ML20140F063

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Rev 13 to Procedure QI-QP-11.4-23, Reinsp of Seal-Coated & Finish-Coated Steel Substrates for Which Documentation Is Missing or Discrepant
ML20140F063
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/18/1984
From: Britton N, Dunham F
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20140F059 List:
References
FOIA-84-487 QI-QP-11.4-23, NUDOCS 8507080090
Download: ML20140F063 (6)
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Text

)f-s l REVISION)l ISSUE INSTRUCTION

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PREPARED BY:

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fA-M-/ 7-84 REINSPECTION OF SEAL gg :

A EL STRATES APPROVED BY-.46G[

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CATE IS MISSING OR DISCREPANT

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1.0 REFERENCES

1-A QI-QP-11.4-29, of the Elcaneter Adhesion Tester for Isolating Areas stionable Coating Adhesion" j

1-B CP-QP-18.0, "I in R

  • gports" CCP-30, " Coating S'[eh)6~

tes Inside Reactor Buildings 1-C and Radiation Areas" "

1-0 CCP-30A, " Coating Steel S nside Reactor Buildings j

and Radiation Areas" y-i J

1-E QI-QP-11.4-1,

" Inspection of eel Abstrate Surface Preparation and Primer Application"*

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1-F QI-QP-11.4-5, " Inspection of Steel Su

.yat imer Repair and Seal and Finish Coat Application and ~.

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1-G QI-Q P-11.4-25, " Inspection of Steel Substrate Surface Pre-paration, Primer Application, Primer Repair, Seal and Finsih l

Coat Application and Repair" I

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l 1-H CP-QP-15.0, " Tagging System" j

i 2.0 GENERAL 2.1 PURPOSE AND SCOPE This instruction shall describe methods utilized by Quality Control in the neasurement of the dry film thickness (DFT) and adhesion to steel subs'trates of existing seal or finish l

coat applications using the Mark II Tooke Gage and the Elcometer l

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8507080090 850311 PDR FOIA HUGE 84-487 PDR

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CPSES an APR18 1984

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106 Adhesion Tester respectively.

The above tests are destructive in nature which will necessitate a' repair of the coating systen at each spot test beation.

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3'a INSTRUCTION I

,...,.., For each seal or finish coated steel iten or component for

-... which. documentation is missing or discrepant, the tests discussed in Paragraphs 3.1 and 3.2 shall be perfomed at the frequencies indicated therein.

3.1 TOOKE TEST (SCRATCH TEST)

The scratch test shall be perfomed by using a Mark II Tooke Inspection Gage using a 2X tip.

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A daily confidence check shall be perfomed to insure accuracy of the Tooke Gage. The gage shall be inspected for damage, j;

tip ware and a scratch shall be made with the Tooke Gage and-compared to a reading obtained using a calibrated Elcometer Inspection DFT Gage or equivalent.

Tne reading obtained with-the ZX tip of the Tooke Gage shall not vary by more than t 0.5 mils from that obtained with the Elcaneter Inspection DFT Gage.

E Five tests shall be taken for every 100 square feet. of coating.

For areas of less than 100 square feet, frequency of testing shali be as foilows:

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Size of Itan (Sq. Ft.)

Number of Tests Required

- IM40 5

80-50 4

50-10 3

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. No minimum topcoat thickness shall be specified however, I

the topcoat shall provide full " hiding" properties of.the primer.

Maximum combined thickness of primer and *apcoat average shall be.013 in, with maximum spot check of.015 in.

Dry film thickness shall be as follows:

Any Single Reading Ave rage l

CZ 11 Primer 1.5 - 7.0 1.5 - 7.0 D6 1.5 - 7.0 1.5 - 7.0 Carboline 191 1.5 - 7.0 1.5 - 7.0 l

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TEXAS UTILITIES GENERA..dG CO.

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-In the event that any reading (s) is found to be outside of the acceptable primer thickness' range, additional readings 2 -

shall be taken to detennine the extent of the unacceptable area.

Dimensions and locations of. unacceptable areas and results of additional testing shall be documented on -

This area (s) shall be repaired in accordance l

with Reference 1-C or 1-D.

