IR 05000382/1980004
| ML19331B849 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/23/1980 |
| From: | Crossman W, Stewart R, Tomlinson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19331B845 | List: |
| References | |
| 50-382-80-04, 50-382-80-4, NUDOCS 8008130414 | |
| Download: ML19331B849 (19) | |
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LOI U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION ANE ENFORCEMENT
REGION IV
Repcrt No. 50-382/80-04'
Docket No. $0-382 Category A2 Licensee:
Louisiana Power and Light Company 142 Delaronde'St.reet New Orleans, Louisiana 70174 Facility Name:
Waterford Steam Electric Station, Unit No. 3 Investigation'at: Waterford Site, Taft, Louisiana Investigation conducted: February 26-27, March 13-14, April 3-4, 29-30
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and May 1-2, 1980
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Inspectors:
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bu 23 80 R. C: Stewart,' Reactor Inspector, Projects Section eate L..
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. P.' temrCinson, Tteactor Inspector, Engineering Support Date Section
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6!Ed8d Approved:
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W. A. Crossman, Chief, Projects Section Date fl Y
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"r x E E. Ifall,4hief, Engineering ydpport Section Gater
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Investigation Samrcary:
Investigation 'on February 26-27, March 13-14, April 3-4, 29-30, and May 1-2, 1980 fReportNo. 50-382/80-04)
- Areas Investigated:
Special investigation of allegations by two former QC inspectors. assigned as Level I inspectors on the painting of protective coatings in the Reactor Containment Building (RCB). The investigation involved eighty-
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three inspector-hours by'two NRC inspectors.
Results: Of the twelve allegations investigated, two were partially substantiated; however, the matters were previously known by the Sline Co. and the licensee.
No-items of noncompliance or deviations were ioentified.
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INTRODUCTION Waterford Steam Electric Station, Unit 16. 3 (Waterford, Unit No. 3) is under construction in St. Charles Parish, Lotisiana, near the town of Taft, Louisian'a.
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Louisiana Power and Light Company is the Construction Permit holder with Ebasco, Inc. serving as both the Architect / Engineer and the Construction Manager.
REASON FOR INVESTIGATION The Region IV office staff was notified on February 21, 1980, by an individual by telephone, who stated that he wanted to report irregularities by the painting
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subcontractor at the Waterford 3 construction site. The individual stated he was terminated by the site painting contractor and was a former Level I QC painting inspector. He also stated that the irregularities involved painting activities inside the Reactor Containment Building (RCB) and the painting of safety-related equipment.
SUMMARY OF FACTS On February 27, 1980, two IE inspectors met with the above referenced individual (Individual "A") to obtain specific it'ormation as to his allegations regarding painting irregularities.
In addition, the II inspectors met uith a second individual (Individual "B"),
on April 4, 1980.
Individual "E", a former co-worker of Individual "A" and former Level I QC painting inspector, was identified by Individual "A" as a corroborating witness. The alleged painting irregularities identified by Individuals "A" and "B" are as follows:
Allegation No. 1 Indivi'aals "A" and "B" alleged that miscellaneous steel (the majority in the '.orm of 3" x 3" x 3/8" angle iron) was painted and accepted by QC with-out the proper surface preparation and that some final coatings were ac.cepted by y. without documented paint batch numbers or acceptable coating thickness.
In addition, Individual "A" alleged that the QA Manager, on numerous occasions, falsified inspection document reports by the use of " white-out" in order to make unacceptable inspection findings acceptable and/or replaced his or other' signatures in place of the original QC inspector's signature.
Individual "A" provided the IE inspectors with copies of alleged original inspection documents held in his possession, which Individual "A" stated were evidence of the unacceptable miscellaneous steel and would demonstrate the alleged falsification.
Allegation No. 2 Individuals "A" and "B" alleged that a general condition existed where final paint coatings were applied, in multiple paint coatings, without the proper QC control of paint. batch numbers of each coat.
Individual
"B" alleged that poor quality of rework painting and QC inspection resulted in unacceptable repair painting on structural steel in the RCB.
