IR 05000400/1985011

Insp Rept 50-400/85-11 on 850304-07.Violation Noted:Failure to Install Reinforcing Steel in Accordance W/Design Drawings

ML18018B930
Person / Time
Site:	Harris
Issue date:	03/29/1985
From:	Conlon T, Harris J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18018B928	List: IR 05000400/1985011 ML18018B927 ML18018B929
References
50-400-85-11, NUDOCS 8505210055
Download: ML18018B930 (20)

Text

v

'

~Q AECIJ (4

~4

oe 0O rrrr0 vo Yg~

i (L>

vp +w*w+

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323 Report NoseI 50-400/85-11 Licensee:

Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Docket NoeI 50-400 Facility Name:

Harris

Inspection Conducted:

March 4-7, 1985 Inspector:

J.

R Harris I'pproved by:

T. E.

Con on, Section C se Engineering Branch Division of Reactor Safety SUMMARY License No.:

CPPR-158 te Signed V g ea ate cygne Scope:

This special unannounced inspection involved 32 inspector-hours on site

,evaluating potential enforcement matters identified by the Construction Appraisal Team (CAT) in the areas of structural concrete and employee concerns on coatings.

Results:

One violation was identified - Failure to install reinforcing steel in accordance with design drawings, paragraph 3.

85052i0055 05000400 pDR ADOCK PDR

<<

) f >~<<~

~ ~

C"

<<<<l>

I

<<

,

> r'

""~r;>>

li

~

'

i<< i

~

f"<<>h l><<(

<<>

)c 1>)

$ p>J~)<l<,

~-,:

l

", ) ~,

li Cf i

h

<<

II Q

I "ill

- >'>>

V

<<

<<g>> "

>>

I) '<<";'>"if >)gf

<<'<<VP<<'

>>

I '>I" 4>

I',Pf <)

>'

)"

I'f Q )

<< tg )

)[)i (

II'

)

"Ij~ih C

<< i~ >',J,

<<Ii

)

<<r I>'I

@>>>,I

~

)'<< "l1I<<lf<

> <<>> 1l'l,l" P>>

> j.

'('.> )

II f lt" i <<'>I<<5+%'

ll f ii If>

i <<<<>II>"

If~,~f4'4l '$',

i '>

~['f')

'>I '<,l>

.

i

>'

" 1'

>><<half <<'

.'f ->"'>'l.J'><<>>,".,P

REPORT DETAILS Persons Contacted

~

Licensee Employees

• R. A. Watson, Vice President - Harris Nuclear Project

• R. M. Parsons, Project General Manager Completion Assurance

• E. J.

Wagner, General Manager Engineering

• N. J. Chiangi, Manager of Quality Assurance/Quality Control (QA/QC)

E.

R. Armstrong, Project Civil Discipline Manager

• A. H. Roger, Manager Construction Inspection

• D. C. Whitehead, QA Supervisor

• D. A. McGr aw, Superintendent QA

• B. Langlois, Construction Inspection Supervisor

• M. G. Wallace, Construction Specialist L. Garner, Senior Construction Specialist G. Dolderer, Coating Engineer B. Pridgen, Construction Engineer, Civil R. Taylor, Senior Coating Inspector Other licensee employees contacted included construction craftsmen, engineers, and technicians.

Other Organization

• G. F. Cole, Vice President, Daniel Construction Company NRC Resident Inspector

• R. Prevatte

• Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on March 7, 1985, with those persons indicated in paragraph above.

The inspector described the areas inspected and discussed in detail the inspection findings listed below.

No dissenting comments were received from the licensee.

Violation 400/85-11-01, Failure to install reinforcing steel in accordance with design drawings - paragraph 3.

The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio W Il

tf

'H

)H

) t))ll II P h I

HV

,'"ll) )

",

li tf "~

ll I>> H,'

tt t ft w'll

'. i ft

)

h h

I I'I 'f I')

"fl)) l

')I H

H I fIt I

t l

II H

lt )

rthl fV t"

M)

IIH)

)')II,I ))

~)t, Ml,

'

M)'Htt) I H

I tl) 'M

)

H I

CI I '

~ I H

I lt

~"

~

'"

~ I'

H It tl

~

tt

H t HM

')))

f'.'H(H H $

tl I

HHl I,) gM It l>IH I

H H )

'

')i"'

HCH)

V tf,

'M H)

I MH

)

Hlt) td IH)h

>> H~)g

')'I I

Mh ~

f,Hl'H hh t

') )

H

~

hfh H tl t

'I,

.I

"~f")

"')tHH I

I Mgltt

)

I j

t

~

I')

hll)

<

'll h,

II )"

H+

Hg

3.