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- NOTE:

Seal-or finish coated surfaces meeting the following descriptions shall not be subject to "

testing with the Tooke gage:

a.

Areas or items which are inaccessible due to installation of pennanent itens or equipment.

b.

Items that due to their size or configuration will not accamodate testing with a Tooke gage.

c.

Areas or items which have acceptable Primer Records shall be tested wi th a Elcaneter Inspection DFT Gage or equivalent.for total system.

3.2,

ADHESION (PATCH) TEST i

The QC inspector shall perfonn an Adhesion (Patch) Test on i

each seal or finish coated iten (See Note 1). A calibrated Elcometer 106 Adhesion Tester shall be used to verify that the minimum acceptable tensile strength of adhesion of the coating systen to the steel substrate has been attained.

Adhesion testing shall be performed in accordance with

. Reference 1-A.

(See Note 2 and 3 below).

- NOTE 1:

For larger seal or finish coated areas such as -

containment building liner plate, the Inspector shall perfonn one test for every 500 square feet of' coating.

i NOTE 2:

For itens with total exposed surface. area of 10 square feet or less, each adhesion test shall consist of only one dolly tested.

o NOTE 3:

Seal or finish coated surfaces' meeting the following descriptions shall not be subject to adhesion testing:

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TEXAS UTILITIES GENERAv.dG CO.

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a.

Areas or items which are inaccessible due.to I

. installation of permaner.t items or equipment.

b.

Itens that due to their si::e or configuration will not accomodate testing with an Elcometer 106 Adhesion Tester.

Acceptance Criteria:

The minimum acceptable strength per dolly shall be 250 psi

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If a dolly should fail the minimum strength criteria, the following-additional adhesion testing shall be perfonned:

1)

On large surface areas such as liner plate, four additional dollies shall be adhesion tested at approximately one foot fran the failing dolly and spaced radially at approximately 90 degree intervals.

2)

On components with smaller surface area such as miscellaneous steel or supports (conduit, cable tray, or pipe), two additional dollies shall be adhesion tested at one foot or less fran the failing dolly with one located on each side of it.

If any of the additional dollies should fail the minimum i

strength criteria, additional dollies shall be placed and tested in accordance with 3.2 or as applicable until area of loss of adhesion is isolated.

This area (s) of coat ~ing shall be renoved to the substrate, and new coatings applied in.accordance with Reference 1-C or 1-0.

3.3 STATUS INDkCATORS A

During backfit activities when itens are unsatisfactory and could be inadvertently recoated with the unsatisfactory condition renaining, a reject tag shall be used in accordance with Reference 1-H.

A reject tag shall be placed on the

~ ites or area referencing the unsatisfactory Inspection Report number and applicable NCR number.

3.4 DOCUMENTATION Results of inspections per Paragraphs 3.1 through 3.2 shall be documented on Inspection Repo rt, Attachment 1,

in accordance with Reference 1-B.

The completed IR shall be forwarded to the PPRV for retention.

For inspections of coated containment liner su rfaces, the Ins pector may document one IR for each 500 square feet of surface area.

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INSTRUCTION ISSUE RWl' 4

PAGE TEXAS UTILmES GENERA 4.'NG CO. - NUMBER DATE

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CPSES QT-QP-11.4-23 13 APR 18 1964 5 of 6

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3.C REPAIRS Repairs of each coating area either scratch-tested or adhesion tested shall be performed in accordance with.

Reference 1-C or 1-D and reinspection of repaired coatings shall be in accordance with Reference 1-F or 1-G as ' applicable.

3.6

... MAPPING. OF LARGE AREAS

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For large areas (such as reactor containment liner plate) each IR No. and the inspection area to which the IR corresponds shall be indicated on the map drawing.

The map drawing shall be' maintained by the QC Supervisor, or his designee, until the entire surface has been inspected as required. Completed map drawings shall be transmitted to the Pennanent Plant Recanis Vault.