Specific areas identified by Individual "B" are:
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at the +46 foot elevation, Columns No. 20-23 2.
at the +21 foot elevation, Columns No. 1-7.and Columns No. 9-12 and 3.
the structural steel at the bottom of the elevator shaft (the steel was not properly prepared or top coated as required).
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_llegation No. 3 A
Individual "A" alleged that all RCB dome clips were painted by painters unqualified for the type of paint being applied.
Allegation No. 4 Individual "A" alleged that the training of QC painting inspectors was, essentially, nonexistent and that answers to written test examinations were given to the examinee just prior to taking the test.
Allegation No. 5 Individuals "A" and "B" alleged that there were no mil test readings taken to determine film thickness on any of the painted surfaces of the concrete
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structures in the RCB.
Individual "A" alleged that neither Ebasco nor Sline Company had any painting specifications for painting of concrete.
In addition, he alleged that concrete floor paint is blistering and failing in many areas of the.RCB.
Allegation No. 6 Individual "B" alleged that Amercoat No. 66 paint requires thinning with Amercoat-No. 7 thinner; however, Amercoat thianer No. 6 was used without verifying with Ameron Corporation as to the compatibility of No. 6 versus No. 7.
Allegation No. 7 Individual "B" alleged that both Carboline and Ameron paints were used in the RCE without any evidence that the different types of paint were compat-ible.
Allegation No. 8 Individual ~"B" alleged that the paint on the RCB HVAC ring header contains c
sand.as a' result of poor workmanship during the painting of HVAC sections in the paint yard.
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. Allegation No. 9 Individual'"A". alleged that on numerous occasions painted miscellaneous steel was removed from the 'ainting yard " hold" area without the proper p
'QC clearance.
Allegation No. 10 Individuals "A" and "B" alleged that embeds throughout the RCB were painted without traceability of paint coatings.
Allegation No. 11 Individual "A" alleged that Level I. painting requirements call for sand-blasting steel surfaces in accordance with Cleaning Specification SSPC-SP-10; however, the QC Manager instructed Sline workmen to terminate sand-blasting in the RCB without reason or prior approval.
Allegation No. 12
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During the IE inspector's interview with Individual
"A" concerning allega-tion No. 1, Individual "A" alleged that QC documents relating to structural steel painting and generated under Ebasco Release No. 612 are additional evidence of documents replaced with falsified documents.
The specific area of structural steel, identified by Individual "A", was the structural steel framing in the areas above the steam generators.
CONCLUSIONS Allegation No. 1 Although the allegation was partially substantiated in what had occurred, the matter was identified as alleged,~ subsequently corrected and documented in accordance with Sline QA/QC program requirements.
There was no evidence of documentation falsification.
This allegation was partially substantiated.
Allegation No. 2 Although it was evident that prior problems of maintaining RCB coating trace-Lability did exist in ' August 1979, corrective action implemented in September and October of 1979 was satisfactory and acceptable to Ebasco and the licensee.
This allegation was partially substantiated.
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Allegation No. 3 Painting of the RCB dome clips was used as a qualifying application demonstration for painters and was permissible by an appr'oved procedure.
This allegation was'not~ substantiated.
Allegation No. 4 The Sline Company QC training program records reflect compliance with the Sline
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Company program requirements and the ANSI N45.2 series standards.
This. allegation could not.be substantiated.
Allegation No. 5-Sline Company QC inspection records indicate Individuals "A" and "E" appear to have been involved in a practice that they allege was improper; however, accepted at the time.
This matter remains unresolved.
Allegation No. 6 The Sline Company representatives verified the compatibility of Ameron thinners No. 6 and No. 7, on June 21, 1978.
This allegation could not be substantiated.
Allegation No. 7 Documented evidence indicates that the compatibility and use of Ameron and Carboline protective coatings were evaluated in accordance with the requirements of the ANSI standards N5.12 and N101.2 as specified in the Waterford 3 FSAR.
This-allegation could not be substantiated.
Allegation No. 8 A visual examination and a QC inspection records review of the.HVAC ring headers do not' reflect any' evidence that sand or other detrimental contaminates were entrained in the coatings during application.
