IR 05000424/1986026
| ML20197A654 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/09/1986 |
| From: | Conlon T, Novak T, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20197A573 | List: |
| References | |
| 50-424-86-26, NUDOCS 8610270359 | |
| Download: ML20197A654 (29) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION y , ' REGION ll
< C 101 MARIETTA STREET, E E . ATLANTA, GEORGI A 30323
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Report No.: 50-424/86-26
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Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No.: CPPR-108 Facility Name: Vogtle 1 Reviews Conducted: April 14 - August 1,1986 Onsite Inspections Conducted: April 14-18, May 5-9, June 9-13, June 30 - July 3, and July 28 - August 1, 1986 Inspectors: J. R. Harris, Reactor Inspector, Region II J. J. Lenahan, Reactor Inspector, Region II Reviewer: J. Wing, N Approved by - W' h /O M T. E. Conlon, Chief Date Signed Plant Systems Section
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L DivisionoflRactorSafety, Region 11ml/Le a,%a& &
T. Royak, Chief (Module - Seftion 3.0 - 3.4) Data Signed Deputy Director y Division of PWR Licensing A Office of Nuclear Reactor Regulation (NRR)
Y M. V. SinEQle, Chief LL - n /0 %-
Dpe' Signed Projects Section 3C Division of Reactor Proje ts 8610270359 861017 PDR ADOCK 05000424 G PDR
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SUMMARY The Readiness Review is being conducted at the initiative of Georgia Power Company (GPC) Management to assure that all design, construction and operational commitments have been properly identified and implemented at the Vogtle Electric Generating Plant Unit 1. Module 13B which is the eleventh module submitted by Georgia Power Company presents an assessment of the design and construction activities associated with protective coatings for the Vogtle Electric Generating Plan Unit 1. This evaluation was conducted to determine if the results of the program review for coatings presented in this module are an effective and accurate assessment of design and construction requirements, that these requirements are being properly implemented, and that the resolutions of findings identified in the module were correct and that the corrections were mad This evaluation was performed by NRC a reviewer from the Office of Nuclear Reactor Regulation (NRR), and inspectors from Region I Th'is evaluation was accomplished through a detailed review of all sections of the module by:
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Verifying that design and construction commitments listed in the module are correct and comply with FSAR commitments and regulatory requirement Reviewing the module findings and evaluating the correctness of their resolutio Reviewing a comprehensive and representative sample of the records reviewed by the Readiness Review Staff and an independent sample of documents selected by the inspector Walkdown observation of construction activitie During the review, it was apparent to the NRC reviewer and inspectors that GPC management supported the program by active participation in the development and implementation of the progra This evaluation also indicates that the licensee's program review for coatings was comprehensive and provides adequate assurance that the coatings have been designed and applied in accordance with NRC requirements and FSAR commitment No findings were identified during the review of this module, iii
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1. Scope of Review This review which consisted of an examination of each section of the module, was performed by a reviewer from NRR and inspectors from the NRC Region II office in Atlanta. Module Sections 1.0, 2.0, 4.0, 5.0 and 8.0 which contain information concerning the module introduction, company organization, program description, audits and special investigations, and conclusions regarding the assessment of the module, did not require as detailed a review or evaluation as the remaining section The more significant aspects of the module appear in Sections 3.0, 6.0 and These sections discuss licensee commitments, methods of implementing commitments, methods of design and construction program verification and results of an independent design review. Review of these sections included a detailed review of the content, examination of items identified as findings, an examination of a sample of records reviewed by the GPC Readiness Review Staff and an examination of an independently selected sample of records. Methodology used for this review and an evaluation of each section are presented in the following paragraph . Methodology The review and evaluation by NRR which focused on Section 3.4, Commitment Matrix, was conducted in the Bethesda office. The review consisted of a comparison of the commitments listed in Section 3.4 with the guidance contained in the Standard Review Plan (SRP) and other regulatory documents (SER, FSAR and Generic Letters). Commitments were also reviewed to ensure that all commitments necessitated by the Standard Review Plan were included in the modul The review and evaluation by Region II inspectors was accomplished by reviewing the module in its entirety in the Atlanta Regional Office beginning on March 4, 1986, and by inspections at the Vogtle site on April 14-18, May 5-9, June 9-13, June 30 - July 3, and July 28 - August 1, 198 Section 1.0, Introduction which presents an introduction to the intent and content of the module and Section 2.0, Organization and Division of Responsibility, which presents a description of the organization and responsibility for design and application of coatings, were reviewed for general content and needed background dat Review of Section 3.0, Commitments, was accomplished by. examining the Commitment and Implementation Matrices and by verifying that the applicable commitments were implemented. Verification that the applicable commitments were referenced and implemented was accomplished by reviewing the FSAR, SER, specifications, procedures, regulatory guides, applicable industry standards and responses to NRC generic letter Review of Section 4.0, Program Description was accomplished by examining the four subsections and comparing the described work processes used by design and construction with FSAR, specification, and procedure requirements. The inspectors also compared the described work processes with the understanding of program requirements that were examined during inspection of coatings conducted during the review of this modul % 0
Review of Section 5.0, Audits and Special Investigations, was accomplished by examining the two subsections, and reviewing the referenced audits and findings identified in Subsection 5.1 and 5.2. Region II inspection reports were also reviewed to verify that the identified NRC findings had been properly addressed by the license Review of Section 6.0, Program Verification, was accomplished by reviewing Subsections 6.1, Design Program Verification and 6.2, Construction Program Verification. Review of Subsection 6.1, Design Program Verification, included a review of the referenced design criteria, design comitments, specifications, deviation reports, and the two findings identified by the Readiness Review Staff which involved concerns with purchase specifications and FCR approva Review of Subsection 6.2, Construction Program Verification, included a review of referenced licensing requirements and commitments, the nine findings identified by the Readiness Review Staff and associated corrective actions, and pertinent records for the preparation, application and inspection of coating Review of Section 7.0, Independent Design Review, was accomplished by reviewing FSAR requirements, specifications and procedures, deviation reports, design test data, and the nine findings identified by the Independent Design Review Staff and their associated corrective action Review of Section 8.0, Program Assessment / Conclusions, was prir.irily for content and background information. Evaluation of this section was effectively accomplished during review of the other module section . Evaluations The evaluation of each section reviewed is provided below. For each section, a description of the section that was reviewed, and the basis of acceptance is provided, Section 1.0 - Introduction This section of the module presents an introduction to the intent and content of the module organization, areas of evaluation, and status of the projec This section was reviewed primarily for content and background information. No additional followup or evaluation of the section was required, Section 2.0 - Organization and Division of Responsibility This section presents a description of the organization and division of responsibility of Georgia Power Company, Bechtel Power Corporation, and William Contracting Inc. for design and construction activities related to coatings. This section of the module was reviewed for content onl No additional followup or evaluation of this section was require . .
