ML20151R130

Discusses Transfer of Lead Responsibility for Evaluation of Concerns Associated W/Containment Coatings Sys.Nrr Requested to Assume Lead.Licensee Position Documented in Dh Smith to HR Denton

ML20151R130
Person / Time
Site:	Braidwood
Issue date:	01/31/1986
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Novak T Office of Nuclear Reactor Regulation
Shared Package
ML20151R123	List: ML20151R119 ML20151R130
References
NUDOCS 8602050377
Download: ML20151R130 (1)

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3 , pa neog unita3 sTAfss z 1 NUCLEAM REGULATORY COMMIT $lON 1 , RsGION lil ll 5 799 noosavet? poAo i .u a s u.v a. ui . . i n

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MEMORANDUM FOR: T. M. Novak Deputy Director, Division of PWR Licensing-A, NRR FROM: Charles E. Norelius, Director, Division of Reactor Projects, j Region III i SU6 JECT: TRANSFER OF LEAD RESPONSIBILITY FOR THE EVALUATION OF CONCERNS i ASSOCIATED h!TH THE BRAIDWOOD CONTAIMENT COATINGS SYSTEM 3

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l' On January)7,1986, contractor QA Manager Region  !!! was contacted and QC Manager by the who expressed Midway concerns (coatings with the I disposition by Sargent & Lundy (S&L) of a Midway NCR. The NCR identified that the coatings in Unit 2 containment [there is another NCR for Unit 1) were reworked in 1978 using a coating system not qualified to a Design Basis Accident (DBA) in accordance with ANSI N101.2. The basis for their concern was the S&L disposition of "USE-AS-15" which was based on a test program using pull tests described in ANSI N5.12. Although the two individuals do not desire confidentiality and continue to have ongoing discussions regardinfi this issue with appropriate S&L, CECO. and contractor personnel, this matter < s being :lassified as an allegation by Region III.

The Itcensee's position regarding the adequacy of the traidwood containment I protective coatings was occumented in a letter from D. H. Smith to H. R. Denton on January 28,1986. '

Region III requests the Office of Nuclear Reactor Regulation to assume the lead responsibility for the evaluation and resolution of the concerns

regarding the adequacy of the reworked containment coatings system.

dis &S N Charles E. Morelius, Director Division of Reactor Projects cc: J. R. Miller, NRR C. J. Paperiello, RI!!

J. Stevens, NRR S. A. Treby, ELD t

l D602050377 060131 i DR ADUCK 0500 if;6

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- - , Commonwealth Edison oao Fust Na 109 1 P>sts C51 sp h:A3a Address Reply to Fost 0 hce Box 767 Cht:3go.1:hnis 60690 January 28, 1986 1

Mr. Harold R. Denton U.S. Nuclear Regulatory CO2 mission y office of Nuclear, Reactor Regulation Washington, DC. 20555 i

Subject:

Braidwood Station Units 1 and 2 Containment coatings NRC Decket Nes. 50-456 and 50-4)2

Dear Mr. Denton:

A conference call was held today between Cornonwealth Edison Company and rembora of your staff to discuss the coating cpplication in the containments of Braidwood Units 1 and 2. The purpose of this letter is to provide inforcation to address this issue and to create a basis for further discussion. Additional information is being assembled and we would be prepared to present that infor=ation in a meeting between us and your staff so early as Priday. January 31, 1986, should that be necessary to obtain resolution of the issue.

We will coordinate further exchange of information with Ma.

. Janice A. Stevens of your staff.

4 One signed original and 3 copies and enclosures are

[ provided for your review.

3 Ve truly y urs, 1

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/w/ JA David it. Umith Nuclear Licensing Administrator

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Enclosures cc: Resident Inspector Braidwood R. Gardner (BIII) l 1210K g(4p sy -[t"j A ES

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COMMONWEALTR EDISON COMPANY BRAIDWOOD STATION

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CARBO ZINC 11/ PEEN 0LINE 305 CONTAI_NMENT LINER COATING .9YSTEM t

The Braidwood Station containment liner coating system consicts of a prime coat of Carbo Zine 11 over the entire surface and a finish coat of Phenoline 305 from Elevation 377'-0" to 436'-0"

. . (10? above mezzanine floor). The prime coat of Carbo Zine 11 . I was applied in the shop with exception of plate edges which were l coated after the liner seam welding was completed. l The prime coat of Carbo Zinc 11 had become aged and weathered; therefore, it was restored prior to applying the finish coat of Phenoline 305. The restoration consisted of brush blasting the original coat of Carbo Zine 11 and applying a second coat of Carbo :ine 11 to restore the originni thickness of the prime coat.

