ML20091B588
| ML20091B588 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/25/1984 |
| From: | Lettieri V, Oechsle S, Taylor J BROOKHAVEN NATIONAL LABORATORY |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20091B572 | List: |
| References | |
| NUDOCS 8405300337 | |
| Download: ML20091B588 (9) | |
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April 25, 1984 l
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i U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV l
1 INTERIM REPORT ON PROTECTIVE C0ATINGS e
PREPARED BY BROOKHAVEN NATIONAL LABORATORY LICENSEE:
Texas Utilities Generating Company i
2001 Bryan Tower Dallas, Texas 75201 FACILITY:
Comanche Peak, Units 182 Glen Rose, Texas l
/
J dk TECHNICAL SPECIALISTS:
(((dk t
v<ncent Letriert (cate) 6 T 7-2d 9/b
- s. John Oechsle*
(date)
APPROVED:
V fMV John H. Tdylor (dater) s
- Stephen G. Ptnney and Associates O
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CONTENTS I
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I N T R OD UC T I O N.....................................................
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!!. BAC K GR OU ND.......................................................
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!!!. INFORMATION REQUIRED TO DETERMINE ADEQUACY OF APPLIED PROTECTIVE l
COAT INGS THROUGH THE BAC KF IT PROGR AM.............................
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i IV. FINDINGS RELATED TO THE ADEQUACY OF APPLIED PROTECTIVE l
C OA T I N GS.........................................................
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l V.
S UMMAR Y A N D C O NC L US I O N S..........................................
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l INTRODUCTION l
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This is an interim report in response to an hRC Region IV recuest to item-i tre the inforriation that is necessary to assess the adequacy of the Applied l
Protective Coatings Backfit Progran at Comanche Peak Steam Electric Station (CPSES). Units 1 & 2.
That information is contained in Section !!! of this
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report.
The remainder of the report is organized as follows:
I Section !!:
Provides historical background related to CPSES and GNL's work to date Section !!!: Outlined above Section IV:
Summary of findings to date Section V Conclusions The major portion of DNL's effort to date has been in evaluating approx.
imately 60 allegations. A report on this subject is due April 30, 1984 i
t it. MCKr.ROUND 1
There are two major reasons for applying protective coatings inside the reactor containrent building.
The first reason is to protect exposed carbon Steel surfaces from corrosion.
The second reason is to provide for easier decontanination, which also reduces the level of occupational radiation expo.
j sure.
If coatings are not properly applied and subsoouently fail, they can have i
an adverse safety impact by clogging pump strainers, taray nozzles, and fan filters which can degrade safety equipment operation.
l This is more than a theoretical concern since a number of protective coatings failures have occurred at nuclear power stations.
For e nmples o Beaver Valley (1975) - During construction, the coatings failed on the containment done.
o Brunswick 2(1980)- During operation, coatings fatturt occurred below the torus water line, o Dresdnn 2 (1971)
During operation,' Torus coatings failure occurred.
o Peach Gotton 2(1971,1973)- Ouring prooperational testing, torus coatings failure occurred.
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I In 1981 Region IV of the NRC conducted an inspection of protective coat-f j
tras at Comanche Peak. As a result of this inspection (Inspection Report
- 81-15), a Notice of Violation was issued regarding fatture to follow quality I
assurance crocedures for the inspection of protective coatthos. From late Septenber 1970 through October 1981, documentation for protective coatings was 1
not maintained or was incomplete. As a result of this notice of Violation, 1
Comanche Peak instituted a Backfit Progran to vertfy that the applied protec-tive coatings were themselves adequate even though adequate documentatton did i
not exist.
Starting in 1983, numerous individuals have made allegations concerning the adequacy of the applied protective coattnqs at Conancho Peak.
Brookhaven National Laboratory (BNL) was contracted to provide technical assistance in perforntno on site inspections of the protective coatings l
program at Comanche Peak.