This allegation could not be substantiated.
Allegation ~No. 9 Although the problem of coordinating material through the paint yard with the various contractors was a recurring problem in late 1979, the problem was properly identified and corrective: measures established in accordance with QA program requirements.
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' This allegation could not be substantiated.
' Allegation No. 10 The Sline Company QC' inspection records and documents demonstrate protective
? coating; traceability on RCB embeds.
This allegation could not be substantiated.
Allegation No. 11 The t'ermination of sandblasting in the RCB was initiated by Ebasco, by memorandum, dated November:1979.
This allegation could not be substantiated.
Allegation No. 12 It is evident that portions of the specific documents referenced by Individual
"A" are missing; however, there is no evidence to support the allegation that the remaining documents are replacement documents, nor is there any indication of alteration of the. acceptance status contained in the reports.
This allegation could not be substantiated; however, in view of the extent of missing documents, the matter will remain unresolved pending a review by the IE inspector of the resolution of the discrepancy.
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DETAILS 1.
Persons Contacted Principal Licensee Employees
- T..Gerrets, Quality. Assurance Manager
- L. Bass, Protect QA Engineer C. Chatelain, QA Engineer B. Toups, QA Engineer Technician Ebasco, Inc. Employees
- L. Stinson, Manager, Site QA Program S. Horton, QA Engineer Sline Industrial Painters, Inc. Employees R. Sline, QA Manager
- T. Sleger, Jr., QC Manager
- B. Dupuy, Project Manager B. Ward, QC Supervisor Former Sline Industrial Painters, Inc. Employees Individuals "A" and "B", former QC inspectors
- Denotes those present at the exit interview.
The IE inspectors also interviewed other licensee and contractor personnel including members of the Engineering and QA/QC staffs.
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Investigation Allegation No. 1 Individuals "A" and "B" alleged that, during the period November / December 1979, approximately fifty-five pieces of miscellaneous steel (the majority in the form of 3" x 3" x 3/8" angle iron of varying lengths) were surface cleaned, primer coated and top coated in accordance with Level II, Balance of Plant (B0P) requirements; however, approximately twenty days later, it'was realized that steel cleaning and painting should have been accomplished in accordance with Level I Reactor Containment painting requirements.
Individual "A" alleged that the QC documents, including Surface Preparation and Coating' Records (SPCRs) and Concrete Substrate and Steel Substrate Forms, were falsified in order to correct the oversight.
Individual "A" provided the IE inspectors with copies of SPCR No. 1128, dated December 31, 1979; Steel Substrate Form No. 983, dated December 29, 1979; SPCR No. 983, no date; Steel Substrate Form No. 1128, dated December 29, 1979; and three handwritten notes.
Individual "A" stated that the above documents-were copies of the.ciginal-QC inspections conducted by him and held in his~ possession. 2nd that SPCR documents, now contained in the permanent Sline QC-files bearing the'same SPCR numbers, are forgeries.
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During the' interview by the IE inspectors on April 4, 1980, Individual
"B" stated that he was one of the QC inspectors doing the QC inspection of the miscellaneous steel and the originator of the QC inspection documents
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identified and provided by Individual "A" above.
Individual "B" further stated that, after the error in painting classification requirements was discovered, the QC Manager instructed Individual "B" to restructure the inspection documents to reflect the Level I inspection requirements.
Individual "B" stated that he restructured the SPCR to the best of his recollection; however, he did not sign off the document since no mil read-ings were taken on the primer coating.
Individual "B" also stated that-the matter may have been corrected at a later date since he was not aware of the final outcome of the specific incident and that he was not aware of any " white-out" or attempted forgery.
Findings The on-site Sline QC records indicate that the specific fifty-five pieces of miscellaneous steel, representing approximately 1000 feet, were released from Fischbach & Moore (F&M) and received by Sline for protective coating application on Ebasco Release Form No. 758, dated November 16, 1979. The steel is used for hangers and supports by F&M and stamped with the identifying mark C-300.
The results of an on-site audit conducted by Sline and F&M show that only two of the fifty-five pieces have been installed.
