ML20205Q763
| ML20205Q763 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, 05000000 |
| Issue date: | 10/12/1984 |
| From: | Shao L NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | Ippolito T NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| Shared Package | |
| ML20204J134 | List: |
| References | |
| FOIA-85-59 NUDOCS 8606030232 | |
| Download: ML20205Q763 (138) | |
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Nl OCT 121934 EEP.ORMiDt!.f' FOR: Thor.as A. Ippolito Project Director Comanche Peak Technical Review Tean FR.0!;: Lawrence C. Shao, Leader Civil /l:echanical Team Cemanche Peak Technical Review Team-SULJECT: POTErlTIAL OPEM ISSUES OF C0f7.NCHE PEAK TRT REVIEL' IN
, NECHMiICAL/ PIPING AREA l
We havt reviewed 147 allegations related to TRT effort-in the mechanical / piping a m? , The following are five potential open issues which we found m.y have potential safety significance and require action on the part of utility:
a, Inspection for certain types of skewed welds in NF supports,
- b. Impreper shortening cf anchor bolts in steam ger.crator upper latertl supports,
- c. Design consideraticns for piping systens between Seismic Category I and non-Scismic Categcry I buildings,
- d. Uncontrolled piug wcids,
- e. Piping installaticr prcbleps.
j A brief description of those potential open issues and required actions are enclosed, anc we are ready to make the presentation to the liRC maragtment and the applicant, j
/5 Laurence C. Shao, Leader Civil / Mechanical Team Cccanche Peak Techt.ical Faview Tear'
Enclosure:
es stated cc w/ crc 1: RLMinogue DISTRIBUTION GFRoss DAS files i GAArlotto LCS Subj/RF DGEi:or. hut LCShao JGagliardo SMou RETYPED FOR MIi40R (HANGE " SEE PREVIOUS CONCURRENCE.
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l t:cchar.ical & Piping Ogn issues
- a. Inscection for certain types of skewed welds in NF supports The TRT investigated inspection procedures of Erewn & Root (B&R) for welds in pipe su; ports designed to ASME III Code, Subsection NF. The TRT found that no fillet weld insoection criteria existed for certain types of skewed welds. By definition, skewed welds are those welds joining (i) two nonperpendicular or non-colinear structural members, er (2) two members with curved surfaces or curved cross secticns, such as a pipe stanchion (a section of pipe used as a struc'. ural metter) welded to another pipe stanchien or to a curved pipe pad.
hotice that for type (2), the effect of curvature at the weld connection induces skewed considerations, even though the two joining members are physically perpendicular. The B&R weld inspection procedures CP-QAP-12.1 and QI-QAP-11.1-28 for tiF support have addressed the type (1) skewed weld, hcwever, the TRT found that GI-QAP-11.1-28 did not include weld inspection criteria for type (2) skewed welds. Although the TRT was told by S&R personnel that a procedure for piping weld inspection, QI-QAP-11.1-26, was used since such weld connections were similar in configuration to a pressure boundary stanchion attachtrent weld, no evidence documenting the use of this inspection procedure was prcvided to the TRT. According to records reviewed by the TRT, these welds were actually categorized as "all other welds" rather than " skewed welds" on the required QC checklist. Instead of using fillet weld gages for measuring the size , of ncrskewed welds, a type (2) skewed weld'shall use a straight edge and,a-steel scale'for measurement as cescribed in 01-QAP-11.1-28. In addition, due to the varieble profile along its curved weld connecticn, the weld size shall be measured at several different locations. The lack of inspection criteria and lack of verification of proper inspection procedures being conducted for type (2) skewed welds are a v,iolation of ASME Code for NF supports comitted by TUEC in FSAR Section 5.2.1'and a violation of Criterion
' XVII in Appendix B of 10 CFR 50.
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The TPT revies.e ws Ir ins;":t ion t rocedures, welc cata carcs, and visually ir.srected several typt (2) skcv.ed welds in rancor ly sar ple; fd support s wherc pipe stanchions were used. Although the rcsults of the TRT inspection of this scall sar:ple of welds are acceptable, due tc deficiencies in inspection records and the apparent lack of inspection criteria, the TR1 is not certain whether other type (2) skewed welds were inspected properly.
This is a generic issue involving many NF supports in varicus safety related syster.s. The lack of decur.ented inspection and criteria for type
(?) skewed welds in NF supports represents a safety concern of possible existence of under-sized welds in these supports, which are required to resist various design leads.
Accordingly, TUEC shall (1) Revise B&R weld inspection procedures CP-0AP-21.1 and CI-0AP-11.1-28 to properly address type (2) skewed welds of stanchien to stanchion and stanchicn to pipe pad, and (2) provide evidence to verify that previous inspection of these types of skewed welds were performed to the appropriate procedures.
- b. Improcer shorteninc of anchor bolts in steam cenerator urter lateral supports i.i The TRT was inforred that some anchor bolts in the stear cenerator upper v ]L,
support teans were shortened to a length less than sheen on the design Ns s drawinc without proper authorization during installation of the teams. Tne w
TRT was tolakthat the bolt cutting incident' occurred when either the hole of the anchor device was filled with debris, or the thread portion of the bolt had concrete mix stuck to it. There are totally 144 bolts with 18
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bolts at each end of 4 beams, and one beam for each steam generator. The bolt has thread engage ent with an anchor device entedded in the concrete wall. The acceptable bolt length or the length of bolt thread engagement
, with the anchor device is vital to ensure structural capability of the-support beams.
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The TFT a t ter.pted to review TUEC records for ul trasonic (UT ) r easurement results anc general installation. The TRT was told that ultrasonic testing of these types of bolts was not a procedural requirenent, however , TUEC was unable to provide any other installation records for TRT review. The TF.T concludes that such unauthorized bolt cutting and lack of installation inspection records is a violation of OA procedures and Criterion XVII in Appendix B of 10 CFR 50. Since the support beams are essential to provide lateral restraint for the steam generator during a LO~.A or seismic event, adecuate anchoring capability of the bolts has safety significance, and appropriate measure is needed to ensure conformance of Ceneral Design Criterion 1 of 10 CFR 50.
Accordingly, TUEC shall provide evidence such as ultrasonic measurement results to verify acceptable bolt length. Shoulo unauthorized bolt cutting be verified, TUEC shall:
(1) replace shortened bolts with tolts of proper length, or provide analysis to justify the adecuacy of shortened bolts as installed, and (2) provide justification or propose measures to ensure that no similar concern exists for bolting.
- c. Desian Consideration for Picing Systems Between Seismic Category I and Non-Seismic Category I Buildings In April 1984 the Commanche Peak Special Review Team (SRT), formed and coordinated between NRR, IE and Region II ~and IV, perforced a limited review of Commanche Peak. The TRT, in reviewing the SRT findings in the area of piping design considerations, has discovered tho* en area of concern has not been addressed. Piping systems such as Main Steam, Auxiliary Stean and Feedwater are routed from the Electrical Control Building (Seismic Category I) to Turbine Building (Non-seismic Category I) without any isolation.
To be acceptable, each Seismic Category I piping system should be isolated from any Non-seisaic Category I piping system by separation, barrier or c ons traint.
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If 1 solation is not feasit.le then the ef fect on the Seisr.it Category I
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] piping of t he failure ir. the Non-seismic Category 1 piping must te consicered j
(CPSES FSAF 3.78.3-12.1).
In the case of CPSES, the FSAR, section 3.78.2.8, establishes tnat the Turbine Building is a Non-seismic Category I structure and failure is postulated during the seismic (SSE) event. The ef fect of Turbine Building failure en any Non-isolated piping routed through the Turbine Building froT any Seismic Category I building must te considered.
4 In addition, for Non-seismic Category I piping connected to Seismic Category I piping, the dynamic ef fe, cts of the Non-seismic Category I piping must te censidered in the seismic design of the Seismic Category I piping and supports, unless the applicant can show that th- fynamic ef fects of the Non-seismic Category I piping are isolated by anchors or restraints. The anchors or restraints used for isolation purposes must be designed to withstano the combined loading imposed by both the Seismic Categcry I and Non-seismic Category I piping,
, lA TUEC shall provide documentation that the piping systens routed from Seismic Category I to Non-seismic Category I building meet the stated FSAR criteria.
- d. Plue Welds The TRT investigated alleged generic problems regarding uncentrolled repairs to holes in Units 1 and 2, which had teen nisdrilled during fabrication, by plug welds. The welds were alleged to exist in pipe supports, cable
< tray supports and base plates. Since these supports are Seismic Category I .
supports and their effects have not been evaluated, this constitutes a violation of Criteria IX and XVI of Appendix B to 10 CFR 50. Region IV.
inspections have confirmed the existence of such welds in cable tray supports located in the Unit 2 Cable Spreading Room. 1 l
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.f Although the ef fects of unauthorized, undocunented and uninspected plug welds in somc locations (e.g., the webs of I-beams or in structural members in compression) will be incensequential, their effects in critical locations (e.g. , flanges of I-teams in flexure or in structural me-ters in tension) in critically loaded supports or base plates could affect their structural integrity and intended function.
Accordingly, TUEC shall perform one of the following:
(1) Modify its proposed inspection plan to P.egion IV (TXX-4183 and TXX-4259) to include inspections of all areas of the plant having plug l
l welds which include cable . tray supports, pipe supports ano base plates; and to prepose alternate methods of inspection where the oblicue lighting rethod is not viable (e.g., locations covered by heavy coats of paints). Ferform assessments of the effects on quality due to uncontrolled plug welds found during the proposed inspections a s modified above. A report documenting the results of inspections-and assessments shall be submitted to the TRT for review.
(2) Perfom bounding analyses to assess the generic effects .of uncontrolled plug welds on the ability of pipe supports, cable tray, supports and base plates to serve their intended function. A report documenting the results of assessments shall be submitted to the TRT for review.
- e. Installation of Main Steam Pices The TRT investigated an allegation that a Unit 1 main steam line, which had beeg installed incorrectly, had been forced into proper alignrent after flusing operations by use of the main polar crane and come-alongs. It was
'so claimed that pipe supports had teen modified to maintain the line in its forced position and vibrations following detachment of the flushing line cculd have damaged the main steam line. Based on its investigations, the TRT detemined that the alleged incident related to restoration of the Unit 1, loop 1 main steam line to its initial, correct
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installati0r, position (the line had shif ted during flushing o; erat icr.s due to the w(ight of added water and sagging of tc..gorary surforts). The TRT also determined that the r:odifications to pemanent pipe supports were necessary not as alleced, but only to provide proper support to the n.ain steam line in its restored position (initial designs for and construction of the supports had been based on the shifted position of the line) and although the alleged viorations could not be confirmed, their associated stresses might not have damaged the main stear line (the highest stresses would have occurred in the weaker, temporary flushing line). The TRT reviews of a TUEC analysis, performed 1 year af ter the incident, concluded that the analysis was incomplete. Evaluation for the full sequence of events leading up to the incident had not been performed. The TRT review of Gibbs & Hill Specification No. 2323-MS-100 indicated that the requirements for (and the resulting Brown & Root construction practice related to) the support of the main steam line during flushing and temporary supports for piping and equipment in general were inadequate. In particular, evaluations to assure the adequacy of temporary supports during flushing and installation were not required. The deficiencies in the analyses, specifications and construction practice identified above constitute a violation of Celterion V of Appendix B to 10 CFR 50.
Accordingly, TUEC shall:
(1) Modify Gibbs & Hill Specification No. 2323-MS-100 requirement, and institute procedures for support of the main steam line during flushing and temporary supports for piping ard equipment in general to assure that the quality of affected piping and equipment are not affected.
(2) Perform an assessment of stresses in the portions of the Unit 1, loop 1, main steam and feedwater lines that were affected in the sequence of events involved during their initial installation, flushing and final installation. Conditions of concern are:
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- a. Flushing condition when the lines were full Of water and te.nperary supports had sagged or settled.
- b. Disconnecting condition when vibrations of the ten.porary line could have occurred.
- c. Lifting conditon when forces were applied by the polar crane and c ane-a l ong s .
Tnese assessments shall be based on appropriate piping configurations invol ved.
(3) Perfom a non-destructive examination of locations in the Unit 1, loop 1, main steam and feedwater piping involved where stresses greater than relevaht stress allowables were exceeded during the
, conditions of concern in a. through c. above.
(4) Review the existing baseline UT examinations for those portionr. of the Unit'1, loop 1, main steam and feedwater involved in all the conditions
, of concern in a. through c. above for unacceptable indications.
(5) Review records of hydrostatic testing of the main steam and feedwater line to verify quality of piping involved in the incident.
(6) Provide similar assessments for circumstances involvea in a lifting incident identified during the TRT inspections for_ the Unit 1, locp 4, main steam line.
(7) Provide assessments of effects on quality of safety relatec piping and equipment which were involve 1_in_sicilar ip_c.idents of sagging, settlements and failures, if any, of temporary supports. )
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(8) The results of analyses, examinations and reviews shall be documented and submitted in. a report for TRT review.
j CNMMM i CPSES NRC TRT DRAFT 1 SSER - COATINGS ,4 8 NOV 84 COATINGS PROCEDURES W. C. WELLS
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TAGE 1 ,
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[! 1. Allecation Grouo: Coatings 4 - Coatings Procedures J2 -
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! 2. Allecation Number: Parts of AQO-01, AQO-02, AQO-03, A00-04, ,
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AQO-05, ACO-06, AQO-07, AQO-08, AQO-09, AQO-10, AQO-ll, AQO-12, AQO-15, AQO-17, AQO-18, AQO-19, AQO-20, AQO-23, AQO-24, AQO-31, '
AQO-34, AQO-36, AQO-38, AQO-39, AQO-40, AQO-41, AQO-42, AQO-43, AQO-44, ACO-45, AQO-48, AQO-49, AQO-51, AQO-58, and AQO-62. . . .
- 3. Characterization: _
It is alleged that:
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A-ComanchePeakSteamElectricStationJCPSES) coating work _
procedures and related instructions allowed the use of coating i
, systems and application methods that were not Design Basis Accident f
(DBA) qualified. Specific allegations are: .
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~! - CPSES procedure CCP-40, paragraph 4.3.1.2, allows application of Imperial coatings in the sequential order #11S/1201/lls/1201 or
- 11S/1201/11/1201. (AQO-01)
- CPSES Nonconformance Report (NCR) #C83-01752, June 23,1983, and Table A2 in Appendix A of CPSES specification 2323-AS-31 allow repair coatings to be applied in sequences different from the original application sequences. ?
(AQO-02) s I
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CPSES NRC TRT DRRFT 1 SSER - COATINGS 4 8 NOV 84 COATINGS PROCEDURES W. C. WELLS PAGE 2 ~~ .
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, - CPSES Design Change Authorization (DCA) #17,142, revision 2, I d
!! allows application of Carboline Phenoline 305 (P-305 )"6ver 'anoth'er d
ll man'ufacturer's epoxy coating.
(AQO-03) ,
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.. ~7 ll - CPSES DCA #12,374, revision 1, allows Carboline Carbo Zinc 11 (CZ-11) to be topcoated with Imperial 1201. (AQO-04)
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, - CPSES procedure #CCP-30A, revision 2, paragraph 1.3.1 allows .,, ,.
l application of P-305 over Ameron Dimetcote 6 (D-6). (AQO-05) i, 1
- CPSES procedure #CCP-40, revision 5, paragraph 4.1.1.3 allows application of Imperial Nutec ll'S sur' facer over foreign objects embedded in concrete. (AQO-06) - -
- Inorganic zinc application in three coats is allowed. (AQO-09) l i . . I
_, - CPSES DCA #18,489, revision 1 allows primer to be applied to a thickness of 0.5 mils. (AQO-ll)
- CPSES procedure #CCP-40, revision 5, paragraph 4.3.1.2 allows the Lnperial coating system 11S/1201/11S/1201 to be applied to a thickness of 102 mils. (AQO-12)
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- CPSES procedure #CCP-30, revision 11, paragraph 4.4.3.0 allows CZ-11 or Carboline 191 primer'(191P) to be applied over P-305, and P-305 to be applied over Imperial 1201. (AQO-15)
1 CPSES NRC TRT DRAFT 1 SSER - COATINGS'4 8 NOV 84 COATINGS PROCEDURES -
W. C. KELLS
-PAGE 3 -' ,
B - CPSES coating work procedures and related documents include I instructions which are technically incorrect. Specifid aliegations a r e': -
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- CPSbS NCR #C83-01986 provides a repair disposition for cr-acking and flaking of concrete coatings which will not remedy the cause of the deficiencies. (AQO-07)
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-CPSES procedure #CCP-30, Rev. 11, allows inorganic zinc primer to be applied over zine residue which will cause adhesion problems and prevent galvanic action. (AQO-08)
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- TUGCO procedure QI-QP-ll.4-5, revision 27, paragraph 3.2.2.3 permits acceptance of non-qualified and technically inadequate _
power tool cleaning methods for surface preparation. (AQO-10) 4 j - The method used at CPSES to remedy high dry film thickness (DFT) of CZ-ll will result in poor adhesion of the topcoat. (AQO-38)
- Applied P-305, one and two years. old was topccated with new P-305 with little or no surface preparation. (AQO-39)
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- Residues-resulting from power tool cleaning of surfaces were
. removed by improper methods. (AQO-40) t e
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CPSES NRC TRT DRAFT 1
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SSER - COATINGS 4 8 NOV 84 COATINGS PROCEDURES W. C. WELLS PAGE 4 ,
- A foreign cleaning solution was used to wipe surfaces ibmediately I
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- j prior to repairs. (AQO-41)
- ! a i - The methods used at CPSES to verify the cure of inorganic zinc ,_ .f primers are not adequate, and inorganic zinc primers are not ,
properly cured prior to topcoating. (AQO-43)
- The " nickle test
- for verifying the cure of inorganic zinc . . . .,
primers prior to topcoating was not performed properly. (AQO-44)
C - Backfit inspection procedure's and'metho3's were inadequate.
Specific allegations are: 1
- Q.C. Inspectors were not allowed to identify visual defects during backfit inspections. (AQO-18) ,
- TUGCO procedures QI-QP-ll. 4-23 and QI-QP-ll. 4-24 are very vague regarding the way that backfit inspections are to be conducted, (AQO-19) i - Adhesion tests of protective coatings were not properly performed.- (AQO-20) ,
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.g f - Excessive thinning of P-305 'resulted in a weak and brittle film l and made it ig.possible to obtain a Tooke gauge reading. (AQO-51) 4
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i CPSES NRC TRT DRAFT 1 SSER - COATINGS'4 8 NOV 84 COATINGS PROCEDURES W. C. WELLS PAGE 5 ,
D - Coatings were applied to surfaces where they should not have
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been applied. Specific allegations are:
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- Q Coatings have been placed over rusty, scaly unprepared metal *
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- surfaces inside pipe supports made of tube steel without end-caps.;
(AQO-24) -
- Imperial 11S and 1201 were applied over duct tape and foam rubber
.on Richmond Inserts. (AQO-42)
- Coatings were applied over joints which were filled with foam.
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(AQO-4&) -
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- Overspray was allowed in areas which had been inspected' ,
previously. (AQO-49) 1 E - Quality Control Inspections were inadequate. Specific allegations are:
- Tests of the cleanliness of compressed air used for spray i application of coatings were invalidated due to the practices of
- production. personnel. (AQO-17) '
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} - The coatings Q.C. program at CPSES is inferior to such programs 6
at other nuclear power plant project. (AQO-23) l L1 ;
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i CPSES NRC TRT DRAFT 1 l SSER - COATINGS 4 8 NOV 84 i COATINGS PROCEDURES W. C. WELLS l -PAGE 6 -
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I - QC management ' interpreted an SSPC-SP-6 blast requirement given on a CPSES DCA as "do the best you can" and told the QC 16spsct' ors
! "no't to worry" about difficult access areas.
(AQO-31) 3 1 . F.
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- Repairs of defects have been accomplished with no reinspection of the defects. (AQO-45)
- CPSES QC inspection procedures require that inspections be , , , ,
'. performed with inadequate light. (AQO-58) i i
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F - Procedures were inadequate t'o ass'ure coating materials traceability. Specific allegations are: -
- The requirements of ANSI /ASME N45.2.2-1978 were not met for a
material-storage. (AQO-34) '
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- The traceability of coatings materials was not always maintained.
(AGO-36) r - Some paint used at CPSES in Service Level I areas was 1
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'l contaminated with grease and oil prior to application and was l
. applfed anyway. (AQO-62) -
i f 4. Assessment of Safety Sionificance: The implied safety significance of these allegations is that the use of improper l I
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CPSES NRC TRT DRAFT 1 1' SSER - COATINGS'4 8 NOV 84 COATINGS PROCEDURES -
W. C. WELLS ll -PAGE 7" ,
f procedures for performing and inspecting coating work could result
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in defective finished work. Defective coatings could fail'during service and interfere with the functioning of engineered safeguard
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systems. An evaluation of the significance of this safety concern.i is reported- in {......LATER}. The Technical Review Team (TRT) evaluation of the quality assurance aspects of these allegations, as characterized above, is discussed below.
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The TRT reviewed the procedures and instructions which, governed the performance and inspection of protective coating work at CPSES' to determine the acceptability of those procedures and
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instructions and to verify the ihclus' ion of appropriate- .
quantitative and qualitative acceptance criteria for determining that important activities have been satisfactorily accomp'ished. ,
l The TRT reviewed the measures established at CPSES to control the review, approval, and issuance of instructions. and procedures and revisions thereto. The TRT also observed coating work activities and reviewed coating work records to determine whether important activities had been accomplished in accordance with the governing procedures and instructions. ,
The TRT also performed a detailed review of procedures related
, to specific allegations, grouped in several generic or functional ,
areas. This review included an evaluation of the adequacy of the written procedures as well as the normal practice ~s followed for j performing coating-related activities at CPSES. Many of the
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- specific allegations discussed below have also been considered
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CPSES NRC TRT DRAFT 1 i SSER - COATINGS 4 8 NOV 84 CCATINGS PROCEDURES W. C. WELLS
-PAGE 8 " ,
separately in other Coatings SSER functional groups; they are included herein as well for consideration of their predednral elements. - '
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. .. t General Review of CPSES Coating Work Procedures and -
Procedure Control System
The TRT interviewed responsible supervisors, engineers, and ,,. .