c. Section 3.0 - Comitments (1) This section contains a listing of comitments and implementing documents which are presented in two matrices. The first matrix is the Comitment Matrix which contains a listing of the s'ources and subject of licensee comitments. Comitments listed in this matrix were identified by the Readiness Review Staff through a review of the FSAR, responses to NRC questions, Generic Letters, and I&E bulletin The second matrix is the Implementation Matrix which contains a listing of documents and features discussed in the FSAR and implementing document The Readiness Review Staff reviewed these documents to verify compliance with the comitment requirement (2) The NRR reviewer and Region II inspectors review and evaluation of this section was performed by comparing licensing comitments and corresponding source documents with the Standard Review Plan (SRP), the NRC Regulatory Guides, the provisions of industry
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standards, the staffs SER, Generic Letters and the FSAR. The review also included an examination of comitment sources and implementing procedures and specifications to verify that the FSAR comitments were being properly implemented and that all comitments necessitated by the Standard Review Plan were included in the Readiness Review Progra (3) Review of this section showed that the Vogtle licensing omitments and implementing documents for the protective coating stems comply with the requirements of the FSAR, SRP, Regulatory G ides, industry standards and a letter from C. J. Heltemes, Jr.,
J NRC to C. Eicheldinger, Westinghouse Electric Corporation, '
"Results of Westinghouse Letter on Regulatory Guide 1.54,"
April 27, 197 Review of Comitment Number 3919 by an NRR reviewer did result in a question regarding the use of inorganic zinc coatings applied to
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the interior surface of the emergency diesel generator fuel oil
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storage tank NRC Inspection and Enforcement Circular Number 77-15 is concerned with the presence of zine in fuel oil, which can accelerate certain processes detrimental to the performance of the diesel generator. As a result of this concern, Bechtel Engineering Corporation along with the coating manufacturer Ameron, made recomendations regarding maintenance and surveillance requirements for the fuel oi These recommendations which call for sampling the fuel oil in each tank i quarterly and sending the samples to a qualified offsite laboratory for analysis are to be incorporated into Vogtle Procedure 30080, Diesel Fuel Chemistry Contro No NRC findings were identified during the review of this sectio !
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d. Section 4.0 - Program Description (1) This section of the module, which is divided into four
, subsections, describes work processes utilized by design and construction for coatings at Vogtle Unit Subsection 4.1, Design Architecture Engineering, describes the architectural /
engineering scope, workflow, documentation, and design control activities related to coatings utilized on plant structures, components, and equipmen Subsection 4.2, Coating Materials, discusses development and control of specifications for coatings, Supplier Quality Surveillance Verification Programs, supplier quality verification documentation and deviations, and receipt inspection and storage of coating material This section also includes a table with a partial list of specifications for items inside containment. Subsection 4.3 contais,> a description of the project programs for training and qualification of the AE design engineers, Georgia Power Company construction engineers, and contractor staff, craft and inspector Subsection 4.4, Preparation, Application, and Inspection; contains a description; flow chart; and list of procedures and specifications applicable to preparation; application; and inspection work relevant to Module 13 (2) Review of this section included a detailed examination of the four subsections and a comparison of the program description with FSAR requirements, and specification and procedure requirements. The described program was also compared with the inspectors understanding of program requirements inspected against and reported in NRC Inspection Report Nos. 50-424/86-36 and 50-425/86-1 (3) Review of this section indicated that the program described in the subsections is in accordance with the NRC inspectors' understanding of the work processes used by design and construction for coatings at the Vogtle Plant. No NRC findings were identified during the review of this sectio e. Section 5.0 - Audits and Special Investigations (1) This section, which is divided into two subsections, contains a discussion of the QA audit process, NRC inspections, and special evaluations by INPO and a self-initiated inspection tea Subsection 5.1, QA Audits of Design, contains a discussion of audits pertaining to design. Subsection 5.2, Construction Audits, contains a discussion of audits related to construction. These subsections discuss organizations, programs, investigations, evaluations, and audits and list audit findings that are applicable to coating . .
(2) Review of this section included a review of the two subsections, the referenced audits and associated audit findings and their corrective actions, the referenced NRC reports and findings, and the referenced special evaluations by INP0 and non-project senior technical management personnel from Georgia Power Company. Review of the referenced audits showed that the GPC QA Department has conducted 17 audits that addressed the design aspects of coatings and 22 audits that addressed the construction aspects of coating These audits resulted in 34 findings being identified by the GPC QA auditors. Review of these findings showed that they involved omissions in the coating supplier,s procedures and QA manual, inconsistencies in complying with Regulatory Guides, and deficiencies in coating materials, application, inspection, training, testing, document control and QA record Review of the resolution of these GPC audit findings showed that the audit process had been controlled in accordance with FSAR requirements and that proper measures were being taken to correct the deficiencies identified by the QA auditor Review of the two NRC inspections of coatings which are reported in NRC inspection reports 50-424/84-14 and 50-424/84-27 disclosed that deficiencies in the Williams' coating procedures were identified by the NRC inspecto This was identified as unresolved item 50-424, 425/84-27-01, Adequacy of Coating Contractor QC Inspection and Application Procedures. Review of the GPC QA Audits showed that the same deficiencies had also been identified by GPC QA auditors. During the review of this module, the inspector reviewed William's procedures and QA manual to verify that these deficiencies had been correcte The review showed that the procedures had been corrected to meet the requirements of 10 CFR 50, Appendix %
3 (3) Review of this section indicated that it is an accurate presentation of the audit process and previously identified construction and design problems and NRC inspection result No additional NRC findings were identified during the review of this sectio f. Section 6.0 - Program Verification (1) This section discusses methods used to verify conformance to design and construction requirements. This section is divided into subsections 6.1 and 6.2. Subsection 6.1, Design Program Verification, covers activities related to the design program verificatio The design program verification was covered in two phase Phase I consisted of verifying that licensing commitments identified in this module were implemented in design
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criteria and design documents (i.e., specifications and drawings).
