View source for TXX-6157, Forwards Response to Request for Supplemental Info Re Coating Performance Program (Sser 9,NUREG-0797).Program Implemented on 850617 for in-process Coating Work Assures Integrity of Containment Coatings Throughout Life of Plant

{{Adams
| number = ML20207D774
| issue date = 12/16/1986
| title = Forwards Response to Request for Supplemental Info Re Coating Performance Program (Sser 9,NUREG-0797).Program Implemented on 850617 for in-process Coating Work Assures Integrity of Containment Coatings Throughout Life of Plant
| author name = Counsil W
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = Noonan V
| addressee affiliation = NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| case reference number = RTR-NUREG-0797, RTR-NUREG-797
| document report number = TXX-6157, NUDOCS 8612310192
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 11
}}

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Log # TXX-6157
           ,                                                                                                               File # 10010 906.2 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER . eeB NOftTH OLIVE STREE"F. l R. St . DALLAS, TEXAS 763DI December 16, 1986 E.Y1".Lff.UEL Mr. Vince S. Noonan Director of Nuclear Reactor Regulation Comanche Peak Project Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 SUPPLEMENTAL INFORMATION ON CONTAINMENT C0ATINGS PERFORMANCE REF: NUREG-0797, SUPPLEMENT 9, APPENDICES L AND M.

==Dear Mr. Noonan:==

Attached is Texas Utilities Electric Company's (TVEC) response to your staff's request for supplemental information regarding the CPSES Coating Performance Program referenced above.
l Very truly yours,
                                                                                   $*                                hw W. G. Counsil lU By:                             .
                                                                                                                       ,1       ~
M '-
l
                                                                                       'G.                       S. Keeley                      I Manager,NuclearLMensing GLB/grr Attachments (2)
CO l
I  I F612310192 861216 PDR   ADOCK 05000445 E                  PDR

4
                                                                                                                                                                     ;/
1 Attachment 1                                                                                                                                  s' TXX-6157                                                                                                                                       '       L, Page 1 of 3 l                    jj
                                                                                                                                                          -i    e' PRE-AND POST-OPERATIONAL                                             .'l           '
TESTING AND SURVEILLANCE                                            , 1,/
                                                                                                                                                        ,              e
.!              The following summarizes those actions taken to date and proposed future                                                      '
,               methods for assuring that protective coating work inside.the containment (s) at CPSES will reasonably maintain their integrity, without separating from the                                                                           ..
sur_ faces to which they have been applied. These actions and proposals are: ..
submitted to demonstrate TUEC's compliance with the intent of NUREG-0737,SSERu i:
9,-Appendix L, Section 3.0, and 4.0 and 5.0.                                                                                               I m            .
I. PROTECTIVE C0ATINGS APPLICATION, INSPECTION AND TESTING                                                                   1 0
.                                                                                                                                            ;                          e Consistent with the conclusions of Supplement 9 to the Comanche Peak Safety Evaluation Report (SSER-9), containment building coating work w'as                                                           f reclassified to a Non-Safety Related Activity. . Appropriate FSAR revisions were implemented to reflect this change in Quality classification.
s
.                      In order to demonstrate TUEC's commitment to assuring the integrity of                                                                              ;
J containment coatings throughout the life of the plant, a comprehensive                                                                               '
coatings engineering inspection and documentation program was established for in-process coating work. This program was implemented June 17, 1985, and is presently implemented in accordance with a series                                                                         '1 of procedures and instructions designated ECE-PC                                                                                                   -
(Engineering / Construction Engineering - Protective Coatings). These procedures provide programmatic and operating requirements for the                                                                               i implementation of the program, including:
                                                                                                                                                                 ,e A.                   Qualification and training of engineering inspection personnel.
l B.                   Inspection and testing procedures which specify:
;                                          1.              Detailed operational methods for each inspection and test;
: 2.              Inspection instruments and apparatus to be employed;                                                    's L
: 3.               Frequency of test / inspection routines;                                                                     q 1
: 4.               Acceptance criteria for each inspection and test; and                                                         .l
: 5.              Records to be generated to document inspections and tests.
C.                  Verification of coatings storage and handling.
D.                   Calibration requirements for measuring and test equipment.
E.                   Reporting, disposition and tracking of deficiencies identified.
F.                   Completion, issuance and control of documentation.
G.                   Maintenance and Control of the Unit 1 Coatings Exempt Log.
l l
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c Log # TXX-6157
, . ?, ,          ,
File # 10010
 ;n      -
906.2   <
TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER . 488 NORTH OLIVE errREET.1.B. 88 . DAt1AS, TEXAS 75301 December 15, 1986 s
i flvt MCE Po e e#7
.                      Mr. Vince S. Noonan Director of Nuclear Reactor Regulation Comanche Peak Project Division of Licensing                                                                                         ,
U.S. Nuclear Regulatory Commission Washington, D.C. 20555

