ML14259A389
| ML14259A389 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 09/08/2014 |
| From: | Ayer L Underwater Construction Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 50434 | |
| Download: ML14259A389 (8) | |
Text
{{#Wiki_filter:0910X12014 0//2)US. Nuclear Regulatorv Con ~kissin Onerations Center Event Rennrt Poop, I Part 21 (PAR) Event# 50434 Rep Org: UNDERWATER CONSTRUCTION CORPORATI Notification Date I Time: 09/08/2014 16:41 (EDT) Supplier: UNDERWATER CONSTRUCTION CORPORATI Event Date / Time: 06/18/2014 (EDT) Last Modification: 09/08/2014 Region: 1 Docket #: City: ESSEX Agreement State: No County: License #: State: CT NRC Notified by: LES AYER Notifications: TODD JACKSON R1DO HQ Ops Officer: DONALD NORWOOD PART 21 GROUP EMAIL Emergency Class: NON EMERGENCY 10 CFR Section: 21.21 (d)(3)(i) DEFECTS AND NONCOMPLIANCE PART 21 - FAILURE TO MEET SPECIFIED IRRADIATION DURING TESTING OF COATED TEST PANELS The following information is a synopsis of information received via facsimile: Underwater Construction Corporation (UCC) was notified by Steris Isomedix Services (SIS) that test panels coated with Bio-Dur 560Blue epoxy coating, which SIS had been contracted to irradiate to a minimum accumulated dose of 1000 Mrad, could possibly have received a dose of only 949 Mrad due to a variance of 5.1 percent not previously reported on the Steris Component Irradiation Certificate. Bio-Dur 560Blue is a Service Level I coating. Failure to meet irradiation requirements for qualifying Service Level I coatings could result in the coating disbonding from the substrate, thus clogging Emergency Core Cooling Strainers during a postulated Loss of Cooling Accident (LOCA). Bio-Dur 560 Blue was used to reline the toruses at Peach Bottom Units 2 and 3. Also, 588 square feet of Bio-Dur 560 Blue was applied to the liner of the suppression pool at Limerick Unit 1. UCC notified Exelon concerning the irradiation failure and provided the following recommendations:
- Perform evaluation of their Safety Analysis Report to determine if 949 Mrad meets licensing commitments. - Perform a review and determine if Supplemental Test Report per Exelon Contract 00045628, Release 00735, whereby irradiation testing of BioDur 560Blue was performed to 1000 Mrad by University of Massachusetts will provide reasonable assurance that coating will not fail during a LOCA.
Notification to NRC provided by Les Ayer, UCC QA Manager, 860-767-8256, x-169.
SEP. 8.2014 5:23PM UNDERWATER CONSTRUCTION NO.5992 P. 1/7 UNDERWATER CONSTRUCTION CORPORATION 110 Plains Road Phone 860m767.8266 P.O. Box 699 Fax 860e767e0612 Essex, CT 06426 FAX COVER SHEE To:-og~ \s From: Lcs
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Subject:
PAeg3 2_1 Ao IfcATriOac Date: 1/811 Pages: . (Including cover page) COMMENTS: If you do not receive all pages, please call back immediately. Phone: 860-767-82S6 The information contained in this facsimile message is privileged and confidential information intended solely for the use of the individual or entity to whom it is addressed. If you are not the intended recipient you are hereby notified that any dissemination, disclosure, copying or distribution of this telecopy is strictly prolibited. you received this conummuication in error, please immediately notify us by telephone and return the original message and documents to us at the above address via the United States Postal Service. Thank you.
