/3.3-Q1, drop weight test program was abbreviated, when compared to the D. C. Cook POR No. 3-8, drop weight testing, the inspectors found that either method met the requirements of the ASME Code.

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] b.7 Procedure Qualification Record (POR) GT/3.3-02

a. Inspfction Scoca The inspectors reviewed the documentation supporting special welding procedure qualification testing for the Point Beach Unit 2 steam generator replacement project.

b. Observations and Findinos A recent NRC Region Ill inspection of Point Beach related welding activities raised questions concerning the requalification of the Gas Tungsten Arc welding (GTAW) portion of WPS GT-SM/3.3-2PB.

One of the questions involved the use of a single process POR to expand the qualification range of a multiple process WPS, On May 20,1997, a 1%-inch thick test plate was welded using the GTAW process and high heat inputs. At the time of the test, the test assembly was assigned the POR No. GT/3.3-Q2.

This test plate was welded using the GTAW process for the %-inch from the center of the plate to one surface; the opposite side of the plate was also welded with the GTAW but only to i balance the welding stresses and maintain the straightness of the test assembly. The test assembly portion of the weld was made using heat inputs of 61.4 kJ/in. through 105.9 kJ/in. On May 27,1997, Bodycote Taussig, Incorporated (BTI), reported that the weld metal from this test assembly had been successfully impact tested as a welding procedure qualification coupon.

The inspectors determined that, having completed welding and testing of POR GT/3.3-Q2 assembly in May 1997, MK/SGT did not immediately follow through by documenting the test with a POR. The ricords showed that MK personnel considered canceling the POR No.

GT/3.3-02 because they felt that the test was not needed to support the WPS used at Point Beach. The records also showed that MK/SGT considered that POR GT-SM/3.3-Q1 was technically in compUance with ASME requirements. POR No. GT/3.3-Q2 was finally issued on April 16,1998.

The inspectors also found that the documentation of the decision process involved in: the original decision to weld test assembly No. GT/3.3-Q2; the decision to not complete the POR process; and the decision to finally issue the POR were not clearly documented.

On the question of a single process POR being used to expand the qualification range of a multiple process WPS, the inspectors reviewed the original test weld data for POR No. GT-SM/3,3-Q1. This review showed that the original test weldment consisted of a 1%-inch thick test plate welded using the GTAW process for the %-inch from the center of the plate to one surface, and the SMAW process for the other %-inch from the center of the plate to the i

opposite surface. This method of welding the 1%-inch thick test plate essentially constituted two separate welding procedure qualifications which could then be used separately or in combination. ASME Section IX specifies that %-inch of weld metal deposited in a 1%-inch thick test plate constitutes a test. The inspectors also agreed that ASME Section IX allows the i

requalification of a single process to support changes to essential elements. (There is no requirement to retest both welding processes to support essential element changes in only one of the processes.)  ;

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c. Conclusions i j

i The inspectors found that in the specific cases reviewed, the welding procedure qualification  !

processes were in compliance with the requirements of the ASME Code.

b.8 D.C. Cook Main Steam and Feedwater Welds The NRC inspectors reviewed D.C. Cook procurement records and an SGT/MK Work Package,

1. 1531-A, and noted a disparity between licensee and vendor records. A September 18,1997, j

American Electric Power (AEP) letter, AEP NRC 1273, to the NRC Region ll1 staff indicated that the Code requirements of ANSI B31.1 was the applicable piping Code used to fabricate the ]i steam generator replacement main steam and feedwater final closure welds (new-to-old piping joints), at D.C. Cook. However the MK/SGT Work package provided by the MK/SGT staff j appears to indicate that actual weld fabrication was performed to ASME Ill Code requirements.  !

3 The NRC Inspectors noted that MK could not easily identify the exact welds joints in question .

from the work package without extensive review, and the D.C. Cook Steam Generator Project  !

Report was not present to determine whether the final closure weld joints had been reconciled back to the code of record. The inspector determined that this issue concerns certain D.C. j Cook field welds and will be transmitted to NRC Region lli for its consideration for follow up.

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.I 3.4 Entrance and Exit Meetings In the entrance meeting on May 20,1998, the NRC Inspectors discussed the scope of the inspection, outlined the areas to be inspected, and established interfaces with the MK/SGT management. In the exit meeting on May 22,1998, the NRC Inspectors discussed their findings and concerns.

4. PERSONS CONTACTED MORRISON KNUDSEN CORPORATION - ENGINEERING & CONSTRUCTION GROUP T.H. Zarges President & CEO M.F. Hendricks Group Quality Director (MK & SGT)

G.N. Hlifka Corporate Welding Engineer F.B. Kovacs Senior Quality Engineer L.E. Pardi Executive Vice President, Power Division THE STEAM GENERATING TEAM M.D. Cepkauskas President DUKE ENGINEERING AND SERVICES R.W. Bonsall Executive Vice President, Engineering & Environmental Group M.C. Scott Senior Engineer

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