ML19277F383
| ML19277F383 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/23/1984 |
| From: | Novak T Office of Nuclear Reactor Regulation |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19277F384 | List: |
| References | |
| TASK-AS, TASK-BN84-015, TASK-BN84-15 BN-84-015, BN-84-15, NUDOCS 8312120157 | |
| Download: ML19277F383 (2) | |
Text
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Docket Nos.-
50-445 and 50-446 MEMORANDUM FOR: The Atomic Safety and Licensing Board for the Comanche Peak Steam Electric Station, Units 1 and 2 FROM:
Thomas M. Novak, Assistant Director for Licensing rivision of Licensing SUBlECT:
BOARD NOTIFICATION - COMANCHE PEAK POTENTIAL 10 CFR 50.55(e) REPORT ON C0ATING ADHESION TEST DATA (BN 84-015)
This notification is provided in accordance with NRC Procedures regarding Board Notifications.
The purpose of this BN is to inform the ASLB (Comanche Peak) that on January 16, 1984 the licensee advised NRC Region IV that it had found a deficiency which is considered potentially reportable within the context of 10 CFR 50.55(e).
The deficiency relates to the reinspection program for paint (coatings) applied to the inner wall of the containment liner.
The program utilized an adhesion tester to determine the coating adhesien to the substrate at selected areas of the inner wall. The tester nodel used is subject to drift and therefore testers were calibrated periodically to assure their accuracy.
The licensee has indicated that the calibration data was not properly applied during evaluation of the test res ul ts.
The licensee is in the process of matchino specific calibration records to corresponding test records.
At this time, the significance of this deficiency is not known.
The enclosed memorandum provides additional information on this matter. The staff will continue to keep the ASLB advised as to the disposition of this matter.
Thomas M.
lovak, Assistant Director for Licensing Division of Licensing P'. Bloci, ASLB cc:
K. McCollom, ASLB W. Jordan, ASLB
Enclosure:
1.
Memorandum to D. G. Eisenhut from J. T. Collins dated January 18, 1984, with attachments Ah}
CONCURRENCES.
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1/J 4 1/; 84-r NO 5 8312120157
4 DISTRIBUTION LIST FOR BOARD NOTIFICATION Comanche Peak Units 1&2 Docket Nos. 50-445/446 ACRS Members Peter B. Bloch, Esq.
Dr. Robert C. Axtmann Mr. John T. Collins Mr. Myer Benoer Mrs. Juanita Ellis Dr. Max W. Carbon Mr. R. J. Gary Mr. Jesse C. Ebersoie Dr. W. Reed Johnson Mr. Harold Etherington Dr. Walter H. Jordan Dr. William Kerr Dr. Kenneth A. McCollom Dr. Harold W. Lewis Thomas S. Moore, Esq.
Dr. J. Carson Mark David J. Preister, Esq.
Mr. William M. Mathis Nicholas S. Reynolds, Esq.
Dr. Dade'W. Moeller Alan S. Rosenthal, Esq.
Dr. David Okrent Mr. Lanny Alan Sinkin Dr. Milton S. Plesset Mr. Rchert G. Taylor Mr. Jeremiah J. Ray Mr. Spencer C. Relyea, Esq.
Dr. Paul C. Shewmon Mr. Homer C. Schmidt Dr. Chester P. Siess Atomic Safety and Licensing Mr. David A. Ward Board Panel Atomic Safety and Licensing Mr.ppeal Panel A
H. R. Rock Mr. A. T. Parker
[ %'g UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION IV ig-
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611 RYAN PLAZA DRIVE. SUITE 1000 t,,
ARUNGTON. TEXAS 76011 JAN 181984 MEMORS UUM FOR:
Darrell G. Eisennut, Director, Division of Licensing, NRR FRCM:
John T, Collins, Regional Administrator 3UBJECT:
PRCPOSED BOARD NOTIFICATION - COMANCHE PEAK POTENTIAL 10 CFR 50.55(e) REPORT ON C0ATING ADHESIGN TEST DATA The cuality of coatings appliec to tne inner wall of the containment liner prior to October 1981 was considered indeterminate due to inadequate and/or lack of documentation.
Consequently, a coating reinspecti,on program was initiated to determine the adequacy of the coatings.