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TEXAS UTILITIES GENERATING CO.TIIRNY t,

2005 RRY AN TOWER DAtJ.AA TEX AS 7520s

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Noyember 19, 1981 TXX-3439 Mr. G. L. Madsen, Chief Reactor Projects Branch 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 PEAX STEAM ELECTRIC STATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NO. 81-15 FILE NO:

10130

Dear Mr. Madsen:

We have reviewed your letter dated October 26,19R1 on the inspection conducted by Mr. C. E. Johnson of activities authorized by NRC Construction Pennits CPPR-126 and CPPR-127 for the Comanche Peak f acili 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, i

R.

. Ga ry RJG:kh i

Attachments RECEIVED NOV 2 4198L QUAUTY ASSURANCE i

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cc:

R. J. Gary (2)

8. R. Clements D. N. Chapman R. L. Ramsey f

J. C. Kuykendall J. T. Merritt D. Frankum H. C. Schmidt B. S. Dacko R. G. Tolson R. G. Taylor F. B. Shants e

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Inspection Report

. 81-15 TXX-3439 Page,

l APPENDIX A NOTICE OF VIOLATION 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 Ouality Assurance Procedures for the Inspection of Coatings 10 CFR 50, Apppendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by documented instructions, 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 perfom inside containment buildings ( ANSI N10* 4, Service Level I) such Protective Coati'ng inspections as needed to verify conformance of activities affecting coating quality in accordance with Quality Instructions and Procedures."

2.

QI-QP-11.4-3, Revision 5, " Inspection of Steel Substrate Prime Coat Applications", states, in part, " Inspection of Prime Coat Applications, shall be documented on the Primer Application Checklist. The Inspector shall perfom a Dry Film Thickness (DFT) i 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 mils."

Contrary to the above:

1.

Fran late September 1979 to'the present date, there has been no documentation of coating applications for miscellaneous steel, cable tray supports or pipe supports inside Unit 1 and 2 Containment Buildings {as required by the above procedures.

I 2.

The majority of the records reviewed for the Unit 2 Containment 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 reviewed pertained.

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This is a, Severity Level IV violation.

(Supplement II, Paragraph D)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

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TEXAS UTILITIES GENERATING COMPANY

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Docket Nos. 50-445

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50-446 (Comanche Peak Steam Electric

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Station, Units 1 and 2)

AFFIDAVIT R. J. Gary being &ly sworn, hereby deposes and says that he is Executive Vice President and General Manager of Texas Utilities Generating Company; that he is &ly 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, information and belief.

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R. d.fiaary

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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 l

h Amt onthisggd day of dLa wm40, 19 M.

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L fnspection Report i 81-15 j

TXX-3439 Page '

CORRECTIVE STEPS WHICH HAVE BEEN TAXEN AND THE RESULTS ArMIEVED 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 i

of existing records and reinspection of affected 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 us.ing 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 app oved procedures.

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CORRECTIVE STEPS WHICH HAVE BEEN OR WILL BE TAXEN TO AVOID FURTHER VIOLATIONS i

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 -

allowable range for application of the coating system.

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2)

Inspection (Quality) Procedures / Instructions have been revised and j

reissued.

These efforts include the following salient actions:

j a)

Transmittal of inspection records to the Permanent Plant Records Vault on a timely basis.

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b)

Consolidation and simplification of the inspection instructions j

and associated documentation.

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c)

Relative to liner inspections, the establishment of mapping j'

techniques to assure that required inspections are accomplished and to provide positive accountability of inspection records.

i d)

Indoctrinetion of inspection personnel in the revised Procedures / Instructions which included emphasis on the proper completion of inspection records.

i, 3)

Relative to miscellaneous steel and supports, development and implementation of a unique identification system providing l

traceability of inspection documentation from blasting through

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l installation and final coating.

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Quality Engineering is also reviewing Procedures / Instructions for finish coat l

l applications and inspections.

These documents will be revised as appropriate l

to provide results similar to those outlined above.

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' Inspection Repo t.. 81-15 TXX-3439 Page.

DATE OF FULL COMPLIANCE i

Preventive measures were initiated immediately following the NRC inspection i

and are schedJ1ed for completion on or before December 31 1981. Corrective actions are currently in progress and will be complete $ c,onsistent with the construction schedule.

