NPL-98-0470, Responds to NRC Re Violations Noted in Insp Rept 50-301/98-05 on 971216-980309.Corrective Actions:Subsequent to Issuance of QFR 01,PQR GT-SM/1.1-Q6 Was Developed

Responds to NRC Re Violations Noted in Insp Rept 50-301/98-05 on 971216-980309.Corrective Actions:Subsequent to Issuance of QFR 01,PQR GT-SM/1.1-Q6 Was Developed

ML20248J807
Person / Time
Site:	Point Beach
Issue date:	06/04/1998
From:	Patulski S WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-301-98-05, 50-301-98-5, NPL-98-0470, NPL-98-470, NUDOCS 9806090317
Download: ML20248J807 (12)

Text

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Wisconsin

,Electnc CNW scoli A. PATULSKl p ,,, , , , SITE VICE PRESIDENT 6610 Nuclear Rd.. Two Rivers. WI S4241 (920) 755-6214 NPL 98-0470 10 CFR 2.201 June 4,1998 Document Cor. trol Desk U. S. NUCLEAR REGULATORY COMMISSION Mail Station PI-137 l Weshington, DC 20555 Ladies / Gentlemen:

DOCKET 50-301 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT 50-301/98005 i POINT BE ACH NUCLEAR PLANT. UNIT 2  !

In a letter from Mr. John Grobe dated May 5,1998, the Nuclear Regulatory Commission forwarded the results of an inspection conducted by your staff at our Point Beach Nuclear Plant. The inspection was conducted from December 16,1997, through March 9,1998. The inspection report included a ,

Notice of Violation which identified four violations of NRC requirements. j We have reviewed the Notice ofViolation and, pursuant to the provisions of 10 CFR 2.201, have prepared a written response to the four violations requested by your letter of May 5,1998. Our written response to these violations is included as an attachment to this letter.

We believe that the attached reply is responsive to the Notice of Violation and fulfills the requirements identified in your May 5,1998, letter.

New commitments that have not been previously docketed are identified by italics.

I l ifyou have any questions or require additional information regarding this response, please contact /

me.

Sincereg, .. b 3 M

kWw (JScott A. Patuiski Site Vice President Point Beach Nuclear Plant Attachment cc: NRC Resident Inspector NRC Project Manager NRC Regional Administrator PSCW 9906090317 990604 <

PDR ADOCK 05000301 4'Msen EwWuzuur O PM i

A'ttachment to NPL 98-0470 Page1 4

DOCKET 50-301 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT 50-301/98005 POINT BEACH NUCLEAR PLANT. UNIT 2 During an NRC inspection conducted from December 16,1997, through March 9,1998, four violations of NRC requirements were identified. Inspection Report 50-301/98005 and the Notice of Violation (Notice) transmitted to Wisconsin Electric on May 5,1998, provide details regarding the violations.

In accordance with the instructions provided in the Notice, our reply to the violation includes, as appropriate: (1) the reason for the violation, or if contested, the basis for disputing the violation; (2) the corrective action taken and the results achieved; (3) corrective action to be taken to avoid further violations; and (4) the date when full compliance will be achieved.

As requested in the NRC's May 5,1998 letter, in addition to responding to the four cited violations, our response also includes a discussion ofissues associated with welding audits conducted in support of our Unit 2 Steam Generator Replacement Project (SGRP).

Violation 11 "10 CFR 50, Appendix B, Criterion IX, " Control of Special Processes," requires, in part, that measures shall be established to assure that special processes, including welding, and heat treating, are controlled and accomplished by qualified personnel using qualified procedures in accorciance with applicable codes, and standards.

The 1995 Edition of the American Society for Mechanical Engineers Code,Section IX, Paragraph QW-409.1, requires that "A che.nge 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."

(a) Contrary to the above, in November and December of 1996, weld procedure WPS GT-SM/1.1-1 PB, Revision 4, used to fabricate steam generator replacement main steam and feedwater welds, did not meet the requirements of QW-409.1. Specifically, this weld procedure authorized welding with an increase in heat input over that which had been qualified.