The reinspection program incluced a test to determine coating adhesion to the substrate at selected areas of paint (coatings) on the inner wall of the containment vessel.
The equipment uti'i:'ed to perform the tests was an Elcometer Adhesi a Tester marke.ted oy Kenneth Tator Associates, Inc., Pittsburg, PA.
The aceptance criterion for achesion to the sub u rate was set at 200 psi in accordance with ANSI Standard N5.12, 1974.
Due to the inherent fatigue of Bellville washers within the equipment which allowed a constant drift with use of the adhesion tester, it was found necessary to calibrate the meters roughly every 2 weeks.
Calibration was made with a dead weight tester.
The licensee has indicated that the calibration data was not properly applied during evaluation of the test results. The licensee is in the process of matching s;,rific calibration recoras to correspondiLg test records.
This deficier.cy is considered cotentially reportable within the context of 50.55(e) in that sufficient margin may exist within the test data to accommodate appropriate application of the calibration data.
The applicability of coatings to the Comanche Peak Steam E'ectric Station ASLB hearing as a licensing issue and its associated safety significance is discussed in the attached memorandum for Gordon ~ Edison, NRR, from T. F. Westerman, Region IV, dated January 6, 1984 Because the subject of coatings is an ou Jng issue in the ASLB hearing or.
Comanche Peak, I am recommending that the coard be notified immediately of this potential deficiency We will continue to keep you advised as to the disposi. ion of this matter.
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o Darrell G. Eisenhut JAN 181984 If acditional ir. formation is required contact W. A. Crossman (728-8151) or T F Westerman (723-8145).
/ f0 ffw'sI*vf?(+V' John T. Collins Regional Administrator cc:
G. Edison, LB1 E. Case, NRR R. DeYoung, CIE
- 5. Trecy, ELD S. Burwell, NRR J. Gagliardo E. Johnson O
uNITEo STATES f
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NUCLEAR REGULATORY COMMISSION se REGloN IV E,l,l,
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611 RY AN PLAZA oRIVE. su!TE 1000
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8 ARLINGTON. texas 76011 N,,
0 6 J AN 1984 MEMORANDUM FOR:
Gordon Edison, NRR Allegation Coordinator Thomas F. Westerman, Enforcement Officer, Region IV FROM:
SUBJECT:
ADDITIONAL INFORMATION REGARDING PROPOSED BOARD NOTIFICATION FOR CPSES ATOMIC SAFETY LICENSING BOARD (xSLB)
The open hea"ilg issue before the ASLB at Comanche Pei.k is Contention 5.
Contention 5 to stated as follows:
"The applicants' failure to adhere to the quality assurance /
quality control provisions required by the construction pe* 7its for Comanche Peak, Units 1 and 2, and the reauirements of Appendix B of 10 CFR Part 50, and the construction practices employed, specifically in regard to concrete work, mortar blocks, steel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft labor qualifica-tions and working conditions (as they may affect QA/QC), and training and organization of QA/QC personnel, have raised substantial questions.
as to the adequacy of the construction of the fecility.
As a result, the Commission cannot make the findings required by 10 CFR Part 50cS7(a) necessary for issuance of an operating license for Comanche Peak."
The ASLS nas taken a very broad interpretation of this contention.
The Citizen Association for Safe Energy (CASE) in their November 9, 1983, filing with the ASLB discusses the Lipinsky memorandum, as well as other coating related allegations.
The subject of coatings is considered to be a licensino issue.
The safety significance of coatings relates to the potential for the loss of adhesion between successive coats that could result in paint material being carried into the containment sump as a result of a reactor accident which is followed by initiation of the containment spray system.
The scenario of contain-ment coating failure represents the potentia'i to exceed the allowable blockage of the inner sump screen (reference NRC Regulatory Guide 1.82).
There is also the possibility of paint interaction during the accident condition whicn does not appear to be in question at Comanche Peak.
I have attached the Lipinsky memo.
If you need further information, then you may want to review the CASE Novemoer 9, 1983, filing with the ASLS.
wegue
_2 In my previous memo of November 23, 1983, to 5. A. Treby, ELD, the date for completion of the ine.pection should be changed to March 1984, and the inspection report issue date should be changed to April 1984.
