ML20235B738
| ML20235B738 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/24/1987 |
| From: | Mcdonald E TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 10300, 10300-V01-R03, 10300-V1-R3, NUDOCS 8902140381 | |
| Download: ML20235B738 (63) | |
Text
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EMPLOYEE CONCERNS SPECIAL PROGRAM VOLUME 1 CONSTRUCTION CATEGORY SUBCATEGORY REPORT 10300 COATING AND PAINT UPDATED i
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c TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 b
SPECIAL PROGRAM j
REPORT TYPE: Subcategory Report - Construction REVISION NUMBER: 3 (Final Report)
TITLE: Coating and Paint PAGE I 0F 35 REASON FOR REVISION:
Incorporate SRP coments, corrective action.
Revision 1 executive sumary, and to finalize the report.
Revision 2 Incorporate SRP coments.
i Revision 3 Correct procedure.
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7 24 *M W/A DATE MANAGER OF NUCLEAR POWER DATE C') ECSP MANAGER CONCURRENCE (FINAL REPORT ONLY) 0004T 1-
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r Preface, Gloscary, and List of Acronyms for ECTG Subcategory Reports HISTORY OF REVISION REV NUMBER PAGES REVISED REASON FOR CURRENT REVISION 3
i To clarify that one or more attachments will belp the reader find where a particular concern is evaluated
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM FRONT MATTER REY:
3 PAGE i 0F vili Preface This subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Va13ey Authority (TVA). The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of Nuclose Power to evaluate and report on those Office of Nuclear Power'(ONP) employee concerns filed before February 1, 1986. Concerns filed after that date are handled by the ongoing ONP Employee Concerns Program (ECP)..
The ECSP addressed over 5800 employee concerns. Each of the concerns was a formal, written description of a circumstance or circumstances thet an employee thought was unsafe, unjust, inefficient, or inappropriate. The mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, the NRC, and the general public. The results of these investigations are communicated by four levels of ECSP reports:
element, subcategory, category, and final.
Element reports, the lowest reporting level, will be published only for j
those concerns directly affecting the restart of Sequoyah Nuclear Plant's i
reactor unit 2.
An element consists of one or more closely related
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issues. An issue is a potential problem identified by.ECTG during the i
evaluation process as having been raised in one or more concerns. For i
efficient handling, what appeared to be similar concerns were grouped into elements early in the program, but issue definitions emerged from the evaluation process itself. Consequently, some elements did include only one issue, but often the ECTG evaluation found more than one issue per element.
Subcategory reports sununarize the evaluation of a number of elements.
However, the subcategory report does more than collect element level evaluations. The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.
This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparent at the element level.
To make the subcategory reports easier to understand, three items have been placed at the front of each report:
a preface, a glossary of the terminology unique to ECSP reports, and a list of acronyms.
Additionally, at the end of each subcategory report will be a Subcategory Summary Table that includes the concern numbers; identifies other subcategories that share a concern; designates nuclear safety-related, safety significant, or non-safety related concerns; designates generic applicability; and briefly states each concern.
Either the Subcategory Summary Table or another attachment or a combination of the two will enable the reader to find the report section or sections in which the issue raised by the concern is evaluated.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 t
SPECIAL PROGRAM TRONT MATTER REV:
2 PAGE 11 0F viii The subcategories are themselves summarized in a series of eight category reports.
Each category report reviews the major findings and collective significance of the subcategory reports in one of the following areas:
management and personnel relations industrial cafety construction material contec1 operations quality assurance / quality control welding engineering A separate report on employee concerns dealing with specific contentions of intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.
Just as the subcategory reports integrate the information collected at the element level, the category reports integrate the information assembled in all the subcategory reports within the category, addressing particularly the underlying causes of those probicms that run across more than one subcategory.
A final report will integrate and assess the information collected by all of the lower level reports prepared for the ECSP, including the Inspector l
General's report.
I For more detail on the methods by which ECTG employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employee Concerns Task Group Program Manual. The Manual spells out the program's objectives, scope, organization, and responsibilities.
It also specifies the procedures thac were followed in the investigation, reporting, and closeout of the issues raised by employee concerns.
s TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE 111 0F viii ECSP GLOSSARY OF REPORT TERMS
- classification of evaluated issues the evaluation of an issue leads to one of the following determinations:
Class A: Issue cannot be verified as factual Class B:
Issue is factually accurate, but what is' described is not a problem (i.e., not a condition requiring corrective action)
Class C: Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue was undertaken Class D: Issue is factual and presents a problem for which corrective action has been, or is being, taken as a result of an evaluation Class E: A problem, requiring corrective action, which was not identified by an employee concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.
collective slanificance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
concern (see " employee concern")
corrective action steps taken to fis specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence.
criterion (plural: criteria) a basis for defining a performance, behavior, or quality which ONP imposes on itself (see also " requirement").
element or element reDort an optional level of ECSP report, below the subcategory level, that deals with one or nors issues.
employee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-form.
t l
s TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE iv 0F viii
. valuator (s) the individual (s) assigned the responsibility to assess a specific e
grouping of employee concerns.
findings includes both statements of fact and the judgments made abeut those facts during the evaluation process; negative findings require corrective action.
issue a potential problem, as interpreted by the ECTG during the evaluation I
process, raised in one or more concerns.
K-form (see " employee concern")
requirement a standard of performance, behavior, or quality on which an evaluation judgment or decision may be based.
root esuse the underlying reason for a problem.
- Terms essential to the program but which require detailed definition have been defined in the ECTG Procedure Manual (e.g., generic, specific, nuclear safety-related, unreviewed safety-significant question).
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TVA EMPLOYEE CONCERNS REPORT NUMBER: Fv300 s
SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE v 0F viii Acronyms I
i AI Administrative Instruction AISC American Institute of Steel Construction ALARA As Low As Reasonably Achievable ANS American Nuclear Society ANSI American National Standards Institute ASME American Society of Mechanical Engineers ASTM Enerican Society for Testing and Materials AWS American Welding Society BFW Browns Ferry Nuclear Plant BLN Bellefonte Nuclear Plant CAQ Condition Adverse to Quality CAR Corrective Action Report CATD Corrective Action Tracking Document CCTS Corporate Commitment Tracking System l
CEG-H Category Evaluation Group Head CFR Code of Federal Regulations CI Concerned Individual CMTR Certified Material Test Report COC Certificate of Conformance/ Compliance DCR Design Change Request DNC Division of Nuclear Construction (see also NU CON) l l
4 TVA EMPLOYEE CONCERNS REPORT NUhBER: 10300 SPECIAL PROGRAM i
FRONT MATTER REY:
2 PAGE vi 0F viii DNE Division of Nuclear Engineering DNQA Division of Nuclear Quality Assurance l
DNT Division of Nuclear Training DOE Department of Energy DP0 Division Personnal Officer DR Discrepancy Report or Deviation Report ECN Engineering' Change Notice ECP Employee Concerns Program ECP-SR Employee Concerns Program-Site Representative ECSP Employee Concerns Special Program ECTG Employee Concerns Task Group EEOC Equal Employment Opportunity Commission EQ Environmental Qualification EMRT Emergency Medical Response Team EN DES Engineering Design ERT Employee Pesponse Team or Emergency Response Team FCR Field Change Request FSAR Final Safety Analysis Report FY Fiscal Year GET General Employee Training HCI Hazard Control Instruction HVAC Heating, Ventilating. Air Conditioning II Installation Instruction INPO Institute of Nuclear Power Operations IRN Inspection Rejection Notice
v TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE vil 0F vill L/R Labor Relations Staff MLAI Modifications and Additions Instruction MI Maintenance Instruction MSPB Merit Systems Protection Board NT Magnetic Particle Test $ng NCR Nonconforming Condition Report NDE Nondestructive Examination NPP Nuclear Performance Plan NPS Non-plant Specific or Nuclear Procedures System NQAM Nuclear Quality Assurance Manual NRC Wuclear Regulatory Commission NSB Nuclear Services Branch NSES Nuclear Safety Review Staff NU CON Division of Nuclear Construction (obsolete abbreviation, see DNC)
NUMARC Nuclear Utility Management and Resources Committee OSHA Occupational Safety and Health Administration (or Act)
ONP Office,of Nuclear Power OWCP Office of Workers Compensation Program PHR Personal History Record PT Liquid Penetrant Testing QA Quality Assurance QAP Quality Assurance Procedures QC Quality Control QCI Quality Control Instruction
7 m-TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE vill 0F viii QCP Quality Control Procedure QTC Quality Technology Company RIF Reduction in Force RT Radiographic Tarting SQN Sequoyah Nucleac Plant SI Surveillance Instruction SOP Standard Operating Procedure SRP Senior Review Panel SWEC Stone and Webster Engineering Corporation TAS Technical Assistance Staff Tdt Trades and Labor TVA Tennessee Valley Authority
.TVTLC Tennessee Valley Trades and Labor Council UT Ultrasonic Testing l
j VT Visual Testing WBECSP Watts Bar Employee Concern Special Program WBN Watts Bar Nuclear Plant WR Work Request or Work Rules WP Workplans l
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v TVA EMPLOYEE CONCERNS REPORT NUNDER: 10300 SPECIAL PROGRAM REVISION NUMBER:
3.