This is a Severity Level IV violation (Supplement I).

(b) Contrary to the above, in November of 1996, weld procedure WPS GT-SM-BU/1.3-1 PB, Revision 1, used to perform welding on the steam generator feedwater nozzle weld, did not meet the requirements of QW-409.1. Specifically, this weld procedure authorized welding with an increase in heat input over that which had been qualified.

This is a Severity Level IV violation (Supplement 1)."

Attachment to NPL 98-0470 Page 2

. 1 pa==a=== to Violation 1.m:

We concur this is a violation of NRC requirements as characterized in the inspection report.

- Welding Procedure Specification (WPS) OT-SM/1.1-1PB was utilized during the PBNP Unit 2 Steam Generator Replacement Project to perform pipe-to-pipe welds on the main steam and feedwater piping i systems. GT-SM/1.1-IPB Revision 3, and earlier revisions, allowed welding on applications which did not require post-weld heat treatment (PWHT). Revision 3 permitted maximum allowable heat inputs of 28.8 kj/in for the GTAW process and 85.8 kj/in for the SMAW process. Revision 3 of this WPS was supported by PQRs GT-SM/1.1-Q4 and Q1 and Q2.  ;

During the Unit 2 steam generator replacement outage, it was necessary to revise

. WPS GT-SM/1.!-lPB to perform unanticipated welds required by a minor steam generator fit-up problem. Revisicn 4 to this WPS was developed to allow welding on either non-PWHT or PWHT applications. In changing the WPS from Revision 3 to Revision 4, the maximum allowable heat inputs were increased to 47.4 kj/in for the GTAW process and reduced to 52.8 kj/in for the SMAW process. Revision 4 to this WPS is supported by PQR GT-SM/1.1-Q5, which was qualified specifically for PWHT.

While incorporating PWHT requirements into Revision 4 of the WPS, pertinent information for non-PWHT welds was not carried forward from the previous revision. Revision 4 of this procedure was written to allow both PWHT and non-PWHT welds, but the heat input limits listed in the revised J procedure were those qualified for PWHT welds. These heat inputs were higher than those for the non-PWHT applications. Under Revision 4, welds not requiring PWHT could have been welded utilizing the GTAW process with heat inputs as high as 47.4 kj/in. This condition resulted in a welding procedure that was not qualified for non-PWHT welds because available qualification records limited GTAW heat inputs to 28.8 kj/in for non-PWHT welds. Revision 4 of the procedure should have contained a note to limit heat inputs for non-PWHT welds.

Corrective Actions Taken: i This ASME Code variance was self-identified by Morrison Knudsen in January 1997 in Quality Finding Report (QFR) 01 associated with Assessment C-96-022. Subsequent to the issuance of i

QFR 01, PQR GT-SM/1.1-Q6 was developed. This PQR qualifies a maximum heat input of 83.3 kj/in for the GTAW process and 98.8 kj/'mfor the SMAW process for weld applications which do not i require PWHT, These higher heat input limits bound the heat inputs of any non-PWHT welds made to Revision 4 of WPS GT-SM/1.1-1PB during our Unit 2 steam generator replacement project. PQR ,

GT-SM/1.1-Q6 qualified the non-PWHT welds with heat inputs well in excess of the maximum heat f inputs listed in Revision 4 of GT-SM/1.1-1PB.

In addit. ion, WPS GT-SM/1.1-IPB Revision 5 has been issued by Morrison Knudsen to reference PQR GT-SM/1.1-Q6 and to include appropriate heat input restrictions for welds not subject to PWHT.

Revision 5 brings WPS GT-SM/1.1-1PB into full Code compliance.

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The development of PQR GT-SM/1.1-Q6 assures that non-PWHT welds made during the PBNP Unit 2 Steam Generator Replacement Project pursuant to Revision 4 of WPS GT-SM/1.1-IPB are i fully qualified.

