ML20140H267

Rev 7 to CPM 13.1, General Calibr Procedure

ML20140H267
Person / Time
Site:	Comanche Peak
Issue date:	12/09/1981
From:	Frankum D BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.)
To:
Shared Package
ML20140H266	List: ML20140H259 ML20140H267
References
FOIA-85-59 CPM-13.1, NUDOCS 8510150451
Download: ML20140H267 (22)

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}0TO-E TEXAa UTILITIES GENERATING COMlwNY gg OFFICE MEMOR A NDUM sTo R- G. Tnison 'F Dallas, Tex as hnuary 2? lor 7 IjPi Subject COMANCHE PEAK STEAM Et ECTRIC STATION EVALUATION OF AUDIT RESPONSE TCP-24 PROTECTIVE C0ATINGS QA AUDIT FILE: TCP-24 Your additional response to TCP-24 logged TUQ-1085, dated December 30, 1981, has been evaluated by TUGC0 QA. We consider your responses to Deficiency No.1 and Concern No.1 acceptable. No further response is necessary. As discussed with you, we plan to evaluate your preventive measures for Concern No.1 during a site audit scheduled for the week of January 25-29, 1982. We will schedule an audit to evaluate your corrective actions as described in your response dated December 30, 1981, consistent with your April 30, 1982 implementation date.

Thank you for your cooperation.

D. N. Chapr n j Manager, Quality Assurance DNC/AV/DLA/R S:med cc: B. R. Clements J. T. Merritt G. R. Purdy G. W. Parry RECEIVED i JAN 2 51982 l

QUAuTy As

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w D. N. Chapman Glen none. Texas December 30, 1981 Subjeet TUGCO- OA Audit TCP ,

F6rinil~ Resp 6nse

Reference:

TUQ-992,QTQ-96,TUQ-1016 The following represents our femal response to TUGCo QA Audit TCP-24 DEFICIENCY NO. 1 Requirenent:

QI-QP-11.4-10, Revision 1, paragraph 3.1.1 states, in part. "The surface temperature shall be detemined by placing a calibrated surface temperature themometer in contact with the substrate surface to be water blast cleaned.

CP-0P-13.0, Revision 2, paragraph 3.3 states, in part, "The quality engineering supervisor shall be notified in writing by the! calibration facility when M&TE or reference standards are found to be out of calibration. He will assure that all equipment tested or calibrated by the deficient item since the last calibration is identified and sufficient investigation perfomed to either re-establish the acceptability of the

- equipment or to confim a nonconfomance with completed installations. The results of such investigation shall be documented.

Finding:

I Contrary to the above the following discrepancy was found.

0 M&TE 444 used on 5/6/79 and 5/17/79 on RB #2 El. 808' for AZ 7 - AZ 40 was calibrated on 3/9/79 and calibration was due again on 6/9/79. The surface

' themometer was found to be out of calibration on the high-range scale per

, j IEI-25.

On 6/7/79 a letter was sent to the Paint Department Superintendent stating the aoove condition and requesting a check for possible nonconfomance. The

. Paint Department Superintendent replied on 6/15/79 stating that the

! themometer had not been used in conjunction with any final acceptance

. records. However a QC final acceptance of a surface application checklist was identified using M&TE 444 (checked out to the Paint Department) for final acceptance on 5/17/79.

RESPONSE

l After further investigation into the nature of the condition identified by Deficiency No.1, we have concluded that said condition is in fact not a 4 deficiency. The subject QC inspection checklists for inspections performed on 5/4/79 at El. 808' in Reactor Containneng Building Unit #2 indicate a concrete surface temperature reading of 62 F. This reading is close to the i ,

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} O. N.' Chapman' Page 2 ,

December 30, 1981 l midpoint of the low range scale of M&TE 444 (0 to 110 F) and M&TE 444 was 1 found to be within low-range calibration limits of IEI-25 during the calibration check co.lducted on 6/7/79. The high-range scale of M&TE 444 was found to be out of calibration on 6/7/79 but it was not used in this Quality Inspection.

In addition, a further check of all concrete coatings records revealed that i

, M&TE 444 was used by QC in 27 other Quality Inspections bgtween g/8/79 and j  ! 7/5/79 with recorded surface temperatures ranging from 72 to 88 F - all within l

! the low-range scale. It should be noted here that since early 1980, all surface f thermometers have been celibrated to the low-range scale only because it was determined that they were not being used in the high-range scale.

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- We have concluded that the condition noted in Deficiency No.1 is not a l

I deficiency, and therefore, no corrective action is required.

CONCERN NO. 1 ,

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) Curing review of QC Inspection documentation, Auditors identified three 3

a types of problems occurring within the 8 packages (35 Inspection Documents) observed in the course of the audit. It is understood that no final acceptance

- of these documents has been made but is is felt the problems identified j could have a detrimental impact on the final acceptance process of the records i involved. The problems identified are: l e

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1. Procedural Inconsistencies 4

) i, Incorrect pot life 2 of 35 l

l M&TE number not recorded 6 of 35-l ,

Applicable Quality Inspection '

not recorded 6 of 35 Applicator not listed 2 of 35  ?

No date 1 of 35  ;

No Inspector initials' or  !

signature 1 of 35

Mixing time / Batch number left 1

blank 1 of 35 i j Dry Film Thickness recorded but

not initialed or dated 1 of 35 l

i The majority of the inspection documentation has not had final acceptance j and has not been formally transmitted or accepted in Permanent Plant Records j Vault.