l PAGE 2 0F 35 1
Page Number Outline of Contents l
l EXECUTIVE
SUMMARY
j 1.'O CHARACTERIZATION OF ISSUES 1.1 Introduction 7
1.2 Description'of Issues 7
1.2.1 WBN - Improper Mixing. Application, and Surface Preparation 1.2.2 WBN - Excessive Dry Film Thickness 1.2.3 WBN and BLN - Coating Application and Maintenance 1.2.4 WBN - Surface Preparation 1.2.5 WBN - Inappropriate Coating 1.2.6 WBN - Surfacer Deleted 1.2.7 WBN and SQN - Uncoated Welds 4
2.0
SUMMARY
2.1 Summary of Issues B
2.2 Sunnary of Evaluation Process 9,
2.3 Summary of Findings 9
2.3.1 Improper Mixing. Application, and Surface Preparation 2.3.2 Excessive Dry Film Thickness 2.3.3 Coating Application and Maintenance 2.3.4 Surface Preparation 1
2.3.5 Inappropriate Coating 2.3.s Surfacer Deleted 2.3.7 Uncoated Welds 2.4 Summary of Collective Significance 11 1
O TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 3 0F 35 Page Number 2.5 Summary of Causes 12 2.5.1 Improper Mixing. Application, and Surface Preparation 2.5.2 Excessive Dry Film Thickness 2.5.3 Coating Application and Maintenance 2.5.4 Surface Preparation 2.5.5 Inappropriate Coating 2.5.6 Surfacer Deleted 2.5.7 Uncoated Welds 1.
WBN 2.
SQN 2.6 Summary of Corrective Action 13 2.6.1 Improper Mixing, Application, and Surface Preparation 2.6.2 Excessive Dry Film Thickness 2.6.3 Coating Application and Maintenance 1.
WBN 2.
BLN 2.6.4 Surface Preparation 2.6.5 Inappropriate Coating 2.6.6 Surfacer Deleted 2.6.7 Uncoated Welds 1.
WBN 2.
SQN 3.0 EVALUATION PROCESS 3.1 General Methods of Evaluation 14 3.2 Reautrements or Criteria Established for Individual 15 Issues 3.2.1 Improper Mixing Application, and Surface Preparation 3.2.2 Excessive Dry Film Thickness 3.2.3 Coating Application and Maintenance
.'s. 2. 4 Surface Preparation 3.2.5 Inappropriate Coating 3.2.6 Surfacer Deleted 3.2.7 Uncoated Welds
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f TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 4 0F 35 Page Number 4.0 FINDINGS 4.1 Findings on Issue 1.2.1 - Improper Miring.
16 Application, and Surface Preparation 4.1.1 Generic f
4.1.2 Site specific 4.2 Findings on Issue 1.2.2 - Excessive Dry Film Thickness 17 4.2.1 Generic 4.2.2 Site specific l
i 4.3 Findings on Issue 1.2.3 - Costing Appliestion and 18 l
Maintenance l
4.3.1 Generic 4.3.2 Site specific i
I 4.4 Findings on Issue 1.2.4 - Surface Preparation 20 I
l 4.4.1 Generic 4.4.2 Site specific
,4.5 Findings on Issue 1.2.5 - Inappropriate Coating 20 4.5.1 Generic 4.5.2 Site specific 4.6 Findings on Issue 1.2.6 - Surfacer Deleted 21 4.6.1 Generic 4.6.2 Site specific 4.7 Findings on Issue 1.2.7 - Uncoated Welds 22 l
4.7.1 Generic l
4.7.2 Site specific I
1.
WBN 2.
SQN l
l l
L--_____________
n TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM
?
REVISION NUMBER:
3 PAGE 5 0F 35 i
I Fage Number 5.0 COLLECTIVE SIGNIFICANCE 5.1 Significance of Each Issue 26 5.1.1 Improper Mixing. Application, and Surface Preparation 5.1.2 Excessive Dry Film Thickness j
5.1.3 Coating Application and Maintenance 5.1.4 Surface Preparation 5.1.5 Inappropriate Coating 5.1.6 Surfacer Deleted 5.1.7 Uncoated Welds 1.
WBN 4
2.
SQN 5.2 Collective Significance of the Subcategory 28 5.2.1 Generic 5.2.2 Site specific 1..
VBN 2.
SQN 6.0 CAUSE 6.1 Improper Mixing. Application, and Surface 30 Preparation 6.2 Excessive Dry Film Thickness 30 6.3 Coating Application and Maintenance 30 6.4 Surface Preparation 30 6.5 Inappropriate coating 30 6.6. Surfacer Deleted 30 6.7 Uncoated Velds 30 1.
WBN j
2.
SQN J
l 3
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 6 0F 35 Page Number 7.0 CORRECTIVE ACTION 7.1 Corrective Action Already Taken 31 7.1.1 Improper Mixing. Application, and Surf ace Preparation 7.1.2 Excessive Dry Film Thickness 7.1.3 Coating Application and Maintenance 7.1.4 Surface Preparation 7.1.5 Inappropriate Costing 7.1.6 Surfacer Deleted 7.1.7 Uncoated Welds 1.
WBN 2.
SQN 7.2 Corrective Action From CATDs 32 7.2.1 Improper Mixing. Application, and Surface Preparation 7.2.2 Excessive Dry Film Thickness 7.2.3 Coating Application and Maintenance 7.2.4 Surface Preparation 7.2.5 Inappropriate Coating 7.2.6 Surfacer Deleted 7.2.7 Uncoated Welds 1.
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2.
SQN 8.0 ATTACHMENTS Attachment A - Listing of Employee Concerns Indicating Safety Relationship and Generic Appilcability Attachment B - List of Evaluators Attachment C - List of Concerns by Issue
, EXECUTIVE
SUMMARY
COATINGS AND PAINT Report Number:
10300 l
Revision Number:
3
SUMMARY
OF ISSUES This report addressed seven issues that were derived from twenty-two employee concerns. The seven issues identified were improper mixing, application, and surface preparation; excessive dry film thickness; coating application and maintenance; surface preparation; inappropriate coating; surfacer deleted; and uncoated welds. All seven issues were evaluated at Watts Bar Nuclear Plant (WBN). One issue (Uncoated Welds) was evaluated at Sequoyah Nuclear Plant (SQN). One issue (Coating Application and Maintenance) was found to be generic to Bellefonte Nuclear Plant (BLN) because of the f act that construction work was ongoing at that site.
MAJOR FINDINGS Two of the seven issues (Surface Preparation and Inappropriate Coating) were not a problem. No evidence of improper surface preparation was discovered, and coatings were found to have been applied in accordance with specifications. One of the remaining issues (Improper Mixing, Application, and Surface Preparation) was found to be factual in that excessive application of inorganic zine was verified. However, the coating had been repaired in the unit 2 containment dome as directed by NCR 6144. The remaining issues required corrective action due to the evaluation of the subcategory. With the issue of Dry Film Thickness, cracks and loss of adhesion had been discovered in some areas of the Auxiliary Building. Under the issue of Coating Application and Maintenance, unit 2 at WBN (which was in the construction phase) had sustained considerable damage to concrete floor ourfaces. Cracking was found to have occurred due to excessive dry film thickness of Phenoline 305 in the evaluation of the Surfacer Deleted issue.
In the investigation of the Uncoated Welds issue, some corrosion of welds was uncovered primarily in areas that had low corrosion rates though it was discovered that welds in the north and south valve rooms (high corrosion areas) had not been coated.
COLLECTIVE SIGNIFICANCE OF FINDINGS A pattern noted in the evaluation of the concerns in this subcategory report dealt with a failure of timely inspections early in the coatings program.
This along with the craftsmen and foremen's failure to adhere closely to specifications and misinterpretations of DNE documents by site employees contributed to the problems involving improper application and excessive coating dry film thickness.
4378T Page 1 of 2
3 EXECUTIVE
SUMMARY
(Continued)
These problems led to improper applications which were detected, documented, j
and corrected via NCRs, workplans, and training. These isolated cases, when compared with the total coatings program, were found to have little or no importance to the overall scope ano no significant impact on the safe operation of the plant facilities.