Wisconsin Electric's audit team reviewed this Code compliant issue during Audit 97-130, which was completed in October 1997. - WPS GT-SM/1.1-IPB Revision 4 was reviewed during the audit. The PQRs were compared to the essential, supplementary-essentia;, and non-essential variables contained in the WPS. The PQRs attached to the WPS reviewed during the audit did not include PQR l GT-SM/1.1-Q5, so the WPS allowances for heat input of 47.4 kj/in with the GTAW process and PWHT was questioned. Upon receipt of PQR GT-SM/1.1-Q5 from Morrison Knudsen during the ,

audit (October 3,1997), this PQR was reviewed and had been made with PWHT and a heat input of l 47.4 kj/in. for the GTAW process. ASME Section IX was not interpreted to indicate that the maximum heat input to be specified in the WPS was limited based on the weld made with or without PWHT. Therefore, the audit team failed to identified this issue as a Code nonconformance.

Corrective Actia== to be Takan: j I

There are no additional corrective actions planned to be taken.

Date Of Full Cornnilanca:

Full compliance with NRC requirements was achieved concurrent with Wisconsin Electric's review and acceptance of PQR GT-SM/1.1-Q6 and WPS GT-SM/1.1-IPB Revision 5.  :

i Da==a=== to Vial = flan 1.h:

We concur this is a violation of NRC requirements as characterized in the inspection report.

1' WPS GT-SM-BU/1.3-IPB Revision I allowed heat inputs above those qualified in referenced PQR GT-SM-BU/1.3-Ql. WPS GT-SM-BU/1.3-IPB Revision 1 allowed welding with a maximum heat input of 73.3 kj/in for the GTAW process and 85.8 kj/in for the SMAW process. The maximum heat inputs supported by the referenced PQR are 46.3 kj/in for the GTAW process and 54.3 kj/in for the SMAW process. Because of the heat input disparity between the WPS and the PQR, WPS GT-SM-BU/1.3-IPB, Revision 1 was not fully Code compliant.

WPS GT-SM-BU/1.3-IPB Revision I was used during the PBNP Unit 2 replacement project but not for any permanent plant weldments. This buttering welding procedure was used on the main feedwater nozzles, but the buttering was subsequently machined off, and therefore, was not part of the

' final weldment.

1 The feedwater nozzle extension is a P3 type msterial. The feedwater pipe that was to be welded to the extension is a P1 type material. The welding of thisjoint would have required PWHT. The purpose of the buttering procedure was to allow the P3 to P1 postion of the weld to be accomp ished by  !

buttering the feedwater nozzle extension with a P1 type weld filler material. The weld to be made in '

the field would then be a P1 to P1 weld which would not require PWHT. Such buttering would allow

Attachment to NPL 98-0470 Page 4 -

the PWHT to be performed in the fabrication shop, thereby eliminating the need to PWHT the weld inside the containment building.

After buttering the feedwater nozzle extensions, using WPS GT-SM-BU/1.3-IPB Revision 1, and prior to machining the weld preps, informational radiographs were performed. Results of the radiographs indicated discontinuities that would have necessitated repair. As a result of these indications, a decision was made to remove the buttering by machining to the original weld preparation configuration. This machining removed all weld metal which was deposited using WPS GT-SM-EU/1.3-1PB Revision 1. The feedwater nozzle extension to feedwater pipe weld was subsequently made using a different qualified WPS.

Corrective Actions Takent This Code compliant issue was identified by Morrison Knudsen in their Quality Finding Report (QFR) 01 and associated Assessment 96-C-022. Morrison Knudsen dispositioned this finding by validating that the buttering weld material had been removed and that WPS GT-SM-BU/1.3-IPB Revision I was therefore not used on any permanent plant weld applications. Verification that WPS GT-SM-BU/l.3-1PB Revision I was not used for permanent plant welds was documented in Morrison Knudsen's letter dated June 6,1997.

In preparation for Wisconsin Electric's Audit 97-130, this buttering procedure was discussed and acknowledged to have been removed and was not part of a permanent plant eldment. Therefore, the scope of the audit did not review the issue in further detail other than to verify that the buttering weld meterial was removed.