-managers, reviewed correspondence, and reviewed applicable procedures to evaluate the methods used to control the review, hpproval, and issuance of instructions and procedures and revisions thereto'.
Work instructions and requirements for coatings applied a't ,
CPSES are given by Brown & Root procedures CCP-30, CCP-30A, and CCP-40. Inspection methods and requirements are given ,
by a number of procedures given QI-QP-ll.4 designations; specific inspection procedures and requirements are identified as apptcpriate elsewhere in this SSER and SSER's Coatings #1, 2, 3, 5, 6, and 7.
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i The TRT reviewed the following TUGCO procedures, which !
provide requirements for the review, approval and issuance of procedures used for' coatings inspection:
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) CPSES NRC TRT DRAFT 1 SSER - COATINGS ,4 8 NOV 84 COATINGS PROCEDURES -
W. C. WELLS PAGE 9 ,
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.i Quality Control organization.
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- C'P-Q P-6. 0, revisions 2, 3, and 5, " Preparation of Quality 1 .
Procedures and Instructions. ,,
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- CP-QP-7.1, revisions 2, 6, and 9, " Issuance and Control of Quality Procedures and Instructions."
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The TRT reviewed the following Brown & Root procedures, . .
, -which provide requirements for the review, approval and issuance of procedures for coating work operations:
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- CP-CPM-6.1, revision 4, "Prepar'ation'& Approval of Cdnstruction Procedures & Instructions" _
- DC P - 3 , revision 18, "CPSES Document Cont,rol Program" The TRT found evidence to indicate that these procedures are implemented in a manner to satisfy specific requirements.
The TRT considers that these procedures to'not provi?.e adequate controls in the following. areas:
- The TRT found that inspection procedures reference construction procedures, and. require inspectors to verify l requirements or use methods described only by the construction procedures.
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CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 8 NOV 84 COATINGS PROCEDURES '
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} Further, the TRT found that the referenced construction
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procedures are not issued to inspection personnel as controlled copies.
- An example is given in the discussion of ,
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allegation #44. .
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- The TRT found that the qualifications of personnel who review and approve procedures do not demonstrate their ability to perform these functions. Examples are discussed , ,
in SSER's - Coatings 2, and 7.
- In the'CPSES FSAR, TUEC commits to ANSI. N101. 4-1972. This
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standard requires that the coati _ng mahufacturer approve-application procedures. The TRT found that evidence to show that such approvals are only periodically obtained for ,
construction. procedures, and that such approvals as are available are not controlled in a manner adequate to assure their proper use and retention. Further, the TRT found no evidence of manufacturer approval for important revisions to requirements.
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+
,.mm*
.. ~ . . . . . . _ . . _ _ . .- - .. . . _ . , . ..
- .. .-- . - - .. .... .-- -... .-- -.~.-.. - -.4 - i-- - X- ~ - ~ ~ - - -
.( .. -
l 9
l
}
DRAFT 1 SSSR - COATINGS 4 . -- 8 NOV 84,,
I COATINGS PROCEDURES W. C . WELLS
" ,! PAGE 11 -
Review of, Individual A1.iecations:
j l
~
, }.
A. Allegations AQO-01, AQO-02, AQO-03, AQO-04, A00-05, ,./
.. 't AQO-05, AQO-09, AQO-ll, AQO-12, and ACO-15, are all concerned with Design Basis Accident qualifications of .
coating materials, systems, and procedures used at Comanche Peak. It is alleged that the governing procedures and
. Instructions allowed the use of coating systems and application metheds tha.t were not D*dA qualified.
Mcst oT the allegations in this group concern special non-standard coating systems, which .were e; ployed at CPSES
.- a for coating repairs or overlaps between different systems or between repairs and originally' applied coatings.
A detail'ed evaluation of each of these allegations is provided in SSER - Coatings 2. The following is a summary of the TRT's findings in regards to these specific fLh}\f ,,,j ,y,/,$O-69s:
un.me. u ne m,ssedha.!!u e n ese etewsihouiYt.t& v s r e c sLn 06- .
Q?7 b CGII9n]
allegation's, as reported in SSER Coatings 2.biolation of procedures and is not technically incorrect or contrary to data.provided by DBA testing.
1
- - , - - . _ _ , _ . . . . _ _ . . .. .,_.m..., . . . . , _ . _ . . , _ . _ . _ . . . , . , _ _ , _ , , ,,
I CPSES NRC TRT DRAFT 1 I
SSER - COATINGS 4 8 NOV 84 COATINGS PROCEDURES . .. W. C. YELLS l
PAGE 12 t
1 The TRT found that the systems described by the other i . ..
I allegations in this group were not supported by adequate DBA testing data.. However, the systems described by three of , ;. ,
the. allegations, AQO-03, AQO-04, and AQO-ll were properly 'Y.
handled by TUEC, by entry of the affected items into the -
protective coatings exempt log (CEL. ) The systems described in the remain'ing six allegations, AQO-01, AQO-02, AQO-05, ,
AQO-06, AQO-12, and AQO-15, were used only in limited areas .
of caerlaps and repairs.
The TRT's.- evaluation of these allegations which is provided .
. in SSER Coatings 2, as summarized'above, fo used upon th'e significance of the use of coating systemi~for which DBA qualification testing data was inadequate. The TRT's evaluation of these allegations which is reported herein is concerne.d with the subject of the adequacy and appropriateness of CPSES procedures and methods which permitted the use of these non-qualified coating systems.
In investigating this subject, the TRT reviewed pertinent CPSES procedures and specifications, referenced below, the specific DCAs and related supplementary in'struction documents described in the allegations, and the governing
.American hational Standards Institute, (ANSI), standards, ANSI N101.4, N101.2, and N512. The TRT also evaluated the subject of coating system overlaps,, interfaces, and repairs, l from a technical standpoint and with consideration of I
- - . . _ - .-- - ~. . . . . . - -.
! SSER - COATINGS 4 8 NOV 84 COATINGS PROCEDURES - - -
W. C.. WELLS
, PAGE 13 -
1 standard industry practices at other nuclear power plants.
'i The-governing ANSI standards provide specific methods for qualif'ication- testing and evaluation of coating systems, and ,
), ,
A that ANSI N512 section 5, "Repairability and Maintenance. 5 Test," provides for testing of repair systems and methods'ln accordance with the same test methods and evaluation criteria which are used for testing. of the original coating ,
systems. The TRT also found that throughout ANSI N101.2 and -
N512 reference is made to the coating manufacturer's recommendations as a basis for procedures for coating work, includ,ing_gepairs, both for the preparation of test
. specidens and for the performance of actual coating wor'N in nuclear plants. .-- a The TRT recognizes that coating manufacturers' recommended precedur.es for the use of their products cannot be comprehensive enough to address every possible circumstance that may occur during the use of those prcducts. The TRT also recognizes the physical impossibility of performing complete independent DBA testing for every possible coating method, repair system, or ccmbination of c'oating materials which may occur where different coating sy' stems interface in actIsl I field applications. The TRT acInewledges that standard industry fractice has been to accept the use of f nonstendard, untested systems in the special case instances of overlaps and intoffaces, while limiting such areas to the .
I i.
O
@OE * * ' " O
[4 #
4[ O N3 MM b * .
-...:- _ 2 _ ,_ - . . . - . . - - - - . - ~ . . . - . . -- --
CPSES NRC TRT pRAFT 1 SSER - COATINGS 4 8 NOV 84 COATINGS PROCEDURES .. W. C. ~
WELLS
~ PAGE 14 i l
smallest practical size. Nonetheless, the TRT conciders it to be important that such nonstandard coating systems 5e evaluated for. technical viability and to assure they de not , ,,
- r
. include materials, methods, or systems which have been shown ~7 by previous testing to be incapable of withstanding DBA -
conditions. It is also important that such special cases
- are explicitly addressed in procedures and instructions ,
! which govern the work and that those procedures and -
instructions, are reviewed and approved by technically qualified individuals and by the coating manufacturer as l required ,by, ANSI.N101.4.
. The TRT determined that TUEC's system for review of procedures by technically qualified persodhcl ar.d by the coating manufacturers was inadequate, as. discussed under
" General Review of CPSES Coating Work Procedures and 1 Procedur.e Control System" above, and in SSER - Coatings 2.
The TRT also determined that TUEC's procedures and instructions in regards to special case coating systems for overlaps and repairs, were complex, confusing, 1
inappropriate, and inadequate in many cases. .
The TRT considered the case of interfaces between coating 4
sysi' ems applied over steel substrates, which occur where
! repairs are performed and where different syst. ems join.
i d
D *~_~_~*'__'_~ *_T ______ ' *'? _~~ T ' . . _ _ _
- ""'^~ " *~~ ^^^~__^~'- --_- *~~~l'~~P'___'T~-_L____-r.__'__'~
f-.. .
. J .-
s g CPSES NRC TRT CRAFT 1
[ CO.iTINGS PRCOEDC.TES -
W. C. WELL5
-PAGE 14 -' ,
j Ucnetheless, the TRT considers it ho be important that cuch l nonstar.dard coating systems be evaluated for technical ~ ;
, ); viability and to assurs they do not inc1Gde materials,
. s.
rethods, or systems wh.'.ch harte been shown oy previcus ,, ..f
~
testing P.o be incapable of withstanding c51 conditions. It.
is also important that such special cases are explicitly addressed in procedures and instruct.icas which gove.rn the work and that those preceduras ,and inutructicns; are reviewed and approved by technically qnatified individuals '
, and by the coating manuf acturer as required by A1 SI N101,4.
The TRT determined that TUEC's systes .for . review of procedures by technically qualif~iod perschnei a.nd by the-coating ranufacturers was inad6quate,I. as discucced under
" General Review of C?SES Conti.qg Work Procedures and ,
- Procedure Control System" above, and in SSSR
- Coatings 2.
- l. The TRT also determined that TUEC's procedures. cnd l instructions in regards to special case coating systems for .
, overlaps and repairs, were complex, confusing, ,
, inappropriate, and inadequate in many cases.
t
.l The TRT cen.sidered the case of interfaces between conting t
j, systems applied over steel substratos, which occur wb.ere j repairs are performed and 'where different systens join, i
s
- )
~
f CPSES NRC TRT DRAFT 1
,! SSER - COATINGS 4 8 NOV 84 i COATINGS PROCEDURES W. C. WELLS d *PAGE 15-~ -- -
Such interface areas are the subject of allegations ado-02
~'
and AQO-15. The TRT found that interfaces were first""
! pro'cedurally addressed in Brown and Root procedure CCP-30, s
i j revision 9, DCN #3, November 16,1981, paragraph 4.4.3.0, .l1 (althhugh the TRT noted that earlier instructions did -
include a requirement to feather the edges of repaired areas . ) The TRT peviewed the evolution of this procedural requirement through many subsequent revisions and ,,, ,
i supplementary instructions . including: Brown & Root Request.
1 \
for Information or Clarification (RFIC) (unnumbered),
January I,1983; CPSES .--
NC2 #C83-01752, July 5, 1983; CCP-30, revision 11, August 16, 1983; CC'P-30,' revlslon 11, DCN $2, October- 19,.1983; RFIC [ unnumbered), October 20, 1983;
.-- +
CCP-30, revision 11, DCN #4, November 8, 1983; CCP-30, , ,
revision 12,. March 4, 1984 (wherein the requirements are moved to paragraph 6.1. 3 ) . The TRT observed that these ,
changes, revisions, and clarifications involved changes in the applicability of interface instructions to different cases, changes in limitations on the width of interf ace areas, explanations of which coatings were permitted to be applied over which other coatings, and the.like. The TRT considers that many of these changes did not provide t
improvement or clarification, but caused confusion and I raised additional questions. Numerous versions of these
, instructions included the statement: "Within the interface
} -
1 t
1 l
1 ,
~
CPSES NRC TRT DRAFT 1 SSER - COATINGS'4 8 NOV 84 ,
COATINGS PROCEDURES W. C. WELLS
, ~PAGE 16'" ,
area, overlapping of any materials or systems is
~ ~~
' acceptable." (%dch%dddt.d) ,
~
Certain unqualified combinations of coatings such as the 7 application of one manuf acturer's qualified epoxy on top of--
another manufacturer's qualified inorganic zinc, or the overlapping.cf one manufacturer's epoxy onto another's (within certain total thickness limitations), can reasonably ., ,
.be expected to exhibit good performance, based upon industry experience and inferences from related test data. On the other hand, it is known that certain ccmbinations and
_, w .-
sequences of materials are techn'ically inborrect; for example inorganic zine which is applied on-top of epoxy will _
not exhibit adequate adhesion, and excess 1ve thicknesses 'of, either zine or epoxy which may occur at overlaps between
~
, systems or surrounding repairs may result in cracking or
- flaking, or both. The net result of the continuously changing and confusing instructions in this area described above is that the overlap or interface areas of applied coatings which now exist at CPSES gan include every possible combination and sequence of coating materials which were
. ever used, and the degree to which control .was exercised
, over-the application in any given interface, area is
,- impossible to determine. The TRT considers that this
,j situation could have been prevented by clearly written 4
i ' instructions which delineated, at the outset, that certain
- m. - - _ . _ _ _ . _ ._
i CPSES NRC TRT DRAFT 1 l SSER - COATINGS 4 8 NOV 84 j COATINGE PROCEDURES W. C. WELLS PAGE 17 ,
.j combinations of materials were permissible at interfaces and certain combinations were not, and requirements for' exEra~
t i car'e in application and inspection of interf aces to lassuro ,
i t '
. e.
Ii that,these requirements were met. A similar situution , ..f exists in regards to the concerns expressed in allegation -
1., AQO-06 on the subject of concrete coating materials applied .
I ove.r foreign objects embedded in concrete.
The TRT
! recognizes that small areas of embedded " wood fuzz", metal ,,, ,
cbjects, and the like are sometimes found in concrete, that-procedures must address how coating application should be performed in such cases,, and that ir, is not necessarily practical er possible to cbtnin compl'ete DB'A testing data i-for every possible circumstance which might be encountered.
~
In examining precedures that deal with this subject and l'n -
3 reviewing correspondence frcm TUEC 'n regards to this
,j allegation, the TRT found considerable evidence to indicate ,
f j that TUEC had given consideration to the subject and had elicited the manufacturcr!s recommendations.
~
- i However, translation of the results of technical evaluations and the manuf acturer's reecmmendations into appropriate procedures
,p to govern the work did not always occur.
'i ;
In TUEC's letter 4TXX-4201, June 22, 1964, a ecpy of an imperial Report 1462-1181 cf Cak Ridge National Laboratories
', DBA testing is included. This report indicates that r Imperial Nutec llS provides reasonably good performance over i
f f
1
_cw_ n n _n - - _ ,- a e ..-. --. . . , - . n nn n -. m. . . . _ . . . -.-
_ _ _ . _ _ - - _ ~ , _ . _ . . _ . _ . _ _ . _ . . . . . - . _ . . . _ . . .. _ _ . . _ _ _ _
CPSES NRC TRT ,
DRAFT 1 SSER - COATINGS 4 8 NOV 84 COATINGS PROCEDURES -
W. C. WELLS
'PAGE 18 _
abrasive blasted steel surfaces, but inadequate performance
~ ~~
l over power tool cleaned steel surfaces, and includes l ~
Imperial's reccmmendation that llS should not be applied
.. e, over. power tool cleaned steel surfaces with suitable ..
.4i
]1 roughness greater than two square inches. However, Brown &- ,
Root procedure CCP-40, revision 5, allows the application of S
llS over em'edded o steel objects, up to four square inches in
, size, which have been ground flush or smooth. Regardless of , , , ,
q
, the fact that 11s over steel is not a qualified system, and.
regardless of the fact that the areas involved are minor, t .
.: although very numerous, the TRT considers that proper q _. .-
technical evaluation and good ju'dgemeht shoh'I d have resulted
, in a procedural requirement to assure that-small steel objects embedded in concrete were adequately roughened by' ,
localized abrasive blasting or other methods prior to the j- application of liS. .
i -
B. Allegations AQO-07, AQO-08, AQO-10, AQO-38, AQO-39, 1
i ACO-40, AQO-41, AQO-43, and AQO-44. are all concerned with procedures and instructions and related documents which provide methods and requirements for performing coating work activities,, which are alleged to be technically incorrect.
j Although some of these allegations are evaluated in other I
coatings SSER functional groups, they have been included-f ,
I 'herein as well for the purpose of evaluating the addquacy of 1
the related procedural requirements.
).c.-. _, . ._ .
.. . -.m . . . . _ . .
]
- - - . . . . , _ . . . . _ _ m_ _ _ . _ . _ _ _ . _ . _ . _ . . . . .. . . _ _ _ _ .
I I
CPSES NRC TRT DRAFT 1 *
- SSER - COATINGS 4 .
8 NOV 84
- COATINGS PROCEDURES -
W. C. WELLS -
~
' PAGE 19
.j -
j REPAIR OF CRACKED CONCRETE COATINGS (AQO-07) . ..
.s This allegation identifies NCR #C83-01986, concerning the -
r;
- t
{ cracki.ng of concrete coatings, and disputes the disposition of the NCR. The disposition states, in part, that " cracking of coatings is due to excessive stresses in the coating during drying and curing," and directs repair of cracks in ,
$ accordance with existing procedures. It is alleged that -
I this repair method will not remedy the condition that caused the cracks. The implied significance of this is that the repair.will--not permanently remedy the defic.iency and that , ,
the cracks may recur. -
i ._- a The TRT reviewed the referenced NCR and found documentation
, to show that'the cracked coatings had been repaired. The i TRT examined Brown & Root procedure CCP-40, revision 5, which was the governing work procedure in effect, and found 1
repair methods described in paragraph 4.3.2.5. The TRT considers that these repair provisions are generally in j accordance with the manufacturer's recommendatiens and generally accepted practices. The TRT considers the j documented disposition to be an acceptable remedy for the ,
~
)
deficiencies reported in NCR'#C83-01986.
{
i l
1 The TRT considered whether TUEC's original application ,
methods included adequate measures to prevent recurrence.
TUEC letter
i i
.: I
'j CPSES NRC TRT DRAFT 1 l SSER - COATINGS 4 8 NOV 84 l
COATINGS PROCEDURES -
W. C. WELLS i
PAGE 20
- j -
'. ;l #TXX-4201, June 22, 1984, responding to this allegation, . ._
.l states, in part, "The preventative measure to preclude 1 ,
! recurrence of'this condition is the proper application with . .$ .
A' emphasis on control of film thickness (see manufacturer's .
bulletin attached.)" The referenced attachment is a bulletin from Imperial dated January 19, 1983. TUEC letter
- TXX-4249, August 10, 1984, states that specific procedural .
revisions were not necessary because CCP-40 "was already --
i in accordance" with these application parameters.
The TRT_. compared -the statements of Imperial'_s January 19, 1983 bulletin to the requirements of,CCP-40, revision 5.
The TRT found that the bulletin iden ifieY film thickness, ,
topcoat times, .and thinning as controlling parameters which-4 affect cracking. Contrary to,the manufacturer's j instructions, the TRT found that CCP-40, revision 5:
a) contains no requirements for additional curing of Imperial Nutec 11 applied 10 to 20 mils thick, cr Nutec 11S i applied in excess of 35 mils thick' (as may typically cccur I
at interior corners, bug holes, etc.);
2 l b) does not provide an equivalent test of hardness prior to i recoating thicker areas of 11 or llS; -
)
i
..--...-.n.-. . . .. . - . . - . . . . , ,.._ mem+, . .,,,M. ...,,m. . ~ . - - . . . . _ . - - . _ -
l
' 8 NOV 84 COATINGS PROCEDURES -
W. C. WELLS PAGE 21 l . .-
c) employs non-conservative interpolations of the . . . _.
man,ufacturer's curing schedule for Nutec 11, llS, and s
Reactic-1201.' - " .
Ai The TRT requested responsible site construction engineering -
personnel to supply other applicable manufacturer's instructicas, and received Imperial's application -
~
instructions dated August 7, 1981. The TRT compared these --
instructions to Brown & Root procedure CCP-40, revision 5, and found conflicts between the manufacturer's instructions and the-procedur6. Examples are: , _ ,
a a) The procedure provides for the use of' concentrations of tri-sodium phosphate (TSP), used for washing concrete surfaces, which are well in excess of the manuf acturer's '
recommendation, does not require that the TSP be mixed with warm water, and does not require pH testing after rinsing the TSP from the concrete.
b) The procedure does not provide for a final blow-down of
- the prepared surfaces with oil-free compressed air.
i
, c) The procedure does not provide equivalent treatment of i
! concrete surf aces on which Nutec 10 was used as a curing I membrane.
i 1
e
..,_,._........-...-....---.-..-.....~--.----..-...--..-.._-.~,,m-~~- .-c-- - .-
I
~l ~s ,
- ! l i CPSES NRC TRT DRAFT 1 ;
SSER - COATINGS 4 8 NOV 84 COATINGS PROCEDURES - --
W. C. WELLS 1 PAGE 22 d) The procedure permits application at relative humidity.. _
.; levels above 85%.
. I: .
' A' e) The procedure uses non-conservative interpolations for curing times.
f) Th'e procsdure provides that up to 16 mils of Reactic 1201 .
~~ '
i, may be applied, (the manufacturer's recommended maximum is -
, 12 mils).
g) The.pr.ocedure-does not require that high , film thickness, i' runs, A~nd sags be abraded at least 2 mils below the specified maximum thickness. ~
- 4 ZINC OVER ZINC RESIDUE. (AQO-08) .
It is alleged that that there will be coating adhesion problems, and that the necessary galvanic action will fail to occur, in areas where inorganic' zine primer has been applied over a steel substrate which has a metallic zinc
,' l j
. l residue in the profile of the steel. Such an application is permitted by Brown & Root procedure CCP-30, revision 11, paragraph 4.1.3, which states: "
i[ ... shadows of tight residue is ll of primer which may remain in the profile of the previously )
l prepared sEbstrate is acceptable."