CAUSES OF THE MAJOR FINDINGS These irsues were due to a combination of management and employee weaknesses, which ranged from craftsmen and foremen's failure to follow specifications and misinterpretation of DNE documents by site personnel which resulted in deficient coatings.
l I
CORRECTIVE ACTION OF MAJOR FINDINGS No further corrective action was specified in the area of improper mixing, application, and surface preparation. The areas in question had already been corrected, and G-55 was revised to remove the dry film thie.kness limit chart.
The Employee Concerns Task Group (ECTG) recommended that damaged coatings in unit 1 bu repaired due to problems with excessive dry film thickness (reference CATD 10300-WBN-01). This program was to be developed and in place before unit 1 start-up.
In the area of coating application and maintenance, ECTG recommended that damaged coatings at WBN in unit 2 are'as be repaired (reference CATD 10300-VBN-02).
Discrepant coatings had been identified in walkdowns and were scheduled for rework on QCI 1.60 workplans. The same recommendation was made for units 1 and 2 at BLN (reference CATD 10300-BLN-01). BLN was to implement a formal surveillance program by June 30, 1987 to verify that protection of coatings was provided in high-risk areas.
Identification and repair of coatings were already covered by BNP-QCP-2.4 and BNP-QCP-9.2.
In the area of deleted surfacer ECTG recommended that failing coatings be replaced along with training for foremen and painters (reference i
CATD 10300-WBN-03). Training was provided by WBN-QCI-2.13 and SOP-21. These procedures cover Service Level I and II coatings. QC inspections were provided in Level I areas while CQC and CEU performed surveillance of Level II coatings.
At WBN, ECTG recommended that welds in high corrosion areas be cleaned and coated (reference CATD 10300-WBN-04). Work had begun inside containment using workplan E-6351-1. Work in the valve rooms had not begun. At SQN, maintenance requests were to identify rusting welds (reference CATD 10307-SQN-01). The response to the CATD acknowledged that rusted welds had been discovered during the implementation of several Preventive Maintenance packages. The packages were being evaluated by DNE.
Page 2 of 2
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 7 0F 35 l
1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction There were 22 employee concerns submitted and evaluated concerning l
coatings and paint. This subcategory report addressed ten of these concerns e.s six separate issues which were site specific to Watts i
I Bar Nuclear Plant (WBN). One separate issue addressed one concern generic to WBN and Bellefonte Nuclear Plant (BLN).
l The remaining 12 concerns were grouped and addressed as one issue.
l l
Six of these concerns were WBN site specific. The other six concerns were generic to SQN and only two of these concerns were to be addressed with regards to SQN in this report. The four remaining l
generic concerns were addressed for SQN in the Welding Project l
Generic Employee Concern Evaluation Report WP-08-SQN.
1.2 Description of Issues
- 1. 2..
Improper Mixing. Application, and Surface Preparation -
IN-85-243-001 l
This concern dealt with improper mixing and excessive spray l
application on uncleaned surfaces in the domes of the unit 1 and 2 Reactor Buildings.
1.2.2 Excessive Dry Film Thickness - IN-85-472-010, IN-85-511-001 l
l These concerns involved excessive coating dry film I
thicknesses in ereas of the unit 1 Reactor and Auxiliary Buildings.
1.2.3 Coating Application and Maintenance - IN-86-273-001 This concern addressed recoating applications and maintenance of previously costed containment surfaces in units 1 and 2 and was made generic to BLN as a result of the evaluation at WBN. The portion of the concern pertaining to maintenance at BLN was addressed at the subcategory report level without l
actual site evaluation. This concern addressed the construction program aspects from initial application up to trenster of the affected areas to operations. Concern KI-85-087-001-SQN covered this issue and was evaluated by Operations for all sites in Subcategory Report 301.07 and was not addressed in this report.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 8 0F 35 1
1.2.4 Surface Preparation - IN-85-472-009. IN-85-511-003 j
These concerns addressed improper surface preparation both on previously coated surfaces and uncoated surfaces for concrete j
and steel substrates in the unit 2 Auxiliary Building and lower portions of unit i reactor containment.
i 1.2.5 Inappropriate Coating - WI-85-077-001, IN-85-043-001 1
These concerns questioned the selection and qualification of coatings in the steam generator room.
1.2.6 Surfacer Deleted - PH-85-040-003, IN-85-711-001 These concerns involved the deletion of surfacer from the coating system in the unit I reactor containment and Auxiliary Building.
i 1.2.7 Uncoated Welds - WI-85-013-005 EX-85-059-001, IN-85-149-002, IN-85-192-002, IN-85-243-002, IN-85-273-001 IN-85-451-001, IN-85-511-002 IN-85-833-001, WBN-MM-85-001, IN-85-192-001, and IN-85-511-N05
)
i These 12 concerns questioned the decision to leave welds and other structural items, particularly above the decontamination dado, uncoated. Concerns EX-85-059-001, IN-85-192-002, IN-85-273-001 and IN-85-451-001 were evaluated and addressed in the Welding Project Generic Employee Concern Evaluation Report WP-08-SQN and were not addressed in this report.
2.0
SUMMARY
2.1 Summary of Issues 2.1.1 Coatings were not alzad in accordance with the procedure and were applied too heavily on uncleaned surfaces in the containment domes of the Reactor Buildings.
2.1.2 Coatings were applied excessively, resulting in dry flim thicknesses being out of specification in the unit 1 Reactor and Auxiliary Buildings.
2.1.3 Recoating procedures were not followed for the application of Phenoline 305 on containment surfaces of both units at WBN as well as improper care of coated surfaces.
2.1.4 There was a failure to properly prepare concrete and steel surfaces prior to coating in the unit 2 Auxiliary Building and the lower compartment of the unit i reactor containment.
~
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMLCR:
3 PAGE 9 0F 35 I
2.1.5 There was improper use of epoxy in the steam' generator room and inorganic zine coating applied to hangers.
2.1.6 Carboline 295 surfacer was eliminated causing cracks, loss of adhesion, and sealint against radiation on floors of the i
i unit S. Auxiliary Building ar.d reactor containment.
I 2.1.7 There was a reduction or elimination of requirements for
)
i coating welds, resulting in reduced structural integrity, I
reduction in ability to decontaminate, and increase of cost because of scheduling.
2.2 Summary of Evaluation process Applicable speciflettions, drawings, manufacturer's directions, project procedures. TVA construction specifications, existing N. sear Safety Review Staff (NSRS) reports, WBN construction i
investigation reports, flies, and other criteria required to l
evaluate and document conclusions reached for each issue were reviewed. Visual and/or physical inspections were made of each subject area.
2.3 Summary of Findint.s l
There were seven issues in this subcategory. All seven were evaluated at WBN while one issue each was evaluated at BLN and SQN.
l 2.3.1 Improper Mixing. Application, and Surface Preparation This issue was factual and identified a problem, but corrective action for the problem was initiated before the employee concerns evaluation of the issue was undertaken.
Excessive application of inorganic zinc, carbo-zine eleven (CZ 11), was found. However, improper mixing and application over improperly cleaned surfaces could not be verified. The coating had been repaired in the unit 2 containment dome as directed by NCR 6144.
2.3.2 Excessivo Dry F21m Thickness cracks and loss of adhesion had been found in some areas of the Auxiliary Building because of excassive application of Phenoline 305 finish coat. This issue was factual and identitled a problem, but corrective action for the problem was initiated before the employes concerns evaluation of the issue was undertaken. No large areas that would indicate the coating in the unit 1 Reactor Building were out of specification were found. The repair work performed on the containment dome and elsewhere may have covered the areas of the concerns. This issue could not be verified as factual.
I l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 10 0F 35 2.3.3 Coating Application and Maintenance This concern was not verified totally in units 1 or 2 with respect to the construction phase. The specified coating system was used following the proper application and inspection procedures. Investigations, including NSRS investigation report I-85-817-WBN, disclosed no problems with concrete coatings.
From a maintenance standpoint, unit 2, which was in the construction phase, had sustained considerable damage to concrete floor surfaces and would l
require repairs. Plant procedure QCI-2.12 was in place for implementing coating repairs where necessary and would not sacrifice the quality of the overall flove coating. Because of the repair work required, the issue was factual and presented a problem for which corrective action had been, or was being, taken as a result of an employee concerns evaluation.
2.3.4 Surface Preparation No evidence of improper surface preparations were found in the lover compartment of unit 1 Reactor Building.
Therefore, the issue could not be verified as factual.