==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 SUPPLEMENTAL INFORMATION ON CONTAINMENT C0ATINGS PERFORMANCE REF: NUREG-0797, SUPPLEMENT 9, APPENDICES L AND M.

==Dear Mr. Noonan:==

Attached is Texas Utilities Electric Company's (TVEC) response to your staff's request for supplemental information regarding the CPSES Coating Performance Program referenced above.
Very truly yours, W
W. G. Counsil By:
G. S. Keeley Manager, Nuclear Licensing GLB/grr      y Attachment (2) s 4
A inVssio% or TE%As LTil1TIFA FlFCTnte twerANY

    , Attachment 1                           '
TXX-6157 Page 1 of 3                                 4            -
PRE-AND POST-0PERATIONAL TESTING AND SURVEILLANCE The follow 1'hg summarizes those actions taken to date and proposed future methods for assuring that protective coating work inside the containment (s) at CPSES will reasonably maintain their integrity, without separating from the                                               j sur_ faces to which they have been applied. These actions and proposals are                                               '
submitted to demonstrate TUEC's compliance with the intent of NUREG-0797 SSER-9, Appendix L, Section 3.0, and 4.0 and 5.0.
I. PROTECTIVE C0ATINGS APPLICATION, INSPECTION AND TESTING Consistent with the conclusions of Supplement 9 -to the Comanche Peak Safety Evaluation Report (SSER-9), containment building coating work was reclassified to a Non-Safety Related Activity. Appropriate FSAR revisions were implemented to reflect this change in Quality classification.
In order to demonstrate TUEC's commitment to assuring the integrity of containment coatings throughout the life of the plant, a comprehensive coatings _. engineering inspection and documentation program was established for in-process coating work. This program was implemented June 17; 1985, and is presently implemented in accordance with a series of procedures and instructions designated ECE-PC (Engineering / Construction Engineering - Protective Coatings). These procedures provide programmatic and operating requirements for the implementation of the program, including:
A. Qualification and training of engineering inspection personnel.
B. Inspection and testing procedures which 'specify:
: 1.        Detailed operational methods for each inspection and test;
: 2.          Inspection instruments and apparatus to be employed;
: 3.        Frequency of test / inspection routines;
: 4.       Acceptance criteria for each inspection and test; and
: 5.        Records to be generated to document inspections and tests.
C. Verification of contings storage and handling.
D. Calibration requirements for measuring and test equipment.
E. Reporting, disposition and tracking of deficiencies identified.
F. Completion, issuance and control of documentation.
p, G. MaintenanceandControloftheUnit1andUnit2)CoatingsExempt n
Logy.                                                                                              -   -