- 1 l
l _.
-- L t. .. . . . . - - . . . - . . . . . . . - . . - j
- i. l i
CPSES NRC TRT DRAFT 1 i j
']
~~
COATINGS PROCEDURES C. WELLS W.
PAGE 23
~ j: The TRT reviewed test data provided by TUEC in , _,
'}
- correspondence to the TRT, and compared CPSES procedures i governing the ' repair of inorganic zinc coatings with methods -
'I-' :
.t that have been used successfully at other nuclear -
facilities. The TRT observed that there is adequate test data to demonstrate that inorganic zinc may be applied over
, itself and over steel and will exhibit adequate performance -
~ '
provided that prope'r procedures are followed for cleaning -
and preparing the surf ace prior to application and for applying,the new inorganic zinc coating. The TRT did not
~
find any.Avidence that the application of inorganic zinc over tightly adhering residues of existing inorganic zine on properly prepared steel will have any adverse impact upon, subsequent performance in regards to adhesion or galvanic action. The TRT considers this to be an acceptable and proven application technique. '
COATINGS APPLIED OVER SURFACES CLEANED BY POWER TOOLS.
(AQO-10)
This allegation concerns repair o'r touch up coating work in which coatings are applied over surfaces cleaned with power tools. TUGCO instruction QI-QP-ll.4-5, revision 27, paragraph 3. 2.2.3 states : " Surfaces that have been power l
'I
}. . -
__ _._._. . _ _ . . L._.__.._.. . . _ . . - _ . . . . _
f j CPSES NRC TRT DRAFT 1 i
SSER - COATINGS 4 -
~'
8 NOV 84 COATINGS PROCEDURES -
W. C. WELLS PAGE 24
{ tooled with '3-M Clean-N-Strip,' 80-grit or coarser ' flapper I
- whe.els,' sanding dises, ' roto peens,' or equivalent provide i '
- acceptable surface profile." It is alleged that these -
methods will not result in a DBA qualified cocting system but will provide a smoothed or polished surface with inadequate surf ace roughness and therefore inadequate adhesion of' subsequently-applied coatings. ,
This subject is discussed in detail in SSER - Coatings 2, in regards to the DBA qualifications of coatings applied using these sur-f-ace preparation methods. To evaluate the adequacy of the procedural requirements affecting power tool cleaning for touch up work, the TRT reviewed relevant CPSES A procedures, manufacturers' recommendation ~s, test data, and correspondence on this subject from TUEC to the TRT and between TUEC and the manufacturers.
The TRT considers that power tool cleaning as an alternative surf ace preparation method for touch up and repair work, while inferior in general to more rigorous methods such as i
abrasive blasting, is normal industry practice for minor repairs and can produce acceptable results. Acceptable i results are dependent upon control of power' tool cleaning 1
through appropriate methods and procedural instructions for l
l . performing and inspecting the work to assure the resulting surface is adequately cleaned and roughened to provide good adhesion for touch up coating materials.
I I
..._._ . . _ . _ . ._ .__. J
~
~ . . - .a .- _ .-.. :. ... :aA.-- ~.- . . . - . . w . --- 1 l
l CPSES hTC TRT DRAFT 1 i SSER - COATINGS 4 ' 8 NOV 84 COATINGS PROCEDURES - --
W. C. WELLS -
~
PAGE 25 4
i In reviewing TUEC's letter TXX-4201, June 22, 1984, and test f t_ , ,
i j data and correspondence attached thereto, the TRT observed I
that all available data demonstrate that good adhesion over '
.- t power , tool cleaned surfaces is dependent upon the use of the '
proper tools, specifically 3M " Clean-N-Strip" or 60 grit or coarser sanding devices. The TRT found that the allegation that the methods permitted by the section of QI-QP-ll.4-5 .
~~ ~
quoted above, (i.e. "80-grit or coarser" and "or --
equivalent",) will provide a smoothing or polishing action .
rather than adequate roughness for proper adhesion, is technically-correct. The TRT ccnsiders that,the use of 1
these tools will not provide adequate surface roughness, and further considers that this inspection inTtruction which .
instructs the inspector that surfaces prepared by such methods are acceptable, rather than requiring performance of an inspection t'o determine the acceptability of surface -
,' roughness, is inappropriate.
The TRT also noted that the instructions for performing repair work provided in Brown & Root procedure CCP-30, revision 11, (which was in effect at the same time as QI-Q P-ll . 4 - 5, revision 27 quoted above), contained the same -
- - (technically incorrect) listing of tools to be used to
- perform the work. The TRT found that there was no
~" .
4 1
n 1
_-_ a : . _. . . . . _ . , _ _ . . _ _ _ . _ . - . - . - . . _..-----.s. --
.i
.I c!
l CPSES NRC TRT DRAFT 1 ll SSER - COATINGS 4 . 8 NOV 84
! COATINGS PROCEDURES - --
W. C. WELLS PAGE 26 -
t
. requirement for inspection or documentation to determine the
- extent of roughness or the specific tools which had been
.. E .
used, and that therefore it cannot be determined to what *
.t extent, if any, power tool cleaned surfaces weic - -
unacceptably smooth due to the use of 80-grit sanding devices or equivalents. However, the TRT recognizes that power tool cleaning was used only as a repair surf ace .
~~ '
preparation method and that therefore the total size of the -.
areas involved is relatively minor.
The TRT_ reviewed-the current revisions of CC.P-30 and QI-QP-55.4-5, and found that this problem has now been corrected through specification of the proper tools for e ,
t power tool cleaning and a requirement for inspection of power tool cleaned surf aces for adequate roughness by comparison against an approved visual standard' .
I d
i GRINDING EXCESSIVE CZ-ll DFT. (AQO-38)
, t 1
- This allegation is concerned with the method used at,CPSES i
to remedy unacceptably high thicknesses of applied.CZ-ll, by
~
a powArgrindingtoreducethe'thicknesstoanacceptable
, level. It is alleged that this method will result in a i. burnished or polished surface that would cause poor adhesion l l of the topcoat to the zinc. l }.
. ___ . _ - . _ - _ ,___ . :r- __ . . l. - - _ _._ _ _ _ - _ _ .
1 i 's CPSES NRC TRT DRAFT 1 8 NOV 84
~
- { SSER - COATINGS 4 .
j COATINGS PROCEDURES
- ~'
W. C. WELLS
- PAGE 27 The TRT reviewed relevant CPSES procedures, correspondence from TUEC on this subject, recommendations of the manufacturer,'and industry standards. The TRT did not find -
..t any 6v.idence to support this allegation. The standard accepted method for remedying high DFT of inorganic zinc is I
by abrading, sanding, screening, or.other appropriate mechanical s.ethods to reduce the thickness to acceptable .
~~ '
I levels, and TUEC's procedures conform to this method. Any -- observed burnishing or polishing effec.t will not have any 1 appreciable adverse impact on the subsequent physical and chanical-adhesion of the topcoat to t,he zinc. coating. o l
'RECOATING P-305. (AQO-39)
This allegation is concerned with the methods used to prepare previously applied Phenoline 305 (between 1 and 2 years old) prior to being topcoated with new P-305. It is alleged that the method used to prepare the old coating, (solvent wipe), does not constitute adequate surface preparation. The implied significance of this allegation is that the new p-305 will not exhibit adequate adhesion to the old ccating. , ,i . . . . . _ , _ . . - . _ _ _ . ___ -
a _ -_ . - . . . _ . - - . - - - - -
.1 CPSES NRC TRT
~
DRAFT 1 SSER - COATINGS 4 . 8 NOV 84 COATINGS PROCEDURES - -- W. C. WELLS i PAGE 28
.t . -
The TRT reviewed relevant CPSES procedures, correspondence
*. from TUEC on the subject, and the manufacturer's j .
Il recommendations. The TRT found that the solvent wipe method . E, d
.; used at CPSES is in accordance with the manufacturer's --
instructions, provided with TUEC's response in TXX-4201, July 22, 1984. The TRT found no evidence that solvent wiping as a' surf ace preparation method under these . circumstances was inadequate or improper, or would have any -. adverse affect on performance of the coatings. _,w..-
~
REMOVAL OF DEBRIS FROM POWER TOOL CLEANED SURFACES. (AQO-040) .--- e
, This allegation states that certain cleaning requirements
! are not satisfied. The allegation references TUGCO .
,. procedure QI+QP-ll.4-5, revision 27, paragraph 3.2.2.d, i
which requires that inspectors verify that blasted or power tcol cleaned surfaces have been adequately brushed or vacuumed to remove cleaning debris' prior to coating epp11 cation. The allegation states that power tool cleaned
\
l surfaces were never cleaned as specified by this paragraph, I and that instead these surf aces are blown down with a
't i,
I l - a
l 1 1 CPSES NRC TRT CRAFT 1 i SSER . COATINGS 4 ~~ 8 NOV 84 1 COATINGS PROCEDURES - W. C. WELLS PAGE 29
, compressed air or wiped with rags. The concern of this ,
, allegation is that surfaces might become contaminated with oil, water, or lint by the practice of removing debris with . E; ll ' " *? compressed air or rags. I TUEC, discussing this allegation in. letter #TXX-4201, June 22, 1984, observes that the same procedure requires > inspection to verify that cleanliness criteria are satisfied -* 4 ij after removal of cleaning debris. The TRT considers that i; such visual inspection will generally be adequate to detect i: substantia-1-quantities of such o.il, water
, e and lint; l* however, the TRT further considers that inspection is not an ; adequate substitute for work procedure requirements to ",
j minimize er prevent such problems from oc' curring in the i first place. i' . l The TRT reviewe/. the requirements of the governing work procedure, Brawn & Rcot procedure CCP-30, revisions 11 and
- 12. These procedures provide that, at a repair area where f; the entire thickness of the inorganic zine primer has not
- il d
been removed, solvent cleaning shall be employed to remove i grease and oil on the surface. lj . The typical method is wiping with solvent-dampened rags. 'The TRT concurs with this }; , i; practice. } .
)
I 1
- . - - . .- - - . -. .-.- - .. ~. - .
v CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 -
~'
8 NOV 84 W. C. WELLS COATINGS PROCEDURES - PAGE 30 The TRT interviewed ten inspectors concerning this subject. , ,,
+
l The,TRT found that blowiny down with compressed air has been , used to removd cleaning debris, and solvent wiping is used r5:
, v't in a~ limited manner. Further, the TRT found that inspectors
! will reject any cleaned surface exhibiting evidence of contamination by oil, water, or lint.
~ "
-The TRT considers that the effectiveness of an,y of these r .
cleaning methods, e.g. brushing, vacuuming, blow'down, or wiping, will be primarily determined by the skill and . diligenca-of. the craftsman. The,TRT consid,ers that brushinh, vacuuming and blow down are acceptable for
- removing debris from surfaces cleane to Eare metal. ",
l Air-driven power tools may release small quantities of I lubricating oil from exhaust ports, and subsequent solvent j cleaning. is 'an acceptable method to remove lubricating oil l from surfaces. Solvent cleaning of bare metal using rags i should be prevented, so that lint does not become hooked on the peaks of surface profile. 1
] 4 The TRT has discussed concerns ,about contaminated air a l supplies in the discussion of allegation #AQO-17 in section f: 4, E below. TRT found,that procedures do not provide adequate controls to assure that compressed air used to blow down cleaned surfaces is suitably free of entrained oil and 9
0 _-- _.m
._.-_ ,,_y,--
. .- _ - . _u -
. . _ _ _ _ _ _ _ . _ , , _ _ . _ . .2._...
4 CPSES NRC TRT DRAFT 1
. SSER - COATINGS 4 ~~
8 NOV 84
' COATINGS PROCEDURES -
W. C. WELLS
~
PAGE.31 '4 { water. The TRT was not able to clearly determine the extent , 4- to which the practices described by this allegation ~may have
! affected coatings applied at CPSES. The TRT further ' $
consid.ers,'however, that any oil, water, or lint which are deposited on surf aces during . final cleaning and -hich are not detected during inspection and which are present in more.
, than very s: hall quantities will generally tend to be .
l revealed during coating application and inspection. The TRT -- 1 has commented further on this topic in the discussion of l ja Allegation #AQO-17.
. _~ , _ ,
I. I *
, FOREIGN CLEANING SOLUTION. (AQO-41) -
e This allegation concerns the use of a foreign cleaning agent to wipe coated surfaces immediately prior to repairs. It is
- i' alleged that the solution used is a hospital disinfectant
! which contains 2% chlorides. The concern is that this I j material is not allowed by procedures, and the implied j significance is that chloride.containing materials within
- l i' -
- l. containment might come into contact with stainless steel and
!4 '
, result in stress corrosion cracking of the stainless steel.
i - p -
- i *
,i
- 1
,I o
. . . . ~ - - . .. ---. . . . - . .. -- . - - - -
j CPSES NRC TRT
- DRAFT 1 L SSER - COATINGS 4 .
8 NOV 84 4 COATINGS PROCEDURES - ~~ W. C. WELLS- !l PAGE 32 y . - 13 lj . TUEC indicated in TXX-4201, June 22, 1984 that the material in question was Econolemon Disinfectant Cleaner-Hospital l]I s !! Type, manufactured by Garland Supply Company, Fort Worth ' ,
. - .e.
A Texas., USNRC Regulatory Guide 1.54 prohibits the use of any a
,t*
chloride containing material for cleaning stainless steel, l l and requires testing of any material to be used for this ]! purpose. However, the TRT found no evidence that this , material had ever been used on stainless steel at CPSES. ~~ ' t <1
, The TRT's review of procedures CCP-30, revisions 10 and 11,
.; - and CCE=10A-revisions 2 and 3, found that,c,ertain specific r* ._ solvents are specified for use at CPSES prior to repair of
;i _
j primer and topcoat. The TRT interviewed Teveral QA/QC '
- )
- 4 personnel on the use of this unapproved foreign cleaning it solution. The persons interviewed had no knowledge of this material.being used prior to repairs on the steel liner
- - plate, nor of this solution being used on any stainless steel inside containment. One individual informed the TRT l} that this material had been used for a washdown of applied finish coat on the steel liner plate in unit 1 containment,
- u. . .
j- and that CPSES NCR # C-83-01694 had been written as a '
. I C result. The interviewed individuals also informed the TRT l
tha[theseareasarealwaysrinsedthoroughlyaftersuch 5
.- l m
... .._.__ ._. ___..._._ . L. - .._ . -- . - -- --
-i
- i j CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 ~~
8 NOV 84 COATINGS PROCEDURES - W. C. WELLS
~
PAGE 33
. ~
cleaning. The TRT's review of the subject NCR found that it , , ~I l concerned the use of this material on top of the topcoat
- l only, and there was no indication that the material had been -
b;
'n lf used for repair work as indicated in the allegation. -
~ ;
~
~
!' The TRT reviewed the contents of this material and
~
determined that it is a detergent and would have no adverse a effect upon the finish coat if tnorough rinsing occurred -- -l j; after use. The TRT found no fault with the governing <! procedures or with the disposition of NCR #C-83-01694. _, n . . l-The TRT also reviewed Brown & Root procedure #CP-CPM 9.2,
- ' revision 0, June 25, 1984, which was provTded by TUEC in' TXX-4249, August 10, 1984. The TRT determined that this new
..; procedure provides the necessary controls to assure that foreign chemical materials do not enter the containment area in the future. CURE OF INORGANIC ZINC PRIMER: (AQO-43) - - {t
- l This allegation states that inorganic zine primers were not properly cured prior to topcoating and that* procedures were not followed to determine if the primer was properly cured. ,
The implied significance of this allegation is that I . e .
....P_ s 10 0. i +OP .
_***M*. ***-'NM** **6-** --** P***** __a -
J
- . . . 4- - , . . ~ . d s - .s..--.-- +.. . . ~ .._ - - - a--**~*
j i CPSES NRC TRT ' DRAFT 1 ( SSER - COATINGS 4 - 8 NOV 84
~'
ll COATINGS PROCEDURES - W. C. WELLS
~
jj PAGE 34 l1 . -- ll ll inadequately cured inorganic zinc primers are not equivalent ,
}
j to ,the qualified coating system and might fail during ii . postulated accidents. - -'/
, , ,9
. ... t l
The TRT reviewed procedures providing work and inspection . requirements for the curing of inorganic zine primers. All revisions to date of Brown & Root procedures CCP-30 and .
~ "
CCP-30A describe methods to perform and inspect the cure of -- inorganic zine primers. The current inspection requirements are given by TUGCO procedures QI-QP-ll. 4-5, revision 29, and l QI-QP-ll.4-26; r6 vision 6, which, require ' cure verification. The TRT found that methods and requiremen'ts of the Brown & Root procedures referenced above adequately correspond to the recommendations of the coating manufacturers, with one a . exception discussed under allegation ,#AQO-44, below. A generally accepted practice is to accelerate curing by providing the required moisture by wetting the primer with j water af ter initial drying; this practice was incorporated
; into Brown & Root procedures after April, 981. The TRT i ' interviewed eleven pt. nently-cmployed inspectors concerning ll .- .
l, cure verification proced.ures,' and found no hvidence to show
_ __ [ ._ _ _ . _ . . _ _ _ . _ . - . _ . - _ . - . _ . _ _ _ _ . _ _ _ _ . _ - - - ii lt j' l CPSES NRC TRT DRAFT 1 l SSER - COATINGS 4 8 NOV 84 l' COATINGS PRCCEDURES - ~' W. C. HELLS PAGE 35 t . ~ that curing requirements have not been consistently , ,_ ,, , l implemented. The TRT found this procedure was generally I i . s employed there~after. . ': .
.4
. .. i The TRT further considers that the adhesion testing of the (see. Co4b gs 55 M-Q '
- Backfit ProgramAprovides an acceptable measure of confidence that inorgariic zinc primers applied prior to November, 1981 .
, were adequately cured. The TRT did not substantiate this --
1; l allegation.
.<.-- ~
PERFORMANCE OF THE " NICKEL TEST" (AQO-44):
, .- a i This subject allegation states that the " nickel-test" used l to verify the cure of inorganic zine primers prior to topcoating was n'ot properly performed due to verbal i i instructions received from QC Supervisors. The allegation further states that inspectors were instructed to perform the test by lightly rubbing the coating with the coin, 4
applying just enough pressure,to hold tile coin in cor. tact
- with the surface. The implied significance of the j
allegation is that improper instructions resulted in the 1 . 1
! topcoating of inadequately cured primers, and that those -
primers might fall in cervice. i I . ' L -._._._--_ , _ = . - - = - _n--_=- - - - - - - ~ , - - . ~ - - - . _
. _ _ _ , . _ __ - _ . . _ m. _ _ _. .. .
i ' CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 .
~'
8 NOV 84 ', COATINGS PROCEDURES - W. C. WELLS -
~
PAGE 36 l The TRT considers that the " nickel. test" is a generally ,,
- aceepted technique to verify the cure of inorganic zine i
coatings, which has been used since the development of these .. I. ;
~'
.s materials during the 1940's. Various authorities describe slightly different methods for performing this inspection; a consensus standard is currently under development by ASTM committee D'01.48.
~
The TRT considers that there is a . i
~~ ~
general recognition in the coatings industry that -- interpretation of the results of this test can be very subjectire. I Inorganic zine coatings harden during cure; the
" nickel = test" provides a comparison of the h,ardness of t e
~
crganic coating to a uniform reference. TUEC letter TXX.-4201, June 22, 1984, states in part that "I. [ is our opinion that the " coin test" method described in CCP-30 and CCP-30A conforms with (the manufacturer's) preferred method for the coin test as described in the attached (manufacturer's) letter." e I ) 3 i t i t 4 i i e
~
",......- _........w_..-.
.,,~c.....--..g .-. -- . .. . . .. . _ .
.- *A..----..-.----=. -- - . - .--. - - .- - - - - --
t CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 ,
~'
8 UOV 84 COATINGS PROCEDURES W. C. WELLS i PAGE 37 The TRT reviewed TUEC's governing procedures. The use,of,,, ,4
- the," coin test" or " nickel test" to verify .the cure of
.; inorganic zinc coatings was initiated in Brown & Root -
b: ' proc 4 dure CCP-30, revision 7, dated 5/7/81. Paragraph *
. 4.4.1.1.6 of this revision states in part that "(The coating) is sufficiently cured for topcoat when the coating may be burnished rather than removed when rubbed with the .
~ ~
flat portion of a smooth edged coin such as a nickel." The --
, statement is maintained substantially unchanged through subsequent revisions, and was similarly incorporated into Brown &_Roob procedure #CCP-30A, , revision,1,, and subsequent revisions. ,
.--- a The TRT noted that cortain inspector qual'ification 4 s examinations require Q.C. inspectors to describe the method l of performing the test. The response given by the' prepared answer key corresponds to the statements of procedures.
l
- i The TRT found that QC inspectors are not issued centro 11ed copies of CCP-30 and CCP-30A, The TRT found that the
, nearest available controlled copy of those procedures is !
maintained in the paint superinterdent's office. P i . 4 l . t
. . . . .- .- . . ~ . . ~ . - . . - . . . .. . - . -
4
; CPSES NRC TRT DRAFT 1
'l SSER - COATINGS 4 - 8 NOV 84 COATINGS PROCEDURES - W. C. WELLS-PAGE 38 1 i { The TRT requested selected inspectors to demonstrate the li l nic,kel test, or describe in detail the method of the test. s The TRT found'that inspection personnel conduct the test by . F:
, , //'
lightly rubbing the inorganic zine with the flat of a - nickel, and visually examining for the presence of x burnishing and removal of the coating.
~ "
The TRT found that the procedure employed at CPSES differs - l in specifics from the statement given by the manuf acturer referenced by TUEC letter TXX-4201. The cited letter states "Put heav,r pressere on the coin ,with the _ finger tips and rub
'~
the coin back and forth (8-10 times.)" The procedure used at CPSES dces not specify the use of heavy pressure or th,e l number of times. the coin is to be rubbed.' The TRT was not able to establish the extent to which improperly performed
" nickel-tests" might have resulted in the coating of, partially-cured inorganic zinc primers. The TRT considers, however, that the water curing procedure discussed under allegation #AQo-043 is sufficiently effective to eliminate significant concerns of inadequate inspection practices.
l .
