ML20205Q712
| ML20205Q712 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/1984 |
| From: | NRC |
| To: | Oliu W NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20204J134 | List: |
| References | |
| FOIA-85-59 NUDOCS 8606030026 | |
| Download: ML20205Q712 (93) | |
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SSER WRITEUP DOCUMEi!T CONTROL /RO'JTE $HEET Afp. _ All egation Numbers McT__- ! . R 3 4 I, [7, (/ /( , f/ f y ,f 3, f f . Subject of Allegation T>r; .e,6 6, ql. p,,. (,1;,gq g pgm g g g 7 ,z TRT Group C e ,d i ~ 6 1* . 3 Author: __ M/.m ll4J This shaet will be initialed by cach reviewer. It stays with all revisiens to the SSER writeup and ser' v es as a routing and review record. work package when the writeup is published. It will be filed in the / .
. Draft Numbei- -
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- 1. Allegation Group: Coatings No. 2 - Design Basis Accident (DBA) Qualifica-( l
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tion Testing-
- 2. Allegation Number: Parts of AQO-01,'AQ0-02, AQ0-03, AQO-04, AQO-05, AQO-06, AQO-09, AQO-10, AQO-11, AQO-12, AQO-13, and AQO-15 -
- 3. Characterization: It is alleged.that some protective coating systems .
applicd at the Comanche Peak Steam Electric Station (CPSES) are not DBA - qualified.. Examples are: -
. Tmperial coatings (Southern Imperial Coatings of New Orleans) applied in the siqueritial order #11S/1201/11S/1201 or #11S/1201/11/1201, in i
.accordance with B&R Procedure CCP-40, Paragraph 4.3.1.2. (AQO-01) .
. Repair coatings ' system applied'in sequences which are different from
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the original application sequences, as discussed in noncon.formance report (NCR) #C83-01752, ' Jure 23,1983. (AQO-02) -
. Carboline Phenoline 305 (P-305) applied over another manufacturer's epoxy coating, in accordance with design change authorization (DCA)
#17,142, Revisfon 2'. (AQO-03)
. Carbo 11ne Carbo Zinc 11 (CZ-11) topcoated with Imperial 1201, in accordance'with DCA #12,374, Rev-ision 1. (AQO-04)
. P-305 applied over Ameron Dimetcote 6 (D-6), in accordance with
_..CPSES Pro adure #CCP-30A, Revision 2, Paragraph 1.3.1 (AQO-05) WD #
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. , Imp *erial Nutec 115 surfacer applied over f. sist. cv;s :ts ee. bedded ir
- concrete, in accordance with CPSES' Procedure #CCP-40, Revision 5, Paragraph 4.1.1.3.. (AQO-06) _,
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. Inorganic zinc primer applied in'three coats. (AQO-09)
. Coatingsappliedtosurfacespreparedbypowertoolcleaningwbich were smoothed or polished and thus do not have adequate surface.
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. Primer ~ applied to a thickness of 0.5 mils, in accordance with k
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,DCA #18,489, Revision 1. (AQO-11) _.
- . Imperial coating system 11S/1201/115/1201 applied at a thickness of j 102 mils, in accordance with CPSES Procedure CCP-40, Revision 5, ,
Paragraph 4.3.1.2. (AQO-12)
. Coatings applied in the reactor core cavity which will be subjected
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j , te 'h'ighe'r lehis~ of neutron and gamma exposure than coatings in other i areas. (AQO-13) . y . 'CZ-11 or Carboline 191 primer (191P) applied over P-305, and P-305 l
; applied over Imperial- 1201, in accordance with CP,SES Procedure ! . CCP-30, Revision 11, Paragraph 4.4.3.0. (AQO-15)
- 4. Assessment of Safety Significance: The implied safety concern of iihese
, allegations is that protective.coatir.g systems inside the primary contain-ment structure which' have not been qualified by DBA testing"cou.1d fail
~ during service and interfere with..the functioning of engineered safeguard -
systems. An evaluation of the significance of this safety concern is reported in (LATER). The Technical Review Team (TRT) evaluation of the' j quality assurance a'spects of these allegations follows. ' 1 r. f Review of DBA Qualification Test Data In assessing these. allegations, the TRT reviewed the requirements pertinent ll, t,o DBA testing o.f protective coating materials u' sed-inside primary contain-ment structures at CPSES. The CPSES FSAR and Technical Specification AS-31 commit Texas Utilities Electric Company (TUEC) to' compliance with'American m g g .g , e= 4- *
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_4_ ! National Standards Institute (ANSI) 's'tandards N101.2 and N5.12, Nhich pro-vide the methods and criteria for DBA testing. This testing must be per-formed under temperature, pressure, and irradiation conditions which simu-late both nomal plant operating conditions and Loss of Coolant Accident
.. I (LOCA),84DBA,. conditions. The standard specifies that the coating /,
systems tisted must be the same as those actually used in the plant in terms of surface preparation, coating materials, application methods and - f conditions, and coating thickness. CPSES Specification 2323 AS-31, which governs safety-related coating work, requires that the DBA testing be performed by'th'e' coating manufacturers
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and Oak Ridge National Laboratories (OR'NL). The CPSES FSAR also commits
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TUECtoco'mpliancewithANSIN45.2.11,whichprovidesrequirementsfor design. activities, including evaluation of design input information (such as DBA t'ests), biitti for initial design and all changes thereto, and for records which.must be maintained to 'docume.nt c. ,ign activities. *
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The TRT investigated compliarce with these requirements at CPSES, con-centrating on the coating systems which were used for,,the major surface areas inside the containment building. Secondary consideration was given by the TRT to the many different " coating sys'tems" that were usid in cer-tain small areas, such as overlaps between different systems, repairs, and other special cases, including those described in the allegations. ,
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The TRT inves'tigation included interviews.with approximately 12 individuals i involved in design and engineering relative to coatings at CPSES. Those 1 interviewed were from Gibbs & Hill, ORNL, Texas Utilities Service, Inc. 1 (TUSI), TUGCO,.EBASCO, and Brown & Root and,were involved in design, l chemical engineering, DBA testing, field engineering, design changes, l design and design change control, records manag'ement, and quality assur-ance. T TRT conducted an in7 depth review of numerous DBA and'other test ,.
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. reports,, elateT documents provided by TUEC, of pertinent CPSES site files
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of DCAs,/and of, vendor-approva1 records. The TRT also reviewed relevant , industry standards, NRC information reports, TUEC licensing documents,
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TUGC0' procedures and Regulatory Guides. e b e.
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The TRT requested from TUEC' copies oTDBA test data and eva]uat16ns appli- , i cable to CPSES containment structure coatings systems. On August 10, 1984, TUEC provided a package labeled "DBA Reports - Site Civil Engr File," and on August 29, 1984, TUEC provided five packages of DBA data from the CPSES vault. TUEC e'xplained that the five " vault packages" we.re the official , DBA Test Reports which confirm th'e acceptability of the major coating .'. i systems at CPSES, and this was confirmed in a September 3, 1984, TUGC0 7 l memorandum from the former CPSES AQ Manager (TUEC's contact for coa. tings l TRT) to TUGC0 Vice President and CPSES Project General Manager which TUEC , presented to the TRT on September 10, 1984. The TRT reviewed all of the above test. reports and found them to be incomplete,' inconsistent, and 1 inadequate in demonstrating that the major coating systems us'ed at CPSES , j had.b.een qualified in accordance with ANSI N512 and N101.2. The TRT veri-fied this finding by performing a second review of only the five official
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vaultJpackag'e's afid reached the same results. Although the packag*s con- ' tained some pertinent testing data, they also contained a large quantity l
. of informa' tion which was not applicable or not valid, and the pertinent
- data'was not, adequate to deinonstrate' that the coatings were qualified.
. The TRT found no records to demonstrate that the DBA testing data had been reviewed by CPSES personnel, and no records o'f engineering evaTGation of .
the data by TUEC, either in the test report packages, the vendor file, or elsewhere. Information provided to the TRT by TUEC in the September 3, , l 1984, memorandum indicated that Gibbs & Hill (the CPSES Archite,ct/ Engineer) was involved'in the design process for coatings, but did'not demonstrate that an engineering evaluation of the DBA test data had been performed. The TRT concluded that such a recorded engineering evaluation was neces-sary, not only because it is required by ANSI N45.2.11, but also because the files of testing data by themselves were insufficient to demonstrate the qualifications of the coatings without inte'rpretation and additional data. The TRT observed that the DBA data base files were deficient in
. that:
's) The test report data bases used by Gibbs & Hill, CPSES field engineering, and kept in the CPSES vault were not the same.
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r __m (b) Many of the reported DBA tests 'd'id not include all important: .- criteria,,. (temperature, pressure, and irradiation). , J (c) Many of the repor'ted DBA tests were not performed by Oak Ridge National' Laboratories (ORNL) as required by CPSES spectfication , 2323-AS-31. : , h h l (d) Many .of. the, . reported tests inc1cded coating materials and coating i I systems not used at CPSES in combination with materials and systems which were used at CPSES. The inclusion of these " foreign" materials in the systems tested invalidates the app'11'cability of this test data to CPSES.
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(e) In some of the reported tests, the test samples failed, indicating j
.th'a't thise maie~ rials and systems were not qualified to the required j criteria,.yet these repcrts were included in the qualification test data-base without comment.
i; ' l (f) Many of the test reports did not include suffici,ent data to identify j either the materials or system tested, the test criteria, or the
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1 (g) The data bases included instances of two different, incomplete ,
;, versions of.the same report. ,I .. _ .. - . . !> "(h) The data bases included instances of two different reports of two j different tests of the same system, with different results - i.e.,
j one test passed and one failed. , j " ' (1) The data bases did not include any one complete, acceptable, valid i test tilat corresponded to each major CPSES coating system. j ...
? The following two examples ill'ustrate the deficiencies observed in these
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(1) The site field enginee' ring file's' included Carboline test fehort SR-149 that recorded an ORNL test report of August 16, 1978, which included temperature and pressure only, for the system: CZ-11, at 1.7 to 2.9 mils, topcoated with P-305 at 1.5 to 3.8 mils. In the j official vault file there was a different version o.f this same l ORNL report of August 16, 1978, which included temperat'ure and pres- . ' . sure o'nly for the system; CZ-11, at 3 to 4 mils, with a topcoat
- k i different from that used at CPSES.
(2) The official vault package included a Carboline Laboratory test' report for Testing Project Number 01931,' February._10, 1981. The report gave the results of a' test performed by Carboline' for tempera-
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. ture and pressure criteria only on the repair , system: Carboline 191 primer (191P) at 4.0 to 4.5 mils, topcoated with P-305 at 3.0 to
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3.S'at1'i,overApower-tool-cleanedsurface(thathadpreviouslybeen l abrasive blas-ted) and coated with the CZ-11/P-305 system). The report
. indicates that the samples tested passed. The site field engineering '
~ package included a report of Carboline Testing Project #01978 which l l
reported a DBA test by ORNL of April 7, 1982, wh,1ch included tempera- i . . ture, pressure, and irradiation for the same system: power tool cleaning,191P at 4.5 to 5.25 mils,'and' P-305 at 3.25 to f.,0 mils. In this report, two of the six samples tested at ORNL failed the test. As a final check on the validity of the DBA test data, the TRT technically ! analyzed the' data in.the five official vault-packages for the major steel
! coating system at CPSES: abrasive blasting to Steel Structures Painting
} Council (SSPC) standard SSPC-SP-10 (Near White Metal), CZ-11 primer, and P-305 tepcoat. -The dry film thickness; acceptance criteria for this system t \ g at CPSES is 1.5 to 7.0 mils for CZ-11, and P-305 thickness adequate to pro- ! j vide " full hiding" but with a total system thic'kness less than 15.0 mils. j The purpose of the TRT analysis was to determine whether these packages j . included.enough valid information to enable an engineering evaluation to be performed to. demonstrate that this system, as applied at CPSES, met the
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criteria of ANSI N101.2 and N512. For the analysis, _the TRT assumed that the data in the packages was accurate, and that testing performed by the 1 I e . " 25T*'"I~' . N ~ . . i-
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a_ ._ _ _ , l ,, l manufacturer had technical applicabiitty, although such testini did not include irradiation. -Test data were not considered in this analysis if
. 1 the test did not include either CZ-11 or P-305, if the samp'le(s) tested I did not meet the ANSI N101.2 and N512 acceptance criteria, or if the test l
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1 report did not -include sufficient' detail to identify the particulars (e.g., dry fiim thickness) of the material (s) tested. The TRT found that: ' l 2 (a)theonlyitemforwhichtherewasfullORNLtestingdatawasCZ-l1,byk itself, at 2.0 to 3.5 mils DFT; (b) there was no irradiation data f.or P-305 by itself or for the CZ-11/P-305 system; (c) there was no independent t a. . 1 j (ORNL) testing data for the CZ-11/P-305 system, as a system; and (d) there i
) was no testing data for the CZ-11/P-305 system'that' included or closely , !
s approached the thickness ranges used at CPSES. The TRT concu1'ded that this - testing data did not provide adequate information to enable an engineering l . ,
, analysis to be performed which would demonstrate the qualification of this
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coating'systmasahp~1iedatCPSES.
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e 3 . . J - In light of the deficiencies in the test data files, and particularly in. 4 '
]p because there were instances of different incomplete versions of the same !
ORNL report and different-test results for the same system, the TRT 3_ investigated what action, if any, TUEC had taken upon receipt of NRC IE Information Notice No. 83-60. The TRT found that TUEC had received and I analyzed this notice and determined that no action by them was appropriate l because they did not require their coatings to be tested by an independent . i
. laboratory. The TRT found that all testing reports were, in fact, provided to TUEC.by the coating manufacturers. Although 4t is true that the NRC '
did not require any action by TUEC based on the IE Notice, the TRT dis-j; agrees with' TUEC's.analysfs and conclusion that no action was appropriate, { because that conclusion was based on the errorieous statement that TUEC
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1 does not require independent laboratory testing. CPSES Specification { AS-31 does, in fact, require DBA testing by an independent laboratory, in i< 4 this case ORNL, as'well as by the. coating manufacturer. The TRT also examined vendor files to determine if they contained j evidence of engineering evaluation of'0BA test data as part of the vendor j approval process. This'examinat' ion inc1,uded a review of vendor files for y. 1 . . l I
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coating manufacturers Ameron, Carbolin'e, and Imperial. These file's did I l contained evidence of a functioning vendor-approval system which included l evaluation of vendor-QA program manuals, surveillance and audit.s at the f vendors' facilities by TUEC representatives, and inclusion of pertinent qu'ality requirements in purchase orders to the vendors. .However, these i files did not-include evidence that TUEC engineering had evaluated DBA .' , test data. ' ' k Review of Design Changes ,
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The TRT next investigated TUEC's design change' process in regards to
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engineering evaluation of DBA tes,t data as input and justificition for , design changes that affected CPSES coating systems., This investigation included interviews with persor.nel involved in the design change process,
~ ~ ! areviefofTljSIp5c~eduresCP-EP-4.0andCP-EP-4.6,andanexaminationof
{ coatings design. change records. The subject of design changes is addressed t
- i. in furthlif detail in SSER writeup Coatings No. Sc. ,'
! The TRT reviewed all revisions of the major procedures which governed coating work at CPSES, including Procedures CCP-30, CCP-30A, and CCP-40, selectedinspectionproceduresforinspecting'thecoatingwork,[ including backfit inspections, the governing specification, 2323-AS-31, and design changes which affected the above. Further details on procedures and on the backfit program is provided in SSER writeup Coatings No's. 1,and 4.
