ML20135G021
| ML20135G021 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/30/1985 |
| From: | Burch R, Hayes B, Vorse J NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20135G014 | List: |
| References | |
| 2-84-015, 2-84-15, NUDOCS 8509180064 | |
| Download: ML20135G021 (169) | |
Text
{{#Wiki_filter:Title: NORTH ANNA POWER STAT 10N POSSIBLE WILLFUL USE OF NON-NUCLEAR QUALIFIED C0ATING MATERIAL ON CONTAINMENT DUCTWORK AND FALSIFICATION OF. QUALITY ASSURANCE DOCUMENTATION Licensee: Case Number: 2-84-015 Virginia Electric and Power Company Report Date: April 30, 1985 P. O. Box 26666 One James River Plaza Control Office: OI:RII Richmond, Virginia 23261 Status: CLOSED Docket Nos.: 50-338 and 50-339 Reported by: Reviewed by:
'TO' . &
Robert H./Burch L.tl.lb gmesYgVorse Investigator. 01:RII Birector", 01:RII Ap ed by: N Y N B. Htfyes TA)1 ec r A Office of Inves iga ons , G G
SYNOPSIS This investigation was initiated pursuant to an allegation that. non-nuclear qualified coating materials were deliberately applied to the galvanized steel Air Cooling and Purging System (Ventilation ring ductwork) in both the Units 1 and 2 containment buildings during December 1982 and April 1983 . respectively, at Virginia Electric.and Power Company's (VEPCO) North Anna Power Station (NAPS), Mineral, VA, hereafter referred to as "the licensee." Inquiries to determine the extent of licensee managements' knowledge of and involvement in these alleged coatings improprieties were conducted. Applicable regulatory requirements, standards, NRC guidance documentation, NAPS procedures and the safety analysis report were identified and reviewed during the investigation process. Background data revealed that a Confidential Source alleged in April 1984 that improper coating materials (epoxy finish coat over an enamel base coat) had been deliberately, and with NAPS supervisory concurrence, applied to the ventilation ring du::twork in Units I and 2 to mitigate the effects of corrosive borated water leaking onto the galvanized steel surfaces. After substantive evaluations of the allegation by Region II, NRC staff members and the NAPS Resident Inspector, the licensee was requested to analyze test coupons selected from portions of the ventilation ring ductwork. In July and August 1984 correspondence and meetings between NRC and licensee officials revealed that the base coat applied over the galvanized steel ventilation ring ductwork surface in Unit I was non-nuclear qualified and the coating materials applied to the Unit 2 system, although nuclear qualified, were not compatible with the galvanized steel surface. Technical remedial actions regarding these improprieties were implemented by the licensee and approved by the NRC staff personnel associated with this matter. During the investigation, Region II, NPC staff members reported that the ventilation ring ductwork coating projects had failed to receive a NAPS engineering evaluation for health and safety implications, which possibly accounted for the painting discrepancies. An NRC official , advised that a NAPS Quality Control inspector involved in these coating projects inforTned him that he (inspector) was " overruled by someone in engineering" when he objected to coating galvanized steel surfaces. The initial alleger stated during interview that he l informed the NAPS Construction Supervisor (Coatings) that the base and ' finish coating materials he selected were non-nuclear qualified, incompatible and not suitable for coating a galvanized steel surface. NAPS contract painters interviewed during the investigation related : similar conversations with the same NAPS Construction Supervisor and ! advised that in spite of their objections, they were directed by this individual to perform coating activities with non-nuclear qualified materials over a galvanized steel surface. Some paint personnel also advised that the NAPS Quality Control (QC) Inspectors assigned to independently verify the craft coating activities did not conduct inspections in the proper manner and they concurred with false and inaccurate data contained in the QC documentation associated with these two projects. I
l l Neither the paint manufacturer nor representatives of his company recalled any i contacts with the NAPS Construction Supervisor (Coatings) regarding
' paint compatibility or cualification for galvanized steel or in-containment use.
~ ~
NAPS Construction De'partment officials above the level of the Construction Supervisor (Coatings) categorically denied that they were aware of deficiencies in the ventilation ring ductwork coating process or discrepancies in the record keeping requirements associated with these projects until they were notified of the same by the NRC in July 1984 Other officials at the NAPS facility, including management personnel from the Maintenance, Operations, Engineering and Quality Assurance Departments also claimed no knowledge of coating or associated record keeping improprieties until they were informed by the NRC. Two NAPS Quality Control inspectors assigned to the ventilation ring ductwork coating projects acknowledged upon interview 1 that they failed to perform inspections of these projects as required ! by applicable procedures and regulations and they signed and dated QC docurentation without performing independent verification to ensure 4 that the activities were completed in the manner indicated. They acknowledged that they collaborated with the NAPS Construction Supervisor (Coatings) to certify inaccurate product identification and/or surface preparation data on the QC documentation associated i with the ventilation ring ductwork coating projects. Licensee docurentation, records and/or printed data supplied by various sources i during the investigation also corroborate statements by painters that incorrect base coat paint identi'f er infermation is recorded on QC i i docurertation associated with the Unit I ventilation ring ductwork and that " surface preparation" activities were not completed in the manner indicated by QC documentation. No substartial evidence of licensee management involvement in or knowledge cf coating and/or record keeping improprieties above the lesel of the Construction Supervisor (Coatings) was revealed during the investigation. f 4 2 4
TABLE OF CONTENTS Page No. Synopsis . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Applicable Regulations . . . . . . . . . . . . . . . . . . . . 4 Interviewees . . . . . . . . . . . . . . . . . . . . . . . . . 6 Details of Investigation . . . . . . . . . . . . . . . . . . . 7 Purpose of Investigation ................ 7 Background ....................... 7 Interview of NRC Officials ............... 9 Interview of A11eger . . . . . . . . . . . . . . . . . 10 Interview of Contract Painters . . . . . . . . . . . . 11 Interviews of Construction Department Officials . . . . 12 Interviews of Maintenance Department Officials . . . . 16 Interviews of Operations Department Officials . . . . . 17 Interviews of Technical Services Personnel . . . . . . 18 Interviews of NAPS Plant Officials . . . . . . . . . . 18 Interviews of Paint Manufacturing Representatives . . . 20 Interviews of NAPS Quality Assurance Personnel . . . . 21 Review of Licensee Records . . . . . . . . . . . . . . . . . 24 Review of BAULER's Records . . . . . . . . . . . . . . . . . 26 Liaison With The Recuestor . . . . . . . . . . . . . . . . . 28 Status of Investigation ..................29 Willfulness / Intent . ....................30 Exculpatory Information ..................32 Conclusions . . . . . . . . . . . . . . . . . . . . . . . . 33 List of Exhibi ts . . . . . . . . . . . . . . . . . . . . . . 34 3
1 I APPLICABLE REGULATIONS A review of 10 CFR regulations, standards, NRC guidance documentation, North Anna Power Station (NAPS) procedures and the Updated Final Safety Analysis Report identified those which are applicable to the investigation. 10 CFR Part 50 (Domestic Licensing of Production and Utilization Facilities), Appendix B, Quality Assurance Criteria For Nuclear Power Plants and Fuel Processing Plants, requirements are pertinent to the investigation. Licensee's responsibilities described in Criterion I,
" Organization;" Criterion II, " Quality Assurance Program;"
Criterion III, " Design Control;" Criterion VII, " Control of Purchased Material, Equipment, and Services;" Criterion X, " Inspections;" Criterion XVII, " Quality Assurance Records;" and Criterion XVIII,
" Audits," pertain to the allegations which initiated the investigation.
American National Standard Institute (ANSI) NIO1.4-1972, entitled
" Quality Assurance For Protective Coatings Applied to Nuclear Plants" defines and provides "a common basis for the ouality assurance of protective coatings applied to nuclear facilities." Specifically, Sections 2, 3, 4, 6 and 7 of this standard are applicable to the investigation.
U. 5. Nuclear Regulatory Comission Regulatory Guide 1.54, entitled "Cuality Assurance Reouirements For Protective Coatings Applied To Water-Cooled Nuclear Power Plants," references the requirements and guidelines included in ANSI N101.4-1972. This document s.tates that guidance centained in ANSI N101.4-1972 for protective coatings applied to "...zir:-coated (galvanized) steel... surfaces of water-cooled nuclear p:.er plants" is " generally acceptable" and provides "an adequate basis for complying with the pertinent quality assurance requireme" s" of 10 CFR Part 50, Appendix B. The NAPS L: dated Final Safety Analysis Report (UFSAR), Section 3.E.2.7.6, entitled " Protective Coatings (Paints)," contains requiremer:s for coating " exposed concrete and carbon steel surfaces within the containment boundary." This section also states "...it is also necessary that protective coatings remain intact if subjected to the environment associated with postulated..." Loss of Coolant Accidents (LOCA's). Tables 3.8-10 and 3.8-11 list nuclear and non-nuclear qualified coatings, respectively, used inside containment. Investigator's Note: The UFSAR does not contain specific guida*ce regarding the coating of galvanized steel surfaces inside the containment boundary. North Anna Specification (NAS) 1016, entitled " Painting - Part II. Applicatior. of Protective Coating Materials Within The Containment," defines the requirements for " materials and workmanship" for field applicatior of protective coatings... within the reactor containment liner boundary. The contents of Sections 1.0, " Scope;" 2.0 4
" Applicable Documents;" 3.0 " Requirements," and 4.0 " Quality Assurance" are all applicable to this investigation. Attachments to NAS-1016 identify nuclear qualified coating materials and schedules for in-containment painting.
Virginia Electric and Power Company Multiple Power Projects Quality Control Instruction QCI 11.1 establishes the program for " controlling protective coating materials, surface preparation, and application of protective coating to assure that they conform to the governing specifications," (NAS-1016). Sections 3, " General" and 4. " Procedure" specify responsibilities of both the Construction Supervisor and the QC Inspector regarding the entire coating process. This instruction further states that the Construction Supervisor shall complete and sign the Protective Coating Surface Preparation Record (PCSPR), (Attachment 5.2 of QCI 11.1), and the Quality Control Inspector shall assure that all procedures therein have been performed according to the specifications and instructions. Copies of all the regulations, standards, guides, procedures, instructions and/or reports referenced in this section of the investigation report are being retained in the case file. Investigator's Note: According to numerous itcensee and contractor personnel interviewed during the investigation, NAS-1016 and QCI 11.1 were initially developed and promulgated as coatings procedures with plant construction orientation. These individuals advised that, although they were subsequently adapted as plant maintenance procedures, in their opinions they have not been adeouate for this purpose. Af ter learning of the incidents which precipitated this investigation and in apparent recognition that NAS-1016 and QCI 11.1 were inadequate as plant' maintenance procedures, licensee management at NAPS developed and implemented VEPCC site /Section Operating Procedure 50P 8.8.0N, " Coating Applicatien," dated August 14, 1984 and NAPS Quality Assurance Department Instruction CADI 10.13 " Coatings Inspection," dated August 17, 1984. Several interviewees advised that quality centrol, operations, maintenance, engineering and construction inte-face at NAPS became more amenable with the implementation of these procedures. i l l 5
1 INTERVIEWEES The individuals listed below provided pertinent information and testimony regarding the allegations and issues of the investigation. ASKEW, Floyd Ray, contract painter, Exhibit 5 BOWLING, Martin luther, VEPC07HAF3 Aisistant Plant Manager, Exhibit 14 BURNS, William Drayton, Jr., VEPC0/ NAPS Quality Control Inspector, Exhibit 18 CANFIELD, Norman Roderick, Coatings Technician and Salesman, Exhibit 6 FRALEY, Albert Demore, VEPC0/ NAPS Project Manager, Exhibit 11 HARPER, Joseph Ralph, VEPC0/ NAPS Maintenance Superintendent, Exhibit 12 HARRIS, William Juniorous, VEPC0/ NAPS Quality Control Inspector, Exhibit 19 HUNLEY, George Henry, contract painter, Exhibit 6 JONES, John Michael, former VEPCO/ NAPS Construction Superintendent, Exhibit 10 LANG, Marvin Nash, contract painter Supervisor. Exhibit 7 LONG Henry L. Jr., Paint Manufacturer Company President, Exhibit 15 NOBLES. Wilson Carey, Construction Engineer, Exhibit 9 PARKER, Alfred Quinton, Engineering Supervisor, . Exhibit 13 SMITH, James Allen, Quality Assurance Superviser, Exhibit 17 In addition to these sources of information, other individuals were interviewed and provided repetitious and/or clarifyir.g testimony concerning the purpose of the investigation. The identities and comments of these individuals are reccrded in the " Details of Investigation" section of the report of investigaticr.. An Organization Chart (Exhibit 2) identifies the location / management chain of each licensee and contract employee who was interviewed during the investigation. l 1
. E l I
DETAILS OF INVESTIGATION i Purpose of Investigation The purpose of this investigation was to determine whether non-nuclear cualified and/or nuclear qualified coating materials (primer and/or finish) were deliberately and knowingly applied to the galvanized steel surface areas of the Air Cooling and Purging Systems ,. (ventilation ring ductwork) in the Unit I and 2 containments at Virginia Electric and Power Company's (VEPC0) North Anna Power Station (NAPS), Mineral,VA. These systems were coated to mitigate severe boric acid corrosion at numerous locations. According to an alleger, the non-nuclear qualified coating materials were applied to the galvanized steel ventilation ring ductwork, with a NAPS supervisor knowing it was not Loss of Coolant Accident (LOCA) qualified. During the investigation of this allegation, evidence of willful and deliberate falsifications of Quality Assurance (QA) documentation associated with these ventilation ring ductwork coating projects was developed and. pursued to its logical conclusion in accordance with the initial request from the originator of the investigation.
Background
/
In an August 23, 1984 memorandum (Exhibit 1) from James P. O'REILLY, then Regional Administrator, Region II, U.S. Nuclear Regulatory Comisstor. (NRC), Atlanta, GA, investigative assistance was requested regarding the alleged willful and deliberate use of non-nuclear qualified coating materials on the galvanized steel ventilation ring ductwork inside the containment structures of Units 1 and 2 at the NAPS facility. Accompanying the request letter were documents obtained or generated by the NRC, Region II Investigation / Allegation Coordination Section (!/ACS) which set forth the chronology of these . alleged incidents. According to this documentation, the Unit 1 ventilation ring ductwork was coated in December 1982 and January 1983 and the Unit 2 system was coated in April and May 1983. The following information is provided in order that pertinent events prior to the initiatior of the investigation request are properly focused and
- referenced:
(1) April 16, 1984 - informed the NAPS Senior Resident Inspector tfiiit-~ improper coating materials (epoxy finish coat over an enamel base coat) had previously been utilized on the ventilation ring ductwork inside the Units 1 and 2 containment buildings. indicated to the Senior Resident Inspector that NAPS construction officials had knowingly applied incorrect coating materials to these duplicate systems and that the paint had peeled on several occasions before bonding was achieved. Upon receiving the information the NAPS Senior Resident Inspector reviewed North Anna Specification 1016 (NAS-1016), the existing and applicable coatings procedure at the NAPS facility, and after 7
t evaluation determined that concern " appeared to be valid." Investigator's Note: According to NAPS files and records, the Unit I ventilation ring ductwork wa's coated in December 1982 and January 1983 and the Unit 2 project was done during April 1983. (2) I/ACS documentation reflects that Region II, NRC staff' officials were requested on May 8, 1984 to further review and evaluate concerns and to "fomulate" appropriate action to address and resolve the issue. In a June 15, 1984 memorandum from the Region II, NRC Division of Reactor Safety to the I/ACS, it was recomended that the NAPS Senior Resident Inspector query VEPC0 (NAPS) officials to determine the existence of an operational safety or health issue concerning allegation. (3) On July 17, 1984, was recontacted telephonically by a Region II, NRC I/ACS staff member, at which time he comented that knowledge of his concern (use of improper coating materials in the containment structures of Units 1 and 2) was widespread among " management" personnel at NAPS, including (Robert) BAULER and Wilson NOBLES. The I/ACS staff member informed that the NRC intended to inform VEPCO, without revealing his identity, of the alleged use of improper coating materials and further, to request them to analyze test coupons selected from portions of the ventilation ring ductwork. ~ (4) On July 17, 1984, A VEPCO Corporate officials was informed that an allegation had been received by the NRC which , indicated improper and non-nuclear qualified coating materials had been used on the Units 1 and 2 ventilation ring ductwork. Further, it was requested that VEPC0 conduct sufficient inquiries to detemine the identities of coating materials utilized and to ascertain the loss of Coolant Accident (LOCA) significance and implications of these products. Further, on July ?7, 1984, a VEPCO official telephonically infomed Regich II. NRC that their analysis disclosed that non-nuclear qualified base coat was probably utilized on the ventilation ring ductwork in Unit I but that Unit 2 " appears to meet" procedures specified.in NAS-1016. (5) On August 3, 1984, at the request of VEPC0 Corporate management, a meeting was held with NRC officials in Bethesda, MD to discuss technical and health and safety implications of using non-nuclear cualified coating materials inside containment environment and of using paints not approved for galvanized steel surfaces. An August 13, 1984 NRC memorandum, with attachments, sumarizing contacts with the licensee pursuant to their options regarding corrective actions for health and safety implications is Exhibit 3. 8
_. . . . - = _ - - -- . ._ 4 (6) On August 21, 1984, the NAPS Senior Resident Inspector advised the I/ACS staff that William BURNS, a site Quality Control Inspector who inspected the initial ventilation ring ductwork coating project, had stated NAPS " engineering people" were told by him (BUPNS) before the Unit I coating project was initiated that paint should not be applied to a galvanized steel surface. According to the NAPS Senior Resident Inspector, BURNS was informed by " station i engineering" that the ventilation ring ductwork was not a safety related system; that he (B'JRNS) should not be concerned about this aspect of the project and that he should "just apply the paint." The investigation initiation letter, referenced above, asks for interviews initially with the confidential alleger, the two NAPS
' supervisors and the Quality Control inspector but requests expansion of investigative activities if infonnation is developed which would
} warrant such actions. 4 Interviews of NRC Officials
- During the investigation, the following Region II, NRC officials were
- interviewed regarding their knowledge of these incidents as a result of their participation in the technical resolution of this matter:
i Stephen E. ELROD, Section Chief James G. LUEHMAN, Resident Inspector ELROD, on September 7,1984, reiterated the contents of the NRC memorandum dated August 13, 1984 (Exhibit 3) and the investigation request memorandum (Exhibit 1) and provided historical data regarding the vertilation ring ductwork coating projects at NAPS Units 1 and 2. . He advised that, in his opinion, the obvious failure of the licensee to properly evaluate the maintenance work requests for safety significance and implications regarding this system resulted in the use of non-nuclear qualified coating material and the coating of a galvanized steel surface. ELROD further opined that NAPS Construction Department supervision responsible for coating matters was aware that their coating procedures were being violated when this work was i accomplished. LUEHMAN, specifically on September 10, 1984 and i December 4, 1984, cnd at various intervals during the investigation, provided pertinent coments and information he had obtained during the routine performance of resident inspections at the NAPS facility.- He i reiterated the allegations and concerns of the alleger and explained ! the technical and operational evaluations performed by both the
- licensee and the NRC regarding the Units 1 and 2 ventilation ring
- ductwork coating projects. Additionally, LUEHMAN advised of I
' conversations with NAPS Ouality Control (QC) personnel, including Site Manager Andrew HOGG, Supervisor Jim SMITH and Inspector BURNS, wherein i ' they acknowledged that objections raised by QC regarding coating of a ) galvanized steel surface was over-ruled by "someone in engineering," l not further identified. LUEHMAN also advised that during an August 20, 1984 meeting with these NAPS Quality Control personnel, BURNS made claims regardirg preparation of the coated surfaces which 9 l l - _._. _ _ _ _, ,_ _ ___ _ _ . _ , _ _ . _ ,
were later determined to be inaccurate. He said BURNS adamartly asserted that all coated surfaces of the ventilation ring ductwork were prepared to the exact specifications stated in the PCSPR's . He to achieve an SP-10 surface as indicated , a comparator on the PC standard was used to insure the required surface. finish had been achieved. standard usedLUEHMAN advised that upon asking to see the comparator
" copies were o,n order."HOGG told him that none was available on site b Investigator's Note:
NAPS Construction personnel were asked to provide comparator standard for surface preparations. All of the they were unaware of the existence of this it either during or prior to the ventilation ring ductwork coating projects. Interview of Alleger I i 10 i
Interviews of Contract Painters ASKEW, in Exhibit 5, related in essence the following infomation: As an FC contract painter at the NAPS site from June 1982 to March 1983, and from June to December 1983, he mixed and batched and forwarded to the Unit 1 containment building Debevoise Dereka No. 505 Red primer (base coat), not Mobil Chromax 13-R-50, and Dupont white Epoxy (finish coat) at the direction of BAULER for use during the Unit I ventilation ring ductwork coating project. He was told by BAULER to transport the paint (Dereka No. 505) to the Unit I containment building in " unmarked" containers, a violation of the NAS-1016 procedures. The NAPS QC inspectors were not present at any time when the paint used on the Unit I ventilation ring ductwork were selected, mixed and batched. Investigator's Note: Both the North Anna Power Station procedure NAS-1016 and VEPC0 Multiple Power Projects QCI 11.1 require QC participation in these processes. Joseph Edward BROWN, Jr., an FC contract painter at the NAPS site since June 1982, related that Robert BAULER, the NAPS Construction Supervisor and " coatings expert," completely managed, directed and supervised the Unit i ventilation ring ductwork coating project. BROWN advised he personally infomed BAULER that the enamel (base coating) and epoxy (finish coating) materials he (BAULER) had selected were not nuclear qualified and/or should not be utilized together to coat a galvanized steel surface. He said BAULER forcefully told him to either do as he had instructed or to " hit the road," a coment he (BROWN) interpreted as a termination threat. BROWN concluded that, i although knowing he was using non-nuclear qualified paint to coat a galvanized '+ eel surface, he followed the directions of BAULER while involved in the Unit 1 ventilation ring ductwork coating project. HUNLEY, in Exhibit 6, related in essence the following information: As an FC contract painter at the NAPS facility from June 1981 to May 1983, he participated in the ventilation ring ductwork coating project in December 1982, under the total supervision of BAULER. He voiced concern to BAULER that the enamel base and the epoxy finish coats were incompatible and non-nuclear qualified for a containment environment. The galvanized steel surfaces of the ventilation ring ductwork were inadequately and incorrectly prepared under BAULER's direction, even though the QC documentation in the form of the PCSPR's he prepared reflects proper surface preparations.
, 11
The PCSPR's for the Unit I ventilation ring ductwork contain false, erroneous and incorrect paint identifier and coating process related inforrration entered by BAULER and concurred with by NAPS QC Inspectors Bill BURNS and Bill HARRIS. The NAPS QC inspectors were not present to inspect all of the Unit I ventilation ring ductwork coating project, even 4 though they signed PCSPR's indicating they had independently performed their responsibilities. Charles Cecil LAMB, an FC contract painter at the NAPS site from October 1980 to March 1983, advised he prime (base) coated the entire Unit I ventilation ring ductwork using Debevoise Dereka No. 505. LAMB advised that in his opinion, BAULER failed to follow the NAS-1016 coating procedure by allowing impropar surface preparations before paint application and by using non-nuclear qualified coating materials. He said BAULER, through threatening and intimidating management practices, required all coating work to be perfomed in the manner he directed which was not always according to NAS-1016 requirements. LANG, in Exhibit 7, related in essence the following information: As an FC contract painter and foreman at the NAPS site since July 1981 he participated in both the Units 1 and 2 ventilation ring ductwork coating projects. The NAPS Maintenance Department concurred with the Construction Department recommendation to coat the Units 1 and 2 ventilation ring ductwork to mitigate boric acid corrosion damage. BAULER directed all painting activities on the Unit i ventilation ring ductwork. The PCSPR forms associated with these. coating projects in Units of surface 1 and 2 contain preparation incorrect inasmuch entries as they regarding)the (surfaces were not manner prepared as indicated by BAULER, who completed these forms. The use of non-nuclear qualified coating materials over a galvanized surface during the Unit I ventilation ring ductwcrk project resulted from failure by NAPS officials to conduct an engineering evaluation and the failure by t,he QC Department to perform their responsibilities. He contacted the Keeler and Long field representative regarding the base and finish coating materials utilized on the Unit 2 ventilatior ring ductwork and was told that these products were nuclear qualified and approved for use on a galvanized steel surface. Interviews of Construction Department Officials NAPS Construction Department officials who were affiliated with the Units 1 and 2 ventilation ring ductwork coating projects were 12 l t
interviewGd recarding the purpose of the investication, ' 4 e e 1 4 13
r NOBLES, infonnation: in Exhibit 9, related in essence the following pertinent NAPS employee BAULER, as Construction Department Coatin Supervisor, managed all coating / painting activities at the ductwork projects in 1982 and 1983. facility, including He (NOBLES) was minimally involved only in the Unit I coating project. Although he (NOBLES) supervised BAULER and they both were tware that the ventilation ring ductwork system was constructed of galvanized steel, neither recognized the safety implications or the NAS-1016 procedure requirerrents
~ pertaining to the coating of galvanized surfaces.
BAULER was an "opininated" supervisor who failed to utilize sound and impartial management principles; a style which resu'ited in animosities between him, BAULER and other NAPS management and craf t personnel. Although BAULER was responsible for ensuring that PCSPR's were prepared, the QC Inspector is required to sign and date these forms certifying that an independent verification of coating activities has been performed. He (NOBLES) the Unit I ventilationsaid he wascoating ring ductwork unaware that PCSPR's as project contained false information and he did not recognize the safety implications containment. of coating a galvanized surface inside selected for these projects were non-nuclear qualifie 14
Investigator's Note: During post interview remarks by NOBLES, he alluded to personality, philosophical and professional conflicts with BAULER, resulting in " vicious" . and false accusations by BAULER. N0BLES appeared to provide l responses to questions regarding interpersonal and professional relationships with BAULER with apparent
. sincerity, candidness and forthrightness. '
JONES, in Exhibit 10, related in essence the following pertinent information: He was serving as the NAPS Construction Department Superintendent when the Units I and 2 ventilation ring ductwork projects were initiated. BAULER was delegated the responsibility to manage, coordinate and supervise these projects. He did not know why these projects were regarded as non-safety related or why a safety analysis was not performed. JONES denied he was aware that the NAS-1016 coating procedure was violated when these projects were accomplished and that non-nuclear qualified coating materials were utilized. He further den!?d that he allowed or directed vio'ations of procedures and practices which impacted upcn health and/or safety considerations. He claimed no knowledge of false or discrepant entries on QC documentation associated with either of these projects. FRALEY, in Exhibit 11, related in essence the following pertinent information: The NAPS work requests which initiated the Units I and 2 ventilation ring ductwork coating projects are Maintenance Reports (MR) rather then Design Change Packages (DCP). Since an MR requires no safety or engineering analysis or evaluation, this explains why the safety implications of these projects were inadvertently overlooked. The actual coating proc BAULER under the superv, isionesses wereand of JONES directed and These NOBLES. managed by individuals had daily access to and were supposedly knowledgeable of the NAS-1016 coating procedure. After learning from the NRC in July 1984 of potential procedural and safety violations associated with both ventilation ring ductwork coating projects he noted inaccurate and discrepant data in the PCSPR's, including the manner of surface preparations and type of primer coating used in Unit 1. He identified BAULER as the NAPS supervisor responsible for preparing / approving inaccurate QC documentation. He also 15 t l
intimated that JONES may have been aware that the NAS-1016 procedure was being violated at the time the projects were in progress, only because he supervised BAULER. He stated he was never consulted by BAULER regarding coating materials used during these projects and he did not direct BAULER to consult with any paint manufacturer regarding these materials. He denied personal knowledge that construction, engineering or quality centrol procedures were violated during these projects. He claimed he is unaware that any NAPS management officials, except BAULER and perhaps JONES, were aware that procedures were violated. Interviews of Maintenance Department Officials HARPER, in Exhibit 12, related in essence the following pertinent information: As the Maintenance Department Superintendent, he authorized, approved and obligated funding for the Units 1 and 2 ventilation ring ductwork coating projects. He consulted with Construction Department Coating Supervisor BAULFR, who recommended coating the galvanized surfaces to mitigate the effects of boric acid corrosion. He concurred with this recomendation, issuming BAULER was knowledgeable of applicable coating procedures. He stated that a safety or engineering evaluation was not performed regarding these projects because, to his knowledge, coating / painting had never before received such an analysis at the NAPS facility. He advised that safety implications associated with these projects were inadvertently ignored. He claimed no deliberate disregard of procedures governing these activities. The following NAPS Maintenance Department employees were interviewed regarding the purpose of this investigation: Doswell Stubbs P!ERCE, Maintenance Coordinator Ronald Eugene STILES, former Maintenance Contractor Coordinator James Richard STRATTON, Maintenance Supervisor PIERCE, interviewed on September 13, 1984, related he was responsible for initiating funding and authorization documentation regarding the ventilation ring ductwork coating projects in Units 1 and 2. He said he was not responsible for determining whether work activities are safety related and that he is not qualified to make this determination. PIERCE advised he was unable to provide any insight into the manner in which these projects were performed or the , , 16
decisions made by personrel directing, managing or supervising these activities. He denied any knowledge of improprieties associated with either of these coating projects. STILES, interviewed on September 13, 1984, advised he reviewed i documentation associated with the ventilation ring ductwork coating projects in Units 1 and 2 to make certain all signatures / dates were affixed. He said the actual work activities, including any safety evaluations, procedure requirements and the accomplishment of the coating process are the responsibilities of officials outside of his department. STILES was unable to provide an explanation regarding the failure by appropriate NAPS official (s) to perform a safety analysis. He said that Construction Department Coating Supervisor Robert BAULER told him to annotate the " Work Performed" section of the Unit 1 Maintenance Peport with the comment that "all painting was done IAW (in accordance with) station specificationt." STILES denied knowledge of deliberate violations of procedures or falsification of QC documentation associated with these coating projects. 1 STRATTON, interviewed on October 19, 1984, related in essence.the same comments provided by HARPER, PIERCE and/or STILES, above. He also claimed no knowledge of deliberate procedural violations, willful utilization of improper coating materials or falsification of QC documentation. Interview of Operations Department Officials Tiie following NAPS Operations Department officials were interviewed on December 4 cnd 5, 1984: Robert Carrull STARR, Shift Supervisor Curtis George MEYER, former Shif t Supenisor i Both of these individuals advised separately t at coating the
- ventilation ring ductwork in Units 1 and 2 was recommended and I approved by the NAPS Maintenance and Construction Departments to
! mitigate boric acid corrosion. Both stated that at the time the ventilation ring ductwork was approved for painting, they did not consider the safety implications of coating inside of containment. STARP advised that, at the time, he inadvertently failed to consider the impact of peeling paint in the event of a LOCA. He said that since painting, in his interpretation, did not structurally alter the ventilation ring ductwork, he did not consider it necessary for an engineering or safety analysis to be performed. MEYER stated also that he inadvertently failed to consider the safety implications of l coating in containment and for this reason a safety analysis by the i engineering department was not requested. Both individuals denied any deliberate attempt to violate procedures or to corsciously preclude the engineering department from performing an evaluation / analysis of these projects. T l l 17 .
Interviews a of Technical Services Personnel The following NAPS Technical Services (Engineering) personnel were interviewed on October 11, 1984 regarding the purpose of this investigation: Peter Thor KNUTSEN Supervisor of Nuclear Engineering Michael Glenn PINION, Engineer Both individuals advised separately that they did not recall requests from NAPS Construction, Maintenance or the Operations Departments for a safety analysis regarding the ventilation ring ductwork coating projects in Units 1 and 2. KNUTSEN advised that had the Engineering Department given advice or rendered assistance regarding these projects it would have been documented with an Engineering Work Request fore. He said no such forms or documentation exists in the NAPS Engineering Department regarding these projects. He stated that
^any engineering guidance provided regarding these prof,ects would have been within the parameters of NAS-1016, the coating procedure generally available to all NAPS departments. heither individual was able to explain the reason a safety or engineering analysis was not requested, although they opined the " low priority" and relatively insignificant status of coating projects likely contributed to this failure.
Investigator's Note: William BURNS, QC Inspector at the NAPS facility stated in testim'ny recorded in a subsequent section of the report that he psrsonally notified the Engineering Department upon learning no safe.v analysis had been performed prior to coating the ventilation ring ductwork in Unit 1. Both KNUTSEN and PINION, at the request of the investigator, researched engineering records and files and cortacted other engineers regarding BURNS' assertions. This effert failed to locate any evidence that the Engineering Departreet was informed of this matter by BURNS or any other QC persconel. Interviews of NAPS Plant Officials _ PARKER, in Exhibit 13, related in essence the following pertinent information: During the summer of 1982, he attended a meeting with NAPS Corstruction Department personnel FRALEY, JONES and BAULER and then Station Manager Robert CARTWRIGHT, which resulted in the decision to paint the Unit 1 ventilation ring ductwork to mitigate boric acid corrosion. He approved the Unit 1 " Request For Work" form and forwarded it to the NAPS Construction Department for implementation. 18
Although not involved in the actual work process, he did not recall any comments by any NAPS personnel pertaining to the safety implications of coating the ventilation ring ductwork in either Units 1 or 2. These projects should have been perfomed in accordance with NAS-1016 and QCI 11.1 coating procedures for Construction and Quality Control respectively. He attributed subsequent Units 1 and 2 ventilation ring ductwork coating defects to BAULER's failure to follow existing procedures and because of ineffective communications between all of the NAPS departments involved in these projects. He claimed no knowledge of willful, deliberate procedural vi?lations or QC records falsifications regarding these proj ects . E0WLING, in Exhibit 14, related in essence the following pertinent information: Although he was not employed at the NAPS facility when the Units 1 and 2 ventilation ring ductwork were coated, since July 1984 he has attempted to determine the circumstances which caused non-nuclear qualified materials to be utilized in coating a galvanized steel structure inside of containment. To his knowledge no NAPS plant officials were aware that non-nuclear qualified paint was used on the ventilation ring ductwork or that galvanized surfaces inside containment were coated in violation of NAS-1016. He reviewed PCSPR's associated with the ventilation ring ductwork coating projects in Units I and 2 and acknowledged false and discrepant inferration therein, including the method of surface preparation and type of primer coating utilized en Unit 1 syster.. Responsibility for preparing PCSPR's and ensuring the accuracy of the data therein was jointly shared by Construction Supervisor'BAULER and the assigned QC inspector. Edward Wayne HARRELL, Station Manager, interviewed on October 10, 1984, related he was an Assistant Station Manager wher, the Units 1 and 2 ventilation ring ductwork was coated. He reiterated the testimonies of NAPS Construction Maintenance'and Operations Department personnel concerning the decisions to paint these systems. HARRELL acknowledged limited participation in general discussion sessions with Construction ard Paintenance personnel regarding these projects but stated detailed decisions were made at the department level. He claimed no knowledge of procedure violations, utilization of improper coating materials or i l 19 l
any other improprieties associated with these projects. He said he did not learn of these problems until the NRC notified VEPCO's Corporate Office (CARTWRIGHT) of these deficiencies about July 1984 HARRELL advised that VEPCO ordered an immediate investigation of the allegations reported by the NRC and determined an option acceptable to the NRC for alleviating these deficiencies. HARRELL further acknowledged discrepant surface preparation and paint identity information in the PCSPR's associated with these projects. He claimed no personal knowledge of deliberate deviations from established procedures or of intentional falsification of QC documentation. William Robert CARTWRIGHT, fonner Station Manager, was interviewed on December 7,1984 and reiterated the comments of HARRELL, above. He 2 denied knowledge of deliberate violations of procedures or any records improprieties associated with the coating projects in Units I and 2. Interviews of Paint Manufacturing Representatives LONG, in Exhibit 15, related in essence the following pertinent information: , Neither he nor any member of his staff recall any telephone
- contacts by anyone from NAPS in 1982 or 1983 regarding the suitability of using Keeler and Long products or those of 3 any competitors on galvanized steel ventilation ring ductwork inside containments, i
In July or August 1984. Keeler and Long received three telephone calls from VEPCO/ NAPS regarding the suitability of using Keeler and Long 6548/7107 primer and E-1 Series top coat on a galvanized surface in a containment environment. i The callers were informed that these materials were not - suitable for the use described.
; CANFIELD, in Exhibit 16, related the following pertinent information:
He is acquainted with Robert BAULER, former Construction
- Supervisor at NAPS. At no time did BAULER or any NAPS or contractor employee at the facility solicit information or advice from him regarding the use of any coating materials for the ventilation ring ductwork in the containments of Units 1 and 2. .
Investigator's Note: l , All Keeler and Long personnel j contacted during the investigation recall no contacts j of any sort with BAULER regarding 1982 and 1983 ventilation ring ductwork coating activities in Units 1 i or 2. LANG (Exhibit 7) claimed he telephonically l 1
, 20
contacted CANFIELD regarding compatibility of paint for the Unit 2 project, however, CANFIELD did not recall this or any other consnunications with NAPS personnel regarding the ventilation ring ductwork coating . projects.
- Interviews of NAPS Quality Assurance Personnel 1
' Andrew Logan HOGG, Jr., Site QA Manager, interviewed on October 10 and i December 6, 1984, related he held his current position during the periods when the Units 1 and 2 ventilation ring ductwork coating i projects were being performed. HOGG claimed that his involvement in
- these projects was minimal. He identified QC Inspectors Bill BURNS and Bill HARRIS as the individuals assigned to conduct required
) inspections of the ventilation ring ductwork coating activities. H0GG 1 advised that he never questioned these inspectors regarding their { inspection activities on the ventilation ring ductwork and he never had reason to doubt their integrity concerning these matters. He l claimed no knowledge of any QC records improprieties by HARRIS or
! BURNS and said they never discussed their coating inspection duties or l ' the contents of the PCSPR's they signed and dated regarding the ventilation ring ductwork coating activities in Units 1 and 2. j i
i Investigator's Note: HOGG appeared defensive of BURNS and HARRIS when answering ouestions regarding possible records improprieties : by these individuals. He strongly asserted that they were above reproach in all respects and that they always performed in a professional and competent manner. The suggestion that they I could have performed these coating inspections in other than a professional manner caused HOGG to become irritable and antagonistic. SMITH, in Exhibit 17, related the following pertinent information: ) - He supervised both BURNS and HARRIS when they conducted inspecticns of the ventilation ring ductwork in Units 1 and
- 2. He acknowledged that these inspectors did not participate in the selection, mixing, batching and labelling i
and in some primer and top coat application activities in j i the Unit 1 project because the Construction Department failed te notify the QA Department of this project in c timely manner. He does not knew whether BURNS and HARRIS performed the , inspections functions as indicated on the PCSPR's for Units 1 and 2 since he performed no verification activities, i - In August 1984, when the licensee was directed by the NRC to determine the circumstances of the coating deficiencies in ]i Units 1 and 2 he questioned BURNS regarding his signatures on the PCSPR's. He said BURNS told him his (BURNS)
- signature represented independent verification according to i j applicable QC procedures, i
4 1 .
?!
f
l Both BURNS and HARRIS told him subsequently they had 4 inspected the ventilation ring ductwork coating projects according to existing procedures and that their signatures on PCSPR's certified their independent verification. j - Subsequent evidence. indicates that both BURNS and HARRIS may have failed to properly perform their inspection duties, j although he (SMITH) never confronted them regarding apparent ' ! records discrepancies. ! BURNS, in Exhibit 18, related in essence the following pertinent 1 information: 1 - Upon being assigned to inspect the Unit 1 ventilation ring
- ductwork coating activities in December 1982, he informed a
! NAPS engineer, not further identified, that no engineering
- evaluation had been performed regarding this project.
1 He informed the same engineer that required surface preparation for the ventilation ring ductwork had not been properly achieved and that paint was being applied to a j galvanized steel surface, i j - He signed and dated PCSPR's without performing certain of
! the inspection functions and responsibilities required by i
NAPS Construction and Quality Control procedures. He i acknowledged his actions in this regard as a deliberate and conscious falsification of QC documentation, j - He collaborated with and was manipulated and coerced by BAULER to falsely certify that QC functions and responsibilities had been properly accomplished during the [ Units 1 and 2 ventilation ring ductwork projects. i In August 1984, he discussed the false and inaccurate entries on the PCSPR's with two supervisors and both dirs!cted him to make a full disclosure to the NRC regarding i his actions. Investigator's Note: During the interviews of HOGG and l SMITH both advised that they had not discussed records j improprieties or ventilation ring ductwork inspection ! activities with BURNS or HARRIS. Based upon BURNS' I testimony, both HOGG and SMITH were aware of false i entries in the ventilation ring ductwork PCSPR's in i August 1984. Both HOGG and SMITH categorically denied l BURNS' assertions. His failure to properly perform inspection duties and ! enforce procedures resulted in the utilization of j non-nuclear qualified coating materials and applications of i paint over a galvanized steel surface. 22 l I
HARRIS, in Exhibit 19, related in essence the following pertinent information: i As one of two QC inspectors assigned to the ventilation ring s ductwork coating activities in Units I and 2, he knowingly e signed and dated PCSPR's which contained false, erroneous and inaccurate entries and which are not reflective of his inspection efforts regarding these projects. i - He permitted NAPS coating supervisor Robert BAULER to
, initiate PCSPR's containing inaccurate date.
He accepted BAULER's data entries on the PCSPR's without performing an independent inspection as required by NAPS procedures. He allowed BAULER to manipulate him in an unprofessional manner and he failed to perform inspection duties associated with these projects in a co:npetent professional manner. 1
\
23 l
i 1 REVIEW OF LICENSEE RECORDS
- Pertinent licensee files and records were reviewed during the course of this investigation. Exhibits 20 through 32 are copies of documents from these files and records, provided by Steven B. EISENHART, Licensing Coordinator, at the NAPS facility. '
Exhibits 20 and 21 are two dimensional drawings of half of the NAPS Units 1 and 2 Containment Air Recirculation System and Purge Exhaust, reflecting both the inner and outer ductwork of the system. j Exhibits 22 and 23 are copies of the completed " Request For Work"
- fom, Number 1499999160, dated December 13, 1982 and Maintenance i
Request form (MR) Number N1-82-12230510 (Unit 1) and the " Request For
!~ Work" form Number 1499999240, dated March 22, 1983 and MR fom Number N2-82-06030033 (Unit 2).
1 Investigator's Note: R.E. STILES, NAPS Maintenance Coordinator during the period December 1981 to March 1983, related that these documents were prepared, for planning purposes, "well in advance" of the actual accomplishment of the ventilation ring ductwork-coating projects. He advised that this fact accounts for the "6/14/82" date on the Unit 1 " Request For Work" fom and for the "06/02/84" (typographical error) date on the Unit 2 MR. A.Q. PARKER related he inadvertently indicated "No" QA Approval on the Unit 1 Request For Work and R.C. STARR advised that'he j indicated "No" in the Safety Related sections of each MR since he i inadvertently failed to consider the health and safety '
- implications of painting the galvanized steel ventilation ring j ductwork.
Exhibit 24 is a handwritten memorandum from Stephen B. EISENHART, NAPS Licensing Coordinator to Investigator Robert H. Eurch, which documents the results of his search for "an enguieering decision or j determination" regarding the Units 1 and 2 ventilation ring ductwork
- coating projects. According to the memorandum, no documented ;
i
" engineering decisions" were located regarding these projects.
J , Exhibit 25 is a copy of VEPCO's License Event Report (LER) . No. LER-84-006 dated April 30, 19.84. This licensee document describes ! , "the event" (application of non-nuclear qualified coating materials on l l' galvanized steel ventilation ring ductwork inside containment), l addresses the cause and sets forth the licensee actions to be taken to ' correct these deficiencies and prevent their recurrence. ;
- Exhibit 26 is a copy of an Impell Corporation report entitled
! " Administrative Controls Assessment Concerning Coating Controls at i North Anna and Surry Power Stations." This document is the result of
. Impell's analysis and review of coating / painting controls and l' procedures at both the North Anna and Surry Nuclear Generating Plants after VEPCO officials were informed by the NRC that non-nuclear j qualified coating materials had been utilized on ventilation ring i
ductwork. The comments reflected in the " Executive Summary," i I 24
" Scenario" and " Observations" sections regarding QC involvement corroborate certain of the investigative disclosures set forth in this report of investigation.
Exhibit 27 is a copy of a NAPS Construction Department memorandum dated October 15, 1984 entitled " History of Ring Duct Coatings Unit I and 11 North' Anna Power Station." This memorandum sets forth discrepancies which have been noted in PCSPR's associated with the Units 1 and 2 ventilation ring ductwork coating projects, including surface preparation activities and identification of Unit 1 primer coating. Exhibit 28 is a copy of NAPS Purchasing Department memorandum dated October 15, 1984. This document states that no Mobil 13-R-50 (Mobil Chemical Company product) coating material was purchased by VEPC0 for the NAPS facility. Exhibit 29 is a copy of a paint label provided by former FC painter Ray ASKEW on October 10, 1984. ASKEW, in providing the paint label, advised unequivocally that Dereka No. 505 Red Primer and not Mobil 13-R-50, was used as the primer coating on the Unit I ventilation ring ductwork. Exhibit 30 is the primer coating PCSPR's (4 documents) 'for the NAPS I Unit I ventilation ring ductwork. Exhibit 31 is the finish coating PCSPR's (5 documents) for the NAPS Unit I ventilation ring ductwork. Exhibit 32 is the primer and finish coating PCSPR's (4 documents) for the NAPS Unit 2 ventilation ring ductwork. Investigator's Note: The inaccuracies and discrepancies contained in Exhibits (30) through (32), above, are set forth in the sworn statements of BURNS and HARRIS, which have been attached to the Report of Investigations as Exhibits (18) and (19),respectively. 1 l 25
REVIEW OF BAULER'S RECORDS The files and records pertaining to Robert N. BAULER, applicable to his employment tenure at the NAPS facility, were made available to the NRC Office of Investigations by Corporate licensee official R. J. HARDWICK, Jr. Information and documentation contained in BAULER's files and records, which is deemed pertinent to thir' investigation, is set forth in this section of the investigation report. VEPC0 Personnel Department records reflect BAULER was employed in the NAPS Construction Department from March 1980 to June 1981 and again from September 1981 to March 1984.
