ML20141F019

Forwards Util Providing Results of Review of Coatings Nonconformance Repts w/use-as-is Disposition & Description of Coatings Surveillance Program for Containment Coatings Over Life of Plant

ML20141F019
Person / Time
Site:	Comanche Peak
Issue date:	12/26/1985
From:	Noonan V Office of Nuclear Reactor Regulation
To:	Mccracken C Office of Nuclear Reactor Regulation
References
NUDOCS 8601080493
Download: ML20141F019 (2)

Text

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s OEC24 W MEMORANDUM FOR: Conrad McCracken, Section Leader PWR Project Directorate #6 #(O w f '

Division of PWR Licensing-B FROM: Vincent S. Noonan, Director PWR Project Directorate #5 Division of PWR Licensing-A

SUBJECT:

PROTECTIVE C0ATING SURVEILLANCE PROGRAM By letter dated November 18, 1985, from W. Counsil to V. Noonan, TUGC0 submitted the results of their review of the coatings Non-conformance Reports where use-as-is was the disposition. In addition, this letter describes a program that will provide an in situ performance evaluation for coatings in the CPSES containment over the life of the plant. Please review this material and inform us by December 31, 1985, of the date you can provide your Safety I

Evaluation.

Vincent S. Noonan, Director PWR Project Directorate #5 Division of PWR Licensing A

Enclosure:

Letter from Counsil to Noonan, dated November 18, 1985 cc: J. Stolz F. Miraglia Distribution u ,Decket erzCentraliFileL;

.NRC PDR Local PDR PD#5 Reading File H. Thorrpson Project Manager M. Rushbrook B601w o m 851226 ADOCK 05 45 D. Eisenhut gDR

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i MEMORANDUM FOR: Conrad McCracken, Section Leader PWR Project Directorate #6 Division of PWR Licensing-B FROM: Vincent S. Noonan, Director PWR Project Directorate #5 Division of PWR Licensing-A

SUBJECT:

PROTECTIVE COATING SURVEILLANCE PROGRAM By letter dated November 18, 1985, from W. Counsil to V. Noonan, TUGC0 submitted the results of their review of the coatings Non.conformance Reports where use-as-is was the disposition. In addition, this letter describes a program that will provide an in situ performance evaluation for coatings in the CPSES containment over the life of the plant. Please review this material and inform us by December 31, 1985, of the date you can provide your Safety Evaluation.

Vincent S. Noonan, Director PWR Project Directorate #5 Division of PWR Licensing-A

Enclosure:

Letter from Counsil to Noonan, dated November 18, 1985 cc: J. Stolz F. Miraglia Distribution

-Docket or central File NRC POR Local PDR PD#5 Reading File H. Thompson Project Manager M. Rushbrook D. Eisenhut

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ENCLOSURE a -

Log # TXX-4613 TEXAS UTILITIES GENERATING COMPANY F He # 10010 mETWAT TUEFES . <tes feOSTN OBJVW WTREST. E B. 85

• DALAAa, TREAS TSSet WILLaAnd 4. COUsestL '

Director of Nuclear Reactor Regulation Attention: Mr. Vince S. Noonan, Director Comanche Peak Project Division of Licensing .

U. S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION DOCKET NOS. 50-445 AND 50-446 CONTAINMENT C0ATINGS PERFORMANCE

Dear Mr. Noonan:

This letter provides the results of our review of the coatings Non-conformance Reports where use-as-is was the disposition. The requirements of Supplement 9 of the CPSES SER (Action required for Category 3 Coatings issues) was carried out. In addition, this letter describes a program that will provide an in situ performance evaluation for coatings in the CPSES Containment over the life of the plant.

A search of the records on coatings NCR's has been conducted. In addition to the NCR's discussed in SSER 9, fif teen additional NCR's concerning the processing of protective coating material have been identified. Of the total of eighteen (18) NCR's, seven (7) were dispositioned use-as-is (see Attachment I) and eleven (11) were dispositioned scrap, rework, or return-to-vendor (see Attachment II).