Phase 11 consisted of a review of design documents for compliance with applicabla procedures. The assessment of the Design Program Verification resulted in two findings being identified by the Readiness Review Staf These involved irregularities in specifications and field change requests (FCRs). Subsection 6.2, Construction, covers activities related to the construction program for the application of field coatings. The assessment of this aspect of the coatings by the Readiness Review Staff was done by reviewing implementation of commitments and construction activitie Review of commitment implementation was accomplished by identi fying and reviewing the project documents that implemented the commitments. The assessment of construction activities was accomplished by a technical review of construction records and a walkdown inspection of coated hardware. Nine findings were identified by the Readiness Review Staff during the review of the construction program for coatings. One of the findings was identified during review of commitment implementation and the other eight findings were identified during review of the construction activitie (2) Review of Section 6.0 by Region II inspectors included a review of the program verification activities listed in subsections 6.1 and 6.2 and resolution of the findings identified by the Readinass Review Staff. Details of the reviews of these subsections are discussed in the following paragraph (a) Review of Subsection 6.1 showed that this subsection focused on the programmatic aspects of design to verify that design documents were implementing licensing commitment (Engineering design calculations typical to other design items are not part of the design program for coatings). Review and verification that Subsection 6.1 was an accurate assessment of the programmatic aspects of design was accomplished by reviewing the commitments listed in FSAR Sections 1.9, 5.4.1, 6.1.2.1, 8.3.1.1.3 and 9.5.4.2.1.4, and verifying that these commitments were implemented in Design Criteria DC-1000-C, General Design Criteria (Civil Structural),
DC-1000-A, General Design Criteria, and in procurement and construction specification Deviation reports and Field Change Requests (FCRs) were also reviewed to verify that they were properly dispositioned. The Region II inspectors also reviewed the findings identified by the Readiness Review Staff to verify that these findings were properly resolve Review of these findings identified by the Readiness Review Staff and the corrective actions associated with the resolution of these findings are as follows.
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1) Finding 138-20 During review of seven materials specifications issued for purchase of equipment to be installed inside
- containment, the Readiness Review Staff noted that three of the specifications did not specify ANSI N101.4 and NSI N101.2 as standards. The concern was that the coatings installation for inside the equipment containment may (not i e.,be
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qualified coatings fornot may have been qualified to DBA tests). The three specifications in question were as follows:
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Specification X4AL01 for the containment building polar crane i
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Specification X2AG03 for Category I structural steel
- Specification X3AB03 for electrical penetrations
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Review of this finding by the licensee and Bechtel
! engineers disclosed that ANSI N101.2 and N101.4 were not
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referenced in Specification X3AB03 because these standards do not apply to the electro deposited zinc plating finish on the electrical penetration The review also showed that the two ANSI standards which were not referenced in Specifications X4AL01 and X2AG03, did appear in the approved vendor coating procedures and that the procedures complied with the Standards. Review of these vendor procedures by the NRC inspectors for the coating of the polar crane and structural steel verified that these procedures referenced and complied with the ANSI standards.
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As a result of this finding, Bechtel engineers reviewed 24 additional specifications for equipment to be
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installed inside containment to determine whether they
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disclosed that 12 of the specifications referenced the ANSI standards, and 12 did not reference the ANSI standards. Review of vendor procedures for specifications not invoking ANSI Standards showed that seven of the procedures did invoke the ANSI standards and that five of the procedures did not invoke the ANSI standards. The NRC inspector examined selected procedures and specifi-cations and verified that ANSI standards were reference Specifications / procedures examined are as follows:
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Specifications with ANSI Standards X4AJ16, Containment Cooling Unit X4AH34, Containment HVAC Fans X5AC07, Nuclear and Non-nuclear Solenoid Valves X2AG07, Containment Personnel Hatches
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Submitted Vendor Procedures which invoked ANSI Standards (specifications did not reference ANSI standards)
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Anchor Darling Procedures 158-1, Painting Carbon Steel for Nuclear Service (Specification X4AR01)
- Bristol Steel Procedure Coap - 0316-1, Surface Preparation, Cleaning and Painting, (Specification X2AG03)
Review of QA audits showed that this same problem was identified by the licensee's QA staff during a QA audit conducted in 1983 in AFR 44 In order to resolve this problem, deviation report CD-4825 was written and the licensee made a detailed review of all specifications for equipment to be installed inside containment to determine which equipment may have been coated with unqualified coatings (i.e., coatings which do not comply with ANSI N101.2 and N101.4). In addition, a walkdown inspection was conducted to determine the quantity of total square footage of equipment painted with unqualified coating The results of this walkdown are documented in a Bechtel letter dated September 28, 1983, Walkdown for Unqualified Coatings. In this walkdown, Bechtel engineers concluded that approximately 1500 to 2000 square feet of reactor building equipment had been coated with the unqualified coating. The containment building design allows for up to 6000 square feet of unqualified coating. Based on review of the corrective action for AFR 442 and Deviation Report CD-4825, the inspectors concluded that this finding was adequately resolve In order to prevent any problems in the future with ordering replacement equipment for installation inside containment, procurement specifications will be revised to reference ANSI N10 and N10 ) Finding 13B-21 Review of 10 field change requests (FCRs) issued against Specification X1AJ07 revealed several minor discrepancies. Examples of these problems and their resolution are as follows:
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Approval of FCR 14, 433 by project office engineer and fowarding a copy to the home office engineer (H0E) for information onl Subsequent review showed that this change had been concurred in by the H0E by telephone prior to its issuance. Thus, this problem was only a minor design control procedure violation and had no safety significanc The problem involved checking the wrong box on the FCR for Box "Yes" (Home Office concurrence required) of line 16a of the FCR should have been checked instead of box "No" (forwarded to Home Office for information only). Even though this occurred, the FCR was still reviewed by H0E. The licensee reviewed several other FCRs and no others were found which required HOE concurrence but was not so indicated on the FCR for Approval of FCRs to make general type changes to Specification X1AJ07 without the issuance of a construction specification change notice (CSCN).
