View source for TXX-4225, Forwards Response to Section III of BNL Interim Rept on Protective Coatings,Per NRC .Commitment Made to Perform Destructive Testing on Coatings as Necessary. Response to Section IV Expected by 840720

{{Adams
| number = ML20114A019
| issue date = 07/16/1984
| title = Forwards Response to Section III of BNL Interim Rept on Protective Coatings,Per NRC .Commitment Made to Perform Destructive Testing on Coatings as Necessary. Response to Section IV Expected by 840720
| author name = Merritt J
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = Bangart R
| addressee affiliation = NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM), NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION IV)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| document report number = TXX-4225, NUDOCS 8501250491
| title reference date = 05-23-1984
| package number = ML20114A010
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 17
}}

=Text=
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TEXAS UTILITIES GENERATING COMi%NY P. o. box 1002        Gl.EN ROSE. TEXAS 76043 July 16, 1984 TXX-4225 Dockets:       50-445 g@MDMS  %
Mr. Richard L. Bangart, Director Region IV Comanche Peak Task Force                                             g    g7 g United States Nuclear Regulatory Commission                                       v 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 h
COMANCHE PEAK STEAM ELECTRIC STATION
                                                             '' NITS 1 AND 2 BROOKHAVEN INTERIM REPORT ON PROTECTIVE COATINGS FIIE NO. 906.1, 10010

==Dear Mr. Bangart:==

This responds to your letter of May 23, 1984, relative to the interim report on CPSES protective coatings prepared by Brookhaven National laboratory (BNL) . We have previously responded to each of the sixty allegatiota that you had received relative to the adequacy of protective coatings at CPSES (Letter: TXX-4201, dated June 22, 1984).
The attached responses provide information relative to Section III of the BNL Interim Report. We plan to provide a written response to Section IV of the 11NL Interim Report on or before July 20, 1984.
Please advise if you require additional information, ince        ,
Q I. Mer       , Jr' sista t Projec Manager JTM:la cc: Mr. Thomas A. Ippolito Mr. John Collins (w/o documentation) 8501250491 841106 PDR ADOCK 05000445 A                   PDR A Dit'INit>N t Dr TEXAN t*1ELETDEN ELKt"E REV VtbMi*ANY L