The remaining pieces are stored in the F&M storage yard and a few pieces remain in the Sline paint yard.
The surface preparation and coating records, provided to the IE inspector by Individual "A" and alleged to be evidence of forgery, are exact duplicates of records contained in the Sline QC records file.
The documents are as follows:
SPCR No. 1128, Ebasco Release No. 758, dated December 31, 1979, signed by Individual
"B" SPCR No. 983, Ebasco Release No. 983, dated December 29, 1979;
" Steel Substrate," signed by Individual "B" SPCR No. 983, Ebasco Release No. 983, " Top Coats," no date, no signature, inspector:
Individual "B" SPCR No. 1128, Ebasco Release No. 758, " Steel Substrate,"
dated December 29, 1979, signed by Individual "B" There was no indication that the documents were altered, nor was there any evidence of " white-out" being applied.
The " comments" section delineated the oversight that the initial treatment of the steel surface was to the Level II, rather than a Level I cleaning, and that mil readings were not taken on the primer coat.
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The'Sline QC record files reflect that the above four documents were voided on January 8, 1980, and replaced with SPCR No. 1143 and SPCR No. 1144, both dated January 9,_1980, and signed by Individual "B".
This verified the statement by Individual "B" that he had restructured the original SPCR No.
1128 and No. 983' documents.
It was also observed by the IE inspector that the " comments" section contained the notation that the primer coat was acceptable with the_ exception that mil readings had not been taken prior to the. top coat application. This requirement was properly waived and approved by the cognizant Sline QA Manager and the Ebasco QC inspector.
As an additional follow up, the IE inspector, representatives of the licensee, Ebasco, and Sline conducted a visual and destructive examination of portions of the C-300 miscellaneous steel pieces located in the paint yttd.
The destructive examination consisted of removing the top paint coatings with a power grinder and hand sanding through to the primer coat. A visual examination was made of the surfaces with a 10x magnifying glass. This examination was conducted on three pieces of 3" x 3" x 3/8" steel selected at random by the IE inspector. There was no evidence of rust, lack of bond, deleterious conditions or any other evidence to suggest that the paint application was not in accordance with the related QC documentation records, SPCR No. 1143 and SPCR No. 1144.
Although the allegation was partially substantiated as to what had occurred, the matter was-identified, corrected and documented in accordance with Sline QA/QC program requirements.
No items of noncompliance or deviations were identified.
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' Allegation No. 2 Individual "A" alleged that a general condition existed where multiple i
final-paint coatings had been applied to RCB structural steel without l
traceability of paint batch numbers.
Individual "B" alleged that damaged paint surfaces, on RCB structural steel, requiring rework were not controlled and documented.
In addition, primer
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coatings applied by other suppliers were not identified or documented.
Specific areas of structural steel identified by Individual "B" are:
The +46 foct elevation, Vertical Columns, Numbers 20-23;
The +21 foot elevation, Vertical Columns No. 1-7 and No. 9-12;
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The Structural Steel at the bottom of the elevator shaft (the steel was not properly prepared or top coated as required).
Findings During the IE inspectors review of QC records and related internal correspondance regarding this allegation, the IE inspector observed that
'the-subject of the problem of RCB paint coating traceability was identified in August 1979, with specific references to the RCB structural steel.
Internal correspondence related to the subject and reviewed by the IE inspector included the following:
Memo, Ebasco to J. A. Jones; Subject:
" Application of Protective Coatings," dated August 28, 1979 Memo,'Sline QC Supervisor to Sline QA Manager; Subj ect:
" Generic Problems," dated September 21, 1979
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Memo, Ebasco to Sline; Subject:
" Minutes of October 5, 1979 Meeting," dated October 16, 1979 Memo, Sline to Ebasco; Subject:
" Corrective Action,"
dated October 24, 1979 Memo, Sline to Ebasco; Subject:
" Status Report," dated February 11, 1980 Memo, (Handwritten) Ebasco to Sline; Subject:
" Documentation for Coatings of RCB Structural Steel," dr.ted February 13, 1980 Memo, Ebasco to all Site Contractors, Subject:
" Danger to Protective Coatings," dated February 14, 1980 Ebasco Nonconforming Report No. W3-1898; dated February 12, 1980 The above correspondence clearly identifies the problems and corrective actions initiated by Sline and Ebasco in maintaining the protective coating.tracability in the RCB in compliance with ANSI N101.4, " Quality Assurance for Protective Coating Applied to Nuclear Facilities."