WPS GT-SM-BU/1.3-1PB was canceled by Morrison Knudsen on May 28,1998, and is no longer in use.

Corrective Actions to be Taken:

No additional corrective actions are planned to be taken.

Date Of Full Comnli==ce:

Full compliance was achieved upon verification that WPS GT-SM-BU/1.3-IPB Revision I was not used for permanent plant welds and upon cancellation of WPS GT-SM-BU/1.3-IPB on May 28,1998.

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'Attcchment to NPL 98-0470 Page5 s

Violation 2:

"10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings" requires that l

activities affecting quality shall be prescribed by documented instructions and procedures and shall be accomplished in accordance with those instructions and procedures.

Contrary to the above, activities affecting quality were not performed in accordance with documented I

procedures, in that, on December 9 and 10,1996, post weld heat treatments were applied to two main steam weals, FW-6 on steam generators A and B, which had a material thickness of 1.3 inches; however, the procedure prescribing heat treatment, WPS GT-SM/1.1-1PB Revision 4, contained no instructions for material thickness below 1.5 inches.

This is a Severity Level IV violation (Supplement I)."

D=na== to Vinlatlan 2 l-We concur this is a violation ofNRC requirements as characterized in the inspection report.

Performance of PWHT on two main steam pipe welds were not prescribed in WPS GT-SM/1.1-lPB, Revision 4. The WPS lacked specific instructions to perform PWHT for main steam welds made on pipes of material thickness of less than 1.5 inches.

The original plan for welding of the main steam piping consisted of three welds for each steam  ;

generator. Field Welds 2 and 3 joined P1 and P1 type base materials approximately 1" thick along the

- horizontal run of the of the main steam pipe. These welds were made utilizing WPS GT-SM/1.1-1PB and did not require PWHT. Field Weld 1 joins the elbow of the main steam piping to the steam generator outlet nozzle. This weldjoined P1 and P3 type base material, approximately 1.35 inches thick, utilizing WPS GT-SM/1.3-1PB which required PWHT.

As the result of an unanticipated minor steam generator fit-up problem, it was necessary to install a small pipe pup piece, of approximate 4" length, between the steam generator outlet nozzle and the main steam elbow. This resulted in an additional weld, Field Weld 6, thatjoined the pup piece to the main steam elbow. Field Weld 6 joined P1 to P1 type base material which did not require PWHT.

Due to the close proximity of Field Welds 1 and 6, it was determined to not be possible to PWHT Field Weld I and not affect Field Weld 6. A decision was made to PWHT both welds at the same time. The decision to PWHT Field Weld 6 prompted Revision 4 of WPS GT-SM/1.1-1PB to include PWHT. Revision 4 was supported by PQR GT-SM/1.1-Q5.

WPS GT-SM/1.1-1PB Revision 4, which was used to make Field Weld 6, provided PWHT instructions for welds 1.5" thick and greater, but was silent on PWHT instructions for welds less than

' l.5". The wall thickness for Field Weld 6 was approximately 1.35".

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- The WPS revision was written to include PWHT Code requirements. ASME Section IX requires that i the WPS ad kesses all essential and non-essential variables. PWHT is an essential variable. While the l

' WPS did address ASME Section 111 mandated PWHT requirements, it was silent on PWHT guidance l for thicknesses less than 1.5", At the time of the WPS revision, it was known that PWHT was not i l

" Attachment to NPL 98-0470

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required by the Code for material thicknesses ofless than 1.5", therefore, we believed that the WPS was not required to address PWHT for welds less than 1.5".

Corrective Actions Taken:

An additional review of WPS GT-SM/1.1-IPB Revision 4 was performed to re-confirm compliance with applicable Code requirements regarding PWHT. From this review, we reached the same conclusion summarized in the NRC inspection report. We concluded the WPS and affected welds are in conformance with Code requirements and Field Weld 6 is fully qualified.

Wisconsin Electric Audit 97-130 evaluated this issue and determined that although the WPS was silent for PWHT of base material below 1.5", a Heat Treatment Record was prepared for this weld which provided instructions for the PWHT process. Wisconsin Electric's audit team did not consider this issue a Code compliant issue.