The work, 43 stated in the contract, is to " Provide
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technical assistance in perfurning an inspection of the protective coatings t
progran at the spectfled Nf0L nuclear power plant.
This inspectton wt11 include the enanination of site procedures and verification of tNo adequacy of l
these procedures anainst standards and FSAR connitnents, the adequacy of
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i applied coattnas, the adequacy of rework, and the procedures governing rework, i
the adequacy of vertfication testing, and the adequacy of completed quality records. Also included in the scope of this task will be the followup on l
specific technical questions contained in sworn testinony fron persons making l
allegations of the adequacy of the protective coatings progran."
I The responsibility f(r reviewing the statistical adequacy of the licon.
see'sBackfitProgran,(t.o.,sanpitnatechniques,acceptancecriteria,etc.)
has been assigned to the hRC Auxtlfary Systens Granch. With the concurrence of hRC Region IV, a meeting was held between ASD and Bhl on April 2,1984 The outcome of this neettna was that additional statistical infornattun is i
required.
This information has ben incorporated into Section !!! of this report.
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!!!, thr0PMAfl0N pt0VIRED TO DETERHlhE ADE00ACY OF Apf L!CD PROTECTIVE
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COMI%h THHt) UGH THl; H At;kF IT PR@W AM_
-t Dated on interviews with various personnel on the licensee's staf f, it is ONL's understanding that the Backfit Program is limited to the primer coatings applied prior to the NRC's issuing Notice of Violation, inspection Report No.
81 15.
That is to say, no statistical analysis of Cleometer adhesion pull tests and fooke Scratch tests was perforned for coatinal applied since the NRC tssued its violation and for the too coat that has been applied since the coattnas application first began.
Therefore, if this understanding is accu =
rate, BNL does not believe that the Backfit Program will be yteful in deter.
l mining the adequacy of applied coatings as far as total coating systen is concerned.
It is understood that in sono if not all cases, the testing nJy have t'een perforced for the total sygten.
However, the licenseo chose to perform a stattstical inalysis only in regard to the primer coat, and does not i
address the statistical sinnificance of test results for the total coatinos I
systen.
This will be resobed when the required information is supplied by the Itcensees i
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Information Recuired i
Note: The information requssted in this section should be provided in revinw-able form to BNL or made available at the site.
A.
Procrammatic 1.
Provide the document or series of documents that explains the Backfit Program in its entirety.
2.
What is the estimated total square footage of applied coatings in Unit 1 containment? What portion of the total applied coatings t
represents coatings applied to concrete surfaces, miscellaneous steel and containment liner plate?
3.
Provide the location and boundaries and define all areas that have been exempted from the Backfit Program. Also provide the justifica-tion for the exemption.
4 Provide the percentage of the three ma,jor areas (see Question 2),
that was included / exempted in the Backfit Program.
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Trainino Provide the operating procedure for instruments used during tho Backfit Program.
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Provide indoctrination and training records that denonstrate that those individuals performing testing for the Backfit Program were qualified.
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Provido procedure reference for field checking of instrunents during the Dackfit Program.
C.
Instrumentatinn and Testing 8.
Provide instrument history / calibration records of each instrument l
used in the Backfit Program.
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Provide the method used to evaluate and account for instruments found.
to be out of calibration during the Backfit Program. How was and is i
the deviatinn incorocrated in reporting Elcometer Adhesion Test t
results?
Additionally, for an instrument found out of calibr,ation, provido docurentation that shows that all tests done with that instrument since its last calibration were invalidated. Also, provide the procedure used to handle those inspection reports writton after the instrument went out of calibration.
10.
If not penvided in the answers to Questions 7 and 8, provide the total number of instrunents used in the Rackfit Prooram.
Provido the t
type and serial number of each instrument.
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Statistical 11.
Provide the total number of individual pull tests performed and the number of individual pull tests that failed for each of the three j
major areas (see Question 2).
12.
Provide the final calculations for each of the three major areas (see Question 2) that demonstrate the estimated failure rate with its associated confidence limits, for each of the three major areas individually.
