ML19345F383
| ML19345F383 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/26/1981 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19345F381 | List: |
| References | |
| 800126, NUDOCS 8102170369 | |
| Download: ML19345F383 (21) | |
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P.o sox 5000 e CLEVELAND. oHlo 44101 e TELEPHONE (216) 822-9000 e iLLUutNATING BLDG e 55 PUBLIC$oVARE Serving The Best Locat'on in the Nation Murrey R. Edelman u2Nacta January 26, 1981 NUCLE Aa OUAUTV AS59m ANCE DEPARTMENT Mr. Caston Fiore11i United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Re: Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Actions Planned /Taken to Resolve SWN 81-01, CAR 0504, and USNRC Findings on SP-64 Contractor
Dear Mr. Fiorcili:
As a result of the findings identified by Mr. F. C. Hawkins of your office during an inspection on January 21-23, 1981, we have initiated strong immediate action, including a Stop Work Notification (SWN) issued to our nuclear coatings contractor, Metalweld, Inc.,at 11:02 a.m. on January 23, 1981.
l Attached is a listing of the actions planned or already taken by Metalveld, Inc.,
and the PNPP Project Organization to correct weaknesses in the Metalweld Quality Program and its implementation. Necessary actions outside of Metalweld's responsi-bilities have also been delineated.
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We have just received Metalweld's response to our Corrective Action Request No. 0504 which was attached to our Stop Work Notification No. 81-01. Although we have not had time to review all the details, we find it generally acceptable and consistent with the list of actions attached to this letter. We have enclosed a copy of the Metalweld response for your review.
We solicit your comments and suggestions on our " action" list and the Metalveld response.
If we have misinterpreted the findings of your inspector or understated the corrective action you consider appropriate, please contact us immediately.
Very truly yours,
& f N V $ f ~7X d [
Murray R. Edelman Manager Nuclear Quality Assurance Department MRE: bas Attachments cc: Mr. J. Hughes, US NRC U.S. Nuclear Regulatory Commission 8302170309 c/o Document Management Branch Mr. J. Konklin, US NRC JAN 2 81981 t
ACTIONS TO RESOLVE SWN 81-01, CAR 0504, AND USNRC INSPECTION FINDINGS The following corrective actions shall be taken to resolve Stop Work Notification No. 81-01, Corrective Action Request No. 0504, and USNRC findings during January 21-23, 1981, inspection. Action parties include both METALWELD, INC. (MW) and CEI PNPP Project Organization (PO). Each action item contains: a description of the action taken or planned, desig-nated action party, and completion and intermediate action dates. Items indicated with asterisk (*) require resolution prior to any release.
- 1.
Response to Corrective Action Request No. 0504 Action by: METALWELD, INC.
Submit to PO by:
28 January 1981
- 2.
Evaluate METALWELD response to CAR No. 0504 Action by: PNPP Project Organization Complete by: 28 January 1981 3.
Conduct intensive, comprehensive indoctrination and training of METALWELD Site Quality Control personnel.
Action by: METALWELD Corporate Quality Assurance Manager with assistance from Corporate officers.
Complete by:
Initiated 24 January 1981. Ongoing with total program complete by 15 March 1981, i
Intermediate dates: Prior to each partial Stop Work Release, Q.C. personnel shall be recertified for each activity of the partial release in which the individual inspector is to be involved.
4.
Requalify/recertify all METALWELD Site Quality Control Inspectors based upon satisfactory completion of new indoctrination and training program.
Satisfactory completion shall be achieved by attendance at indoctrination and training sessions and passing written and, if applicable, practical examinations.
Action by: METALWELD Corporate Q.A. Manager with assistance from Corporate officers.
Complete by:
Initiated 24 January 1981. Ongoing,_with total program complete by 15 March 1981.
Intermediate dates: Prior to each partial Stop Work Release, Q.C. Inspectors shall be recertified for each activity of the partial release in which the individual inspector is t' he l
involved.
1 1
- S.
Issue PNPP Deviation Analysis Report (DAR) to initiate internal PO evaluation of significance of CAR No. 0504 items.
