ML20129J261
| ML20129J261 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/23/1984 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20129J236 | List: |
| References | |
| FOIA-84-487 EA-83-132, NUDOCS 8506100045 | |
| Download: ML20129J261 (12) | |
Text
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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ) Docket Nos. 50-445
) 50-446 TEXAS UTILITIES GENERATING )
COMPANY, et al. ) Permit Nos. CPPR-126
~~ ~~
) CPPR-127 (Comanche Peak Steam )
Electric Station) ) EA No.83-132 LICENSEES' ANSWER PROTESTING CIVIL PENALTY On December 22, 1983, the NRC Staff ( Region IV) proposed a S40,000 civil penalty in the captioned ,
enforcement action against Texas Utilities Electric Company,1 et al. (" Licensees") for an alleged violation of Pursuant to 10 C.F.R. Part 50, Appendix B, criterion I.
10 C.F.R. I 2.205 Licensees hereby respond to that Proposed Imposition of Civil Penalty.
I. Denial of Violation For the reasons set forth in Section II of
" Licensees' Response to Notice of Violation" (incorporated herein by re ference) , Licensees deny the alleged violation l
l and respectfully request that the proposed civil penalty l
be withdrawn in full. Alternatively, Licensees request .
that for the reasons set forth in Section III of i
1 Please note that CPPR-126 and CPPR-127 were amended on December 30, 1983, to re flect the substitution of Texas Utilities Electric Company for Texas Utilities l
! Genersting Company as a licensee.
8506100045 850110 A PDR FOIA HUGE 84-487 PDR g[
o 9
" Licensees' Response to Notice of Violation" (also incorporated herein by reference), the proposed civil penalty be mitigated in full.
II. Extenuating Circumstances The extenuating cirewastances which Licensees believe warrant the withdrawal or complete mitigation of the proposed civil penalty are set forth in Section IV, below.
III. Error in the NOV Licensees submit thas the Notice of Violation and Proposed Imposition of Civil Penalty ("NOV") is incorrect.
t First, contrary to the Atomic Energy Act and the NRC Rules of Practice, the NOV fails to identify with adequate specificity the date, facts and nature of each act with which Licensees are charged. Second, the NOV fails to take into account responsive actions Licensees initiated f?h'o' '2m '
prior to this enforcement action. Because of these errors the proposed imposition of a civil penalty is inappropriate. .
Failure to Disclose the Basis for the NOV. Section 234(b) of the Atomic Energy Act provides that when NRC has reason to believe that a person has become subject to the imposition of a civil penalty, NRC must notify such person in eriting " setting forth the date, facts, and nature of n
(
^
}
each act or omission with which the person is charged ..
1
. ."2 This requirement is reflected in 10 C.F.R. $
2.205(a).
In Radiation Technology, Inc.3 the Atomic Safety and Licensing Appeal Board addressed the questjan of whether the Staf f provided a licensee with adequate notice of an alleged violation as required by the Atomic Energy Act and NRC Rules of Practice when proposing a civil penalty. The Staf f in Radiation Technology, Inc. alleged in the Notice of Violation and Proposed Imposition of Civil Penalty instances of excessive radiation at two specified .
locations and at "several locations" not identified.4 The licensee requested a hearing on the civil penalty, during which the Staff attempted to submit evidence relating to the areas of excessive radioactivity not specifically identified earlier. The presiding officer declined to ad. nit such evidence. The Appeal Board upheld his ruling on the grounds that a " licensee is entitled to notice of 2 42 U.S.C. $ 2282(b).
3 ALAB-567, 10 NRC 533 (1979).
4 Radiation Technology, Inc. ALJ-78-4, 8 NRC 655, 658 (1978), af f'd in part and rev'd in part, Radiation Technology, Inc. ALAB-567, supra, 10 NRC 533.
e i specific violations before civil penalties may be imposed" and that a reference to excessive radiation at "several locations" did not provide such notice.5 Licensees submit that they have not received notice of the specific violations for which the Staff proposes to issue a civil penalty as required by Section 2.205. Among other things, the NOV fails to identify the OC inspectors who were not provided sufficient organizational freedom, the identity of the OC supervisor allegedly intimidating personnel working for him, and when and under what specific circumstances the alleced intimidation took place.
The Report of Investigation 6 issued along with the NOV is equally uninformative. It refers to two meetings scheduled by the " supervisor in question" but does not state where and when the meetings took place. The Report also notes the existence of " additional craft management _
complaints," yet fails to identify the content of any
^'
craft management complaints.
_ Lastly, the Report states that onc QC inspector did not report defects for fear o f
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5 Radiation Technology, Inc., ALAB-567, suora, 10 NRC at 549 n. 51.
6 Report of Investigation, Comanche Peak Steam Electric Station, Intimidstion of Coatings QC Personnel, Case No. 4-83-001, A_ gust 24, 1983 (" Report of Investigation").
o O
e reprisals. However, the, Report does not disclose either the identity of the inspector or of the so-called defect allegedly not reported.
At bottom, just as in Radiation Technology, Inc.,7 where the NRC Staff provided insufficient in fo rma tion, here the Staff has not satisfied the requirements of law because it has failed to provide Licensees with the factual basis for its claim that Appendix B, Criterion I was violated.8 For this reason, Licensees submit that the NOV is erroneous and that the civil penalty in this ,
proceeding should be withdrawn.9 i
7 ALAB-567, supra, 10 NRC 533.
8 In Connecticut Light and Power Company v. NRC, 673 F.2d 525, 530, cert. denied, 51 U.S.L.W. 3254 (1982), the Court observed that "to allow an agency to play hunt the peanut with technical in forma tion, hiding or disguising the information that it employs, is to condone a practice in which the agency treats what should be a genuine interchange as nere bureaucratic s po rt. " Although the observation was made in l connection with the duty of NRC to disclose the
' technical basis for proposed rules, Licensees submit that it is equally (if not more) applicable here, where Licensees must respond to claims made by NRC or face a substantial civil penalty.
9 Inlile Licensees may have investigated the alleged incident of harassment, their inquiry did not focus on -
the question of how NRC perceived the incident or on i
uncovering any information in the possession of NRC.
Therefore, Licensees' investigation does not change the fact that it simply has no way of knowing the staf f's underlying factual bases for the instant enforcement action. ?4oreover, the fact that Licensees investigated the incident does not absolve NRC from its legal duty to disclose the anderlying bases of this enforcement action.
O
o One additional point should be noted regarding this deficiency in the NOV. Two goals of the Enforcement Policy are to obtain prompt corrective actions and to deter future violations of NRC requirements.10 The NOV cannot serve these goals if the licensee is not informed with specificity of the facts on which an alleged violation is based. A licensee cannot formulate its responsive actions and evaluate the effectiveness of those actions unless the factual bases for the enforcement action are known. Similarly, future violations of NRC requirements cannot be deterred by enforcement actions unless the underlying bases of a violation are identified so that the licensee will know precisely how its conduct violated NRC requirements. There fore, apart from the ^
requirements of the Act and the Rules of Practice requiring NRC to disclose with specificity the facts surrounding an alleged violation, sound enforcement policy also dictates that NRC reveal the underlying factual bases for the alleged violations in this proceeding.
Mitigating Factors. The Enforceinent Policy states that the promptness and extent to which a licensee takes corrective action, including actions to prevent recurrence, may be considered in modifying the civil 10 10 C.F.R. Part 2, Appendix C $ I.
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e penalty to be assessed.ll When applying this provision, the Staff has in the past considered mitigetion prior to proposing civil penalties formally. There have been approximately thirty-two Notices of Violation issued for severity Level III violations where no civil penalties L
have been proposed.12 In at least some of them civil <
penalties were not proposed because of a licensee's prompt and extensive corrective action.13 i i
Despite the provision in the Enforcement Policy {
allowing mitigation and the past practice of the Staff to consider mitigation prior to proposing a civil penalty, there is no indication that the Staff at any time even considered responsive actions taken by Licensees here before NRC issued the Proposed Imposition of Civil Penalty. On September 28, 1983, Licensees responded to the Notice of Violation and Proposed Imposition of Civil Penalty in EA No. 83-64. In that response they set forth numerous responsive actions, all of which have been j
11 10 C.F.R. Part 2, Appendi:t C, 4 IV.B.2. .
12 SECY-93-487, " Revised General Statement of Policy and Procedure for Enforcement Actions," November 29, 1983, (SECY-93-487) at 3.
13 See, e.g., 7anuary 6, 1984, letter from Thomas E.
Murley, Regional Administrator, Region I, U. S.
Nuclear Regulatory Commission to Mr. J. J. Carey, Vice President, Nuclear Division, Duquesne Lighting Co.
regarding Enforce.nent Conference 50-334/83-27.
m
e . ll
.g-implemented 14 Licensees committed to these actions well before the instant enforcement action was initiated by NRC. Indeed, because Licensees were aware in September, 1983, of the allegstions involving harassment raised in this proceeding, they developed generic actions specifically designed to address such issues.
