ML20204G282
| ML20204G282 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/17/1987 |
| From: | Brown W, Elliott W, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20204G202 | List: |
| References | |
| 301.07-SQN, 301.07-SQN-R03, 301.07-SQN-R3, NUDOCS 8703260372 | |
| Download: ML20204G282 (10) | |
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- TVA INPLOYER CONCERNS REPORT NUMBER: 301.07-SQN
- SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 3 ,
TITLE: General Paint Concern Reactor Building REASON FOR REVISION:
Revised to incorporate SRP comments Revision 1 Revised to incorporate SRP comments and include SQN corrective Revision 2 action response.
To incorporate revised SQN corrective action plan Revision 3 PREPARATION PREPARED BY:
, . 3 ' / 2 "0 f SIGNATURE DATE REVIEWS PEER: -
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CONCURRENCES CEG-H: *o kL lY0l SRP- M 3~ / 7-8 7 SIGNATURE DATE SIGNATURE
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APPROVED BY f b A Il N/A
' DATE ECSP MANAGER 1 DATEl MANAGER OF NUCLEAR POWER CONCURRENCE (FINAL REPORT ONLY)
*SRP Secretary's signature denotes SRP concurrences are in files.
0703260372 DR 870319
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l-TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Mechanical Equipment Reliability and Design Element: General Paint Concern Reactor Building Report Number: 301.07-SQN Revision 3 XX-85-087-001 Evaluator: G. D. Gardner /d)[., . ?-/ 2 -8[ G. D. Gardner Date Reviewed by: //> X//r 7 OPS / CEG4fember
/ Date Approved by: F t 3 M f[
- W. R. Lagergren Ifate 1451T
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L. R , Revision 3
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I. GENERAL PAINT CONCERN REACTOR BUILDING This report evaluates a specific employee concern identified for Sequoyah Nuclear Plant (SQN). II-85-087-001, regarding the integrity and maintenance of containment paint coatings ~ This issue was determined to be potentially safety related by the Employee Concerns Task Group (ECTG) Technical Assistance Staff. II. SPECIFIC EVALUATION NETHODOLOGY The employee concern' identified to Quality Technology Company (QTC) for SQN-is as follows: XX-85-087-001 Sequoyah unit 1 & 2: Containment paint coatings (#295 and #305) are not properly maintained. The integrity of the-coatings is being
- eroded and questionable. CI is concerned that the paint will curi end pop-up and clog the drains in case of a (LOCA) accident when the temperature and pressure builds up in the reactor. Paint specifications and standards are not followed, especially in recoating of 305. NUC Power concern. CI has no further information.
The ECTG files were reviewed and a' Nuclear Safety Review Staff (NSRS) report was found for the above concern. The report was reviewed for. adequacy-and a cognizant engineer in SQN QA was contacted for the status of NSRS recommended corrective actions. Revision 0 of this evaluation included IN-86-273-001 which was an
-identical issue identified for Watts Bar Nuclear Plant by the same concerned individual. The IN-86-273-001 will be evaluated by the-Construction Category Evaluation Group (CEG) in Subcategory C0 10300 for issues related to the construction phase and will not be addressed by the Operations CEG.
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4E Revision 3
'III. FINDINGS The NSRS report forLSQN (Reference 1) was reviewed and determined to
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' adequately address Employee Concern 11-85-087-001. Therefore, this report" endorses'the findings and conclusions of the NSRS report.
The NSRS report.found that concrete coatings were adhering well with _ somel exceptions where.significant mechanical damage has occurred with water seepage' causing some delsmination in these areas. The report'noted that. although some corrective maintenance has been
. performed, a formalized program of periodic inspection and maintenance did not exist. Preventive maintenance routines were being developed at that time,-however.
NSRS inspections of the steel containment liner found areas of
-phenoline 305 delsmination and areas where total film thickness was exceeded.