Intercoat adhesion failure did exist at the elevator landing on elevation 713 of the Auxiliary Building but did not appear to be a pervasive problem. The issue was factually accurate, but what it described was not a problem (i.e., not a condition requiring corrective action by ONP.)
2.3.5 Inappropriate Coating Epoxy coatings were used in the steam generator rooms and inorganic zine was applied on the hangers without top coating above the dado throughout the containment. In both instances the products were applied in accordance with the specifications and procedures with problems being nonexistent, j
The issue was factually accurate, but what it described was not a problem (i.e., not a problem requiring corrective action by ONP).
2.3.6 Surfacer Deleted Finish coat (Phenolic 305) was applied directly to concrete surfaces in the Auxiliary Building under a program developed at WBN with the manufacturer's (Carboline) approval for service 1evel II areas (WBN Standard Operating Procedure (SOP]-21,
)
Actachment C. " Application Instructions Floor Coating Sykten CF").
i l
l 1
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 11 0F 35 Investigation of the bsue determined Carboline 295 surfacer was used; however, cracking was caused by excessive dry film thickness of the Phenoline 305 top coating. Coating systems such as those which used Carboline 295 did not protect against radiation and were never intended to be used as a decontamination coat. The issue could not be verified as factual.
2.3.7 Uncested Welds i
Uncoated welds evaluated at WBN'and SQN had displayed some
)
corrosion. This corrosion was above the dado of decontamination coating and was primarily located in areas that had a low corrosion rate.
Welds on supports, hangers, etc., in the north and south valve rooms at WBN, should have been coated because of the q
probability of high corrosion conditions. The issue was factual and presented a. problem for which corrective action i
had been, or was being, taken as a result of an employee concerns evaluation.
To schedule coating of hangers and supports immediately after their inspection would affect little savings in surface l
preparation but could increase the cost for painters. Tamper markings were used on bolted connections, not welded connections. The issue was factually accurate, but what it described was not a problem (i.e., not a condition requiring j
corrective action by ONP).
The decision for WBN to leave some welds uncoated on hangers and supports above the six-foot dado will not present problems for plant operations from either a structural or a decontamination standpoint.
Refer to Section 4.7.2
" Discussion," of this report for clarification. The issue was factually accurate, but what it described was not a problem (i.e., not a condition requiring corrective action by ONP).
i 2.4 Summarv of Collective Significance Six of the issues addressed in this subcategory report were factual.
However, portions of issues 1.2.3 and 1.2.4 could not be verified.
Issue 1.2.5 was determined to be not factual. Two of the issues, 1.2.1 and 1.2.2, had oeen corrected or were in the process of being correct >d.
The factual issues were due to a combination of management and employee effectiveness inadequacies. No valid issues were due to technical inadequacies. The established DNE and site procedures were adeguate to perform the application correctly. The investigations determined that there had been a failure of timely inspections early in the coatings program. This along with the
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 12 0F 35 painter foremen and craftsmen's failure to adhere closely to specifications and application instructions and misinterpretations of General Construction Specification G-55 and TVA drawing 46W466-1 by system engineers and craftsmen led to problems with improper application and excessive dry film thickness. The discrepancies had been detected, documented, and corrected via NCRs, workplans, procedure / drawing revisions e:1d training. The problems were specific to WBN. Collectively, the issues identified by these concerns will have no significant impact on the safe operation of the plant facilities and equipment. A problem was noted with a lack of a surveillance program and/or policy whereby coatings would be protected and required repairs would be identified and corrected due to the fact that management (both ONP and DNC) did not recognize a need for a program. This problem was generic to WBN and BLN.
Responsible site Construction and Operations personnel were aware of the requirements for demaged areas, particularly in unit 2, to be repaired and inspected prior to fuel loading for units 1 and 2.
Unit I repairs were made using MI-270.10 and the maintenance request process. Unit 2 repairs will be made using QCI-2.12 and the construction work release program.
2.5 Summary of Causes 2.5.1 Improper Mixing, Application, and Surface Preparation Misinterpretation of allowable dry film thickness requirements in
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the G-55 Specification by c~aftsmen and inspectors.
2.5.2 Excessive Dry Film Thickness Failure to follow the specification by craftsmen and foremen.
2.5.3 Coating Application and Maintenance Failure to properly protect and maintain coated surfaces.
2.5.4 Surface Preparation None 2.5.5 zna,,ro,,iate comu ng None
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2.5.6 Surfacer Deleted Excessive application of finish coat Phenoline 305 because of lack of attention by applicator and foreman.
2.5.7 Uncoated Welds 1.
WBN - The recommendations of the Coating Task Force of l
1983 which added Note 17 on Drawing 46W466-1.
2.
SQN - The rusting welds were the result of current modification and repairs.
i 2.6 Summary of Corrective Action 2. 6.1 Improper Mixing, Application, and Surface Preparation None - The areas had already been corrected and the G-55 Specification was revised to remove the dry flim thickness limit chart.
2.6.2 Excessive Dry Film Thickness Remove and replace failing and out of specification coatings. Some workplans had already been written and work was to follow. All applicators had been retrained. CATD 10300-WBN-01 was written. A formalized program for coatings maintenance and repair was to be developed and in place before unit startup. A procedure was to be developed requiring inspection and repairs of any areas identified as deficient during each outage.
2.6.3 Coating Application and Maintenance 1.
WBN-Repair existing damaged coatings in unit 2 areas.
CATD 10300-WBN-02 was written. Walkdowns had identified deficient areas and workplans had been written for repair.
The repairs were to be completed just before transfer.
2.
BLN-Repair any damage to existing coatings in units ik2.
C&TD 10300-BLN-01 was written. A formal surveillance program was to be implemented by June 30, 1987 to verify that protection of coatings was provided in high-risk areas.
2.6.4 Surface Preparation None - Repairing the small areas found was to be performed during the course of turnover and normal maintenance.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 14 0F 35 2.6.5 Inappropriate Coating None 2.6.6 Surfacer Deleted Remove and replace falling coatings.
Review the coating systems and requirements with foremen and painters assigned to do the work. Ensure QC inspection was performed on all floor coating operations. CATD 10300-WBN-03 was written.
QCI-2.13 covered training for foremen and painters for Service Level I areas. SOP-21 covered training of personnel for Service Level II areas. QC inspections were performed on all Level I areas. CQC or CEU performed surveillance of coatings outside Service Level I areas.
2.6.7 Uncoated Welds 1.
WBN-Clean and coat welds in high corrosion areas such as the north and south valve rooms and inner crane wall of unit 1 containment.
Corrective action had been recommended by Division of Nuclear Engineering (DNE) personnel in the disposition of NCR W-378-P.'
CATD 10300-WBN-04 was written. Work was in progress to coat welds inside the crane wall for unit 1 containment using workplan E6351-1. The work in the valve rooms was to commence once this work was complete.
2.
SQN-No corrective action required on specifications and drawings. Maintenance Requests (MRs) for coating repairs were being written according to Modification and Repair Procedures. CATD 10307-SQN-01 was written. Rusting conditions were found during the implementation of several preventive Maintenance packages. DNE was evaluating these packages.
3.0 EVALUATION PROCESS 3.1 General Methods of Evaluation The first step taken to evaluate the concerns described in the issues of this report was to conduct visual and physical inspections i
of each area.
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Secondly, pertinent documents, including existing NSRS reps ts WBN l
construction lovestigation reports, and files relative to the TVA Coatings Program, were reviewed for correctness and order.
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3 PAGE 15 0F 35 This was the most logical approach to take in order to substantiate and determine the accuracy of each of these concerns.
Samples of coatings were removed and inspected microscopically for surface preparation, dry film thickness, and other studies.
Actual site evaluations of protective coatings were not performed at BLN. The coating specifications and requirements were found to be in order in the WBN evaluations. Since the same specifications and coating requirements applied to BLN, no site investigation was deemed necessary.
3.2 Reautrements or Criteria Established for Individual Issues 3.2.1 Improper Mixing Application, and Surface Preparation Criteria used for evaluating this issue were the notes on TVA drawings 46W464-1 and 46W466-1 to 9. TVA General Construction IR3 Specification G-55, Construction Specification N3A952, QCP 2.12
" Protective Coating Inspection," QC and QA records for areas stated and NSRS Report I-85-817-WBN.
3.2.2 Excessive Dry Film Thickness criteria used for evaluating this issue were the notes on TVA drawings 46W464-1 and 46W466-1 to 9. TVA General Construction IR3 l
Specification G-55, and Construction Specif! ation N3A932.
Samples of coated surf aces were removed from various locations pertaining to concern IN-85-511-001.
These samples were attached to Element Report 10302, Ezeessive Dry Film Thickness."