The TRT found that there were many substantive changes in the coating systems as applied, including changes in allowable thickness criteria, coating materials, sequencing and combinations of materials, surface pre-paration and coating application ~ methods, and acceptance criteria. All
, such changes affect the coating system design in that they affect the relationship between the coatings as applied at'CPSES and the coatings as DBA tested.
The TRT examined the files for eight different d'esign changes affecting coating. Design Change Authorizations'(DCA), Change Verification Check-itsts, and supporting documentation were. reviewed for each. In some cases
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the engineering justification for ap'p'roval of the change was evident in
- the documents reviewed, e.g., cases where specification requirements were j , not met and the coated item in question was placed on the coatings-exempt log. However, the majority of the documentation reviewed did not provide any engineering just'ification or'other reason for approval of the change, such as evaluation of new DBA test data. The TRT concluded that there .
were not adequate records to demonstrate the engineering basis for design changes for coatings at the time those changes were approved. __ As an attachment to the September 3, 1984, memo referenced above, TUEC ! provided the TRT with discussions of the engirieering justification for , l l the changes made in selected DCAs. These discussions reference j manu;Tacturer's test. Eeports, ORNL test reports, and accepted industry ~~ l standards as the basis for the changes. The TRT does not fully agree !
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with..th'e' technical validity of these discussions in all cases. For l example, it is.not appropriate to apply a standard which gives a range .
- of allowable deviations from a specified single-point coating thickness, ' .
to a pre-specified thickness range. Nor is it appropriate'to cite a l
- repor't of testing performed by Carboline, which does,not include an irradiation test, for various thicknesses of CZ-11 topcoated with one mil of P-305, as justification for increasing the thickness of CZ-n used in the CPSES system with a much higher thickness of P-305 topcoat, without additional supporting information and evaluation. Further discussion ,
and assessment of the CPSES design changes control system is provided in the SSER writ ~eup QA/QC No. (later). - .. Review of Individual A11e'aations The TRT investigated the DBA qualifications of the various coating systems that were used for touchup work, overlapping, and other special
; cases described in the allegations.
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- Imperial Concrete Coating Sequences '(AQO-01) . u .- . _ ,
1 A I - The following sequences of Imperial concrete coatings are permitted by
; CPSES Procedure CCp-40, paragraph 4.3.'1.2: #115/1201/115/1201 and .
l l 11S/1201/11/1201. The TRT reviewed CCP-40, Imperial Letter VBR-7697, l May 8,1978, -Imperial Technical Report #759, April 19,1984, . Imperial : , , Technical Report #495-81, June 10,1981, and related correspondence fr'om -(/ ! TUEC to the TRT. CCP-40. permits appl-ication of these secuences for_ repair
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and touchup work. Imperia 1 Letter VBR-7697 states, "Although the resultant , systems #115/1201/11S/1201 or #11S/1201/11/1201 have not been qualification tested, there is no reason'to believe that the9 are not viable systems." It is clear that these systems were used and that they were not qualified,'
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a con,dition which TUEd has acknowledged in correspondence to the TRT. Imper.tal Techwical Re~ port #759 provides some information to support the l finding that these. systems are technically viable. This report documents l , in-house adhesion tests of these systems performed by Imperial, with
, acceptable results. Imperial Technical Report #495-81 provides ORNL test i data that indicates that the individ' al u coating materials in these systems ,! will perform satisfactorily under normal service and DBA conditions. TUEC .l statedincorrespondencetotheTRTthatthesesystemswereused;calyin j limited areas as needed for overlapping to achieve a smooth application l adjacent to previously coated surfaces and repairs. Because of the areas
.! where the overlap w'as used, TU$C stated that information on the total sur-l face area is 'not available, and that these.. areas .have not been entered in f the coatiings-exempt log. During examinations of coated concrete surfaces 'I at CPSES, the TRT did not ' observe any aoticeably thicker areas or ridges
- .; in the concrete. coatings or any other evidence to refute TUEC's statement that only limited areas of smooth transitions were involved.
't The TRT concluded that although these systems are not DBA qualified, their lj . use"at'CPSES war ~ acceptable. ~
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- I Repair System Sequences Which Differ Trom Original Sequences (AQO-02) ,
l The TRT reviewed CPSES NCR #C83-01752, June 23,1983, Table A2 in j Appendix A of Specification 2323-AS-31, CPSES Procedures CCP-30, Rev.10, January 26, 1982, CCP-30A, Rev. 2', September 20, 1982, and CCP-40, Rev. 5, August 18, 1982, and related correspondence from TUEC to the TRT. ,
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' i In NCR #C83-01752., the disposition states, " Table A2 in Appendix A of l AS31 specifies acceptable coating systems, i.e., primer and final coat, , ,
product identification, and vendors' . . This table does not identify full system sequencing or application parameters. ?The TRT's review of l l the Table A2 revealed these statements to be accurate; however, a note to , this. table found in .Rev. 2, March 15, 1984, of spectfication AS-31 states, "It is essential that coating systems be used only as specified above, l
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unless aii alternne' system is proposed by a coating manufacturer and subsequently approved by the Engineer." l l
. l . The concern expressed in this allegation is that repair coatings are j applied in different sequences than the original coati,ng system and that ;
these repair sequences are not DBA qualified. The TRT's review of CPSES application procedures CCP-30, CCP-30A, and cdp-40, generally supports j TUEC's statement in correspondence to the TRT that repair sequences are . l not different from original application sequences, except in areas where . they ove.rlap. SSER writeup Coatings No. 4 provides additional information .
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about these p'rocedures and an assessment of their. adequacy. The adequacy "of DBA test data for the original application sequences, and engineering evaluations of changes to them, are discussed under Review of DBA
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g$Y Oualification Test Data in this assessment. .TUEC in correspondence to'the TRT that nonstandard sequences occurred only in reas of overlap, that the total area involved is indeterminate but minor,'and that these areas are not significant enough to warrant.special consideration, such as' DBA
. qual'iffcation, aiid that .they are not included in the exempt log.
l Except as, specifically noted elsewhere in this assessment, the TRT con-
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cluded~that applying coatings in nonstandard sequences that are not t 2
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l i i specifically DBA qualified, when used' ~1n small areas of repair artd overlap, I was acceptable. erM2fety rigM"cance D .. '~~ l
. Applying P-305 Over Another Manufacturer's Epoxy Coatina (A00-03)_ y
.In as'sessing this allegation, the TRT reviewed correspondence'from TUEC on .' ,
this subject, TUSI Procedure CP-EP-16.4, Rev. O, October 31, 1983, ef
" Protective Coati.ngs Exemption Log," selected entries from the Coatings j I
e Exemption Log, and DCA 17,142, Revisions 2 and 3. (Further discussion of , the exemption log is provided in SSER writeup Coatings No. 6.) The TRT i foundthat.althoughRev.2ofDCA17,142 permit'tedtheuseofthisnon- , qualified system, Revision 3 provided justification by reference to entry , No. 22 in the coatings Exemption Log. The TRT's review of the log found that entry No. 22 recorded 2300 square feet of P-305 applied to the Unit 1 manipulafor Hane! ~ ~'Titis area is considered small compared with the
~~
approximately 600,000 square feet of coated surface inside the Unit 1 l
. containment- building. Because entry of an item into the exempt log effec-tively removes it from Service Level I and S'pecification 2323-AS-31 requireinents, the TRT concluded that this item had bee,n handled properly
. by TUEC. TUEC did agree with the TRT that the allegation was correct in that this coating system had not been DBA'quafif.ied.
~
CZ-11 Topcoated With 1201 (A00-04) i k' The TRT reviewed DCA.12,374,.Rev..1, November 2,.1982, Protective Coatings Exempt Log (CEL) entry No. 30, Imperial Technical Report #553-81, and l i related correspondence froin TUEC to the TRT. The TRT found that this l I version of Imper 4al Technical Rep ~ ort #553-81 (which consisted of extracts from a larger report) gives enough information to provide confidence that the CZ-11/1201 system meets DBA qualification re'quirements. That report, however, does not provide sufficient detail to identify the particulars of -
~
the 'iys~ tem tested in regards to application methods and conditions, du Jm "D'thrW' (DFT),etc. The TRT found that DCA'12,374 provides for
~
coating of Richmond inserts in concrete using this system in accordance j
~
with the. requirements of CPSES Specificat. ion 2323-AS-30, which is the l l 1
' ' " ~~' ~ ~ * '
i , ,;.- . . , . < - 4, ,.4'. .,'a-- ! , ' sF . . , . . - . - + .. , .
..non afety-related coatings' specification. The DCA does not mention or /-
reference either test report #553-81 or the CEL as justification for this change. The adequacy of the DBA test report data base and of recorded engineering evaluations of design changes is discussed under Review of DBA Qualification Test Data elsewhere in this assessment. The TRT reviewed the CEL and found that entry number 30 records 2258 - , square feet of this system applied to Richmond inserts in the Unit _1 con-tainment building. The TRT found that the area estimated was acceptably , conservative. (SSER writeup Coatin'gs No. 6 provides additional discussion on the CEL ) Because this item is included in' tee 'CEL and involves a ' relatively small area, the TRT concluded that it is without adverse conse,quencesorsafethsignificance.
~
P-305. Applied OveT D-6 (A00-05) Y The TRT weriewed CPSES Procedure #CCP-30A, Rev. 2, September 10, 1982,
" Coating Steel Substrates Inside Reactor Building and Radiation Areas,"
Carboline Testing Project 401684, August 11, 1978, and,related correspond-ence from TUE0 to the TRT. The TRT found that Procedure #CCP-30A is the procedure for application of alternate coating system D-6/P-305~to safe'ty-related steel surfaces. Rev. 2 of this procedure provides for a DFT of 1.5 to 5.5 mils for D-6, with total-system thickness of 7 to 11.5 mils. ~ .
, TUEC pro.vided the. Carboline Testing Project,#01684 report to demonstrate l' the DBA. qualification of.tl.is system. The..TRT reviewed the report and l
'found th'ta it documented a test performed by Carboline for this system, which included only temperature and pressure criteria only for thickness ranges of for 2.4 to 3.5 mils for D-6 and from 7.3 to 11.1 mils for the total system DFT. .
~ '
~
The use of Ameron's D-6 with Carbpline's P-305 is technically acceptabl '7y X
. th.e TRT,,in that'~both materials are commonly used nuclear safety-related
~
materials. Ameron's D-6 is an' inorganic zinc, eg'nerically similar to ' CZ-11, and is commonly used at other nuclear facilities with various Ameron~ epoxy top coats which are' generic.;11y similar to P-305. However, h g o 0
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i . . the testing data provided by TUEC are' insufficient to demonstrate-th.st this system is qualified, in that no irradiation data are included for either material or for the system, other related test data for these materials as used in other systems has' not been provided, referenced, or , ev'aluated, and the Carboline test report is not independent and it does l not include testing over a broad enough range of thicknesses'to provide ' comparability to the thickness range used at CPS S. d
- The TRT has little technical concern that this system will not perform ,
adequately in service.
. y ;j -
11S Over Foreign Objects (A00-06) 4 .. . . - This allegation concerns DBA qualification of Imperial Nutec 115 surfacer applied'over"sarf6ui~ foreign objects embedded in concrete such as nails, rebar chairs, bolts, wood, or plastic. The TRT reviewed CPSES Procedure
, No. CCP-40,- Revision 5, August 18, .1982, " Protective Coating of Concrete
._ Surfa'ces,"' correspondence between Imperial and TUEC, correspondence from TUEC to the TRT, and linperial Technical Report No. 462-81, January 22,
~
. 1982, which was provided with TUEC's correspondence to the TRT.
The TRT found considerable evidence that TUEC had investigated this item
~
to determine the technical consequences of applying NUTEC 115 over embedded objects. The TRT also found that there was no DBA test data to demonstrate
' the qualification of.such applications. The.TRT. reviewed Imperial Te'chnical Report No. 462-1-81 and noted that it included ORNL testing of NUTEC 115 over steel in which the tested samples did not meet the ANSI N101.2 and N5.12 acceptance criteria. ;The fact that, in correspondence to the TRT, TUEC stated that "These tests demonstrate adequate coating per-formance under DBA conditions" is illustrative of inadequate Engineering evaluation by TUEC. Because of the varied locations of embedded objects,
- . TU.EC'st'at.ed tha Iinformation concerning the total surface' area involved was not available, and that these areas were not" included in the CEL.
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s The TRT concluded that, except as not'e'd above, TUEC exercised reisonable
, prudence in determining the proper treatment of. embedded foreign objects and in performing affected coating work in accordance with the coating material manufacturer's recommendation. Becau.se the areas involved were relatively small,- the TRT found that although these systems are not DBA ,
qualified, TUEC's treatment of this item was acceptable. . .
//
f Application of Inorganic Zine Primer in Three Coats (A00-09L _. 3 This allegation is concerned with th'e application of three coats of inorganic zinc primer at CPSES, which ~was alleged to be contrary to CPSES
~
Procedure No.,QI-QP-11.4.5, Revision 27. It is also alleged that a three-coat _.syst3m,would lack adequate cohesion and is not,0BA qualified.
' ' ~ ~
, The TRT reviewed Procedure QI-QP-11.4.5, CPSES Procedures CCP-30 and CCP-30A, correspondence f, rom TUEC to the TRT on this subject, and DBA and related tVYt data provided by TUEC,. including Carboline Laboratory Test Report No. 01978.1, May 14, 1982, Carboline Testing Project'02182, October 27, 1983, and Ameron Test Report No. TRC-089-03, October 10, 1979.
Both the TRT and TUEC noted that the application of three coats of inorganic zine is not a violation of CPSES procedures. The tesi reports provided adequate data to demonstrate that application of inorganic zinc. , in two coats rather than one would have no adverse effect upon material . {
. qualification. Accordingly, there is no cohesion or compatibility problem caused by multiple coats of inorganic zinc, provided that proper thinning , procedures are followed and that the total dry film thickness is within acceptable limits. The TRT observed that proper thinning practices for overcoating inorganic zine with inorganic zine were in effect onsite. ,, Furthermore, the TRT determined that excessiv'e DFT due to multiple coat i; appitcation was not a problem because overcoating was employed for the j specific purpose of bringing thin. areas up to the required minimum thickness. ,
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~
Coatings Applied Over Surfa'ces Cleaned by Power Tools (AQO-10)'*~ , This allegation concerns the DBA quali,fications of repair or touch-up coating work in which coatings are applied over surfaces cleaned by power tools. CPSES' Procedure QI-QP-11.4-5,'Rev. 27, paragraph 3.2.2.3 states:
" Surfaces that ha've been power tooled with '3-M Clean-N-Strip,' 80 grit .
or coarser flapper. wheels,' sanding discs, ' roto peens,' or equivalent *f provide acceptab.le surface profile."' The allegation states that: _.