~~ .
C. Allegations AQO-18, AQO-19, AQO-20, and'AQo-51 concern the Backfit Test Program, and alleged inadequacies in !, procedures and methods which were employed. A detailed analysis and evaluation of the significance of these
. . . , . . . . . ... . . . . . ~ _ . - - . . , w. - _ - -m.~,._...__
_ 4 CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 ~~ 8 NOV 84 COATINGS PROCEDURES - W. C. WELLS -
~
PAGE 39 j allegations in regards to effects upon the Backfit Program .. ) is provided in SSER - Coatings 1. These allegations are considered separately herein to provide an evaluation of the - E: n' adegnhey of the governing procedures. In evaluating these allegations, the TRT reviewed pertinent revisions of the Backfit inspection procedures, TUGCO instructions QI-Q P-ll . 4-2 3 (Steel Substrates) and QI-QP-ll. 4-24 (Concrete .
~ '
Substrates), as well as other related inspection procedures. --
?
VISUAL.DEFEGTS DURING BACKFIT INSPECT, IONS. ,fAQO-18)
~, , This allegation is concerned with inspectTon for visual 4 , ; defects such as cracking or blistering; i~t is alleged that f inspectors were not allowed to identify such defects during
- backfit inspections. '
In reviewing the backfit inspection procedures and related NCRs referenced therein, the TRT found that, although scme
! visual inspection parameters were included in certain I .
revisions of the procedures, that visual inspection per se
; was not an element of the backfit inspection program.
TUEC 's 1.etter TXX-4201, June' 22, 1984, provides the explanation that visual inspections were performed separately in accordance with other procedures that governed I
-4*.
[' CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 . 8 NOV 84 COATINGS PROCEDURES - -- W. C. WELLS PAGE 40 - ongoing inspection work, (i.e. TUGCO instructions .
;i . . . . . ; QI-QP-ll.4-5 for steel substrates, and QI-QP-ll.4-10 for 3
jj' concrete substrates). The TRT has evaluated the adequacy of ,.. E;
. i'l
't
,, the visual inspection requirements of those other procedures under section 4,E, below. o 1 Given the fact that the backfit program was instituted as a . remedy for previous deficiencies in performance and -- documentation of inspections, and that these deficiencies included, lac.< of adequate records of visual inspections, the TRT considens that it would have been approgriate to include , visual inspection as part of the backfit program. The lack of such visual inspections as part oh the"backfit program, created an unnecessary complexity in inspection requirements and records which could have been avoided by including all inspection criteria, (DFT, adhesion, and visuai evaluation for defects), in a single procedure, and the results in a ' single report for each area. l BACKFIT INSTRUCTIONS VAGUE. (AQO-19) l This allegation concerns TUGCO instructions QI-QP-il.4-23 and QI-QP-ll.4-24 which are the procedures governing the 1 performance of backfit inspections.- It is alleged that 1 i l l
' -- ..---r-.---.--.
~
. _ _ _ m_..__- . . . _ _ _ _ . . _ _ _ . . _ _ _ _ _ . _ _ _ . . _ . . . . . . . ..l ._ . . .
e i i CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 ~' 8 NOV 84 COATINGS PROCEDURES - W. C. WELLS
~
PAGE 41 1 j these procedures are very vague regarding the way the , ,, i bac,kfit instructions are to be conducted. i,
.t The TRT reviewed all revisions of these procedures including QI-QP-ll.4-23 revision 0, November 19, 1981, through . revision 13, April 18, 1984, and QI-QP-11.4-24 revision 0, February 5,'1982, through revision 7, April 18, 1984. The .
TRT also interviewed inspectors who had performed backfit -- inspections and examined records of their training in the performance of backfit inspections.
~ '
_n - , '_ __ The TRT found that, although these procedures included detailed instructions in certain areas, tEere were other', areas in which the instructions were inco~mplete or missing. Examples ares
- a. These instructions are entitled " Reinspection of Seal Coated and Finish Coated Steel Substrates for which Documentation is Missing or Discrepant" (QI-QP-ll.4-23), and
" Reinspection of Protective Coatings on Concrete Substrates f
for which Documentation is Missing or Discrepant" (QI-QP-ll.4-24). However, neither instruction provides 3 . adequate details regarding what plant areas'or items the
,, procedures apply to (i.e. which areas or items have missing
) or discrepant documentation), or provide details on how such
! areas are to be identified or by whom.
~
CPSES NRC TRT DRAFT 1 , SSER - COATINGS 4 - 8 NOV 84 I C. WELLS
~~
COATINGS PROCEDURES - W.
'l PAGE 42
~
j J
- b. These instructions do not provide detailed operating ,,
ins,tructions on the use of the two principal instruments employed for backfit inspections, the Tooke gauge and the - E is Elecmeter Adhesion Tester. Despite these procedural deficiencies, the TRT considers that these Instructions are adequate to permit proper .
~' ~
performance of the inspections by individuals who have been - trained in the correct use of the instruments and implementation of the procedures. Training and qualificatlon of" inspection personnel, including backfit inspectors, has been reviewed separately, and the TRT's evaluation is reported in SSER - Coa ings'7. Although th,e TRT did find deficiencies in training and qualification of personnel, there was no evidence that these deficiencies resulted.in improper performance of backfit inspections. During interviews with former backfit inspectors, the TRT confirmed that all individuals questioned had an adequate understanding of the proper use of the instruments and the performance of the inspection procedures. 1 ADHESION TESTS NOT PROPERLY PERFORMED. (AQO-20) This allegation concerns the method used by backfit inspectors at CPSES to perform adhesion tests of coatings i L
't i CPSES NRC TRT DRAFT 1 a SSER - COATINGS 4 ' 8 NOV 84 , COATINGS PROCEDURES - -- W. C. WELLS - PAGE 43 0 using the Elcometer ad.iesion tester. It is alleged that the
- t Q.C. inspectors were instructed not to cut the coatings t
around the adhesion test dollies prior to performing the . I t
, test; ,amd that this is contrary to the instructions provided by the manufacturer of the instrument. (CPSES specificatio'n ] +
2323-AS-31 references these manufacturer's instructions. )
-t ; Based upon a review of TUGCO's backfit inspection --
1 _ procedures, the specification, the adhesion tester n j manufacturer's instructions, and correspondence from TUEC,
'I the TRT,d,ete.rmined that this allegation was substantially
- , correct; CPSES Q.C. inspectors did not scribe around dollies
~
i j although the manufacturer's specificdlly instruct the user - to score around the dollies prior to performing the tests. ( 1, The TRT reviewed the results of on-site testing conducted by TUEC to demonstrate that scribing or not scribing does not affect test results. The TRT also solicited input on this
! subject from qualified individuals in the industry including persons currently ergaged in developing an ASTM standard en -
^t I the subject of adhesion tests for coatings. Based upon this
, information the TRT determined that failure to scribe around 'l '
the hollie's was not technically improper and would not have had any appreciable adverse impact upon the validity of. test 1 -
!, results. .
i -i I e
..._m._..:__ ..-.u._...._. . . _ ..- . _ . ; 2 - ~ . _. _._ - .L ._ _ _ . _ . . . _ _
/
t CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 -
~'
8 NOV 84 COATINGS PRCCEDURES W. C. WELLS -
~
j PAGE 44 j . . . - The TRT noted, however, that in this case, TUEC had provided , verbal directions to the Q.C. Inspectors that were contrary
. s- l to the writte.i instructions (2323-AS-31 and the ,- P: . . ?,I manuf acturer's instuctions), The TRT also noted that TUEC '
has since modified site practice to institute scoring around
] dollies in compliance with the manufacturer's instructions.
3 i
; ~_.
t . 1 P-305 50/50 MIX. (AQO-51) i This allegation concerns the practice, employed at CPSES of i 1 thinning Phenoline 305 by adding two, quarts of thinner'per gallon. It is alleged that this practice' caused the ~, material, when dried, to become as brittie .as glass and to lose its impact and abrasion resistance. It is alleged that the material became so brittle that it was not possible to obtain a Tooke gauge reading. t I The TRT reviewed TUEC's application procedures, Brown & Root CCP-30 and CCP-30A, and TUEC's correspondence on the subject t-1, (with attached letter providing the manufacturer's 1
; recommendations).
l - i The TRT determined'that thinning of P-305 up to two quarts
.per gallon for certain application conditions, (i.e. " tie"
. _ _ _ _ <_..Z.._.___i.._..-_._---.-__. - - - . . . . ._.-..-:---
~' ~ CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 8,NOV 84 C. WELLS
~'
COATINGS PROCEDURES - W. ' PAGE 45 ,1 or " seal" coats, pre-treating sharp edges, and application , , at relatively low ambient temperatures,) was procedurally if , i addressed, in accordance with the manufacturer's . E; n instru.c tions, and technically correct. There is no evidence i: to indicate that thinning the material in this manner will cause the applied coating to become. brittle and to lose its impact and abrasion resistance. . l . The TRT concurred with TUEC's statement in TXX-4201, June l il
; 22, 1984 that any apparent embrittlement which made it
- . impossible-to obtain a Tooke gauge reading- was more likely -
f the result of a dull tip on the gauge than of deficient characteristic of the coating film. This' explanation e
- { ,
- i li however raised an additional question in regards to backfit t
inspection procedures and the use of a Tooke gauge with a dull tip. (Tooke gauge tips must be sharp to provide a smooth cut and an accurate reading. ) i
,i j Although the TRT did not find any records to demonstrate that backfit inspectors had received specific instruction in
.c this area, during interviews conducted by the TRT all
, backfit inspectors questioned were well aware of the consequences of dull tips on'Tooke gauges. "The TRT also
.t.
. noted that backfit inspnction procedure QI-QP-11.4-23 !
requires a daily confidence check of.Tooke gauges, including
~
an examination for evidence of tip wear. il -
_ . . . _ _ _ _. _ -._..._____.. _ _ . 1 _ _ _ .. ._ _.. -. . I .! CPSES NRC TRT DRAFT 1 j SSER - COATINGS 4 . 8 NOV 84 COATINGS PROCEDURES - -- W. C. WELLS h;! PAGE 46 ~ r
- , The TRT did not find any evidence that the "50/50" mix
} resulted in any deficiency in the coatings applied or that ,
3 ' l there was any related improper use of Tooke gauge with dull . .I. ,
.u tips. . - .I i } D. Coatines acclied to areas where thev should not Itave been .
applied: ~~ " l Allegation AQO-24, AQO-42, AQO-48, and AQO-49 concern 1 . ll application of coatings to surf aces where they should not
- - - ~~
have been applied. In each case the concern is that such ,j misapplied coatings could fail thereby creating debris which *
- s could interfere. with the proper operation of engineered safeguard systems.
- j '
ll Allegation AQO-24 concerns Q coatings that have been placed l' I over rusty, scaly, unprepared metal surfaces inside pipe supports made of tube steel without end-caps. The TRT reviewed correspondence from TUEC on this subject, DCA
- (
<t
#16,106, and the protective coatings exempt log (CEL) entry ; number 32. The TRT found that entry #32 in the CEL documents 6,000 square feet of CZ-il/P-305 misapplied to
. .i
; tube steel support ' interiors without proper surf ace
'i i
~ . -
. , .- ..- .~ - . . . . . - . . . - - . . . . . - . - --- :
u-....... - . . . . . - . . . - - . - . . . . - . - - .. ....... .... . . . . . . . . - - i i j CPSES NRC TRT DRAFT 1
, SSER -~ COATINGS 4 8 NOV 84 COATINGS PROCEDURES - --
W. C. WELLS -
~
PAGE 47 i i j preparation or inspection. The TRT also noted that DCA i
#16,106, revision 1, stated that, " Coatings extending into 1 3 i open tube steel members resulting from spray operations -
n' perfor.med on the ends and exterior of the member is - acceptable."
; Allegation AQO-42 concerns coatings which were applied over .
I "' i duct tape and foam rubber in Richmond Inserts. The TRT --
.j reviewed correspondence from TUEC on the subject, DCA 1
#12,374, ,and the CEL. The TRT found that DCA #12,374 j . downgrades-all coatings on Richmond Inserts to specification ,
1 [ 2323-AS-20, (Non-Q), and that entry #30 in the CEL documents i 2,258 square feet of Richmond Inserts in-Reactor ouilding 1. , Allegation AQO-48 concerns coatings which were applied over
" seismic. joints" which were filled with foam and were not to
~
be coated. The TRT reviewed correspondence from TUEC on the subject and the CEL. The TRT found that the joints described in the allegation were in fact expansion joints rather than seismic joints, that the total area involved was 1-
.(; approximately 125 square feet, and that this item had been ) '\* l entered into the CEL. j .b '
1
~
i j In all three cases, the TRT found that TUEC's estimate of d ' the size of the area involved was acceptably conservative, and that entry of the item into the CEL provided an acceptable resolution of the problem.
.I.
! CPSES NRC TRT DRAFT 1 , SSER - COATINGS 4 -
8 NOV 84 C. WELLS
~'
COATINGS PROCEDURES
' W. - ! PAGE 48 In evaluating this issue, the TRT reviewed the governing ,
specification and all pertinent procedures and instructions referenced in"section 9, below. The TRT found that, . N. s'l although specification 2323-AS-31 provides a listing of - items which require coatings and items which do not requiEe coatings, nowhere in the specification or procedures are there any . instructions or requirements for protecting items >
' ~~ ~
which are not to be coated or for inspection activities to -
, assure the adequacy of protective measures which ' are taken.
The TRT confirmed this finding through interviews with CPSES coatings. quality ~ engineering personne1 who _s.tated that no
'~
procedural requirements for masking or inspection of masking f exis t, and that any misapplied coati gs wEich are detectie.d during other inspections are handled on a' case-by-case basis.
,I Allegation AGO-49 concerne overspray of coating materials onto coated surfaces that had previously been inspected. It is alleged that this has been allowed and is co=monplace.
l The TRT reviewed correspondence on'this subject from TUEC and pertinent procedures and examined completed coating work i la Reactor Buildings 1 and 2. The TRT concurs, in. general,
- with the evaluation of this issue provided by TUEC in letter l
, TXX-4 201, June 22, '19 8 4, i.e. overspray is a common l l , phenomenon during the spray applicati'on of coatings and is }
1 not harmful provided that adequate methods are employed to l l
?
, CPSES NRC TRT DRAFT 1
! SSER ' COATINGS 4 8 NOV 84 COATINGS PROCEDURES W. C. WELLS -
PAGE 49 i . . . l detect and correct any excessive or detrimental overspray which , , 1 g occurs. The TRT,found no evidence of excessive uncorrected i 1 . s A
] overspray its' examination of finished coating work at CPSES. -
A However, the TRT noted that the governing procedures do 'not provide guidelines or instructions for the prctection of finished work. - r The TRT found that the lack of instructions or methods for ~ e masking and protecting items not to be coated and the lack l of inspections for adequate masking were the cause of the , j specific def-iciencies described ,in these allegations. , The. t - [' TRT also found that these procedural deficiencies would
- A allow continued and possibly undetected application of .
. coatings to non-specified surfaces which'could result in j failure of such misapplied coatings as well as potential l damage to sensitive plant equipment from coating work
- j activities.
t i E. Allegations AQO-17, AQO-23, AQO-31, ACO-45, and AQO-58 are all concerned with the performance of quality control
- q inspections for coating work at Comanche Peak. These j allegations concern inspections which were not performed or
, ~. .
j were performed improperly, and which were therefore i 1
! inadequate to correctly assess the acceptability of the 3
{ coating work and the applied coatings. i I 'l .
' --. -n..,.--. .
o.-..,.~~ - , -
i i CPSES NRC TRT CRAFT 1 SSER - COATINGS 4 -
~'
8 NOV 84 COATINGS FROCEDURES C. WELLS
, W. -
PAGE 50 l 1
.l; AIR ACCEPTAMCE INVALID: (ACO-17) -
3
-{ .
j This allegation states that the inspections of compressed ' .
, air cleanliness prior to conventional spray application of coatings are invalid because production personnel insert cigarette filters into the air line.immediately ahead of the test point withoat the knowlefge of Q.C. inspectors, and .
~~ '
then remove the cigarette filter after the test. It is i further alleged that construe: ion and Q.C. management were i
! aware of , the practice. The significance of this allegatica .
is that_t.%.-use of compressed air containing entrained oil i
, and moisture which is used for sand blasting, blow down, cnd conventional spray application will degrace the service 4 l ,
t l characteristics.of applied coatings. ; a I
-i , The TRT interviewed inspectors,~Q.C. management, and .
reviewed TUEC's response to this concern given by letter 'l TXX-4201, dated 6/22/84. The TRT found that the described practice did occur, and that the practice has been stopped.
! The CRT found that construction management was aware of the j
practice; the TRT was not able to establish whether Q.A. l management had any knowledge of the practice before this
' ~
concern was raised by insp-ectors. The TRT examined current practices used at CPSES. The TRT .I found that air supply equipment for Unit I was replaced . I, i
- ~
. u.....---.-.. ~.- - ._ ..- - --~ . . - . - . . . - . - . . . - . -
i i i i CPSES NRC TRT DRAFT 1 l SSER - COATINGS 4 8 NOV 84 1 COATINGS PROCEDURES - ~~ W. C. WELLS >{ PAGE 51 i during September, 1983. The TRT found that this equipment +; . . . .! was moved to Unit 2 during August, 1984. During the TRT
! review, the TRT tested the air supply at a Unit II coating . E.
! .I operat, ion and found it acceptable. - - '
~
".'he TRT found that inspector.3 periodically reject compressed air cleanliness, and that replacement of filtering elements .
~' -
is performed and is adequate P.o correct the adverse . conditions. The TRT considers that the experience of the coatings industry indicates that oil and water in compressed air will,nat.have significant adverse effects on coating performance unless present in sufficient quantities to condense. This observation has resul'ted chi the generally . .
, accepted test method, used at CPSES, of holding a clean ' white blotter in the compressed air stream and then examining the blotter for traces of oil or moisture. The -
TRT noted that CPSES procedures require a 30 second test; a 30 second test is at the lower' limit of the range of periods for which this test is typically conducted. l n- . j When oil and water are present in sufficient quantities to l l condense, ef fects upon the applied coatings will of ten be j . . . .
; readily visible to a trained observer, without benefit of l t
the blotter test. Unacceptable quantities of water will I shorten the pot life of coatings in. pressure pots,
, _ _ . _ . , .. -..,=,e-----==-===-e=-*+ +=w,
. . _ _ _ . . . _ _ L _ .c_.. .-- _ _ . . . . . _ . . . _ _ _ _ . . . . . . _ . _ . . _ . . _ .. ~. _ _... - ..
j CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 8 NOV 84
; COATINGS PROCEDURES - --
W. C. WELLS PAGE 52 I - especially for inorganic zines, or cause certain discolorations. Water deposited on surfaces by blasting or blow dcwn will cause rapid rusting discoloration. . I:: n Unacceptable quantities of oil deposited on surfaces by - blasting, blow down, or spray atcmization will cause a visible defect known as " fisheyes,".or a sliding of the coating knosn as " creeping," and may produce discolorations ,
~~~ ' ; of the coating film. Minute quantities of insoluble oils --
I may be retained within coating films without appreciable adverse effect; water will be able to transmit out of the coating S im.- - - l' The TRT examined the current revisions oS'the applicable ^- . TUGCO inspection procedures from the QI-QP-ll.4 series. The l TRT considers that the procedures provide generally i acceptable methods for a properly trained inspector to i identify and verify correction of such defects in the applied coating which might result from the use of inadequately clean compressed air. The TRT found that procedures do nct provide rigorous' methods to limit the l 1 recurrence of the deficiencies. e
- 1 I
l I I 1 i 1 1 I I.__.... y .y . . . . .. . . ,.
. m.. . . - . . . - ---- - -- ..--.. .. - ... .- . ..._.,.,._.j
CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 ~~ 8 NOV 84 COATINGS PROCEDURES - W. C. WELLS - l- PAGE 53 4 COATINGS Q.C. PROGRAM INFERIOR. (AQO-23) t j* Although this allegation represents a subjective judgment, *
. E.
.u it is , concerned specifically with " standard" inspection - '
methods and techniques. It is alleged that the Comanche Peak Coatings Q.C. inspection program is inferior to similar
~
programs at other. nuclear plants because inspection methods .
~' -
used at other plants are not used at CPSES. The example -
) given in the allegation is the American Society for Testing and Materials (ASTM) tape adhesion test which, it is al[ged, was used. regularly at another site, but not allowed at CPSES by one of the Q.C. lead men. ,
.-- e The TRT reviewed TUEC's governing procedures and specification correspondence from TUEC on the subject, and relevant. standards, and censidered common practices at other nuclear power plant projects.
The TRT noted that specific coatings inspection practices and procedures vary somewhat from site to site depending upon each applicant's or licensee's interpretation of regulatory and industry standard requirements, and translation of those requirements into a site-specific quality control program. 4
,ca:. .e*- -
'I
- - - ___..;-_.__________.____ _ . . _ . . _ _. i i l i <
CPSES NRC TRT DRAFT 1
.{ {
? SSER - COATINGS 4 9 NOV 84 i I
COATINGS PROCEDURES - -- W. C. WELLS PAGE 54 i 1 j In terms of the types of inspection techniques, instruments, f and methods employed, the TRT found that CPSES was not 1 . . o -
) appreciably different from other sites as to inspections .
A;
; //
addres. sed by the coatings Q.C. program. - t -- 1 - Specifically in regards to not allowing the ASTM tape l l adhesion test, the TRT does not consider that this , i ~' ~ i demonstrates that TUEC's coatings Q.C. program is inferior. -- 1 .