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Thomas F. Westerman Enforcement Officer
Enclosure:
Memorandum to R. B. Roth cc:
J. T. Collins T. F. Westerman <'
M.D-83-0096 Atg :st 8,1983 TO:
R. 6. Retn
.::: J. J. Norris P.:n
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1ri: Report OGO Sob H:. MS301 (Coman:ne Peak Unit 1-01en R:se, TX)
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Tne writer was on the su:Je:. site July 26, 27, and 28,1933.
3 Tne f J1owing individuals were met vn11e on site:
H.. R. 9.:Say (TU5I) Engineering Ka. aper
~. T. Eran:t (EBAS D) Proje:t NT-ASIE 0: Su0ervis::
0:ne ;rane (TU.') Construction Resloent Manager J:rry no::s '(EBA20) Personnei 2:nn Herritt (TUCO3) xanager of 5tsrt 110 T. L. w. iller (EBmEJD) Paint ins?c:ter g.
R. T:1sen (TU::CO) ;A Manager P. ark wells (Ci :s i Hill) Engdn er narry william.s (~.;i::s & Hill) CC Paint Se::rvisor Tne f:ll.<ing activities were performed snile on site:
July 26, 1953
- Net
. T. Ersndt (Ebase:s)
- walk site witn Harry Williams (~ites & Hill)
- Meet R. P:sgay (DEC) - discuss painter cualifi:stions and site ::nditions/: : ele s in general "eet Mark wells (Gibas an: Kill)
.;c: Bae;ed Juif 27, 1963
- xsik around. site - : serve scrx on colar ::an: anc ::rne
- Brie f meetin'g witn R. Tclson (T6 J) and C. T. Bran:t (Enasco) - preliminary assessencnt by J.J.L. that Comanene Peak nas pr:clems in areas of material storage,
" work =ansnio '(ouality of werk anc painter cualification &
inuo trination), not satisfying ANSI recuirments and 00ssicly coating integrity.
All of above 00uld affect NRC licensing tD Which R. Tolson red 312d "That's not my
,jcc cr concern".
A]so discussed former 08: employees with emph: sis on T.
L. Miller (Ebasco). R. Tolson (TLOCD) asked JJL if JJL would renire T. L. Miller (Ebasco).
JJL replied "Decending on cirttnstances, yes".
C.
T.. Brandt (Ebases) volunteered to have T. L. Hiller (Ebasec) at the airocrt by three o' clock.
August 8, 1983 Page 2
' O
',y 27, 19S3
- Go tnrough project see:1fications
- Hest with swing shift insce: tion personnel
- 0: serve swing shift werk on polar crane and dome xly 28, !.983
- Heet JJN and give run cown on observations and potential or:clem areas
- Hest with Hark Wells (Gibds and Hill) and go over soe:1fication 2323A531 and FSAR commitments to ANSI Standards.
ANSI N5.12, 101.2, 101.4 (which ties into N45.2) and Regulatory Guide 1.54 are referenced in eitner tne soecif1:stion or FSAR.
Acvise JJN on specification /FSAR c:mitments
-Heeting witn J. Herritt (TUCOD), G. Crane (TUSI)
R. Tclson (TUC00), H. H:3ay (TUSI), J.}4, J3.
A)
JJN gave introduction whi:n included the fact that the Comanene Peak site is committed to ANSI recuirements and JJN then attempted to turn over dis =ussion to JJL.
B)
JCL s:arted by stating tnat baseo on 00se.rvations and soecification/ ANSI coraitments that there are areas for people to oe cncerned accut at C:canene Peak.
3CL oriefly reviewed for the indiviouals present that 050 nas nad extensive experience on nuclear oroje:ts, and tnat CSC is familiar with various means/metnces of satisfying ANSI recuirements.
R. Toisen (TUCCD) asked for examples of soe:ifi:
creolem areas or items.
JJL replied that sce:1 ries cannot be given witnout a th rougn review / audit.
How2ver, described ;rcolems witn material sLcn;;, :: inter cualificaticn/ino :trination, oossible cc:tsnentati:n ceficiencies, an: morale preelems.
C) JJL indicated that by Brown and Root estimates, only 36
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out of 452 individuals are of any value as painters.
JJL also stated that if Quality work is out in place
- nen they would be a lor way to r2 solving site proclems. Further JJL stated that there is currently a "No Win" situation on site between the craft and QC
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Inspectors, and even though this sounds corny, Brown and Root needs to develop a " Win-Win" situation.