- a. The coating systems applied to surfaces prepared using the tools ,
spect.f ted above are not DBA qualified.
- cfl._ -
, b. . These surface preparation methods provide a smoothing d polishing V ~ action, rather than a penetrating action, as obtained with sasdblastinfo~r~withaneedlegun.
. c. The" profile that is obtained using these methods occurs in a sparse .- pattern and not a densely packed pattern. .
TheTRTreviewedCPSESprocedureQI-QP-11.4-5,Rev.2Nandsubsequent revisions, ANSI N101.2, and correspondence fiom TUEC to the TRTI including I
~
attached copies of related correspondence with coating manufacturers, and test reports. (Further discussion of the adequacy of procedures and methods for repair work surface preparation is provided in 3SER, writeup l Coatings No.'4.) The TRT noted that ANSI N101.2 does allow surface pre-paration other than abrasive blasting to be used for repair work, and pro-vide's testing methods for ~ qualifying repair coating systems using alternate surface preparation methods. The TRT,:after reviewing the supporting data provided by TUEC, observed that there was considerable evidence that power tool cleaning as a surface ~ preparation method f'or repair work can provide acceptable results, although there was not complete independent laboratory DRA test. data for all methods allowed and used at CPSES. . Power tool cleaning does not, generally, provide the same degree and type of surface cleanliness'and roughness as abrasive blasting, and if improper
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-7_- _ t tools or improper methods are employe~d, power tool cleaning.can result in a smoothed or. polished surface with inadequate roughness to assure satis-
, fr.: tory coating adhesion. The information provided to the TRT by TUEC
} iod(cated that the mest satisfactory results are achieved with 3M "Cl ean-N-St rip'i or 60 grit or coarser sanding devices, and experience at
~
other n; clear- f acilities and the industry literature support this conclu- . ' .
~
[' sion. Thus'it is crucial that power tool cleaning be performed only With h the proper. tools used correctly and that the work be carefully inspscted to assure adequate roughness and cleanliness. , The TRT noted that the wording in QI-QP-11.4-5,' Rev. 27 permitted the use cf improper tools (a.c., "80 grit" and "or equivalent"). The'TRT also noted.that the inspection records for a large quantity of the repair work -' performed at CPSES do not provide adequate information to identify the
~'
precise Tools orTnethods used, or to demonstrate that adequate surface roughness was achieved. (The TRT also noted that current precedures and ' inspectternnethods have remedied this deficiency for current and future
- repair work.) -
Tne TRT has concluded that, although power tool cleani$g :an result in acceptable coating repair work, there'is' inadequate evidence to~demonst' rate !
, that surface preparation for coating repairs at CpSES was acceptable. How-i ever, these methods were used only for repair work in limited, but .
i, unquantified areas. Primer Thickness of 0.5 Mils (AQO-11)
! This allegation-concerns DBA qualification for primer applied at a thickness of 0.5 mils. It is alleged that CPSES DCA #18,489, Rev. 1, 22
[, l August 1983, permits 0.5 mils thickness cf primer and that this system is not DBA qualifted. The TRT reviewed DCA #18,489, Revisions 0 and 1,"TUEC's correspondence to . the TRT on this subject, and the CPS'ES CEL entries Nos. 8 through 15. The TRT observed that DCA 18,489,'Re' vision 1, does not accept or allow 0.5-mil 1 ..
. ;: n . ,e - A '. %, m . 'e s ..h~ ,s.'o. b < - ,**
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l thickness, recognizes that t'his thick'n'ess is unacceptable, and di's~ positions the affected areas where this thickness was observed by placing them on the CEL. (Further discussion of the use. of a DCA, rather than a noncon-
.! formance report, for this purpose is provided in SSER writeup Coatings No'. 5.) The~TRT reviewed the CEL where entry Nos. 8 through ,18 record approximately 100' square feet of surface area exempted because primer I thickness wa's below the specified minimum. (Further discussion of the Mr CEL is provided,in SSER writeup Coatings No. 6.)
[ The TRT concluded that the allegation was, incorrect in that a primer ' thickness of 0.5 mils was not allowed at CPSES,"and' areas with this thickness were exempted and not a,ccepted. , Applying Imperial System 11S/1201/11S/1201 to a Thickne'ss of 102 Mils
. Thisa1Ngationconcernstheconcretecoat1Igsrepair/overlapsystemdis-cusse'd in the SSER writeup for AQO-01, above. It is alleged that, if the maximum limits given in CPSES procedure CCP-40, Rev. 5., paragraph 4.3.1.2 are used, a 102-mil thickness of the Imperial System 115/1201/11S/1201 is
' ~'
allowed, and that this system is not DBA quaTified. , The TRT. reviewed all revisions of CPSES procedure CCP-40, correspondence ll from TUEC to the TRT on this subject, and related test reports., The TRT !j recognized that the total area involved could-not be quantified and was not entered in the CEL, but based on the review of this information and the investigation described under "AQO-01" above, including TRT examina-l tions of coated concrete surfaces, the,.TRT found that this system was used
', only in limited areas, if at all. The TRT found that the test data pre-
!j sented provides some confidence that this systen$ at this thickness will ! perform acceptably but does not constitute DBA qualification for the sy-stem permitted by the procedure. !i{6 * * !! The TRT concluded that, due to the iimited area involved, this item jl is without adverse consequences.
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Reactor Core Cavity Coatingi (A00-13T -
' ' ~ '
s This allegation concerns DBA qualification of coatings applied to the CPSES reactor core cavity. ,It is alleged that these coatings have not been DBA tested for the higher racitation exposure levels in this area, and that, in the event of a LOCA, failed coatings would interfere with the, . .. engineered safeguards systems. /r/ The TRT reviewed correspondence from TUEC to the TRT on this subject, .
, including correspondence between TUEC and,Gibbs &, Hill, entry #41 in the CEL, and physically examined the reactor core cavity. Because of the -
physical configuration of the reactor core cavity and its location in the
~
1 plant, fa,il,ed and flaked-off. coatings would not flow out of this area during a LOCA. The reactor core cavity is located below all other areas
~
. of the-cintainmenTbu11 ding and below the emergency core cooling system '
I sump screens; the only openings to the cavity are in the ceiling. Because - of the hTgTer radiation exposure levels in this area, TUEC has assumed '
'~
that the coatings will f, ail, and accordingly, placed this area on the CEL. The TRT reviewed the CEL and confirmed that entry #41. documents . 3135 square feet of coatings in this area. ' i The TRT concurred with TUEC's analysis and disposition of this item. -
. Applying CZ-11 or 191P over P-305, and P-305 over 1201 (A00-15) g i . .- . . . .
l This allegation concerns DBA qualifications of nonstandard systems used in repairs where coatings ove'rlap. It is alleged that CPSES procedure CCP-30, Revistorr 11, paragraph 4.4.3.0. allows ~CZ-11 or 191P to be applied
~
over P-305 without sanding back to a " mottled' i transition, that this same paragraph allows applying P-305 over 1201 and vice versa, and that these , systems are not DBA qualified. The )RT revie.<ed all revisic,ns of CCP-30, correspcodence from TUEC to the . TRT on th,is subject, and CPSES requests for information or clarification (RFICs) which addrest this subject. Tne,TRT found that the proce.dures
.- 9
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21 included incorrect and cor.fdsing inst'r'uctions in regard to r.epair's where , coatings overlap, and that the RFICs did not clarf fy the situation. (Further discussion of the adtquacy of,CPSES procedures is provided in SSER writeup Coatings No. 4.)
~TUEC has stated that the overlapping of coating systems, although the .
resultant systems have not been specifically DBA qualifid, is standar.h -A
} practice in the, nuclear industry. The TRT concurs with this statemeni.,
provided that such areas are limited to the smallest practical size, and . . that such overlaps are performed in accordance with " standard good coating ( j practices" .and the manufacturers' instructions, and'are carefully , j ' inspected, and provided that there is adequate technical justification for
- the overlapping systems and the application methods employed.
h; '
~
~ ~
j The TRT 'e'va10ated ov'erlapping systems used at CPSES and determined that i their limited use was not an item of concern. However, the TRT deternir.ad
'! that applying inorganic zin.c over an castig is nct technically )(
f .. *
- p - accAptable and that there is considerable evidence' tha*. this system will not perform satisfactorily. TUEC estimated that the surface area' coated with inorganic zine on top of epoxy ranges from 2,500 to 6,500 square feet;
' ~'
. the TRT c6ncurs with this estimate.
- t .
The ide,quacy of design evaluations and justifications for coat'ngs systems I , i at CPSES is discussed elsewhere in this report. Because of'the.re:atively minor surface areas involved in these overlap-systems, the TRT cencluded 1 that this item is without adverse consequences, l l . I
- 5. Conclusion _and Staff Positions: The s,pecific nonstandard coating systems l _
( described in these allegations represent a small port.entage cf the total area coated within the CPSES ccatainment buildin0s. The significance of the size of this area is discussed in SSER writeup Coatings No. 6, and an ) evaluation of the safety significance of potential coating failure (both ^ for this area and for the major coated areas) is reported in (LATER). )( l i l l l
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Based upon the TRT's broadir investigition of TUIC's design.and 6tig!neering - i for the major. coating systen,s at CPSiS, as well. as t,he investigations of specific allegations, the TRT 6:niludes that performar.ce of desi6n and ' engineering functions 'for coatings was inaccquate. Engineevicg review and {
- i. evaiuation was evide.",ced by the deficier:1es in the DBA data,basa and in design control activities and d:cumenution, and can be generally charac.- .' I ' ' '
terized as 'a failure tu make accurate techaical assessments and valid ', engineeringjudgper'.sinregardstccoatif.TheTRTfoundthatthis 4 i engineering performanct clearly temenstrated i that seme personnel estigned , by TUEC to perform entings engineering f. unctions ser a either not capabb j or qualified to perform these functior.s, and that the.*e was implem.ntation of 6ngineering review and ebacking measures which should have' detected and ,
~~
correct 6d poor engineering performance. ,
~
~ ~
'The res'u'lt of thete deficiencies is that TVEC has not demonstrated that the coating systems applied at CPSES are OliA qualified, in accordance wit' ANSI N101 2 end N512. Thtse deficiencies have also resulted in deficient '
I e coating work ' hat could have te.an prevented by proper design and effe::tive engineering evaluation. - -
- The generic implication of these conclusions 'is that TUEC's quality assurance program failed to implement effective design control of' safety-
; related coatings, and to detect and remedy that deficient implemettation, . [
L. thus rendering the overall effectiveness of the QA program and of batde engineering functions indeterminate. - . l d*Eno y
. 5. Actions Required: PriortofiveSercentoffullpgwer,TUECshallcomply 1
A j with the following requirements. . j (a) Obtsin directly from ORNL complete .0BA tes't report data which demonstrates t. hat all ma,1or. safety-related coating systems' used 3t
. .. CPEES are qualified in accordance with ANSI N101.2 and NS12. Where suchtestreportdatadonotexist, anew $RNLDBAtestshallbe per, formed and reported. Each such test report shall be complete in l
.all respects including compete date on test methods, sample g -W . ,
,. .~
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preparation, and test 'results for all samples included _in 'thE test. -
'The major systems for which this data is required are: ..
k ' OVER STEEL SUBSTRATES i SURFACE PREPARATION PRIMER SEAL COAT FINISH COAT
~
SSPC-SP-1 - Carboline (Optional) Carboline j Followed by Carbo Zinc 11 Carboline Phenoline 305 i SSPC-SP-10 . 1.5 to 5.5 mils Ph~enoline 305 Total System. j 1 to .3 mils Prefile' Approximately Thickness: 1 mil 7.0 to 11.5 mils - b SSPC-SP-1
- Carboline (Optio'al) n - Carboline 2
Followed by Carbo Zinc 11 Carbo 11ne Phenoline 305 .
.f SSPC-SP-10 1.5 to 7.0 mils Phenoline 305
~
Total System 1 mil minimum profile ~ '
- Approximately Thickness: --
(No maximum) - - 1 mil - less than 15 mils i - . SSPC-SP-1 .- --
-- Carbo 11 ne (Optional) Carboline
} - Followedb7 Carbo Zinc 11 Carboline Phenoline 305
,j SSPC-SP-10 -1.5 to 7.0 mils Phenoline 305 Total System
'4 1 mil minimum profile. Approximately Thickness:
;s 'l mil less than 15 mils
.. - (No maximum)
,j Water Blast at Imperial 11S Iinperial '11 Imperial 120
>a' Approx. 4000 psi 1.0 to 35 mils 3 to 20 mfis - 3 to 16 mils or
)
i Water / sand blast .- - 3 or -
~
Acid etch
-J-or Sandblast t/ Then steam clean, "
- J TSP wash, or .
- - ~ ~ " ;5 Detergent wa'sh 'a Power Tools may ~1 also be u' sed. . - b. Perform and record a comprehensive engineering evaluation of the test VO datadescribedin[a]above,toincludeevaluationofthecompleteness h of the data, the acceptability of the methods and results and the applicability of the data to the coating systems applied at CPSES.
_,_Io any.cas_e_where there is not a direct one-to-one c,orrelation between the tested system and the CPSES sys. tem, the engineering j .. evaluation shall provide the j,ustification which demonstrates the .y applicability of the test data to CPSES.
- ] .
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TVi C- - (c) YtiGC4 shall perform a ' review of..every'DCA which affected fafety-related coating work at CPSES and perform and record an . engineering evaluation as in(b) and(ci above, as appropriate, e in each case where such an evaluation does not already exist. , (d) Prior to the performance of the actions required in (a) through (c). .' , above,' TUEC shall provide complete documentation to identify the k
. personnel who will perform these actions and to demonstrate tb.eir qualifications to perform these activities.
(g) In any case where the actions required above " ' demonstrates that any coating work at CPS 5 is not acceptable, . TUEC shall document the particulars in accordance with Tl)EC's QA
' ~
~
program and submit the proposed corrective action to the NRC for review prior to implementation.
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I 8; Attachments: None. l ~
- 9. Reference Documents: , ,
~ '
1 CPSES -FSAR, Section 1A(b)-26.
- 2. CPSES FSAR, Section 17A. f.
- 3. NRC Reguistory Guide 1.64, " Quality Assurance Requirements for the ,
Design of Nuclear Power Plants." . . .
- 4. NRC Regulatory Guide 1.54,- " Quality Assurance Requirements for -
Protective Coatings Applied to Water Cooled Nuclear Power Plants."
, ._ 5. American National Standards Institute (ANSI) N101.2, " Protective I
Coatings (Paints) for O ght Water Nuclear Reactor Containment .
. Facilities." -
- 6. ANSI N101.4, Quality Assurance for Protective Coatin's Applied to Nuclear Facilities."
i
- 7. ANSI N512, " Protective Coa' tings (Paints) for the Nuclear Industry." -
- 8. ANSI N45.2.11, " Quality Assurance Requirements for the Design
! of Nuclear Power Plants."