! The TRT did not find that the ASTM tape test was' regularly f
- or extensively used at other sites, and the TRT did not find any goversing stendard or regulation requiring the use of
'~~
this tes't. When adhesion testing is performed at nuclear ' i sites, the commonly used method is that deploying the 4 Elcometer Adhes_ ion Tester, which is the method addressed by ANSI N512 in relation to testing of samples used for DBA
. tests. The TRT found that the Elcometer Adhesion Tester '
method is the method required by CPSES specification 4 9 2?? + AS-31 and governing TUGCO quality instructions, and it
, was therefore appropriate for TUEC to direct the O.C.
inspectors not to use an unspecified alternate method. e 8
.i I
- f _ _
't
~; CPEES NRC TRT DRAFT 1 SSE2 - COATINGS 4 6 NOV 84 COATINGS PROCEDUlGS - --
W. C. WDLLS PAGE 55 f l LIMITED ACCESS AREAS. ( AQO-31) . . . _ 9 t t -
- s
; This allegation concerns nhe interpretation of CPSES DCA - I; 1 A
#13,140 which addresses performance and inspection of - '
; surface preparation on steel surfaces which had limited access or which were inaccessible. .nevision 2, February 21, 1983, of this DCA, which has been incorperated into the .
~ ~
current revision, (revision 2), of specification 2323-AS-31 - specifies that limited access areas shall b3 prepared to Steel Structures Painting Council (SSPCI specification SP-10 (near-yhite metal- blast), or equal if possib'e, with a 4 r udnimum requirement of SSPC-SP-6 (commerical blast) or equal. The DCA further specifies that insecessible areas. shall be treated on a best efforts basis and that 0.C. inspection on inaccessible areas is not required. The DCA includes . drawings which illustrate and def.ine " limited access" and " inaccessible" areas. It is alleged that Q.C. management interpreted the SSPC-SP-6 minimum requirement for limited access areas to mean "do the best you can" and stated to 0.C. inspectors that if they could nct get to an
; area, not to worry about it.
i i The TRT reviewed all revisions of DCA #13,140, specification t 2323-AS-31, and correspondence from TUEC on this subject. l The TRT recognizes that limitdd access and inaccessible
-l ,-
l
j i '
. CPSES NRC TRT DRAFT 1 ! SSER - COATINGS 4 . 8 NOV 84 COATINGS PROCEDURES C. WELLS -
W. l PAGE 56 areas exist in all. nuclear power plants, where it is not possible to perform coating work operations and inspection activities in'accordance with normal specification ,
. i '
.l requirements. The TRT considers that the requirements in DCA #13,140 provide appropriate instructions for performing and inspecting surf ace preparation work in such areas. The TRT noted that the .'1anges from revision 0, to revision 1, to revision 2 of this DCA provided progressively more -.
explicit criteria for determining the classification of an area or iten as a limited access or inaccessible area.
- w. . . . -
The TRh could not confirm the alleged statements made by Q.C. management to dilute or downgrade thE-requirementsA . specified in the DCA for limited access areas, but the TRT considers it reasonable that such statements may have been made legitimately by way of clarifying or explaining the , distinction between limited access and inaccessible areas. The TRT considers that any areas which have been classified as inaccessible or limited access areas in accordance with i this DCA, do not meet the normal specified requirements for f Service Level I coatings, and should therefore be entered
- 4 into the CPSES CEL. However ' DCA #13,140 makes no provision for entry of these' areas into the CEL as a justification for
_j the downgraded requirements. In TXX-42 62, August 21, 1984, i I A 1 ~;
)
. ,- . s -.-. - ---
.~ -
-- ~ .--. - -- . . :. .- - _ _ . . . . . . . . . . - . . . - . -
CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 ~~ 8 NOV 84 COATINGS PROCEDURES - W. C. WELLS - PAGE 57 j .. TUEC provided an estimate of approximately 6,100 square feet of surface area classified as inaccessible or limited access, and the TRT found that this figure was acceptably '
.i .
.1 conser.vative. Further discussion of the CEL is provided in SSER - Coatings 6.
REINSPECTION OF REPAIRS. (AQO-45) -- i This allegation concerns the reinspection of repairs that are performed - to remedy defects in applied c,oatings. It is alleged that some coatings repairs at CPSES were never reinspected and that other coatings repairs were not given , the same type of final inspection that would have been performed for regular production work. The implied significance of this concern is that repairs which are not
- i~
reinspected properly may have defects or sustain damage which would not be detected and corrected. The TRT reviewed the current gcVerning procedures identified by TUEC, TUGCO QI-QP-ll. 4. 5 and QI-QP-ll. 4-26, and correspondence on this subject'from.TUEC. The TRT also reviewed all revisions of TUEC's procedures' which have governed coatings repair work in the past, including
'I .
~ . ,
t
^
CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 . 8 NOV 84 COATINGS PROCEDURES - -- W. C. WELLS -
~
PAGE 58 1 QI-QP-ll.4-5, QI-Q P-11. 4 -10, QI-QPell.4-26, and
.j QI-QP-ll.4-27. ,
i: The TRT found that the requirements for reinspection uoon ' comoletion of repair work were not clearly addressed in ail cases, although the requirements for inspections to be performed during repair operation were, generally, .
~'
adequately addressed. An example of adequate procedural -- ll address of repair inspection requirements is found in
;k *
]; QI-QP-ll.4-26, revision 6, paragraphs 2.10. 2 and 2.10. 3. These sections provide specific inspection requirements for repaiE~~of both major and minor defects, and include requirements to "perf orm inspection in ser- ~. . 2. 9" A ("?inish Coat F.inal Acceptance Inspection"). This procedure l also includes provisions for a " Steel Protective Coating I <i Inspection Repair Traveler" to document and track repaired
. areas to insure completion of all required inspections. An
- i example of inadequate procedural address of repair inspection requirements is found in QI-QP-11. 4-5, revision 29, May 4, 1984, wherein paragraphs 3.7.2 and 3.7.3 do not 5
ij provide equivalent reqt irements and do not address .{ performance of " Finish Coat Final Acceptance Inspection" (in 1 - ll accordance with paragraph 3.6 of that procedure) for
.l repairs. Similar deficiencies occur in earlier revisions of iI e#
I il i
. . . . _ . = . . . . . . . .-
- t I
CPSES NRC TRT DRAFT 1 i ii SSER - COATINGS 4 - ~' 8 NOV 84 COATINGS PROCEDURES W. C. WELLS - l PAGE 59 the governing procedures. The TRT found that both in .. current and historical' inspection procedures, clear s I instructions were not always provided for reinspection of - F: I '
.- )
i repair.s. --- {!a
- ^
a 4 t i The TRT noted that TUEC has made a distinction between the inspection requirements for " minor" versus " major" repairs, a f .
"~ '
l and this issue was discussed by TUEC in letter TXX-4201, -- 'l .
. June 22, 1984. In regards to this specific issue, the TRT
}
jj ) found that the distinction made by TUEC was appropriate, and i
. considers-that it is acceptable standard industry practice '
.[; to perform final inspection of minor, repairs (such as
} touching up pinholes) during the performaEce of the repa'i,rs.
i ' 'l The TRT also noted that TUEC has stated in correspondence f and interviews that a final visual inspection performed by l
- l! ~
CPSES engineering in accordance with TUGCO Engineering id -Division Instruction CP-EI-4.0-51, revision 1, provides
- assurance that all coated areas, including repairs receive a
, final visual inspection. The.TRT reviewed this procedure s ? and found it inadequate for the purpose stated above in that it does not include visual inspection methods, criteria, or ji adequate documentation of same, and does not require l
1
! performance of such inspections by personnel who are trained ) and qualified in these activities. - .I 1 .
4
,W o. , eegoe- em===== . _ * = * * " * = * * * - *-+- h wenap
- - ~
. - - ._ . :__ _ .c .- . . ..-.~. _ .. - - -
- 1. =-
i i ] .1 CPSES NRC TRT SSER - COATINGS 4 DRAFT 1 8 NOV 84 I COATINGS PROCEDURES - -- W. C. WELLS
! PAGE 60 1 . . . . .
j . However, during examinations of coated surfaces within CPSES I unit 1 containment building, the TRT did not observe any
~
evidence of inadequate or unacceptable coating repair work, ]j M t or of, uncorrected damage to repaired areas. - 8
-"=
INADEQUATE LIGHTING FOR INSPECTION. (AQO-58) . This allegation concerns procedural requirements for illumination used to perform coating inspections and cites
! TUGCO ins.truction QI-QP-ll.4-1 as an example. -
It is alleged j that the instructions provide for inadequate lighting. The implied concern is that inspections . performed under a q - inadequate illumination will not adequately assess.the j quality of the coating and may not identify defects which 1 .
- j are present.
l l ] The TRT reviewed the governing procedures and specifically j.i
't examined QI-QP-ll.4-1, revision 20, March 5, 1984, which is currently in effect. Paragraph 3.0 of that instruction states: " Visual inspection of surf aces as addressed by this 11 instruction shall be made at approximately an arms. length 1 .
j 1 frcm the surface being inspected. The area' of inspection I l
!' shall be adequately lighted during the inspection activity.
1
.i
?
W
.l \
j 1 4.
.-....__~-_._..mpm_- . _ _ _ _ _ _ _ _ . <.._ __.m__-a .. ,_ '-- _-
t I ! CPSES NRC TRT DRAFT 1 f SSER - COATINGS 4 ~~ 8 NOV 84 1 1 COATINGS PROCEDURES - W. C. WELLS -
~
l PAGE 61 j . .- t l Adequate lighting is defined as the minimum light produced by a two (2) D-cell battery flashlight. Flashlight shall be 9 j held perpendicular to the strface during visual inspection." - A;* The TRT considers the language of this paragraph to be l confusing, technically inappropriate, and contrary to - 1 i recognized standard practice for performing visual
! inspections'of coatings. .
~~
t ' l Proper practice involves the examination of coatings work frca dif ferent angles, and sidelighting the surf ace to i ~ j identify- cer-tain' defects (e.g. h.ackle,s or_ protrusions in i
, blasted steel, and blisters, craters, and runs in applied A
l coatings.) It is therefore important thaY visual , 'l inspections require the use of a movable ' light source and i i side lighting of the surface as needed (rather than a requirement to maintain the light " perpendicular" to the i [ surface. The inspector should also have the freedom to vary
! his distance from the surface (both for overall examinations for shadowing and color uniformity, and for closer ; examination of questionable areas) rather than being !~ ; restricted to an " arms length from the surf ace. " The language in the paragraph quoted above regarding light a -
i intensity can easily be misinterpreted, to ~ imply very weak 1
-l light or no light, but even if it means the light provided by a fully-charged, fully-functioning 2 D-cell flashlight, this may not be adequate in all cases.
1 i.. ..-. .
l l
^
CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 8 NOV 84 C. WELLS COATINGS PROCEDURES - W.
~
{ PAGE 62 j ' I i The TRT found that the allegation was correct in that TUEC , provided inappropriate and inadequate requirements for { performing visual' inspections in paragraph 3.0 of . I- [ l . /t'
- QI-Q P- 11. 4-1, revision 20. -
i
.~
} Rigorous adherence to the limitations of this paragraph
; would severiy restrict an inspector's ability to adequately .
~ '
perform visual inspections and to identify coatings defects. -- i h l F. TRACEABILITY'- -
-~
b i ' Allegations AQO-34, AQO-36, and AQO-62 al'I- concern coatings traceability in that they address alleged deficiencies in TUEC's handl'ing, storage, and use of coating materials that would render traceability of applied coating materials to DBA tested batches indeterminate. These three allegations 'l t are evaluated and discussed in detail in SSER - Coatings 3. i j They have been included for discussien in this SSER as well i l for consideration of their procedu'al r aspects. A brief t.
- 1 j summary of these allegations and the TRT's evaluation of i each as provided in SSER - Coatings 3 follows
~. .
4 AQO-34 concerning nonccmpliance with ANSI N45.2.2 for
; coatings material storage was substantiated but considered a not significant because compliance with thati standard is not i
l required by the CPSES FSAR. I i -
p _ . _ __ . . _ . . _ _ _ . _ . _ . _ . . . i CPSES NRC TRT DRAFT 1 I SSER - COATINGS 4 8 NOV 84 COATINGS PROCEDURES - - - W. C. WELLS. PAGE 63 - AQO-36 concerning failure to maintain coating materials
; traceability was substantiated . in regards to areas included
- 1. .
in the Backfit Test Program for which previous records were , i ,
"4 missing or discrepant.
.. e 1 ~ *
- t
{ AQO-62 concerning contaminated materials being applied was
'l ~not substantiated to the extent theh the TRT did not find ,
j evidence that contaminated materials had been applied. - j Ecwever, in the TRT's generic review of TUEC's system for control o,f_soating materials, as reported in SSER - Coatings .
. 3, the TRT determined that the procedurally addressed system ,
f . . _ ll was inadequately rigcrcus in several 'respe. cts. . 3 'i . >l !! Brown & Root' procedure CP-CPM 8.1, revision 1, " Receipt, Storage, ,and Issuance of Items, " provides requirements for [ control o'f stored coating materials prior to issuance to the l[j paint department. However, once m,3terials have been issued i 3 i frem the site warehouse to the paint department, the only stora~ge control requirements are these provided by CCP-30,
- 1. CCP-30A, and CCP-40. These procedures address storage temperature ranges and location of Q materials in the paint storage wa'rehouse segregated -from non-Q materials and little j else. These procedures do not address any physical j inventory control measures or requir.ements for moving
- .f4 materials in and out of the paint warehouse. They do not
. . - . - - - - N:. -~. -
1 CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 8 NOV 84 COATINGS PROCEDURES .. W. C. WEL,LS
.PAGE 64 -
l describe controls to assure the continued segregation of Q
- }i
-j and non-Q materials when they are moved in and out of the i warehotise 'and .are transported to and from different ) ,
1 . ~3 locations on site. ..
' r' t . TUGCO procedure QI-QP-ll.4-17, revision 6, " Surveillance of Storage and Handling of Protective Coatings," provides for ,
'l monthly storage inspection of storage facilities by Q.C. but .. r
. imposes no requirements for more frequent checks to verify physical' control is maintained in the interim and no control by Q.C. of materials during transport on,the job site or w - --
. storags~'at other jcb site locations.
)
__ a
! 5. Conclusions and Staff Positions: Based upon the reviewing of individual allegations described above, the TRT . concludes that:
O A. Allegations concerning DBA qualifications (AQO-fl, AQO-02, AQO-03, ACO-04, AQO-05, ACO-06, AQO-ll, AQO-12, and '1 AQO-15): - 1 I I A detialled' evaluation ^' "- -' '--- of these u t'e.lo.ted +b DBA gual R eanoIWccaf.~,95 allegationsAis provided in SsER - Coatings 2. The t j rndividual items described by the allegations are not significant because they concerned only minor surface areas, l.1 , l i -
._ . . . - . .~ -....... - . .. '1 i ; CPSES NRC TRT DRAFT 1 9 l SSER - COATINGS 4 8 NOV 84 j COATINGS PROCEDURES . -. W. C. WE.L.LS } PAGE 65 -
or because they were properly corrected by TUEC, or because they were not substiantiated.,Mo w n gi doufd b8Mdok YiMf M b. . 4 a , conc ualsRc on 4 o e resses oc hi TRY rechn emain o.a ca.)d are. erns rela.+ed Scope to DBAbged o .. t S6 IrdI V c o ns. "t I i g he significance of ese allegations from a procedural . i
, perspective is that TUEC's failure to properly address -
l ' A- . l special case coating systems for overlaps and repairs, has
- resulted in applied coating materials that are both not ,
- qualified systems, and not technically viable. -
I
?
B. Allegations concerning procedures and instructions which provide te,ch,nically incorrect directions,. (AQO-07, AQO-08,
,. AQO-10, AQO-38, AQO-39, AQO-40, AQO-41, AQO-43, and AQO-44):
Q J a TiW-fouc} the Ass oskiM dMd.YMaW 'E8'" N NCE '0VC\V'd j MC m N oh s po. wh[ti<.Mu de$c. Tion to be,ge.vtetc1Q d.c.r#_{'Td\dj~ .
' ^ ^ ' ' '
The TRT found that TUEC's procedures governing I application of concrete materials as detailed above, were
, i .j not in compliance with the manufacturer's instructions. The !. significance of this finding is that such materials as applied at CPSES may not perform adequately in service or under DBA conditions.
AQO-08: This allegation was not substantiated. j AQO-10: The TRT found'that TUEC's procedures for power tool cleaning surfaces for touch up work, and inspection of this work were inadequate to assure accep, table roughening of the
~
surface. The. significance of this finding is that materials ,l applied to these areas may not exhibit adequate adhesion. I.;. 11
- z. ... y.1 , .._.. .
1 1 . 1 CPSES NRC TRT DRAFT 1 j SSER - COATINGS 4 - 8 NOV 84 COATINGS PROCEDURES - W. C.
-WELLS -
PAGE 66 AQO-39: This allegation was not substantiated. _ j . .. t j AGO-40: The TRT found that TUEC's procedures for removal of I debris from power tool cleaned surfaces were inadequately - E
, .t I rigo'rous, but unlikely to result in undetected defects in applied coatings. This allegation is therefore not significant.
j _ AQO-41: The TRT found that the'use of the foreign cleaning
~ '
i j agent as it occurred at CPSES did not have any a'dverse i effect upon applied coatings, and that current procedures adequately co'ntr'ol future use o# such materials. Therefore this allegation is not significant. ,
.; .-- a j AQO-43 and AQO-44 : The TRT found~that the concerns raised I by these allegations did not result in improper curing of i ; inorganic zinc at CPSES. Therefore these allegation.s are J not significant.
C. Allegations concerning Backfit Inspections (AQO-18,
? AQO-19, AQO-20, and AQO-51):
- l. AQO-51: This allegation was not substantiated.
.) -
1 l 2 I AQO-18, AQO-19, and AQO-20: As discussed above demonstrate
.that backfit inspection procedures were inadequate in
)
l l 1
' ^
.- - ,. 76 7 .. p . ...-.. . ____ ,
,-,___.7_ ;
_7 __. I
l CPSES NRC TRT DRAFT 1 *
! SSER - COATINGS 4 - ~~
8 NOV 84 l COATINGS PROCEDURES W. _C. WELLS-PAGE 67 certain respects, however the TRT did not find that these - , f { inadequacies would have any significant effect upon the d.ata generated by the Backfit Program. (SC.4 OO 5$ ~
, QS i A'
{ D. ' Allegations concerning coatings applied to areas where 1 i they should not have been applied (AQO-24, AQO-42, AQO-48, - l and AQO-49): j
'" ~
The TRT found that the areas described in AQO-24, AQO-42, - f ' i j and AQO-48 have been entered into the CEL and therefore i these al. legations are not significant. AQO-19 was not substantiated. Bowever, the TRT found th_at inadequate li procedural address of protective. measures to be taken for
! items not to be coated resulted in defects which could have i
i been avoided and created the possibility'of unnecessary i [ damage to other plant items. (The TRT did not find evidence l that such damage occured.) 't i f E. Allegations concerning the performance of Q.C.
! inspections (AQO-17, AQO-23, AQO-31, AQO-45, and AQO-58):
i k { AQO-17: Was substantiated in regards to the insertion of
; filters during air acceptance 'ests, t which invalidates those test results. The TRT,did n'ot find any evi~dence that this resulted in defects in the work. However, this allegation 1
1 l-e' _ , _ _ - Ls ?
s i *
} CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 . 8 NOV 84 COATINGS PROCEDURES - --
W. C. -WELLS . PAGE 68 is significant in that it represents interference with the. proper performance of a Q.C. inspection activity and . . therefore renders recorded results for air acceptance tests,
.i -
i and possibly 6ther inspections, indeterminate. ,
.. ?. .
'I . ni
. AQO-23: This allegation was not substantiated.
t i AGO-31: Th'is allegation was not substantiated. . AQO-45 : Was substantiated in regards to inadequate 1 procedural address of reinspection for repair work. The significance of ~this finding is .that there may be undetected and uncorrected defects in repaired areas, although the TRT did not observe any such cases. The TRT~Yound that TUEC',s provisions for.a final engineering walkdown inspections are not an acceptable remedy for this concern. I AQO-58: Was substantiated in regards to inappropriate instructions and requirements for' illumination during visual inspections. The significance of this finding is that
-visual inspections may not have been performed properly and there may be undetected defects in the applied coatings.
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T .. CPSES NRC TRT DRAFT 1 l SSER - COATINGS 4 - " 8 NOV 84 COATINGS FROCEDURES W. ,C . WELLS-PAGE 69 I F. Allegations concerning traceability (AQO-34, AQO-36, and
-. AQO-62): .. . ] .
j A detailed evaluation of the significance of these . E. ll l alle'gations is provided in SSER - Coatings 3. The
- 3 significance of these concerns in regards to procedures is ,
j that inadequately rigorous procedural address of coating material control measures may have resulted in unnecessary . I loss of traceability. -- i. i
. The sign.ificance of all of the allegations discussed above, excluding-those which were not substantiated, in regards to L
the TRT's evaluation of TUEC's proce,dures and instructions governing coating work activities at CPSE3, is that those procedures were inadequate and inappropriate in many respects. This allowed the performance of defective work in certain -instances, which resulted, in an unnecessarily large area of exempt coating work as entered in the CEL. This also resulted in in' adequate performance of inspections in certain instances where the proper performance of those inspections could have prevented or corrected that defective i - j work. The TRT concludes that these procedural deficiencies i demonstrate that review and approval of procedures and
~- . .I instructions by TUEC was ina'dequate to dete'ct and correct l these deficiencies. Inadequate performance of procedures I
review and approval activities demonstrates that the 1 A . . u - .. ._ - - _- _
- . .. _ _ _ . . . . ._ _ _ . _ . . _ . . _ . _ _ _ . . . _ . . . . . . _ _ =
CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 - 8 NOV 84 COATINGS PROCEDURES W. _C . WELLS' PAGE 70 personnel who performed those activites were not qualified - to make the correct technical and quality evaluations of , those procedures. This conclusion has the generic l implication that ' inadequate review and approval of .- '! - n' I proc"edures may .have occured in areas other than coatings'and may have resulted in inappropriate or inadequate procedures '
; and possible defects as a result in other areas or TUEC's construction program.
