ML20205Q715
| ML20205Q715 | |
| Person / Time | |
|---|---|
| Issue date: | 11/01/1984 |
| From: | Matthews P NRC |
| To: | Oliu W NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20204J134 | List: |
| References | |
| FOIA-85-59 NUDOCS 8606030028 | |
| Download: ML20205Q715 (12) | |
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. l SSER WRITEUP DOCUMENT CONTR01./ ROUTE SHEET Allegation Numbers A Ca 7,i4 Subject of Allegation CoaN d % cc.-d o evn.t.e c W m--Ts ( N C.W 3\
TRT Group (i e .d', o o 4 iA4 ' Author: o G Luh se.1 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. . i i Draft Number Draft 1 2 3 4 5 st Author
//I'mluly i Group Leader /YUt / s hsh 4 Tech. Editor '
, Wessma n/Vietti i J. Gaoliardo
- T. Ippolito _
Revision Number ._ J . i Final 1 2 3 4 5 . Author _ l' Tech. Editor ._ ;; .h Group Leader - - J. Gaoliarco l T. Ipoolito Adninistrativt . 4 Writeup integrated into SSER Pote :tial Violations to Region IV Workpckage File Complete _ , Workptekage Returned to Group Leader ;
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Document Name: AQ0-7-14-NCRS Requestor's ID: DECEB01 Author's Name: , Chet Poslusny , Document Comments: e 9 l l i l
- 1. Allegation Group: ProtectiveCoatingsCategory(5b)-{NonConformance ReportsT (.NC.h
- 2. Allegation No.: AQO-7, -14
- 3. Characterization: It is alleged that:
o Disposition of NCR C 83-01975 which dispositions cracking and flak-ing of concrete coatings witl not remedy the probiem. (AQO-7) o After an NCR is written, anyone can sign off on it. (AQO-14a) j -
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o NCRs cannot be written, and that irs must be written Nuesefe'. . i (AQ0-14b) i o A past OC supervisor voided many NCRs. (AQ0-14c)
- 4. Assessment of Safety Significance: The implied safety concern of these
. allegations is that dispr;sition and appropriate engineering approval of
.l i coating NCRs are not adequately performed. An evaluation of the signifi-cance of this safety concern is reported in (later). The team evaluation' of the quality assurance aspects of the allegations related to protective coating NCRs as characterized above is discussed below.
2_ - To address the allegations concerning disposition and approval of NCRs for protective coatings, the TRT conducted a generic examination of TuEG theANCR system in this area. The TRT reviewed TUGC0 Procedure-
- CP-QF-16.0, "Nonconformances" which describes the system for identifying, resolving and closing out of nonconformdnces. Specifically, revisions 8 and 14 were selected since they bracket the time period of the allega-tions. Procedural definitionf of a nonconformance is a deficiency in characteristic, docunentation, or procedure which renders the quality of an item unacceptable or indeterminate. To audit implementation of the system, TRT reviewed approximately 30 completed NCRs. As discussed in the following writeup of NCRs the overall implementation of system is in compliance with TUGC0 procedural requiremeits. However, there are some discrepancies noted and discussed in the report below.