Licensee Action Previous Enforcement Matters (Closed)

Unresolved Item 400/84-44-03, Installation of Reinforcing Steel in Accordance With Design.

Examination of this item showed that reinforcing steel in beam 55-L-KZ in the fuel handling building and beam 38 in the reactor auxiliary building were not installed in accordance with design drawings.

This unresolved item is closed and upgraded to Violation 400/85-11-01, Failure to install reinforcing steel in accordance with design drawings.

4.

Unresolved Items Unresolved items were not identified during the inspection.

5.

The following potential enforcement items and items of concerns were identified by the Office of Inspection and Enforcement Construction Appraisal Inspection Team (CAT).

Evaluation and resolution of these items are as follows:

a.

Potential enforcement Item - Mislocated reinforcing steel (CAT Report Page B-1, paragraph 2a.b and page V-2, paragraph 1.B.

This potential enforcement item identified by the CAT inspector indi-cated that reinforcing steel in beam 55-L-KZ in the fuel handling building and in beam 38 between line FZ and the exterior wall of the reactor auxiliary building were not installed in accordance with design drawings.

Examination of this item by the NRC Region II inspector showed that the top reinforcing steel in beam 55-L-KZ in the fuel handling building and the bottom reinforcing steel in beam 38 in the reactor auxiliary building were placed one-half to one-inch outside the tolerances specified by design drawings.

The licensee has written nonconformance report numbers NCR-84-2120 and NCR 84-2152 to address this item.

The mislocated reinforcing steel in these beams is currently being evaluated by the licensee's design engineering staff.

Nislocation of reinforcing steel in these beams was identified to the licensee as Violation 400/85-11-01, Failure to install reinforcing steel in accordance with design drawings.

b.

Concern - Additional reinforcing steel not placed in doorway opening (CAT Report page V-2, paragraph 1.b).

This concern involved placement of additional reinforcing steel in a

doorway opening at elevation 305 in the B line wall of the reactor auxiliary building.

Design drawings require that when an opening in a wall or slab interrupts the reinforcing steel in a wall or slab that the interrupted reinforcing steel be placed as additional reinforcing

I, N

K WH '(,

ll

'.,

f

"K) K ')>>

)

tv

,Of H

)) WW(i)K

'll ghv K,N (

H w

wll hfw It V I()

I Wt It

~vh "~

v

)

w h'l v'II.5 )

K IN w v ih'

~ v)f, H

Hl H IN

).w )

V) HN IIVI'll I

I Pwv t

h H')

W'

(I WW'K f>>

I Vt'v(, -

W lpt( ',

w

.

Ill(

lif w)

WH ll v w

h

~

'I-ll H

))l f'H>> W.

Nt tl)v W

lt ll w

M

'I f )

H K',

'

))

W "W'"

,)

WI'w w

/WWI>>

VH) H t<<W'<<0"Il V )

1'I

, l I v'lW h

/gl f

vt J

HWV w )

It)

"l,) H

',I l

I'KW)

Ih )'ttt&f'WP

'I f, P wl()

I~

~ Hl,4 w

N Wt~g vl I

v )

W H,PI K ),

v P y

t I

KO" "'I 'I)tll)'

.'1(W H

~ lf+

W (~

I, y

NIH w'I h ) v v/I>> l cw 'v N

ll

)

H w

vl ll Nv'I f f WPNPNN I

v t, t w g)'

o IH w"

I'ill w

~

Hvpt K

II W

('

V

'l((

W I )

~ I, IN tl V

~ LI fI,t v

,'

H, f

W II W

I I

t

'I 'll tl(

I l

I t'w K vvt W

H W

tl)

h (H ) P,WWH,"

~,

W,)

) ((H fi W

p I

$

tl t, WII, Hlt

'

w I

K

c ~

d.

steel on each side of the opening.

During the CAT inspectors'xamina-tion of this doorway opening, all of the additional reinforcing steel above the doorway had not been installed.

The Region II NRC inspector's followup of this item showed that the concrete around this doorway had not been placed and that the final inspection of the reinforcing steel by the craft supervisor, field engineers and construction inspector had not been made during the time of the CAT inspection.

The inspector's examination of this item showed that the doorway concrete placement was made after the CAT inspection and that the required additional steel was placed in accordance with design drawings.

Concern -

Honeycomb area identified in a

beam (CAT Report page V-2, paragraph 1.b).

This concern involved identification by a

CAT inspector of a honeycomb area in a

beam at elevation 216 in the reactor auxiliary building.

Subsequent chipping on this area disclosed that the bottom reinforcing steel was mislocated as discussed in paragraph 5.a.

above.

Followup of this item by the Region II NRC inspector disclosed that the licensee has an ongoing 'final inspection program for identifying defects in concrete.