3.2.3 Coating Application and Maintenance Criteria used for evaluating this issue were the notes on TVA drawings 46W464-1 and 46W466-1 to 9. TVA General Conste setion IR3 Specification G-55, construction Specification N3A932, QCP 2.12 l
" Protective Coating Inspection", QC Quality Training Program Manual Section III, QC and QA records for areas stated. NSRS Report I-85-817-WBN, NSRS Report I-35-812-FQN and DNP-QCP-2.4.
3.2.4 Surface Preparation Criteria used in regards to this issue were the notes on TVA drawings 46W464-1 and 46W466-1 to 9. TVA General Construction IR3 Specification G-55, Construction Specification N3A932 ANSI-N l
101.4-1972, and US NRC Regulatory Guides 1.54 dated i
June 1973 and 1.33, Revision 2.
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l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 16 0F 35 3.2.5 Inappropriate Coating Criteria used in regards to this issue were the notes on TVA drawings 46W464-1 and 46W466-1 to 9. TVA General Construction lR3 Specification G-55, Construction Specification N3A932, TVA drawings 47E235-42 to 47 - Temperatures, ANSI-N 101.4-1972, and US NRC Regulatory Guides 1.54 dated June 1973 and 1.33, lR3 Revision 2.
3.2.6 Surfacer Deleted.
Criteria used in response to this issue were the notes on TVA drawings 46W464-1 and 46W466-1 to 9. TVA General Construction IR3 Specification G-55, Construction Specification N3A932 and QC and QA records for stated areas.
3.2.7 Uncoated Welds Criteria used in regards to this issue were the notes on TVA drawings 46W464-1 and 46W466-1 to 9. General Construction IR3 Specification G-55, QC Quality Training Program Manual Section III, and QC and QA records for areas stated.
4.0 FINDINGS 4.1 Findina.s on Issue 1,2,1 - Improper Mixinr. Application, and Surface Preparation 4.1.1 Generic - No generic applicability for this issue.
4.1.2 Site specific Discussion Investigations of the domes in both unit 1 and 2 Reactor Buildings revealed an acceptable coating consisting of inorganic zine and epozy Phenolic top coat had been applied. Some arear in the unit I dome where adhesion testing was performed needed repair and touchup. The scope of the work on unit 1 in this area was defined in memorandums to the Architectural Branch Flies dated September 17, 1985 (B61 850917 003 and B61 850917 004).
The QA records covering surface preparation and application showed considerable repair of coatings was performed on the unit 1 dome in 1984.
The QA records covering unit 2 revealed the inorganic sinc coatings had been repaired during the last two months of 1985 as required in NCR 6144. Revision 0.
TVA ENPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER:
3-PAGE 17 0F 35 The memorandums and NCR 5144 confirmed the NSRS Report I-85-817-WBN finding on dry film thickness on the unit 2 dome. Because of the nature of the coatings and the fact that repair had been accomplished, it was impossible to l
confirm or deny the allegations of improper mixing and application over dry dirty surfaces.
A chart was included in G-55. Revision 3, to determine the allowable range of. dry film thickness from a single specified thickness. This chart was misapplied to a stated range in the specification and, consequently, allowed applications well in_escess of those required.
Conclusion i
The investigation of this issue showed that excessive application of inorganic zine (CZ 11) did occur. Improper mixing and unclean (dusty) surfaces could not be verified as i
factual. The coatings had been repaired as directed in NCR 6144. Therefore, the issue was factual and identified a problem, but corrective action for the problem was' initiated before the employee concerns evaluation of the issue was undertaken.
4.2 Findings on Issue 1.2.2 - Excessive Dry Film Thickness 4.2.1 Generic - No generic applicability for this issue, 4.2.2 Site specific i
Discussion
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l Cracking and loss of adhesion was confirmed at all four areas 7
designated in concern IN-85-511-001. The samples removed from these areas of the Auxiliary Building all demonstrated 40 or more allis dry film thickness. Bubbles or voids were observed in some of the samples, indicating thinning and/or I
conventionni spray application.
l A general inspection of the coatings in the unit 1 Reactor Building did not confirm the allegation that "the coatings are out of specification" as stated in IN-85-472-010.
Samples of coatings removed indicate both coating system WBNP-N-934-I and WBNP-N-946-II could have been used.
WBNP-N-934-I would allow thinning, conventional spray application, and a dry film thickness of 12 allis for the finish coat. WBNP-N-946-II was to be used with Watts Bar S0P-21.
This system restricted thinning, required airless spray application, and allowed up to 30 allis dry film thickness.
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PAGE 18 0F 35 The Architectural Branch Files contained two memorandums related to the unit 1 Auxiliary Building floor coatings (B51 850913 002 and B61 860207 002). Memorandum i
B61 859013 002 attributed the failures to poor concrete or surface preparation, moisture. improper use of Carboline 295 surfacer, and excessive. application of Phenoline 305 epoxy phenolic finish. Memorandum B61 860207 002 stated Phenoline 305 epoxy phenolic finish was found with dry film thickness in excess of 90 mills which developed forces strong enough to shear the coating system from the concrete surface.
The files made no direct reference to concern IN-85-472-010.
i It was probable that there were small areas that were either in excess or were less than specified required flim thi cknes s.
It was also possible this concern made reference l
to the issue discussed in 4.1.2 above. The investigation' could not show this concern to be factual.
Conclusion Floor coatings had cracking and adhesion loss-in the Auxiliary Building. This failure resulted primarily from the excessive application of Phenoline 305 finish coat. This issue was factual and identified a problem, but corrective action for the problem was init' lated before the employee concerns evaluation of the issue was undertaken.
No large areas could be found in the unit 1 Reactor Building that would indicate the coatings were out of specification.
The repair work which had been performed on the dome and elsewhere may have eliminated these concerns. The issue could not be verified as factual.
4.3 Findinas on Issue 1.7.3 - Coatina Appliestion and Maintenance -
4.3.1 Generic - This issue had generic applicability to SQN and BLN. As stated in the Description of Issues, paragraph 1.2.3 of this report, Concern XX-85-087-001-SQN will be addressed and reported by Operations in Subcategory 301.07 and will not be addressed in this report.
4.3.2 Site specific Discussion Concrete coatings system consisting of Carboline 295 surfacer and Phenoline 305 finish were used in both units 1 and 2.
Investigation of these surfaces revealed a small amount of mechanical damage in unit 1 and a considerable amount of-damage in unit 2.
The repaired and recosted areas in unit 1 G
v TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 19 0F 35 4.3.2 Site Specific (continued) were in good condition with only three repairs showing adhesion problems. The adhesion problem appeared to be confined to applications that had been completed and beyond the parameters of the prepared surf aces.
Concern IN-86-273-001 was investigated and reported by NSRS report I-85-817-WBN, finding 3.
"The general inspection of unit 1 containment indicated that the coatings on concrete were adhering well, and no significant areas of damage were observed. In the professional judgment of the coatings specialists, failure to follow specifications and procedures when recoating Phenoline 305 would be expected to result in delamination between coats of 305. This type of failure was not observed, except in some small areas around the periphery of a repelred area, where repair coatings may have been l
spplied slightly beyond the limits of the area prepared by.
abrading or wiping with solvent."
The NSRS report was extended to include the inorganic zine i
and Phenoline 305 coating system. This investigation confirmed and supported the ECTG findings as noted in paragraph one of this discussion.
The site procedures for recoating Phenoline 305 were compared to the requirements of G-55, N3A932, and the manufacturer's directions. No discrepancies were noted.
WBN QCF-2.12, Attachment C, " Surface Preparation and i
Application Records," were obtained from the QC files for I
representative areas where repales had been made and deviations from proc 9dvees or specifications were not reported in these records.
Conclusion This concern could not be totally validated. The specified l
coatings systems were used following the proper application and inspection procedures. Neither this investigation nor the NSRS investigation disclosed a problem with concrete coatings l
application and repairs. However, Construction needs to j'
address the issue of protecting the initial coating applications, repairing existing damaged coatings, and making provisions for repairing any subsequent damage which may occur. Therefore, the issue was factual and presented a problem for which corrective action had baen, or was being, taken as a result of en employee concerns evaluation.
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3 PAGE 20 0F 35 4.4 Findings on Issue 1.2.4 - Surface Preparation 4.4.1 Generic - No generic applicability for this issue.
4.4.2 Site specific Discussion Concern IN-85-472-009 indicated coating problems in the lower compartment of the unit 1 Reactor Building. Investigation of areas both inside and outside the crane wall showed a minor amount of mechanical damage and some welds not coated.