- 9. NRC IE Information' Notice No. 8360, " Falsification of Test
- Results for Protective Coatings." '
- 10. . Texas Utilities . Service, Inc. , Procedure CP-EP-4.0, Revision 3, l
" Design C,ontro Al
\
- p. m. . -- .-
g_ _. 7 av. - g y >y 3ny 3 g 3353y;r~ 3 3 3-["[['
. . - , _. , _ n . , ,: _m - ..__ . .
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- 11. CPSES FSAR, Table 6.2.1-1, T'able 6.2.5-2, Figure 6.2.1-1, anil Figure 6.2.1-2. - -
~
- 12. TUGC0 CPSES Protective Coatings Specif t, cation 2323-AS-31, all .
. revisions to date. ,
~
- 13. Brown & Root, I'nc., CPSES Procedure No. CCP-30, " Coating Steel Substrates Inside Reactor Building and Radiation Areas," all - - .b revisions to'date.
- 14. Brown & Root, Inc., CPSES Procedure Nd. CCP-30A, " Coating Steel
'Substrates'Inside Reactor Building and Radiation A'reas," all -
revisions to date.
- 15. Brown & Root, Inc., CPSES Procedure No. CCP-40,' " Protective -
Coating of Concrete Surfaces," all,' revisions to date. .
- 16. Five CPSES,"yault Packages" of DBA test. data identified as CPPA-6680, CPAA-7387, CPPA-19,717,.CPPA-22, 217, and Caioline letter to
' ~
TUEC date~d No'v' ember' },' 1983.
- 17. TUEC correspondence to the NRC identified as TXX-4201, ,
June 22;1984, TXX-4225, July 16,1984, and TXX-4262, . ;. ,
. Augusi21,19846) . Ir
- 18,.
TUGC0 office memorandum, Rt G. Tolsorr to J. B. George... - " September 3, 1984.
- 19. Texas Uttittfes Services, Inc., Procedures CP-EP-4.0, Revision 3,.
. and CP-EP-4.6, Revision 10. .
- 20. Specific Test Reports, NCRs, and DCAs as identified in this report.
~
- 10. 'This statement prepared by: - - - -
W94 4 W m C. Wells) W T Date M Reviewed by: Group Leader Date h 9UCNJ//10> Approved by:
~. Project Director Date l Y YWI s L->
? - - - - -
w r - --# .
/ e i c .
. SSER WRITEUP DOCUMENT CONTROL / ROUTE SHEET
~
Allegation Numbers AkO-21,31,'33,3[,5/ _ Subject of Allegatign Codinh 5 Tnsv'ectoPWPo. der Thniu +MiticaTTon TRT Group Coaf, n e 4 h L:.dR '7 ' s Author: B en , Hoda son d Q . This sheet will be initialed by each reviewer. It stays with all revisions to the SSER writeup and serves as a routing and review record. It will be filed in the work package when the writeup is published. Draft Number Draft 1 2 3 4 5 Autho 0U/Mt11/D/2dM Group Leader /Wm /s/ukt' ' Tech. Editor - Wessman/Vietti " J. Gagliardo T. Icoolito _ Revision Number , J _.- , Final 1 2 3 4 5 . Author ' Tech. Editor ..._ s .E - Group Leader .- ". J. Gaaliardo T. Ippolito Adininistrative . Writeup integrated into SSER Potential Violations to Region IV Workpackage File Complete Workpackage Returned to Group Leader S
- - _ _ . . . , . _ - - - - - _ . , , , , . , . , - , . ~ , _ . _ . . -
z, . 4
- f Document Name:
- AQ 22 - AQ 61 Requestor's ID
DEDIR02 . i .ss , Author's Name: Poslusny/Matthews . 1 a 4 Document Comments: 1 - { SSER Coatings Training - 10/27/84 i 4 i i l 1 1 I J l i i l i, l l 4 r- . - .-r--, - - , . . . _ . ,.--..,--,.._m.~,c-.~,,.., _
,,myy.,_. ._, .._ _ _ , - , . , ,
w.y --.,,- r..y.- ,m ,-_yy,.--w.....--- 7#..,,--, .m-2.,,,
z , , s - l i AQ-22,AQ-32,AQ-33,AQ-35, and Parts of AQ-61 Draft 1 - 10/27/84
.s-SSER
~
- 1. Allegation Group: Protective Coatings 7 - Training and qualification of coatings inspectors and painters.
- 2. Allegation Numbers: AQ-22, AQ-32, AQ-33, AQ-35, and parts of AQ-61.
- 3. Characterization: It is alleged that:
Coatings inspectors must perform backfit program adhesion testing without first completing training. (AQ-22) Reading list contents have been changed after inspectors sign the list. (AQ-32) A lead coatings inspector lacked the qualifications to properly perform his duties. (AQ-33) Some persons providing training to prospective inspectors are not properly qualified. (AQ-61a)
- \
- Level II inspectors " sign-off" for training conducted by Level I inspectors. (AQ-61b)
- Workmanship is poor because painters lack the qualifications .
.i- <
necessary to produce quality work, and painter certification documentation is deficient. (AQ-35)
- 4. Assessment of Safety Significance:
The general concern of these allegations is that the methods used in the CPSES quality assurance program for protective coatings to evaluate the prior _ experience, provide adequate training, and certify the ability of coatings personnel are not adequate. The implied significance of these allegations is that inadequate qualification of personnel could result in inadequate application and inspection protective coatings. Defective coatings.could fail during postulted accidents or during service. An - evaluation of the significance of this safety concern is reported in (LATER..........I.TheTechnicalReviewTeam(TRT)evaluationofthe quality assurance aspects of these allegations, as characterized above, is discussed below. Review of Requirements for Training and Qualification: The TRT evaluated generai and specific features of coatings inspection and application personnel qualification systems, and the basis of each specific allegation.
In the CPSES Final Safety Analysis Report (FSAR), TUEC commits to American National Standards Institute (ANSI) standard N101.4-1972, " Quality Assurance for Protective Coatings Applied to Nuclear Facilities", and Regulatory Guide 1.54, (June 1973), which endorses ANSI N101.4-1972, with comments. ANSI N101.4-1972 requires that the QA program include provisions for.the qualification of application and inspection personnel.
/ Effective with. revision 15 (April 30, 1981) of the FSAR, TUEC committed to Regulatory Guide 1.58, Revision 1, with minor modifications. This regulatory guide endorses, with comments, ANSI N45.2.6-1973, "Qualifi-cation of Inspection, Examination, and Testing Personnel for Nuclear Power s Plants." ANSI N45.2.6-1978 provides guidelines and criteria for the
'N . evaluation and qualification of inspection personnel.
~ -
~~. . . . . . . _ _
CPSESspecification2323-AS-31"(LATER: TITLE)" requires certification of x. coatings.. inspectors and applicators in Appendix C, paragraphs 6.3a and l 5.2b1 respectively.
~
l l Requirements for Certification of Inspection Personnel l l l l The TRT reviewed each revision erencedbeljoftheTexasUtilities Generating Company (TUGCO) procedures +providing methods and requirements to qualify coatings inspectors. These procedures are: CP-QP-2.1," Train-ing of Inspection Personnel", CP-QP-2.3, " Documentation Within QA/QC Personnel Qualification File", and QI-QP-2.1-4, " Qualification of Pro- i l tective Coating Inspection Persennel". These procedures also specify l 1
- _, ,__..,.m_ . - _ . . , _ _ , .__ .
si requirements for documentation of training, testing, and certification activities. e m , . . .
,'N ANSI N45.2.6-1978 defines the minimum capabilities required for each level of inspector certification. Capability is to be established by suitable evaluationsofeducation, demondfit'ien.The TWT experience,trainingtestresult,andcapaks4 e.ta.wn neM tutdcu C cep hl J
\bilityAevaluations,asdiscussedbelow.
N - - ~ .._ _ The TRT reviewed the complete qualification files of twenty-three QC personnel certified between 1978 and present, ar.d portions of other files described hereafter. The TRT also interviewed eleven Level I and Level II inspectors, two Level III Quality Engineers (QE's), two former QC supervisors, and the former QA manager. The TRT did not contact previously coatings personnel relative to training and qualification. Certification of Level I Inspectors The TRT found that the previous experience of inspectors, which might serve to establish their capability, is not in every case evaluated in accordance with applicable requirements ANSI N45.2.6-1978 and TUGC0 procedure CP-QP-2.1 require certain "related experience in equivalent inspection, examination, or testing activities"
/
for each level of certification ~-ANSI N101.4-1972 states that an
. ._. . . . . \
inspectors' " qualifications shall include his prior training and inspec- I tion experience for work of comparable scope with generic coating systems l l l
1 similar to those used for the work in question." The TRT considers that
~
this statement defines " equivalent" experience when cited as a qualifica-tion basis. .
. i *.
The TRT found previous experience as a journeyman applicator (painter) credited on inspector certifications as a qualification basis, including the certifications of four presently-employed inspectors. The TRT con-siders that, though experience as an applicator of nuclear coatings is
~
beneficial, such experience does not constitute " equivalent inspection experience," and is not a suitable basis of qualification, nor a suitable basis to waive indoctrination and training requirements.
~
~
The TRT found that_ education and preiious work experience us~e'dii ala~ sis 7 of" inspector qualification is not adequately do~cuinented iri~all c'ases) The TRT noted fourteen instances where the verification of education and previous. experience cited as a qualification basis by certifications is missing or incomplete. The TRT did note that, in a few of these cases, such verification is available from other existing uncontrolled files. Other factors may demonstrate inspector capability. ANSI N45.2.6-1978 and TUGC0 procedure CP-(P-2.1 provide that required education and experience levels should be treated to recognize that factors, such as job performance, training, and testing, may provide reasonable assurance that a person may competently perform a task. Regulatory Guide 1.58 requires ] documentation that these factors show the competence that would be gained j from having the required education and experience. The TRT evaluated
other available evidence to demonstrate each inspector's capability, as described below. ANSI N45.2.6-1978, requires that on-the-job training (0JT) be included in the training program. During interviews, the TRT questioned inspectors' concerning OJT which they have given or received. The TRT found that training at CPSES regularly includes OJT, in which inspector trainees
' perform actual inspections.. The TRT found that OJT serves as a primary training vehicle for personnel without equivalent previous experience, which is one acceptable method.
OJT records examined by the TRT show the procedure (s) covered during the OJT session, date and time, and names of the trainee and instructor. [RT found the OJT records do not provide ~EifficTent detiil~to iss~eTi the-] quantity and_ quality of the OJTy bJT records do not identify ' activities, functions or inspections performed, do not show that acceptable inspection documentation was prepared, and do not show that the requirements of the ' l inspection work were successfully demonstrated by the trainee'. The TRT noted that OJT requirements are often waived on the bsis of previous experience and/or examination results. For example, OJT requirements were partially or completely waived for fourteen of twenty-four inspectors certified to perform Backfit Program inspections. The TRT did not evaluate whether there was acceptable justification for waiving OJT requirements, except in one case discussed below. Further. the TRT noted that all sxaminations do not include practical tests for important operations, such as visual identification of film defects. t .
t The TRT reviewed selected Level I examinations. The TRT found that written examinations primarily test aspects of the inspector's capability to identify specific work and inspection criteria, such as film thickness and ambient condition requirements. pe"TRTfoundthatwriM
.\r exarninations-do-not-test-the inspectiirTtnowledge of7ppTicable~ quality)
~; _ -
pssurbe.quirementsguch_as_ _ instrument and docum_ eat. control j
$qulrementsj,..f &;M'y,_the method _ of op_er.ating instruments or perf6riifEg'~~7 Tmportant inspection tasks,_or_iden4My the precision characteristics of)
~fisoection.Jnethods and jnstruments).
3 The TRT reviewed selected examples of the prepared answer keys used to grade examinations, arid compared the responses given by answer keys to the
~
responses given on examinations. { TRT found incons E E d ] > goperly_ graded examinationQ In one instance, the correct answer key response is a description of the method for an inspection; an examination 1 response which identifies only the name of the inspection was fully , credited. The TRT considers that these inconsistencies may obscure the 1 4 inspector's failure to understand important requirements. 1 The TRT found that a number of examinations consist of written and practical (e.g., demonstrated ability) test elements. , The TRT conclude]d, on the basis _of jaterylews and review of.reWds~~that ~ ~ - - = practical -tests are *
- graded QD a pass / fail basis.without M t,,teh~gDdiiTi s i'fo'r]gra g g Prgl.teitGnEluded.JDjarious_ednilRatii5iis provide 24% to 50% of the
-...~~----__ ,
- grade._of,thecombined.Wr_fttenand. practical.. examination.,Jhe,,TRT^noted) ..
~. ,
i that, as ale 5ul,t ,9 _sco_r. f jag.50 points _on.the. practical. test elements, 4
inMho i~chTEVid c the requife-d passing grade of-80%-had. 'in 4t, sco D nly 50 Con ~ the~diiten rtionTo h he examinalf5 G The TRT considers that the formal classroom training does not assure the capability of inspectors because the training is primarily a review in preparation for-the corresponding examination, .and does-not-include al j
. . m . m . --
. ~'
Jesson plan which shWs an adequate review of necessary reWirement.s.), The TRT noted one instance of color vision deficiency shown for a presently employed inspector. The type of deficiency is not noted, and there is no objective evidence of the inspector's visual acuity in field conditions. ,0ne of the~1nspector's annual examinations, during wiiich hie J _
~
}ailedtoidentifynineoftwelvetestJ1ates,waswaivedon'th'e' basis._of._)
}a~supplementarytestaiven_with_ colored _ph)
The TRT considers that documentation provided by Level I inspector files is not adequate or sizfficient to demonstrat t required cap ~abil.ity of all personnel has be.en achieved. l The TRT randomly selected twenty inspection reports generated between 1978 ! and the present to verify the qualification of each inspector to perform the documented inspections at the date of the report. The TRT found no records for the inspector who signed report #PC03511, dated 2/24/79. The signature is difficult to read, and the TRT could find no record of a similar signature for this individual in the Permanent Plant Records 1
.g.
Vault. The TRT found certification documentation for the other inspectors. The TRT evaluated the procest of Lt.lel I inspector recertification, to - establish that the proficiency of inspectors is maintained. The completed recertification forms (approximately eight) reviewed by the TRT showed
'that written, oral, or practical recertification examinations have been
! given. However, the TRT fo'Dd no7upporting evidence that written ora,,1,J j pr'6r~actical examinations were g'ivenjobhtor_.r,ecertificatig; Q TRT found that recertiffiation consists of an infornal evaluat'fEly the] responsible 0C~itT6iR[sM, based on personal knowledge supplamented by information from the responsible lead inspector. The TRT interviewed personnel and found that, to maintain their i proficiency, inspectors are directed to read revisions to governing documents. Tle__TRTfound_documentationforonejnstanceofrequireG ,
~~ ~
s'upplHental reiding included in_ several inspectorsi_ files, in ~accordancy with the requirements _of TUGC0_ procedure _CP.-QP. .2d,__.Ike_IRf_.lodiid nol
~
verificati6n7f readir.g, or records of formal Tr~alrifng~for ~other' imp 6rtan,t
~
r_evisiins t6_ governing _ documents.JiuctLas. revision _2 of CPSES
- specification 23.23.-M-31.}
, The TRT considers that the methods used at CPSES to recertify Level I i coatings inspectors do not demonstrate the continued capability of these - i personnel. j .