Our concerns in this regard represent far more than a disagreement with the Staf f over the correct procedures to be followed when proposing a civil penalty. Instead, they raise fundamental questions as to the basic fairness of this enforcement action. As the Staff is aware, most licensees believe that they are "tried and convicted in
,C the press" when NRC proposes a civil penalty, and that even if the penalty is subsequently mitigated or remitted, O
the damage to their reputation has already been inflicted.15 Moreover, the Staff has conceded that it takes escalated enforcement actions in part because of the :-
bad publicity they generate.16 ;
14 These and other responsive actions are set forth in Section II of Licensees' Response to Notice of Violation in EA No.83-132, and are incorporated here by reference.
15 SECY-83-487 at 2.
16 During a January 4, 1984, briefing by the Staff on the En forcement Policy, Commissioner Gilinsky asked the Director of Inspection and Enforcement whether the NRC was trying to deter future violations through the threat of bad publicity or through the actual imposition of civil penalties. The Director (footnote continued)
6 AccordIngly, it is particularly unfortunate that the Staff did not consider mitigation prior to proposing the civil penalty in this proceeding. The mere proposal of the civil penalty has already done considerable damage to the Licensees' reputation, and subsequent mitigation (which we obviously seek as an alternative to total withdrawal of the enforcement action) will not repair the damage. In short, it is difficult to understand'what valid regulatory policies were served by proposing a civil penalty in this proceeding without first considering prior responsive actions initiated by Licensees.
Finally, Licensees again wish to emphasize that the responsive actions set forth in Section II of its Response to Notice of Violation are not designed merely to address specific alleged violations. Rather, they are programmatic in nature. Moreover, by any objective measure, these actions are comprehensive. There fore, given Licensees' responsive actions, we submit that the civil penalty in this proceeding should be withdrawn or mitigated fully.
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(footnote continued from previous page) responded, "I think a combination. I think it's more the publicity than the amount of money." Transcript of January 4, 1984, Commission Meeting, " Discussion of NRC Enforcement Policy" ("Jan. 4, 1984 Tr.") at 10.
4 . .
J e
IV. Extenuating Circumstances Licensees believe that the instant enforcement action was not taken in a timely manner. Because of this and the extensive corrective actions to which Licensees have already committed, no valid regulatory policy will be furthered by imposing the proposed civil penalty.
Therefore, Licensees submit that it should be withdrawn.
During the January, 4, 1984, Commission meeting on the Enforcement Policy, the Staff represented that it takes about ten weeks from the tims m. alleged violation ,
is identified until a resulting enfoecement action is commenced. However, the Staf f added that in certain cases, such as Where an investigation is involved, the period could exceed ten weeks.17 When measured against these standards, the instant enforcement action is clearly not timely. The Report of Investigation indicates that the investigation into the matter took eight months. That inquiry was closed on August 3, 1983. The NOV was issued on December 22, 1983.
The Staff has recognized correctly that when enforcement actions are not taken on a timely basis, their effectiveness is limited. It has stated in this regard as follows:
17 Jan. 4, 1984, Tr. at 36.
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e In the past, civil penalties have frequently been proposed months after a violation was identified and corrective action taken. In thest cases, issuance of a civil penalty probably had little remedial effect and may have had a negative effect on licensee morale.18 The instant case is a model to illustrate this point.
Here the civil penalty was proposed nearly five months after a violation was finally identified and nearly four months after generic corrective actions were taken.
Additionally, many of the individuals apparently involved in the incident, including the Oc supervisor who allegedly '
intbnidated OC personnel, are no longer employed at Comanche Peak. To impose a civil penalty under such conditions is inappropriate and unfair, could clearly
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undermine morale and has no valid policy justification.
Lastly, we note that on January 10, 1984, NRC Region II notified a licensee thst the Commission decided not to propose a civil penalty for an alleged violation involving a material false statement. The violation was categorized as Severity Level III. The Commission declined to propose a penalty because the violation was over one year old and substantive improvement had been made to prevent .
i 18 SECY-83-487 at 4. Commissioner Gilinsky stated recently that timely enforcemeat is needed because "as we know, with children and pets and other such instances, if a penalty comes late, it can be down-right harmful." Jan. 4, 1984, Tr. at 34.
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e recurrence of the problem.19 It is difficult for Licensees in reviewing the results of that case to ,,
understand the reason for such disparate treatment here.
Therefore, because the instant enforcement action is not t
timely and in view of responsive actions already implemented, Licensees submit that the proposed civil penalty should be withdrawn. I V. Conclusion For the reasons set forth above, Licensees request that the proposed civil penalty be withdrawn or mitigated t in full.
January 23, 1984 .
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19 Janaury 10, 1984, letter from James P. O'Reilly, Regional Administrator, Region II, U. S. Nuclear Regulatory Commission to Mr. E. E. Utley, Executive Vice President, Carolina Power and Light, regarding Proposed Imposition of Civil Penalty in EA 83-88.
TEXAS UTII ITIES GENERATING COMPANY
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May 31, 1984 n ._ -.
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I. 1 Mr. Richard L. Bangart, Director I Nf Region IV, Comanche Peak Task Force JUN - 41984 J (Jnited States fluclear Regulatory Commission .J 611 Ryan Plaza Drive, Suite 1000 3 k
Arlington, TX 76011 !
_ _ _ _ _ _ _.. ... __ ..J
Dear Mr. Bangart:
Your letter of flay 23, 1984 transmitting the " Interim Report on Protective Coatings" prepared by Brookhaven flational Laboratory and dated April 25, 1984 requested additional information (identified in Section III of the report) in order to complete your review. While the information requested is generally available or obtainable and can be transmitted to you or reviewed on site at your request, we would like to propose an alternate approach.
Our review of the Brookhaven report indicates basic philosophi-cal differences, and to a very large degree, a misunderstanding of the purpose and scope of the backfit program established by us in partial response to I&E Report flo. 81-15. In view of our fuel load schedule and your policy in avoiding unnecessary delays, we believe that a meeting with you and your subcontractor is essential to reso-lution of these protective coating issues. We, therefore, reouest that such a meeting be established at the earliest possible date. -
Thank you for your consideration.
Sincereh, ,.
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JBG: pew cc: T. Ippolito 6
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.4 DEVinlON 09' TEXAN t'TEL8 TIEN ELECTRIC t'O.%ti*.sN1*
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TEXAS UTILITIES GENERATING COMi%NY P o box 1002 GI FN HOSE. TEX.AS 76043 July 16, 1984 TXX-4225 -
Dockets: 50-445 50-446 Mr. Richird L. Bangart, Director Region IV Comanche Peak Task Force United States Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 BROOKHAVEN IKIERIM REPORT ON PROTECTIVE COATINGS FILE NO. 906.1, 10010
Dear Mr. Bangart :
This responds to your letter of May 23, 1984, relative to the interim report on CPSES protective contings prepared by Brookhaven National laboratory (BNL). We have previously responded to each of the sixty allegations that you had received relative to the adequacy of protective coatings at CPSES (Letter: TXX-4201, dated June 22, 1984).
The attached responses provide information relative to Section III of the BNL Interim . Report. We plan to provide a written response to Section IV of the BNL Interim Report on or be fore July 20, 1984.
Please advise if you require additional information.
ince v, I. Mer t , Jr' sista t Projec Manager JTM:la cc: Mr. Thomas A. Ippolito Mr. John Collins (w/o documentation)
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- Question III.A.1 Provide the document or series of documents that explains the Backfit Program in its entirety.
Response III. A.1 On September 14-18, 1981 TUCCO QA Audit TCP-24 was perforced on Protective Coatings at CPSES. The findings of this audit ident ified deficiencies and concerns related to the Protective Coatings QA Program. The NRC's Region IV found the same de ficiencies in the Program and reported its findings Docket 50-446/Rpt 81-15 and Docket 50-445/Rpt 81-15 dated November 6,1983 which was responded to in Mr. R.J. Gary's letter to Mr. C.L. Maden, Chief Reactor Projects Branch, I&E, dated November 19, 1981.
The site's response to these findings are described in a mere froc R.G. Tolson, TUGCO Site QA Supervisor, to D.N. Chapman, TUGCC QA Manager, dated December 30, 1981.
In the response, a com=itment was made to per form destructite testing on coatings as necessary. This destructive testing progra: has become
I
, e to be known as the "Backfit Program". The details of the program are identified in the follovirs procedures:
QI-QP-11.4-23 " Reinspection of Seal Coated and Finished Coated Steel Substrates for which Documentation is Missing or Discrepant" QI-QP-i l .4-24 " Reinspection of Protective Coaticgs of Concrete Substrates for which Documentatier is Missing or Discrepant" Copies _ of all relevant documents including the procedere history files are enclosed.
i o Question III. A.2 Whht is the estimated total square footage of applied coatings in Unit I containment? What portion of the total applied coatings represents coatings applied to concrete surfaces, miscellaneous steel and containment liner plate?
Re s'po nse III.A.2 The total estimated footage of protective coatings in Unit 1 2
- co nta inme nt is 618,080 ft . This is distributed between the various areas as follows:
2 Liner Plate 145,000 ft 23.5%
2 Co ncrete 285,000 ft 46.0%
2 Miscellaneous Steel 188,080 ft 30.5%
i
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Question III. A.3 Provide the location and boundaries and de fine all areas that have been exempted from the Backfit Program. Also provide the justification for the exemption.
