ML20136B782
| ML20136B782 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/16/1984 |
| From: | Lettieri V BROOKHAVEN NATIONAL LABORATORY |
| To: | Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20136B196 | List:
|
| References | |
| FOIA-84-779 NUDOCS 8511200286 | |
| Download: ML20136B782 (5) | |
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BROOKHAVEN NATIONAL LABORATORY l^'
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ASSOCIATED UNIVERSITIES, INC.
L Upton. Long is'onc. New York 11973 (516) 282s 4092 Ceocriment of Nuclect Energy F TS 66$,.
Febru a ry 16, 1984 i
Doyle it. Hunnicutt J
U.S. fluclear Regulatory Ccrnmission Recion IV 611 Ryan Plaza Drive, Suite 1000 Arli'ngton, Texas 76011
Dear Doyle:
Attached are allegations eighteen (18) throuch thirty-three (33) con-cerning the protective coatings at Comanche Peak.
I would appreciate your forwarding these allegations to the utility. We also request that util-ity responses to the allegations be available on site for our review on Februa ry 27, 1984
'1 Yours truly p
A j
Vincent lettieri Plant Systems a Equipment Analysis Group VL/nn Enc.
cc:
R. Bari R. Hall
'F. Hawkins (fiRC Reg. III)
J. Hincins C. Johnson (flRC Reg. IV)
E. Johnson W. Kato J. Taylor T. Westerman hI%0 851025 GARDE 84-779 PDR J ') 3
2/16/84 ALLEGATIONS CONCERNING COMANCHE PEAK PROTECTIVE COATINGS Note: For Allegations 1 through 17 see inspection report 50-445/84-03; 50-446/84-01, Attachment 1.
I 18.
It is alleged that QC inspectors are not allowed to identify visual de-fects such as cracking or blistering during backfit inspections.
19.
It is alleged that Instruction Number QI-QP-11.4-23 and QI-QP-11.4-24 are very vague regarding the way the backfit inspections are to be conducted.
20.
It is alleged that adhesion testing of the protective coatings are not performed properly. The QC inspectors are instructed not to cut around the adhesion test dollies when conducting adhesion tests. The instructions that come with the machine tell you to do so (and Specifica-tion AS-31 references these' instructions).
21.
It is alleged that Brown & Root is doing tne calibration on these adhesion testers, and they are not using a corrected value curve (which snould have been supplied witn each unit).
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22.
In the present oackfit program, QC inspectors are required to take read-ings with adhesion testers without receiving formal training.
23.
It is alleged that the Coatings QC Program at CPSES is inferior to the same programs at other nuclear power plant projects. One reason is tnat standard inspection practices, used at other sites, are not used at CPSES.
For example, a sample adhesion test used by a QC inspector regularly at another site, was not allowed at CPSES by one of the QC lead men. This is the ASTM tape adhesion test.
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. i 24 It is alleged that Q coatings have been placed over rusty, scaly un-prepared metal surfaces inside pipe supports made of tube iteel without
~1Eid-caps.
In these cases, the protective coating gets on the rusty inside of the tube.
This coating material could later crack, scale, come off the pipe, and then travel to the sumps.
25.
It is alleged that a seal coat was accepted prior to the finished coat being applied, when in fact tna seal coat should have been rejected.
The area in question is just outside the Skimmer Pump Room, in Reactor Con-tainment Building-Unit 1, on the steel liner plate. Tne stains on the 4
liner plate in the opinion of the inspector were not acceptable per pro-cedure and should have caused the seal coat to be rejected for finish coat application. The QC insoector brought the condition to management's at-tention and requested their opinion. Management stated that the stains were in fact rust stains and acceptable, wnile the QC inspector felt it was obvious that the stains were not rust and unacceptable.
The QC in-spector stated: "The reason I accepted this was because I feared adverse action would Le taken against me if I rejected it."
The QC Inspector goes on to say that this area has the finish coat on it now and none of the stains are visible.
26.
It is alleged that Design Change Authorization (DCA) documents are not I
controlled.
27.
It is also alleged that DCAs at CPSES are originated and approved totally by engineering. QA/QC has no input in the review and disposition of DCAs.
28.
It is alleged that DCAs are used frequently and conveniently to cover up a condition for which a Nonconformance Report (NCR) should be written. The alleger estimated that 40% of the DCAs are for NCR conditions.
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- 29. It is further alleged that DCAs are written to overcome a problem area which will take considerable time for repairs.
In other words, the DCAs are used to facilitate the completion of a job even though this means that i
I accepted procedures will not be followed.
4 30.
It is alleged that on numerous occasions DCAs have been issued to down-grade the surface preparation from an SP-10 to an SP-6 standard prepara-tion.
It is further alleged that DCAs are also written to downgrade Specification AS-31 requirements in containment to AS-30, wnich is the i
non-safety specificatio.
The downgrading of an SP-10 to an SP-6 surf ace preparation is an example of DCAs being written to downgrade from an AS-31 to an AS-30 requirement.
i 31.
It is further alleged that QC management interpreted an SP-6 on a DCA to mean "do the best you can".
For example, when difficult access areas were involved, QC management tilegedly stated to the QC inspectors, if you can-not get to an area, do not worry about it.
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32.
It is alleged that after a reading list was signed by QC inspectors, the document that they read was removed and replaced by a different document, yet the reading list coversheet remained the same.
t
l Coatings Lead Inspector's (Individual K) lack of experience in QC. An 1,
example of this was when he identified the rust on an A-frame in the core
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area as being D-6 residue.
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nac Form 307 ALLE2ATl5N DATA FORM u s Nuctor.a trGutAvo::v Cowissios (11 5 6 instructens on revem suse RECEIVING OFFICE Docket Number (if applicable)
- 1. Facility (les) Involved:
Imamei in mo.. sens.orn unrMcHe 0MW 0 5~O O O 4 4 S
genenc. wnta GENERICI f LFA/ $BW 1'Y, 0 $ O C) O 4 4
$9 v
- 2. Functional Areats) Involved:
(Check opproonate boitesi l operations onsite health and safety 1 construction offsite health and safety safeguards emergency preparedness other tspecifvl 3.
Description:
b @lA2 SI / IDI IM EI III I I I I I I I I I I ll I IIIIIIIIIIIIII!III IIIIIIII II IIIIII II IIIIII II II IIIIII IIIIIIIIIIIIIIIIIIIIIIIIII
- 4. Source of Allegation:
(Check oppropnete boal contractor employee security guard licensee employee news medie NRC employee private citizen organization tspecifvl I other (Speelfyl,M#MA E [N d #
7 MM 00 YY
- 5. Date Allegation Received-N8 9I
- 5. Name of Individual trir.: ew. 6nisini end wet namei Receiving Allegation:
- 7. Office:
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ACTION OFRCE 8AI
- 8. Action Office
Contact:
Fir. ew. 6nitini and so. nemet S. FTS Telephone Number:
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7 g fC Open,if followup actions are pending or in progress c
Closed, if followup actions are completed 2
MM OD YY ii. D.t. Ci s.d; j
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- 12. Remarks:
l g l,jglgl lglflgl l l l l l l l l l l l l l l l l f time to 50 cherectorsi IIIIIIIIIIIIIIIIIIIIIIIIII Office Year feumber
- 13. Allegation Number:
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