ML20032E586

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IE Insp Repts 50-445/81-15 & 50-446/81-15 on 811013-16 & 19-23.Noncompliance Noted:Failure to Follow Procedures for Insp of Steel Coatings
ML20032E586
Person / Time
Site: Comanche Peak  
Issue date: 11/05/1981
From: Randy Hall, Clay Johnson
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20032E578 List:
References
50-445-81-15, 50-446-81-15, NUDOCS 8111200717
Download: ML20032E586 (7)


See also: IR 05000445/1981015

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APPENDIX

U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND Ef:FORCEMENT

REGION IV

Report:

50-445/81-15; 50-446/81-15

Dockets:

50 445; 50-446

Category A2

Licensee:

Texas Utilities Generating Company

2001 Brycn Tower

Dallas, Taxas 75201

Facility Name:

Comancne Peak, Units 1 and 2

Inspecticn at:

Comanche Peak Site, Glen Rose, Texas

Inspection caducted:

October 13-16 and 19-23, 1981

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Inspector:

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[C.E.' Johnson,ReactorInspector,Engineeringand

Date

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Materials Giction

Other

Accompanying

Personnel:

R. E. Hall, Acting Chief, Engineering and Materials Section

(October 23, 1981)

Approved: /' /f.le

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R. E. HalIN Acting Chief, Engineering and

Date

MaterialY Section

Inspection Summary

Inspection Conducted October 13-16 and 19-23, 1981 (Report No. 50-445/81-15;

50-446/81-16)

Areas Inspected:

Routine, unannounced inspection of construction activities

incluaing a site tour and observation of work and review of records for

safely-related pipe supports, protective coatings, and restraint systems in

Units 1 and 2.

The inspection involved sixty-five inspector-hours by one NRC

inspector.

Results:

In the three areas inspected, no violations or deviations were

identified in two areas.

One violation was identified in the area of

protective coatings (violation - failure to follow procedures for the

inspection of coatings

paragraph 3.b).

8111200717 811106

DR ADOCK 05000

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DETAILS

1.

Persons Contacted

Princir al Licensee Personnel

  • D. N. Chapman, Texas Utilities Generating Company (TUGCO), Quality

Assurance Manager

  • R. G. Tolson, TUGCO, Site Quality Assurance Supervisor

B. C. Scott, TUGCO, Quality Engineering

Other Personnel

  • J. R. Merritt, Texas Utilities Services, Inc., (TUSI), Engineering

and Construction Manager

J. V. Hawkins, Brown & Root (B&R), Project Quali / Assurance Manager

H. Williams, B&R, QC Superintendent, Non-ASME

J. Ragan, B&R, Site QC Manager

The NRC inspector also contacted other licensee and Brown & Root

employees during the inspection period including both craft labor and

QA/QC personnel.

  • Denotes presence at the exit interview conoucted October 23, 1981.

2.

Site Tour

The NRC inspector toured the site several times during the inspection to

observe construction activities in progress and to inspect housekeeping.

The areas toured included the Units 1 and 2 Reactor Containment Buildings,

Safeguards Building, Auxiliary Building, paint shop, and paint warehouse.

There were no violations or deviations identified.

3.

Protective Coating

a.

Concrete Coatings Application

The NRC inspector reviewed six records of protective coating

application on concrete in Reactor Containment Building No. 2.

The NRC inspector identified some procedural inconsistencies

including those listed below.

(1) no inspector initials or signature

(2)

incorrect pot life specified or indicated

(3) dates missing

(4)

induction time signed N/A when there should have been a

minimum time listed

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In four of the six records observed, the finish coat had been

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applied; however, checklists documenting the preceding applications

had neither been completed nor finally accepted. The majority of

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the inspection docuiaentation had not hac final acceptance.

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The NRC inspector informed the. licensee representative of the

discrepancies found. The licensee representative then informed the

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NRC inspectcr that they were aware of the problems. After a brief

discussion, the licensee representative showed the NRC irspector an -

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audit report performed during September 14-18, 1981, by TUGC0 QA

pertaining to this matter. The audit report was' titled, " Protective

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Coatings," QA Audit File: TCP-24. This audit identified the same

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deficiencies as did the NRC inspector. The scope of the audit

included receiving, storage and handling, certifications, measuring

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and testing equipment, application, and inspection documentation

regarding protective coatings on concrete. This audit requested a

response to the deficiencies and concern: identffied by November 6,

1981.