. The IE. inspector conducted ~a sampling review of the Slin,e QC Records file related to painted surface repairs conducted on columns and gusset plates at elevations.-4 to +21 elevations.
Specific SPCR Reports selected at random, were:
SPCR No. 1243, Ebasco Release No. 875, dated March 20, 1980 SPCR No. 1254, Ebasco Release No. 875, dated March 26, 1980
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SPCR No. 1268, Ebasco Release No. 875, dated March 14, 1980
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SPCR No.;1276, Ebasco Release No. 875, dated March 21, 1980 It was observed by the IE inspector that each inspection document contained a sketch identifying the area (s) of repair, color codes as to the status
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of repair,-primer, top coat, etc., and the related type of cleaning, inspection requirements, paint batch numbers and approvals.
This identi-fication and traceability is in compliance with ANSI N101.4, " Quality Assurance for Protective Coating Applied to Nuclear Facilities," and the traceability requirements specified by the Ebasco category schedule contain-ed in their letter of August 28, 1979.
'It was also observed by the IE inspector that the area of painting repair on structural steel at the bottom of the RCB elevator shaft "D",
as identi-fied by Individual "B", was identified by the Sline QC Manager in a Stop-Work Order and Noncomformance Report No. W3-1898, dated February 12, 1980.
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Final repair and inspection has not been accomplished as of May 2, 1980.
As an additional follow up on the allegation regarding the quality of
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painting of RCB structural steel, the IE inspector with representatives of the licensee, Ebasco, and Sline conducted a destructive / visual examina-tion of fourteen areas on the RCB structural steel painted surfaces.
The areas examined and recorded by the Sline QC Manager are as follows:
Elevation -4, Columns No 4, 5, and 7 Elevation -21, Columns No. 3, 4, and 7 Elevation -46, Steel Grating Supports Between Columns 21 & 22 (two areas)
Elevation -46, Column No. 23 and Adjacent Angle Bracing Four randonly selected areas on the structural frame above the steam generators In all cases,-the painting appeared to be well bonded with the absence of any rust or deleterious conditions that would conflict with the QC documenta-tion on application and inspection records.
No items of noncompliance or deviations were identified.
This allegation was partially substantiated, however, the problems were previouslyl identified and corrective actions implemented in September and October of 1979.
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' Allegation No. 3 Individual "A" alleged that all RCB dome attachment clips were painted by painters unqualified for the type of paint'being applied.
Findings
'At the' time of this inspection, the IE inspector found that all dome clips were being prepared for sandblasting in preparation for final primer and top coating.
In discussing this-matter with the Sline QC Manager and through review of records presented by the QC Manager, it was determined that no. painting on' dome clips was ever considered acceptable.
The clips were-initially used as the " actual service level I" components for demonstrating qualification of production painters.
The procedure is acceptable and in accordance with the approved Sline, " Qualification of Production Workers," Procedure No. 1101-8, paragraph 5.1.2.2, which states-in part, " actual service Level I work may be used for demonstration if so approved by the Quality Control Supervisor." It was further stated by the QC Supervisor and demonstrated by QC records that, since no painters were able to demonstrate a qualifying application, no dome clips were approved.
The painters who did quality, qualified on "I" beam coupons painted and the test was performed in the paint yard.
No items of noncompliance or deviations were identified.
This allegation could not be substantiated.
Allegation No. 4 Individual "A" alleged that the training of QC painting inspectors is, essentially, ncnexistent and that answers to written examinations are given to the examinee just prior to taking the examination.
Findings
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The IE inspector reviewed the training records of five Sline QC department personnel in conjunction with an overall review of the Sline orientation and training program.