. BAULER was separated from VEPCO/ NAPS on March 2, 1984. These personnel records O
26
m . - ~ 4: - 4 a- - -L -- _.,__ ~ O*G e e r 1 27
LIAISON WITH THE REQUESTOR During the course of the investigation the Region II Office of the Regional Administrator and/or members of his staff, including the NAPS Resident Inspector, were frequently apprised regarding the progress and disclosures of the investigation. At the conclusion of the investigation, the Region II staff personnel were apprised of all investigative disclosures and no additional investigation was requested. 4 .l i 28
STATUS OF INVESTIGATION Inasmuch as all logical and significant investigative activities have been completed, the status of this investigation is CLOSED. i I 4 l J i i
+
'I 1 29
.c ,
,-. , -- .ge -
WILLFULNESS / INTENT This investigation was initiated to determine and/or resolve: (1) Whether non-nuclear qualified paint was deliberately and knowingly used to coat galvanized steel surfaces of the ventilction ring ductwork inside the containments of Units V and/or 2, in violation of applicable regulations and procedures. (2) When licensee management became aware of the apparent use of non-nuclear qualified paint; what level of licensee management was aware of this deficiency / discrepancy and to what extent did licensee officials discuss this matter. (3) Other discrepancies and deficiencies resulting from or associated with the apparent use of improper coating materials on the ventilation ring ductwork. With regard to item 1 above, it was determined through interviews that:
- Robert N. BAULER, then NAPS Construction Supervisor (Coatings) (first line supervisor) knowingly directed l painters to apply a non-nuclear qualified base coating over the galvanized steel surfaces of the ventilation ring ductwork inside Unit I containment. This determination is based upon the testimonies of HUNLEY (Exhibit 6) BROWN and LAMB. These individuals further surmissed that, because the Unit I and. Unit 2 ventilation ring ductwork is identical, BAULER also knowingly directed the application of nuclear cualified coating materials over the galvanized steel ventilation ring ductwork in Unit 2.
With regarding to Iter 2 above, it was determined through interviews
- and licensee documentation that:
- Licensee management, except BAULER, was apparently unaware that non-nuclear qualified paint had been used to prime coat the Unit 1 galvanized steel ventilation ring ductwork until the NRC notified VEPCO officials in July 1984. Further, inquiries disclosed that licensee management was apparently unaware of the safety implications resulting from the use of nuclear qualified coating materials over the galvanized steel ductwork in Unit 2 until after the NRC advised VEPC0 officials of the coating discrepancies in Unit 1.
- Based upon interviews of contract painters and NAPS Construction, Maintenance, Engineering, Operations and Quality Assurance officials no evidence of management l knowledge of these discrepancies beyond the level of BAULER l was developed. Although indicated NAPS Construction Department officials FRALEY, JONES and N0BLES and 30 l
Maintenance Department Superintendent HARPER (see Exhibit 2 for level of management) were aware that a galvanized steel system was being coated in the Units 1 and 2 containment, all denied deliberate or willful violations of existing coating regulations and safety procedures. These and all other NAPS management officials claimed that the health and safety significance of coating the galvanized structures was inadvertently overlooked at the time the decision was made to paint the ventilation ring ductwork. A significant number of licensee officials in the NAPS Construction, Maintenance, Engineering, Operations and Quality Assurance Departments alluded to " communications deficiencies" between departments as one cause of these coating discrepancies, (see Exhibits 9, 10, 11, 12, 13 and 14). With regard to Item 3 above, it was determined through interviews that: QC Inspectors assigned to inspect the ventilation ring ductwork coating projects in Units 1 and 2 failed to perform their inspection duties as required by procedures (see Exhibits 4, 5, 6 and 8). Further, during the interviews of the two QC inspectors assigned to the ventilation ring ductwork, both acknowledged that they collaborated with NAPS Construction supervisor BAULER to certify false and inaccurate entries on the PCSPR's associated with these projects (see Exhibits 18 and 19). 31 c ,,
EXCULPATORY INFORMATION Based upon the testimonies of a significant number of interviewees, it was disclosed that several factors contributed to the coating deficiencies associated with the Units 1 and 2 ventilation ring ductwork projects. Those factors are enumerated as follows: (1) The apparent failure of NAPS facility management personnel (Maintenance, Construction. En Quality Assurance Departments)gineering, Operations to discuss and/or and comunicate ramificatiors and safety implications of coating these systems at che times the decisions were made to perform this activity. (2) Historically, the low priority and relative unimportance of the coatings process at the NAPS facility by management officials. (3) The apparent inadvertent failure of NAPS Operations Department management officials to recognize that coating / painting a safety related system is, in effect, a design change requiring an enginee-ing evaluation. (4) The apparent lack of quality control inspectors with experience in the coatings discipline when the ventilation ring ductwork projects were initiated. (5) The inaccessibility to and/or unfamiliarity with NAPS coating procedure NAS-1016 by craft personnel involved in coating activities. (6) The apparent inadequacy of the coating and/or quality centrol procedures in effect at the time the ductwork systers were coated. ~ Investigator's Note: Evidence of Item 6, above is the fact that on August 14, 1984 and August 17, 1984 NAPS implemented VEPC0 Site /Section Operating Procedure 50P No. 8.8.0N and Quality Assurance Department Instructions QADI 10.13, respectively. These procedures were developed and implemented to provide guidance regarding " Coatings Application" and " Coatings Inspection" at the NAPS facility. Exhibits 4, 6, 7, 9, 10, 11, 12, 13, 17, 18 and 19 discuss and address l one or more of the above listed factors. I 32
- -~
CONCLUSIONS The evidence obtained during the investigation, in the form of documentation and interviewee testimony set forth in signed statements and Results of Interviews disclosed the following: BAULER, then the NAPS Construction (Coatings) Supervisor (first level), directed craft painters to apply a non-nuclear qualified primer coating material on the galvanized steel ventilation ring ductwork of Unit 1. He further directed the application of an incompatible top coating on this same structure and he directed applications of nuclear qualified primer and top coating on the Unit 2 galvanized steel ventilation ring ductwork. QC Inspectors BURNS and HARRIS, in collaboration with BAULER, knowingly placed false and erroneous information on the PCSPR's after failing to perform their inspection duties and responsibilities. All three individuals signed and dated the PCSPR's certifying that data contained therein was correct and factual and that independent QC verification had been performed in accordance with applicable procedures. No NAPS management official above the level of BAULER apparently recognized the safety and health implications of coating the galvanized steel ver.tilation ring ductwork inside of containments until the licensee was notified by the NRC in July 1984. Exhibits 4, 5, 6, 8, 18, 19, 29, 30, 31 and 32 discuss and support the conclusions as set forth in this section of the Report of Investigatien, i 33
EXHIBITS (1) Region II, NRC investigation request memorandum, dated 8/23/84 (2) VEPCO/ NAPS Organization Chart (3) NRC memorandum from L. ENGLE to J. MILLER, dated 8/13/84 (4) (5) Results of Interview of F.R. ASKEW, dated 10/10/84 (6) Signed Statement of G.H. HUNLEY, dated 9/26/84 (7) Results of Interview of M.N. LANG. dated 9/12/84 (8) (9) Results of Interview of W.C. NOBLES, dated 10/18/84 (10) Results of Interview of J.M. JONES, dated 12/8/84 (11) Results of Interview of A.D. FRALEY, dated 10/10/84 (12) Results of Interview of J.R. HARPER, dated 12/6/84 (13) Results of Interview of A.Q. PARKER, dated 9/13/84 (14) Results of Interview of M.L. BOWLING, Jr., dated 9/12/84 and 10/10/84 (15) Signed Statement of H.L. LONG, Jr., dated 10/3/84 (16) Results of Interview of N.R. CANFIELD, dated 12/10/84 (17) Results of Interview of J.A. SMITH, dated 10/9/84 (18) Signed Statement of W.D. BURNS, Jr., dated 12/4/84 (19) Signed Statement of W.J. HARRIS, dated 12/5/84 (20) Two dimension drawing of one half of the Units 1 and 2 ventilation ring ductwork system (21) Two dimension drawing of one half of the Units 1 and 2 ventilation ring ductwork system (22) Request For Work Form No. 1499999160 and associated ' Maintenance Report No. N1-82012230510 (23) Request For Work Form No. 1499999240 and associated Maintenance Report No. N2-82-06030033 (24) Memorandum from EISENHART to BURCH regarding Document l Search, dated 10/11/84 l - (25) VEPC0 letter to the NRC, Washington, DC, dated 10/30/84, with attached LER 84-006 (26) Impell Corporation report, dated August 1984 (27) NAPS memorandum from G. LUDDEN to A. FRALEY, dated 10/15/84 regarding " History of Ring Duct Coatings Units I and II" (28) NAPS memorandum from K. CUMMINGS to A. FRALEY, dated 10/15/84 regarding purchase of Mobil 13-R-50 material. (29) Label from Dereka No. 505 Red Primer paint can (30) PCSPR's (5 sheets) for Primer Coating, Unit i ventilatior ring ductwork (31) PCSPR's (5 sheets) for Finish Coating, Unit 1 ventilation ring ductwork (32) PCSPR's (4 sheets) for Primer and Finish Coatings, Unit 2 ventilation ring ductwork 34
e,a mars, UMTED ST ATES g o, mdCLEAR REGULATORY COhWisSION [ CEGION II g g 101 M ARIETTA STT.EET.NR ATI. ANT A, GE CRGI A 30303 Qg
*...* huo6 Tl lY EH E 27 Pi! 3: 34 j MEMORANDUM FOR: James Y. Vorse, Director Office of OfMigiggjptyJjyp Atlanta Field Office IF Tc: egg ,T .
FROM: James P. O'Reilly, Regional Administrator
SUBJECT:
REQUEST FOR INVESTIGATIVE ASSISTANCE NORTH ANNA NUCLEAR PLANT CASE NO. RII-84-A-0078 An allegation concerning paint applications on ventilation ductwork in the North Anna containments was received by Region II. The information indicated that an improper type of paint had been applied on the ductwork. Subsequently VEPC0 was verbally requested by Region II to conduct a technical review to determine the facts and circumstances surrounding this concern. That review by the licensee indicated that the paint may not have been LOCA qualified as required by the FSAR. Through preliminary interviews conductad by the Senior Resident Inspector and Investigative Coordinator infomation w developed which indicated that a first line supervisor at North Anna may have been aware that improper paint materials were used on ductwork in the containments. Considering this infomation, I am requesting that you conduct an inquiry to detemine when the licensee first became aware of the apparent use of improper paint (other than when informed by the Region) and what level of licensee management was aware of the problem to include the extent and depth of that knowledge. In addition, your inquiry should examine what resultant actions were taken by the licensee and the extent of comunications within licensee management relative to this problem. Your inquiry should be initiated with formal interviews with the alleger and the two individuals identified as having knowledge of the problem. In addition, you are requested to interview a quality control inspector who claims to have expressed concerns to " engineering" that the paint was not being properly applied. It appears from infomation presently available that these interviews may provided sufficient information to test the concerns and answer the above questions; however, should your inquiry develop information which would warrant expanding to a full investigation you would be expected to pursue the matter to a logical conclusion. We will provide any technical assistance that you may need at your request. If infomation of any significance is developed during your inquiry into this matter, please infom me imediately. Please contact Bruno Uryc who will provide you the specific details concerning the individuals involved in this matter. p O mes P. O'Reilly 1 m EXHIBIT (/) Fage / of I Pages
e i. Senior Vice-President Exec. Mgr. Quality Assurance Vice-President Vice-President Construction Nuc. Operations NAPS - Fraley SUP't of ~ NAPS - Ilarrell Project Manager Projects Plant Manager - (Cartwright) ! I Parl;cr .
. Construction Asst. - Rowling Sup't. - (I nes) Plant Manager - (llarrell) i Nobles Bauler NAPS 1.ang Site QA/QC Mgr. Askew Operations Maintenance Sup't of Brown contract 3,p e t. Sup't. Tech.. Services Gibson painters Hogg l """ "Y Starr llarper Knutsen Smith Lamb Burns Pfeyer Pierce Pinion liarris (Stilen)
Stratton
] -
( )= No longer in this posit ion EXHIBIT (2) t Page _ / ne_ / Pa m
[.##"*k p UNITto STATES NUCLEAR REGULATORY COMMISSION m s wecrow.o.c.noess 4
\, ],' ,
AUG 13 g Docket Nos.: 50-338 and 50-339 MEMORANDUM FOR: James R. Miller, Chief Operating Reactors Branch #3 Division of Licensing FROM: Leon B. Engle, Project Manager Operating Reactors Branch #3 Division of Licensing
SUBJECT:
SUMMARY
OF MEETING WITH THE VIRGINIA ELECTRIC AND POWER COMPANY (VEPC0) REGARDING NON-QUALIFIED PAINT INSIDE CONTAINMENT AT NORTH ANNA POWER STATION, UNITS N05. 1 AhD 2 Introduction A meeting was held on Friday, August 3,1984, with VEPC0 and the NRC staff in l Bethesda, Maryland regarding the subject as noted above. A list of attendees is provided in Enclosure 1. Prior to the August 3,1984 n:eeting Region II had received allegations that certain paint inside containment at NA-1 was non-nuclear qualified. VEPC0
- comenced an investigation into the allegation and on Friday, July 27, 1984, Region II notified NRR that VEPC0 had confirmed the existence of non-qualified paint on the surface of the lower ring ventilation ducting inside the NA-1 containment. The surface area affected was approximately 8100 square feet.
The ventilation ring in the lower level of containment consists of galvanized surfaces. Although these galvanized surfaces are designed to withstand a ' containment environment, infrequent boric acid solution had impinged on these galvanized surfaces and caused minor corrosion. To prevent further corrosion on the lower ring duct, VEPCO, as a preventive measure, had the ducts painted during December 1982 and January 1983. j In response to the allegation, VEPCO, in mid-Sumer 1984, checked the NA-1 Protective Coating Surface Preparation Records and detemined that the coatings applied to the lower ring duct were: ( I '!) An alkyd primer Mobil Chromax Red Primer, No.13-R-50, and (2) A catalyzed polyamide epoxy finish, Dupont Corlar Dual Build Epoxy Enamel, No. 823-Y-67632 with Activator No. VG-Y-8g i Page / of 6
2-Upon further investigation, VEPC0 determined the Mobil Alkyd Primer was non-nuclear qualified and, although the Dupont epoxy (finish coat) was nuclear qualif ted, neither primer nor topcoat were approved for use on galvanized surfaces. As noted previously, the affected area was approximately 8,100 square feet of ductwork and supports which had been coated with the above noted primer and finish coats. The average dry film thickness of the coating is 5 to 6 mils. Based on the above, Region II requested NRR assistance since paint expertise rested on the NRR staff. On Wednesday, August 1, 1984, VEPCO requested a l meeting for Friday, August 3, 1984 with the appropriate NRR staff in Bethesda, 1 Maryland, in order to discuss these matters. In addition, upon the identification of non-qualified paint at NA-1, VEPC0 l inrneciately proceeded to scrutinize the NA-2 Protective Coating Surface ' Preparation Records. These records indicated conflicting reports as to specific ! applications of primer and finish coats of paint applied to the NA.2 lower ring ventilation ducts. VEPCO, therefore, determined to shut down NA-2 until such time that conflicting paint records could be unraveled. Shutdown of NA-2 comenced at approximately 18:00 hours. Thursday, August 2,1984 It is noted that NA.1 was in a refueling outage and scheduled for restart August 12, 1984 Upon discovery of the non-qualified paint, VEPC0 initiated test programs to evaluate the perfonnance of the applied coating under Design Basis Accident (DBA) conditions and to verify the coating materials used. Test coupons were selected 4 from representative samples of ductwork and sent to the Oak Ridge National Laboratory (ORNL) for DBA testing. VEPC0 specified that the test and procedures to Le und at ORNL would be in confonnance with the NA-182 Updated Final Safety i Analysir Teport (UFSAR) as specified in Appendix 3D, " Testing of Protective-Coatings Under Design Basis Accident Conditions". In addition, VEPC0 initiated chemical analyses to be perfomed by KTA-Tator to verify the generic type of l coatings applied to the ductwork. Discussion On Friday, August 3,1984, VEPCO presented its meeting agenda to the staff to be followed and discussed during the meeting. A copy is provided as Enclosure 2. NRR requested Region II attendance could not be met due to existing ~ Region II manpower requirements, l VEPC0 stated that it is necessary that protective coatings within Containment
- remain intact on applied surfaces following postulated Loss of Coolant Accident
, (LOCA) environmental conditions. VEPCO further stated that the NRC approved NA-142 FSAR specifies that coatings applied after initial construction must meet the technical performance requirements for simulated DBA testing set forth in the American Nuclear Safety Institute (ANSI) standard N101.2-72. VEPC0 went on to say that, since the coating system utilized at NA-1 on the lower ring ventilation ducts had not been nuclear qualified, corrective action was required by VEPCO. ! EXHlBIT (3) ! Page 2 at 6 Pages
l 1
\
l VEPC0 had evaluated various options for implementing corrective actions. These options are: , (1) Install new ductwork which would impact the NA-1 restart , schedule of August 12,1984 by 3 months and represent signif- ) icant cost expenditures and shutdown time. ' (2) Remove the non-qualified paint from the ductwork and supports i by chipping and abrasive tools which would cause a non-suitable environment for NRC required electrical work underway to meet NUREG-0737, " Post TMI Requirements". (3) Install a stainless steel wire mesh screen over the affected surfaces of the ductwork and supports in NA-1 containment to retain any coating material which could potentially cause blockage of the containment sump screens. l Because of the above noted impacts and associated problems noted in items (1) and (2) above, VEPC0 had decided to take corrective action specified in item (3) above. VEPC0 stated a stainless steel wire mesh screen would be installed over all affected surfaces of the coated ductwork and supports. The installed screer, would be a 8x8 mesh per linear inch and fabricated from Type 304 stainless steel. The width of the screen opening would be 0.097 inch, which is smaller than the opening of the fine mesh sump screen (0.120 inches). Sheet metal ribs would be installed approximately every four linear feet of ductwork and the 1nesh screen then riveted to the metal ribs. In addition, a seismic analysis Would be performed to ensure that the ductwork and supports with tlie increased weight would be within the envelope of design criteria. VEPC0 then provided its bases for ensuring that the proposed corrective actions for non-qualified paint would not result in say impact on the operation of safety required equipment required to mitigate the consequences of a DBA. Assuming that the non-qualified paint coating releases from the galvanized substrate following a 08A, the wire mesh surrounding the ductwork would entrap a significant portion.of the paint. In addition, the entrapment of the paint particles on the mesh screen would build up on the screen as a function of time and, thereby, allow only an increasing preferential small size of paint particles to pass through the screen. Also, a large portion of the lower ring ductwork is not located in the area of containment sump and water on the floor in these areas flows to the sump at a low velocity following a postulated LOCA. A large portion of the paint particles which might escape the wire mesh , screen would settle out or become entrapped elsewhere before reaching the fine i mesh screen on the containment recirc pumps. Finally, any paint particles , reaching the containment sump would be of a !maller size than the pump screen l mesh and could be circulated through the recirc-system. EXHIBIT (3) Page 3 of /5 Pages) i
)
~
i I 1 VEPC0 then provided the staff with an update on the status of paint conditions at NA-2. VEPCO stated that its decision to shutdown NA-2 the previous day was due to the uncertainty and validity of paint records which might verify paint qualification on the NA-2 lower ring ventilation ducting. This ducting had , been painted in April and May 1983 to mitigate corrosive effects as in the case for NA-1. VEPC0 stated that the NA-2 Protective Coating Surface Preparation l l Records indicated that the following coatings were applied over the galvanized l surface, j (1) Prirrer: Keeler and Long White Epoxy primer 6548 (2) Finish: Keeler and Long White Epoxy Finish 6548. VEPC0 stated that at this time the above identified primer and finish coats
- present a coating system which is nuclear qualified over carbon steel surfaces.
However, disparities in paint records could not provide 100 percent assurance that I the identified coatings were in place on the affected ring duct surface area. l Therefore, test coupons had been prepared and expedited to ORNL for DBA testing l as in the case for NA-1. Finally, VEPCO stated that paint procedures and records will be reviewed and revised to provide stricter quality control for verifying qualified paint inside containment is properly applied and nuclear qualified. Conclusions The NRC staff recessed to consider VEPCO's proposals.and determined the following, which was presented to VEPCO. (1) The results of particle-dynamic calculations of particle inter-actions and granular flow have shown that gracing of small size fines can in certain cases collect on surfaces with openings of l greater size than the particle fines in question. The staff suggested the licensee assure therrselves that such interaction would not take place. (2) The staff finds VEPCO's cor'rective action.(as discussed above) to be acceptable for NA-1. Should final analysis confirm similar l problems for NA-2 ring duct ventilation paint, the proposed corrective measures are also acceptable for NA-2. (3) VEPC0's corrective measures are acceptable on a short term and long ters basis providing the results of the Comanches Peak Task Force (non-qualified paint) identify no new generic concerns. (4) The staff also reconmends that VEPCO upgrade quality control for qualified paint records inside containment and the procedures for application of surfaces inside containment. . EXHIBIT (3) Page # ni /f Pages
- - - - - - - -- - - _. ._- .. l _ _ _ _ _ _ _ _ _ _ _ . _ ___
- S-Subsequent Events Related To Meeting Summary The meeting was adjourned at approximately 2:00 pm, Friday, August 3,1984, wherewith NRR called Region II at approximately 2:30 pm and stated the staff's conclusions as stated above. Region II inoicated the staff's finding, regarding the licensee's corrective action to be acceptable to Region II. ,
On Tuesday, August 7,1984, VEPCO informed NRR that preliminary tests conducted i by ORNL had confirmed degredation of both' NA-182 paint samples under simulated ' 08A conditions. In the case of NA-1, a significant 75-80% of sample surface I was observed to be blistered. For NA-2, a 10-20% flaking was observed in a failure adhesion test. ORNL testing is not scheduled to be completed until approximately September 1,1984 Therefore, the corrective measures identified above will be implemented at both NA-182. The corrective measures will be completed at NA-1 prior to restart, now scheduled for August 23, 1984 NA-2 was officially placed in its refueling outage on August 9,1984 and the corrective measures will be completeo prior to restart (not yet officially established). f' ' e \ m .-. Leon B. Engle, r< ject Manager
- Operating React Branch #3 Division of Licensing
Enclosures:
As stated I a 1 EXHlBIT (3) Page 5 of 6 Pages
ENCLOSURE 1 List of Attendees for Meeting With VEPC0 S.". August 3, 1984 Subject of Meeting: Non-Qualified Paint Inside Containment g VEPC0 V. Benarcya J. M. Anderson S. P. Chan R. M. Berryman L. 8. Engle M. L. Bowling J. S. duo J. O. Eastwood D. Sells A. D. Fraley F. Witt R. B. Green R. Hardwick 1 EXHIBIT (3) . Page 6 nt_&__.Pages
a a + - ENCLOSURE 2 AGENDA 1 INTRODUCTION M. L. 80WLING DISCUSSION OF C0ATINGS APPLIED R. M. 8ERRYMAN DISCUSSION OF CORAECTIVE ACTION R. M. BERRYMAN TO 8E TAITM e 4 9 O EXHIBIT (3) Page 'T of /i Pages
m l ATTENDEES M. L. 8OWLING A. D. FRALEY R. HARDWICK R. M. BERRYMAN R. 8. GREEN J. M. ANDERSON J. O. EASTWOOO 4 EXHIBIT (3) Page lot /5 Paget
POTENT!hL UNQUALIFIED C0ATING CONTAI.~ nr AIR tuuLING MU PUR61m SYSTEM NORIM MMA UNIT NO.1 i
- Ventilation ring duct in the lower level of containment was coated in i December,1982 and January,1983 to mitigate corrosion. !
I
- Protective Coating Surface Preparation Records indicate that the coatings applied were:
(1) An alkyd primer. Mobil Chromax Red Primer, No.13-R-50 (2) A catalyzed polyamide epoxy finish, Dupont Corlar Qual Build teny Enarel . No. 421 v.s7su wteh Ar,4wnene . No. VG-Y-8339 . e The Mobil Alkyd Primer is not nuclear cualified. The Dupont epoxy is i nuclear qualified but neither primer or topcoat is approved for use over galvanized surfaces. ' e Approximately 8,140 ft.2 of ductwork and supports have been coated. ! Average dry film thickness of the coating is agproximately 5-6 mils. I i i l i r l i e l l l EXHIBIT (3) Page 9 of /8 Pages!
.-s-. . - --,- - - - - - ~ ~ , . . . - - . _ . - _ - - - - - - - - - - . , - r. - . . - - ~ ,,..,...r
CORRECTIVE ACTION UNIT RO. I e It is necessary that protective coatings within Containment remain intact following a postulated LOCA. e UFSAR states that coatings applied af ter fnitial construction must meet the technical performance requirements for simulated 06A testing set forth in ANSI N101.2-72. e Since the coating system utilized has not been nuclear qualified, correc-tive action will be taken. e The_ corrective action will be to install a stainless steel wire mesh screen over the coated surfaces of the ductwork and supports in Unit No.1 Containment to retain any coating material which could potentially cause blockage of the sump screens. e i l
' EXHIBIT (3)
Face /4 of tf_. Pages
..1
~
DESCRIPTION OF PROTECTIVE COVERING SYSTEM Unir No. 1 l l l l
- A stainless steel wire mesh screen will be installed over all surfaces of the coated ductwork and supports.
e $creen to be installed will be 8 X 8 mesh per linear inch fabricated from Type 304 stainless steel. The width of the opening is 0.097 inch.
- The maximum width of the opening is smaller than the ~ opening in the fine mesh sump screen (0.120 inch).
e Sheet metal ribs will be installed around the ductwork and the wire mesh screen will be riveted to the metal ribs. .
- A seism'ic analysis will be perfomed to ensure that the ductwork and supports will meet design criteria with the increased weight.
i 4 e EXHIBIT (3) Page Hd /5 Pages
5AFETY EVALUATION UNIT NU. I e Assuming that the unqualified coating releases from the substrate following a postulated LOCA. it is unlikely that paint would pass through the wire mesh surrounding the ductwork. e Any paint particles that might pass through the protective screen would be of a size that would pass through the sump screens. e A large portion of the ductwork is not in the vicinity of the containment sump and water on the floor in these areas flows to the sump at 4 low velocity following the postulated LOCA. .
- Paint particles which may escape the wire mesh screen. that do not settle out or become entrapped elsewhere will pass through the fine mesh screens on the pump suction and be circulated through the system.
- Therefore, there will be no impact on the operation of safety related equipment required to mitigate the consequences of the accident.
I i l EXHIBIT (3) Page /2. og /i p,g,,
. l UNQUALIFIED COATIM TEST PROCEDURE UNIT 50. 1 > e Test programs were initiated to evaluate the performance of the applied coating under DBA conditions and to verify the coating inaterial used.
e Test coupons were selected from representative samples of the ductwork and sent to ORNL for DBA testing. The test procedure to be used will be as specified in Appendix 30 of the UFSAR. e Chemical analyses will be perforsned by KTA-Tator to verify the generic type of coatings applied to the ductwork. I I a I l EXHIBIT (3) Page /3 of d g
PROTECTIVE C0ATING APPLIED TO CONTA! 6 5YSTEM RUMIM NWUL UNH NO. Z
. Ventilation duct in lower level of Unit No. 2 containment was coated in April and May,1983.
s Protective Coating Surface Preparation Records indicate that the following coctings were applied over the galvanized substrate: (1) Primer: Keeler and Long White Epoxy Primer 6548 (2) Finish: Keeler and Long White Epoxy Finish 6543
- Coating system applied is nuclear qualified over carbon steel surfaces.
- Test coupons have been prepared and sent to ORNL for 08A testing.
e i 4 l f e EXHIBIT page _ i+(3) a is y I
MEETING 5UmARY Ol5TRIBUTION Licensee: Virginia Electric and Power Company (VEPCO)
- Copies also sent to those people on service (cc) list for subject plant (s).
Docket File MAC POR
.L POR 0R8#3 Rdg OR8f3 Sumary File JRMiller PMKreutzer Project Manager DELD ELJordan JMTaylor ACAS-10 NRC Participants EXHIBIT (3)
Page 'S af '6 Pages
i
- RESULTS OF INTERVIEW WITH FLOYD RAY ASKEW ON OCTOBER 10, 1984 AS PREPARED BY INVESTIGATOR ROBERT H. BURCH f
i 4 ' On October 10, 1984, Floyd Ray ASKEW was interviewed at his residence by
! NRC Investigator Robert H. Burch. ASKEW advised that hq.. resides at
} . He
! said he is currently self employed as a painter and advised he previously t worked as a painter with Fruin-Colnen (FC) at the North Anna Power Station
! (NAPS) from approximately June 1982 to March 1983 and again from June to December 1983.
ASKEW said that he was assigned to the " sand house" during his employment with FC where he mixed, batched and labelled coating materials in accor-dance with the requirements of North Anna Specification 1016 (NAS-1016). g He said he was supervised during this period of time by NAPS employee l Robert BAULER and FC employee Marvin LANG. ASKEW advised that he was ' l directly involved with the mixing, batching and/or labelling process for the coating materials used on the ventilation ring ductwork coating project during December 1982 and January 1983. He said that his supervisor ~: Robert BAULER told him to send Debevoise Dereka No. 505 Red Primer from the
" sand house" to Unit I containment as the primer or first coating for the ventilation ring duckwork and to use Dupont White Epoxy as the top or finish coating. ASKEW advised that he has not seen the Quality Control (OC) records associated with this project but he emphasized that, at the direction of BAULER, Dereka No. 505 and not Mobil Chromox 13-R-50 was used as the primer. ASKEW further advised that BAULER instructed him to " send all primer paint to the Unit I containment building" for the ventilation ring ductwork coating project in unmarked buckets, apparently so no one would know what type of paint was being used. He said that this practice violated the NAPS coating procedures regarding container labelling, .;
however, since BAULER was the supervisor he did not dispute his instructions. ASKEW also advised that from his experience as a painter he " was aware that Dereka No. 505 and Dupont Corlar Epoxy were not compatible : but said he did not voice this cor.cern to BAULER. ASKEW said he also knew I from experience that galvanized steel should not be coated but again stated
' he did not express any objections regarding this matter to BAULER. He advised that the NAPS coating procedures require OC inspectors to verify
' the mixing, batching and labelling process, however, at no time while ,
', preparing coating materials for the Unit I ventilation ring ductwork did j any QC inspector perform these required tasks. ASKEW advised that the Unit 2 ventilation ring ductwork was coated during the period in mid 1983 when he was not employed by FC at the NAPS. He stated that he did not participate in the Unit 2 project since he was not employed at the site. l At the conclusion of the interview ASKEW provided the investigator with the , manufacturers label from a can of Dereka No. 505 coating material which, ! l i i i l i
- EXHIBIT (.O - - !
! Pe p -- I d S Pagesl
! I I
l 1 l l according to ASKEW, is identical to the labels which were affixed to the l containers of the primer coating used on the Unit 1 ventilation ring ductwork. This Results of Interview was prepared by Investigator Robert H. Burch on October 10, 1984. Robert H. Burch, Investigator i ' EXHIBIT (6) Ps;e '2. n, o~. p,,,, 2 1.
' STATEMENT PLACE: N rth Anna Power Station DATE/ TIME: 9-2o-84/10:45 y, George Henry Hunley , do hereby make the folTowing voluntary statement to Robert H. Burch who has identified himself to me as an Investigator with the United States Nuclear Regulatory Comission. I do hereby make this voluntary statement without any threats having been made against me or any promises extended to me. I reside at .
I have worked at the nortr. An .a l'o ~er Station (UAFS), :*.ineral, Virgir.ia since 1974. I worked with Stone and
.lebster fron 1974 to 1979 during construction and I work.d with (FC)
V;PCG frcn 5/80 to 6/81 and with Fruin-Colnon/fron 6/81 te 5/83 when I was laid off. I cane back to FC in 6/84, where I an pres.ntly em-ployed. I have always worked as a painter at adJS, at nost of the buildings on the site. I work cut of the Painters Aocal 1018 in Rich-
.cnd, VA. and /. busir.eiz as.ent c:r.vinced ne t: return tu FC in 6/de.
I had experier.:ei some very undesirable situa icr.: with Rebort EA :.:i when I was previously workir.g fer FC but I f und that BAv-c.s had been ter-ir.at;d curir.g the ti .e I had been on layoff. SAUL. <, wa a very strange perscn ar.d he insistad that ever/tning be done nis way. To get teis way, he threatened paii.ters with layoffs and sir. e ne controlled th FC painters we all did as r.e .toald say. GM
- n about 1c/6c I was
. .P.'<HIBIT (d) , PAGE / of 5
-3 ' ^f b Pages
a :igned to a crew of FC pair. tors to coat the ventilation ductwork in the unit one containnent building (dCl). 3A M n made tr.e work assignn:nts and supervised this project. he told us there was a big onM r rush to got the job done and he pushed us constantlho complete this s job. I did not select the pain; material to be used on this project but when I learned the type of primer to be used I explain.d to , 3AULiR that it was not cc=patible with the top coat that 4.ad been RCl selected. To my recollection, the primer used on this/ project was a Devoise 505 Dark hed snanel and the top coat was a Dupont Corlar white epoxy. 3AULEd tolc. me that the two coating materials were conpatible because he had checked with the manufacturer and had been 6No assured that the two were compatible. I did es# question him as to
*hel enn ?lb v;hether the4 ccating naterialomonser approved for a containment environ-Gpp and'N &M' me dhe ownufne due fa d i l a 1.
.ent4 I knew that the surft:e to be coated was galve.nized steel and was aware that the horth Ar.na Specification 1016 (nAd 1016) on coat-ing in cor.tainment did not recommend coatini; a galvanized surface but
&MM Qau/er.14 tsms obre/y auere o/ afNr.
I did not .enti:r. This to JEE88ldre I was assi. ned mainly to the inner
~
do rir.g ductwork in ..' l ir.1 p1rticipated in the entire prc: ss fror sur-face prepara:icr. :: t:p cr fic. sh contir. . Ir. y opinior. t... surface preparati r. .as ver3 carelessly and hurriedly conducted. At first we scraped, sar.ded and washed the top, outer side and botton cf the ver.t du : work but thi.s proved to be a slow,ti e c :.su.ing pr ::ss so the ordsr was given by 3A -:... to jus wipe d:wr. tr.ese surfa:;s with a GMP ~
@ cloth da .pened .zi;;. :1. ir.r. e r . -..e re ca; cr.17 a r.ir.ir.ur c.f str.;ir.;
and scrapin. ar.i tr.e re _ .c ri.f.in_ .. i . a erir. der as sta:ed in ens
- c.e c r: :ec t_ve Oc1 i:..
~
cfe:e F.mi'rati:n .e: Ords for t..e primer c:a;. de nostly .viped d. : fr: . the surfaces of the ver.tilation duct-l G w:r:. and scraped off any crystallir.e deposit f boric acid corrosion l 1 l that had accunulated in vario;s places. There was some light sanding l E'<HlBlT D* ' d (6) VPages I2Ge E of S
of tnese spots bu . nc hin6 of the magnit'ude tr.at is represe.ted' by Sks the Protective Coatinc records. Mr. 3;rch has asked agr me to review 6M these records fo he primer coating and top coating in RCl and point est out any discrepancies in these records that I may so note. Ir eviewinc these records it appears tha't hAUn a has written most or tne infor-6 M A W er osal nation 6n the forms. I also note the signatures of M ets,QC ., Inspectors 3ill harris or Bill Burns on these five records. This in-dicates to ne that both BAUuda and the inspectors have apprcved of all the infor ation on the records, that it is true and correct, and that the work of coatin; the ventilation ductwork in RC1 was accemplised in the mann-r represented by the form. The first discrepancy I note in all cf thes= forms is 5F # 10 surface preparation, obtained by 6rinc.er. According te aA31:16 an SP510 surface can be obtained only by near hi e sandblastine, a practice prohibited in containment. Also, if galv=.nized steel cas blasted, it would disfigure and possibly destroy 49 the .at: rial. de were working in respirators during this prcjects and
;rir.d ir.e or t_?stici as indicated aculd have created sericus contam-6?A n/A0 ir ation pr:1_ ens . A: 5F,45dfsurface aar not a:nieved and cr.ly a slicht
. . _ - sandpaper ar.cun: c f g r i r.d i r.- . is done. I als; r.ote that the profil- r. umber of Gan 1.C cr 1 5 is in err:r as this profil .annot be achieved with sanding.
GPM 11:0 note :.a: tr.e s=nopaper texture on the primer Fr:t-0tive Con ir.g rec:rds states a mediur paper was ured. '.ediur paper is it the range cf 100-120 grade and I recall that we used 40, 60 and oO grade paper. GMA Pr.wer a d & cool ., Ine, records also s;5.:e that f:r fir.nl cleanir.g,,,custins an: vacuunin6 cas perf:rnec ar.: as recall these pro:edares were never done. I also GJA frime, nc.e t~.1: c thear,re:Ord; stste a .:ctil Chro'.ax primer ne 13-R-50 was used and tr.is is nc c:rrect. As I st=ted above a 505 dark red primer eMM nw was used, hay Askew, an FC rainter who works with me told aw;he would swear under oath :nat the priner used was 505 because ha nixed this G/M i naterial at the sar.d h:use and sent i.+y.g,wn do to ACl in unmarked con-
"'" BIT,(6) ,Qf Fage 3 of 5
i tainers. ile said bAOL.1 teld hi , to dc inis. aitn re6 arc tc the ::obil Chronax pri:.er reflected on the trotective Coati:.6 reccrcs, I have not i seen any of this type priner at ..Ab sir.ce they built tna p;.a n t . As stated above, the signatures of Ba ler and narris or burns on these for~:s ir.dicates they have ap;.reved the records for a :uracy and co .pletun*ss of infor .ation , contained tnerein, as well as certifying that the work was done as 1;.dicated. Inis is not the case since I know tnere are deficiencies in these records an' that s or.2 of the information is not correct. To ne this represents a falsification of records an:. _4 n T.y opinion Sauler and harris or Burns did t. ., s kr.owing that th2 infernation was not correct. As I st ted above I was involved
.catly On ::.c i:.ns r rint s as 1. ._er asri;.ned his frie:.d: c.. the outer OH ..
rad creas. Durin6 the tine ring and a.1; ,ron t.n e h l._.s. ;;.r.:ec on .. .. vs t h :i.. :.:crk, I never sa.. any .0 i..spectors in t:.is area. In
.y epi...:n, the surface prep ar.d ;J records were pre;ar d'by 3a..ler in the pain; shop and .lere sigr.ed there by him, ha.ris 1:.d 3arns.
..";.ile a.:;"; ic.; the priner ani :: : c: :: I ncver observ.d a 40 ir.spect:r
, , . - ,._ p ._ ..,. , , ., e ... c _, .,
. _4
..._ :. e_._ _
. . . _ . = ,
.. _ . . . . . 2., e .
. . . . ._ . . b o .'-
. ..a
..c o.c . r e ~. .~.~ ' .=. - _= . . .- . . . = _ . ~ r-
. .- .-'~e-_=-.....c
- ~
w e .r c.
; . _ , c . a ,
.c.=..a.
_. _..t. .... .. c.._,..__.c o.
- m. e. _. .. .e _
.c r . . v.m. a- hela
&&... --Coa lM .
.. -e 2-4.:recedure, ho. lever, .vn ._e
- :: tir._ %1 .. cu.:.i.rk . do not reca__ ..crectors perforting this function. I do not k..:w why ins;ecti:n were not r.ade but I sus set that they 3 ot I:gs :.er with Bauler and ock his w rd that the work was done.
~
%. s .....
/ s e
pa=*""
~~,
y e#
/
EXHIBIT (6)g g Page y of g gg
The paint rs were always rushed to co.pleto coatin6 the v.:.t duc twork in rtC1 by Bauler. I did no participate in the coating of TtC2 ductwork but I understand there were also problens associated with thnt project. In my opinion, VEPCO relied too much on Bauler regardinc paintin6 ; natters. His supervisors di; son nobles anc Johnny Jones w.re not ss# A . 4 1t ses aof coatirq; procedures and they delecated all of this 4to Bauler. Bauler, in my opinion was not suited en i to supervise. In ny opinion, VrFCu has tried to blane t.4 painters for i SMH Canb4 l the,probl.ns associated witn dCl and 2 vent ductworks but we only , followed tha orders of Baaler. e@ I have read the foregoing statement consisting of [ kr.dc'ttr/ typed pages. I have made and initialed any necessary corrections. I swear that the foregoing statement is true and correct. Signed on f/24/8Y at 2 O N.M-SIGNATURE: M /d NAME # g' # Subscribed and sworn to before me this day of YmNr 1984 at $$S finerel $re?Wa . INVESTIGATOR: _ NAME / WITNESS: NAME/ TITLE EXHIBIT (6) PAGE 8 0F 8 Page 5 nd Pages
RESULTS OF INTERVIEW WITH MARVIN NASH LANG ON SEPTEMBER 12, 1984 AS PREPARED BY INVESTIGATOR ROBERT H. BURCH LANG was interviewed at the office of the Senior Resident Inspector, Virginia Electric and Power Company (VEPCO), North Anna Power Station (NAPS), Mineral, Virginia on September 12, 1984. He advised he has worked at NAPS since July 1976; first as an employee with Stone and Webster until July 1981 and currently as a General Foreman with Fruin-Colnon Inc. (FC). He said he supervises the daily activities of the contract painters supplied by FC, a personnel service company at the NAPS site. LANG advised that the FC paint work is assigned, directed and managed by a VEPCO Construction Department Supervisor. He identified the VEPCO supervisor of painters in 1982 and 1983 as Robert BAULER, who has been terminated from the company for approximately nine months. LANG described BAULER as an overbearing individual who had a "know it all" attitude. He said 8AULER was antagonistic towards the contract painters and he l frequently harassed and intimidated them by threatening to terminate their , employment. LANG recalled that about November 1982 he first discussed coating the Air Cooling and Purging System (ACPS) ventilation ductwork in 4 the NAPS Unit 1 Reactor Containment Building (RC1). He said that on this 4 occasion Joe HARPER, VEPCO Construction Superintendent asked him, Ron STILES, Construction Coordinator and Jim RUSSELL, Construction Super-visor to review boric acid damage to the ACPS ventilation ductwork in the RC1 building. He said HARPER instructed them to review the damaged ductwork and make a recomendation to either (1) coat the ductwork or (2) replace the ductwork. LANG advised RUSSELL expressed the opinion that the ductwork could be coated. He said he concurred with RUSSELL's opinion so STILES informed HARPER of this recomendation. LANG said the Maintenance Report (MR) had been prepared and submitted on June 3, 1982 by STILES. He said the Request for Work was not prepared and signed by the VEPC0 Maintenance Department until December 13, 1982, a delay of approxi-
- mately six months. LANG stated that although he was not privileged to VEPCO conversations regarding the reason for the delay he assumed it was related to having a convenient plant outage to complete the coating prcject. LANG reviewed both the MR and Request for Work pertaining to RC1.
He noted that the Request for Work form contained a block entitled "QA Approval" which was marked "no." LANG advised he did not know who checked this block in the manner indicated and stated that there should have been
. "0A Approval" for this project." He noted that the MR fonn contained a block entitled " Safety Related" which was also marked "no." LANG advised that he did not know who had completed this section of the MR and said he was not qualified to make this type of decision.