IV. FINDINGS RELATED TO THE ADEQUACY OF APPLIED PROTECTIVE COATINGS.
A.
Testina l
1.
BNL has performed independent tests on the protective coatings at the site. On a random basis, 6 areas of approximately one hundred (100) square i
feet were chosen at various elevations and various azimuths.
Two areas i
represented liner plate, two areas represented miscellaneous steel and two areas represented concrete surfaces.
In each area, five (5) test dollies of approximately 1/2 square-inch were glued to the protective coatings and a pull of 250 psi was applied to the test dollies.
If a dolly separated from the
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surface, the force that caused the separation was recorded.
If the dolly did j
not pull off the surface at 250 psi, a reading of 250 psi was recorded and the dolly was knocked off of the surface after the instrument had been returned to
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a reading of zero and removed.
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For the liner plate, a failure rate was exhibited' of 4 out of 10, or I
Failures occurred in both test areas with corrected readings of 156, 186,,40'..
t 186, and 186. For miscellaneous steel, no failures were recorded in ten (10) 2 tests, and for concrete surfaces, a failure of the concrete was experienced at a corrected reading of 156 ost for one test and no failures of the protective coatingsinnine(9) tests.
1 InadditiontoE1cometeradhesionpulltests,30Tooke(scratch) tests were performed adjacent to the pull tests.
No "out of specification" condi.
r tions were recorded in the dry fim thicknesses testing.
BNL's observed failure rate for the liner plate is unacceptable. 'Althou1h it was limited in scope, it raises questions about the adequacy of the Backfit Program for the liner plate.
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2.
During the week of March 18. 1984, BNL observed an area at approxi-mately elevation 860 and azimuth 175 of the liner plate that was being repaired because of recent unacceptable adhesion test readings and visible i
deterioration.
This same area had acceptable adhesion test readings durinq initial backfit testing in December 1982.
This again raises doubts about the adequacy of the Backfit Program for the liner plate.
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Prncedural 3.
Contrary to good industry practice, solvent has been used excessively to wipe down primed surfaces prior to the top coat application.
Excessive solvent retention will inhibit the curing of inorganic films and can lead to coatings failure under operating conditions.
The licensee's procedures do not provide direction or caution on solvent use, nor is there evidence of proper training to this offect.
In three areas of coating system failures on the containnent Ifner plate. BNL observed a solvent odor that was far in cxcess of what would be considered nornal.
4.
Contrary to CPSES FSAR Section 1A(B), Regulatory Guide 1.58. and ANS!/ASME N45.2.6-1978 Section 4 and Table 1. Level 1 Coatings QC Inspectors have been naking judgments and evaluations that they are not qualtfled to i
nake.
Examples of this were evident in procedures where level ! inspectors were:
a) evaluating surface preparation without instruments or approved visual standards, b) evaluating the adequacy of coatinos materials when its " pot 11fe" had been exceeded, and c) ovaluating the acceptable extent of overlap-ping dry spray beyond the specific areas to be coated.
5.
Contrary to Gibbs & Hill, Inc., Protective Coatings Specification flo. 2323-AS-31, Revision 1 tiarch 15, 1978 for CPSES. Section 6.1 b and Brown and Root. Inc. letter BRV-12605, dated May 7,1984 to Tin Dolen, Cartoline Company fron D. C. Frankum, Project ftanager, proper surface preparation wts not achieved.
Instruction Number O!-0P 11.4-5 allows 80 grit " flapper wneels" i
versus the 60 grit "flappor wheels" used to qualify surface preparation.
6.
BNL has identified numerous procedural deficiencies. A summary of some of the more serious deficiencies follows:
a)
ContrJfy to good industry practice and 10 CFR Part 50, Apcendix 0 Criterion V; 1)
The procedures are not " stand alone" documents, acceptance criteria are found in other referenced documents.
2)
Procedures such as Instruction Nunber 01-0P-11.4-1, and Q!-QP-11.4 5 reoutres a flashlight to be held perpendicular to the inspection surface only.
