ML20078A593
| ML20078A593 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/28/1988 |
| From: | GEORGIA POWER CO. |
| To: | |
| Shared Package | |
| ML20078A351 | List:
|
| References | |
| PROC-880628, NUDOCS 9406020248 | |
| Download: ML20078A593 (200) | |
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O VOGTLE ELECTRIC GENERATING PLANT UNIT 2 READINESS REVIEW PROGRAM MODULE 13B - COATINGS 1
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9406020248 940512 l PDR ADOCK 05000424 i P PDR l
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PREFACE Georgia Power Company (GPC), in order to gain added assurance of .
i the operational readiness of the Vogtle Electric Generating Plant (VEGP), conducted a pilot Readiness Review Program for Unit 1. The VEGP pilot Readiness Review Program was a systematic, in-depth self-assessment of work processes and verification of compliance with regulatory commitments. To accomplish the VEGP pilot Readiness Review Program, the work processes and regulatory commitments were divided into manageable segments called modules. There are 22 modules. Each module is a predefined scope of VEGP activities.
Each module provides a brief description of the method of complying with project licensing commitments pertaining to the module scope and is not intended to make further commitments or to revise in any way prior commitments. ;
l hetivities common to several modules are defined in General Appendixes. There are seven appendixes. These appendixes, as appropriate, are referenced in the modules and are augmented in l each module with module-scope-specific details as needed.
The VEGP pilot Readiness Review Program was conducted on a schedule to provide added operational readiness assurance to GPC i management in support of the VEGP Unit 1 operating license.
Conclusions reached regarding programmatic and technical O adequacy through review of VEGP Unit 1 are indicative of Unit 2, since both units are being designed and constructed together l
under a single quality assurance program: with similar j management controls, procedures, specifications, and criteria. ;
The Unit 2 Readiness Review Program extends the results of the Unit 1 review by assessing activities, hardware, and documents within the scope of selected modules and ascertaining compliance with licensing requirements.
The VEGP Unit 2 Readiness Review Program is'being condu:ted on a j schedule to provide added operational readiness assurance t9 GPC management in support of the VEGP Unit 2 operating license.
The VEGP Readiness Review Program is not. intended to eliminate or to diminish any authorities or regulatory responsibilities now assigned to or exercised by the Nuclear-Regulatory Commission or GPC. Further, the Readiness Review Program is not intended to change the techniques of inspections or assurance of quality program activities. Rather, the VEGP Readiness Review Program is an adde? program initiated by GPC management to I assess'the VEGP and to provide' additional feedback to management j so that_they may initiate any needed corrective actions in an i orderly and timely manner.
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The work processes and regulatory commitment compliance covered by each module scope will be assessed by, and the module prepared and reviewed by, individuals collectively familiar with the design, construction, and preoperational processes of lh nuclear power plants. It is the collective opinion of the Readiness Review Task Force, Readiness Review Board, and GPC management that, based on their experience, the methodology used in the module process will assess, on a programmatic basis, the adequacy of project commitment implementation.
Readiness Review findings and resulting dispositions are reviewed by the Project Quality Assurance staff and are input into the normal project process for safety significance and potential reportability evaluations in accordance with regulatory requirements.
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EXECUTIVE
SUMMARY
This module documents a review conducted to ascertain whether the design and construction aspects of protective coatings at Vogtle Electric Generating Plant Unit 2 comply with licensing commitments and whether compliance is verifiable using existing project documentation. Protective coatings reviewed are the prequalified systems applied within the containment.
The ruview program for Unit 2 used the results of the Unit 1 review program as a base, and focused on differences between the units. These differences included added or revised licensing
'committants and changes resulting from project evolution or correct'.ve actions to Nuclear Regulatory Commission (NRC) findings, project findings, design changes, or hardware modifications. The review consisted of technical and programmatic evaluations of the design and construction processes and results. Project documents such as design criteria and procedures; design output such as specifications and drawings; and construction results such as applied coatings and quality documentation were examined during the review.
Discrepancies noted during review activities were issued to the Project as findings. Following receipt and evaluation of the .
responses, the findings were subject to categorization as follows to indicate their relative importance:
Level 1 - Violation of licensing commitments, project procedures, or engineering requirements with indication of safety concern.
Level II - Violation of licensing commitments or engineering requirements with no safety concern.
Level III - Violation of project procedures with no safety concern.
The Readiness Review Program evaluation of protective coatings in VEGP Unit 2 consisted of three major activities:
Commitment Implementation Review ,
Readiness Review has maintained the listing of commitments for design and construction developed during the Unit 1 Readiness Review Program through review of Final Cafety Analysis Report amendments and letters to the NRC. The Project Engineering and Construction organizations were issued the listing of commitments applicable to this module at the beginning of the review period; and the Project provided Readiness Review with updated implementation !
information which is presented in section 3.
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Unit 1 Findino Followup During the assessment of Unit 1, the Project committed to h the performance of certain corrective actions. For Unit 2, Readiness Review provided Project Engineering and Construction with a list of Unit 1 findings and corresponding corrective actions. These two groups evaluated those findings applicable to Unit 2 activities and informed Readiness Review as to the action taken. The listing of Unit 1 findings and Unit 2 actions is presented in section 5.
Assessment The Unit 2 assessment of protective coatings consisted of an evaluation of commitment implementation, Unit 1 finding followup, and an assessment of design and construction activities to ascertain project compliance to commitments.
During the assessment, Readiness Review verified the updated implementation and Unit 1 finding followup information provided by the Project.
During the assessment of design and construction, Readiness Review chose and evaluated a sample of design documents, in-process applications, and applied coatings to determine acceptance to specified criteria and conformance to installation and procedural requirements. Three in-process applications, 10 applied coatings and approximately 140 documents were examined. lll Six findings were issued during the assessment; five classified as Level II and one as Level III.
None of the corrective actions required repair or rework of applied coatings. Some quality records were found deficient; however, sufficient documentation to provide objective evidence of required quality was found. Four of the findings related to contractor procedure deficiencies; however, these deficiencies had not resulted in defective coatings or programmatic concerns.
The findings collectively showed a lack of attention to detail in contractor procedures. Evaluation showed that these errors in detail had no effect on applied coatings and did not represent a safety concern. The findings were judged to be isolated instances of failure to comply with engineering or licensing requirements, or with procedures, with no safety concern and do not indicate, either individually or collectively, programmatic concerns.
Readiness Review Conclusion Based on the results of the review, and with the implementation of effective corrective actions to the identified findings as ll l
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committed to by the Project, Readiness Review concludes that adequate programs exist to ensure: the quality of design and j
% construction; objective evidence of that quality has been i(>3 documented; and the licensing commitments within the scope of l this module have been implemented.
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MODULE 13B i COATINGS TABLE OF CONTENTS Section 1 Introduction 1.1 Scope 1.2 Module Organization 1.3 Status l Section 2 Organization 2.1 Introduction 2.2 Design 2.3 Construction Section 3 Commitments 3.1 Introduction 3.2 Commitment and Implementation Matrices Section 4 Program Description 4.1 Design 4.2 Construction Section 5 Audits and Inspections 5.1 Introduction 5.2 Project Audits 5.3 Nuclear Regulatory Commission Inspections 5.4 Reportable Deficiencies and Special Evaluations 5.5 Unit 1 Finding Followup Section 6 Program Assessment 6.1 Introduction 6.2 Program Description 6.3 Summary and Conclusions 6.4 Assessment Activities and Results
6.5 Findings
i Section 7 Assessment of Module Adequacy Project Quality Assurance Readiness Review Board Section 8 Assessment Plan and Checklists 0
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1 INTRODUCTION O
k_) 1.1 SCOPE This module is one in a series of modules that provides an evaluation of the design, construction, and preoperational testing of the Vogtle Electric Generating Plant Unit 2. It is intended to describe the method of complying with the project commitments found in the Final Safety Analysis Report (FSAR) and is not intended to make further commitments or revise in any way, prior commitments. If any differences exist between the commitment descriptions in this document and the FSAR, those differences are unintentional and the FSAR shall take precedence and shall define the project commitments.
The scope of this module encompasses design, procurement, construction, and inspection activities associated with protective coatings inside containment.
The checks, reviews, inspections, audits, and verifications performed to ensure the adequacy of design and construction functions are examined. The organizations responsible for performing design and construction activities are identified and the work activities that the organizations perform are described. The project commitments for coatings are identified, the method of implementation is listed, and the results of a review for' compliance to the committed requirements are O presented.
The effective date of the module is February 1, 1988. Changes to the included programs, organizations, commitments, etc.,
occurring after this date are not necessarily addressed.
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i 1.2 MODULE ORGANIZATION f This module is divided into the following sections:
- 1. Introduction.
- 2. Organization - A brief description of the project l organizations and their division of responsibilities as :
applicable to this module. .
- 3. Commitments - Project licensing commitments pertaining >
to coatings as found in the Final Safety Analysis f Report, responses to Inspection and Enforcement ;
Bulletins, and correspondence to the Nuclear Regulatory f Commission (NRC). This section also lists the documents that demonstrate implementation of these commitments. i
- 4. Program Description - A brief description of the l processes for design and construction applicable to the !
scope of this module. ;
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- 5. Audits and Inspections - Listings of Quality Assurance !
(QA) audits and findings and NRC inspections and -
violations applicable to the scope of the module and i conducted since the Unit 1 module. A description of special investigations is provided. The Readiness i es Review findings and NRC violations f rom the Unit 1 l module activity are listed, the corrective actions are .
presented, and their applicability to Unit 2 is !
-indicated. ,
- 6. Program Assessment - A description of the assessment !
plan development, plan implementation, and results, l including corrective actions.
- 7. Assessment of Module Adequacy - The evaluations and )
conclusions of this module by the Project, QA, and the i Readiness Review Board. l
- 8. Assessment Plan - The assessment plan and checklists utilized by the Readiness Review Team.
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1.3 STATUS
'O As of the February 1988, the design of coatings was essentially
\) complete and application of coatings inside containment was approximately 68-percent complete.
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I 2 ORGANIZATION
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2.1 INTRODUCTION
Georgia Power Company (GPC), acting on its own behalf and as agent for the Oglethorpe Power Corporation, the Municipal Electric Authority of Georgia, and the City of Dalton is responsible for the design, procurement, construction, and operation of the Vogtle Electric Generating Plant. GPC administers the overall quality assurance program, provides procurement services, controls materials issue, performs certain quality control inspections, and provides construction services for calibration, tests, inspections, document control, and nonconformance control.
Bechtel Western Power Company (BWPC) is contracted by GPC to provide architect / engineering services for plant equipment / systems contained within the Seismic Category I structures and is responsible for the overall design coordination of all plant equipment / systems.
Williams Power Services, Inc. (Williams) is the contractor for coatings and is responsible for the application and inspection of coatings within the scope of this module.
Figure 2-1 shows the overall Project organizational structure for the scope of this module. The following sections contain
() brief descriptions of the individual GPC, BWPC, and Williams groups that perform activities related to coatings.
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2.2 DESIGN l
/~N Project Engineering is responsible for the design of coatings.
This responsibility ir divided between two project organizations: Design Engineering (DE), and Installation Engineering (IE). These organizations are comprised of personnel from Bechtel Western Power Company (BWPC) and Southern Company Services, with BWPC having overall design responsibility. The Project Engineering organizational structure for the scope of this module is shown on Figure 2-2, 2.2.1 DESIGN ENGINEERING DE is located at the jobsite with support staff in Norwalk, California. The design of coatings is primarily performed by the civil discipline with specialty support provided by the Materials and Quality Services Department of the Research and Development group of Bechtel.
2.2.2 INSTALLATION ENGINEERING IE is located at the jobsite and is primarily responsible for '
the resolution of field problems identified by the project construction organization. IE is responsible for. maintaining the construction specification for field coating applications.
IE reports to the Georgia Power Company Civil Discipline for O,. project direction and to the plant design and civil project engineer and the civil / structural / architectural engineering group supervisor (EGS) of DE for technical direction.
2.2.3 ORGANIZATIONAL CHANGES In January 1987, Project Engineering, then comprised of Home Office Engineering (HOE) and Project Field Engineering (PFE) was restructured to better support the construction effort. The major elements of this restructuring were:
o Transfer of personnel from Norwalk (HOE) to the site.
This onsite group, along with the few remaining personnel in Norwalk, became DE.
o Relocation of PFE personnel from one central onsite location to individual groups located in proximity to each construction discipline. These groups became IE.
o Designation of a single EGS for each design discipline with overall responsibility for DE and IE work.
o Design activities in direct support of construction work were assigned to the IE groups.
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o Design activities of a general or oversight nature were l assigned to the DE group.
o Control of Project Reference Manual, Design Manual, and O i responsibility for providing technical direction to the IE groups were assigned to DE.
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P 2.3 CONSTRUCTION Project Construction-is responsible for installation and O inspection of protective coatings. This responsibility is divided between the Civil Discipline and Quality Control (QC).
These organizations are comprised of personnel from Georgia Power Company (GPC) and contractors reporting to GPC. The overall Project Construction organization is shown on Figure 2-3.
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t 2.3.1 CIVIL DISCIPLINE Tne Civil Discipline organization includes three groups I performing coatings activities under the direction of the civil :
discipline manager. Those groups are GPC Civil Engineering j Section, Civil / Architectural Installation Engineering, and !
Williams Power Services, Inc. (Williams).
The GPC Civil Engineering Section provides technical direction !
and support to the coating contractor, including review and '
approval of contractor application procedures, resolution of problems such as constructability issues and deviation reports.
- and material requisitions and releases to support contractor ;
needs.
Civil / Architectural Installation Engineering, as described in !
section 2.2.2, performs design activities to support resolution j of field problems.
The coating contractor, Williams, stores, applies, and inspects coatings and is responsible for providing craft, supervisory, and inspection personnel. Williams QC inspection is controlled j by the Williams quality assurance (QA) program. The Williams QA Manual is reviewed for conformance to project commitments and l approved by GPC QA. The Williams organization is shown in l Figure 2-4. .
Williams QC verifies that surface preparation, environmental !
conditions, and coating application conform to approved specifications and drawings, codes, and manufacturer's ,
, requirements. Inspections are controlled by procedures developed by Williams QC to implement provisions of the Williams QA Manual. Inspectors are certified in a program contrulled by ;
procedures and meeting ANSI N45.2.6 requirements. Williams QC procedures are reviewed and approved by GPC QC. l 2.3.2 GEORGIA POWER COMPANY QUALITY CONTROL j GPC QC is divided into five groups under the direction of the !
manager of quality control as shown in Figure 2-5. GPC QC monitors the contractors QA/QC program, provides tool i 5
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calibration service, reviews and approves Williams QC procedures, and performs receipt inspection of GPC procured, prequalified coating materials. llh The Civil QC Section conducts surveillance inspections of coating work as it is performed by Williams craftsmen and inspected by Williams QC. Surveillance inspection is conducted in accordance with GPC QC procedures and to the requirements of the applicable contractor procedures, construction specification, and design drawings.
2.3.3 CONSTRUCTION ORGANIZATIONAL CHANGES No significant changes have been made in the construction organizations with coatings responsibilities since the Unit 1 Readiness Review assessment.
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O O O LEGEND PROJECT DIRECTION
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CIVIL / MECHANICAL CONTRACTOR QA/OC l OC SECTION PROGRAMS e COATINGS SURVEILLANCE # WILLIAMS PROGRAM
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Figure 2-5 Georgia Power Company Quality Control
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J 3 COMMITMENTS
3.1 INTRODUCTION
This section contains, in matrix form, licensing and project l commitments and the corresponding implementing documents. These !
are presented in two matrices, the commitment matrix and the )
implementation matrix. )
l Commitments '
A commitment is an obligation to comply with the described l requirements of an industry standard, Regulatory Guide, Branch ;
Technical Position, or owner plan of specific action. For the l purposes of Readiness Review, commitments are identified from the following sources:
o Final Safety Analysis Report (FSAR), including responses '
to Nuclear Regulatory Commission (NRC) questions.
o Responses to Inspection and Enforcement Bulletins.
o Correspondence to the NRC.
These sources were reviewed and commitments were selected for ,
inclusion on the matrix using the following guidelines:
o Specific design and/or construction requirement.
o Specific standards of acceptance.
o Specific cited technical data used as a design basis and/or unique design methodology.
o Specific codes, standards, or regulatory requirements.
Descriptions, detailed data and/or parameters resulting from design activities, general codes, and regulations are not generally considered licensing commitments. These include:
o Dimensions.
o System operational concepts or operational descriptions.
o Design calculation details such as strength parameters, flow rates, etc.
o References to general standards such as 10 CFR 50, American Society of Mechanical Engineers (ASME),
American Concrete Institute, etc. (specific requirements from such bodies, however, are commitments).
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Implementation An implementing document is a working level document that h imposes the requirements of the commitment to a specific activity. Implementation of comaitments is typically found in the following:
o Design Criteria.
o Material Specifications.
o Construction Specifications.
o Project Reference Manual.
o Field Procedure Manual.
o Drawings.
Additionally, the Project has a commitment to comply with 10 CFR 50, Appendix B, Quality Assurance Criteria, and industry standards such as ANSI /ASME N45.2 and N45.2.11. Although they may not have been identified as specific commitments in this module, Readiness Review considered the applicable requirements of these types of commitments in preparing and assessing the scope of work presented by this module.
Commitment descriptions in this section are for identification and are not intended to make further commitments or to revise in lh any way prior commitments.
Differences, if any, between the descriptions in this section and the commitments in the FSAR are unintentional and the commitments in the FSAR take precedence.
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3.2 COMMITMENT AND IMPLEMENTATION MATRICES
-During the Unit 1 Readiness Review Program, the task force O ~
performed a systematic review of licensing documents and identified the Project commitments. Once identified, these commitments were listed in a document called the commitment matrix. Readiness Review has maintained the' matrix current for design and construction through review of Final Safety Analysis Report (FSAR) amendments and letters to the Nuclear Regulatory '
Commission. Additionally, during the Unit 1 Readiness Review, the task force identified project controls that implemented the commitment requirements (i.e., design criteria, specifications, .
construction procedures, etc.) and listed them on a document called the implementation matrix. For Unit 2, the commitment matrix and implementation matrix were transmitted to the ;
appropriate project organizations for updating of the !
implementation matrix data to reflect the latest implementing documents. Upon completion, the updated matrix was returned to i Readiness Review which verified the accuracy, on a sampling basis, as described in section 6.
Each commitment entry in the commitment matrix is identified by a un'ique reference number. This reference number is also shown !
for the same commitment line entry in the implementation ,
matrix. A single commitment may be addressed by multiple entries in the implementation matrix, either to address separate elements of commitments or to provide space to reference a number of implementing documents. I'n such instances, the O multiple entries are distinguished by decimal numbers after the commitment reference number.
There have been no changes in commitments for this module since the Unit 1 assessment.
Th'e commitment and implementation matrices are presented following this section. Commitments are current through i Amendment 34 of the FSAR.
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- PLANT VOGTLE UNIT 2 READINESS REVIEW PROGRAM .
COMMITMENT MATRIX
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REF. COMMITMENT COMMITMENT COMMITMENT DOCUMENT / MOD DES CON FSAR REMARKS NUMBER SOURCE SECTION SUBJECT FEATURE ULE IGN ST AMEN
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EXPLANATION OF FIELDS REF. NO. - A reference number that corresponds to the appropriate time entry is the implementattom matrix COMMITMENT SOURCE - The document costeleing the commitment (FSAR, Generic Letter, l.E.
Bullette Respoase, etc.l COMMITMENT SECTION - identlfles th* FSAR sectles, letter member, or questlos number
- COMMITMENT SUBJECT The subject of the FSAR section or Generic Letter DOCUMENT / FEATURE -
The document discussed la the FSAR section or the pleet festero 4 descrlhed in the FSAR section MODULE - The module for which the commitment is implemented DESIGN / CONSTRUCTION - An X is placed under the headlag for the orgenlaetlos responsible
.for laplementetlom of the commitment FSAR AMENDMENT - FSAR emoedmont number for revised commitments la aero lel is placed In this colume for changes made prior to Amendment 13 '
intert of Unit i Reedlaess Revleell NOTE:
Commitment changes from those presented la the Unit I modulo are identlflod by a vertical row of X's la the left margin.
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PLANT VOGil.E UNIT 2 READINESS REVIW PROGRAM ,
COMMITNENT MATRIX - HODULE 138 i ======================================
REF. COMNITNENT CONNITNENT CONHITHENT DOCUMENT / FSAR REMARKS l NUMBER SOURCE SECTION SUBJECT FEATURE MODULE DESIGN CONST AMEN
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1 1(,03.00 FSAR 1. 9. 54 0.A. REQUIREMENT FOR RG 1.54, REV. O, 13B X X 0 SEE TABLC 6.1.2-1 PROTECTIVE COATINGS 6/73 FOR CONFORMANCE i APPLIED TO WATER-COeA ED NUCLEAR PLANT l 1604.00 FSAR 1. 9. 54 Q.A. REQUIREMENT FOR ANSI N101.4 (1972) 138 X X O SEE TABLE 6.1.2-1 PROTECTIVE COATINGS FOR CONFORMANCF APPLIED TO ,
, WATER-COOLED NUCLEAR PLANT
- 1317.00 FSAR 6. 1. 2. 1 ORGANIC MATERIALS ANSI N101.2(1972) 13B X O ,
PROTECTIVE COATINGS IN CONTAINMENT 1310.00 FSAR 6. 1. 2. 1 ORGANIC MATERIALS RG 1.54, REV. O, 138 X X 0 SEE TABLE 6.1.2-1 PROTECTIVE COATINGS 6/73 FOR CONFOHNANCE IN CONTAINMENT 4820.00 FSAR 8. 3. 1. 1. 3.k STANDBY POWER SUPPLY FLOOR OF DIESEL 138 X X 0 TO MINIMIZE DUST GENERATOR BUILDING COATED WITH EPOXY TO 4
PREVENT CONCRETE ABRASIVE DUST FROM INTERFERING WITH OPERATION OF 1 ELECTRICAL EQUIPMENT t 3918.00 FSAR 9. 5. 4. 2 ENERGENCY DIESEL EXTERIOR SURFACES OF 138 X X O FOR CORROSION GENERATOR FUEL OIL FUEL OIL STORAGE PROTECTION STORAGE AND TRANSFER TANKS COATED WITH l j SYSTEN COAL EPOXY. '
PIPING AND TANK i SURFACES I
'3919.00 FSAR 9. 5. 4. 2 EMERGENCY DIESEL' INTERIOR SURFACES OF 138 X X 0 FOR CORROSION 4 GENERATOR FUEL OIL ' FUEL OIL STORAGE PROTEQTION i STORAGE AND TRANTEER T ANKS PROTECTED BY 1
. SYSTEM INORGANIC ZINC -
PIPING AND TANK COATING. i SURFACES.
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RE F. COMMITMENT COMMIIMENT COMMIIMENT DOCUMENT / FSAR REMARKS NUNBER SOURCE SECTION SUBJECT FEATURE MODULE DESIGN CONST AMEN
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4141.00 NRC uuEST. Q430. 20 FUEL OIL STORAGE FUEL OIL STORAGE 138 X X 0 RESPONSE TO OUESTION CORRES. TANK COATING TANKS COATED INSIDE AND OUT. EXTERIOR COATED WITH ONE LAYER OF COAL TAR EPOXY WITH AVERAGE DRY FILM THICKNESS OF'22 MILS.
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PLANT V0GTLE UNIT 2 READINESS REVIEW PH0GHAM IMPLEMENTATION MATRIX
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DESIGN . CONST HEF. SOURCE AND DES CON CURRENT DESIGN CURRENT CONSTRUCTION NINBER SECTION SUBJECT DOCINENT/I'EATURE IGN ST. AS OF: IMPLEMENTATION AS OF: IMPLEMENTATION REMARKS
======= =============== ==================== ================= == === === ======== ====================== ======== ====================== =================a EXPLANATION OF FIELDS REF NO. - A reference number that corresponds to the appropriate llae entry in the comaltment metrix.
SOURCE AND SECTION - The comalteenf source and sectice to be laplemented SUBJECT - The subject of the comaltment peregraph DOCUMENT / FEATURE - The document' discussed la the FSAR section or the p?amt foeture descelbed la the FSAR section. (See Comaltment Matrix.)
DESIGN / CONSTRUCTION - A .* K la placed under the headlag for the organitettom responsible for Implementottee of the commiteomt DESIGN CURRENT - The date that commitment Implementation was verlfled AS OF CONST CURRENT
- AS oft DESIGN - The Project documeat(s) that were revleged to verify commiteest BMPLEMENTATION laplementatlon CONSTRUCTION IMPLEMENTAT60N S
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Page No. j 05/19/88 PLANI V0 GILE UN!I 2 RE ADINESS REVIEW PRuGRAM IMPLEMENTATION MAIRIX - MODUtl 138 DESIGN CONSI REF. SOURCE AND DES COM CURRENT DESIGN CURRENT CONSIRUCTION NUMBER SECTION SUBJECT DOCUMENT /FEAIURE IGN St. AS OF: IMPL E ME NI All0N AS OF: IMPL E M[NI A T ION REMARIS
- - :::: ::::::::::::::= :::::::::::::::::::: r::: -- ::.::::::::: ::: ::: :::::::- ::::::::::::.:::: :::: :::::::: ::r :: : :::::::::: -- :::::-:-:- :-- ::
1317.00 FSAR ORGANIC MATERIALS ANSI N101.2(1972) X 07-07-87 DC-1000-A, REV. I,
- 6. 1. 2. I PROTECTIVE C0ATINGS SECT. 10 12-4-85 IN CONTAINMENT 1318.00 FSAR ORGANIC MATERIALS RG 1.54. REV. O, X X 02-03-88 XIAJ07. REV. 27, 02-03-88 X1AJ07. REY. 27,
- 6. 1. 2. I PROTECTIVE CCAT[NGS 6/73 8-27-87, SECT. 12.3 8-27-87 SECT. 12.3 IN CONTAINMENT DC-1000 SECT. 12.3, REY. 3, 9-30-83, APPENDIX E PC-1000A, REV. 1, 12-4-85, SECT. 10 1603.00 FSAR 0.A. REQUIREMENT FOR RG 1.54. REY. O, X X 07-07-87 SEE REMARIS. FOR 05-21-87 SEE DETAIL SELOW SEE REF. 1318 FOR I. 9. 54 PROTECIIVE COAi]NGS 6/73 CONSI . SPEC. SEE DESIGN.
APPLIED TO DETAIL BELOW CONSTRUCil0N WATER-COOLED NUCLEAR APPLICABLF 10
. PLANT NON-NSSS COMPONENIS ONLY 1A03.01 FSAR 0.A. REQUIREMENT FOR RG 1.54, REV. O, X X 02-03-88 X1AJ07, REV. 27, 02-03-88 XIAJ07. REY. 27, COAT [NG MATERIALS
- 1. 9. 54 PROTECTIVE COATINGS 6/73 8-27-87, SECT'S. 8-27-87, SECi'S. FOR IIEMS WITHIN APPLIED 10 12.l.l.A. 12.2.8 4 12.I.l.A. 12.2.8, & CONTAINMENT $NALL WATER-COOLED NUCLEAR 12.8 12.8 NEET REQUIREMENTS PLANT OF ANSI N101.2 WNENEVER POS$1BLE 1603.02 F $ia 0.A. REQUIREMENT FOR RG 1.54. REV. O, A X 02-03-88 X1 AJ07 REV. 27, 02-03-80 XIAJ07 REV. 27, COATING MAIERIALS
- 1. 9. 54 PROTECTIVE C0ATINGS 6/73 8-27-87, SECT 'S. 8-27-87, SECT'S. FOR ITEMS WITHIN APPLIED 10 12.1.1.A. 12.2.B. L 12.1.1.A. 12.2.8 & CONIAlHMENT SNALL WATER-COOLED NUCLEAR 12.8 12.8 MEET SELECTED PLANI REQUIREMENTS OF ANSI N5.12 WNENEVER .'OSSIBLE 1603.03 FSAR 0.A. REQUIREMENT FOR RG 1.54, REV. O, X X 02-03-88 XtAJ07. REY. 27, 02-03-88 X1AJ07. REV. 27, COATING MATERIALS
- 1. 9. 54 PROTECIIVE COATINGS 6/73 8-2 7-8 7, SE CT . 12.1.1 0-27-87, SECT. 12.1.1 FOR ITEMS WITNIN APPLIED TO CONTAINMENT ARE WATER-COOLED NUCLEAR DOCUMENTED IN PLANT ACCORDANCE Wi!N ANSI N101.4 4
Page No. 2 05/19/88 PLANI V0 GILE UNii 2 READINESS PEVIEW PROGRAM IMPLEMENT ATION MAIRIX - MODUL E 138 DESIGN CONST REF. SOURCE AND DES CON CURRENT DESIGN CUR RE N T CONSTRUCTION NUM8ER SECTION SUBJECT DOCUMENT /FFAIURE IGN ST. AS OF- IMPLEMENTAi!ON AS OF: IMPL E ME N T Ai!0N REMARES
- = ::::::::::::::: : : ::::::::: -- ::= ::: : :::::::::: ::: ::= : :::::: : -- :-- -: : :: :::::= ::::.::= ::- :- : :.:.:-- :- :- :::.:---- :::-:--
1603.04 FSAR 0.A. REQUIREMENT FOR RG 1.54. REV. O, X X 02-11-88 XI AJ07. RE V. 27, 02-11-88 XIAJ07. REV. 27 SSPC - 1963, 1971,
- 1. 9. 54 PROTECTIVE COATINGS 6/73 8-27-87, SECTS. 12.3 & 8-27-87, SECTS. 12.3 & ANSI N101.2-1972 APPLIED TO 2.0 2.0 ANSI N5.12-1974 W ATER-COOLED NUCLE AR PLANT 1603.05 FSAR 0.A. REQUIREMENT FOR RG 1.54, REY. O, X X 02-03-88 XIAJ07 REV. 27, 02-03-88 XIAJ07. REV. 27, FORMS SIMILAR 10
- 1. 9. 54 PROTECTIVE COATINGS 6/73 0-27-87 SECT. 12.7, 8-27-87, SECT. 12.7 ANSI N101.4 APPLIED TO WATER-COOLED MUCIEAR PLANI 1603.06 FSAR 0. A. REQUIREMENT FOR RG 1.54. REV. O, X X 02-03-88 XIAJ07. REY. 27, 02-03-88 XIAJ07. REV. 27 SYSTEMS PRfutfAL.