It was observed by the IE inspector that an area in an adjacent trailer is provided inspection trainees for their study and training requirements.
The "QA/QC Qualification Summary" records for each individual reflects an initial 30 to 45 days full time training course prior to a specific job assignment. The training course, developed by the Sline Corporate Offices, incorporates requirements of the N45.2 series ANSI Standards; Ebasco Specification LOU 1564.734; 10 CFR 50, Appendix B; and-the principal industrial painting standards.
The training records for Individuals "A" and "B" were reviewed in detail.
It was ' observed, by the IE inspector, that both individuals met or
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exceeded the minimum training' time; requirements, with. Individual "B" certifying as a. Level I. inspector'on May 14, 1979, and subsequently certifying as a Senior inspector June 18, 1979. The training records for' Individual "A" reflect: a hire date of September 10, 1979. All training requirements for Indi7idual "A" were acknowledged by specific dates and signed by the Sline QC Supervisor. A series of three examinations were also acknowledged by the QC Supervisor with a final written examination indicated October 3, 1979, and a certification as a' Level.I, dated' October 11, 1979.
In discussing the methods employed by the Sline Company in administering the. examinations, the cognizant Sline representatives stated that answers -
to'a'given examination.are not given to the examinee prior to the written test; however, sample questions are provided the trainee in order to indicate to the trainee the type of questions that may appear on the final examination.
No items of noncompliance or deviations were identified.
The IE inspector questioned other QC inspectors, including Individual "B".
Individual "A's" allegation regarding this matter could not be substantiated.
Allegation No. 5 Individuals "A" and "B" alleged that thera e re no mil test readings taken to determine film thickness on any of the painted surfaces of the concrete structures in the RCB.
Individual "A" further alleges that neither Ebasco nor the Sline Company have painting specifications for-painting of concrete.
In addition, Individual'"A" stated that, where' concrete floors of the RCB have been painted, many areas are blistering and failing.
Findings The Ebasco Specification LOU 1564.734,- dated November 15, 1976, Section 6,
" Surface Preparation-General," delineates the general requirements for surface preparations for painting.
Paragraph 6.03, " Concrete Surfaces," specifically treats the require-ments for concrete surfaces. Section 10.1.4, " Inspection for Coating Material, Handling and ~ Application," paragraph (j) states, "take and record wet. film thickness measurements at randon, during application."
- Paragraph l' 1.5 states, "use.Nordson wet film gage in accordance with manufattare's recommendations."
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The above referenced Ebasco Specification is required reading for each of the Sline Company inspectors and is identified in their. training records.
'The'Sline'QC records / documents' indicate'that there are no painted concrete
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surfaces approved, nor have any previously been approved by the Sline QC department. -Altho'gh individual inspection reports (SPCRs) indicate u
acceptance, a QC document review, correlation and QC Manager approval is a prerequisite to the final acceptance.
-As a result of this allegation, a QC records review was initiated by the Sline QC department. The record review indicated that earlier SPCRs reflect that wet film thickness measurements were taken on a random basis; however, subsequent SPCRs (late 1979) indicate a "not applicable" (N.A.)
notation where wet film thickness measurements were to be recorded.
Specific examples of SPCRs on which this notation was made included SPCR 1086 and SPCR 1095.
SPCR 1086, Ebasco Release No. 751, with inspection dates of November 28-30, and December 5,1979, indicated the inspections were performed and accepted by Individual "A".
SPCR 1095, Ebasco Release No. 751, with inspection dates of December 4, 6, and 13, 1979, was accepted and signed by Individual "B" on December 19, 1979.
Individuals "A" and "B" appear to have been involved in a practice that they alleged was improper.
In discussing this discrepancy with the licensee ' representatives, the IE inspector was informed that the licensee will attempt to locate the former Sline QC Manager to determine why some Sline QC inspectors were recording wet film thickness measurements and others were not.
This matter is considered unresolved pending IE review of additional information to be provided by the licensee.
Allegation No. 6 Individual "B" alleged that Amercoat No. 66 paint requires thinning with Amercoat No. 7 thinner;'however, Amercoat thinner No. 6 was used without the compatibility of thinners being verified with the
' manufacturer.