                 ,
* Attachment 1 -
TXX-6157-Page 2 of 3 At the present time all coating application work is performed in accordance with engineering approved construction procedures. These procedures contain all those operating instructions necessary for the actual coating application, and are prepared in strict accordance with project specifications and the coating Manufacturers' written instructions.
The coating application, inspection, and documentation process as outlined above will be maintained throughout the Coating Application Program inside both containments. This program, or a similar program will also be implemented for coating repairs required throughout the life of the plant, as identified in " Operational Coating Surveillance."
II.                OPERATIONAL C0ATINGS SURVEILLANCE The following methods and criteria for operational surveillance for contai.nment building coating work shall be employed:
!                                                              A.              The. qualification and training of engineering surveillance personnel implementing the operational program will conform to the general requirements of the qualification / training program presently in effect for the in-process inspection program detailed in procedure ECE-AD-2-1, " Qualification and Training of Coating Field Engineers." Specific training and experience requirements will be established to ensure that persor.nel are qualified to perform surveillance.
Each Coating Field Engineer (CFE) must be physically capable of performing the assigned tasks and shall have natural or corrected near distance visual acuity.
Prior to performing work, each CFE will be trained to the requirements of all applicable specifications, procedures, codes and standards pertaining to their work. Subsequent revisions to any of these documents will require the same degree of training prior to implementation. Additionally, each CFE must demonstrate proficiency in the use of test equipment and inspection techniques outlined in the applicable procedures and instructions governing this work.
The CFEs will be provided technical direction by engineering personnel with appropriate experience and training in engineering and inspection of nuclear coatings. The Lead Engineer (responsible for coating and coating surveillance) will provide the necessary technical input and will coordinate the surveillance effort during operational coating inspections and application.
B.               Prior to plant operation and at each respective refueling outage, a protective coating surveillance walkdown of the Unit 1 or 2 ccatainment building will be conducted to identify and report any current or incipient coating degradation or failure. Coating surveillance walkdowns will be performed by qualified CFEs under the direction of the Lead Engineer responsible for coating and coating surveillance.

  . Attachment 1 TXX-6157 Page 3 of 3 The walkdowns shall consist of visual inspection of coated surfaces throughout the containment building, in accordance with approved Engineering Procedures. This visual inspection will be accomplished using optical aids such as binoculars where required.
Temporary scaffolding and supplemental lighting will be used as required in areas of particular interest.
Particular emphasis will be placed on examining those areas of coating work which nave been added to the Coating Exempt Log.        l Particular emphasis will also be placed on coating work adjacent to the sump areas at elevation 808', as failed coating in these areas have the greatest potential for migrating to the sumps under accident conditions.
Coating deficiencies or degradation identified during the walkdowns will be documented and mapped on applicable drawings. Additional inspection and testing may be required to establish the scope and severity of the deficiencies. An engineering evaluation will be performed and a determination made as to the methods, extent, and scheduling of appropriate repairs.
Concrete coating repairs, except where embedded plates exhibit corrosion may be based on a risk assessment of potential radiological exposure due to the extent of decontamination required to restore the surface. All work will be performed in accordance with ALARA guidelines for personnel performing these tasks.
All coating touchup and repairs will be performed by qualified personnel in accordance with the coating application, inspection
,                                              and testing program previously described.
l C. The program described in SSER-9, Appendix L. paragraph 4.1.1.
recommends the use of in-situ temperature and pressure testing for coating adhesion. We believe there is no need for this test to be part of our program for the following reasons:
Adequate assurance of the acceptability of coating initial conditions will be provided through the comprehensive backfit test program and final walkdown inspections.
In-service conditions will be verified with a thorough coating surveillance and inspection program during each outage.
This type of testing is destructive (to the coating) and, in view of the other actions prescribed by the program, is considered an unwarranted hazard to testing personnel.