The SQN plant response-to the NSRS report (Reference 3) indicates that '
^t he NSRS recommendations. wore being implemented. The NSRS accepted the plant: response _(Reference 4) along with the corrective actions being performed under. Corrective Action Report SQ-CAR-86-01-001 (References 5 and 6).
The cognizant QA engineer who prepared the CAR stated that his evaluation had occured about the same time as the NSRS investigation.
.The QA survey had reached the same conclusions although he was unaware of the ongoing'NSRS investigation at that time. He stated that the corrective actions specified by the plant in response to the CAR
. included resolving the NSRS recommendations and performing a baseline
.ovaluation and inspection to determine the present condition of all containment coatings at SQN. He also stated that QA would require documented verification for completion of all corrective actions prior to closure of the CAR.
The CAR as written is identified as " nonsignificant." The Nuclear Quality Assurance Manual (NQAN) defines a "significant condition adverse to quality" as "Those which represent gross or widespread noncompliance with procedural requirements which negate the effectiveness of quality assurance controls imposed by this quality
- assurance' manual; or.any condition which has recurred with such a frequency that it indicates past corrective action (if any) has been t- ineffective." Based on this definition, the lack of an overall TVA program to ensure the quality of Critical Structures Systems, and Components (CSSC) protective coatings appears to be a significant condition adverse to quality. The " nonsignificant" designation of the CAR by SQN QA does not appear justified based on the NQAM definition since the CAR addresses the lack of an upper-tier program and not just a SQN noncompliance with an existing procedure.
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. Revision 3 L . CONCLUSIONS The issue presented by Employee Concern KK-85-087-001 regarding i maintenance of coatings was validated by the NSRS report. The report I noted areas of delamination and mechanical damage, however, it was believed no impact on safety existed. The report concluded that the need for maintenance was recognized by responsible personnel; however, a formalized program was not yet complete, although it was in a
~ development stage. The lack of a formalized program for ensuring the i quality of protective coatings appears to represent a significant breakdown in the QA program relative to the specific area investigated.
I IV. PERCEIVED ROOT CAUSE I j The root cause specified by the SQN plant staff in response to i SQ-CAR-86-01-001 was the lack of a controlling upper tier document for I coating repairs and maintenance. This report concurs with that root l cause and, based on the findings of the NSRS evaluation for SQN and j NQAM definition, considers it to be a significant condition adverse to i quality. t V. GENERIC APPLICABILITY l e Specific concerns on containment coatings exist for SQN and WBN and evaluations have been conducted by NSRS and ECTG. Based on the results of these evaluations and the root cause specified above, the issue of I coatings repair and maintenance is considered generically applicable
-for BFN.
The issue is not considered generically applicable to BLN because g-limited coatings have been applied there and the plant is in a s construction rather than maintenance / operation phase. h 2 9 ? i i I Page 3 of 7 i 1 Y
p' Revision 3 i ' VI. REFERENCES 5
- 1. NSRS Investigation Report I-85-812-SQN, " Containment Protective Coatings Repair," Employee Concern XX-85-087-001, January 26, 1986
- 2. NSRS Investigation Report I-85-817-WBN, " Containment Coating Repair," Employee Concern IN-86-273-001, March 11, 1986
- 3. Memorandum from H. L. Abercrombie to K. W. Whitt on response to NSRS Report I-85-812-SQN, dated February 20, 1986
- 4. Memorandum from K. W. Whitt to H. L. Abercrombie on Corrective Action Response Evaluation, dated April 9, 1986 1 5. Corrective Action Report (CAR) SQ-CAR-86-01-001, dated January 24, 1986
- 6. Memorandum from C. R. Brimer to P. R. Wallace on Corrective Action for SQ-CAR-86-01-001, dated February 18, 1986
; (S01 860218 832)
- 7. Memorandum from P. R. Wallace to H. L. Abercrombie on completion of Corrective Actions for SQ-CAR-86-01-001, dated July 11, 1986 (S01 860711 910) s 4