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QTN-434 TEX.a UTILITIES GENERATING COLNY OFFICE MEMOR ANDUM October 2, 1981 J. T. Merritt Danas. Texas Tc.

Subject COMANCHE PEAK STEAM ELECTRIC STATION TUGC0 QA AUDIT REPORT TCP-24 PROTECTIVE COATINGS QA AUDIT FILE: TCP-24 On September 14-18,1981 TUGC0 QA Audit TCP-24 was performed on Protective Coatings. The audit team was composed of Bobby Shoemake (Acting Team Leader), Debra Anderson, Cecil Manning (Observer) and Al' An Kesler (Observer).

Attachment A of this report contains an audit summary and the attendees of the pre-and post-audtt meetings.

Any deficiencies, concerns and observations noted during the course of the audit are contained in Attachment B.

No response is required by you.

By copy of this memo to R. G. Tolson, we request a response to Deficiency No. I and Concern No.1 by November 6,1981.

In your response, please provide the following information for each deficiency.

1.'

Describe what corrective action has or will be taken for each deficiency.

2.

Describe your preventive action to prevent recurrence of the

- deficiency.

3.

Indicate the date your corrective action, as described in item 1 above, will be implemented.

Should you have any questions, please contact Bobby Shoemake at 214-653-4665.

Very truly yours, R.

,w D. N.

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Manager, Quality Assurance DNC/AV/DLA/AX:med Attachments cc:

B. R. Clements R. G. Tolson G. W. Parry

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TCP-24 Audit Summary Personnel Contacted:

Mark Wells Bobby Hamilton Bobby Lockamy Jim Brackin Roy Giddings J. D. Martin Scope:

The audit scope included receiving, storage and handling, certifications, l

M&TE, application and inspection documentation regarding protective coatings i

on concrete.

In the course of the audit the following documents were reviewed:

y Coating Application Personnel Certifications Applicable Receiving Records QC Personnel Certifications and Indoctrination Records QA Surveillance Checklists for Storage and Control of Coatings for the 3

1 Previous 12 Months Coating Storage Weekly Temperature Recorder Charts for the Previous 12 Months QC Concrete Substrate Surface Preparation Inspection Checklis'ts j

QC Concrete Material Identification and Mixing Checklists i

QC Concrete Substrate Surfacer Application Checklists 1

QC Concrete Substrate Finish Coat Application Checklists l

Calibration Records on Instruments Used on QC Concrete ChecG:sts Auditors also observed the protective coatings storage facility and actual preparation work being done prior to application including QC Intpectors verifying ambient conditions.

One deficiency regarding calibrated equipment and one generic concern in the area of inspection documentation were identified.

In addition two observations were noted during the audit.

Details of these items are contained in Attachant B.

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TCP-24

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Paga 2 Summary:

Overall the Protective Coatings Concrete program appears adequately implemented except as noted in Attachment B.

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b A&?%n R. H. Shoemake i

Acting Team Leader e

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ATTACHitENT B TCP-24 DEFICIENCIES, CONCERtlS & OBSERV5TIONS e

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Audit No. TCP-24 Deficiency No, t

Requirement:

QI-QP-11.4-10, Revision 1, paragraph 3.1.1 states, in part, "The surface temperature shall be determined by placing a calibrated surface temperature thermometer in contact with the suhstrate surface to be water blast cleaned.

CP-QP-13.0, Revision 2, paragraph 3.3 states, in part, "The quality engineering supervisor shall be notified in writino by the calibration facility when M&TE or reference standards are found to be out of calibration. He will assure that all equipment tested or calibrated by the deficient item since the last calibration is identified and sufficient investigation performed to either re-establish the acceptability of the equipment or to confirm a nonconformance with completed installations.

The results of such investigation shall be documented."

lj Finding:

t Contrary to the above the following discrepancy was found.

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MSTE 444 used on 5/6/79 and 5/17/79 on RB #2808 for AZ 7 AZ 40 was

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calibrated on 3/9/79 and calibration was due again on 6/4/79. The surface i

thermometer was found to be out of calibration on the high-range scale per IEI-25.

g On 6/7/79 a letter was sent to the Paint Department Superintendent stating the above condition and requesting a check for possible nonconformance.