The TRT reviewed the NCRs for adequate disposition ard noted several NCRs that indicated insufficient documented engineering justification. Since
.Aes.3n basic, sc de#
theseNCRsmainlyinvolvdBA)qualificationofcoatingsorcoatingtrace-ability, they are assessed in Coatings SSER Categories 2 and 3. Also, QA/QC SSER Category 50 discusses the generic problem noted that the TUEC system does not specifically require, for significant conditions adverse to quality, the identification of the cause and corrective action to prevent re-occurrence. e
Further review of NCRs by TRT indicate that NCRs in protective coatings are not trended properly. The present Quality Trend Analysis Reports issued in accordance with TUGC0 procedure CP-QP-17.0 " Corrective Action" combine all coating NCRs with other civil engineering NCRs to determine - , a composite trend that is not representative or accurate for protective coatings. The proper method of trending would be to separate coatings NCRs from iYil ,fd y e < U ] N O D 5-Concrete Coatinc,s Cracking and Flaking: (AQO-7) , The allegation states that NCR # C83-01986 discusses the cracking and 5 flaking of concrete coatings systems (NUTEC'11,117,1201). The dis-position section of this NCR states " cracking of coatings is due to excessive stresses in the coating during drying and curing." The alle-gation is that repairing these cracks will not remedy the condition which caused the cracks. The alleger considers that the disposition is inadequate. 4 TRT review of NCR-C83-01986 and the manufacturer's (Imperial) application bulletin indicates that the disposition is adequate. Chemically converted organic coatings develop internal stresses due to shrinkage during the process cure which may cause cracking and peeling. This is not uncommon in concrete applications. Proper application prevents reoccurrence of this condition. TRT review of TUGC0 procedures Ql-QP-11.4-27 and CCP-40 l include requirements for assurance of proper application with emphasis on l
l l l control of film thickness. TRT walked through the Unit I containment and sverc e no visual signs of stress cracking wee observed. Ob:cr;M imo, ef these 3fyef,r 3 areas appear to be repaired. There is no safety concern to this issue. This instance is an example dociht.P of 6-mece generic review by TRT relat e to ti.e TUEC metnod of incorpo-tucme,JtTaas a cu%s rating coating vendorAapplication bulletins into siteApr ocedures. This , review is discussed in Coating SSER Category 4 - Procedures. f After an NCR is Written, Anyone can Sign Off On It. (AQ0-14a)
! The TRT reviewed TUGO procedure CP-QP-16.0 which indicates that NCRs are the primary means used to document nonconforming conditions that cannot
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be corrected by standard procedural repair ora ndeterminate,TRT review of CP-QP-16, revision 8 & 14 prior, during and after the allegation was made, indicates that NCRs are prepared, reviewed, dispositioned and signed by - authorized personnel. Both revisions of CP-QP-16.0 indicate the appro-priate authorized personnel to verify the witnessing and closure of an a s4 rni NCR. CP-QP-16.0 states that QC supervisors eetere work items are verified / witnessed by QC inspectors. QA/QC supervisors shall sign the ty*d t4 C.W s verification block. Further review off,P Q" 15.0 indicates that the alleger may be concerned about the signatures of typed copies. The original. handwritten copy of the NCR is signed and dated by th'e QC (te.a on\ d inspector. However, subsequent typed copies of NCRs/,e-J .cvi>q N uf 9su E runs $nci I
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A are not initialed and dated.by the reportirg-QO in;pe:w ';ckvi QC iaspect r'; iii Liais ,alivws dian3cs Lu be mode Lu cuc dcas. .piivn u-i
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a~ce-fc ming conditie.a noid van influcouc v. cc. edify th; dispc 44en u thout the inegou;.e- , s.,v ing about or agrestrT trthrdrongertertrip-Heud.ve.t 3
.t. ion . A TUGC0 procedure CP-QP-16.0, "Nonconformances" (1 3.2.7) requires necessary approvals for portions of NCRs that are affected by revisions.
Mh i e deficienuy nas g eiid rit- tmpHeations-to- other-const.ruction- di sci-n11nes. Tha kpi;;. tion, vi tl,i; finding is f,rther_-:;,;es. sed.-as-peet---- nf +he e >cr:li pceg, .. tic , c.-i:,, of MC"3 aod Uie resuits afe repur ied-
-truder QA/QL atx category ca, NLK5. .
TRT review of CP-QP-16.0 verifies that anyone cannot sign off on an NCR as stated in allegation AQ0-14a.cxcept f r thc di;;r ;;n:3 noted cic.c. NRCs Cannot be Written and Nonconformances Must be Reported on Inspection Reports (irs) "45 ,e ""h5Gsfae
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TUGC0 procedure CP-QP-16.0 provides for all site employees to report non-conforming items to their supervisors or to the TUGC0 site QA supervisor. There is no written procedure / instruction which prevents any emp Myee ., .,
) 3 ' w e GtsTu7er.
from identifying or writing NCRs. For assessment of irs writteng uneat', J refer to Coatings Category (Sa), Inspection Reports.