- 1. 9 54 PROTECTIVE COAi!NGS 6/73 8-27-87, SECT. 12 0-27-87, SECT. 12 10 ANSI NI01.2 APPLIED 10 WATER-COOLED NUCLEAR PLANT 1603.07 FSAR 0.A. REQUIREMENT FOR RG 1.54. REV. O, X X 02-03-88 XIAJ07, REV. 27, 02-03-88 X1AJ07. REY. 27, SURFACE
- 1. 9. 54 PROIECTIVE C0ATINGS 6/73 8-27-87, SCHEDULE A 8-27-87, SCNEDULE A PREPARATION APPLIED 10 ILLUSTRATES WATER-COOLED NUCLfA4 PROCEDURE SSEP FOR PLANT TESTING 1603.08 FSAR 0.A. REQUIREMENI FOR RG 1.54, REY. O, X X 02-03-88 X1AJ07, REV. 27, 02-03-88 XIAJ07, REV. 27 SURFACE PROFILE
!. 9. 54 PR01ECTIVE COATINGS 6/73 8-27-87, SCHEDULE A 8-27-87, SCHE DULE A REQUIREMENTS ARE APPLIED TO MET WATER-COOLED NUCLEAR PLANT 1603.09 F SAR 0.A. REQUIREMENT FOR RG 1.54 REV. O, X X 02-03-88 X1AJ07. REV. 27, 02-03-88 X1AJ07, REV. 27, APPLICATION PER I. 9. 54 PROTECTIVE COATINGS 6/73 8-27-87, SECTS. 3.0 & 8-27-87, SECT'S. 3.0 & MANUF ACTURE R'S APPLIED TO 12.5 12.5 PROCEDURES WATER-COOLED NUCLEAR PL ANT 1603.10 FSAR 0.A. REQUIREMENT FOR RG 1.54. REV. O, X X 02-03-98 X1AJ07, REV. 27, 02-03-88 X1AJ07. REY. 27, INSPECIIONS AND
- 1. 9. 54 PROTECTIVE COAIINGS 6/73 8-27-87, SECT'S. 5.0 & 8-27-87, SECT'S. 5.0 & NON-DESTRUCTIVE APPLIED 10 12.6 12.6 IESTS ARE WAIE R-COOLED NUCLEAR PERFORMED PLANT O O O
Page No. 3 05/19/88 PLANT V0 GILE UNIT 2 READ]NTSS REVIIW PROGRAM IMPLEMENTAi!0N MAIRIX - MODULE 138 DESIGN CONSI REF. SOURCE AND DES CON CURRENT DESIGN CURRENT CONSIRUCTION NUM6TR SECTION SUBJECT DOCUMENT /FEAIURE IGN St. AS OF: IMPLEME NI ATICN AS OF: IMPLEMENIAIION REMARES
- :::::::::::::: ::::t::::::::::::::= :-:::::::::::::::::: ::= ::= :::::::= :::::::::::::::::::::: :::::::: :::::::::::::::::::::: ::::-::::::::::::
1603.11 FSAR 0.A. REQUIREMENT FOR RG I.54. REV. O. X X 02-03-88 XIAJ07 REV. 27, 02-03-88 XtAJ07. REV. 27 NONCONFORMANCES
- 1. 9. 54 PRofECTIVE C0ATINGS 6/73 8-27-87. SECT. 12.1.1 6-27-87, SECT. 12.I.1 ARE IDENTITIED AND APPLIED 10 EVALUATED WATER-COOLED NUCLEAR PLANT 1603.12 FSAR 0.A. REQUIREMENT FDR RG 1.54. REY. O. X X 02-22 88 XI AJ07. REY. 27, 02-22-88 XIAJ07. REV. 27 CERT OF COMPL. AND
- 1. 9. 54 PROTECTIVE C0ATINGS 6/73 8-27-87. SECTS. 12.1.1 6-27-87, SECIS . 12.1.1 OR DOCUM.
APPLIED TO & 12.7 & 12.7 PROCEDURES ARE WATER-COOLED NUCLEAR FURNISHED
, PLANI f 1603.13 FSAR 0.A. RE0UIREMENT FOR RG 1.54. REV. O, X X 02-03-88 XIAJ07, REV. 27, 02-03-88 XIAJJ7. REY. 27 LIMITS ON HALOGENS
- 1. 9. 54 PR0iECTIVE C0ATINGS 6/73 8-27-87, SECT. 12.2.C 8-27-8 7. SEC T . 12.2.C IN CLEANERS &
APPLIED TO SOLVENTS WATER-COOLED NUCLEAR .)
PLANT 1604.00 F SAR 0.A. REQUIREMENT FOR ANSI N101.4 (1972) X X 07-07-87 DC-1000-A. REV. I, 02-03-88 XIAJ07. REV. 27, I. 9. 54 PROTECTIVE C0ATINGS SECT. 10, 12-4-85 8-27-87, SEci'S. 12.1 APPLIED TO 12.2, 12.3 L 12.7 WATER-COOLED NUCLEAR PLANT 3418.00 FSAR EMERGENCY DIESEL EXIERIOR SURFACES OF X X 07-07-87 X4 AH03. REV. 9. SECT. 05-21-8/ X4AH03, REV. 9 9 5. 4. ' 2 GENERATING FUEL OIL FUEL OIL STORAGE 4.4.1. 4-29-86 4-29-86, SECT.'4.4.1 STORAGE AND TRANSFER TANT 3 COATED WITH SYSTEN C0AL EP0XY 3919.00 ISAR EMERGENCY DIESEL INTERIOR SURFACES OF X X 07-07-87 X4 AH03. REV. 9. SECT. 05-21-87 X4AN03. REY. 9 I 9 5. 4. 2 GENERATING FUEL OIL FUEL OIL SiORAGE 4.4.2, 4-29-86 4-29-86 SECI. 4.4.2 STORAGE AND TRANSFER TANKS PROTECTED BY SYSTEM INORGANIC 7INC
- COATING 4141.00 NRC QUEST. FUEL OIL STORAGE FUEL OIL STORAGE X X 07-07-87 X4AH03 REV. 9. SECT. 05-21-87 X4AH03 REV. 9 CORRES. IANK COATING IANf3 C0ATED INSIDE 4.4.1, 4-29-86 4-29-86, SECT. 4.4.1 0430. 20 AND OUI. EXTERIOR C0AIED WIIN ONE LAYER OF C0AL TAR EP0XY WITN AVS. DFT.
OF 22 MILS f
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Pago No. 4 05/19/08 I PLAHi V0 GILE UNIT 2 READINESS REVIEW PROGRAM IMPLEMENTATION MAIRIX - MODifLE 138 l
DESIGN CONST REF. SOURCE AND DES CON CURRENT DESIGN CURRENT CONSTRUCTION NUMBER SECil0N SUBJECT DOCUMENI/FEAIURE IGN $1. AS OF: IMPLE MENI ATION AS OF: IMPtENENTAll0N REMARES
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4820.00 FSAR STAND 8Y POWER SUPPLY FLOOR OF DIESEL X X 02-22-88 2XID07A05. REY. 5 02-22-88 2xtD07A05. REV. 5
- 9. 3. 1. 1. GENERATOR BLDG. 12-10-85 12-10-85 3.R COAIED WITH EP0XY 10 PREVENT CONCRETE ABRASIVE DUST FROM INTERFERING WITN OPERAfl0M OF ELECTRICAL EQUIPMENT i
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4 PROGRAM DESCRIPTION O 4.1 DESIGN This section provides a description of the work flow, documentation, and design control activities for protective coatings for permanent plant items. The emphasis is on coating materials and approved coatings systems for areas and equipment inside the containment building.
The civil discipline of Design Engineering (DE) is responsible for the coatings program implemented at the VEGP project. This program was implemented through architectural and civil design criteria, various procurement specifications for equipment, architectural finish schedule drawings, and the construction specification for field coating application.
4.1.1 COATING SERVICE AREAS Coating service areas are specified on the basis of expected environmental exposures depending upon'the location in the plant. The expected service areas have been reduced to three basic designations as follows:
A. Areas within the containment building are identified as
% N-areas. Items to be located inside the containment building ~ require N-coatings.
B. Areas outside the containment but where potential contamination from radioactive sources exists are identified as D-areas. D-coatings can be the same as N-coatings except that the QA program and quality documentation requirements are not required.
C. Areas other than U and D-areas are identified as C-areas. C-area coatings can be suppliers' commercial ,
standard providing the coating will withstand exposure to the anticipated service environment and storage during construction. C-area specifications provide material performance standards.
4.1.2 COATING SYSTEMS The architectural group from DE, with the assistance of the Materials and Quality Services (M&QS) group of Bechtel, has selected coating systems to meet the requirements of the service areas, the surface to be coated, and the architectural and special service conditions as applicable.
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4.1.2.1 Desian Basis Accident Tests Coating systems specified for use on items located inside containment were tested in accordance with the requirements of h!
ANSI N101.2 and selected portions of ANSI N5.12. The tests were originally conducted in Oak Ridge National Laboratories. The ,
l test data and results were reviewed by M&QS group of Bechtel, )
San Francisco, and Oak Ridge Laboratory for acceptance and l approval for application inside containment. The architectural group has final approval of the coatings to be applied. The I documents containing original test data and results of approved l l coatings systems are retained by the M&QS group. l l
I 4.1.2.2 Field Coating Systems Field coating systems applied and utilized in the field at the VEGP jobsite are listed in schedule A of Field Coatings Specification X1AJ07, which includes the types of coatings, manufacturer of acceptable coatings, product identification, surface preparation, number of coats, dry mill thickness to be applied, and inspection requirements. The coating systems i acceptable for use on items located inside the containment '
building are prequalified. Four primary prequalified systems l are specified- l 1
i o Inorganic zinc-rich coating with no finish coat.
o Inorganic zinc-rich coating with epoxy top coat, O o Clear epoxy sealer for concrete.
o Two coat epoxy coating for concrete.
In addition, other prequalified systems for touchup or repair of the primary coating system are specified.
4.1.2.3 Shop Coatinos l
The coatings provisions for items purchased from suppliers and equipment manufacturers are contained in the purchase specifications. For items located inside the containment-building, the purchase specification specifies use of l prequalified coatings. Use of coatings of equal quality is I permitted. In such cases, the supplier of this item is required to submit DBA test data per Regulatory Guide (RG) 1.54 and l ANSI N101.2 for evaluation by Project Engineering. After
! consultative approval by M&QS, the architectural group approves such coating if it is found to be acceptable.
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4.1.2.4 Unqualified Coatings Unqualified coatings are coatings applied without documentation,
(' coatings where the surface preparation, material, or application deviate from those qualified by DBA test, or coatings that have not been prequalified. The use of these coatings in containment is limited to small coating repairs, small production line items where special painting requirements are impracticable, surfaces to be insulated, surfaces contained within a cabinet or enclosure, and concrete sealer.
4.1.3 DESIGN DOCUMENTS The design documents produced relative to coatings include:
o Specifications:
- Construction (field coating).
- Material (procurement).
o Drawings:
- Finish schedules.
- Finish and door schedule details.
The procedures for control, issue, and revision of design documents are described in project procedures for each type of design document including design change documents.
4.1.3.1 Specification Development The specifications relative to coatings consist of the Field Coatings Specification X1AJO7, and purchase specifications for permsnent plant items (structures, components, and equipment).
Thn architectural group has the overall responsibility for the fi. eld coatings specification and for coatings requirements in purchase specifications.
t When the specifications were prepared each responsible engineer (RE) coordinated the selection of appropriate coating requirements with the architect. The coating requirements were incorporated into the body of the technical provisions of the specification.
The architect reviewed the specification for compliance to the coating requirements when it was issued on a Design Review Notice. The draft of the specification was forwarded to the M&QS organization for review and comment. The M&QS reviewer O
O222m/172-8 4-3
forwarded his review comments to the architect, who forwarded comments to the RE for necessary action.
4.1.3.2 Material Purchase Specifications Material purchase specifications are written and controlled by applicable DE disciplines. The purchase specifications include coating requirements and specify Regulatory Guide 1.54, ANSI N101.4, and ANSI N101.2 requirements for items within containment, consistent with the FSAR commitments.
4.1.3.3 Field Coating Specification l Field Coatings Specification X1AJ07, written and controlled by l the architectural group, describes coating requirements for the field finish of shop-primed ferrous metal surfaces, uncoated shop- or field- fabricated items, repair of coatings, concrete l surfaces, and architectural paint finishes. Coating material is I purchased from qualified suppliers by GPC Construction, based upon the requirements in the specification.
4.1.3.4 Drawings The VEGP plant coating requirements are shown on architectural design drawing finish schedules. The finish schedule shows finish coating systems by room. numbers (space numbers), by lh levels of building, and by material to be coated.
These drawings are developed and controlled by the architectural group. The architectural group coordinates the color scheme and coating requirements with GPC.
4.1.4 SHOP COATING PROGRAM Prior to starting any coating work, each supplier of shop-coated items is required to submit its coating p*acedures for review and acceptance by Engineering. The VEGP architect and M&QS review the procedures to ensure compliance with the specification requirements. Copies of supplier coating procedures, approved and accepted by Project Engineering, are retained in the M&QS files and the project files. Accepted (approved) procedures are returned to the supplier for use.
4.1.5 QUALITY REQUIREMENTS Quality assurance and documentation requirements are in accordance with ANS: N45.2-71 and ANSI N101.4 for both coating 9
0222m/172-8 4-4 l
r materials and the application procedures. The quality assurance ,
requirements are applicable to both the shop-coated items and to coatings applied in the field under GPC direction.
RG 1,54 is implemented by requirements as follows:
o Use of specific coating systems prequalified to ANSI i N101.2.
o Surface preparation standards.
o Surface profile requirements.
o Application of the coating systems in accordance with the paint manufacturer's instructions.
o Inspections and nondestructive examinations. ,
o Identification of all nonconformances. Coatings which do not conform with Regulatory Guide 1.54 are limited in use and are evaluated on a case-by-case basis for impact and acceptance.
o Certifications of compliance and/or documentation procedures to satisfy project requirements.
o An inventory of unqualified coatings is maintained to ,
ensure appropriate control of coatings inside O containment.
4.1.6 WESTINGHOUSE COATING PROGRAM The nuclear steam supply system (NSSS) is coated in accordance with the Westinghouse coating program approved by the Nuclear Regulatory Commission.
Westinghouse has developed an alternate approach to ANSI N101.4 :
for satisfying Regulatory Guide 1.54 for the NSSS components inside containment. Requirements are specified for the painting of major components-in Westinghouse Process Specifications, ,
which are imposed on vendors by procurement documents. -Large equipment must have coating systems quali'fied to meet ANSI N101.2; and requirements are defined for surface preparation, use of undercoating, and inspection.
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4.2 CONSTRUCTION This section contains a brief description of coating and
. 0- inspection activities, a flowchart, and a list of codes and standards applicable to receipt, storage, application, and inspection activities, e
Coatings material is purchased, received, and receipt inspected by Georgia Power Company (GPC). Upon receipt the material is issued to the contractor, Williams Power Services, Inc. '
(Williams) for storage. Material with GPC hold tags is ,
segregated in the Williams warehouse and withheld from use until the discrepancies are resolved and GPC Quality Control (QC) removes the hold tags.
Material released by GPC is stored in and released for use from the Williams warehouse. Storage and issuance of material and verification of warehouse conditions by Williams QC is controlled by Williams quality program procedures. ,
Williams prepares substrate surfaces mixes and applies the coatings. Testing of environmental conditions, verification of proper coating material, mixing and application, and inspection of substrate preparation and applied coatings are performed by Williams QC. Inspection and application activities are controlled by Williams procedures.
The flowchart (Figure 4-1) illustrates the contractors' work O' activity as well as the inspection activities required to support, inspect, and document these work processes. Each organization listed in.the left hand margin of the flowchart is responsible for the activities shown to the right of it. The nodes (circles) denote the starting and completion points of work activities. Between the nodes are descriptions of the work activities performed and the applicable procedure governing that work activity. The dotted lines with directional arrows indicate the flow of documentation or instructions for an activity. The flowcharts do not contain the flow of documents such as Deviation Reports or Field Change Requests, as they may be generated at any time.
Receipt, storage, application, and inspection of coatings are performed following the applicable GPC or Williams procedures.
Williams procedures are reviewed and approved by GPC. In-addition, the work is governed by Specification X1AJO7, Field Coatings. Principal codes and standards referenced in the >
specification are:
o ANSI N101.2, Protective Coatings (paints) for Light Water Nuclear Reactor Containment Facilities (material ;
qualification.only)-
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0222m/172-8 4-7 l l
o ANSI N101.4, Quality Assurance for Protective Coatings applied to Nuclear Facilities.
o ANSI N5.12, Protective Coatings (paints) for the Nuclear O
Industry (material qualification only) -
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IG. I 311 Figure 4-1 Coatings Activity Flow
5 AUDITS AND INSPECTIONS O
5.1 INTRODUCTION
Module section 5 contains a brief discussion of Quality Assurance audits, Nuclear Regulatory Commission inspections, and Project reportability evaluations performed in the area of coatings. In addition, a description of special evaluations and a discussion of the project evaluation of Unit 1 finding followup are included. The findings, violations and evaluations applicable to coatings were reviewed by the Readiness Review Team and factored into the assessments presented in section 6 of this module. Audits and findings, inspections and violations, eportability evaluations, and the Unit 1 finding followup esults are listed at the end of this section.
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5.2 PROJECT AUDITS Project Quality Assurance (QA), consisting of Georgia Power
{' Company (CPC) QA and Bechtel Western Power Company (BWPC) QA, conducts regularly scheduled audits to verify compliance to project requirements. Any finding from an audit is reported to the management of the audited organization for corrective action. Table 5-1 at the end of this section includes the audits conducted and findings issued since the effective date of the Unit 1 module, July 1, 1985.
5.2.1 GEORGIA POWER COMPANY AUDITS AND FINDINGS GPC QA conducted 4 audits within the scope of this module.
These audits resulted in 14 findings, which identified a failure to follow procedures and identified discrepancies in documentation requirements, in procedure preparation, and in material storage.
For each finding, the extent and significance of the discrepancy was identified and corrective action was taken to resolve the deficiency.
5.2.2 BECHTEL WP, STERN POWER CORPORATION AUDITS AND FIMO:nG3 BWPC QA audits are generally performed in design functional areas such as drawings, calculations, and Field Change Requests and are applied to all disciplines, rather than a specific discipline or hardware category. Therefore, it is impractical to assign audits to a specific module, however findings were categorized by module. Two findings were within the scope of this module. One identified a failure to meet committed dates for completion of Unit 1 Readiness Review corrective-actions.
The finding was resolved by completion of the committed corrective action. The second finding documents conflicting references to the steel structures painting council standards.
Final Safety Analysis Report, Table 6.1.2-1, was revised to resolve this finding.
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5.3 NUCLEAR REGULATORY COMMISSION INSPECTIONS Readiness Review identified six Nuclear Regulatory Commission Os inspections within the scope of this module (listed on Table 5-2). No deviations or violations were identified as a result of these inspections.
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l 5.4 REPORTABLE DEFICIENCIES AND SPECIAL EVALUATIONS <
Reportable Deficiencies Within the scope of this module no deficiencies have been reported to the Nuclear Regulatory Commission (NRC) and no Deficiency Evaluation Reports have been issued since the '
completion of the Unit 1 module.
Special Evaluations !
Diesel Fuel Oil Storage Tank Coating ;
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Georgia Power Company conducted a review of the effect of the inorganic zine lining of the diesel fuel oil storage tank on the operability and reliability of the diesel generators. This ;
review was in response to Unit 1 Licensing Condition 2.c(8), ,
which expressed the concern of the NRC that the reaction !
products of the acidic impurities in diesel fuel oil with the zine lining might cause plugging of lines and fuel injectors. ;
A report on the technical issues reviewed addressed the i beneficial effect of the corrosion-resisting properties of inorganic zinc on tank life and industry experience with the combustion-improving properties of zinc naphthenates, the ;
principal soluble reaction product. The report also discussed the use of duplex fuel oil line filters to remove corrosion !
products or degradation products which could plug the fuel line O and surveillance procedures to check the quality of the fuel oil, to monitor the differential pressure across the fuel oil i line filter, and to inspect the diesel generator fuel injectors ;
for zine deposits. i The report concluded that it is acceptable to store diesel fuel in zinc-lined tanks with proper attention to fuel quality. It was submitted to the NRC as justification that the zine coating would not affect the operability and reliability of the diesel r generators. l The NRC evaluated the report and additional technical information, concluded that the justification was acceptable, j and resolved the licensing condition, (NRC letter dated .
October 15, 1987).
Cracking of Concrete Floor Coating l
Small areas of concrete floor coating in the Unit 1 containment '
have cracked and disbonded from the floor. The. estimated total ~ '
area of failure is about 300. square feet, located in the !
stairwells and random locations in other floor areas. ;
Bechtel Engineering was requested to review the coating .
specification and application procedures to determine if changes should be made to preclude future cracking. !
0223m/172-8 5-7
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The review included observation of damaged coatings in both Unit 1 and Unit 2 and discussions with the coating manufacturer and construction personnel. lh The most probable cause was identified as a high film thickness in local areas coupled with mechanical damage to the coating.
Project Engineering recommendations included measures to minimize total film thickness of the coating system and a monitoring program to facilitate identification and repair of any local areas which may crack in the future. (Letter BG 36148 dated April 18, 1988).
Project Construction has had further discussions with Engineering and with the coating manufacturer to identify specific application techniques to effectively implement the -
engineering recommendations. Actions taken will include training of applicators and revision to application procedures, as necessary. A formal response to the engineering recommendations will be issued by July 14, 1988.
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0223m/172-8 5-8
5.5 UNIT 1 FINDING FOLLOWUP Unit 1 finding followup consisted of identification of all p)r
- g. findings and corrective actions for findings as a result of Unit 1 Readiness Review or Nuclear Regulatory Commission evaluation of the Unit 1 modules. For Unit 2, a list of those findings was compiled and transmitted to the responsible project organizations for verification that corrective action taken continued into Unit 2. The Project evaluated each finding to determine the following-1 o If the finding was an isolated occurrence in Unit 1 and did not require Unit 2 action (or applicable to Unit 1 only).
o If corrective action taken for Unit 1 remains in place and acceptable, o If corrective action in place for Unit 2 has changed 1 from that specified in the Unit 1 module. j l
o If corrective action taken for Unit 1 has not been i entirely effective in Unit 2 and therefore is modified.
For each finding that the Project determined was applicable to Unit 2, a response was returned to Readiness Review that stated which documents identified the corrective actioh required, any changes to committed actions, and action taken if~ corrective O' action was not effective. The listing at the end of this section (Table 5-3) presents the findings, the type of action taken for Unit 2, and explanations if corrective action was changed or not entirely effective. The findings were included in the assessment discussed in section 6 to provide independent Readiness Review verification of the project evaluation results.
Sixteen findings were identified for Unit 1 applicable to Module 13B. The Project Design and Construction evaluation of these findings concluded that 11 of the 16 were applicable to Unit 2 and for 9 of the 16 the Unit 1 corrective action had been applied to Unit 2. The Readiness Review assessment identified two findings where the corrective action was not entirely effective:
RRF 13B-007 Revision to Williams Warehouse Procedure WW-I-01, in response to ,
Finding RRF-13B-OO7, established the Warehousing Records as I quality documents, meeting requirements of ANSI N101.4. ;
Subsequently this procedure was revised and the Warehousing Records document requirements were omitted, although the Warehousing Records were maintained as a nonquality document.
Unit 2 Finding 2RRF-13B-003 was issued (section 6 contains a discussion).
d(s 0223m/172-8 5-9
RRF 13B-021 Unit 1 Finding RRF-13B-021 identified discrepancies in FCR processing, including improperly designating generic-type changes as not to be incorporated in the specification. The Unit 2 assessment identified similt.r discrepancies. Unit 2 Finding 2RRF-13B-002 was issued (section 6 contains a discussion).
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06/16/88 1-O O f- PLANT V0GTLE UNIT 2 READINESS REVIEW PROGRAM QUALITT ASSURANCE AUDITS TABLE 5-1
==================e============
- t. EDIT AUDIT FINDING NO SOURCE MUMGER NUMBER DATE SUBJECT REMARES
============= ============= ============= ======== ============================================= ==================
22 BPC CAR RRF-R-07-86 03/04/86 RR FINDING 138-12 SPECIFICATIONS NOT REVISED BY DATE COMMITTED RR FINDING 138-20 SPECIFICATION NOT REVISED BY DATE COMMITTED 73 BPC CAR VS-86-181 03/05/86 DBA TESTING DONE TO SSPC-1971 WHERE FSAR STATES 1963 1192 GPC CP01-87/60
- 12/21/87 QA AUDIT OF THE ADEQUACY OF COATING l
ACTIVITIES AS DEVELOPED AND IMPLEMENTED BY WILLIAMS POWER SERVICES. INC.
1263 GPC CP01/CP14-85/ 11/27/85 OA ASSESSMENT AUDIT OF WILLIAMS CONTRACTING, 56 INC 204 GPC CP01/CP14-86/ 10/31/86 ADEQUACY OF WILLIAMS POWER SERVICES' QA 28 PROGRAM FOR COATINGS ACTIVITIES AS PER 7 FUNCTIONAL AREAS COVERING 18 CRITERIA 0F 10CFR50, APPENDIX B 259 GPC CP14-86/27 05/30/86 WILLIAMS POWER SERVICES' QA PROGRAM FOR SERVICE LEVEL 1 COATINGS ON CONCRETE AND STE E L' 354 GPC AFR 0868 11/27/85 WILLIAMS DOCUMENT CONTROL PROCEDURES NOT CPOI/CP14-85/56 ADEQUATELY IMPLEMENTED 355 GPC AFR 0869 11/27/85 FAILURE TO ADEQUATELY DEVELOP SEVERAL CP01/CP14-85/56 REQUIREMENTS OF ANSI N45.2-1977 IN THE QA PROGRAM ,
356 GPC AFR 0870- 11/27/85 WILLIAMS NON-CONFORMANCE PROCEDURE DOES NOT CP01/CP14-85/56 ,I DEFINE " CORRECTABLE DEVIATIONS" 357 GPC AFR 0871 11/27/85 FAII.URE TO DEVELOP AND CONDUCT A CP01/CP14-85/56 COMPRENENSIVE STSTEM OF-AUDITS 358 GPC AFR 0872 11/27/85 WEAENESSES IN DOCUMENTING AND UTILIZING THE CP01/CP14-85/56 i EFFECTIVE CERTIFICATION OF QUALIFIED COATINGS APPLICATORS 359 GPC AFR. 0873 11/27/85 APPLICATION PROCEDURES NOT CLEAR, NOT CP01/CP14-85/56 DEFINATIVE
____2_-_a__--x__ - - - --_x--------- - - - - - - - - - - - - - - - - -- -
O Page No. 2 O . O 06/16/88 PLANT V0GTLE UNIT 2 READINESS REVIEW PROGRAM QUALITY ASSURANCE AUDITS TABLE 5-1
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EDIT AUDIT FINDING NO SOURCE NUMBER NUMBER DATE SUBJECT REMARKS
============= ============= ============= ======== ============================================= ==================
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360 GPC AFR 0874 11/27/85 QC PROCEDURES LACK DETAIL AND CONTINUITY CP01/CP14-85/56 361 GPC AFR 0875 11/27/85 SPECIFICATION DEVIATES FROM FSAR COMMITMENT CP01/CP14-85/56 TO ANSI N101.4 362 GPC AFR 0876 11/25/85 S10NERS NAMES MISSING FROM WILLIAMS' CP01/CP14-85/56 !
DOCUMENTS 363 GPC AFR 0877 11/27/85 TRINNERS USED WITR "N" COATING SYSTEMS NOT CP01/CP14-85/56 SEGREGATED IN A DESIONATED AREA IN WAREROUSE 471 GPC AFR 0983 10/31/86 INADEQUATE CONTROL OF FCR's/DCM's BY WILLIAMS CP01/CP14-86/28 POWER SERVICES 472 GPC AFR 0984 10/31/86 WILLIAMS QA MANUAL REQUIRES VERIF. OF CP01/CP14-86/28 MATERIAL CERTS. VERIF. IS BY GPC 474 OPC AFR 0985 10/31/86 FAILURE TO MAINTAIN STORAGE OF A NON "N" CP01/CP14-86/28 C01 TING MATERIAL WITRIN TRE TEMPERATURE REQUIREMENTS SPECIFIED BY TRE MANUFACTURER G
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O O O Pcgo Co. 1 06/15/88 '
PLANT V00TLE UNIT 2 READINESS REVIEN PROGRAM NRC INSPECTIONS TABLE 5-2
===============================
EDIT INSPECTION VIOLATION NO SOURCE NUMBER NUhBER DATE SUBJECT REMARKS
============= ============= ============= ======== ============================================= =======================
623 NRC 424/86-026 10/17/86 REVIEN OF HEADINESS REVIEW MODULE 13B 632 NRC 424/86-036, 08/08/86 INSPECTION OF EMPLOTHE CONCERNS REGARDING 425/86-016 COATINGS 1134 NRC 424/87-025, 04/13/87 INSPECTION OF POST-TENSIONING AND EMPLOTER 425/87-017 CONCERNS IN CONCRETE AND COATINGS 1143 NRC 424/87-040, 07/09/87 INSPECTION OF STRUCTURAL CONCRETE, 425/87-028 FOUNDATIONS, COATINGS, STRUCTURAL STEEL AND PENETRATION SEALS 1156 NRC 424/87-059, 11/13/87 INSPECTION OF REPAIRS TO COATINGS IN THE UNIT 425/87-044 2 CONTAINMENT BUILDING 1159 NRC 424/87-065, 12/04/87 INSPECTION OF CONTAINMENT 1 TENDON 425/87-046 SURVEILLANCE, BACKFILL OPERATIONS, COATINGS REPAIR ON UNIT 2 CONTAINMENT DOME LINER PLATE AND TENDON RAM CALIBRATION RECORDS
M. .
Page No. 1 06/15/88 PLANT V0GTLE UNIT 2 READINESS REVIEW PROGRAM FOLLOW-UP OF UNIT 1 FINDINGS (RR.IDR,NRC)
TABLE 5-3
================================================
EDIT SOURCE AND DESCRIPTION OF DESCRIPTION OF UNIT 1 DESCRIPTION OF UNIT 2 NO FINDING DESIGN CONST LEfEL FINDING CORRECTIVE ACTION FOLLOW-UP ACTION
=============== ====== ====== ===== ============================== ============================== ==========================
483 RRF X II NO CERTIF. THAT MATERIAL MEETS REVISE SPECIFICATION CORRECTIVE ACTION REMAINS 138-001 VEGP TEMP / PRESSURE CURVE IDENTICAL AND ACCEPTABLE 484 RRF X III INSP. REPORTS DO NOT DOCUMENT INSPECTION PRACTICE CHANGED TO ISOLATED INSTANCE /0NE TIME 13B-002 SURFACE PROFILE TO GPC-SP15 SPECIFICALLY DOCUMENT GPC-SPl5 CORRECTIVE ACTION SURFACE PROFILE ACCEPTANCE 485 RRF X III ENTRY ERRORS IN INSPECTION ENTRIES CORRECTED ISOLATED INSTANCE /0NE TIME 13B-003 DOCUMENTS CORRECTIVE ACTION 486 RRF I II THINNER USED OUTSIDE TEMP. DR - USE-AS-IS, PROCEDURE CORRECTIVE ACTION REMAINS 13B-004 RANGE REVISED IDENTICAL AND ACCEPTABLE 487 RRF X II EPOKY THINNED MORE THAN DR - USB-AS-IS, PROCEDURE & CORRECTIVE ACTION REMAINS 138-005 ALLOWED BY SPEC. & PROCEDURE SPEC REVISED IDENTICAL AND ACCEPTABLE 488 RRF X II FSAR COMMITMENTS TO RG 1.54 SPEC. REVISED CORRECTIVE ACTION REMAINS 13B-006 AND ANSI N101.4 NOT COMPLETELY IDENTICAL AND ACCEPTABLE INPLEMENTD IN SPEC.