Issuance of a CSCN results in a change to the specificatio This problem involved FCRs CRB-14969, 14433, 13934, and 1398 Review of these FCRs disclosed that two of them (13934, 13989) were written to cover isolated changes to the specification and in the judgement of the dispositioning design engineers did not require a specification change (CSCN). The inspector concurs with this conclusion. The remaining two FCRs were generic repetitive changes which should have resulted in changes to the specification. As a result, the licensee and Bechtel reviewed all FCRs issued against specification X1AJ07, and revised the specification to incorporate generic change The NRC inspectors examined 30 selected FCRs and verified that a CSCN had been issued for those FCRs that involved generic repetitive changes or that the FCRs had been previously incorporated into specification X1AJ0 Approval of FCR C-FCRB-14683 which appeared to provide an alternate method of surface preparation without revising specification X1AJ07. Further review of this FCR disclosed that it was not a generic change, but rather limited to a specific area in the Unit 2 containment. The inspector reviewed the FCR and concurs with the conclusio ,
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Approval of FCR 14969 which approved change to requirements for touch-up of coating on equipment provided by Westinghouse without any evidence being noted on the FCR that Westinghouse approved the chang Further review of this FCR disclosed that the Westinghouse field engineer signed and concurred with the FC The inspectors examined Part c, Section 17 of the Bechtel Project Engineering Manual, Field Change Requests and Georgia Power Procedure DC-A-03, Change Request and Notice These procedures establish controls for requesting and approving changes to design documents (specifications and procedures) in accordance
- with requirements specified in 10 CFR Appendix B. Based on review of the above problems and the listed procedures, the inspectors concluded that the finding was non-technical in nature and only involved minor violation of design change control procedures. This finding had no safety significance and is considered t be adequately resolve (b) Review of Subsection 6.2, Construction, showed that this subsection focused on implementation of construction commitments and assessment of construction activitie Review and verification that Subsection 6.2 was an accurate assessment of the construction program for coatings was accomplished by reviewing the construction commitments listed in the commitment matrix and the nine findings identified by Readiness Review Staff and verifying that these commitments were properly implemented in project documents, that the work was performed and documented in accordance with these documents and that the findings identified by tt Readiness Review Staff were properly resolve This was accomplished by reviewing project specifications, procedures, training qualifications of QA inspectors and coating applicators, all deviation reports written by the coating contractor and the licensee, GPC QA Audits, QA inspection records, all certification records for coating materials, storage controls on coatings, design based accident test data for coatings, calibration controls on measuring and test equipment, and by performirg a walkdown inspection of coatings in the Unit 1 containment, auxiliary, control, and fuel handling buildings. Resolution of the findings identified by the Readiness Review Staff were also evaluated to verify that they were properly resolved. Review of the findings identified by the Readiness Review Staff and the corrective actions associated with the resolution of these findings are as follows,
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1) Finding 138-1 Certification that coating materials were tested to the Vogtle Nuclear Plant Temperature / Pressure Curve was not found in any of the receipt document package Evaluation of this item by project engineering showed that the materials conformed to ANSI N101.2 curve which encompassed the VEGP temperature pressure curv Specification X1AJ07 was revised to require certification of the materials to meet the intent of ANSI N10 The NRC inspectors reviewed certification records for all coating materials used in Category I areas and reviewed temperature pressure curve data for coating materials that were supplied to the NRC inspectors by Bechtel Coating engineer Review of the certification records showed that all of the coating materials supplied to the site met ANSI N10 requirement except for materials supplied by the Keeler and Long Coating Company between June 1980 and May 198 Review of records showed that the Keeler and Long materials supplied during this time frame were not used in Category I coating area Review of test data supplied by Bechtel engineers showed that all the coating materials used in Category I areas exceeded the Vogtle temperature pressure curve and the ANSI N10 temperature pressure curve. The inspector concurs with the resolution of this findin ) Finding 138-2 Review of inspection reports by the Readiness Review Staff showed that in two cases out of 33, surface preparation inspection reports do not document inspection of required substrate profile comparable to SSPC standard SP15 when the surface is not prepared by sandblastin Review of this item by the licensee showed surfaces prepared by power tool cleaning have always been visually inspected to SSPC standard SP15 by Williams' QC. This was documented by annotating the surface acceptance block, indicating acceptance of the surface and annotating the surface profiles as N/A, This was done because no numerical figure can be obtained from a profile comparator as power tool cleaning results in a surface with no measurable profile. The block should have been marked OK instead of N/ __
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This practice contrasts with that followed for blasted
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surface in which a visual inspection for cleanliness to SSPC standards is followed by a separate measurement of profile with a profile comparato The visual inspection is documented by annotating the surface
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acceptance block and entering the measured value in the
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surface profile bloc The practice of marking the surface profile N/A for
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surfaces prepared by power tool cleaning was questioned in May 1985 during a Georgia Power QC review of coating documentatio As a result, the Williams' coating contractor agreed that separate documentation of surface profile acceptance would be a better practice and so directed the QC inspector This change was a documentation change only with no change in inspection or acceptance criteria. No substandard surfaces were accepted or coated as a consequence of the earlier inspection practic : Review of inspection reports and discussions with coating applicators by the NRC inspector indicated that the above change is being implemented and that in the past that quantitative entries for surface profiles of i blasted surfaces were being recorded. Review of this finding showed that it was a documentation error and
, safety of coatings was not affecte ) Readiness Review Finding 13B-3 Of 527 entries on application reports, six are cases of incomplete or erroneous entries were found. The errors cited in this finding are minor oversights or recording errors; e.g., referenced attachment documents missing,
- wrong manufacturer's product number, which identified the
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wrong coating color, and numbers in batch identifier transpose Review of records showed that the correct information was obvious by reference to other QC document entrie As a result of this finding, the incomplete or erroneous entries were correcte None indicated a deficiency in coatings applie The NRC inspectors concur with the project response to this findin ) Finding 13B-4 and 138-5 Thinner for Keeler and Long 0-1 epoxy was used outside
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temperature range (13B-4) and a 50 percent cutback of Keeler and Long sealer 4129 is not approved in the I
containment, but was used on the secondary shield wall (138-5).
