TXX-3439, Responds to NRC Re Violations Noted in IE Insp Repts 50-445/81-15 & 50-446/81-15.Corrective Actions:Const Procedures Revised to Indicate Pot Life within Allowable Temp Range for Application of Coating Sys.Affidavit Encl
| ML20040B583 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/19/1981 |
| From: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20040B572 | List: |
| References | |
| TXX-3439, NUDOCS 8201260211 | |
| Download: ML20040B583 (5) | |
Text
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TEXAS UTILITIES GENERATING CO.TilnNY 2(N#1 lif tV AN TOW Ett = DAI_I AN. TEA AN 75201
";ch[,h[hh;ly' Noyember 19, 1981 TXX-3439 Mr. G. L. Madsen, Chief Reactor Projects Branc.h l
U. S. Nuclear Regulatory Commission Office of Inspection & Enforcement 611 Ryan Plaza Dr., Suite 1000 Docket Nos. 50-445 Arlington, Texas 76012 50-446 COMANCHE FEAK STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT N0. 81-15 FILE NO:
10130
Dear Mr. Madsen:
We have reviewed your letter dated October 26, 1981 on the inspection conducted by Mr. C. E. Johnson of activities authorized by NRC Construction Permits CPPR-126 and CPPR-I?7 for the Comanche Peak facili ty.
We have responded to the finding listed in Appendix A of that letter.
To aid in the understanding of our response, we have repeated the requirement and your finding followed by our corrective action.
We feel the attached information to be responsive to the Inspector's finding.
If you have any questions, please advise.
Very truly yours, R.
. Gary RJG:kh Attachments 8201260211 820119 gDRADOCK 05000445 PDR
r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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TEXAS UTILITIES GENERATING COMPANY
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Docket Hos. 50-445
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50-446 (Comanche Peak Steam Electric
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Station, Units 1 and 2)
AFFID AV_I_T, T
R. J. Gary being duly sworn, hereby deposes and says that he is Executive Vice President and General Manager of Texas Utilities Generating Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached response to the Notice of Violation identified in NRC Inspection Report 81-15; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, infonnation and belief.
K. J./ Gary
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Executive Vic6 President and General Manager STATE OF TEXAS
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ss COUNTY OF DALLAS
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Subscribed and sworn to before me, a Notary Public in and for h
onthisgt)d day of km.u=J 40, 19p.
M Notary Public My commission expires EM.
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Inspection Report No. 81-15 TXX-3439 e:ge !
APPENDIX A l
l Texas Utilities Generating Company Dockets:
50-445; 50-446 Comanche Peak, Units 1 and 2 As a result of the inspection conducted October 13-23, 1981, and in accordance with Interim Enforcement Policy, 45 FR 66754 (October 7,1980),
the following violation was identified Failure to Follow Quality Assurance Procedures for the Inspection of l
Coatings 10 CFR 50, Apppendix B, Criterion Y states, in part, " Activities I
affecting quality shall be prescribed by documented instructions, l
procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
1.
QI-QP-11.4, Revision 4, " Inspection of Protective Coatings",
states, in part, " Quality Control personnel shall perform inside containment buildings ( ANSI N101.4, Service Level I) such r
Protective Coating inspections as needed to verify conformance of activities affecting coating quality in accordance with Quality Instructions and Procedures."
l 2.
QI-QP-11.4-3, Revision 5, " Inspection of Steel Substrate Prime Coat Applications", states, in part, " Inspection of Prime Coat l
Applications, shall be documented on the Primer Application l
Checklist.
The Inspector shall perform a Dry Film Thickness (OFT) inspection of the cured primer. The minimum average DFT of the prime coat shall be 2.0 mils and the maximum DFT shall be 4.5 i
mils."
r Contrary to the above:
l 1.
From late September 1979 to the present date, there has been no documentation of coating applications for misedlaneous steel, j
cable tray supports or pipe supports inside Uait 1 and 2 i
Containment Buildings as required by the above procedures.
2.
The majority of the records reviewed for the Unit 2 Containment I
Steel Liner revealed incomplete " Primer Application Checklists".
No visual inspections and no DFT readings were recorded. The seal coat has been applied over the surfaces to which the records s
reviewed pertained.
l This is a Severity Level IV violation.
(Supplement II, Paragraph D) y.-m-
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Inspection Report No. 81-15
. TXX-3439 Page CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The cited discrepancies have been documented as nonconforming conditions in accordance with established CPSES procedures.
Quality Engineering personnel are currently reviewing the matter and developing plans for complete review of existing records and reinspection of iffected areas.
Although some details of this effort are still under development, it is anticipated that required re-inspections will be based on a statistically sound sampling plan using both scratch tests (with a Tooke Gauge) and adhesion tests to evaluate the condition of the applied coatings.
Discrepant areas, if any, will be clearly identified and corrected in accordance with approved procedures.
CORRECTIVE STEPS WHICH HAVE BEEN OR WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Preventive measures have included the following actions:
1)
Application (Construction) Procedures have been revised and reissued and now clearly indicate pot life at all temperatures within the a
allowable range for application of the coating system.
2)
Inspection (Quality) Procedures / Instructions have been revised and reissued.
These efforts include the following salient actions:
a)
Transmittal of inspection records to the Permanent Plant Records Vault on a timely basis.
b)
Consolidation and simplification of the inspection instructions and associated documentation.
c)
Relative to liner inspections, the establishment of mapping techniques to assure that required inspections are accomplished and to provide positive accountability of inspection records.
d)
Indoctrination of inspection personnel in the revised i
Procedures / Instructions wtlich included emphasis on the proper i
completion of inspection records.
3)
Relative to miscellaneous steel ara supports, development and implementation of a unique identification system providing traceability of inspection documentation from blasting through installation a id final coating.
Quality Engineering is also reviewing Procedures / Instructions for finish coat applications and inspections.
These documents will be revised as appropriate to provide results similar to those outlined above.
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Inspection Report No. 81-15 TXX-3439 Page DATE OF FULL COMPLIAtJCE Preventive measures were initiated immediately following the NRC inspection and are scheduled for completion on or before December 31, 1981.
Corrective actions are currently in progress and will be completely consistent with the construction schedule.