Requirements for this program are specified'n Procedure TP-48.

Discussions with responsible construction inspectors, observation of ongoing work, and examination of records showed that concrete defects such as honeycomb are being identified and documented by the licensee.

Concern - FSAR proctor curves not representative of compaction controls (CAT Report page V-5, paragraph 4.b).

This concern involved Final Safety Analysis Report (FSAR) proctor curves shown by Figures 2.5.4-99 through 2.5.4-105 not being repre-sentative of compaction controls used for the backfill.

Followup of this item showed that FSAR figures 2.5.4-106 through 2.5.4-110 are the proctor curves which represent compaction curves used for the backfill.

Discussions with responsible engineers and examina-tion of documentation showed that the licensee is correcting the FSAR to reflect the correct proctor curves used in qualifying the backfill.

6.

Employee Concerns, Discussions and Findings The following employee concerns in coatings were reviewed:

a ~

Inexperienced painters and painting not being done in accordance with procedures

Ht, lfl

'NN" N ),i,,ll

~

'I tl Vi>>J lhr 1,'.p II W N

'

t N

, li

~ ) fl H

'

) W 'lh)" W II 'N f

lli )

I

~ N W

'l Pf'I '

W I'),ll 1 N

I

"h 1 IC)N

) Ill I

~ W NV I

lt N

'I PN y )f N)

4 f'h

,]

N W

,'N V

k

fN h

I,r I

N I

,ffi>> H>>

f N>>

J

~ I N

If H

IN 'HJI l r

,)'f if '

H N

N

'I" N I

N fWIH)

N h

~ N WI,I

)fi If N I'tf

[

II H

IJ I'

)I I 'tlr

~

W'

N

~

I

'f(>>p t

V IH W 11'

h p

)Nl if

~

~

HW N

II>> tl II I'l Ii

'I Htr rl I

'

~

'l H]'l

'I >>,,

I I

~ H'HN

)

N C)N 'I N

I It h ~

~

h il NN N

HW f NN.

~

'I

',H"

)

N)>>

I

)

I'

c-1

~

H tl 1 lt tl Nil H, I fl

Concern Painting being done at the plant is generally poor because of the inexperienced workers.

Painting being done in the waste process area at elevation 216 is not in accordance with application guidelines and procedures.

Discussion Investigation of this concern showed that some problems had occurred with certification records of painters.

These were identified in NRC Inspection Reports 50-400/84-10 and 50-400/

84-23.

The licensee was given two violations in this area.

In response to these violations, the licensee recertified painters and performed adhesion tests to verify the quality of coatings.

The inspector examined coatings in the waste-process building and discussed coating application methods and requirements with responsible construction inspectors.

Examination of the coatings showed that coating applications have been completed.

No adverse problems such as blistering, cracking or peeling which could develop from improper coating applications were observed.

Some minor flaking and chipping of painted surfaces due to construction damage were observed.

The construction inspectors stated that these would be repaired prior to turnover of the building for operations.

Examination of the licensee's commitments showed that the waste process building is considered a Class II service level for coating applications.

American National Standards Institute (ANSI) Standard N101.4-1972, guality Assurance for Protective Coatings Applied to Nuclear Facilities, which is endorsed by NRC Regulatory Guide 1.54, guality Assurance Requirements for Protective Coatings Applied to Water, Cooled Nuclear Power Plants, specifies the requirements for Class I and Class II service level coating applications.

Class I service level applies to,those systems and components of nuclear facilities which are essential to prevent postulated accidents which could affect the public health and safety or to mitigate the consequences of these accidents.

Class II service level applies to those systems and components of nuclear facilities which are essential to the attainment of the intended normal operating performance.

The quality assurance and/or documentation for Class II service levels is not mandatory.

Findings The waste-process building is a service level II coating area and is not considered an area where failure of coatings could affect the safety and health of the public.

Examination of coatings showed no evidence of coating failure which could result from improper application.

Some problems with painter qualifications

HM, f NMNH P

W M))

It I>>t

) I,

,wlif '.

t

>>HI M

t

'll H

r H

>>Wr Jl tf t

M HW M>I, I

),w

~,

Pill I

)W W

~

I H>> IH ~,H

'I I'I I )

M f f,f> fi,"'

I'

~

n M

'>>

~ '"'I'I M

M I" H

~

')1f

')

M)

N M...'I ll

'> )'

~

MI W

lt M HI

)

Mt

)(W i

H

. f V "'

H t

) i t g

I,lf)

]

H >I I

)

t, ',l H>>

'

$

>>

Mj

t>>

• W

~ MH>W I,WI>-0, I,'

lf>>,,l >>f l>)ll<<)W>)f

~

NI Nt

',

'

>f M

w W

I

~

H l

t W

H'W H

r.