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December 30, 1981 i l

2. Surface Temperature is required to be 50 higher than dew point prior ,

to application. One checklist was found where this criteria was not met.

3. In 3 of the eight packages observed, ty finish coat had been applied:

however, checklists documenting the pre:eding applications (i.e. surfacer

! and surfacer repairs) had not been completed ner finally accepted.

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! Please indicate what actions you propose to take with the inspection documents l currently stored in the PPRV to address the above three problem areas.

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1 RESPONSE l An extensive review of concrete coatings inspection documentation is now in i process. The problems which we have identified are similar in nature to those i

, identified in Concern No.1. We share your concern that these documentation *

! problems could have a detrimental impact on the final acceptance process of l

subject documentation. l 1

l Corrective Action: 3 j  ; As indicated above, we have. begun a review of all concret coatings inspection

, documentation. Based upon problems noted in a prelimina review, we have

} i initiated NCR numbers C-81-01613. R.1 and C-81-01823. These NCR's identify the fact that a majority of concrete coatings inspection reports issued prior 4 to 11/11/81 exhibit omissions of various entries including dry film thickness, l  ! final acceptance signature and date, applicable inspection instruction, M&TE j  ! number for test equipment used, visual defects and continuity inspection

i i results, names of qualified applicators, etc. We will attempt to complete i , , entries in subject documentation based upon infomation available from cor-responding inspection reports which contain the missing information or from a

l field books and sketches maintained by QC Inspectors. All records for which l missing entries cannot be obtained shall be presented to Civil Engineering

! , for evaluation and inclusion as part of disposition to the above mentioned '

l l NCR. In some cases it may be necessary to perfom , destructive testing on 1

[ concrete coatings to verify confomance to Specification AS-31 and Quality ,

, t  ; Instructions.  ;

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Action to Prevent Recurrence

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! . As previously noted in our preliminary response to prevent recurrence of l

conditions noted in Concern No.1, the following action has been taken:

1) Quality Instructions describing coatings application on concrete substrate j  ! have been incorporated into a single Inspection Instruction QI-QP-11.4-10, 1 I " Inspection of Concrete Substrate Surface Preparation and Coatings Applica-

] l l tion and Repair", which was issued 11/11/81.

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! 2) All Protective Coating inspection personnel were indoctrinated in the l i new QI-QP-11.4-10 including explicit instructions on completion of new i g inspection reports.

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!j D. N.' Chapnan l Page 4 December 30, 1981 i

Date Corrective Action to be Fully implemented:

As noted above corrective action is presently in process of being implemented.

We anticipate that corrective action on concrete coatings documentation will j j be fully implemented by April 30, 1982.

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h l M R. G. ' Toison j '

TUGCo Site QA Supervisor l

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.TUGC0 QA. Audit TCP-24 '

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" Action to' Prevent Recurrence

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Reference:

TUQ-992 and QTQ-96 I '

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I Attached find preliminary response to prevent recurrence of findings /

concerns expressed in TCP-24. As stated in TUQ-992, formal response to this audit will be provided on or before January 4,1982.

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e PRELIMINARY RESPONSE TO PREVENT RECURRENCE i

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i j Preliminary action to prevent recurrence is corplete. Quality Procedure ,

l CP-QP-11.4 was revised 10/29/81 to require documentation be cocoleted 4  ; and submitted to the Permanent Plant Records Vault in a timely fashion.

l Quality Instructions concerning inspection of surface preparation of '

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, steel substrate, primer application and repair have been consolidated j .into a single inspection instruction Ql-QP-11.4-1, " Inspection of Steel

Substrate Surface Preparation and Primer Application and Repair". This j l procedure was issued 10/23/81.

! I 1 Quality Instructions describing application and repair of seal and finish j coat were combined into a single instruction QI-QP-11.4-5, " Inspection of i Steel Substrate Seal and Finish Coat Application and Repair", which is to be issued this date.

! Quality Instructions describing coating application on concrete substrate 4

l have been incorporated into a single Inspection Instruction QI-QP-11.4-10,

! " Inspection o.f Concrete Substrate Surface Preparation and Coatings l .

'*- -)g - Application and Repair", which was issued 11/11/81. t

) All Protective Coating inspection personnel were indoctrinated in new 4 i procedures / instructions, including explicit instructions on completion i of new inspection reports.

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i QTQ-96 TEXha UTILITIES GENERATING COMrANY i OFFICE MEMOR ANDUM To R. G. Tolson Dallas, Texas November 13, 1981 )

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3 Subject TUGC0 DA AUDIT TCP-24 j I

The extension requested for additional time to provide response to audit TCP-24 will be conditional. The extended time requested for response to corrective action is acceptable; however, it is necessary that your response to prevent recurrence be submitted by November 23, 1981.

I N. Chap

! Manager, Ouality Assurance WCY DNC/AV/DLA/RHS:med 1

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OFFICE M EM OR A N DU M T.. . D.,N,. Chapman ,.

an.... it. ., *r.. a. October 30, 1981 s .i.i.,.i TUGC0 9A Audit TCP-24 I

Due to the amount of program restructuring in the area of protective coatings as a result of the NRC citation on the subject, we are requesting an extension until January 4,1981 to provide response to the subject audit.

Additional time is necessary to evaluate the program before providing response.

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R. G. Tolson l TUGC0 Site QA Supervisor j

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