However, no areas that would indicate coating problems because of improper surface preparation existed. A few small areas of delamination of Phenoline 305 because of excessive or improperly cured CZ 11 were present.
The elevator landing at elevation 739 in the Auxiliary Building had a small area (less than 1 square foot) of intercoat adhesion present as indicated in concern IN-85-511-003.
Microscopic examination of delaminated (intercoat) coatings was made. This sample showed insufficient abrasion or insufficient solvent softening.
There was no indication of dirt or contaminants causing this problem.
Conclusion Investigation of the coated surfaces in the lower :ompartment of the unit 1 Reactor Building did not uncover leproper surface preparation caused failures. 'Therefore, the issue could not be verified as factual. Intercoat adhesion was found to be confined to a small area at the 713 lending of the Auxiliary Building elevator. The issue was factually accurate, but what it described was not a problem (i.e., not a condition requiring corrective action by ONP).
4.5 Eindings on Issue 1.2.5 - Inacoropriate Coatina 4.5.1 Generic - No generic applicability for this issue.
4.5.2 Site specific Discussion festings with an epoxy binder were investigated in the steam generator rooms of both units and were found to be present as stated in concern WI-85-077-001. The epoxy coating was approximately six feet above the top platform and from the floor to the 726-foot elevation.
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-PAGE 21 0F 35 Zine coating existed on most hangers above the six-foot dadoLin the. Reactor and Auxiliary Buildings.
TVA Drawings 47E235-42 to 47 show a normal operating peak lR3 temperature of 170'F in the steam' generator rooms. The coating system had been qualified to a Loss of Coolant Accident (LOCA) of 280*F.
TVA Drawing series 46W466-1 through -9 did not require lR3 top coating above the six foot dado except in specific areas.
TVA General Construction. Specification G-29 allowed inorganic zine on carbon steel surfaces contacting stainless steel.
Conclusion These concerns were correct from the standpoint that epoxy coatings had been applied in the steam generator rooms and inorganic zine existed on hangers without top coating.
However, in both instances the products had been applied in accordance with the specifications, and no problems were found to exist. The issue was factually accurate, but what it described was not a problem (i.e., not a problem requiring j
corrective action by ONP).
4.6 Findings on Issue 1.2.6 - Surf acer Deleted 4.6.1 Generic - This issue was determined to have no generic applicability because upper tier documents were adequate.
4.6.2 Site specific Discussion Inspections of the floor areas and a review of the QCP-2.12, i
Attachment C, records for the floors in unit I containment did not show any deletion of the 295' surfacer. Based on these investigations, concern PH-85-040-003 could not be verified factual for the unit 1 containment floors.
Investigations of the Auxiliary Building floor coatings found that cracking and intercoat failure was primarily because of excessive dry film thickness, water damage, and improper considerations of surface conditions at-the time of application. TVA memorandum (B61 850913 002) confirmed this findins during the investigation for concern IN-85-511-001.
The Carboline 295 surfacer was deleted from the floor coating system for level II areas. This resulted in the implementation of Coating System N3A-932, WBNP-N-946-II, for applications over specified bare concrete. The carboline 205 free coating system was jointly developed by-DNE and Division
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PAGE 22 0F 35 of Nuclear Construction (DNC) personnel and approved by John Montel. Technical Director of Carboline. The system had been Very successful when properly followed. However, excessive film buildup, thinning of the top coat, and failure to follow appilcation instructions had resulted in cracks and loss of adhesion, both from the substrate and intercoat.-
j Conclusion The failure of the floor coatings in the unit 1 Auxiliary Building was directly linked to excessive dry. film thickness of Phenoline 305 finish and to the rowetting.or improper use of Carbolins 295 surfacer. Concern PH-85-040-003 partially stated that the intent of the 295 surfacer was to seal the item from radiation. The carboline 295 was designed to fill and level a concrete surface prior to the application of the epoxy finish coat. The Carboline 295 surfacer had never i
been suggested for use as a decontamination coat. The issues could not be verified as factual.
4.7 Findings on Issue 1.2.7 - Uncoated Welds 4.7.1 Generic - This issue was generic to WBN and SQN only. The findings were site specific for each plant.
4.7.2 Site specific 1.
WBN Discussion I
Investigations of the,12 concerns which made up this issue revesled that the concerns stemmed from i
misinterpretations or misunderstandings of Note 17 on Drawing 46W466-1 which reads as follows:
Weld joints on hangers and supports, fabricated from precoated stock, may be left unprimod with no further conting required (in areas.of low risibility and above the protectively coated dado) at the distration of the constro; tion engineer (unit 1 only),
i Note 17 resulted from the Coating 76sk Force, established by memorandum EDC 830919 602. The consensus of the task i
force was that Note 17 would facilitate meeting the fuel loading date targeted at the time end would help reduce i
cost overruns. However, note 17 had been deleted and incorporated into note 20 which reads as follows:
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 23 0F 35 Weld joints on pipe and instrumentation hangers, and cable traf and conduit supports fabricated from precoated stock may be left unprimed with no further coating required (in areas of low visibility, low corrosion conditions, and above the protectively coated dado). This note does not apply to the main steam valve rooms and areas inside the crane wall.
l Also, note 21 provided the protective coating boundaries l
when specifically denoted on the 46W466 series drawings for platforms and ladders and reads as follows:
For platforms and ladders located in this area:
Protective coating to extend six feet above height of platforms and three feet horizonte11y beyond edges of platforms wherever platforms come in contact with the walls. Protective coating to eztend three feet horizontally on each side of ladders to the full height of each ladder.
Notes 20 and 21 have clarified the protective coating requirements for units 1 and 2.
Areas listed and investigated for concerns IN-85-192-001, IN-85-192-002, IN-85-273-001, IN-85-451-001, IN-85-833-001, and WBN-MM-85-001 were of the same nature. They demonstrated rusty welds and the elimination of some top coating did exist in the Reactor and Auxiliary Buildings.
The investigation of concern IN-85-149-002 showsd some welds were coated to the six foot dado while others were not in the unit 2, 1-4 accumulator rooms.
It was also noted installations and welding were still in progress in these areas.
Concern IN-85-243-002 which stated:
"All hangers and structural steel over six feet above the floor in the Reactor and Auxiliary Building units 1 and 2 are unpainted" could not be confirmed.
After concern IN-85-511-002 was investigated, it was determined the walds in the unit 2 north and south valve rooms would be touched up and that unit 1 valve room welds would either be touched up c'c that a corrosion allor2nce for each weld would be calculated. Form TVA 45D dated September 17, 1985, stated:
"...without the assurance the area can be kept dry, it is best to pa$nt any of these rusting and unpainted welds... "
This information was transmitted to WBN by way of memorandum B61 850925 009.
l TVA EMPLOYEE CONCERNS' REPORT NUMBER:
10300 SPECIAL PROGRAM REVISION NUMBER:.3 PAGE 24 0F 35 Concern EX-85-059-001 questioned'the scheduling of painting welds. The CI stated a'saving in surface preparation, metal loss, and tamper detection markings would be effected.
In actuality the surface preparation and resulting metal loss would be about equal and in either case " tamper detection" markings on welds was's moot question because these markings were used on bolted connections, not welded.
In conclusion 4-f this discussion. Specification G-55 called
' for blast cleanir.g or power tool cleaning, if blasting was prohibited. Specification N3A932 stated the details of the coating system.
Drawing 46W466-1 and 46W464-6 dictated the coating system for each area. As a general guide in the Reactor and Auxiliary Buildings, carbon steel was primed with CZ 11.
Decontamination coating of Phenoline 305 was applied as.the finish coat to all surfaces that may be subject to radioactive contamination. This was usually the floors and.
lR2 six feet up the wall and any equipment located in the area or prJjecting from the floor Or Wall. Above the six foot height, except around ladders, platforms, etc., painting was for corrosion control only.
Conclusion Basically, the concerns covered in this issue were confirmed; uncoated welds did exist and had resulted in some corrosion.
This corrosion was above the dado of decontamination coating level and for the most part located in areas that had a low corrosion rate.
Since note 17 had boon deleted and incorporated into Note 20, the uncoated welds in the unit 1 main steam valve rooms (both north and south).and inside the unit 1 crane wall will have to be coated. The issue was factual and presentou a problem for which corrective action had been, or was being, taken'as a result of an employee concerns evaluation.
No requirements existed which dictated a particular seguence of construction activities.. Coating operations were based on good engineering judgment intended to maximise the efficiency of the overall construction schedule. The issus was factually eccurate..but what it described was not a problem (i.e., not a condition requiring corrective action by ONP).