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This matter will be listed as an unresolved item until a satisftctory

reply to the QA Audit, TCP-24 has been documented in a timely manner

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and reviewed by an NRC inspector on a subsequent inspection.

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b.

Steel Coatings Application

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The NRC inspector also reviewed records on protective coating appli-

cation on steel. During the review of these records, the NRC

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inspector noticed that the most current records for miscellaneous

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steel and supports dated from late September 1979 and back. The

NRC inspector reviewed one package which contained several records

of miscellaneous embedments and door frames in Reactor Building No. 2.

This cackage contained documents that were not properly filled out

or Mere incomplete. For example, dry film thickness (OFT) of primer

after application was not recorded and initialed by Quality Control

inspectors on the checklist prior to application of the seal coat as

required. The NRC inspector also noticed incorrect pot life require-

ments on the protective coating material identification and mixing

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checklist. The licensee representative was informed of the defi-

ciencies noted by the NRC inspector.

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The NRC inspector inquired about records of inspection conducted

since September 1979. The licensee representative informed the

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NRC inspector that from late September 1979, there had been no

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checklists maintained as required by the procedures for miscella-

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neous steel, cable tray supports, and pipe supports noted in

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paragraph 3.f below. The licensee representative presented a

log book that Quality Control was maintaining on cable tray

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supports. The licensee representative also informed the NRC

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inspector that they have maintained a log book on miscellaneous

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steel, pipe hangers, and supports. After reviewing the log book,

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the NRC inspector determined that this did not appear to satisfy

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the records requirements'of the procedures. The NRC inspector also

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reviewed protective coatings records of Unit 2 Reactor Building steel

iiner plate, from September 1980 to October'1980.

In reviewing these

records, the NRC inspector noticed that documentation on the " Steel

Substrate Primer Application Checklist" had not been completely filled

out prior to seal coat applications as required by procedure.

This appears tol be in violation of procedural requirements and

10 CFR 50, Appendix B, Criterion V.

c.

Paint Shop

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The NRC inspector toured the paint shop and reviewed coating records

in process by a Quality Control inspector. All records reviewed at

the paint shop appear to conform to Procedures QI-QP-ll.4-1,

QI-QP-ll.4-2, and QI-QP-ll.4-3 as listed in paragraph 3.f.

The NRC

inspector discussed procedural requirements with the Quality Control

inspector in char ge of the paint shop. The Quality Control inspectcr

demonstrated an apparent level of knowledge sufficient to inspect

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protective coating on steel.

The NRC inspector also discussed procedural requirements and qualifi-

cations for applicators with a paint foreman. The paint foreman also

appeared to have the level of knowledge required for protective

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coating applications.

During the tour, the NRC inspector observed some sandblasting taking

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place; however, there was no coating application going on at the time

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on safety-related items.

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There were no violations or deviations identified.

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d.

Paint Warehouse Storage

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The NRC inspector toured the "Q" paint warehouse and randomly inspected

for opened containers and expired dates for shelf life of containers.

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There are two warehouses, one a non "Q" and the other a "Q'" warehouse.

The NRC inspector verified the readings of the temperature recorder

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which varied between 70 degrees and 75 degrees. The temperature was

well within the specification. The temperature recorder calibration

date was current. The NRC inspector reviewed records of the temper-

ature charts and the surveillance checklist for storage and control

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of coatings. The temperature charts covered from January 1,1981, to

August 31, 1981, and the temperature was maintained within the speci-

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fied range. The checklists were filled out and signed. The only

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discrepancy noted on the checklist was in the block " shelf life

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expired", which had been checked in the "yes" blocks. After inquiring

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into this matter, it was found to be in error since the shelf life had

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not been exceeded. This was an isolated case which was immediately

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corrected.

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There were no violations or deviations identified.

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Qualification Records (Coatings)

The NRC inspector reviewed qualificati^n records for six Quality

Control inspectors and ten painters.

