ML20214U367
| ML20214U367 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/18/1986 |
| From: | Gardner G, Murphy M, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214G966 | List:
|
| References | |
| 301.7-SQN, 301.7-SQN-R02, 301.7-SQN-R2, NUDOCS 8612090244 | |
| Download: ML20214U367 (11) | |
Text
TVA EMPLOYEE CONCERNS REPORT NUMBER: 301.07-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 2 TITLE: General Paint Concern Reactor Building REASON FOR REVISION:
Revised to incorporate SRP comments Revision 1
! Revised to incorporate SRP conuments and include SQN corrective l action response. Revision 2 l
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PREPARATION PREPARED BY:
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APPROVED BY:
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- SRP Secretary's signature denotes SRP concurrences are in files.
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..-t TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS .
CEG Subcategory: Mechanical Equipment Reliability and Design Element: General Paint Concern Reactor Building Report Number: 301.07-SQN Revision 2 II-85-087-001 Evaluator: ne$$fa;1er 11-% %
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Revision 2 I. GENERAL PAINT CONCERN REACTOR BUILDING This report evaluates a specific employee concern identified for Sequoyah Nuclear Plant (SQN), XX-85-087-001, regarding the integrity lEl and maintenance of containment paint coatings. This issue was I determined to be pctentially safety related by the Employee Concerns Tast Group (ECTG) Technical Assistance Staff.
II. SPECIFIC EVALUATION METHODOLOGY The employee concern identified to Quality Technology Company (QTC) for SQN is as follows:
XI-85-087-001 Sequoyah unit 1 & 2: Containment paint coatings (#295 and #305) are not properly maintained. The integrity of the coatings is being eroded and questionable. CI is concerned that the paint will curl and pop-up and clog the drains in case of a (LOCA) accident when the temperature and pressure builds up in the reactor. Paint specifications and standards are not followed, especially in recoating of 305. NUC Power concern. CI has no further information.
The ECTG files were reviewed and a Nuclear Safety Review Staff (NSRS) l report was found for the above concern. The report was reviewed for IR1 adequacy and a cognizant engineer in SQN QA was contacted for the I status of NSRS recommended corrective actions.
Revision 0 of this evaluation included IN-86-273-001 which was an l Identical issue identified for Watts Bar Nuclear Plant by the same l concerned individual. The IN-86-273-001 will be evaluated by the (R1 Construction Category Evaluation Group (CEG) in Subcategory CO 10300 l for issues related to the construction phase and will not be l addressed by the Operations CEG.
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Revision 2 III. FINDINGS The NSRS report for SQN (Reference 1) was reviewed and determined to adequately address Employee Concern XX-85-087-001. Therefore, this report endorses the findings and conclusions of the NSRS report.
The NSRS report found that concrete coatings were adhering well with I some exceptions where significant mechanical damage has occurred with l q ' water seepage causing some delamination in these areas. l 4
The report noted that, although some corrective maintenance has been I performed, a formalized program of periodic inspection and maintenance IR1 did not exist. Preventive maintenance routines were being developed I at that time, however.
NSRS inspections of the steel containment liner found areas of I phenolins 305 delsmination and areas where total film thickness was l exceeded.
The SQN plant response to the NSRS report (Reference 3) indicates that the NSRS recommendations were being implemented. The NSRS accepted the
. plant response (Referecce 4) along with the corrective actions being performed under Corrective Action Report SQ-CAR-86-01-001 (References 5 and 6).
The cognizant Q& engineer who prepared the CAR stated that his evaluation had occured about the same time as the MSRS investigation.
The QA survey had reached the same conclusions although he was unaware of the ongoing NSRS investigation at that time. He stated that the corrective actions specified by the plant in response to the CAR included resolving the NSRS recommendations and performing a baseline evaluation I and inspection to determine the present condition of all containment 111 coatings at SQN. He also stated that QA would require documented l b
verification for completion of all corrective actions prior to closure of J
the CAR.
The CAR as written is identified as " nonsignificant." The NQAM l defines a "significant condition adverse to quality" as "Those I which represent gross or widespread noncompliance with procedural l requirements which negate the effectiveness of quality assurance l controls imposed by this quality assurance manual; or any condition I which has recurred with such a frequency that it indicates past l
.. corrective action (if any) has been ineffective." Based on this IR1 j definition, the lack of an overall TVA program to ensure the quality I of CSSC protective coatings appears to be a significant condition l adverse to quality. The " nonsignificant" designation of the CAR by l
SQN QA does not appear justified based on the NQAM definition since l the CAR addressss the lack of an upper-tier program and not just a l SQN noncompliance with an existing procedure. I t
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. Revision 2 CONCLUSIONS
- The issue presented by Employee Concern XX-85-087-001 regarding i maintenance of coatings was validated by the NSRS report. The i report noted areas of delamination and mechanical damage, however, it was believed no impact on safety existed. The report l I
concluded that the need for maintenance was recognized by _ IE1 responsible personnel; however, a formalized program was not l yet complete, although it was in a development stage. The lack l
-of a formalized program.for ensuring the quality of protective l coatings appears to represent a significant breakdown in the QA 1 progets relative to the specific area investigated. l IV. PERCEIVED ROOT CAUSE The root cause specified by the SQN plant staff in response to "
i SQ-CAR-86-01-001 was the lack of a controlling upper tier document I for coating repales and maintenance. This report concurs with that l11 root cause and, based on the findings of the NSRS evaluation for SQN i and NQAM definition, considers it to be a significant condition adverse to quality. l I
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Revision 2 V. GENERIC APPLICABILITY i
Specific concerns on containment coatings exist for SQN and WBN and I evaluations have been conducted by NSRS and ECTG. Based on the I results of these evaluations and the root cause specified above, IRL the issue of coatings repair and maintenance is considered generically I applicable for BFN.