The Paint Department Superintendent replied on 6/15/79 stating that the thermometer had not been used in conjunction with any final acceptance records. However a QC final acceptance of a surface application checklist was. identified using MATE 444 (checked out to the Paint Department) for final acceptance on 5/17/79.

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Audit No. TCP-24 Concern No.

1 During review of Qb Inspection documentation, Auditors identified three -

types of problems occurring within the 8 packages (35 Inspection Documents) observed in the course of the audit.

It is understood that no final acceptance of these documents has been made but it is felt the problems identified could have a detrimental impact on the final acceptance process of the records involved.

The problems identified are:

1.

Procedural Inconsistencies Incorrect pot life 2 of 35 M&TE number not recorded 6 of 35 A'pplicable Quality Inspection not recorded 6 of 35 Applicator not listed 2 of 35 No date 1 of 35 No Inspector initials or signature 1 of 35 Mixing time / Batch number lef t blank 1 of 35 Dry Film Thickness recorded.but not initialed or dated 1 of 35 The majority of the inspection documentation has not had final acceptance and has not been formally transmitted or accepted in Permanent Plant Records Vaul t.

2.

Surface Temperature is required to be 50 higher than dew point prior to application. One checklist was found where this criteria was not met.

1 3.

In 3 of the eight packages observed, the finish coat had been applied; however, checklists documenting the preceding applications (i.e.

surfacer and surfacer repairs) had not been completed nor finally accepted.

Please indicate what actions you propose to take with the inspection documents currently stored in the PPRV to address the above three problem i

areas.

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s OBSERVATION NO.1 During the course of the audit, Auditors discovered some confusion regarding the method of determining dry film thickness on concrete. The procedures QI-QP-11.4-12, paragraph 3.2.2 and QI-QP-11.4-14, paragraph 3.3.2 state that dry film thickness shall be determined "by taking suffi'cient wet film thickness readings and multiplying each reading by the percent volume solids." QC indicated that due to the small amount of paint shrinkage the wet film thickness measurement is used without multiplying by percent volume solids. There appears to be a need to clarify the methods to be used to l

detennine. dry film thickness.

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TCP-24 OBSERVATION NO. 2 l

While reviewing the Quality Assurance Department Surveillance Checklist for 3l storage and control of coatings che'cklists and the weekly temper.ature recorder charts, several inconsistencies were noticed.

Some of the recorder charts had missing time, periods of hours, days and on one chart, a week was unaccounted for. Weekly charts were also being used to record 2, 3 and more weeks on a single chart. One discrepancy betwee'n the recorder chart dates and the checklist date was also observed.

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TEXAa UTILITIES GENERATING COMhtNY gg OFFICE MEMOR ANDUM R G Tolson h V

Dallas, Texas January ??- 14R2 gTo llPl~

i Subject COMANCHE PEAK STEAM ELECTRIC STATION EVALUATION OF AUDIT RESPONSE TCP-24 PROTECTIVE C0ATINGS 4

i QA AUDIT FILE:

TCP-24 Your additional response to TCP-24 logged TUQ-1085, dated December 30, 1981, has been evaluated by TUGC0 QA. We consider your responses to Deficiency No.1 and' Concern No.1 acceptable. No further response is necessary. As discussed with you, we plan to evaluate your preventive measures for Concern No. I during a site audit scheduled for the week.

of January 25-29, 1982. We will schedule an audit to evaluate your corrective actions as described in your response dated December 30, 1981, 2

consistent with your April 30, 1982 implementation date.

Thank you for your cooperation.