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3 PAGE 25 0F 35 It was determined that leaving some welds uncoated on hangers and supports above the dado level would not present operational problems. The issue was factually accurate, but what it described was not a problem (i.e., noc a condition requiring corrective action by ONP).
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SQN Discussion Concern IN-85-243-002 addressed hangers, structural steel sembers, and associated welds. ' Field evaluation, as a part of this, confirmed the SQN-CAR-86-01-001 baseline evaluation. findings that there were some rusty welds on steel member.s. The rusting welds were the result of current modifications and repairs - not design requirements at SQN.
Concern IN-85-833-001 addressed the lack of top coat above the six-foot dado for decontamination in most areas l
where "smearable" contaminat3on may be present. The requirements for application of decontamination coat up to a six-foot dado in oating service levels I and II areas were established from the experience at the Browns Ferry Nuclear Plant and to meet the As Low As Reasonably Achievab1w (ALARA) commitments. Carbon steel, including velds above the six-foot dado, should be primed for corrosion protection. Corrosion protection for carbon steel should be provided in areas of high humidity and temperature such as inside the containment crane wall where temperatures will range up to 98'F and humiolty will be in the 98 percent range, and in the valve rooms where temperatures are high and rain can find its way into the area. Welds and/or carbon steel above the six-foot dado were not required to meet decontamination requirements. Rusting of carbon steel created a problem of (1) decontamination, (2) adhesion of coatings, and (3) was an indication of structural failure (this depended on the extent and rate of corrosion.)
conclusion l
There were some rusty welds and structural steel members that were to be scheduled for coating repair as they were identified and MRs were to be written from the baseline evaluation report.
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In accordance with drawings and specifications, improper deletion of top coating or limiting of coating in general had not occurred as SQN. The issue could not be verified as factual.
5.0 Collective Slanificance 5.1 Stanificance of Each Issue 5.1.1 Improper Mixing, Application, and Surface Preparation Degradations raised in this concern could not,be totally confirmed at the time ECTG investigations were conducted. Improper mixing and unclean (dusty) surfoces could not be verified as factual, j
i Excessive application of inorganic zine did occur due to a misinterpretation by craftsmen and inspectors of a chart in G-55 stating an allowable range for dry film thickness.
Repairs had been made in unit 1 by Plant Maintenance through the Maintenance Request program.
Deficiencies identified in Unit 2 by NCR WBN 6144 had been corrected with acceptable coating dry film thickness now in place. No physical damage to the plant existed in regards to this issue.The NSRS report, I-85-817-WBN, revealed that no formal preventive maintenance program had been developed at WBN prior to the investigation of this issue. The development and implementation of this program was to be addressed in Operations Subcategory Report 30100.
5.1.2 Excessive Dry Film Thickness It was probable that concern IN-85-472-010 in this issue was closely related to the issue discussed above in 5.1.1.
In this case, no significance was assigned to this concern since acceptable repairs had been made in the unit 1 Reactor Building and only applied to small isolated areas.The conditions identified in concern IN-85-511-001 were found to exist in the unit 1 Auxiliary Building. This concern had some significance in that the excessive thickness of the coatings applied indicated a failure to follow specifications by the craftsmen and foremen. It also indicated inspections and wet or dry film checks were not made during the continr. operations. The problem was identified before the employee concerns investigation and all applicators had been retrained. Investigations of this issue revealed no physical damage to the plant.
5.1.3 Coating Application and Maintenance Since this concern could not be found factual in unit 1 and construction procedures were in place for making repairs in unit 2, this issue was nonsignificant.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 27 0F 35 5.1.4 Surface Preparation This issue was nonsignificant.
Investigations revealed that intercoat adhesion failure was limited to a very small area at the Auxiliary Building elevator landing at elevation 713.
No improper surface preparation caused deficiencies in the lower compartment of the unit 1 Reactor Building.
5.1.5 Inappropriate Coating This issue was found factual from the standpoint that an epoxy coating was applied. However, investigations of this issue determined the correct coating systems (N3A932) had been applied in accordance with application instructions (WBNP-N-934 for concrete surf aces and WBNP-N-904 for carbon steel substrate). This issue was nonsignificant, since it was determined to be unfounded.
5.1.6 Surfacer Deleted A review of the WBN QC records covering application of floor coatings in the unit 1 Reactor Building did not show the deletion of 295 surfacer as stated in concern PH-85-040-003 of this issue. This concern, therefore, could not be found factual and was nonsignificant.
Concern IN-85-711-001 of this issue involved the elimination of Carboline 295 surfacer in the appilcation of floor coatings in the unit 1 Auxiliary Building. During the summer of 1982, a surfacer free coating system was developed by TVA at WBN with the approval of Carboline to be used in service level II areas such as those in the Auxiliary Building. This coating system was outlined in WDNP-SOP-21(RO).
Implementation of this coating system proved to be an acceptable and cost saving method of applying the finished epoxy coating. In view of the fact that surfacer was eliminated during applications in the Auxiliary Building, this issue was partially factual, but was nonsignificant.
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3 PAGE 28 0F 35 5.1.7 Uncoated Welds 1.
WBN This issue was determined to be nonsignificant since uncoated and rusty welds were found to exist primarily in low corrosion rated areas and above the decontamination dado level. The Coating Task Force of 1983 recommended that welds at WBN on hangers and supports above the protectively coated dado could be left unprimed with no further coatit.g required. This was implemented by Design and Construction with the addition of note 17 on drawing 46W466-1. This note was the source of misinterpretation s
by DNC system engineers, QC inspectors, and craftsmen.
The note had since been deleted and the subject was clarified by note 20.
Investigation of concern IN-85-511-002 in this issue resulted in a reevaluation of the conditions of welds in the valve rooms of both units. Rustirg or unpainted ucids in unit 1 ware to be coated and welds in the unit 2 valve rooms were to be touched up as necessary due to high corrosive conditions present in ti.e rooms.
2.
SQN Rusty welds, hangers, and other structural members were found to exist as a result of modifications and repairs-not as an oversight of design requirements.
Improper deletion of top coating or limiting of coating in general had not occurred, therefore, this is. sue was determined nonsignificant.
5.2 Collective Significance of the Subcategory 5.2.1 Generic The seven issues comprised of 22 employee concerns evaluated in this subcategory report were f ound generically to have no collective significance for WBN or SQN. Drawinas, specifications, and other pertinent information. re provided by the Architectural Design Branch to support at dequate coatings program.
hMW '
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 l
REVISION NUMBER: 3 PAGE 29 0F 35 5.2.2 Site specific 1.
WBN The factual issues were due to a combination of management i
and employee effectiveness inadequacies. No valid issues were due to technical inadequacies. The established DNE and site procedures were adequate to perform the applications correctly.
A significant pattern determined from the evaluation of the concerns relevant to the issues in this report determined a failure of timely inspections early on in the
)
coatings program. Coupling this with the painter foremen i
and craftsmen's failure to adhere closely to l
specifications, application instructions, etc., and misinterpretations of General Construction Specification G-55 and TVA drawing 46W466-1 by system engineers and craftsmen contributed to the concerns involwing improper application and excessive coatings dry film thickness.
Failure of timely inspections and foremen and craftsmen's j
l adherence to criteria created impropter applications which
{
were detected, documented, and corrected via NCRs.
l workplans, and training where applicable. These isolated cases, when compared with the total coatings program.
4 were found to have little or no importance to the overall scope and no consequence to plant facilities. Repairs had been made and procedures for making minor isolated repairs were noted for unit 1.
Unit'2 repairs had been j
made in accordance with NCR 6144 directions. Additional repairs were to be made to the protective coatings in l
unit 2 areas as the construction program phased out at l
WBN and at BLN as construction progressed, j
2.
SQN The issue, comprised of two concerns, which were site specific to SQN, was collectively nonsignificant. The concerns pertained to rusty welds and uncoated surfaces above the 6 foot dado and had no bearing on management and employee effectiveness or the operations of plant l
facilities.
.n
v TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM REVISION NUMBER:
3 l
l PAGE 30 0F 35 6.0 Cause 6.1 Improper Mixina. Application and Surface Preparation The misinterpretation by craftsmen and inspectors nf the chart in G-55(R3) stating an allowable range for dry film thickness resulted in applications in excess of that desired and. required.
6.2 Excessive Dry Film Thickness The failure of craftsmen and foremen to follow the specifications in the application of Phenoline 305 finish coat.
6.3 Coating Applications and Maintenance There was no cause associated with application. Early applications I
of coatings during the construction phase with little protection being provided led to coated surfaces which required considerable repairs and rework.
6.4 Surface Preparation No apparent cause could be determined for this issue.
6.5 Inappropriate Coating No cause could be determined for this issue since coatings present were applied in accordance with the specifications and coating requirements.