We have also reviewed the PWHT instructions associated with Field Weld 6. The Violation

. description implies that adequate controls were not in-place to perform the PWHT for Field Weld 6 because the WPS did not give specific guidance for. material thicknesses for less than 1.5". Weld Data Card 3081-B-10 and Heat Treatment Record 3081-B-10 used for Field Weld 6 provide appropriate instructions necessary to correctly perform the PWHT.

Corrective Actions to be Taken:

No additional corrective actions are planned to be taken.

i Date of Full Compliance Full compliance was achieved upon our confirmation that the WPS and affected welds are in conformance with Code requirements and that PWHT instructions were provided in the applicable Heat Treatment Record.  !

I Violation 3: I "10 CFR 50, Appendix B, Criterion XVII," Quality Assurance Records," requires, in part, that

. sufTicient records shall be maintained to furnish evidence of activities affecting quality.

Contrary to the above, as of March 9,1998, records for the welding processes used on Unit 2 steam ,

generators, were not sufficient to furnish evidence of activities affecting quality in the followmg

. instances:

(a) . Weld Date Card (WDC) 3042-A-2 and WDC 3042-B-2 for steam generator A and B feedwater nozzle welds, listed a weld procedure which was not used to fabricate the weld.

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(b) WDC 3081-B-7 for a feedwater weld, did not record the correct weld procedure revision used j to fabricate the weld.

(c) WDC 3081-A-2 for a main steam weld, did not record the correct weld procedure revision used to fabricate the weld.

This is a Severity Level IV violation (Supplement 1)."

P==a== to Violation 3:

Documentation associated with welding activities perfonned during the PBNP Unit 2 Steam I Generator Replacement Project were managed as quality records in accordance with the SGT Ltd. and PBNP Quality Assurance Programs. These programs were implemented during the project to assure the accuracy, retrievability, and maintainability of records for activities associated with quality. We j acknowledge that the three examples cited in Violation 3 represent a failure to fully meet our standards and the standards 10 CFR 50 Appendix B, Criterion XVII for accuracy and retrievability of l records, i i

The cited examples can be characterized as either a deficiency to clearly identify the welding procedure specification used for a particular weld or as a deficiency to assure that the correct revision number for the welding procedure specification was identified on the Weld Data Cards.

Corrective Actions Taken:

l Condition Report 98-1351 was created on March 31,1998 to document the apparent deficiencies in the permanent plant records cited in Violation 3 and recommended that the permanent plant records be ]

corrected as necessary. Each of the Weld Data Cards cited as examples in Violation 3 have been  !

! reviewed in detail.

i l Weld Data Cards for the project were generated by the SGT Ltd. Project Welding Engineer and l l reviewed and approved by SGT Ltd., Wisconsin Electric, and ANI personnel in accordance with

project quality execution procedures. At the time the Weld Data Cards were generated, the Project ,

l Welding Engineer could authorize the use of one or more qualified welding procedure specifications l to make the weldment. The authorized welding procedure specification (s) were listed on the Weld Data Cards. For Weld Data Cards 3042-A-2 and 3042-B-2, both WPS GT-SM/3.3-2PB (a manual j

process) and WPS GTM/3.3-IPB (an automated process) were listed on the Weld Data Cards as an

~ acceptable procedure for use. At the time the weldment is made, construction supervision was

. empowered to use either of the acceptable procedures listed on the Weld Data Card.  !

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Attachment to NPL 98-0470

- Page 8 For the welds made by the subject Weld Data Cards, the manual process, WPS GT-SM/3.3-2 PB was used. Traceability to WPS GT-SM/3.3-2 PB was validated through a review of the filler material identification numbers listed on the Weld Data Cards. The filler material identification numbers listed on the subject Weld Data Cards correspond to the manual process, WPS GT-SM3.3-2PB. For Weld Data Cards which may have listed more than one authorized WPS, a similar validation can be made to determine which WPS was used. However, we acknowledge that relying on such validation process to historically determine from permanent plant records which WPS was used is not a best practice.