H,l <<H)')ff, I

I

)

W tr)

f",>>

",

I', 'f '>f t I Nl II H

'li>>>

I" r

If "lf

'w M

I

)I'

)

H

~

'

$

, ). 'll,

)lr)

>

$,')

"w fl,"

))fr 'I '

t)

II Wl H~

>> I, M

t Nf>, I It,, 'I.'l t>>

lff, >

I

'I wr)

t'I>>,

'J

,HW f tl

~

IP

>p)

W P'M pl*'

f>>

">M>>

>> I ("f>

)lJf WW

"It II

+I H')

~ %) )

M t

~,

H,'WW

~ )

~ '

were identified by NRC inspectors.

Followup of this item showed that painters were requalified and that adhesion tests were made to verify the quality of coatings.

b.

Coatings on concrete surfaces used for curing are not being removed Concern (2)

Coatings on concrete surface used for curing are not being removed as required by specifications.

FCR-057 states that concrete curing only needs to be sanded prior to applying epoxy coating.

It is not believed that this position is correct.

Discussion The inspector examined Specification CAR-SH-COR-02-R2, Protective Coatings Application for Nuclear Power Plant Concrete and Steel, FCR-PC-057 and Imperial Technical Report 639-82, Adhesion of Nutec lls Over Various Concrete Curing Membranes.

Examination of Specification CAR-SH-COR-2-R2 showed that Nutec

is being applied on concrete surfaces for purposes of a form-release agent and concrete-curing compound.

Paragraph 9.6.2.1 states that glossy areas due to build up of Nutec

on the surface shall be corborundum stoned or sanded prior to application of Nutec 11.

Paragraph 9.7. 1.1 states heavy build-up resulting in a glazed effect must be removed.

Because of the apparent conflict between these two statements FCR-057 was written to clarify specification requirements.

Paragraph 9.7.1. 1 was deleted and paragraph 9.6.2. 1 was modified to include the statement that such areas may still appear glossy and feel smooth, but still be acceptable.

Examination'f FCR-057 and discussions with respon-sible coatings personnel showed that FCR-057 is only applicable to service level II and balance of plant structures.

Discussions indicated that the curing compound was removed by sand blasting in the containment building which is the only designated service level I area.

Examination of Imperial Technical Report 639-82 showed that tests were made to evaluate and compare the adhesive properties of coatings applied over the Nutec 10 concrete curing compound.

Test results showed that ten concrete samples were coated with the Nutec 10 curing compound at a film thickness to produce a gloss.

Three of the samples were sanded to reduce gloss, three were blast-swept to eliminate gloss and the remaining four received no surface preparation.

The samples wer e then coated with Nutec 11s which is the coating being applied over concrete curing compounds at the site.

After curing for seven days, the samples were tested for adhesion properties.

Test results showed that the coated samples exceeded the 200 psi minimum adhesion criterion

i)-'>c'8 ).'19'i)

?if(

>>

"

'IJ'I'l0ifbi,"'>0 9'> Ill,)>('ti'I yC},J9f fl'+i('ll)I'"(I;I 1"4~(>c>I

'~'"c'0 2JP9I

'1>> 2 >fit)b fb;,IJ

~c> I)I'i< > "> c) 31 9 >03".c"'3 1 "IiO 06 I

>>

. 2P(l Id 9>3 )

')

";,> f II> >,I

'3 I >

(t I "197 i),V;)19'1 Oui)

J

9')f> p II'"I'I>

<<0 t)97"J

~ cac>

>U

~r.:I'" )9>),c f>9 Pc) Ic J>>.>0

.(J f)~9 )9 ) )

) rI>>.-;>

I frf)f3c(

g Jcc

.) II'lfc, c )

>c)w f)c)2)I

~~3'> "'IUc'09"19'c>r 'c() Qp'li p">(3.3

'<<'()-Ã9

.J,rr160r",~).1~7 y

$

b~

i>J>SW

.:<<I)if>>') cr.'Ofl">

t() III >tl.>> '6 9.

"I.>r'13

)3 t.>"IGC

0."

2i '>1 Pf~ 3 'V"IUO

.:..>>aaO~

al 0)))i..O~ "rrlf ~3,')9V:)f')~ t9>>i,-.!

>I 3~

2402 f(l c'P )

95(rI1 c" )-

3 0

" Ic "'r'f3 >)OI i <<)f f'39q?

Ic> ca)(3 391 ) I, fci

'>flT

. t. )0?

