ML081070172
| ML081070172 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Cooper, Pilgrim, Duane Arnold  |
| Issue date: | 04/09/2008 |
| From: | Graham C Underwater Engineering Services |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| 44129 | |
| Download: ML081070172 (6) | |
Text
04/09/2008 U.S. Nuclear Regulatory Commission Operations Center Event Report General Information or Other (PAR)
PaEhe 1
Event #
44129 Rep Org: UNDERWATER ENGINEERING SERVICES, IN 'Notification Date / Time: 04/09/2008 11:59 (EDT)
Supplier: UNDERWATER ENGINEERING SERVICES, INC.
Event Date / Time: 04/08/2008 (EDT)
Last Modification: 04/09/2008 Region:
1 Docket #:
City: PORT SAINT LUCIE Agreement State: Yes County:
License #: NA State:
FL NRC Notified by: CHRIS GRAHAM Notifications: RICHARD CONTE R1 HQ Ops Officer: JEFF ROTTON ANNE MARIE STONE R3 Emergency Class: NON EMERGENCY RICHARD DEESE R4 10 CFR Section:
VERN HODGE N RR 21.21 UNSPECIFIED PARAGRAPH JOHN THORP NRR OMID TABATABAI NRO POTENTIAL PART 21 NOTIFICATION REGARDING TORUS IMMERSION/VAPOR PHASE COATINGS The reporting organization provided the following information via facsimile:
"NUPIC identified that a potential problem of unqualified coatings exists with results of the 1996 DBA/Irradiation Test on February 29, 2008. UESI initiated Nonconformance Report NCR # 2008-01, insured that no coating applications were scheduled in Nuclear facilities requiring adherence to ANSI N101.2-1972, notified parent company President of potential Part 21 and under his directive began investigation.
"Based on NUPIC Audit No. 08.03SPAFL.08. 1, Finding No. 1, a review of Historical Design BasisAccident (DBA) /
Irradiation Test Results dated 12/16/1996, and subsequent internal investigation and evaluation, it has been determined that UESI Proprietary Underwater Coating Picco UT-15, when applied over the substrate Carboline CZ-11 only, does not meet all acceptance criteria of ANSI N101.2-1972 and ANSI N5.12-1974 for DBA qualified Coating Service Level I repair material.
"The evaluation concluded, that while Picco UT-15 is fully qualified to ASTM D-3911-95 for all Service Level I and.
Torus/Immersion Area coating repairs on all substrates tested, use of the product should have been limited to ANSI N 101.2-1972 qualified on all substrates tested with the exception of CZ-1 1.
"Beginning immediately, UESI will cease to market and install its product as ANSI N101.2-1972 / N5.12-1974 irradiation and DBA qualified when applied as a repair material over Carboline CZ-1 1 substrate.
"Identification of the facility the activity or the basic component supplied for such facility or such activity within the United States which fails to comply or contains the defect.
04/09/2008 U.S. Nuclear Regulatory Commission Operations Center Event Report Page 2 General Information or Other (PAR)
Duane Arnold Energy Center - DAEC has been contacted.
Event#
44129 Facilities with CZ-1 1 substrate and repairs performed with Picco UT-1 5, but may be exempt from Part 21 impacts are as noted:
Cooper Nuclear Station-NPPD has been advised of the finding as a courtesy.
Pilgrim Nuclear Station - PNS has been advised of the finding as a courtesy.
Peach Bottom - PBAPS has been advised of the finding as a courtesy.
GREENMAN-PEDERSEN, INC.
UNDERWATER ENGINEERJŽG SERVICES, INC.
INSTRUMENT SALES INC. a GPI.Company Mailine Address 1326 SW Biltmore St Port St. LuceiFL 34983-2958 Ph: 772-337-3080 Fnx: 772-337-0294 FACSIMILE COVER SHEET TO:
0PCXpsetnvPis CZ'i7,rct COMPANY: /V al M1(/e CCULA tAI ro FAX: (301) v/(, -4 '
PHONE:.3i
/-50 FROM:
jite' Ca4ML.1!0 DATE:
06 o,2o0D PAGES INCLUDING COVER PAGE:
4 MESSAGE; A'tc,4rf' 7;
J s
tol
,44ry
UNDERWATER ENGINEERENG SERVICES, he.
S a 1326 S..