Response III. A.3 A) Liner: The location and boundaries of areas not included in backfit inspection are shown on the enclosed map and inspection reports (PCE) . The areas not included in the inspections were either tot coated at the time of backfit inspection or the surface was inaccessible for test equipme nt .
B) Co ncre te : The location and boundaries of areas included in the backfit inspection are shown on the 634 inspection reports enclosed. The areas not subjected to backfit inspection were: areas cet coated at t he t ime o f backfit inspection, areas inaccessible to test equipme nt , and areas cet inspected due to termination of the test prograc. Ter ination was the result of a very high accepta ca rate as demonstrated in the Response to Question I::. A.12.
C) Miscella neous: The location and boundaries of areas included in the backfit inspection are shown on the 2,189 inspection reports and printouts enclosed. The areas not subjected to backfit were: areas not coated at the time of the backfit inspection, areas inacessible to test equipment, and areas not inspected due to terminatien of the test program. Termination was the result of a very high acceptance rate as demonstrated in the Response to Question III. A.12.
Question III. A.4 Provide the percentage of the three major areas (See Question 2),
that was included / exempted in the Backfit Program.
l Response III. A.4 A) Liner: Approximately 96% of the surface was backfit inspected. ,
B) Co ncre te : Approximately 50% of the surface was backfit inspect e d.
C) Miscellaneous: Approximately 22% of the surface was backfit inspected. As agreed in a July 13, 1984 discussion with NEC project management, this figure was derived fro = t he information available for pipe hangers, cable tray hacgers and conduit supports. This information is considered to be representative of all miscellaneous t
steel items.
l Lists of all hangers and supports installed inside the contaictent and those that were backfit are enclosed with Re sponse III. A.3. 1 calculational purposes it wa s a s s ==e d t ha t all hangers and supports inside the co nta ic=e nt were installed at the time of backfit, even though we know that some supports were not installed at t he ti=e of the backfit inspection.
Question III.B.5 Provide the operating procedure for instruments used during the Backfit Program.
Response III.B.5 The operating procedures for the E1cometer Model 106 .\dhesion Tester and Micrometrics Tooke Cage are in the manufacturer's instructions acciosed. Quality Control inspectors are trained and tested in the use of each of these instruments as shown on page 2 of the examination enclosed.
1 l
1 Question III.B.6 Provide indoctrination and training records that demonstrate that tho se individuals performing testirs for the Backfit Program were qualified.
Response III.B.6 Enclosed are the indoctrination and training records for each of the subject Quality Control Inspectors. These records also include examinations and certifications.
Question III.B. 7 Provide procedure reference for field checking of instruments during the Backfit Program.
Response III.B. 7 The ocly instrument requiring field checking is the Tooke Cage.
The method of performirg this check is described in QI-QP-14.4-23 paragraph 3.1, enclosed with Response III. A.I.
Question III.C.8 Provide instrument history / calibration records of each instrument used in the Backfit Program.
Response III.C.8 Records of calibration for the adhesion testers and dry film thickness gauges are enclosed. There is no requirement for calibratirs the Tooke Gage as the scale is built into the optics of the instrument.
l I
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1
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Question III.C.9 Provide the method used to evaluate and account for instruments found to be out of calibration durits the Backfit Program. How was and is the deviation incorporated in reporting Elcometer Adhesion Test results?
Additionally, for an instrument found out of calibration, provide documentation that shows that all tests done with that instrument since its last calibration were invalida t e d. Also, provide the procedure used to handle those inspection reports written after the instruc:ent went out of calibration.
Response III.C.9 The method used to evaluate and account for instruments is described in CPM 13.1, " General Calibration Procedure" (enclo se d) . Paragraph 3.7 details the handling of instruments found to be out of calibration.
Deviations are not incorporated in reporting Elcoceter Adhesion Test results as the calibration department ensures accuracy within specified limits prior to issue.
B .
Z There have been no cases where the E1cometer Adhesion Tester was found to be out of calibration as procedurally prescribed during the backfit Program such that it rendered the previous tests invalid. Should such an instance arise, Quality Engineering would have issued a nonconformance report (NCR) as specified in CPM 13.1, paragraph 3.7.
O
-. . . - - , . . ,, ., ~ , - _ . - . - . - . . . - . - . - , - - - - _ _ _ _ _ _ _ _ _ .
Question III.C.10 If not provided in the answers to Questions 7 and 8, provide the total number of instruments used in the Backfit Program. Provide the type and serial number of each instrument.
Response III.C.10 The total number of instruments used in the backfit program was as follows:
(a.) Adhesion testers 14 0).) Tooke Gages 10 (c.') DFT gauges 341 The serial numbers or other permanent identification numbers are on the enclosed data and/or computer print-outs.
Question III.D. ll Provide the total number of individual pull tests performed and the nunber of individual pull tests that failed for each of the three major areas (See Question 2). ,
Re spo nse III.D.11 The total number of Adhesion dollies (individual tests) pulled is 7711. The breakdown by major area is as follows:
Area Number Pulled Number Failed Liner plate 869 20 Co ncrete 2128 0 Miscellaneous 4 714 26
s Question III.D.12 Provide the final calculations for each of the three major areas (See Question 2) that demonstrates the estimated failure rate with its associated confidence limits, for each of the three major areas individually.
Response III.D.12 As agreed in the July 13, 1984 conversation with NRC project management the following response is for adhesion tests only. The mean failure rate of concrete adhesion dollies is zero as their were no fa ilures.
If one failure is assumed, then the 95% upper confidence limit is approximately 1/10 of 1%. Thus even assuming one failure there is 95%
confidence that greater than 99% of the subject coatings on concrete in Unit 1 is acceptable.
The mean failure rate of miscellaneous steel adhesion dollies is 0.0055 or 0.55%. The 95% upper confidence limit is 0. 73%. Thus there is 95%
confidence that greater than 99% of the subject coatings on miscellaneous steel in Unit I have acceptable adhesion.
The mean failure rate of liner plate adhesion dollies is 0.0230 or 2.30%.
The 95% upper confidence limit is 3.14%. Thus there is 95% confidence I
that greater than 97% of the subject coatings on the liner plate in Unit I have acceptable adhesion. j l
1 UNIT I BACKFIT ADHESION FAILURE ANALYSIS For each area, a one-sided confidence int e rval for t he int e rval for t he binomial parameter p (the proportion of failures) was developed with Of = . 05,
~f < f # 4 E,og " l.645 Co ncre te 1
4 0 4 l 00 fu LIzs " O fo*
As stane I failure:
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.p, 2,z, =.o00+7 , q, = . 949ss
. . p, ' 4 . 00 / 2, Miscellaneous Steel
^
26 9,
4 m ,, =.ooss ; y. . 9us
-fs < .0073 Liner Plate 4 20 6
.p, c psg =
0230 ;
9 = .9770
$s < .0314
. .- s 4
4 List of Attachments Question Enclo sure Box Number 1
(a) Audit Report TCP-24 4 (b) Memo: R. Tolson to 4 D. Chapman, 11/06/84 (c) Letter: R.J. Gary to 4 G.L. Madsen, 11/19/84 -
(d) Procedure s QI-QP-11.4-23 4 and QI-QF-ll.4-24 2 None 3 (a) Map of Licer PCR 'S 4 (b) PCRs 1-Liner 2 2-Cencrete 2 3-Miscellaneous 1 (c) List of Eangers 4 Computer Print-outs 4 None 5
(a) Manufactcrer's Instructions 4 (b) Inspectors Test 6 (a) Inspectors training and 4 certification Records 7 None 8
(a) M&TE Reccrds DFT 2/3 (b) M&TE Reccrds Adhesion Testers 2 9
(a) Procedure CPM 13-1 4 10 (a) List of Adhesion Testers 4 (b) List of ITT gauges 4 Computer Print-out (c) List of T:cke Cages 4 11 None 12 No ne 1
. . . _ . , - _ _ . . _ _ _ _ , _ , _ . _ . _ _ _ _ _ - , _ _ . _ _ . . = . _ _ - _
TEXAS UTILITIES GENERATING COMPAhT eMYWAY TOWER
- 4fMD NORTH OLIVE MTH EET. L.B. Al
- DALLAm. TEX At6 73201
_gr. ,;MAa July 20, 1984 TXX-4232 $@@Qg Dockets: 50-445 ki'-
j 50-446 M 24g Mr. Richard L. Bangart, Director #
' Region IV Comanche Peak Task Force -
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United States Nuclear Regulatory Comission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 BROOKHAVEN INTERIM REPORT ON PROTECTIVE C0ATINGS FILE NO. 906.1, 10010
Dear Mr. Bangart:
~
This responds to your letter of May 23, 1984 relative to the interim report on CPSES protectin'e coatings prepared by Brookhaven National Laboratory (BNL). We have previously responded to each of the sixty allegations that you had received relative to the adequacy of pro-tective coatings at CPSES and have provided documentation and other infomation relative to Section III of the BNL Report (see our letter numbers TXX-4201 dated June 22, 1984 and TXX-4225 dated July 16,1984).