The technical justification for the use-as-is disposition has been reviewed by the Coatings Engineering Manager and a third party consultant who found the technical justifications adequate to demonstrate the acceptability of the batches of coating materials listed in the NCR's.

A comprehensive. program will be carried out to assess the performance of the Containment coatings throughout the life of the plant. Attachment III outlines performance the during procedures that will be followed for review of coating operation. The areas that are chosen for emphasis in the coatings surveillance program are the areas of the Containment which can contribute debris to the recirculation sumps and the areas identified in the Coatings Exempt Log (CEL).

Very truly yours, f f /f*

W. G. Counsil

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• ATTACHMENT 1 The following NCR's for protective coatings processing were dispositioned use-as-is. The technical justification for these dispositions have been reviewed by the Coatings Engineering Manager and -

an independent reviewer and found to be acceptable. No further action is required for any of the items.

NCR C-83-03307 (revision 2), dated February 13, 1984, documented that foreign contamination, apparently paint chips, was observed in three 5 gallon cans of thinner batch 3J3033M. A sample of the thinner was analyzed by Carboline using a gas chromotograph. No dissolved contamination was found. Carboline, in reference 1, stated that the chips may have been baked Phenolic and the thinner would have no effect on it. The remaining thinner was strained to remove any particles.

, NCR C-82-02173 (revision 1), dated December 3,1982, indicated that a batch of Phenoline 305 thinner, batch 2K3374M, was amber in color instead of being clear. Adhesion tests were performed on one of the items coated with this batch. The test values were 525 psi. 400 psi and 600 psi. A test panel was prepared using this material. The sample's surface was free of irregularities and appeared to cure normally.

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NCR C-81-01724 (revision 1), dated December 14, 1981 identified indeterminate conditions for three batches of Phenoline 305 Catalyst Part "B". Batch OM2708M was a dark wine in color rather than being an amber color. It also had settled particles in the can. Settled particles were also found in batch OL2531M. Suspended fine particles were found in batch 1J2791M. Samples of all three batches were sent to Carboline. The batch with the dark wine color was tested and the color aid not affect the cure. Carboline stated that the particles were foreign material which may have fallen into the can prior to loading.

They stated in reference 2 and 3 that if the batches are screened the effect on the performance of the coating will be negligible. It was also stated that the dark wine color would not affect the coating system

, performance.

NCR C-81-01673, dated December 6, 1981, noted that pigment was floating in a batch of Phenoline 305. In reference 4 and 5 Carboline stated that this often occurs when thinned greater than one quart per gallon and the product should cure properly and be suitable for use. Nine electrical supports coated with this product were visually inspected and found to be acceptable. Dir.ections were given to use an agitated pot if float occurred.

NCR C-1758, dated October 17, 1979, stated that Carbo-Zinc 11 Base, batch number 9K5382M contained unidentifiable deleterious matter and/or foreign containments. The batch was checked and it was determined that the material was base material'which was not totally dispersed into the liquid due to a variation in grind size. The material was thoroughly

- mixed and then strained. Where accessible this batch of zine was reinspected for cure and appearance. The areas inspected are listed on inspection reports 2242, 2243, 2245, 2246, 2472 and 2473. In all cases the coating was found to be acceptable.

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. NCR <-436, dated November 29, 1976, documented that the temperature in paint storage dropped below 400F for approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. In reference 4 Carboline stated that a temperature of 32of could be tolerated for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without affecting the cure, physical and * }

t j chemical properties, or the LOCA performance of the coatings. The  !

i temperature never was as low as 320F. t 1

NCR C-82-02115, dated November 23, 1982, documented that 199 gallons of

Phenoline (Primer and Finish), Batch Numbers (Part A) 2L363M and (Part

8) 213547M, were received with no temperature recording device or other '

i evidence that temperature was maintained during shipment, with reference i to Specification 2323-AS-31 R1. Para 3.3.8. Material received was not

! marked with itorage conditions on original unopened containers as

required per Specification *2323-AS-31 R1. Para 4.0.4A. Paragraph 3.3.8.