489 RRF X II COATING PROCEDURES DO NOT MEET SPECIFICATION & PROCEDURE CORRECTIVE ACTION NOT ENTIRELY 138-007 ALL SPECIFICATIONS AND ANSI REVISED EFFECTIVE REQUIREMENTS SEE SECTION 5.5 490 RRF X III COATINGS AS APPLIED DO NOT DR - REPAIR / REWORK, USE-AS-IS ISOLATED INSTANCE /0NE TIME 13B-010-1 MBET ACCEPTANCE CRITERIA (HIGH MILLAGE) CORRECTIVE ACTION 491 RRF X III COATINGS AS APPLIED DO NOT REVISE PROCEDURE, DR - CORRECTIVE ACTION REMAINS 138-010-2 MEET PROCEDUPE ACCEPTANCE USB-AS-IS IDENTICAL AND ACCEPTABLE CRITERIA 478 IDR X II CONFLICTING REQ *MTS FOR SPEC. REVISED TO CORRECTIVE ACTION REMAINS 13B-011 AMBIENT CONDITIONS IN SPEC. CLARIFY / CORRECT PROCEDURES IDENTICAL AND ACCEPTABLE FOLLOWED INTENT OF SPEC. NO DEFICIENCT IN COATING 479 IDR X III SPEC. bOES NOT CALL OUT SPEC. REVISED, WORE TO DATE CORRECTIVE ACTION REMAINS 13B-013 REVISION OF SSPC STANDARDS TO HAS FOLLOWED THE SAME REVISION IDENTICAL AND ACCEPTABLE
, BE USED USED FOR QUALIFICATION
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06/I5/88 PLANT V0GTLE UNIT 2 READINESS REVIEW PROGRAM FOLLOW-UP OF UNIT I FINDINGS (RR.IDR.NRC)
TABLE 5-3
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EDIT SOURCE AND DESCRIPTION OF. DESCRIPTION OF UNIT I DESCRIPTION OF UNIT 2 NO FINDING DESIGN CONST LEVEL FINDING CORRECTIVE ACTION FOLLON-UP ACTION
==== =============== ====== ====== ===== ============================== ============================== ============================== 7 480 IDH E II DEFICIENCIES IN QUALITT PROCEDURES REVISED. WORK WAS CORRECTIVE ACTION REMAINS 135-014 CONTROL PROCEDURES CORRECT IDENTICAL AND ACCEPTABLE 481 IDR I III UNQUALIFIED COATING SYSTEMS SPEC. IS MISLEADING. UNQUAL. CORRECTIVE ACTION REMAINS 135-015 ARE SPECIFIED SYSTEMS WERE NOT INTENDED AND IDENTICAL AND ACCEPTABLE - .
NOT USED. SPEC. REVISED
~
482 IDR E II SEE RRF 138-022 SEE RRF 135-022 ISOLATED INSTANCE /0NE TIME 138-019 CORRECTIVE ACTION 493 RRF X III FCR'S IMPROPERLT APPROVED OR SPEC. REVISED. FCR'S CORRECTIVE ACTION NOT ENTIRELT 135-021 IMPROPERLT MARKED FOR NO INCORPORATED, FCR'S REVIEWED BFFECTIVE r INCORPORATION INTO SPEC. SEE SECTION 5.5 494 RRF X III DR DISPOSITION / JUSTIFICATION DISPOSITION OR JUSTIkICATION ISOLATED INSTANCE /ONE TIME 13B-022 DOES NOT MEET PROCEDURE REVISED CORRECTIVE ACTION REQUIREMENTS 796 RRF X II MATERIAL SPECIFICATIONS.FOR SPECIFICATIONS REVISED. ISOLATED INSTANCE /0NE TIME 13 t --2 0 EQUIPMENT INSIDE CONTAINMENT UNQUAL. COATINGS TABULATED AS CORRECTIVE ACTION
- DO NOT REQUIRE COATINGS APPLICABLE MBETING ANSI N101.2/N101.4 r
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l 6 PROGRAM ASSESSMENT
6.1 INTRODUCTION
This section describes the program developed and actions performed to as'certain whether the design and construction activities related to. coatings for Vogtle Electric Generating Plant Unit 2 have been adequately controlled to implement licensing commitments, to ascertain whether the corrective actions resulting from the Unit 1 Readiness Review were applied l to Unit 2, and to verify that the results of the design and construction activities conform to project procedures and design )
requirements. ;
The Headiness Review Team assembled for Module 13B consisted of l one Readiness Review Task Force member and three members of site Quality Assurance with 55 years combined nuclear design and l construction experience. Approximately 800 manhours were !
expended in performance of the module review and assessment activities. The team members are listed in Table 6-1.
Discrepancies noted during review activities were issued to the :
Project as findings. The Project was required to respond in a manner that addressed the specific issue identified, addressed project investigative action to determine possible generic implications, and described corrective actions performed.
These project responses were evaluated and the findings were subject to categorization as follows:
o Level I - Violation of licensing commitments, project procedures, or engineering requirements with indication of safety concern. (No findings in this module were categorized as Level I) o Level II - Violation of licensing commitments or engineering requirements with no safety concerns.
o Level III - Viola _on of project procedures with no safety concerns.
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0224m/172-8 6-1
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0224m/172-8 6-2
t 6.2 PROGRAM DESCRIPTION The Readiness Review Program evaluation of coatings in Plant
(~}
\- Vogtle Unit 2 consisted of three major activities. These were commitment implementation review: followup of Unit 1 finding corrective actions as applied to Unit 2; and development and execution of an assessment plan to examine programs, activities, ,
and hardware. -
Sections 3 and 5 of this module discuss project actions related to the commitment matrix and the application of Unit 1 finding corrective action to Unit 2, respectively.
The assessment for Unit 2 coatings was developed to accomplish the following objectives:
o Provide added assurance that project documents and ,
procedures implement licensing commitments.
o Determine whether actions taken to resolve problems identified during the Unit 1 Readiness Review have been !
effective in preventing recurrence in Unit 2.
o Determine whether program and organizational enhancements made for Unit 2 have maintained the quality of the design and construction effort.
o Assess design completion and design change activities !
O- for compliance to engineering procedure controls.
o Assess installed hardware for compliance to engineering and vendor requirements.
l The assessment and results are discussed in the following sections.
0224m/172-8 6-3
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0224m/172-8 6-4
6.3
SUMMARY
AND CONCLUSIONS Module 13B addresses protective coatings inside Unit 2 O containment. Selected coating samples and coating applications were examined and the related design and construction documents I were reviewed to verify the adequacy of the design and construction processes and results. Plans for selecting verification samples and verification attributes were developed '
to ensure comprehensive coverage of the various types of coatings and documents.
The samples selected included 3 in-process application activities and 10 areas of applied coatings. Touchup coatings used to repair deficiencies or damage were selected as part of the applied coating samples. The two storage facilities for prequalified coating materials were included in the sample.
Documentation assessed was directly related to the sample or in-process activity wherever possible.
The assessment plan addressed:
o Implementation of licensing commitment requirements.
o Unit 2 application of corrective actions resulting from the Unit 1 Readiness Review.
o The effects of program enhancements and newly developed programs.
The above assessments resulted in six findings, five of which were classified as Level II and one as Level III. Each of the findings identified was evaluated to determine the extent of the deficiency, the root cause of the finding, and the impact on hardware or documentation. A project response was prepared which documented remedial action for the specific case reported in the finding, corrective action for any additional deviations identified during the project evaluation, and any action necessary to prevent recurrence of similar deficiencies.
Of the six findings, four reported contractor procedure deficiencies. In each of the four cases, investigation showed that the intent of the requirement addressed in the procedure had been met. The investigation also showed the deficiencies to be limited to the item or procedure identified in the finding. I Of the remaining two findings, one was an isolated case of conflict in a purchase specification and the other one was due ,
to repetitive errors in processing Field Change Requests j (FCRs). The investigation of the FCR deficiencies showed them '
to be limited to the coating specification.
O 0224m/172-8 6-5
None of the findings reported deficiencies in applied coatinge or inspection documentation. None of the remedial actions involved applied coatings. h The four findings reporting deficiencies in contractor procedures, collectively indicate a lack of attention to procedural details. In addition to correction of the procedural deficiencies, the action to prevent recurrence includes a commitment for increased attention by the contractor quality assurance / quality control manager to these details. No other commonality of cause between findings was established.
Based on Readiness Review assessment activities and Project responses to findings, Readiness Review has concluded that all the findings represent isolated cases of failure to comply with engineering or licensing requirements, or with procedures, with no effect on applied coatings and no safety concern and do not individually or collectively represent generic program concerns.
The findings are listed in Table 6-2. Individual findings and the Project responses are presented in section 6.5.
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l 0224m/172-8 6-6
6.4 ASSESSMENT ACTIVITIES AND RESULTS
(')
b' Readiness Review activity for this module consisted of the development and implementation of an assessment plan to provide a systematic review of activities, programs, and hardware associated with protective coatings. The assessment was performed to provide added assurance that the Project continued to comply with licensing commitments. This section describes the development and implementation of the plan and the results of the assessment.
The assessment was organized into three parts:
o Part 1 - Commitment Implementation and Unit 1 Finding Followup, o Part 2 - Design and Construction Programs and Activities.
o Part 3 - Design and Construction Completion. ,
In preparation for development of the assessment plan, Readiness Review examined the information presented in section 5 of this module [ audits. Nuclear Regulatory Commission (NRC) inspections, etc.] to ensure that areas with a history of deficiency or weakness at Vogtle Electric Generating Plant or within the industry were factored into the assessment.
The following were evaluated for inclusion in the assessment:
(
o Quality Assurance Audit Finding Reports and Corrective Action Regrests.
o NRC violations.
o Quality concerns.
o Industry problems.
This review and evaluation identified the following issues that were included in the assessment plan: -
Issue Source Where Addressed Procedure Adequacy QA AFR Parts 1, 2 & 3 Unit 2 Dome / Hanger Quality Concerns Part 3 Coatings Application Activities Quality Concerns Part 2 A compilation of problems identified during the Unit 1 startup phase was obtained from Operations and was reviewed to identify design or construction-related problem areas. Additionally, l
0224m/172-8 6-7 i
copies of the NRC inspections of Comanche Peak, Browns Ferry, Sequoyah, and Watts Bar for 1985, 1986, and 1987 were obtained and examined to identify any new areas of industry concern. In h the area of coatings, no areas not already addressed were identified from these sources.
A listing of the sample used for the module assessment is shown in Table 6-3.
6.4.1 PART 1, COMMITMENT IMPLEMENTATION AND UNIT 1 FINDING FOLLOWUP Tha objective of part 1 of the assessment was to assess implementation of licensing commitments, with emphasis on those ~
revised or added since Unit 1 Readiness Review by Final Safety Analysis Report amendments or project letters and to assess the adequacy of application to Unit 2 of corrective actions resulting from Unit 1 Readiness Review.
6.4.1.1 Commitment Implementation l
Desion The commitment matrix presented in section 3.2 contains eight individual design commitments, all which were reverified for implementation into design criteria and working level documents k such as specifications and drawings.
During the review of purchase specifications for incorporation of licensing commitments, conflicting coating requirements were noted in Specification X4AJ16, Containment Cooling Units. The conflict was documented in Finding 2RRF-13B-004 (Level II).
' Specification X4AJ16 described the coating system to be used. It required prequalification to ANSI N101.2, but also listed coating materials which are not prequalified to ANSI N101.2. In addition, the list did not include all the materials necessary to apply the specified coating system. The conflict was reported in Finding 2RRF-13B-004 (Level II).
The investigation by Engineering determined that the containment cooling units had been coated with prequalified material and proper documentation is on file to provide evidence. The specification has been revised to resolve the conflict.
With the minor exception as documented in 2RRF-13B-004 Readiness Review concluded that the design licensing commitments had been appropriately and adequately implemented.
O 0224m/172-8 6-8
Construction O, The commitment matrix, presented in section 3.2, contains seven entries requiring construction implementation; all of which were reviewed. The evaluation ascertained whether the commitment was included in the construction specification and, where applicable, whether the contractor quality control and application procedures also incorporeted the commitment.
Four of the seven construction commitments were found to be fully implemented. The remaining three commitments are to Regulatory Guide (RG) 1.54 and ANSI N101.4. These commitments are divided into 13 separate requirements for analysis on the implementation matrix. The implementation of two of these requirements was found to be deficient and the deficiencies were reported on Unit 2 Findings 2RRF-13B-003 and 2RRF-13B-005, both Level II.
The project commitment to RG 1.54 requires meeting the documentation requirements of ANSI N101.4. These include maintenance of a warehouse record, showing receipt and issuance of each batch of coating material. No contractor procedure prescribing this document was found (Finding 2RRF-13B-003).
Investigation showed that the requirement had been deleted during procedural and organizational changes, although the record vac maintained as a nonquality document for inventory cont-- p poses. The Project response was to reinstate the x, proi ~' tral requirement and upgrade the existing nonquality recuros.
This deficiency was also noted by a Unit 1 finding. Further corrective action to address the repetition includes listing the record in the document control procedure and a commitment for incr' eased quality assurance / quality control manager attention to procedural details.
The commitment to RG 1.54 also requires that application procedures conform with the coating manufacturer's written instructions. The Project has met this requirement by obtaining the manufacturer's written approval of each application procedure. The contractor's general procedure for control of application procedures allowed exceptions to this requirement (Finding 2RRF-13B-005).
Investigation showed that the exceptions were used to implement changes that had been discussed with the manufacturer, and were i acceptable, but had not been reviewed and signed. All such changes were subsequently approved in writing by the manufacturer; none are outstanding. The contractor's procedure has been revised to delete the exceptions.
1 0224m/172-8 6-9 l
Readiness Review concludes that with the minor exceptions documented in 2RRF-13B-003 and 2RRF-13B-005, the implementation of construction commitments is acceptable.
6.4.1.2 Unit 1 Findina Followup Unit 1 finding followup consisted of a review of actions taken by the Project to prevent recurrence in Unit 2 of the types of problems identified by Readiness Review during the Unit 1 assessment. A listing of the Unit 1 findings was provided to the Project, a review was performed by the Project, and information indicating the actions taken to address Unit 2 programs was provided to Readiness Peview. Readiness Review evaluated these responses to asseuL the accuracy and adequacy of the information provided.
The Unit 1 findings were evaluated for continued application of corrective action to Unit 2 activities and the Unit 2 assessment results were reviewed for repetition of Unit 1 findings. For 14 of the 16 Unit 1 findings, the corrective action was found to be effective.
The corrective action for one Unit 1 finding, to establisn a procedural requirement to maintain a warehouse record, was found to be not fully effective, as described in the discussion of Unit 2 Finding 2RRF-13B-003 in section 6.4.1.1.
For the remaining Unit 1 finding, an element of the finding was O
found to be repeated in Unit 2. In both assessments. FCRs were found making generic changes to the coating specification, but the FCRs were identified as not requiring incorporation in the specification (section 6.4.2.1 contains a discussion of Finding 2RRF-13B-002).
6.4.2 PART 2, IN-PROCESS ACTIVITIES The objectives of part 2 of the assessment were to examine ongoing design and construction processes.
6.4.2.1 Desion Programs i The design portion of part 2 examined the design programs controlling design changes.
l Design Chance Control l
l Thirteen Field Change Requests (FCRs) were evaluated to assess compliance with applicable procedures and licensing commitments and control of design changes.
0224m/172-8 6-10
The review identified repetitive failure to properly identify and process changes affecting Project Class 02C coatings O (coatings inside containment). FCRs concerning coatings inside containment were improperly identified as Project Class 62C and were not sent to QA for review. In addition, FCRs properly identified as Class 02C were not sent to Quality Assurance for review as required by procedure. Finding 2RRF-13B-002 (Level III) was issued. The finding also identified procedural errors in classifying FCRs for incorporation into the specification, failure to provide justification, and improper incorporation. The investigation determined that the problem area was limited to the coating specification. The technical adequacy of FCRs with procedural errors was verified by an Engineering review, and corrections were made to the documents.
Affected personnel have been retrained in the problem area.
Readiness Review concludes that the deficiencies have had no adverse effect on the technical adequacy of the specification and no effect on applied coatings.
6.4.2.2 Construction Procrams The construction portion of the Part 2 assessment examined in-process coating application, coating material storage and deviation reports.
{} In-Process Application In-process application activities were assessed by observing preparation, inspection, and application activities in the field. Attributes assessed included proper environmental i testing, surface preparation and inspection, documenting and l mixing of materials and application of coating. No deficiencies were identified in these activities.
Material Storace j The two prequalified material storage areas were examined for compliance to procedural requirements. Attributes assessed included temperature control, area cleanliness and material identification. No deficiencies were identified. j Deviation Reports The contractor's deviation report procedure was reviewed in preparation for assessment of a sample of deviation reports. A deficiency in procedural requirements for deviation tracking and conflicts in the procedure were identified and reported on Finding 2RRF-13B-008 (Level II). The Project invest.igated the finding and determined that deviations had been processed in a timely manner and that no errors in processing had occurred as a .
C) 0224m/172-8 6-11
result of the procedure conflicts. Revisions to the procedure have corrected the deficiencies.
A sample of contractor deviation reports was assessed for O
compliance to project requirements. The reports were reviewed for adequate description, appropriate disposition, proper justification, and required approvals. No deficiencies were identified.
Procedures The two contractor document control procedures were reviewed.
Both referenced an incorrect revision of ANSI N.45.2.9. Finding 2RRF-13B-006 (Level II) was issued. Investigation determined that no deficiencies in the contractor's document control program had occurred as a result of this error, and the procedures were corrected.
6.4.3 PART 3, COMPLETION The objective of part 3 of the assessment was to evaluate the construction completion process.
Applied Coatings Samples of applied coatings were examined in the field for compliance to procedural and specification requirements. The llh samples included coatings applied to touch up deficient or damaged coatings. Coatings were inspected for dry film thickness and visual deficiencies such as cracking, pinholes, l runs, and inclusion of contaminants. Surrounding areas were
! checked for overspray, droppings, and masking of nameplates, moving parts, etc.
The applied coatings assessed were found to be acceptable. No findings were issued.
Two small coating areas not meeting specification requirements i
were noted at a hanger in the containment dome area, the overlap l area of the touchup work had excessive dry film thickness and the coating had been applied over a small amount of weld spatter. The excessive dry film thickness had been identified by Quality Control on a deviation report at the time of acceptance inspection and had been dispositioned use-as-is.
Examination of applicable documents also showed that the coating over weld spatter occurred at the time when acceptance standards were changed from "a small amount of tightly adhering weld spatter" to "no weld spatter." No retrofit requirement was associated with this change. The amount of coating in question on the assessed hanger is very small (about one square inch).
O 0224m/172-8 6-12
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During the field walkdown it was noted that some applied coatings had been damaged by subsequent construction I activities. Review of the area turnover procedure revealed that acceptable coatings is an attribute for area turnover walkdown and repairs are made as identified by this final inspection.
This process had not started in the Unit 2 containment at the time of the assessment.
Quality Documentation
' Inspection records associated with the coating samples inspected were reviewed for conformance to procedural requirements and agreement with the product observed in the field. No deficiencies were found.
Material Traceability Sample batch numbers from the inspection records reviewed were traced to the manufacturers certificates and the certificates were reviewed for compliance to requirements.
All samples were successfully traced and the certificates demonstrated that the materials were qualified.
Inspector Oualification Approximately 30 inspectors have worked on Unit 2 containment
(~}
\'
coatings. Records for six inspectors were selected from the inspection records reviewed and were assessed for compliance to procedural requirements. No deficiencies were found. The document packages were complete and showed the inspectors to have been properly qualified at the time of inspection.
Painter Certification Approximately 80 painters have applied coatings in Unit 2 containment. Records for seven painters, selected from the inspection documentation assessed, were reviewed to ascertain if the painters were certified at the time of application for the application performed. No discrepancies were found.
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0224m/172-8 6-13 c
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0224m/172-8 6-14
6.5 FINDINGS O'
This section presents, in numerical order, the six valid findings issued during the assessment; the Project response, including corrective actions taken; and the Readiness Review Task Force conclusions for each finding.
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0224m/172-8 6-15
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1-0224m/172 8 6-16
Finding 2RRF-13B-002 (Level III)
() Requirements:
Project Reference Manual, section 17, states, in part, the following:
o 17.5.2.a. After review and disposition by Engineering, if a design change is needed to the affected documents, an "X" is placed in blocks 2 and/or 6 of the Field Change Request (FCR) form.
o Construction Specification Change Notices (CSCNs) and Mechanical Specification Change Notices are incorporated in accordance with part C, section 26.
o 17.5.3, Justification and concurrence shall be provided on the FCRs prior to approval of block 16.
o 17.6.2.5, FCRs initiated for specifications that are Q-Class, fire protection or radwaste shall be forwarded to Quality Assurance (QA) for their concurrence prior to submitting the originals to Georgia Power Company Document Control.
Finding:
T Contrary to the above, of a sample of 13 FCRs~ reviewed for Readiness Review Module 13B, Coatings, the following discrepancies were noted which were written against Specification X1AJ07:
o C-FCRB-22524 - Generic change identified as NA/NA, missing QA review. ,
o C-FCRB-21176 - Missing QA review, incorrect project l class.
I o C-FCRB-21175 - Missing QA review, incorrect project i class. i o C-FCRB-19820 - Generic change identified as NA/NA, missing QA review and justification.
i o C-FCRB-20176 - Missing QA review, incorrect '
incorporation.
o C-FCRB-19891 - Missing QA review.
l O
0224m/172-8 6-17
Project Response:
I. INVESTIGATIVE ACTION To determine the extent, the 48 FCRs written since January 1, 1986, against architectural specifications that are Q-Class, fire protection- or radwaste-related (X1AG10, X1AH02, X1AH05, X1AH07, X1AJ07, X1AR10, and X1AR28) were reviewed. Fourteen of these were found to contain procedural errors similar to, and in addition to, those cited in the finding. All of these 14 additional FCRs with errors were written against Coating Specification X1AJ07.
No FCRs with errors were found written against any other architectural specification. Therefore, the extent of the concern identified in this finding is considered to be isolated to FCRs issued to Specification X1AJ07.
Revision 24 to Specification X1AJ07 was written in December 1985 in response to a Unit 1 Readiness Review finding. This general revision included incorporation of outstanding change documents and a review and rewrite of the entire specification. FCRs written against the specification subsequent to January 1, 1986, were reviewed during the investigative actions from this finding. To assure that all FCRs with procedural errors, written subsequent to the baseline revision 24 had been identified, FCRs written against revision 24 of Specification X1AJ07 in December 1985 were reviewed. No additional FCRs with jl errors were found.
Of the 20 FCRs with procedural errors identified in the finding and the project review, one (C-FCRB-22,524) had been voided, as the application process authorized by the I
FCR was neither incorporated in a Williams Power Services, Inc. (Williams) application procedure nor used on the Project.
The remaining 19 FCRs were reviewed to determine if an impact to hardware or testing could exist as a result of the problems noted. The review concluded that the 19 FCRs contained adequate and acceptable technical design changes. The conditions are limited to programmatic documentation errors; therefore, there is no impact on hardware.
Root Cause:
The personnel processing FCRs had an inadequate understanding of the coatings project class designation and the QA review requirement associated with the coatings 02C class.
O 0224m/172-8 6-18
II. REMEDIAL ACTION
() Correction of the 19 FCRs identified was completed on April 28, 1988, with the exception of CFCR-B-20176, which was identified as being improperly incorporated in the specification. Specification X1AJ07 was revised May 12, 1988. This revision corrected the revision block to indicate that the FCR was modified. The actual incorporation of this FCR is technically adequate and the word " modified" had been inadvertently omitted.
III. ACTION TO PREVENT RECURRENCE Training of appropriate architectural personnel has been conducted regarding the coatings project classification (02C versus 62C), the need for QA review of FCRs with the project class 02C, and identification of generic changes requiring incorporation into the specification.
Readiness Review
Conclusion:
The Project review of the 19 discrepant FCRs demonstrated that the procedural errors in processing the*FCRs had not resulted in any deficiencies in applied coatings.
The Readiness Review assessment and the Project review identified repetitive procedural lapses; however, the Project
(, ) review of architectural FCRs is evidence that the problem is limited to Coatings Specification X1AJ07.
The finding is partially repetitive of a Unit 1 Readiness Review l finding in that Unit 1 Finding 13B-21 reported an improper l designation as NA/NA for two FCRs containing generic changes.
This same deficiency was identified for the voided FCR and three ,
others during the Unit 2 assessment and Project review. '
The corrective action and action to prevent recurrence is appropriate to the finding and the identified root cause.
The response is acceptable and there is no impact to the applied coatings.
l 1
l 0224m/172-8 6-19
Finding 2RRF-13B-003 (Level II)
Requirements: h Specification X1AJ07, paragraphs 12.1.1A, 12.7.1, and 12.7.2 require that the documentation requirements of ANSI N101.4 be met and allow alternate forms providing the same degree of documentation to be used. Example 3 of the Quality Document Forms Attachment to Specification X1AJ07 is a warehousing record, docuraenting the receipt and withdrawal of coating material for each batch of coatings material received.
Finding:
No procedure was found prescribing preparation and turnover of the required warehousing record or equivalent.
Note: An informal inventory record is kept in the Williams warehouse which is equivalent to the required Warehousing Records. During the assessment it was determined that this inventory record included all the required data for the selected samples of coating materials.
Project Response:
- 1. INVESTIGATIVE ACTION Williams does not currently address the Warehousing Records in any procedure. A similar finding was reported in Unit 1 Readiness Review Finding 1RRF-13B-7 in 1985. At that time, a commitment was made to place the Warehousing Records in Warehouse Procedure WW-I-01. This was completed on September 26, 1985. On August 12, 1987, Procedure WW-I' 01 was revised and the requirements for the Warehousing Records were dropped from the procedure.
The root cause of Unit 2 Readiness Review Finding 2RRF-013B-003 was the fact that the Warehousing Records were never recognized as a quality document. In addition, the Warehousing Record was not designated as a quality document in Procedure WC-003 and in response to the Unit 1 finding, it was placed in a warehousing procedure instead of a Quality Control procedure.
Williams has historically used the Warehousing Record as an inventory control vehicle. The Warehousing Records have been continuously maintained and document turnover has not begun, thus assuring the availability of adequate material traceability.
O 0224m/172-8 6-20
II. REMEDIAL ACTION
() Procedure WC-015-253, Warehouse Coating Records, has been written for the upkeep and turnover of the Warehousing Records. In addition, the existing Warehousing Records have been reviewed by the Williams Quality Control department. The review found that records were missing for the period of September 9, 1986, to December 16, 1986. The missing records were 3ddressed in Deviation Report WC-88-003 dated May 26, 1988; the approved disposition was hardware not affected. The Williams quality assurance / quality control (QA/QC) site manager has concluded, after completing the review, that the existing l Warehousing Records are acceptable as quality documents.
1 III. ACTION TO PREVENT RECURRENCE The new QC procedure has been approved by GPC Quality Control and is controlled by the Williams QC Department through Document Control Procedures WC-003 and WC-019.
Williams Quality Control will monitor the Warehousing Records closely to assure compliance.
1 Readiness Review
Conclusion:
The Unit 2 Readiness Review assessment evaluated Williams compliance with specified record keeping provisions of
() ANSI N101.4. Each record requirement was reviewed against Williams procedures and samp.les of the records. All records except the Warehousing Records were found to be properly prescribed by Williams procedures. During the material traceability assessment, material qualification and traceability to specific batch numbers was ascertained without using the Warehousing Records.
The process of adjusting Williams warehouse activities to accommodate changed workload levels involved procedural and personnel changes. During this process, the quality aspects of the Warehousing Records were overlooked as stated in the root cause investigation, j j
The corrective action of including the Warehousing Records in the Quality Control procedures and under Quality Control purview should prevent any repetition.
The remedial action to review the informal inventory record and verify acceptability (to ANSI N45.2.9 standards such as legible, completely filled out, and stamped, initialed, or signed and dated by authorized personnel) provides the records required to meet the specification.
Based on the response and the above considerations, Readiness
() Review concludes that the response is acceptable.
0224m/172-8 6-21
Finding 2RRF-13B-004 (Level II)
Requirements:
Design Criteria DC-1000A, section 10, requires that coatings inside the containment building meet the requirements of ANSI M101.2.
Specification X4AJ16 (Containment Cooling Units), revision 10, dated December 10, 1986, paragraph 6.3.1, requires that coatings be certified to ANSI N101.2. Paragraph 6.3.A requires an inorganic zinc primer followed by an epoxy topcoat and also lists acceptable suppliers and products.
Finding: -
A. The Ameron and Carboline inorganic zinc primers listed are not their N101.2-qualified products.
B. The products listed are all inorganic zinc primers. No epoxy topcoat is listed.
Project Response:
- 1. INVESTIGATIVE ACTION Extent of the Problem:
This finding identifies conflicting requirements within O
Specification X4AJ16. Paragraph 6.3.1.2.a requires documentation in accordance with ANSI N101.4 and Regulatory Guide 1.54. In the same specification, paragraph 6.3.A.4 requires specific name brand coatings which will not meet these documentation requirements and makes no allowance for acceptable alternates.
To determine the extent of this problem with conflicting coating requirements, a sampling of 8 out of approximately 40 specifications requiring the ANSI N101.4 and N101.2 documentation was reviewed. These specifications were:
X2AG03, X2AG05, X2AG06, X2AG07, X2AG08, X2AH01, X2AH02, and X2AP01-C9.1. No conflicts or discrepancies between the approved coatings list and documentation requirements were identified; therefore, the discrepancy is an isolated event.
Significance of the Deficiency:
The purchase order document PAV2-86 was reviewed to determine the quality of paint actually supplied for items in X4AJ16. The Supplier Quality Verification Document List-Detailed documents that the paint meets the requirements of paragraph 6.3.1.2.a of X4AQJ16. Also, the l Product Identity and Quality Assurance Certification Record lh l
j 0224m/179-8 6-22 l
t
certifies that the paint meets the manufacturing requirements of ANSI N101.2, ANSI N101.4 and ANSI N5.12
()
l when properly mixed. Documentation that the paint was )
properly mixed and applied is provided. These documents l provide objective evidence that the paint meets the more !
stringent requirements of paragraph 6.3.1.2.a of X4AJ16 and i that the conflict in the specification did not degrade the j installed paint quality.
Root Cause:
The root cause of this finding can be attributed to human l error. The specification writer did not realize that the paint specification contained conflicting requirements and the review process failed to uncover the mistake.