The attachment provides our responses to findings in Section IV of the BNL Interim Report.
l Based on the infomation we have provided in responses to the sixty )
allecations, the documentation and other information provided to you ,
in our response to Section III, and our responses to the findings in Section IV, we do not agree with the Conclusions (item 2 and 3) in Section V of the Brookhaven Report.
l Our position is that there are no safety concerns with the protective i I
coatings at CPSES, the backfit program was properly conceived and im-plemented, and.therefore, no corrective actions are necessary.
,J 7-1
$go(D l
A DIVidiON 09' TEXAS t*TILITits ELECTMir COMPANT f
Mr. Richard L. Bangart July 20, 1984 Page 2 Please advise if you require additional infomation.
Sincerely,
~7 5L. F Fik r %
LFF: pew cc: Mr. Thomas A. Ippolito Mr. John Collins 6
-TXX-4232 07/20/84
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Finding IV. A.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 feet were chosen at various elevations and various azimuchs.
Two areas 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 ps1 was applied to the test dollies. If a dolly separated from the surface, the force that caused the separation was recorded. If the dolly did 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 a reading of zero and removed.
For the liner plate, a failure rate was exhibited of 4 out of 10 or 40%. Failures occurred in both test areas with corrected readings of 156, 186, 186 and 186. For miscellaneous steel, no failures were recorded in ten (10) tests, and for concrete surfaces, a failure of the concrete was experienced at a corrected reading of 156 psi for one test and no failures of the protective coatings in nine (9) tests.
In addition to the Elcometer adhesion pull tests, 30 Tooke (scratch) tests were performed adjacent to the pull tests. No "out of specification" conditions were recorded in the dry film thicknesses testing. .
BNL's observed failure rate for the liner plate is unacceptable.
Although it was limited in scope, it raises questions about the adequacy of the Backfit Program for the liner place.
Page 1
TIX-4232 07/20/84 Response IV. A.1 Applicants disagree with the finding by BNL relative to the coatings backfit program as the result of the few adhesion tests performed by them. This disagreement stems from two basic areas of the BNL evaluation:
, 1) BNL has apparently expanded the scope of the backfit program beyond that intended and documented by Applicants. A review of Applicants response to NRC I&E Report 81-15 as well as the backfit procedures clearly establishes the backfit program scope. It was designed to establish confidence in coatings that had been applied prior to late 1981 (where inspectiFon records were incomplete) and not as a measure of coatings application activities accomplished since late 1981. These latter activities have been accomplished and fully documented in accordance with the established QA program.
- 2) The area under the equipment hatch (approximately Azimuth 225 and Elevation 813') where three of the four adhesion values were less than 200 psi (actual recorded readings were 150, 180 and 180 psi), had not been included in the backfit program because this area had not been painted at the time the backfit program was implemented. Furthermore, the BNL test results were classified as nonconforming via NCR C-84-00921. Additional testing clearly show the lower values obtained by BNL to be extremely isolated and of ne consequence.
The fourth lower reading (180 psi) obtained by BNL was at Elevation 945' and Azimuth 180. Again, additional testing has sh=wn this value to be extremely isolated.
Contrary to the finding by BNL, results of the backfit progra= demonstrate adequacy of the liner plate coatings. (See Response III. D.11 and III. D.12 TIX-4225 dated July 16, 1984).
Page 2
TXX-4232 07/20/84 Finding IV. A.2 .
During the week of March 18, 1984, BNL observed an area at approximately elevation 860 and azimuth 175 of the liner plate that was being repaired because of recent unacceptable adhesion test readings and visible deterioration. This same area had acceptable adhesion test readings during initial backfit testing in December 1982. This again raises doubts about the adequacy of the Backfit Program for the liner plate.
Response IV. A.2 The area in question had been "backfit" inspected ih December 1982.
These tests were performed by pulling 3 dollies per test; each test representing 500 square feet of coating. NCR C-83-03015 (attached) was prepared November 9, 1983 for loss of adhesion properties. A sketch of the area found defective is attached to the NCR. BNL personnel observed rework of this area in progress as directed by the NCR disposition.
k'e are unable to reach the same conclurion drawn by BNL with regards to this NCR, i.e., raising doubts about the adequacy of the backfit ,
program, for two reasons:
- 1) As only 3 dollies were pulled in an area of 500 square feet, it is certainly possible that the dollies were not placed over coatings which ultimately failed, and Page 3
TXX-4232 07/20/84
- 2) Coating work (which stripped existing coatings by power tooling),
was performed in the referenced area after backfit inspection occurred. (See, for example, PC49,983 and PC100,005, attached).
If these were the coatings that subsequently failed, they would not have been subjected to the backfit program.
In either case, the coatings which failed were identified by the QA program and subsequently reworked to acceptable standards. No further action is warranted.
Page 4
( E PEE STEW ELEC CS EN
- T E s, .5, lT.LITIES GENERATIFS CO. NONCONFORMANCE REPORT (NCR) C b3-03015 E 1 ITEM / COMPONENT TAG /ID NUMBER LOCATION R ELEVATION RIA NC UNIT STRUCTURE / SYSTEM Protective Az. 16 Reactor 866' - 867' N/A 1 Containment Bldg. Coatings N/A NONCONFORMING CONDITION Applied coatings on Containment Liner Ilate exhibit loss of adhesion properties, therefore rendering the quality of the applied coatings indeterminate. Original y cause of failure appears to be mechanical dama68, but surrounding areas exhibit total b loss of adhesion properties. (i.e. total coating system, phenoline 305 & cz-11, is W *s+ bast EMC
$ peeling at ed6es and exposing steel m.ptg.gd Area is located directly behind colum
- 9 at Az.1690 El. 866' - 867'. Additional areas have been identified as approximately 5 feet to the left of the area directlyArbehind column #9 (3-4 spots less
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w hlV$ YAY N / 26/ 0 0 DEPARTMENT ACTION ADDRESSEE Engineering Kissinger ,
DISPOSITION:
REWORK REPAIR E USE AS IS N t h ac$esion tegts With addition of other small areas in same a{ .
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l Dolly #1: Dolly #2: Dolly #3 '
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.ANCHE PEAK STEAM ELEC IC 5* ION
.g , y , ., . t 3 ""
GENERATING CO NONCONFORMANCE REPORT (NCR)
G83-030/f ITEM / COMPONENT TAGliONhBER LOCATION OR ELEVATION RIR NO.
UNIT STRUCTURE / SYSTEM MM70%gr fcorarWf ,( ifE. Ma* gl/g Q I LIld 00A'Tl $5 S$* &$> '* $~f '
NONCONFORMING CONDITION h$/l* htkT/Y${b Q h A*/bi $ $ k /Y f A. fL $7"[ S f ///d i f
~
n doss of Abwesiex) bzosairres 7 w-izerexe b-xteliq '
y . rire pawzer]/ or 7A'E sic /Ain , coa-rix/+sabe72xxiaAn-8 .ftiga/M CAidr or FAu WtE' /?//fAl6 ?b AE' A'd~dMW/ML 2%qc, 6tt7 fe/uatJD/AJq MCAS FX x/6/f 76 7A~ l
@ *f y A06b @ AhM83/6).) /0te/6/L1/Es . (Se 7b7A 4. dcAT/Aff t
ls .Sp754 , Ma%ardroS-/d2-M, /s Arswa+ Ayn is / r*s%cs xoes77.2 y 4rR.5Mg .srsz% .cresswrr)
$ $ $/ h $0 &l(/fbYf S r /hf# [d. fbb h ll$0Vd 23ZS-AS-3/ M
/
3/i REFEAENCE DOCUMENT
- ff~~ M //e 4#- REV PARA !
" "' Fizb % /Hata /dC W h & 1 # ,7l6 OATE' CE REVIEW / APPROVAL:
CAhWQ() A lll Y 8) w f h. /
C ACTION ADDRESSEE DEPhTMEPjT
- b. .'c.euw3 9e o REWORK REPAIR USE AS IS SCRAP Lack of adhesion iS limited to area adjacent to impact (mechanical damage).
W Repair per CCP-30.
E
[dii, lhf0Ed'[ildtM UIid.
p P A M' ' '
DATE:
ENG.RE W _ NtiM M ll / If4 /63 K \
CE REVIE4L )pp ACV AL- DATE: 1 j
y ll/k/
DATE: 1 DISPOSITION (ERidhiON & CLOSURE:
/ /
l j
COMMENTS:
et,, .,a -
SEPM. PLT. RECORD' _
~ '
jgg{X{g
, ,a w c.
u ,.
CcMANCHE FEAK STEAM ELECTRIC S TAT 1Ch - I y 1
L 17.1.99.3 w e,-
evenu. wc. INSPECT 1CN REPCRT j.e g g 9 g 3 SOOlPC #
ht0TN T N OATINGS [ Y/), hh/ ..'
av. av. u ac. a uv. a c. mot no. paswu ca rasr ccma. :cor.pc.
r.nc.3c.
AS-31 s i . 01-0P-11.4-5, Rev. /3 J.,74oy[zyo3'z y6 t(/6 # ,
aiag;gis, aeggyca s w i g ,m a e,~,3Jnc, 'aeasigo, c o
u.sr. nesm.Ts .