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Review of the project response to this finding showed that approval for the use of these thinning techniques was received from appropriate authorities and documented in correspondence, but the application procedures were not revised to allow the 50 percent cutback thinnin Applications in violation were documented in deviation reports WC-85-247 and WC-85-24 Letter files, procedures and specification revisions were reviewed to identify any similar implementation of changes before application procedure were revised. Two additional instances were found where alternate procedures were informally approved but never used. In another case, an alternate thinning procedure was used once followed by informal approval. This was documented by Deviation Report WC-85-25 Review of the referenced deviation reports and correspondence from the coating supplier by the NRC inspectors showed that the project response was accurate and that the application of coatings was not affected by this findin ) Finding 138-6 Three of eight FSAR commitments involved requirements from Regulator.y Guide 1.54 and ANSI N101.4. Coating Specification X1AJ07 does not completely implement FSAR commitments to Regulatory Guide 1.54 and ANSI N10 Deficiencies were in the areas of documentation distribution, materials certification, identification of governing application criteria and quality assurance requirements for unqualified coating Review of the records showed that the FSAR commitments to ANSI N101.4 and Regulatory Guide 1.54 were followed in application and inspection activities even though these coninitments were not specifically or completely prescribed in the specifications and procedure Specification X1AJ07 was revised to clarify these requirement Review of records and inspection activities by the NRC inspectors confirmed that the FSAR commitments had been implemented and that this finding did not affect the acceptability of existing coating Review of procedure X1AJ07, Field Coatings, showed that the specification has been revised to clarify FSAR commitments to ANSI N101.4 and Regulatory Guide 1.5 .
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6) Finding 138-7 Willitm's coating contractor procedures do not meet all the requirements of coating specification X1AJ07 and ANSI N10 Several deficiencies were noted in documentation format, documentation requirements, and application procedure As a result of this finding, applicable revisions were made to application procedures, the warehouse procedure, the William's QA manual and Specification X1AJ07. This resulted in the specification clarifying the acceptability of William's application and inspection procedure Changes to procedures and the QA manual prescribe practices already in effec None of these changes required any change in the William's application or inspection activities nor did they have any affect on the applied coatings. Review of the William's QA manual, procedures, Specification X1AJ07 and inspection records and the inspection of applied coatings by the NRC inspectors showed that the project response to this finding was correct and that the quality of coatings was not affected by this finding. Review of procedures, Specification X1AJ07, and the QA manual showed that the referenced revisions were complete ) Finding 13B-10 During a walkdown inspection of coatings, the Readiness Review Staff identified 12 instances where coatings failed to meet acceptance criteria examples are as follow Overspray on stainless steel pipe
- Containments contained within coatings
- Pinholes in concrete coating
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Run or drip in intermediate coat was top coated
- Excessive dry film thickness
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Sag in coating
- Overspray coated over
- Insufficient dry film thickness The project response to this finding showed that cited sags, runs, and lint contaminants were within the acceptance criteria allowed by ANSI N101.4. Williams'
Procedure WC-010. Acceptance Criteria for Coatings, which was not clear on this item was revised to clarify acceptance criteria for runs and sags. Deviation Report WC-85-246 was initiated to document and correct the remaining finding ___ _________ _ __ ___- _ _
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As a result of this finding, an additional investigation of coatings was conducted by William's QC. These included reinspection of six areas of concrete coatings, 50 field coated embeds, and 1000 square feet of liner plate. This investigation resulted in finding two embeds to have contaminants. These were documented on Deviation Report WC-85-262 and as a result the embeds were reworked. No other discrepancies were found in the other areas of investigatio None of the discrepancies were considered to have any effect on the integrity of the coatings since the total area in question was small and procedural acceptance criteria were more stringent than the specification requirement In following up on this finding, the NRC inspectors
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reviewed applicable procedures, Specification X1AJ07 and the referenced deviation reports and performed a walkdown inspection of coating This followup
- confirmed that the rework had been done and the deviation reports were properly dispositioned, and that Procedure WC-010 was revised to clarify acceptance 9 criteria for runs and sag Inspection of coatings confirmed that the integrity of the referenced coatings i was not affected. The inspectors concur with the
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resolution of this finding.
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8) Finding 13B-22 In two instances deviation reports reviewed failed to meet the requirements of site procedure GD-T-01 as follows, i - CD-3378, disposition to obtain valid documentation i is not acceptable. The dry film gauge in question was not used by QC to verify acceptance but was used by production personnel.
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- CD-3423 justification for hardware not affected in the disposition does not support the dispositio Justification supports out of specification coating which requires engineering disposition.