II. REMEDIAL ACTION I Specification X4AJ16 was revised June 8, 1988, to delete paragraph 6.3.A.4. This will eliminate the conflict between the documentation requirements and avoid the procurement of unqualified coatings in the future.
III. ACTION TO PREVENT RECURRENCE The remedial actions taken assure that future materials procured under X4AJ16 will meet the requirements of
() paragraph 6.3.1.2.a.
Readiness Review
Conclusion:
^
The response demonstrates that the coatings material used to shop coat the containment cooling units procured under Specification X4AJ16 was properly qualified and that the specification conflict resulted in no hardware deficiency.
The project reviewed eight specifications and found no similar errors. During the assessment, Readiness Review examined nine specifications, identifying the one conflict described in the finding. The remaining eight specifications were in compliance with ANSI N101.2 and without conflict. Three of these eight were also included in the project review sample. Based.on these investigations, Readiness Review agrees that the discrepancy is isolated and not indicative of a programmatic problem.
The revision to the specification deletes the section listing specific coating products, thus resolving both the omission of any epoxy topcoat product and the listing of inorganic zine products not qualified. The requirement to shop coat cooling units with a coating system prequalified to ANSI N101.2 remains i
i 1
0224m/172-8 6-23
in the specification assuring consistent requirements meeting project commitments for any future use of the specification.
The response is acceptable.
O 1
0 0224m/172-8 A _ y e,
Finding 2RRF-13B-005 (Level II)
() Requirements:
Final Safety Analysis Report (FSAR), section 6.1.2.1; Specification X1AJ07, section 12.5.1; and Williams QA Manual, section 5.4.4, and Job Specific Addendum, section 5.4.1, require written approval of the manufacturer for application procedures.
Findinc:
Williams Procedure WC-300, sections 300.4.1.4 and 300.7 allow exceptions to this requirement.
Project Response:
- 1. INVESTIGATIVE ACTION
. Williams QC reviewed all application procedures and found options or exceptions stated or implied in sections 300.2.2, 300.2.3, 300.4.1.4, and 300.7. The Williams QA/QC site manager confirmed that exceptions to this manufacturer approved application procedure were made. _
i lt has been the practice of the Civil Engineering Discipline to converse with the coatings manufacturer prior to recommending any changes involving Q coatings. In
() addition, it has been the practice of the Williams QA/QC site manager to be in agreement with the coatings manufacturer prior to sending a procedure to them for approval. No procedure changes have been disapproved by ;
the coatings manufacturer and procedures have promptly received written approval. All application procedures have been sent to the coatings manufacturer.
Root Cause:
1 Williams Management, in an effort to provide timely l response to site conditions or specification changes, i permitted application procedure requirements to be '
superseded, based on oral concurrence, prior to receiving l written approval from the coatings manufacturer. l l
II. REMEDIAL ACTION Williams has revised Application Procedure WC-300, sections' l 300.2.2, 300.2.3, 300.4.1.4, and 300.7, to remove any l reference to exceptions. l III. ACTION TO PREVENT RECURRENCE The Williams QA/QC site manager and the Williams project
() manager generate and approve Application Procedure WC-300.
0224m/179-8 6-25 l
In the future, they will ensure that the procedure is revised and written approval from the coating manufacturer is obtained prior to implementation.
Readiness Review
Conclusion:
The investigation showed that the exceptions to manufac'turer's approval of application procedures, allowed in the contractor's procedure, had been used to implement changes in application procedures while written approval was in progress. In no instance had procedures been issued without the oral approval of the manufacturer. All procedures have been submitted to the manufacturer and have been approved in writing. No coatings have been unacceptably applied as a consequence of this discrepancy. The remedial action and action to prevent recurrence should prevent any further instance of the use of an application process before the required documentation is in place.
The response is acceptable.
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O224m/172-8 6-26
Finding 2RRF-13B-006 (Level II)
- Requirements:
FSAR, section 17.1.2, and Williams QA Manual, Job Specific Addendum, section 5.10, require conformance to ANSI N45.2.9 1973, eleventh draft.
Finding:
Williams Procedures WC-003, Document Security, and WC-019, Controlled Document Revision and Distribution, reference ANSI N45.2.9. 1974.
Proiect Response:
- 1. INVESTIGATIVE ACTION The investigation into this finding found the Williams QA Manual and Procedures WC-003 and WC-019 to be generic / corporate documents. All three documents reference ANSI N45.2.9. 1974. The Job Specific Addendum to the QA Manual, paragraph 5.10, requires conformance to ANSI N45.2.9 1973, eleventh draft, as required by section 17.1.2 of the FSAR.
Williams relied on the Job Specific Addendum to the QA
() Manual to prescribe site-required conformance to ANSI N45.2.9, 1973, eleventh draft. The root cause of the finding was that no reference in the QA Procedures Manual would lead the user to the Job Specific Addendum of the QA Manual as the source of the correct edition of referenced ,
standards.
The Williams QA/QC site manager checked the QA Procedures l to verify that other standards referenced are the edition j stated in the Job Specific Addendum of the QA Manual. All !
were found to be the edition stated in the Job Specific l Addendbm.
II. REMEDIAL ACTION Williams revised Procedures QC-003 and WC-019 to reference ANSI N45.2.9-1973, eleventh draft. These revisions were completed by April 19, 1988.
III. ACTION TO PREVENT RECURRENCE The Williams QA/QC site manager generates and approves these procedures. He will ensure that all future procedures have the correct standards referenced.
O 0224m/179-8 6-27
Readiness Review
Conclusion:
The remedial action will correct the deficiency found. h Readiness Review knows of no changes between the 1973, eleventh draft, and 1974 revisions of ANSI N45.2.9 that would adversely affect the quality of Williams' documentation.
Readiness Review checked the Williams QA Manual for correct revisions of reference standards to further evaluate the broadness of this finding. No discrepancies were found.
Readiness Review also checked the remainder of the Williams QC Procedures Manual for reference to correct revisions of standards. Four additional references to specific standards were found. All were in agreement with the specification or unspecified and in agreement with the Williams QA Manual.
Readiness Review concludes that this discrepancy was isolated, with no programmatic implications.
The response is acceptable.
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O224m/172-8 6-28
= _ _ _
i Finding 2RRF-13B-008 (Level II) !
t
'() Requirements:
Vogtle Electric Generating Plant.(VEGP) QA Manual, section 15.2 !
states: I i
A. The identification, documentation, segregation, review, !
disposition, and notification of affected organizations of i nonconformance of materials, parts, components, or services ;
is controlled. i B. Nonconformances concerning departures from design l specification and drawing requirements which are '
dispositioned use-as-is or repair are dispositioned by the ,
responsible engineering organization. i s
i Finding: I
- 1. Williams Procedure WC-000 contains no provision for tracking j reworkable deficiencies defined in section 008.5.1.2. !
Requirements for identifying non-reworkable deficiencies are l conflicting. (Sections- 008.5.1.3 and 008.5.2.1) i 2 ., Provisions of Williems Procedure WC-000 for approval of l use-as-is or repair dispositions are conflicting, and do not ,
identify Project Engineering as the responsible engineering i organization. (Sections 008.5.2.4, 008.5.7.2, 008.6.3.21, !
O. 008.6.3.23, 008.6.3.26) l Project Response:
I. INVESTIGATIVE ACTION The Williams QA/QC site manager confirmed that the original )
intent of procedure WC-008, section 008, section 008.5.1.3; was to address the tracking of rejected items which were reworkable. A typographical error was made and section 008.5.1.3 inadvertently stated " rejected items which are not reworkable."
Section 008.5.1.3 also addresses an Open Item Log.
Williams QC stopped using the log in May of 1986. At that time, the responsibility for keeping the log was moved from the QC clerk to the QC inspectors. The investigation found that the Williams QC inspectors failed to use the log and that Williams QC management failed to ensure that the inspectors used the log.
The purpose for the Open Item Log was to track reworkable, rejected items. Prior to May 1986, the log documented and verified that reworkable items were handled in a timely manner. . Williams QC replaced the Open Item Log with a 1
'0224m/172-8' 6-29 !
designated Hold File. Williams QC management failed to make the appropriate change in procedure WC-008 to reflect the new method of tracking.
The Williams QA/QC site manager reviewed all reworkable, rejected items reported between May 1986 and April 6, 1988. There were 568 reworkable, rejected items reported during this period. A random sampling of 72 of the 568 items was reviewed and it was determined that 50 were reworked within 4 days, 2 within 7 days, and 20, all of which were on one inspection report, were not reworked for 4 months. Although the Open Item Log had not been used since May 1986, these 20 rejects mentioned above were recorded in the Open Item Log in May 1987, but were never placed on a Deviation Report. The inspection report was placed in the designated Hold File until it was reworked.
The Williams QC Site Manager did not write a Deviation Report because the delay was caused by construction restraints which did not allow the workers back into the area for rework. Williams Management concluded from this~
review that items were reworked in a timely manner except as constrained by other construction activity. As of April 6, 1988, there were no outstanding reworkable, rejected items in the designated Hold File.
The root cause of this finding was the inappropriate attention level of Williams QC management.
Investigation into the second part of this finding, O
established that section 008.6.3.23 had three editorial errors. The words " recommended dispositions" are used twice in this section. The correct words should be
" approved dispositions." The third error had the " owner or l designee" approving what should have been the approved i disposition. The " design engineering group" should approve
- the approved disposition.
As previously stated, Williams procedure WC-008 required the owner or designee to approve any use-as-is or repair approved dispositions. In practice, Williams sent deviation reports requiring this approval to the Project Construction Civil Engineering Discipline. The Civil Engineering Discipline, in accordance with Georgia Power Company Procedure GD-T-01, sent the use as is or repair deviation reports to Project Engineering. In fact, all Williams use as is and repair deviation reports have received Project Engineering approval.
l The root cause of the errors in section 8.6.3.23 was the inadequate review of the final printed text prior to final approval.
O 0224m/172-8 6-30 l
NOTE: Williams QC Procedure WC-008 employs the terms
" owner or designee" and " design engineering O group." The Williams organization construes the terms " owner or designee" to mean the Project Construction Civil Engineering Discipline and
" design engineering group" to mean Project Engineering'.
II. REMEDIAL ACTION Williams has revised Procedure WC-008, section 008.5.1.3, to direct any inspection reports which identify reworkable deviation to be placed in a designated hold file and to remain in that file until the area has been reworked. This file will be reviewed monthly by the QA/QC site manager.
Any item over 60 days old shall be reported on a deviation report. The inspection report shall remain in the hold file until it has been closed by the approved disposition on the deviation report. Deviation Report WC-88-002 has been written to resolve the procedure violation cited herein and it has been dispositioned " hardware not affected." The typographical error in section 008.5.1.3 has been corrected.
Williams has revised Procedure WC-008, section 008.6.3.23, to state " approved dispositions" instead of " recommended dispositionc" and " design engineering group" instead of
" owner or designee". Future changes will be more O' thoroughly edited.
III. ACTION TO PREVENT RECURRENCE Williams QA/QC has reviewed their Quality Control procedures and determined that the QC manager reviews deviation report trends and rejected open items on a monthly basis. No other monthly review requirements were found. The trend review (Form WC-008D) is in place and a checklist for the monthly review of rejected open items (Form WC-008E) has been added to the nonconformance control procedure (WC-008).
Remedial action will prevent recurrence.
Readiness Review
Conclusion:
The investigation determined that subsequent to May 1986, the tracking system for reworkable coating deficiencies, intended to be established in this procedure, was not used. A hold file system was used and deficiencies were corrected promptly or, where prompt correction was not possible due to access ;
constraints, the deficiencies were corrected uhen access was again available. However, deviation reports were not issued after a predetermined period of time and the reports were not 0224m/172-8 6-31
entered in the formal tracking system. The investigation further showed that deviations with use-as-is or repair dispositions had been approved by Project Engineering. lh Readiness Review concurs that the root cause was inadequate QCi manager attention and inadequate review of final procedure text.
The procedure changes, correcting the conflicts and errors and adding a review checklist will remedy the finding. These changes, and the commitment to more thorough editing of procedure text, should prevent recurrence.
The response is acceptable.
9 0
0224m/172-8 6-32
l TABLE 6-1 l READINESS REVIEW TEAM O FOR MODULE 13B ,
1 P. R. Thomas Read.iness Review Task Force D. G. Lunsford GPC Quality Assurance J. H. Draggs GPC Quality Assurance B. A. Dragon Bechtel Quality Assurance O
I l
s 3
I E
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0227m/168-8/l
TABLE 6-2 UNIT 2 FINDINGS O
NUMBER LEVEL DESCRIPTION 2RRF-13B-002 III Errors in Processing FCRs.
2RRF-13B-003 II Required Warehouse record not maintained by contractor.
2RRF-13B-004 II Conflicting coating requirements in purchase specification.
2RRF-13B-005 II Contractor procedure does not meet specification.
2RRF-13B-006 II Contractor procedures cite different revision of standard than contractor QA manual and FSAR.
2RRF-13B-008 II Conflicts in contractor procedure for deviation reporting.
O O
0227m/168-8/2
i TABLE 6-3
^
ASSESSMENT SAMPLE O
Item Number Assessed Design Field Change Requests 13 Licensing Commitments 8 Unit 1 Findings 8 Construction In-Process Applications 3 Material Storage 2 Deviation Reports 10 Completed Coatings 10 ,
- Material Traceability 4 l Inspector Qualification 6 Applicator Certification 7 '
Licensing Commitments 7 Unit 1 Findings 8 i e
F
.O i 0227m/168-8/3
(
Georgic Pow:r Comptny Project MinigimInt Post Offico Box 282 Waynesboro. Georgia 30830 TOephona 404 724-8114 404 554 9961 h
(~\
U Vogtle Project June 15, 1988 MEMO TO: R. W. McManus
SUBJECT:
Plant Voctle Unit 2 Readiness Review Module 13B C
Engineering has reviewed Module 13B, Coatings, for general accuracy and completeness. To the best of our knowledge and belief, the module is a complete and accurate representation of the engineering process and commitments related thereto.
/
W.
~
C. Ramsey, Jr.
,f Project Engineering Ma ger RWM/WCR/bjb 7
L 0225m/166-8
Georgia Pow 2r Company Project Minigem;nt Post Offica Box 287.
Wayniscoro, Georgia 30830 TO:Dhona 404 724 8114 404 554 9961 L
n>
Vogtle Project June 15, 1988 MEMO TO: R. W. McManus
SUBJECT:
Plant Vogtle Unit 2 Readiness Review, Module 13B Nuclear Construction has reviewed Module 13B, Coatings. To the best of our knowledge and belief, the module is a complete and accurate representation of the site coatings program and
/'N commitments related thereto.
'y/
- -7
/11 /' / .-t'. Y ' "
R. H. Pinson Vice President Vogtle Construction RWM/RIIP/bjb e
/~%
i )
%.)
0225m/166-8
Georgia Pow;r Compiny Project Minig; mint Post offica Box 282 Wrynxboro. Georgis 30830 Telephona 404 724 8114 404 554-9 % 1 L
,)
'- Vogtle Project June 15. 1988 MEMO TO: R. W. McManus
SUBJECT:
Plant Vogtle Unit 2 Readiness Review Module 13B Project Quality Assurance has reviewed Module 13B, Coatings. To the best of our knowledge and belief, the module is a complete
/'N and accurate representation of the site programs and commitments U related thereto.
/l,
) p.
C. W. Hayes Project Quality Assurance Manager RWM/CWII/ b j b i
(V 0225m/166-8
r
(
PLANT VOGTLE UNIT 2 READINESS REVIEW PROGRAM Coatings - Module 13B Readiness heview Board Acceptance Letter The Readiness Review Board has been apprised of the scope and content of Module 13B, Coatings.
The Board has reviewed the program verification, as well as corrective actions, both proposed and implemented, by the Vogtle Project. Based upon this review and based upon the collective experience and professional judgement of the members, the Readiness Review Board is of the opinion that the corrective actions proposed are acceptable, coatings at Plant Vogtle are
- sound and, with implementation of corrective action, the coatings program complies with commitments set forth in the FSAR.
(v^}
- ^
m .
v APPROVED: '
Doug Dutton Chairman, Readiness Review Board Vogtle Electric Generating Plant i
j l
0225m/167-8 I
1
~
s PLANT VOGTLE READINESS REVIEW PROGRAM ASSESSMENT PLAN FOR MODULE 13B COATINGS ASSESSMENT PLAN APPROVAL
/
TEAM LEADER: ' M DATE: 2 ~ 'hb RR PROGRAM MANAGER: ,/' f# DATE: // #58 M6 RR BOARD SPONSOR: I/ DATE: 2,!28 ((
/ /
O 0209m/035-8 l
-)
UNIT 2 READINESS REVIEW MODULE 13B, COATINGS ASSESSMENT PLAN 1.0 OBJECTIVE This assessment plan provides direction for evaluating Vogtle Electric Generating Plant (VEGP) Unit 2 design and construction activities associated with protective coatings.
2.0 SCOPE This secti'on describes the project components and activities ;
included in Module 13B, Coatings. The section also describes the scope of the assessment planned for Unit 2 activities.
i 2.1 MODULE SCOPE Module 13B, Coatings, includes design, procurement, construction and inspection activities associated with protective coatings inside containment. Other coatings are reviewed for specific licensing commitments or industry problems. -
O ;
0209m/060-8 1 i
i
2.2 ASSESSMENT SCOPE O
Based on a review of the Unit 1 module results, and on Quality Assurance (QA) audits, Nuclear Regulatory Commission (NRC) inspections, Unit 1 licensing event reports, Unit 1 coating performance, industry problems, and project program changes since the Unit 1 assessment, the Unit 2 coatings assessment will review a sampling of the following activities, items, and programs:
o Commitment implementation.
o Application of corrective action for Unit 1 findings to Unit 2 activities.
O l
o Design changes. j l
l o Material control and traceability. ,
l o In-process application. ]
o Applied coatings. j i
)
o Inspection and inspection documentation.
o ' Qualification and certification of inspectors.
l 0209m/060-8 2 l
I
o Certification of coatings application personnel.
O o Control and turnover of documentation.
Coating samples are selected from the Unit 2 containment.
Design and inspection documents reviewed are selected from those relating to Unit 2 containment and, where feasible, relating specifically to the coating samples selected for assessment.
3.0 IMPLEMENTATION The assessment will be conducted in three stages of grouped activities or parts. Part 1 is an assessment of commitment implementation and Unit 1 finding followup, Part 2 is an assessment of design and construction programs and activities, and Part 3 is an assessment of completion activities and documentation.
3.1 COMMITMENT IMPLEMENTATION AND UNIT 1 FINDING FOLLOWUP The commitment matrix data base has been maintained current by Readiness Review. Updated implementation data has been provided to Readiness Review by the responsible project organizations and input to the data base by Readiness Review. In the commitment implementation assessment, the implementation data provided by 0209m/060-8 3
the project organizations will be assessed to ascertain its
() correctness.
Findings identified by either Readiness Review or the NRC during the Unit 1 Readiness Review process were listed by Readiness Review in a data base together with the corrective action applicable to each finding. Responsible project organizations reviewed the listing, categorized the findings as to applicability to Unit 2, and verified that the corrective action to applicable Unit 1 findings had been applied to Unit 2 activities. The results of this project organization review were provided to Readiness Review and input to the data base.
In the Unit 1 finding followup assessment, the data provided by the project organizations is assessed to ascertain its correctness.
The Part 1 assessment is performed by Readiness Review as described above.
3.1.1 COMMITMENT IMPLEMENTATION For each commitment applicable'to Module 13B, review the commitment in the source document [ Final Safety Analysis Report (FSAR) or correspondence responding to NRC questions] and any cited standards or reference documents. Check any listed O
0209m/060-8 4
cross-references. Identify any inconsistencies or conflicts as
() " Reject". Describe the inconsistency or conflict in the
" Comment" section of the checklist.
Verify that the implementation document cited on the implementation matrix satisfies the commitment.
Further direction on commitment identification and '
verification is found in the Vogtle Project Unit 2 Readiness Review Program Procedure 3.2. .
Note: The implementation and commitment matrixes are an index and an aid to maintaining VEGP conformance to licensing commitments. The matrixes are not, of themselves, Project commitment documents. Errors, conflicts or lack of clarity in the matrixes are not findings against the Project Quality Program and should not be marked as " Reject" on the checklists. Any such problems should be noted as " Comments" for resolution by Readiness Review.
Document results on Checklist 13B-101.
O209m/060-8 5
3.1.2 UNIT 1 FINDING FOLLOWUP O
The Unit 1 coatings module identified a total of 16 findings.
Assess each of these to ascertain that corrective action has been properly applied to Unit 2.
Check that the designation of the finding as applicable or not applicable to Unit 2 is correct. Note any errors as " comments" for correction of the tabulation. For any findings with corrective action determined to be changed as applied to Unit 2, note details as " comments" for incorporation in section 5 of the module report.
Assess the effectiveness of the corrective actions applied to Unit 2. If this assessment can be more effectively performed in conjunction with the Part 1, commitment implementation assessment, or with the Part 2 or Part 3 assessment, so note as
" comments" and reference the applicable commitment implementation, part 2, or part 3 checklist. ;
I Document results on Checklist 13B-102, 3.2 DESIGN AND CONSTRUCTION PROGRAMS AND ACTIVITIES i
A sampling of documents and activities associated with coatings
- inside Unit 2 containment will be assessed to assure engineering I V
l 0209m/060-8 6 l
and construction compliance to design and procedure
() requirements. Engineering documents will be assessed for technical adequacy. Construction in-process app'lication activities, material storage, and deviation reports will be assessed for compliance to applicable procedures.
Part 2 assessment is performed by QA.
3.2.1 DESIGN PROGRAMS AND ACTIVITIES Select 10 Field Change Requests and Construction Specification i
Change Notices to Specification X1AJ07, Field Coatings, issued or in effect subsequent to July 1, 1985, the effective date of the Unit 1 coatings module. Assess the design change documents ;
i for compliance to licensing and procedural requirements and for technical adequacy.
Document results on Checklist 13B-201.
3.2.2 CONSTRUCTION PROGRAMS AND ACTIVITIES i
Select a minimum of three in-process applications of coating systems prequalified to ANSI N101.2 and Section 3 of i ANSI N5.12. Include one application to steel and one l
application to concrete. Assess environmental testing, O.
O209m/060-8 7
e inspection of substrate, mixing of materials, and coating
) application for compliance to application and inspection procedures. Record results of tests, batch number (s) of coatings, amount of thinner used, and identification of applicator and inspector.
Document resulta on Checklist 13B-202.
Identify storage locations containing coating material required to be prequalified to DBA environmental conditions. Assess storage area and a sampling of coating materials in each area to ascertain that procedural and specification requirements for storage and traceability are followed.
Document results on Checklist 13B-203.
Select 10 Deviation Reports initiated since July 1, 1985, from the Williams Deviation Report Log. Assess each report for ,
i compliance to procedural requirements. l Document results on Checklist 13B-204.
3.3 COMPLETION ACTIVITIES AND DOCUMENTATION l 1
Completed coatings in the Unit 2 containment will be sampled and
_ assessed to ascertain product acceptability. Quality records 0209m/060-8 8
relating to the selected coating samples will be assessed for
() compliance to applicable procedures and specification requirements. I Part 3 assessment is performed by QA.
3.3.1 COATINGS, WALKDOWNS, AND DOCUMENTATION Select 10 samples of completed coatings inside Unit 2 containment. Samples selected should include:
o Coating on concrete floor.
O o Coating on concrete wall or ceiling.
o Coating on steel liner plate.
o Coating on structural steel, o Coating on embed. ;
o Coating on pipe support, electrical support, or heating, ventilation and air conditioning support.
O ,
0209m/060-8 9
o Coating on supports in the dome area.
O .
o Coating on dome liner plate.
Perform visual examination of coating for discrepancies in accordance with applicable inspection procedure. For coatings on structural steel, measure and record dry film thickness.
Note location of sample.
Obtain inspection documentation for coating samples selected.
Assess inspection documents for compliance to inspection procedure requirements. Check that application and environmental data recorded on the inspection report meets the requirements of the application procedure. Check that dry film thickness measured during walkdown meets application procedure requirements. Record names or identification of inspector and applicator. Record coating product and batch number.
Document results on Checklist 13B-301.
3.3.2 MATERIAL TRACEABILITY Select four of the coatings batch numbers from the walkdown and documentation assessment or from the in-process application i assessment. Review contractor's warehouse records to ascertain that required receipt and issuance record for that batch is O
0209m/060-8 10
maintained. (Specification X1AJ07, Quality Documentation Forms,
) example 3). Check GPC receiving records to ascertain that required manufacturers certificates are on file.
Document results on Checklist 13B-302.
3.3.3 INSPECTOR QUALIFICATION AND CERTIFICATION Select six inspectors who performed the inspections reviewed h
during the walkdown and documentation assessment or the in-process application assessment. Review the inspectors qualification and certification records to ascertain that he was certified to perform the inspection at the time performed, and that the record package reflects that he was qualified to be certified (e.g., eye examination, high school graduate, use of test equipment, experience).
Document results on Checklist 13B-303.
3.3.4 APPLICATOR CERTIFICATION Select six applicators who applied the coatings reviewed during the walkdown and documentation assessment or the in-process application assessment. Review the applications certification 0
0209m/060-8 11 l
record to ascertain that he was certified to apply the coating
() at the time of application.
Document results on Checklist 13B-304.
4.0 GENERAL INSTRUCTIONS -
Additional instructions for performing assessment activities are contained in the Vogtle Project Unit 2 Readiness Review Program Procedures Manual. In particular, personnel perf orming the ,
assessment activities outlined in this plan should be familiar with the requirements of procedures 2.3, Responsibilities:
2.4, Qualifications: 3.5, Unit 2 Assessment; and 4, Readiness T
Review Task Force - Quality Assurance Interface.
4.1 CHECKLIST COMPLETION INSTRUCTIONS t
An individual checklist is to be used for each component assessed. The checklist column marked " item" provides a numerical reference if needed when corresponding with the ,
Project. Numbers in this column in parenthesis () indicate
- reference to the Master Commitment Tracking List. The column marked " reference" provides.the source of the requirement to be verified. The column marked " requirement" is repeated from the source document. t 1
t 0209m/060-8 12 f
The column marked " finding / comment" is for explanatory materials and recording of supplementary data. Comments entered on the checklist should include as appropriate:
o A description of the actual condition found, o Document filing locations and hardware identification to permit tracing the specific documents and hardware reviewed.
o Data gathered during reviews to facilitate interrelating assessment attributes, o Any necessary explanation of assessment activity'and methods, concerns, findings, or issues requiring further assessment. ;
o An explanation for all reject conditions found.
o An explanation for reject conditions closed by further assessment without a finding.
A checkmark in the acceptable column indicates that the
]
condition found is acceptable. An N/A in the acceptable column i
indicates that the attribute listed is not applicable. An N/V l I
entry in the acceptable column indicates that the attribute was A
U 4 l
0209m/060-3 13 i
- not verified (due to accessibility, work in progress, etc.).
() N/A and N/V entries require a short explanatory statement in the Finding / Comment column, (see 4.2 below for direction in substituting items).
A checkmark in the Reject column indicates that the requirement of the checklist item was not met at the time of assessment. If the reject column is marked, add a brief statement in the finding / comment column explaining the basis for rejection. The Resolution column is used to indicate whether a Readiness Review Finding or Audit Finding Report was issued, or if the Project was able to provide sufficient information to close the item.
The checklists are to be signed and dated on each page by the person or persons performing the assessment and are to be completed neatly and legibly in black ink. Original checklists are to be returned to Readiness Review for storage.
4.2 SAMPLE REPLACEMENT OR REDUCTION i
The selections for assessment indicated on the checklists may prove inadequate for evaluation due to attributes not applicable to selections or for other reasons. In such cases, additional ,
[
items, components, or attributes are to be selected for assessment in the following order of preference:
O O209m/060-8 14 I
e . , --. . < ,,
l l
l l
l l
- 1. Additional components or attributes from the items, procedures, or standards already selected for assessment.
- 2. Additional items or components from the population of items and components within the systems selected for assessment.
- 3. Additional items and components from the population of items and components in other systems within the scope of the module.
Plans for expanding or reducing the sample size, or concerns that the sample may be inadequate, shall be reviewed with the Readiness Review program manager, who will provide direction.
(
,C)
%)
0209m/060-8 15 m<
m-ATTACHMENT 1, CHECKLISTS O
o 13B-101 Commitment Implementation j o 13B-102 Unit 1 Finding Followup o 13B-201 Design Change Documents o 13B-202 In-process Application o 13B-203 Storage o 13B-204 Deviation Reports o 13B-301 Walkdown and Documentation o 13B-302 Material Traceability o 13B-303 Inspector Certification and Qualification o 13B-304 Applicator Certification O
O 0209m/060-8 16 j 1
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Georgia Power Company Post Othce Box 282 Waynesboro, Georgia 30830 Telephone 404 554-9961, Extension 3413 404 724 8114 Extension 3413 m m
.'(s ) P. D. Rice Georgia c Power Vice President June 28, 1988 Vogtle Protect .r.
._ ,,,7 % .,,, e,,try( ys em United States Nuclear Regulatory Commission ATTN: Document Control Desk File: X7BD102 Washington, D. C. 20555 Log: GN-1463
Reference:
Vogtle Electric Generating Plant - Unit 2 Readiness Review Program Module 13B of the Vogtle Unit 2 Readiness Review Program, entitled Coatings, is enclosed for review and acceptance by the Nuclear Regulatory Commission (NRC).
Based on the review detailed in this module, I am of the opinion that adequate controls exist to ensure the quality of work and the implementation of Final Safety Analysis Report commitments within the scope of the module. Additionally, with resolution of the specific findings identified, the "g(_w) Project will fully comply with our licensing commitments.
The info,rmation herein is, to the best of my knowledge, factual and technically correct.
This submittal contains no proprietary information and may be placed in the NRC Public Document Room.
24 P. D. Rice RWM/PDR/bjb Enclosure xc: See attachment fd'
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xc: Cover letter H. G. Baker, Jr. G. Bockhold, Jr. I R. P. Mcdonald L. T. Gucwa D. R. Altman D. H. Smith, (OPC)
J. A. Bailey J. E. Joiner, (TSLA)
R. H. Pinson NORMS C. W. Hayes RR File C. W. Whitney Module Distribution:
P. D. Rice NRC:
D. E. Dutton J. N. Grace R. A. Thomas M. V. Sinkule (3)
C. T. Moore R. P. Correia W. E. Burpa J. Hopkins (2)
W. C. Ramsey R. J. Schepens D. T. King R. W. McManus (3)
L. B. Glenn Oi L. N. Brooks G. R. Frederick E. D. Groover J. E. Swartzwelder R. T. Oedamer
'~J 0228m/179-8
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VOGTLE ELECTRIC GENERATING PLANT UNIT 2 READINESS REVIEW PROGRAM 1
MODULE 13B - COATINGS O t i
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PREFACE Georgia Power Company (GPC), in order to gain added assurance of the operational readiness of the 1.gtle Electric Generating Plant (VEGP), conducted a pilot Readiness Review Program for Unit 1. The VEGP pilot Readiness Review Program was a' 1 systematic, in-depth self-assessment of work processes and verification of compliance with regulatory commitments. To accomplish the VEGP pilot Readiness Review Program, the work processes and regulatory commitments were divided into manageable segments called modules. There are 22 modules. Each module is a predefined scope of VEGP activities.