(fourcenen cowurro , au. AraucAsu erzxs sAnsractec [ M , G h 3-/g.g3 l
- *5'557*"
^
1 Oiaseecion co-evro, unsansacrew irtus usTro in.ow ect
. INSPECTICN ATTRIBUTES O f oATE 33, g
/ e- 11 a l l
- 1. I For recair of sacs and runs over 5.5 mils DFT cerform I #//8 l l l I ! l l OFT of Primer Coat in areas which have been sanded or
} screened per Para. 3.2.1. (For multiple items, indicate l l l l !.
i l Min. Spot, Max. Spot and Average DFT with corresponding l l l l l l !
l QP & ID No's for each item in " Remarks.") '
! RECORD: Minimum Soot Test: e n ,- u r- . u . l -. . !
l Maximum Soot Test:
tun ;ftrl GinilON Uill i Average DFT: l l l l l l
- 2. I Abrasive acceptable per Para. 3.2.2./. c . Fvss @ lyf4 l l l
- 3. I Separators installed. drained, and drains left lu/Al I i t
l partially coen. l l l l l
- 4. l Air supply free of contamination. \t> /A-l l S. l Blasted or power-tooled surface and profile: .sr.3 l l l l i a. Surface and surrounding areas cleaned per lM l l !
Para. 3.2.2.$. d -fg,,. g g j
l l l l l b. Surface free of foreign matter incl. grease & oil l<1 i !
I c. Sharp (non-rounded) crojections removed i4l l I d. Anchor cattern death 1.0 mil . minimien Id i l !
l e. Surface lightly abraded per Para. 3.2.3 14/4 l l !
I f. Surface wiped clean oer Para. 3.2.3 or 3.2.4 l#/4 l l !
l (Repairs Only) l l l l t
- 6. I Unioue Number stamoed on eiece(s). Record Unieue l#lA l l l l l l l l NumberN in " Remarks" below. L.s m- F/ e. 6-
- 7. I Ambient conditions checked per Para. 3.3.2 orier to idl l l 4 l primer application and record belcw: l l l !
i lDATE: J- / t- t 3 TIME: /./o 441 WET BULB TEMP: /,0 'l i I l i
I I I I l DRY BULB TEMP: $ t* RELATIVE HUMIDITY: 2 5 7.
SUPJACE TEMP: 37' l l l l lOEW POINT: V2*
- 8. I Substrate surface fraa of centaminants and less than I#I I I 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> elacsed since 91-"-9 59 3 #d.,e. 9 - l I I I I l !
I (Continued on Next Sheet)
/
b' l 1
CDM ANCHE PEAK STEAM ELECTRIC STATION 01-QP-11.4-5,Rev./3 INSPECTION REPORT Sheetl of &
(SUPPLEMENTAL)
W DATE o.c.
ITEM INSPECTION ATTRIBUTES ,
a a sauna no.
,l ! .o n
Trao. filter or seoaratne installad nar nar, 3.3.4 ( W!
9.
- 10. Air supply free of contamination. t)-
- 11. Qualfication of aoolicator. (List Aeolicators:)F. L,er W
- 12. Verify Mixing Operations per para. 3.2.2.h. 4
- 13. I Coating Material Product Identification: c. 2 - / / ..A'
- a. Base Lot No.: 2 I 59 2 i M PART A: Ai/A I
- b. Filler Lot No.: z 3 3 o Ss M
- c. Thinner Lot No.: Z rA 312 7 M
- d. Time Mixed: 12:3 5 M.M.
- 14. Pressure pot agitated. J 15 . Pot life not exceeded.
- 16. Hose less then 75 feet. W
. l I
I I Pre kAue Pre o - Pmhieds l
l ' I DATr J-i%-93 (
-ri m e I:or A.M - I V8 l,0
- I I
'I I 08 tz' 57 97* FIN. R...F HJ.M.8.T. l. H. Tk '
Flh I" z s 7e I I RH ll 1
! ! I REM ARKS: (Dwst, specs.rTc.) %fs, / gricie r r e g e. .'e * (S P- 3 f. be.re, s g 6 s fe c.te,
- w;% .some permer c m c. co.uS ;n +Ae p,.n. te) +. .f;,, -F. u t _ ,5 lo ed.'e a an -h e I;,a, plate 3 1 M /
6.v- SSg.T : +, g(,<j ::
A z- 13 s 'e +. iito' go'.:
i
- $ C a r r e ef*e .s s have has a 1._ -r l' t. ce c.# P. < .
pr_4TE:: =ca no I i8*ANS ##oc p/A .s 1.R. CLOSED C p//A I snsptcicR ,,,
)
l FC scc,oc $~
7 W ! 2.-)?
COM AN CHE FCAK STEAM ELECTRIC STAECN
/ .
d INSPECTION REPCRT p_._jt g.
irr.mcwrica j w .r.iicar.ca so.
FMy dsis:w RC6#1e sTwcrun cuione r.ca .l PR0 RcTIVE COATINGS e L w e ,- .,0.
u v. nu o.:. c c. a nsv. s c.nnnst no. # 2%#z sn: :so.
AS-31 s I e 01-0P-11.4-5, Rev. / 3 lueasune 2497 ca zur ew. ygo :cca.Jz ,.
a w asa, awen egw.= cF=,ofo, dmgo, ,
I
-gM, MM[ J f "S.g3 vise. uut.Ts i
marecitoa cowu:Tro , au anucasu: iras sAr:sracreny ~
O insece:rea c==m.rrro,urisariracrent irtus untro setow
' *" INSPECTICN ATTRIBUTES
' OATE sic afunt l For repair of sacs and runs over 5.5 mils CFT. cerfom MAI I I 1.
l l l l l j DFT of Primer Coat in areas which have been sanded or l !
l screened per Para. 3.2.1. (For multiple items, indicate l l l l Min. Spot, Max. Spot and Average DFT with corrr 'anding l l l l l l l 7 :
l QP & ID No's for each item in " Remarks.") '
l Il l l RECORD: Minimum Scot Test:
- l Maximum Soot Test: f flN M ONMA[lllff [RIlII e ! !
l Average- DFT: l l 'l @ l V i
- 2. l Abrasive acceptable per Para. 3.2.2./.b. %%.o @ NMI N l 9: O i
- 3. I Seoarators installed. drained, and drains left lAld4l (IJ ll 5: MI !
I partially ocen. I l. I " 82I *
- 4. l Air supply free of contamination. ly/A l 9 L~'
l l l 1 @ 6 5.
Blasted or power-tooled surface and profile: 39 5
- a. Surface and surrounding areas cleaned per l vi l 2 d I j
' I Para. 3.2.2.(.cl. Py',,. ,, g l l l @ z ._Q l4i 0- I* !
- b. Surface free of foreign matter incl. grease & oil E t l c. Sharp (non-ro;nded) projections removed l.d' i l l d. Anchor cattern deeth 1.0 mil . minin um l4i l I l e. Surface lightly abraded per Para. 3.2.3 lN/A l l l l f. Surface wiced clean oer Para. 3.2.3 or 3.2.4 IN/4 l l, l i
(Repairs Only) l l l l l
I Unioue Number stamoed on piece (s). Record Unicue I NMI l
- 6. I l l ,1 P l Number (s) in " Remarks" below. f 'NM 94 A TE
- 7. l Ambient conditions checked per Para. 3.3.2 orior to l-45 R I l primer application and record below:
l CC 8 l lDATE: 3-19 85 TIME:/2:Zo 6 WET SULS TEMP:6 z' f l 7 fE I RELATIVE HUMIDITY: 2 6 '"/ . l l l l 0 l DRY BULB TEMP: $Y*
l OEW POINT: f4' SURFACE TEuP: TJ' l ll l 3.
I'I I I
- 8. l Substrate surface free of contaminants and less than '
D ,5. r.r I I I l 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> elaosed since t':;f c. S /'. 3 I I ! I l (' 4tinued on Next Sheet) v l
)
COMANCHE PEAK STEAM ELECTRIC STATION Ql-0P-11.4-5, Rev. /3 INSPECTION REPORT Shecti of 1.-
(SUPPLEMENTAL) g 5fE INSPECTION ATTRIBUTES h
'"2
- er a a .o
!! 3.3.4 14
- 9. Trao filter or secaratne installpa nor na, ,
v
- 10. Air supply free of contamination. '
v
- 11. Qualfication of aoolicator. (List Aeolicators:) F. Be se-
- 'I ,
- 12. Verify Mixino Ooerations per para. 3.2.2.h. '
- 13. Coating Material Product Identification: d. 2 -II '
- f~
f
- a. Base Lot No.: 2t. 5g4'G A PART A: a /A
- b. Filler Lot No.: 7_A so36 p1
- c. Thinner Lot No.: 2 M39 27 A1 ! I
- d. Time Mixed: /7.;eo /1.ri.
rressure pot agitated.
- A
- 14. 8 l 6'i 15 . Pot life not exceeded. l f I
- 16. Hose less than 75 feet. la i I
l l I A e* 6'r,4 G ee);'hi~wJ Pre Sus Ice e fre rs
' f I \ l!