', does not apply to storage and shipping prior to jobsite receipt; it refers to materials control following site receipts. Coatings storage j and shipping prior to jobsite receipt was not addressed in Specification 2323-AS-31 Rev. 1. DC/00A 1615, issued on March 15, 1978, waived the requirements of having the storage requirements on the container labels ,

for coating materials received by Brown & Root. DC/00A 1615 was  !

incorporated into Specification 2323-AS-31 Rev. 2 on March 15, 1984.  !

i REFERENCES i

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1. Stewart, Duncan M., Carboline QA/QC Manager, Letter to Kelly, Tom, 1 Ebasco Services, dated January 30, 1984.

2. Noles, Rick, Carboline. Telex to Frankum, D. C., dated December 31,

1981.

i 3. Salem, Linda, Carboline Laboratory Projects Manager, letter to

!" Frankum, D.C., Brown and Root, Inc. dated February 19, 1982. l

! 4. Robinson, Perry, Carboline Nuclear Coatings Engineer, Telex to Wells, Mark, dated December 10, 1981.

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! 5. Robinson, Perry A., Carboline Nuclear Coatin s Engineer, letter to Wells, Mark, Brown and Root, dated December $6,1981.  !

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! 6. Tegtmeyer, Ro j November 30, 1976, ger; of Carbo 11ne, telex to Sutton, Don, dated i I l

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6 ATTACHMENT II The material listed on the following NCR's for protective coatings processing were either returned to the vendor, scrapped or reworked as '

appropriate.

NCR C84-01320 dated April 30, 1984: One can of Phenoline 305 Finish, Part 8, batch 4A0108M contained a foreign substance and was scrapped.

The other containers for this batch did not have any evidence of contamination.

NCR C-84-00446, dated February 7, 1984: One 25 gallon can of Phenoline 305 Finish, Part 8, batch 3H2668M contained a foreign substance and was scrapped. The other containers for this batch did not contain any evidence of contamination.

NCR C-82-01245, dated August 18, 1982: The certification received for Phenoline 305 batches 2G2139M (Part A) and 292140M (Part B) referenced the wrong P.O. number. The vendor resubmitted documentation reflecting the correct certification number.

, . NCR C-1729 (Revision 1), dated October 17, 1979. Carbo-Zinc 11 base, batch 945381M, contained contaminants believed to be grease. The batch was returned to the vendor.

NCR 1709, dated September 19, 1979: Carbo-Zinc 11 base, batch 9F5366M, was noted having thin viscosity and lumping after mixing. The batch was returned to the vendor.

NCR C-1542 (revision 1) dated August 30, 1979: Southern Imperial (now

, known as Imperial Professional Coatings) thinner OL-54, batch 1737-E249 contained foreign contaminants. The material was scrapped.

NCR C-1060, dated August 1, 1978: Carboline Zinc dust had lumps which would not mix with the base material. It had a grit-like texture and numerous bubbles were present during mixing. The material was returned to the vendor.

NCR C-1044, dated July 26, 1978: Southern Imperial thinner OL-54 contained suspended red particles. The material was returned to the vendor.

NCR C-948, dated April 13, 1978: Eighty-one containers of Imperial Coatings Nutec 11 curing agent varied in weight. The containers were weighed. Forty-one were acceptable, thirty-nine which were incorrectly labeled were reltbeled and one was scrapped.

NCR C-719, dated July 22, 1977: Twenty-nine, 5 quart containers of Carboline 305 catalyst were leaking. The material was returned to the i vendor.

NCR 391, dated October 5, 1976: Carboline zine filler, batch 6J6770Z, twenty-seven, 73 pound units; on site with no source inspection. An on-site receiving inspection was conducted by quality control and the l

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material found to be acceptable. The vendor was' notified in writing that the requirements of the P.O. must be met.