Action by: PNPP Project Organization Completed:
23 January 1981
PAGE ACTIONS TO RESOLVE
- 6.
Report conditions to USNRC Region III as a possible signi-ficant deficiency as defined by 10CFR50.55e.
Action by: PNPP Project Organization Completed:
23 January 1981 in telephone call by W. J. Kacer, P.O./CQS, to Richard Knopp, USNRC at 1400.
- 7.
METALWELD Corporate Q.A. Manager (Registered Nuclear Safety Related Coatings Specin!ist) is to be temporarily assigned to PNPP Site on a full-time basis until the new indoctrination and training program has been completed and the MEiALWELD Quality Program has been implemented to the satisfaction of the METALWELD management and the Project Organization.
Action by: METALWELD Completed:
23 January 1981
- 8.
METALWELD Corporate Officers to be on-site, as necessary, to assist in resolving corrective action and to provide management overview of implementation.
Action by: METALWELD Complete by:
26 January 1981 Executive Vice President (Registered Professional Engineer, Corrosion, and Registered Nucleer Safety Related Coatings Engineer) and Vice President of Sales and Marketing (Registered Nuclear Safety Related Coatings Specialist), to arrive on-site.
NOTE: Vice President of Field Operations (Registered Professional Engineer, Corrosion, and nationally Registered Nuclear Coatings Engineer) has been on-site since 22 January 1981 and is currently assisting the Corporate Q.A. Manager.
9.
Issue Engineering Change Notices (ECN's) to:
A.
Delete requirement for measuring base steel readings after surface preparation. ECN to include technical justification for deletion of requirement.
B.
Provide requirement for frequency of dry film thickness (DFT) readings on coatings applied to steel shapes (i.e. pipe, hangers, channels, etc.).
i C.
Provide frequency requirement for taking surface profile measure-ments on steel substrate after surface preparation.
l D.
Provide requirement for frequency of wet film thickness (WFT) reading on coatings applied to ccacrete.
Action by: PNPP Project Organization / Gilbert Associates, Inc.
Complete:
Item 9.A. by:
27 January 1981 Item 9.B. by: 27 January 1981 Item 9.C. by: 29 January 1981 Item 9.D. by: 30 January 1981
PACE ACTIONS TO RESOLVE 10.
Review, update, and revise, as necessary, the entire measuring and test equipment (M & TE) system, including recall methods, accuracy, and effectiveness.
Action by: METALWELD Completed review:
25 January 1981 Complete updating by: 27 January 1981 Complete revision by:
15 March 1981 NOTE:
Prior to issuance of each partial Stop Work Release.
- M & TE to be used for the affected activities shall be verified to be calibrated with traceability to NBS.
Actions in excess of procedural requirements may be implemented and documented on Q.C. records, prior to revising program. Any actions contrary to or less stringent than those delineated in currently approved procedures shall be incorporated by procedure revision prior to implementation.
- 11.
Revise CAR procedure (QAP-016) to simplify / clarify.
Action by:
METALWELD Complete by:
28 January 1981
- 1 se all forms to include revision number and date and re-issue forms.
Action by:
METALWELD Complete by:
27 January 1981
- 13.
Provide new resume for one (1) Q.C. inspector to include previous employment in nuclear coating inspection.
Action by:
METALWELD Completed:
24 January 1981
- 14.
Revise receipt inspection procedure to include requirement to open each carton to examine coating containers for damage, leakage, and l
proper identification.
Action by:
METALWELD Complete by:
27 January 1981
- 15.
Prepare Nonconformance Report (NR) for material accepted in unopened carton and later rejected for damage to containers.
Action by:
METALWELD Complete by:
27 January 1981 16.
Revise procedure for qualification / certification of QC personnel to include certification for specific activities / inspections / tests.
Action by:
METALWELD Complete by:
15 March 1981
PACE ACTIONS TO RESOLVE NOTE:
Certifying Q.C. inspectors to perform only specific activities is not prohibited by the current approv$d procedure. Therefore, such method of certification shall be implemented immediately in recertification program currently underway as part of the intensive indoctrination and training being conducted on-site.
17.
Perform internal audit of PNPP activities by METALWELD exec-utives independent of PNPP operations.