Findings In discussing this allegation with the Sline QC Manager, the IE inspector was provided a copy of a telephone log, dated June 21, 1978, wherein an Ameron representative ' confirmed the compatibility of Amercoat No. 6 thinner as a suitable alternate to Amercoat No. 7 thinner for use in Amercoat No.
66 and Amercoat No. 71 paint.
In addition, the IE inspector requested and received a copy of an Ameron letter, dated May 8, 1980, addressed to the Sline Project Manager, confirming the June - 21, 1978, telephone conversation.
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No' items of noncompliance or deviations were identified.
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This' allegation could not'be substantiated.
' Al'legat' ion No.~ 7
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Individual "B" alleged that both Carboline (EZ/CZ 11) and Amercoat (90/
Phenoline 305) are used in the RCB without any evidence that the different types of paint.were compatible.
Findings The selection and schedules for protective coatings are specified by the Designer / Engineer, Ebasco, as indicated in the Ebasco Specification LOU 1564.734 and/or Ebasco Release Schedules issued by Ebasco Engineering.
In discussing this matter with the licensee representatives, the IE
- inspector was informed that the compatibility of protective coatings was a consideration in the design; and although not stated in the specifi-cation, campatibility of these specific coatings was established prior to use. The Carboline coatings are used primarily on hangers and supports,
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l with Ameron coatings making up the majority of coatings in the RCB.
In addition, the areas where Carboline and Ameron coatings interface are very limited.
In.a handwritten memorandum telefaxed to the site on May 2, 1980, the Ebasco cognizant design engineer pointed out that both the Carboline Zine 11 and EZ (Dimetcote) are inorganic zine primers and both Phenoline 305 and Amercoat No. 90 are modified phenolics of a similar generic type and confirmed that their compatibility had been established prior to use.
It was further stated that if failure did occur with an inorganic zinc
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primer, the primer would "come off" the substrate in the form of dust.
In the case of modified phenolic coatings, " curing" is in the form of a highly cross-linked thermoset Polymer.
The film of these coatings is very hard.
If coating failure occurs, the film will break up in small pieces (caused by water turbulence, etc.); therefore, there is an unlikely chance that the modified phenolic coatings _ failure or primer coat failures would clog the screens on the sump pumps, which is the principal concern.
The Waterford Unit 3 FSAR, Section 6.1.2.1, " Protective Coatings," describes the coating systems used in the RCB and commits to the requirements of ANSI standards N5.12, " Protective Coatings (paints) for the Nuclear Industry" and N101.2,
" Protective Coati.igs (paints) for light water nuclear reactor containment facilities."' The foregoing indicates evaluation of these coatings in accordance with these standards.
No items of noncompliance or deviations were identified.
The matter of the compatibility of Carboline and Ameron coatings were considered in the initial design; consequently, this allegation could not be' substantiated.
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Allegation No._8
. Individual "B"~ alleged that'the paint on the RCB HVAC ring header contains sand as a result of. poor workmanship during the painting of the ring header sections in the paint yard.
. Fi[ dings A records _ review of the inspection records (SPCRs) for the ring headers
.did not' indicate unacceptable conditions during the paint application by the various Sline inspectors. The licensee QA representatives, accompanied by an Ebasco engineering representative, conducted a complete walk-around of the installed HVAC ring header to observe the surface condition of the
' paint coating.
The_ licensee representatives stated that there is no evidence of the pai ted surfaces containing sand or other contaminates during application.
No items of noncompliance or deviations were identified.
This allegation could not be substantiated.
Allegation No. 9 Individual "B" alleged that on numerous occasions painted miscellaneous and structural steel was removed from the paint yard without the proper QC clearance.
Findings In reviewing this matter with the Sline QC representative, the IE inspector was informed that the problem of coordinating material through the paint yard with the various contractors was a recurring problem in late 1979,
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particularly with the erector of structural steel; however, the problem was_ identified and corrective measures established to further prevent material being removed from the paint yard without proper QC approval. The IE_ inspector was provided copies of correspondence which demonstrated the awareness and resolution of the problem.