6.6 Surfacer Deleted Excessive application of Phenoline 305 finish coat was due to lack of attention by painters and foreman.
6.7 Uncoated Welds 1.
WBN The cause for this issue was due to misinterpretations of Note 17 which was added to TVA drawing 46W466-1 upon the i
recommendations of the Coating Task Force of 1983.
2.
SQ'!
Rusting welds because of current or ongoing modifications and repairs were determined to be the cause for this issue.
- ____.=_--- -_ ----
C 0
~
I TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 31 0F 35 7.0 Corrective Action 7.1 Corrective Action Already Taken
-l 7.1.1 Improper Mixing, Application, and Surface Preparation No corrective action required. Areas evaluated in this issue j
had been corrected, and the dry film thickness limit chart had been removed from the G-55 (Revision 4) specification.
7.1.2 Excessive Dry Film Ibickness
{
All applicators had been retrained to WBN-QCI-2.13. Revision
- 4. " Qualification of Protective Coating Applicators," per the requirements of NCR 6144, and some workplans had been identified from.the "1985 unit 2 ws.1kdown" performed by the DNC Civil Engineering Unit. A few examples of these were CAP 00BZ and CAP 00FZ for the Auxiliary Building and CRP00AZ and CRP02GZ for the Reactor Building.
7.1.3 Coating Application and Maintenance Repairs had been made in unit 1 areas. Coating repairs had been made in unit 2 in accordance with NCR 6144 directions.
7.1.4 Surface Preparation No corrective action required.
7.1.5 Inappropriate Coating No corrective action completed.
7.1.6 Surfacer Deleted No corrective action required.
7.1.7 Uncoated Welds 1.
WBN Corrective action had been recommended by DNE for NCR-W-378-P in a memorandum dated September 22, 1986 from K.C. Gandhi to D.M. Lake (B26 860922 035).
2.
SQN MRs were being written for necessary coatings repairs and cross checked against the baseline evaluation report.
s
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 32 0F 35 7.2 Corrective Action from CATDs 7.2.1 Improper Mixing, Application, and Surface Preparation None 7.2.2 Excessive Dry Film Thickness Protective coatings which had been determined to be damsged, i
failing or otherwise out of specification in unit 1 were to 4
be removed or replaced with existing MRs.
I CATD 10300-WBN-01 The line management response was:
A formalized program for coatings maintenance and repair will be developed and in place before unit startup.
A' procedure will be developed requiring inspection and repairs of any areas identified as deficient during each outage.
A new procedure wl11 be written or instructions incorporated into existing procedures to provide requirements for maintaining a formal list of unqualified coatings by January 5, 1988.
7.2.3 Coating Application and Maintenance l
1.
WBN Repair protective coatings in unit 2 which have been determined to be damaged, failing, or otherwise out of specification with existing construction workplars.
Develop and implement a surveillance progray and/or policy whereby coatings will be protected and required repairs identified and corrected.
)
1 CATD 10300-WBN-02 4
The line management response was:
j i
The November 1985 walkdowns identified damaged coatings.
j These areas are identified on QCI 1.60 workplans. Prior t
to i psuing cnese wors.paans auw 6uw. 1 mu w-.. 1. r-. f....d j
d cum a
n rwis ut pecificy 1beidenti}iedonNonconformance of s b
L l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 33 0F 35 Reports. Fach as NCE 6144 RO.
The defielencies shall be correct.eu per was utspv.awava v s' u = 'vuw u.^v....us.
o g *Unitd*g pts to protect RdyttY.7T E
Irh[jlifd damage by oatingsShdrh' p
c eqvering miting ess to a here coatings ne&h1Ad made and h Lve been[: coup A
d saged coat'ih....
u....
.;......;....,_.._.._ist.
^
Rapaars are cu=yAswwu su.6 v6 avi uv w..u..
2.
BLN l
Develop and implement a surveillance program and/or policy whereby coatings will be protected and repairs l
identified and corrected.
CATD 10300-BLN-01 The line management response was:
DNC BLN has an informal program for protecting applied coatings in vulnerable areas. A formal surveillance program will be implemented by June 30, 1987, to verify that protection is provided in high-risk areas.
Identification and repair of coatings are already covered by BNP-QCP-2.4, " Protective Coatings for Concrete and I
Carbon Steel Surface's," and BNP-QCP-9.2, "Trar.sfer of Permanent Plant Equipment Systems, or Structures to the Office of Nuclear Power."
l 7.2.4 Surface Preparation None i
l 7.2.5 Inappropriate Coating None 7.2.6 Surfacer Deleted Review the coating systems and requirements with foremen and painters assigned to do the coatings work. Ensure QC inspection is performed on all floor coating operations.
CATD 10300-WBN-03
v.
l 1
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10300 SPECIAL PROGRAF REVISION NUMBER:
3 PAGE 34 0F 35 The line management response was:
WBN-QCI-2.13 " Qualification of Protective Coatings Applications" requires the Civil Quality Control (CQC)
Unit to provide a training program in all ses of the protective coatings program in WBN-QCI
. 2 " rotective Costings - Application Instructions This eo ers Service Level I coatings. Training of e
and pain rs is documented on WBN-QCI-2.13 a
and Atca ment B.
A revision effective Feb
,,to WBN-P 1 requires the Civil Engineerin a
i S/t tr program for craft foremen to e
ures V
-21 covers Service Level Fkreme n
ainters will be trained t o
phai lowed to work in l
these a
trai umented on WBN-QCI-1.11-1 o
At Q
ti hg4 ormed on all coatings in Service Le I area y
C inspectors as required by WBN-QCP-2.12
" Pro ective ings Inspection." A CQC inspector or Civil Engin el Unit representative performs surveillance inspec ons of coatings outside Service Level I areas as required in WBN-SOP-21.
7.2.7 Uncoated Welds l
1.
WBN Clean and coat welds in high corrosion areas such as the north and south valve rooms and inner crane wall of unit 1 containment.
CATD 10300-WBN-04 The line management response was:
Work is in progress to clean and coat welds inside the crane wall for unit 1 containment using workplan E-6351-1.
The work inside containment is scheduled to be complete prior to startup.
Work in the north and south main steam valve rooms has not begun but will start as manpower becomes available from the work inside containment.
There is no requirement that any of this coating work be completed before startup. If all coating work is not completed before startup, the remaining uncoated welds will be coated as access to these areas becomes available during outages.
l
~
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10300 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 35 0F 35 2.
SQN Rusting welds and structural steel members are to be scheduled for coating repairs as identified through the Maintenance Request process.
CATD 10307-SQN-01 Line management response:
Rusting conditions were found during implementation of the following Preventive Maintenance packages:
PM-1474-364 PM-1521-364 PM-1434-364 PM-1436-364 PM-1435-364 PM-1437-364 PM-1438-364 PM-1473-364 PM-1439-364 PM-1518-364 PM-1520-364 PM-1519-364 i
These Preventive Maintenance packages are being evaluated by DNE. All rusting conditions have been given a repair priority of 2.
Priority 2 items are not required for restart. Maintenance Requests and Work Releases will be generated on these items.
B.O ATTACHMENTS Attachment A - Listing of Employee Concerns Indicating Safety Relationship and Generic Applicability Attachment B - List of Evaluators Attachment C - List of Concerns by Issua
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ATTACHMENT B List of Evaluators Watt Bar Nuclear Plant (WBN) Concerns E. C. Mcdonald SeouoYah Nuclear Plant (SON) Concerns E. C. Mcdonald Bellefonte Nuclear Plant (BLN) Concerns l
E. C. Mcdonald 0
6 l
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,, e ATTACHMENT C List of Concerns by Issue l
1.2.1 Improper Mixing, Application, and Surface Preparation Concern Number IN-85-243-001 1
l l
1.2.2 Excessive Dry Film Thickness l
l Concern Numbers IN-85-472-010 IN-85-511-001 1.2.3 Coating Application and Maintenance Concern Number IN-86-273-001 1.2.4 Surface Preparation Concern Numbers IN-85-472-009 IN-85-511-003 1.2.5 Inappropriate Coating Concern Numbers IN-85-043-001 WI-85-077-001 1.2.6 Surfacer Deleted Concern Numbers IN-85-711-001 PH-85-040-001 1.2.7 Uncoated Welds Concern Numbers EI-85-059-001 IN-85-149-002 IN-85-192-001 IN-85-192-002 IN-85-243-002 IN-85-273-001 l
IN-85-451-001 IN-85-511-N05 l
IN-85-511-002 IN-85-833-001 WBN-NM-85-001 WI-85-013-005
_