On 7st- .3. r 1 - 13 II rio r '. G ; S o R M . I I I 66 . 63' \ l 1 (04- 99* l1f I I 57' SY' M. ...lU
. . IN..Gil2MLilflM
- , . . . , . . . . . OS w .u, ;
- y. g, Iil I
/W- Zo% i l i i f i I l 6D G1r,*ct,%s Aave L. < < a a de fe Ref. car <euf I I I i 1 I
i I Pc r. .
.s v 5 6-fr a fe.
REM ARKS: (owas, specs,tTc.3 %-fo / gr/av1e r y e pc.e'r (5f-3 r#o be rc La Nh s a e c yr,%e r- cema,,,;ny ;a -fhe pnfa /e ) -t'-a -Hee /c4 w P I ' ~
r er
- - ~
ELV- 9(.%' S Q:fres Te<pch*'
4 c.arEO ,
7"
/ - ..
Fur- 9 6 0 f
P '
i /
i gh' '
A 2 - o s 4 *- 3 0 A2 - I4 6"! s
- islGNA M E NO 1.R. CLOSED oc
'S C 1/[A- I ,% set ::n ,
l
TXX-4232 07/20/84 Finding IV. B.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 effect. In three areas of coating system failures on the containment liner plate, BNL observed a solvent odor. that was far in excess of what would be considered normal.
Response IV. B,3 Although some small areas have experienced a loss of coating adhesion, we do not concur with BNL as to the cause of failure. BNL is correct in stating that " excessive solvent retention will inhibit the curing of inorganic films...." We do not, however, agree with BNL's implication that the source of the entrapped solvent was the solvent wipe.
Apparently, BNL has hypothesized that " excessive solvent" from the solvent wipe would permeate the inorganic zine film and become " trapped" when overcoated with Phenoline 305. They conclude from this hypothesis that this solvent is retained, thereby inhibiting full cure of the inorganic zinc. As stated above, we do not concur with this conclusion. If solvent becomes
" trapped" in a partially or fuliy cured zine film due to the porous nature of the inorganic zinc, it will eventually escape as a gas on the topcoat side of the zine primer. (That teing the path of least resistance). If and when this occurs, the escaping solvent would cause one of two things to occur:
- 1) The solvent could escape through the topcoat leaving a " bubbled" or cratered appearance, and/or Page 5
TXX-4232 07/20/84
- 2) The solvent could escape between the primer and topcoat causing lack of adhesion at this interface.
Neither of the above mentioned possibilities has been observed in finish coated steel at CPSES. The overwhelming majority of " adhesion f ailures" observed at CPSES, (including the " adhesion failures" described by BNL above), have been cohesive f ailures of the inorganic zine primer. (See response to Allegation 38. TXX-4201., dated June 22, 1984).
The solvent retention noted in areas where " adhesion failures" have occurred is from the solvent applied with the inorganic zinc, not from the solvent wipe prior to topcoat.
l l
l l
l Page 6
TIX-4232 07/20/84 Finding IV. 3.4 Contrary to CPSES FSAR Section 1A(B), Regulatory Guide 1.58, and ANSI /ASME N45.2.6-1978, Section 4 and Table 1 Level 1 Coatings QC Inspectors have been making judgments and evaluations that they are not qualified to make.
Examples of this were evident in procedures where level 1 inspectors were: a) evaluating surface preparation without instruments or approved visual standards, b) evaluating the adequacy of coatings materials when its " pot life" had been exceeded, and c) evaluating the acceptable extent of overlapping dry spray beyond the specific areas to be coated.
' ')
Response IV. B.4 We contend that there is not a significant judgment f actor involved in the inspection process. The facts relative to the examples cited are as follows:
- a. evaluating surface preparation without instruments or approved visual standards - First, it must be kept in mind that the issue is power
. tooling of areas in need of repair prior to reapplication of primer l
- ', (where required) followed by top coat application. Our combined j Engineering and Quality Control experience indicated that an appropriate profile consistent with coating material manufacturer's recommendations could be achieved by simply specifying the process and equipment to be used for power tooling. Initial attempts at measuring this profile using available devices were not satisfactory.
Accordingly, the process was specified in procedures. The inspector does not have to exercise judge =ent, but rather monitors the craft activities to assure that the specified process is used.
Page 7
1 l
TXX-4232 07/20/84
- b. evaluating the adequacy of coatings materials when its " pot life" has been exceeded - The coating materials used at CPSES reach a point (at the end of their " pot life"), when they can no longer be sprayed from the application equipment. Identification of this point is obvious to all and does not require " judgment."
- c. evaluating the acceptable extent of overlapping dry spray beyond the specific areas to be coated - Specifications state that a moderate amount of dry spray is acceptable for finish coat. Since dry spray is of commercial concern only and does not affect the integrity of the coating system, we fail to see how judgment by the inspector is required. Whatever judgment is required was put into the specifications and construction and quality control procedures. .
Page 8
TXX-4232 07/20/84 Finding IV. B.5 Contrary to Gibbs & Hill, Inc., Protective Coatings Specification No.
2323-AS-31, Revision 1 - March 15, 1978 for CPSES, Section 6.lb and Brown & Root, Inc. letter BRV-12605, dated May 7,1981 to Tim Dolen, Carboline Company from D. C. Frankum, Project Manager, proper surface preparation was not achieved. Instruction Number QI-QP-11.4-5 allows 80 grit " flapper wheels" versus the 60 grit " flapper wheels" used to qualify surface preparation.
Response IV. B.5 ,
Specification AS-31, Section 6.1.b simply requires manufacturer's application instructions to be complied with for surface preparation. The manufacturer's recommendation in this case is to obtain a minimum one mil surface profile. As stated above, our experience indicates that the desired profile vill be achieved through power tooling (3-M Clean and Strip or Flapper Wheel). BRV-12605 reports the results of site tests to demenstrate the ef fectiveness of power tooling on adhesion (the important coating characteristic - not profile). Carboline responded to this letter on August 28, 1981 (attached) concurring with the results of the site tests and agreeing that additional preparation efforts on the surf ace were not necessary.
Page 9
TXX-4232 07/20/84 The site tests for flapper wheels were performed with 60 grit paper. In preparing the construction and quality control procedures, 80 grit paper was referenced inadvertently. However, the quality procedure statement was an explanation and not a specific inspection attribute. Additionally, the quality procedures prior to mid-August 1983 required measurement of surface profile on power tooled surfaces using roughness gauges or equivalent. Most measurements were taken with a needle point micrometer; however as stated above, neither the use of the roughness gauge nor the needle point micrometer produced repeatable results, which was a partial basis for reverting to process specifications. The oversight in the procedures (80 grit vs 60 " grit) was corrected in early March 1984. It should also be noted that a review of purchasing documents shows that only a small amount of 80 grit paper was purchased. This material has been used for feathering of interface areas or stripping of surfaces and not to establish minimum profile.
BNL's subcontractor during the site evaluation recommended to again measure surface profile using a tape manufactured by Testex, Inc., stating in passing that some surfaces he observed in the field appeared as smooth as glass. We had previously considered the use of this device (in mid-1982) but rejected its use based on experience with lack of repeatability. We did experiment recently with the use of this tape and are currently using it in the field.
In summary, our experience and tests have shown that suitable surface preparation is achieved through the specified use of power tooling equipment. Attempts at measuring the resulting profiles have repeatability problems and are really stretching the art of protective coating application to an unjustified scientific level.
Page 10
r- . 3 .
~ ~ BrownffRootlnc. Post ottice sox ,00,, cien sose. Texas 7eo4a W
,,7 + . . w May 7,1981 BRY: 12605 CARBOLINE COMPANY 350 Hanley Industrial Court St. Louis, Missouri 63144 Attn: Tim Oolen
Reference:
Purchase Order #35-1195-(Carboline 8.0. #15795)
TEXAS UTILITIES SERVICES, INC.
COMANCHE PEAK STEM ELECTRIC STATION RE: PURCHASE ORDER No. 35-1195-15795 Gentlemen:
Recently the question of minimum acceptable surface preparation has arisen for steel inside contairiment structures to be coated with carno zinc 11.
Under nomal conditions, spot blasting, e.g. open or vacuum would be the most cost efficient method of surface preparation for repair work. ;
However, inside containment buildings airborne contaminates must be limited because of delicate equipment. Presently, we are utilizing an elaborate system of enclosing an item or area to be repaired, and blast- ;
ing or using a 3M Clean-N-Strip for removing camagea coating followed oy needle scaling for adced . surface profile. l The necessity for follow-up needle scaling has been questioned where the repair is perfomed over previously blas.ted steel. In January of this l year, we perfomed surface preperation on two pipe hangers in the cont- ,
tainment which had previously been blasted and primed, utilizing 31 i Clean-N-Strip only. After prime, one with Oimetcoat 6 and one with l Carboline CZ-11 and cure, a pull test was perfomed on January 29, 1981 1 with results on Dimetcoat 6 ranging from 200-600 PSI and on Carboline 1 CZ-11 from 200-900 PSI. Note PSI on attached pull test results.