The second and third cited examples associated with Violation 3 regard Weld Data Cards which apparently did not record the correct weld procedure specification revision. As described earlier, due to emerging work activities associated with a minor steam generator fit-up problem, it was necessary to revise some of the WPSs during the replacement project while work was in progress. Insufficient care when issuing a revised WPS to assure work already in progress reflected the correct WPS revision contributed to this deficiency.

Weld Data Card 3081-B-7 was generated for the welding of Field Weld 7, which was made on the vertical run of the feedwater line to lower the horizontal run into the steam generator. This was a work scope change which was controlled by Work Package Change Notice 14. Weld Data Card

. 3081-B-7 documents the use of Revision 3 of WPS GT-SM/1.1-1PB. Revision 4 of this WPS was issued on November 28,1996.

A myiew of the Weld Data Card indicates that SGT Ltd. Nonconformance Report (NCR) 209 was written because the original Weld Data Card was lost. Weld Data Card 3081-B-7 was reconstructed in accordance with NCR 209 by review of the Quality Control Daily Inspection Reports, Weld Filler Material Withdrawal Slips, and NDE Reports.- In review of NCR 209 and associated documents, it has been determined that this weld was fit and tacked on November 28,1996. The weld also appears to have been completed on this date as no Weld Filler Material Withdrawal Slips associated with this weld were believed issued any later han November 28,1996.

We believe that the use of Revision 3 as documented on Weld Data Card 3081-B-7 is correct.

Revision 4 of WPS GT-SM/1.1-IPB was approved on November 28,1996, the same date as the apparent completion of the weld. It is believed that Revision 4 was not posted to the controlled document stations until after completion of the subject weld. In addition, Revision 4 was developed for the purpose of adding PWHT requirements to the WPS. The weld completed by Weld Data Card '

3081-B-7 did not require PWHT.

Weld Data Card 3081'-A-2 was issued for main steam Field Weld 2, which is on the horizontal run of -

the main steam line. This weld was fit and tacked on November 23,1996. The revision of WPS GT-SM/1.1-IPB that was in effect at that time was Revision 2 and was so documented on the Weld Data Card. Records indicate that the WPS was revised to Revision 3 on the same day that the welding began. By reviewing the Weld Data Card, the record indicates that work on this weld

. continued past the Revision 3 issue date of November 23,1996. While it appears that Revision 2, when documented on the Weld Data Card was correct, the Weld Data Card should have been changed to document Revision 3 of WPS GT-SM/1.1-IPB when it was issued.

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~ Attachment to NPL 98-0470 Page 9 Revision 3 of WPS GT-SM/1.1-IPB changed the amperage ranges for the GTAW process. The change from Revision 2 to Revision 3 gave a wider amperage range on the low end. Therefore there  ;

were no hardware impacts based on the conclusion that Revision 3 did not have any affect on the maximum allowable heat inputs.

Corrective Actions to be Taken:

Work is in progress to complete actions associated with Condition Report 98-1351. We are in the process ofreviewing each Weld Data Card usedfor the PBNP Unit 2 Steam Generator Replacement Project to assure that each WeldData Card clearly depicts which WPS was usedfor the weldandto assure that the proper WPS revision is documented. Permanentplant records will be modified i appropriatelyfor any identified deficiencies. We expect this review to be completed byJuly 15,1998.

Date Of Full Compliance:

Full compliance will be achieved by July 15,1998 with the close-out of Condition Report 98-1351.

Audit Adequacy Issues Wisconsin Electric performed Audit 97-130 to evaluate the issues identified in Morrison Knudsen Quality Finding Report 01 and associated Assessment C-96-022 and to address the issues stated in the NRC's letter to Wisconsin Electric dated August 5,1997.

As stated in the scope of Audit Report 97-130, the audit addressed the following points:

1. Timeliness of reporting the QFR C-96-022 to Wisconsin Electric. The QFR was written in January 1997 but was not reported to Wisconsin Electric until August 1997.