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b Revision 3 VII. IMMEDIATE OR LONG-TERM CORRECTIVE ACTIONS Corrective actions are currently underway.in response to SQ-CAR-86-01-001 and NSRS Report I-85-812-SQN which includes a baseline inspection to determine all areas requiring repair and development of new procedures to control all aspects of containment coatings at SQN. Corrective actions will be tracked and verified by SQ-CAR-86-01-001 prior to closure.The plant identified corrective actions for'the CAR (reference 6) does not specifically identify the NSRS recommendations to be resolved-nor does it specify actions taken to resolve the root ' cause issue on a corporate level. The root cause specified by SQN was a lack of an upper tier document controlling coatings repair and l-maintenance. The corrective actions are currently scheduledto be [ complete by November 1, 1986 (reference 7) prior to unit startup. L Because the CAR identifies a lack of an overall TVA Program to ensure the quality of CSSC coatings and the NQAM definition of a significant l CAQ, it would appear that SQ-CAR-86-01-001 should be upgraded to l- "significant." The following. acceptable corrective action plan was provided by SQN: l Comments on CATD OP 30107-001-SON
-SQ-CAR-86-01-001 was not written because'of deficiencies found by Nuclear Safety Review Staff (NSRS) Report I-85-812-SQN. This Corrective Action Report (CAR) was generated by an audit that was conducted by site QA staff. Sequoyah Nuclear-Plant (SQN) has responded to the NSRS report in a memorandum from H. L. Abercrombie to K. W.
Whitt dated February 20, 1986. This Corrective Action Plan (CAP) further specifies which steps have been taken and the documents that the work was implemented under, f L The upper-tier document specified by the CAR is for the SQN site and will be generated as a SQN Standard Practice Procedure (SQM). This SQM will be written from the specifications and requirements of G-Specifications-55. l. Schedule l All physical work necessary to bring each unit containment protective coating within limits of the uncontrolled coating established by the Division of Nuclear Engineering (DNE) will be completed before each unit startup. Program changes (issues of revised G-55, MI-10.14, and a new SQM), will be required. Revision of G-Specification-55 and issue (R3 l of a new SQM is required for unit 2 restart. Revision to other i l procedures (MI-10.14 and SQEP-13, etc.) is not required for restart. l Action Items The following actions have been taken in response to NSRS Report I-85-812-SQN, and SQ-CAR-86-01-001. Page 5 of 7 b _ , - -
.. l Revision 3
- 1. NSRS Recommendation I-85-812-SON-01
- a. The deficient areas of lower containment floor were recoated by Engineering Change Notice (ECN) 6682. This was implemented by Workplan 12069. All physical work is complete.
b&c. The liner wall delaminating carboline 305 topcoat was removed on both units by MR Nos. A523804, AS48573, and AS47675 This work was inspected by Maintenance Instruction MI-10.14. The l carboline 305 topcoat will be reinstalled at a later outage. lR3
- d. The floor on 734' elevation was determined not to require repair. NSRS accepted this position.
- e. S.G. Pinney & Associates, Inc., (SGPI) was contracted to do a l detail baseline evaluation inspection using the Preventative l Maintenance (PM) program data sheets. Attached is a summary l of the results of the inspections. Deficient areas have been I added to the uncontrolled coating inventory maintained by lR3 Division of Nuclear Engineering (DNE). The data sheets from l the PM program will be reviewed prior to U2 restart to verify l that all priority work (required before restart) has been l completed and documented. I
- 2. NSRS Recommendation I-85-812-SON-02 Delaminating topcoat was removed by MR Nos. A523804, A548573, and A547675. Further inspection for all areas was conducted by preventative maintenance (PM) 1435-364 and 1439-364.
- 3. NSRS Recommendation I-85-812-SON-03 A formalized PM instruction for inspection of Level I coating has been developed. This group of instructions is on System 364. All preliminary inspections have been completed.
- 4. NSRS Recommendation I-85-812-SON-04 MI-10.14 will be revised in accordance with G-Specification-55 upon revision of the G-Spec. This action is being tracked by SQ-CAR-86-01-001. A draft revision has been proposed by DNE, and SQN site has made comments to the proposed draft.