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ATTACHMENT III COATINGS SURVEILLANCE PROGRAM l

Background:

CPSES Safety Evaluation Report, Supplement 9 concludes that

, the coatings inside the reactor containments of Comanche Peak have no

! safety significance. However, in the same document the NRC staff j requests that CPSES undertake a program to monitor performance of the

coatings systems over the Itfe of the plant. This attachment describes j the program that CPSES proposes to follow.

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i. Pronram Content: The* Coatings Surveillance Program contains the

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1 1. Selection of paint areas for inspection that have higher radiation

exposure and may not have had full QA/QC verification (indicated by

appearing on the Coatings Exempt Log).

2. Selection process for coatings surveillance will consider the station ALARA guidelines to minimize exposure consistent with a good r surveillance program.

3. A training and qualification program to assure that personnel

{ conducting surveillance can properly detect, classify and record paint failure as well as verify the adequacy of repair.

j 4. A prograssiatic approach that assures regularly scheduled j survelliance with adequate records keeping.

Selection of Inspection Areas: Areas for inspection will be selected on the following bases:

1. Areas in higher radiation zones that are accessible for rapid inspection.

. 2. Areas which are listed in the Coatings Exempt Log.

3. Areas where hydraulic studies have concluded that some paint flakes

! could migrate to the sump. This area is defined by the floor at EL 808, cei'ing under EL 832'6", the liner plate and steam generator

! compartment wall from azimuth 315 clockwise to azimuth 60 and l from azimuth.120 clockwise to azimuth 225 in Unit 2.

1 Program Training Requiroments: Personnel conducting the inspections will be experienced personne' with demonstrated capability to identify the conditions discussed in the Inspection Requirements section below. In addition, they will be trained to initiate correct work documents for p repair and to record all inspection activities as appropriate to plant j procedures and as discussed below in Inspection Requits.ments.

j Program Implementation: The responsibility for. execution of the Coatings Surveillance Program will be assigned in plant procedures and will include ir.spection activities, resultant repair activities and documentation of both inspections and repairs. Plant procedures will assure that the Coatings-Inspections are factored into the work plan for each outage. All documentation of coatings inspections and coating repairs or recoatings will be reviewed for completeness and accuracy.

l Inspection Requirements: Inspections will be conducted in the areas as indicated above using scaffolding or optical aids as necessary. The following conditions will be noted where occurring:

Fine line cracking Checking

- Softening Tackiness Blistering

Flaking 4

Delanination

Undercutting Discoloration

, Nechanical damage Rusting '

See attached Description of Coating Failure Types for description of failures. Failures will be documented by mapping, marking or photographing as appropriate.

! Repair Determination: Concrete coatings exposed to severe or moderate radiation levels (light, moderate, and severe radiation are defined by

' procedure) will be repaired as soon as practical. For coatings on steel surfaces repair will be based on the Steel Structures Painting Council (SSPC) publication Standard Methods of Evaluating Degree of Rusting on Painted Steel Structuras (see Scale and Description of Rust Grades i attached). Schedule for repair will be determined based on the degree of rusting discovered during the inspection and a predetermined table of~

expected life time using degree of rusting as an entering argument.

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DESCRIPTION OF COATING FAILURE TYPES l

The following is a description of coating failure most commonly found in an operating facility.

Crackins  !

Cracking is an age-related failure. It is not a surface phenomenon but one where breaks in the coating penetrate to the underlying surface.

Alliastorina Alligatoring can be considered a macro-checking failure and is caused by internal stresses set up within and on the surface of the coating. The stresses cause the surface of the coating to shrink much more rapidly and to a much greater extent than the body of the coating.

i Mud-Crackins Mud-cracking can be considered a macro-cracking phenomenon where the breaks in the coating usually go down to the substrate. It can cause immediate corrosion surface. and result in the chipping and flaking of the coating from the It is not a common failure of organic coatings such as epoxies (Carboline 191) or modified phenolics (Phenoline 305).

Mud-crading is of ten a phenomenon of improperly cured or excessively thick films of inorganic zinc primers such as Carbo Zine 11.