Test plates were made and the panels were sancblasted to SP-10-63 and p rimed. After cure 34 Clear-N-Strip and 60 grit flapper wheels were l used to clean the cured coatings from tne panels, we again coated with 1___
% *) .
- BRV 12605 Pg #2
- Brewilffh CARBOLINE COMPANY -
3 primer. After initial cure adhesion tests were perfonned, however
/ .
Carboline CZ-11 on two panels had unacceptable results. The unaccept-able adhesion could have resulted from cure time or application method; therefore, these two panels were tested again on March 17, 1981 with acceptable adhesion from 300-500 PSI. More panels were made by blast-ing/ priming / cleaning after cure and recoating then pull test perfomed on March 23, 1981 with results per attached result sheet.
i
- The above adhesion testing was perfanned by Brown & Root Paint Q.C.
Department; also witnessed by Paint and Engineering Department repre-sentatives. All testing was perfomed over previously blasted steel and is not intended to reflect or imply satisfactory results over non-previously blasted steel. A slight amount of residue of coating was left on the surface after final preparation to simulate possible field conditions. .
We feel the removal of damaged coatings by 3M Clean-N-Strip, or equi-valent from previously blasted steel does not require a follow-up of needle scaling f_. proper adhesion of the coating. We,woulo apprec-ciate your professional opinion of the previous proposal as well as any ideas or procedure which Carboline may have for conditions such as we encountered inside of containment structures. Also, if the above is found acceptable, what limitations would we face in rela-tion to size limitation, any difference in curing before top-coating, or any other limitations which we might encounter. If furtner infor-mation or clarification is needed, please contact us.
T J
Very truly yours, BROWN & ROOT, INC.
f d'4M
- 0. C. Frankum Project Manager DCF/TVE/MW/vl ATTACHMENTS cc: Mark Wells (ll, l A)
J. B. Scott (1L, l A)
Bobby Lockamy (ll, l A)
Harry Williams (ll, l A) i i
l
Brownf5Roouric.
ADHESION TEST RESULTS
)
TEST DATE: l_29-81 C0ATING: DIMETCOAT 6 OVER PIPE HANGER SURFACE PREPARATION:. PREVIOUSLY ABRASIVE BLASTED TO SP10, REFURBISHED WITH 3M CLEAN _N-STRIP ADHESION TESTER: ELCOMETER DOLLIE # TYPE FAILURE
- 1. 600 PSI (GLUE)
- 2. 600 PSI (GLUE)
- 3. 500 . PSI (GLUE)
- 4. 750 PSI (GLUE)
- 5. 200 PSI' (GLUE) r p __ _____________________ _
TEST OATE: 1-29-81 C0ATING: CARBO ZINC 11 0VER PIPE HANGER . . _ _ . . _ . . ..
SURFACE PREPARATION: PREVIOUSLY ABRASIVE BLASTED TO SP10, REFURBISHED WITH 3M CLEAN _N-STRIP ADHESION TESTER: ELCOMETER TYPE FAILURE 3 00LLIE #
- 1. 250 PSI (GLUE)
- 2. 525 PSI (GLUE) -
- 3. 900 PSI (GLUE)
' 4. 200 PSI (GLUE)
- 5. 200 PSI (GLUE)
TEST OATE: 2-24-81 CDATINGS: CAR 30 ZINC 11 OVER STEEL PLATES SURFACE PREPARATION: PREVIOUSLY ABRASIVE BLASTED TO SP10 REFURBISHED WITH 3M CLEAH-N-STRIP (dos.1-13) 60 GRIT FLAPPER kdEEL (Nos.14-18)
ADHESION TESTER: ELCOMETER DOLLIE # FAlldRE TYPE
~
_ __.___._______...__l_____ _ _ _ _ _ . _ . _ ._ _ __
.3
' ' BrownCrRoot.inc. . , ,,
ADHESION TEST RESULTS b .__ _ ____ _ ______. -- -. _ ______
TEST DATE: 2-24_81 COATING: DIMETCOAT 6 OVER STEEL PLATES SURFACE PREPARATION: PREVIOUSLY ABRASIVE BLASTED TO SP10,' REFURBISHED WITH 3M CLEAN-N-STRIP (Nos. 6-10) 60 GRIT FLAPPER WHEEL- (Nos.1-5)
DOLLIE # FAILURE TYPE I '
TEST DATE: 3-17-81. ,
COATINGS: CARBO ZINC 11 OVER STEEL PLATE (PREVIOUS TEST PANELS FROM 2-24-81)
SURFACE PREPARATION: PREVIOUSLY ABRASIVE BLASTED TO SP10, REFURBISHED WITH -
3M CLEAN.N-STRIP (Nos. 1-5) 6 GRIP FLAPPER WHEEL (Nos. 6-10)
ADHESION TESTER: ELCOMETER ,
TYPE FAILURE
.) DOLLIE
- 1. 500 i
PSI (GLUE / PAINT) 6. 375 PSI (GLUE)
TEST DATE: 3-23-81 C0ATIN35: CARSO ZINC 11 OVER STEEL PLATE SURFACE PREPARATION: PRE /IOUSLY ABRASIVE SLASTED TO SP10, REFURSISHED WITd 3M CLEAN-N-STRIP (nos. 6-20) ana 60 GRIT FLAPPER 'nHEEL (Nos.1-5)
ADHESION TESTER: ELCOMETER DOLLIE i TYPE FAILURE
- 3. 350 PSI (COATING)
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.O August 28, 1981 Mr. D.C. Frankum -
Brown & Root Inc.
P.O. Box 1001 Glen Rose, TX 76043 .
Reference:
Purchase Order #35-1195, Your letter of May 7
Dear Mr. Frankum:
We have evaluated the Elcometer Adhesion data you have developed on Carbo Zinc 11 over power tool cleaned steel. In regard to your question as to whether needle scaling is necessary after using the
) 3M Clean-N-Strip for application of Carbo Zinc 11 to previously SP 10 blasted steel, we concur that if the Elcometer Adhesion is at least 200 psi without using the needle scaling then it is not necessary.
In regard to size limitations for this type of surface preparation, we can only comment that our primary recommendation is to abrasive blast wherever practical for the highest assurance of optimum long-term performance. Generally, this type of surface preparation should be restricted to small components of difficult surface configuration or to touch-up of small areas. It is difficult and arbitrary to assign a specific size limitation. There are no limitations on cure time nor other parameters other than possible long-term performance.
To answer Mark well's question on date discrepancies on Carboline Test Summary Report 149, we have had to have Oak Ridge National Laboratory send us a revision to page 10 because initially they l
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Mr. D.C. Frankum Brown & Root Inc. l
'-} August 28, 1981 l
Page 2 omitted the initial temperature on the chart. When they received this page to correct this omission at our request, they put a current revision date on it also.
Please advise us to whether any clarification or additional information is desired on these matters.
Very truly yours, CARBOLINE bOMPANY GM-Dan W. McBride Power Industry Manager 1rb/1/614/
- Frankum/082881 oc
- Mr. Mark Wells Brown & Root Inc.
P.O. Box 1001 Glen Rose, TX 76043 cc: Mr. Charles Rushing
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1 een
TXX-4232 07/20/84 Finding IV. B.6.a.1 The procedures are not " stand-alone" documents, acceptance criteria are
. found in other referenced documents.
. .I .
Response IV. B.6.a.1 We disagree with this finding. Acceptance criteria required for inspection are furnished to the inspector and in most cases the required criteria are contained in quality instructions prepared expressly for the inspection function.
4 i Occasionally, data needed by both the craf t and QC (e.g. , cure time, pot life, etc.), may be included in the construction procedure and referenced in the quality instruction. Irrespective, the needed information is available to QC via a controlled office copy of the construction procedure. There is no practice of referencing acceptance criteria which may be contained in proj ect specifications or codes and standards which this BNL statement may infer.
Page 11
TXX-4232 07/20/84 Finding IV. B.6.a.2 Procedures such as Instruction Number QI-QP-11.4-1 and QI-QP-11.4-5 requires 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 minimum light required is not specified.
Response IV. B.6.a.2 We disagree with this finding, but have difficulty responding since we are dealing with a matter of opinion. Our experience is that defects which are detrimental to coating performance can be adequately evaluated by observing i
the inspection area from an arms length position and looking perpendicular at the surface. Looking parallel to the inspected surface may show surface dust not visible from the perpendicular position, but by ASTM definition of contaminants this is not deleterious to the coatings.
Minimum light is in fact defined in the procedure. It is the light produced from a two cell flashlight.
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. 1 TXX-4232 07/20/84 Finding IV. B.6.a.3 Procedure QI-QP-11.4-1, paragraph 3.1.2, states that for abrasives ". . . All grease, oil and deleterious material is unacceptable", and fet provides no methods to determine if,these materials are present. The procedure also does not define deleterious material.
Response IV. B.6.a.3 This statement is taken out of context. The exact quote is as follows:
"The inspector shall obtain a sample of the abrasive to be used from each work area. The abrasive shall be verified to be dry by feel. All grease, oil and deleterious material is unacceptable.