Proper inspection technique would require a light to be positioned parallel to the surface to locate certain types of defects. Additionally, the mininum 11gnt reautred is not specified.
3)
Procedure 01 0P 11.4 1 paragraph 3.1.2, states that for Jbra-sives "... All grease,, oil, and deleterious material is unac=
coptable", and yet provides no methods to determine if these l
natoriJIs are present.
Thq procedure also does not define deleterious natorial.
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b)
Contrary to 10 CFR 50 Appendix B Criterion V and CPSES FSAR, para-graph 17.1.1.5, the final coatings walkdown procedure contained no l
acceptance criteria and did not contain appropriate instructions regarding hidin4 Quality, cracking, delamination, peeling, excessive h
overspray,excessiveroughness, flaking, blistering,orcracking.
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conjunction with inadequate inspection procedures, this could allow I
acceptance of inadeouate coatings.
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Contrary to CPSES FSAR, page 1A(0)-22; R. G.1.54, and ANS!
N101.4-1972, paraoraph 4.4.3, CPSES coatings procedures allow weld i
splatter to renatn on metal surfaces. This could contrthute to coatings failure.
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Contrary to CPSES FSAR, page 1A(B) 22; R. G.1.54, and ANS!
N101.4-1972, paragraph 5.2.2, CPSES coatings procedures provide for the writing and approval of special coatings procedures, without the approval of the coating manufacturers.
e)
Contrary to CPSES FSAR, paragraph 6.10.2 and ANSI N.101.2 coatings f
applied over "drypack" concrete repairs were not t,0A cualtfled, i
Additionally, the "drypack" does not appear to meet paragraph 6.4.2 of ANSI N101.2 1972.
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Documentattnn/0aston conten!
7)
Based on a brief review of Design Change Authorizations (DCA's) written in the coatings area, it does not appear as thouoh Quality Assurance is included in the review and approval chatn, as would be required by 10 CFR 50 Appendix B, Criterton !!!. Also, there is no fornal nochanism to ensure that users of controlled coptos of the Coatino Specification have received and are aware of all anplicable OCAs. Finally, there 15 no requirenent for spect f tcation revist an after DCA's nave been issued against it, either based on tine or nunber of OCA's. Additional review in this area is needed to i
determine how quality is assured in the DCA program, 0)
Contrary to FSAR Section 6.10.2,ANS! N101.2, Section 4, a nunbar of Coatings systems have been specified and used that have not been 00A
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qualtfled. Af ter identification of this by ONt., tno Itcensee has I
comnitted to submitting these coatings systens to the appropriate DBA -
l testing.
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ContrarytoFSARSection1A(B),RegulatoryGuide1.54SectionC.4, i
"$TAF Hospital Soray Disinfectant"', en aerosol containinq chlorides, was used by oainters Instdo containment where stain lvis steel 15 located.
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A nureer of the 60 allegations against CP$tS's protective coatinas l
Have been substantiated and additional alle9ations N y be substan.
- tlated, The status of all 60 allocations will l'o stated in a follow up report due Apri1 30, 1904,
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V.
Suf*AR f AND CONCLUSIONS 1.
An adequately conceived and properly implemented Backfit Program will permit an evaluation of the applied coatings at Conanche Peak.
The informa-j t
tion requested in Section !!! of tnis report will permit an assessment of the i
Itcensee's Backf tt Progran.
t 2.
As demonstrated in Sections IV 8 and C. the coatings procedures and destqn control foa coatings at CPSES appear to be inadequate to assure the specification of proper coatings systems and the application of coatings, once they are specified. As such, no determination can be made as to the acequacy of coating for the following applicationst a) any repate work completed i
subsequent to the backftt testing, b coating applications not included in the l
Scope of the Backfit Program, and c))all coating work for Unit tio. 2.
i 3.
As stated in section IV A, and further retnforced by Conclusion number 2, the Ifner plate Coating apDears to be inodoquete.
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