Each module provides a brief description of the method of complying with project licensing commitments pertaining to the module scope and is not intended to make further commitments or to revise in any way prior commitmente..
Activities common to several modules are defined in General Appendixes. There are seven appendixes. These appendixes, as appropriate, are referenced in the modules and are augmented in each module with module-scope-specific details as needed.
The VEGP pilot Readiness Review Program was conducted on a
- schedule to provide added operational readiness assurance to GPC management in support of the VEGP Unit 1 operating license.
Conclusions reached regarding programmatic and technical adequacy through review of VEGP Unit 1 are indicative of Unit 2, since both units are being designed and constructed together under a single quality assurance program: with similar management controls, procedures, specifications, and criteria.
The Unit 2 Readiness Review Program extends the results of the Unit 1 review by assessing activities, hardware, and documents within the scope of selected modules and ascertaining compliance with licensing requirements.
The VEGP Unit 2 Readiness Review Program is being conducted on a schedule to provide added operational readiness assurance to GPC management in support of the VEGP Unit 2 operating license.
The VEGP Readiness Review Program is not intended to eliminate or to diminish any authorities or regulatory responsibilities now assigned to or exercised by the Nuclear Regulatory Commission or GPC. Further, the Readiness Review Program is not intended to change the techniques of inspections or assurance of quality program activities. Rather, the VEGP Readiness Review Program is an added program initiated by GPC management to assess the VEGP and to provide additional feedback to management so that they may initiate any needed corrective actions in an orderly and timely manner.
O 0210m/179-8
The work processes and regulatory commitment compliance covered by each module scope will be assessed by, and the module prepared and reviewed by, individuals collectively familiar with 1 the design, construction, and preoperational processes of )
nuclear power plants. It is the collective opinion of the !
Readiness Review Task Force, Readiness Review Board, and GPC management that, based on their experience, the methodology used in the module process will assess, on a programmatic basis, the adequacy of project commitment implementation.
Readiness Review findings and resulting dispositions are reviewed by the Project Quality Assurance staff and are input into the normal project process for safety significance and potential reportability evaluations in accordance with regulatory requirements.
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EXECUTIVE
SUMMARY
This module documents a review conducted to ascertain whether the design and construction aspects of protective coatings at Vogtle Electric Generating Plant Unit 2 comply with licensing commitments and whether compliance is verifiable using existing J project documentation. Protective coatings reviewed are the l prequalified systems applied within the containment. !
l The review program for Unit 2 used the results of the Unit 1 l review program as a base, and focused on differences between the ;
units. These differences included added or revised licensing l commitments and changes resulting from project evolution or corrective actions to Nuclear Regulatory Commission (NRC) findings, project findings, design changes, or hardware modifications. The review consisted of technical and programmatic evaluations of the design and construction processes and results. Project documents such as design criteria and procedures; design output such as specifications l and drawings; and construction results such as applied coatings and quality documentation were examined during the review.
Discrepancies noted during review activities were issued to the Project as findings. Following receipt and evaluation of the .
responses, the findings were subject to categorization as follows to indicate their relative importance:
Level I - Violation of licensing commitments, project procedures, or engineering requirements with indication of safety concern.
Level II - Violation of licensing commitments or engineering requirements with no safety concern.
Level III - Violation of project procedures with no safety
, concern.
The Readiness Review Program evaluation of protective coatings in VEGP Unit 2 consisted of three major activities:
Commitment Implementation Review Readiness Review has maintained the listing of commitments for design and construction developed during the Unit 1 Readiness Review Program through review of Final Safety Analysis Report amendments and letters to the NRC. The ,
Project Engineering and Construction organizations were !
issued the listing of commitments applicable to this module i at the beginning of the review period; and the Project provided Readiness Review with updated implementation information which is presented in section 3.
O 0218m/179-8 1
Unit 1 Findino Followup During the assessment of Unit 1, the Project committed to h the performance of certain corrective actions. For Unit 2, Readiness Review provided Project Engineering and Construction with a list of Unit 1 findings and corresponding corrective actions. These two groups evaluated those findings applicable to Unit 2 activities and informed Readiness Review as to the action taken. The listing of Unit 1 findings and Unit 2 actions is presented in section 5.
Assessment The Unit 2 assessment of protective coatings consisted of an evaluation of commitment implementation, Unit 1 finding followup, and an assessment of design and construction activities to ascertain project compliance to commitments.
During the assessment, Readiness Review verified the updated implementation and Unit 1 finding followup information provided by the Project.
During the assessment of 'esign and construction, Readiness Review chose and evaluated a sample of design documents, in-process applications, and applied coatings to determine acceptance to specified criteria and conformance to installation and procedural requirements. Three in-process applications, 10 llh applied coatings and approximately 140 documents were examined.
Six findings were issued during the assessment; five classified as Level II and one as Level III.
None of the corrective actions required repair or rework of applied coatings. Some quality records were found deficient; however, sufficient documentation to provide objective evidence of required quality was found. Four of the findings related to contractor procedure deficiencies; however, these deficiencies had not resulted in defective coatings or programmatic concerns.
The findings collectively showed a lack of attention to detail in contractor procedures. Evaluation showed that these errors in detail had no effect on applied coatings and did not represent a safety concern. The findings were judged to be isolated instances of failure to comply with engineering or licensing requirements, or with procedures, with no safety concern and do not indicate, either individually or collectively, programmatic concerns.
Readiness Review Conclusion Based on the results of the review, and with the implementation of effective corrective actions to the identified findings as l Vi 0218m/179-8
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committed to by the Pr.oject, Readiness Review concludes that adequate programs exist to ensure: the quality of design and construction; objective evidence of that quality has been O documented; and the licensing commitments within the scope of this module have been implemented. l l
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MODULE 13B COATINGS
(~%
(_) TABLE OF CONTENTS Section 1 Introduction 1.1 Scope 1.2 Module Organization 1.3 Status Section 2 Organization 2.1 Introduction 2.2 Design 2.3 Construction Section 3 Commitments 3.1 Introduction 3.2 Commitment and Implementation Matrices Section 4 Program Description 4.1 Design 4.2 Construction Section 5 Audits and Inspections i
5.1 Introduction l 5.2 Project Audits l 5.3 Nuclear Regulatory Commission Inspections i 5.4 Reportable Deficiencies and Special Evaluations i 5.5 Unit 1 Finding Followup Section 6 Program Assessment 6.1 Introduction 6.2 Program Description 6.3 Summary and Conclusions 6.4 Assessment Activities and Results
6.5 Findings
Section 7 Assessment of Module Adequacy Project Quality Assurance Readiness Review Board Section 8 Assessment Plan and Checklists O
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1 INTRODUCTION 1.1 SCOPE This module is one in a series of modules that provides an evaluation of the design, construction, and preoperational testing of the Vogtle Electric Generating Plant Unit 2. It is l intended to describe the method of complying with the project commitments found in the Final Safety Analysis Report (FSAR) and is not intended to make further commitments or revise in any way, prior commitments. If any differences exist between the ;
commitment descriptions in this document and the FSAR, those j differences are unintentional and the FSAR shall take precedence '
and shall define the project commitments.
The scope of this module encompasses design, procurement, construction, and inspection activities associated with protective coatings inside containment.
1 The checks, reviews, inspections, audits, and verifications l performed to ensure the adequacy of design and construction functions are examined. The organizations responsible _for performing design and construction activities are identified and the work activities that the organizations perform are I described. The project commitments for coatings are identified, the method of implementation is listed, and the results of a review for compliance to the committed requirements are O presented.
The effective date of the module is February 1, 1988. Changes to the included programs, organizations, commitments, etc.,
occurring after this date are not necessarily addressed.
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1.2 MODULE ORGANIZATION This module is divided into the following sections:
- 1. Introduction.
- 2. Organization - A brief description of the project organizations and their division of responsibilities as applicable to this module.
- 3. Commitments - Project licensing commitments pertaining to coatings as found in the Final Safety Analysis Report, responses to Inspection and Enforcement Bulletins, and correspondence to the Nuclear Regulatcry Commission (NRC). This section also lists the documents that demonstrate implementation of these commitments.
- 4. Program Description - A brief description of the processes for design and construction applicable to the scope of this module.
- 5. Audits and Inspections - Listings of Quality Assurance (QA) audits and findings and NRC inspections and violations applicable to the scope of the module and conducted since the Unit 1 module. A description of special investigations is provided. The Readiness Review findings and NRC violations from the Unit 1 O module activity are listed, the corrective actions are presented, and their applicability to Unit 2 is indicated.
- 6. Program Assessment - A description of the assessment plan development, plan implementation, and results, including corrective actions.
- 7. Assessment of Module Adequacy - The evaluations and conclusions of this module by the Project, QA, and the Readiness Review Board.
- 8. Assessment Plan - The assessment plan and checklists utilized by the Readiness Review Team.
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1.3 STATUS As of the February 1988, the design of coatings was essentially O complete and application of coatings inside containment was approximately 68-percent complete.
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2 ORGANIZATION O
2.1 INTRODUCTION
Georgia Power Company (GPC), acting ~on its own behalf and as agent for the Oglethorpe Power Corporation, the Municipal Electric Authority of Georgia, and the City of Dalton is .
responsible for the design, procurement, construction, and I operation of the Vogtle Electric Generating Plant. GPC administers the overall quality assurance program, provides procurement services, controls materials issue, performs certain quality control inspections, and provides construction services .
for calibration, tests, inspections, document control, and I
nonconformance control. .
Bechtel Western Power Company (BWPC) is contracted by GPC to >
provide architect / engineering services for plant equipment / systems contained within the Seismic Category I structures and is responsible for the overall design coordination of all plant equipment / systems.
Williams Power Services, Inc. (Williams) is the contractor for coatings and is responsible for the application and inspection of coatings within the scope of this module.
Figure 2-1 shows the overall Project organizational structure for the scope of this module. The following sections contain O brief descriptions of the individual GPC, BWPC, and Williams groups that perform activities related to coatings. l l
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2.2 DESIGN i i
Project Engineering is responsible for the design of coatings.
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This responsibility is divided between two project l organizations: Design Engineering (DE), and Installation :
Engineering (IE). These organizations are comprised of i personnel from Bechtel Western Power Company (BWPC) and Southern l Company Services, with BWPC having overall design i responsibility. The Project Engineering organizational l structure for the scope of this module is shown on Figure 2-2. l 2.2.1 DESIGN ENGINEERING j l
DE is located at the jobsite with support staff in Norwalk, California. The design of coatings is primarily performed by l the civil discipline with specialty support provided by the )
Materials and Quality Services Department of the Research and l Development group of Bechtel. l l
2.2.2 INSTALLATION ENGINEERING IE is located at the jobsite and is primarily responsible for the resolution of field problems identified by the project construction organization. IE is responsible for maintaining the construction specification for field coating applications.
IE reports to the Georgia Power Company Civil Discipline for O project direction and to the plant design and civil project engineer and the civil / structural / architectural engineering group supervisor (EGS) of DE for technical direction.
2.2.3 ORGANIZATIONAL CHANGES In January 1987 Project Engineering, then comprised of Home Office Engineering (HOE) and Project Field Engineering (PFE) was restructured to better support the construction effort. The major elements of this restructuring were:
o Transfer of personnel from Norwalk (HOE) to the site.
This onsite group, along with the few remaining personnel in Norwalk, became DE.
o Relocation of PFE personnel from one central onsite location to individual groups located in proximity to each construction discipline. These groups became IE.
o Designation of a single EGS for each design discipline with overall responsibility for DE and IE work.
o Design activities in direct support of construction work were assigned to the IE groups.
0221m/179-8 2-3
o Design activities of a general or oversight nature were assigned to the DE group.
o Control of Project Reference Manual, Design Manual, and O
responsibility for providing technical direction to the IE groups were assigned to DE.
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i 2.3 CONSTRUCTION Project Construction is responsible for installation and
( inspection of protective coatings. This responsibility is divided between the Civil Discipline and Quality Control (QC). ,
These organizations are comprised of personnel from Georgia '
Power Company (GPC) and contractors reporting to GPC. The overall Project Construction organization is shown on Figure 2-3.
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2.3.1 CIVIL DISCIPLINE The Civil Discipline organization includes three groups performing coatings activities under the direction of the civil discipline manager. Those groups are GPC Civil Engineering l Section, Civil / Architectural Installation Engineering, and i Williams Power Services, Inc. (Williams). l The GPC Civil Engineering Section provides technical direction and support to the coating contractor, including review and approval of contractor application procedures, resolution of problems such as constructability issues and deviation reports, and material requisitions and releases to support contractor needs.
Civil / Architectural Installation Engineering, as described in section 2.2.2, performs design activities to support resolution of field problems. l O- The coating contractor, Williams, stores, applies, and inspects l
coatings and is responsible for providing craft, supervisory, and inspection personnel. Williams QC inspection is controlled by the Williams quality assurance (QA) program. The Williams QA Manual is reviewed for conformance to project commitments and approved by GPC QA. The Williams organization is shown in Figure 2-4.
Williams QC verifies that surface preparation, environmental l conditions, and coating application conform to approved l specifications and drawings, codes, and manufacturer's !
requirements. Inspections are controlled by procedures l developed by Williams QC to implement provisions of the Williams l QA Manual. Inspectors are certified in a program controlled by l procedures and meeting ANSI N45.2.6 requirements. Williams QC l procedures are reviewed and approved by GPC QC.
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2.3.2 GEORGIA POWER COMPANY QUALITY CONTROL GPC QC is divided into five groups under the direction of the manager of quality control as shown in Figure 2-5. GPC QC monitors the contractors QA/QC program, provides tool 0221m/179-8 2-5
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calibration service, reviews and approves Williams QC i procedures, and performs receipt inspection of GPC procured, ,
prequalified coating materials.
The Civil QC Section conducts surveillance inspections of coating work as it is performed by Williams crcftsman and inspected by Williams QC. Surveillance inspection is conducted in accordance with GpC QC procedures and to the requirements of the applicable contractor procedures, construction specification, and design drawings.
2.3.3 CONSTRUCTION ORGANIZATIONAL CHANGES No significant changes have been made in the construction organizations with coatings responsibilities since the Unit 1 Readiness Review assessment.
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O O O LEGEND PROJECT DIRECTION
---ADMINISTRATIVE DIRECTION
. GENERAL PROJECT MANAGER DIRECTOR NUCLEAR OPERATIONS I
GENERAL 1 MANAGER I QUALITY l ASSURANCE I I
ASSISTANT I PROJECT l MANAGER I PROJECT '
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PROJECT PROJECT REVIEW I E PRESIDENT BUDGET AND PROGRAM ENGINEERING LICENSING A A R PROJECT CONSTRUCTION SCHEDULE MANAGER MANAGER ^"
MANAGER SUPPORT MANAGER Figure 2-1 Project Organization m____ ____ .__ . _ _ , _ _ . _ _ , _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ - . ._ _ m - , .-
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-- FUNCTIONAL, TECHNICALJ ADessNISTRATIVE DIRECTION PROJECT
-- PROJECT COORDINATBON ENGINEERING MANAGER BECHTEL PROJECT ENGINEERING MANAGER ~~~~~~~~~~~7 I
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I I PROJECT ENGINEER PROJECT ENGINEER PROJECT ENGINEER PROJECT ENGINEER p PROJECT ENGINEER ELECTRICAL DESIGN FIELD CIVilINSTALLATION DESIGN CIVIL AND PLANT DESIGN INSTALLATION INSTALLATION Figure 2-2 Project Engineering
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s MAN AGE R OF QUALITY CONTROL DOCUMENT ELECTMICAL TECHNICAL SUPPORT REVIEW AMISTANT MAN AGER INSPECTION SECTION SUPERVISOR QUALITY CONTROL SUPERVISORS SUPERVISOR
- DOCUMENT STORAGE
- DOCUMENT REVIEW CIVIL / MECHANICAL CONTRACTOR QA/OC OC SECTION PROGRAMS
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- COATINGS SURVEILLANCE e WILLIAMS PROGRAM e TOOL Call 5 RATION MONITORING e RECEIPTINSPECTION - STAF FING
- OUALIFICATION
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- WILLIAMS PROCEDURE REVIEW Figure 2-5 Georgia Power Company Quality Control-
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. l 3 COMMITMENTS
3.1 INTRODUCTION
This section contains, in matrix form, licensing and project l commitments and the corresponding implementing documents. These '
are presented in two matrices, the commitment matrix and the implementation matrix.
Commitments A commitment is an obligation to comply with the described requirements of an industry standard, Regulatory Guide, Branch Technical Position, or owner plan of specific action. For the purposes of Readiness Review, commitments are identified from the following sources:
. o Final Safety Analysis Report (FSAR), including responses to Nuclear Regulatory Commission (NRC) questions.
o Responses to Inspection and Enforcement Bulletins.
o Correspondence to the NRC.
These sources were reviewed and commitments were selected for inclusion on the matrix using the following guidelines:
) o Specific design and/or construction requirement.
o Specific standards of acceptance. .
o Specific cited technical data used as a design basis and/or unique design methodology.
o Specific codes, standards, or regulatory requirements.
Descriptions, detailed data and/or parameters resulting from design activities, general codes, and regulations are not generally considered licensing commitments. These include: ,
o Dimensions, o System operational concepts or operational descriptions.
o Design calculation details such as strength parameters, flow rates, etc.
o References to general standards such as 10 CFR 50, American Society of Mechanical Engineers (ASME),
American Concrete Institute, etc. (specific requirements from such bodies, however, are commitments).
0220m/168-8 3-1
v m. .
Implementation An implementing document is a working level document that h imposes the requirements of the commitment to a specific
> activity. Implementation of commitments is typically found in the following:
o Design Criteria, o Material Specifications.
o Construction Specifications, o Pro]ect Reference Manual.
o Field Procedure Manual.
o Drawings.
Additionally, the Project has a commitment to comply with 10 CFR 50 Appendix B, Quality Assurance Criteria, and industry standards such as ANSI /ASME N45.2 and N45.2.ll. Although they may not nave been identified as specific commitments in this module, Readiness Review considered the applicable requirements of these types of commitments in preparing and assessing the scope of work presented by this module.
Commitment descriptions in this section are for identification and are not intended to make further commitments or to revise in lh any way prior commitments.
Differences, if any, between the descriptions in this section and the commitments in the FSAR are unintentional and the commitments in the FSAh take precedence.
O O220m/168-8 3-2 l l
3.2 COMMITMENT AND IMPLEMENTATION MATRICES ,
During the Unit 1 Readiness Review Program, the task force O
t performed a systematic review of li'ensing documents and ,
identified the Project commitments. Once identified, these commitments were listed in a document called the commitmer.t matrix. Readiness Review has maintained the matrix current for design and construction through review of Final Safety Analysis Report (FSAR) amendments and letters to the Nuclear Regulatory Commission. Additionally, during the Unit 1 Readiness Review, the task force identified project controls that implemented the commitment requirements (i.e., design criteria, specifications, construction procedures, etc.) and listed them on a document called the implementation matrix. For Unit 2, the commitment matrix and implementation matrix were transmitted to the appropriate project organizations for updating of the implementation matrix data to reflect the latest implementing documents. Upon completion, the updated matrix was returned to Readiness Review which verified the accuracy, on a sampling basis, as described in section 6.
Each commitment entry in the commitment matrix is identified by a unique reference number. This reference number is also shown ,
for the same committ.nt line entry in the implementation matrix. A single commitment may be addressed by multiple entries in the implementation matrix, either to address separate elements of commitments or to provide space to reference a number of implementing documents. In such instances, the s multiple entries are distinguished by decimal numbers after the commitment reference number.
There have been no changes in commitments for this module since the Unit 1 assessment. ,
The commitment and implementation matrices are presented following'this section. Commitments are current through A1:*ndment 34 of the FSAR.
i I
l 0220m/168-8 3-3
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PLANT V0GTLE UNIT 2 READINESS REVIEW PROGHAM COMMITMENT MATRIX
======s====2:==========: =
REF. COMMITMENT COMMITMENT COMMITMENT DOCUMEST/ MOD DES CON FSAR REMARKS NUMBER SOURCE SECTION SUBJECT FEATURE UtB IGN ST AMEN
===== ========== ==================== ==================== ======*====a======== === :== *== ==== ====a= s-2 ' 'i= c-=
EIPLANATION OF FIELOS BEF. NO. - A reference member that correspeeds to the oppropreete Blas entry le the Implementation metrIn COMMITMENT SOURCE - The decaneet costeleleg the comalteemt IFSAR. Generic Letter. 1.E.
Selletle Response, etc.)
COMMITNENT SECT 80N - Ideettfles the FSAR sectles, letter seeber. or questdos eseber COMMITMENT SUBJECT - The sehject of the FSAR secties or Generic Letter
, DOCUMENT / FEATURE - The decoment discussed le the F$AR sectIce er the pleet festore i described le the FSAR section MODULE - The modele for which the comalteset is leptemented DESIGN / CONSTRUCTION - An X Is pInced under the headleg for the orgenlaattee responsible for leptementatlos of the comalteest FSAR AMENDMENT - FSAR emendoset number for revised comaltments le aere (0) Is placed In thIs celess for changes made prior to Ameadeest 83 istert of Walt i Reedleess ResIsoll MOTE:
Cosetteest changes from these presented In the Unit I module are Identitled by a vertical res of X's se the left mergia, l.
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PL ANT VOGILE UNIT 2 READINESS REVIW PROGRAN COMMITNLNi-MATRIX - HODULE 13B
==========================
REF. CONMITNENT CONNITHENT CONNITNENT DOCUNLNT/ FSAR REMARKS NUMBER SOURCE SECTION SUBJECT FEATURE MODULE DESIGN CONST AMEN
= ========== ==================== ==================== ==================== ====== ====== ===== ==== ==============
le.03.OO FSAR 1. 9. 54 0.A. RLOUIREMENT FOR RG 1.54, REV. O. 138 X X 0 SEE TABLE 6.1.2-1 PROTECTIVE COATINtiS 6/73 FOR CONFORMANCL APPLIED TO WATER-COOLED NUCLFAR PLANT 1604.00 F SAR 1. 9. 54 0.A. REQUIREME N T FOR ANSI NIO1.4 (1972) 13B X X 0 SEE TABLE 6.1.2-1 PROIECT1VE COATINGS FOR CONFORMANCE APPLIED TO WATER-COOLED NUCLEAR PLANT 1317.00 FSAR 6. 1. 2. 1 ORGANIC MATERIALS ANSI N101.2(1972) 138 X O PROTECTIVE COATINGS IN - CONT AINME N T t
1310.00 FSAR 6. 1. 2. 1 ORGANIC HATERIALS RG 1.54, HEV. O. 138 X X 0 SEE TABLE 6.1_2-1 PROTECTIVE COATINGS 6/73 FOR CtW ORMANCE IN CONTAINMENT 4020.00 FSAR O. 3. 1. 1. 3.K STAND 8Y POWER SUPPLY FLOOR OF DIESEL 138 X X O TO MININIZE DUST GENERAlOR BUTLDING COATED WITN EPOXY TO PREVENT CONCRETE ABRASIVE DUST FROM INTERFERING WITN OPERATION OF ELECTRICAL EQUIPMENT 3918.00 FSAR 9. 5. 4. 2 EMERGENCY DIESEL EXTERIOR SURFACES OF 138 X X 0 FOR CORROSION GENERATOR FUEL OIL FUEL OIL STORAGE PROI~ECTItW4 STORAGE AND TRANSFER TANKS COATED WITN SYSTEH CO.AL EPOXY.
PIPING AND TANX SURFACES 3919.00 FSAR 9. 5. 4. 2 EMERGENCY DIESEL INTERIOR SURFACES OF 138 X X O FOR CORROSION GENERATOR FUEL OIL FUCL OIL STORAGE PROTECTION STORAGE AND TRANSFER TANKS PROTECTED BY SYSTEH INORGANIC ZING PIPING AND TANK COATING.
SURF ACES.
P<sge No. 2 05/19/00 PLANT VoGILE UNIT 2 READINESS RE.VIW PROGRAM COMMITMLNT MATRIX - HODULE 138
_:::::::::::::===============_::
Rt F. COMMI T t4EN T COMMITMENT COMMITMENT DOCl#1ENT / FSAR REMARKS NUMBER SOURCE SE CTION SUBJECT fEATUHE MODLR_C DEGIGN CONST AMEN
= ========== ::=:================ ==================== ==================== :::::= ====== ===== ==== ====_=========
4141.00 NRC uuEST. 0430. 20 FUEL OIL STORAGE FUEL OIL STORAGE 138 X X 0 RESPONSE TO QUESTION CORRES. TANK COATING TANKS COATED INSIDE AND OUT. EXTENIOR COATED WITH ONE LAYLR tW COAL TAR EPOXY WITH AVERAGE DRY FILM THICKNESS (F 22 HILS.
G 4 9
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i PLANT VOGTLE UNIT 2 READINESS liEVIEW PHOGRAM IMPIE}tENTATION MATHIX
=========_:=============
DESIGN CONST IfEF. SOUNCE AND DES CON CUHRENT DESIGN CUNHENT CONSTHUCTION NtPEElf SECTION SUBJECT DoctMENT/FEAftHE IGN ST. AS OF: I N LEMENTATION AS OF: IMPLINENTATION MMARKS
'======= ==============: ==================== ==================== === ===.c======= ====+r================ ======== ====================== ==============5===
i L
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I EIPLANATION OF FIELDS I
REF NO. - A reference eunber that corresponds to the appropriate Slee entry I
le the comaltment metriu. '
i SOURCE AND SECTION - The cometteemt source end section to be leptemented j SUBJECT - The s u bj ec t of the comaltment peregraph L
DOCUMENT / FEATURE - The document discussed le the FSAR section or the pleet festere I
- descrlhed le the FSAR section. (See Comalteemt Metrin.)
i DESIGN / CONSTRUCTION - An X la placed ender the heedlag for the orgealtettee respoeslble for Implementatlee ~ of the comelteent !
I f i
DESIGN CURRENT - The date that cometteset leptementetles was vertfled y AS OF:
i
- CONST CURRENT l t
j AS OF ,
4
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j DESIGN - The Project documeetts) that were re.sewow te verify comeltment [
l i IMPLEMENTATION loplementeflos I
CONSTRUCTION IMPLEMENTATION 3
1 j
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e o rh Page No. 1 05/19/94 PLANI V0GTLE UNti 2 READINESS REVIEW PROGRAM IMPLEMENTATION MATRit - MODULE 138 DESIGN CONST REF. SOURCE AND DES CON CURRENT DESIGN CURRENT CONSIROCil0N NUMBER SECIl0N SUBJECT DOCUMENI/TEAIURE IGN St. AS OF: IMPL E ME NT AT ION AS OF: IMPL E MENI AI]ON R[MARIS
- - :::: ::::.:: ::::::: ::: ::::::::: ..:::= :::: ::--:--:::::::: ::: := :::::::: : ::: :: = .:::-- ::: ::.::::: :::: : :::::::::::- :- ::::=-:: :::-- :::
1317.00 FS AR ORGANIC MATERIALS ANSI N101.2(1972) X 07-07-87 DC-1000-A. REV. 1
- 6. 1. 2. I PROTECTIVE C0ATINGS SECT. 10 82-4-05 IN CONIAINMENT 1318.00 F S A R ORGANIC MATERIALS RG 1.54. REV. O. X X 02-03-88 XtAJ07. REV. 27 02-03-88 X1AJ07 REV. 27,
- 6. 1. 2. 1 PROTECTIVE COATINGS 6/73 8-27-87. SECT. 12.3 0-27-87. SECT. 12.3 IN CONTAIMMENT 0C-100C. SECT. 12.3 REV. 3. 9-30-83.
APPENDIX E DC-1000A. REV. 1 12-4-85, dECT. 10 1603.00 F SAR 0.A. REQUIREMENI FOR RG 1.54. REV. O. X X 07-07-87 SEE REMARRS. FOR 05-21-87 SEE DETAIL BELOW SEE REF. 1314 F OR I. 9. 54 PROTECTIVE COATINGS 6/73 CONSI. SPEC. SEE DESIGN.
APPLIED TO DETAlt BELOW CONSTRUCTI0d WATER-COOLED NUCLEAR APPLICABLE 10 PLANT NON-NSSS COMPCNENIS ONLY 1603.01 FSAR 0.A. REQUIREMENT FOR RG 1.54 REY. O. X Y 02-03-88 X1 AJ07, REV. 27 02-03-88 X1AJ07. REY. 27 COATING MATERIALS
- 1. 9. 54 PROTECTIVE C0AIINGS 6/73 8-27-87. SECT'S. 8-27-87. SE CT 'S. FOR ITEMS WIIHIN APPLIED 10 12.1.1.A. 12.2.8 4 12.1.1.A. 12.2.8. & CONTAINMENT SHALL WATER-COOLED NUCLEAR 12.8 12.8 MEEI REQUIREMENTS PLANI 0F ANSI N10) 2 WHENEVER POSSIBLE 1603.02 FSAR 0.A. REQUIREMENT F OR RG 1.54. REV. O. X X 02-03-88 XtAJ07. REV. 27 02-03-88 XIAJ07. REY. 27 COATING MATERIALS
- 1. 9. 54 PROTECilVE COAi!NGS 6/73 8-27-8 7. SECI'S. 8-27-87. SECT'S. FOR IIEMS WITHIN APPLIED 10 12.1.1.A. 12.2.8. 5 12.1.1.A. 12.2.8. & CONIAINMENT SHALL WATE R-COOLED NUCLE AR 12.8 12.0 MEET SELECIED PLANI REQUIREMENTS OF ANSI N5.12 WHENEVER POSSIBLE 1603.03 FSAR 0.A. REQUIREMENT FOR RG 1.54. REV. O. X X 02-03-88 alAJ07. REY. 27 02-03-88 XIAJ07. REV. 27 C0ATING MATERIALS
- 1. 9. 54 PRoiECTIVE COAllNGS 6/73 8-27-87. SECT. 12.1.1 6-27-87. SECT. 12.1.1 FOR IIEMS WITHIN APPLIED TO CONTAINMENT ARE WATER-COOLED NUCLEAR DOCUMENIED IN PLANT ACCORDANCE WIIN ANSI N101.4
Page Co. 2 05/19/83 PLANI V0 GILE UNIT 2 READINESS RFVIEW FROGRAM IMPLEMENT ATION MAIRif - MODULE 138 DESIGN CONST REF. SOURCE AND DES CON CURRENT DE S IGN CURRENT CONSTRUCTION NUMBE R SECTION SUOJECT DOCUNFNT/FEAIURE IGN SI. AS OF- IMPLEMENTATION AS OF: IMPLEMENTATION REMARES
- :: : : : :::::.:::: = .::::::::::::: ::: : ::::::::-- : ::::: ::: ::: ::::::: -- :-- ::-- ::::::::: : ...:: ------ : ::::: : :- :: :::::: :- :..=- ::
1603.04 FSAR 0.4. REQUIREME NI FOR RG 1.54 REV. O, X X 02-11-88 X1AJ07. REV. 27 02-11-88 XIAJ07, REV. 27 SSPC - 1963. 1971
- 1. 9 54 PROTECTIVE COATINGS 6/73 8-27 87 SECTS. 12.3 & 8-27-87. SECTS. I?.3 & ANSI N101.2-1972 APPLIED TO 2.0 2.0 ANSI N5.12-1974 WATIR-COOLED NUCLEAR PLANT 1603.05 FSAn 0.A. REQUIREMENT FOR RG 1.54. REY. O. X X 02-03-88 XIAJ07. REY. 27 02-03-88 X1AJ07. REV. 27 FORMS SIMILAR 10
- 1. 9. 54 PROIECTIVE COATINGS 6/73 8-2 7-8 7. SEC T . 12.7 8-27-87. SECT. 12.7 ANST N101.4 APPLIED TO WATER-COOLED NUCLEAR PLANI 1603.06 F SAR 0.A. REQUIREMENT FOR RG 1.54. REV. O. X X 02-03-80 XI AJ07. REV. 27 02-03-88 XIAJ07. REV. 27 STSTEMS PREQUAL. .