Action by:
METALVELD Complete by: 28 February 1981 18.
Define requirements and methods for documenting in process (as opposed to acceptance) inspections.
Action by:
METALWELD Complete by:
15 March 1981 NOTE:
Documentation of inspections, including in process, is part of the I & T currently being conducted. Target completien date above includes not only coverage in I & T sessions, but also the development of a procedure speci-fically addressing in process inspection.
19.
Provide direction on certification / chemical analysis requirements for solvents and degreasers in light of Reg. Guide 1.54 limitations.
Action by:
PNPP Project Organizations Complete by: 30 January 1981 20.
One hundred percent (100%) overview of Metalweld to include:
A.
Representatives at each Metalweld I & T session.
B.
Concurrence with Metalweld lesson plans.
C.
Acceptance of recertification of Metalveld Q.C. inspectors.
D.
Inspection of coating activities and Q.C. inspectors' perfor-mance after issuance of Stop Work Releases.
E.
In process auditing of program implementation after issuance of Stop Work Releases.
F.
Progran audit of all eighteen (18) criteria, Appendix B to 10CFR50.
Action by:
PNPP Project Organization Complete 20.A and 20.B by: 15 March 1981 (Begun 24 January 1981).
Complete 20.C by:
15 March 1981 NOTE: Review and acceptance of recerti-fication for activities involved shall be performed prior to each Stop Work Release.
i PAGE ACTIONS TO RESOLVE Complete 20.D and 20.E by: Until confidence in Metalveld's performance is achieved.
Complete 20.F by:
30 April 1981
- 21.
Prepare package of all documentation of corrective actions which justify issuance of partial / full Stop Work Releases. Present package of documentation to NRC Resident inspector prior to issuance of partial / full Stop Work Releases.
Action by:
PNPP Project Organization Complete by: Upon satisfactory completion of consolidated (Metalveld and Project Organization) actions required to justify issuance of partial / full Stop Work Releases.
22.
Issue partial / full stop work releases.
Action by:
PNPP Project Organization Complete by: Upon satisfactory completion of consolidated (Metalweld and Project Organization) actions required to justify and support issuance of partial / full Stop Work Releases.
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W 1000 Conshohocken Road + Conshahrden. PA 19428 Phore 215 825 8800 Serial Letter WP-2903-V-085 26 January 1981 RECEIVED CLEVELAND ELECTRIC ILLUMINATING COMPANY M 2 61981 10 Center Road Perry, OH 44081 jo,(,,o,gg, ATTN:
Mr. Gary R. Leidich Supervisor-construction Quality Engineering RE:
Perry Nuclear Power Plant Contract NP-2903-V Corrective Action Request #Q504 Gentlemen:
The objective of this response is to obtain a "Stop Work Release" as expeditiously as possible within the confines of the " Corrective Action Request".
An attempt will be made to obtain "Stop Work Releases" in stages, with emphasis placed in the following sequence:
1.
Unit #1 Containment Dome (remaining activities).
2.
Coating shop-structural steel and piping.
3.
Unit #2 Containment Liner Plate.
4.
Service Level II.- Concrete Coatings.
The attached lesson plans or Indoctrination and Train-ing are devoted solely to those actions and operations required to complete the Unit #1 Containment Dome.
The lesson plans re-present a brief outline of each applicable Inspection Plan, Quality Control Procedure, W>rk Instruction, and Work Procedure applicable to the METALWELD work remaining to be completed on l
the Unit #1 Dome.
Intensive Indoctrination and Training will be held for the l
following Quality control individuals on 24 January through 27 i
January 1981:
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John B. Vaspoli, Jr.
Level II Alan G. Booth Level I l
Norbert J. Holdash Level I Douglas L. Leaverton Level I l
Scott J. McAslan Level I Theodore J. Tobiasz Trainee Terry G. Gordon Service Level II-Inspector I
l Cast and Sprayed Urethane Sheet Urmng Protectne Coating Sand and Gnt Ekashng
- Metalkzmg
- Nuclear Sennce Level I Coatmgs woung Machang Madonery Rebuttng Casong Repers
PAGE 26 January 1981 CLEVELAND Electric Illuminating Co.