'> Ic> ~.f-)oaf)u'll;ll a9;;e",

.I = I",N'(I;

~ )l)IOrl'<~]3;p)IDIO'.I

')'29('.13%, '. >)C(J

!a",'-1 fl'. '<Ra).'fa:qlli I).

~ 0-.')'l-U',

"I t'll

~ "3 I>;;", JcJ Jgg I..-.),Ie i If>1 g I c'

2L f

>>41.",, +G.i"

!

"r>,(ia >8->-~, )3-HR-1"-

I ',)if~3ftf" "t8 cO

~c?t 'I>f>6Ã3

- >.'7(rl

) "9>0"">U'3 c)

230I> li'>U..> I'3'(.)IIl),r i; 3

" ")f f(ccqr.

cl

> 'l 2i

~

> ~ (3 ~ c

>I '

19m> lf>

N

~ 0'cc (c III03

)>III I 'l )"'I)c)" 3 ':.c iIII> 3 II >,a.~

'> c.">

", fg"I gf

>~<<r)la>

c '1 ( II 6'j fIJ4 p )

c" >h 75'>'cr

~ ~>2>) f p r r>c)

>

)'g 9>j7 1 3> ">Jf lqq

>

)1 >Of f~ "))')~c>c" "0 Ir rIIJJ ~

",Ilii>AU")'4S )"

I>>.

I

$ f>feed a3'>3 f!19

'<<r pa,'"',>'IJ<;1 q(r-i)[fIJ~

~VAPO) 79r>2 t.$.3. r J;c,~nf'a( 9,.'c."

g>3U',c 't; a.)

>

> ~~()')

<<'~')I i,t")Ic "<<IZ

~ 0 I '>" >0 I)9>r 3 I )~

crcJ JPIl,il r )->++~~~

>c'JK'>f )

I>

3>' f I. f 3

>i

'1~4 >'" IIV

'I>Ã RVQ" 3 r 713'fl9il>)"

.)>V>>

829f/z II. "Vtc)'I

~

." (rs>Ol~'>,;IV f..'.3 ';c( ",Sl ')

.'l>>-:,'I <<Si 13:I".

>IOI.. a.i;9q7

>l)c>2 'tfi"Ii) 'I>19~'&Jbrc'.

~,'l f

.I") llD>1i 9i

>>.-r tlat)O>c

~ b"..'>.(J.P fi"[I>'I'r'~1>>(I Jg

) f f

> '

J~

c I J >v'"Ic> t99t

> I

>

",~2>)~ f)

)b 'gg'5

" I f J2

'c"'l i>>>0cf>

-OO>> <>>

Iaf)

Z(I t r..>IO;ih,"i= c,

~; I>J-)IJ= =0,,)'-)bflr<<r,'0

. >>db~q". 1.

1.; 9l".

a >'q" V,fa9 f V:8-4J-I I, h~)@III. f 3 >V,J I. II

..c..fdr rf72'JDc H3

.2'U4'34'I.', c!

.3",i') 10

>0

> r> 6d Jfl&

N

)'l') I

< r)V I>)"

<Ii 9 l

IJ /(i,>,ii)>2 ',r'r>J'3>119'1 2>i';J

.)>100g>>103 rill "'I" )

"PH I 0'i"t

. >dvbi J>l f bbJ411;>f '.'.3 Vl(IO ~~c'".,'.I (l3fAid (>"lf )(i>JV:lhlcr I

'r>8110;)

<<,

) r; ).

7t"')'l f ~

c crV.,A2

-. '-',f.~,>> +1(3""'f,'(c'rlfrfl09i I "r<<">.">It

~; )

I.>>$ >;II> ~I&)(]

> pig'jc)fg>>

((

ctr I'p')f4)>t

>rl, J 'll <<jill'JJ kg

'>

3+9>IJ t I>>J "'~,r.

) )fr>II

.bc I."Ofl,'.10~ 'qf 'I,~ ca>930 >~~ f)f g9+II""

lrl~ "IVVO;r)><<(I>."> ecflr$ ;.3 c

c)fli

cc

<<QWfi(39

"~ "cr $

c> ) lg>III.i c 9v )r>>3'3 PP>'~

<P l)9)all'r" c 7 kfIJ29'I

~ ~c.Of/ v a'r I"f)"(<<.t ~~,'3'>':)illa',lif '> '>.,'> U'.""l'I>)') "ll i >Up 3>

• )'c '3'c~r ccci"cfl<,-,',) I p c),r(, -.

>3 I'195>f>b'I"I c~'...' (ti>4>~')'(i tA c>c)NUT 0'))r," ~ca IU;)I';J ill)SVP'I r rl'. c>

~20f" r'., I>IIlifa "3'; >W2-0;".>>I

."