. However, during the course of interviews, the TRT asked inspectors to explain a number of generic and specific requirements, and methods of implementing those requirements. These discussions were not detailed enough to fully assess the inspectors' understanding of requirements; however, in th0 opinion of the TRT, each inspector demons'trated an adequate understanding of methods and requirements.for the topics covered.
Certification of OJT Instructors l i TUGC0 procedure CP-QP-2.1, beginning with revision 8, requires that OJT be conducted under the direct supervision of an individual (e.g., Level I) certifi,ed as an OJT Instructor, or a Level II or Level III inspector. The basis of qualification of OJT Instructors, is stated on the certification form given as an attachment to the subject procedure. i I l The TRT interviewed coatings inspectors, and coatings QA supervisors, and
! examined coatings inspector qualification files (as previously noted) in order to evaluate implementation of this requirement.
1 l The OJT Instructor certification form contains entries for " type of examination given: (oral, written, practical)" a.nd "results of examination (s)." Certification forms exa dg R ty ic show satisfactory examination results. The TRT found that, wherega written ve canduded testi;indiceted,dhecitedtestistheinspector'soriginalexamina*. ion for Level I certification instead of an examination specific to instructor
1 qualification. The TRT found that, where oral examinations are indicated, specific oral examinations did not occur. The TRT found that the " satisfactory evaluation of the individual's demonstrated proficiency" used to establish " reasonable assurance that the individual can competently perform as an OJT QC Instructor in this
' activity" (s.tated by the OJT Instructor certification form) is an informal evaluation conducted by the responsible QC supervisor, based on the supervisor's personal knowledge and information from the responsible lead inspector.
The TRT found that inspectors are not, in every instance, notified of their certification as an OJT Instructor at the time of certification, nor l are they specifically notified that they have been recertified. As discussed under allegation #61 below, the TRTTdeTitTfi~ed two firdividuals~]
~
who conducted OJT without being certified for that activity. ] _ , i The TRT noted a requirement of TUGC0 procedure CP-QP-2.1, revision 16, l (July 17,1984) that inspectors are responsible for determining their certification status, and that since about June,1984, there is a report showing each inspector's certific.ation status. Based on the above, the TRT considers that the_CPSES_ qual.ity.assuran.g_e., prog.r,am 1,acks sUff1cient-~f ,
~
fo}tiols"to assure that OJT is conductid[by qua).ified ,in,s_tiu]jorsJ I i
l ..
\
. l Certification of Level II Inspectors The capability described for Level II inspectors by ANSI N45.2.6-1978 include: planning inspections, evaluating the validity and acceptability of inspections, supervising inspection personnel, and qualifying lower ,
level personneh The TRT considers that, in the CPSES protective coatings quality control program, lead inspectors regularly perform the functions ascribed to Level II inspectors by ANSI N45.2.6-1978. The TRT noted that, prior to June 1984 Level I inspectors were regularly appointed as lead inspectors. The TRT examined evidence which follows. 3he TRT'found no docuemnt estabfishing the pos'ition~of~l'e'ad inspecto,r, anty no document __assignjgJn individuaLas _a. lead inspector for_ coating, wor,b} The TRT found that inspectors and lead inspectors understand that the I responsibilitiesoftheleadinspectorsconsist(innoparticularorder) j of: interfacing with production supervision to accomplish needed [ inspection work on a timely basis, supervising other inspectors to the extent necessary to provide efficient performance of inspection work, , monitoring the performance of inspectors, OJT instructors and trainees, providing the first and primary level of response to the questions of other inspectors regarding technical and operational problems, providing feedback to QC supervision on the performance and capabilities of other , I inspectors, and contacting responsible QE's on questions or problems i l I s
beyond the capability of the lead inspector. The TRT concluded that the position is verbally defined and assigned by a responsible supervisor. The TRT found that TUGC0 procedures require that certain functions be -
.s~
performed by lead inspectors. For example, TUGC0 procedure QI-QP-11.4-26, revision 6, paragraph 2.3.1.1.c assigns lead inspectors to the task of reviewing and approving a log of environmental inspections. Further, certain requirements documented on Protective Coatings Technical Training Outlines are verified and signed by a lead inspector, and the responsible supervisor may indicate completion of other items on these outlines on the basis of statements by lead inspectors. The TRT interviewed six recently certified Level II inspectors. The TRT found that the Level II certification process consists essentially of: an undocumented study and review of current requirements, a documented classroom review of requirements, and a written examination.
- The TRT reviewed approximately six Level II examinations. The TRT found that the examination tested knowledge of specific cbjective requirements
~
in greater detail than for Level I examinations. Th~i'TRT'f6iiiid th~at 1[h[] ixaminatidri'dfd not dem.o..ns.t.r.a.t..e or estalilith the-individual'Icapabi.l.'i..t[. / either to_p.er. form _the fun:tiorn,,d,.es_cribe,d_by, ANSI N45.2.6-191S_.as. lj.s..ted) or aboveMto perf6nn tOunct. lins regu.1)r.,1ylequired"of'l' ad e inspector's__and,)
, Level II inspector _s fn .nt .CPSES. coatings _ inspection. program. -]
)
Certification of Level III Coatings Personnel The TRT found that individuals assigned as QC supervisors at CPSES i
- typically have Level III certifications. TUGC0 Procedure CP-QP-2.1, revision 16, provides that Level III Civil certifications include protective coatings in their area of responsibility. ,Th.CIECf6und' h ope _- J instance of a recent supervisor of the coatings QC inspection department, certified as a Civil Level III., whose file does not'fndT03e~docuWtEd7
_ _t . . - _ . _ _ - . . . .-. - I study-of-coating requiFements and p_rocedures anTwhose_resuji]t dg@ clearly. demonstrate _previoustechnical_experiencewithth(ghetkk_.) coatingt systems'used at CPSES} As a supervisor, this individual attested to the capability of a number of inspectors, and made other technical decisions concerning coatings inspection work. TUGC0 letter TXX-4262, dated August 21, 1984, identifies individuals who have been assigned to supervisory functions for the coatings quality control program since January, 1982. This letter identifies three individuals assigned such functions who did not have certifications for coating work. The TRT found that these individuals have signed QC inspector certification documentation, as QC supervisors, to verify evaluations of capability, and have made other technical decisions l concerning coatings inspection work.
~
~~
The TRT~f' o und that recoTdOo noi' demonstrate the capa6flTtiiif 08 ', _.= ,,,,__; r- :C'. _ _ . .-"J . ' ' ' ' _ _ ' ,
,,supervisorstoper,(prm_.their,assignedfunctions.)Duetotimerestraints,
l I i TRT was unable to assess the effect of this finding upon the quality of coatings applied at CPSES. Review of Individual Allegations: -
.\%
Backfit Program Training (A00-22): . This, allegation states that coatings inspectors are required to conduct tests of the adhesion of applied coatings, as part of the Backfit Program, without first completing formal training in the proper methods to be used in performing the tests. The' testing method cited by the allegation j requires operation of the E1cometer Model #106 adhesion tester. The impliedsignificanceoftksallegationisthatthetestsmayhavebeen improperly performed and that the data generated may have resulted in the : improper acceptance of coatings. A discussion of the history and requirements of the Backfit Program and the evaluation of the Backfit ' Program inspection data is given by SSER Coatings 1. ! I' . Coatings inspectors performing Backfit Program inspections are certified to TUGC0 procedures QI-QP-11.4-23. " Reinspection of Seal Coated and Finish Coated Steel Substrates for Which Documentation is Missir;g or Discrepant", and/or QI-QP-11.4-23, " Reinspection of Protective Coatings on Concrete Substrates for Which Documentation is Missing or Discrepant". Each of the procedures require the use of the Elcometer adhesion tester. l
- _ . _ _ ~ _ . ,
, . - . . . - . . _ _ _ _ _ _ ~ - . -
The TRT randomly selected twenty Backfit Program inspection reports, and found that the inspectors who prepared the reports were certified at the date of each report. The TRT's review of logs since 1982 found one NCR,
#C-83-00852, which dispositioned nineteen Backfit Program inspections
- performed by an uncertified inspector.
The TRT examined the files of the twenty-four Q.C. inspectors certified to TUGC0 procedures QI-QP-11.4-23 and/or QI-QP-11.4-24 between the start of the Backfit Program and the present. As previously mentioned, ANSI N45.2.6-1978 requires that training include OJT. .This standard further provides that uncertified personnel may be used "in data-taking assignments" provided they are supervised by qualified personnel. OJT for Backfit Program adhesion testing and Tooke gauge film thickness measurements are generally data-taking operations. Regulatory Guide 1.58 requires that, in such an instance, these trainees have completed training adequate to assure competent performance prior to performing data-taking OJT. During its review of files, the TRT noted ten instances where records show that OJT for Backfit Program training preceded study of appropriate requirements. The TRT also noted seven instances where OJT for Backfit Program certification was completely waived; however, in each case the inspectors studied requirements and completed a written / practical exam prior to certification. The TRT found that inspectors have been c'ertified i
)
l
- 17 -
! for this inspection on the basis of the single demonstration of capability during a practical examination. The TRT has commented above on practical examir.ation grading practices. .
. 's
! The TRT found that the training program does not require that an inspector 1 trainee complete a formal training session or read. applicable instructions
-prior to performing inspection tasks while participating in OJT. During interviews wit.h inspectors, the TRT found that trainees are instructed to read the applicable requirements prior to OJT, but there is no consistent verification that the instruction is followed.
The TRT noted that TUGC0 procedures QI-QP-11.4-23 and QI-QP-11.4-24 do not provide a detailed operational method for operating the E1cometer 106 i adhesion tester. CpSES specification 2323-AS-31 directs that the instrument be operated in accordance with the manufacturer's recommenda-i , tions. The TRT found that the Protective Coatings Technical Training Outlines do not show that inspectors have read the manufacturer's recommendations. . I i The TRT found no copy of the referenced manufacturer's instructions available at the QC inspectors' office or in the possession of inspectors.
, The TRT found that a copy of the instructions are available from responsible coatings QE's upon request.
1
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. I Since about July, 1984, TUGC0 procedure QI-QP-11.4-29, "Use of Elcometer AdhesionTester'forIsolatingAreasofhuestionableCoatingAdhesion",has been employed as stated by the title of the procedure. This procedure describes a detailed operational method for use of the instrument.
~
The TRT noted a-separate but similar deficiency. TUGC0 procedures do not provide a detailed operational method for the use of the magnetic dry film thic,kness gauge used for regular inspection work at CPSES (e.g. not BackfitProgram). CPSES specification 2323-AS-31 requires this inspection be conducted in accordance with a standard consensus specification, Steel Structures Painting Council (SSPC) specification PA2-73T, which provides detailed instructions. The TRT found that files of three present inspectors do not shown study of SSPC PA2-73T. It is the technical opinion of the TRT that the majority of possible operator-induced errors in the operation of the adhesion tester will
- result in lowering the indicated adhesion values, and thus wo~uld .show failure of coatings with actually acceptable adhesion. Further, it is the technical opinion of the TRT that, although mis-operation of the instrument may adversely affect its cal.ibration accuracy, the probability of this occurring is low. The effect of calibration accuracy on the Backfit Program data is assessed in detail in SSER Coatings 1.
The TRT considers the allegation is substantially correct in identifying that the training program does not provide adequate measures to assure l 4
that trainees are fully familiar with instructions and requirements prior to OJT, and does not demonstrate adequate inspection experience or testing where OJT was waived. The TRT considers that these practices are a subjectofconcern)(. However, such training which was given was beneficial. Further, the probability of the described practices affecting the Backfit Program adhesion test data in a non-conservative manner is
' low.
READING LISTS (AQ0-32): The subject allegation states that, after a reading list was signed by QC , inspectors, the document which they had acknowledged reading was exchanged for another document and yet the reading list acknowledgement form remained the~same. The significance of this allegation is that inspectors might be held responsible to implement requirements of which they are not aware. - The TRT did not identify any instance where a reading list prepared as part of initial training shows evidence of being altered or adulterated. The TRT reviewed certain reading lists with present inspectors, and found the lists accurate. As noted previously, the TRT.found that periodic reading requirements given by TUGC0 procedure CP-QP-2.1 are not evident. The TRT did not find evidence to substantiate this allegation.
- , . . --- . . _ - - - -, p.- . . _ . . _ . . -- . - . .
. QUALIFICATIONS OF LEAD COATINGS INSPECTORS (AQ0-33):
The subject allegation states that may problems with the coatings inspection program occurred because of the inexperience of one of the idad
.s-inspectors in the coatings QA/QC department. The allegation cites as an example an instance where this individuti identified rust on an A-frame at
~the Seal Table room as being resid b of Ameron D-6 primer.
The concern of this example requires the TRT's coment that the various oxides of iron are typically described as " reddish-brown" to " black" in color; the color of the primer coating is typically described as
" reddish-grey". The implied significance of this allegation is that inadequate technical knowledge of supervisory personnel will contribute to defective inspection work, and defective analysis of the results of inspection.
The TRT reviewed the permanent file of the lead inspector named by the allegation. This individual's resume shows five years of experience as a journeyman and foreman painter for nuclear coating work, and nineteen years as a journeyman painter for industrial and commercial coating work. Previous coatings inspection experience was limited to one (1) three month period of intermittent coatings inspection, lhe_TRTfoundnoind6Eio3 i o]n,the_1ndividual's resume of training _in the technical chaFaitefistYcs_ o,f]
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pgg ; cia t.7% u .. u c .. , Yer_ificationof_previousemploymentandeducationwasnotinthefile,)
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Adt3xperience and education was_ citAsLby_cettif_ications as a basisToJ qualification Verification efforts by TUEC during the course, of the TRT , review showea Inat the individual _had not_ received his cla1med hig p , t i . c m. school diploma, and tha fclaimed work __egpatience was_ inaccurate] The TRT - l . j
- found that certifications for this individual completely or partially /
i ! waive OJT requirements on the basis of his previous experience. i, 1 The TRT noted that creditteiraspon.s.es_of_ qualifying examinations _taken by_)
}
j this individual _ deviate from the responses 4f- the-prepared _. answer key _fd j > l [theexaminations) . 7 i j 'The TRT found that the ind_ividual was cert'.fied'to~hAfforni'Ba'ckfiti !