Emphasis will be placed on both classroom and field training.
Written and practical examinations will be given to each individual to insure their knowledge of the subject matter and their confidence in conducting tests and inspec-tions.
Educational sessions will be conducted by Mr. William C. Wells, Quality Assurance Manager for METALWELD with assis-tance from the undersigned. (Resumes attached).-Sc ?*
Indoctrination and Training Sessions will continue to be held by Mr. Wells after the dates noted above, until such time as METALWELD and the Project Organization are convinced as to the capabilities and performance of the inspection staff.
Additional lesson plans for work not included in the dome are currently being prepared and will be submitted as soon as they are complete.
Indoctrination and Training for those additional areas will be performed at that time.
All other items listed on Corrective Action Request 40504 are attached to this letter.
Each item indicates METALWELD'S recommended corrective action and the anticipated completion and intermediate action dates.
To further assist in the resolution of the Corrective Action Request, additional METALNELD Executives will be on the Perry Nuclear Power Plant on Monday, 26 January 1981 to support our efforts.
In addition, Mr. Wells and the undersioned will remain on the site until such time as all items are resolved and operations are again running smoothly.
Very truly yours, METALWF.LD,g INC.
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CORRECTIVE ACTION REQUEST #0504 ITEM #1
" Project Organization concern action requests Nos. 344, 346, 347, and 351."
RECOMMENDED CORRECTIVE ACTION Concern Action Request #344 Item #1 - Profile test frequencies were not delineated in the specification.
METALWELD is expecting an engineering change notice specifying the frequency rate.
Completion Dates Request ECN by 28 January 1981 Procedure submittal 30 January 1981 Request review and approval by 6 February 1981 i
Controlled issue 10 February 1981 Item #2 - The " Specific Intervals" required by QCP-014 is not applicable since Section #10.1 of Inspection Plan #IP-210 states that the inspector must verify immediately prior to coating that the prepared surface is free from dust and spent abrasive and that blasted steel exhibits no rust bloom.
No completion dates required.
Action Request #346 It was never the intent of METALWELD'S quality documents to have the inspector witness every single batch of material which is mixed, but rather that he monitor the activities on a periodical basis.
Each individual actually doing the mixing has been qualified previously for mixing that partic-ular coating.
No completion dates required.
Concern. Action Request #347 Indoctrination and training of all METALWELD Q.C. personnel is currently in process as evidenced by Items #2 and #3 of this response.
Completion dates are the same for Items #2 and #3.
Action Request 2351 This topic will also be covered by the Indoctrination and Training Program.
Completion dates are the same for Items #2 and #3.
NOTE:
Written responses to the AR's will be submitted by the
" Action Due by Date" indicated on each AR.
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CORRECTIVE ACTION REQUEST #0504 ITEM k2 i
" Personnel qualifications / certifications are too broad for the documentation substantiating the level of cerification i.e. Medical Technician and NDE as previous experience qual-ifying for certification as Level I coating inspector with only minimal on-job training".
RECOMMENDED CORRECTIVE ACTION As evidenced by the cover letter, on 24 January 1981 METAL-WELD began an extensive, intensive indoctrination and train-ing program for all inspection personnel.
Previous experi-ence in many instances was not used as a basis for qualifying individuals but was intended to show a complete employment history for the inspector.
Continuing Indoctrination and Training and on the job training will continue until METAL-WELD and the site organization are confident as to the capa-bilities of each inspector.
Completion dates:
I and T - Dome 27 January 1981 I and T - Shop 30 January 1981 I and T - Liner plate 30 January 1981 I and T - Level II concrete 2 February 1981 Continuing I and T and supplemental training 15 March 1981 i
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CORRECTIVE ACTION REQUEST #0504 ITEM #3
" Indoctrination and Training of O.C. personnel is inadequate as evidenced by the inability of various individuals to answer basic OC and QA questions related to their jobs, i.e. frequency of testing for a specific item, conditions under which noncon-formance report or CAR would be issued."
RECOMMENDED CORRECTIVE ACTION As mentioned previously, intensive indoctrination and training is taking place.