3') >

I>r> fI3 iW IJ",> J>')')

c> )I>>'r 4 >v)

."'. I q I (

-

If AQi4'

>, 1'3(l

.'>Of>f 1>I,'.">iIIJ Ji~

I. ) t)fli c>1>> "-> ~ "=>'>Or

'IZV I

...1 f90$If c (J nfl fZc> y'3

) I >

7i f(3 i'I.'c 0 I.I>l

> > t (fill/>

') ~"

c 2'/fry rip<")c~

I 8')r'1 f'IU,)

I.JJ ij(

~

l > I

~

)cI'i

~ f>

,fb

.Ib>I I)OW0(I7

.';,>>~a'I O29<

. >.)J.'"ea(n.)

fl > I -I )'fi f~

r>')f'cr I,)f>

c> I;If 1) Ill r $ f)pC,)f;<

L)yg'r q'.>)(<" g,";I'I)re~

Q ), bc) I

(3)

established by ANSI N5.12, Protective Coatings (Paints) for the Nuclear Industry.

Findings Examination of Specification CAR-SH-COR-02-R2 showed that there were some conflicting statements in the specification regarding the removal of coatings used for curing compounds on concrete surfaces.

FCR-057 was written to clarify the specification and the requirement to remove concrete curing compounds in service level

areas (non-safety-related coating areas)

was deleted.

Responsible coatings inspectors and coatings engineers stated that curing compounds in service level I areas were removed by sand blasting.

Examination of tests performed on coatings applied over concrete surfaces on which the curing compound was not removed showed that the adhesion properties of the coatings were not affected by the concrete-curing compound.

Based on the above, it is considered that the licensee's position that it is not necessary to remove concrete curing compounds is correct.

Power tooling for surface preparation of steel surfaces Concern (2)

Specifications limit the use of power tooling for surface prepara-tion on steel to one square foot.

FCRs have been written to delete limits on surface area preparation with power tooling.

Power tooling causes smooth surfaces on steel and thus affects adhesion properties.

Discussion The inspector examined specification CAR-SH-COR-03, Protective Coating Materials and Application for Nuclear Power Plants Structural Steel, FCR-PC-129 and Imperial Technical Report 612-82, DBA Nutec 6/1201, Nutec 1201/1201 Applied Over SSPC-SPR-3 (Power Tooled)

Prepared Steel.

The inspector also examined coatings in the containment building.

Paragraph 4.2.5, on page 13, of Specification. CAR-SH-COR-03 states that the field may power tool clean defective areas of one square foot or less to remove all loose coating and contaminants.

The Specification also states that areas larger than one square foot shall be sandblasted to achieve the degree of cleanliness and anchor pattern as originally specified.

Examination of FCR-PC-129 showed that this FCR was written to clarify the extent to which power-tool cleaning can be used for preparation of steel surfaces.

The FCR states that the intent of the one square foot area limit is to avoid large areas of repair where both dimensions exceed one foot.

The area repaired by power-tool cleaning may exceed 144 square inches when such areas are long and narrow such that only one dimension exceeds one foot.

Examples of such areas are, but

<< I I

I~

lt Ih

~

lf il

~ ) I) Ni I

<<f)N'g w

'l,l P

III

, '))+iip>

~" Ci(ttt)

1 1

) r r

i NN I",I r Itl gf"

'1 f<< 1

~

I','l

'V II fh I

II<<gh ),

lit)

Ir<<

c

<<I I I)

$

~

" I.i it)

ltf'f

~ ft N

1'1 0 hd II II 1 4 lh ~

)

t i

I" I

pi

'4

~

W

<<V

h it I ),

~

I tt<<N )I I

',NI <.I

-

I a

I

~

'

i

)

I

'

4,"

',<<1""

N W

~

g

,,

II

" '1 I II f I't

~ 4

)

P,W<<hit r

1

.III I',I

I

'l

)4

)4<<P.

I ~ ri

<<

. ~

~)"

""'I

'I

<<4 t)IN lii

, 'll'

i.

LJ"'ll Nli,

)

NI I

)

-~N

~

N.

t,

~ Nhl

~ rt 1 lg 4 I I << '

$ r" ','t,lil I li

,4)) 4, tl I

IC I li

)

~

lr)- =,

V II

,)

r v

~ l N

'N')

II'll I. 'l

I I tl N 'I

) 'c I

Wit lt

)

s)()

<4)

4 '

(3)

not limited to, weld seams and long scrapes or scratches which damage the coatings.

Examinations of Imperial Technical Report 612-82 showed that Design Base Accident (DBA) tests were run on steel panels that were cleaned by power tooling and subsequently coated with the Nutec coatings used at the Harris site.

The tests were run because it was recognized that sandblasting is not always feasible and, in some cases, power tooling would be required to clean the steel.

