ML20041F175
| ML20041F175 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/08/1982 |
| From: | Opera G, Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, ST-HL-AE-796, NUDOCS 8203160261 | |
| Download: ML20041F175 (4) | |
Text
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The Light COE f Ifouston Ligluing & I ower I!O. Box 1700 1Iouston. Texas 77001 (713) 228-9211 ST-HL-AE-796 SFN: V-0530 March 8, 1982,/
lLk/ g Mr. John T. Collins fr ',
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Regional Administrator, Region IV
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Nuclear Regulatory Commission Qi g gefk.,
611 Ryan Plaza Dr., Suite 1000
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Dear Mr. Collins:
South Texas Project
' @n n-n q Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Final Report Concerning Service Level I Paintings & Coatings On September 22, 1980 in accordance with 10CFR50.55(e), Houston Lighting
& Power Company (HL&P) notified your office of an item related to the quality program for Service Level I Coatings applied by Brown & Root to concrete and steel surfaces within the Unit 1 Reactor Containment Building. A test program nas been completed by an independent agency and the results evaluated by Brown
& Root. The conclusion is that the very low percentage of required repair substantiates the quality of the coatings applied prior to January 9,1980.
Bechtel Power Corporation (BPC) has reviewed the subject reports and concurs with the disposition. As stated in our Third Interim Report, coatings were applied subsequent to January 9,1980 only after the applicable construction procedures were revised to conform with the Service Level I Concrete and Steel Coating Specificationr. Our final report concerning this item is attached.
Very truly yours, J
j M
prea Jr Exectl ive V President MEP/blt Atachment f[i
//s 7
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8203160261 820308 PDR ADOCK 05000498 S
Iketon ighung & Rmer Company cc:
G. W. Oprea, Jr.
J. H. Goldberg ST-HL-AE-796 J. G. Dewease SFN: V-0530 J. D. Parsons Page 2 D. G. Barker C. G. Robertson R. A. Frazar J. W. Williams J. W. Briskin J. E. Geiger R. L. Ulrey S. M. Dew J. T. Collins (NRC)
D. E. Sells (NRC)
W. M. Hill, Jr.
(NRC)
M. D. Schwarz (Baker & Botts)
R. Gordon Gooch (Baker &Botts)
J. R. Newman (Lowenstein, Newman, Reis, & Axelrad)
STP RMS Director, Office of Inspection & Enforcement Nuclear Regulatory Commission Washington, D. C. 20555 R. L. Range /G. W. Muench Charles Bechhoefer, Esquire Central Power & Light Company Chairman, Atomic Safety & Licensing Board P. O. Box 2121 U. S. Nuclear Regulatory Commission Corpus Christi, Texas 78403 Washington, D. C.
20555 R. L. Hancock/G. Pokorny Dr. James C. Lamb, III City of Austin 313 Woodhaven Road P. O. Box 1088 Chapel Hill, North Carolina 27514 Austin, Texas 78767 J. B. Poston/A. vonRosenberg Mr. Ernest E. Hill City Public Service Board Lawrence Livermore Laboratory P. O. Box 1771 University of California San Antonio, Texas 78296 P: 0. Box 808, L-46 Livermore, California 94550 Brian E. Berwick, Esquire William S. Jordan, III Assistant Attorney General Harmon & Weiss for the State of Texas 1725 I Street, N. W.
P. 0. Box 12548 Suite 506 Capitol Station Washington, D. C.
20006 Austin, Texas 78711 Lanny Sinkin Citizens for Equitable Utilities, Inc.
Citizens Concerned About Nuclear Power c/o Ms. Peggy Buchorn 5106 Casa Oro Route 1, Box 1684 San Antonio, Texas 78233 Brazoria, Texas 77422 Jay Gutierrez, Esquire Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Revision Date 2-22-82
5 Final Report Concerning Service Level I Paintings & Coatings I.
Sumary During a review of quality control documentation, inadequacies were discovered in some of the application records associated with Unit I Reactor Containment Building coating work which was performed by Brown & Root prior to January 9, 1980. Because containment coatings are considered safety-related and because documentation irregularities could potentially conceal significant deficien-cies, it was decided to report the matter to the NRC.
An independent agency was retained to assess the magnitude of the apparent documentation problem. Though the predominance of availaole data suggested a satisfactory level of coating application quality in general, the nature of inadequacies discovered during the review of coating work records was suffi-ciently serious to warrant additional assurance. A program was developed to supplement the documentation by a series of field tests of the affected coatings.
The generally good results demonstrated by the tests have dispelled our prior concerns. We are confident that the existing documentation, as supplemented by physical field tests, provides ample assurance of good quality work, and that the applied coatings will not present a safety hazard.
II.
Description of Incident In January 1980, a Nonconfomance Report and Stop Work Notice were issu a for Service Level I coatings as a result of deficiencies discovered in coating records during a review of construction and quality control documentation.
Areas of concern included the Applicator's Coating Record, Surface Preparation Record, and the Coatings Inspection Book.
In order to fully evaluate the im-portance of these documentation concerns, Brown & Root contracted a consulting fim to perfom a survey of the records and procedural requirements. The con-sultant's report was issued in August 1980 and, based upon our evaluation, the NRC Region IV office was notified of an item pursuant to 10CFR50.55(e).
In addition to the documentation concerns, the integrity of the reactor cavity coatings was reviewed because the combined operational and accident radiation dose level is calculated to exceed the qualification basis of the coatings, particularly in the upper cavity region. The coating material could, therefore, become unstable and fail.
III. Corrective Action / Recurrence Control The first element of corrective action and recurrence control occurred in January 1980 and consisted of revising the construction procedures to bring them into confo mance with the specifications.
In June 1980, both the speci-fications and construction procedures were further improved.
, IV.
Safety Evaluation A comprehensive program to field test coatings that were applied prior to January 1980 was initiated to supplement the documentation with physical data.
The first stage was the establishment of basic parameters, acceptance criteria, and methods of testing.
The next stage was the actual physical testing. A description of the separate test programs for concrete and steel was provided in our Third Interim Report.
Final reports of the test programs were provided by the consultant to Brown & Root for evaluation.
Tests were conducted throughout the containment building on coatings over steel and concrete substrates. Tests at each location included measurements of film thickness and adhesion. The latter was measured by two different methods on concrete coatings and by three methods on steel coatings. Results were then compared with acceptance criteria.
The generally high quality of the coating application was substantiated by the fact that, on the basis of these tests, only 1,636 square feet of the over 200,000 square feet that were type-tested have been identified as being in need of corrective action.
In view of this, it can be deduced that the deficiencies in the documentation did not constitute evidence of a s1961ficant degradation in overall coatings quality and that the coatings will not present a safety hazard.
Regarding the coatings in the reactor cavity, it is conservatively assumed that in the case of a DBA, coatings receiving total radiation doses in excess of their qualification basis will fail.
An analysis considering the specific gravity of the failed coatings, the flow rate and velocity at floor level of the recirculating cooling water, as well as the distance and the configuration of the flow path to the emergency sumps, concluded that the failed coating material from this source will not unacceptably degrade the operation of the recirculation system and therefore will not present a safety hazard.
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