SEP. 8. 2014 5:23PM UNDERWATER CONSTRUCTION NO. 5992 P. 2/7 UNDERWATER CONSTRUCTION CORPORATII ON 7-0612 110 PLAINS ROAD, PO. BOX 69a, ESSEX. CT 06426-0859 / TEL: 860-757-8256 (8003 USA-DVE FAX: (8601 78 September 5, 2014 TO: Document Control Desk Nuclear Regulatory Commission Washington, DC 20555 FROM: Leslie Ayer/ QA Manager Underwater Construction Corporation 110 Plains Road Essex, CT. 06426
SUBJECT:
Notification of 10 CFR Part 21 Steris, an approved 10CFR 50 Appendix B supplier, was contracted by Underwater Construction Corporation (UCC) to provide irradiation services in support of Design Basis Accident Testing (DBA), in accordance with ASTM D4082-89. In accordance with Steris's Quality Assurance Manual PROC-00829 Revision 3 Dated 1/28/13, UCC issued Steris Purchase Order 13-23Q to irradiated coated test panels to a minimum accumulated dose of I x 109Rads, or lO00OMrad. UCC also issued Purchase Order 11-03Q to Kinectrics in order to perform Design Basis Accident Testing in accordance with ANSI 101.2 and ASTM 3911-89. Kinectrics contracted Steris to perform irradiation testing in accordance with ASTM D4082-89. UCC received notification from Steris on June 18, 2014 that a possible 10 CFR Part 21 defect had been identified. Steris was unable to determine if a 10CFR Part 21 existed as part of their notification. Upon UCC's review of Steris's notification it could not be determined that a 10CFR Part 21 had occurred, due to lack of additional information and confirmation of panel placement in relation to the gamma source. On July 11, 2014 Exelon Generation Company was notified of a possible 10CFR Part 21 defect that may have affected the irradiation test results per Contract 00045628 Release No. 00844 (Limerick Generating Station) and Contract 00045628 Release No. 00652 (Peach Bottom Generating Station). On Wednesday September 3, 2014 UCC conducted a conference call with Steris for further information and clarification of the reported possible Part 21 defect. It was determined upon further review that a Reportable Part 21 defect does exist and is reportable under Title 10 Code of Federal Regulations Part
- 21. UCC has generated Nonconformance 14-06 as a result of this identified deficiency.
4318 N. ROOSEVELT ROAD 684 GULF VIEW DRIVE 25-15 HON-SYOTOKru lC-IKAWA-SI-I 1 SENSVILLE, MI 49127 SODDY DAISY. TN 37379 CHIBA-AEN JAPAN 272-0103 Th (SO[)422-3935 TEL:(088) USA-OIVE TEL- 21-90-4813-1158 FAX: (289) 429-6579 FAX: (423) 332.-679 FAX 81-47-357-6450 An FquA1 Oppwrmadgy &qdoy!)er
SEP. 8,2014 5:24PM UNDERWATER CONSTRUCTION NO. 5992 P. 3/7 The basic component affected by this discrepancy is identified as Aio-Dur 56OBlue, epoxy coating. Bio-Dur 560Blue is a Service Level I coating, manufactured by Thin Film Technology and distributed by UCC. This coating was used to reline the Tori at Peach Bottom Units 2 and 3 and in Umerick Unit 1 Suppression Pool where 588 ft2 of coating was applied to the liner. The Code requirements for qualifying Service Level I coatings states, that irradiated panels shall be subject to 1 x 109Rads, or 100OMrad. NRC Report Number 99901445/2014-201 identifies a variance of 5.1% not previously reported on the Steris Component Irradiation Certificate. As a result of this variance the previous reported value of l00OMrad was determined to be 949Mrad. Failure to meet irradiation requirements for qualifying Service Level I coatings could result in coating to disbond from substrate, thus clogging Emergency Core Cooling Strainers during a postulated Loss of Cooling Accident (LOCA). The following recommendations were provided to Exelon:
- Perform evaluation of their Safety Analysis Report to determine if 949Mrad meets licensing co mitments.