LANG advised that he and VEPCO Supervisor Robert BAULER experienced personality and philosophical differences prior to the beginning of the ventilation ductwork coating project in RC1. He said for this reason he was excluded by BAULER from the paint crews working in the RC1 building during surface preparation and primer coating of the ductwork. He stated i he participated in the topcoat application in the RC1 building. LANG said ! he knew that the ventilation ductwork was constructed of galvanized steel and assumed that the VEPCO construction and engineering personnel had EXHIBITof (1) 3g Page I i
conducted the necessary engineering and safety reviews and had authorized use of the selected coating materials over a galvanized surface. He said . he was not familiar with the contents of North Anna Specification (NAS) 1016 at the time the ventilation ductwork was coated in the Unit 1 and 2 containments. He said the painters relied upon VEPC0 supervisors in the construction and engineering departments to direct all coating activities, including surface preparation and the selection of materials, in accordance i with NAFS coating procedures. He said he did not realize at the time coatings were applied that neither the NAPS engineering nor the construc-tion departments had conducted an evaluation of this activity and that the painters followed the directions and instructions of NAPS Construction Department Supervisor BAULER. LANG said that VEPC0 appeared to blame the painters for using improper coating in Unit I and for coating galvanized surfaces in Units 1 and 2. He said VEPC0 is currently writing new coating procedures and specifications which will be more compatible with an operating plant and the painters who were dismissed in mid 1984 are being i reinstated when they requalify in accordance with the revised procedures. LANG said the new procedures are designed to more closely control coating activities in a containment environment. He opined that the reasons non-nuclear qualified coatings were painted onto a galvanized surface are failure by engineering and construction departments to perform a review and evaluation of the project; failure by the Quality Assurance Department to properly perform their duties and failure of all departments to coordinate their responsibilities regarding this project. LANG advised that he is not aware of any willful or deliberate attempt to violate procedures and said he does not personally know of any false QC records associated with the , ventilation ring ductwork coatings in Units I and 2. LANG did state that ! some of the Protective Coating Surface Preparation Records for the ductwork l in Unit I contain the notation "SP#10" in the " Surface to Be Obtained" block and the notation " grinder" in the " Method of Surface Prep" block. LANG explained that according to the NAS-1016 coating procedure, a SP#10 surface can only be achieved by near white sand blasting, a practice prohibited in a containment environment. He said a grinder was not used to prepare the entire ventilation ductwork surface although it could have been used to remove boric acid corrosion build up from the affected areas. LANG , advised that the entire surface of the ventilation ductwork was not prepared in the manner indicated by the Protective Coating Surface Prepara- ' tion Records. He said painters George HUNLEY, Ray ASKEW and possibly , others who participated in the ductwork surface preparation in Unit I containment could coment regarding this aspect of the coating process. LANG advised that he was extensively involved with the coating activities regarding the Unit 2 containment ventilation ductwork. He said he tele-phonically contacted a Mr. CANFIELD, salesman for Keeler and Long, Inc. (K&L), manufacturer of the coatings used on the ductwork in Unit 2 contain-ment to determine if they (coatings) were compatible with a galvanized steel surface. He said CANFIELD informed him that both the primer and finish coats were nuclear qualified and compatible with this type of surface, providing the surface is ~ properly prepared. LANG concluded that he did not question the application of the K&L coatings with any VEPCO officials after learning from CANFIELD that the coatings being used were compatible with a galvanized surface when properly prepared. D'HIBIT (7) ~ 2 Page 1_of J p g,, i --- -- --
This Results of Interview with Marvin Nash LANG was prepared by Investigator Robert H. Burch on September 13 and 14,1984 71.3/ Robert H. Burch. Investigator I 4 1 f.XHIBIT (7) Pode 3 af J Pages 3
l l l l RESULTS OF INTERVIEW WITH WILSON CAREY NOBLES ON l OCTOBER 18, 1984 AS PREPARED BY INVESTIGATOR i ROBERT H. BURCH l l l On October 18, 1984 Wilson Carey NOBLES, Senior Staff Engineer, Virginia Electric and Power Company (VEPCO), Bath County Pumped Storage Facility, Warm Springs, VA 24484, Telephone Number ..... was interviewed in his office by MRC Investigator Robert H. Burch. NOBLES advised he has been i employed by VEPCO since June 1969 and said he was assigned to the North Anna Power Station (NAPS) as an Engineer in the Construction Department from October 1980 to May 1983. NOBLES stated that one of his responsibilities at NAPS during the period from July 1981 to December 1982 was the procurement of contract craf t personnel utilized at NAPS. He advised that the craft labor contract was 4 administered by - Fruin-Colnon. Inc. (FC), a personnel service company connonly referred to as a " body" shop. He said that in about 1981 VEPCO cancelled planned construction on additional generating units at NAPS and , some of the limited term and full time VEPCO employees involved with work on the cancelled units were transferred to the two operating units. He i
. stated that one of the individuals so transferred and converted to a full
' time VEPC0 employee was Robert N. BAULER, a former FC union painter and limited term VEPC0 employee. NOBLES stated that because of BAULER's experience in the coatings discipline he was assigned as the NAPS , Construction Department Coating Supervisor, a first level supervisor, in i i charge of all safety and non-safety related coating projects. NOBLES advised that BAULER was responsible for selecting and purchasing the correct coatings for particular specified projects, maintaining receipt, accountability and traceability records, preparing and maintaining coating Quality Control (OC) records in coordination with inspectors and interfac-ing with the NAPS site Quality Assurance department on all matters concerning the quality control process involved in coating activities. . NOBLES advised that he supervised BAULER but acknowledged that day to day decisions concerning coating projects were delegateo to BAULER with minimal interference. ! NOBLES stated that he recalled the coating project associated with the !
- Unit 1 Air Cooling and Purging System (ventilation ring ductwork) during December 1982 and January 1983. He stated that the NAPS Operations Depart-
' ment had previously reported, as a result of a walkdown inspection, advanced boric acid corrosion on certain portions of the inner ventilation ring ductwork and they had referred this problem to the NAPS. Station - Maintenance Department for resolution. He stated that he, Johnny JONES, then the Construction Department Superintendent and BAULER discussed coating the ventilation ring ductwork as a " temporary fix" until such time as the affected portions of the ductwork could be permanently replaced. HOBLES advised that at the time of this discussion, possibly in November 1982, he, JONES and BAULER were aware that the ventilation ring ductwork i was constructed of galvanized steel. He said he was also aware, from past personal experiences, that galvanized steel should not be coated. NOBLES
- advised that he was not aware that coating the galvanized steel ventilation ring ductwork violated NAPS Procedure NAS 1016, which governs coating in a containment environment, nor was he aware of the safety impli'ations of I
EXHIBIT. 9 Pese ' w 4 h
..__..._,,,,__,_.,m. _ , , . _ _ _ _ , , _ - _ , , _ , _ _ _ _ _ , _ . , . _ , _ _ - . _ . - . . . _ , , _ _ _ , _ - , _ _ , . . , _ _ , . -
l f
- paint peeling from the ductwork during a Design Basis Accident (DBA).
NOBLES said he mentioned to JONES the fact that paint did not adhere well ! to galvanized steel, however this was not mentioned to him from an objectionable, dissenting viewpoint but rather as a matter of general i conversation. He said the final decision to coat the ventilation ring ductwork was made by the NAPS Maintenance Department. He said that to the best of his knowledge, JONES informed NAPS Maintenance management officials , that it was unacceptable to coat galvanized steel with any type of coating.
,. He said that JONES apparently was not aware of any safety implications concerning the coating of the ventilation ring ductwork in Unit I since he (JONES) had the ultimate responsibility of accounting for the work performed on this system. He described JONES as an extremely safety conscious individual and said he would not have allowed the ventilation ring ductwork to be coated, knowing it to be safety related without an engineering evaluation. NOBLES was unable to explain why no safety evaluation was performed regarding this coating activity.
N0BLES stated that inasmuch as BAULER was the Construction Department ] Coating Supervisor he was responsible for selecting the proper coating materials for all projects. He said BAULER selected the materials, both
- primer and topcoating, that was used to coat the Unit I ventilation ring ductwork in December 1982 and January 1983. NOBLES advised that BAULER was supposed to have contacted the manufacturer of the coating material selected to ensure that it was nuclear qualified for use in a containment environment. He said he did not know which coating materials had been selected by BAULER or if he had in fact contacted the manufacturer regarding their qualification for use in a containment environment.
NOBLES denied that undue pressure had been exerted upon members of the paint craft to complete the coating project during the Unit 1 plant outage l in late 1982 and early 1983. He said the only pressure applied by super-vision was the constant and frequent reminder to all craft personnel that all work, including painting, should be completed during the scheduled outage so the plant could begin operating as planned. He said he did.not consider his actions in this respect to be other than the norval super-visory encouragement which is present in all outage situations. He l explained that all work must be accomplished within a particular window of l time and that this concept requires constant and close monitoring of craft
- activities to ensure that all schedules are completed. NOBLES sta nd he is
! unaware of any VEPCO construction manager conducting himself in any manner other than he has described. He stated that the painters were basically an i unhappy and malecntent group and they were beset with internal management problems and complained of supervisory discrimination. NOBLES stited he began to recognize that BAULER was not using sound management practices about December 1982. He said he began to receive complaints about the manner in which BAULER managed and supervised the painters and stated he also learned that BAULER was " making deals" with the union hall steward to retain'his (BAULER's) re!atives on the job at the NAPS, in favor of other l painters. NOBLES said this represented a conflict of interest since in - effect a VEPCO supervisor was orchestrating and influencing the employment practices of the painters union and the contract service company. He stated that as a result of these and other similar activities BAULER fell into " general disfavor" with other NAPS construction department ; supervisors. NOBLES explained that BAULER subsequently suffered a l EXHl81T.9 l . 2 p.,, 2 ,, a p.,,,
disabling back injury at NAPS which required medical attention and lost days from work. He stated unequivocally that he has never forced or coerced BAULER into working while he had a back injury to prevent NAPS from i having " lost days" due to accidents by VEPC0 employees. t i L
- N08LES explained that the Protective Coating Surface Preparation Records,
! the QC documents for the Unit I ventilation ring ductwork, were also the i responsibility of Coating Supervisor BAULER. . 'He said BAULER always
- prepared these records even though the QC inspectors were supposed to
! personally verify all data entered on these forms by BAULER. He stated he is not personally aware of the manner in which the QC inspectors verified
- BAULER's data on the forms, however, in his. opinion their (QC inspectors) signature on the form certifies they had accurately and personally verified all data thereon.
I N0BLES advised that in his opinion, no one at NAPS' realized or was aware l that coating procedures were being violated when the. Unit 1 ventilation t ring ductwork was coated. He explained-that since BAULER was delegated respcnsibilities to ensure that. procedures were followed and the proper coating material were , utilized,a none of the management officials in the { Maintenance, Construction. Engineering or Operations- Departments. became { involved with this activity. NOBLES further stated that he is not aware : ! that BAULER and the QC inspectors collaborated to falsifying the QC records i associated with the Unit I ventilation ring ductwork coating project. He j said he always assumed that the QC department had performed independent-4 inspections and/or verifications rather than merely accepting the data provided by BAULER. NOBLES reiterated that the signature 'of the OC inspector on the Protective Coating Surface Preparation Records indicates that the inspector has in fact independently verified the data reflected on the form. NOBLES advised that he was unable to coment regarding tre contents of the QC records associated with the Unit 1 ventilation ring ] ductwork coating project since BAULER was responsible for completing these , docurents as a part of the total project. NOBLES repeated that when he directed BAULER to supervise and coordinate the L' nit I ventilation ring ductwork coating project, he (NOBLES) never
. considered that the paint could peel from the galvanized steel surfaces in
! a DBA or loss of Coolant Accident and subsequently clog the filters and screens in the containment sump pumps. He stated he now recognizes the j safety significance involved but did not at the time the work was accom-l , plished. N0BLES reiterated that he is unaware of any ' NAPS management i officials.who deliberately violated plant coating or safety procedures when , I the coating activities were performed on the Unit 1 ductwork. He also '
. stated he is unaware that any of these officials knew the coating materials i selected for this project were not nuclear qualified. '
j NCBLES emphatically denied any intentions or knowledge of wrong doing. i regarding the Unit 1 ventilation ring ductwork coating project. He l reiterated that this project should have been initiated under a Desigr, i Change Package which would have required an engineering evaluation. He again stated he did not know why this was not done but said this was not J his responsibility. He said if he had recognized safety implications regarding this project he would have taken appropriate measures to have a l 3 EXHlBIT 9 Page 3d # Pages
i safety evaluation completed. NOBLES said he did not participate in the planning or performance of coating activities regarding the Unit 2 ventilation ring ductwork in April 1983. This Results of Interview with Wilson Carey NOBLES was prepared by l Investigator Robert H. Burch on October 22, 1984 f/ Robert H. Burch, Investigator i 1 l t I i a b I t EXHIBIT. 9 4 Pese-*a l g 5
RESULTS OF INTERVIEW WITH JOHN MICHAEL JONES, SR. ON DECEMBER 8, 1984 AS PREPARED BY INVESTIGATOR. ROBERT H. BURCH i On December 8,1984, John Michael JONES, Sr., Project Manager, Power Cutting Incorporated, Lake Bluff, IL, was interviewed at his residence by NRC Investigator Robert H. Burch. JONES advised he resides at
. He said he was employed by Virginia Electric and Power Company (VEPCO) at the North Anna Power Station (NAPS), Mineral, VA from March 1977 to March 1984. He said he served as the Construction Superintendent from November 1980 to May 1983.
JONES stated he recalled the ventilation ring ductwork coating projects in Units 1 and 2 during December 1982 and April 1983, respectively. He said that the Unit 1 project was planned during the fall of 1982. JONES
! explained that the NAPS Maintenance Department, acting upon a request from the Operations Department, sought advice regarding boric acid corrosion on
- the top surfaces of the ventilation ring ductwork in Unit 1. He said a
; Maintenance Recuest (MR) was initiated by the Maintenance Department to ! mitigate the corrosion problem. JONES advised that he did not know why an MR rather than a Design Change Package (DCP), was used to initiate these projects. He stated that a DCP initiated project requires the engineering ! department to evaluate and analyze the request for safety implications.
JONES advised that, to his knowledge, all coating requests at NAPS had been previously initiated by an MR rather than a DCP and possibly through l " habit" the ventilation ring ductwork coating projects were initiated by the Maintenance Department under MR's rather than a DCP's. He advised that - j he vaguely recalled some corporate engineering involvement in these project coating but could not recall specifics of this involvement or the identity
; of the engineer. JONES continued that Robert BAULER, the Construction
' Department Coatings Supervisor was delegated the responsibility to inter- ' face with NAPS Maintenance Department officials regarding this project and i to coordinate and supervise the completion.of the jobs within the time ! frame allotted. I j - JONES stated he held preliminary discussions with BAULER regarding the i ventilation ring ductwork coating pro # cts. He said he discussed the j selection of the primer coating with BAULER to ensure that the material selected would adhere to the surface of the galvanized ventilation ring ductwork. He advised that initially it was decided to coat only the l portions of the ventilation ring ductwork tha,t was actually affected by the boric acid corrosion. He said there were two areas of the Unit I system which were severely deteriorated and these areas were coated first. He said as the painters moved over the surface of the ventilation ring ! ductwork, they found other areas of deterioration. He advised that the ; i Maintenance Department, upon being notified of these additional areas of deterioration, decided to coat the entire ventilation ring ductwork. JONES i reiterated that he delegated the' responsibility for accomplishing this project to BAULER, which included the actual selection of materials, surface preparation and the utilization and supervision of craft painters. He advised that he did not recall the identity of the primer or top coatings and he did not observe the actual accomplishment of this project by the painters. He said BAULER kept him apprised regarding the progress EXHI8li /o 9aee 4 ** Faean
of the work. JONES advised that, in his opinion, BAULER was knowledgeable of coating procedure NAS-1016 and was instructed by him to accomplish the work in accordance with the requirements of this procedure. He stated he did not interfere with BAULER during the time he was involved with the Unit i ventilation ring ductwork coating project. 1 J0NES advised that he did not learn of problems associated with these i coating projects until approximately July or August 1984 when a friend contacted him. He said he did not know that non-nuclear qualified coating materials were utilized on this project and nor was he aware that the Protective Coating Surface Preparation Records (PCSPR's) contained inaccurate and discrepant infomation. He said the PCSPR is a Construction Department document and is completed by the supervisor of the project. JONES reviewed the PCSPR's associated with the ventilation ring ductwork coating projects in Units 1 and 2 Containment and advised that the writing style appears to be that of BAULER. He said NAPS Quality Control (QC) Inspectors are supposed to independently verify the data entered on the PCSPR by BAULER and attest to its accuracy by signing and dating the fom. JONES emphasized that he relied heavily upon BAULER regarding the ventila-tion ring ductwork coating project in Unit I and at the time he (BAULER) appeared to do a good job. JONES advised that he was not involved in the Unit 2 ventilation ring ductwork coating project inasmuch as he was not the Construction Superintendent when this project was accomplished. JONES concluded unequivocally that he was not aware of any procedural violations regarding the Unit 1 project until July or August 1984. He categorically denied that he directed or instructed BAULER or anyone else to violate coating procedures or to place incorrect and discrepant infomation on the PCSPR's associated with this project. He further stated that he knows of no VEPCO/ NAPS employee who intentionally violated the coating procedures or placed false information in the QC records. This Results of Interview was prepared by NRC Investigator Robert H. Burch on December 10, 1984 and on January 11, 1985. i & Robert H. Eurch, Investigator 1 l EXHlBIT /0 2 Pase 2_ d 2. Pages
k 1 RESULTS OF INTERVIEW WITH ALBERT DEMORE FRALEY ON OCTOBER 10, 1984 AS PREPARED BY INVESTIGATOR ROBERT H. BURCH l I On October 10, 1984 Albert DeMore FRALEY was interviewed at the North Anna l Power Station (NAPS) site by NRC Investigator Robert H. Burch. He advised ! he resides at He said he has been employed by Virginia Eie'c'tric and Power Company (VEPCO) at the NAPS for approximately 21/2 years and has served as the Project Manager (Construction) since December 1982. i l FRALEY advised that the Construction Department performs all of the maintenance tasks for NAPS, including Engineering work requests which are l t initiated by Design Change Package (DCP) and Construction work requests which are initiated by Maintenance Reports (MR). He said DCP initiated work pertains to safety related items and requires an engineering evaluation, whereas MR initiated work is non-safety related and does not j require an engineering evaluation. FRALEY advised that the NAPS Unit 1 ventilation ring ductwork coating project was initiated by a MR and funding was approved for the work about June 1982. He said the actual work did not begin until about December 1982 to coincide with a scheduled outage of the unit. FRALEY recalled prelimi-nary discussions in the fall of 1982 regarding coating of the ventilation ring ductwork with various NAPS personnel in the operations and maintenance departments and with his staff members John JONES, Wilson NOBLES and Robert BAULER. He advised that the reason for coating the ventilation ring ductwork was to mitigate corrosion caused from boric acid leaking onto the top surfaces. FRALEY advised that NAPS management, through initiation of a MR and approval of funding, directed the Construction Department to evaluate and alleviate the problem by coating or painting the affected surfaces. FRALEY opined that since the coating of the ventilation ring i ductwork was cosmetic in nature and due to the relative inexperience and ! lack of knowledge regarding the coatings process, this project was viewed by NAPS management as a non-safety related activity. FRALEY advised he delegated to JONES, the responsibility of implementing the Unit I coating project. He said JONES placed BAULER in charge of the actual work process, including the selection of coating materials, surface preparation activities and utilization of the contract painters provided by labor contractor Fruin-Colnon (FC). He said BAULER was directed to implement this work process in accordance with North Anna Specification (NAS) 1016 requirements. FRALEY said he was satisfied that both JONES and BAULER were knowledgeable of the contents of NAS-1016 and that they were aware process.of the significance of this procedure as it relates to the coatings He said that he was not personally involved in the actual perfor-mance of the Unit i ventilation ring ductwork coating project and was unaware of any problems associated with this matter until the NRC notified VEPCO in July 1984. FRALEY advised that upon learning from the NRC in July 1981 that a non-nuclear qualified coating material had been used to coat a galvanized steel surface he reviewed the Protective Coating Surface Preparation EXHIBIT.// l ' d # Pase Phess i 9
-n- - - y , mm.---,--- --.---.._,-,-.-_.--rw - - - - . , - -
, , , , . - - - _ - - - - - , . - , . . - - - - - . - - - - - , , .,,-m-,. .,,e-,mw--,.- - - - - - . _ , _ . -
Records (PCSPR) associated with both the Unit I and Unit 2 ventilation ring I ductwork coating projects. He advised that the Unit 2 project was initiated in the identical manner as Unit I and was completed about May 1983. FRALEY advised that upon reviewing the PCSPR's for. Unit 1 in about August 1984 he inanediately recognized that there were inaccuracies and incorrect data contained therein. He explained that the discrepancies he noted on these records relate to such items as the manner in which the surface was prepared; the actual primer coating used and other activities associated with the coating process. He said the PCSPR's indicated the surface of the ventilation ring ductwork was prepared by sandblasting, an activity prohibited in a containment environment and that Mobil , l Chromox 13-R-50 primer was used, an item not in the coating materials inventory for Units 1 and 2. FRALEY advised that he is currently in the process of researching documentation relating to the Units 1 and 2 ventilation ring ductwork coating projects and that a fomal report will be prepared for NAPS management regarding this effort. FRALEY blamed BAULER for preparing and initiating false PCSPR's and stated JONES should have noted these incorrect items of data during his review of the documentation. FRALEY advised that the inaccuracies and discrepancies contained in the PCSPR's indicate a total disregard for NAS-1016 require-ments. He opined that BAULER, and perhaps JONES, were both aware that NAS-1016 requirements were being . violated when the coating projects in Units 1 and 2 were being performed and that BAULER apparently ignored these requirements for the sake of completing the job expeditiously. FRALEY stated BAULER never consulted him regarding the coating materials used on the ventilation ring ductwork in Units 1 and 2. He said BAULER was never instructed by him to call Keeler and Long regarding materials used during these projects. FRALEY stated that, in his opinion, there are several reasons why non-nuclear qualified coating materials were used to paint the ventilation ring ductwork in the Unit I containmert building. He said that the failure of NAPS management to initiate the wed under a DCP precluded an evaluation by the engineering department. He saic that supervisory inexperience in the coating discipline and the lack of a quality control inspector at NAPS - with coatings knowledge, qualifications and certification were also factors. FRALEY advised he was nct personally knowledgeable that procedures had been violated and that non-nuclear qualified coating materials had been used until the incident was reported by the NRC in July 1984. He said, to his knowledge, no other NAPS or Construction Department management personnel besides. BAULER, and possibly JONES, were aware of procedural violations regarding the ventilation ring ductwork coating project in Units 1 and 2 containment building. FRALEY advised that BAULER was subsequently dismissed from VEPCO and a VEPC0 corporate management decision was made not to interview him regarding his involvement in and knowledge of the ventilation ring ductwork coating projects. FRALEY categorically and vehemently denied any VEPCO/ NAPS management collusion or conspiracy to violate coating procedures or to falsify quality control records regarding the Units 1 and 2 ventilation ring ductwork coating projects. 1 Pages
f I
; This Results of Interview was prepared by Investigator Robert H. Burch on
- October 12, 1984 b
j Robert H. Burch, Investigator l l e 6 l l
.i l
i f I I 4 j EXHIBIT.// l . . 3 Page 3 af 3 Pages . l
l 4 RESULTS OF INTERVIEW WITH JOSEPH RALPH HARPER ON i DECEMBER 6, 1984 AS PREPARED BY INVESTIGATOR ROBERT H. BURCH On December 6,1984 Joseph Ralph HARPER was interviewed at the North Anna i [ Power Station (NAPS) site on December 6,1984 by NRC Investigator Robert H. Burch. He advised that he resides at -
' ~
He said he has been employedbytheVirginiaElectricandPowerlom/any(VEPCO)attheNAPSin the maintenance program since June 1970 and he currently serves as the j Superintendent of Maintenance. HARPER advised that about the fall of 1982 the NAPS Maintenance Department was requested by the Operations Department to evaluate and repair boric i acid corrosion on the top surfaces of the ventilation ring ductwork in j Unit I containment building. He stated he consulted with Construction Department Supervisor Robert BAULER and contract paint supervisor Marvin LANG, who suggested that the ductwork be painted to mitigate the effects of the boric acid. HARPER stated he informed BAULER that the 4 ductwork was constructed of galvanized steel, whereupon BAULER told him that he still recomended painting the affected surfaces. He said that both BAULER and LANG were knowledgeable of North Anna Specifications (NAS) l 1016 which governs all coating activities in a containment environment. HARPER. advised that the recommendation to coat the ventilation ring ductwork in Unit I was first suggested by BAULER. He said he concurred l .
- with the recommendation because he assumed that BAULER was the Construction
' Department coating expert and was aware of all implications of NAS-1016, i ' When asked why no safety evaluation was performed regarding the Unit 1 ventilation ring ductwork coating project he stated that, to his kr.owledge, a safety evaluation had never before been conducted on a coating project at i'
the NAFS facility. He aisc stated that he was not cognizant of the safety implications regarding paint peeling when he concurred with BAULER's reconenendation to coat the ventilation ring.ductwork. HARPER advised that once the coating project was funded and approved by the maintenance depart-ment and referred to the ccnstruction department for implementation he was not further involved in the process. He advised that BAULER was also the j i responsible construction supervisor for the ventilation ring ductwork l' coating project perfomed in the Unit 2 containment building. HARPER said i
' he was not involved in the unit 2 project, except to approve the work request and funding and to prepare necessary documentation. ,
; This Results of Interview was prepared by Investigator Robert H. Burch on December 6 and 10, 1984.
t , Robert H.'Burch, Investigator ! i I EXHIBIT 4 I l Paee I 'L W ;
- 4 !
l
RESULTS OF INTERVIEW WITH ALFRED QUINTON PARKER ON SEPTEMBER 13, 1984 AS PREPARED BY INVESTIGATOR ROBERT H. BURCH l On September 13, 1984 Alfred Quinton PARKER, Construction Supervisor, Engineering Projects Group, at Virginia Electric and Power Company's (VEPCO) North Anna Power Station (NAPS), was interviewed at pe site by NRC Investicator Robert H. Burch. PARKER advised he resides at VEPCO at NAPS since April 1977. PARKER said he is responsible for managing the capital budget on NAPS capital projects and serves as the interface between Engineering and Construction at the site. He said he recalled a conversation about the sunner of 1982 with NAPS Construction Department officials Albert FRALEY, Johnny JONES, Bob BAULER and then Station Manager Bob CARTWRIGHT regarding a ventilation ring ductwork corrosion problem in the Unit 1 Containment . Building. PARKER advised that during the discussion three alternatives 4 were presented to mitigate boric acid corrosion on the top surfaces of the ventilation systems. He identified these alternatives as, (1) replacing the deteriorated surfaces of the ductwork, (2) regalvanizing these surfaces, or
- i (3) coating the entire ductwork. He said BAULER suggested the coating alternative which was subsequently concurred with by others present.
PARKER advised that the Engineering Projects Group relied upon the recommendation of the Construction Department (BAULER), assuming that they had researched applicable regulations and procedures in sufficient detail; that any required evaluations and/or safety implications had been identified and that the Quality Assurance Department had " blessed" this method of correcting the corrosion problem. PARKER advised he approved the
" Request For Work" fem initiated by Ronald STILES and forwarded it to the Construction Departcent with a fund accountability number (1499999160) which obligated funding for the Unit I ventilation ring ductwork coating project. A copy of the corpleted " Request For Work" form for the Unit I coating project provided by the NAPS Licensing Coordinator Stephen B.
EISENHART was reviewed by PARKER during the interview. The "QA Approval"
- section of the form, containing the words "yes" and "no" reflects "no" was
! , checked. PARKER advised that this section of the form notifies Cuality Assurance (QA) they will be involved in the project when it comences.
, PARKER said that he checked "no" but that the form should have been checked "yes" since it was intended to be QA involvement in the project.
PARKER could not explain why he checked the "no" space of the form. PARKER
- then reviewed the " Request For Work" form, approving funds to coat the ventilation ring ductwork in Unit 2 (number 1499999240). He noted that the
! "yes" space was checked on this form, indicating that QA was notified of
- their involvement in this project. PARKER explained that regardless of whether these forms are checked "no" or "yes" the construction department 1
is responsible for accomplishing the actual work in accordance with the
- requirements of coating procedures NAS-1016 (Construction) and QCI 11.1 l
(Cuality Control). PARKER advised that he does not recall any discussions regarding the safety implications involved in coating the Units 1 and 2 E7.HIBIT./3 Pase 'd - 1 Pases
ventilation ring ductwork but he said he did recall conversations pertaining to the completion of these projects during the scheduled outages of each unit. PARKER opined that the problems associated with these projects are the result of Robert BAULER's failure to follow requirements of NAS-1016 and the apparent lack of emphasis regarding the importance of coating processes. PARKER also alluded to failure of the various NAPS departments, including Construction. Operations, Maintenance Engineering and QA to adequately comunicate, coordinate and interface with each other and the incorrect assumptions by each department that another department had performed all the required research, evaluation and analysis. He said that NAPS procedures in existence at that time were not sufficiently detailed and process. clear to identify responsibilities as they relate to the coating PARKER advised that, in his opinion, there were no willful intentions to violate procedures and/or to falsify records by any NAPS employee regarding the coating projects. He said that, to his knowledge, responsible VEPCO/ NAPS officials were unaware of any coating problems regarding the ventilation ring ductwork in Units 1 and 2 until the NRC identified them in about July 1984. This Results of Interview was prepared by NRC Investigator Robert H. Burch on January 11, 1985. M Robert H. Burch, Investigator EXHIBIT. /3 2 Pese O E N
-.re. ., -
L i I RESULTS OF INTERVIEW WITH MARTIN LUTHER BOWLING, JR. ON SEPTEMBER 12 AND OCTOBER 10, 1984 AS PREPARED BY j INVESTIGATOR ROBERT H. BURCH i i l I On September 12 and October 10, 1984, Martin Luther B0WLING, Jr., Assistant Plant Manager was interviewed in his office at the North Anna Power Station (NAPS) site by NRC Investigator Robert H. Burch. 80WLING advised that he i resides at He said he has been i ' employed by Virginia Electric and Power Company (VEPCO) since June 1975 and i advised he has been assigned in his present position at NAPS performing
- safety related and licensing duties since June 1984, i
i 80WLING' advised that when the ventilation ring ductwork coating projects were performed in Units 1 and 2, he was an engineer in the Engineering and . ! Construction Department at the VEPCO Corporate headquarters. He said he ' did not recall any participation in these projects when they were accom- ; plished in December 1982 and April 1983, respectively. He advised he was i not personally involved in the performance of either coating project; ' however, since about July 1984 when the NRC notified VEPC0 of discrepancies j regarding these activities he has attempted to determine the circumstances which caused these problems. BOWLING explained that maintenance requests from the NAPS Maintenance Department are initiated either by a Design i Change Package'(DCP) document or by a Maintenance Report (MR). He said the j DCP is utilized when a request requires.an engineering evaluation and the work to be accomplished is analyzed for health and/or safety implications, i
' He said the MR is utilized for work of a non-safety related nature, j
although safety related processes and procedures are observed to accomplish the particolar task. B0WLING advised that, basically, the difference { between the two processes is the safety analysis performed when the DCP is utilized. He stated that the Maintenance Department is responsible for initiating either the DCP or the MR and that a determination of safety 4 implications involved in a particular project is first made by management i officials in this department. ; l B0h".ING advised he was assigned to resolve the NRC concern that non-nuclear i i
~ qualified coating materials were used to coat the ventilation ring ductwork
! in L' nits 1 and 2 and/or that a galvanized steel surface was improperly prepared and coated. He said he did not pursue procedural violations since } it was already apparent that NAPS coating procedures NAS-1016 and QCI 11.1 l had not been observed. BOWLING advised that VEPCO was primarily concerned with " fixing" the coating problems so that the units could return to
/ service.
BOWLING advised that, to his knowledge, no VEPC0/ NAPS management officials were aware that coating procedures had been violated until notified of this i by the NRC in July 1984. He explained that NAPS would probably "still not i ' be aware" of these ventilation ring ductwork coating discrepancies if the t NRC had not brought these to the attention of VEPCO. l BOWLING advised that, based upon his inquiries, the two key NAPS personnel j involved in the Units 1 and 2 ventilation ring ductwork coating projects are former Construction Superintendent John JONES and former Coating Supervisor Robert BAULER. i He advised that his review of the Protective j EXHI8IT /V i case ' s2._ e e. ! 5 _._.-_-_--,-m _ _ - - _ - - - - - - _ _ _ . -
Coating Surface Preparation Records (PCSPR), the Quality Control (QC) records, associated with these coating projects contain false and discrepant infonnation. He said that BAULER was responsible for preparing these records and that a QC inspector is required to concur with data thereon through an independent verification. BOWLING advised that the principal items of incorrect data on the PCSPR's relate to the manner of surface preparation and the identity of primer coating utilized on the ventilation ring ductwork in Unit 1. BOWLING advised that VEPC0/ NAPS has not initiated any actions to correct this false information contained in the PCSPR's because they (VEPC0 officials) considered " fixing" the problem more significant than amending the records. BOWLING concluded that he has not been made aware that any NAPS officials deliberately violated coatings procedures or that they falsified QC records. He opined that he does not believe any supervisor above Robert BAULER had knowledge that coating procedures were violated or that QC records contained false information. This Results of Interview was prepared by NRC Investigator Robert H. Burch on December 17, 1984 and January 10, 1985. 7.4 Robert H. Burch. Investigator EXHIBIT /V 2 p.,, > og & poses
?t
l l D STATEMENT l PLACE: DATE/ TIME: /e/J//f- / I'#"'
'/
I, Meary I- d o 9, M.
. do hereby make the ~following voluntar; statement to fah,/ N' 2aev4 who has identified himself to me as an Investigator with the United States Nuclear Regulatory Commission. I do hereby make this voluntary statement without any threats having t.een made against me or any promises extended to me. y /efe /c of
% dm sicds,/ of hje oxo/ larsy, Dei NC ' i+ r' C}
/??on brtr/ oh},) or/ 6eday MdbWcb /kie/$oe, cih/y & ieds s/ oayl,[,./,
kt- rcl f G/ W /tk Obb kklme Co//J ,[ mif/h hd /&licts' th /db 7'f/Z QAd' s2- A7' W M /.S rom shush of (/Eftei /Zt O G r n ] wer S$$d*- 8 ud el r/pkMed' hal /kele CAWf 4)hl -b f fWtb dbtl bke b kb Vf,1 000$ /710kr,*s/J, lb}r***/P l?Ad' h Y eno)4 ed f a,yeth (/7hW oss' 21 f) EXHIBIT /$ PAGE / of f Page / of *f peg,,
/ L2. /fdebr Onta '
nm/sb f/7t/itsnmsa OAc/ syf>- O. Go/pon, zed f6// SCrhee. Spee, ' Scot 4 /7/r A,c4
/ , /
No/cisu/ -/Aa b 8Ae
&r/b Erm f/f9do in /a le /9/Z.
, / .
oxofet, f ntio' /ff3 teaW /isot dun & L]ns/ net 4 #~ i i / spor lntish J/frfonns/ ob -d%c /frz.O 0/14 Ntsf/r I Sb4firh OA d $e cd/kV /1/st/t/ /10ef- Ofte/ a/n6 w/ae /?id,/ Chuau ied7,isver id./3-r-so oa
/ /
_))per/ 0r/ce Ave / $uiKl [b/y 6As"n'. dti/Y 6. QglWn,'2td
. . / l .
l
' 4 fee / Ar/ ice /ren4'/sfin, i-;u olefwa) int,/e
~ o/ -De
/
L / / f/ sis'f l bAbdin/71/k JV?r. htCb O fe/Te / Y df O g 0(hi-(r) n% 08s Nore /tarvowd Ql sed de t/js_ of
/ /
brNr es/ /mf SSyf' rz 7/079;mse ou' E / feries
-/rp coat
/
stry G- Go/aonino' Slee/ 6/sce /aa/ r4 0{cluert< ) in
-/Ae 1 i l ._ 01&ntriinf >l lb , d 2 . //t/ gg, y,y,,/ , f
/
,,y,, }f,,, f
_f hit in quin d' of /71cf .fd~al/ dj -f& lede/ds'r
/ /
, k ore af d en- o ut l m s sete,u d de4&< cx40
/ /
l Jom Ak/A Arura. /4wir f (e b <>, e % e < c /.i /i /c(e
/
M/2 sas' m,o' / c 5 reos,6 1 -dho dw4x13 o/ Ek.
/ / /
1 Wed*blen riit4 ' Otedail ,n -f2e t/s, i' / / 2 6n/cas,inuf-
/
EXHIBIT./f % M Statement Continuation- Page (2) of (5)
ba;/dA4. ~Z- cd /7df Mec// Ok 6As/me O//.c
/
i _
/ l
; //re' m Ont6b S/7a- //wer fede of./cids ,A /c{e /9/Z.
l , ds//w thid /923 W4oroixe ~8e [scNM c/ //O f
/ / / /
HA.4 defwwX- ih (J4;/s / oss' 2 d n biomsof 4/r_
/
deul /k Nerro'r of 6m 6xbck . si /An- h/Adsrrt '
./
ex- an.4n. ' n eor 4% mok4n t/oto ihn /u/
/ /
w:t'h /deAv ost 44 MasroSu 7%e Coeda< f / / / , %nh. /ls 07e en 17 % Neff Mu/S Aed a U0 . / Qw{def(t) //h (K/4'o HGssd(h 797;r spra//tr. Y / ' Z o't-( / / ds~r fdo// /?1saNr /Dd' Nai& /n9eitir1 MGdrdA4 et.
/ .
/ / /
Avredbr/'~~Dndtf M. G i n W /le f 4 set d a m n /ec/
/
07' ir dilcSibl=, sz 4 L d C d ?ze 4 m .r f?dre M (7s' AcW
. / ,
/va be/r 9ec/dco4a.r. T-f u Ast/ km aide /
d { GN^f G. /dtbv eM' / 4 D ia b e b rr 'Dsedeb,
/ / / /
fi/An- b5'/S n- 7// 7 QML 2- / Sn e r ~7 96s/ v <
/DJfr C- Golwns2et/ <ht/ }e kee fed C./ h
/
) f/4l hk4 dc/nAl /d (sw k/o w d T G/o' /97/*Nr/ ! . / . . . t/ /u f4f/ /nx/r/ Asa Ato' Ge o/Ar
/
- l st 'f ua. 2% cre, a.
es/etes .%dee. ' EXHIBIT '6' % t statement continuation- Page (3) of (I) l l
j )pg O/Jo /gst/ g;/4 pq Q,,, ,. g,,, , l
/ -
F[fiekb,{}ssiki4. LtdstafA< Orkeb ka O / 7 / 2 & Q A n t.
/ / /
9sy, ((c/r> tIdaic/>- 0ncnni8 -be [cs,ds.r.r cf
/ /
On,-{ / or/ Z. t//sf 1/A4 t Vce fw n s. ~~fdi:r .fE 41/24n,
/ -
x
/71/. //trnas ~S. 6n&co / tcsi l .t he f.o' nde 4 ,!: rn,
$$.sftr7d Ch lYd2 f~h 0/7Ad. %r koh,'M k he l
/ / /
6xku s/ z% we/ rm ddwt. ~ t con m .
/ /
J ,i G b/?t4t/Wac4//u W /10 dtfe d& Nede ans' (snq AikN:o " l N in /otVM6z n m.e'irfy
.__ 071lOtb -brm f
llffde 0tO br7A AkWes*s/r ,- a cab (.o/>g \ - A
- $eC44 inbNipcden t440r($44 fr8A4 //fxf n44 dt ?oet l in
- / / / / /
/ch / sw 2 an-/s;si>~A ine /4,/6, irts<rs,x x
/ '
/
/
/'er74 h, ar ok ,
h a. -fee /s;e / uswadado< , tuior
/dft/sr snt f. /M41c. rte r;es/ $ -/r/Ss/rne 6dl.f ,
/ '
VE040 {}ptth 0nna. ckfte */> rn tea 1 st- $w! /ff9' ,
/ /
_ 6c 4 callsv - at/ -{Atte As,x4 cdf4mf ikhwefe of.i, 7 , i /)lltff tr % /YM/6&- i f lN t/5&- e s oc 4 i / / _ /
- lo nt/7/s1 /D+;sn- out,e-/ _Ss,,n -Aped ns./
/
(/ , 000/* -d'fr/ .- kk We /A d 0 +1 /C 4 n ss { f/7/4 m /M n f
/ / - -
tain a.
@/wsaid sk/ 6kee. She f/r/ USEs
/
l EXHlBIT./5' O b Pages Statement Continuation- Page (Y) of ( 8) .
W k lek ',rf y dit h h h e x p & lc h r ia l/ A/,W Afb
$,- k 4/c Gj hje o / We r
k fp f f dCs // he Ad/M/J f OY Cd h 6 71 hcf s f fryf lgsg, l
! ,a A &/,s s",4aye as aw/~6- % ~
h ht $ d/'/J h'Vikl *i W6
- h/4.
Mf
! yd<4 I am en /.;,, 4x,/
na uis u,,,, l l'A/~ " /' h M 's air,y- a e4/ wgg,
# ' b*Jt CAA$ h krs pp/p l g ; 01 [f*f [ dry d//c [f is i f lgtt!
uu x % y ./' o ns' HL, 44 pm6'
< a ~ s' ' 4x f7g (/ggg#.jpv f dlMirifW $ eL W a luta w.rer 14 N url $l Acb & tht'~
fa bw L4uf Bue 4,e d/ m' /w dA'ir- fper JuhnN I have read the foregoing statement consisting of handwritten / f[Ah pages. I have made and initialed any necessary corrections. I swear that the foregoing statement is true and correct. Signed on f b ~3" k at 3 0 Fb SIGNATURE: . t NAME' gj h Subscribed and sworn to before me this b day of 8thd* 1984 at INVESTIGATOR: NAME / WITNESS: NAME/ TITLE EXHIBIT. /5' Pese # of # P88 PAGE S OF f
RESULTS OF INTERVIEW WITH NORMAN RODERICK CANFIELD ON DECEMBER 10, 1984 AS PREPARED BY INVESTIGATOR ROBERT H. BURCH On December 10, 1984, Noman Roderick CANFIELD, Coatings Technician and Salesman, r.eeler and Long, Inc., Watertown, CT 06795, wes telephonically interviewed by NRC Investigator Robert H. Burch. CANFIELD edvised that he lives at He stated he is employed by Keeler and Long as a technical expert and salesman and he identified Virginia Electric and Power Company's (VEPCO) North Anna Power Station (NAPS), Mineral, VA as one of his current accounts. CANFIELD advised that his sales contact at NAPS was a VEPCO employee named Robert BAULER. He said he has spoken with BAULER on numerous occasions regarding Keeler and Long products, providing him with both technical and service information. CANFIELD advised that he recalled a conversation with BAULER in late 1982 or early 1983 wherein BAULER solicited advice regarding exterior coating for a section of the turbine building, a galvanized steel structure. He said BAULER purchased a large quantity of Keeler and Long paint for this project, even though he (CANFIELD) recomended that the galvanized surface not be coated. CANFIELD advised that he has known from previous experiences that coating materials do not adhere well to galvanized surfaces no matter how they are prepared or the type of coating used. CANFIELD advised that BAULER has never asked him for any advice or infomation concerning coating materials for the coating of ventilation ring ductwork in the Unit 1 or 2 containment buildings. He said he would have ascertained from BAULER the type of surface to be coated and upon learning it was constructed of galvanized steel inside of the containmeht building would not have recomended either a Keeler and Long product or one of another manufacturer. CANFIELD concluded unequivocally that neither BAULER nor any other person at the NAPS site ever sought advice or infomation from him regarding Keeler and Long coating materials or those of a competitor for use on the ventilation ring ductwork in the Units 1 or , 2 containment buildings. This Results of Interview was prepared by NRC Investigator Robert H. Burch on January 10, 1985. . Robert H. Burch, Investigator EXHIBIT. % - Page t ,d I Pages
RESULTS OF INTERVIEW WITH JAMES ALLEN SMITH ON OCTOBER 9, 1984 AS PREPARED BY INVESTIGATOR ROBERT H. BURCH i On October 9,1984. James Allen SMITH, Quality Control (QC) Supervisor at Virginia Electric and Power Company's (VEPCO) North Anna Power Station ; (NAPS), Mineral, VA, was interviewed at the site by NRC. investigator j Robert H. Burch. SMITH advised that he resides at j He said he has been employed by VEPC0 at NAPS since June 1981 where he currently serves as the Quality Control Supervisor. SMITH advised coating project in that abouthe first learned of the Unit I ventilation ring ductwork l late November 1982 from NAPS QC Inspectors Bill HARRIS contractor inspector.and Bill BURNS and from a Pittsburgh Testing Laboratory He said these three individuals told him that a Maintenance Report (MR) and funding authorization had been issued to the Construction Department to accomplish this work. , SMITH advised that there was a sense of urgency associated with the request since it was being accomplished during a scheduled outage. He said that, to the best of his recollection, some of this ventilation ring ductwork coating project had already been accomplished by the Construction Department when the QC Inspectors were notified of the work request. He said that the coating materials had already been selected; the mixing and batching process had been accomplished; the primer coating had been applied, and possibly some of the top coating had also been applied. He said that inadequate lines of i comunication between the Construction, Maintenance and Quality Assurance Departments is, in his opinion, the reasons the QC inspectors were not notifiedcomenced. until the Unit i ventilation ring ductwork coating project had already SMITH said that this was a violation of existing coating procedures NAS-1016 and QCI 11.1. , He also adviseo that he was net accepted or well liked by officials outside the QA Department and they we e often not supportive of the QC program that he was attempting to initiate at NAPS. SMITH advised that he assigned both BURNS and HARRIS to inspect the
- ventilation ring ductwork coating project in both Units I and 2. He said he did not actively participate in these inspection programs and only became involved in any of the inspection activities if problems developed.
SMITH stated he did not verify any of the inspection activities performed by BURNS and HARRIS on the Units 1 and 2 ventilation ductwork. He said he does not know if they conducted the inspection efforts which are noted by them on the Protective Coating Surface Preparation Records (PCSPR's). He advised that he did not learn of any problems, difficulties or discrep-ancies associated with these two projects until about August 1984 when NAPS employee Quinton PARKER informed him about the NRC discoveries. He said PARKER told him that an anonymous person had alleged that non-nuclear . i qualified Units 1 and 2. coating materials were used on the ventilation ring ductwork in ! SMITH advised that he told BURNS about his conversations with PARKER and then obtained and reviewed copies of the PCSPR's associated with the coating of the ventilation ring ductwork in Units 1 and 2. He said that he then recontacted BURNS with the PCSPR's and questioned him concerning his (BURNS') signatures on these documents. He said BURNS told him that his signatures and dates on the PCSPR's indicate he had verified EXHIBIT 'T Page / of
- Paget
I all entries thereon and that he had perfomed his inspections of the ventilation ring ductwork in accordance with applicable QC procedures. SMITH stated that he furtter reviewed the PCSPR's associated with the Units 1 and 2 ventilation ring ductwork coating projects and, based upon l this review and his conversation with BURNS, noted no discrepancies or i deficiencies in the documentation. He advised that the NAPS Site QA ! Manager, Andrew HOGG, appointed a team of QA personnel to review these i PCSPR's along with existing coating procedures to determine whether the instructions were adequate for coating activities. He said that as a result of HOGG's efforts NAPS procedure QADI 10.13 was developed and implemented.
! He advised that he was not further involved in the Units 1 and 2 ventilation ring ductwork coating matter after about the middle of August 1984.
SMITH emphatically reiterated that both BURNS and HARRIS told him unequivocally they had performed inspection activities associated with the ventilation ring ductwork in Units 1 and 2 in accordance with existing coating procedures and that they had verified all infomation contained on the PCSPR's. He advised that it was subsequently determined that the primer coating used on the ventilation ring ductwork in Unit I was different from that shown on the PCSPR's. He said that this discrepancy casts some doubt upon the integrity of the inspectors and the PCSPR's. SMITH said that although BURNS and HARRIS denied they had violated coating procedures, their inspectionevidence duties.supports the fact that they failed to properly perform SMITH concluded he is not personally aware that NAPS coating procedures and/or QC coating instructions were willfully and intentionally violated during Units 1 and 2 ventilation ring ductwork coating projects. I This Results of Interview was prepared by NRC Investigator Robert H. Burch l en October 17, 1984 and December 17, 1984
' EO/h Robert H. Burch, Investigator t .I i
I l EXHIBIT. / 7 Page d ef 2- pages
STATEMENT . PLACE: N rth Ar.na Pcwer Station DATE/ TIME: 10-11-84/10:15 . 1 g, Willia- Drayton Burns, Jr.