The Quality Control inspectors

and painters selected for review were indicated on the records of

six safety related items which had been painted and inspected.

The

NRC inspector traced the qualifications of each Qualitiy Control

inspector and painter on the records during that time period to verify

each individual's qualifications.

All Quality Control inspectors and

painters were qualified during the period of applications.

There were no violations or deviations identified.

f.

Review of Coating Procedures

The NRC inspector reviewed the coating procedures listed below.

All procedures reviewed appeared to include sufficient instructions

and appropriate quantitative and qualitative acceptance criteria for

determining that important activities would have been satisfactorily

accomplished.

Procedures reviewed:

Steel

CP-QP-ll.4, Revision 4, " Inspection of Protective Coatings"

QI-QP-ll.4-1, Revision 3, " Inspection of Steel Substrate Surface

Preparation"

QI-QP-ll.4-2, Revision 4, " Inspection of Steel Substrate Protec-

tive Coating Mixing Operations"

QI-QP-ll.4-3, Revision 5, " Inspection of Steel Substrate Prime

Coat Applications"

QI-QP-ll.4-5, Revision 4, " Inspection of Steel Substrate

Finish Coat Application"

QI-QP-11.4-17, Revision 1, " Storage and Handling of Protective

Coatings"

Concrete

QI-QP-ll.4-10. Revision 1, " Inspection of Concrete Substrate

Surface Preparation"

QI-QP-ll.4-12, Revision 1, " Inspection of Concrete Substrate

Surface Application"

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QI-QP-11.4-14, Revision 1, " Inspection of Concrete Substrate

Finish Coat Application"

There were no violations or deviations identified.

4.

Safety-Related Pipe Support and Restraints

a.

Moment Limiting Components

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spector toured Unit 1 Reactor Containment Building and

randomly selected three monient restraints listed below for inspection:

(1) S-1-0538-06 - Safety Injection System (incomplete)

(2) 5-1-0538-02 - Safety Injection System (complete)

(3) S-1-0538-08 - Chemical and Volume Control System (complete)

The NRC inspector visually inspected the completed moment restraints

in accordance with referenced design drawings. Welds, attachments,

and location all appeared to be in compliance with design drawings.

The NRC inspector reviewed the traveler package contents on work

being performed in Unit 1 Reactor Containment Building, on the

Safety Injection vertical line restraints in each of the four steam

generator compartments.

All documentation appeared to be in the

traveler package as required.

All changes and modifications had

been approved.

The moment restraints reviewed were all fabricated by an off-site

vendor.

The constructor erected, aligned, and welded as required

by the design drawings.

The records of the two completed restraints indicated that verifi-

cation of elevation, location, plumb, and levelness had been verified

by Quality Control.

All welds were in accordance with design drawings

and verified by Quality Control.

Completion of all operations were

verified, signed, and initialed by Quality Control.

The NRC inspector

verified welder qualifications from the completed travelers and also

for work in process in the field.

All welders were found to be

qualified by procedure for the work being performed.

b.

Pipe Supports

The NRC inspector reviewed the records of five pipe supports.

The

records indicated the type and classification of the supports.

The

records confirmed that the specifications and installation procedures

had been met.

The required scope of QA/QC inspections was met. Weld

identification and location corresponded to respective weld card,

drawirig, and work order.

Welders were qualified for the welding

procedures used.

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Records reviewed were for the pipe supports listed below:

CT-1-029:118-C82S - (Contrinment Spray System)

CT-1-014-421-C62R - (Containment Spray System)

CT-1-031-307-C92R - (Containment Spray System)

CS-1-074-047-542R - (Chemical and Volume Control System)

CS-1-074-041-542R - (Chemical and Volume Control Syste.1)

There were no violations or deviations identified.

S.

Unresolved Items

Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items, violations, or

deviations.

An unresolved item disclosed during this inspection is dis-

cussed in paragraph 3.a.

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Exit Interview

The NRC inspector met with tSe licensee representatives (denoted in

paragraph 1) and R. G. Taylor, NRC Resident Reactor Inspector, on

October 23, 1981, and summarized the purpose, scope, and findings of

the inspection.

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