Grease and oil would not be dry. Deleterious material cannot be totally defined since it could be anything except sand. We elected to not define the issue. Instead we decided to let QC identify matters of concern via established procedures and then evaluate the inspection results with senior QC and technical personnel.
Page 13
TXX-4232 07/20/84 Finding IV. B.6.b Contrary to 10CFR 50 Appendix B Criterion V and CPSES FSAR, paragraph ,
17.1.1.5, the final coatings walkdown procedure contained no acceptance criteria and did not contain appropriate instructions regarding hiding quality, cracking, delamination, peeling, excessive overspray, excessive roughness, flaking, blistering or cracking. In conjunction with inadequate inspection procedures, this could allow acceptance of inadequate coatings.
Response IV. B.6.b There is no paragraph 17.1.1.5 in the'FSAR and it is assumed that the reference is to paragraph 17.1.5. 'The requirements of Criterion V of 10CFR50, Appendix B and FSAR Section 17.1.5 are not applicable to the final walkdown procedure. All QA program mandated quality control inspections are accomplished prior to implementation of the final walkdown procedure. These quality control inspections are accomplished in accordance with a series of instructions denoted by the prefix QI-QP-11.4 ... In contrast, the final walkdown procedure is a procedure authored and implemented by CPSES Engineering personnel. Its purpose is to assure that the previously completed QC inspections have been maintained to the owners' satisfaction (i.e., construction activities subsequent to completion and QC acceptance of coatings work have not damaged the coatings). In the event that major damage is observed, the area is returned to the craft forces for rework in accordance with craft procedures and QC instructions applicable to the original work.
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i TXX-4232 07/20/84 Finding IV. B.6.c .
Contrary to CPSES FSAR, page 1A(B)-11, R.G. 1.54, and ANSI N101.4-1972,
' paragraph 4.4.3, CPSES coatings procedures allow weld splatter to remain on
~
metal surfaces. This could contribute to coatings failure.
Response IV. B.6.c The correct terminology is weld spatter. Consistent with paragraph 4.4 and 4.4.3 of ANSI N101.4-1972, the project specification did and does " provide for" removal of all welding scale and spatter considered necessary by Engineering "to avoid contamination of substrates." We are not aware of nor does the Brookhaven report establish a basis.for a concern with weld spatter from a safety related viewpoint. Commercial concerns are not subject to the stringent requirements applied to safety related activities. Neither the FSAR reference nor Reg. Guide 1.54 discusses the issue of weld spatter.
Page 15
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TXX-4232 07/20/84 Finding IV. B.6.d Contrary to CPSES FSAR, page 1A(B)-22; R. C.1.54, and ANSI 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.
Response IV. B.6.d The finding by BNL is correct, but is a matter of form rather than substance. Nine special coatings procedures exist at CPSES. For eight of these procedures, the manufacturer's Product Data Sheet is the substantive portion of the procedure, and therefore, are approved by the coatings manufacturer. The remaining special coatings procedure is for repair of a Carboglass lining of the component cooling water heat exchangers. This procedure was developed to match the vendor's (Struthers Wells Corp) procedure which was based on Carboline's Product Data Sheet. As the coatings manufacturer's Product Data Sheet was an integral part of the special coatings procedures, the intent of the ANSI Standard has clearly been satisfied.
Page 16
TXX-4232 07/20/84 Finding IV. B.6.e Contrary to CPSES FSAR, paragraph 6.lB.2 and ANSI N.101.2, coatings applied over "drypack" concrete repairs were not DBA-qualified. Additionally, the "drypack" does not appear to meet paragraph 6.4.2 of ANSI N101.2-1972.
. Response IV. B.6.e Section 6.1B.2 of the FSAR simply discusses the types of coating materials used at CPSES and the industry standards which are applicable to them.
Paragraph 6.4.2 of ANSI N101.2-1972 discusses general comments relative to preparation of concrete surfaces. Since "drypack" is a standard repair technique for concrete and since drypack is composed of the same basic ingredients as concrete, we fail to appreciate the significance of this finding.
Page 17 lb
TXX-4232 07/20/84 Finding IV. C.7 Based on a brief review of Design Change Authorizations (DCA's) written in the coatings area, it does not appear as though Quality Assurance is included in the review and approval chain, as would be required by 10 CFR 50 Appendix B, Criterion III. Also, there is no formal mechanism to ensure that users of controlled copies of the Coating Specification have received and are aware of all applicable DCAs. Finally, there is no requirement for specification revision after DCA's have been issued against it, either based on time or number of DCA's. Additional review in this area is needed to determine how quality is assured in the DCA program.
Response IV. C.7 Criterion III of Appendix B provides for the establishment of design control measures for verifying or checking the adequacy of design. The verification process shall be performed by individuals or groups other than those who performed the original design but may be from the same organization.
' Criterion III does not require that Quality Assurance be included in the
" review and approval chain" for the design verification of the original design or subseqvent design changes.
Contrary to this finding, formal procedures exist which describe the measures that have been' established and implemented for the control of design documents. These. procedures meet the require =ents established for Criterion VI, Document Control, of 10CFR50, Appendix B.
Page 18
TXX-4232 07/20/84 Relative to specification revisions, il is true that no requirement (regulatory or otherwise) exists which mandates when a specification should be formally revised, either based on time or number of DCA's. This is a management decision and specifications are revised when considered appropriate by management.
In summary, we fail to define a regulatory issue and thus do not agree that
. additional review is warranted.
Page 19
TXX-4232 07/20/84 Finding IV. C.8 Contrary to FSAR Section 6.lB.2. ANSI N101.2, Section 4, a number of coatings systems have been specified and used that have not been DBA qualified. After identification of this by BNL, the licensee has committed to submitting these coatings systems to the appropriate DBA testing.
Response IV. C.8 _
As delineated in our separate responses to the sixty allegations transmitted by Mr. Bangart's letter of May 19, 1984, some minute combinations of coatings have not been separately DBA tested. However, where these conditions do occur, they are small in magnitude and have been applied consistent with normal industry practice. It should be noted that no formal committment to test these combinations of coating systems has been made nor is one currently anticipated. It was made quite clear to Region IV and BNL i
personnel at the outset, that no testing would be undertaken without management concurrence, particularly when the testing could be classified as "Research and Development."
6 Page 20
TXX-4232 07/20/84 Finding IV. C.9 Contrary to FSAR Section 1A(B), Regulatory Guide 1.54 Section C.4, "STAF Hospital Spray Disinfectant", an aerosol containing chlorides, was used by painters inside containment where stainless steel is located.
Response IV. C.9 -
This matter is explained fully in our formal response to allegation number
- 41. (See TXX-4201, dated June 22, 1984).
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p L AW CrrlCEO ROGOVIN, HuoE & LENZNER
- a. Paortssionat concomation MITCHELL ROGOVIN 873o RHoDC ISLAND AVENUE, N. W. JAMES r. NEAL
"^""*" WASHINGTON, D. C. Zoo 36 ERRY r EN2NER GEORGE T.FRAMPTON,JR.
JONATHAN D.SCHILLER TELEPHONE DAVID R.BOYD June 12, 1984 (2o2) 4ss e4e4 RONNA LEE SECM EUGENE J.COMEY TELECOPIER VICKl C.JACMSON KRISTA M. FOGLEM AN (202) 466 6420 SUSAN L. CARNEY SAUL B. GOODMAN RANDALL LEE SPECK MICHAEL D.LOWE GARY K.HARRi$
LISA R.M ARX JEFFREY H 8LATTNER JAMES E.PFANDER Joseph Felton PREEDOM OF INR)RMATION Director ACT REQUEST Division of Rules and Records Office of Administration U.S. Nuclear Regulatory Commission h d -/,J -[ [
Washington, D.C. 20555 Re: Freedom of Information Request
Dear Mr. Felton:
Pursuant to the Freedom of Information Act, 5 U.S.C.
S 552, and the regulations promulgated thereunder by the Nuclear Regulatory Commission ("NRC") at 10 C.F.R. Parts 2 and 9, we hereby request that you provide us with the fol-lowing documents:
- 1. Copies of all records in NRC's files pertaining to any studies, investigations, inquiries (formal or informal) concerning the Comanche Peak Nuclear Power Plant (" Comanche Plant") in Texas as well as any agency documents, internal memoranda, reports, complaints, citations and orders which pertain to the Comanche Plant.
We are primarily interested in any materials related to or concerning construction of the Comanche Plant, by Brown &
Root, Inc., including safety conditions, employee relations, work standards, allegations of inferior work, faulty workmanship, deficient work standards, and deficient performance.
- 2. Copies of all records in NRC's files pertaining to any studies, investigations, inquiries (formal or informal),
agency documents, internal memoranda, reports, complaints, citations and orders which pertain to Brown & Root, Inc., a Texas corporation involved in the construction of nuclear power plants.
660'. god t
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RocovlN, HUGE & LENZNER A PRO FESStON AL CORPORATeON Joseph Felton June 12, 1984 Page 2 Please call the undersigned as soon as the documents are available and please notify us if you anticipate that the expense of complying with this request exceeds $200.00.
Thank you for your cooperation.
Sincerely, ROGOVIN, HUGE & LENZNER t - I f By: NO Harry Huge }
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