l
                           ,     Attachment'2 TXX-6157 Page 1 of 5 ACTIONS REOUIRED OF TUEC-SSER-9, APPENDIX M, SECTION 4.
                                  "Although the TRT did not recommend any actions to remedy deficiencies in the coatings at CPSES, actions were required to document the status of existing coatings so that future inspection and test programs implemented to comply with SSER-9, Appendix L could.be based on known coating conditions,"
These " Actions Required" and-TUEC's response to each issue are contained in the following:
I .. BACKFIT TEST PROGRAM A.         Actions reauired of TUEC Apply the Elcometer calibration correction for the 4714 adhesion tests covering 2,189 miscellaneous steel items tested to establish a more reliable estimate of.the adhesion test failure -
rate. This revised analysis should include statistical analysis showing the 95% confidence upper limit of the failure rate for all miscellaneous steel items inside the containment building.
Analyze the corrected data to establish a more reliable estimate
:                                                 of the adhesion test acceptance criterion. Enter the resultant failed areas in the Protective Coating Exempt Log. The Coating Exempt Log will be used in planning future inspections of coatings, consistent with the guidelines of Appendix L (to SSER-9).
B.         TUEC's Actions and Results Regarding the Unit I containment coating, the Elcometer calibration correction data was applied to each Elcometer reading
;                                                . obtained during the period of improper calibration. A total of
:                                                   2,056 Protective Coating Reports (PCRs), documenting 4,882 individual adhesion test results were found to be affected, and
:                                                   were included in the analysis.
When the Elcometer calibration carrection was applied, it was determined that 490 of the 4,882 readings could have failed the minimum test criterion of 200 psi.
i An evaluation of the adhesion test results using a cluster sampling statistical analysis technique, determined that with a 4                                                   95% confidence factor as much as 20% of the coated surface on i
miscellaneous steel inside Unit #1 Containment could have failed the minimum test criterion of 200 psi.
1 i
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           .t - Attachment-2
                -TXX-6157 Page 2 of 5 Accordingly, thirty six thousand (36,000) square feet of coating on miscellaneous steel surfaces inside Unit #1 containment have been added to the Exempt Log.
II.      TRACEABILITY
                         -A. Actions Reauired of TUEC CPSES Nonconformance Reports (NCRs) C-81-01724 and C-81-01673 provide "Use-As-Is" dispositions for discrepant coating materials with inadequate technical justification for the disposition.
Accordingly, provide adequate technical justification to demonstrate the acceptability of.the batches of coating materials listed in the NCRs or, alternatively, identify and quantify the areas where these batches were used and place these areas in the Coating Exempt Log. Additionally, review all other NCRs which report discrepant or irregular conditions in coating materials.
For any such NCRs which were dispositioned "Use-As-Is", identify the batches and provide adequate technical justification for their acceptance, or identify and quantify the areas where batches were used and place these areas in the Coatings Exempt Log.
The Coating Exempt Log will be used in planning future inspections of coatings, consistent with the guidelines of Appendix L to this-Supplement (SSER-9).
B. TUEC's Actions and Results A compilation was made of all containment coating Nonconformance Reports (NCRs) pertaining to discrepant coating materials which have "Use-As-Is" dispositions. These NCRs were evaluated by the CPSES Coating Engineering Manager and an independant third party
:                               reviewer for technical adequacy of each "Use-As-Is" disposition.
All "Use-As-Is" dispositions have been found to be acceptable.
This list, along with the technical justifiction for each disposition was submitted to the NRC on TUGC0 Letter TXX-4613, dated November 18, 1985. No further action is required.
III. C0ATINGS PROCEDURES l
A. Actions Reauired of TUEC l                               The TRT found deficiencies in procedures and instructions for coating work and related inspection activities during the construction phase, which rendered them inappropriate or i                                inadequate for determining satisfactory accomplishment of i                                important activities. The TRT also found that the procedure review and approval system was inadequate to detect and correct these deficiencies.