Biltmore Street Port Saint Lucie, FL 34983 I'*
Page 1 of 3
Subject:
10CFR Part 21, Initial Notification of Potential Safety Related Noncompliance Deviation Notification By:
Underwater Engineering Services, Inc, (Formerly S.G. Pinney and Associates - UES)
Phone:
(772) 337-311.6 (x114 Chris Graham), Fax: (772) 337-0294 Based on NUPIC Audit No. 08.03SPAFL.08. l, Finding No. 1, a review of Historical Design Basis Accident (DBA) / Irradiation Test Results dated 12/16/1996, and. subsequent internal investigation and evaluation, it has been determined that UES1 Proprietary Underwater Coating Picco UT-1 5, when applied. over the substrate Carboline CZ-1 1 only, does not meet all acceptance criteria of ANSI N101.2-1972 and ANSI N5.12-1974 for DBA qualified Coating Service Level I repair material.
The evaluation concluded that while Picco UT-I5 is fully qualified to ASTWE D-391 1-95 for all Service Level I and Torus/Immersion Area coating repairs on all substrates tested, use of the product should have been limited to ANSI N 101.2-1972 qualified on all substrates tested with the exception of CZ-1 1.
Beginning immediately, UESI will cease to market and install its product as ANSI NiOI.2-1972 / N5.12-1974 irradiation and DBA qualified when applied as a repair material over Carboline CZ-l 1 substrate.
The flb]owinR information is provided.as required by 1.0 CFR. 21.21 (d) (4):
i) Name and address of individual informing the coMnuission.
Chris Grahpn' UESI Quality Assurance Manager Robert J. Waljcesld, UESI Assistant Vic President and Technical Manager Jon R. Cavallo, PIE. _P
, Vice President of GP affiliate Corrosion Control Consultants &
Labs, Ine, UEST Certified Level III Coatings Inspector, registered Professional Engineer, ASTM D-33 Nuclear Coatings Committee Chairman, SSPC certified Protective Coatings Specialist.
Underwater Engineering Services, Inc. (formerly SG Pinney & Associates-UTES) 1 326 SW Biltmore St.
Port Saint Lucie, FL 34983 Ph. 772-337-3116 (ii)Identification of the fcilits. the'activity, or tMe basic omponent su=nicedtr such facility or such activity within the.United States which fails to comply or contains the defect.
Duane Arnold Energy Center-Pieceo UT-15 stating ANSI NI01.2 coating repairs performed in CZ-1. Torus per Final Engineering Report's (FER) SGPAI 096 (7287), 0980104, 2001103 and 2004106. DAEC has been contacted and issued CAP 0560444 (Eric Sorenson).
Facilities with CZ-11 substrate and repairs performed with Picco UT-IS, but may be exempt from Part 21 impacts are as Noted:
UNDEFRWATER ENGINEERING SERVICES, Inc.
S E ES I1326 S.W. Biltmore Street Port Saint Lucie, FL 34983
- """**'*"°
- "Page 2 of 3 (iaLldentification (continued)
Note 1: Cooper Nuclear Station-Picco UT-15 stating coating repairs performed in CZ-1 1 Torus per SGPAT (Final Engineering Report) FER 097 (7301) - Contract # 96-75. Code compliance not referenced in Final Engineering Report nor C of C issued stating ANSI N101.2 conformance. Per NPPD Cooper station personnel, coatings were classified "unqualified" based on revised Drywell and Wetwell curves. NPPD (Joshua Swele. Russ Wenzi) has been advised of finding as a courtesy, Note 2: UESI (under the name of S.G. Pinney and Associates - UES) has provided UT-15 coating repairs for tho Pilgrim Nuclear Station under the contract conditions of ASTM D-3911-95, which product is shown to satisfy the requirements of on CZ-1 1 substrate, therefore they are exempt from this Part 21 notification, but PNS has been advised of the finding as a courtesy.
Note 3:
1325 (under the name of S.G. Pinney and Associates - UES) has provided UT-i 5 coating repairs for the Peach Bottom Nuclear facility, but the coatings material was determined to be considered not a "Qualihfied Repair" due to the SGPAI-UES Inspectors not being provided opportunity to perform a Final visual examination of the applied coatings due to time constraints. On this basis, PECO must evaluate impact of this Part 21. notification, and have beenadvised{(Dan Testa, Paul Macuiba) of the finding as a courtesy.