' Program inspections two weeks after hiring _ and as a Level I inspector]
1 .- I fo \
- r_.oiher_ functions four weeks after' ~hiring,
~ ~ ~ ~ ~ - -
. . ~ . . . . was ap~piihted"hsTleaif]
,s T inspec. ton,within_fo,ur, weeks _of hiring. _atuLwas cfrtified as an _ OJT./
Ins.tructor approx 1mitely'sixNe'ek'sNe1hirjngu_The TRT notieLthA_t,_ah
~
e / a;,le.ad_inspectot...this__ individual veriffe lthat.j,nspector t~rainees ha d /^ successfully completed hqij[jte_tr.ainMQ i (d4A.6cd l The TRT noted that the individual named by the allegation was A cd l from employment about May 1983, i i 1 1
- The TRT reviewed documentation of the incident cited in the allegation, l l including inspection reports #PC47854 (11/4/82), #PC47874 (11/5/82), and I
i l
- 1 22 -
NCR#C-82-02403(12/30/82), with attached inspection reports. The TRT found evidence in these records to demo [istrate that three inspectors believed the residue was rust. The TRT noted evidence that responsible ! ! QE's disagreed with the evaluation of the inspectors. * ' l {he TRT cqnglud_es that records do not demonstrate the capability o_f th_e_f
}hdfViduai named by the rilegation to,,per, form'thFd0ttes required for~hT3 1
. ~
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;posi. tion as Level I inspector, OJT'Tiistructor, amLleAd inspeM The TRT did not determine the extent to which the inadequate qualification of .
this individual may have affected the quality of coatings applied at CPSES. The TRT concluded that the instance cited by this allegation l \ demonstrates one example of defective evaluation on the part of inspectors or' responsible QE's. The TRT was not able to clearly identify l which group made a defective evaluation, but noted that the adhesion of these coatings failed after the original engineering identification of
- the residue as primer. Repair of failed areas is documentedgto tho
' ~' NcR wb d eA Oov6, . QUALIFICATION OF INSTRUCTORS (AQO-61a, AQ0-61b): j l The subject allegations state that leve.1 I inspectors who are not properly qualified to provide OJT instruction are training other Level I inspectors, and that Level II inspectors sign-off for training conducted ' by Level I inspectors. The implied significance of this allegation is that inadequate training of new inspectors will result, and that these personnel will not be able to provide adequate inspection of coating work. l 1 i
.__n -..-,-n---.. -- - - - - - --- .. _ - , - - - - - . . . ~ -
l j I The TRT reviewed the OJT records for six inspectors certified prior to October 1983, and the files of ten inspectors certified since that date. This review identified thirty individuals who conducted 0JT. !ThETR3
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nd two instances of Level I' inspectors not yet_ certified to conduct * ]
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OJT who sinned _DaI_ records-as-instructots dur,1ngj9[ Ihe TRT found nol (evidence tnat this deviation from requirements"was detected or identif 3 )
!as a nonccnformth p inTition.2 The TRT found no indication that OJT has been conducted by individuals other than those who have signed the OJT recstd form, or that formal training has been conducted by individuals other than those documented on '
available recor.ds. 1 The TRT has discussed above that lead inspectors and QC Supervisors verify the completion of various training requirements, as indicated by I their signatures on the inspector's Protective Coatings Technical Training Outline. The TRT considers these allegations substantia theTRT'sassessmentis discussed during above sections covering OJT instructors and lead inspectors. QUALIFICATIONOFPAINTERS(AQO-35): The subject allegation states that the abilities of coating application personnel are inadequate. The allegation states that there are problems i _- - . ~ _ -
24 with workmanship, quality of work, and the indoctrination and qualification of painters. The allegation cites as an instance that the documentation of painter qualifications and in-process work do-not-consistently satisfy requirements. The implied safety significance of *
.s ,.
this allegation is that painters might produce defective work which might i i go undetected during inspection. - , sdow t This. allegation does not =:: it. tifidh areas for which the documentation of in-process work is deficient. The TRT has addressed general and specific concerns about work and inspection procedures and the adequacy of coating work documentation elsewhere in this SSER and in SSER.'s.. Coatings 1, 2, 3, 4, 5, and 6. l The TRT examined the requirements, methods, and practices employed to qualify painters to apply coatings. The TRT reviewed the requirements of applicableBrown& Root (B&R) procedures,examinedpaintercertification files, and interviewed painters and supervisory personnel. l ANSI N101.4-1972 requires that " application personnel shall be qualified in accordance with the coating applicator's qualification procedures." , , c ! The TRT found that B&R procedure (CP-30, " Coating Steel Substrates Inside Reactor Building & Radiation Areas," CCP-30A, " Coating Steel Substrates Inside Reactor Buildir:g & Radiation Areas," and CCP-40 " Protective Coating of Concrete Surfaces" have provided qualification methods in each revision. The painter certification form c.orresponds to the form recommended by ANSI N101.4-1972. l
The TRT interviewed two painter foremen and four journeymen painters.
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The TRT verified that the qualification files of these painters correspond to the information given by a current painter qualification summary listing distributed for use in the field. During the interviews,
.Is the TRT asked questions to establish the character and extent of the i training given to journeymen. The TRT found that training cited by certifications was given as stated. The TRT found that these journeymen exhibited an a,dequate knowledge of work requirements.
During a review of logs since 1982, the TRT noted only one NCR resulting from application by an unqualified journeyman, NCR #C-83-00310 (Revision' 1,1/31/83.) The TRT interviewed one painting supervisor who has overseen painter demonstration applications and conducted the formal training session given to. painters. The TRT asked questions to establish the nature and character of training and qualification practices since 1980, and found n.o discrepancies with the statements of painters. This supervisor delivered to the TRT copies of the lesson plans presently used for classroom training, and copies of an examination given to painters upon conclusion of the training session. The TRT reviewed the lesson plans and compared the information contained in the lesson plans
- against project requirements. The TRT found that, in general, the lesson
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plans contain adequate, useful, and accurate information that is of substantial value in a well-conducted training session. The TRT found certain subjects inaccurately, incompletely, or not addressed by the lesson plans. Specifically:
.ss Inspection-hold points are not adequately described. The lesson plans do not define " hold point," or include sufficient detail to clearly identify that there are certain inspection verifications required immediately prior to coating application.
Good application techniques are not fully covered by the lesson
. plans. There is no evidence of a review of the proper use of spray equipment, such as adjustment of the equipment, techniques to minimize spray application errors, and techniques to spray apply coatings to complex shapes. Thare is no evidence of discussion of good brushing techniques or the treatment of brushing to accommodate
~
the characteristics of certain materials. (The TRT noted th.at painters must complete a practical test prior to certification.)
- There is no evidence of training (or testing) in the proper and accurate use of the instrument's regularly used by painters to check the accuracy of their work, such as dry film and wet film thickness gauges.
-m
I d6-- - The TRT found that examinations accurately reflect project requirements, are consistently used, accurately graded, and regularly updated to reflect new requirements. The TRT noted that more complex examinations have been given to certain foremen.
- The TRT randomly selected the names of six journeymen identified as certified applicators by inspection records between 1979 and 1984. The TRT verified that each journeyman was certified for the specified application on the dates shown by inspection records.
(r - The TRT reviewed the certification files of fourteen painters, including the six interviewed journeymen. The TRT found that, in some instances, painter certification documentation contains statements of misleading or incomplete information which is cited by certifications as a qualification basis. The TRT is concerned that such statements might be used as a basis to assign painters to work beyond their true level of capabilities. For example, some certifications state that, " employee has previous experience as a painter," without identifying.the nature or extent of the stated experience. The TRT found that the previous experience of certain journeymen does not include full-time professional experience or experience applying the generic coating types used at CPSES or previous experience with related nuclear, industrial, commercial, or architectural coatings. _ _ , _m - - _ ,
2 Further, most certifications state that the employee has " experience with the following product types: zines, phenolines, epoxies, latexes, enamels, and thinners," and do not describe the type of experi~ence. The TRT found that such experience is stated when painters have not had experience with these generic coatings prior to their hiring at CPSES, and the cited experience consists of providing support to and observing certified applicators at CPSES. l The TRT found that, with the exception of the deficiencies noted above, the CPSES system of qualifying applicators is effective and in accordance with requirements and the general practices used for nuclear coating work.
- 5. Conclusions and Staff Positions:
The TRT examined important features of the systems used at CPSES to qualify coatings inspection personnel and painters, and the merits of specific allegations involving qualification systems. ' The TRT has concluded that AQ0-22 is partially substantiated, and that personnel have performed Backfit Program adhesion testing without first receiving all of the appropriate training in the methods and requirements of performing this inspection. The TRT has further concluded that this deficiency tends to cause data errors in a conservative direction, and so I should not have a significant adverse impact upon Backfit program data.
The TRT has concluded that allegation #AQO-32 is unsubstantiated. The TRT has concluded that allegation #AQO-33 is substantiated ~, but was not able to assess the significance of this deficiency. The TRT has concluded that allegations #AQ0-61(a) and #AQO-61(b) are substantiated. The TRT has concluded that the CPSES coatings quality control program lacks sufficient controls to assure the capability of instructors or the accurate assessment of capability demonstrated during training. The TRT has concluded that allegation #AQ0-35 was partially substantiated by the evidence examined, however the TRT considers the specific deficiencies noted to be without significance to completed work. Requirements for the correction of deficiencies are given below.
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f i The71(T's evaluation of the general features of CPSES' coati 6ps~in~spe~ction
/ personnel qualification systems has concluded that, as implemented, the I
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system lacks controls sufficient to assure the required capability of l 1 (- personnel performing functions ascribed to Leyel I, Level II, and Level -l
,III personnel by_ ANSI _ N45.2.6-1978.----
,J e _
The TRT's evaluation of the general features of the CPSES painter qualification system has concluded that, with the exception of specific noted deficiencies, the system is adequate to satisfy all requirements.
. r l
- 6. Actions Required:
The TRT reviewed the requirements for the training and qualification of protective coatings application personnel (painters) and inspection personnel, interviewed randomly selected personnel, and examined records of personnel training and certification. . A. , The TRT found that records of inspector qualification do not provide evidence adequate to establish or demonstrate the capability of inspection personnel. Specifically:
. Inspector certifications may cite inappropriate previous experience as a qualification basis. Also, in some cases, this experience is used as a basis to reduce training requirements.
Many inspector files do iot adequately document education and previous experience used as a basis for qualification. ~ y OJT records do not demonstrate that each inspector has read and understood important instructions referenced by governing documents.
- Inspector files do not demonstrate that each inspector has read and ,
j understood important instructions referenced by governing documents.
- OTT r(cords da w1de mon,Trake OaD 6e e aes u e m t r A c A a n ot c h c.c d m % <._ p t maw _ e.
- u. docuw d dscu oba.z ar s A im peb d m39,c b
1 l Written examinations for Level I and Level II inspectors are not adequate to demonstrate the individuals' comprehension of important I generic and specific requirements, or to demonstrate the~ individual's capability to perform the functions described by ANSI'
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N45.2.6-1978 and TUGC0 precedure CP-QP-2.1. Further, the prepared answer keys (used to grade examinations) do not provide the actual basis by which all examinations are graded. Examinations with written and practical (e.g., " hands-cn") tests are graded so that an inspector may give incorrect responses to as much as 40% of the written test and still achieve the minimum 80% passing grade for the combined written and practical examination. 7
?
- All qualification examinakions do not include practical tests for each important operation. '
i Color vision requirements have been improperly waived. Supplemental training to maintain the proficiency of inspectors is not consistently implemented and documented in appropriate files. For example, there is not adequate evidence of instruction given for important revisions to governing documents. Level I inspector recertifications and certifications of OJT instructors are not based upon adequate evaluations of the l
s
. individuals' capability to perform the certified function (e.g.,
inspection or instruction), and cxaminations did not take place as indicated by the certification /recertification forms.- -
.i -
Accordingly, TUEC shall review the training, qualification, certification and recertification files of each presently employed
. coatings inspector against project requirements and provide information in such a form as to demonstrate that each requirement is shown to have been satisfied or exceptions justified. This review shall be adequate to establish that each file provides documented objective evidence of each inspector's capability to identify and implement each generic and specific function described for the individual's stated level of capability. Information provided to establish each conclusion of the review shall be traceable to specific records. The review shall assess each deficiency identified above or detected during the review.
B. The TRT found that all inspectors have not been adequately notified of their certification status, and have performed prescribed activities prior to certification. Accordingly, measures shall be established to promptly notify l inspectors of each initial certification, OJT instructor certification, recertification, or other change in certification l status. l
C. The TRT found that the files of some individuals, who were certified as Level III personnel and assigned to positions of responsible Q.C. supervision, do not demonstrate the required capability. ' Specifically, the qualification files of these individuals lack
.t-documentation of suitable previous experience with the generic coating systems used at CPSES, lack documentation of study of all current requirements, and lack other evidence which might support
,their capability to conduct the evaluations and technical assessments which they perform.
TuliCS M \fedtCM Accordingly,Athe files of each presently employed individual and certified to Level III capability for protective coatings 4shall -be ytowde re'/:er i and information 0h:11 Lo gio,;ded in such a form as to demonst. rate that each individual has, at the time of certification, completed a documented study of the current applicable project requirements and that the individual has suitable training or experience to demonstrate knowledge of the technical characteristics of the coatings, coatings application, and coating inspection l l trocessas used by CPSES. l D. The TRT found that the lesson plan for the formal training given to painters prior to certification contains inaccurate or incomplete information on important subjects. Specific examples are: l
- Inspection hold points are not adequately described (e.g., hold point definition, hold point prior to application.)
- Good application techniques are not fully covered by the lesson
.1~
plans (i.e., adjustment of spray equipment, treatment of complex spray applications such as corners and radii,. prevention of spray application errors such as arcing of the gun.).
~
- Training is not evidenced for the instruments regularly used by painters to check their work (e.g., wet film and dry film thickness gauges).
Accordingly, TUEC shall review and update the painters' training lasson plans to correct the deficiencies noted above, and any other deficiencies identified by TUEC. E. The TRT found that painter certification documentation contains instances of misleading or incomplete information, cited as a qualification basis, which may result in painters being assigned to work beyond their true level of capability. Specifically:
- Many certifications state that, " employee has previous experience as a painter," without identifying the nature (i.e., previous experience as an applicator or helper for nuclear, industrial,
commercial, or a.chitectural coatings) or extent (e.g., period of i full-time professional work) of the stated experience. I ! - Many certifications state that the employee has " experience with the
. ~.~
following product types: zines, phenolines, epoxies, latexes, ' enamels, and thinners," and do not qualify the type of experience.
'. Such experience is cited when painters do not have previous
, experience in the ap,elication of these generic coatings, and the cited experience consists of providing support to and observing certified applicators at CPSES.
Accordingly, TUEC shall provide explicit statements of the painter's verified or claimed experience with present and future certification documentation. Statements of previous experience shall distinguish { application experience from other related experience, shall identify the extent of. the citedexperience, and shall distinguish between experience . gained at CPSES and other nuclear or commercial / industrial work. l
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- 8. Attachments: None. i
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l 9.
References:
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- 1. 10 CFR Part'50, Appendix B, " Quality Assurance Criteria for Nuclear j Power Plants and Fuel Processing Plants" i
j 2. Comanche Peak Final Safety Analysis Report ! 3. Regulatory Guide 1.54, June 1973, " Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants"
- 4. ANSI N101.4-1972, " Quality Assurance for Protective Coatings Applied
) l to Nuclear Facilities"
- 5. Regulatory Guide 1.58, Revision 1, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel"
- 6. ANSI N45.2.6-1978, " Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants"
- 7. TUGC0 Procedure CP-QP-2.1, Revision 0 through 16, "Trainihg of Inspection Personnel"
. i-
- 8. TUGC0 Procedure CP-QP-2.3, Revision 4, " Documentation Within QA/QC Personnel-Qualification File"
'9. TUGC0 Procedure QI-QP-2,1.4, Revision 6, " Qualification of Protective Coating I.nspection Personnel" -
- 10. TUGC0 Procedure QI-QP-11.4-23, Revision 13, " Reinspection of Seal Coated and Finish Coated Steel Substrates for which Documentation is Missing or Discrepant" .