   +-
l
             .                      - Attachment 2                                                                                                                                             '
                                              -TXX-6157 Page 3 of 5 Accordingly, make the necessary changes to the procedure review and approval system to assure review and approval by technically qualified individuals, to prevent recurrence of the types of deficiencies discussed in Coatings Category 4 (of SSER-9) and to
,_                                                                 assure that procedures are reviewed for consistency and clarity.
Apply this revised review and approval system to the .issurance and revision of all procedures which govern future coating work, inspection and testing at CPSES, consistent with the guidelines
;                                                                  of Appendix L to NUREG-0797, Supplement 9.
B. TUEC's Actions and Resulb
:                                                                  Pursuant to the receipt of Supplement 9 to the Comanche Peak
;                                                                  Safety Evaluation Report (NUREG-0797), TUEC took those necessary actions to implement a Non-Safety Related Containment Coatings Program at CPSES, consistent with the guidelines of SSER-9 Appendix L. These actions included a complete engineering review of the technical requirements for containment building coating work, which resulted in the complete rewriting of all procedures and instructions pertaining to coating application,. inspection, testing and documentation. These procedures were prepared and reviewed by engineering personnel who are technically qualified in nuclear coating work, to assure strict compliance with all i                                                                 applicable Codes, Standards, Project Specifications and the coating Manufacturer's written instructions.                                      Specific attention was directed toward correcting those procedural deficiencies identified by the TRT in Coatings Category 4 of SSER-9, relative to the use of Non-DBA qualified coating systems and inadequate or
;                                                                  inappropriate technical requirements for coating work.
In conjunction with the overall revision of the CPSES Containment Coatings Program; procedure CP-EP-6.2, " Review and Approval of Engineering Procedures for Verification of Protective coating Work Inside Containment" was developed and implemented June 13, j                                                                 1985. This procedure required technical review and approval of                                                            ,
all coating inspection and documentation procedures by the i
Coating Engineering Manager and the Unit #2 Project Civil Engineer.
i                                                                  Subsequent to this procedure issuance, all coating engineering i                                                                  procedures were incorporated into the TUGC0 Nuclear Engineering (TNE) Manual. At this time, the requirements of CP-EP-6.2 were incorporated into procedure TNE-AD-3, " Preparation of Procedures i                                                                  and Instructions."
T l                                                                  NOTE:    Due to a reorganization move, the TUGC0 Nuclear Engineering Manual is evolving into the Engineering / Construction Engineering Manual.
I i
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__           _                             ___                  _                   .. _ _ _ _                           _   m l
3 - Attachment 2
:                    TXX-6157' Page 4 of 5 IV. C0ATINGS EXEMPT LOG (CEL) 4.
A.      Actions Reauired by TUEC Provide updated estimates of the additional items, including those detailed in Coatings Category 6 to be entered in the Exempt Log. Although all coatings are now considered exempt, maintain the CEL separately to identify all items which did not meet the requirements in affect at the time the coating work was performed. The CEL will be used in planning future inspections consistent with the guidelines of Appendix L of NUREG-0797, Supplement 9.
B.      TUEC's Actions and Results
: 1)               Elcometer Calibration Error Based on the study performed on the affects of Elcometer adhesion tester calibration deficiencies on miscellaneous steel coatings inside the Unit I containment building, it has been determined that as much as 20% of the coating could have actually failed the adhesion test criterion.
Accordingly, thirty six thousand (36,000) square feet of coating on miscellaneous steel surfaces have been added to the Unit 1 Protective CEL.
: 2)               Unsatisfactory Dry Film Thickness Based on the TRT's determination that the coating dry film thickness failure rate on miscellaneous steel surfaces in Unit I containment was as much as 8.5% for the miscellaneous steel categories, TUEC's original estimate of 5% may be low.
Accordingly, the amount of miscellaneous steel coating placed on the CEL as a result of unsatisfactory dry film thickness areas identified in NCR C-83-03103 Rev. 2, C-83-03104 Rev. 2, and C-83-03105 Rev. 2 has been increased from 8,155 square feet to 13,863 square feet.
: 3)              Non-Standard Coatings
:                                                   TUEC estimated that 2,500 to 6,500 square feet of inorganic zinc coating was applied over organic topcoats in overlap
,                                                    areas that surround repairs to protective coatings over J
steel. The resultant coating system is not DBA qualified.
Accordingly, 6,500 square feet of coating has been placed l                                                  on the Unit 1 Protective CEL to document non-standard coatings.
i i

  .-   Attachment 2 TXX-6157 Page 5 of 5
: 4) Inaccessible or Limited Access Areas TUEC letter TXX-4262 to the NRC dated August 21, 1984, describes 6,100 square feet of coating work applied in inaccessible or limited access areas which did not meet the requirements of Specification 2323-AS-31.
Accordingly, 6,100 square feet of protective coatings have been added to the Unit 1 Protective CEL to document coating applications in inaccessible or limited access areas, where all specified requirements were not met.
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