, do hereby make the Y$11owing voluntary statement to Robert H. Burch who has identified himself to me as I an Investigator with the United States Nuclear Regulatory Comission. I do hereby make this voluntary statement without any threats having been made against me or any promises extended to me. I reside at I have worked at Vt FCw's North Anna Power Station (hA?d) 2/lL wat.
as a Quality Control (,C) Inspector since (ABA. Prior tc this I worked with Fi;;sburgh Sesting Lab at m?S and I also wcrked with Daniel Cor.struction Co. at the Surrey site. When I first went to work for VIFCU at nAFS, the QA progran vias fragmented and understaffed. There were two QA/QC groups at OAF 6 then: one in cons;r.;; ion and one en the plant side (Operr ions and .. air. enance). neith:r gr:up cooperate (wc4
..ith One ar.::her ar.d there was a dislike of ,C ty r.e craf;
. . . . . and.4a.s oladd' Sevt. w6t-. ,,
m oto6oc - d . pers:r.ne_. . a .r.:Ing er cea:Ing wasA vle'/.i! as an 1T.s15T.. :. iny*an! af aWJ wa-10 <. prl:rity activity f:r the nest part. The re ues :: ;.rferr pain - ing actici:7 was c enerally initiated en the ,o he plar.t side :r.nsir.:enance Mmed 4 M ud. dwd). wo-g by g d::u .en* g,as the cn inser' c '.g . O rk .Te r,u e s :A St.i s i s C L i ! e differer.: from the Design Jhir.ce F.:'...se. .
.ich is a stru::ured and better crranized docu.'.ent fron the s 2r. reint that a:; p:1r.:e cri.5ria
~
f4dAepoe4ad.wh for ir.sp=::i:ns is spelled outa n the 2 r. inspection activities. :here by on w ec fus parrs w w/ M - c.as to t: a great deal of research and ciscussions 4to id=r.tify 20:e;;an Thi3 w&- criterir. g Ahas a tendency to create adverse feelincs between the J& Smolen inspect:r and nenbers of the craft s the work. I recall that the coating work on the vent ring ductwerk in Unit 1 was initiated on EXHIBIT /8 g PAGE l of IO Page / pf Pages
a Work dequest and the actual coating began in Decer.bar 1962 I was Where snewtjern *b no:gthe rsgular c:atir.gs ir.spector assigned to do ccating ir.spectier.s.
- .:y co-worker, Bill Harris was the regular ir.spector but due to limited resources and because Harris was busy on another prcject, I filled in W o/Jo in tM 2. ws*>.
for him some on the Ur.it 1 vent ring project 4 I remenbar that when I p,y .marre.so- w3L was notified by, Jim S .ith that I would be assisting with inspections Com+rk:adnel6 m w60- aa+z. uArs u on this reject there was a sense of urgency,and g pressure g g applied by maintenance mar. age.ent,to get the job done without delaying restart of the unit. I re e.ber that I received the work request one day and was told that the job must be done i.nediately. When I reviewe the scope of work for the project, it was initially planned that only TMa sa. the irr.er ring and no: :he cutside exh1ust rir.g would be ::sted.g 4e;<e o'n la o #1-
- uS g eliminate boric acid corrosion forming on the inner ring. As I recall' wora: u*g the job came forward on a hequest and not a Design Change w, aci,. w- a 1,,. m w .-a- n Fackage4 This meant that there was no engineering evaluation of this 4
project for safety inplications and there was no evaluation for an actual design change. A: the time I was assigr.ed to inse::t this of the ved ny cfufcork, w& nica sag A l w A g I felt s: .ewhat ur.:cnicr:able in :r.at there was r.:4 er.eir.. rin e , eval-uation. Since the ven ring cu::wcrk :: be ::a:ed ;2s ir. side a contair ment er.vir:nment)I felt and believed :nere sh:.li te ar. =r.gineerir.g roject. I felt so str:ngly at:u this :nat I first evalust: n of this p//aic. a 44,*/ ws*- telephoned ands later visited the p ant engineering offi:: to discuss theyreaf & my concern with an engineer. The ;hene call and meeting with an engi- {yne,c mlreedho') >> fta uPh. neer,took place just before the actual coating work one .i r 1 vent rin e ductwork began. I recall the time as about during the tnird week of 12/62 but prior to the work beginning. I have tried to race..ber which engineer I ta ked with but I have nc: been able to do so. I just do noi y;M /4is Concerts. udA-remember whoe discussed Durin,e the discussion ) m& specifically recall that I expressed concern 3 to g// sisengineer VEKO Nthat coat
=
.q jj I
- f. ' '2-
' OI--24/
--. Pages AAe b o[
was going to take place in e containnent witnout any .ngineering war evaluation and that I believed as an inspe::or lll[ :na work should be acconplished under a Design Change Package where acc.ptance criter.
/3
- gggspelledout. I had, at this time, already done sone r= search re-garding the project and knew some of the specific requirements as spelled out in coating procedures which were effective at the tine, with Two of ::.=se procedures /which I am very familiar are oAd 1016, " Coa-i.
in Containenent" and ,CI 11.1 " Coating Inspections". I had researched these procedures and was aware during my nesting with the engineer in 12/82 that an SP F10 type of surface was required by nad 1016 before the vent ring ductwork could be properly coated. The SP p10 surface i achieved by ne2r white sandblasting which is prohibited in a containn hiber & environment. Also during ny conversation with the engineer, I. express. steel concern that a coating naterial was being placed over a salvanized/su. face, which is the type of metal the ven: ring ductwork is made of. I recall that, after expressing these concerns to the engineer he told : that naintenance work for the aAFS did nc; fc_ low the requirenents cf the d 4-no 1016 specificati:ns and therefere the i. 510 surface was not re-quired. Th= engineer also tcld ne that : .e 2:1 icn (. aintena'nce) wann the werk done before the hatch was clesed f:r restart. I also renenter the engineer tellin e me that the st2:icn :nl canted th= coating on :n Unit 1 ven: ring due: work to last until :ne next outag= and then the e systen wculd be repalced. aith this infor a icn fror _ni i neering I cid not discuss the issue further. I an familiar with the Frotective Cet:-
//IANelsM W $
ing durface Preparation ..ec:rd, which is described in t:.a procedar=
.CI 11.1. This docunan; is :ne QC form whi:h c:ntrols th. coating pr::-
1 fron s:l=ction, mixing, b=. ening, etc., tnr .eh surfac= pre;ar2:icn arj werdercaal. 4% i en to final i.spection of the conpleted llll Althous h this is a 4 f:rl Mie$ der **$ itisnot, filled,3ll[ty;Cnerisacopy5;intainedbysw, ser even thcual
\
EXHIBIT, /8 % Page 4,g 24 Pages A l.oMD '
of ggral $ red /ca$*rs on.W6-the QC inspecter is required to sign 4the form. The *C .sie r.a turce :n r, f:r. certifies r.at the in: se::r .as verified a'.1 o; tr.e d a t a e ' ' ='-,. -! Aded besM, v6- J ,prn!,4z &#--
' q the Csnstructinr ne Prote::ive Coating Surface pre;-
aration records that I have signed regarding the coatings of the vent ring ductwork in Units 1 and 2 in December 1982 and April 1983 were
/k W b filled g 4 and prepared by Robert Bauler, who was the hAPd Construct-ion Department Coating Supervisor at those times. The Protec tive Coating records that I si (typod ownbers 001 sed 002) v&gned for these 2 prcjects are identified as 1rC-1P and.1PC-2P 4 (Unit 1 vent ring, primer coat)
/ fare >$ nstmkS 012,0iS, oI$ et$ et/}>* and
$ 2PC-2P and F.
2PC-3F and 2PC-4P and F,(L' nit 2 vent ring, , prim,'er and finish coats). A copy of these Protective Ccatings records are at cached to and are a part of my statement. rea$trafr. *W us% I M ,that my signature on g :hese/ aAro plant pr::ed res c(, # for s v& is, according to/wCI 11.1 ar.d .m3 1016, a certification that I ainspect schabeson/'er ov PrettM1 4W g the items 11sted h the forms and found them to be in the condition or to have been performed in the manne" indicated. I have reviewed the comcleted for s either s t that I/did not insrec ott * /1: ens as indicated s.1%-- or was aware at the time I signed he re:Ords tha; certain f.n:tions had not beer. per-f:r..ed as indic? ed. I '1 identify ;>.cse ite.9s which I know to be in err:r on the orts ar.d explain a.y :ne. are not correct, even th ugh I signed the for..s ir. dica:ir.g that the infornation herein was verified by .e. negarc;n , e::1ve cating records (rtAds ool+ 002),'ve 1F;-lP and 1PC-2P4 the ,ven ring due: work was no prepared to an SPfl0 surface as indicated. In crder to achieve this type of surface, a near white sandblasting is required and this activity is prohibited in a contain ent. The me: nod of surface preparati:n is indicated as " grinder and a grinder was not used, except possibly on a trial basis or to remove excessive depcsits of corrosion. If a grinder was used to prep the surface as indicated, ther ao.ld have been th- isk of grinding EXHIBIT ja* /B % A g e f. o / l.9 eaa. Pagu
through the galvar.ized surface, plus danger of spreading contanina:i:n, As I have s:::ed, grinding was not used to prepare :ne surfaces of :..e vent ring due: works or.ly sandpaper or wire brushing was used. At the on Jrdto wAt time I signed these ferns I knew that g surface had not and would not be obtained because I had already discussed this with an en61neer. I do not know why I signed the protective coatin6 r:ccrds indicating an SP 510 surface by grinding was achieved. Bauler placed this infor-wgh Z Mneul ps*k mation on the forns ar.d I si6ned j g concurring with him. g that this was no correct. I would like to say that I eitner did not see i this entry or that it was not there when I signe che forms but this I cannot say. I simply do not have a asonable explanation for l my actions. The entr/ under " Final Cleaning", indicating a" vacuum" cleaner was used is ir.::rrect. As I recall there was a vacuum cleaner
, in cor.tain .ent on this occasion but I never saw this equipment used to l DUwh clean the ven:4du::wcrk. I did no: verify that this was done and o not think it was done as indicated, even though Sauler checked that it was used. ?ne data reia_ ding Tenpe.atures, humidity anc dew point were re:Orded by 3a;1er er.: tock :?.ese ;sarings. Ir. sc .e ic. stances I verifie:
u 6h - mateSL-his readir.cs by :se._..e ._ , . . . .u : in, g instances I used the data he obtair.ed and signe d ::.1: I .ad verifi=d his readin3s. A'.- o/Jo u 9 1--- the. ugh I did verif;. s:ne of his rs : c.gs . I, :Ocx nis w:rd for scne of then by jus: signir.g the fer- ir.:._: sting I c.ad p rs .. ally verified the data, dith regard to :ne Lry tilr
.h ic'.ne s s (2:2) naasurenents, I did not perfor . these fur.:tions as rec,uired by ^a 1C16. Ib.is procedure re-quires a .easurenen; every 20 squa.e feet and I did not do this, even though my si3 nature indica:es I fci;c..ed "ac ICic. I did take rande-samples ever the =.rst 2 bout cr.co daily but nc according to the pr:-
ceduro. Cne r asen I did not follo.. pcceedures is b=cause of the tre-
- r no.d d 4 u keA.w n w 5a--
vious c or.versati:n g4.r. e:. :...e.r g tcid me that I did not have 2 EXHIBIT, /B - .
'5'ofjp __
Page 5 ,4 2V PageS
o - . . . . . . m ginspe:: / coating = =.. :1y a : . .cding to 6 . A.: _:_6. A_s:, I h :a_1 that when I first 'a.b c to ' Aid as an ins;=ct:r, I asked if coa:ing inspectors were supposed to witness the .ixinc, batching and creparation
- of coating naterials and I was told by Murrell Eurns, A%4.es To;rm us(Mt) yK%- s no re'.ation,and no longer q pVd CO k .*AF< that we did not have ::
w ta 6 A do so. iven though the protective ,for uni: Cea y race osoot+oa) 1 centain ny sienature indicating I participated in and verified :ns gbc e $ selection, .ixing, batchind^of the coating naterials, I did not do s: wDA of I :::2 :ne <;crd g3ob 3auler that all of this data was corre:- i/n Arms Wah- /srbrmalinA A and I signed g as if I had verified this,to be correct. It was defin-ly a .istake on ny part to do this and I cannot explain ny actions, f.fe 06 ocboilie.1 QM V & excep: to say that coating g generally regarded as a very nundane, crdin ry, lov. profile type activity and little or no significance is attached to ne importance of this function. As to the type of primer used ir Cnit 1 cn the vent rinr du::wcrk, all I can say is that it was a red pri.er. I do not kn:v. the nanufacturer of the coating nor the iiintifica:icn of the priner coating. 'dith regard to the Unit 2
... . . . . c . . : , .s.
. ... .s 2 c . .., . _ :. . 2 ..e y, .he,e .,o __
s i . .....m.
., ... . _ , , o ... o, , ..
(typeris att- ots) 9 6 la':.lled 2? -2P and F, 2F':-JF and 2.20 cP and 3F (Lnit 2 priner and/cr
- < .= _
- e. ~. .. _.: _e ) . . . , ...
_ _.. . .. _4 .: . .._ _ :
. 2._:,__o... r .c .. . ._. . r.4 e .
c oc _ .: : . tha vi:uur blastic.g ::as use: : a:nieve an M #10 surface. Bob 3auler
.~. . ,_ _. . ..:
= ..._: ..
.___4
....c,.. :. on
.w=. .__..a.
... ... . . . =... I s4e nec .=._ inc c. 4._c ..e _: . . a_.
d4sf W A verified this .e:hed of surface preparation and athis type of surface w achiev=d. This is incorrect data since an SP fl0 surface was not achiev and va:uun blasting <as no used. Also certain iter.s of data appearing me W 4%.- elsewhere on these records was not verified by in all instances. This inf or .ation includes tenperatures, hunidity, dry fil- l tr.icknessyselection anc preparation a naterials, =tc. Alt.nougn I di: . r pericr s:ne inspections, I also used data compiled by Construction - l l EXHIBIT. /8 - Aire _.fz. ,/ L Pag, 6 ,4 24 Pages ; l
Sapervisor 3:b 3auler and si6ned the forns indicatir.g I had verified and/or independently obtained this data. Again, I car.. : explain .y actior.s except to state the v 0- och fe.s W6 boet that. coating (at oAra %always been regarded
*b heet.
as very low priority work and gnever been given tn e full attention and inportance it shcaid be given. I acknowled6 e that when I did veri. 3auler's data or condue inspections of the Unit 1 and 2 vent righ duc work, id not cor. duct the indepth and detailed insp=ctions that I sh. knew.shculd have M N b woo-. Z ws%- i:ne. Bob Bauler was aware of, and took advantage of it. I knew better as a professional inspector, yet Iw allowed d- it to happen on these two projects. I now recognize this ollaboration with Construction as a violation of 10 CFR Part 50, Appendix 3, since I did not perforn these inspections in an independer.: nanner. I first realized the seriousness of my actions regarding false and ir.2: curate data on the protective coating records dAe u h J Wy associated with -nits 1 and 2 vent ring ductwork about, late g or early August 1954 ti. .e frane . It was about this time that VEPC0 (aAF5) began Iceking ir.: 0 circunstances involvin ; the Units 1 and 2 e ve r.: ring c:atir.g. I d_s:ussed M0c.Ccyclt 080'NJe with v 6h--ny supervisor Jim Snith my con-cerns about theg ista .r the protective coating records. Da 92-I als: discussed this c:ncern v ith th= site QA :J.anager, Ar.dy Hogg in August 1904 Cw.v.a & A I recall on one occasion b6 fore discussing this4with Hogg that he, g Jim Snith and ne were in a discussion with the hAC resident inspectors about August 21, 1984. On this occasion Hogg defended ne and ny inspecti:ns of the Unit 1 and 2 vent ring coating prcjects. Hogg :cid the anC that if my si nature appeared on 2$ 'E I 6 CD a ,C for. then he was satisfied that I had done the inspection as $ indicated. Gn this occasien I wanted to say, "I:r.Ho6g, I'm sorry but 1 I did not do the inspecti:n _.s indicated by my si nature" but I did 6 a not want to enbarass hir in the treser.ce ofynew& the hnC. saA. Later on after f.3 this conversati:n with the onC, I told Hogg what I have stated in this s 4
,.,w
ga ,[z%e statement, that is, I did not verify, data on the protective coatin6 records as indicated by my signature on the forns. When I told Smith and Hogg about what wet I had done neither one of the- instructed me to clear up the records 74ey M4 deV m w'5% or report this to anyone else.at;(/,;h b
" - - ~ _ ~.W w,mg w rt - n W Ad8fr M A8
~ ~_f-_s,A2/as33#4'*j e g e4 #-n
-_ - + _ -_
eg, - - s- 3 7 g w._ s1h
'X%-_-C Q .9004 4M *@h' M , d Q W & hi9 640' O.
[d"_ _ _"'; _ ggggg M YM **v*f d*W avr 9/br/ N 1 acknowledge that my it.srection efforts on the vent ring ductwork viere either a non-5cis:er.: or superficial. I did .c: c or.s ider ::.. va r.: ri. .es to
.c.ve 2n; safety ra_ :ed si nificance 6 when I worked cn th5se pro-jects. I: r.as been only within the las 2-3 nonths t..at I have cone to realize the safety implications of coating the vent ring due:rork.
.Vith repri to c:her increcticns that I have conducted at 306, I am certified in a nunber of other disciplines, it.cludir.g welding, electri .
cal, 55chinical and c:hers. I have never beforeIm aa UK% UA c{ir, q v 6 - superficial, O w o-gsinspections of these activities. I have never falsified an inspecti:n report or certified data :nat I did not verify in these discipiir.er. I reitrd .yself as a pr:fessional insp:: tor and an also cogr.izant :f the sEfsty related inplicati:ns involvi .6 these other a :ivities. I . '.11 a i .i: that I have been very sup-rficial and lax
- .n c :nn u::_c.;. ::her ::ating inspec; ions but to my kr.2= ledge none of thess .eer safety significant.
\ tk vs% If I had been performing ny job proper-i ly as an inspector onynits 1 and 2 vent ring ductw;rk, I would not have allowed inproper/uncualified ccatings to have b .:n applied and i I would no: nav w **>--- N93 11cwed a .-alvanized surface to be c:ated, even thoush I assumed 3 engineering had approved cf this activity. I allowed myself
- o be taken advantage cf by Bob 3auler, a cor.structi:n supervisor, and i
1 I t I permitted nin to .anipulate ne when I should have been independently verifying c.is data. I also should not have retarded coating as a nun-
/o w P s Ne w O v
dane, insie .ificangactivity but rather should have approached the in-EXHIBIT,/6 pg Page y ,g 72 p.g , 8 ,/.l.2. l
W C-g 6-- spection process en tne vent ring ductwork as seriously as I do the other disciplines. I cannot ex,r_ain why I allowed myself to be manipulated by Bauler or why I basically took his word that all data on the forms was correct. Possibly, due to pressure put on the dead y w/%- craf t and to some extent on me to complete the, jobs. I took short cuts for the sake of savin 6 time. I acknowledge that I violated not only plant procedures QCI 11.1 and nAd 1016 which govern coating activities, but also 10 CFR Fart 50 Appendix B,by nct maintaining bo ita--- an inspection process independent of th= construction effort. WN g WW N s N
'N i
l 1 k EXHIBIT,,/P
,, 2s~p,,es Pese 9.q .7,g
I would like to re-emphasize that, to the best of my knowledge, at no time has any supervisor or co-worker made any effort to cover up any wrong doing on my part which has been set forth in this statement. I would like to say that the NAPS QC Department does not do their inspections in the manner in which the coating inspections on the vent ring duct work was performed. k'e have restructured our organization in such a manner that this situation would never occur again due to internal checks and balances. We also have better interface with other departments which did not exist at the time of the coating projects. W b W F I have read the foregoing statement consisting of lO / typed pages. I have made and initialed any necessary corrections. I swear that the feregoing statemen is true and correct. Signed on h ffat /l N h SIGNAT.RE: /f3 - NAE // j/2f4 Subscribed and sworn to before me this / day of MM 1984 at MM #p/ . INVESTIGATOR:
' ~
NAME WITNESS: NAME/ TITLE PAGE /0 0F j EXHIBIT. /8 - Page /c nf W Pages
~
A/M b
~
PROJECT:
- APPLICATOR'S SUPV k.e [2) g lb F b
_ J. O. N O. I 3 O '$ 6 GENER.'l FIRST REASON F071 PnEPARATION PRIMING SEAL COAT FINISH FINISH COAT TOUCH UP OTHER Y SUBSTRATE BUILD UP g . . DATE: //12 -fL REPORT NUMBER: OO/ 5 MASONR Y SHIFT: /8 b ]
- CONCRETE SURFACE TO BE OBTAINED p/C ANCHOR PATTERN:
SURFACE PREPARATION METHOD OF SURFACE PREP: $//My'2 SPECIFIED: /* I- J WERE WATER AND OIL FILTER.S USED? YES NO N , GROUT FINISH: WERE THEY CHECKED REGULARLY FOR CLEANLINESS? YES NO SANDPAPER TEXTUR WERE THE 'FOLLOWING USED? - - FORM RELE ASE AGENTS: TYPE: I " ' FINAL CLEANING: . CURING / HANDLING COMPOUNDS: huSTED
, TYPE:
hVA GEN, PRIMING SEAL COAT IST FINISH FINISH COAT
~ TOUCH UP OTHER._
PAINTING SUPERVISOR f fonf;L .
, 0C INSPECTOR 2.- -
lu ctu ~
- Y $~aA~?a"5."h". k 6., .!.l S l e U . 2 / U . b Hu 7 M //E N Oef hw/>i ' FAN /R UF-18-JJ oao o ' 76 Co IL W6- Cs t I . 0?$'
ClJMS
- 9$O b'55[W 1-80/'1~-
f --0h;UR^{-h'. b'r 36'} f TM4 ; 3 W$/- Elf $2o-8 f
- N ~ W$1-fft*. U-l~6 $ * * - ' -
, , , . ,. 's,/ 3-{ , GEN. PRIMING SEAL COAT IST FINISH FINISH COAT , TOUCH'UP OTHER__
l DATE:'s '.T- % f M. : f) .jl} - Q A . "% - y '
.s- -
AMBIENT TEMP.A. 14 We a ' f/ -- SUR F ACE. TEMP. 5% ** ':* . fO ' . .o D EW POI NT:". N ' 40 s .*'
- ff 'y ..
RE L. HUMIDITYiNY' #- 4/JO/6 ' f '
**'E DATE: - - ..V -/
f2.-2.3-81 . . r - - i'J . FILM THICKNESS i R E. ADINGS: - -u j'g< . # '.4 :: 4 7 . O 9" _.* NN/A DFTs ' WF Ts ' ;.:. - . O;O DFTs WFTs DF Ts WF Ti 07 - DFTs WF Ts
,0 . O il DF Ts' W OBTAINED: 4 F & 6 ".W -*' $ltf' 3pXf4 j N/A 5 MIN. ' MAX. * ' MIN. . M AX.' MIN l MAX.! MIN." Mr SPECI FI E D: b- 7 ' 'i k W. M dp N/A i . MIN. MAX. M i N.' ' M AX.' M I N. 'M AX. '. MIN l 'M/
' d .> . [ ,-; ,g f.' g %~4 GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHER 3
.",..s
/ ';.i . EXP. DATE EXP. DATE EXP. DATES EXP.DATE Evp D A T ' cxP.DAT
- D. *,.' f . -lh . -
_PA INT: *tl- N .:'.~ ' 't ' '
~~ ~
- -' "~~"
*) A 89D L
~ BATCH NUMBERS r '
. {' K *~ 'hi-. }** .
* .- ;. .'id' ACT:,m > .EXP. DATE EXP. DATE EXP.DATE EXP. DATE EXP.DATE EXP. DAT
, v ',- :. f Q ;, g 3 . + .. . ,, .
. , , - -
- lr, .'. ? . -
REDUCER USED
.3,:
- '[' Mr'f T..
(S% 3 q ( 9 APG * - APG* APG* APG* APG* *
.-~
APG*
-J- /t. J. i' COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR CC
& Nf[$h
~
' COATING APPLIED -
k' '* * * #- *
@B. [R
.- ;,, _ . g.*h @ ; p l h g.
~
COATING EQUIP. y*d '"et : OS-B R C8 OR a R Oe OR a'E TRIAL MISTM S . S OS OS OS
, '.f. - 4f' ]YES* [ YES,3
- DEMONSTRATION ,
~--
s gO'
- NO'
,,,,, YES NO
, [ YES. _*
- YES * -
] YES NO NO s NO ,-
MES
*A $2 ':.k d.
YES YES APPLICATORS QU ALIFI ED"5' ;5'M #I' ' ~ YES YES .' v YES-NO C NO ~ NO __ NO
~
NO' ' * " [ NO - ' PAINT CONTR ACT SUPV.' ( kgtD og , mm ,, _ * ' * ' ' " - *- CONST R SUPV. N . b t_i_ b I""",',% 9 ~C_ .- - O.C.INSP. fy /~ A._ , , W *
'Y
. .- t
.
- AMOUNT PER GALLON B/ BRUSH S/ SPRAY R/ROI.I,
>R OJECT: M
,p ,
.6 . , * .. - *
# s ,:
C
. ** * } ( ,;,.
GENERAL SEAL FIRST FINISH TOUCH UP OTHER REASON FOR PREPARATION PRIMING COAT FINISH COAT 8UILD UP ky SUBSTRATE 3 ATE: . M N1 '-
- STEEL.
4EPORT NUMBER: - - . 601, < Q MASONRY SHIFT: N l57 : CONCRETE-SURFACE TO BE 08TAINED S#lO """ SAJ. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. V OBTAINED: /. O 3URFACE PREPARATION WETHOO OF SURFACE PREP: d e/ W [ SPECIFIED: ), O - l WERE WATER AND OIL FILTERS USED? YES NO O GROUT FINISH: WERE THEY' CHECKED REGULARLY. FOR CLEANLINESS?. YES " NO .L.2 ' WERE THE FOLLOWING USED? .
-SAND'.P.ARER. -
, -FORM RELEASE AGENTS: TYPE:. - FIN . CLEANING:
h . CURING / HANDLING COMPOUNDS: TYPE: D STED' h GEN PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHER
#AINTING SUPERVISOR k' [M n /Is .
1 3C 1NSPECTOR - to p^rMAe/L ~ ' *- ' LOCATION AND REMARKS: .g( 'F- 4 - * * ~ *: * - s & y ,. . . . . v."cp IQ_#,y w '7 7 M y ' . __ c - do
..}s hh 7'M kA kE'Pb 00.I ,
h ff N ; h h.
' 'ft 5 :
.j;;&l.f&*[
_. : -; w
-l $ , . . '_- y.,4j. i&'
- L M- 9SM-EM 4-/-83 ' ' 'dfr 1431- D r y..
R3 Y Jh&?101.-:nH W-n GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP 3 ATE: OTHER
/,2.,28 -j") . .. ,.-- r. . .
.r AMBIENT TEMP. */7 * - *
-A . *r .cw s.
SURFACE TEMP. '/,y ' . ;. . :/ " ..! ,.
., .. . . ,. 4 ?
DEW POINT:
- h* g, -
.e. 3 1- , . -
REL. HUMIDITY: - - " 4// $( - 4- T~-< ~~ s % 6 0=. -- f.Wr v+'-7 *e ; i Wi. -M s v. t. .> - . DATE: .
/J ) ')' . g 2,,, - -- e,- . A ' . . a, - p. .e : s c.-, .c ., *cA FIL,M THICKNESS , , . q ,. . ., .' 7
%;Bv READINGS:
- F-* **.- DFTs WF 'Q* t.( A . D: F-/)'% Ts ' W 0FQFs D F Ts. g'* -gDs$.WF O4 =DQrs Ts -
OBTAINED: ' - f)(N. tag i N/A f '* '
' MIN.IM'AX.D '~ M I N.'GI AX.N.' MIN.$MAXA "MINJ[h SPECIFIED: 5-M. l_q(p - ?) N/A '.~. *d MIN 2" MAX"C
- MINYMAX.T MIN.5 MAX.i MIN /h
~
) .- '; -- ~g ?. ,f- GEN. PRIMING SEAL' COAT ' '1ST FINISH') FINISH COAT.? .TOOCH'OP[ 'OTHER7
~
T '. . , , . . , . EXP.DATE+ EXP.DATE EXP. DATE'. .EXP.DATE." EXP. DATE EXP. DA
'P INT:,d 5.,t',:E.I*' f I y','!.S'sh'; '-
BATCH NUMBERS A. DD-$W3L -* 'R
%M%P- ,.~h le[ ^*
2 [*
. C'f Q l
ACT: ? EXP.DATE EXP.DATE EXP.DATE j * ' ' ' , ~ , N.5'. gj,, g , E XP. D ATE . .EXP.DATE EXP.DO l
; : :i _. 'W. ggy p.1*'.:s A<y,.ji efg,. NT,g%! t.s.e ..
t ..
. .) *:4 - APG*' APG*. N i
-APGm ?M APG *-.--4 ' , - APG*s's T APG' REDUCER USED - 4' W /pg 4fdgy . W .v i. . .as:4saa4AA7 .re%>h e p,wmaW VM J- /8- 'COLQR CODE COLOR CODE COLOR CODE ' COLOR CODE COLOR CODE COLORG COATING APPLIED Md M.d*ffd
- Eh *
'.* dj* b Ii O.tM $ M I MW: ~ .. d 7 i' B OR OS- " OS m OsSOR s
COATING EQUIP. TRIAL MIST
@OS@. . < .
R
<rT-1 c 0 S '-
a O R- 0 8 'll OS
]'no ,, * ,,. ] NYES YES JEMONSTRATION .
g,,, 3,f .,
';, [ YESig4;NO.4. -
[ yES'{y, A .. ;Ms -[ NO *,- Jt YES,l4 [ Y3 O .*3 - NO - NO [ES ,]'
~ _
APPLICATORS 3UAllFIED '"- -
%. g,'t
%.I ~ ] YES .i> YES +.y' _ 'YES
...R [ YES{( .aL [ YE9 NO . NO T _ NO 't Y NO' D -
NO'4 u NO PAINT CONTRACT SUPV.- [ hy/g *~ . MMg 34 iC U.F * *Y . CONSTR.SUPV. /( h jjf 4 1
% _ / Z- nd 'W % .
O. C. INSP. /sj /. 4, ,e - *' *'8i e
- AMOUNT PER GALLON .
8/8 RUSH S/ SPRAY R/ROI.I. ..r . . . (
,a ;. w t . ...
'ROJECT:
. ,N D -
. u APPLICATOR'S SUPV N. l.IM(ll M J. O. NOl / 7 O 6 d:
,9 4
,.-6..-
- GENERAL SEAL FIRST FINISH TOUCH UP OTHER % SUBSTRATE lEASON FOR PREPARATION PAIMING COAT FINISH COAT ButLD UP p' STEEL
) ATE: T.. 'i 11hn 22 *
- . TM MASONR Y IEPORT NUMBER: /$d3 ,s tZ CONCRETE iHIFT- 4-
/ '# -ANCHOR PATTERN IURFACE TO BE O8TAINED .* F /O w*3 b
IURFACE PREPARATION Sp UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. OBTAINED: AETHOO OF SURFACE PREP: @/ud'r' SPECIFIED: /O-2 CERE WATER AND OIL FILTERS USED? YES $ NO GROUT FINISH: YA
#ERE THEY, CHECKE'D. REGULAkY 'FOR CLEANLINESS? YES NO SANDPAPER TEXTUR
.--e
- NERE THE FOLLOWING USEDM.7 .< -FORM RELEASE AGENTS: YPE: FINAL CLEANING: [
,l[ ~ . -
CURING / HANDLING COMPOUNDS: A TYPE: hDUSTED hVA
. , . y,%* -
GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHER J 8AINTING SUPERVISOR /(. ga,1/> _ . 3C INSPECTOR 4'*'*.i * - %)(,4VMAit?/
^"U T. ; *
. ?^"f. (s .
0 EU h Y fRMf/W6* Y 7~ 0&th 7~
?. Y gg .7 y .1 wy g & j /_ff()_ f h j h; .N T,[ . .., / , $ ,- *
.- h.'f -
. .n. .y.. . , %.,
~*
'.} . . :- sp.y y s
.T '
7+' yj ,.. %, -.%. i., - .'.* .'1, . GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHER JAT .. i. .t d.-h 9,'_. i # 6- 1/274892 - ~ - AMBIENT TEMP. !d* 97# SURFACE TEMP. *
- Ag4 # -
DEW POINT: - Wh .~. -*
' //8 #
R E L. 'HUMIDITYi'84W ~ " ~
**;7. 9 [#
?.* L "-
D ATE: - M-.W Ne W #
/- M 3 - -
.' N * -
FIL,M THICKNE.SS c!.' Q * ~. ,,
', , . -,. N/A , . O O. -0 ; '
;;-E "V~g.
s- h ' C R E ADINGS: "'-t Ad D Ts WFTs DFTs WFTs DF Ts W F Ts ' D F Ts". WF Ts DFTs WI OBTAINED:"i SM.M. '.' #-i
- J tbi.i SA[ ' N/A . MIN. M A X.' MIN." M AX. MIN.' M AX. MIN.i MJ SPEClFIED: ' ..D I#~. Y, Y)BT M ' Pj,64/ ". MIN. MAX. MIN. MAX. MIN. M'AX.' . 5dlN.'.*.'M
'a GEff9[yMirfG SEAT. M M([@.* ' ' . . . , 's j e r .
[ ... EXP.6 ATE MEXP. DATE IST FINISH EXP.DATE FINISH COAT EXP.DATE TOUCH UP. OTHER$b EXP.DATE EXP.DAT 5.,.*W e([ V} [. :
' 'D 3.M, q [, _ PAINT: .*[
* =.~~ % -} ,. ',", *
'i ' ' ?;l~',
,'.'} -*b '. ,' 5 0 .*e I * 'd # B S D - I N 1 1. - M < t- :- '
' lb'ATCH NUMBERS ? EXP. e DATE EXP.DATE
}'[~ E XP. D ATE - EXP. DATE EXP.DATE EXP.DAV V -l,
. -Y'. .,
kh., ACT:'? N%Y 'f,, p. g3 ' -~ ; 1..' .
'r
. . a. -
. . . . g . -:.s.;: .- . *% .
. ." APG* APG*-
- APG* APG** APG*. APG*
REDUCER USED'.
' , /0% y eq3 .. , -
, .',... 8 4* " '"*
COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR CC COATING ' APPLIED' h[hfo & W ' {
;., ;.Q*,g ,j. ..
.. Q B '. R 0B R QB R B R 0B R B'Q COATING EQUIP. " 3 w S
S OS . OS OS OS TRI AL FEIST I .. ..:.yl :',..'. 4 ,- D D EMONSTR ATION h -p;i! ~t i '*!.,$ [T _yWO YES YES ,
] YES [ YES ] YES f. ] YES C -
NO _ NO NO' NO- ' NO YES *'- ] QUALIFIED *.d ').h,'.Q"i . +'5g-j7'i[YES ] YES. [ YES [ YES APPLICATO,RS J-.n _ YES - ,
- D ." -
- NO - NO NO NO NO * . NO PAINT CONTR ACT SUPV.?"Y !"*7 [,/h h .
. . . @]g[f /p , q- 2:' . - C' CONSTR. SUPV. - - g . gf., E fu pm /.3 ' ' ,d ZY m_
'!,1A l To
~
O.C.INSP.
* ~
~ .1
(
- AMOUNT PER GALLON B/ BRUSH S/SPR AY . R/ ROLL
' ' .a
A/8M b--di"*d 2 uW PR3 JECT
.4. me. *..n.- ' .f . 0. W h s',W, '
APPLICATOR'S SUPV E ted.t.VG9 'N * * - * - ' UAULFA' 7 J. O. NO. / 2 (*) ?
- H -
~
r',4 J.,~,. N t ". 4 .W 4 4 g . GENERAL , SEAL FIRST FINISH TOUCH UP OTHER REASON FOR PREPARATIONZ PRIMING COAT FINISH COAT SUILD UP T SUBSTRAT
'OATE:M M@W*n.'h. / -7.U
**'d' '
REPORT NUMBER: 4 - T $ owe
-- . .i . - -
Y
= MASONRY SHIFT: 4. . I c.-G: t G35". 7- f. l.D" 1 CONCRETE SURFACE TO BE OSTAINED e - Y /O i - "'
% +' .r.735 *. .c SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS.
SAT.UNS. OBTAINED: /, D SURFACE PREPARATION y * . METHOD OF SURFACE PREP: 6,d,- i
- SPECIFIED: /. O * .
WERE. WATER A,N,D' OIL' F.ILTERS ., p . US.ED? YES D NO
... , . * . ~
GROUT FINISH: 2 WERE. THEY CHECKED . % .% scREGUL,ARL . . . ,- FOR CLEANLINESS? .* YES NO - - SANDPAPER TEXTL WERE THE FOLLOWING USEDF ,;,. .
.i.g FORM RELEASE AGENTS: TYPE:
FINAL CLEANING:.
' I-/ - f hi 4. h . Ci.lRING / HANbLING COMPOUNDS: TYPE: , bDUSTED.h
. / , .tgi w 2 .*fs- GEN. _ PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHEf PAINTING SUPERVISOR k' s O /4dn_/L/ . .
OC INSPECTOR '.T .t'*2-'uM iffQff(t)n G , .--4*.- ' ~- -=' *- . * - - t .ue
- __h . -: !* '- ? -
.*?Q?.?
n 5%w%i?,1 - SEfo/?Y DO 3
- 00 W W [0[ . -- .- h
.c 1-35%:EyK 3.,&.*s.:.
.. t.l-1-83 li%:. -:. ;4. %; .. .... '.' : w .- '.k l O.* 5.'5.
; 0F1- W31-EJ6 2 2143 ' SQL Q , #@M.E fhf q. GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP' OT'HER DATE:x . '. ' f 'J - f.7 -t * "* .t-' '* s-AMBIENT TEMP. W90f'. ' *-T -J// 6 '? A h' e -
'O 'i SURFACE TEMP.45Ppp?t4^- "Md f.* 2lN . . .4 -
+
- 1 .:.*- 7,%g.
-DEW POINT:Vfn(%T $2/ h@s@. . >.".r- . ,
x .-
.a '
dEC HUM 1DITY:"$N 5.L 2 1&W6****: ' %gt.'
'? ~~- --
'~. P%** < -ka*!
DhTE:i 'i-Cw \* &-M fJf-f2/- oHOW - 4 w i;
'FILgTHICKNESS READINGS:? -
'#* y QQ N/A 4 : O- -
eO. 'O;0, sOf
' - D F Ts . .TWF Ts ,- 'e ' '.MU% DFTs WFTs DFTs WFTs
- DFTs WFTs ' DF Ts
'OBT'AINED: * -M~Mf @idTif%s' T.;N/A"40# M I N.' M A X. MIN.7 M^X. ? MIN. "M AXf. [ MIN;"
S
' PEClFIED:S PN<314t4.El#/> d 7 N/.A-t '- Mi N.' '
max. Mis. " MAX.9 MIN. MAX.i 9 t N.* [ t G'EN ' PRIMING SE AL" COAT iST FINISH
} giy, 'L*k Ja ].y7('--
f ~_._ q ' EXP. ~DATE : EXP.DATE EXP. DATE FINISH ' COAT. TOUCH UP. OTHER$
..n EXP. DATE.. EXP. DATE EXP. Dl 'i,
- f.f lqMPAI,,, ,
4 g s
-6.,~
N
'g"6; p;fg.. %,
f
# BATCH NUMBERS ~ SW.7 f i- 3 ' 'C' ' ,4. 4 ' - ),L y-' ' Y }' b' -, " ',
- f
- q' " " '
#*Q Y .... $ EXP.DATE EXP.DATE
&,+EXP.DATE E XP. D ATE - EXP.DATE EXP.Dt s 93:* 1 ? o :v=- 4 ..
~
k :. ~ .n .' c.: < ~ c: .
-4 :=t.*=%QEtJey TF ~APG*4 8 APG* -
APG' - APG ' = - APG' APG, REDUCER USED . Jeg' yo q3.n ~e c.d.
.: + . : w r .
s :! ~ :
.w . x
- r-
, . sM ih-7 " * ~~ %JOLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR COATINGhPLIED. y_ wyN/;M SM ?.",L r J MN/f .d . ':r, ' '.,,[@t N 4.p<,s!" u. . W i~ d Y' ,
hlMk 3R.- BJOR O s"G R O e- R~ s '- B 'i COATING EQUIP, M' iff.@ $%p.P #<C S M R S _O S v . s O S.4 ..Ot
. t.
g; TRIAC MIST. * *' Y s _ S YESj , Y.ES.g-i YES 2.4' . Y@1 DEMONSTRATION ,; . ,c " ' _ _ YES. , , NO
- NO
.- NO T ;O NO ' i NC!
M '" l' E ~ NLIC'AJORS -
- ~
YES.Og- YES YES.i YES *T. YES , ,' '
$6M ,,..
OU LIFiED ~ . YE PAINT CONTRACT'SUPV.)liN [dMJy' [ NO W M.i'Ar. . -: - NO 8 '. nob f NO D
- 5 'Nd
~ E X N ,* /y ' ;i-e - A i'l CONSTR. SUPV4MtFirh /.' F . /h a/& .. 7. A
%#4 i dM Pneu! ^-
O. C. INSP. ?,%' M 4.*N R C 1 - /d Wff}.y
- j >+ '
'1- ' .* ", f e- - '
. . .'d. .5NEcf 7da ?.{ AMOUNT PER GALLON . B/ BRUSH S/ SPRAY R/ ROLL
~'
, -mm mmy r n n m r rvu,nnsewerusW ppOJECT: /VM k b ' '
APPLICATOR'S SUPV K IMU L F R "* ' J. O. NO.f. IAOi s GENERAL SEAL FIRST FINISH TOUCH UP OTHER REASON FOR PREPARATION PRIMING COAT FINISH COAT = M SUBSTRA1 BUILD UP . V STEEL . DATE: f- 6 f 2. . REPORT NUMBER: 604 MASONRY SHIFT: l gj CONCRETI SURFACE TO BE O8TAINED St#l6 - d SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. OBTAINED: V
/.
SURFACE PREPARATION METHOD OF SURFACE PREP: (fe.NDFA r , SPECIFIED: /.C WERE WATER AND OIL FILTERS USED? YES @ NO - G ROUT. . FINISH: __. WERE THEY CHECKED REGULARLY FOR CLEANLINESS 7 YES. NO ' ' 3 s- .-
~ . . ,. v:f < SANDPAPER TEXT WERE THE FOLLOWING USED? .
- FORM RELEASE AGENTS: ,. '
PE:*
~ FINAL CLEANINGl
.- : .. ."N[I 4
- 2 .
CUR 8NG / HANDLING COMPOUNDS: - TYPE: hDUSTED G_EN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHE PAINTING SUPERVISOR K, /jnn h a-e- >
- a OC 1NSPECTOR ~'
- 4).N)hAbd
'.;*'V'*
'- *
- l1 '-
LOCATION AND REMARKS: 4 '
'r y$
' UW' A U . 'Ow T$&
W!-p.-k.. E.n;-v:7.. . .
' . f" . . fC* " ...;OyCfT & [
~
.21oo_ aem ro e t. 2 3 l-v Beam ou rea ;ei.u c. Peru.rwe
~.*y,(..:e l 'M *. U E .;t C.
Fau. Noi rs re Rc.Grf ooi y .,y.; J%, g* Q f, ,~ p .s.::
" n '1$$9 tN. 4-\-93 OFT-W 31 - EYP. ~3 93 St.f hG'- 9 603 - Et A 4 89
- TjE GEN. PRIMING SEAL COAT IST FINISH FINISH COAT -TOUCH UP DATE: OTHE
/ - (,- f 3 .
.a <
. .m ' - - *ar, ; . - *5f se AMBIENT TEMP. r? g # -
. -I' "
7 .+ *d.' . -* t
**+ .
SURFACE TEMP.'- - g ,;L # . v- . * , - 't * *i, - b g. :: 8 4Y*, DEW POlNT: .. t/ g # - - -',-4-*.l'.> Yde46-r / ~.a iN.A REL. HUMIDITY: ^ ** " " f//% +-
~ * + %.e- ' .V "Fr==& 6 = 4PM4 2&# 4%')W DATE: .
-/ '7 f2 - - *~ ;
- r - ,v.W W*e + .1 a:
- 414 -
FIL.M . THICKNESS
' ; -' ' ;,t '
Q .