- 1. 9. 54 PAGIECTIVE COATINGS '6/73 8-27-87. SECT. 12 6-27-87 SECT. 12 TO ANSI NI0t.2 APPLIE D TO WATER-COOLED NUCLEAR PLANT 1603.07 F S AR 0.A. REQUIREMENT FOR RG l.54 REV. D. X X 02-03-88 XIAJ07. REV. 27 02-03-88 X t AJ07, RE V. 27 SURFACE I. 9. 54 PROTECTIVE COATINGS 6/73 8-27-87 SCHEDULE A 8-27-87. SCHEDULE A PREPARATION APPLIED TO ILLUSYRATES WATER-COOLED NUCLEAR PROCEDURE USED FOR PLANT TESTING 1603.Gd F SAR 0.A. REQUIREMENT FOR RG !.54. REV. O. X X 02-03-88 XIAJ07. REV. 27 02-03-88 X1AJ07. REY. 27 SURFACE PROFILE
- 1. 9. 54 PROTECTIVE COATINGS 6/73 8-27-8 7, SCHE DULE A 8-27-87 SCHEDULE A REQUIREMENTS ARE APPLIED TO MET WATER-COOLED NUCLEAR PLANT 1603.09 F SAR 0.A. REQUIREMENT FOR RG 1.54. REV. O. X X 02-03-88 XIAJ07. REV. 27 02-03-88 XIAJ07. REY. 27 APPLICATION PER I. 9. 54 PROTECTIVE COAllNGS 6/73 8-27-87. SECTS. 3.0 8 8-27-87. SECI's. 3.0 L MANUFACIURER'S APPLIED TO 12.5 12.5 PROCEDURES WATER-COOLED NUCLEAR PLANI 1603.10 FSAR 0.A. REQUIREMENI FOR RG 1.54. REV. O, X X 02-03-88 X1 AJ07. REV. 27 02-03-88 X'AJ07. REV. 27 INSPECTIONS AND
- 1. 9. 54 PROTECTIVE COAi!NGS 6/73 8-27-87. SECf'S. 5.0 8 8-;7-87. SEci's. 5.0 & NON-DESTRUCTIVE APPLIED 10 12.6 12.6 TFSIS ARE WATER-COOLID NUCLEAR PERFORMED PLANI O O O
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- Re. 3 j 05/19/C3 PL ANI V0 GILE UNif 2 READINESS REVIf W P90GRAN IMPLEMENTAi!ON MAIRIX - N0Dulf 138 DESIGN CONSI REF SOURCE AND DES COM CURRENT DESIGN CURRENT CONSTRUCTION i
'KUMBER SECTION SUBJECT DOCUMENT / FEATURE IGN ST. AS OF: IMPLEMENIAIION AS Of: IMPL E ME NT A T ION REMARES .!
.:ss::= :::::: :::::::= ::::::::::::::::::.: :: ::::::::::::::::: === ::: :::::::: ::::::::::::: :::::::: :::::::: :::::::::::::::::::= ::::: ::-:::::::::
-L 1603.11 FSAR 0.A. REQUIREMENT FOR RG 1.54. REY. O, X X 02-03-88 X1AJ07. REV. 27 02-03-88 XIAJ07. REV. 27 NONCONFORMANCES
- l. 9. 54 PROIECTIVE C0ATINGS 6/73 8-27-87. SECT. 12.1.1 6-27-87, SECT. 12.I.I ARE IDENIIF IED AND
.f APPLIED [0 EVALUATED ;
WAIER-COOLED NUCLEAR j PLANT j 1603.12 FSAR 0. A. REQUIREMENT FDR RG !.54 REY. O. X X 02-22-88 X1AJ07. REV. 27, 02-22-88 XIAJ07. REV. 27 CERI 0F COMPL. AND I. 9. 54 PROTECTIVE C0ATINGS 6/73 8-27-87. SECTS 12.1.1 0-27-87 SECIS 12.1.1 OR DOCUM.
APPLIED TO & 12.7 & 12.7 PROCEDURES ARE WATER-COOLED MUCLEAR FURNISHED PLANI ,
i 1603.13 FSAR 0.A. REQUIREMENI FOR RG I.54. REV. O, X X 02-03-88 XIAJ07. REV. 27, 02-03-88 XIAJ07. REV. 27 LIMITS ON HALOGENS I
- 1. 9. 54 PR0lECTIVE COATINGS 6/13 8-27-87, SECI. 12.2.C 8-27-8 7. SEC T . 12.2.C IN CLEANERS & l APPLIED TO SOLVENTS {
WATER-COOLED NUCLEAR l PLANI i 1604.00 FSAR 0. A. REQUIREMENT FOR ANSI N101.4 (1972) X X 07'-07-87 DC-1000-A. REY. 1 02-03-88 X1AJ07. REY. 27, ,
- 1. 9. 54 PROTECTIVE COATINGS' SECT. 10, 12-4-05 0-27-87, SECT'S. 12.1 i APPLIED TO 12.2, 12.3 L 12.7 WAIER-COOLED NUCLEAR PLANT 3918.00 ISAR EMERGENCY DIESEL EXIERIOR SURFACES OF X X 07-07-87 X4 AH03 REV. 9. SECT. 05-21-87 X4AH03 REV. 9, i
- 9. 5. 4 2 GENERATING FUEL OIL FUEL OIL STORAGE 4.4.1. 4-29-86 4-29-86. SECT. 4.4.1 SIGRAGE AND TRANSFER TANES C0ATED WIIH I SYSTEN C0AL EP0XT y i
3919.00 FSAR EMERGENCY DIESEL INTERIOR SURFACES OF X X 07-07-87 X4AH03, REV. 9. SECT. 05-21-87 X4AH03, REY. 9 !
- 9. 5. 4. 2 GENERATING FUEL Olt FUEL OIL STORAGE 4.4.2, 4-29-86 4-29-86 SECT. 4.4.2 !
STORAGE AND TRANSFER TANT 3 PROTECTED BY SYSTEN INORGANIC ZINC !
COATING ,
i 4141.00 NRC QUEST. FUEL OIL STORAGE FUEL Olt STORAGE X X 07-07-87 X4 AH03. REV. 9. SECT. 05-21-87 X4AH03, REV. 9 CORRES. IANt COATING IANES C0ATED INSIDE 4.4.1, 4-29-86 4-29-86, SECT. 4.4.1 0430. 20 AND CUT. EXTERIOR !
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l 4 PROGRAM DESCRIPTION 4.1 DESIGN This section provides a description of the work flow, documentation, and design control activities for protective coatings for permanent plant items. The emphasis is on coating materials and approved coatings systems for areas and equipment inside the containment building.
The civil discipline of Design Engineering (DE) is responsible for the coatings program implemented at the VEGP project. This program was implemented through architectural and civil design criteria, various procurement specifications for equipment, architectural finish schedule drawings, and the construction specification for field coating application.
4.1.1 COATING SERVICE AREAS Coating service areas are specitied on the basis of expected environmental exposures depending upon the location in the plant. The expected service areas have been reduced to three basic designations as follows:
A. Areas within the containment building are identified as N-areas. Items to be located inside the containment O building require N-coatings.
B. Areas outside the containment but where potential contamination from radioactive sources exists are identified as D-areas. D-coatings can be the same as N-coatings except that the QA program and quality documentation requirements are not required.
C. Areas other than N- and D-areas are identified as C-areas. C-area coatings can be suppliers' comn.ercial standard providing the coating will withstand exposure to the anticipated service environment and storage during construction. C-area specifications provide material performance standards.
4.1.2 COATING SYSTEMS The architectural group from DE, with the assistance of the Materials and Quality Services (M&QS) group of Bechtel, has ,
selected coating systems to meet the requirements of the service areas, the surface to be coated, and the architectural and special service conditions as applicable.
O 0222m/172-8 4-1
4.1.2.1 Design Basis Accident Tests Coating systems specified for use on items located inside h containment were tested in accordance with the requirements of ANSI N101.2 and selected. portions of ANSI N5.12. The tests were originally conducted in Oak Ridge National Laboratories. The test data and results were reviewed by M&QS group of Bechtel, San Francisco, and Oak Ridge Laboratory for acceptance and approval for application inside containment. The architectural group has final approval of the coatings to be applied. The documents containing original test data and results of approved coatings systems are retained by the M&QS group.
4.1.2.2 Field Coatina Systems -
Field coating systems applied and utilized in the field at the VEGP jobsite are listed in schedule A of Field Coatings Specification X1AJ07, which includes the types of coatings, manufacturer of acceptable coatings, product identification, surface preparation, number of coats, dry mill thickness to be applied, and inspection requirements. The coating systems acceptable for use on items located inside the containment building are prequalified. Four primary prequalified systems are specified:
o Inorganic zinc-rich coating with no finish coat.
o Inorganic zinc-rich coating with epoxy top coat. 9 o Clear epoxy sealer for concrete.
o Two coat epoxy coating for concrete.
In addition, other prequalified systems for touchup or repair of the primary coating system are specified.
4.1.2.3 Shop Coatinos The coatings provisions for items purchased from suppliers and equipment manufacturers are contained in the purchase specifications. For items located inside the containment building, the purchase specification specifies use of prequalified coatings. Use of coatings of equal quality is permitted. In such cases, the supplier of this item is required to submit DBA test data per Regulatory Guide (RG) 1.54 and ANSI N101.2 for evaluation by Project Engineering. After consultative approval by M&QS, the architectural group approves such coating if it is found to be acceptable.
O O222m/172-8 4-2
4.1.2.4 Unqualified Coatings Unqualified coatings are coatings applied without documentation, O. coatings where the surface preparation, material, or application deviate from those qualified by DBA test, or coatings that have not been prequalified. The use of these coatings in containment is limited to small coating repairs, small production line items where special painting requirements are impracticable, surfaces to be insulated, surfaces contained within a cabinet or enclosure, and concrete sealer.
4.1.3 DESIGN DOCUMENTS The design documents produced relative to coatings include: -
1 o Specifications: '
- Construction (field coating).
- Material (procurement).
c Drawings;
- Finish schedules.
- Finish and door schedule details.
The procedures for control, issue, and revision of design documents are described in project procedures for each type of design document including design change documents. l 4.1.3.1 Specification Development l The specifications relative to coatings consist of the Field Coatings Specification X1AJ07, and purchase specifications for permanent plant items (structures, components, and equipment).
The architectural group has the overall responsibility for the I field coatings specification and for coatings requirements in i purchase specifications.
When the specifications were prepared each responsible engineer (RE) coordinated the selection of appropriate coating
]
requirements with the architect. The coating requirements were '
incorporated into the body of the technical provisions of the l specification.
The architect reviewed the specification for compliance to the coating requirements when it was issued on a Design Review Notice. The draft of the specification was forwarded to the M&QS organization for review and comment. The M&QS reviewer i
1 0222m/172-8 4-3
forwarded his review comments to the architect, who forwarded comments to the RE for necessary action. l l
l 4.1.3.2 Material Purchase Specifications )
Material purchase specifications are written and controlled by applicable DE disciplines. The purchase specifications include coating requirements and specify Regulatory Guide 1.54, ANSI N101.4, and ANSI N101.2 requirements for items within containment, consistent with the FSAR commitments.
4.1.3.3 Field Coating Specification Field Coatings Specification X1AJ07, written and controlled by the architectural group, describes coating requirements for the field finish of shop-primed ferrous metal surfaces, uncoated shop- or field- fabricated items, repair of coatings, concrete surfaces, and architectural paint finishes. Coating material is purchased from qualified suppliers by GPC Construction, based upon the requirements in the specification.
4.1.3.4 Drawings The VEGP plant coating requirements are shown on architectural design drawing finish schedules. The finish schedule shows finish coating systems'by room numbers (space numbers), by lh levels of building, and by material to be coated.
These drawings are developed and controlled by the architectural group. The architectural group coordinates the color scheme and coating requirements with GPC.
4.1.4 SHOP COATING PROGRAM Prior to starting any coating work, each supplier of shop-coated items is required to submit its coating procedures for review and acceptance by Engineering. The VEGP architect and M&QS review the procedures to ensure compliance with the specification requirements. Copies of supplier coating procedures, approved and accepted by Project Engineering, are retained in the M&QS files and the project files. Accepted (approved) procedures are returned to the supplier for use.
4.1.5 QUALITY REQUIREMENTS Quality assurance and documentation requirements are in accordance with ANSI N45.2-71 and ANSI N101.4 for both coating O
l 0222m/172-8 4-4
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materials and the application procedures. The quality assurance requirements are applicable to both the shop-coated items and to
~N coatings applied in the field under GPC direction.
(O RG 1.54 is implemented by requirements as follows:
o Use of specific coating systems prequalified to ANSI N101.2.
o Surface preparation standards.
o Surface profile requirements. ;
o Application of the coating systems in accordance with the paint manufacturer's instructions.
o Inspections and nondestructive examinations, o Identification of all nonconformances. Coatings which do not conform with Regulatory Guide 1.54 are limited in use and are evaluated on a case-by-case basis for impact and acceptance.
o Certifications of compliance and/or documentation procedures to satisfy project requirements.
9 An inventory of unqualified coatings is maintained to ensure appropriate control of coatings inside O containment.
4.1. 6 WESTINGHOUSE COATING PROGRAM The nuclear steam supply system (NSSS) is coated in accordance with the Westinghouse coating program approved by the Nuclear Regulatory Commission.
Westinghouse has developed an alternate approach to' ANSI N101.4 i for satisfying Regulatory Guide 1.54 for the NSSS components !
I inside containment. Requirements are specified for the painting of major components in Westinghouse Process Specifications, l which are imposed on vendors by procurement documents. Large l equipment must have coating systems qualified to meet ANSI N101.2: and requirements are defined for surface preparation, use of undercoating, and inspection.
O i 0222m/172-8 4-5 !
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4.2 CONSTRUCTION gg This section contains a brief description of coating and by inspection activities, a flowchart, and a list of codes and standards applicable to receipt, storage, application, and inspection activities.
Coatings material is purchased, received, and receipt inspected by Georgia Power Company (GPC). Upon receipt the material is issued to the contractor, Williams Power Services, Inc.
(Williams) for storage. Material with GPC hold tags is segregated in the Williams warehouse and withheld from use until the discrepancies are resolved and GPC Quality Control (QC) removes the hold tags.
Material released by GPC is stored in and released for use from the Williams warehouse. Storage and issuance of material and verification of warehouse conditions by Williams QC is controlled by Williams quality program procedures.
Williams prepares substrate surfaces mixes and applies the coatings. Testing of environmental conditions, verification of proper coating material, mixing and application, and inspection of substrate preparation and applied coatings are performed by Williams QC. Inspection and application activities are controlled by Wil.liams procedures.
r^g The flowchart (Figure 4-1) illustrates the contractors' work
() activity as well as the inspection activities required to support, inspect, and document these work processes. Each organization listed in the left hand margin of the flowchart is responsible for the activities shown to the right of it. The nodes (circles) denote the starting and completion points of work activities. Between the nodes are descriptions of the work activities performed and the applicable procedure governing that work activity. The dotted linec with directional arrows indicate the flow of documentation or instructions for an activity. The flowcharts do not contain the flow of documents such as Deviation Reports or Field Change Requests, as they may be generated at any time.
Receipt, storage, application, and inspection of coatings are performed following the applicable GPC or Williams procedures.
Williams procedures are reviewed and approved by GPC. In addition, the work is governed by Specification X1AJ07, Field Coatings. Principal codes and standards referenced in the specification are:
o ANSI N101.2, Protective Coatings (paints) for Light Water Nuclear Reactor Containment Facilities (material qualification only).
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(
O222m/172-8 4-7
o ANSI N101.4, Quality Assurance for Protective Coatings applied to Nuclear Facilities.
o ANSI N5.12, Protective Coatings (paints) for the Nuclear Industry (material qualification only) 6 l
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l 5 AUDITS AND INSPECTIONS 5.1 . INTRODUCTION Module section 5 contains a brief discussion of Quality Assurance audits, Nuclear Regulatory Commission inspections, and Project reportability evaluations performed in the area of coatings. In addition, a description of special evaluations and j a discussion of the project evaluation of Unit 1 finding l followup are included. The findings, violations and evaluations j applicable to coatings were reviewed by the Readiness Review Team and factored into the assessments presented in section 6 of this module. Audits and findings, inspections and violations, i reportability evaluations, and the Unit 1 finding followup l results are listed at the end of this section. !
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I 5.2 PROJECT AUDITS Project Quality Assurance (QA), consisting of Georgia Power O' Company (GPC) QA and Bechtel Western Power Compa.ny (BWPC) QA, conducts regularly scheduled audits to verify compliance to project requirements. Any finding from an audit is reported to the management of the audited organization for corrective action. Table 5-1 at the end of this section includes the-audits conducted and findings issued since the effective date of the Unit 1 module, July 1, 1985.
5.2.1 GEORGIA POWER COMPANY AUDITS AND FINDINGS GPC QA conducted 4 audits within the scope of this module.
These audits resulted in 14 findings, which identified a failure to follow procedures and identified discrepancies in documentation requirements, in procedure preparation, and in material storage.
For each finding, the extent and significance of the discrepancy was identified and corrective action was taken to resolve the deficiency.
l 5.2.2 BECHTEL WESTERN POWER CORPORATION AUDITS AND FINDINGS l O-s BWPC QA audits are generally performed in design functional.
areas such as drawings, calculations, and Field Change Requests and are applied to all disciplines, rather than a specific discipline or hardware category. Therefore, it is impractical i to assign audits to a specific module; however findings were I categorized by module. Two findings were within the scope of this module. One identified a failure to meet committed dates ,
for completion of Unit 1 Readiness Review corrective actions.
The finding was resolved by completion of the committed I corrective action. The second finding documents contlicting '
references to the steel structures painting council standards.
Final Safety Analysis Report, Table 6.1.2-1, was revised to resolve this finding. l 1
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~5.3 NUCLEAR REGULATORY COMMISSION IN9PECTIONS Readiness Review identified six Nuclear Regulatory Commission inspections within the scope of this module (listed on Table 5-2). No deviations or violations were identified as a result of these inspections.
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5.4 REPORTABLE DEFICIENCIES AND SPECIAL EVALUATIONS ,
Reportable Deficiencies '
Within the scope of this module no deficiencies have been reported to the Nuclear Regulatory Commission (NRC) and no Deficiency Evaluation Reports have been issued since the completion of the Unit 1 module.
Special Evaluations Diesel Fuel Oil Storage Tank Coating Georgia Power Company conducted a review of the effect of the inorganic zine lining of the diesel fuel oil storage tank on the operability and reliability of the diesel generators. This review was in response to Unit 1 Licensing Condition 2.c(8), ;
which expressed the concern of the NRC that the reaction ,
products of the acidic impurities 'n diesel fuel oil with the l zine lining might cause plugging or lines and fuel injectors. l A report on the technical issues reviewed addressed the beneficial effect of the corrosion-resisting properties of inorganic zinc on tank life and industry experience with the combustion-improving properties of zinc naphthenates, the principal soluble reaction product. The report also discussed the use of duplex fuel oil line filters to remove corrosion '
/'T products or degradation products which could plug the fuel line
(_/ and surveillance procedures to check the quality of the fuel oil, to monitor the differential pressure a.zoss the fuel oil ,
line filter, and to inspect the diesel generator fuel injectors
- for zinc deposits.
1 The report concluded that it is acceptable to store diesel fuel '
in zinc-lined tanks with proper attention to fuel quality. It was submitted to the NRC as justification that the zine coating ,
would not affect the operability and reliability of the diesel I generators, l 1
)
The NRC evaluated the report and additional technical i information, concluded that the justification was acceptable, j and resolved the licensing condition, (NRC letter dated '
October 15, 1987).
Cracking of Concrete Floor Coatino Small areas of concrete floor coating in the Unit 1 containment have cracked and disbonded from the floor. The estimated total area of failure is about 300 square feet, located in the stairwells and random locarions in other floor areas.
Bechtel Engineering was requested to review the coating specification and application procedures to determine if changes O, should be made to preclude future cracking.
0223m/172-8 5-7
The review included observation of damaged coatings in both Unit 1 and Unit 2 and discussions with the coating manufacturer and construction personnel. lh The most probable cause was identified as a high film thickness in local areas coupled with mechanical damage to the coating.
Project Engineering recommendations included measures to minimize total film thickness of the coating system and a monitoring program to facilitate identification and repair of any local areas which may crack in the future. (Letter BG 36148 dated April 18, 1988).
Project Construction has had further discussions with '
Engineering and with the coating manufacturer to identify
- specific application techniques to effectively implement the engineering recommendations. Actions taken will include training of applicators and revision to application procedures, as necessary. A formal response to the engineering recommendations will be issued by July 14, 1988.
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0223m/172-8 5-8 l l
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5.5 UNIT 1 FINDING FOLLOWUP Unit 1 finding followup consisted of identification of all
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\_ findings and corrective actions for findings as a result of
, Unit 1 Readiness Review or Nuclear Regulatory Commission evaluation of the Unit 1 modules. For Unit 2, a list of those findings was compiled and transmitted to the responsible project organizations for verification that corrective action taken continued into Unit 2. The Project evaluated each finding to determine the following:
o If the finding was an isolated occurrence in Unit 1 and did not require Unit 2 action (or applicable to Unit 1 only).
o If corrective action taken for Unit 1 remains in place and acceptable.
o If corrective action in place for Unit 2.has changed from that specified in the Unit 1 module.
o If corrective action taken for Unit 1 has not been entirely effective in Unit 2 and therefore is modified.
For each finding that the Project determined was applicable to Unit 2, a response wa9 returned to Readiness Review that stated which documents identified the corrective action required, any changes to committed actions, and action taken if corrective O. action was not effective. The listing at the end of this section (Table 5-3) presents the findings, the type of action taken for Unit 2, and explanations if corrective action was changed or not entirely effective. The findings were included in the assessment discussed in section 6 to provide-independent Readiness Review verification of the project evaluation results.
Sixteen findings were i'dentified for Unit 1 applicable to Module 13B. The Project Design and Construction evaluation of these findings concluded that 11 of the 16 were applicable to Unit 2 and for 9 of the 16 the Unit 1 corrective action had been applied to Unit 2. The Readiness Review assessment identified two findings where the corrective action was not entirely effective:
RRF 13B-007 Revision to Williams Warehouse Procedure WW-I-01, in response to Finding RRF-13B-007, established the Warehousing Records as l quality documents, meeting requirements of ANSI N101.4. I Subsequently this procedure was revised and the Warehousing Records document requirements were omitted, although the '
Warehousing Records were maintained as a nonquality document.
Unit 2 Finding 2RRF-13B-003 was issued (section 6 contains a discussion).
O 0223m/172-8 5-9
RRF 13B-021 Unit 1 Finding RRF-13B-021 identified discrepancies in FCR processing, including improperly designating generic-type changes as not to be incorporated in the specification. The Unit 2 assessment identified similar discrepancies. Unit 2 Finding 2RRF-13B-002 was issued (section 6 contains a discussion).
t 0
0223m/172-8 5-10
PsE o. 1 06/16/88 PLANT VOGTLE UNIT 2 READINESS REVIEW PROGRAM QUALITY ASSURANCE AUDITS TABLE 5-1
===============================
EDIT AUDIT FINDING NO SOURCE NUMBER NUMBER DATE SUBJECT REMARKS
============= ============= ============= ======== ======================= ===================== ==================
22 BPC CAR RRF-H-07-86 03/04/86 RR FINDING 135-12 SPECIFICATIONS h0T REVISED BY DATE COMMITTED
-RR FINDING 138-20 SPECIFICATION NOT REVISED BY DATE COMMITTED 73 BPC CAR VS-86-181 03/05/86 DBA TESTING DONE TO SSPC-1971 WHERE FSAR STATES }963 1192 GPC CP01-87/60
- 12/21/87 QA AUDIT OF THE ADEQUACY OF COATING ACTIVITIES AS DEVELOPED AND IMPLEMENTED BY WILLIAMS POWER SERVICES. INC.
1263 GPC CP01/CP14-85/ 11/27/85 QA ASSESSMENT AUDIT OF WILLIAMS CONTRACTING.
56 INC 204 GPC CP01/CP14-86/ 10/31/86 ADEQUACY OF WILLIAMS POWER SERVICES' QA 28 PROGRAM FOR COATINGS ACTIVITIES AS PER 7 FUNCTIONAL-AREAS COVERING 18 CRITERIA 0F 10CFR50 APPENDIX B ,
259 GPC CP14-86/27 05/30/86 WILLIAMS POWER SERVICES' QA PROGRAM FOR SERVICE LEVEL 1 COATINGS ON CONCRETE AND STEEL 354 GPC AFR 0868 11/27/85 WILLIAMS DOCUMENT CONTROL PR'CEDURES NOT CP01/CP14-85/56 ADEQUATELT IMPLEMENTED 355 GPC AFR 0869 11/27/85 FAILURE TO ADEQUATELY DEVELOP SEVERAL CP01/CP14-85/58 REQUIREMENTS OF ANSI N45.2-1977 IN THE QA PROGRAM ,
8 .
356 GPC AFR 0870 11/27/85 WILLIAMS NON-CONFORMANCE PROCEDURE DOES NOT CP01/CP14-85/56 DEFINE " CORRECTABLE DEVIATIONS" 357 GPC AFR 0871 11/27/85 FAILURE TO DEVELOP AND CONDUCT A CP01/CP14-85/56 COMPRERENSIVE SYSTEM OF AUDITS 358 GPC AFR 0872 11/27/85 WEAENESSES IN DOCUMENTING AND UTILIZING THE CP01/CP14-85/56 EFFECTIVE CERTIFICATION OF QUALIFIED COATINGS APPLICATORS 359 GPC AFR 0873 11/27/85 APPLICATION PROCEDURES NOT CLEAR. NOT CP01/CP14-85/56 DEFINATIVE l
-1
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O Pass No. .2 O . O 06/16/88 PLANT V0GTLE UNIT 2 READINESS REVIEW PROGRAM QUALITT ASSURANCE AUDITS -
TABLE 5-1
===============================
EDIT AUDIT FINDING NO SOURCE NUMBER NUMBER DATE SUBJECT REMARKS
============= ============= ============= ======== ============================================= ==================
360 GPC AFR 0874 11/27/85 QC PROCEDURES 84CK' DETAIL AND CONTINUITT CP01/CP14-85/56 361 GPC AFR 0875 ll/27/85. SPECIFICATION 6dfIATES FROM FSAR COMMITMENT CP01/CP14-85/56 ;
TO ANSI N101.4 362 GPC AFR 0876 11/25/85 SIGNERS NAMES MISSING FROM WILLIAMS' CP01/CP14-85/56 DOCUMENTS 363 GPC AFR 0877 11/27/85 THINNERS USED WITH "N" COATING STSTEMS NOT CP01/CP14-85/56 SEGREGATED IN A DESIGNATED ARTA IN WAREHOUSE 471 GPC AFB 0983 10/31/86 INADEQUATE CONTROL OF FCR's/DCN's BT WILLIAMS CP01/CP14-86/28 POWER SERVICES 472 GPC AFR 0984 10/31/86 WILLIAMS QA MANUAL REQUIRES VERIF. OF CP01/CP14-86/28 !
MATERIAL CERTS, VERIF. IS BT GPC 474 GPC AFR 0985 10/31/86 FAILURE TO MAINTAIM STORAGE OF A NON "N" CP01/CP14-86/28 COATING MATERIAL WITHIN THE TEMPERATURE i REQUIREMENTS SPECIFIED BT THE MANUFACTURER l
L
m Pete Co. 1 06/15/88 PLANT VOGTLE UNIT 2 READINESS REVIEW PROGRAM NRC INSPECTIONS TABLE 5-2
===============================
EDIT INSPECTION VIOLATION NO SOURCE NUMBER NUMBER DATE SUBJECT REMARES
============= ============= ============= ======== ============================================= =======================
623 NRC 424/86-026 10/17/86 REVIEW OF READINESS REVIEW MODULE 138 632 NEJ 424/86-036, 08/08/86 INSPECTION OF EMPLOYER CONCERNS REGARDING 425/86-016 COATINGS 1134 NRC 424/87-025, 04/13/87 INSPECTION OF POST-TENSIONING AND EMPLOYEE 425/87-017 CONCERNS IN CONCRETE AND COATINGS ,
1143 NRC 424/87-040, 07/09/87 INSPECTION OF STRUCTURAL CONCRETE, 425/87-028 FOUNDATIONS, COATINGS, STRUCTURAL STERL AND PENETRATION SEALS 1156 NRC 424/87-059, 11/13/87 INSPECTION OF REPAIRS TO COATINGS IN THE UNIT 425/87-044 2 CONTAINMENT BUILDING
-I 1159 NRC 424/87-065, 12/04/87 INSPECTION OF CONTAINMENT 1 TENDON 425/87-046 SURVEILLANCE. BACEFILL OPERATIONS, COATINGS c REPAIR ON UNIT 2 CONTAINMENT DOME LINER PLATE AND TENDON RAM CALIBRATION RECORDS e
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O O O Page No. 1 06/15/88 PLANT V0GTLE UNIT 2 READINESS REVIEW PROGRAM FOLLOW-UP OF UNIT 1 FINDINGS (RR.IDR.NRC)
TABLE 5-3
================================================
EDIT SOURCE AND DESCRIPTION OF DESCRIPTION OF UNIT 1 DESCRIPTION OF UNIT 2 NO FINDING DESIGN CONST LEVEL FINDING CORRECTIVE ACTION FOLLOW-UP ACTION
=============== ====== ====== ===== ============================== ============================== ==========================
l 483 REF X II NO CERTIF. THAT MATERIAL MBETS REVISE SPECIFICATION CORRECTIVE ACTION REMAINS 138-001 VEGP TEMP / PRESSURE CURVE IDENTICAL AND ACCEPTABLE 484 RRF X III INSP. REPORTS DO NOT DOCUMENT INSPECTION PRACTICE CHANGED TO ISOLATED INSTANCE /0NE TIME 138-002 SURFACE PROFILE TO GPC-SPIS SPECIFICALLT DOCUMENT GPC-SPIS CORRECTIVE ACTION SURFACE PROFILE ACCEPTANCE 485 RRF I III ENTRY ERRORS IN INSPECTION ENTRIES CORRECTED ISOLATED INSTANCE /0NE TIME 13B-003 DOCUMENTS CORRECTIVE ACTION 486 RRF I II THINNER USED OUTSIDE TEMP. DR - USE-AS-IS, PROCEDURP CORRECTIVE ACTION REMAINS 13B-094 RANGE REVISED IDENTICAL AND ACCEPTABLE 487 RRF I II EP0XT THINNED MORE THAN DR - USE-AS-I
S. PROCEDURE
& CORRECTIVE ACTION REMAINS 135-005 ALLOWED BT SPEC. & PROCEDURE SPEC REVISED IDENTICAL AND ACCEPTABLE ,
488 RRF E II FSAR COMMITMENTS TO RG 1.54 SPEC. REVISED CORRECTIVE ACTION REMAINS 138-006 AND ANSI N101.4 NOT COMPLETELT .