- O i 6. Actions Recuired:
' l. The TRT found deficiencies in procedures and ,_
instructions for coating work and related'~ inspection ". activities that rendered them inappropriate or inadequate for determining satisfactory accomplishment of important activities. For example: (a) Texas Utilities Generating Co. (TUGCO) procedures QI-QP-ll.4-1, revision 20, QI-QP-ll.4-5, revision 29, and QI-QP-ll.4-26, revision 6, provide inadequate and inappropriate instructions regarding lighting to be used during visual
- inspections of coating work.
This would result in the inability of i . the inspectors to properly detect and identify defects in the work. I . . 1_
. --- ~ . . - . . . . . - . . - . . :( . - - -
I CPSES NRC TRT DRAFT 1 SSEE - COATINGS 4 - " 8 NOV 84 COATINGS PROCEDURES W. _C. WELLS-PAGE 71 l s (b) TUGCO procedure QI-QP-ll.4-5, revision 27, provides ,for , i j acgeptance of turf aces which have been power tool cleaned using i N inappropriate methods. TUEC data on file supports the - n acce'ptability of power tool cleaning only when specific tools and.' I nethods are used. The procedure allows for the acceptance of less . rigorous power tool cleaning, using different tools and finer abrasive gr'ades, which would produce an inferior surface. . (c) Brown & Root procedure #CCP-40, revision 5, provides criteria for cleaning concrete surf aces and for curing times and dry film thicknesses of c6ncrete coating, materials _._.These criteria are
~
contrary to the coating manufacturer,'s instructions.
.-.' A (d) Brown & Root procedure #CCP-30 M-7,' revision 1, requires the use of Keeler & Long coating #6548 to be applied to steel surfaces, . however CPSES specification #2323-AS-31, revision 2, specifies the i
use of Keeler & Long coating materials on concrete substrates only. The TRT found numerous other examples of procedures which were inappropriate, inconsistent, . confusing, and technically inadequate. 3 ,; Accordingly, TUEC shall perform a review of all procedures and
. ~. .
instructions which gov,ern co'ating work and 'related inspection
!i -
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CPSES NRC TRT DRAFT 1
- SSER - COATINGS 4
8 NOV 84
- COATINGS PROCEDURES W. ~
C. WELLS- ) PAGE 72 ! activities which are currently in progress and scheduled for' !I the future, and shall issue revisions to correct all , ,, , inadequacies and inconsi'stencies such as those detailed
~
i above. ,.- .I 1
- ot
- 2. The TRT found that the procedure review and approval system .
which had been employed by TUEC for coating work and inspection procedures was inadequate to detect and correct the type of - i ~ ' j deficiencies detailed in 1, above. The procedural review and
, approval system did not include appropriate review by technically ; qualified individuals, and approval by the coating manufacturers, as require 6 b~y'Afherican National Standards Jnstitute ( ANSI) standard N101.4. ,
i Accordingly, TUEC .shall review and inake the necessary changes to the system which controls the review, approval, and issuance of these procedures. This review system shall provide .for: e (a) Review and approval by technically qualified individuals to
, prevent recurrence of the types of deficiencies detailed in 1 above j i
(b) Review for consistency and clarity, and h l 4 1 l (c), Review and. approval by the coating manufacturers. I I
-l
_....,.~........:.. . - . . , - . . . . i
^
- . - - . . . . . . . ~ . . - - . . . -
l CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 - 8 NOV 84 COATINGS PROCEDURES W. _C. WELLS' PAGE 73 The review process required by item 1 above shall be conducted in accordance with this new system. If this review detec.t.s ,any.
~
areas in which inadequate procedural requirements ' have resulted in .l - s
- l; unacceptable coating work, then the deficiencies shall be -
//
{ docu'mented in accordance with TUEC's Quality Assurance Program, and j proposed dispositions shall be submitted to the NRC for approval , prior to implementation. i 3: l! 7 3:a4 Potential violations: f4) ANSI N1-Oh:4-1972' requires that coating
- ma_nuf acturers approve
, application procedures for their coating systems. Contrary
- to the above, TUEC has not secured approihl for'all ', X application procedures.
1 (b) 10CFR50~, Appendix B, Criterion V requires that } [ " Activities affecting quality shall be presribed by 't' documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished f_ in accordance with these instructions, procedures, or 1
~
drawings. Instructions, procedures, or drawings shall
. include appropriate quantitative or qualitative acceptance
.l
! criteria for determini.ng tha't important act'ivities have been
- t ti satisfactorily accomplished."
~
' /
g CPSES NRC TRT ,' DRAFT 1 SSER - COATINGS 4 -
~'
8 NOV 84 COATINGS PROCEDURES W. C. WELLS-PAGE 74 ,
. i-s Contrary to the above, there arel nany cases in which TUEC,',s
~ '
1 procedures governing the performance and inspection of j , I: l coating work ' activities at CPSES, were inappropriate, or did . not' include appropriate acceptanc'e'briteria, or were not'
- followed. / ~
t An example of an inappropriate procedure is found in TUGCO *
~ '
{ . instruction QI-QP-ll. 4--1", revision '20, paragraph 3.0 which - ! provides inappropriate directions for illumination of areas l ] being inspected and would interfere with the< inspector's abilitr to-de~terinine the acceptab'ility of tih e item [ inspected. , + __ a f
- An example of procedures not being .folloked is the practice of inserting cigarette filters into air lines during the
- performance of,. air acceptability tests, which invalidates I
! those test results. i ) 8. Attachments: None f
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i CPSES NRC TRT DRAFT 1 i SSER - COATINGS 4 - 8 NOV 84 COATINGS PROCEDURES W..C. WELLS' PAGE 75
- 9. Reference' Documents: - -
, a., TUGCO procedure #CP-QP-0.l', revision 226, August 24, 1984, q ~
3
" Quality Procedures Manual Table cf Contents" (and items listed' ;
n ther'ein pertinent to coatings)
- b. TUGCO procedure #CP-QP-2.0, revision 1, October 9, 1979, ,
" Implementation of the CPSES QA Program" ' ;l .
1
,; c. TUGCO procedure #CP-QP-3.0, revision 15, July 30, 1984,
, "CPSES S.ite Quality Assurance / Quality Control Organization"
- d. TUGCO procedure #CP-QP-6.0, revision 5, April 27, 1984, (also revision 3, May 4, 1981 and revision 2, 5Bvember 20, 1979),
" Preparation of Quality Procedures and Ihstructions"
-i t
.) .
l
- e. TUGCO procedure #CP-QP-7.1, revision 9, August 24, 1984, i
;f (also revision 6, March 3, 1983, and revision 2, October 18, I 'l
- 1979), " Issuance and Control of Quality Procedures and Instructions"
.i i f. TUGCO procedure ECP-QP-0.4, revisien 166, August 9, 1984, '
- I i "Protecti e Coating Inspection' Manual Table of Contents" (and all i
i i
, documents listed there.in)
I
- l
.t l
- 1 i
n_w. -
. . . - - ~ . _ -
CPSES NRC TRT DRAFT 1 j SSER - COATINGS 4 - 8 NOV 84 i COATINGS PRCCEDURES - ~' W. C. -WELLS - PAGE 76
< g. TUGCO instruction #QI-QP-ll.4-1, revision 9, September.8, 1982, through 13, August 19, 1983,." Inspection of Stee1 Substrate _ ,
- Surface Preparation and Primer Application"
- i:
- h. 'TUGCO instruction #QL-QP-ll.4-5, " Inspection of Steel '
l Substrate Seal and Finish' Coat Application and Repair" (all revisions) 1< . i
- i. TUGCO instruction #QI-QP-11.4-10, revision 9, September 13," --
] 1982, through 14, August 19, 1983, " Inspection o~f concrete
{ Substrat.e Surface Preparation and Coatings Application and Repair."_ - -
.i '.
~
- j. TUGCO instruction #QI-QP-ll.4-23, rev1sions 0, November 19, 1 1981, through 13, April 18, 1984, " Reinspection of Seal Coated 1
and Finish Coated Steel Substrates for which Documentation is Missing or Discrepant" 4 'i k. TUGCO instruction #QI-QP-ll.4-24, revisions 0, February 5, i; 1982, through 7, April 18, 1984, " Reinspection of Protective. Coatings on Concrete Substrates for which Documentation is Missing or Discrepant"
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l l 1me x.--. . - , . r m : - . w r- - - - - - --
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1 CPSES NRC TRT DRAFT 1 SSER - COATINGS 4 , 8 NOV 84 COATINGS PROCEDURES W. f. KELLS PAGE 77
- 1. TUGCO instruction #QI-QP-ll.4-26, revisions 0, December- 29, 1983, through 6, May 16, 1984, " Inspection of Steel.Subst. rate Surface Pr,eparation, Primer Ap' plication, Primer Repair, Seal and s
Finish Coat A'p plication and Repair" - C;
=
nf
~~
j m. TUGCO instruction #QI-QP-ll.4-27, revisions 0, December 29, , I 1983, through 6, July 11, 1984, " Inspection of Concrete Substrate 'I
- Surf ace Preparation and Coatings Application and Repair"
; n. Brown & Root procedure iCP-CPM 6.1, revision 4, December 22, i
l 1981, " Preparation and Approval of Construction Procedures and Instructions"' '~ , '._.
- o. Brown & Root precedure #DCP-3, revisi6n 18,'May 9, 1984, i .
! "CPSES Document Centrol Program" l
- p. Gibbs & Hill specification #2323-AS-31, revision 2, March 15,'
1984, (also revision 1, March 15, 1978), " Protective Coatings" i
- q. Brown & Root procedu're #CCP-3.0, revision 0, July 16, 1976, t .
j, through 12, March 4, 1984, " Coating steel Substrates Inside -l i Reactor Building & Radiation Areas" t e r. #TXX-4201, letter . dated '6/22/84, concer'ning allegation
#AQO-040r. Brown & Root procedure #CCP-30A, revision 0, October I
7 17, 1979, through 4, March 4, 1984,'" Coating Steel Substrates Inside Reactor Building &. Radiation Areas" i = i l
~ z.-=
.:... ...__a--.
s' . Brown & Roo't procedure (CCP-40, revision 0, November 29, 1977, through 7, March 4, 1984, "Yrotective Coating _of rencrete Surfaces" .. e.- e 6 4
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O Wg ~ Dockets: 50-445 h [ 50-446
- b i la Texas Utilities Electric Company ATTN: M. D. Spence, President, TUGCO Skyway Tcuer 400 North Olive Street Lock Box B1 Dallas, Texas 75201
Dear Mr. Spence:
SUBJECT:
COMANCHE PEAK REVIEW On July 9,1984, the staf f began an intensive onsite effort designed to complete a portien of the reviews necessary for the staff to reach its decision regarding the licensing of Comanche Peak, Unit 1. The onsite ef fort covered a number of . areas, including allegations of icpreper construction practices at the facility. On Septe=ber lu, 1984, th : zet with you and other Texas Utilities Electric Cczpany representatives and pro /ided you with a number of technical issues in the general areas of electrical / instrumentation, l 1 civil / structural, and test progracs having potential safety implications. I l The issues discussed censtitute a portion cf the te.chnical issues and ' allegations being evaluated by the Technicci Revieu Team (TRT). F01A-85-59 4 -
Texas Utilities Electric Company . The activities of the IRT have progressed to the point where it is appropriate to provide you with additional itees that have potential safety i=plications for which we require additional information. These items are in the general areas of Coatings and Miscellaneous Itecs and are listed in the enclosure to this letter. Further backgrcund informaticn regarding these issues will be published in 1 a Supplement to a Satety Evaluation Report (SSER), which will J docu=ent the overall TFT's assesseent of the significance of the issues examined. The items in the enclosure to this letter cover only a portion of the TR affort. The TRT evaluation of items in the areas of eechanical, QA/QC, and the TRT consideration of the progra=matic i=plications of these findings, are still in progress. A summary of these issues vill be provided to you at a later date. You are requested to submit additional information to the NRC, in wr 1, including a progra= and schedule for completing a 1 detai ind thorough assessment of the issues identified in the ] l enclosure to this letter. This program plan and its implementation , l will be evaluated by the staff before NRC considers the issuance j l
Texas Utilities Electric Company of an operating license for Comanche Peak, Unit 1. The program plan should address the rcot cause of each problem identified and its generic implica-tions on safety-related systems, programs, or areas. The collective significance of these deficiencies should also be addressed. Your program plan should also include the proposed TUEC action to assure that such problems vill be precluded from occurring in the future. Inis request is submitted to you in keeping with the NRC practice of promptly notifying applicants of outstanding information/evalua-cion needs that could potentially affect the safe operation of their plant. Future requests for additional information of this nature vi?.1 be made, if necessary, as the activities of the TRT progress. Sincerely, Darrell G. Eisenhut, Director Division of Licensing, NRR
Enclosure:
1 As stated ' cc w/ enclosure: i See next page i I l
4 ~.. REOUEST FOR ADDITIONAL INFORMATICN
*IV. Protective Coatings Area
- a. Backfit Test Program The Technical Review Team (TRT) reviewed the procedures used and the inspection reports (PCRs) and statistical data resulting from the Coatings Backfit Test Program.
For the 2189 miscellaneous steel ite=s (such as pipe hangers, cable trays, and equipment and conduit supports) that were tested under the backfit test program fro: about Dece=ber 1981 to February 1984, the TRT found that TUEC did not correct any of the coating adhesion test field data to account f or the calibration error of the Elcometers used for the tests. Consequently, the field test data could be in error by as much as 200 psi in a nonconservative direction. Thus, any Elcometer reading less than 400 psi potentially represents a test that
- failed to meet the test acceptance criterion of 200 psi.
l 1 l
- Parts I, II, and III vere provided in the NRC letter to you of a
! Septe=ber 18, 1984. I
f Based on TRT analysis of sampled data covering 78 test results for 42 miscellaneous steel items, the appropriate calibration correction could increase the adhesion test failure rate fro ='about 1% to 19%. The following inspection reports (PCRs) indicated acceptable test results ( 200 psi) before correction but unacceptable test results ( 200 psi) af ter correction: PCR-02103 PCR-02164 PCR-02105 PCR-02166 PCR-02515 PCR-02171 Accordingly, TUEC shall:
- 1. Apply the E1cometer calibration correction to the data
, for the 4714 adhesion tests covering 2189 miscellaneous steel items tested to establish a core reliable esticate l 1 l l I d
J i 1 l of the adhesion test failure rate. This revised i analysis should include a statistical analysis shewing the 95% confidence upper limit of the failure ratt for all j the miscellaneous steel items inside the containment building.
; It is appropriate to assume that the approximately 22% of the total miscellaneous steel coated surface that was backfit tested is a representative sample of the remaining miscellaneous steel surface.
- 2. Analy=e the corrected data to establish a core relicble i
esticate of the fraction of tested .. cellaneous rteel coated surf ace that f ailed the adhesion test acceptance criterion. The resulting failed at should be i repaired /reworke'd or be otherwise dispositioned, such as by l entry in the Protective Coating Exenpt Log (see itet IV.f. i' below). i 4 i }
- b. DBA Qualification Testing I
- c. Coating Traceability 4 The Technical Review Team (TRT) reviewed the coating materials control and traceability to determine the adequacy of the measures employed by TUEC to assure,that coating materials which were applied at CPSES retained their qualifications i
by virtue of tr eabi ity to centing caterials which passed original Qualification Design Pasis .\ccident (DBA) tests. j The TRT reviewed satf work inspec-ion records, coating material receiving and warehoure records.. vendor surveillance records, and coating material tanufacturers' certifications, and observed site coating storage areas and coating mixing and use operations.
- 1. The TRT fot de tiencies in CPSES records that rendered the traceabilit, of r :e coating materials indeterminate.
Examples are as follows: coating work inspection reports PC01279 and PC03650 contained discrepancies between mixing l i and application dates that invalidate the traceability of the batches recorded. l i
. .-. --~
l i i l l Many other inspection recores, for inspections conducted prior to November 1981, contained deficiencies such as lack of signature and missing or discrepant data which render the inspection reports unacceptable. Examples of such records are: PC0 Nos. 3506, 3508, 3511, and 3657. No receiving inspectio, records or manuf acturer's certification could be located for coating batch No. OM2708M of Carboline Carbo Zine 11. Additionally, TUEC letter to the TRT, TXX-4201, dated June 22, 1984, stated, " Traceability does not exist in all cases for centings applied prior to November 1981. These coatings, hcwever, are within the scope of the backfit inspectica program which determines their adequacy." The TRT censiders that the backfit inspection program and the backfit inspection records do not restore traceability or DBA qualification of applied cor. tings for which deficient previous records cannot establish traceability or DEA qualification. The backfit inspections only determined the adhesion and thickness of the applied coatings at the time those inspections were perforced. These two physical attributes alone do not demonstrate that the applied
t
- coating materials are certified nuclear-grade materials which have been manufactured, stored, mixed, and applied without alteration or contamination, and do not demonstrate that these materials are qualified in accordance with ANSI N101.2 and N512, as discussed in Section lv.b. above.
l 1 Accordingly, TUEC shall conduct an investigation to identify 4 the amount and location of surface areas for which material traceability does not exist, and shall provide this informa-tion to the NRC. This information vill be used by NRC 1 to assess the validity of the Backfit Test Program ! (see IV.a. above).
- 2. The TRT screened a number of coatings NCRs and selected
- four which affected traceability. Of these four, the TRT found that NCRs C-81-01724 and C-81-01673 provide "use-as-is" dispositions for discrepant coating materials but do not provide an adequate technical basis for this disposition.
t kk, Furthermore, there is no record that TUEC investigated the {
,g F If cause or origination of the deficiencies,.or tock any action to correct that cause by increased surveillance of the manuf acturer or changes to the materials handling, storage, control, and use system at CPSES, as appropriate. The TRT
, noted other exampics of discrepant coating eaterials that i vere rejected or returned to the vendor. )
. i Accordingly TUEC shall: (a) provide adequate technical
- justification to de=onstrate the acceptability of the batches of coating materials listed in these NCRs or, alternately, identify and quantify the areas where these these batches were used and place these areas in the coatings exempt log; (b) review all other NCRs which
~
were dispositioned "use-as-is," TUEC shall identify
- the batches and provide adequate technical justification for their acceptance or identify and quantify the areas where they were used and place these coated areas in the coatings exempt log.
- d. Coating Procedures
- e. Inspection and Nonconformance Reports
- f. roating Exempt Log (CEL)
The TRT has conducted a generic review of the operations of the CEL at CPSES. This log was established by TUEC procedure No. CP-EP-16.4, " Protective Coatings Exe:ption Log," to " provide the cathod for caintaining identification of items and/or l areas that do not meet project coating requirements." i
The TRT interviewed several TUEC civil engineering and QA personnel regarding the CEL and examined a number of documents by which scme of the larger areas (larger than 1000 feets) were placed in the log. These documents. included TUEC memorandum QTQ-416, DCA 17, 142; NCR-C-84-00710; DCA.6114, Rev. 1; DCA 12, 374, Rev.1; DCA 16, 106; and NCR-C-84-1488, Rev. 4.
- 1. ~.n its review of the CEL system, the TRT found that
! TUEC procedure No. C'F-EP-16.4 places responsibility for approving items to be included in the CEL with.
the civil engineer or his representative. However, CP-EP-16.4 provides no specific direction and criteria to assure that items not meeting project ! coating require =ents and not scheduled for repair or rework are systematically entered into the CEL. Accordingly, TUEC shall a=end the CEL procedure 4 to provide such specific direction. The procedure should make it clear that all discrepant items which meet the following criteria shall be l
- . _ - . ~- -
I l 1 automatically included in the CEL: (a) dispositioned "use-as-is" by NCRs, (b) have been downgraded from service Level I by DCAs, or (c) deternined not to meet project coating requirements by the civil l . engineer based on vendor equip =ent specification.
- 2. The TRT reviewed some of the larger area items in the CEL, provided by the TUEC letter dated August 10, 1984.
The review examined the document; e.g. , NCR, DCA, . hat led te the inclusien of the ite= in the CEL, and the cethod of estimating the coated surface are of the item. i In the course of its review, the TRT found a number of items that should be included in the L. The largest of these are. the areas of miscellanecus steel, concrete containcent liner which f ailed the coating backfit t est f program adhesion tests af ter the original data were corrected for the E1cometer calibratica error (see Section IV.a. above).
- A second additional item for the CE nvolves coated areas with deficiencies other than poor adhesion. For example, I
a nunber of UCRs relating to unsatisf actory Dry Filn Thickness (DFT) (C-83-03103, Rev. 2; C-83-03104, Rev. 2; and C-83-03105, Rev. 2) direct that all miscellaneous steel itecs with unsatisfactory DFTs be "used-as-is" and be entered into the CEL. 2
b TRT cound find no records showing that all of the discrepant . miscellaneous steel ite=s have been included in the CEL provided by TUCCO in the letter dated August 10, 1984. Also, according to interviews between TRT and TUEC, QA personnel, a number of discrepant areas were still not finally dispost-tiened by either rework or entry into the CEL. All of the coated areas not meeting project coating specifications should be entered into the CEL. A third p' roble: area which is not included in the CEL involves more standard coa:ings which were not D3A qualified ( ec S : tion IV.3. above). One of these areas is where inorganic zinc coatingn vere applied over organic topt .t i overlap areas surrounding repairs to i protective ccatings over steel. By letter dated i August 21, 1984, TUEC estimated this overlap area to be between 2,500 feets and 6,500 feets, Before including the three additional areas discussed above, the EL i vided by TUGC0 in the letter of August 10, '84, dentified approximately 55,000 feet 8 of unqualified or indeterrinate coatings. This value 1 i 4
n is already considered high by the TRT, and may be doubled by including the three additional items. However, a reasonably accurate estimate of'the amount , of unqualified coating is required to assess the safety and quality aspects and can be of use in planning an performing inspections such as inspecting for debris that could restrict containment sump inlets as specified in Section 4.5.2.d.2 of the proposed CPSES .'echnical Specification of the protective coatings. . Accordingly. TUEC shall provide updated estimates of the amounts of each type of nonconforcing or discrepant area which will be entered into the CEL.