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As a result of this finding, the deviation reports were
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redispositioned. Deviation report CC-3378 shows that the gauge was not used for acceptance and CD-3423 required reinspection of the applicable coating. A review of the handling of deviation reports reporting
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indeterminate dry film thickness due to out of calibration, and lost or broken material and testing equipment showed that the disposition and justification for such deviation reports initiated prior to June 30, 1983, were not always correctly handled. As a result of this, the Readiness Review Staff reviewed all deviation reports issued prior to June 30, 193 Five required revised dispositio In following up on this item, the NRC inspectors reviewed all deviation reports issued by the Williams'
coating contractor and Georgia Power Corporation staf Review of these deviation reports showed that the required corrections had been made and that the deviation reports were being properly dispositione The NRC inspectors concur with the resolution of this findin (c) Review of Section 6.0 indicated that the review conducted by the Readiness Review Staff for the design and construction verification program was comprehensive and adequat Examination of the findings indicated that the Readiness Review Staff did a thorough job in identifying and correcting deficiencies in the coatings program. Examination of records and observation of work activities for coatings showed that the records were representative evidence of quality controls and that work activities were being controlled in accordance with applicable requirements. No additional NRC findings were identified during the review of this section, g. Section 7.0 - Independent Design Review (1) This section describes the Independent Design Review (IDR)
conducted by Stone and Webster Engineering Corporation of coatings in the containment at the Vogtle Electric Generating Plan The IDR review focused on the following activities:
(a) Engineering specification requirements for coating type, thickness, surface preparation, application methods and inspection requirements for steel and concrete surface (b) Coating application procedure requirements for qualification of applicators, monitoring of ambient conditions, methods of determining coating thickness, and cleaning material (c) Design Basis Accident (DBA) testing and acceptance criteria for coatings to be qualifie (d) Evaluation and dispositioning of deviations from project requirements for the above item _- -
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This review by the IDR inspection team resulted in identifying
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nine finding (2) The review by the NRC Region II inspectors consisted of a detailed
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review of Section 7.0 of the module and review of the resolution of the IDR finding (3) A summary of the IDR findings and resolution of the findings are as follow (a) IDR Finding 1 (RRF 13B-17)
There was no requirement in the coating application procedures for verification of cure of inorganic zinc primers prior to application of the top coat material The inspectors reviewed the licensee's evaluation of this finding. The evaluation stated that there is no requirement in any code, standard, or in the coating manufacturer's procedures which require checking of cure or hardness of inorganic zinc primers prior to coating. However, inorganic zine that has not cured properly can be detected by either solvent wiping or high pressure water washin The inspectors reviewed Bechtel Specification X1AJ07, Field Coatings, and William's Application Procedure WC-310, Application of Epoxy Top Coat on Previously Coated Ferrous Substrate. This specification and procedure require surfaces coated with inorganic zinc primers to be either wiped with solvent or high pressure water washed prior to application of the epoxy topcoat. These methods for surface preparation are addressed in Williams' Application Procedure Nos. WC-301, Solvent Cleaning and WC-305, Pressure Washing. Thus, any uncured inorganic zinc primers would have been detected and removed during surface preparation prior to application of the epoxy top coat. In addition, the licensee furnished a
, list of all inorganic zinc II batches used at the Vogtle site
- to Carboline, the primer manufacture Carboline was asked j to report to the licensee whether any problems such as delamination, improper adhesion or cohesion, or cure, had been reported with those batche '
Carboline stated in a July 16, 1985 letter that none of the organic zinc batches used at the Vngtle site have had any i reported problem Based on the additional
- information/clarificatoin supplied by the Vogtle Project
- staff, the IDR classified this finding as Level IV, a j non-findin No problems have been identified with the
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inorganic zinc primer. This finding is resolved.
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(b) IDR Finding 2 (RRF 138-12)
Coatings specifications lacked sufficient detail on the coating requirements to ensure that the coatings are applied in accordance with FSAR commitment Examples of deficiencies in the specifications identified by IDR were failure of the specifications to reference the FSAR commitment to apply coatings in accordance with the manufacturer's requirements, and failure of the specifications to c '1 out specific application instructions from the various coating manufacturers. As a result of this finding, the licensee made a detailed review of FSAR commitments, the Bechtel specifications, and vendor documentatio This review disclosed that the total documentation package properly addressed FSAR commitments for coatings, including surface preparation, application, and inspection. This review also disclosed that the Bechtel specifications required that coatings be applied in accordance with manufacturer's apolication instruction Based on the re-examination of coa'ings specifications and procedures, the IDR team considered this finding as a Level IV finding, that is, a non-finding, since the technical requirements for application, inspection, and documentation of safety related coatings were adequately addressed in the project documents. This finding is resolve (c) IDR Finding 3 (RRF 13B-15)
Field coating system FN-8 of Specification X1AJ07 specifies touchup of inorganic zinc primed surfaces with Amercoat 90 Per Specification X1AJ07 Amercoat 90 N is only qualified to be used as a finish coat over Amercoat D6N. Williams'
procedure specifies Amercoat 90 N for touch-up and finish coat irrespective of type primer use Review of this finding by the licensee resulted in the following clarification. Amercoat 90 N is used as touchup and finish coat only in areas where the inorganic zinc primer was damage If the primer is intact, the manufacturer's respective finish coat is use Areas where Amercoat 90 N was applied have not been topcoated (finish coated). The specification was revised by field change request C-FCRB-15, 988 to clarify the use of Amercoat 90 This finding is resolve (d) IDR Finding 4 (RRF 138-19)
Nineteen coating related deviation reports were reviewed for adequacy of the engineering evaluations anc* resulting dispositions. This review disclosed that nine of the
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deviation reports evaluations, justifications or dispositions were found to be deficient. These deficiencies are as follow ) CDR-3275, Method of repair does not address touchup of primer, inspection requirements not addressed, use of 191 HB for touchup of CZ-11 does not appear to be DBA qualifie ) CD-3410, Acceptance of coating applied outside of
, coating manufacturer's recommended ambient conditions by visual inspection is not vali ) CD-3423, This DR addressed two conditions: 1) a dry film test (DFT) gage reading low and 2) a DFT gage reading hig The justification for 1 was not acceptable in that the CZ 11SG coating could fail under DBA conditions with coating thickness in excess of mils. The justification for 2 did not adequately
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address the deviation in that if the gage was reading
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high when calibrated, it is not clear that readings
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taken before calibration are correc ) CD-3306, Subdivision of coating kits should not be done without the use of calibrated measuring equipmen ) CD-3346, Justification is not clear, coating materials may be effected by storage outside the coating manufacturers recommended condition Altered coatings may appear visually acceptable under normal conditions but fall in a DBA conditio ) CD-3378, Justification acceptance is not clear; DFT gage at time of calibration was reading 3.5 mils for the 8.16 mil standard and 6.0 mils for the 14.8 mil standar Excessive film thickness on inorganic zinc may result in a coating without visual defects, but the performance of the coating system may be altered in a DBA conditio ) CD-3248, Disposition of two of the four deficiencies in
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this DR are not acceptable. In item 1, it is not clear why a crack observed in the coating system will not affect performance of the coating. In item 3, it was indicated that the exposed steel that was touched up was not acceptable due to holidays and bare steel and yet the justification for acceotance is; accept as is.