Perform a review and determine if Supplemental Test Report per Exelon Contract 00045628 Release 00735, whereby irradiation testing of BioDur 560Blue was performed to lO00OMrad by University of Massachusetts will provide reasonable assurance that coating will not fail during a Loss of Coolant Accident-Should you require additional information I may be contacted at 860-767-8256 X169. Les Ayer UCC QA Manager 2
SEP. 8. 2014 5:24PM UNDERWATER CONSTRUCTION NO. 5992 P. 4/7 SSTERIS Isomrex $ervices June 18, 2014 Kinectrics Inc. 800 Kipling Avenue Unit 2 Toronto, Ontario MB25G5 Attention: Serena Krause Re: Isomedix Service Whippany NJ NRC Inspection Findings
Dear Valued Customer:
As a-valued eustomerof-S-TERIS Isomedix Servicesr ganim prcfcessing sevices, Wvwant to make you aware of the results of an inspection recently conducted by the U.S. Nuclear Regulatory Commission (NRC) under 10 CFR) Part 50, Appendix B with respect to equipment qualification testing of nuclear safety-related components processed in off-carrier positions at the Whippany, New Jersey facility. The NRC issued a Notice of Nonconformance stating that the measuring and testing equipment used to determine the applied radiation dose reported to you on the Isomedix Certificate of Processing provided with each run did not account for all the uncertainties involved (i.e., density of unrelated products in carriers, off-carrier location within the irradiator and Cobalt-60 source decay) and therefore the actual radiation dose applied to components could be less than requested and as reported on the Certificate of Processing STERIS Isomedix Services has completed an evaluation of the dose rate variability of items processed in off-carner locations in the irradiator. This evaluation determined that there may have been variability in readings as great as +/- 5.1 % of the dose delivered for components processed in off-carrier positions, depending on the location within the irradiator where the component was processed. As a result, the actual dose delivered to your component may have differed up to +-5.1% from the value reported on the Certificate of Processing. This variability is in addition to the standard measurement uncertainty of the Red Perspex 41034 dosimetry system (+/-t 6.5%) noted in all purchase quotations. Because Isomedix is unable to evaluate the affect this variation may have on the components processed, we are notifying you under the requirements of 10 CFR Part 21. Isomedix strives to provide processing services in strict compliance with Customer specifications and Isomedix quality processes and procedures. We apologize for any inconvenience that this unique situation may have caused. If you have questions or require additional information, please contact me at (973) 887-2754 or ScottComstock@STERIS.com. Very Truly Yours Scott Comstock Plant Manangr STERIS Isomedix Services 9 Apollo Drive Whippany, NJ 07981 STERIS Isomedix Services 11880 Industrial Drive, Ubertyville, IL60048 1847.367.1911
SEP. 8. 2014 5:24PM UNDERWATER CONSTRUCTION NO 5992 P. 5/7 June 27, 2014 Underwater Construction Corporation 110 Plains Road KIN ECTRICS Essex, CT 06426 KINECTRICS*US Re: Steris Isomedix NRC Inspection Findings Attention: Les Ayer On June 24, 2014 Kinectrics received notification from Steris Isomedix Services (Steris), a supplier of irradiation services, that a U.S. Nuclear Regulatory Commission (NRC) inspection indicated that applied radiation doses reported by Steris did not account for all the uncertainties involved. As such, the actual radiation dose applied to test specimens may be less than the dose reported by Steris to Kinectrics, and by extension, less than the dose documented in the associated equipment qualification test report(s) provided to you .............. by-Kectrics.-The-NRC-inspection report-whichidentifies-this issue is report number -- 9990144512014-201. As Kinectrics cannot currently determine ifa defect exists, you are being notified under the requirements of 10CFR Part 21. Kineotrics has assembled a team to address this issue and is currently performing the following actions: KINECTRICS INCORPORATED 1. Reporting this potential issue to all of Kinectrics' affected customers. Bon Kipling Avmnu, Uniti 2. Reviewing past and current projects to determine ifSteris was utilized for irradiation Toronto, Ontario, Canada services. MBZ S56 3- For affected projects, Kinectrics is working closely with Steris to verify the variability of 16-.207.6000 the doses applied, as described inthe attached correspondence, and determine the 4*16.207.6532 actual radiation dose applied to test specimens as accurately as possible. Kinectrics is planning to have this information available within 25 days. www.kmnectrics.com 4. For projects in which the unaccounted variability could have resulted in the actual dose being less than that reported to our Customers, Kinectrics will formally notify those affected Customers of the following:.
- a. Advise them of the potential difference in the reported dose.
b- Work with customers to determine ifa defect, as defined by 10CFR Part 21, does indeed exist. The following purchase orders have been affected by this issue:
. . .. .. .... . ... . . l- 3Q .. -- -... .. . .. .