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It Is Alleged That a Past QC Supervisor Voided Many NRCs. (AQ0-14c) On September 10, 1984, the Coatings TRT Group Leader telephoned the alleger in the evening at his residence to cbtain further information on this allegation. The alleger was asked.if he ceant by the term
" voided" that an NCR was cancelled but remained 1n the record file or that it was destroyed and there was no lenger a record. He was not certain whether any of his NCRs were physically destroyed, but because
% the subscquent disposition of an NCR was not adequate in his opinion, he considered that his NCRs were, in effect.." voided." He also stated that he had prepared only few (unspecified) NCRs and thus was not alleging that "many" NCRs were voided. He'could only recall one ,
de70sr % rt specific NRC instance; namely, the one discussed in his ASLB ta ti w i dated July 13, 1984g Q A i s m e, e d M c , On September 11, 1984, TRT located in the site record vault NCR C 00060, Revisions 0 and 1. This NCR involves deposition of oil based soot from forced curing heaters on 16 electrical hangars and 51 hangar shims while their final coat was still " tacky." The NCR dispositioned the hangars for rework by wiping contaminated areas with solvent and, if necessary, lightly sanding until discoloration is removed. After repair, these areas were rechecked for film thickness. The shims were dispositioned to "use-as-is" because of the small amount of exposed mm em ee ~ o m n
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1 l O coated surface after placement of shims which would require rework after installation. l The alleger considered his NCR " voided" by allowing localized repair ' rather than sand blasting and entirely re-coating the hangars and shims, and contrary to site procedures and ANSI standards. The TRT considers the'dispositioned repair to be technically adequate and consistent with the site procedures referenced in the NCR and with ANSI standards.
- 5. Conclusion and Staff Positions:
TRTconclusionisthattheallegationsf C are not substantiated. The overall NCR system is in compliance with ~~~;10') Howeve r; Ncf spiem weawetes.ndd yAicja rdde g j jg procedgal n 3 u T t C.1 C reauirements. A],he{e WT ".M C.WM R*,'.
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- 1) TUEC shall revise their Quarterly Trend Analysis Reports issued in accordance with TUGC0 procedure CP-QP-17.0 to treat protective coating NCRs separately from other civil cngineering NCRs to pro-vide analyses that are more representative of protective coating trends.
TUEC shall take action as requested in QA/QC SSER Category SD, 2) NCRs, relative to T. $lI NRCs requiring for significant conditions adverse to quality, the identification of the cause and corrective action to prevent reoccurrence, e4-ft) QC in:gmw a aign4 p e-VThe %'
ar";'"g in fo. ..mic.. ;n-'ttypeettEP.s . Etne deficiencin W '
_3 generic implications to other construction activities.
- 8. Attachments: None
- 9. Reference Documents: .
(1) CP-QP-16.0, "Nonconformances," Revision 8 ( ,
) and 14 (7-2-84).
(2) NCR #C-83-01986. (3) QI-QP-11.4-27, Revision 6 (6-11-84). (4) CCP-40, " Protective Coating of Concrete Surfaces," Revision 7 (3-4-84). (5) TUGC0 Quarterly Trend Analysis Report,(6-4-84).
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(6) CP-QP-17.0, " Corrective Action," Revision 4 (4-27-84).. (7) NCR #C-82-00060. . (8) Telephone Interview with Alleger A ,31 by NRC CPSES Coatings Technical Review Team Group Leader, dated September 10, 1984. { }) AS L B De- yo'+M on ( 7 $ 9) ek b\\t ge f' b'3\
- 10. This statement prepared by:
Claude Johnson Date Reviewed by: . Group Leider Date Approved by: Project Director Date .
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