2. Review of other QFRs or quality records for issues which have not been shared with Wisconsin Electric.

3. Review of welding procedures, weld data cards, procedure qualification records, and other information as necessary to assure ASME Code requirements were met.

The audit team restricted their scope of evaluation of Morrison Knudsen to only those procedures and activities affecting PBNP.

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The primary focus ofItem 3 of the above listed audit scope was to review the welding procedure specifications to determine that they were properly qualified in compliance with ASME Code requirements and the procedure qualification records supported their qualification. Weld Data Cards were reviewed to ensure:

1. Proper WPSs were used for each weld based on the base materials and thickness.

2. Filler materials were appropriate for thejoint and were in compliance with WPS requirements.

3. Weld heat input was monitored and met WPS requirements.

4.- Post-weld heat treatment was performed when required.

in addition to review of the WPSs, PQRs and weld records pertaining to the project, QFR C-96-022 was reviewed in detail, as well as 21 other Morrison Knudsen audits dating back to 1993.

. The results of Audit 97-130 were summarized in our letter to the NRC on October 16,1997. In that letter, we concluded that all permanent welds met or were subsequently demonstrated to meet relevent qu'ality assurance standards and applicable ASME Code requirements.

Violations 1.a. and 1.b. of this subject NRC inspection report depicted two specific Code violations.

Both of these were identified as apparent Code violations in Morrison Knudsen's Assessment C-%-022. Wisconsin Electric's audit team reviewed both of these issues.

Our audit team failed to recognize that WPS GT-SM/1.1-IPB Revision 4 failed to meet Code requirements. The auditors reviewed PQR GT-SM/1.1-Q5 during the audit to assess heat input restrictions. ASME Section IX was not interpreted to indicate that the maximum heat input to be {

specified in the WPS was limited based upon the weld being made with or without PWHT Therefore,  !

the auditors believed that PQR GT-SM/1.1-Q5 properly dispositioned this issue. We now acknowledge that WPS GT-SM/1.1-lPB was not fully qualified until development of PQR GT-SM/1.1-Q6.

The Wisconsin Electric audit team acknowledged that WPS GT-SM-BU/1.3-1PB was not Code compliant. The audit team dispositioned this issue by verifying that the buttering weld material was removed and was not a' permanent plant weld.

, Subsequent to Audit 97-130, and concurrent with the NRC inspection of these issues, Wisconsin Electric documented additional minor welding procedure discrepancies. Condition Report 98-0149 was written to document that WPS FC/3.3-IPB contained a footnote that was inconsistent with ASME Section IX requirements. The footnote was not applicable to welding performed at PBNP and therefore, had no impact on the weldment. However, this WPS has been revised to assure it is fully L Code compliant.

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- Condition Report 98-0339 was written to document a PWHT temperature variance. WPS GT-SM/1.1-1PB Revision 4 lists an authorized PWHT temperature of 1150 *F +/-25 F. A review of the PWHT strip charts for this weld demonstrated that actual field PWHT deviated from the range defined within the WPS. However, the PWHT temperatures remained well within those required by ASME Code. The WPS applied a conservative temperature range. An expanded review of other SGRP work packages was conducted as a result of this Condition Report. This review identified that WPS GT-SM/1.1-3PB specified a similar PWHT range. PWHT strip chart records confirm that actual PWHT temperatures were not maintained within the WPS specified range; but again, were well within the heat range requirements required by the Code. These procedure discrepancies will be fully -

dispositioned with the close-out of Condition Report 98-0339. l Because some inconsistencies exist between the conclusions drawn in our Audit Report 97-130 and the Bndings in the NRC inspection report, Quality Condition Report (QCR) 98- 0130 was written on March 30,1998. This QCR noted these inconsistencies and expressed the need to assure that audits include necessary substantiating evidence to document conclusions. This QCR has been assigned to our Quality Assurance Group for assessment and to determine what corrective actions may be needed to improve special audits in the future.

The QCR 98-0130 assessment is expected to befully completed by July 31,1998. Recommended corrective actions will be administeredin accordance with the PBNP Corrective Action Program. 1 l

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