Attached are lesson plans detailing the items to be covered.
Each inspector will be qualified for each area of inspection and will not be permitted to perform these in-spections until he has satisfactorily evidenced the ability to conduct the inspection and has passed written and practical examinations.
Completion dates:
I and T - Dome 27 January 1981 I and T - Shop 27 January 1981 I and T - Liner Plate 30 January 1981 I and T - Level II concrete 2 February 1981 Continuing I and T and supplemental training 15 March 1981
CORRECTIVE ACTION REQUEST #0504 ITEM #4
" Corrective Action Report procedure OAP-016 is difficult to understand as evidenced by the fact that 0.C. personnel could not explain how it is implemented or under what circumstances."
RECOMMENDED CORRECTIVE ACTION Ouality Control Procedure #0AP-016 will be revised to simplify the method for implementation of corrective action.
Indoctrin-4 tion and training of all inspectors will be conducted.
Parti-cular emphasis will be placed on the indoctrination and training given METALWELD'S 0.A.
Supervisor pertaining to the actual work-ing mechanisms of the procedure.
Completion dates:
Procedure submittal 28 January 1981 Request review and approval by 4 February 1981 Controlled issue 6 February 1981 l
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CORRECTIVE ACTION REQUEST #0504 ITEM #5
" Receipt inspection does not require opening of boxes to check for damage to coating containers."
RECOMMENDED CORRECTIVE ACTION Attached is revision #3 to METALWELD'S Quality Control pro-cedure #0Cp-023 which requires that all containers, except for the final container, shall be opened to inspect for damage.
METALWELD will begin this reinspection as soon as notified by the site organization.
Consistent with this reinspection, METALWELD will prepare nonconformance reports for all items previously received which have been found to have been damaged.
please nobe that the attached procedure is "FOR INFORMATION ONLY" since it has not been through the complete review and approval cycle and issued as a controlled document.
Completion dates:
procedure submittal 26 January 1981 Request review and approval by 2 February 1981 Controlled issue 4 February 1981 M*
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CORRECTIVE ACTION REQUEST #0504 ITEM #6
" Forms which are attached to and part of the OAP'S and OCP'S do not contain a revision number /date."
RECOMMENDED CORRECTIVE ACTION All forms included as attachments to all OAP's and OCP'S have been revised to show revision number and date of revision.
As soon as approval is received, METALWELD will reissue the forms as an attachment to the applicable document.
Completion dates:
Forms Revision submittal 26 January 1981 Request review and approval by 2 February 1981 Controlled issue 4 February 1981
CORRECTIVE ACTION REQUEST *0504 ITEM #7 "An internal audit by METALWELD of site activities has not been performed to date."
RECOMMENDED CORRECTIVE ACTION METALWELD will conduct an internal audit prior to the completion dates indicated.
The audit team will be qualified, executive level personnel from the home office.
Emphasis will be placed on insuring that those items included in Corrective Action Request
- 0504 have been properly corrected.
All other pertinent quality aspects will also be reviewed.
Copies of this and all future internal audits of METALWELD Perry Nuclear Power Plant activities (as well as related vendor audits) shall be available for review on-site.
Completion dates:
Internal Audit 20 February 1961 Publish results 27 February 1981
CORRECTIVE ACTION REQUEST #0504 ITEM #8 "O.C. procedures do not define DFT testing frequencies required for various steel shapes."
RECOMMENDED CORRECTIVE ACTION METALWELD requires additional engineering change notices from the site organization so that we may include specified accep-tance criteria in the applicable procedure.
Immediate correc-tiva action is to train each inspector as to the approximate number and location of the readings to be taken.
METALWELD will also require additional ECN'S on the frequency of profile measurement readings, and the frequency of wet film thickness measurement readings on concrete.
Additional unique sha~.3 not covered by the ECN'S and procedures will be discussed with the site organization prior the operation, utilizing the field question (FO) system.
Completion dates:
procedure Revisions One (1) week after receipt of ECN Review and approval Two (2) weeks Controlled issue Two (2) days
CORRECTIVE ACTION REQUEST #0504 ITEM #9
" Control and calibration of measuring and test equipment are inadequate as evidenced by broken mikrotest number 273 being in the field without a reject / hold sticker to indicate status and a calibrated standard thermometer (Ref. QAp-012.1, para. 4.3.1) is not available.