Testing showed the panels were exposed for two weeks to induce rusting.

The rusted panels were then power-tool cleaned to a bright metal surface and then coated with Nutec coatings.

The coated panels were then submitted for DBA testing.

All panels exceeded the acceptance requirements of ANSI N101.2 for DBA testing.

Examination of coatings in the containment building showed no evidence of adhesion failure.

Some damage to existing surfaces due to ongoing construction activities were observed.

Discussions with responsible inspectors indicated that damaged coating surfaces would be repaired prior

. to turnover of the plant for operations.

Findings Specification CAR-SH-COR-03 does state that power tooling of steel surfaces is to be limited to one square foot.

FCR-PC-129 was written to modify and clarify the specification to allow. power tooling of long narrow strips.

The DBA tests showed that Nutec coatings used at the site achieve adequate adhesion over a power-tool cleaned surface.

Examination of surface coatings in the containment building showed 'no evidence of adhesion problems.

It is concluded that power tooling methods being used at the site are in accordance with referenced acceptance criteria.

d.

Overspray, Embedded Particles, Orange Peel, Runs and Sags on Coatings Concern (2)

Specification CAR-SH-COR-03 states that dry overspray, embedded particles, orange peel, runs and sags shall not be permitted.

FCR 119 was written to modify acceptance criteria of these defects.

This is contrary to ANSI standards and no testing was done to substantiate this FCR modification.

Discussion The inspector examined applicable portions of CAR-SH-COR-03, Protective Coatings Materials and Applications for Nuclear Power Plant - Structural Steel and FCR 119.

Examination of Specifica-tion CAR-SH-COR-3 showed that the specification states that orange

"4'14 ""

it(

If 3 lilt

tfl J) H45 ilf4 II c

lf f

, i'

'I I')

)4 i

Hfil

I 4,4 4 flip ( t't,i II r.f)))

(4

<4

~ "II

I'l)44 I tl

)4

~fif

~ 4 l

I I g

'jl t(yc '

)'llf (, H'4<)

4(')) Il "I II HI I)'

, 41 If)

(I )

rl" '"

ll

' Il,f II) IT

~ 4 4')

Ii, 4 q j 4(.

44=,,f IL) 4 l c."

)

it 4H(ll VH 3)r

.>> )4',

, >()

)4 IH Ill 44 f Il

~ t II

I, 4 ~

),

4 >(ti)H, I ('I",;

i 4',

II i

I

~ IIII i 4,

HI r

L'i P I

4 I

ii H(H(W (

ri) 'i JH ti I

)t J

I

Hf) 1 f \\),

4'Er

r 14 tt.

'4 Hi )

r

'4 tf Hg, I'I H

It

"t)r

4

~ JH HI '.;I Hi f ( I i'll

'I I4 5

)4 4(

,c If

'

4 4 li,tr

"4,~

I

H'='ll

4

)'

H) 44

peel (pebbled surface on spray applied coating)

is generally acceptable; dry overspray (rough, sandy surface on spray applied coating)

shall not be permitted; acceptability of runs and sags (V or U-shaped buildups on the surface)

shall be determined by comparison with panels illustrating these defects; and embedded particles (dust particles such as blasting abrasives and other foreign materials)

shall not be permitted.

The specification also states that inspection items such as orange peel, runs and sags, dry overspray, and embedded particles that may be subject to judgement may be discussed as necessary during a prestart-up meeting with representatives from Carolina Power and Light (CPSL's)

guality Assurance Department, CPSL's Construction and Engineering Departments, EBASCO's Engineering Department, Applicator and Coating Inspector.

Examination of FCR-PC-119 disclosed that this FCR was written because of the apparent conflict between the above specification statements and because there was no documentation of a startup meeting addressing the above areas that may be subject to judge-ment.

Because acceptable toler ances for orange peel, runs and sags, overspray and embedded particles could not be clearly defined on paper, FCR-PC-119 required panels to be prepared showing acceptable and unacceptable examples of the above items.

Investigations by this inspector showed that the panels were prepared and that the panels are being used as a visual inspection reference and for inspection training.

Review of the FCR also showed that the following modifications were made to the specifi-cation to clarify the specification conflict:

Embedded particles on the substrate (uncoated surface to which a coating is to be applied)

can trap moisture and may prevent a continuous bond between the paint film and the substrate and thus are not acceptable.

Embedded particles in the paint film are not in contact with the bare substrate and therefore cannot wick moisture to the substrate.

These types of embedded particles only pose a problem from an aesthetic viewpoint.

However, gross amounts of embedded particles are not desirable and may compromise a film's integrity.

Panels 1-8 show acceptable embedded particles.