- g. Training /Qttalification of Personnel -
7N The TRT reviewed the requirements for the training and qualification of protective coatings application (painters)'
'd inspection personnel, interviewed randomly-selected arsonnel, and examined records of personnel training and ,
certification, j 1 l l
- 1. The TRT found that inspector qualification files do not provide documented objective evidence adequate to establish or demonstrate the capability of personnel to perfor= their duties. Specifically:
Inspector files do not in all cases contain evidence of verification of education and prior employment used as a basis of qualification. Experience cited by inspector certifications as a basis for qualification in some cases includes related experience which is not experience in equivalent inspection activities. This experience is cited in some cases as a basis to reduce training 4 requirements. l Records of on-the-job training (0JT) do not provide j sufficient detail to demonstrate that inspectors have received instruction and practice in the performance h and documentation of each activity which comprises a complete inspection task. Further, OJT records do not, in most cases, indicate that the activity was successfully performed. i 1 e m - ,_- _ . _ _
s Written examinations for Level I inspectors do not provide detailed or comprehensive testing of the individual's understanding of important generic and specific requirements, such as the identification of nonconforming conditions or conditions which might adversely affect the accuracy of instruments. Written examinations for Level II inspectors do not provide comprehensive or detailed testing of the individual's capability to prepare reports, provide technical direction to Level I inspectors, or perform the special functions of Level II inspectors described in ANSI N45.2.61978 and CP-QP-21. Examinations are not consistently and properly graded. For exa=ple, disproportionate credit is given for examination responsed which do not fully and properly identify each important element in the prepared answer key. There is no documented evidence that inspectors have read the ennufacturer's recot= ended practices for the operation e instruments, where those ' recoc=endations are used as instructions for operational method in accordance with the requirements of a site specification or procedure.
l : 1 ? l i t l Certain qualification examinaticas include both a I written test and one or more practical ('* hands-on" demonstrations) tssts. The scoring of each part ! (written and practical) is ecmbined for the total examination scors. The practical tests are effectively scored en t pass / feil basis, and provide ' up to $0% of the total examinatiets score. The result is that inspecters who ptcvide incorrect i responses to as mush as 40*. of the written questions still achieve the einimum 90" pascing grade on the total examination. Practical examinations are not included for some important operations in each qualificatipn examinatic 1 Color vision requirementa vere vaived for cnc inspector who failed 75" of the color visica test en the basis of the inspector's ability to identify colored earking pens.
- Documentation of reading and suppleetntal training to maintain the proficiency of 17spectors is tot in all T
cases reviewed by the [ . implener.ted and included in qualification f$1ce. Tor exarple, this is speci-fically the case for revisions te project inspection, work, and quality assurance requirements
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i 4 1 3 Examinations and evaluations indicated by OJT instructor certification forms are not specifically designed or given to evaluate the individual's capability to perfors the certified function; e.g. , instruction. j i Examinations and evaluations indicated by inspector ! recertification forms are not specifically desigred or j 4 , given to evaluate the individual's continued capcbility i to perform the cercified functions. 1 i ! Accordingly. TUEC shall review all coatings QC inspection ! personnel training, qualification, c t *ication, at.d i Q recertification files against project requireients and 1 i provide the information in such a for : t each ree,uire- i
! ment is clearly shown to have been cet by each individual. l This review shall include the deficiencies identified ,
above plus other qualification deficiencies detected during th review. If an individual is found not to ; meet the training, qualification, certification, or j recertificatica requirements, TUEC t ' review the !
- i records to determine the adequacy of n ections,
, evaluations, and approvals cada by the unqualified l
, individuals and provide a statement on the 'icpact of ,
1 j the deficiencies noted on the safety of the project. l l TUEC shall also indicate the corrective actions taken j i i or to be taken to prevent recurrence of the deficie7eins. . t
~. _ - _ -_ . =
- 2. The TRT found that inspectors have not, in all instances, I been fully notified of their certification status, and may, therefore, perform prescribed prior to certification.
l Accordingly, TUEC shall establish nessures to promptly 1 , notify inspectors of each initial certification, OJT
; instructor certification, recertification, or other enange in certified status. .
t
- 3. The TRT found that some individuals certified as Level III 3 .
i personnel and assigned to positicns of responsible QC ! supervision have < 'ification file.s thct do not de=enstrate ' the required capability. i ! I Specifically, the qualification files of these individuals may lack documentation of required previous technical experience with the teneric coating systees c<ed at CPSES ' i and may lack docueented st Wy of applicable specifications, i standa;ds, and procedures, or other bases for qualification
- vhich eight suppe heir capability to perform the functions ,
] described by prev ec for their positions. $ 1 i i
- Accordingly, TUEC shall verify that each individual certified I to Level III capability for protet.ve coatings bas ecmpleted.
d ] prior tc certification, the docu:ented study of applicable , i
l ' l l l l project requirecents and, where the individual lacks l specific and extensive technical experience with coatings, i has completed on appropriate course of study of the I technical chart.cteristics of the coatinEs and ccatings applicatien and inspection processes used at CPSES.
- 4. The TRT found that the training and procedure for the
" nickel test" used to verify the cure of inorganic zinc coatit.gs is not performed in accordance with the manufacturer's statement cited by TUEC letter TXX-4201, dated June 22, 1984.
t Accordingly, Tt!EC shall revise procedures CCP-30 and P-30A and required training to explicitedly correspond to the statement in item No. 2 of the referenced manu-facturer's letter and shall document the training of inspectors in the content of the revised procedure.
- 5. The TRT found that the method and content of the for=al l
l raining session required prior to certification of I l
, ainters is generally adequate, useful, and appropriate, 1
! but contains inaccurate or incomplete information on important subjects. Specifically:
J i s 4 Some procedural requirements are not adequately emphasized; i.e., "should" instead of "shall I *
-Inspection hold points are not adequately' delineated; e.g., hold peint definition, hold point prior to $ application i
Good application techniques are not fully covered by i [ the outline; i.e., adjustment of spray equipment, I treateent of complex spray applications such as
- i i corners and radii, prevention of spray application l
! errors such as arcing of the gun. l l j Painters regularly use instruments to check their work (e.g., wet film and dry film thickness gauges); training in the accurate use of these instruments l i is not indicated by the training outlines. ~ Accordingly, TUEC shall review and update the 1 l applicator's training guidelines in accordance with the t
- above commentary.- L i
- 6. The TRT fotand that painter certification docueentation .
l i contains instances cisleading or incocplete information. i This can result in painters being assigned work beyond } their true level of experience. e
e I S Specifically, many certifications state that, " Employee l has previous experience as a painter," without identifying the nature (i.e., previous application or assistance a experience for nuclear, industrial, commercial, or architectural coatings) or extent (e.g., period of
; full-time professional work) of the stated experience Many certifications state that the employee has
" experience with the following product types:
zines, phenolines, epoxies, latexes, enamels, and i ! thinners . . . . ." and do not qualify the type of i - j experience. Painters are credited with this experience i l l towards application certification when that experience ' a I #
/
may be limited to providing support to certified applicators at CPSES, and not include previous application experience which supports the painters qualification basis. l l Accordingly, TUEC shall provide statetents of the paister's , claimed experience on certification documentation, in accordance with guidelines indicated above. 1 a k &
- . _ . _ . - . . - . . . . . . . . ~ . . ..
,! ' ' ' . " . Docum2nt Mame: I ' TUGC0 LETTER 10/1/84 Requestor's ID: L f NORMA , (/ i 0 , ',,~ ' '" ' ~ . Author's Name: Poslusny Document Comments: 11/25/84 REDRAFT PLEASE RETURN THIS SHEET
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4 . 4 1 Docket Nos.: 50-445 l ,
, and 50-446 i
Mr. M. D. Spence Presider.t , Texas Utilities Generating Company - 400 horth Olive Street - Lock Eox 81 ' Dallas, Texas 75201 ' i -
Dear Mr. Spence:
Subject:
Comanche r ak Review On July 9,1984, the staff began an intensive onsite effort to complete a por-tion of the reviews necessary for the staff to reach its decision regarding the licensing of Comanche Peak, Unit 1. The onsite effort covered a number of areas, including allegations of inproper construction practices at the facility. On September 18, 1984, the NRC met with you and other Texas Utilities Electric Company representatives to provide you with a number of technical issues in the electrical / instrumentation, civil / structural, and test' program areas having
~
potential safety implications. The issues discussed constitute a portion of the technical issues and allegations being evaluated by the Tcchnical Review - Team (TRT). The activities of the TRT have progressed to the point where it is appropriate 1 i' to provide you with a status of additional items under review and to request
~
additional information. These items, in the coatings, mechanical, and miscel-1aneous areas, are listed in the enclosure to this letter. Further background information regarding these issues will .be published in a Supplement to a Safety I Evaluation Report (SSER), which will oocument the TRT's overall assessment of
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the significance of the issues examined. ' i
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.l The items in the enclosure to this letter cover only a portion of the TRT's effort. The TRT's ongoing evaluation and conversations with allegers may re- ;j veal additional items in the coatings, mechanical, and miscellaneous areas for which additional requests for information may be appropriate. Also, the TRT ; evaluation of QA/QC issues, and its consideration of the programmatic implica-tions of these findings, are still in progress. A summary of these issues will be provided to you at a later date.
You are requested to submit additional information to the NRC, in writing, in-cluding a program and schedule for completing a detailed and thorough assess-ment of the issues identified in the enclosure to this letter. This program plan and its implementation will be evaluated by the staff before NRC censiders the issuance of an operating license for Comanche Peak, Unit 1. The program plan should address the root cause of each problem identified and its generic implications on safety-related systems, programs, or areas. You should also address the collective significance of these deficiencies. Your program plan should also include the proposed TUEC action to assure that such problems will not occur in the future. This request is submitted to you in heeping with the NRC practice of promptly notifying applicants of outstanding information needs that could potentially affect the safe operation of their plant. Future requests for add Nional information of this nature will be made, if necessary, as the activities of the TRT progress. Sincerely, Darrell G. Eisenhut. Director Division of Licensing Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/ enclosure: See next page 3 I
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h ! DISTRIBUTION: Docket File } NRC PDR } L PDR PRC System LBf1 R/F MRushbrock RWessman RCTang SBurwell . L. Shao R. Bangatt R IV
- W. Cummins, R IV-
, .C. McCracleen . P. Matthews S. Mou l + l e 1 1 i i t I CP:TRT D:DL -
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I i 1 , REQUEST FOR ADDITIONAL INFORMATION !, IV. Protective Coatings Area } i
- a. Surveillance and Test Program for Coatinos The protective coatings Technical Review Team (TRT) reviewed the backfit program, design basis accident qualifications, traceability, application and repair procedures, training, coating exempt log and dispositioning of non-conformance reports. Concurrently, the staff is evaluating the effects on containment emergency sump performance of paint and insulation debris.
The results of the two concurrent reviews will be combined in one supple-mental safety evaluation which is scheduled to be issued by January 1985. Actions required for resolution of protective coatings issues will be delineated in the supplement. V. Mechanical Area
- a. Inspection for Certain Tyoes of Skewed Welds in NF Supports The TRT investigated inspection orocedures of Brown & Root (B&R) for welds
, in pipe supports designed to ASME III Code, Subsection NF. The TRT found that no fillet weld inspection criteria existed for certain types of skewed welds. By definition, skewed welds are those welds joining (1) two non-perpendicular or non-colinear structural mem.bers, or (2) two members with curved surfaces or curved cross sections, such as a pipe stanchion (a sec-tion of pipe used as a structural member) welded to another pipe stanchien
, or to a curved pipe pad. Notice that for type (2), the effect of curva-
[ ture at the weld connection induces skewed considerations, even though the j two joining members are physically perpendicular. The B&R weld inspection j procedures CP-QAP-12.1 and QI-QAP-11.1-28 for NF supports have addressed type (1) skewed weld; however, the TRT found that QI-QAP-11.1-28 did not include weld inspection criteria for type (2) skewed welds. Although t-i er n ----
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1 ' i i l the TRT was told by B&R personnel that procedure QI-QAP-11.1-26 for piping j weld inspection was used, since such weld connections were similar in con-figuration to a pressure boundary stanchion attachment weld, no evidence ~ documenting the use of this inspection procedure was provided to the TRT. q
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A'ccording to recoFds~ieVie'wed by the TRT, these welds were actually cate-gorized as "all other welds" rather than " skewed welds" on the required QC checklist. Instead of using fillet weld gauges for measuring the size of nonskewed welds welders were supposed to use a straight edge and a steel scale for measurement for a type (2) skewed weld, as described in QI-QAP-11.1-28., In addition, due to the variable profile along its curved weld connection, the weld size should have been measured at several dif-ferent locations. The lack of inspection criteria and lack of verification of proper inspection procedures being conducted for type,(2) skewed welds are a violation of ASME Code for NF supports committed to by TUEC in FSAR Section 5.2.1 and a violation of Criterion XVII in Appendix B of 10 CFR 50. The TRT reviewed weld inspection procedures, weld data cards , and visually inspected several type (2) skewed welds in randomly sampled NF supports where pipe stanchions were used. Although the small sample of welds inspected by the TRT are acceptable, due.to deficiencies in inspection records and the apparent lack of inspection criteria, the TRT is not cer-tain whether other type (2) skewed welds were inspected properly. This is a generic issue involving many NF supports in various safety-related sys-tems. The lack of dccumented inspections and criteria for type (2) skewed welds in NF supports represents a safety concern regarding the possible existence of under-sized welds in supports which are required to resist - various design loads. Accordingly, TUEC shall (1) Revise B&R weld inspection procedures CP-QAP-21.1 and QI-QAP-11.1-28 to properly address type (2) skewed welds of stanchion to stancrjion i and stanchion to pipe pad; and, j i
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j % i (2) provide evidence to verify that previous inspections of these types f of skewed welds were performed to the appropriate procedures.
- b. Improper Shortening of Anchor Bolts in Steam Generator Upper Lateral j
Suoports The TRT was informed that some anchor bolts in the steam generator upper support beams were shortened during installation to less than the length shown on the design drawing without proper authorization. The TRT was told that the bolt cutting incident occurred either because the hole of the anchor device was filled with debris, or the threaded portion of the bolt had concrete mix stuck to it. There are 18 bolts at each end of each of 4 beams, totalling 144 bolts. There is one beam for each steam genera-tor. The bolt threads into an anchor device embedded in the concrete wall. The acceptable bolt length or the length of bolt available for threading into the anchor device is vital to ensure structural capability of the support beams. The TRT attempted to review TUEC records for ultrasonic (UT) measurement results and general installation practices. The TRT was told that ultra-sonic testing of these types of bolts was not a procedural requirement; however, TUEC was unable to provide any other installation records for TRT I review. The TRT concludes that such unauthorized bolt cutting and lack of installation inspection records is a violation of QA procedures and Cri-terion XVII in Appendix B of 10 CFR 50. Since the support beams are essen-tial to provide lateral restraint for the steam generator during a LOCA or seismic event, adequate anchoring capability of the bolts has safety sig-nificance and, as a result, appropriate measures are needed to ensure conformance with General Design Criterion 1 of 10 CFR 50. j Accordingly, TUEC shall provide evidence, such as ultrasonic measurement results, to verify acceptable bolt length. Should unauthorized bolt j cutting be verified, TUEC st.all:
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Q a ~V 10 4 (I) replace shortened bolts with bolts of proper length, or provide -) analysis to justify the adequacy of shortened bolts as installed; j and, '2 (2) provide justification or propose measures to ensure that no similar concern exists for bolting.
. c. Desian Consideration for piping Systems Between Seismic Category I and Non-Seismic Catecory I Buildings In April 1984 the Comanche Peak Special Review Team (SRT), formed and coor-dinated between NRR, IE and Region II and IV, performed a limited review of Comanche Peak. The TRT, in reviewing the SRT findings in the area of
. piping design considerations, has discovered that piping systems, such as Main Steam, Auxiliary Steam and Feedwater, are routed from the Electrical Control Building (seismic category I) to the Turbine Building (non-seismic category I) without any isolation. To be acceptable, each seismic cate-gory I piping system 'hould s be isolated from any non-seismic category I piping system by separation, barrier or constraint.
If isolation is not feasible, then the effect on the seismic category I
] piping of the failure in the non-seismic category I piping must be I,
considered (CPSES FSAR 2.78.3-13.1). I For CPSES, FSAR section 3.7B.2.8 establishes that the Turbine Building is a non seismic category I structure and failure is postulated during the seismic (SSE) event. The effect of Turbine Building failure on any non-r isolated piping routed through the Turbine Building from any seismic
, category I building must be considered. ,
In addition, for non-seismic category I piping connected to Seismic l Category I piping, the dynamic effects of the non-seismic category I' piping
- j must be considered in the seismic design of the seismic category I piping
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fU.NM.7Ed. 2--- j- M'O 'i 1 and supports, unless TUEC can show that the dynamic effects of the i j non-seismic category I piping are isolated by anchors or restraints. The i .i anchors or restraints used for isolation purposes must te designed to
- withstand the combined loading imposed by both the seismic category I and '
i Y non seismic category I piping. 1 i I 'i Accordingly, TUEC shall provide analysis and documentation that the piping systems routed from seismic category I to non-seismic category I buildings meet the stated FSAR criteria. 1
- d. Plug Welds'
'i l The TRT investigated alleged generic problems regarding uncontrolled j repairs to holes existing in pipe supports, cable tray supports and base plates in Units 1 and 2. These holes,. which had been misdrilled during j fabrication, were repaired by plug welds. Since these supports are Seismic l Category I supports and the effects of the welds have not been evaluated, i this constitutes a violation of Criteria IX and XVI of Appendix B to 1 10 CFR 50. Region IV inspections have ccnfirmed the existence of such ] welds in cable tray supports located in the Unit 2 Cable Spreading Room, j Although the effects of unauthorized, undocumented,and ~uninspected plug j welds in some locations (e.g., the webs of I-baams or in structural members p 1' in compression) will be inconsequential, their effects in critical loca- y . tions (e.g., flanges of I-beams in flexure or in structural members in f tension) in critically loaded supports or base plates could affect their 4 structural integrity and intended function. Accordingly, TUEC shall perform one of the following: l
. (1) Modify its proposed plan to Region IV (TXX-4183 and TXX-4259) to } include a sampling inspection of all areas of the plant having plug welds, to include cable tray supports, pipe supports and base -
j i plates. Propose alternate methods of inspection where the oblique l W C " 9 s - u
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] of paint). Perfom an messment of the
- ffects on quality due to j uncontrolled plug welds u.und during the prvased inspection, as
] modified above. Submit a ruort documenting W results of the in-
.nection and assesscent to the NRC for review.
(2) Per: s m bounding analyses to asses > the generic effects of uncon-trolle plug welds on the ability of oipe supports, cable tray sup-
, ports au base plates to serve their intended function. Submit a report dog e*nting the results of the assessment to the NRC for review.
i e. InstallationcQSinSteampipes t The TRT investigated an allegation that a Unit I main steam line, which had been installed incorrectly, had been forced into proper alignment after flushing operations by use of the main polar crane and come-alongs. It was j also claimed that pipe supports had been modified to maintain the line in its forced position and vibrations following detachment of the flushing { line could have damaged the main steam line. Based on its investigation, I the TRT determined that the alleged incident pertained to restoration of the Unit 1, loop 1 main steam line to its initial, correct installation post- 'I tion. (The line had shifted during flushing. operations due to the weight l of the added water and because the temporary supports sagged.) The TRT
] '
also determined that the modifications to permanent pipe supports were necessary to provide proper support to the main steam line in its restored I position (initial designs for and construction of the supports had been
) based on the shifted position of the line) and, although the alleged vi-l brations could not be confirmed, their associated stresses might not have j damaged the main steam line. (The highest stresses would have occurred in j
the weaker, temporary flushing line.) The TRT review of a TUEC analysis, !
- performed 1 year after the incident, concluded that the analysis was incom-plete. An evaluation for the full sequence of events leading up to the I
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l j incident had not been performed. The TRT review of Gibbs & Hill Specifica-tion No. 23?3-MS-100 indicated that there were inadequate requirements and 4 construction practices for the support of the main steam line during flushing, and for temporary supports for piping and equipment in general.
] In particular, evaluations to assure the adequacy of temporary supports j during flushing and installation were not required. The deficiencies in i
the analyses, specifications and construction practice identified above constitute a violation of Critarion V of Appendix B to 10 CFR 50. l Accordingly, TUEC shall: i j (1) Modify Gibbs & Hill Specification No. 2323-MS-100, and institute pro-cedures for support of the main steam line during flushing and for ' temporary supports for piping and equipment in general to assure that the quality of piping and equipment are not affected. (2) Perfom an assessment of stresses in the portions of the Unit 1, loop 1, main steam and feedwater lines that were affected in the sequence of events involved during their initial installation, f flushir.g and final installation. Conditions requiring stress analysis f are: l - 9 (a) Flushing condition when the lines were full of water and tmporary supports had sagged or settled.
} (b) Dis:onnecting condition when vibrations of the temporary line could have occurred.
(c) Lifting condition when forces were applied by the polar crane
- j. and con:e-alongs.
E. j These assessants shall be based on appropriate piping configurations j involved.
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loop 1, main steam and feedwater piping where stresses were exceeded 4 !) during the conditions of concern in a. through c. above. V (4) Review the existing baseline UT examinations for those portions of 1 the Unit 1, loop 1, main steam and feedwater involved in all the conditions of concern in a. through c., above, for unacceptable indications. (5) Review records of hydrostatic testing of the main steam and feedwater
, line to verify the quality of piping involved in the incident.
i (6) Provide similar assessments for circumstances involved in a lifting incident identified during the TRT inspection for the Unit 1, loop 4, 4 main steam line.
+ .: (7) Provide assessments of effects on quality of safety-related piping and equipment which were involved in similar incidents of sagging, settlements and failures, if any, of temporary supports.
I t (8) Submit the results of analyses, examinations and reviews in a docu-mented report for NRC review.