.- N/A e O . . O '+ 'C: *s 0 4 READfNGS: '
DFTs WF Ts Dd'.D OFTs WFTsY i:DFTs O p;WFTsE- i O ?'- DFTs WFTs :-DFTs *C - DBTAINED: . MIN. M AX:~ - J~ N/A E '
~
MIN. ' MAX. [ -[MlN.'YMAN.C M'IN'. l fdAX.$ !. min 3
~ ^
SPECIFIED: ' 3Mlp gA6K. M N/A' & ' M IN'. M AX. ' MINNAX.C '
' MIN.* M'AE.T SlN'T
~
GEN. PRIMING SEAL COAT. 1ST FINISH - FINISH' COAT - TOUCH'UP ' OTIlER
~
EXP. DATE EXP.DATE EXP.DATE ,EXP.DATE . EXP. DATE. EXP.C
,,V"*
p'AINI: , ' d
'.*,.M.42 .t
*ff*d, . ,,'-[N;d f;) , M -
~
t
,- BATCH NUMBERS r- 3 n- SM)L L.<'- ' ' - - ' - , % i/ w. **t% kr. h
- Q* *q ACT:4 EXP.DATE EXP.DATE EXP ;'.DATE
., . .,4..' EXP. DATE EXP. DATE : EXP.' t
' .;;-s, .g,;g,.p:4 p ,, g 3 . . . . .. ,- . . .a 3. ,- . .aggp3,cq ' .,;q;4p
..4 APG* APG. *' i APG' " ,* APG* EC *'
APG * ..a - .**AF REDUCER USED 4" 'i - ) 08/3 y og g -r . - - rr, . r.,e i rairs.vany- Teseis W#-+ . Mesm L.' - ' COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR CODE' COLOF COATING APPLIED afo.11-t '$c YF~f\ D UTi MNNb MEb N
., **,; , y .* . . - V ', @B @R
*k
, . 8 R 0 B~ R. QB' R;. OB R- 0B5 COATING EQUIP.
OS - . S s- S .-
- c,O Sa tre < "c 0 S r: u.O TRIAL MIST [YES [
DEMONSTRATION NO *
, YES ,i- [ YES.Tg'* '
[ Y,,E , .
] NO.u.YESg ,L ; )
NO *
- NO ~
NO W E '
- P APPLICATORS i /-
P *
~VYES OUALIFIED' ' YW' . O. '!I- "
NO . " '
~ YES 4 ~ YES .b.
- 4 YESg YES 3 ;* i NO* -
bOf UO - d
- k'O % f PAINT CONTRACT SUPV. 8 [h (,. C .- 7 9$$f7k/g MWM NU CONSTR. SUPV. (k (% o u , Qn YW n
- Y 'S d *'*~
O. C. INSP. - 4;i//4e$1
"... ;& , , . . , , . : . . AMOUNT PER GALLON B/ BRUSH ,. , S/ SPRAY;l, , R/R,OLL .'y.$&
OANh PROJECT: APPLICATOR'S SUPV- M G or, f # M- - .O.NO. J ,/ ) A T C-
' GENERAL SEAL FIRST FINISH TOUCH UP OTHER CEASON FOR PREPARATION PRIMING COAT FINISH COAT BUILD UP dM SUBSTRATE DATE: A TEEL
~
1 h' M /-/.D b - REPORT NUMBER: SHIFT: I'-
.M b o O [,,
/ 3-f" g MASONRY SURFACE TO BE OSTAINED di"X"~~T r*/ ; , _
M ORP SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. SURFACE PREPARATION UNS. OBTAINED: / J w/ METHOD OF SURFACE PREP: 04T SPECIFIED: /r , WERE WATER AND OIL FILTER,S USEDP YES NO Mgg. GROUT FINISH: q/. WERE THEY CHECKED REGULARLY FOR CLEANLINESS? YES N'O M - SANDPAPER TEXTURE WERE THE FOLLOWING USED? - FORM RELEASE AGENTS: TYPE: k FINAL CLEANING. CURING / HANDLING COMPOUNDS: TYPE:n OOuSTED OvAc GEN PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP PAINTING SUPERVISOR OTHER.__ A Rf, , . Oa., OC INSPECTOR Q%j jd LOCATION AND REMARKS: .-- "
,A* R C 'I Et c v a t s. ' - A.,g;,q u c,7 L T .
F u I H L' G- o a - a ooo o 7*o c oi t;, I sMt. 8 t-g.g ,ogo, sw -v -i . P,T D uy,- e r ', s3 o bVains ~~. ca. t.S
~ '
a w - m r -, ,, . s m ,. ,. . n .s r , < n r. . o. a. GEN. PRIMING SEAL COAT IST FINISH' FINISH COAT DATE: TOUCH UP OT'H E R _.,
/. /O. g,3 AMBIENT TEMP.
SURFACE TEMP. DEW POINT: *
$8 R
g* , j[g/ C/j - _fL HUMIDITY: . - DATE:
/, pg.Q3 FILk THICKNESS O O N/A - 0 O' E REA[,1NGS:
'OBTAINED:
DFTs WF Ts - - DFTs WFTs DF Ts WFTs. ' Dgs WFTs O. .O DFTs WF E MIN. MAX. N/A MIN. MAX. MIN /jfMA$ MIN. MAX. MIN. MA; SPECIF'ED: MIN. MAX. ' N/A - MIN. MAX. MIN. MAX. ' MIN. MAX. MIN. MA) GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHER _ EXP.DATE EXP.DATE EXP. DATE EXP. DATE EXP. DATE EXP. DATE l i PAINT: BATCH NUMBERS s ' ' '
,,.. ~}.- ,
- ; , ,M- ,.
k3-yG")6h, * , ,
~ .
ACT:, EXP.DATE EXP.DATE. EXP.DATE EXP. DATE EXP.DATE EXP. DATE il G. 84. (3 'F9 APG* APG' APG' APG* REDUCER USED . - - APG* APG' gg 7g p( COLOR CODE
~
COLOR CODE COLOR CODE COATING APPLIED * ' gOLg*R. CODE COLOR CODE I COLOR COI
., " J. . -
,1 *ff COATING EQUIP.
B 0R B 0R B R & B' }R QB R B" OS OS OS S OS OS TRIAL MIST 'YES YES l DEMONSTRATION
~
YES ' *' ~ ~ , YES YES APPLICATORS NO- NO' s N O '" 2 )NOfE$ I NO ~" ~
~
NO i OUALIFIED - e [ YES ;; c [ YES, g ] YES . - - 2 YES .,, [ YES [___YES NO t *'. ~C l NO' NO I'T ' NO * ' NO NO PAINT CONTRACT SUPV. CONSTR. SUPV.
$ Qg {A W II,/P -1 O.C.INSP.
A R,&fWN d-- " D-l 4,)Qf 5s io n"~
' AMOUNT PER GALLON B/ BRUSH S/ SPRAY R/ ROLL
PROJECT: M4 4$ APPLICATOR'S SUPV d h -; / 4 M J. O. NO. 11AT%
~
3 M
~
GENERAL SEAL FIRST FINISH TOUCH UP OTHER SUBSTRATE REASON FOR PREPAQATION PRIMING COAT FINISH COAT BUILD UF 4
-STEEL D ATE- -
/ # Y N Of MASONR Y DEAQAT.-NUMBER: -
/M - -
}
SHI FT-- /L f'
- ANCHOR PATTERN SURFACE TO BE OBTAINED 3/r w SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. OBTAINED: / T
, SURFACE PREPARATION /
METHOD OF SURFACE PREP: M( SPECIFIED: /J }y
' CERE WATER AND OIL FILTER,5 USED? YES NO GROUT FINISH:h WERE THEY CHECKED REGULARLY FOR CLEANLINESS? YES WERE THE FOLLOWING USED?
NO k SANDPAPER TEXTURP z
- FORM RELEASE AGENTS: TYPE: FINAL CLEANING:. + . ,
CURING / HANDLING COMPOUNDS: TYPE: DUSTED 0 vacc GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHER_ PAINTING SUPERVISOR li J k.Om - OC INSPECTOR tr } l% C'- - > ' ~ . g g, g g gC LOCATION AND , REMARKS: g { g7 @.+
..+ 'f*:. 0
.. p mT~g WlO& y <..ng,g g.; m ;,
y 0LPDfT OO} Qo J, j g y,, g .i .-_, .
% "- ,L . ' -
_ ' , s , .:. ; . 3
.r.' b S T'~ *7 Tr' T 6 Y /3 V-/- f 4 O F T' . */u r/ *f 3t-9T St . . *75 6 T KV 4 2/.'r- f
~
GEN. PRIMING SEAL COAT IST FINISH FINISH CbAT TOUCH UP OTHER __ DATE: /.16,/ 73 ,- AMBIENT TEMP. 79' 4 , SURFACE TEMP. .<' g , e. - DEW POINT: S '/ * - '
- a. 5 ,. -.
REL. HUMIDITY: M $ #j 4 %i .. MM DATE: I j
/- / _*/ -9 3- .
. 4 4.=i FILM THICKNESS READINGS: DFTs WF Ts O N/A DFTs WF Ts O Y_ ._ C .-
CE DF Ts WFTs *f ,D F Ts WFTs DFTs WF'
-OBTAIN ED:. l MIN. MAX. N/A MIN. MAX. MIN 56MAXW' MIN. MAX.- . M IN.* 54A)
SPECIFIED:' MIN. MAX. N/A MIN. MAX. MIN. ' M AX. *
- MIN. MAX.? MIN 9 A$
! GEN. PRIMING SEAL COAT 1ST FINISH l FINISH COAT TOUCH UP OTHER Y EXP.DATE EXP.DATE EXP.DATE EXP. DATE. EXP.DATE EXP. DATE PAINT: ' I 3 2* T*3*l-D .','L~.YN
.:;'. U ' -
. BATCH NUMBERS
D- Y I'" ~ 7'
ACT: ~ EXP.DATE EXP.DATE EXP.DATE EXP. D ATE . EXP.DATE EXP. DATE ! g, , yy <
.f ,,,.;* +. - f-:-
APG* APG* APG* ~APG* APG* APG*. REDUCER USED ,n.7, Jpy,- . . - . .+ %
. .. COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR COI COATING APPLIED uY,e FLOR 'p t CO}'E %- .~. . 'M ' d.*'
N ,. s# B R B R B R B 'O R- - a OR COATING 'EOUIP. OS OS S OS OS -OS ( TRIAL MIST DEMONSTRATION [ YES 2YES [ YES' ES _ ;, , YES . #* , [ YES , NO _ NO _ NO v NO *
- __
NO
- _ NO y i
APPLICATORS OU ALIFIED.
;# . y. YES YES . YES [YES, % [ YES -t; . YES~.
NO :*7 - ./ 1 NO,N: NO l NO NO NO - 3 PAINT CONTRACT SUPV.
@ & .0m yggs ..
M' N' CONSTR. SUPV. Ni Mo [/M ; 2 '_h" * '..', T D' O. C. INSP. ,I( / t . d '- CIM %
,,
- AMOUNT PER GALLON B/ BRUSH S/ SPRAY R/ ROLL W., .
-- . ..re, PROJECT: bA45 APPLICATOR S SUPV R O A. t < /> J.O.NO. /10 3 m
' GENERAL ' SEAL FIRST FINISH TOUCH UP OTHER F REASON FOR PREPARATION PRIMING COAT FINISH COAT BUILD UP 4 SUBSTRATE 4 .
/ STEEL '
DATE: /.' fD . REPORT NUMBER: dh9 J'M ASON R Y SHIFT: /Y ANCHOR PATTERN: SURFACE TO BE OBTAINED / fire OBTAINED:,/M' SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SURFACE PREPARATION ./ METHOD OF SURFACE PREP: A n T' SPECIFIED: [.O-Q WERE WATER AND OlL FILTER,5 USED? YES NO h GROUT FINISH: /NK WERE THEY CHECKED REGULARLY FOR CLEANLINESS? YE k NO .. - SANDPAPER TEXTUREr WERE THE FOLLOWING USED7
- FORM RELEASE AGENTS: * ' TYPE: FINAL CLEANING: ,' ';
CURING / HANDLING COMPOUNDS: TYPE: DUSTED VACI GEN. PRIMING SEAL COAT IST FINISH EINISH CO_AT TOUCH UP OTHER _ PAINTING SUPERVISOR iT b l_/pg .
- QC INSPECTOR l -
/MMMSAh .
LOCATION AND REMARKS:[y g gI g g p, ), jg. p ,r
~
g.k 09T3eoZ.b-iij O OC% Io $ L. *& '3 1 - L. 0 Es m D A E(Z ({,n5 , pf, j, O ~ .._, ? Q
~
' Vf% I- H U [ l C- fan n/arTg % & g d o h D o I "
..m j - :'. '
ST *) S r1 E t o 4-1-13 { D c t" *1 u .11 'Evo 3 3 -!t .sth. M oi-r*D V.tc GEN. PRIMING SEAL COAT IS'T FINISH FINISH COAT# TOUCH UP dTHER __ DATE: /-/*'). p'3 r ,V AMBIENT TEVP . [O8 . - - -, f .* , SURFACE TEMP. T- f[g)O .' e., " m ' r. . - DEW pol'.T *
.J' -
U*- .' r . '*i' R E L. H U '." D ' TY : 7 '~ ' '- N (g'. 4.w V" W~ D ATE: /-Zo f 7 .'- - - FILM Thi:= *.Ess READINOi O DFTs WF Ts N/A , Q. ..
- 4. ] 4 O . O4 DF Ts WFTs - DF Ts - WF Ts
- DFTs WFTs DFTs WF OBTAINE: MIN. MAX. N/A MIN. MAX. MINNMA)f/d MIN. . M/LX. MIN.'*M'A;
~"'
SPECIFIE . MIN. MAX. N/A MIN. MAX. MIN. M A X.- MIN. MAX. ~ MIN.~ MA) l GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTH E R _.*"._ EXP.DATE EXP. DATE EXP.DATE EXP.DATE EXP.DATE~ EXP. DATE BATCH NUMBERS PA!NT: ,
, *
- d- * .* h*( 6f-(/1C.) y 5~~,y'.i; j T Iy o . . .u r .o L & '-
~
*r a-ACT: EXP.DATE EXP. DATE EXP.DATE EXP.DATE .. EXP.DATE EXP. DATE 7TM ~~**~~2-* ~ ^ ' ** * * *
~
APG* APG* APG*
- APG* APG* -
APG** REDUCER USED . /o T, 7 9 ") l osa 4v*
~
COLOR CODE COLOR CODE COLOR CODE ' COLOl3 CODE COLOR CODE COLOR COI COATING APPLIED -- - - If.*fd. *e < O*v*- ~4* M* E . B. R B R B- R dB - P B R B COATING EQUIP. OS S OS. OS OS - -OS- - TRIAL MIST DEMONSTRATION
]YES NO
[ YES NO
] YES .~;
NO -
)ES N7.J~-
y-,, , [ YES NO ^ q,
~
,, ] YES NO "
APPLICATORS lYES ~ YES YES ,_
~
/YES ; . : a YES .
~
^
YES NO'
- Y QUALIFIED
- NO NO NO "-N NO t _.
NO PAINT CONTR ACT SUPV. .$ 3Mg m g pra M3 ~ - l CONSTR. SUPV. \ 4 i [k".ufgA E'
/3 ] TM cea
\ G.C.INSP fik.ily l*w '
- AMOUNT PER GALLON B/ BRUSH S/ SPRAY R/ ROLL '
._ ,rrr r v - n s. w n v PROJECT; bkbh J4 APPLICATOR'S SUPV N Om 4 L E d' J. O. NO. /1 n T F
, . GENERAL SEAL FIRST - FINISH REASON FOR PREPARATION PRIMING TOUCH UP .OTHER COAT FINISH COAT BUILD UP [ SUBSTRATE
/ STEEL
_D_ ATE:
/. ' / F3 REPORT NUMBER:
SHIFT: M9 MASONRY
/kP i SURFACE TO BE OSTAINED 5(.,., o ANCHOR PATTERN:l SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT.UNS. OBTAINED: /O SURFACE PREPARATION SAT.UNS.
,,,,,/
METHOD OF SURFACE PREP:
/) > n-f SPECIFIED: [ d.1 WERE WATER AND OIL FILTER,5 USED? YES NO GROUT FINISH:$
WERE THEY CHECKED REGULARLY FOR CLEANLINESS? YESh NO WERE THE FOLLOWING USED7 SANDPAPER TEXTUR
- FORM RELEASE AGENTS: #1//n TYPE: FINAL CLEANING:
CURING / HANDLING COMPOUNDS: TYPE: DUSTED e GEN. PRIMING SEAL COAT IST FINISH FJNISH COAT PAINTING SUPERVISOR TOUCH UP OTHER. OC INSPECTOR W U(UOM d-MAb LOCATION AND REMARKS: Q cu/E l-C O., 1 8 (./
.g g \ ,
Aa'.nTl[h# Thy =
~ f* , , , -
floc'TL Fro m R t p ocT oc i. _ t)o w^ 7O ;% 1,-H. V- F - 1 A / 3 O Jod st
- s. p .;.4-S T 7 5 O Evo V I - 8 '1 O F r 7v3 E.vo 7 .i r - F
- It.n* 7foi Er5 W GEN. PRIMING SEAL COAT IST FINISH FINISH COA"T DATE: TOUCH UP OTHER.
AMBIENT TEMP. l- 11 V5 SURFACE TEMP. Pg
- DEW POINT:
REL. HUMIDITY: -p " - Q* . DATE sf f3/6
/ - )(, 5( h -
J FILY THICKNESS R E ADINGS OF Ts WF Ts
.,, N/A '
DFTs WFTs O WO 'O - Ol D FTs WF Ts . DF Ts WF Ts DFTs % OBTAINED:
- MIN. MAX. N/A MIN. MAX. Mid OMAXN MI N. M AX. MIN. M SPECIFIED: MIN. MAX. N/A MIN. MAX. MIN. MAX. MIN. MAX. MIN. M.
' GEN. PRIMING ' SEAL COAT IST FINISH
- FINISH CO AT TOUCH UP OTHER EXP.DATE EXP.DATE EXP. DATE EXP.DATE EXP.DATE EXP.DA1 PAINT: N; '( l-d '
T N-Q -4't (,7 p"' ~ BATCH NUMBERS ACT: EXP.DATE (L A M i.ai n EXP. DATE EXP. DATE _ EXP. D ATE ' EXP.DATE EXP.DAT V(a 'u f'1 T* ' APG* APG* APG* REDUCER USED - APG* APG' APG' e m i o V, w , , . COLOR CODE COLOR CODE COLOR CCDE COATING APPLIED f0 LOR. CODE COLOR CODE COLOR Ci i k .- 1. M M Y' k .: COATING EQUIP.
- Os OR Os OR e OR M'O R -aOR s'E TRIAL MIST OS OS - OS O S -4' - OS OS YES
~ YES YES . YES DEMONSTRATION NO NO
' ~
NO 7 Y'yY N Q /'
.- NO'
~
YES NO APPLICATORS - [ YES OUALIFIED ~~', '
-h^' N O ^ *
[ YES [ YES EiES 9 YES YES i NO % NO 4-a - N O W .'+' NO . -f NO PAINT CONTRACT SUPV. 4 --?
,CONSTR.SUPV.
d W e', ppg. g ygjaS,, ;- /s, O C. INSP.
.l( {_Tu2.fgj nE 7' [ Ja
') )Uh i e , .,,,, " ' ' M
' AMOUNT PER GALLON B/B RUSH S/ SPRAY R/R O.L. L -
I PROJECT: Il 9,O 5
- APPLICATOR'S SUPV M hiM J. O. NO. l) e
, . ,. GENERAL SEAL .FIRST' F1NISH . TOUCH UP OTHER M
' RE SON FOO PREPARATION PRIMING COAT FINISH COAT BUILD UP M /SUBSTRATEI 1 s STEEL - . '
DATE: .
/~)7-b '
REPORT NUMBER: $[0 ,
. MASONRY SHIFT: .
/W '
SURFACE TO BE OSTAINED 6 (,o a ANCHOR PATTER > SAT. UNS. SAT. UNS. SAT. UNS. SAT. pNS. SAT. UMS. SAT. UNS. SURFACE PREPARATION OBTAINED: [O
/
METHOD OF SURFACE PREP: a _ , .f ' SPECIFIED: [ M _ WERE WATER AND OIL FILTER,5 USED? YES h NO GilOUT FINISH: WERE THEY CHECKED REGULARLY FOR CLEANLINESS? YES h NO ~ SANDPAPER TEXTU WERE THE FOLLOWING USED? -FORM RELEASE AGENTS: M/* TYPE: FINAL CLEANING: GEN. PRIMING CURING / HANDLING COMPOUNDS: SEAL COAT IST FINISH TYPE: hDUSTED h FINISH COAT TOUCH UP OTHEF PAINTING SUPERVISOR H ,1 $alf tstj OC INSPECTOR l //J W " 41A S . LOCATION AND REMARKS: *
. R f */ W ' M P% T., g UEnT O = c.T . g b
n... - .. R (JocT oo3 O ev ~ T. /- H u A 2. c.,-
; .b
+ .ny
[ CT
*'l S .5 9 Ev o - u ih nGT34i [<n T- 3 s. h Ri. . . n in6 GEN. PRIMING SEAL COAT IST FINISH FINISH COAT DATE: TOUdH UP OTHER
/. ; 7 93 AM8IENT TEMP.
7 74 SURFACE TEMP. 78 8 DEW POINT:
- REL. HUMIDITY:
- 6'f8 .
k$Tg -
.e5 DATE:
7 _ f. p'A - FILM THICKNESS READINGS:
' 0 DFTs WF Ts 0
- N/A 7 ] ,Q, DFTs ' WFTs I)F Ts WF Ts D Ts WF Ts DF Ts tBT AIN ED: .'
~
M
- MIN. MAX. N/A MIN. MAX. IAIN9 MAX /- [ MIN. MAX. MIN. P SPECI FIED:# *i**1 MIN. MAX. N/A MIN. MAX. MIN. MAX. MIN.' MAX. MIN. A
.- GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHER.
EXP.DATE EXP. DATE EXP. DATE EXP.DATE
'^ EXP.DATE, EXP. D/
.' ' PAIN T:$ ' . ;. * .
- W'f =Vl&%, ' ' *
.- BATCH NUMBERS -
' -? " # -
% . .' f .dw -
ACT:.' EXP.DATE EXP.DATE
$ . t [* ~ ~ . '
EXP.DATE ~ 8MDAT5' EXP.DATE EXP.DA q 6/C .u 7'3jt
<",~--4
-) APG* APG* APG* APG# APG* APG REDUCER USED -
ID8 "I t '1 f I COLOR CODE COLOR CODE COLOR CODE COATING APPLIED ' C LOR CODE COLOR CODE COLOR Dm a M tI.c - * " COATING EQUIP., 8 R 8 R Os R Va'~O R ~ Os R s' OS S OS OS OS Os TRIAL MIST ?. [ YES DEMONSTRATION
, - ,J;:
- .* NO
* , [ YES NO
[ YES [y/ ] YES
] YE NO s NQ NO _
NC APPLICA TORS, g* gA',b* ff" YES.,- YES YES ,giES [ OUALIFIED' - NO Y NO ' NO NO ~ YES, NO
, [ YE NC PAINT CONTRACT SUPV.
CONSTR.SUPV. k fd ,.m n m.r e-O. C INSP. }f '[hM P"Y* ~~ ~ U4/
- s t ' . e' le * * . ;v %
., ,
- AMOUNT PER GALLON B/8 RUSH S/ SPRAY R/ ROLL
\ -
7_R.018 F m T ECTIVE COATING SUL;&Ns WWEPAwavcOR Rg(c;gt;JLg): '.~
OJ E CT: A/M8 N
, APPLICATOR'S SUPV O Adtf1E#
J. O. NO. f 16 < m GENERAL SEAL FIRST FINISH TOUCH UP OTHER '/' SUBSTRATE 1EASON FOR PREPARATION PRIMING COAT FINISH COAT BUILD UP k STEEL
) ATE: //-ji D .
"#' MASONRY
=
IEPOILT NUMBER: - c /0 . . . SHIFT: Jg4 $ COERETE ANCHOR P ATTERN: SURFACE TO BE OBTAINED $ e/0 SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. SAT. UNS. OBTAINED: ' '/M SURFACE PREPARATION V WETHOD OF SURFACE PREP: f48 sO-f SPECIFIED: Y,, CERE WATER AND OIL FILTERS USED? YESi / NO ' - GROUT FINISH: 4 CERE THEY CHECKED REGULARLY FOR CLEANLINESS? YES NO SANDPAPER TEXTUF
#" FINAL CLEANING:
WERE THE FOLLOWING USED? FORM RELEASE AGENTS: ' i TYPE:
- CURING / HANDLING COMPOUNDS: TYPE: DUSTED h,
. GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHER.
FAINTING SUPERVISOR 47 ffaul.4 * -
- 3C INSPECTOR 1 'sm /, f p/ f , . a , s' -
.-- * * '*
- a s t . 6 *% e... .-
kY W hy"f' SCf.,. *, . doowc.Co,/8'5 * ' 80o u~6 Co i c 'd L %_'$)__
');.30-)
-Yih-b f. ;u & E &{ h* f !*.-[.,*}
, .,.~_,q -
GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHER DATE: //./9-2.7 ~ AMBIENT TEMP. 7(f * -. **e. .*- v - :- SURFACE TEMP. %* - - * - . r'~ - s,".. "-
'5 i-DEW POINT:' jl, ' . e**A. r -
REL. HUMIDITY: fS Ye - -' **E'
- S-M 'A' t i 1. - - % - 1 DATE: // /9. P T - . - u- *1 -O A c - 7, A'. .-
FILM THICKNESS R E ADINGS:
, d C..
DFTs WFTs E 59 4*
- 1. N/A q T. ] 7 DFTs WFTs' DF Ts'- WFTs 2 OFTs WF Ts t ] je d g \] - . - -] y DF Ts OBTAINED: 3 MIN. .$ AX. .~. N/A MIN. MAX.'W ' MIN.M MAXh MIN. MAXJ MIN'. [ F
' ~
SPECIFIED: 3 MIN. $ MAX.
' N/A #
MIN. MAX.b MIN. - liAX.P MIN. M X. MIN. l GEN. PRIMING SEAL COAT IST FINISH' ' FINISH COAT < TOUCH UP OTHER
.EXP.DATE EXP. DATE EXP. DATE EXP.DATE;; EXP.DATE EXP.D
' PAINT: M' U- 6*J $ +
Jr## S.T. p 4 3 _- g-Q%~* "- Ms - yf[M-h " f* %-
$ { ~,~. F ' ; 1* j r BATCH NUMBERS ~ .
ACT: EXP.DATE EXP. DATE EXP.DATE EXP. D ATE - EXP. DATE EXP D. u c. n . o r n mas.o.e4
- - *4 , * .
APG* APG* APG* - APG */. -* APG*. APC REDUCER USED pq q - je % -: .- S , so. -e. Wr% '*. M ~ v' COLOR CODE. COLOR CODE COLOR CODE COLOR CODE COLOR CDDE COLOR d}/MTb '*- . '* F R.' /t.^ ehi/OM !*-?! D COATING APPLIED MTf /,fyf/ '
'. '4.
$ R 8 R B R B R - B R B" COATING OUIP. S OS. S -
OS - OS O-Y TRIAL MIST - QvES ] YES,; [ YNOES_g., [ YES g - ] YES ,
]
NO ~" - DEMONSTRATION . vNO
- NO ,. NO. N
<- = -.-- = -- -
i APPLICATORS .g',,**- *
.. g ES g , YES '.ft , Y E S .p ' - , YES S .4,. , YES,b, . Yj QUALI FI ED * .-** NO ? " __
N O **? __ NO". - # .
- NO N3 NO '> _
N i PAINT CONTR ACT SUPV. / ggf,,* G* U* '* ' M s'* - .'s' *
' 'O?
- e aw_, % .,. fa CONSTR.SUPV. # /fMm * *
. # v l~ "* 5h' $ "
D_ O. C. INSP.
' t ' d. *
, s. .
~
-- I
- ..
- AMot mT --- - ' - - ..f . . .; ; . '/~ R AY
. R/ ROLL
w-- n-urvu r - ML+99MLfts_%TfuWX'fL'i PROJECT: A/AFS '
-' APPLICATOR'S
- ' - SUPV N
- M 4/1l Ed ' ^* *' ' ~ J. . N O. I 20 sd s r; e.) .e '
4 . * .t . -_ .
- g. - -
GENERAL SEAL FIRST FINISH TOUCH UP OTHER , REASCN FOR PREPARATION PR! MING COAT FINISH COAT BUILD UP '
%MUBSTRATO i
k STEEL. . g bI M I DATE: a // 8 -81 . - t
-b REPORT NUMBER: -- %* ' D/1, # --
- '--'C7 3 ' "
~
. 2 -
- SHIFT: ,.
m
.f N .
1 I* ~. * ' -
-SUREgE TO BE OefRTNEu~. gr,r ,
T/ _ .:a _. T $9 d .$. ..
- ANCHOR PATTERa
- f*
SURFACE PREPARAT
--ga. ~ MM -
SpNSr V -- SAT. pNS. SAT. UNS. SAT.UNS. SAT.UNS. SAT.UNS. OBTAINED: V ---~ - *
' METHOD OF SURFACE PREP: jgf(jd . .M
- ~ ' ~ '
' SPECIFIEDi A.
ISERE WATERND'Oll' FILTEly US5DbES '~' ' '- _ . _ wy ". NO ~ - t...6%.. -Y .,.. GROUT FINISH: 3 WERE TEEY CHECKED REGOLAltLY,_F_OR MEANLINESS? YESW 'l NO '~ f s~ ' p WERF/THE FOLLOWING. .USED?.
"t.
FO.R, ao M R E LE ASE 1.] - .AG E
. ,. 7 A. FINAL y' TYPyE..
CLEANING: . l
,r- s I ,a _ . -
as .. - ., .
. n. .
i f5 -
.< ~ CURING
.- / HAN.DLING CO.MPOUN.DS. - iTYPE: USTED 4
-C..' GEN. PRIMING SEAL COAT IST FINISH FINISH COAT TOUCH UP OTHEB
\ "= % 2:^&'GCr^ . ._Y-)%M71lz - h-f f.fuea Ie - ' (X, Ikspyr'9fM'6m-f (%.ga. > -~ s,Q2- (h p y. w .
- *~ . u- w:: . 4 a;y :-
-5 . l$ ',_ .-i
- 1 I- " kWL 2-1% ' . .' $ f Fi V'?
&QMm- M ir K( Q &.g ,afa,,Wj.!!. .; .
k* . % F.d'2 .
?.
d ' _;. *_. .iWSMF.
.'s -a.s(AG K ,.;W~42'..%$1-i$'# -u , ' p 4 _,n; *. JJa. - . - V*~t$h.MQfjj$.PF t.p
- Nd!
) ~. - % ,'. _ $ ,
Re.
" ~ ~ " ' ~
- T'
_ GEN. PRIMING fEAL COAT. 2iS' T FINISH FINISH COAT TOUCH UP V OTHE00 _OA1.E:_ "__ 3 @_~'~_' Af_)) f f f - V. t : ' . .., . g q,gf . ~' g. . & . . . . ' .f -y,, -c .r *
. AW E N T_IF W# '- h.~ W! %7 ; D i,.M y Q f, 's ." "'
*X & :' 1 'd.&'l #M STiRTACE^-TG'@. E * '[--i 5*7Y/f '._-/ -
; - T .'.y__ *. . f/p.,*._- s
. M.".%?. - ..D .3 - 'M
; DEW POlNT.- ~
s M# / AC , ft./ f . 2 . - . . . . .. . . . Ia -. n. ,,'4, y R E L. HUMI D'iT'Y.*-A #' /,/// N *~ ' t/ f % ';> ' M .' ** *- % e-T L W+-t ;ettty D ATE:. - 1,Afd-f-] '. : * - VA!: =: * * -:-'u :'v,% 33 4 1. c -- 'i> %& FlLM THICKNESS READINGS: '-!
,Q' 7.p. 4 ,:.,
. M # b -
D@F T.s*g-Q',ywf Ts N h g;gN/A ' + DFTs& 0 a,- 30 er - @a WFTs 1 ' DF Ts 4 WFTs CCw cG4i DFTi WFTs 4 0FTd.*
'OB TAIN E D:" ' t @k.W.:1?_b 3)N. 'fgK.S <?-W7AM' MIN 7MAXb 1AiN.FMAN.3 IWIN.'. MAX.O %tlNN]
! SPEClF'IEDi NY' " M k.$(Aggd# #'*A%'; ' MIN.'" M A X.~' MINI MAX.' '. MIN. . MAX. iAIN.i ; 7 Z -$ [@$Gd?C.P8'1,MJNG1 SEA'L*C 'AT$ '1ST FINISH ' ~ FINISH COAT. TOUCH 'UP ^ OTH'E R I
#AY EXP.DATE--'*.EXP7 DATE - EXP.DATE EXP.DATE.. EXP.DATE EXP.@ .N' h M y[ [*pEKP..DATEM 4XIhAAPE ; EXP. O ATE . .- EXP. DATE -
E EXP. Dd
- h.h.2e % LAY 11 W:n'94 G s' W e: ->R f fff&: +-Y- s.X P. ' D~A!"
*?O;:Y AT E
.f.s. t. - E' g .-
. W#-3 ar" -APG *#V - "-9f'APG'. h "*WAPGW '
t . APG* M -
- APG* M . P APCi REDUCER USED' Y./ ),2,& - ff,pqp M r~si. 'jO % q qf: --49. s . .-. ,5 . :u c. ys 1 - . ,,m?~9
.:. g;;d- 'E'.? 1; -d .,#
?' 'CO' R' CODE < CO g gODE DE COLOR CODE COLOR CODE CO COATING A __
h-M' j,//ffI.~ 'M SM.N NeD T.,L d M
' COA' TING EQUIP.6' '#p E*. ,. . - $2 Wgdne' L r% *@'@ h .B's.
R E84.C R. O8- ai 8 0.a Oat
. S ,-
D*C S)# D M S 4t* ., C S vie r 0 S -s . -@ g d'~Y E S " '""#
.W F H,gST yT- [ Y.ySg: .* g TRIAL MIST M .M -W W . :.p d DEMONSTRATION r,-Ja '
NON ~~ La i NO-
.Y ES ~^
NO N '. ]y
+ rAK -
APPLICATORS M': c) '..g k f $ G 'TES. '# w Y.. Sg'@y-=E
-~~
- - = i's. Y,,ES. j ., ,) ==
' c.+ a .W qQUALIF. LED . ' ~ =
NO' NO M.'i.d NO .. NO S \ .N .- iNC PAINT CONTRACT SUPV. . [jl5Af' ."% Q' , gM/~ .-~' .
". g Jdhff/ gh yath
*~' '
CONSTR. SUPV..' _ f/. $pk .- .' ._ [~fMo h - *h> .:. * .. 'p - -
.1 t . E NM
- O C. INSP/ - * - /d8 -_ -! 7 M,7 /T(icFe__._ 't Y .. . . -%' ~-
t*9
~.
. ,.4. , , , , m.. AMOUNT PER gat iOR * }feG ,
at' yly,0,9 AY, .f..e.
.. . R/ ROLL :1.7. .c .*d.
...s.
___m - ' _= = ~ - __
. . . s. w n v PRCUE d: _ N M S '**
APPUCATOR3 SvPV N I...__. M!. ~f.
.J.O.NO M 28 60 I
- xM,,
MENET2L - SEAL ATIS T ' FINtSH g -i ! - 4 UP OTHER 18EASON FOR .aniPATIATiON e ' PPR1Mi&G COAT ' FifRSH ' CMT 9Uf* DUP LSUBSTRATE
, . -. y ggg V STEEL 3 -l'.),f l ,_ - -
. c .~ c ,2 -
u .g s
. - Q' g p1/ $ l MASONRY
,. e.
.; T : -- -
1 CONCRETE .! iURFACE ,,,"i, -,PTAINED ,, ' s
- j. 13
' ANCHOR PATTERN. '
... c-SAT.'UN'i SAT. Ub AT. UNS. c T. SA T. JNS. SAT.UNS. OBTAINED: 4
. >U P .' : * ^. - ' r. ' TION lW . UNS l _
- AEb 6C - *: .v ...- AcF. l' REP:
.. , .. . MI. i 'r
.\
SPECIFIED:
' *,n
../. . L, C e t. FI LT' ',S US E D ? YES $ . O
, GROUT FINISH: N
..TRE THEY CMErir.c0 REGUI AlftY.FOR C FAN'
':SS7 Yi- I.. ~
N f'$ SANDPhPER . TEXTU
., g . ir.x.cfh= =p; ifr q i "N- .
,i s - *-
. _ r. YPE:
FINAL C EENING:Y -
, CURING i .fANDLING COMPOL .c s- *
. . TYPE: h DUSTED; h AC
~
.- GCN F5IM NG ' SEAL COAL :iT FINiE- ~. tNISH COAT TOUCH UP OTHER_
'.1 M:NG SM 'e /ISOR, s , 3 '
f 8n/A ' 1Mrw
's.
"' T CT.O_ .P h -' M.
N ' R EMM.e.~- 0860 FT !!a'sc7 Elv. 2/(,. .. 4)e.A-P'*-5"'%..:*.0ti
,J;g!+:.,A *u
* ~
s, y ....
*b (,)).'/ s .p .
.sc Git . 4 y,.- g.r
. . . - B ; . >., .- .
e ,. : 2.=
' ,..;,.' ' ~' -
-s .a .
q... - u
- ? -f . ,s.T O .
; ./.4 ' - ' - , -
- i.
' H COAT TOUCH UP . OTHER _.
,A i
-t;-
.-m w w-i
- w. w e,w
- t
?. .'* 7; 9HtJ :tt t F + .'
' 0;.
w .mu ,
- . w:.y.r M 'r .-
'-[- -
~
,a ..- m.-
l CF Ts l.] Il
' 'A
.' *)
. ) ,1bd bb$b NFer i .- :~Ts WF Ts
.. DF s WFTs ': DFIs WF
' MIN. MAX. N 'A 7
3-l ?.%. .fr i * $1N. MAX. MIN. MAX.$ ' M:N7.' MA)
, MIN. ? % .* N'A , ?.1$. .'[ ,
N. MAX. MIN."M X.R . MIN.I M A) 3 GEN. PRIMI %. - L CCAT l 1ST .No:- - f.iSH COAT TOUCH 'UP ,. OTHERet-EXP.D TE~ t E DATE r AP_ b IE EXP I lgfcw [A TI- EXP.DATE' EXP. D ATFi
,,y7.
r ' .. g '.. F. H NUMBER 4 3- - 11 d Y N *% VT: - Dr.P,C A 4 " .g ' T_.5 . sY V, f" _ .P. D ATE EXP.DATE EXP.- D ATE
-n W t)' < R4 . .
t APG* APG'S - - APG*4 4 . .. . . .
..w e gtsamseet C" ' ' '
JR CODE COLOR CODE COLOR'COC
.' W +
'. ".' 1E . . . . . . ], . .E '.D W!N.';
I.
'j
*b * ?"
l i. i 3 '
' i .: i On I *
']S. ' -
s .D a . s40
- i, ' .> ",j't. ..u i_. .
- v. .
O S .=:4e ezO Srd
. 1. . < E S l : '. .
'YES.+ )
Y.ES, ' . 4 1-
'.-.. M
. r .h , ^^-
,d - Y. E.S..
NO X NO N
' :. NO -
P3 , ,~ . . S i
~
l't '1b -I
' ej i , .
YES ",:
. Y ES
....-D .-U
'.'N' NO ' D j .-2 N r
s '- EXHIBli /f aw < " *.#. #. "
> a . M.
g .p,, g .r+^ . 4%m :m HHHS u 7*. %MLite:=' r MY
A*.JUaOLIDEW8-MM'=am
*ROJ a. . . . Al4 Fl -
*
- APPLICATOR'S SUPV_' A - b A b i O L_ . J;O. NO;
. p, . . , ' r .' e u. :..; n a :
l'J-0 M A :-:t;7 M
- W >Tl.:,.s... ,_= ;.. - -m A:MNTe;4 %*Epgf DENERAL .,$EALj J.-FIRST, . 6fNISH , TOUCH UP:. OTHER 4EASON' FOR (REPARATION . .? PRIMING COAT 4 FINISH '5IJB$UR 3 0 COAT. '8UILD UP -f Jami. 4 1 -
g SATE- 4."tg;p'iWp/g ///*fM .*
- up .%Q.q <..','g*,j a .
g* , 7 ff?
~~
.b.:.K IEPORT NUMBER:" * -iN;4ML'[// D "'S~ ~.L rid /[ 1 'PQ._ - W ' *- ~
' N SHIFT: .~ D *- e= A M k/88"E Y' / Q'. '
' 7 -- . j - .,a- . .
d '-- SURFAC.E.TO 8E OSTAINEDd 1 ' :.
. .; !Tg pt rsrd > M' 'a'.* "
f//0 SAT. 'UNS. SkT. UNS.
' v "9 ' ~~fM'Li 'i
~*
.d UNS. .
- 4. "
1 W' TNS. SAT.UNS.
'OBTAINg_
""" "T/ - .;' -
SUNF ACE "PR EPARATION - - d.7
; ~
- 5. .--
' ~
qy WETHOD 'OF SURFACE PREP: gf g/,A J.U ;'"i f)is m 3 );"F*',% - A SPECIFIED:
~
CERE WATER AND.plL; FILTERS USED?.: - .. # *'NO M ' ' ..I. . . .. . q't .' . N
. . .. . a _; .. _
s . , - p w.'.?,'."*:' .f... .-
'.'G.
. ROUT, F I N. IS,H: ,
#ERE;THE,Y CHECKEQ REBULARI.V FOR_ CLEANCigSS?,,,;,,YES_%gO
, ,g.h g' SANDPA gPTpTURE
#ERE' THE FOLLOWING USED? , ,. " . FORM RELEASE AGENTS:. -
PE:- - - - - jF pg - 7 ,I ) -
~
5.~. TYPE
.c.. *[ CURL'NG / HANDLING.CO POUNDS - .a.T r QuSI,b 6"
.(.. .j q . , GEN. PRIMING SEAL COAT IST FtNISH-""F4NISH COAT = ' TOUCH. Uw-..voge _
8AINTING SUPERVISOR ~ i g . g a n /s - V- _. ((_. Aan /ss -N ~~-. v S,- M-* . t ., . V-
~~.
3C~ INSPECTOR : - i /n 114L __ " ' * ~ ^
'ld'n d% "M** 5 - --
_~~ LOCATION AND REMARKS: !' . A~ '
-d1.,iY' J.E . '
- - ..-, . .y O ' Y ? .%-? : -
., _, ,..., ,.e : :
- a. .14,,p..%.;3,,.,ie7=,gs-M..) ),Ao s -
r (. 9. x. % ) 6 Y.. m , k
. X s. .. .
T c. %- . . a.~; .a. - y. A. y 3-t/N
- 4/L 3 ' T , % ' d o o.. -
x-OfQ?Q ,
, ~ ~K.' _
. m .+ ~ D .t. ..
n v.l. ~y. ..
. -l. - .
- ~; --
%y 3 ATE: ^;~. $. . , . . , , , , .. .
- \
_GEN.g PRIMING t/.2 7 . P ? SEAL COAT -tST FINISH (. b .f f FINI'5H,9QATT.TOUC$UP
~
W . AMBIENT TEMP.
- M ry /, * *, 'f f ' -- ~
h .f
- SURFACE TEMP. - -
.F ~ ~
~
~~
~ ~ #
- d74( #
- DEW POINT: 'f*3f -'
--1 go# - - i4 ftEL HUMIDITY: ' ') ~*** " 7- . ~~3
//ko1 -
- -gg -- - -- - - -
~ f- . '*
DATE: '! J.,/. 2 f,. JP _? - ~ ' f':f9 f 7- -- "' - r*'" FILM THICKNESS R E ADINGS:
'G DF Ts WF Ts O "'A 1. &-& -E -O .- O C--- G E DFTs WFTs -OF Ts -WF-Tr -- D F Ts WFJsi-7.DF-Ts WF OBTAINED- ' MIN. yMAX. N/A ~
MIN. ADt-@l N. --M AX. --MI5;;MAh, 'iAff." UN SPECIFIED: glN. syMAX. N/A Mgh t AXh- hibr-- MAX *]vi MAdhg]A? GEN. PRIMING SEAL COAT IST FINISH MINISH COAT --TOUCit 'tJP J TR O ER""" EXP.DATE EXP.DATE EXP.DATE E X P. D AT E--
- EXP. DATE EXP Daft PAINT: N~ N ~M r - **. /'E*IS*E' N * * "
BATCH NUMBERS FI/.T-T-88/ *
- 7 32.f-8 V " , * - ^Y d
ACT: EXP.DATE EXP W /rfE -EXP.DATE 5EXP. D ATE -EXR,DATE EXP. 9drFE
~
* ' L et. TY-e191*r
~
& 1. f.' S ( #Ye #' -
-- - ~
APG* = APG* ": / APG - - :APG* REDUCER USED .' . ,- PG * # '*'~ -W Q3q q pef)( _ f a M - (,/g y y -. - . --
. COI O'R C00f COLDR COOE ' COL'OR ' CODE
' COLOR CgE gpg~DE COLOR COI COATING APP E01).(
- ~
. WJ/f M kirke [ *"NM tjge/vtr/Y ^- - '"
~
e a
-@CS OR *OS- @OS R E s : D.R--
COATING EQUIP. , S- Bir
-O &,i- E s-~8 OS TRIAL MIST.
- D ., 2YE S * , [ Y,ES se, 6Y.ES-- . MES - i- [YES i.--YES -
DEMONSTRATION- - i 4+70 i NOh J84 8
'NQ C NO NO 4* b, MES h- pNOES ' .
APPLICATORS ~ ___ OUALIFIED .-
- NO
,,,, YES NO
[ YES . g YES 6 [YES NO . NO l NO PAINT CONTRACT SUPV. ~' [./w ,1h,,,- [_gd d - -*
~ ' ~~ ~
- CONSTR. SUPV. . - '. /{.8rtn11,
- d M , /4, M 3333 3 ._!# JR'""# -J ---
Q. C. INSP.
,a-
- M h% . -
. c' k y{ Rah '= a -
ruuma -;
*AOOUNT. PER G ALLON B/BPUSH. .S/SPR A Y R/ ROLL
O l 6
, STATEMENT -
i PLACE: North Anna Power Station e i DATE/ TIME: 12-5-84/10:15AM i . i I, Willi"* U""i * "* H*i' l , do hereby make the fbilowing voluntary ; statement to Robert H. Burch who has identified himself to me as ! an Investigator with the United States Nuclear Regulatory Comission. I do hereby make this voluntary statement without any threats having been made against me or
; any promises extended to me. I reside at i
I have been employed with Virginia Electric l b and Power Company (VEPCO) at the North Anna Nuclear Station (NAPS) as a Quality
' k W ON CtrNked Control (QC) Inspector since September 1980. I have inspected 4 1n the civil, elec-tricalandreceiptdisciplines;andalsoinpaintingandcoatings.Theonlytrain-ing I have received in coat g inspections is On-The-Job training at th APS site.