i The issue is not considered generically applicable to BLN because I limited coatings have been applied there and the plant is in a IR1 construction rather than maintenance / operation phase. I Page 4 of 8
Revision 2 VI. REFERENCES
- 1. NSRS Investigation Report I-85-812-SQN, " Containment Protective Coatings Repair," Employee Concern XX-85-087-001, January 26, 1986 2.
NSRS Investigation Report I-85-817-WBN, " Containment Coating Repair,"
Employee Concern IN-86-273-001, March 11, 1986
- 3. Memorandum from H. L. Abercrombie to K. W. Whitt on response to NSRS report I-85-812-SQN, dated February 20, 1986 4.
Memorandum from K. W. Whitt to H. L. Abercrombie on Corrective Action Response Evaluation, dated April 9, 1986
- 5. Corrective Action Report (CAR) SQ-CAR-86-01-001, dated January 24, 1986 6.
Memorandum from C. R. Brimer to P. R. Wallace on Corrective Action for SQ-CAR-86-01-001, dated February 18. 1986 (Sol 860218 832)
- 7. Memorandum from P. R. Wallace to H. L. Abercrombie on completion of Corrective Actions for SQ-CAR-86-01-001, dated July 11, 1986 (S01 860711 910) f L
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Revision 2 VII.
IMMEDIATE OR LONG-TERM CORRECTIVE ACTIONS Corrective actions are currently underway in response to SQ-CAR-86-01-001 and NSRS Report I-85-812-SQN which includes a baseline inspection to determine all areas requiring repair and development of new procedures to control all aspects of containment coatings at SQN. Corrective actions I will be tracked and verified by SQ-CAR-86-01-001 prior to closure. 1 j The. plant identified corrective actions for the CAR (reference 6) lE2 j
does not specifically identify the NSRS recommendatione to be I
' resolved nor does it specify actions taken to resolve the root IEl cause issue on a corporate level. The root cause specified I by SQN repair andwas a lack of an upper tier document controlling coatings maintenance. l The corrective actions are currently scheduled I
to be complete by November 1, 1986 (reference 7) prior to unit startup. l Because the CAR identifies a lack of an overall TVA Program to ensure the i quality of CSSC coatings and the MQAM definition of a significant C&Q it P
would appear that SQ-CAR-86-01-001 should be upgraded to "significant."
i The following acecpisbic cGcrective action plan was provided by SQN: lR2 Comments on CATD OP 30107-001-SON SQ-CAR-86-01-001 was not written because of deficiencies found by i Nuclear Safety Review Staff (NSRS) Report I-85-812-SQN. This l Corrective Action Report (CAR) was generated by an audit that was I l conducted by site QA staff. Sequoyah Nuclear Plant (SQN) has responded l to the NSRS report in a memorandur,fe'on H. L. Abercrombie to K. W. l l Whitt dated February 20, 1986. This Corrective Action Plan (CAP) t l further specifies which steps have been taken and the documents that I the work was implemented under.
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The upper-tier document specified by the CAR is for the SQN site and [
will be generated as a SQN Standard Practice Procedure (SQM). This l SQM will be written from the specifications and requirements of i G-Specifications-55.
IR2 Schedule i l
l All physical work necessary to bring each unit containment protective I I
coating within limits of the uncontrolled coating established by the l Division of Nuclear Engineering (DNE) will be completed before each I unit startup. Program changes (issues of revised G-55, MI-10.14, and l a new SQM), will be completed before the U2C3 outage. These program I changes are not required for U2 or U1 restart.
l Action Items l l
l The following actions have been taken in response to NSRS Report 1 I-85-812-SQN, and SQ-CAR-86-01-001.
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Revision 2 f 1. NSRS Recommendation I-85-812-SON-01
- a. The deficient areas of lower containment floor were recoated 1 by Engineering Change Notice (ECN) 6682. This was implemented l
) by Workplan 12069. All physical work is complete.