Panels 9-11 show unacceptable embedded particles.

Overspray consists of wet overspray where the paint bonds to the surface and dry overspray consists of dry particles which do not adhere to a surface.

Dry overspray should be removed prior to application of subsequent coats.

Dry overspray on a

topcoated surface will not affect the integrity of the coating film and shall generally be acceptable.

Panels

and 2 show examples of wet overspra N 1>>

~

N C

~

p I

IC)

h h

~ ) ")p)

C C

tl VJ w

PC If F ~, u 1<<C I)

r <<14 Ilf C

I H P

J

'

C frp lr

) wp Il lr II I'

F I

w w

IV h

' I'l PP ~

II

'

>>

vff I

\\, )

<<tl"

'v

'I V ),",I

Il 8')')>>p<<1 r,

il lh)

4>>

'1 It,,

1)1 I

H I'1l '", }

)

<<Jt I'>)p

)v'pf" Iw

" )Jf)1 r

Pl, (y" I)

H )ff) <<II s.ll '>>C 'U '"

111

)I,, I, P

tl C

blf ff1

h

I 'l w

I'<<1

"IP"I, hw t

XFH

PI Iu

h(

,I ~

P'Ill<<

'

I

"'I C

II t) I

~)

<)"I I II, C '

w W I w

'it 111)tl,

'td

<<1f<<f W

)

<<

I )

<<'l p

I)

~ 'l f Pt'g v

H

"<<Il I Ill fC

)

I'l

IJ

<<,

t

>)JC I

II I<<

Xb

hl uf glf

>>

F>>

hi I

>>1

..v" p'f r

I

)

)

)I I

v li

~ v

'II)f pl P I,"'t, w

tl

<<HII h

I'I I

tl

Orange peel, an uneven texture similar to an orange, is generally 'acceptable.

Panels 1 and 2 show acceptable orange peel.

Panel 3 shows unacceptable orange peel.

Runs and sags are caused by too much material in one place or application of a coat before the prior coat has had a chance to set.

Runs and sags in service level 1 areas shall not exceed dry film thickness limits and must pass a test where a

two inch or larger putty knife does not dig into the run or sag when passed over the run or sag.

Panels 1-4 show acceptable runs or sags.

Panel 5 shows an unacceptable run or sag.

Discussions with responsible coating inspectors and engineers disclosed that in addition to the above clarifications listed in FCR-119, Procedure TP-65, Coatings Walkdown Inspection, was issued in December 1984, to provide for a final walkdown and inspection of coatings which will be made prior to turnover of the plant to operations.

Examination of this procedure showed that the procedure covers methods to be used for performing walkdown inspections of coatings and identification and correction of existing defects.

(3)

Findings Specification CAR-SH-COR-03 does not state that orange peel and runs or sags are unacceptable.

The specification does state that embedded particles and dry overspray shall not be permitted.

The specification also stated that items such as orange peel, dry overspray, embedded particles, and runs or sags that may be subject to judgement may be discussed as deemed necessary during a

prestartup meeting with responsible parties.

FCR-119 was written to clarify the apparent specification conflict and to provide clarification and guidance for inspection of the items of concern.

In addition, panels were prepared showing acceptable and unacceptable levels of the items of concern.

These panels are being used both for training and inspection.

Procedure TP-65 has been prepared to provide for a walkdown inspection of coatings to be performed prior to the final turnover which will cover coating completeness and damage.

Examination of coatings in the contain-ment building and results of adhesion tests showed no evidence of adhesion failure.

Examination of this item indicated that the licensee took proper measures in clarifying specification require-ment it h

)Ht It H

Ihtf VI'I N

I H

J'lh

~

lt ll ~,

h H

1 H F

I I'

'I'l V F

A Hhi

,I

> 'V)

Vi h

h h',I)

H y.

H FH tl tt fhj H

h hh Hl

)

hi h

g)kl'.) ') 'I h Hh Hfl ) g

'F HL HH II

~

I I

HV Ell

,h k I

'lF h

h

'V.

I I '

tv) fgi h tl i).>

lt tl

)

Hlhv h

Il, ~

PQ

)F ll,l)k 'f tl

'I

'I hf/ ) ')I

~

) 'tf h.

P

>)'f)

hFI F thil', )

F I 't)l I

.

It

)"'f i

)

tf=

'

')

HH W

hvar

~

I

)") i,

Il W

~

\\

Il)

I

)

jihad j

ll )

~ 'h yh

) "'>

II a)

ttg H

Htllt.lh

) ',,

h ') )t'h "'

~

I

,

~ ) h'))

H)f>

I I h C't(), f'g tl

~ *I

)

h

'

t tl III p

tt Ilia

'

)

I

"

L h

1