M des IN projects on which I performed inspection work at,M
,e do> Cag eed A*yo*ag fysbors i
is the coating of the[ ventilation ring ductwork)$ in the containment buildings of j Unit 1 and Unit 2. The unit I coating work was done in December 1982 and Januarv 1983 and the unit 2 work was done about April 1983. For the most part I was the
' & ca.wKt**
- full time inspector on u it 1, assisted on this project by my entandneer. Bill Q in2Ateft/ ytaf dx{wK Coehag m Berris. To a lesser extent I N unit g 2, diy assisting Burns on this project.
As I recall my supervisor Jim Smith informed me e that I would be the lead in-spector on unit 1 but I do not recall if I was designated as lead on unit 2. I also emember that both jobs were completed during an outage and there was Loce
! @ cdjency ; assegedegcommunicated to me to get the job done within the time alloted forWavht. the 4 anddJGaspassi I recall that I had several discussion $ WKe s with Bobenphyn Bauler regarding 3
- these projects, especially on unit 1. Bauler was the Coating supervisor in the l
' NAPS Construction Department and he was the person actually responsible for getting the job done on time and in the proper manner. As I recall, the purpose for coat-EXHIBIT. /9 PME / of S' Page / rd f Pages
ing unit 1 and 2 ventilation ring ductwork was to eliminate patches of boric acid corrosion that was forming on certain sectio f the ductwork. Specifically, M MmA4du 64 with regard to unit 14ductwork, I recall Bauler explaining to me that the decision W Jgtbne to coat this .was a temporary one and that at some later time the corroded sections would be removed and replaced with new ductwork and parts as required. This conversation with Bauler occurred about November 1982 and I remember that he told me that the station maintenance department had approved the temporary measures to correct the corroding uctwork. In my opinion Bauler a$ did not emphasize to me the importance of 2 c$t oating project and as a result I 4 did not perform my inspect ons of this work with a serious and positive attitude. W /4 M. frerb Mdas# I have reviewed the Protective 4 Coating Surface Preparation Records (PCSPR) for units] and 2 and I have identified M certain entries that do not W enddrede* accurately reflect theworkIperformedonthesetwoassignmegs.Althoughatthe 4 W Cer Wfi 4 U time I signed my na=2 to these PCSPR's I did not realize that I was AtidWddf4/ k Whib M work was nperformed in a manner other than stated, however, I now realize that by signing my name to these records without verifyi.ng that work was performed as stated is a falsification of records. 'I did not deliberately or intentionally falsify these PCSPR's, however, I do acknowledge that I did not perform.the necessa verification in all instances as required by NAPS Procedures NAS 1016 M and N hi4 QCI 11.1, the only procedures which were in effect at the time dierdgEd4 the inspection and/or application of coating materials in a containment environment. With regard 4 to the PCSPR's for unit 1 and the information contained therein, I did not actually witness th ainters cleaning the surface of the ventilation rin. ductwork in preparation for 6 coating. Due to the contamination involved in this process, I did not observe surface preparation until it had been completed. i h used to obtain an SP ANl Nhough the PCSPR's for S t 1 state tb w ont t a grinder was 14 uW
# 104 surface, M not know M method was used to obtain this type of surface.
4 N An SP #10 surface, according to NAPS M procedure, can only be obtained by EXHIBIT /f w
- a"w me g./L
Y .
)
6 which is prohibited in containment. Although I certifiad that an & SP #g0 surface was obtained by grinding I do not know if this is true because dP fdidknot obserygAn$m )nnymehne. W M In my opinion and based upon an inspection after the surface was pre ared, I believe the surface was of SP#10 quality. I make this statement 4 f $ d.t/ opened based upon4experiene rior to this M with this type of surface. To my know-ledge, a comparitor scale was not used on the unit 1 or 2 projects to make a deter-mination regarding the type of surface obtained. Basically what hapened is that N tN \ Bob Bauler, Construction. Supervisor told me that the surface was M SPfl0 W and ' N I took his word for it. IM assumed that since Bauler was a professional in his job and had the best interest of NAPS in mind that he w uld not provide me O && with misleading information. In reality, I accepted what Bob M told me about surface preparation signed my name on the form and intended for my' signature to snet%ef M 6 ess6in ihr 19dM /krtGN. Zeht / Ant' 0(r f*. mean I had verified the 6 Also,with regard to temperature entries on the PCSPR's, I did take some verifying temperatures but in some instances I accepted the temperatures as recorded on the PCSPR by Bauler and signed that I agreed with 1M Z Win *' /JW e4tAhff d's dhil. and had verified his work.4 I did not verify hisJMdirwork in each and every instance, although I did do this on a number of occasions. Again, I was lax in not M
$ O hnnyst $ M fo d'iaf 4 verifying Bauler's data and $ did not perform my duties as an inspector of coatings in accordance with the procedures which were in place at the time. k'ith regard te the pri=er coating used in unit 1 on the ventitlation ring ductwork, I again was told by Bauler what had been used and did not do an independent verification. As !
M recall, the paint buckets were all marked with M Mobil Chromax, meaning the & l M M r d e diff p e l type of primer used. I did not verify and confirm as to h whethey this was g the l ring @ W QF l type of coating used to prime the unit 1 ventilation /M ductwork. %py signature on the PCSPR's should mean that I did verify this but in reality I did not do so. The only reason I can think of as to why I did not verify this is that previouslyj k JrdPdd48 Mhs % t(se/ Mien M 88I 4Bauler had minimized the importance of coating gthe ring ductwork, telling me & EXHIBIT /9 Page 3 of 5 W
.1 d1'
%ng;lh it vu o tstporary corrective meesuro @ reth2r thrn c N I supposa 4
S atWJ this caused me to have a relaxed attitude about K inspection process regarding the unit 1 ventilation ring ductwork and caused me not to approach this in a k I W approached this inspection [n, serious frame 4 dit 6Imb, of safA4f
.6/eet mind. 7I recognize now that hh kh A
and did not have the proper frame of mind. I also recall that4I gave some thought to the fact that the ventilation ring ductwork was constructed of galvanized steel, a material that should not have been coated. I did not express this concern to anyono ~ at the time and thought that it would not matter k OnNe9 since S was going to be a tem-4 porary action. I was also aware at the time the work was done that the NAPS Engineering Department had not done an engineering evaluation of the project. I did not express this concern to anyone either. I also wondered about the safety aspects of the coating project since it was be performed in a containment environement, however, I did discuss this auf with anyone. My inspection efforto-on Unit 2 in April 1983 were W much less extensive that those on unit 1 but I QY gh4f # N I A could say that my attitude and my approach to d er project g and the methods I used were the same as for unit 1. Again, I did not deliberately falsify or certify to inaccurate date, I simply just did not consider the importance of making sure that the coating materials were applied according to the existing procedures. The reason tdN dhd 1 I did not consider the importance is because Bauler had previously S Nt,me that 4 dAg M sitnNdPden all of W corroded P& ring ductwork 4 would be permanently replaced at a later date. I also did not consider the safety implications of coating N& a galvanized steel surface h lossA of coolant accidant or DBA. This aspect of safety, had I thought about it, would have caused me to raise a concern immed-iately with my supervisor. I a= not aware that anyone else, either in the QC department or construction department, considered this aspect of safety when the decision was made to coat the ventilation ring ductwork in units 1 or 2. I was un-
& g)p,Z)mr$vneefM405'ebdel aware,that paint peeling from the vent ductwork during a LOCA/DBA could clog fil-ters and screens in the cump puma N I am now aware i
of this possibility. EXHlBIT /9 Page V of f Pages #
conting In conclusion, I would lika to state that I did not parfore c:y/incpsetion duties on unit I and 2 ventilation ring ductwork in a professional manner because I did N not take serious the 4 deer nature of the work. I also allowed Bob Bauler to use me in an unprofessional manner. I state unequivocally and steadfastly that I have never performed any other inspection at NAPS in the manner in which I NM performed the coating inspections and I have never falsified m .QC document orulif e entered any data on a QC form or report 6 withou An N OS e it as being accurate and con:plete. I regret that I failed to perform thesgcoating inspect ions on the unit 1 and 2 ventilation ring'ductwork in the manner which I am accustomed to performing all my inspection duties. To the best of my knowledge, or management 9 / fR I know of no craf t/ personnel at NAPS & with whom I do not relate well and I can think of no one who dislikes me. I have never made a statement to any painter or anyone else that I am afraid of radiation. I have never shunned my duties in e, containments because of this. I respect radiation but I am definitely not afraid of it. k I have read the foregoing statement consisting of I k _,,/ typed pages. I have made and initialed any necessary corrections. I swear that the foregoing statement is true and correct. Signed on /2/6/f4 at 3lb'f* SIGNATURE: NE/ZEnt b_t A/QAAM NAME (/ Subscribed and sworn to before me this day of cemkr 1 84 at h $M&e8 f/. . INVESTIGATOR: NAME WITNESS: NAME/ TITLE EXHIBITM PAGE 8 0F [ Page 5 at # Pages
i sesed l -@ p 89ng . **
=
l
~.. .
OZ lf8tHX3 s ~ ' ; a o G,_
* '~'. ,..
~~~ i l
n
/ ,, . -
i u .o a l :- EI! g
/- <;j w
' # = I .
g m ".
/ ,s . :
- [
a: : e i 4 . . . ,. / ,! -
; i
,l e ag:
_~, l:el
* *==* r*
, , !! d">:r;si. .e:;-
w s ,., . ~
\ -. N- =. w ,
. s a = ,f..
m<it
.2
- . =Le- se I =a g!. .,g, s-
*a /
u l, u.en,t,
- ,w .
.- = , . .g w ; ,,
j
- f:.!., s. . ' - {v.s . s caza y f \,
* /f.- =II I,
.e 2.
vy , e,
'\ i *I . lJ
,- 8., .sh 4 . .
ge
,/ j .
lw' - y} jj
.. 1
% \'c. :- sl 1.,- ~. s
,i i j 'N l.is i$ . f% n: *\ m., pQ{<f,N I t
t ti -^ ,, s'- , . - l,* i .- ** Q,* , L o ,- j
$ jl , .,.*,\l,)..v.e.
e ' j ' .* ,,- . -e
- >ug n nlf.lg, !
il i
\ .< , / .,
t . . ' i.. , , , e as
- s. s : ..u- 1,s .. . .
; i .
.+,.
i I Ly t , TE .t, .*%
-5
~ E
/, ,, . s J
.~:- . ~
~
"'E# ' t}_
e,, , in j .l ,
*j' ,~*A .? k , j ., % _)I k'x
! y x ~~.. a y
; .~. .-
s l - l 13
% 'st i v-: . m.
8-
.. +by
.2 v.
/
- .v e.,
x y s s 8 '; , ~\.........
.t s
=
q r-
- I 3a j
.i> ' ! r - .; r b,nig J ',$ ' ' '%. .-l -
1 - N! .
- . y k
'k
{iRmit' Y* Y- --I t* d e M.4, j i
,s { ,[f0 Hu sI I y. i '-%,T,c,,.I.. ;..
s.. . i e i, , s
,4 g. > 4,a s , A'v 1*-,. ' 9 ry .w 4
i 21- ,q!:;,i .T e
\
St
, .,3mr *'p .- - % .i, ,
.s
\ \ ~!g-:
i - a ,:- 2, . s.y ,:$ s s n y~ .
\
- t. g#' ,-
y. e.
- -- g .:: ., ,.
a Wa.
- a. ., -
,..i.y .
- 1. ,
a , .i
...~ - ~.< e .s s ..
e
,.. 1 /g'. I <.-
s
. ,v,
.. . , .~ ,
, ,. i.
ef.\l11 t l 4 :'{ W' j& t.
f.a s'* . \ ? ' '
*' L l$* Q :; 7 1 j
i
)~ s ,ll.' 'b,. .,
j \\ i k, ,$_ ;F [A s
!! 6 [ R O 1i E.
- ]@.EdS
.E @ "'
'.s\ ~ 's x\ s' LN' % !sin(4,- .4,
'.4t '> '. N '
,- i t\.D\\, s( \, i'D ' .',
k i' .. N 2 llq!,: v I fg[. ,!
~'.!.~ % ,
l F Q , .
h;'n\ w' '
. -' y.. s T , w. ---$
t( j .
>>.. : s .
.
- a ?
-$m. g .~
s f,k
} ', it'-
- r l
,s ,
g ap g
',$ ,j Nc .
$,.;f. ,r p..
! - ~
.j .. s.p I
!!i..k..'
- %m.. *
. . . Q rg Es 3
-o ss
., y 4.s ,
D = , -- g <; .
i? l seg l
-a?'& , ' - ..
' T wy , .
t.5 N' .C /Z Ll8IHy3 e f Zu CD ca s.L - ,
, .. 2
- )
l
- - 4 :: I
<i s j 82
.s- : ===
. , ,. Uw* h N.
s r 's.s ',.\ , l =w l r
=g; i !.. N. s l
Ae i N- ! <D,
.r 3 I.
N N I. =g l, l'5
- 4. g xs N L ;.
- 7 n
y .- N .*x sm s:
*: . : a
- - +s . x w.
- s VM am
=
= x sn* 1.
ig. Ex gpi se y 3 _ l; c a \p;*-[s!~"at..g\
\
k. i 1
, y \
Ei, I t. i w=8 ! ll \ a-
! I=IJf ji t -.:f..s..-f. \ .>
n
\
- a. . ;
,4, . .-
s is e 9 ' .. -
- .. ~ x
, , 'sj;
,. L. , s. ,U, t . ^ *
\('
-f -- g
. . yl \ \
I O t\ I &y f!!![E I a. %
'% \s. 9.,1
. { ,A! .
j' Nm h ? I rj
- r
-t a
h>i
~
$@p-,.s ?!%j w-.21
* < (
.; % <.:,/,G] 'M y
3' ,: i%g:
~! . - .
- 4. .'r .
'+. - *-
a l 1
- p. !;k,j(.g,x,
.y-i i
; '~t '. A~~ % ); '.'.g?i !
- - .s
') x% .t
.g..,
'yfy& f TR. k.\ ' g/
~ ,
' ' i ,
la - - II ' ~ s.lh Lw. .s i.- . 3,.
,., , .. g,s, c6 ./ _/ .
;;. g. . . .. ..
/
u.n
.t j ;... ..
I _! / s
. e f, '
j -
) . - s
/
- }
s' '
._l--
s '
\ k .
I e l s i
- n. .;'.' j / - ,
e _.g? : _1 . L 1-. 1... , pV
).
n
.f 3
\ h ..,
- w. t . ,
T.. , (s'I t { ..- .- .*..
.. 1
.- ** 0 i- 'p g
~'
- y. , . ' "_
.) e
( f . - . . . , , , r- - -T-- m --e - - - --- - - - - - - - -
PPM-8
/' Attachnant 7.1 Page 1 of I 05-05-82
, REQUEST FOR WORK MPP SUPPORT NORTH ANNA POWER STATICN UNITS 1 & 2 l
TO: HPP Construction Superintendent Date:jj ,, Unit No.: 7; Station Approvpd : Account No.: M S J Hi 3 s1 f.2. 9/8 Mf.?' gns for Date Project No. (Station Use only) Q A A - lYO' 57 $2 /&n / fUti-Dp r n y g t. Designee Date Station Project Activity [ 1 Code Code Code No
/ e / /z-n-A z__.
Superidtendent Pr yets/ Des. Date QA Approval:
- ME i
Description of York: fes,ea de, /a dae r- ca ,,,,a fe, .ry,,,, f,, ,, Qa, y / A c h v s-se l A e d's pa r'/ Z Aek e/or &" A'k *
/'r*]
m e f A* re = re d is I ** cayce: l j N crion Supe tendent/ Designee Dhte MPPEtinatedpst g f r.a or 45, oo. cb zat, .e A,,ro e Materia 1 APoo co l
- Supv. - !
- Greater than $5,000 - Station Manager or Assistant Station Manager l SS,000 or 1ess - Departmental Superintendent AD U V MAJ- . 00 0 Work lated:
e ,, n/w MPP Constru ion S4 rintendent/ Designee A i ss-
/ DInte l W Y /A b )
Station <oepletion Concurrence (Ongs.nator)
.2-M-93 Date Distribution:
Station Manager, Asst. Station Manager, Supt. Proj e:-
@ lS$7, 8 2,- Station Accountant, Supt. Maintenance, Supt. Ope ra ::.:
Page /
,4 1 p , Supt. Technical Services , ' Originator, I. abor / Cost PR::.
Budgeting Dept. OJRP/5 i
..g :
?
r., .., Mtl'saEI ,.: D0 3 -,s w 1. ,,4 4,
. ee wenm ' ,e u. e m ,,e u tesyge.ea e Peeensra s
.* *
- j .' *
. ] '- To Pf?V ?? s*mrn0gf
;'s T ' A 's NAT 't?:' CnVEPCI) :'I TE s
~ .
s tais seaeat ' E. I ,IU
' E weet.on De*e a Swee.as B a.o oSassae.s Pts ed !Locanon 5, T.
8 Dec 12/22/eIsne 1Js2s , $,7 . . = ! . . ' f t :t; . J measese' . Tec> Spec stea' A feen Sees See .44 so s
' I' Dene Tsee peugnet see 9 oT 4e .a .* ;,; i ,,
Date FA Tone J
,p Res monnaaes To teswoo wenn . EA peanas to totende 3 Dr ts ass.Dese,aed To essous speen MA Messg to N M $ h. Osw Am Team }
n ,ase to sma Des a ga .* 4A aci a e s .t.a.ssa ooe+ Rosen
, iaia we ca. 1 * / 2 .' t, e sito
@es, % n 1. .
. Alt: Mama
.a P"*'
. 'a y ff re ~ a=ena,*r,c,ui, /s. % es'~ ,/,,;u
.+
=. usse p,,, ar ... , , , ,
/_, . .:
Dem i
/A Tanw gpg a w .v M
m.i 5 to na-- % t er . _ d naaerr. a envirwens _7a-wo mes er Ng O seeseis casca nooi. n . a .u.eese ino esse cce in. r
- 2L /j 2/.-1 -_ i i, s'_ / M . - 2 *: .
-- u ee
'" M _ : u.se ,
4 essese a see er tagras m esert e, oss twar
= - . #et= = o ee s.
0**** euw seen h amasse w ses per e messr
-* /[.J 64, * - "'""' O" "'
1 M/N1 Tasao7/J
- - - u - a a, .,.m. . . . =
c a t ,- / t , - 1. i m .a m, t . . .3
. t t t 1 e i e I t I t t t iR R I I 3 a R 3'3 9 it t I t ia e a r 1 I t a 9 1 R 1 0 & RJ dh N unse (p" weasesmeeran " hei y " sensi see " vesse mese ses vases M
~
t' - _ge . 3 8,, m
' d "
,Jg
! yno E1 _ -j .g I -- - EXHIBIT. 22 . i
- .,c,- Z- rd
** MAIY A , ., Page 3 7-
~
's [I G, .
4 '.e "n ,, i
^
,g.
^ Ceeb"_ , ! teses esser.T'.M 'hM " '
- 45. re cour - - -
- r. . . . - _
.. 7 ,.
s.
' ' - - m . .. Lit d .,,a >l g
, , Ee., '
- .s
.. ~, ' - .
4,, "* n 6 4 ) i. ftt,i. . 15 f **'
.%, .' )w m,3.,.. ev,N h.,-
? w=
s .. , . g ree e s . 4 p
- s.
- ws - -o .; . *, .s
*~ '
?, '... 4* A *E i ' .
. *-' ,s4'. f.', ', '.:-e ','
l , - y- :r *
.t.t, . * : ',;
\ . (-. . r .; sr.. s'...
- bl '
~
l .y ..);h '. 69 . '? Y: COPY I ~
-a *
'b 4fB %*
'. ^
.' ; .,L .. .-
N %* , 4 .. 3 '[ *
%.2 4 , h ~ ; Z %j.-_ 1 ,
a 7A'
- F
.1 J
_D .g. samoren unse g ouen we l aers put es. I se.,%o lvmosex.No l <ac so we Eg.l. ' i 1 1 1
-r '
I i l '. , , j
- l unee ' ,idlT 2 E , _ ___
F a .e O' - :'- ' I'*" 1 ~$ , a - . _ . _ _ l I _ d s 1 l l l 1 1 3
/ g i,Q ' 3 N' ? ,_
fi VEPCO NORW ANNA P0WR STATION 7f' ggg gy men eso C2'02=9603008 Te scopersmen.n ' CIClab! CAL case.esas.en sogg!gg syvem SLDC " - - FAE ***'*** BODE D'****** EA pescr.,e.on ne 9 oemm FA!DT TMEa10! 0! COET&!DMERT RECZEC FAE DOCT WORE e s a sawe esecee 8 LeM m AC2 eis.as.en 291 assait 3033 { sw6m.tsed Eo BilLES B.R. " C'** 06/02 8V'* SSE%5 A m e 5008 S* COLD 889tDOWl sere ,normeat 30 toca seesstemt 30 fecn sees esa 3A g*,y'** Eg== " ( Dean " me i= Freneet Nc 801 Agg!gggs i, go , mens i. Nei nosurnes te ser==e w.in.n
#A News se en asees 3 er Dese SA tame 34 is gau,pmens la Not Returned To Syvese Wnha SA News se in asene a ey Osas pg fame 34 yg re m'=e't.et" na se., rue se f ' L *" se An.n Sweervoor- StJAf A.Ce Does g/s2 Tms o
23 l Comnen<s I!* r nveras = --.. av r- amo n:T nasemiaa ns /
;e.,.2e.
. .- o.a. yo ,- -
1s
- e. as.e . s/s W, Tee *A, EM* 'CNe M ""*tS4f Jf/ M . Ovm 5%
Je Ass ,ee te pied ae. asseine er //pt.4 D S. es= 9)M%.fineogro
$$ Nh 1
!^;L..? /Nua "*a 4'4 4 i'='s iW6 ~
TO M aa*'fTED tv osmetesEm 0F_W4ftff. 8 h-=4 Tagging Wer.foo Sr hM
- O Casst some hereneewes a uns The Seat Of 78w Form al teo M e.1 A O M lh-S ab ^ en =ff 0 W*- __ u .
wyg p'"k,.,,og hDLA q. KLpJL,'
"j Piecedwesa used hh* 'fene gewlennen 9ene '
e .,e. come.ei.e . - . . e, [ Aree Casened Or sowiement was
$lP/p/
j st.shers Aenesee DCja ve
- mee
.aoe,,
0.a 'a '( ta.a fvu['I / Beciew Osorstae
Dear _ fans Teest S:
,_Tay,s g Howe Ons The edit Coues e Pouer Ass,.t.i sa $ Emeses
- meat
.m u ,,. .
(#4r M 7adweag - of MOFw v- a Y f#w. i i i ! - a..........m....4..........................e..'..v......................
- u. - ,. u.es " g;*,," O e,:'
- i 1
uen,es ,w w. es., = " e, ne " veces e.em =" ve, so . . h aIn ah dd ,
--~^ "
] .. a.w. * * *
- _ _ _ . _ . ...o Mrh ,t a "" . --, I kh sj ;*,- ! Ale . '
- DEc.s . GMY I 84y
- l l
{' *. .. ri.p,y EXHIBil . 2J l Vage MA reso P_ _t-A m Ceee IHa Sesek. F8ees Osser, 94teses.& Sedn't to temen, 44ters Oeuer. '
* ~~~'
;rses.L'*"~'" M & .. N d sInl n "r~ 1. M ~
& *, - A . si O 4_)j, ' ' "D- p /
~
"\ f1
- ~
=h -
m*
.- y- , - - -_ .,,,,__--_v,_.- _ . - - - - - . - - - - - - - - - _ _ . , , _ . . - - - -
MEMORANDUM ' ' ' d oAL k .a - 9ma % or , . :. d%4 a ,, t4
,, u 4_ Q.4. L cL
,,,,, s.B.ca L.Jr suestc7 *NT O N CM kk wov/ fEc o G4k . T Da< cmed o. c$ o c u m e.de. Nod l l ' i h cA. f.a u .ea a, .ae, , .M, ch e a .'. c e a__
cleter mba.M. o <e ieds el b JL. .na.,A4,h. i e.l 4tte 5 Ou;L L ud 2-- v.'n a c%ch sk s.h w ha .'n .,- c4 4 les 4Le oe,ied h c. i482. LA<o es,L. b gusb iR t3 1_ wa.6 mk o.Me %e, loc A a.o.i dee.omedd i en ed ee < .N darla io~ vst a_4a.J 4e th6 Ie ps'c dov., An i s . i 4kis 4me La.me .
~"
EXHIBIT,2(% Page / rd / 1 Pa m - isis.r:: OM ~ Lh s 6 C.=v E - A
- w. newcr rou caus sr vsma ruas rone. ruirt utssact n toknaro. esisc rocn..
v.. .. .. 3 Q Q v i e ;i e.. a t tc*m*C a=0 meste : veam-
=C a * = a asse a a:s t e l' a o w y(, b f ,' O.503 402 unseg m A L, vin ciass a 23 tit August 30, 1951.
U. S. Nuclear Regulatory Commission Serial No. N-84-014 Document Control Desk N0/RCS: nih 016 Phillips Building Docket No. 50-338 Washington, D.C. 20555 50-339 License No. NPF-4 NPF-7
Dear Sirs:
The Virginia Electric and Power Company hereby submits the following ' License Event Report applicable to North Anna Unit No. 1 and 2. Report No. LER 84-006 This report has been reviewed by the Station Nuclear Safety and Operating Cotz:ittee and vill be forwarded to Saf ety Evaluation and Control for their review. Very Truly Yours, D p E. ='ayne Harrell Station Manager Enclosures (3 copies) ' cc: Mr., James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 2900 Atlanta, Georgia 30303 l EXHIBIT 25s Page Q g g
"1.-""
. .r..coom.oea_. J UCENSEE EVENT REPORT (LER)
- c. ... .. . ..- ... . . .
,,,,,,,,,,.,, occa st %=e s a .s. .m i Ner _'. A .na Power Stat: on nits 1 and o l 5 l 0 l 0 l c 13 o t 8 i f or'; i ...u..,
l Application of Unqualified Protective Coat:.ngs on Conta:.nment Ventilation Du twork ovic navn e i um au=mem = j ...o , oars .ri i ovos. ..cisais: vos.so e. l"Uf,U. " ca. .pa **c-"**=** occ= 8' %.esa s
=c=-l o ,L ua!'u= <
'f.'l7:l =c='-
o1 5!oIo'!o a i3 9 O jo 0l8 3l0 8j 4 8f 84 0l0l6 ,,,,a,,,,, , 0l8 0l1 mis aeroc e amsirvio .wam.,ac to n.s asou.asmace o io ces i <cw
- _ im
=ese 3, 5 j , .,,,, _
.n.,,,,
,3,,,,
X m twion.' 71 rue
,. I massawins ~
e as**ni
~ ~
emsa s==
"*E,. O1 0; O m an=uinsi
~
es.mi e
~
strsweaan ~ m as..n umi serm anu a rsm an.=nas 'm~mu~ ~ ~ '~ ' * *
~ ~
~
a me. .n ns.. es rawanei a rawan eiros a Welfinst a tsissallel a raneeQ1tal sJCtesE S CostTaCT Som vise .3 m .ttb TIKE'*ohl 9We.ege anaase masa caos . E. Wavne Harrell 7 D 13 81914 P- 15 l1 15 l:
.m sm .si.. . uc,.e ri.- .. % . o. .... .. ,.. . m x , is c;:c ,yac
~
- u. m. co - ..a a t;",;.*;;' u.s. n. co c.. r at;*,,;;;p .
I 1 1 I I I I t i I e l- I I I l l l l l l I f I 8 l l ! SusetDeItr'.4 eEPoet 8.XPtC?Eo ,ie asoarTie ! Dav ,g4e toa.'38'om
"") ,en w t ore ro ruen.asee= ca m 50 =e ; ; ;
r=.c-..=-..--.... ABSTRACT The Air Cooling and Purging Syste= galvanized ductvork and supports in the lower level of Unit No. I and Unit No. 2 Contain=ents have been ceated to mitigate corrosion. Review of Station Records indicated that the coating =aterials selected were not known to be qualified for application within the Contain=ent when applied over a galvanized substrate. Subsequent DBA and adhesion tests were perfor=e'd on test panels removed from the ductwork which verified that the coating did not meet the required performance criteria. The cause, of the event was determined to be primarily due to inadequate classification of the work and secondarily to a failure of personnel to follow site procedures controlling application of coatings within the Containment. The corrective action taken was to install a Type 304 stainless steel wire mesh screen over the coated surf aces of the ductvork and supports. The wire screen vill retain the coating material which may disbond from the ductwork following a LOCA and therefore ensure that there vill be no impact on the operation of safety related equipnent. Site procedures have been strengthened in order to prevent recurrence and training has been provided. EXHIBIT 25 Page 2 of I ,__ Pages
'.7: *
- UGkNbtt E NT MkPORT (LEM) ItA i GUN IINU/ 'UN mos easo ts n -
'N'yl.~.' '" . c . . . . ...m . . *"""."'"* .,
" '"
- l e*
... t
!";- n;: * ::.?,:::
4l I, 0 :C ' 6 l-l. 010 01 2.08 0 North Anna Pcwer Station Units 1 and 2 0 15 t o l o 10131318 81
- 1. Description of the Event The Air Cooling and Purging Systec (EIIS system identifier VD) ductwork (EIIS identifier DUCT) and supports (EIIS identifier SPT) in the lower level of Unit I and Unit 2 Containments have been coated to mitigate corrosion in areas where borated water could leak on galvanized surfaces of the duct. The application of the coating was completed in Unit No. I and Unit No. 2 Containments in January, 1983 and May, 1983, respectively. Following a recent report that the coating system utilized in Unit No. 1'may not have been qualified, an investigation was initiated to determine the suitability of the coatings applied.
Section 3.8.2.7.6 of the UFSAR states the general requirements for protective coatings within the containment liner boundary. It is necessary that protective coatings remain intact if subjected to the environment associated with a postulated LOCA. This section of the UTSAR also states the the coating systems used during initial construction were qualified by DBA testing. A description of qualified coatings that were specified for containment interior painting is given in Table 3.8-10 of the UFSAR. The extent to which unqualified coatings were used in the Containment is given in UFSAR Table 3.8-11. The UFSAR states that coatings applied after initial construction vill be acceptable if they meet the technical performance requirements for simulated DBA testing set f orth in ANSI . N101.2-72,
" Protective Coatings (Paints) for Light Water Nuclear Reactor Containment Facilities."
Review of the Station Records indicated that the following coating materials were applied to the galvaci:ed ductuerk and supports: Unit No. 1 Containment Primer - Mobile Chro:cx Red Pri=er, No. 13-R-50 Topcoat - Dupont Corlar Dual Build Epoxv Enamel, No. 823-Y-67632 with Activator No. VG-Y-6239 Unit No. 2 Contain=ent Primer - Keeler and Long White Epoxy Primer 6548 Topcoat - Keeler and Long White Epoxy Finish It should be noted that the Protective Coatings Preparatico Records indicated that the primer selected for application on Unit I was Mobil Chro=ox Red Primer No. 13-R-50. However, a further review of Station purchasing and the batch mixing records impiies that a si=ilar alkyd, Dereka 505 canufactured by Cheeseman - Debevoise Co:pany, was used for the primer on Unit No. 1. EXHIBIT. 25 . Page 3d9 Pages
LUIg}Ndfj [g av ggggg (LL4J) VEXT CORfiftNG ' 1N
~
ne==:.s: e-. s e s e :. siese et a
. .se e-,e . . . occa8' %asse* r,
, , , , ,;g ,, s *n.. * .,.. ** s - * * * * , Ass evasses s ,[ exe a
.s = i !"fi",**f i,'f ",iB 1 Ncrth Anna Power Station Units 1 and 2 0 15 l 0 I O I o 13 I 3 IB ll I 6'4 7 0 l O! 6- ' 3 ! Cl 3 !3 0 'l. -
w e .-. . - . s== sc a.- m .m The Alkyd primer which the records indicated was applied in Unit No. 1 is not nuclear qualified. The Dupont epoxy is nuclear qualified, but neither the primer or topcoat is approved for use over galvanized surfaces. Since the coating system used in Unit 1 was not known to be qualified, a Deviation Report was written on Unit 1 on 08-01-84 The deviation'vas deteti:ined to be reportable under the requirements of 10 CFR50.73 (a) (2) (v) (D) since failure of the coating following a postulated LOCA could have potentially prevented the fulfillment of the safety function of systems required to mitigate the consequences of the accident. Specifically, if the paint came off the ductwork during a LOCA, a concern existed that a portion could be carried to the containment sump. If a sufficient amount of paint . particles enter the sump and they are larger than the smallest restriction in the~ fine mesh sump screens (EIIS identifier SCN), then there may be some blockage of the screens. At the time the deviation was reported Unit No. I was in a refueling outage. Further evaluation indicated that the Keeler and Long epoxy coating system applied in Unit No. 2 is nuclear qualified, but was not known to be qualified over a galvanized substrate. Therefor'e, the Unit No. 2 reactor was shutdown on 08-03-84 pending further evaluation and implementation of any necessary corrective action. A field walkdown was conducted to verify the surfaces of the ductwork zud supports to which the coatings had been applied. It was determined that the total surf ace area coated in Unit No. I was approximately 8000 square feet. A slightly lower total surf ace area had been coated in Unit No. 2. I 2 l 2. Cause of the Event The work was perfor=ed under the Station Maintenance Program and documented in a Maintenance Report. The verk performed did not have sufficient controls. This resulted because, at the time, the painting of the ductwork was inappropriately designated to be non-safety related and it was considered to be a routine maintenance item rather than a , permanent modification to the plant. Further, the require =ent that application of any protective coating materials be conducted in accordance with Specification NAS-1016 was not adhered to. 1 li 'l EXHIBIT. 2A i Page M I Pages me t e t o w see.
, , , . . . . - -,...-----..-,-----,--,--n, - , .
UCLk%I!E E' iT CfEF6TTXiWTETCT CLNTINUt ~) N e :.8: s s . u :.e, ts.StJ S T Tl
.,eu m m. . ,c ,oon.8' wap +
j - . us an t ..o
, u=s !" t '.M .* ' 223: '
t ! North Anna Power Station *Jnits 1 and 2 0 f 5 i O l 0 l 0 D I 3 l 8 l60914 I O l-8 6 l-lO D0 l 4 (08, c w # , . .me=== =ac a== maa ., im
- 3. Evaluation of Coatings Applied
- Following the initi n evaluation, KTA-Tator. Inc. was retained to i evaluate the suitabili;.y of the coatings applied to the Unit I and 2 Containment Air Cooling and Purging System ductwork. The initial coating
! evaluation program conducted by KTA consisted of three phases as described l below:
Phase I - Field inspection of the coating applied to the Unic No. I ductwork to establish the coating thickness and identify locations which
, bracket those cpuditions for subsequent sample removal and Design i Basis Accident -(DBA) Testing.
Phase II - Determination of acceptability of the coating systems through irradiation /DBA testing at Oak Ridge National 1.ab o ra tory * , adhesion testing, and evaluation, of results. The samples tested
, included those removed from Unit No. I as selected by KTA, and . samples removed f rom Unit No. 2 in similar locations as selected by Vepco.
Phase III - Determination of the generic type of coating applied to the Unit 1 and Unit 2 ductvork. A brief su==ary of KTA's findings for each phase of their evaluation is as follows: Phase I - The coating applied to the U::it No. I ductwork is comprised of tuo coats (red primer, white finish) which possesses poor adhesion to l the galvanized substrate. The coating thickness ranges are:
- pri=er - 1.0 to 2.5 mils; finish - 2.0 to 5.0 mils.
I ! Phase II - Eight sa=ple locations were selected from both the Unit I and Unit l 2 ductwork for' evaluation. Four 2" X 4" test panels were removed l from each sample location resulting in a total of 64 samples. Two l panels from each location were preirradiated prior to DBA testing i with the remaining samples DBA tested only. After irradiation, neither the Unit 1 or Unit 2 samples showed any defects with the ! exception of discoloration. The irradiation also appeared to have no effect on the DBA results.
)
*:rradiation/DBA testing perfor:ed in accordance with ANSI Standards.
EXHIBIT.25
- Page S&
j
E -46 5 W
..ciw- a m . sac a r %.n e . # ,,, . .. . ; ,,,,;
, ,, ,. . .. .~ ,, .,2 . , . . .- . . .... p..qua-g;p J. c.y,p; North Anna P:ver Station Units 1 and 2 0 15 I O 101013 I 318 i 9 I 4 --
0 I 9 6 - 01 0 01 5.08 w ,. . - .- -. -- ==c a.- ap ., i m Phase II - (Con't) - l After the DBA test, all the Unit I samples (32 total) failed to seet the ANSI N101.2 criteria (no delsmination and a maximus blister size / frequency of #4 Few). The test .results ranged from
#2 Medium Dense to large blisters and delamination. Upon receipt of the panels at KTA (two days af ter the completion of testing),
i the coating could be easily detached as a complete film on 31 of the 32 panel surfaces. Of the 32 Unit 2 panels tested, 25 failed to meet the ANSI criteria with results ranging froa #2 Few to large blisters and delanination. The seven passing panels ranged from no defects to
#6 Few and #4 Few blisters. Upon receipt of the panels at KTA (two days after testing) the coating on the face of 24 panels could be easily detached as complete or near complete films. Two ; of these panels had previously received passing grades at Oak l Ridge. Of the remaining eigh.t. threit contained blisters outside J of the ANSI criteria. Thus, upon receipt at KTA the number of failures increased from 25 to 27.
In addition.co the Oak Ridge results, laboratory adhesion tests of the Unit 2 samples showed the costing to disbond completely from the galvanized substrate at values less than the 200 psi required by ANSI N5.12. Based on the above, the coating on the Unit 1 and J2 ductwork is considered to be unqualified. PHASE III - The coating syste=s were evaluated for generic type using infrared spectroscopy. The results are: nit 1 Pri=er - Alkyd
! nit 1 Finish - Epoxy Ceit 2 Primer - Epory Enit 2 Finish - Epoxy i
I d l l EXHIBIT.2f Page 6 af 8 Pages l
-e e:e. ans.
*- 663=* W r es-v a.
~ ~
~
- UCENSE EV ' T REPCHT . ER) 9 EXT @OU?iNUA" ^~ s
. . . .n in
,, ..s%.r. m . . . .. _ == = =, 7 , ; 6:3-... l 2 i . .= t \" M :
- 2 :.t::
l North Anna Fewer Station Units 1 and 2 0 1510 l 010 l 3 I3 '8 1 64i 0 ; 0l 6 0 ;0 ,0 ; 6lcs :p vore . . - .- .===== =ac a== m e m 4 Corrective Action , The 1:nnediate corrective action taken was to discontinue power operation
' - 'of both units until the problem could be corrected. Subsequently, all site l l painting was stopped until an evaluation of site procedures controlling the painting process could be made and any necessary revisions made. Finally, a review of Station Records was initiated to determine whether any other inappropriate coatings had been applied elsewhere within the plant.
Since the coating systems applied over the galvanized ductwork .and supports in Unit 1 and 2 were determined to be unqualified, action will be l taken to correct this problem prior to startup of Unit 1 and 2. Several solutions to the problem were evaluated including removal of the coating, i renoval and replacement of the ductwork, and installation of a covering systes :
.over the ductwork and supports to mitigate the consequences of failure of the coating during a postulated LOCA. Based on the investigation of various solutions, the corrective action selected is to install a stainless steel wire .
l sesh screen over. the painted surf aces of the ductwork and supports prior to
' start up of each unit. The wire screen is fabricated from Type 304 stainless steel with 8 K 8 mesh per linear inch. The wire diameter is a 0.028 inch and the width of the opening is 0.097 inch. The wire mesh screen vill encapsulate essentially all ( > 99%) of the affected portions of the ductwork and' j supports. This fix is considered temporary pending further evaluation. A l
general visual inspection from the sump level of the containment will be made l of the screen whenever containment vacuum is broken until a permanent fix is determined. Based on the results of the DBA testing performed, it has been shown that if the paint disbecds during a LOCA, it will separate from the ductwork in relatively large sheets rather than small chips. These sheets are large i ) enough to be entrapped within the wire mesh screen. Based on tests perfor ed a by KTA-Tator, Inc. and onsite tests (simulating actual containment spray flow rate conditions) perf ormed by Vepco, it has been shown that an insignificant i ancunt of the paint particles actually break off and pass through the screen during ,the course of the accident. The testing has also shown that any paint j particles which ' may escape the screen will rapidly settle out (specific gravity % 1.5). Therefore, the major portion of any small particles escaping the mesh will not carry to the containment sump, since most of the ductwork is not in the vicinity of the sump and water on the floor in these areas flows to
- the sump at a low velocity. Since the width of the opening in the wire :esh screen around the ductverk (.097 inch) is smaller than the width cf the opening in the fine cesh screet at the containment sump (.120 inch), it is expected that any s=all paint particles which =ay enter the su=p will pass through the screens on the pucp suction and be circulated through the system.
Therefere, there will be no i: pact on the operation of safety related l l equipnent. ! EXHIBIT.26 ~ ; Page 1 of 8 Psges i eB .*.b ... __.____-___m - , _ _ _ _ _ _ _ , _ _ _ _
LICENSEE EV T REPORT * (LER) TEXT CONT.NU A- 'N e -es: s=e w a a#. } G a
- 408 6'l' W
.. AeSau'T Wame tea - *p- * * ~ * -
HE * ' ' 4 M E"U 'O' h I I
.taa j j'8 f 7,*,,a. 9 ee . c e
{ I l l Fere A. na pewer Statien nits 1 and 2 0 151010 l 0 ' 3! ) is e1 4 lI
;O Ol 6 -'OI O Ol 7;CE-err . . - =ac = ma e, .m 4 Corrective Action (Con't)
An evaluation has been performed to ensure that installation of the wire mesh screen around the ductwork and supports will not create an unreviewed safety question as defined in 10 CFR 50.59.
- Since the ductwork and supports have been designed to meet OBE/DBE seismic criteria, a seismic analysis is l also being performed to determine the impact of adding the additional weight to the ductwork. An initial assessment indicated that no major impact on the existing seismic analysis would result from the addition of the mesh screen to the ductwork. The final assessment will ensure that all supports have been analyzed to ensure that the seismic design criteria is met. Any required modifications to the supports will be installed p,tior to unit startup. Since the modified system will meet the original design criteria, it is concluded that an unreviewed safety question will not be created as a result of this modification. The LTSAR will be updated to reflect the additional unqualified painting associated with the Air Cooling and Purging Systaa. '
- 5. Action Taken to Prevent Recurrence _
Adequate procedures do exist for application of coatings at North Anna. However,: to prevent recurrence, positive steps have been taken to clarify these procedures. To ensure that the requirements of Specification NAS-1016 are adhered to, a Site Operating Procedure (Construction Department) and Quality Assurance Depart =ent Instruction (Quality Assurance Department) have been developed to specify how coatings may be applied at North Anna. The Site Operating Procedure addresses control of materials, control of tools, control of applications, qualification of applicators, training requirements, and I control of documents. The revised Quality Assurance Department Instruction addresses the inspection requirements 'and compliments the Site Operating Procedure. In additien, a training progra= on the requirements specified in l Specification NAS-1016 and the revised procedures controlling the coatings l process has been developed. - Other actions being undertaken are to 1) review Specification NAS-1016 , and update as required. 2) augment the Station Administrative Pro,cedures to further ensure that no plant modification work can be performed under the Maintenance Program, and 3) complete the painting documentation review. Also, a consultant has been retained to independently evaluate the adequacy of the l existing controls over the painting and maintenance program process. This report will be revised if any significant new information becomes available. l l r
. EXHIBIT. 26 -.
I Page 8 d I Pages
. e . e e ... ,
. . . . . - .. l
.)
l
~
ADMINISTRATIVE CONTROLS ASSESSMENT CONCERNING COATING CONTROLS !
. AT
. NORTH ANNA AND SURRY POWER STATIONS
~1
. I . . . . . _ . . -
. .. m .. . . . . ..
....t ........s...... . . . . .. _ . _ . . . .. . . . . . . . . .;,....__..__......_.
.i
/
, _ . . . . . . . . . . . . . . _ _. .. f. . . . .. , . _,_ ,, ..
b- l i
.. . -- ... - .... . e
~
1
- .~..- - - .
1- dh
~
l IMPELL CORPORATION L e
'G o .
s, . ... . 1 II
* ' EXHl81T 26 i .
.. ... Page --/ . g 25' Pages i
l 4 ADMINISTRATIVE CONTROLS ASSESSMENT (X)NCERNING CDATING CONTROLS AT NORTH ANNA AND SURRY POWER STATIONS Volume I
- Report 4
4 1 i Presented To: Virginia Electric and Power Company Prepared by:
. Impe11 Corporation 333 Research Court Technology Park / Atlanta Marcross, Georgia 30092 . '
\
. August,1984 l
\
EXHl81T Page ,E,.of228 6 ~Pages
.. . - a . . .
TABLE OF CONTENTS
- l
, Page j 1.0 Introduction 1 -1 2.0 Executive Sunnary 2-1
. 3.0 Assessment Technique 3-1
. 4.0 Scenario Leading to the North 4-1, i Anna Difficulties 5.0 Observations 5-1 6.0 Recomendations 6-1 Appendices (Separate Volume):
A Documentation of North Anna hactwork Painting
, B Existing North Anna Administrative Controls C Revised North Anna Paint Controls D Surry Protective' Coating Program Review E Corrective Measures Taken By VEPCO t
EXHIBI' N i Page 1 0 Pase5
- - . . - - ,y,-- ,---.4e4.----. -- ,..-~, - - - p m,- ,--.-- . - * . . - - - -
j l
]
1.0 INTRODUCTION
4 __ .. e m
]
8 m G e 4 ' e e G *
- e 4 g
- e. ,
5 %
- e G
e 9
=
0 e g l
,4 7
,e a
! *EI a
Y 9 s L e u . 7
*E a
1 e N m i l EXHIBIT,
- p. Wa 26 d p.g.