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Que stion -III. A.1 "                                                                                                                                       ,
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                                                            ,   .Backfit.. Program in)its entirety.'
Response III. A.1
                                                                                                                                                                                                ~
On September- 14-18, 1981 TUCCO QA Audit TCP-24 was performed on.-
Protective Coatings at: CPSES.- The findings of this audit- -identified deficiencies 'and concerns related to the Protective Coatings QA Program. The NRC's Region IV found' the same 'de ficiencies in' the'                                                                                -
i                                                                  Program and reported its.. findings Docket 50-446/Rpt 81-15"and i'
!                                                               . Docket 50-445/Rpt 81-15 dated November 6,1983 which was. responded to in Mr. 'R.J.                           Gary's letter to Mr. G.L.~ Maden, Chief Reactor
!                                                                  Projects Branch, I&E, dated November 19, 1981.
.                                                                  The . site's response to these findings are~ described 'in a memo from j                                                                                                       .                                                   -
R.G. Tolson, TUCCO Site QA Supervisor, to D.N. Chapman,' TUCCO QA                                                              .
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f'                                                                 Manager, -dated December 30, 1981'.:                               .
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i In the response, a commitment was made ' to perform. destructive Ltesting' 4
                                                                  .on coatings as necessary. - This'. destructive'' testing program has' become 1
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                                    .        to be 'known as 'the "Backfit Program". The details of the program are identified in the followitg procedures:
                                                     'QI-QP-ll.4-23 " Reinspection 'of Seal Coated and Finished Coated Steel Substrates for which Documentation is Missing:or Discrepant"
_ ., , .             ,                           QI-QP-I I .4-24        " Reinspection of-Protective Coatings of Concrete ,
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Substrates for which Documentation is Missing
                                                                      ,4 or Discrepant" Copies of all relevant documents including the procedure history i     files' are ' enclosed.
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p Question III. A.2 What is the, estimated total square footage of applied coatings
                                          'in Unit I contaiment? What ' portion of the total applied coatings represents coatings applied to. concrete : surfaces, miscellaneous
                                          ' steel and containment. Liner plate?                                                             '
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                                         ~ The tota.1, estimated foot _ age of protective coating's in Unit 1 p,            >,    -            -'
containnent is 618,'080 ft                            . This is distributed between the ~
various areas as follows:
                                                                     . Liner Plate'                              145,000 ft -      23.5%
                                                                   ' Concrete                                    285,000 . f t 2   46.0%
Miscellaneous Steel                         188,080.ft        30.5%-
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n Question III. A.3 Provide - the location and boundaries and define all areas that have been exempted from the Backfit Program. Also provide the justification for the exemption.
                   ' Response III. A.3 A)      Liner:       The location and boundaries of areas not' included in backfit inspection are shown on the enclosed map and-inspection reports (PCR). The areas not included in the '
                                                                                                                  .y inspections were either not coated at the time of backfit inspection or the surface was inaccessible for test equipme nt .
B)      Co ncrete :  The' location and , boundaries of areas included in the backfit inspection are :shown on the' 634 inspection reports enclosed. The areas not subjected to backfit inspection were: areas not coated at t he . t ime o f backfit. inspection, areas inaccessible to test equipment, ' and areas not inspected due to termination of the test program. ' Termination was the result of a -very high acceptance rate as demonstrated in the Response to Question III. A.12.
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4 C) . Miscellaneous: The location and boundaries of areas included in the
       .                                                                         backfit ' inspection are shown on the 2,189 inspection reports and printout's enclosed. The areas not subjected, to backfit were: areas not coated at
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                                                                                ..the time of the backfit inspection, areas inacessible to test equipment, and areas not inapected due to termination of the test ' program. Termination was the result of a very high acceptance rate.as' demonstrated in the Response to Question III. A.12.
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Provide the - percentage of' the ' three major areas (See Question 2),'
that' was included / exempted in the Backfit Program.
Respo nse " III. A.4
                                .A)       - Liner:                      Approximately 96%.of the surface was backfit inspected.
B)         Co ncrete :                  Approximately 50% of the surface was backfit inspected.
C)         Miscellaneous: Approximately 22% of the surface was backfit inspected. As agreed in a July 13,-1984 discussion with NRC project ' management, this figure was derived' from the information available for: pipe hangers, cable tray hangers and conduit ' supports. This information is considered to be representative _ of al'1 miscellaneous steel items.
        ,                                                               Lists of all hangers 'and supports -installed inside : the' containment and those .that were backfit are enclosed with Response III. A.3.-         1For calculational purposes it~
was assumed that all hangers and. supports inside the
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                                                                       ' containment were installed at the time of backfit, even though - we know. that some supports were- not installed           ;
                                                    .                   at the time- of: the backfit inspection. -                       .I i              , .       .
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i Question III.B.5
                                                     = Provide the operating procedure for instruments used during the .
                                                     .Backfit Program.
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The. operating procedures,.for the E1cometer Model 106 Adhesion
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Tester and Micrometrics Tooke Cage are in the manufacturer's instructions enclosed. Quality Control inspectors are trained and tested in the use of each of these instruments as shown on page 2 of the examination enclose'd .
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                             ' Question 'III.B.6 Provide indoctrination and training. records that demonstrate that those individuals per forming testire for the Backfit-Program were qualified.