IDENTICAL AND ACCEPTABLE IMPLEMENTD IN SPEC.
489 RRF I II COATING PROCEDURES DO NOT MEET
- SPECIFICATION & .'ROCEDURE CORRECTIVE ACTION NOT ENTIRELT 135-007 ALL SPECIFICATIONS AND ANSI REVISED EFFECTIVE REQUIREMENTS SEE SECTION 5.5 490 RRF K III COATINGS AS APPLIED DO NOT DR - REPAIR /REWORE, USE-AS-IS ISOLATED INSTANCE /0NE TIME 138-010-1 MBET ACCEPTANCE CRITERIA (HIGH MILLAGE) CORRECTIVE ACTION 491 RRF I III COATINGS AS APPLIED DO NOT REVISE PROCEDURE, PR - CORRECTIVE ACTION REMAINS 138-010-2 MEET PROCEDURE ACCEPTANCE USB-AS-IS IDENTICAL AND ACCEPTABLE CRITERIA 478 IDH I II CONFLICTING REQ'MTS FOR SPEC. REVISED TO CORRECTIVE ACTION REMAINS 13B-011 AMBIENT CONDITIONS IN SPEC. CLARIFT/ CORRECT PROCEDURES IDENTICAL AND ACCEPTABLE FOLLOWED INTENT OF SPEC. NO DEFICIENCY IN COATING 479 IDR X III SPEC. bOES NOT CALL OUT SPEC. REVISED, WORE TO DATE CORRECTIVE ACTION REMAINS 135-013 REVISION OF SSPC STANDARDS TO HAS FOLLOWED THE SAME REVISION IDENTICAL AND ACCEPTABLE
, BE USED USED FOR QUALIFICATION
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Page No. 2 06/I5/88 PLANT V0GTLE UNIT 2 READINESS REVIEW PROGRAM FOLLOW-UP OF UNIT 1 FINDINGS (RR.IDR.NRC)
TABLE 5-3
=========================e======================
EDIT SOURCE AND DESCRIPTION OF- DESCRIPTION OF UNIT 1 DESCRIPTION OF UNIT 2 NO FINDING DESIGN CONST LEVEL FINDING CORRECTIVE ACTION FOLLOW-UP ACTION
=============== ====== ====== ===== ============================== ===========2================== ==========================
480 IDR X II DEFICIENCIES IN QUALITT PROCEDURES REVISED, WORK WAS CORRECTIVE ACTION REMAINS 13B-014 CONTROL PROCEDURES CORRECT IDENTICAL AND ACCEPTABLE 481 IDR I III UNQUALIFIED COATING SYSTEMS SPEC. IS MISLEADING, UNQUAL, CORRECTIVE ACTION REMAINS 138-015 ARE SPECIFIED STSTEMS WERE NOT INTENDED AND IDENTICAL AND ACCEPTABLE NOT USED. SPEC. REVISED 482 IDR X II SEE RRF 135-922 SEE RRF 13B-022 ISOLATED INSTANCE /ONE TIME 13B-019 CORRECTIVE ACTION 493 RRF X III FCR'S IMPROPERLY APPROVED OR SPEC. REVISED, FCR'S CORRECTIVE ACTION NOT ENTIRELT 13B-021 IMPROPERLT MARKED FOR NO INCORPORATED. FCR'S REVIEWED EFFECTIVE INCORPORATION INTO SPEC. SEE SECTION 5.5 494 RRF I III DR DISPOSITION / JUSTIFICATION DISPOSITION OR JUSTIFICATION ISOLATED INSTANCE /0NE TIME 138-022 DOES NOT MEET PROCEDURE REVISED CORRECTIVE ACTION REQUIREMENTS 796 RRF X II MATERIAL SPECIFICATIONS FOR SPECIFICATIONS REVISED, ISOLATED INSTANCE /0NE TIME 138-20 EQUIPMENT INSIDE CONTAINMENT UNQUAL. COATINGS TABULATED AS CORRECTIVE ACTION DO NOT REQUIRE COATINGS APPLICABLE MEETING ANSI N101.2/N101.4
--_--_m_ _ _-_--m__ _ -_
6 PROGRAM ASSESSMENT O,
6.1 INTRODUCTION
]
This section describes the program developed and actions ;
performed to ascertain whether the design and construction i activities related to coatings for Vogtle Electric Generating ;
Plant Unit 2 have been adequately controlled to implement ;
licensing commitments, to ascertain whether the corrective l actions resulting from the Unit 1 Readiness Review were applied to Unit 2, and to verify that the results of the design and construction activities conform to project procedures and design requirements.
The Readiness Review Team assembled for Module 13B consisted of one Readiness Review Task Force member and three members of site Quality Assurance with 55 years combined nuclear design and construction experience. Approximately 800 manhours were expended in performance of the module review and assessment activities. The team members are listed in Table 6-1.
Discrepancies noted during revi*ew activities were issued to the Project as findings. The Project was required to respond in a manner that addressed the specific issue identified, addressed project investigative action to determine possible generic implications, and described corrective actions performed.
) These project responses were evaluated and the findings were subject to categorization as follows:
o Level I - Violation of licensing commitments, project procedures, or engineering requirements with indication of safety concern. (No findings in this module were categorized as Level I) o Level II - Violation of licensing commitments or engineering requirements with no safety concerns.
o Level III - Violation of. project procedures with no safety concerns.
0224m/172-8 6-1
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6.2 PROGRAM DESCRIPTION
(~N The Readiness Review Program evaluation of coatings in Plant Vogtle Unit 2 consisted of three major activities. These were commitment implementation review; fo'llowup of Unit 1 finding I corrective actions as applied to Unit 2; and development and
{ execution of an assessment plan to examine programs, activities, and hardware. -
1 l Sections 3 and 5 of this module discuss project actions related ]
to the commitment matrix and the application of Unit 1 finding corrective action to Unit 2, respectively.
i The assessment for Unit 2 coe. tings was developed to accomplish the following objectives:
o Provide added assurance that project documents and procedures implement licensing commitments.
o Determine whether actions taken to resolve problems identified during the Unit 1 Readiness Review have been effective in preventing recurrence in Unit 2.
o Determine whether program and organizational enhancements made for Unit 2 have maintained the quality of the design and construction effort.
('N o Assess design completion and design change activities for compliance to engineering procedure controls, o Assess installed hardware for compliance to engineering and vendor requirements.
The assessment and results are discussed in the following sections.
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6.3
SUMMARY
AND CONCLUSIONS O Module 13B rddresses protective coatings inside Unit 2 containment. Selected coating samples and coating applications were examined and the related design and construction documents were reviewed to verify the adequacy of the design and construction processes and results. Plans for selecting verification samples and verification attributes were developed
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to ensure comprehensive coverage of the various types of coatings and documents.
The samples selected included 3 in-process application activities and 10 areas of applied coatings. Touchup coatings used to repair deficiencies or damage were selected as part of the applied coating samples. The two storage facilities for l prequalified coating materials were included in the sample.
Documentation assessed was directly related to the sample or in-process activity wherever possible.
i The assessment plan addressed:
o Implementation of licensing commitment requirements.
o Unit 2 application of corrective actions resulting from the Unit 1 Readiness Review.
I o The effects of program enhancements and newly developed I
(} programs.
The above assessments resulted in six findings, five of which I were classified as Level II and one as Level III. Each of the findings ~ identified was evaluated to determine the extent of the deficiency, the root cause of the finding, and the impact on hardware or documentation. A project response was prepared which documented remedial action for the specific case reported in the finding, corrective action for any additional deviations identified during the project evaluation, and any action necessary to prevent recurrence of similar deficiencies.
Of the six findings, four reported contractor procedure deficiencies. In each of the four cases, investigation showed that the intent of the requirement addressed in the procedure had been met. The investigation also showed the deficiencies to be limited to the item or procedure identified in the finding. i l
Of the remaining two findir gt , one was an isolated case of l conflict in a purchase specification and the other one was due to repetitive errors in processing Field Change Requests I
(FCRs). The investigation of the FCR deficiencies showed them tc be limited to the coating specification.
0224m/172-8 6-5
None of the findings reported deficiencies in applied coatings or inspection documentation. None of the remedial actions involved applied coatings. h The four findings reporting deficiencies in contractor procedures, collectively indicate a lack of attention to procedural details. In addition to correction of the procedural deficiencies, the action to prevent recurrence includes a commitment for increased attention by the contract'or quality assurance / quality control manager to these details. No other commonality of cause between findings was established.
Based on Readiness Review assessment activities and Project responses to findings, Readiness Review has concluded that all the findings represent isolated cases of failure to comply with engineering or licensing requirements, or with procedures, with no effect on applied coatings and no safety concern and do not individually or collectively represent generic program concerns.
The findings are listed in Table 6-2. Individual findings and the Project responses are presented in section 6.5.
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0224m/172-8 6-6
.e 6.4 ASSESSMENT ACTIVITIES AND RESULTS
- Readiness Review activity for this module consisted of the development and implementation of an assessment plan to provide a systematic review of activities, programs, and hardware associated with protective coatings. The assessment was performed to provide added assurance that the Project continued to comply with licensing commitments. This section describes the development and implementation of the plan and the results of the assessment.
The assessment was organized into three parts:
o Part 1 - Commitment 1mplementation and Unit 1 Finding Followup.
o Part 2 - Design and Construction Programs and Activities.
o Part 3 - Design and Construction Completion.
In preparation for development of the assessment plan, Readiness Review examined the information presented in section 5 of this module [ audits, Nuclear Regulatory Commission (NRC) inspections, etc.] to ensure that areas with a history of deficiency or weakness at Vogtle Electric Generating Plant or within the industry were factored into the assessment.
{} The following were evaluated for inclusion in the assessment:
o Quality Assurance Audit Finding Reports and Corrective l Action Requests.
o NRC violations.
o Quality concerns.
o Industry problems.
This review and evaluation identified the following issues that were included in the assessment plan:
Issue Source Where Addressed Procedure Adequacy QA AFR Parts 1, 2 &3 l Unit 2 Dome / Hanger Quality Concerns Part 3 Coatings Application Activities Quality Concerns Part 2 A compilation of problems identified during the Unit 1 startup phase was obtained from Operations and was reviewed to identify design or construction-related problem areas. Additionally, 0224m/172-8 6-7 -
copies of the NRC inspections of Comanche Peak, Browns Ferry, Sequoyah, and Watts Bar for 1985, 1986, and 1987 were obtained and examined to identify any new areas of industry concern. In the area of coatings, no areas not already addressed were identified from these sources.
A listing of the sample used for the module assessment is shown in Table 6-3.
6.4.1 PART 1, COMMITMENT IMPLEMENTATION AND UNIT 1 FINDING FOLLOWUP The objectivs of part 1 of the assessment was to assess implementation of licensing commitments, with emphasis on those revised or added since Unit 1 Readiness Review by Final Safety Analysis Report amendments or project letters and to assess the adequacy of application to Unit 2 of corrective actions resulting from Unit 1 Readiness Review.
6.4.1.1 Commitment Implementation Desian The commitment matrix presented in section 3.2 contains eight individual design commitments, all which were reverified for implementation into design criteria and working level documents such as specifications and drawings.
lh During the review of purchase specifications for incorporation of licensing commitments, conflicting coating requirements were noted in Specification X4AJ16, Containment Cooling Units. The conflict was documented in Finding 2RRF-13B-004 (Level II).
Spe'cification X4AJ16 described the coating system to be used. It required prequalification to ANSI N101.2, but also listed coating materials which are not prequalified to ANSI N101.2. In addition, the list did not include all the materials necessary to apply the specified coating system. The conflict was reported in Finding 2RRF-13B-004 (Level II).
The investigation by Engineering determined that the containment cooling units had been coated with prequalified material and proper documentation is on file to provide evidence. The specification has been revised to resolve the conflict.
With the minor exception as documented in 2RRF-13B-004 Readiness Review concluded that the design licensing commitments had been appropriately and adequately implemented.
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Construction O The commitment matrix, presented in section 3.2, contains seven entries requiring construction implementation; all of which were reviewed. The evaluation ascertained whether the commitment was included in the construction specification and, where applicable, whether the contractor quality control and application procedures also incorporated the commitment.
Four of the seven construction commitments were found to be fully implemented. The remaining three commitments are to Regulatory Guide (RG) 1.54 and ANSI N101.4. These commitments are divided into 13 separate requirements for analysis on the implementation matrix. The implementation of two of these requirements was found to be deficient and the deficiencies were reported on Unit 2 Findings 2RRF-13B-003 and 2RRF-13B-005, both ;
Level II. '
i The project commitment to RG 1.54 requires meeting the documentation requirements of ANSI N101.4. These include maintenance of a warehouse record, showing receipt and issuance of each batch of coating material. No contractor procedure prescribing this document was found (Finding 2RRF-13B-003).
Investigation showed that the requirement had been deleted during procedural and organizational changes, although the record was maintained as a nonquality document for inventory
') control purposes. The Project response was to reinstate the k' / procedural requirement and upgrade the existing nonquality records.
This deficiency was also noted by a Unit 1 finding. Further corrective action to address the repetition includes listing the record in the document control procedure and a commitment for increased quality assurance / quality control manager attention to procedural details.
The commitment to RG 1.54 also requires that application procedures conform with the coating manufacturer's written instructions. The Project has met this requirement by obtaining the manufacturer's written approval of each application procedure. The contractor's general procedure for control of application procedures allowed exceptions to this requirement (Finding 2RRF-13B-005).
Investigation showed that the exceptions were used to implement changes that had been discussed with the manufacturer, and were acceptable, but had not been reviewed and signed. All such changes were subsequently approved in writing by the manufacturer; none are outstanding. The contractor's procedure has been revised to delete the exceptions.
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Readiness Review concludes that with the minor exceptions documented in 2RRF-13B-003 and 2RRF-13B-005, the implementation of construction commitments is acceptable. h 6.4.1.2 Unit 1 Finding Followup Unit 1 finding followup consisted of a review of actions taken by the Project to prevent recurrence in Unit 2 of the types of problems identified by Readiness Review during the Unit 1 assessment. A listing of the Unit 1 findings was provided to the Project, a review was performed by the Project, and information indicating the actions taken to address Unit 2 programs was provided to Readiness Review. Readiness Re' view evaluated these responses to assess the accuracy and adequacy of the information provided.
The Unit 1 findings were evaluated for continued application of corrective action to Unit 2 activities and the Unit 2 assessment .
results were reviewed for repetition of Unit 1 findings. For 14 of the 16 Unit 1 findings, the corrective action was found to be effective.
The corrective action for one Unit 1 finding, to establish a procedural requirement to maintain a warehouse record, was found to be not fully effective, as described in the discussion of Unit 2 Finding 2RRF-13B-003 in section 6.4.1.1.
For the remaining Unit 1 finding, an element of the finding was O found to be repeated in Unit 2. In both assessments, FCRs were found mak'.1g generic changes to the coating specification, but the FCRs sere identified as not requiring incorporation in the specification (section 6.4.2.1 contains a discussion of Finding 2RRF-13B-002).
6.4.2 PART 2 IN-PROCESS ACTIVITIES The objectives of part 2 of the assessment were to examine ongoing design and construction processes.
6.4.2.1 Design Procrams The design portion of part 2 examined the design programs controlling design changes.
Desicn Chance Control Thirteen Field Change Requests (FCRs) were evaluated to assess compliance with applicable procedures and licensing commitments and control of design changes.
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l The review identified repetitive failure to properly identify 1 and process changes affecting Project Class 02C coatings l O (coatings inside containment). FCRs concerning coatings inside containment were improperly identified as Project Class 62C and i
.were not sent to QA for. review. In addition, FCRs properly identified as Class 02C were not sent to Quality Assurance for review as required by procedure. Finding 2RRF-13B-002 i (Level III) was issued. The finding also identified procedural ;
errors in classifying FCRs for incorporation into the l specification, failure to provide justification, and improper incorporation. The investigation determined that the problem area was limited to the coating specification. The technical adequacy of FCRs with procedural errors was verified by an Engineering review, and corrections were made to the documents.
Affected personnel have been retrained in the problem area.
Readiness Review concludes that the deficiencies have had no adverse effect on the technical adequacy of the specification l and no effect on applied coatings. l l
6.4.2.2 Construction Procrams l
The construction portion of the Part 2 assessment examined l in-process coating application, coating material storage and deviation reports.
(} In-Process Application in-process application activities were assessed by observing preparation, inspection, and application activities in the field. Attributes assessed included proper environmental testing, surface preparation and inspection, documenting and mixing of materials and application of coating. No deficiencies were identified in these activities.
Material Storace The two prequalified material storage areas were examined for compliance to procedural requirements. Attributes assessed l included temperature control, area cleanliness and material identification. No deficiencies were identified.
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Deviation Reports )
i The contractor's deviation report procedure was reviewed in '
preparation for assessment of a sample of deviation reports. A deficiency in procedural requirements for deviation tracking and conflicts in the procedure were identified and reported on Finding 2RRF-13B-008 (Level II). The Project investigated the finding and determined that deviations had been processed in a timely manner and that no errors in processing had occurred as a 0224m/172-8 6-11 i i
result of the procedure conflicts. Revisions to the procedure have corrected the deficiencies.
A sample of contractor deviation reports was assessed for compliance to project requirements. The reports were reviewed for adequate description, appropriate disposition, proper justification, and required approvals. No deficiencies were identified.
Procedures The two contractor document control procedures were reviewed.
Both referenced an incorrect revision of ANSI N.45.2.9. Finding
, 2RRF-13B-006 (Level II) was issued. Investigation determined -
that no deficiencies in the contractor's document control program had occurred as a result of this error, and the procedures were corrected.
COMPLETION 6.4.3 PART 3, The objective of part 3 of the assessment was to evaluate the l
construction completion process.
Applied Coatings l
Samples of applied coatings were examined in the field for compliance to procedural and specification r'equirements. The h samples included coatings applied to touch up deficient or damaged coatings. Coatings were inspected for dry film thickness and visual deficiencies such as cracking, pinholes, runs, and inclusion of contaminants. Surrounding areas were checked for overspray, droppings, and masking of nameplates, moving parts, etc.
The applied coatings assessed were found to be acceptable. No l findings were issued.
Two small coating areas not meeting specification requirements were noted at a hanger in the containment dome area, the overlap l area of the touchup work had excessive dry film thickness and l the coating had been applied over a small amount of weld spatter. The excessive dry film thickness had been identified by Quality Control on a deviation report at the time of acceptance inspection and had been dispositioned use-as-is.
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! Examination of applicable documents also showed that the coating
- over weld spatter occurred at the time when acceptance standards l were changed from "a small amount of tightly adhering weld
! spatter" tc "no weld spatter." No retrofit requirement was l associated with this change. The amount of coating in question l
on the assessed hanger is very small (about one square inch).
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During the field wal'kdown it was noted that some applied coatings had been damaged by subsequent construction activities. Review of the area turnover procedure revealed that
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- s. acceptable coatings is an attribute for area turnover walkdown -
and repairs are made as identified by this. final inspection.
This process had not started in the Unit 2 containment at the time of the assessment.
Quality Documentation Inspection records associated with the coating samples inspected were reviewed for conformance to procedural requirements and agreement with the product observed in the field. No deficiencies were found.
Material Traceability Sample batch numbers from the inspection records reviewed were traced to the manufacturers certificates and the certificates were reviewed for compliance to requirements.
All samples were successfully traced and the certificates demonstrated that the materials were qualified.
Inspector Qualification Approximately 30 inspectors have worked on Unit 2 containment coatings. Records for six inspectors were selected'from the
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inspection records reviewed and were assessed for compliance to procedural requirements. No deficiencies were found. The document packages were complete and showed the inspectors to have been properly qualified at the time of inspection.
Painter Certification Approximately 80 painters have applied coatings in Unit 2 containment. Records for seven painters, selected from the inspection documentation assessed, were reviewed to ascertain if the painters were certified at the time of application for the application performed. No discrepancies were found.
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l 6.5 FINDINGS l O
d This section presents, in numerical order, the six valid findings issued during the assessment; the Project response, including corrective actions taken; and the Readiness Review Task Force conclusions for each finding. ,
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Finding 2RRF-13B-002 (Level III)
(} Requirements:
Project Reference Manual, section 17, states, in part, the following:
o 17.5.2.a. After review and disposition by Engineering, if a design change is needed to the affected documents, an "X" is placed in blocks 2 and/or 6 of the Field Change Request (FCR) form.
o Construction Specification Change Notices (CSCNs) and Mechanical Specification Change Notices are incorporated in accordance with part C, section 26.
o 17.5.3, Justification and concurrence shall be provided on the FCRs prior to approval of block 16.
o 17.6.2.5, FCRs in'itiated for specifications that are Q-Class, fire protection or radwaste shall be forwarded to Quality Assurance (QA) for their concurrence prior to submitting the originals to Geo.gia Power Company Document Control.
Finding:
O' Contrary to the above, of a sample of 13 FCRs reviewed for Readiness Review Module 13B, Coatings, the following discrepancies were noted which were written against Specification X1AJ07:
o C-FCRB-22524 - Generic change identified as NA/NA, missing QA review.
o C-FCRB-21176 - Missing QA review, incorrect project class.
o C-FCRB-21175 - Missing QA review, incorrect project class.
o C-FCRB-19820 - Generic change identified as NA/NA, missing QA review and justification.
o C-FCRB-20176 - Missing QA review, incorrect incorporation.
o C-FCRB-19891 - Missing QA review.
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Proiect Response:
I. INVESTIGATIVE ACTION To determine the extent, the 48 FCRs written since January 1, 1986, against architectural specifications that are Q-Class, fire protection- or radwaste-related (X1AGlO, X1AH02, X1AH05, X1AH07, X1AJ07, X1ARIO, and X1AR28) were reviewed. Fourteen of these were found to contain procedural errors similar to, and in addition to, those cited in the finding. All of these 14 additional FCRs with errors were written against Coating Specification X1AJ07.
No FCRs with errors were found written against any other architectural specification. Therefore, the extent of the concern identified in this finding is considered to be isolated to FCRs issued to Specification X1AJ07.
Revision 24 to Specification X1AJ07 was written in December 1985 in recponse to a Unit 1 Readiness Review finding. This general revision included incorporation'of outstanding change documents and a review and rewrite of the entire specification. FCRs written against the specification subsequent to January 1, 1986, were reviewed during the investigative actions from this finding. To assure that all FCRs with procedural errors, written subsequent to the baseline revision 24 had been identified, FCRs written against revision 24 of Specification X1AJ07 in December 1985 were reviewed. No additional FCRs with h, errors were found.
Of the 20 FCRs with procedural errors identified in the finding and the project review, one (C-FCRB-22,524) had been voided, as the application process authorized by the FCR was neither incorporated in a Williams Power Services, Inc. (Williams) application procedure nor used on the Project.
The remaining 19 FCRs were reviewed to determine if an impact to hardware or testing could exist as a result of the problems noted. The review concluded that the 19 FCRs contained adequate and acceptable technical design changes. The conditions are limited to programmatic documentation errors; therefore, there is no impact on hardware.
Root Cause:
The personnel processing FCRs had an inadequate understanding of the coatings project class designation and the QA review requirement associated with the coatings 02C Class.
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II. REMEDIAL ACTION i 2
() Correction cu the 19 FCRs identified was completed on April 28, 1988, with the exception of CFCR-B-20176, which !
was identified as being improperly incorporated in the !
specification. Specification X1AJ07 was revised May 12, 1988. This revision corrected the revision block to indicate that the FCR was modified. The actual ,
incorporation of this FCR is technically adequate and the !
word " modified" had been inadvertently omitted.
III. ACTION TO PREVENT RECURRENCE Training of appropriate architectural personnel has been conducted regarding the coatings project classification i (U2C versus 62C), the need for QA review of FCRs with the ;
project class 02C, and identification of generic changes !
requiring incorporation into the specification. ;
i Readiness Review
Conclusion:
f The Project review of the 19 discrepant FCRs demonstrated that i the procedural errors in processing the FCRs had not resulted in any deficiencies in applied coatings. :
The Readiness Review assessment and the PIc'ect review -
identified repetitive procedural lapses; however, the Project review of architectural FCRs is evidence that the problem is
( ). limited to Coatings Specification X1AJ07.
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.The finding is partia11'j repetitive of a Unit 1 Readiness Review finding in that Unit 1 Finding 13B-21 reported an improper )
designation as NA/NA for two FCRs containing generic changes.
This same deficiency was identified for the voided FCR and three others during the Unit 2 assessment and Project review. I I
The corrective action and action to prevent recurrence is l appropriate to the finding and the identified root cause.
The response is acceptable and there is no impact to the applied coatings. 4 j
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Finding 2RRF-13B-003 (Level II)
Requirements:
Specification X1AJ07, paragraphs 12.1.lA, 12.7.1, and 12.7.2 require that the documentation requirements of ANSI N101.4 be met and allow alternete forms providing the same degree of documentation to be used. Example 3 of the Quality Document Forms Attachment to Specification X1AJ07 is a warehousing record, documenting the receipt and withdrawal of coating material for each batch of coatings material received.
Finding:
No procedure was found prescribing preparation and turnover of the required warehousing record or eglivalent.
Note: An informal inventory record is kept in the Williams warehouse which is equivalent to the required Warehousing Records. During the assessment it was determined that this inventory record included all the required data for the selected samples of coating materials.
Project Response:
I. INVESTIGATIVE ACTION Williams does not currently address the Warehousing Records O
in any procedure. A similar finding was reported in Unit 1 Readiness Review Finding 1RRF-13B-7 in 1985. At that time, a commitment was made to place the Warehousing Records in Warehouse Procedure WW-I-01. This was completed on September 26, 1985. On August 12, 1987, Procedure WW-I-01 was revised and the requirements for the Warehousing Records were dropped from the procedure.
The root cause of Unit 2 Readiness Review Finding 2RRF-013B-003 was the fact that the Warehousing Records were never recognized as a quality document. In addition, the Warehousing Record was not designated as a quality document in Procedure WC-003 and in response to the Unit 1 finding, it was placed in a warehousing procedure instead of a Quality Control procedure.
Williams has historically used the Warehousing Record as an inventory control vehicle. The Warehousing Records have been continuously maintained and document turnover has not begun, thus assuring the availability of adequate material
. traceability.
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II. REMEDIAL ACTION l
() Procedure WC-015-253. Warehouse Coating Records, has been written for the upkeep and turnover of the Warehousing Records. In addition, the existing Warehousing Records ,
have been reviewed by the Williams Quality Control department. The review found that records were missing for the period of September 9, 1986, to December 16, 1986. The missing records were addressed in Deviation Report WC-88-003 dated May 26, 1988; the approved disposition was hardware not affected. The Williams quality assurance / quality control (QA/QC) site manager has concluded, after completing the review, that the existing Warehousing Records are acceptable as quality documents.
III. ACTION TO PREVENT RECURRENCE The new QC procedure has been approved by GPC Quality Control and is controlled by the Williams QC Department through Document Control Procedures WC-003 and WC-019.
Williams Quality Control will monitor the Warehousing Records closely to assure compliance. ,
Readiness Review
Conclusion:
The. Unit 2 Readiness Review assessment evaluated Williams ,
compliance with specified record keeping provisions of
() ANSI N101.4. Each record requirement was reviewed against Wi111ams procedures and samples of the records. All records except the Warehousing Records were found to be properly prescribed by Williams procedures. During the material traceability assessment, material qualification and traceability to specific batch numbers was ascertained without using the Warehousing Records.
The process of adjusting Williams warehouse activities to accommodate changed workload levels involved procedural and personnel changes. During this process, the quality aspects of the Warehousing Records were overlooked as stated in the root ,
cause investigation.
The corrective action of including the Warehousing Records in the Quality Control procedures and under Quality Control purview should prevent any repetition.
The remedial action to review the informal inventory record and verify acceptability (to ANSI N45.2.9 standards such as legible, ;
completely filled out, and stamped, initialed, or signed and '
dated by authorized personnel) provides the records required to meet the specification. ;
Based on the response and the above considerations, Readiness
() Review concludes that the response is acceptable. !
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Finding 2RRF-13B-004 (Level II)
Requirements: h Design Criteria DC-1000A, section 10, requires that coatings inside the containment building meet the requirements of ANSI N101.2.
Specification X4AJ16 (Containment Cooling Units), revision 10, dated December 10, 1986, paragraph 6.3.1, requires that coatings be certified to ANSI N101.2. Paragraph 6.3.A requires an inorganic zinc primer followed by an epoxy topcoat and also lists acceptable suppliers and products.
Findinc: .
A. The Ameron and Carboline inorganic zine primers listed are not their N101.2-qualified products. '
B. The products listed are all inorganic zinc primers. No epoxy topcoat is listed.
Project Response:
- 1. INVESTIGATIVE ACTION Extent of the Problem:
This finding iden'tifies conflicting requirements within S
Specification X4AJ16. Paragraph 6.3.1.2.a requires documentation in accordance with ANSI N101.4 and Regulatory Guide 1.54. In the same specification, paragraph 6.3.A.4 requires specific name brand coatings which will not meet these documentation requirements and makes no allowance for acceptable alternates.
To determine the extent of this problem with conflicting coating requirements, a sampling of 8 out of approximately 40 specifications requiring the ANSI N101.4 and N101.2 documentation was reviewed. These specifications were:
X2AG03, X2AG05, X2AG06, X2AG07, X2AG08, X2AH01, X2AH02, and X2AP01-C9.1. No conflicts or discrepancies between the approved coatin.gs list and documentation requirements were identified; th.~efore, the discrepancy is an isolated event.
l Significance of the Deficiency:
The purchase order document PAV2-86 was reviewed to I
determine the quality of paint actually supplied for items
! in X4AJ16. The Supplier Quality Verification Document List-Detailed documents that the paint meets the requirements of paragraph 6.3.1.2.a of X4AQJ16. Also, the Product Identity and Quality Assurance Certification Record l 0224m/179-8 6-22
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certifies that the paint meets the manufacturing requirements of ANSI N101.2, ANSI N101.4 and ANSI N5.12
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when properly mixed. Documentation that the paint was properly mixed and applied is provided. These documents provide objective evidence that the paint meets the more stringent requirements of paragraph 6.3.1.2.a of X4AJ16 and that the conflict in the specification did not degrade the installed paint quality.