Pinpoint Rustina Zinc coatings normally fail at the and of their useful life by pinpoint rusting. This occurs primarily in areas that are thinner than the remainder of the coating, starting with an isolated pinpoint of rust showing here and there in these thin spots. Eventually, the pinpoints will become closer together and finally at the time of full failure, the spots of pinpoint rust will be almost continuous and general over the entire surface.

Undercuttina Undercutting is a type of adhesion failure that involves the gradual penetration of corrosion underneath the coating from a break or pinhole in 1

i the film or from unprotected edges.

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l DESCRIPTION OF COATING FAII.URE TYPES A more detailed description and photographs of coating failures can be found in Steel Structure Painting Manual. Good Painting Practices. Volume l

1. Chapter 23. entitled "Causes and Prevention of Paint Failure."

Blisterina Blistering is one of the most cosmon forms of adhesion related coating failure. particularly where t'be coating is immersed in water or other liquide. It can also occur in areas of high humidity where there is continuing or intermittent condensation of the surface.

Blistering is caused by gases or liquids within or under the coating that exert pressures stronger than both the adhesion and the internal cohesion of the coating.

The blister will generally increase in size until the tensile strength of the coating is greater than the internal pressure. If the pressure is greater than the tensile strength. the blister will break. This is often .

the case where a brittle coating with little extensibility is involved.

After the blister breaks. frequently the substrate will be readily

, attacked causing rust.

Peelina Peeling is a coating failure usually caused by a coating having a tensile 1

strength greater that its bond strength to the surfaces.

Any coating will peal or pull from the surface if it has less adhesion to '

the substrate than it has tensile strength, or it reacts adversely with the substrate over a period of time, thus substantially reducing the adhesion.

Plaking and Scalina These two types of failure are adhesion related. Flaking is a term describing a condition where small pieces of coating detach themselves from the surface of the substrate. Its edges are generally raised up fron the surface and the small pieces can be rather easily removed leaving the substrate bare.

Scaling is similar to flaking. except that the pieces that break away from the surface are much larger.

Pieces of coating several inches in diameter may crack due to aging.

stresses, curl and come off in large flakes.

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1 DESCRIPTION OF COATING TAILURE TYPES Intercoat Delanination This is a failure of one coat adhering to an underlying coat, whether applied as one coat following the other or where the finish coat is applied as a maintenance coating af ter some period of time.

The cause is generally within the coating itself. Coatings such as epoxies (Carbolina 191) or modified phenolics (Phenoline 305) are subject to this type of failure. These coatings become insoluble in the original coatings.

An additional major cause of intercoat dalm=f antion is the contamination of the first coat before the application of the second. Moisture, dust, fumes, chemical fall-out, oil and grease can also cause this result.

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.. l SCALE AND DESCRIPTION OF RUST GRADES Rust Photographic Crades Description Standard 10 No rusting or less than 0.01% Unnecessary 9 Minute rusting, less than 0.03% of No. 9 surface rusted 8 Few isolated rust spots, less than No. 8 0.1% of surface rusted 7 Less than 0.3% of surface rusted None 6 Extensive spots but less than No. 6 1% of surface rusted 5 Rusting to the extent of 3% of None surface rusted 4 Rusting to the extent of 10% of No. 4 surface rusted 3 Approximately one-sixth of the None surface rusted 2 Approximately one-third of the None surface rusted l 1 Approximately one-half of the None surface rusted O Approximately 100% of the Unnecessary surface rusted

, The rust grading scale ranges from 10 (no rusting or less than 0.01%

j rusted) to O (100% rusted).

There are four levels of rusting on coated steel surfaces ranging from 0.03%

to 10% rust. These levels correspond to rust grades of 9, 8. 6 and 4.

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. 1 SCALE AND DESCRIPTION OF RUST GRADES 9 a 7  !

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DIAGRAMS REPRESENTING RUST GRADES AND THE CORRESPONDING AREA PERCENTAGES

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