The following correspondence was contained in the Sline record files relating to this matter:
Letter, Sline QC Manager to Sline QA Manager, dated September 21, 1979 Letter, Sline -QC Manager to Ebasco QA Manager, dated December 21, 1979 Nonconformance Report, W3-1797,_ dated December 18, 1979
' Quality Assurance Report, W3QA-9168; dated January 10, 1980 No11tems of noncompliance or_ deviations were identified.
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This allegation.could not be substantiated.
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Allegation No. 10 Individuals "A" and "B" alleged that steel embeds throughout the RCB have been painted without' traceability of paint coatings.
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During the1IE inspector's review of the Sline QC records regarding this allegation, the IE-inspectcr was shown:a series of structural drawings which identify all concrete steel embeds in the RCB. The drawings are used_as:a painting status control of each embed by the use of color coding each embed, in conjunction with the status of work progress and the SPCR inspection activities. The IE inspector conducted a sampling review of the embeds on the west half of the RCB secondary shield wall. The color code on the applicable drawing indicated the proper paint coating for these embeds.
Inspection records reviewed included SPCRs, dated October 2, 1979, through April 3, 1980, and encompassed numbers 955 through 1260, respectively.
No items of noncompliance or deviations were identified.
This allegation could not be substantiated.
Allegation No. 11 Individual "A" alleged that Level I painting requirements call for sand-blasting steel surfaces in accordance with the industrial standard, " Steel Structure Painting Council (SSPC) 10"; however, the QA Manager instructed Sline workman to terminate sandblasting in the RCB without reason or authority.
Findings-In discussing this matter with~the Sline representatives, the IE inspector was provided a copy of an Ebasco memorandum, dated November 1979, which-instructs the Sline Company Project Manager to terminate open air sand-blasting in the RCB due to the sensitive work related to reactor vessel internals at that time. The Sline QC Manager stated that sandblasting to the SSPC-10 specification was not resumed.
Investigation of alternate methods of surface cleaning is still under review by Sline and Ebasco engineering.
No items of. noncompliance or deviations were identified.
This allegation could not be substantiated.
Allegation No. 12
' Individual
"A" alleged that QC Documents related to structural steel paint inspection reports (SPCRs), generated under Ebasco
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-Release No.-612, are in addition to Allegation-No. 1 as' evidence of documents replaced with-falsified documents..The structural steel. identified by Individual
"A" is the steel framingLin the-area above the steam generators.
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Findings The RCB structural steel identified under Ebasco Release No.'612 includes the : steel framing structures above the steam generators which support the main steam piping.
While the'IE inspector was reviewing _the Sline QC records regarding this matter, the Sline QC Manager stated that, in early February 1980, portions
- of the-inspection records-from the Ebasco Release No. 612 folder were found Jon the' ground at'the nearby. trash dumpster. Although Sline QC inspectors were questioned,'an adequate explanation was never determined. The Sline QC Manager further stated that~a subsequent. records audit was initated to
' determine'if records'were'misring.
It is currently' estimated that at least 30% of the Ebasco-Release No. 612 SPCR documents are missing; however, a final acceptance on any portion of the protective coatings on the RCB structural steel has not been.made and the records audit is still in progress.
I This. matter has been identified and contained in Discrepancy Report No. 52, dated February.29, 1980.
.The IE inspector also conducted a sampling review of the remaining Ebasco Release No. 612 inspection records. The review included twenty SPCR reports encompassing SPCRs No. 1030, dated October 4, 1979, through No. 1195, dated
. Februa ry 10, 1980.
It was observed by the IE inspector that all but two
.of'the SPCR inspection documents were prepared and accepted by Individuals
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"A" and "B"..There-was no evidence to support the allegation that the documents.were replacement documents, nor is there any indication of altera-
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tions of the acceptance status contained in the reports.
This allegation could not be substantiated; however, in view of the missing inspection documentation, this matter will' remain unresolved pending a
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review by the IE inspector of the final corrective action and resolution of the Discrepancy Report No. 52.
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