CC-83-0096 August 8, 1983 Page 3 Cony rsation at this point took off on the areas of l'
assuring that individaals putting work in place are
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coing an adequate job or get disciplined, and changing morale.
4 D) Discussion tnen centered on wnat if any changes CSC would reecm.end for the soecification. Essentially Grown & Root is happy with the level of enfort ement/
inspection currently in force for the soecification/
procedum reqJirements. Also a change in the specification this late in the game would only confuse matters on site.
JJN to come up with a DCA for touen-up.
E) Prc0lems with the cuality of the air supply (takes up to half of the shift to have tne oil problem C rrected) were discusse anc now to c:rrect same.
F) Availa:ility and oualification of inspection personnel was discussed.
JON suggested tnat J. Coogan (EEI) may nave some people availacle.
J. Merritt (TUGO.0) suggested J. C ogan contact Jerry Hoops (Ebasco).
-Meeting witn J. Church (TUGOD VD) J. Herritt (TUCCC)
JON, JJ:
A)
J. Merritt (TUC00) reviewed /summari:ed discussi n of earlier meeting.
3)
- 3. Merritt (TLCCC) directed JJN/0GO to do no more
( ther than ree:mnend alternative air supply) until notified by TUCCO.
Inc following are the writers observations /cpinions as a result of this site visit:
A)
To so.e extent a parallel can ce drawn with Coman:ne Peak and Zimme'.
Comanche Peak is doing inspections to '
I tne cegree that they (Conan:ne Peak) are comforta0le witn or will tolerate. However in the real world the m ; - ' ',
are repuirements that have to be satisfied,.and in at
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least the areas of material storage, painter '
cuali Ication/ indoctrination, doc rentation and
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traceavility indications are that Cm.amne Peak f alls j
a snort in adecuately satisfying these requirements.' The writer's opinion is tha'..anagemenFat Coman e Peak
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has deluded itself into thinking eYerything-is alright
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or it will all come out in the wash. The fact that managemant attempts to scuash any efforts to point out cuality problems (No PCR;s, QC reabrting to productior*,
etc.) to some extent confirms the above, and n's led to a morale proclem with the inspection staf f. '
CAS-D-OC96 August 8, 1983
- age A 5)
Almost everyone in the inspection staff is looking to get out of Comanche Peak.
The inspection sta7f worxs 60-70 hours a week.
You Can't work people on an extended basis even with hign salaries (apparently only a few stay a wncle year).
In addition to the long hours the inspectors contacted by the writer (other disciplines included) all have a low opinion of the quality of the work put in place, and in effect are keeping quiet until they can find anotner jcb.
C)
Tne writer did not feel c:cfortable with the way J.71 presented the ANSI recuirements.
This has been discussed witn 2.w, and te a certain extent tne writer feels that at tne least tne manner of presentation was counter p;ccuctive
- Cannon's e f ferts.
The writer would like to state for tne re::::c that OSC ::ces satisfy all ap:11:acle ANSI recuirements and nas cone so on' numerous nuclegr pr::jects.
C. '
JJN and JJL discussed tne ::ossibility of OSC performing an in-oestn aucit.
The writer cannot reconmend an audit at
.nis time 'tecause 55R is nostile to the i ea anc n:: action would ce taken by B&R on pr:clems/:cncerns cetected during tne audit.
E)
Hip DFT of C2#11 is power ground to acce tacle DF'.
This wouic curnisn or polish the zinc, and possi::ly result in poc: acnesion of the tcp coat.
F) 010 Phenoline 305 (between 1-2 years old) is ceing
- c:catec with new Pnenoline 305 with little or no surface preparation (5::lvent wipe).
SUte%RY:
1)
This trip =as not as productive as the writer had hc;ed.
Of ten tne writer felt that B4R = anted to buy the "right" answer.
Inis is sw0stantiated to some extent by the fa::t that they did not try to utilize the expertise and/or experience of the writer with regard to Quality Assurance / Quality Control, and the attitude of the BAR management (especially Quality Assurance).
2)
If 080 tries to obtain a contract on thh site, the writer would suggest that it be a rework contract te:ause it will
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be impossible (by all indications) to salvage what werk is currently in place.
LY'c/l-#
4.A\\J. L'pinskh
[Quahi6 Assur ece Direct 5:
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