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8) CD-3214, Justification for this DR is not clea _ _ -. _ _ _ _ _ _ _ _ _ _ _ ,_ ___ ____ __ - __ . _ . . _ __ _ _ . _ _ . _ _ _ ,
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9) CD-3182, This DR stated, coating was applied over rust; applies over steel without a profile; and applied while the surface temperature was 0 to 2*F above the dew point. The disposition requires rework of coatings applied over rus The balance of the nonconforming conditions are; accept as i No justification is provided for acceptance and no procedure or inspection requirements are provided for reworked area Evaluation and resolution of this finding by the project engineers staff was as follows:
Deficiencies in Deviation Reports 3410, 3346, 3378, and 3423 were addressed in Subsection 6.2, Construction Program, in the resolution of Finding 138-22. Review of this finding showed that all four deviation reports were cases of lost, broken or out of calibration and test equipment. Two of the deviation measuring reports (DRs 3410 and 3346) cited equipment used to measure ambient condition Investigation of these cases showed that in one case DR 3410, the sling psychrometry used to measure ambient conditions was in calibration but was subsequently broken and in the other case, DR 3345, that the coating material in question had been stored in a storage cabinet in an area where ambient temperatures were measured, and that there was no requirement to have a thermometer in the storage cabinet to measure the ambient temperature. The two DRs, CD3378 and CD3423, involving indeterminate dry film thickness, were rejustified or redispositioned to show that the DFT gage was not used and to require a reinspection of the coating. A review was made of all DRs reporting indeterminate dry film thickness due to out-of-calibration lost or broken material and test equipmen This review identified 28 DRs in this area, five of these DRs required revised disposition or justificatio Re-evaluation of DRs CD3275, CD3306, CD3248, CD3214, and CD3182, showed that these DRs had been properly dispositioned. The acceptance of the dispositioning of these DRs was based on additional information provided by project engineering. Based on this information, the IDR team concluded that DRs being dispositioned by the design agency (BPC) were being properly evaluated and dispositioned correctly and consistent with the systems as tested for DBA condition The NRC inspectors reviewed the above responses to this finding, the referenced DRs, and the corrective actions taken to resolve this findin In addition, the inspectors reviewed all DRs written to date on coatings
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to verify that the DRs were being properly dispositioned. This review showed that corrections were made to DRs that had not been properly dispositione The inspectors concur with the resolution of this finding. ,
(e) IDR Finding 5 (RRF 13B-14)
Williams' Contracting Quality Control procedures were incomplete in that they did not completely address the required inspection or acceptance criteri Specific examples included failure of the procedures to specify frequency of the checks for ambient conditions, basis for acceptance of surface cleanliness and lack of detail in the painter qualification procedures. This problem had been previously addressed by the licensee's QA staff during a prior audit and was identified as Audit Finding Report (AFR)
747. Corrective action to resolve this problem was already in progress when IDR Finding 5 was identified during Readiness Revie The inspector examined the corrective actions taken to resolve AFR 747. The corrective action included revision of Williams' procedure numbers WC-002, WC-006, WC-010 and WC-012 to include required inspection and acceptance criteria. The inspectors examined these procedures and verified that they specified inspection hold points, acceptance criteria, frequency of inspection and inspector responsibilitie Prior to revision of the procedures, inspections were performed using the acceptance criteria established by Bechtel specifications and the manufacturer's recommendation The NRC inspectors concur with the resolution of this findin (f) IDRFinding6(RRF138-16)
Williams' application procedure WC-005 allows coating materials which have been stored outside of the coating manufactures recommended storage temperature to be used once the materials have been brought to the required temperature range for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (regardless of length of time outside manufacturers recommendations). Extended storage of products outside of the recommended temperature range may be detrimental to the product Review of the project response to this finding showed that Williams' QC is required by procedure WC-005 to inspect the paint storage cabinets every workday. If the temperature leaves the required storage range, the incident is documented and the paint is transferred to the permanent storage facilit The permanent storage facility provides a controlled environment where the paint temperature will stabilize over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In addition, Quality Control's visual inspection of the mix, application and cure of the paint required by procedure WC-010, will detect any defect .- .
The NRC inspectors reviewed the referenced procedures, inspected storage controls for coatings and discussed storage controls with responsible QC coating inspectors and engineer Review of procedure WC-005 showed that the procedure requires daily inspection of the paint storage cabinets and therefore the time products will be stored outside of the manufacturer's recommendation is limited to 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Review of procedure WC-010 showed that QC inspectors are required to witness mixing, application and curing of paint. Any painting products detrimentally affected by such limited exposure would be detected by the QC inspector. The NRC inspectors concur with the resolution of this findin (g) IDR Finding 7 (RRF 13B-13)
Section 6.1.2 of the FSAR commits to using the latest revision of the Steel Structures Painting Council (SSPC)
standard However, Specification X1AJ07 and the Williams'
procedures did not specify an effective date for the SSPC standards referenced, therefore, the date of the SSPC standards being followed was not clear. Specification X1AJ07 specified that the revision of the SSPC standard in effect at time of award of the contract be followed. The 1971 edition of the SSPC standard was in effect when the contract was awarde The inspectors reviewed a Bechtel Memo dated October 1,1985, Subject: Plant Vogtle Readiness Review Finding 13-B-13 which summarizes the results of Bechtel's review of this findin All coatings specifications were reviewed by Bechtel. This review disclosed that the only standard revised since the contract was awarded that would affect coating performance was standard SSPC-SP1 This standard was revised in 1982. However, since the 1982 standard was not as stringent as the 1971 standard in effect when the contract was awarded, the 1971 standard was followed for work performed onsite. Since DBA tests performed on the coatings followed the 1971 standard, use of the 1971 standard in lieu of the 1982 standard is conservative. A review of all contracts issued since June 1981 for procurement of equipment to be installed inside containment was made to determine which standards were followed by the vendors for painting of the equipment. Only one of 44 contracts did not contain an effective date for standard SSPC-SP10. Discussion with the vendor disclosed that the 1971 standard was use Specification X1AJ07 was revised to state that coatings work be performed in accordance with the latest published code at the time of contract awar * e a
Specifications for future coating work for equipment to be installed inside inside containment will contain a similar statemen The NRC inspectors concur with the resolution of this findin (h) IDR Finding 8 (RRF 13B-11)