- 11. TUGC0 Procedure QI-QP-11.4-24, Revision 6, " Reinspection of Protective Coatings on Concrete Substrates for which Documentation is Missing or Discrepant"
- 12. TUGC0 Procedure QI-QP-11.4-29. Revision 1, "Use of Elcometer Adhesion Tester for Isolating Areas of Questionable Coating Adhesion"
- 13. TUGC0 CPSES NCR #C-83-00852, Revision 0, dated 3/23/83.
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,n<,,. n. iL L "Jp SSER WRITEUP DOCUMENT CONTROL / ROUTE SHEET N Sc .,
Alle:ation Numbers kC -E 1A '. /. ~_ ' * . 0 ' . _ _ ? 11 Subject of Allegation *e., c .' ,
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TRT Group F'm h i,c. 6 ~-2
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T- < e.- u. Author: (_ G . T- u o < - O ~ l l This sheet will be initiaied by each reviewer. It stays with all ~r evisions to the SSER writeup and serves as a routing and review record. It will be filed in the work package when the writeup is published. Draft Number Draft 1 2 3 4 5 g q.to -m Author A E k, Group Leader MM 6%/c,. 4 Tech. Editor / u/ E r)/'/ / Wessman/Vietti I J. Gaaliardo T. Icoolito _ Revision Number ._ - .- 1 Final [ 1 2 3 4 5 . Author Tech. Ecitor ._ f. .i - Grouc Leader - J. Gaaliardo T. Icoolito l Administrative Writeup integrated into SSER Potential Violations to Region IV Workpackage File Complete Workpackage Returned to Group Leader
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?gA-85-59 l a as 1
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bccument Name: AQO-3, II, ETC. . Requester's ID: PAT , Author's Name: Chet Posiusny Document Comments: , 10/31/84 Draft 1l space . I A O i 1 O e e
1 - 9/20/84
- ..-3, -11, etc./CP4 SSER
- 1. Allecation Group: Protective Coatings No. Sc, Design Change Authorization (DCA) ,
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- 2. Allecation Number: AQO-11, -24, -26, -27,i -28,!-29, -30,/-31 .
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- 3. Characterization: It is alleged that:
(1) A design change authorization (DCA) allows primer coat of 0.5 mils without design basis accident (DBA) qualification, G/UL (2) Protective coatings e4 placed over rusty, scaly unprepared metal is surfaces inside pipe supports, (3) DCAs are not controlled, (4) DCAs are originated by Engineering without QA/QC input, (5) DCAs are written instead of .
/
(6) DCAs are written to overcome problems, ; (7) DCAs are used to downgrade surface preparation and specification AS-31, and (8) Protective coatings are not removed when outside the acceptable range.
- 4. Assessment of Safety Sionificance: The implied safety significance of l these allegations is that improper use and processing of DCAs which allow l technically unjustified changes in coating requirements can result in inadequate qualification, application and inspection of protective coatings inside reactor containment buildings. An evaluation of the
~ ^
Protective Coating No. Sc safety significance of this concern is reported in (later). The Technical Review Team (TRT) evaluation of the quality assurance (QA) aspects of the allegations related to coating design change authorizations (DCA) follows. In assessing these allegations, the TRT reviewed the DCA system for coatings generically, as described in site procedure CP-EP-4.0 and 4.6, Design Control and Field Design Change Control; and discussed the DCA system with the TUEC Nuclear Engineering Group (Tll). The DCA system is complex. DCAs are generated when the need for immediate changes critical to construction arise. The changes are authorized by specified engineering personnel following a two-stage process. In the first stage, an authorized person reviews and approves a DCA onsite. (This authorized person may or may not be a Gibbs & Hill (G&H) engineer.) In the second stage, the G&H Architect Engineer performs a final review and approval. At this stage the DCA programs are in compliance with ANSI N45.2.11. The TUEC Design Change Tracking Group (DCTG) tracks and logs all DCAs. Proce-dure CP-EP-4.7, Rev. 10, describes the responsibilities of DCTG. The TRT found that the DCA system described in the site procedures complies with ANSI N45.2.11-1974, Section 4. " Design Process." However, the TRT observed failures to fully implement the procedural system in changes to protective coating requirements which affected DBA qualification of coatings. For further details of these problems refer to the DBA Qualification Tests, SSER writeup for Coatings Group No. 2.
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Evaluation of the DCA system for areas other than coatings is discussed in the SSER writeup for QA/QC Group No. 2. (1) DCA Allows prinier Coat of 0.5 Mils Without DBA Qualification (AQO-11) The allegation is that DCA No. 18, 489, Revision 1, allows a primer thickness of 0.5 mils. 'The alleger is questioning whether this thickness of primer has been DBA qualified in accordance with ANSI 101.2-1972.
Protective Coating No. Sc TRT review of OCA 18, 489 Revisions 0 and 1, indicates that TUEC is aware that this thickness has not been DBA qualified and has listed these unacceptable areas on the exempt log (Items 8-18). (2) Protective Coatinos Placed Over Rusty. Scaly Unpreoared Metal
- Surfaces (A00-24)
The allegation is that Q coatings (that is, coatings in safety-related areas) have been placed over rusty, scaly unprepared metal surfaces inside pipe supports made of tube steel without end-caps. In these cases, the protective coating gets on the rust inside of the tube. The concern is that this coating ratorial could later crack, scale, come off the pipe, and then travel to the sumps. TRT walked through the Unit I containment building and observed that the , structuraltubegt3elsupportshaveprotectivecoatingsplacedapproxi-mat M to 3 h inside the tubing. Most of the areas appear to be coated X ss - with a fine mist, apparently from overspray inside the steel tube. The areas in question.are very small and in many cases there is no coating inside the tube steel. It was obvious to the TRT that these areas would be very difficult to cJean and prepare for coating. Moreover, there is no . regulatory requirement, nor TUEC procedural requiremen tha+ end-caps be placed on tube steel. ' The TRT verified that TUEC entered 6,000 sq. feet of surface inte the , coating th::e 't::? cxempt log, which the TRT believes is a conse.<ative estimate. This amount is only 1% of the total coated surface. (3) DCAsNotControlled[AQO-26) A x. . The allegation is that DCA documents are not controlled. A TRT review of - this allegation indicates that procedures CP-EP-4.6, CP-EP-4.7 and DCP-3 control field design changes, such as DCAs. Comanche Peak Project Engineering (CPPE) initiates the DCA through procedure CP-EP-4.6. The original copy is sent to the Automated Records Manageme,t System (ARMS), '
Protective Coating No. 5c which is a part of the Document Centrol Center (DCC). DCC receives these DCAs. logs them and issues centrol nu ,ers to these documents. Controlled DCAs for coatings were issued from document satellite stations in the field. These stations assured that craft personnel maintaine'd current revisions to all design changes. Prior to April 1984, the TUEC coatin'gs QA/QC group had a control box at DCC in which all DCAs affecting coatings
.{ g I were placed. These were controlled copies.
.}A . _%
/
', f , p h (4) DCAs Originated by Enoineering: QA/0C Has No Input (A00-27)
.~'./ {
s,/. The allegation is that DCAs at CPSES are originated and totally approved by Engineering and that QA/00 has no input in the review and disposition of DCAs. TRT document rev ews and discussions with QA/QC personnel of this allega-
- tion indicate that prior to current procedural revisions and unwritten practices (such as CA/QC group meetings), QC inspectors did not receive all DCAs- Although the QA distribution list for DCAs has always existed, the TRT learned in discussions with QA personnel that someone in QA decided whether or not the QC inspectors needed to receive a specific DCA. QA personnel tol2 the TRT that if a DCA did not affect the procedures or
' quality, then QC inspectors many times would not receive it For example, the TF.T was told that many of these DCAs concerned the placing of coatings ;
in if: accessible areas on the coatingsv="em(c
-H: log. An examination of /
these DCAs by TRT indicated the same. If CCAs which relax coating requirements are not distributed to QC inspectors, their inspections could be in the conservative direction. The TRT found that none of the DCAs they examined made inspection requirements more stringent. TRT review of the present program indicates that QA/QC has no procedural requirements for input in the review of DCAs generated by Engineering. QA/QC, however, is on the distribution list for DCAs. Coating QA Engineers (QE) receive all DCAs related to coatings. Observa-tion and discussions by TRT with Quality Engineering, Engineering and QC , indicate $ that all disciplines are awara of a DCA before it reaches the e e
'i ,
l l l
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_s - ; 1 l i to these docueents. Controlled DCAs for coatings were i nued from wwd .
,O e These stations assured that
^satcIlite 'stetidns in the fie)tl. /
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at 1 l personneI' mainta ned curreit revisio\ to cl1 de ign hanges/, Pript
/
/ i o April 1984, ch' TUEC .c'oatings QA/Q group d a een rol 'ox at DCC i challDCAsaffe[ ting coatin s were placed. These were controlled copies.
TheTRTdiscussionwithacertified[11eAlerkforthecoatings QA/QC group ndicates that the clerk collected all DCAs frem the coatings
.$ control box at DCC and attached them to the coatings specifications in
# } the field. The clerk was also responsible for making the QC
.- I he Efss rs l supervisor aware of the DCA, Th QC rup::;i::: was Aresponsible for N,N / informing QC inspectors. Procedure DCP-3 describes the document control a tivities at CPSES. Comanche Peak Project Engineering (CPPE)
. 3 -04.
, forward' information copies to various disciplines designated on a
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standard distribution list suchy as Quality Engineering and Civil 5 A Engineering. These copies asa not controlled, but they see not used forconstructionandinspection.YThe TRT concluded,that S procedurallyj
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DCAs%erecontrolledlat CPSES). DCAs origNaked by EngineeW; QA/QC Has No I 93-
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y y']
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by engineeridg/ - yMT^C27ob;;[--thitDCA O' - at C QA/QC has no put in the review and disposition o C. A
\ DCAs.
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2 Protective Coating q. Sc place or activity affected. TRT review also indicates that it is an unwritter policy that Engineering frequently discuss proposed DC's with Quality Engineering before they.are issued. QE then indicates their con-
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cerns resulting from the review with Engineering for resolutions. TRT finds no regulatory requirement that Quality Assurance must review or , approve design changes. Criterion III, Ap'pendix B, of 10 CFR 50 does l require design changes to be reviewed by the original design l organization. - l TRT concludes that the present method for controlling DCAs at CPSES vio-lates no procedure, nor is there a requirement that commits TUEC to have
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QA/QE provide input to DCAs. The present system appears to be working in that QA/QC personnel do contribute to most decisions made con:erning DCAs. (5) DCAs Are Written Instead of NCRs (AQO-28)
~* l This allegation is that DCAs are used " frequently and conveniently" to coverupaconditionforwhichanonconformancereport(NRC) shou)dbe !
wri tten. The alleger estimated that 40*. of the DCAs were for l/ l conditions. TRT randomly sampled 70 DCAs attached to specification AS-31. The majority. of the DCAs reviewed by the TRT were originated for clarification purposes or for conditions in inaccessible areas. Five of the 70 DCAs reviewed appeared to indicate an NCR condition. NCRs are supposed to be originated when a deficiency renders the quality of an item unacceptable or indeter-minate. It is the TRT opinion that these five DCAs were indeterminate and should have been addressed in NCRs. AQO-11 discussed earlier is an example of this condition. The time span between these DCAs indicated that they were not frequently used for NCR conditions. Thus, it appears that these i were isolated.
Protective Coating No. 5c TRT review of the five DCAs description and resolutions indicates no technical concern with regard to the quality of the coating; however, , I they are examples of'al' legation discussed above. ,
, The TRT finds that DCAs were used as a tool to resolve problems in a timely fashion when they aros,e and that a few DCAs were written for conditions that should have required an NCR. However, the TRT did not find that DCAs. .
[ wereused"frequentlyandconveniently"tocoverupproblemsorthatk0kof the DCAs written were for NCR conditions. (6) DCAs Are Written to Overcome Problems (AQO-29) The allegation is that DCAs were written to overcome a problem which would take considerable time to repair. In other words, DCAs were used to facilitate the completion of a job even though it meant that QA/QC accepted site procedures would not be followed. TRT review of this allegation indicates that DCAs were generated when changes critical to construction arose. An example would be DCA 16, 106, Rev. 1. (Refer to Allegation AQO-24 in this writeup.) TRT notes that it is acceptable industry practice to modify specification requirements if they cannot be satisfied for one reason or another, provided that basic design criteria are met and safety is not impaired. In this case, the TRT finds that the DCAs generated did not involve conditions where safety would be impaired. (7) Downgrading of Surface Preparation (AQO-30 and 31) 1 Allegation AQO-30 is that on numerous occasions DCAs were issued to down-grade the surface preparation from an SP-10 to an SP-6 standard prepara-tion; DCAs were written to downgrade specification AS-31 requirements in containment to AS-30, which is the non-safety specification. AQ0-31 alleged that QC management interpreted an SP-6 on a DCA to mean "do the l l l l i
l - prete::ive Coating No. Sc
- best you can"; when difficult access areas were involved, QC management allegedly stated to QC ins;:ectors, "if you cannot get to an area do not worry about it."
The TRT review of DCAs for allegation AQO-30 indicates that from time to time Engineering did change or downgrade surface preparation from SP-10 to SP-6. Virtually all the DCAs reviewed applied to inaccessible areas. Allegation AQO-31 in similar.to QAO-30. Review of this allegation by TRT and discussions with QA/QE personnel did not substantiate that QC manage-ment stated to QC inspectors, "if you cannot get to an area do not worry about it." QC inspectors did have questions about DCA 13, 140 Revision 1 involving what areas were considered to be inaccessible and what should be QC inspected. DCA 13,140 Ravision 2 clarified this issue by including definitive criteria for determining whether an area was to be considered inaccessible. I E M. 3 The TRT finds that for allegations AQO-30 and -31, that use of a best-A effort, use-as-is, and downgrading of specification requirements for inaccessible areas, are accepted industry practice. TRT review of the exempt log indicated that virtually all the inaccessible areas documented by DCAs were piaced on the exempt log. Based on exempt log estimates, the total area downgraded is not over 3 percent of the total coated surface.
- 5. Conclusion and Staff Positions: TRT conclusion is that all of the allegations reviewed were substantiated, except for AQO-26. However, the allegations have neither safety significance nor generic implications.
- 6. Actions Required: None.
f' (
- 8. Attachments: None. 1
-S- Protective Coating No. Sc
- 9. Reference Documents:
- 1. Exempt log. .
- 2. DCA #17,142, Rev. 3.
- 3. DCA #18,489, Rev. O and 1.
- 4. CP-EP-4.6, Rev. 7 and 10, " Field Design Change. Control ."
- 5. CP-EP-4.7, Rev. I and 2, " Control of Engineering / Design Review of Field Design Changes."