Midday Industrial contractors, Inc. Nonconformance Reports (NOR)

Nos. 31 and 32 and Commonwealth Edison Company NOR No. 748 were written to address the concern that the second cent of Carbo Zine 11 was not diluted to 50% as recommended by the coatings manuf acturer (Carboline Company) . The manufacturer's application instruction recommends 500 thinning when a second coat of Carbo Zine 11 is applied over a base coat of carbo Zinc 11.

The coating system which has been qualified by DBA test consists of Phenoline 305 finish over a prime coat of carbo Zine 11.

Our position is that we have maintained this system, and therefore, the current DBA tests are applicable. In order to assure that the restored Carbo Zinc 11 behaved as a single coat system, adhesion tests were performed. Tests were performed in-place on the completed liner coating system and on specimens which were coated with a second coat of Carbo Zine 11 over a brush blasted prime coat of aged and weathered Carbo Zinc 11. The tests showed no case of adhesion failure between the Carbo sinc 11 coats. In all cases, they failed in cohesion through the entire thickness of Carbo Zinc 11 as expected. Therefore, the Carbo Zine 11 as applied does behave as a single coat system. In addition, the adhesion values observed on the in-place liner coating system do correlate to a range consistent with those eshibited by the current qualified DBA system.

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The coatings manuf acturer (Carboline Company) concurs with our position (see attached correspondence). They have clarified their position relative to the 50% thinning recommendation an appropriate when applying a second coat to a fresh cured coat of Carbo Zine 11 in order to promote adhesion. Brush blasting of the first cost of Carbo Zinc, thereby establishing a roughened profile, prior to applying the second coat precludes the dilution requirement.

In conclusion, it has been shown that the coating system as applied is representative of that for which DBA teats have been performed.

Therefore, further DBA testing is not required.

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p CARBOLINE COMPANY Jcnuary 22, 1986 Mr. Theodore Rudaitis Sargent & Lundy Engineers [

55 East Monroe Street Chicago, Illinois 60603 7 ,,

subjects carbo Zine 11/305 System Linor Plate .

Braidwood Station .

References:

(1) Lotter dated June 17, 1985 to Mr. T. Pudaitis,

• Sargent & Lundy, from Stevo IIarrison. ,

(2) Lottor dated July 10, 1985 to Mr. R. 7.oigh, Hidway Industrial contractors, Inc., from Steve Harrisont (3) Letter dated Cecember 9, 1985 to Mr. T. Fudaitio, Ssraen't &_Lundy, from_ Stove Harrison. _

Dear Mr. Rudattis t This lotter is to clarify our position with respect to the subject coating system relative to the 50% thinning requirement for a second

, coat of carbo zine 11.

l In our letter of June 17, 1905 we concluded after observing adhesion data from rests performed on the liner plato coating that thorn is no technical reason why this syntom as applied will not perform under cnticipated DBA conditions.

In our letter of December 9, 1985 wo further reinforced our position based on additional tests that the coating as applied does perforn cs a system and, therefore, additional DDA tests are not reqaired.

In addition, the 50% thinning requiremont in our technical literature is not applicabic to the conditions of the Braidwood liner.

2 Cur letter of July 10, 1985 to Mr. R. Leigh, of Midday Industrial, Inc., was only intended to establish that the conting system as applied ct Braidwood station on the linor plate doon not corpromise CBA qualification. Our only technical concern la that the costing behave 4

cs a system and eFhibit appropriate adhonion ChStacteristics.

In conclusion, based on the test results at Draidwood Station, it in cur opinion that the coating system displayed acceptable adhonion characteristics. The coating system an applied is qualiflod by Cxisting DDA tests, egards, Le J in F. Montle b

Vice President, Technology JFH/1ft CC: Mr. Steve Harrinon/Hr. Charlie Wiegers/Mr. Paul Litrainger r'

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