Additionally, recall system is poor as evi-denced by on thermometer being several days beyond the calibra-tion due date.
Thermometers are not checked at three points and calibration reading are not documented on a calibration form."
RECOMMENDED CORRECTIVE ACTION The damaged mikrotest has been removed from the site for repair or replacement.
Thermometers, as well as all calibrated equip-ment has been checked to insure that the calibration period has not expired.
These mistakes in the implementation of the program are being reemphasized in the current indoctrination and training program.
Additionally, METALWELD will be revising Quality Assurance procedure EQAp-012.1, Calibration of Inspec-tion Instruments.
To institute a better recall system for all instrumentation.
In the interim, we have devised a visual mon-itoring system to insure that equipment will not be used after the calibration period has expired.
Completion dates:
Visual Monitoring System 26 January 1981 Procedure Submittal 15 March 1981 Request review and approval by 30 March 1981 Controlled issue 2 April 1981 i
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COh?.ECTIVE ACTION REQUEST N0504 ITEM #10
" program is inadequate in explaining how, in-process inspections will be documented."
RECOMMENDED CORRECTIVE ACTION The current indoctrination and training session is extensively devoted to the documentation required by the inspector.
This instruction is directed toward the proper documentation of all in-process inspections as well as the final inspection.
Addi-tionally, METALWELD is preparing a Quality Control Procedure devoted entirely to Inspection Report Preparation.
The outline on this procedure has been explained and discussed in the In-doctrination and Training Session Lesson Plan attached.
Completion dates:
I and T Documentation 26 January 1981 Procedure Submittal 2 February 1981 Request review and approval by 9 February 1981 Controlled issue 11 February 1981 4
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METALWELD, INC.
INDOCTRINATION AND TRAINING LESSON PLANS (UNIT #1 CONTAINMENT DOME)
TABLE OF CONTENTS INDOCTRINATION AND TRAINING INTRODUCTION IP-210-INSPECTION PLAN - Devoted only to those areas yet to be completed in the Dome.
Discuss and review.
OCP-008-DETERMINATION OF TEMPERATURE, RELATIVE HUMIDITY AND DEW POINT - Review and discuss - Hands on training.
OCP-007-DETERMINATION OF CLEANLINESS OF AIR SUPPLY - Review and discuss - Hands on training.
OCP-Oll-VISUAL INSPECTION OF APPLIED COATINGS - Review sub-jective analysis for inorganic zine and epoxy.
Hands on training.
OCP-015-DRY FILM THICKNESS INSPECTION - Review and discuss -
Hands on training.
WI-210-WORK INSTRUCTION - Devoted only to those areas yet to be completed in the Dome.
Discuss and review.
WP-133-MIXING CARBO ZINC #11 - Explanation of the mixing pro-cess and O.C. involvement.
WP-134-APPLICATION OF CARBO ZINC #11 - Explanation of the application and touch up and O.C. involvement.
WP-142-APPLICATION OF CARBOLINE N191HB - Explanation of mixing, l
application, and touch up and Q.C. involvement.
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INDOCTRINATION AND TRAINING LESSON PLANS EXPLANATION '
l.
Why are we in a "Stop Work" condition.
2.
Who issued it and why?
3.
Review centents of the " Corrective Action Request".
4.
Define steps to be taken to obtain a "Stop Work Release".
5.
The Inspector's personal involvement in obtaining a "Stop Work Release".
6.
Measures required to prevent reoccurence.
7.
How to answer questions asked by an NRC Inspector and others.
8.
Synopsis of the Indoctrination and Training Program.
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INDOCTRINATION AND TRAINING LESSON PLANS IP-210-INSPECTION PLAN 1.
How to use plan as a cross reference to the specification.
2.
Review each section as it relates to upcoming work in the dome.
3.
Read and explain each applicable section.
4.
Written examination.
NOTE:
The inspection plan will be discussed again when indoctrination and training takes place for shop and liner plate operations.
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