I i , ==
1.0 INTRODUCTION
! 1.1 Background In July 1984, Virginia Electric and Power Company was infomed of a potential safety concern regarding paint that had been applied to the North Anna Unit I ring ventilation duct inside containment. Subsequent
, analysis by VEPCO in response to this concern.
indicated that the unqualified paint used had been applied to the galvanized ductwork in Unit 1 and that another unqualified coating had been applied improperly to the Unit 2 ductwork. - 1.2 VEPCO Response Once knowledgeable of the unqualified coating application at North Anna 1, a three tiered assessment was initiated to detemine:
' 1) The extent of coating errors in existence at Surry and North Anna.
- 2) The imediate actions to resolve safety concerns.
- 3) The long-term actions necessary to preclude j
recurrence. The assessment of issue (1) included both sites and was completed by VEPCO staffs on August 12 at Surry and shall be completed'at North Anna by about August 31. To date no other definite examples' of i unqualified coating applications at Surry or North ! Anna have been identified. Immediate action was developed to enclose the ventilation ducting at North Anna with 1/8 inch wire mesh. This activity was being pursued by E8C at North Anna and was scheduled for completion by August ! 25, 1984 for Unit 1, with Unit 2 completion during the present outage, e . l Station management, QA management, and North Anna EAC had conducted evaluations of the events which had resulted in the application of unqualified paint at North Anna. Both Surry and North Anna had identified action plans (see Appendices D and E) to address 1 issue (3). 4 VEPCO management detemined that an independent evaluation by an outside consultant was necessary to assure an objective assessment of the programs which may have been responsible for this occurrence. This report documents that independent evaluation. ! 1 -1 EXHlBIT,16 % Pr* "
J e
- t .g 3 . , ' - 4 . e em
, 2.0 EXECUTIVE
SUMMARY
M
.sw
]
l 6 m e a 3 . e
**& 9
- e
. mss e
6 9 m W
./
m T aru N I N I l
- f. *
'tu a .
o "sem
*tE
"'T E e
e .8
~" EXHIBIT.16 Pee I (I7 hPS
*91
2.0 EXECUTIVE StMMARY 2.1 North Anna The sequence of events which resulted in the ! h application of unqualified coatings to the North Anna l
.' , ventilatidn ductwork (see Section 3.0 and Appendix A) i i
- in 1983 indicate extentive personnel abuse of
~ !
adninistrative controls. 7 i'
' The controls and procedures in existence at the time the coatings were applied appear to be adequate both technically and administrative 1y to produce proper
" applications. Inadequate supervision and QC
- i verification of what appeared to be a mundane task
' are the root factors in this occurrence. Corrective J measures to preclude recurrence must, therefore, include a combination of increased procedural
= stringencies and increased personnel attention and knowledge.
~
I Measures to enhance personnel use of procedures have been initiated since the January and June,1983
" timeframe when the North Anna 1 and 2 containment ducts were painted (respectively). However, the more
~ complicated control systems and heavy use of contractors by E&C at North Anna dilute the onsite
_i enhancement effort for this group. The reliance upon QC/QA to conduct asnagement ! ~ supervision of work being performed reduces their , i ' effectiveness as an objective verification agent. It
' is questionable whether QC was even knowledgeable of the North Anna painting effort, when it occurred.
Conversely, line-management supervision may have been
~1 lacking because of the assumption of QC coverage.
4 .j 2.2 Surry There is no indication that unqualified paint has - ! been applied to any surfaces inside either Surry unit
, containment. Stringent controls maintained by the
! *" onsite contractor have alleviated VEPC0 staff from the necessity for any station control program until recent cleanup efforts prompted Station Maintenance
~
Services to paint portions of the Auxiliary Building. i
' Station Controls have been developed since June, 1984, and appropriate qualification requirements and s procedures have been initiated, but are not yet complete.
2-1 ExHl8tl Page 7 o* Pages l
I 2.0 EXECUTIVE SLMMARY I
?
I 2.3 Overview Although coating application'orograms are different between surry ana Wiirth Anna, their respective-control systems appear so be adequate on paper. Implementation of the revised programs needs to include appropriate degrees of training to workers, i 1 ' supervisors, and QA/QC personnel to assure correct utilization. Based on past experience specific management attention may be necessary to assure j adequate implementation. Associated programs including Consumables Controls, Adninistrative Procedure laplementation, and 1 Evaluation of Safety-Related Activities, also require further rwiew by VEPC0 to preclude similar errors in i other areas of maintenance and modification work. ; i 1 1 ,1 1 l J 1 d' l1 J 2-2 EXHIBig. Nd A "'
} Page
i ROOT CAUSES I. Directly Involved in North Anna Coating Application Errors: 1983 Personnel failure to use existing procedures and painting
,y g specifications; a *
- l Lack non of an effective safety-related evaluation component; of safety-related activity on a y Lack of supervisory direction and control; Lack of Quality Control verification of control; -
I
- Incorrect / inadequate documentation of work; -
i Insufficient definition of work requested. I - II. Program Difficulties That May Be Associated at North Anna l Lack of controls for work conducted using a Blanket Work Order; Consumable qualification data difficult to find by users; Contractor supervision in EAC not knowledgeable of control programs at the nuclear site; Responsibilities in review and approval processes not clear and misinterpreted; Administrative burden on Shift Supervisors dilutes their technical evaluation capabilities. I J i FIGURE 2-1 EXHIBIT.16 s Page L of IS Pages
. ,4 . . -*ya
- as . .. ..;
. t . . . ,
. . .. .. . . .j . . , s ..a,* . .. .
3.0 ASSESSMENT TECHNIQUE.. .
.f. y. ,...?... .....g___ , , _ d A 2-.m u ._ .. _, , . . _ _ _ , . 1 -,
-. .a . 3.
3
. ..e %
i~g ;
- s. *. %*,-g e.as 6=.- -
n,-' C 13 % V T V. '. - - s. * - ,- . .s , n m e . m 1...]
.i m. y. -r
"..*-* s.. . .
... s. -. ., . . .....s.
... s .
... s . . . . , .. . ... , . .
.s. .4 . .
.. .. .......2 .
.. . - ~
.; o. .a .- .. .
. . . . . . ., s ..
t - .. .
.-o..
-t *
..: . . . . .- ..p
.. .s.. .* .
.a . e ,Ae-* . .,. ..
,s s, ,
- . . . . . ,: . . s .6 7..- . .., , ,. -
g ;. . .: g..., .-.. .. . .
..-.'t.
.. . "...<.,.t,,.: .. w . . .- .
.,s. n. .,t. *-c<<....t...
,a . r,. .. ........ ,.. ..;. -
.~.e,.'..
. ... s.
. s .,e -
,,c.. .
v.; - =..- .-
. .. .. a. .
- s. (
. . . . 4 w, .- ..
. w. . ,s. . . . . . ,s , . .
, ; . .. y , .,,4 ..
,e:. . . . .. ,
. , , . . .. . ...-.. . . . . r.
- s. .,.... .. ..
, . V r. , . . . 3. , f.. ,s. . ..
.. w, g . 4. t.-- . ~;, .
*s . . %. . .%
...,. . .. . s 1. * '. h ' . ' a . .s.%. ,=;p.~
.s, ...s * . -.,;-
fn,. ; .2 - :p 1. g . * . g~ r *. Q.
, ... <ie
., s3 4.J ...o.f. yt . *. N. :.
.~ er w my. ) - . Y.u-
* , , . . .. .. w
.. s. .-
.s s
%= n. ...f ,.s..3....,*.s
- s. .,.T.
f .* .cy %* . t .- 5 .
,ys . .' e ..
o
.4. . $%- .r.s *, . . A. .% ,'. ... =.
% ' . 4 ,> .e .*g. >%p . - o
- o.. q .. .. .. -
....t
- 3. ... ,.. s... .stt ,. ,. r. ,*::*,..; .4
*#. n'
,* 9 f ..e
, ....$s.
- w< .3*t.. ,.s'r,a se . . .
...s.
.r.
y
.. . %Y. . v. .;;.i.-- .. .
v...a g. 4 y,.. .:,......... .
. * -. . . .,.s.,..-<s.
. ... e . .
. .. ,, y yr , ,.'.',..a,':7Q%
* .g % , .
4 .
. . . . .p:.. . . . . ,,r.
. .,f.<. . . ;
. 8. - .. . . _ . . . . u.
-*,,7 . .- -
i . ? ~
*.k. .s r .'. ; ,r
- s. -a *..$! J. . . >. k'. v.$.s .7 i.
.*.%c* X;f - - - t.g..'.Y .e u . 4A*
'. .*s ; . s.. ee . %y % ..." *. .
\,. . . .- s. ... h c.s. . .- . .
- p. . . . - ,
n.v :. . '.-,. .t
.? 4 W *** -
. 8.:
o'
.. g. :' s*s. a. a. .s 9>t $; .. y Aa *.,!
* ,e
.u
. . . p, . s ss.-
8 .
- s. . .
>8 ..
.: c.
4,. .,
..a.. .,
. -- 1
. f - ,e6 s...,s . , , . .t .
% -- .s : - ..
. .r . . . . .. ,. .
c .. -e. - . . .,..- .
' s-
~. . . _..,. .. a .s .- a
. . * . ;..p.
... o z .
. . .;r - s .. .
. . . . . . , i; . s. . .. , ,
e, . .. . . . . *
~ ,. .. - .\ ~ * .. . . -, .
. r .
.,=.e.* s. p. . ..; *. . ... ..
?o. . .
,- G. .... ,, ". {. .; 2. * . .
s-.
.n,
* !. . f a ..
s .. e.. , .
- , f. , .N *. . .p:. ,,. .. .
. r. . .. .
. .s e.
-? .
g 7 ..- . t i J 26 - QYNeff w
t i 3.0 ASSESSENT TECHNIQUE Mr. E. H. Nebster of Impe11 Corporation conducted the assessment of the VEPCO control programs involved in coating appilcations at the North Anna and Surry Power Stations. The scope of the assessment is i ! defined in Figure 3-1 and was conducted August 13-24, 1984. During the period August 14-15, the consultant
; interviewed North Anna management personnel at the
, j plant site. Copies of the documentation which describe the ductuork painting operations in 1983 4
, were obtained (see Appendix A). From this and ;
g discussions with Station, QA, and ESC management, the scenario of events in 1983 was developed and the 9 affected pmgrams and procedures identified and obtained (see Appendix B). r The consultant analyzed this data to detemine practical application, adequacy of controls, and, finally, root causes associated with the improper coating application. Since North Anna Station management had alrea@ drafted revised coating 4 4 controls (see Appendix C), these were also obtained and assessed. On August 16, the consultant visited Surry Power Station, where copies of their applicable control programs were obtained (see Appendix D). The e in-house evaluation was reviewed and appeared to be a [ thorough analysis of the existing program. Differences between the North Anna and Surry control i - systans were discussed with both Station management l organizations and detemined to be minor. During the week of August 20 the consultant l completed his analysis of the programs associated !I with coating controls and developed the i recomendations in Section 6.0 of this report. These i recocriendations were discussed with Station 3 management representatives on August 22 and 23 and , finalized in report fem on August 24, 1984 I !I - 1 3 ., l[ exsisir.tge ease s' a a p.
IN-CONTAINMENT PAINTING CONTROLS ASSESSMENT IMPELL, INC. Scope: 1. Activities to be conducted in the assessment of in-containment painting administrative controls include:
- Evaluation of station (North Anna & Surry) reviews and corrective actions taken or planned.
- Identification of additional reviews and corrective actions that may be needed.
- Documentation of the reviews, findings, corrective actions, and assessment in package form, ensuring both Surry & North
- Anna control programs are addressed.
l
- 2. Activities to be conducted based on the result of Item 1 above include:
Identification of other potential problem areas within maintenance, operations, projects, etc. that should be reviewed. I I APPROVED: I i I i
)
I ! i l i i : 1 1 FIGURE 3-1 l Page 1 of 2 { EXHIBIT,26 % ! Page _/% nf If Pai
~l
Action: Task Date le . Item Resp. Completed
- 1. Collect copies of documents and EW 8A5 instructions / controls affected l 2. Evaluate failure mechanisus EW 8A5 which allowed incorrect paint use
- 3. Document findings and portray EW 8A6 1 root causes .
- 4. Assess root causes as to impact on EW 8/16 .
I other " skill of the craf t" areas
- 5. Develop corrective measures to be MLB A HLM input / 8/22 implemented to preclude recurrence l UW
- 6. Document the project work, results EW 8A6 and actions to be taken 1
1 1
] ]
J J FIGURE 3-1 Page 2 of 2 EXHIBIT Ik ) Page 1 01 7 f Page
. . . .s . .. . .. . . , ,. .. .. . . .
4.0 SCENARIO LEADING TO THE NORTH ANNA DIFFICULTIES In June,1982, Maintenance Requests (MRs) were originated to paint the ductwork in the basement of Unit 1 and, separately, Unit 2 containments, to arrest rusting and stains on the ductwork which had resulted from small boric acid leaks in the primary systems. Each of these requests were approved for conduct by Site Construction utilizing a Blanket Work Order in place between Station Maintenance and PIP-N. 4.1 Unit 1 In Deceder,1982, the station turned over the Unit 1
- painting authorization to PIP-N. On Deceder 23, the I effort was initiated and the Construction Supervisor 3
identified the paint systems and surface preparation specifications to be utilized for this work utilizing QCI 11.1 forns. There is no evidence that QC was informed of the work nor any documentation to verify the preparation or paint system actually used. The primer selected, Mobil Chromax Red 13-R-50 was not qualified per Painting Specification NAS-1016, and 4 purchase records for the site indicate this paint was never purchased. Further, the SP-10 surface finish j called for was not physically obtainable with a grinder (as called for). The work was documented through February 1,1983 and closed as completed on February 14, 1983 by PIP-N. 4.2 Unit 2 In March,1983, the station turned over the Unit 2 painting authorization to PIP-N. The work was l )' accepted by PIP-N in April,1983 and work commenced on April 19, 1983. The paint system selected for this effort was Keeler Long 6548 white primer and white topcoat. The surface preparation was specified as SP-10 using a vacuum blast. Although Keeler Long is qualified for containment
. use, the acceptability for application on a galvanized finish was based on a phone call to the vendor and was never substantiated. The surface
; preparation is not credible in that VEPCO does not own a vacuum blast system, would not sandblast in containment and could not attain an SP-10 finish on the thin duct sheet metal.
Documentation indicates that the job progressed through May 1,1983 and was closed on the MR on l < July 21,1983.
. EXHIBIT 16 l, Page 8M ot 1 Pages
y ,. i I l 5.0 OBSERVATIONS l 3- -
- T. . . .- . _ . . . _ , -
7.,.. . .. .
. s .
... s . .-
. . . ..... 3 .
. :~~ :J.js.s r '. - %- . . . . . .
. .x : '. ;
.)
.. . t.T. ; ,. . . . . . . , , _s ,,. . . ,
. . ; .p ,; m.. . p ...
....,g,... . ...
..s.... : . . . .. .
. _.3...
.t, . : q , -:..n
. < i. t. . . . . > . .. ' .'. ' :,. 2 . . :, i n ,, . .. . .
s .-
- .k.
g
.~* ;&y.
.+. . y 4. . .
.s ry.,..t ..., r. .-+- ,a >y s. . . ... .. . . , w'. . . . fp r ,. . . :.... .: . : .._ , ,.
. r
.4,. .3 ..*..,z i n*c . - .A... . c. . . :., : . . . .. .; s . :L...t.
2.,.,..'.. . sc .
.s . . . . ... ., , . . .- s i.; .') .T* ' .
l '.
- ^'.1. ..... , ... ' : 1. V t
,.. .tm.a. y ;:.A.A 2sGr :. .- ,: ';. -
L~y. w as 'e, .-.. a vt.. ,.s2 % . ~ ..%. -
.\ .%.; .: .i:. . ' p.%:.~M:. .* 7,: .: . . 5 i.ty .t;.:4.a
. .. .-. . y. . . f.
. ,. . ,,sW;a.;s u . %
3,
. . :. .ac
- v. s, -
, 93. .
. . t
... . .. .v. v . .m.
s .. ..--
./
. ~.1 v<
.. ' . .,, . ,. . . - . . ...u.
. ,, ,c...ca . v.. > . . ;
.T s
, . . . c;
- e q ., *
.2. . .- .. .
. ' , -g. ?. *
.. ,- .i ..'.-
-s.,~.- -
l g
. .s i .. . .' .
w .
. . ,*n r a
-.~ , >-
- l l .
1 J l I EXHIBIT.U - l Page 1 ol d Paget
. . . . . . . . ..... ., . . .. i 5.0 OBSERVATIONS 1
1 The consultant's review of existing control programs at North Anna and Surry Power Stations resulted in observations which depict specific facts or errors 1 portrayed in the documentation and from interviews. 1 The observations were condensed and grouped according i j ' to direct or indirect involvement in the 1983 ductwork painting errors at North Anna. A third group of observations were developed regarding Surry *
] controls to compare and verify adequate program controls.
These findings fom the basis of the Root Cause
] detemination, the results of which are presented in Figure 2-1.
] 5.1 North Anna Ductwork Painting: Direct Involvement abservations 1) The utilization of a Maintenance Request (MR) in each case for this work was an error since this t J work constituted a modification. As a result:
- No evaluation was perfomed in accordance 4
with 10CFR50.59. -
-
- No in-depth engineering evaluation of
~
qualified surface preparation and' coating l system was conducted. ;
~
- 2) The MRs both denoted the work as not '
- safety-related since the components involved (ventilation ducting) are classified as '
~
nonsa fety-related. As a resul t: !
- QC/QA was not notified of the work prior to ordering accomplishment. QC signatures for document completion were gained apparently after the work was complete.
~
- No documentation directing the use of QCI
= 11.1 nor NAS 1016 was made.
~
- 3) Paint and surface preparation specifications were not fully in accordance with NAS 1016.
~' 5 -1 EXHIBIT. Ik Page d of j d _ Par a
- - - a .~ . . ,
I l l l
- In the Unit I case, the paifiting Specification (NAS 1016) was clearly not utilized.
l
- In the Unit 2 case, it appears the Spec.
was consulted, but that the application I . gualification was not fully substantiated.
- 4) Surface preparation specifications could not have been met based on engineering evaluation of I tools available, duct wall thickness and time required.
- 5) De paint primer specified for Unit 1 was not utilized.
- Purchase records show that this paint (Chromax) was never purchased or batched
- for IMt 1 and 2.
- Records indicate a Cheesman/Debevoise Deveka No. 505 was on hand and batched in the December,1982 timeframe. This paint I is also an alkalyd base but equivalency to Mobil Chromax 13R-50 is not established.
- 6) De construction supervisor responsible for identifying preparation specifications and coating specifications is no longer eeployed by VEPCD, I 7) Documentation for the work does not specify that I the surface was g:1yznized, nor does it specify the surface area intended to be covered. ,
- 8) Records indicate that only 17 gallons of Deveka No. 505 were batched in the affected timeframe which is not sufficient to have primed the entire surface. 111 gallons of topcoat were J batched.
EXHIBIT Ib- - 5-2 page d oti es .l
5.0 OBSERVATIONS i 4 5.2 North Anna Ductwork Fainting: Indi rect Involvement , (mservations: 1) The Consumables Control Program implemented in 1983 has created a data base which is difficult to access by workers.
- An extremely large nisuber of consumables ,
have been qualified by EWR subsequent to the program implementation. Listings of these consumables and their appropriate qualification have never been incorporated into the program administration.
- Consumeble Controls to assure shelf life, service life, and in the case of coatings, operating (pot) life, were frequently mentioned as missing from the existing i
program. l 2) Plant modifications as defined in Administrative
' Procedure 3.7 may be instituted by Design Change Package (DCP) of Engineering Work Request (EWR).
- Both DCP and EWR programs appear to afford sufficient controls to assure proper r reviews of the modification.
I
- Maintenance Requests are not an authorized 4
i mechanism to affect modifications, but i there appear to be no controls to screen ! out requests (MR or WO) which result in modifications.
- 3) Review signatures are required for all documentation involved in design, modification, and maintenance controls.
- Most personnel contacted expressed the belief that a QC signature indicated in-depth technical, administrative and safety verification of the docunent and its associated work / operation.
! EXHlBIT. 2 0- -
~
Page fl of I I het
- _ , , - - - - - - - - - - , - . , . _ _ , . , , _ _ _ - . . _ _ _ - - _ _ . . , _ . _ - _ _ - ~ _ - - _ _
_ - ~ , .._._,_-~_-__-.r----- - _ . + , - - - . _..y ~ , -_, <,. . - -,--, +-
,_. s ... . .
5.0 OBSERVATIONS
- QA/QC expressed a contrasting view that many of their document signoffs only verify that-thrdocumentation has been completed I properly.
- Shift Supervisor approval is required on l ,
all documents affecting the plant. Due to the volume of documents involved, the value ; of this approval is anticipated to be
- 1 limited to safety evaluation at best, although many personnel believed that this included technical approval also.
- 4) Programatic controls utilizing procedures to ,
implement each program have been instituted to meet regulatory requirements and properly operate, maintain and modify the plant and assuiated systems.
]
- Apparently because of the sequence of development of construction-related procedures, some confusion was ext essed regarding which procedures Construction is
] required to use. (PHP, SOP, ADM)
-
- Since Construction supervision below
~
Superintendent level is primarily filled by contractors and little or no training is _ given these people outside of OJT, weakness in procedural compliance is to be expe:ted
- unless VEPCO direct supervision is maintained.
- Complacency and/or lack of knowledge of controls established by Administrative Procedures was expressed as a concern by several managers.
- 5) 10CFR50.50 reviews are instituted in the controls for DCPs, EWRs, and temporary changes.
ed W 5-4 EXHIBIT 26
', ease 4 of_II Page-
l
.m . .. .. .
5.0 OBSERVATIONS Controls in the above named programs appear to be adequate.
- Maintenance Requests, when annotated nonsafety-related, non-Tech. Spec., do not get screened for 10CFR50.59 review.
. Maintenance which impacts safety-related equipment could, therefore, proceed without review. .
5.3 Surry Power Station 1) Painting conducted in containment at Surry prior to 1984 appears to have been conducted by the onsite contractor, Daniel, using Procedure I WP 114.
- 2) The Maintenance Services Group at Surry has 1 conducted aesthetic painting outside containment and is now controlled by Administrative Procedure ADM 102.
- 3) Station evaluation of existing controls has already identified weaknesses and enumerated corrective actions to revise ADM 102, QCI 10.10 and develop MSP procedures to increase the amount of painting Maintenance Services can pe rfom.
i
- 4) A review of the sampling by Station nanagement
, of previous design changes, including j installation of ductwork in containnent, reveals no unqualified coating utilization. This review
- also included a review of the paint applied by Maintenance Services on the liner basement, t
. inside containment.
- 5) Paint is stored in two locations. The warehouse supporting Construction Stores " CAT !" paint, another station warehouse stores paint which is
- not vendor certified. 5-5 EXHIBIT. Ik Page l ot g p g,.
- u. _
,i .s s .;. . . ..
e...- ., . i .,c . , * * - e. ,
,. '..' ~'7.*o*' *.d
' ~
.. 6.0 RECOPHENDATIONS
. ... . k.
f _. s .es,.*
' e ,g s I e;. . e,,q.
- y. ;e. .
, a. m . - w -. - .. ..
..*
- e -.
s s. >
. .s.N.s. . 8. .$w-
.. p. ,.a.Is. r. :
,I ,-
W [ x. _ _ _ s- . . ,. .._ - ---=w , , p
.% m ,=.= . o - -
~t. *
. =...o s
... . -.s.-*s.s.t .
a r
,* i - e,* 3 -v.* .
~
- . s
. .n .
. 6 * *
. , . . ." . g gtd .e . e' L4. s% .... . -
.f-f e. i .' *
.o.
$3.kae..T.. ,.
. **r- . r . .- . . , .
....g.**,
. ** _=. g' :'- , s*
s A. , 3. 1.
=.
. ya ,- .%..,..,..
- ] * * / I..% *-t* 4* 6. s **
. .. . *m .. .
* ,1 . .
..*b} .* . - A.% . ..
4* .' s; . . . .g... .s... . - * , . ..
...%, ,1. .. ..
,=
,\ e. 's *s y*wo * (* .% ? r. *. ;
4 1* t,,*".. *
** .V....'4,. .*.
e .. o " . ., . . . . . y. t
. . ? .* ,s.
* ** '* *. -s. .
- s. .
. h.;-7* ..
*$* ,y@..;*.'*;4.t .: ..',. :/.. .. ' l .
* . . . s
, .* . *t. . . *.*.
, . .-? .. s. .
*g.
; .* .g . . , e-1.
4; .7. %* . 5..* *;
- ag. f . ~ a .,- , . .' .. .
. .- . .-M* *-:- ,..s ,u *.t.* * .;
,..st. . .J,-*' .
..e* *
, y 9; g %j . .' p,e*. * ' ,, y
- e .
- s. . . .* .. .r
,te *
* . ,b , $ . .-
(.,.t'*'4 1 .1 t-.% '.,
.- ,- . - s'. * * . -
s 1 *
. . .9*:W g J,.g..e p
. .%, t.e , . 74 .
t-* - T f . ",e, *. s .. ,
. .. g t.,,
..4.. .., .
g s. .
*, .*, - , t
' b s'. f 't * .
noe .
*e % g A..sgs. . *
..t " . g.se
*.*4 p
- a 8, .-
. ~4 . ,
- g. A.. .... * ==
': * + .
2, .1,. .~ \ t.
*."s .. .* . .*
'..-Y . k * . , p .. .
3 l .
.. .s ,
0 *
*e
- d o
l l l l EXHlBli,16 Page U al i pages 1 l
6.0 RECOMMENDATIONS i Based on the observations and root causes identified by the consultant, the following general reconreendations were developed to provide Virginia Electric and Power Company with the long-term corrective measures to preclude future coating application errors. Items identified by an asterisk (*) have alme@ been addressed by station originated corrective actions comitments. 6.1 Both Stations 1)* Implement controls for the selection of surface preparation and coating applications which reference existing Painting Specifications, mere coating of in-containment surfaces or
- safety-related equipment is involved, secondary evaluation and verification controls involving Quality Control personnel should be specified and documented. - 2)* Conduct training for maintenance and applicable construction personnel including supervisors on the coating difficulties that occurred at North Anna, the hazards of coating misapplication, and the controls established to assure correct , applications.
- 3) Establish system interaction and design basis knowledge at the E&C supervisory and SEO personnel level to develop increased engineering sensitivity.
- 4) Provide continuing training on station administrative controls with emphasis on specific ~
review and approval responsibilities involved in
, existing programs.
- 5) Clarify line-eanagenent and QA/QC roles and responsibilities to assure objective verification processes exist.
l 6) The mechanisms authorized to request coating
= applications should be controlled as potential modifications and should specify surfaces to be coated: . 6-1 -
EXHiglT 26 J Page
- O L I I PA8'S
6.0 RECOMMENDATIONS 4 Area to be coated, identifying boundaries Existing surface material to be coated Reason for coating (e.g.: rust, abrasion, appearance)
- 7) Upgrade existing consimables controls:
to provide a comprehensive listing of qualified materials and qualified , applications; to control consimables once issued to the field to assure traceability.
- 8) Review and revise existing EAC instructions to provide a single integrated set of controls for j each site-specific organization.
4
- 9) Review the Shift Supervisor seministrative workload and adjust as necessary to assure j responsibilities can be met.
I 6.2 North Anna Power s ta tion 1)* Detennine and control the involvement of Station Maintenance Department in coating application. i 2) Establish and enforce controls of the Blanket l Work Order between Maintenance and Construction i to assure coating controls and documentation.
- 3) Establish and maintain a minimus knowledge level i
by Construction Supervisors of nuclear plant j control and adninistrative systems. 6.3 Surry Power Station 1)* Complete the adninistrative controls and i procedures to be used by Maintenance Services to i apply coatings, and implement a qualification program for those personnel involved in surface preparation and coating applications. 2)* Implement controls to specify the types of coating application for which Maintenance Services and the onsite contractor are qualified and author'f zed to conduct. c.2 EXHIBIT U Page II of M Pages
..- . . .~ ,- . .-. ,
6.0 RECOMMENDATIONS 3)* Verify that paint specifications which originate from the original Surry Paint Specification for in-containment applications include D8E evaluation. I e D I i 4 i ] d 6-3 EXHlBIT 26 - Page .II_,ot1 Pops l
. . . . . ... 6 e .
, - ;. ..r,..... *6 --
- s
.* . . t. . . *
,--- . $ r;,. ,p--
., v; . ~. , '
4
? 9 s ..
. . . . *. . A. .e *e
- y g.. . ... Lf.,". ., p.
, t , ;. . . , . e. e - *- , .
+'
, .a
. . , vp [. .#-
. v . . .- .. .. l
....,,e.
e .
*. .. . .. s. . . .- . s. . , .
s .
.. ., 3. ..- , *.c. . ..~. . . A. . ;v. . . *. .. . ,. - ,/e r-.~. . . . d .. s . ,.' . .,'.. Lu 4 L, *6i_,*.i.?i;
~i. .'d. .6. s.r 4 ,,, .
, ..-II i:
. . ,.' .-,;.-C_. . p.
- m=,
.....e.....t... ..s
- s . t . .- . .\ .. : . s+-
A ,u... r. C. ,. p
. ,, T. r~ L.
..y[.,..,. {. . . <r: .,.. r n ., s - s . . s.
.* ;'.*. . 3 .
-.v
.' d. . .) . * .'.
.n
-0.
.
- 5 :s . . , g *., a.. ..r- .3.
- . :.s.
m a b.
~ s.
.sie j
e
&'. p* <. g , , =*
. *.. 8,. t. ., . ',;; 'l.;..T, .
g;t v
.p., . - . ., :
i.,.,.. ..
,. . . . - .. . . s. ..,'* a.t
;.**.;. ,. . ," ,. . . %%_.g, .,,. . ,:, <. ,, ,, . . g - b. {
Ceeperate Offlee ,. .? ' .,. N -
~ ,.... ..
.f. , ,f. . ;.',, . . . I. . _, ., , ., , ,.
... t.
p' .;.: .-. . .4. " . . yt.., . 230 Montgomery Street , .w 4 .j .. - ' ..',L M. *,. 'y N
. San. Franc' co, CA 94104. .
.i:
.. . t.. . n, . U . . . L .f..' ,. 1 .
...,,...r.
..i s
Domestic Offlees - ' 360 Lennon Lane . Walnut Creek. CA 94508 ';/ . . ' ' . ; *
;* .. e' . .:
' 7. . -.
r- :. l'. - - 3
. " .(4 , ,.. , '-,g.
- 1. ..
.. 22u wa'okesan noad; ; - -
l-
/
C~ r ' * * :,. q:g , . .
. . 's 'i ...ce. -
. . ..S.a.n.no.ckb.u. m. a IL.8001!). 5 * .c .4. . . .sJ s4.s t.,c.4 eE* a s'L..':!I. p M N. a'
* ' *** ~ ggg Q Qq{g &. 9, *..<. n 9. . '.2 , as. . . ... k .* a .. s;
. . . . i
*C . t 4..
l
. ....i y( .. . * .T, r,':I.175%, q ~'.;f p..f*,.?:.- q .~t*'
. .$4eMlle. NY 11747 . gc . . ,.,c.,,,,
s
, j ,K .'ps .., "*
, .q ,f j . .,..p.f.,.[.;.'.'.....
i , ,-
-. ,= .. ... .. an Me, arch Cobet' L. .-<' . , , , , .
. , ;}
.. L W, ,. . . h.: 3.-A ..'. ; ,_: .-.,. ..'..
.x.,4. . .f7 g..,-l..
, c :' :. . , .,,
l-: ',. ,,o . a , ,n , (. .i,c
. .'
- Technology PerWAtlants,@, , . * , .
e f
.,. w:..... ,..g.j;; , s. II'=^p:. h -l
,. . . s,a. r s00et ... ,,. . i. . , . t , .. .6 ,- ) . . ... g *. .
.* .:; - hw Offiese 't*i- 5 -
'I C # :* '.*.t.'*: 4/ N : T-yi': . 3.
f n. nSr ... ... c. Genesis Centre, Garrett Field ' ' ' I *
- f -
- Sitchwood,Warrington .
' A wA17gn Unhed Kingdom
. st,. ' . y. tf. ' -
- 10. Mue du Colisee 75004 Paris -
)
France
- moinstresse 19 -
t 4200 Wiseteden I' # i : 'I *r # ' ' ' '
, Woot Germany ;
I Affiliate Company
- Prosest s p.A. (Fiat rio) ' , . , .
...I !XHIB6 g7 e
vie cuneo 21 i 10152 Torino, lla'y Page ,gg,j.,L Poses
POW 3e-16 .
- seer, ePeteete * '
MEMORANDUM to A. D. Fraley. Jr. North Anna FooM G. C. Ludden October 15.1984 HISTORY OF RING DUCT C0ATINGS UNIT I AND 11 NORTH ANNA POWER STATION As requested, we have assembled doumentation to support the coating sequences for the ring ducts on North Anna Units I and II. The Protective Coating Surface Preparation Records (PCSPR) for the two units are shown in Attachments 1 and 2. Although these records are complete, questions have been raised regarding the actual primer used in Unit 1 and the type of surface preparation actually performed. SURFACE PREPARATION Each PCSPR indicates that an SP-10 surface was to be obtained in pre-paration for primer coating. Unit I records indicate that a grinder was
- used; Unit 2 records indicate that the surface was vacuum blasted.
Although SP-10 is a specification for sandblasting; it is common industry practice to quote an SF standard when using other types of surface prepara-tion. The SP-10 notation would indicate prepararion of the surface by the specified means to a cleanliness equivalent to that obtained by an SP-10 blast. Thus, there is no conflict on the Unit 1 PCSPR's regarding that point. The vacuur blasting indicated on the Unit 2 records could not have been accerplished as North Anna does not have vacuum blasting equipment and does not allow blasting of an. type in containment." Discussions with Vep:e construction and painting shop personnel indicate that the following surface preparation technique was used for both Units 1 and 2. Hand held grinders were used to prepare areas of boric acid corrosion and the remaining surface was hand sanded to a cleanliness equivalent to SP-10, as described above. UNIT 1 PRIMER IDENTIFICATION Although the Unit 1 PCSPR's indicate that Mobil Chromex Prirter Red 13-R-50 was used, there is substantial evidence to show that Dereka Pricer Red No. 505 was actually used. First. indicated that Mcbil Chrom:x 'rimer ha,a review s not bee.cf station purchasing purchased records by the station. (At ta:h. en t 3). Second, discussions with Vepec construction and painting shop persennel indicate that Dereka No. 505 was used. Finally, a review of painti .;; sher batch reccrds (Attachment 4) indicates that Dereka No. 505 was batched and used during the period the ring duct was coarc.". Both the Mobil Chrotox and the Dereka No. 305 coatf ugs are alkyd base; primers. Inf rared spectroscepy perforrned on coating semples taken fro- the Unit 1 duct show that the primer was alkyd based, consistent with the Mobil or Dereka primer (Attache:ent 5). EXHIBIT 27-
/
Page of 1 PaFe5
.. - . . . ~_, . - . -. . --
P g2 7
, .petob:r 15,1984 HISTORY OF RING DUCT COATINGS .
T : , 1 I ' d4 7 Ge rge C. Ludden j CCL/smb
- i i* Attachments s
e, i cc: J.R. Locklar F8-6 1 H.J. Fortune. Jr. EB-9 R.B. Green EB-7 j R.M. Berryman EB-3 ) i a ? 1 P 5^ i f i h a I 1
'l EXHIBIT. U
- Psge Sd
/13 ~l % HHG rJ T 3 MEMORANDUM to Mr. A. D. Fraley, Jr. North Anna Purchasing now K. V. Cumings October 15, 1984 PURCHASE OF MOBIL 13-R-50 Purchasing was asked to determine if in fact we had purchased any Mobil 13-R-50 in the year 1982. We conducted a review of all orders placed with Mobil or Mobil distributors for the time frame in question. No such purchase was found on either the Construction or Operations side.
To verify our findings, Mobil Chemical Company was also contacted and asked to research their records since all purchasing at that tirr.e was not done on site. provided to Vepco'sTheir Northrecords did not indicate that Mobil 13-R-50 was Anna site. Investigations did reveal that Mobil has supplied on two eccasions Mobil 13-R-53. However both shipments totaled only fifteen (15) gallons.
. The purchase orders involved were NA3-4667 dated September 28, 1982, for ten (10) gallons and purchase order number NA3-2516 dated February 22, 1982, for five (5) gallons.
~
. /- 5 K. V. Cumings ,
Supervisof Purchasing EXHIBIT. 28 m P* --./ of4 Pages
h , f . i 4 k=
; c. ,
4 . 1
$h, h
@i zg U d'
' _ S i R Rt ? LO N New Wood -
)
. s ' - e . u,o, , ,e on. *ae *'"
t Y.;,, .,7.,5."?.': t,
, , **20 M4.e' L TX["$$$
- ='.1"O.:"*" 3%
k ~ f" r g' .b gF ' k f = s k Ee per.Uli ' ^ F.co7.*' .t 9n ma saa sh a eture of 70* F bet t AJI .etects en the es wedtie.
'g*
- y, L AUTIONI COMSU5TISLEI Keep a y from teot and open fio and breath.ng of vopor or spre 4 prolongee coneoct ..eh ska
. 3,eso,e tM product as apps*ed o not take en , noll Close conto qe ofter each weel
'lM y with odequate ve e K 4
New concerte. plaster, et - spoukt , g OUT OF REACH OF CHILQREd
* ~ * ' ' ' " " ' '
"~T THE BEBEV0lSE NY BRO YN,J.Y.11232
- ,e. . 'm p. . .c<
'$'h(.
s g
M . M M g .~ ? ' % b d % M 3 '4 " A I.i 9
% :[l menerw. r
+x h N -y T <* "- 4 ' w 4 ~; M ,y !
pp.-- , , ,< . 4 s s i; . .et - .; -m .
.I g '~
WACE Q Q WAINED _ IM]O S- *' JacuoR eArTER8' 5'**% 1 h W- ~ =
& & $ W .T W $? & . M Y.N W E
pgpgg WM < .Q.R.% ' .** T 4 .V'4 '&4iQ?.R, & &./.j.Jj
?)?. .
' 4t(lD.,OR, hyAS ASWJ .YES JAG 4 ,, ,. . .. j; .
GRWT FINISH; M#el M'ty SOR'C1.EAftLINES57 M ' ' I 30 gQ*Q}' - NhM' MN #d,,c[ . EANDPAPER rEXTURE: l
' '%}N L CE.E NING:
1 e1 y' ' ,f- } ; '- .i - ' M'/ggAmptgNG ' '4.YWE d-
~ hm hym i
i ' I .. GEpt PRlWING SEAL OOAT IST FINISH FINISH OOAT - TOUCH UP l OTHER __
;PAlWTDeG M.PERVISOR :
f'fnit fA L
- gx
- INyEcToR e r, ~ '
\ $.44 yVF-lB-/s6bos% ixmeKWund; 4l'$t WlW fr1Yj%.hBlevl2 Wt @f (C& ON#
>Z & y % v % k a t e.. - .
=a m &v. ,b 4;. su .e Os.k.. uW e .9..A bk & 1.d.?
r . e m . r.> n wlr.M. ^y. j GEN. PRIMING SEAL COAT ' :;g%.7Tt::~i5.:;T .
? ,1.; 1~g
' f ) .,2 ) - M L tST FIM85H FtsetSH ODAT 10UON M in(R_,,;_
MBET FEMP, 'e
' AM %4 ?-fiM
~ #
ff * .i
*'* -4' . . ' . ' ' *rT- '
M te it-f'IE ' * -
- 10 '
[ SURFACE TBF v.' 1 . 1
> po sit- : ;-
*'"9 ' M Q1 TK- 9
- .$f 1 - - - '
'W 4i t .c:Et nuuaTv. 42 % <
MTE: - 1 l F 2 2. T - 81 ' o
- I l
!MLM TH6CXNESS
.CE ADINGS:
, 7 DFTs M/A . j .
U C (
's DF Ta Ts Of a WFTs -J, ,(O s Ts 's WO hTAINED: $lg W N/A MTN. MAX. WIN. MAX. NIN. BAX. WIN. GRAX hEOFtED: )1% ka N/A , helN. al'A X. ' MIN. 'MJ0( MIN. DIAX. WIN. ARAXj
. . . OEN. PRIMING SE AL CDAT . ET FDcSN PullSt iOGAT h 408M tr a OrHER
U * :5 / : or nATE ; exP. DATE ExP. mart r - e r. o A Ts ."sxP pATr ExP. oATE J yAsr: .;
. ,,.'*J [' h
> n. d6 - %L;
- 9. O - Q;. < Ag -y .. ? .-
mArcu uuustn$ w- -- ' ACT: EXP. DATE EX P. D ATE EXP.DATE EXP DATE EXP. DATE EXP. D ATE - U.l *3 APG- APo- APG' APG' APG' APG- ' flEDUCER USED "
~
'g COLOR CODE COLOR CODE' COLOR CODE COLOR CODE COLOR COOE COLOR COI COATING APPLIED /
!'ct.'*
COATING EQUIP. CB @R 08 Oa e R On OR Os OR Os O OS OS _O S _O $ 0S _O S TRIAL MIST -iYES YES ,,,,, YES YES YES YES D E MONSTR ATION - NO NO NO
= -um NO NO num NO APPLICATORS ,,',, YES YES YES YES YES
, ,,,,, YES OUALIFIED NO NO NO NO NO _
NO 3 PAINT CONTR ACT SUPV CONSTR SUPV
@jgI Oy I l .
, -_/ J [
OC INSP. a ., e re ce e, e . .
.2-w.
, a. +a. =-
( .'94MM iudO4 W ONR , g mn
- p. - , , ;... c % . c . ' - J GENE M u' M e
{ PIEASON FOR >REPARATON FRIMING T FMIN#1 J JDAT SulLD UP 1 Y,* M L l Q, .- s- _ I J .3f f .: y .[ - ( h# A/ i / 1
~~
W aduMBER: .. J -] 3 delft:
'fP
; i j CONCAETE 8U2 FACE TD BE GETAINED. 7'(C ]
SAT, UNS. SAT. Upg. SAT. LAS] SAT l U% SAT.UMS. SAT.' 4JIE. OETAINED: /* /> f
-surface PetsPARArioN t, - s; -o .
a 4 .1 :
. s .:
. +.
IlhKTHOO OF'SNtFACE PREP:
/*, .M ' - ' 1
. c. [ 4. '" s *7~i UEC8FIED /. E'
- J. 6 WERE WATER .AfbD DIL FILTERS USEDf YE3 ' k I . s - GROUT FINISH: D I
.YES.,. hf0 .i SAMOPAPER TEXTURE:0
. WERE THEY OfECKED
-SEGULARLY
. . . .# u' FOR9.--....NE57 - .
AGENT 3i 7, TWERE 1'lE FOLLDWING USED7 - . FORM RE
- TYPE- *:WNAL CLEANJNG:
~
hVA l 'T - /# EURtNG TNANDbftG M TYPE
- DUSTED a . I GEN. PRIMING SEAL OOAT 1ST FINISH FINISH COAT TOUCH UP OTHER _
PAINTING SUN 1tV4SOR - / . /(,4 n l A# OC INSPECTOR
~
)
I", "" *** .*".""*$8 NN ':. Eb>. 2 / 4
- A m ris r6-: uen r
- p. -
. . , * - . . - * . Go e r. . .
c
. pfe r -il u-R x,1 n fi bi 7 00) /
Dou >f . To
. p ..
I ~ /M 2. C k .
$~~f 93*i4-i w. u.a.E3 O r t . 'l W I . C s f 2 2 s , '1 'St.ux . ndh L
GEN. PRIMING SEAL COAT 1ST FINISH FINISH ODAT TOUCH UP' $THER _
'OATE:. , f . *f . if .
[ AMBIENT 'TDsP '
#7 & * ,' ' * '
I ". ' LSJ2 FACE TEMP /, / ' - d < f DEIJ POINT: 2./ 7 '
; GEL HUMIDITY: ) ffh -
! CATE: /. f. f 2
; FILM THICXNESS G E ADINGS.
O O DFTs WF Ts N/A OO DFTs WFTs l O ems WF Ts - ps WFTs O DFO Ts p' l ' 06TAINED. $lK. M N/A ) MAN. MAX. WIN. - M AX. MIN. MAX. MIN. MAX SPECIFIED: M. 3(Igj N/A MJN. av)M. af1N. MAX. MIN. MAX. MIN. MAX
- ~ GEN. PRIMtNG SEAL COAT < 1ST F#NISH < FINtSH CDAT TOUCH UP OTHER I
h EXP. DATE EXP.DATE t,XP. D ATE -EMP. D ATE , EXP. DATE EXP. DATE PAINT: .
] k * '- _. ,
g -;'k. . . 7 t, . W911 , BATCH NUMBERS ACT: EXP.DATE EXP.DATE EXP.DATE EXP. D ATE E XP. D ATE EXP. DATE l' *
'3
, APG' APG' APG* APG' APG' APG' REDUCER USED ,t , ,, ;
/
COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR COI l COATING APPLIED ~, , , ,.' , , i @B @R B Oa Os a a On 8 R On COATING EQUIP. OS OS OS OS OS OS l TOIAL MIST DEMONSTRATION [ YES ] YES [ YES [ YES ] YES ] YES
- %O NO NO NO NO NO APPLICATORS [ YES _ YES _
YES _ YES _ YES , YES i g OUALIFIED NO NO NO NO NO _ NO PAINT CONTRACT SUPV ,
, . EXHIBIT, Jct _--
'CONSTR SUPv. , %D
- Pages O C INSP.