(iiUd.ntification of the firm constructi*_thefacility or supplying the basic crowoMneif which fail5 to _omply with or contains the defect.
Underwater Engineering Services, Inc 1326 SW Biltmore St.
Port Saint Lucie, FL 34983 Ph. 772-337-3116 (iv)_Nature of the defect or failure _.toomplv and the safety kazarid whiphs created by such a defect orlailure to comply.
Review of Design Basis Accident Reports revealed that the post DBA/Irradiation test acceptance criteria for blistering was exceed on 4 of 16 test panels tested on CZ-1 I substrate, when evaluated to the requirements of ANSI Ni 01.2-1972, Blisters and adjacent repair coating were noted as "sound and fully intact", which complies with ASTM D-3911-95, but the size of blisters was documented as size #2 and larger. ANSI N101.2-1972 requires that blister size be limited to few, size #4 and smaller. Pieco UT-15 satisfactorily passed all other acceptance criteria established in ANSI NI0 01.2-1972 (flaking, cracking, delamination, peeling and chalking).
Safety Hazard: On the basis of the UESI evaluation, while the Picco UT-15 coating was incorrectly presented as ANSI NI01.2/N5.12 qualified over Carboline Carbo-Zinc 11 substrate, the results of the irradiation and DBA testing confirm that.UT1 5 remained sound and fully intact with no other coating failures noted. UESI is confident in assessing that UT-15 poses no substantial safety hazard, as it will not contribute to the ECCS debris source term inventory of coatings debris. As the seller and installer of the UT-15 coating material, UESI cannot adequately evaluate the product for purchaser/affected licensee with regard to facility specific Safety Analysis requirements. As referenced in Part 21.21(3)(ii)(b) UESI is
UNDERWATER ENGINEER G SERVICES, Inc.
1326 S.W. Biltmore Street Port Saint Luci, FL 34983 Usa.waa n
UUMn.
Page 3 of 3 informing licensees (within 5 days of this determination) where Picco UT-I 5 was sold and installed on CZ-1 1 substrate under the auspices of ANSI NI 01.2 so that they may properly evaluate in accordance with their I OCFR50 App. B quality program, (v) The date on whic, the information of sueh defect or failure to comply was Qb~tained.
NUPIC identified that a potential problem of unqualified coatings exists with results of the 1996 DBA/Irradiation Test on February 29, 2008. UESI initiated Nonconformance Report NCR # 2008-01, insured that no coating applications was scheduled in Nuclear facilities requiring adherence to ANSI N 1I 1.2-1972, notified parent company President of potential Part 21 and under his directive began investigation.
(vi) lathe case of p basic component which contains a defect orfails to comply. the number
,and location of aL, s1uch com*nments in use at, supniied for, or being supplied for one or more facilities or activiticasubject to the reullations in this part.
Duane Arnold Energy Center: undeternined sq. ft.
(vii) The corrective-action wich. has been._is being. -or will be t.ken: the rname of the individual or organization respoonsible for the action; and the jength of time that has been or will hbetaken to complete the action.
ULTESI Quality.Assurance shall issue a Records Correction. Notice to amend the DBA/Irradiation Test dated 12/16/1996. This record will limit the use Picco UT-i5 on substrate material Carboline Carbo-Zinc 11 runder the auspices of ASTM D-391 1-95 only.
The records correction shall also amend the i-eport to indicate acceptance of product test to ANSI N101.2 for other DBA/Irradiation Tested substrates. This action item is planned to be completed within 60 days of this report.
(vii) Any adyice relat.d to the dpfect or hailure to comt Iy about the facilitAstivi, ob.asic e
.onent that has beM.-is being. or will betgiven to purchasers or-licensees.
Picco UT-15 is DBA qualified for Service Level I coatings applications in accordance with ASTM D-3911-95 and subsequent revisions to date.
Picco UT-15 is DBA qualified for Service Level I coatings application.s in accordance with ANSI N 101.2-1972, excluding application on Carboline CZ-11 substrate.
Picco UT-15 maintains excellent adhesion and resistance to peeling, cracking, flaking and.
delamination, and, based on irradiation and DBA test results, will nbt contribute to the coatings component of the ECCS debris source term.
If you have any questions or need additional information concerning this notification, please contact Chris Graham, UESI QA Manager or Robert Walcheski, UESI Assistant VP and Technical Manager, at (772) 337-3116.'