- 6. CP-QP-6.0, Rev. 9, " Preparation of Quality Procedures and Instruction."
- 7. CP-QP-3.0, Rev. 15, "CPSES Site QA/QC Drganization."
- 8. DCP-3, Rev. 14, 15 and 18, "CPSES Document Control Program."
- 9. DCA #7973, Rev. 1.
- 10. DCA #8232, Rev. 1.
- 11. DCA #11,016, Rev. 1.
- 12. DCA #18,489, Rev. 1.
- 13. Specification AS-31.
- 14. QI-QP-11.4-10, Rev. 4.
- 15. DCA #19,986.
- 16. DCA #16,106, Rev. 1. .
- 17. DCA #13,140, Rev. O and 1.
- 18. DCA #12,145, Rev. 3.
- 19. DCA #12,132.
- 20. DCA #13,156,
- 21. DCA #12,027.
- 22. DCA #11,868. -
- 23. DCA #12,518.
- 24. DCA #19,943, Rev. 1.
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. 1 s
I Protective Coating No. Sc l
- 10. This statement prepared by:
New- , Date
'C , C , /f. . .- _l-4
,.., , . .u $ ,
6 '. Reviewed by:
- Group Leader Date
- f. ) $ 15 I*.* $ ;
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2 Approved by:
- Project Director Date f
[.[' lyt /&/. N, 9 l l
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Before Administrativo Judges ! b" I
- l
- \.A 5
- Peter B. Bloch, Chairman -
f I !, Dr. Kenneth A. McCollom Dr. Walter H. Jordan
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In the Matter of Docket Nos. 50-445 50-446 i TEXAS UTILITIES ELECTRIC COMPANY, ET AL (Application for I l Operating License) (Comanche Peak Steam Electric Station, Urii t s 1 and 2) November , 1984 Staff Response to ASLB Memorandum of October 1, 1984 (Concerns About Start-up Quality Assurance) - The Board, in its October 1, 1984 Memorandum, e:< pressed serious concern about the adequacy of the Applicant's program for quality t i. 1 _ _ . -_ _ _ _ _ _ _ _ _ _ _
assurance during the startup testing activities and enumerated five specific concerns which it wi.shed the Staff to evaluate. These concerns arose in the companion proceeding (50-4452062 and 50-446-062) from pre-filed testimony and direct testimony delivered by two witnesses for the Applicants on September 21, ' l
. )
1984 concerning the credibility of Witness F. l The following evaluation of these concerns responds to the Board's 1 1 I request: l i 1 i Beard _Cenceto_111 For ease in evaluating this concern, the Staff,has separated it into 3 distinct portions as follows: Although Applicents are committed to implementing written start-up test procedures, their start-up test engineers and quality assurance technicians apparently have incorrectly interpreted the phrase " independent verification" in the test procedures. (See, e.g., Tr. 18,400) Staff _Evaluatige - ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions" defines VERFICATION as an act of confirming, substantiating and assuring that an activity or condition has been implemented in conformance with the specified requirements. This standard does not specifically define INDEPENDENT; however, for the , purpose of qualifying an indi~idual v involed in a quality ! assurance position, the generally. accepted definition is an-individual who has no direct responsibility for the performance, supervision, cost or scheduling of an activity and does not report to a management representative who has direct responsibility for any of those functions. The Applicants' Startup Administrative Procedure, CP-SAP-10, Revision 2, (issued on July 13, 1982), "Startup Program Ouality Assurance Plan Implementation", defines INDEPENDENT VERIFICATION as an act of confirming, substantiating and l assuring that an activity or condition has been impleme'nted in accordance with a specified requirement by an individual not assigned to the perf ormance of the activity or establishment of the condition. Independent verification and witness are synonymous. l l l l l
l . . l l Reviea of Tr. 18400-18403 indicates that the witness, lllk ggEEEE used a combination of methods to perf orm independent verification, i.e. verification by an independent person in l the control room as related to im by Witness F and Witness F's then signed for , signature on the test record. test pr'ocedure step being independent verification of tha I performed as stated (required by the test procedure) based upon the above, which he considered to be objective evidence. f ANSI N45.2.10-1973 defines OBJECTIVE EVIDENCE as any statement of fact, information, or record, either. quantitative or qual i tati ve, pertaining to the quality of an item or service based on observations, measurements, or test which can be , verified. i function in performing independent verification of ; hose proeddure steps was to establish gblectivg_gvidgncg that the test was perf ormed in accordance with the specified l requirements. Since the procedure steos had not yet been l verified, the test record should not have been used as l objective evidence. Additionally, since did not personally witness or ' communicate directly'With an independent person in the control room, but rather, relied solely on the word and signature of an individual directly involved in the activity, he should not have considered that as being independent.
- _ _ - - Therefore, it is the Staf f's conclusion that, atleast,h 333335 is in error concerning the correct interpretation of inde _ndent verification and also, possibly, what constitutes objective evidence.
- b. The quality assurance technicians merely verify that there are numbers -- any numbers -- on test data sheets and they do not review whether the numbers are properly calculated, are within the test criteria, or are calculated pursuant to an adequately defined test procedure. ( TR. 18301-04)
Staff _Evgigglige - The ANSI definition of VERIFICATION and the Applicants' definition of INDEPENDENT VERIFICATION, given in the Staff's evaluation of Board Concern (1) a. above, requires a determination that an activity or condition is in accordance with a specified requirement. "118 A review of preoperational test Volt AC Inverter Ferformance", 1CP-PT-02-02, Revision 0, Section 7 and specifically the instruction f ollowing step 7.1.22 and step 7.2.39 indicates that the quality assurance technici an was to verify independently that certain steps in Section 7 of the preoperational test were ggtigtegd by the St' art-up engineer. While some of these steps require recording certain values (numbers), the test procedure does not require the quality assurance technician to revi ew f or the proper application of cv ,s
*. i. . .~A .
9 4 /:.w.3 J h..L - . t formulns, for proper calculations or 3or meeting the' test acceptance criteria. That does not appear to have been the intent of the independent verification required of him in this case. It is also not general practice to perform calculations during the conduct of a- test. The acceptability of v' ,f' values obtained during the conduct of a test should sf be determined by comparing.the values obtained during the test Rh{t V C ,# to the previously estblished acceptance criteria. That gf(Jfunctionishistoricallytheresponsibilityofthetest (whichvalues, engineer outside and is carried
.of the' out toand/or acceptable avoid expected proceeding with a test i range,
' are being encountered. This ~would ultimately result in a f ailed test and could cause equipment damage. The Applicant's Startup
. ) ,. ['(_h,
. Lt f 9, j Administrative Procedure CP-SAP-11, Revision 5, " Review, Approval and Retention of Test Results" and CP-SAP-21, Revision 2, " Conduct
A h j '4(fbngineer Testing" assigns responsibility to the start-up test for review of test results.to ensure that the s
p . p[9 lacceptance criteria are met. Based upon the foregoing, the staff concludes that the quality assurance technician carried out his assigned task correctly I and in accordance with NRC requirements and industry practices. (\ ,
- c. Since there is no qua'lity control check of these same sheets, the only independent review conducted'is through occasional quality assurance audits, which do not appear to be a sufficient independnt review for the importance of many of the, test that are conducted. (TR. 18,301-04; 18,400-03, 18,406)
The Applicant's Startup Administrative Procedure, CP-SAP-11, Revision 5, " Review, Approval and Retention of' Test Results" requires, for pre-o$erational test' procedures upon completion, that copies of the test data package is distributed to the men.bers of the Ap32icant's Joint Test Group (JTG) for technical review and comments or approval. The Applicants' FSA,R, Chapter 14 and Startup Administrative Procedure, CP-96Pc2, Revision 5, "Startup Program Organization and Responsioilities" states that the function of the JTG is to assur's" effective coordination of engineering, construction and operations activities during the startup program in order to conduct and maintain a thorough, efficient and expeditious station startup This is to be accomplished by the review and approval of all preoperational test procedcures, procedure revisions and test results by appropriate members and the allocation of sufficient project resources in support of startup program activities. Memberthip in the JTG included, as a minimum, the Manager, Nuclear Operations; the Lead Startup Engineer; the Manager, Plant Operations; the Nuc1' ear Engineering Manager, the Westinghouse Site Manager (f or test M4cciated with
- w. _
+
3
components / systems supplied by Westinghouse) and the Manager, CPSES Startup. In addition to the above,' representat'ives from other ' l organizations will participate when requested by the JTG l chairman. l It is apparent from the above that the Applicants have charged ,
, -T' the JTG with the responsibillity for the technical review and
/#"-' ' ultimate approval of the pre-operational test data packages,
,, ( While there is not an independent quali ty_c.on,tr_ol . check of . the l d, ' , 5 '- data recorded during tee test, the JTG utili:es this recorded f
b' . U dit'a r6 it's"rMvfew process to~ ensure that structures, systems Tg, efand components perform as designed. . i
'ste" f
'fJ / The staff concludes, therefore, that it is not inappropriate f or the Applicants not to provide an independent quality l control check of preoperational test data sheets provided that a comprehensive review, by technically competent and responsible personnel is performed.
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Esat d_cenc=ce_12) o The 8aard's concern that the applic, ant fails to, document important deficiencies and to f ollowuf in an appropriate f ashion appears to be b aupported onlyAWitness F's original supervisor's actions (or lack thereof) on November 17, 1982. At th<f point in time, when the t supervisor became aware that there was a test deficiency and an STE's violation of procedures (f alsification), the suggtvisgt himself violated CP-SAP-16, " Test Deficiency and Nonconformance Reporting" by not writing a deficiency report (TDR). S*g The En, has not found any indications since that time that supervisors practice or condone the violation of procedures in the NN e::ecution of theirsupervisoryresponsibilities,gewever, the En1 did not see any overt, action on the part of licensee management to prevent such actions in the future since the second supervisor (Mr. London) became aware of the original problem. The khdi rnt considers there are adequate procedures and policies at CPSES to control the documenting of deficiencies, and therefore ik.t suggests 3the incident between Mr. Cheatham and Witness F is an isolated incident.--d -rt r-thy r e cer.re-- '-r- r p-r;-r---tir t e r.d p r i n t et thic tire; i 1 l l l
...~ . ..
EggCd _CgegeCo_fg1 The ASLB e:: pressed concern over the applicant's f ailure to document apparent design deficiencies in the Reactor Protection System j 1 inverter alarm circuits with the consequence that there may be , undetected generic deficiencies in the design of an alarm circuit that was supposed to detect overloads. The board considered this to r be egregious in light of already known generic problems with the RPS Inverter saturation transformers, which are related components. Staf noted The TW that as soon as it became evident, by conduct of the inverter retest ICP-PT-02-02 on June 26, 1984, that the alarm circuit f ailed to f unction as e::pected by the test, a Test Deficiency Report (TDR) was generated in accordance with Startup Administration Procedures CP-SAP-16 3 " Test Deficiency and Nonconformance Reporting." CP-SAP-16 requires a TDR to be initiated in the event a deficiency is found in the operating characteristics of a system or component being tested, as evidenced by its failure to meet the acceptance criteria of the test procedure. At this
~
point)the cause of the f ailure could be a test procedure error,. a component defect, a wiring error, or a design deficiency. In any , event,CP-SAP-16 requires the TUSI Engineering Manager to evaluate TDRs for corrective actions and to determine if the deficiency is potentially reportable under 10 CFR 50.55(e). Concern (3) Alludes to an apparent f ailure to f ollow site procedures
I3)cM'E! concerning the use of a Nonconformance Report (NCR) to report a
.Staf4 deficiency in a component. The Tr"t'T considers the applicant's use of TDRs in accordance with CP-SAP-16 to be propere, rrir-- i+<r rS . i , .;
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. o . l B9fC5!_G90EeCO_IS1 The Board has e:: pressed concern that written startup procedures appear to have been affected by oral and/or wri tten directive.s. , Thebb W has deter, mined that in the case of the specifics mentioned in the ';freeceAC;..x. _ . - M _ac,r. hcId on September 21, 1984, the dire ctives were issued to better manage the application of the af f ected procedures rather than to circumvent or change them. The oral directive was simply issued to instruct the people in the electrical startup group to manage the outages of systems and equipment by identifying all related pending work items before authorizing the outages. The M-r has no way of determining the status of Witness F's efforts to identify the work items when he refused to sign a Startup Work Authorization, but it appears that he was f ollowing the instructions of his supervisor. The written directive was a brief memorandum issued by the Startup Maneger to enable him to personally supervise the initiaticn of NCRs by his people. This was done to ensure that the procedure was being properly fo11 cowed, because he was concerned that some of his people might be errone.ously writing NCRs against issues that clearly chould be addressed on TDRs, as CP-SAP-16 requires. Scq ca-vx . T Uo so re NC~ .Mid e l er . ~ * - .
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(f)G4: 4 / During the courJe of a recent TRT investigation of an allegation that Frerequisite Tests were being signed off by electrical j 1 technicians instead of System Test Engineers as required by /&w * /,@ procedure CP-SAP-21, " Conduct of Testing," a startup memorandum
* \
(SIM-83084) was found that improperly authorized signoffs by the el ectri cal technicians. The applicant has since recinded the . memorandum and in the " Program Plan and Issue - Specific Action Plans" dated October 8, 1984, the applicant has committed to review ci,1 startup interoffice memoranda to determine if any other i directives have been issued which conflict with requirements of the current revision of the Startup Administrative Procedures. Therefore, the Shff ifr considers the issue of management directiV6s and their impact on approved procedures to be a resolved issue, pending the results of the applicants review above. s e l m.,v.u,--b4[.2 - z hu,./ u bk p W jn,cx ; e m. ,;. v i' ? , ,
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t Eoat d_G90cetO-.!Ed. The ASLB called STE qualifications into question on the basis that two STEs failed to detect defective test procedures during the first
~
administration of those procedures in a test situation. SI. The
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noted that in the case of the RPS inverter overload alarm, the wiring diagram (and consequently the installation), not the test procedure, was defective. The test procedure was written to test the system in order to confirm that the system has been installed and functions in accordance with the design specifications. The STE 4kd: is not hold responsible to ensure a3 system is designed _ properly. He i s. responsible to ensure the test procedure will adequately show that the system operates as the design specifications require, and to be sensitive to in process design changes and 4 that the test procedure will reflect these changes. The test procedure in the above case indeed showed that the alarm , I circuit was not wired to perform as the design specifications require, which is the intent of preoperational testing. SO The TfW theref ore gdoes not consider it.appropiate to r211 f r.t o question STE qualification $on the basis of failure to penetrate system wiring diagrams to the level of detail necessary to discover i.s t. tot His responsibility ctg : A assurefg the p test wiring design errors. u v e , (- -r c. - n.d( i ~TG aSl . ,w .w~Y W. g, _ s n . ~d J. M, + sr %_ v:" 7,^ dw > b-6 h<ld; v c: ~s t ~ ~" b I N'il: '- 4 n dd c ,- n.. u.- d 3 J A & uM~ ,* ' x k p . a L .u >. n du u4Bhv .u. .
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procedure will confirm the system 922Catgs in cccordcnco wit!. design specifications. e e o e e G "b- ___..&__ ^ -- - __ .h}}