Root Cause:
The root cause of this finding can be attributed to human error. The specification writer did not realize that the paint specification contained conflicting requirements and the review process failed to uncover the mistake.
II. REMEDIAL ACTION Specification X4AJ16 was revised June 8, 1988, to delete paragraph 6.3.A.4. This will eliminate the conflict between the documentation requirements and avoid the procurement of unqualified coatings in the future.
III. ACTION TO PREVENT RECURRENCE The remedial actions taken assure that future materials procured under X4AJ16 will meet the requirements of
() paragraph 6.3.1.2.a.
Readiness Review
Conclusion:
The response demonstrates that the coatings material used to shop coat the containment cooling units procured under Specification X4AJ16 was properly qualified and that the specification conflict resulted in no hardware deficiency.
The project reviewed eight specifications and found no similar errors. During the assessment, Readiness Review examined nine specifications, identifying the one conflict described in the finding. The remaining eight specifications were in compliance with ANSI N101.2 and without conflict. Three of these eight -
were also included in the project review sample. Based on these investigations Readiness Review agrees that the discrepancy is isolated and not indicative of a programmatic problem.
The revision to the specification deletes the section listing specific coating products, thus resolving both the omission of any epoxy topcoat product and the listir.g of inorganic zine products not qualified. The requirement to shop coat cooling units with a coating system prequalified to ANSI N101.a remains 0224m/172-8 6-23
in the specification assuring consistent requirements meeting project commitments for any future use of the specification.
The response is acceptable.
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Finding 2RRF-13B-005 (Level II)
() Requirements:
Final Safety Analysis Report (FSAR), section 6.1.2.1; Specification X1AJ07, section 12.5.1; and Williams QA Manual, section 5.4.4, and Job Specific Addendum, section 5.4.1, require written approval of the manufacturer for application procedures.
Finding:
Williams Procedure WC-300, sections 300.4.1.4 and 300.7 allow exceptions to this requirement.
Project Response:
- 1. INVESTIGATIVE ACTION Williams QC reviewed all application procedures and found options or exceptions stated or implied in sections 300.2.2, 300.2.3, 300.4.1.4, and 300.7. The Williams QA/QC site manager confirmed that exceptions to this manufacturer approved application procedure were made. ;
It has been the practice of the Civil Engineering i Discipline to converse with the coatings manufacturer prior i to recommending any changes involving Q coatings. In
() addition, it has been the practice of the Williams QA/QC site manager to be in agreement with the coatings manufacturer prior to sending a procedure to them for approval. No procedure changes have been disapproved by the coatings manufacturer and procedures have promptly received written approval. All application procedures have been sent to the coatings manufacturer.
Root Cause:
Williams Management, in an effort to provide timely response to site conditions or specification changes, permitted application procedure requirements to be superseded, based on oral concurrence, prior to receiving written approval from the coatings manufacturer.
II. REMEDIAL 7CTION Williams has revised Application Procedure WC-300, sections' 300.2.2, 300.2.3, 300.4.1.4, and 300.7, to remove any reference to exceptions.
l III. ACTION TO PREVENT RECURRENCE l The Williams QA/QC site manager and the Williams project
() manager generate and approve Application Procedure WC-300.
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0224m/179-8 6-25 l l
i
In the future, they will ensure that the procedure is revised and written approval from the coating manufacturer is obtained prior to implementation.
Readiness Review
Conclusion:
The investigation showed that the exceptions to manufacturer's approval of application procedures, allowed in the contractor's procedure, had been used to implement changes in application procedures while written approval was in progress. In no instance had procedures been issued without the oral approval of the manufacturer. All procedures have been submitted to the manufacturer and have been approved in writing. No coatings have been unacceptably applied as a consequence of this discrepancy. The remedial action and action to prevent recurrence should prevent any further instance of the use of an application process before the required documentation is in place.
The response is acceptable.
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0224m/172-8 6-26
Finding 2RRF-13B-006 (Level II)
Requirements:
FSAR, section 17.1.2, and Williams QA Manual, Job Specific ,
Addendum, section 5.10, require conformance to ANSI N45.2.9, j 1973, eleventh draft. i Finding: l Williams Procedures WC-003, Document Security, and WC-019, Controlled Document Revision and Distribution, reference ANSI N45.2.9, 1974.
Project Response:
i I. INVESTIGATIVE ACTION The investigation into this finding found the Williams QA Manual and Procedures WC-003 and WC-019 to be I generic / corporate documents. All three documents reference l ANSI N45.2.9. 1974. The Job Specific Addendum to the QA t Manual, paragraph 5.10, requires conformance to ANSI !
N45.2.9, 1973, eleventh draft, as required by section ;
17.1.2 of the FSAR.
Williams relied on the Job Specific Addendum to the QA :
-() Manual to prescribe site-required conformance to ANSI N45.2.9, 1973, eleventh draft. The root cause of the l
i finding was that no reference in the QA Procedures Manual would lead the user to the Job Specific Addendum of the QA Manual as the source of the correct edition of referenced '
standards, i 1
The Williams QA/QC site manager checked the QA Procedures l
to verify that other standards referenced are the edition stated in the Job' Specific Addendum of the QA Manual. All j were found to be the edition stated in the Job Specific
-Addendum.
II. REMEDIAL ACTION Williams revised Procedures QC-003 and WC-Ol9 to reference ANSI N45.2.9-1973, eleventh draft. These revisions were j completed by April 19, 1988. ,
III. ACTION TO PREVENT RECURRENCE )
l The Williams QA/QC site manager generates and approves- l these procedures. He will ensure that all future j procedures have the correct standards referenced. l l
l 0224m/179 6-27_ l I
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Readiness Review
Conclusion:
The remedial action will correct the deficiency found.
Readiness Review knows of no changes between the 1973, eleventh h:!
draft, and 1974 revisions of ANSI N45.2.9 that would adversely affect the qualit y of Williams ' documentation.
Readiness Review checked the Williams QA Manual for correct revisions of reference standards to further evaluate the broadness of this finding. No discrepancies were found.
Readiness Review also checked the remainder of the Williams QC Procedures Manual for reference to correct revisions of standa*.ds. Four additional references to specific standards were found. All were in agreement with the specification or unspecified and in agreement with the Williams QA Manual.
Readiness Review concludes that this discrepancy was isolated, with no programmatic implications.
The response is acceptable.
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l l 0224m/172-8 6-28 l
5 Finding 2RRF-13B-008 (Level II)
() Requirements:
Vogtle Electric Generating Plant (VEGP) QA Manual, section 15.2 '
states:
A. The identification, documentation, segregation, review, disposition, and notification of affected organizations of nonconformance of materials, parts, components, or services is controlled.
B. Nonconformances concerning departures from design specification and drawing requirements which are ,
dispositioned use-as-is or repair are dispositioned by the '
responsible engineering organization.
Finding:
- 1. Williams Procedure WC-008 contains no provision for tracking reworkable deficiencies defined in section 008.5.1.2.
Requirements for identifying non-reworkable deficiencies are conflicting. (Sections 008.5.1.3 and 008.5.2.1) r
- 2. Provisions of Williams. Procedure WC-008 for approval of i use-as-is or repair dispositions are conflicting, and do not identify Project Engineering as the responsible engineering ;
() organization. (Sections 008.5.2.4, 008.5.7.2, 008.6.3.21, 008.6.3.23, 008.6.3.26)
Proiect Response:
I. INVESTIGATIVE ACTION ;
The Williams QA/QC site manager confirmed that the original intent of procedure WC-008, section 008, section 008.5.1.3, was to address the tracking of rejected items which were ;
reworkable. A typographical error was made and section 008.5.1.3 inadvertently stated " rejected items which are not reworkable." .
Section 008.5.1.3 also addresses an Open Item Log.
Williams QC stopped using the log in May of 1986. At that time, the responsibility for keeping the log was moved from the QC clerk to the QC inspectors. The investigation found ,
that the Williams QC inspectors failed to use the log and that Williams QC mana:ement failed to ensure that the inspectors used the log.
The purpose for the Open Item Log was to track reworkable, ;
rejected items. Prior to May 1986, the log documented and l verified that reworkable items were handled in a timely l
{} manner. Williams QC replaced the Open Item Log with a i
0224m/172 6-29 f l
designated Hold File. Williams QC management failed to make the appropriate change in procedure WC-008 to reflect the new method of tracking. h The Williams QA/QC site manager reviewed all reworkable, rejected items reported between May 1986 and April 6, 1988. There were 568 reworkable, rejected items reported during this period. A random sampling of 72 of the 568 items was reviewed and it was determined that 50 were reworked within 4 days, 2 within 7 days, and 20, all of which were on one inspection report, were not reworked for 4 months. Although the Open Item Log had not been used since May 1986, these 20 rejects mentioned above were recorded in the Open Item Log in May 1987, but were never placed on a Deviation Report. The inspection report was placed in the designated Hold File until it was reworked. -
The Williams QC Site Manager did not write a Deviation Report because the delay was caused by construction restraints which did not allow the workers back into the area for rework. Williams Management concluded from this review that items were reworked in a timely manner except as constrained by other construction activity. As of April 6, 1988, there were no outstanding reworkable, rejected items in the designated Hold File.
The root cause of this finding was the inappropriate attention level of Williams QC management.
Investigation into the second part of this finding, O
established that section 008.6.3.23 had three editorial errors. The words " recommended dispositions" are used twice in this section. The correct words should be
" approved dispositions." The third error had the " owner or designee" approving what should have been the approved disposition. The " design engineering group" should approve the approved disposition.
As previously stated, Williams procedure WC-008 required the owner or designee to approve any use-as-is or repair approved dispositions. In practice, Williams sent deviation reports requiring this approval to the Project Construction Civil Engineering Discipline. The Civil Engineering Discipline, in accordance with Georgia Power Company Procedure GD-T-01, sent the use as is or repair deviation reports to Project Engineering. In fact, all Williams use as is and repair deviation reports have received Project Engineering approval.
The root cause of the errors in section 8.6.3.23 was the inadequate review of the final printed text prior to final approval.
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0224m/172-8 6-30
NOTE: Williams QC Procedure WC-008 employs the terms
" owner or designee" and " design engineering
(' group." The Williams organization construes the terms " owner or designee" to mean the Project I Construction Civil Engineering Discipline and
" design engineering group" to mean Project i Engineering.
II. REMEDIAL ACTION Williams has revised Procedure WC-008, section 008.5.1.3, to direct any inspection reports which identify reworkable deviation to be placed in a designated hold file and to remain in that file until the area has been reworked. This file will be reviewed monthly by the QA/QC site manager.
Any item over 60 days old shall be reported on a deviation report. The inspection report shall remain in the hold file until it has been closed by the approved disposition on the deviation report. Deviation Report WC-88-002 has been written to resolve the procedure violation cited herein and it has been dispositioned " hardware not affected." The typographical error in section 008.5.1.3 has been corrected. -
Williams has revised Procedure WC-008, section 008.6.3.23, to state " approved dispositions" instead of " recommended dispositions" and " design engineering group" instead of
("
\
" owner or designee".
thoroughly edited.
Future changes will be more III. ACTION TO PREVENT RECURRENCE Williams QA/QC has reviewed their Quality Control procedures and determined tnat the QC manager reviews deviation report trends and rejected open items on a monthly basis. No other monthly review requirements were found. The trend review (Form WC-008D) is in place and a checklist for the monthly review of rejected open items (Form WC-008E) has been added to the nonconformance control '
procedure (WC-008).
Remedial action will prevent recurrence. I Readiness Review
Conclusion:
The investigation determined that subsequent to May 1986, the tracking system for reworkable coating deficiencies, intended to be established in this procedure, was not used. A hold file system was used and deficiencies were corrected promptly or, where prompt correction was not possible due to access constraints, the deficiencies were corrected when access was again available. However, deviation reports were not issued
("}
V after a predetermined period of time and the reports were not 0224m/172-8 6-31
entered in the formal tracking system. The investigation further showed that deviations with use-as-is or repair dispositions had been approved by Project Engineering. h Readiness Review concurs that the root cause was inadsquate QC manager attention and inadequate review of final procedure text.
The procedure changes, correcting the conflicts and errors and adding a review checklist will remedy the finding. These changes, and the commitment to more thorough editing of procedure text, should prevent recurrence.
The response is acceptable.
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0224m/172-8 6-32
TABLE 6-1
( 3 READINESS REVIEW TEAM
's FOR MODULE 13B P. R. Thomas Readiness Review Task Force l D. G. Lunsford GPC Quality Assurance J. H. Draggs GPC Quality Assurance B. A. Dragon Bechtel Quality Assurance l
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0227m/168-8/1
_ - - _ . - - - -- - . - - - -.------___--.---__-----_]
TABLE 6-2 UNIT 2 FINDINGS O
NUMBER LEVEL DESCRIPTION 2RRF-13B-002 III Errors in Processing FCRs.
2RRF-13B-003 II Required Warehouse record not maintained by contractor.
2RRF-13B-004 II Conflicting coating requirements in purchase specification.
2RRF-13B-005 II Contractor procedure does not meet specification.
2RRF-13B-006 II Contractor procedures cite different revision of standard than contractor QA manual and FSAR.
2REF-13B-008 II Conflicts in contractor procedure for deviation reporting.
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1 TABLE 6-3 ASSESSMENT SAMPLE l
(')N
(~ i
\
Item Number Assessed Design Field Change Requests 13 Licensing Commitments 8 Unit 1 Findings 8 Construction In-Process Applications 3 l l
Material Storage 2 Deviation Reports 10 Completed Coatings 10 Material Traceability 4 Inspector Qualification 6 Applicator Certification 7
~
l Licensing Commitments 7 i i
Unit 1 Findings 8 j l
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l 0227m/168-8/3 !
1
Geornia Power Company Proi;ct Managem1nt Post Offica Box 262 Wayn:sboro, Georgia 30830 Tglephone 404 724 8114 404 554 9961 L
U Vogtle Project June 15, 1988 MEMO TO: R. W. McManus
SUBJECT:
Plant Vogtle Unit 2 Readiness Review Module 13B Engineering has reviewed Module 13B, Coatings, for general accuracy and completeness. To the best of our knowledge and belief, the module is a complete and accurate representation of
,r3 the engineering process and commitments related thereto.
(/
ris .
W. C. Ramsey, Jr.
Project Engineering Ma- ger RWM/WCR/bjb
,/
LJ 0225m/166-8
Georgia Power Company Project Manag7nOnt Post Offics Box 282 W:yn:sboro, Georgis 30830 Tcieoboni 404 724-8114 404 554 9 % 1 m
L U Vogtle Project June 15, 1988 MEMO TO: R. W. McManus
SUBJECT:
Plant Voctle Unit 2 Readiness Review, Module 13B Nuclear Constructior has reviewed Module 13B, Coatings. To the best of our knowledge and belief, the module is a complete and accurate repres.entation of the site coatings program and commitments related thereto.
(~~)'s f A)*
f)i u f',( : =f*
R. H. Pinson Vice President Vogtle Construction RWM/RIIP/ b j b
()
L.)
0225m/166-8
Georgia Pow;r Comp;ny Project Man:gerrent Post Offica Box 282 Wryncsboro, Georgia 30830 ,
TWphons 404 724 8114 404 554-9961
( ,, L U Vogtle Project June 15, 1988 MEMO TO: R. W. McManus
SUBJECT:
Plant Voctle Unit 2 Readiness Review Module 13B Project Quality Assurance has reviewed Module 13B, Coatings. To the best of our knowledge and belief, the module is a complete
,r') and accurate representation of the site programs and commitments V related thereto.
['" / / , /
C. W. Hayes Project Quality Assurance Manager RWM/CWH/bjb
, s.
O, 0225m/166-8
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PLANT VOGTLE UNIT 2 READINESS REVIEW PROGRAM 1
Coatings'- Module 13B Readiness Review Board Acceptance Letter ;
i 6
The Readiness Review Board has been apprised of the scope and content of Module 13B, Coatings.
The Board has reviewed the program verification, as well as corrective actions, both proposed and implemented, by the Vogtle l
' Project. Based upon this review and based upon the collective ;
experience and professional judgement of the members, the Readiness Review' Board is of the opinion that the corrective actions proposed are acceptable, coatings at Plant Vogtle are ;
sound and, with implementation of corrective action, the l coatings program complies with commitments set forth in the FSAR. ;
O .
I APPROVED: .
Doug Dutton l Chairman, Readiness Review Board i Vogtle Electric Generating Plant ;
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PLANT VOGTLE READINESS REVIEW PROGRAM ASSESSMENT PLAN FOR MODULE 13B COATINGS ASSESSMENT PLAN APPROVAL k, /
TEAM LEADER: [
DATE: 2~ ib RR PROGRAM MANAGER: ,
/. # DATE: // # 5 8 /16 RR BOARD SPONSOR: / DATE: 2/!28!((
/ /
A 0209m/035-8
UNIT 2 READINESS REVIEW (O_) MODULE 13B, COATINGS ASSESSMENT PLAN 1.0 OBJECTIVE This assessment plan provides direction for evaluating Vogtle Electric Generating Plant (VEGP) Unit 2 design and construction activities associated with protective coatings.
2.0 SCOPE 7')/
-- This section describes the' project components and activities included in Module 13B, Coatings. The section also describes the scope of the assessment planned for Unit 2 activities.
1 1
2.1 MODULE SCOPE j ll Module 13B, Coatings, includes design, procurement, construction and inspection activities associated with protective coatings inside containment. Other coatings are reviewed for specific licensing commitments or industry problems.
i 0209m/060-8 1
2.2 ASSESSMENT SCOPE C
Based on a review of th'e Unit 1 module results, and on Quality Assurance (QA) audits, Nuclear Regulatory Commission (NRC) inspections, Unit 1 licensing event reports, Unit 1 coating performance, industry problems, and project program changes since the Unit 1 assessment, the Unit 2 coatings assessment will review a sampling of the follo' wing activities, items, and programs:
o Commitment implementation.
o Application of corrective action for Unit 1 findings to Unit 2 activities.
O o Design changes.
l o Material control and traceability.
l 1
o In-process application. l l
o Applied coatings. !
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o Inspection and incpection documentation, j l
o Qualification and certification of inspectors. l 1
1 0209m/060-8 2
o Cer'tification of coatings application personnel.
I o Control and turnover of documentation.
Coating samples are selected from the Unit 2 containment.
Design and inspection documents reviewed are selected from those
. relating to Unit 2 containment and, where feasible. . relating specifically to the coating samples selected for assessment.
3.0 IMPLEMENTATION The assessment will be conducted in three stages of grouped activities or parts. Part 1 is an assessment of commitment implementation and Unit 1 finding followup, Part 2 is an assessment of design and construction programs and activities, ,
and Part 3 is an assessment of completion activities and documentation.
3.1 . COMMITMENT IMPLEMENTATION AND UNIT 1 FINDING FOLLOWUP The commitment matrix data' base has been maintained current by Readiness Review. Updated implementation data-has been provided to Readiness Review by the responsible project organizations and input to'the data base by Readiness Review. In the commitment implementation assessment, the implementation data provided by 0209m/060-8 3
the project organizations will be assessed to ascertain its correctness.
(f Findings identified by either Readiness Review or the NRC during )
the Unit 1 Readiness Review process were listed by Readiness Review in a data base together with the corrective action -
applicable.to each finding. Responsible project organizations reviewed the listing, categorized the findings as to applicability to Unit 2, and verified that the corrective action to applicable Unit 1 findings had been applied to Unit 2 activities. The results of this project organization review ;
were provided to Readiness Review and input to the data base. ,
In the Unit 1 finding followup assessment, the data provided by >
the project organizations is assessed to ascertain its correctness. .
The Part 1 assessment is performed by Readiness Review as !
described above.
I i
3.1.1 COMMITMENT IMPLEMENTATION For each commitment applicable to Module 13B, review'the commitment in the source document [ Final Safety Analysis Report (FSAR) or correspondence-responding to NRC questions) and any j cited standards or reference documents. Check any listed ;
0209m/060-8 4 g w e e
cross-references. Identify any inconsistencies or conflicts as
[) " Reject". Describe the inconsistency or conflict in the
~.
" Comment" section of the checklist.
Verify that the implementation document cited on the implementation matrix satisfies the commitment.
Further direction on commitment identification and verification is found in the Vogtle Project Unit 2 Readiness Review Program Procedure 3.2.
Note: The implementation and commitment matrixes are an index and an aid to maintaining VEGP conformance to licensing commitments. The
/*
l matrixes are not, of themselves, Project commitment documents. Errors, conflicts or lack of clarity in the matrixes are not findings against the Project Quality Program and should not be marked as " Reject" on the checklists. Any such problems should be noted as " Comments" for resolution by Readiness Review.
Document results on Checklist 13B-101.
['
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0209m/060-8 5
3.1.2 UNIT 1 FINDING FOLLOWUP O
(. /
The Unit 1 coatings module identified a total of 16 findings.
Assess each of these to ascertain that corrective action has been properly applied to Unit 2.
Check that the designation of the finding as applicable or not applicable to Unit 2 is correct. Note any errors as " comments" for correction of the tabulation. For any findings with corrective action determined to be changed as applied to Unit 2, note details as " c o m m e r.'c s " for incorporation ,
section 5 of the module report.
Assess the effectiveness of the corrective actions applied to Unit 2. If this assessment can be more effectively performed in conjunction with the Part 1, commitment implementation assessment, or with the Part 2 or Part 3 assessment, so note as
" comments" and reference the applicable commitment implementation, part 2, or part 3 checklist.
. Document results on Checklist 13B-lO2.
3.2 DESIGN AND CONSTRUCTION PROGRAMS AND ACTIVITIES A sampling of documents and activities associated with coatings inside Unit 2 containment will be assess 6d to assure engineering 0209m/060-8 6
and construction compliance to design and procedure
() requirements. Engineering documents will be assessed for technical adequacy. Construction in-process application activities, material storage, and deviation reports will be assessed for compliance to applicable procedures.
Part 2 assessment is performed by QA.
3.2.1 DESIGN PROGRAMS AND ACTIVITIES Select 10 Field Change Requests and Construction Specification Change Notices to Specification X1AJ07, Field Coatings, issued or in effect subsequent to July 1, 1985, the effective date of the Unit 1 coatings module. Assess the design change documents for compliance to licensinc and procedural requirements and for technical adequacy.
Document results on Checklist 13B-201.
3.2.2 CONSTRUCTION PROGRAMS AND ACTIVITIES Select a minimum of three in-process applications of coating systems prequalified to ANSI N101.2 and Section 3 of ANSI N5.12. Include one application to steel and one application to concrete. Assess environmental testing, C:)
0209m/060-8 7
l inspection of substrate, mixing of materials, and coating
() application for compliance to application and inspection procedures. Record results of tests, batch number (s) of l
coatings, amount of thinner used, and identification of applicator and inspector.
Document results on Checklist 13B-202. )
I Identify storage locations containing coating material required to be prequalified to DBA environmental conditions. Assess storage arca and a sampling of coating materials in each area to l
l ascertain that procedural and specification requirements for l l l l storage and traceability are followed. j l
Document results on Checklist 13B-203.
1 Select 10 Deviation Reports initiated since July 1, 1985, from the Williams Deviation Report Log. Assess each report for compliance to procedural requirements.
Document results on Checklist 13B-204.
3.3 COMPLETION ACTIVITIES AND DOCUMENTATION Completed coatings in the Unit 2 containment will be sampled and assessed to ascertain product acceptability. Quality records 0209m/060-8 8
._______ - _ _ _ - _-___-__ _ _________ _ _ _ _ _ _ _ _ = _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ -
relating to the selected coating samples will be assessed for
() compliance to applicable procedures and specification requirements.
Part 3 assessment is performed by QA.
3.3.1 COATINGS, WALKDOWNS, AND DOCUMENTATION Select 10 samples of completed coa,ings inside Unit 2 .
containment. Samples selected should include:
o Coating on concrete floor.
o Coating on concrete wall or ceiling.
o Coating on steel liner plate.
o Coating on structural steel.
o Coating on embed.
l o Coating on pipe support, electrical support, or heating, ventilation and air conditioning support.
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0209m/060-8 9 l li g
o Coating on supports in the dome area.
O o Coating on dome liner plate.
perform visual examination of coating for discrepancies in accordance with applicable inspection procedure. For coatings
)
on structural steel, measure and record dry film thickness. l Note location of sample.
Obtain inspection documentation for coating samples selected.
Assess inspection documents for compliance to inspection procedure requirements. Check that application and environmental data recorded on the inspection report meets the requirements of the application procedure. Check that dry film thickness measured during walkdown meets application procedure requirements. Record names'or identification of inspector and applicator. Record coating product and batch number.
Document results on Checklist 13B-301.
l l 3.3.2 MATERIAL TRACE 7.BILITY l
l Select four of the coatings batch numbers from the walkdown and documentation assessment or from the in-process application assessment. Review contractor's warehouse records to ascertain f that required receipt and issuance record for that batch is k>
f 0209m/060-8 10
maintained. (Specification X1AJ07, Quality Documentation Forms,
) example 3). Check GPC receiving records to ascertain that required manufactursrs certificates are on file.
Document results on Checklist 13B-302.
3.3.3 INSPECTOR QUALIFICATION AND CERTIFICATION Select six inspectors who performed the inspections reviewed during the walkdown and documentation assessment or the in-process application assessment. Review the inspectors qualification and certification records to ascertain that he was certified to perform the inspection at the time performed, and that the record package reflects that he was qualified to be certified (e.g., eye examination, high school graduate, use of test equipment, experience).
Document results on Checklist 13B-303.
3.3.4 APPLICATOR CERTIFICATION Select six applicators who applied the coatings reviewed during the walkdown and documentation assessment or the in-process application assessment. Review the applications certification I
O 0209m/060-8 11
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record'to ascertain that he was certified to apply the coating-at the time of application.
-J Uocument results on Checklist 13B-304.
l 4.0 GENERAL INSTRUCTIONS l 1
Additional instructions for performing assessment activities are cont'ained in the Vogtle Project Unit 2 Readiness Review Program I Procedures Manual. In particular, personnel performing the assessment activities outlined in this plan should be familiar with the requirements of procedures 2.3, Responsibilities; !
i 2.4, Qualifications; 3.5, Unit 2 Assessment; and 4, Readiness Review Task Force - Quality Assurance Interface.
4.1 CHECKLIST COMPLETION INSTRUCTIONS 1
An individual checklist is to be used for each component i assessed. The checklist column marked " item" provides a .
numerical reference if needed wh en corresponding with the Project. Numbers in this colur.1 in parenthesis () indicate ,
I reference to the Master' Commitment Tracking List. The column, I I
marked " reference" provides the source of the requirement to be i verified. The column marked " requirement" is repeated from the l
source document. l
-.O 0209m/060-8 12 e r.,s-- s.- m .~. c
The column marked " finding / comment" is for explanatory materials and recording of supplementary data. Comments entered on the checklist should include as appropriate:
e o A description of the actual condition found.
o Document filing locations and hardware identification to permit tracing the specific documents and hardware i
reviewed.
o Data gathered during reviews to facilitate interrelating assessment attributes.
o Any necessary explanation of assessment activity and methods, concerns, findings, or issues requiring further ,
assessment.
o An explanation for all reject conditions found.
o An explanation for reject conditions closed by further assessment without a finding.
A checkmark in the acceptable column indicates that the condition found is acceptablo. An N/A in the acceptable column indicates that the attribute listed is not applicable. An N/V entry in the acceptable column indicates that the attribute was 0209m/060-8 13
not verified (due to accessibility, work in progress, etc.).
( N/A and N/V entries require a short explanatory statement in the Finding / Comment column, (see 4.2 below for direction in substituting items).
i A checkmark in the Reject column indicates that the requirement of the checklist item was not met at the time of assessment. If the reject column is marked, add a brief statement in the finding / comment column explaining the basis for rejection. The Resolution column is used to indicate whether a Readiness Review Finding or Audit Finding Report was issued, or if the Project was able to provide sufficien't information to close the item.
I.
The checklists are to be signed and dated on each page by the person or persons performing the assessment and are to be completed neatly and legibly in black ink. Original checklists j are to be returned to Readiness Review for storage.
( 4.2 SAMPLE REPLACEMENT OR REDUCTION The selections for assessment indicated on the checklists may provo inadequate for evaluation due to attributes not applicable to selections or for other reasons. In such cases, additional items, components, or attributes are to be selected for assessment in the-following order of preference:
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0209m/060-8 14
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- 1. Additional components or attributes from the items, procedures, or standards already selected for assessment.
i
- 2. Additional items or components from the population of items and components within the systems selected for !
assessment.
- 3. Additional items and components from the population of items and components in other systems within the scope of the module.
l l
Plans for expanding or reducing the sample size, or concerns that the sample may be inadequate, shall be reviewed with the Readiness Review program manager, who will provide direction.
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0209m/060-8 15 I i
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ATTACHMENT 1 CHECKLISTS O
o 13B-101 Commitment Implementation o 13B-102 Unit 1 Finding Followup o 13B-201 Design Change Documents o 13B-202 In-process Application o 13B-203 Storage o 13B-204 Deviation Reports o 13B-301 Walkdown and Documentation o 13B-302 Material Traceability o 13B-303 Inspector Certification and Qualification o 13B-304 Applicator Certification 7
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0209m/060-8 16
O O O READINESS REVIEW CHECKLIST .
. NO. RR- /3 8- /o/
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O O O PLANT kOGTLE UNIT 2 READINESS REVIEW PROGRAM INSPECTOR CERTIFICATION CHECKLIST INSPECTOR RR REVIEW BY EMPLOYER DATE _
ACCEPT (A)/
R_ESULTS/ COMMENTS REJ ECT (R)
, __ _ _ _ _ _ _ _ __ _ R EQ UI RE MENT I. Resume in file?
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(Is it cur rent through last certification date?)
II. Proof of high school diploma or GED?
(List high school and date graduated)
III. EYE EXAMINATION (for period June 1985 to present)
Period Was Examiner Accept (A)/
Exam Date (From - TO) Near Vision Far Vision Color Qualified Reject (R)
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IV. Are there any periods in eye exam dW history that have not been s .
I rectified by a later acceptable eye exam?
- s. g 7-w d V PLANT'VOGTLE UNIT 2 READINESS REVIEW PROGRAM INSPECTOR CERTIFICATION CHECKLIST INSPECTOR ,, ___
RR REVIEW BY EMPLOYER DATE V. CERTIFICATIONS (in ef fect June 1985 to present)
Certification Period Academic E xper ie nce Annual Accept (A)/
Area (From - TO) Requirements Requirements Performance Reject (R)
Met (verify Met (if waivers - Report For against is it justified; Each Year curriculum) i f prior experi- Cert, is in e nc e, how was it effect, verified) located in package?
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