4 j                            Response III.B.6 2                                            :      ,
f Enclosed are the indoctrination and training. records for each of the subject Quality Control-Inspectors: These records also include examinations and certifications.                                           >
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: Provide procedure reference for field checking of instruments during the 'Backfit- Program.
4 Response III.B. 7                                                                   ,
The only instrument requiring field checking is the Tooke Gage.
The method of performing this check is described in QI-QP-14.4-23 paragraph 3.1, enclosed with Response III. A.I.
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Questton III.C.8
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                                                       ;   Prov'ide instrument history /calibratio'n records of each instrument used in the Backfit Program.
_                                               Response -III.C.8 .
Records of calibration for the -adhesion testers and dry film thickness gauges are enclosedi There is no requirement for calibratirg the Tooke Cage as the. scale is built. into the' optics of the ' instrument.
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                                . Provide the method used to evaluate and ' account for. instruments found to be.out of calibration durits the Backfit Program.' How was and is -
the deviation incorporated in reporting E1cometer Adhesion Test results?
Additionally, ' for an instrument found out of calibration, provide documentation- that shows that all tests done with that instrument since its last calibration' were invalidated. . Also, provide the.
procedure used to handle those inspection reports written after the -
instrument went out of calibration.
Response III.C.9 i
The method used to evaluate ank account for instruments is described in
                                  . CPM 13.1, " General Calibration Procedure" (enclosed). Paragraph 3.7 details the handling of ' instrument.s found to be out of calibration.
Deviations are 'not incorporated 'in reporting E1cometer Adhesion Test results as the calibration department ensures accuracy within specified limits prior to issue.
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There have been no cases where the Elcometer Adhesion Tester was found to be out of calibration as procedurally prescribed during the backfit
                                       - program such that it rendered the previous tests invalid. Should such an
[                              instance {arise, ' Quality Engineering swobld have issued a nonconformance report (NCR) as' specified in CPM 13'.1, paragraph 3. 7.
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                ,         . Quest io n' III.C. l'0 '
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If' not provided in the. answers to Questions 7 and 8, provide the total number of- instrtunents - used in the' Backfit Program. Provide the type and
                               . serial number- of each instrument.                      .
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The . total number of instruments used in the backfit program was as follows: .
                                          ,,                         ,                 if (a.) Adhesion. testers             14          -
1 (b.) Tooke Cages                   10 (c.) DFT gauges                    341 I
The serial ntunbers or other permanent identification numbers are on the enclosed data and/or computer print-outs.                                       i m lu 9
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                                      ' Question III.D.11                                   '                               '
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Provide the total number of individual pull tests performed and the ntsnber of individual pull tests that failed for each of the three major areas .(See Question 2).
Response III.D.ll The total number of Adhesion dollies (individual tests) pulled -
                                              ' is 7711. The. breakdown by major area"is as follows:
Area      '
                                                                           -Number Pulled'          Number Failed Liner plate            -869 -                 20 Co ncrete               2128                  0 Miscellaneous -     ~ 4 714'    '
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Que st ion - III.D.12 -
Provide 'the ' final calculations for each of .the three major areas        >
                                        ~ (See Question 2) that demonstrates the estimate'd failure rate with its associated ' confidence LLnits, for each of the three major areas individually.-
Response III.D.12 As agreedt in the July 13, 1984 conversation with NRC project management the followiog response is for adhesion tests only. The mean failure rate of concrete adhesion dollies is zero mus their were no failures.
                                                                ~
If one- failure is assumed, then the 95% upper confidence limit is approximately 1/10 of 1%.      Thus even assuming one failure there is 95%
confidence that greater than 99% of the subject coatings on concrete in Unit 1 is acceptable.
The mean failure rate of miscellaneous steel adhesion dollies is 0.0055 ~
or 0.55%.       The 95% upper confidence limit is 0. 73%. Thus there is 95%
confidence that greater than 99% of the ' subject coatings on miscellaneous 2
steel in Unit - l ' have acceptable adhesion.
                                       - The mean failure rate of _ liner plate. adhesion dollies is 0.0230 or - 2.30%.
The 95% ' upper confidence limit is 3.14%. Thus there is 95%- confidence
;                                         that greater. than 97% of the subject coatings on the liner. plate in Unit 1-
                                                       . 1:
have acceptable adhesion.
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UNIT 1 BACKFIT ADHESION FAILURE ANALYSIS For each area, a one-sided confidence inte rval for t he inte rval for the binomial parameter p (the proportion of failures) was developed with CV = . 05,
                                     $<ff                                   E,og " l. 6'45 Co ncre te a           O                    4 2146 ' O          I     $'
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                        .. p < .0o,3 Liner Plate 4        20                       6 g*     869
                                              .0230    j   p*         9770 Pa < .0314

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List of Attachments 4                    Que st io n                     Enclosure                              Box Number 1-                                 (a) Abdit Report TCP-24                    4 (b) Memo: R. Tolson to                     4 D. Chapman,- 11/06/84 (c) Letter: R.J. Gary.to                   4 G. L'. Madsen, 11/19/84'
                                                          -(d) Procedures QI-QP-11.4-23                  4 and QI-QP-11.4-24 2                               None 3                                  (a) Map of Liner PCR'S                     4 (b) PCRs 1-Liner                           2 2-Co ncre te                  2 3-Miscellaneous               1 (c) List of Hangers                        4 Computer Print-outs 4                               None 5                                  (a) Manufacturer's Instructions            4 (b)    Inspectors Test 6                                  (a)    Inspectors training and             4 certification Records 7                               None 8                                  (a) M&TE Records DFT                       2/3 (b) - M&TE Records Adhesion Testers        2 9                                  (a) Procedure CPM 13-1                     4 10                                 (a) List of Adhesion Testers               4 (b)    List of DFT gauges                 .4 Computer Print-out (c) ' List of Tooke Cages                  4
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