Kinectrics is committed to providing the highest level of customer service and will make every effort to work with our customers to reconcile any results affected by this matter. To ensure effective communication during this investigation, please respond to this communication by e-mail at justin.hubbard@kinectrics-com. If you have any questions, or require additional information, please contact me as indicated above, or by phone at 416-207-6000 ext. 6137. Justin Hubbard Kinectrics Inc. Quality Manager
SEP. 8,2014 5:25PM UNDERWATER CONSTRUCTION NO.5992 P. 6/7 UNDERWATER CONSTRUCTION CORPORATION 110 PLAINS ROAD, RO. BOX 699, ESSEX, CT 06426-0699 / TEL; 860-767-4256 (800] USA-DIVE FAX; (860) 767-0612 July 11, 2014 Exelon Generation Company, [IC ULmerick Nuclear Generating Station 3146 Sanatoga Road Pottstown PA 19464
Subject:
Steris Isomedix NRC Inspection Finding Attention: George Triantafilopoulos Underwater Construction Corporation (UCC) was contracted by Exelon Generation Company, LLC to provide Design Basis Accident (DBA) Testing in accordance with Exelon Contract 00045628 Release 844. As part of the testing process UCC contracted Steris Isomedix Services to perform irradiation services. UCC has been notified by Steris of a potential 10CFR Part 21 issue that may exist concerning the irradiation portion of the DBA testing. (See attached Steris notification)- UCC has been in contact with Steris and is performing an ongoing evaluation to determine the accuracy of the issued irradiation report. At this time UCC is unable to evaluate and determine if a 10CFR Part 21 exists. Under the reporting requirements of 10CFR Part 21 you are being notified of a potential condition that may exist. Les Ayer
- UCC QA Manager 800-872-3483 x169 4316 N. ROOSEVLT ROAD 8494 GaLY VIEW DRIW 25-15 HONGYOTOKU ICHIKAWASHI STEVENSVILLE. MI 49127 SODDY DAISY. TN 37379 CHIBA.-KEN JAPAN 272-0103 TEL' (8003422-4935 TEL: (9BB6USADIVE TEL 81,*-.4813-1155 FAX: (269) 429-6579 FAXK [4211] 82-6769 FAX: 81-47-357-6450 An - Oppormity Emp/aroy
SEP. 8. 2014 5:25PM UNDERWATER CONSTRUCTION NO.5992 P. 7/7 UNDERWATER CONSTRUCTION CORPORATION 110 PLAINS ROAD. PO. BOX 69g. ESSEX, CT 08426-0699 / TEL: S6-767-8256 (8003 USA-DIVE FAX: (B60) 767-0612 July 11, 2014 Exelon Generation Company, LlC Peach Bottom Nuclear Generating Station 1848 Lay Road Delta PA 17314
Subject:
Steris Isomedix NRC Inspection Finding Attention: Jeanne Hefner Underwater Construction Corporation (UCC) was contracted by Exelon Generation Company, LLC to provide Design Basis Accident (DBA) Testing in accordance with Exelon Contract 00045628 Release 735. As part of the testing process UCC contracted Kinectrics who in turn contracted Steris Isomedix Services to perform irradiation services. UCC has been notified by Kinectrics of a potential 10CFR Part 21 issue that may exist concerning the irradiation portion of the DBA testing. (See attached Kinectrics and Steris notification). UCC has been in contact with both Kinectrics and Steris, and is performing an ongoing evaluation to determine the accuracy of the issued irradiation report. At this time UCC is unable to evaluate and determine if a 10CFR Part 21 exists. Under the reporting requirements of 10CFR Part 21 you are being notified of a potential condition that may exist. Les Ayer UCC QA Manager 800-872-3483 x169 4316 N. ROOSEVELT ROAD 84S4 GULF VFW DRIVE 25-15 HD6NGY0TDKU ICHIKAWAI-{I STEVENSVILLE, MI 49127 SODDY DAISY. TN 37379 CMIBA-KEN JAPAN 272-0103 TEL: (BOO) 422-8935 7EL: (961 USADIVE TEL: 81-40-4813-1155 FAX; M252) 429-6579 FAX: (423] 332-6769 FAX; 81-47-257-6450 An -~p Opporumity Employer}}