} VI. Miscellaneots Area
- a. Gap Between Reactor pressure Vessel Reflective Insulation (RpVRI)
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and the Biclogical Shield Wall l . I 1 )j
- The TRT investigated an allegation that the Unit I reactor pressure j
vessel outer wall was touching the concrete biological shield wall. j A TRT review of existing documentation and discussions with TUEC ,{ personnel indi ated that this allegatic, was not factual. However,
'} a significant construction deficiency report, submitted pursuant to ) 10 CFR Part 50.55(e), on August 25, 1983, documented that unacceptable j
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.j 44 cooling occurred in the annulus between the RPVRI and the shield wall l] during hot functional testing, apparently because of the existence of an inadequately sized annulus gap and possibly because the presence
- 1
" of construction
- debris in the annulus. TUEC corrected the situation by modifications to allow increased air flow for proper heat dissi-pation and by removal of the construction debris. TUEC representa-
'f tives indicated that testing to verify the adequacy of the cooling i flow will take place when additional hot functional testing is con-ducted. Infomation gathered by the TRT during the investigation l indicatedt that a design change in the RPVRI support ring (i.e., loca-ting the ring outside rather than inside the insulation) resulted in i a limited clearance between the RPVRI and the shield wall. The TRT review of the 50.55(e) report revealed that TUEC failed to: (I) ad- 'j dress the fundamental issue of the design change impact on annulus cooling flow, and (2) determine whether Unit 2 was similarly affected. Accordingly, TUEC shall: (1) Review their procedures for approval of design changes to non- .i nuclear safety related equipment, such as the RPVRI, and make ] revisions as necessary to assure that such design changes do not adversely affect safety-related systems.
'l (2) Review procedures for reporting significant design and construc-tion deficiencies, pursuant to 10 CFR Part 50.55(e), and.make changes as necessary to assure that complete. evaluations are ij conducted.
q (3) Provide an analysis which verifies that the cooling flow in the 11
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annulus between the RPVRI and the shield wall of Unit 2 is j adequate for the as-built condition. f _ .' ,,~.7.- . t ;M '. - "' - ~
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1 i 1 (4) Finally, verify during future Unit I hot functional testing that completed modifications to the RPVRI support ring now allow adequate cooling air flow. The TRT noted that control of debris in critical spaces between components and/or structures was identified as an issue, both in the i investigation of this allegation and the civil / structural area item
; II.c (Maintenance of Air' Gap Between Concrete Structures), contained in Darrell G. Eisenhut's September 18, 1984, letter to TUEC. Accord-ingly, TUEC shall also:
'(1) Identify areas in the plant having critical spacing between t
components and/or structures that are necessary for proper func - l tioning of safety-related components, systems or structures in which unwanted debris may collect and be undetected or be dif- }f ficult to remove; (2) ~ Prior to fuel load, inspect the areas and spaces identified and remove debris; and, j (3) Subsequent to fuel load, institute a program to minimize the i collection of debris in c-itical spaces and periodically inspect these spaces and remo e any debris hich may be prese g /
.hm( p h...e w.-w ~ ' OOE fL ~ * ' V'V j b. olar Crane Shimming /* V / (t 6.ld<*w.A/[M&+'C-~ ~. ~ . /~ .
I The TRT investigated the installation of the polar crane rail support li system by visual inspection, review of associated documentation, and j discussions with TUEC representatives and their contractors. Region IV Inspection Report 50-445/84-08; 50-446/84-04 and Notice of Violation, dated July 26, 1984, documented that gaps on the Unit 1 polar crane f bracket and seismic connections exceeded design requirements. In
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Texas Utilities Generating Company responses of August 23, 1984, and j September 7, 1984, the gaps were attributed to crane and bolting { self-adjustment resulting frcm crane operation. A site design change i i e . n- ,
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(DCA-9872, Revision 4, dated August 24,1984) was issued to document the acceptability of the gaps in excess of 1/16 inch which were l identified in the above NRC inspection report. I 1 I During further investigation of the al' legation that shims for the } rail support system of the polar crane had been altered during installation, the TRT observed gaps which may have been excessive between the crane girder and the girder support bracket. Detailed specifications .ddressing the gap tolerance in the girder seat con-
. nections Idid not exist; however, Gibbs & Hill letter GHF-2207, dated November 28, 1977, stated that the " seated connections will not require shimming since the area in bearing is at least the width of the bottom flange of the crane girder." Contrary to this Gibbs &
Hill assumption, the TRT observed nine girders with gaps which extended under the bottom flange that reduced the bearing surface to less than the 20-inch flange width stated in the letter. The TRT ,' also observed conditions which indicated that the crane rail may i still be moving in a circumferential direction, that three rail-to-rail ground wires were broken, that two shims have partially worked s out from under the rail, and that two Cadwelds were broken.
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i Accordingly, TUEC shall: E j 1. Inspect the polar crane rail girder seat connections for the presence of gaps which reduce the bearing surface to less than the width of the bottom flange and perform an analysis which will determine whether existing gaps are acceptable or require j corrective action. I
- 2. Determine if additional rail movement is occurring and, if so, provide an evaluation o'f safety significance and the need for ;
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! 3. Perfom a general inspection of the polar crane rail and rail j support system, correct identified deficiencies of safety sig- l l nificance, and provide an assessment of the adequacy of existing
! maintenance and surveillance programs.
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, --- ..4 e***Epint Diagnsstics fo'r: TUbCO LETTER 10/1/84 j Total Formatting Exceptions = 1 Total Listed Below = 1 .
4 I. lf The Following Two Fcrmats Will Be Used: Page/Line Format Exception Messaoe Found By The IBM 5520 Sheet Number Format Exception Message Found By The Printer j 5.0.0/2 0033-Line Exceeds Paper Width t
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t M5 i ~ i SCOPE OF CIVIL / STRUCTURAL ALLEGATIONS THERE ARE FIFTY-SEVEN (57) ALLEGATIONS IN CIVIL / STRUCTURAL AREA, THE ALLEGATIONS PERTAIN TO THE FOLLOWING SIX BROAD AREAS: ,
- 1. DESIGN DEFICIENCY
- 2. TESTING OR INSPECTION IRREGULARITIES
- 3. INCORRECT CONSTRUCTION PRACTICES
- 4. INADEQUATE REPAIRS
- 5. UNCORRECTED, UNSAFE CONDITIONS IN THE COMPLETED STRUCTURE 6',' PREMATURE STRUCTURAL LOADING l
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i CATEGORIZATION OF ALLEGATI0t'S l CATEGORY [10. CHARACTERIZATION N0, 0F ALLEGATTONS 1 INADEQUATE MATERIALS USED 6 IN CONCRETE 2 CONCRETE PLACEMENTS 3 3 POOR WEATHER CONDITIONS 3 4 C0f! CRETE VOIDS / CRACKED 7 5 MISCELLAf!E0VS CONCRETE 4 6 REBAR IMPROPERLY IllSTALLED/0MITTED 9 7 CONCRETE - UNDOCUMENTED 1 8 FALSE / WRONG DOCUfENTS 6 9 QC INSPECTOR TRAINING 1 10 IMPROPER TESTING 6 11 SEISMIC DESIGN /C0flSTRUCTION 1 12 CONCRETE CONSTRUCTION AND 1 DEFICIENCIES / TOLERANCES 13 CRACKS IN CONCRETE BE."!EATH THE 1 REACTOR VESSEL 14 SEISMIC DESIGN OF CONTROL ROOM J CEILING ELEMEf!TS 15 REBAR IMPROPERLY DRILLED 5 16 EXCAVATION / BACKFILL 1 17 CONCRETE SAMPLING 1 , TOTAL ALLEGATIONS X ll lI
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j . BASIC APPROACH FOR RESOLUTION OF ALLEGATIONS 1, REVIEW PERTINENT DOCUMENTS DEFINING ALLEGATIONS ! INCLUDING ALLEGER TESTIMONIES, ASU3 HEARING RECORDS NEWSPAPER ARTICLES, AND PERSONAL INTERVIEN RECORDS,
- 2. REVIEW PERTINENT DESIGN CALCULATIONS, PEBAR OR CONCRETE REPLACEMENT PACKAGES, DOCUMENTS, RECORDS, NONCONFORMANCE REPORTS, ETC., THAT ARE RELATED TO THE STRUCTURES OR STRUCTURAL ELEMENTS INDEllTIFIED IN THE ALLEGATIONS,
- 3. AS APPLICABLE REVIEW REGION IV INSPECTION OR ISSUE DISPOSITION REPORTS TO EVALUATE THE ADE0VACY OF THE DISPOSITIONS, AS NEEDED, INTERVIEW APPLICANT'S STAFF AND CRAFT WORKERS WHO WERE INVOLVED IN THE ALLEGED ACTIVITIES, li, AS NEEDED CONDUCT INTERVIEW OF ALLEGERS TO CLARIFY THE l NATURE OF ALLEGATI0flS,
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5, IF THE ALLEGATION IS DETERMINED AS VALID, THEN ASSESS THE f i SAFETY IMPLICATIONS ON THE AFFECTED PORTIONS OF THE STRUCTURES, FURTHERMORE, IT SHOULD BE DETERMINED IF THE DEFICIENCY IS f g6 3 O! t >[- GENERIC. IF IT IS GENERIC, THEN A REVIEW SHALL BE MADE ON
< k AN ENLARGED SCOPE BASIS, EVALUATION OF THE SAFETY IMPLICATIONS I MAY REQUIRE USE OF INDEPENDENT ENGINEERING ANALYSIS, FIELD l INSPECTIONS, TESTING AND AUDIT OF ENGINEERING CALCULA.TIONS, 4
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; BASIC APPROACH FOR RESOLUTION OF ALLEGATIONS (CONT'D) l i
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[ 6',' BASED ON THE AB0VE EVALUATIONS, PREPARE AN SSER FOR RESOLUTION OF THE ALLEGATIONS. IF ADDITIONAL WORK BY THE APPLICANT (TUEC) IS NEEDED TO CLOSE THE ALLEGATIONS INCLUDING TESTING AND/0R ANALYSIS, THEN THE NEEDED SPECIFIC ITEMS SHOULD BE IDENTIFIED AS APPLICANT'S
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ACTION ITEMS FOR IMPLEMEllTATION AND FINAL CLOSURE.
- 7. IDENTIFY POTENTIAL VIOLATIONS'. AlS0, AS APPLICABLE',
REFER ANY EXAMPLES OF WRONGDOING OR FALSIFICATION TO THE 01, f f
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! DEFINITION OF OPEN ISSUES 9
OPEN ISSUES ARE ITEMS THAT MAY HAVE POTENTIAL. " SAFETY SIGNIFICANCE" AND REQUIRE ACTION ON THE PART OF TUEC. , THE FOLLOWING OPEN ISSUES HAVE BEEN IDENTIFIED: REINFORCING STEEL OMITTED IN THE REACTOR l CAVITY FALSIFICATION OF CONCRETE COMPRESSION STRENGTH , TEST RESULTS MAINTENANCE OF AIR GAP BETWEEN CONCRETE STRUCTURES SEISMIC DESIGN OF CONTROL ROOM CEILING ELEMENTS UNAUTHORIZED CUTTING 0F REBAR IN THE FUEL HANDLING BUILDING f i
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i-i DEFINITION OF " SAFETY SIGNIFICANCE" LACK OF " SAFETY SIGNIFICANCE" PERTAINING TO OR AS A RESULT OF A GIVEN DEFICIENCY, OR VIOLATION OF CODES /NRC OR FSAR REQUIREMENTS MEA!!S THAT WHILE AN ACTIVITY OR ITEM DOES NOT FULLY CONFORM TO ALL APPLICABLE CODES /NRC OR FSAR REQUIREMENTS', THE TRT' CONCLUDES ON A TECHNICAL BASIS THAT THE STRUCTURE OR SYSTE.9 WILL NEVERTHELESS FUNCTION PROPERLY WITHOUT INTERFERING WITH SAFETY. 9
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. REINFORCING STEEL IN REACTOR CAVITY l _ DESCRIPTION OF ISSUE _ l '
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e A PORTION OF TIE REINFORCING STEEL HAS OMITTED IN A UNIT 1 REACTOR CAVITY CONCRETE WALL PLACEMENT BETWEEN EL. 812'-0" l 3
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! AND EL' 819'-0 1/2"
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ACTION REQUIRED BY TUEC
; e TliEC SHALL PROVIDE AN ANALYSIS VERIFYING Tile ADE0llACY OF -
i Tile AS-BUILT CONDITION I e TIIE ANALYSIS SHALL CONSIDER ALL PEQUIRED LOAD COMBINATIONS i i t i i { I
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l . i I FALSIFICATION OF CONCRETE COMPPESSIVE STRENGTl! TEST RESULTS !: l i j DESCRIPTION OF ISSUE l e ALLEGATION OF FALSIFICATION OF CONCRETE COMPRESSIVE STRENGTil i. TEST RESULTS COULD NOT BE PR0'ED VALID OR INVALID i e CONCRETE STRENGTil L0ER TilAN TilAT SPECIFIED IN Tl!E DESIGN l NAY PEDl!CE Tile LOAD RESISTING CAPACITY OF STRUCTURES , d ACTION REQUIRED BY 10EC - i t'
; e TUEC Sil0ULD DETERMINE AREAS Wi!ERE CONCRETE WAS PLACED BETWEEN j j JANUARY 1976 AND FEBRUARY 1977 AND PROVIDE A PROGRAM TO ASSURE (
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- j. ACCEPTABLE CONCRETE STRENGTil -
i 1 e TEST PROGRM TO INCLilDE RAND 0M SCllMIDT !!AMMER TEST ON CONCRETE i: 1 . ! O IN AREris WilERE SAFETY IS CRITICAL i n i - a l n
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.i MAINTENANCE OF AIR GAP BETWEEN CONCRETE STRUCTl!RES ct ,
i! DESCRIPTION OF ISSUE I ADEQUACY OF Ti1E AIR GAP COULD -NOT BE DETERMINED SINCE:
- AVAILABLE DOCUMENTATION DID liGT PP.0 VIDE LOCATION OR EXTENT OF REMAINING DEBRIS,
- ADDITIDHAL SITE FIELD INVESTIGATIONS WERE f0I DOCUtiGITED ON j PERMANENT ' RECORDS','
{ H - PEREiANENT INSTALLATION OF ELASTIC JOINT FILLER llAD NOT BEE!! S!!0!aN l TO BE CONSISTENT WITil SEISMIC ANALYSIS ASSUMPTIONS AND DYNAMIC j MODELS USED TO ANALYZE TiiE BUILDINGS, i j 'i ACTION PEQUIRED BY TUEC
! PERFORM INSPECTION OF Tl!E AS-BUILT CONDITION TO CONFIRM THAT ADE00 ATE SEPARATION FOR ALL SEISMIC CATEGORY I STRUCTURES IIAS BEEN PROVIDED', ) < }
'l PROVIDE Tile RESULTS OF ANALY5ES WillC11 DEMONSTRATE TilAT Tile PRESENCE OF , l ELASTIC JOINT FILLER AND DEBRIS BETWEEN ALL CONCRETE STRUCTURES DOES I q .
; NOT RESI U IN ANY SIGNIFICANT INCRE/SE IN SEISMIC RESPONSE OR ALTER TiiE '
DYNAMIC RESPONSE CllARACTERISTICS~0F Tile CATEGORY I STRilCTURES, C0f1PONENTS . 'i
! AND PIPING WilEN COMPARED WITil Tile RESULTS OF TSE ORIGINAL ANALYSES, .
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- i SEISMIC DESIGN OF CONTROL ROOM CEILING ELEMENTS PESCRIPTION OF . ISSUE i
e CLASSIFICATION OF CEILING ELEMENTS lj I , f NON-SAFET( RELATED CONDUITS- --------------SEISMIC CATEGORY 11 LIGHTING FIXTURES----- --------------------SEISMIC CATEGORY II j SLOPING SUSPENDED DRYWALL CEILING------ ---NON-SEISMIC f ' j ACOUSTICAL SUSPENDED CEILING---------------NON-SEISMIC LOWERED SUSPENDED CEILING------------------NON-SEISMIC
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e IN ACCORDAilCE WITH' REG. GUIDE 1.29 AND FSAR SECTION 3.7B.2.8 Tile NON-SEISMIC AND SEISMIC CATEGORY II ITEMS Sil0ULD BE DESIGNED IN SU h 4 l A WAY TilAT THEIR FAILURE WOULD NOT ADVERSELY AFFECT THE FUNCTIO ! SAFETY-RELATED COMPONENTS OR CAUSE INJURY TO OPERATORS. e CONTRARY TO Tile AB0VE FOR THE NON-SEISMIC ITEMS (OTilER THAN Tile l DRYWALL CEILING) AND FOR NON-SAFETY-RELATED CONDUITS Fil0SE 2 INCilES OR LESS, NO EVIDENCE COULD BE FOUND TilAT FAILURE OF THESE ITEMS WAS CONSIDERED. ) e REVIEW 0F CALCULATIONS FOR SEISMICALLY RESTRAINED LIGHTING t SLOPED SUSPENDED CEILINGS DID NOT ACCOUNT FOR POTENTIAL LOA ROTATIONAL INTERACTION BETHEEN CILING ELEMENTS, NOR WERE SPECIFIC SEISM l i RESPONSE CONDITIONS REVIEWED FOR TIIE CEILING ELEMENTS. i l
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ACTION REQUIRED BY TUEC e PROVIDE RESULTS OF. SEISMIC ANALYSIS WHICll DEMONSTRATES TilAT THE NON-SEISMIC ITEMS IN Tile CONTROL ROOM (OTilER THAN Tile SLOPING SUSPENDED l DRYWALL CEILING) SATISFY Tile PROVISIONS OF REG. GUIDE 1.29 AND FSAR
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i SECTION 3.78.2'.8'.
! e PROVIDE AN EVALUATION OF SEISMIC DESIGN ADEQUACY OF SUPPORT SYSTEM FOR i
LIGilTING FIXTURES AND DRYWALL CEILING WilICil ACCOUNTS FOR PERTINENT FLOOR RESPONSE CllARACTERISTICS, , o PROVIDE VERIFICATION TllAT ITEMS NOT INSTALLED IN ACCORDANCE WITil TllE
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r j REQUIREMENTS OF REG'. GUIDE 1.29 SATISFY APPLICABLE. DESIGN REQUIREMENTS. [
' e PROVIDE RESULTS OF AN ANALYSIS TilAT JUSTIFY ADEQUACY OF THE N0thSAFETY j CONDUIT SUPPORT SYSTEMS FOR CONDUIT WHOSE DIAMETER IS 2 INCllES OR LESS. }'
e PROVIDE RESULTS OF AN ANALYSIS WilICH DEMONSTRATES Tile FOREG0ING PROBLEMS [ ARE NOT APPLICABLE TO OTHER CATEGORY II AND NON-SEISMIC STRUCTURES, SYSTEMS AND COMPONENTS ELSEWilERE IN THE PLANT. j t !I a i':'
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I . .- CUTTING OF REBAR IN FUEL llANDLING BUILDING DESCRIPTION OF ISSUE e UNAUTil0RIZED CUTTI'NG 0F REBAR ASSOCIATED WITil Tile ' INSTALLATION OF T11E
- i TROLLEY PROCESS AISLE RAILS IN Tile FUEL llANDLING BUILDING MAY llAVE OCCURRED.
ACTION REQUIRED BY TUEC i: I 4
- j e TUEC SilALL PROVIDE INFORMATION TO DEMONSTRATE TilAT ONLY #18 REBAR IN ,!
ji IST LAYER WAS CUT, OR I e PROVIDE DESIGN CALCULATIONS TO DEMONSTRATE TilAT STRUCTURAL INTEGRITY c IS MAINTAINED EVEN IF #18 REBARS IN BOTH IST AND 3RD LAYERS WERE CUT. L i li j r. f i: 4 e
I ASSESSMENT OF CIVIL / STRUCTURAL CONSTRUCTION i 1. BECAUSE OF THE GENEPALLY NON-SPECIFIC NATURE OF CIVIL / STRUCTURAL ALLEGATIONS, MANY ALLEGATIONS CANNOT BE I SUBSTANTIATED. OTHER ALLEGATIONS ARE FOUND VALID REQUIRING ADEQUATE RESOLUTION.
- 2. ASSESSMENT OF SAFETY SIGNIFICANCE OF SUBSTANTIATED ALLEGATIONS LED TO FIVE (5)-OPEN ISSUES REQUIRING
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TUEC ACTION, THE REPAINING ALLEGATIONS lERE ETERMINED TO HAVE NO SAFETY SIGNIFICANCE, THUS, WERE [y D'ISPOSED WITHOUT REQUIRING FURTHER ACTIONS, g
>' 3. SIXTEEN (16) QA/QC RELATED DEFICIENCIES OR BREAKDOHNS
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WERE IDENTIFIED.' THESE ITEMS WERE REFERRED TO TRT QA/ QC GROUP FOR THEIR INDEPENDENT QA/QC PROGRAFM TIC REVIEW TO DETERMINE PROGRAM ADEQUACY AND ACCEPTABILITY.
- 4. NINE (9) P0TENTIAL VIOLATIONS OF NRC/FSAR REQUIREMEMTS WEREIDENTIFIED'DREEiIVWILLEVALUATDIfESP POTENTIAL VIOLATIONS AND DISPOSE OF THEM, AS APPROPRIATE.
2 5.
.IN SPITE OF THE SIGNIFICANT NUMBER ~0F ALTEBXTTONS- Vf L j OFNRC/FSARREQUlilEMENTSANDQA/0CBREAKD01S,THE g OVERALL CIVIL /STRUCTURA Q RUCTION OF
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i f/U f [ COMANCHE PEAK STATIONS IS-JUDGED AS GENERALLY COMPARABLE a M S#^ TO THAT OF OTHER SIMILAR VINTAGE PLANTS.
- 6. PENDING SATISFACTORY RESOLUTION OF THE FIVE OPEN ISSUES l b
l[ AND ISSUES WHICH MAY ARISE FROM THE QA/0C PROGRAMPATIC REVIEW AND/0R RECENT CASE LETTERS', THE CIVIL / STRUCTURAL ASPECTS OF THE PLANT ARE JUDGED TO POSSESS AN ADEQUATE ! SAFETY MARGIN TO ALLOW THE PLANT TO RECEIVE AN OL WITHOUT l
, UNDUE RISK TO THE~PUBLIC, i -
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