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i b&c. The liner wall delaminating carboline 305 topcoat was removed I on both units by MR Nos. A523804, AS48573, and AS47675. This I work was inspected by Maintenance Instruction MI-10.14. l l
- d. The floor on 734' elevation was determined not to require l repair. NSRS accepted this position. l l
- e. S.G. Pinney & Associates, Inc., (SGPI) was contracted to do a 1 detail baseline evaluation inspection. Deficient areas have I been added to the uncontrolled coating inventory maintained l by DNE.
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- 2. NSRS Recommendation I-85-812-SON-02 l t
Delaminating topcoat was removed by MR Nos. A523804, A548573, and i AS47675. Further inspection for all areas was conducted by I preventative maintenance (PM) 1435-364 and 1439-364. lR2 1
- 3. NSRS Recommendation I-85-812-SON-03 l l
A formalized PM instruction for inspection of Level I coating.has l been developed. This group of instructions is on System 364 All l
,reliminary p inspections have been completed. l l
- 4. NSRS Recommendation I-85-812-SON-04 l l
MI-10.14 will be revised in accordance with G-Specification-55 l upon revision of the G-Spec. This action is being tracked by [
SQ-CAR-86-01-001. A draft revision has been proposed by DNE, l and SQN site has made comments to the proposed draft. (
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- 5. NSRS Recommendation I-85-812-SON-05 l 1
In accordance with SQ-CAR-86-01-001, SQN site will generate a SQM l for the protective coating program. The issue of this procedure I is dependent on the issue of the revision to G-Specification-55. l This "SQM" procedure is the upper-tier document for SQN site. 1 l
- 6. Additional deficiencies were found on the inspection of SGPI. I Minor repair work was done under WRs and MRs. Three major i problems still exist, and need to be resolved or reworked before l startup of either unit.
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- a. Reactor Coolant Pump (RCP) motor coating is unqualified. l SQN-NEB-8610 (attached), documents this CAQ. ECN 7001 will I correct the deficiency by providing a screen to contain the I coating chips at the RCP base. This is a restart action. I Page 7 of 8
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Revision 2
- I potentially has unqualified coating. Further study is required I to determine the qualifications of the coating. If the coating i is unqualified, the exact solution will be determined through I the Significant Condition Report and ECN process. This l resolution is a restart action. This deficiency was I discovered during the baseline evalaution of SQ-CAR-86-01-001. [
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- c. Steam Generator and Pressurizer Enclosures - The coating on 1 i these enclosures were determined to be unqualified. This was IR2 j
determined during baseline evaluation of SQ-CAR-86-01-001. I The area will be recoated by ECN 7012. This is a restart i j action.
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- 7. Sequoyah Element Report 301.07 SON R1 l l
l SQ-CAR-86-01-001 has been reevaluated by the site QA supervis'or. i This CAR is not considered to be associated with a gross deficiency I in the QA program and is therefore not significant. Additionally, I the deficiencies were evalauted by NSRS Report I-85-812-SQN to have i no significant safety impact and was erlusted by PRO No. 1-86-139 l as not reportable to the NRC. There are problems with the program I that have been identified and corrective actions taken are I appropriate.
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T: bit Hil f REllCE - ECPS12OJ-ECPS121C Elemert Summer TEW ESSEE ML [EY AUTNORITY PAGE. 1 OF l,4 FRLQUENCY - REQUEST OFFICE OF WCLEAR PONER - RUN TIME -- 11:(*
ONP - ISSS - RilM EIFLOYEE CSEEW PRGORAM SYSTEM (ECPS) - RUN DATE - 10/,I LIST OF EIM CONCERN INFORMATION .
ATEGORY: OP PLANT OPER. SUPPORT SUSCATE00RY: 30107 *L PAINT CONCERN RX BLDG S GENERIC . KEYNORD A H APPL STC/NSRS P KEYHORD B CONCERN SUB R PLT 5BSH INVESTIGATION 5 CONCERN KEYHORD C NUMBER CAT CAT D LOC FL45 REPORT R DESCRIPTION KEYHORD D XX 087-001 OP 30107 N SON YNYY I-85-812-54N NS SEOUSYAN UNIT 1 & 2: CONTAINMENT PAI. PROTECTIVE COATING NT CDATINGS (#295 AND #395) ARE NOT PREVENTIVE MAINT
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T50186 REPORT
. PROPERLY MAINTAINED. THE INTEGRITY CIVIL GF THE CSATINGS IS BEING ERODED & GU CDATINGS.
ESTIONASLE. CI IS CONCERNED THAT TH E PAINT MILL CURL & PDP-UP AND CLOG THE BRAINS IN CASE OF A (LOCA) ACCID ENT HHEN THE TEMPERATURE AND PRESSUR E BUILBS UP IN THE REACTOR. PAINT S PECIFICATIONS AND STANDARDS ARE NOT FOLLONES, ESPECIALLY IN REC 0ATING OF 0385. NUC PDHER CONCERN. CI HAS N O FURTHER INFORMATION.
1 CONCERNS FOR CATEGORY OP SU5 CATEGORY 38107
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