- 5. NSRS Recommendation I-85-812-SON-05 In accordance with SQ-CAR-86-01-001, SQN site will generate a SQM l
for the protective coating program. The issue of this procedure is i dependent on the issue of the revision to G-Specification-55. This "SQM" procedure is the upper-tier document for SQN site. I 6. Additional deficiencies were found on the inspection of SGPI. Minor repair work was done under WRs and MRs. Three major problems still exist, and need to be resolved or reworked before startup of olther unit. Page 6 of 7 f
Revision 3
-a. Reactor Coolant Pump (RCP) motor coating is unqualified.
SQN-NES-8610, documents _this CAQ. ECN L7001 will correct the lR3 deficiency by providing a screen to contain the coating chips at the RCP base. This is a restart action.
- b. Pressurizer Relief Tank (PRT) - The lower portion of the PRT potentially has unqualified coating. Further study is required to determine'the qualifications of the coating.
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If the coating
-is unqualified, the exact solution will be determined through the Significant Condition Report and ECN process.. This resolution is a restart action. This deficiency was discovered during the baseline evalaution of SQ-CAR-86-01-001.
- c. Steam Generator and Pressurizer Enclosures - The coating on
-these enclosures were determined to-be unqualified. This_was determined during baseline evaluation of SQ-CAR-86-01-001.
The area will be recoated by ECN L7012.- This is a restart lR3 action.
- 7. Secuoyah-Element Report 301.07 SON R1 SQ-CAR-86-01-001 has been reevaluated by the site QA supervisor.
This CAR is not considered to be associated with a gross deficiency in the QA program and is therefore not significant. Additionally, the deficiencies were evalauted by NSRS Report I-85-812-SQN to have no significant safety imptet and was erluated by PRO No. 1-86-139 as not reportable to the hkC. There are problems with.the program that have been. identified and corrective actions taken are appropriate. I Page 7 of 7
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- CCPS120J-ECPS121C E1 ment Summa TENNESSEE VAL [EY AUTNDRITY RUN TIME - l'i d kli f RtilCE OFFICE SF NUCLEAR POWER RUll DATE - r9/.?*-
i f:L 40ENCY - REQUEST EMPLOYEE CSACERE PROGRAM SYSTEM (ECPS) UMP - ISSS - R121 ..'*. ATEGORY: OP PLA!!T OPER. SUPPORT LIST SUBCATEGORY: 30107 DFSE EMPLD@YM CSECERN INFORMATIONL PAINT CONCERN .RX . - BLD KEYHORD A . S GENERIC , KEYllDRD B APPL STC/NSRS P KEYHORD C H CONCERN CCl3CERN SUB R PLT 33SH INVESTIGATION S R DESCRIPTION KEYHORD D NU:1BER CAT CAT D LOC FLQB REPORT PROTECTIVE COATING 3010711 SQti YNYY I-85-812-SQN N3 SEQUOYAN UNIT 1 1 2: CONTAINMEllT PAI PREVEllTIVE MAINT XX 087-001 OP REPORT NT COATINGS (8295 AND 8305) ARE NOT CIVIL T50136 . TROPERLY MAINTAINED. THE INTEGRITY COATINGS OF THE COATINGS IS BEING ERODED & QU ESTIONABLE. CI IS CONCERNED THAT TH E PAINT HILL CURL & PDP-UP AND CLOG THE DRAINS IN CASE OF A (LOCA) ACCID ENT WHEN THE TEMPERATURE AND PRESSUR E BUILDS UP IN THE REACTOR. PAINT S ce PECIFICATIONS AND STANDARDS ARE NOT d3 FOLLDHED, ESPECIALLY IN REC 0ATING OF 8305. NUC POWER CONCERN. CI HAS N 0 FURTHER INFORMATION. 1 CONCER!lS FOR CATEGORY OP SUBCATEGORY 30107 h.
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