Paragraphs 7.2 and 7.6 of Specification X1AJ07 contain conflicting requirements regarding ambient conditions during coating applicatio Paragraph 7.6.1.D prohibits the application of coating materials below 50 degrees Paragraph 7.2.1 allows inorganic zinc to be applied down to 35 degrees F. Paragraph 7.6.1F requires that the surface temperature be at least 5 degrees F above the dew point during coating application. Paragraph 7.2.6 requires the surface temperature to be at least 2 degrees above the dew point during coating applicatio Review of the response to this finding showed that paragraph 7.6.1.0 is a general statement for all coatings while paragraph 7.2.1 refers specifically to organic zine which can be applied at a lower temperatur The requirement in paragraph' 7.2.6 that the surface temperature be at least 2 degrees F above the dew point only applied to inorganic zin Review of the Williams' procedures showed that the Williams'
application procedures which were used by QC inspectors were more stringent than the specification. Specification X1AJ07 was revised to clarify the discrepancie The NRC inspectors reviewed the procedures and changes made in the specification to clarify the confusion between specifications and procedure Review of inspection reports and deviation reports verified that the correct temperature requirements were adhered to by QC inspectors and that deviations from procedure requirements were reported in DR' The NRC inspectors concur with the project response to this finding and consider the finding to be resolve (i) IDR Finding 9 (RRF 13B-18)
This finding concerned control of the amount of zinc being used in protective coatings inside containment. The IDR team interpreted statements in Section 6.1.1.1.2 of the FSAR as limits on the amount of zinc in containment. The concern was that no verification was performed to determine the total quantity of zinc used in the protective coatings inside containmen Further review of this problem by Bechtel disclosed that FSAR Section 6.1.1.1.2 does not limit the amount of zinc going inside containment, but rather
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references FSAR Table 6.2.5-6 which lists the expected quantities of zinc in the containment protective coating These estimated quantities were used in design of the systems for control of combustible gases in containment following a LOC These quantities are used in Bechtel Nuclear Calculation- No. X6 CAB.01 in estimating the total amount of zine used in protective coating inside containmen The calculation has been revised to include updated zinc inventory data. Based on the additional information and clar pations provided by Bechtel, the IDR team classified thei inding as Level IV, a non-finding. The NRC inspectors concur with the resolution of this findin (4) Review of Section 7.0 of Module 138 showed that the IDR was comprehensive in scope and dept The Region II inspectors agree with the IDR team findings and their resolution. No new findings were identified by NRC during the review of this sectio . Findings No NRC findings were identified during the review of Module 13B. Review of this nodule showed that the Readiness Review Staff did a comprehensive review of design and construction activities for safety related coatings and that significant findings were identified by the Readiness Review Staf This resulted in significant corrections in the coating program that clarified inspection requirements, documentation requirements and inspection activitie . Conclusions Based upon the review within the scope of Module 13B, Coatings, the NRC has reached the following conclusions for coatings for Vogtle Unit Summary of Specific Conclusions (1) Commitments - The NRC has reviewed the commitments as listed in Section 3.0 of the module and determined that the licensing commitments and implementing documents comply with the FSAR, SRP, Regulatory Guides, and industry standard (2) Program - The NRC reviewed'the description of the program as given in Section 4.0 of the module. The following areas of the program were reviewed:
Design controls Materials Training and qualification Preparation, Application and Inspection
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We have determined that the description in Section 4.0 is generally correct and is in agreement with FSAR and project requirement (3) Audits and Special Investigations - The inspectors reviewed Section 5.0 on audits and special investigations and concluded that this is an accurate presentation of the audit process and previously identified coating problems and NRC inspection result (4) Program Verification - The program verification conducted by GPC consisted of a design program verification and a construction program verificatio The design program verification consisted of verifying that the design process for Category 1 coatings was adequately controlled and that licensing commitments were implemented in design document The construction program verification consisted of verifying that construction incorporated licensing commitments into implementing documents such as drawings, procedures and specifications and that construction activities complied with design requirement The program verification also included a walkdown inspection of coatings to assess the quality of the coating The program verification identified two findings in the design program and nine findings in the construction area. These were categorized on the basis of their individual significance and cumulative programmatic effec The review conducted by the Readiness Review Staff for the design and construction program was comprehensive and adequat Findings were of minor significance and the resolution of the findings were adequat Quality records indicated they were representative evidence of quality controls for coating activities. Observation of coating activities observed during the review of this module indicated that coating activities were controlled in accordance with applicable requirements and that the assessment of design and construction activities described in this module are correc This specific conclusion can also be supported by performance of the Construction Inspection Program (IE Manual, Chapter 2512) by i Region II Inspectors. This program required observation of work l and work activities of the applicants' personnel regarding their j duties during construction of the facility.
l l (5) Independent Design Review - GPC contracted an outside organization,
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Stone and Webster Engineering Corporation, to perform an Independent Design Review of coating This review was performed to assess the technical adequacy of the protective coating systems inside the containment, and to verify that the project licensing commitments were implemented in a technically adequate manner. This review resulted in nine l
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findings being identified. The NRC concluded that the IDR program for coatings was comprehensive and adequate. The NRC agrees with the findings and their dispositio b. General Conclusions This module presents an acequate assessment of the GPC process for design and construction of coating During the review, it was apparent to the NRC reviewer and inspectors that GPC management supported the program by their active participation in the development of the program. Review and evaluation of Module 13B by the NRC indicates that the review performed by the GFC Readiness Review Staff was sufficiently comprehensive in scope and depth to identify problem areas, and that the dispositions of Readiness Review findings were proper and satisfactory. The procedures for design, construction, and quality control were consistent with commitments and, are therefore, acceptable. Based on the review of this module, and the results of previous NRC inspections, the inspectors concluded that coating activities were performed in accordance with the appropriate procedures and that records reflect quality of the coatings. The NRC finds that the Vogtle program for the design and construction of Category 1 coatings complies with the Final Safety Analysis Report and that compliance is verifiable with existing documentatio The NRC furthermore believes that Module 13B accurately assesses the status of design and construction activities for Category 1 coating This conclusion is based on information currently available to the NRC inspectors and reviewe Should information subsequently become
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available which was not considered during this review or previous inspections and which conflicts with earlier information, it will be evaluated to determine what effect it may have on the above conclusio ..