- . - . . . . -. ._ . , ,c., n . ., o , ,, m . .
e * -
' , _w] tMM&#k'nin9hnWW.M::
l i
.. ..:;t,;.p.Yre p .9 foR hT60N e .g
;hj toAT
.igum ,
1MNISH
.g,
'DOAT ' SdlLD UP Tgypt up p' g g i
' V STEEL '
l'DATE: ll - Y '#i-?
$;$*E{ *
' '\
~~
'Yi '*'
MASONRY f J[ l l [AEFORT MLASER;" w R V -
< . V. ' . H j n o
, CONCRETE '
shirt: r ".. .J '1
- . .i ANCHOR PATTERN'-
- SURFACE TD BE MAINE 4. @{$ j
- ' ' ' ^ '
. . G- . -! 44TABE SAT 3UDE SAT SAT.
EAT. UNS. SATMES. OETAINED: 7. O f
; SURFACE PREPARATION ' '
V ] .N - ,1 9 *'4i .*-9 .Q 1 - Q.W '*
' .0 (afETHOD OF M PREP: Y bf% 'MW .WN '. I
;'dMi + ' ' ' ' i ' '* O ? ' MOlFIEDI__' Y,O- N WERE WATER A40. OIL FILTER $ U,ljEDf .YES M -j GROUT FINISH: N 48 'NO WERE THEY CHECKED RESULAntY FOR 8 8^8 T _ -
SANDPAPER TEXTURE: I WERE THE 70LLblM9db MONS h,Jhelnd liktideffS -
, FiEAL CLEANINGi'I-i w.g .g. og,,,,,g, > % , m. % ,. g y,,
l 4 .' GEN. PRIMING SEAL CX)AT ' TST FINtSH FINISH CDAT TOUCH UP - OTHER._l j PAINTING SUP%RVISOR - ff,/ h OC INSPECTOR ,J ( th 1 # N O. ' hf f ~ ' hat /fi p (Jd T E b A
". pea cr .s ro.1e u 1,3.L8,% gag q;,,g &,,y,ac, g F,sm 4 'h o exc. F,.a Nog
- ru '% Mb_%o n , .; .- : ~-Q i 7 ,. C' , ._
l .f T- 9 $69 U [ 4 4 S ?, OfI.% Il 4 E1(/ 4 4_1 . %I N(.
- 9 $0 3 . I's 8*.N b3 *'
3 ,
, GEN. PRIMING SEAL COAT IST FitGSH j FINISH COAT TOUCH UP $THER _ '
pATE: , f <- (, i f 3 . i. -
. 3i ,
i. r p eigu 7 yg ,, - . yg, . 3 =. .: # g1 -= 5 -
- r -
8 ~' ' - ( ' SURFACE TEMP. 4. i d .= [ DEW POINT: A/ f '
) REL HUMIDITY: t//%
Ft R EAD4NGS THICKNESS DFTs WF Ts jI N/A I Ob DFTs WFTs d - 9F Ts WFTs O O - O, s WF Ts (O f FTs [ OBTAINED: l MtN. MAX. M/A WIN. tr.AX. MIN. MAX. aglN. 14AX. MIN. 41A
' SPECIFIED: M g%X. St/A tilN. %U)K.1 4AIN. MAX., MIN. MAX. MIN. MA
- GEN. PRlWIMG EAL COAT 15TEaNI'SH FWilSH COAT TOUCH UP . OTHER _
-i f . EXP. SATE d EXP. DATE EXP. DATE -EXP. DATE EXP.DATE EXP.DAT1
. . -y FAFNT: .
.s i., jig . k l , "~ q._*dd
' ['. e. '
'. ', 3 S,;; . ,
. BATCH MUM 8ERS : *l fi. S T I S L - ' ' ' ~
ACT: EXP. D ATE EXP. D ATE EXP.DATE E XP. D ATE EXP.DATE EXP. DATI U F
- APG' APG' APG' APG' APG' APG' REDUCER USED i-
.g l'%' =
COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR CE COATING APPLIED T[2' r ',. , t . i t . ._ f _ . i
@B @R B OR e R Os OR e R e E
.. CO ATING EQUIP. OS OS OS OS OS OS TRIAL MIST DE MONST R ATION 2 YES ] YES [ YES [ YES ,
YES ] YES NO _ NO _ NO NO NO _ NO l APPLICATORS g YES _ YES _ YES _ YES ,,,,, YES _ YES OUALIFIED NO __ NO __ NO .NO NO _ NO PAINT CONTRACT SUPV [h,,{., pyg .a j $_ CONSTR SUPV l P ,,,* _m p. m 2 _2 _ ar. . OC INSP ' ' " *
"~
. -.t., .v .s . . . . ...eu e ,can w a ,a m .
_ ~ _ -; PfttMING _MhAT_ 79ADI _ CDAT SulLD UP
$ EAR)N FOR PREPARATION STEEL
'. FSD)-fd '-
NATE: M NRY SEPORT em*8R:
- Ik d83 _ i i' ,
. CONCRETE
~~ Iay .
ANCHOR PATTERN. . SURFACE 10 BE OSTAlltED g /O 1 - N SAT. UNS. TiAT WRE. OSTA8IED. e ~
' ' LNE. SAT, UMS, SAT, UIS. SAT
. .i i3URFACE PREPARATION d ., 2 -
; 3 4 e vci> .-
*ggETHOD
,' OF SARFACE PREP:
1bM l+ -f I 'M
'Ajd . ' " " - -
yECIFIEd:#[O
- 8. '
GROUT FINISH: YA [ WERE WATER AflO DIL FM.TERS USEDF WES M IIO ~ 8 WERE iHEY OMECIED REGULARLY 40R C11ANLMfE5? z -
. ,VES M. SAM ,3. PAP.E.R, - . .
TEXTURE.;
'i FINAL CLM. :
FORhl M. .- AGENTS.-' ' J WERE THE FOLLDERNG USEDf 2i' ,
~ hAC j-ONilNG ? HAN0 LING C00NIXims TYPE: ~ '
! a. ,
, GEN. PRittlNG SEAL COAT IST FINISH FINISH CX)AT TOUCH UP' OTHER__!
- PAINTING SUPERVtSOR
- 6.ge n .
, OC INSPECTOR LOCATION AND REMARKS:
#) f"g,ggj, g /g # 3% ygfgg. g 9g j& y .
' % Not\ TH fM (' Erb N O.0 L . ; ff ' - W .4
~
f5 bS0-$-N'N.-
'.'*[-}-;.,
. ).
1 _ _, , t U ). . e-4 .' 5 h.' , ! - "." GEN. PRitdlNG , SEAL COAT IST F4NISH FINISH COAT TOUCH UPI @TNER : J BATE: , , ,
/JfySf,4 . , . _
p A -,; .
' AMBIENT TERAP. -
- f 77 ' * ' + " "
- 1 T '
4 2* SURFACE TEMP. M' , s- i i OEW POINT: A/f# f REL HUMIDITY: 79[# DATE: /-I ~I 3 - \ FILM THICKNESS R EADINGS-D Ts C WF"s N/A DFTs WFTs O DFTs WFTs U ' 10 .O ' UFs OFTs WFTs DCWR [ OBTAINED: j tl. M N/A aflN. SSAX. MIN. RAAX. MIN. MAX. I WIN. tu ! ! SPECIFIEO: / i j E f'_ M WAf AdlN. MAX. MIN. MAX. AllN. MAX. tilN. WA l GEN.'PfutsfyG SEAC M ET FailSH FINISH CDAT TOUCH UP OTHER _ i I
} ,' ~
~'l b EXP. 6ATT,rd "E)Wl, DATE . Dir .DATE EXP.DATE EXP. DATE , EXP.DAT
' f,.>\l, i f; N ' -!
h
~
PAINT: - . '.- .
~
20- Y/f L " ~ SATCH NUMBERS - 7 ACT: EXP. DATE EXP.DATE EXP.DATE E XP. O ATE EXP.DATE EXP.DAT I L ;3 APG' APG' APG' APG' APG' APG* REDUCER USED v/ s c ,a
',. ,[, ' */' , , COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR COOE COLOR C COATING APPLIED .. ,a -(c
@B @R B R 8 OR e OR s OR Os [
, COATING EOUIP. OS OS OS OS OS OS
' TRI AL MIST ] YES ] YES [ YES [ YES ] YES ] YE! NO OE MONST R ATION & NO _
NO _ NO _ NO _ NO _
, APPLICATORS [YES [ YES ] YES [ YES ] YES [ YES NO
, OU ALIFIED NO NO NO NO NO _
L PAINT CONTR ACT SUPV. / j[,q,,L. EXHIBIT 18- . CONST R SUDV o I , ,,iv Pan 4 ud '
$ W- -
O C. INSP. , ,_ l
l 3JgSTRATE '-
.. ,, 4 T'. ) GENERAL' DCAL9 SINT' PW62H 1 - 'N UP 1FTNER , .cc '
CDAT ' #3154 CDAT SUILD UP gTEE1. . ; .- pg --P *OR PSEPMTWN
- 2 Mball100 '
WY
\ 1 y ' ', '
MTE: * * * ' .t' k' * * .. '
- dS M _5' * ' '
SEFORT 88h888R ~ . MiSi, '
*1 % ' * '
l 00NCRETE' R PATTERN; , M FT: A. .< -.-
.90RFACE TO BE OSTAINEo & lO -
SAT,Ups, EAT. tM- SAT. Ups.., OSTANIED: M-j. -]i UNS. SAT " * ^T, - LK. c-
' - .< - J <
isparAcE enEPARAnON D * )..
" ~'
di."
~
~*~ < i. hEOFnEDs
,m OF SURFACE PREP: b/
- Y
- M _O 7 .. GROUT FINISH:
YES i [WERE WATER Afe Ott F4LTERS USEDF ' 980
; $AND)MER TEXTURE:
WEfd THEY CBGCIED AEGULARLY FOR CLEANUNEN7
~
' ' TYPE: ihE5 -
8NNN CLEANING *
*=' FORM RktfA5E AGENTS: '
kWERE THE FOUNRNG UEED7 3YPE- DUETED hVAC
- ~
. .. CURING / AkNDLhtG COMPOUNDg-k
* - r ."l 2. FINISH CX)AT TOUCH UP OTHEP a
SEAL COAT 1ST FINISH ' N' GER PRIMING i F. Uwhi Id - PAINTING EIUPERVASOR 's ts' f'f,6 . W [d#/ [de u. M L^ ' M /A./ N 6 M M "[' M yN OC INSPECTOR
^"",^*.
- b. ~AArf,f u .. .
O vu r eo! &
^' .
M /m - E.Q . tf'
\
1 Mr 94s1- 1.s u-93 Shne - O M.~ f </ U-1: a ;. Sf 't !H-EM 4./.4.s FINISH ODAT TOUCH LF OTHER GEN. PRIMING SEAL COAT- IST FINISH {$3 '
/f-M -M
- _ .
- ' D; L 't
~'=*
DAThi . 2 ,
"55 4' t
'r i '
m;g,wp- ;
- E rSURFACE TEMP 7,$ ' -
l I g ' DEW POtNT: _h
- I j C'.EL HUMIDITY; d///h f i }} . lF '}. f 1. -
~ /
! > DATE:
@ Q/^ 7 O O > B , M Ts - O Dg'sWFOTs O l DFTs 1st FILM THICKNESS - DFTs WFTs DFTs READINGS: DFTs WF -
MIN. M MIN. MAX. MIN. MAX. MIN. MAX. I ' ,OSTAINED. M pg. M/A MIN. II MIN. MAX. MIN. ' MAX. WIN. MAX. SPECFIED: }5 8 .M/A FilftSH COAT TOUCH UP OTHER.
. GEN. MilMING SEAL COAT ' 1ST Fiff tSH EXP. 6 ATE EXP.DATE EXP. D ATE D 0' O f EXP. DATE < EMP. DATE f .r -
e..
- PAlwT:
l
~ SATCH IMalBERS S O. NIT k E XP. D ATE EXP.DATE EXP.DATE EXP OA b ACT: EXP.DATE EXP. D ATE
- u. s. F 1 APG' APG* APG' APG* 5 APG APG*
REDUCER USiO /rQ{ sJr gy COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR A" E '- COLOR CODE
/ *. / ft" COATING APPLIED k/ # 7,," ,. gr_
['Q s @ Os R Os OR e OR e OR Os COATING EQUIP. OS _O S O5 _O S _O S YES _O_- Yi g
; TRIAL MIST ,,,,
YES ,,,,,, YES _ YES i YES NO NO Na 40 NO <NO 1 = - DEMONSTRATION = l APPLICATORS
=j ES
=
YES NO YES JNO YES NO YES NO YI N l NO l OUAllFIED .59 l : PAlWT CONTR ACT SUPV. [ ffpu/z EXHIR1r
;_L , .
' - - . < . . . . . ...., p,,
g-m '
. Ava d .
WQ &D.5$'-( *Y&i'N k W W'h.Y$Yk?- ** M M 'h FMN43' *Y.-YMD-lNMYMNNb d h 3,ce;gr M FEE %'EM.W284='lmtF4 W d -. S.
%YM$~=_3_@!NbbbMMN 1'1 , -
P- M __
.% 2.k S'$$
MWWM W5&NNW.#J'$&[6 _ _
$~$ _ _ f ,
GEN. PRitMNG SEAL COAT WST FINISH flNISH COAT TOUCH LF ' OTHER l j y EUPERVFSOR N f Y411dSL, ' -I! I K INSPECTOR 's A (, 4 r, a o w ,
-- - w- _ ..:
_.; %q lM.3, .y ~ s ~~ . = ^
~
-p wc := ,w e 14 ~u ~
O *% '
~.
i s': -),.&. . :.c s' . ,w.=;_. W h .- . ;% ,, v y ;
- s.. t' A . -
.g
. _T_ ~ did '+'
} hff E M'.PendlNG ' 4EAL M Tl %.feMiH , N'$3AT . M f[ MS
~ ('.. ' c:c-c3.M W. M j: ,:. ., , c;a
- .h, 1 U e.w -
w.w;t .w m3y:;.-; ; ; w 2. w ..tes . M E (T' W e*-'. -s 4 iAV ~M* 4 -; .+ M i die L'S I-NI.i* ' 3Q703 . -i % =.ji.!ff 7@j *
> race inne O "'Co.' C'i : ~:* ; ~ ~ ^ *A v.d ,*. c -^ .'nWi-:nf5 :WtY1* ' V4 ~x* 43F '65'CVB3
_. .,'..>.;- . p .; . ,. m m:
,p . qp _ 3 g--.-(y g -( -
3yg
' ~
{CEL HUMIDITY.
*[ [~*.. EdiMT.l[, i .,, ' J-T
- i b.jb A 'M . .
) M TE: - _ . , kh.'. . . V -.':i . D' --f . N N *C .I ! - i r. l h j' [' ,. MTAINED . .I M 88AX. N/A ' , 8tfN. 98AX. I t$iNNU MfDC . MAK.' ' 4SfM. Nl l MC1FIEO Y M.' REAX. ~d ' ' 'DUA O iflfM.' 2 SIAK. MitAL'$:,DAX. ' 'nnN. N ' ' twat 3lkX.f g.,..* L,. - ..
. ., e p , . f . ., ; i 4EN.fnablNGi EEAL CDAIj 3ET E)MISy ; M 3$H COAT TOUCHAP ; OTHEflM
'm .ud. e5TE. .'j AMP DATI1 50tPMMl'.32P.4 ATE *.; M. SAM ;
g Q .e..3 ;ygT '.4 G.tysmggygegpgypegg) OP. SATE 5
! - " ' ' ; ACT- EXP. DATE EXP.DATE EXP. DATE ~ W O'AC EXP. D ATE EXP. DATE
- . - 6 .y 7334 APa. - - .
A c. ! REDUCER USED ? -' t 7 , ( COLOR CODE COLOR CODE CX) LOR CODE C6 LOR CODE COLOR CODE COLOR COOL l COATING APPLIED 11 aq B R 8 On e R Es ' O n De OR Os 05 COATING EQUIP _O S S S _O S OS _OS TRIAL MIST YES YES _ YES ,YES YES YES DEMONST R ATION _ NO _ NO __ NO _ NO NO NO APPLICATORS _
'YES _
YES _ YES g YES YES YES OUALIFIED _ _ _ _ . NO ND _ NO o NO NO NO PAINT CONTR ACT SUPV 3 , , g ,3( ( f CONSTR SUPV ,( L /, w.
., ....a..... . , e , .._ . .y. . . .
a .,. , I
, 'dSPRAY
. R/AOai
.. w,.
. ' *
- A M S'[ E 5b ?-
\ s . ,3: *T ; % 2 Fi" W f M E ,
, a . ,- . . N -i . - n .'. p ' ?. .. ?.
W. . ,; y; W' .g .. W' ' ' A..f.~- j' ." gY ,1 i g yE.T w w . a e ; V 7 .'1 6 " M 4s & dst (J B ER % t M 4 W 4$ .. ; I
% aangeusimr,g,pp54J.;('.Q _'QY.3t g M $ % '*h $ ' .
pwn gma :m.M ~ ~-1 T:rW Wat yaTrq e.M 44 g-eaasse.M arrameo h t ~ + w w w A.3 N @ H r# M g %. f3 R F 7
'iL.
- bT--- M'1WEPf NIN WObhd - (k- , ~v _ _ _ _ ,_ _ J W'hh
=c GEN. PRitNNG SEAL OOAT - 1ST FINISH FINISH COAT TOUCH UP. OTHER ,
emTmc suPEmitsOn ' H & ,,O k a .t OC TNSPECTOR ". I,7t', iI E -
. g.y- d . -.
f s *- y b k k, 49 a m a <W- u4-zyn9.R C-:m,.%..B-
.h
.w ;+' .1 Sh m A.; e&se.m. u.e m_J 1
b " c ,"'t- kid. EftiMING M iMSN EDA 7 '4 Duck.NJ MI.Ed hTE: 'M :. .?. '. -? ,M. .h 5 .I-M . N,-:. USENEOAT
. p V < , L~3ST'
- 3. 4, w _. ,-3 %.4y; /.-Jt,yJ. P s.:46 hienT TEmi. _ -;h r ' < 'Wt N; s - J MJV 2-; T i r . E &P.Dr-W MSE!
MF ACE TE802 .' -l ,a- ~^- %* - l - W- Ur :- ~?* ; A " 2~
-". [6We $ $ ^; .;E-!' .1 , %^t t p g g . g , -
..w ,. . . .,,.; .
gr p .q y.,-g. g ,g, ,f
~ ~ ' '~
REL. HUMIDfTY: - J'I ; p's/ f/s . . '- DATE: - '
.4 f_ ~f 3. O ' [ .E C-OLM THICKNESS R E ADINGS:
. O ..O DFTs .9FFTs
=/^ OO DHs NFTs ;s .G I
s ~WFTsa < o s- '
- s. J
- ~,
~
DBTAINED - MtM f M j 'tDM. ' 9AAX.
'88tN. $$AX. J -4UA .i ellN. SAX.l etfN. M JL
~'
1PECIFIED. ' 1 %IN. 'asAX. ' U19E/A -l MTN.'~hn elit."h i '8ashi. h.1 ww 'asAx
.....--? -
GEM. PHIMING SEAL COAT, NT #3HSH .; BIESH M T- ' TOUCH. W l CTMift - C k ,# 4 .t'asa'. -nATE :1 air. pgTE , .txP.DATtP M IP. DATE.! -EIP SATE fKPMTE b * [7.~(UM '
,N $k$$k ..C'h 3:I$dh ~. Q M
'3A W mamanERS 2h2PNMIhj'
$NN. I dhh b-[N M - - - * - -
ACT: EXP. DATE EXP. DATE EXP. DATE EXP. D ATE EXP. DATE E XP. D ATE 4 9. f3 W APG* APG* APG* _ APG* APG* APG* REDUCER USED r ,- } ppyl
~
COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR COC COATING APPLIED p*LORCODE
- n s .. . '."s ,
s OR Os R Os R s' ~ O R Os OR Os O COATING EQUIP. OS OS - OS - Os OS Os TRIAL MIST [ YES ] YES , YES YES . YES YES DEMONSTR ATION _ _ NO NO NO ,7_ NO _ _ _ NO NO APPLICATORS yYES OUALIFIED NO
, YES NO YES NO 2 YES _
YES , YES NO NO a NO PAINT CONTR ACT SUPV. b, . g7 j l CONSTR SUPV '\l4,d,.m_
& _a f W v
, ...n...., n e r.i.. , . .. . c . - :,;n en:p m a v osons e
5 . . g . .;, ' A r.. $ . ~ . Q .1 .v_ ;
'?l.%th ([ * -'f f MQ _' -W * ~~: ~ ' . ; *:
'k.
M " d WT NURSEfL . i .M-'0 m
-J 'E'M- W '
' ! N ' "-6Y E,j ,
.-k jDMFT . --a
-.T] 4'
-V- - -I N5 5 #4 9 % m' pIURFACE TO.SE 9STAMED
' 'i e .' d M Gl[h - - W '9M J e %f . .
SAT,UNS. . SAT the MT 418 '5 4AT. UNS., SAT LNE.' M-h.. u.q m @, f. 7 ,"_.JhW1 JI . c--1 r3 TC <:* ' t- /T: ,., -
-e '. :..'.dl pp.%y@g -( ,
i @ WWpcf 79l$P: '.y 5- T W C XT.i""$ $;_r' - 2 .' 'A ~-@ ARM 'MiTJd{
,M..T.E.E. . . Olt.F.ILTERS,USED?. .Y _
ES , . . ' ND h
. , , . _.~.
x . . . .s,, . . , GROQTMlWISH:M. m .,..4.. RE 'TIEY " EDG;D WEGULARLY FOR CLEANUWES? . . ~~, ' JW .~. 7~, '.t." ,,- *)A. TEXTURE., l r
,&' ~~' Q yg & f Q S.' & &
- M 1
~
&W l
l h'W ~.f.
, , ., - d .@k . ~ -MYMANDLffiG 3 TYPE R' YAC t ?
.f GEN. PRIMING SEAL COAT IST FINISH ilNfSH COAT TOUCH UP OTHER CIAINTiieG )PE RVISOR K {ttLLWL.
oC :NSPECTOR .i - S.V, M
. . W. ., . . . .
.. *f. .', . . ,,, ____.. . . ..
~......-.
,;,. h g ; -~ ; . . . .
h - E *L 3 . . . ;g 3,. &. a .c.Y
.x-r ,e. As - -y x,f i; .
M [r k . gp ...h.gpg. 9 O (,. [} ,% Y g,. .. fu .o. .. P [M9E' ~45 M h, .D W4 S V. .s1 Ms_r1 su -v- . n -a erm. us -warsbs- - t r h *e?(Y.fMQ*f si: .
#f. ' , h% E
,. u~ w. s.
. ~. r I. , . e g . ,'_,'. . .,. 7 2 < GEN. PRIMING SEAL
- COAT , SST FINISH FINISH dQAi# TOUCH (F; dTHER CATE: ' " l-C," ' L .
g ' .~, r, ; i .
- a f ,, /- f(J 7 3 i ?gM ^. ,
. v, , -
.,-- a w -
.l
~ - ~
[SURFACETEnr ;
- -%E fr'y -
i
'l-
, DEW POHiT- -
_ U 'I - i
; REL HUWlDITY: IJ 4/-U/,
SCATE: -
.. /- Ji PJ '
O O w^ O, W . O . ., ' Ms 'IllPFTs 9gsQTs' p's E
' FILM THtCKNESS -
< E l ; READINGS: DFTs WF Ts -
DFTs WFTs ,
! OBTAINED: - '
WIN. MAX. , GUA - WIN. -WAX. MIN 90MA.fl MIN. t$AX.' MIN. Md WA hilN. BM
- GPECIFIED: . MIN. MAX.- ' 1815. MAX. MIN. MAX. MTN. '3E AX.
i GEN. PRIMING ' SEAL COAT SET ftNISH ; FWil$H OOAT; TOUCH 4F - OTHER d i g .! - ',.' < EXP. DATE ' ' EXP. DATE l ,fMP.DATE I - EXP. DATE .4 EXP. DATE - OCP. OA9 g.f.f$' hy*fr'Wh W l ~ -l - - $'i)
^
*~ ~ ' ~
}
SATCH MUMBERS y 9ADLT: '
. ~' 9 } *- -
' ,9 .
B mT . art.fJ L- '
- l- -
~
ACT: EXP.DATE EXP. DATE EXP. D ATE 'lIXP. D ATE EXP. DATE EXP.DAT YW A., -f 13 b APG* APG* APG' APG* APG* APG' REDUCER USED r 5 I k ') 1 COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR O. l COATING APPLIED h f * * ~*, B R 8 R Os R E s" D R e R Os E COATING EOUlP. S S OS - OS OS S TRI AL MIST YES [ YES [ YES YES ,,,, YES ] YES DEMONSTRATION _ NO __ NO _ NO 2 PjO NO _ NO APPLIC A TORS ,,,,,
.YES _ YES ,,,,
YES g YES _ YES , YES OUALIFIED NO _ NO . NO NO NO _ _ _ _ NO PAINT CONTR ACT SUPV. ji. g m h . y l alt _ Il CONSTR SUPV R1 f. e l G 1 g ____ 513 O. C I NSP. - **
- g. _
.. ~. .1,-. w .- s. un ni scw cispnav minnn-
9MHD - _. n ' gg Lg .;, . ' Lv.; 4.. . % ~. '.a - C ,*.'1 ~dd
%W }ef k ' .' '- > ? Ei .W'G& y '
~ .iY-Q .
W anmansn. i.' *% - : ? * .4 . 'd ** $.% 84h %r5.i 2$&. . . ' k~
%IFt: . ~ * . .v .i ' -
-1
; ~;.f ra %. *sj
' YN M*-
i'f6 -
' ^~
-i kfd G S
- t k . .' ~; t f a - .- '
~,gg '.- %RFACE TO SE DETAINGO 1 i .- . - , . -
SAT. UNO TiAT. Uts. SAT UNE. SAy5 g eat OSTAWGY) pu'RFACE MEPARAtt0N
..l :J O C ? %M % MM -
20.4 3 METNOD OF SURFeCE PREP:"- ' '+21~ t . N * ? i dti lM $ltdG & i F .F 'WM @ . _. S
, . 3 .
. .. . u . s. .. , . - . . --
RE. JNATER - . .4fE..)fL FILTERS ASED? YEE _ '
- 5) . . $ b '.:.. .... .'
?.". /,. Q. p ? '. . Qtti
. .- ..v.. . . .. - - - , . .
.g s . .
WERE THEY (MECKED REGULARLY 50R CLEANUNEEP ~'
- .40 .-- - .- B.
%ibdi,
~
W sse l ijs# yo n.ig niih ssEm R 4 W.%gsiu $6 .M.- p/.U( . . t-*;,d.'t'.! - .N-T - Y.' I gat'gk # [ h*-- ih_abTgh( GEN. PRIMING EAL COAT IST FINISH FINISH COAT ' TOUCH W OTHER _ gig PAINTING SUPERVISOR . M lb S'a - K"
' OC INSPECTOR ,1> **D. (a 4 N E.DCATION 4; ? & U[< nu.I ' Eli
4 v.67
%ah,y
}EMASKS.:.;ws:;n.
r,s . - f.
,.4y.
...-+.2 c.L j
. . . - . r .9. .
I.";. k. . . . g ;,
. :. . . .[-;; g' v .. g'- ;. .' -q.- -
inir.%63 si-H A d a i m in s e s &r w 4g 1 - _ t r h1rk 5 w _ u-s-t\ t p.. i;. - - - - GEN. Pftl MING SEAL W T: SET F1MISH ; FlMASH d AT_ TOUCM MOTHER m.- pATEi , ,- .. t :. 1 ,. . :. ; t.x.y n . .~: m -p n FAMBIENT' TEMP. .
* ~ ~ ~
l ' f* N . "U ~? fT T = '79Y '= "Y.T *: E MFACE TUr.
~
-ftf
'~
J . J~# i M
~
M POINT-37 -
' *
- 1
- ^ ' ' 'M
[ REL. HUMIDITY: - M3#3 --
'D
[OATE: . a / #3 73 - E FILM THICKNESS [ READINGS: C OFTs ~5FF Ts _C ' M/A ' ,J
*.- ' 'J GC 1bF7s SFFTs ~ _s 5-L] 1 $ ] 'O C WTs > J FTs GFTs! DF Ts _
[OBTAINED: MIN. MAX. 41/A' 'i MIN. MAX.' ' M d fMAX.T ' MIN. EAX.1 MIN. Mg l f SPECIFIED: MIN. MAX. WA d 141N. MAX. EHN. #Mi tilN. 'WAIC MIN.~ M ' GEN. PRIMING SEAL OOAT, 4tT $4NISH i . FINISH COAT s TOUCH W s 014ER _ 5 it; . 1 , 1- .- EXP. OATE - i OtP. DAh!.j BIP.'OATE , (EP. OATE i DEP. DATE EXP. JD ' & 7 2' c+ "N-' 9S.$..'?i'f (3.);W #$ $ i.hv5.d ,. @ fAmT[-
. t- -.
. ~ .
~'Y '
~
- BATCH NUMBERS
~
Y' F
"DT ^ D #- . ACT: EXP.DATE EXP.DATE EXP. DATE EXP. D ATE EXP.DATE L/C -u . 9.3 %
APG* APG* APG* "APG* APG* APG' - REDUCER USED , , - 4 Jpy, ! COLOR CODE COLOR CODE COLOR CODE COLOR CODE COLOR gLOR CODE COATING APPLIED M # *M B R B R OB R O st a a R OB COATING EQUIP. S OS OS Os OS OS
, TRIAL MIST [ YES [ YES [ YES ],iNO yES ] YES ] YEg . DEMONSTRATION g _
NO NO NO _ _ _ NO _ NO M p APPLtCATORS YES YES YES [ YES YES _ YES y
, OUALIFIED NO NO NO NO l NO _
NO 7 PAINT CONTRACT SUPV. j d dg pygggy [ l. CONSTR SUPV f\ ? '/ t u b e t , Nu ~ (. " ' O.C.INSP. , s. J -
. %._ ..... . .* M 8.Q1! W .. % L.H U % - B/ BRUSH S/ SPRAY R/'12.R - - ~;"
e l' n m-e1 -
~
.# Nh Y,'- ! , h4% ~*
- g g g ; ,) : c y ',o
_. ; -]E '- cf <4tW;{ @'d y.,$ $] :;. s gi W 1 M. *b-). . . ia
.e.o T muusEn. - 4.;d M -4 "W*ihP&9 W rydl gi sNegp . . . @. . : . + 1 2-qq ; r-. :-I m7 -1 -
1 - 4ti p ,o ,E , TuNsp -. -] .v 4 g - - , --g-y.r wm
. --I m p ,.j ,c .-
~
$ ..~ *i;[
W 10F'3RfBRIiGE JPREP:T *- 7 @ @ > $ 7 5 8 - 'l_A 2 [ I V-l N tWS i*EUf
. .*rECE ,$ATER*ge 0H, KgMS g5EMjMES , , , Mg4 , ..;,g ,4 h ROUT,y % , W
- ~ h ~ $. ?
~ '
' .Yf .f
.y __NW .-
1 j wEnE.fuE .~ Mc ueEor
,. gI wpas kliolih . %-..!"rigmmfcc . s .
8 }' ' ' '*yk : 0 : ~7:. W. 7 '" ' d ,.. i iY'PE: d OUSTED .' N:
~
. GEN. PRlWING SEAL COAT . TST FINISH ; FINISH OOAT TOUCH UP OTHE R __._.
PAINTNeG MRVISOR T LMMi
! oC eMsrEcTOR
)~' v r:-J l
~ '
- &. . ~ %.,
. y k,;,
- 4. r . -
, . ;3 ?~,. t'
, ; . -y , - ~3 ys .
i
-Y. f.W Y ~-
t . .ll-
~ .(U ' Y,,.
- AY, s, G ; ,;.;-t .h, !?~ Q :. . ?" .\ -& h_ ,
~
.=
.. , f . ,-4
^
. S. :.' '
.r. ' k.
T f' N M h.~ ID$',85
'* S T 7$$1 T O ' N'I' b '._f. =**'-*'%O FT *I d t'Eha 3 11EfM NEd 4 ..
>-3 '
GEN. Pftl MING SEAL CDAT
~
1ST RNISH , FINISH CDAY TOUCH %F j
- hTE: ll- l t , l& --
V-
-f - * '
-E f. *: f- $'5 -J~ '^ YE MW J'
, TW&. ? ' ' " - - r -
-a " " --- -
~
T a:'r- - - - ~ m-
. SURFACE Tar. .'- * ,
Pr 7-- -
~ '
- e
; _ltEW NRNT. * * .
d' t. ' REL HUMIDITY: $ #
*J 9/t I) ATE: ! c te i l
.. FILM THICKNESS O O- */^ O &O O O E DF Ts WFTs . .OQs WFTs
;_ R EADINGS: OFTs SFFTs DFTs WFTs .DFIs 'WF OBTAHtED MIN. hAAX. .
N/A ' MIN. MAX. MIE OMAb MIN. MAX. WN. MA) SPECIFIED: ~ - M1N. MAX. ' N/A MIN. MAX. MIN. MAX.'# MIN. MAX. M2f. ' MA)
. .. ';9 GEN.fRIMfMG ' SEAL 4X)AT 1ST FINtSH '
FINISH COAT - TOUCH UP - CTMES - l P -4 '5-[ [,Q ; , I =aEXP DATE '-g : StP. CATE 4XP DATE EXP. DATE y OCP DATE $XP.DATE { _- ),,. .
.m ..- .
3
,.,,;l .
.. . 7 Q pg , , .
i C
. SATCH MUMBERS - '
IL U i er - l ACT: EXP.DATE EXP.DATE EXP.DATE $ XP. D ATE ' EXP.DATE EXP. DATE l s' c. ,s
. t a v.
APG* APG* APG* APG* APG* APG* REDUCER USED _rg,,, COLOR CODE COLOR CODE COLOR CODE gOLOR d)DE COLOR CODE COLOR CO ' COATING APPLIED i,P. *.;TL B R 8 R Os R O B hR Os OR s C'
, COATING EQUIP. OS S S OS OS OS l TRIAL MIST DEMONST R ATION
]YES NO
] YES NO YES NO
]
#NO YES _
YES NO [ NO YES l APPLICATORS OUALIFIED
'YES _ YES _
YES [ES _ YES , YES NO _. NO __ NO NO NO _ NO PAINT CONTRACT SUPV. \g 1.ujp, EXHIRIT ill CONSTR. SUPv s Paos QC INSP. t . (tk
.I mL[A S_._...
- R /,Tt 17"r* ~^'
.?
. _ _ _ _ : t> Arm ~.e.1:
- m. _ n/R n t isH s/SP A Av -
E e - t . E .
~'
pacTsc1WE 8047588 _ E W
,. petons oAp5 -
wpim sww e _ m a,h tm E J.E us.
^ ^ ^ " - -
g
- _ ,u.,
g r--1 ,., .- - w- on . w passessE co4T Ipeums SDAT guED UP agagem pga pasPARATeose Daft M-12E ISE% Inseossay y
-.ponT emansR. 61/ 2 ^s' l.
h M T: sun,4cm va si asvameo are
}3!
ep.usst SAT. usa, m1 159 sp t= mat, t= sata == SAT. m pg uns. 08 TAMED suneaca snaramanon
= spec., iso 4s --
se n e o ce suarace ense- u.t -
- v enourresen 48s-mo uses mana ase en ennas unser vus enssoperen instuned uans nesy secuso asautAnty con en saam namen vr.g eso Pomes RELEAN Amer 71 g- FINAL CLEANMsG 1 MM TME P'u ' r*=m'r _DP CURusG /naasens uur. compouset TYPE: h0WT50 hy m -
an== r sammes == v wT mr pose. si i-- w g Eg!h g - fHkh-
- ~ y 1. n,s.ruoao '
$Nh 6tuJn feu..s 'd' '73 Mm ttwo W N
U 0 WO i m m. coat we am. . amt vouca , enen es g nan: es=.en===a 4/.. s .is c.a.sy a er 4 - ps* min g assert inw. v.a.- w siii g sumac vow mas g es= soort te' a- ime L asL. nuamorTv 4/W, agg% $ enn u.u.sa s.s.12 EE . e@. ak. 5., M. s0.hr. hi M.E
'nEas"e"*t er , .. w .. - -- .-
E ,, o mA 'M test anax. est aanx. met sana, spearien Set .e"?- sWL f estsammus MAL cent est cames ausse out souow w ones jf g an. nnn g, me. .an muss muss natos mun.eas r #. f-M9 7 -24J W acT: anP. amin my eats ar. ann aw. aan aze. aan p A S 2 feed 9r $ 't.b #4 ~ " I m-
- A .
_ ca co... c -n.wn mSo.m
-s . y= ,
. B1 e_- % a" abP' *~bP' ab P" abP' abP' c e'
.... - , c v.
. " " z" ^
sg) esO WD
. M bgwest .41 Kui E anD_
se YW [ YtB
'NS Y. [ ['t.
2 APPteCA10sts ] TES ao =D _C _- j paart cournact an consTn surv
- - I -
2 d2 *"
<4
/
Ad JA - 1 Gr '* ^ r 0 C , sNSP ,,
~ -
= _:
M M ***** . L.*
I r-- 4 r --* -- 6 y, , 3 = Ya 6 - asameAL saAL puest summe t'= m uW ofumm 'masTmAft M WhAT SuEDLP fr asAdos Pon pageAAAfgOst ramenS EDaY ir IMS mamany h DATE M i MfOef ML @ g g ggy pgg y , lg 9mFT
-mJetp ACE 10 SE cBTAMED M WT m g --
p Im*T_ t= EAT; La* SAT.La* SAT. tan SAT.La* SAT.t=* i gJAF AC$ PREPAAATuost V . specurup y ' _J~ O estipeoD or sumpACs w SAOLIT Puest L
' mas mAfta Ase cet FeLTEas unsor vs1 WD vusI aAssoresen 11 6 uses nov osecuso mar == ^4Lv Pon '= saa= ====
Ponas saLEJW AssuTE _ - TYPE. FueAL CLEAameo. mag net pcLLousso LSEDP CUAmeGiesamma uma mM TVPt h0WTW GEC hM [ asa pasasses ***' - M T eLT Fasse FWEEN @ T Tr= = LF _ MC-A W - : 7 m,==,nymena A _=_ . . . X m tJe Me
" ** ~ Rt* 2 VevT Duet E k i. M . 4 6
2"
% 6a c 'b W 4,uuc % %
Yb A $ poseM cDAT ==y em 2 l est Femmus MAL enAT asT pumpe E 4 l=D n1= T=: 7d' > samorf Year. Ol' _ampAss Tor. . T/' '
~eps pourT M&n REL tammorTY h I.s.ff mAft-2, 5, K 2. s, 5. M G,. G, R i rT- ~- .E .L ex - w e aluL at u InfA ( ?? angt eut m abefL IIE. Om k getsputD-GER PanEIuS MAL CDAT Wr WWEDe PEEDI***T 196E38 tr M 4 v
Sr. DATE M EW, SA1R M M' g ensut. ' eY e 3 O$OY a n. aats gg,.ani, W 9Aint imm aup. oAft er.Saft er. ants acT: c =oma m war - coton coot cotas cone 'op coot coup caos cosos come couas sese
= l cOATipsG APPttED 010a Es Ja 01' os On O "L' 0 8 O L"'Da "" 3' ' '0 a "'
* " ' "" ; vt1 ves ; ves ,, m ; VW F Tmattest ,, VEB se e amu em 11 0 W e-M u0a6Y n Aigut NO, v5 W , m YtB , YW g'TW ,, ,,
IIW t W __ NIPLICA10sts ,, teed -
;IID 1W aIG -
OUALWISO *-- 3o
'#- .r pastT (MurTRACT a rv J c. i A
' ' ' ' " 4 ' '~ ; I - -
J I."-
.- ' * - "5 -
CtpWTa SJPW N las A - - - REILL O C seP WWIWBI SDRAY
*AsER Sif SWII SALA SB
o - . e 7R.010 SROTECTUN 3 E -R* = t am ggg N =A MA _ J ICA M S M M 1 _ ___ L 'E
-- g PWebS88G EDAT FM GRAT ENLD W
=AACue FM PWiFAAAfiON 4Hf E .,
oAn mpORT amJantR, O RNI ACE TO SE WTasaffD fraf/O L% SAT. LSE WT N d SA LNG SAT. LNE. BAT. LM 1AT. L% SAT. ENtf ACE PREPAAATIObs pqC38DED Ya WTMID OF_q,CE PREP h% __ WOUT FBIEM Ma M WATER ARS DIL FILTEM LMOP YEB d NO 310 sad.F4pgR Ytm;3 mat THEY CMGCK10 R$GULARLY Fo# CLEAffL80ERE? Yts mm o uno, Foa muAsa === Tm. F
== T Foi.to hAgnam CunessG I **Aasna ener: Cons'ouseDS. Tm Fem 8mf mmW mean_ pgggggggg am an _r_:T STpages l
mpger,2 1 K ^^ R blEM % n.n'
^"" * ~ fdj VM hot,f No h. W h -
tg
&pg &y a '
& $ 04 M b C6fL $ ,
. 'r
"? W Ofte -
8088. F9HiessG MAL CDAT IST Peset F88eSM COAT P. BATE: 'U F- FJ - T T.W w .. -
- a. , P . ,8 i
W. FOlfff A* )i:' ML MLaelotTY; .#F%
^
1 enn. M-n 9t 8
- 1".::llll"= F .a. *^
RR RR RR RM aunt tung Imu Desa. 9Ax. swa uma swL asma max. east awl y arTAseso. aunt amML GEE WUL GIEL WUL - punt n -- avA anst enas
-- youriso ~
essL FRAINIG MAL COAT ISTFWES4 FWees 84T 10 Mist er efter
^"
EW. SATE Elr RATE EJr. BATE SIF MfB M g pefuT iM as.ese,
.m s . m .,. . .
. - nn . .m ue .- w .m .
aan . m,F.s2 n
-us .11 eo, - - - . ,,.. -
=, ,. v.
.. - . m,o ,
COLOm CODE acrh.M CDDC COLOft CDDE CX3 LOR CEE36 CDW CMIG CM M - l CDATIE APPLIED Ae,L grf fyf'Da O//c.mst _~O s OR'DTDa ns m: on no Da TJs Dafo coati c iow i o: Js -
; e i
mm
; m vus
-[J s- ;
~-
i .L v.si vis - ; vts . vis ,,
=c no
=o no ao 1 _
niesm uim , _ vts ~,, W v35 [ vES ] VWE ,, , NPLIC M OR$ Es ] ano e m = mm.neto ano _ no -
/ g ... A _ EAMit: i 3 2. . ,
PAsert CosetRACT SUPV . ed. y, y COsasT. 'Eipy
~
g C a. -_ % 3 _ O C IBEir ~' Af ""
- Um#
~~ ~ ~ '
* %e 'qvt ame naan lM @ p _
. u mag g
4, -
. a .
. s,,
mummiAAL SAL M pm 1"'" LW OT W m yg ' mAmosspos PasPAAATIont pensuus 0047 FW W Eb4T susLD LP DATE: 8-M NM y N In2EER JSbf& 013 EE"" torf f I'F st* c RISPACE To SE OBTmemo kPJ P 1983 } SAT LNm SAT. LNE BAT h BAT, LNE SAT.LaK SAT. nsE WI N j suarAcs reePAAATions 6/ V asTHop OF SJafACE PREP- Ad/ M N MA m MATER Age Ost plLTtfu L e t was *" W en0UT Pam M . _ _ MHE TMy - mens anLY POR n samm anamma yp gaggpepEd Mxtuan M mmE TME POLLomuso UNDP Ponas si smas agWrTE. A TYPE; pasAL ESAtessG. OJasses / naamma man yyyg: gm Mat PResseg a"^i Eb4T ET pam pam WT Tam L. ertaa mesp r m- a r -,. _ r specroa p- - . l . d A- gNT hvef &, JE/in AlO 25 b & h.Jyg 8il ' W' 17, 6;,ib we Gol $ pasos h
/J.o -marv, do i _
- est en== s um. cont of r-
- l mafu w .rr m.m '
i mmme=T Taw ' o ,- n- s j a leP Act fansP. 7F ' 03, * < l 38E Pontf yh* At
- a l amt. sammoiTv: 4f7 M efug
.t Daft: s.rs TJ i
"'a"ce an "an W. E.
S. S. S. E SS W SI asTuamo- met met =A man. max. met anna. == man. msL .nas.1 F W 3PtED- M '^ - WA M WUL M gnX. M E45. M G45, .a hM MAL COAT yW pm T
~
peart. me.aan W- 91'099' mLass g . aan nato ===a 9 r-se e-me-sw AcT: se am er em nr. ann mLass mLaan l , NW aer . m-I . a' - ape- es-sul rwet a e sa t' .jegf y;- _ l coot cocos coce"co(pa coot cosos coag coton coes cotas ages i COATI *ec Amst0[/ IM
~ ~ ~ ~ ~
i spg k)IM8
- 3f_ Da 05. D a Q On DA. L _I son COAT 18eG EOM Os Ol _J_eS D a Er]Da S LJS S Tm
- AL aW51 YES ; YES 1 YES [ TES ,, TWs [ v3 O(LO 61RATcas _ _
3 ' Iso _ ano ks'eso eso eso _ suD
. m .eai m ,i ns ; vis = +s ,,, vm ; vas ; vWs up aunt es et o __
no _ so mo no I no _ A 'E A PASET CORT =ACI R7V. [ _ fi A ,1' ) 2 2_ m , eaurra may as 1 _= -- A m _ 4 . 4" m - e c new A> -_ L 19- - - - musmarf fem aanana ,inaume esimAv mesta,}}