E% d' D. N. Cha pp n

Manager, Quality. Assurance j

DNC/AV/DLA/R S:med cc:

B. R. Clements i

J. T. Merritt l

G. R. Purdy G. W. Parry 6

RECEIVED JAN 2 51982 i

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' TEXAS UTILITIES GENEllATING COMinNY OFFICE MEMOR ANDUM Decembe r 30, 1981 D. N. Chapman clen nme. Texas To subject TUGC0;0A, Audit,TCP Formal Response

Reference:

TUQ-992, QTQ-96, TUQ-1016 The following represents our formal response to TUGCo QA Audit TCP-24.

t DEFICIENCY NO. 1 Requi rement:

QI-QP-11.4-10, Revision 1, paragraph 3.1.1 states, in part, "The surface temperature shall be determined by placing a calibrated surface temperature thermometer'in contact with the substrate surface to be water blast cleaned.

CP-QP-13.0, Revision 2, paragraph 3.3 states, in part, "The quality engineering supervisor shall be notified in writing by theicalibration f acility when M&TE or reference standards are found to be out of calibration. He will assure that all equipment tested or calibrated by the deficient item since the last calibration is identified and sufficient investigation performed to either re-establish the acceptability of the equipment or to confinn a nonconformance with completed installations.

The results of such investigation shall be documented.

Finding:

Centrary to the above the'following discrepancy was found.

0 MATE 444 used on 5/6/79 and 5/17/79 on R8 #2 El. 808' for AZ 7 - AZ 40 was l

calibrated on 3/9/79 and calibration was due again on 6/9/79. The surface thermometer was found to be out of calibration on the high-rar.ge scale per l

l IEI-25.

On 6/7/79 a letter was sent to the Paint Department Superintendent stating the above condition and requesting a check for possible nonconformance. The 4

Paint Department Superintendent replied on 6/15/79 stating that the l

thermometer had not been used in conjunction with any final acceptance records. However a QC final. acceptance of a surface application checklist was identified using M&TE 444 (checked out to the Paint Department) for final acceptance on 5/17/79.

RESPONSE

Af ter further investigation into the nature of the condition identified by Deficiency No.1, we have concluded that said condition is in fact not a deficiency. The subject QC inspection checklists for inspections performed on 5/4/79 at El. 808' in Reactor Containneng Building Unit #2 indicate a concrete surface temperature reading of 62 F.

This reading is close to the e

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'l O. N.' Cha.pman' Page 2 December 30, 1981 0

midpoint of the low range scale of M&TE 444 (0 to 110 F) and M&TE 444 was found to be within low-range calibration limits of IEI-25 during the calibration check co,lducted on 6/7/79. The high-range scale of V&TE 444 was found to be out of calibration on 6/7/79 but it was not used in this Quality Inspection.

In addition, a further check of all concrete coatings records revealed that M&TE 444 was used by QC in 27 other Quality Inspections bgtween g/8/79 and 7/5/79 with reco,rded surface' temperatures ranging from 72 to 88 F - all within the low-range scale.

It should be noted here that since early 1980, all surface thermometers have been calibrated to the low-range scale only because it was determined that they were not being used in the high-range scale.

We have concluded that the condition noted in Deficiency No.1 is not a deficiency, and therefore, no corrective action is required.

CONCERN NO. 1 Ouring review of QC Inspection documentation, Auditors ide tified three i

types of problems occurring within the 8 packages (35 Inspection Documents) observed in the course of the audit.

It is understood that no final acceptance of these documents has been made but is is felt the problems identified could have a detrimental impact on the final acceptance process of the records involved. The problems identified are:

1 1.

Procedural Inconsistencies Incorrect pot life 2 of 35 M&TE number not recorded 6 of 35 Applicable Quality Inspection not recorded 6 of 35 Applicator not listed 2 of 35 No date 1 of 35

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signature 1 of 35 Mixing time / Batch number left blank 1 of 35 I

j Dry Film Thickness recorded but not initialed or dated 1 of 35 The majority of the inspection documentation has not had final acceptance t

and has not been formally transmitted or accepted in Permaisent Plant Records

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Vault.

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.1 D. N.' Chapman l

Page 3 December 30, 1981 0

2.

Surface Temperature is required to be 5 higher than dew point prior to application. One checklist was found where this criteria was not met.

3.

In 3 of the eight packages observed, tha finish coat had been applied:

however, checklists documenting the prebeding applications (i.e. surfacer and surfacer repairs) had not been completed nor finally accepted.

Please indicate what actions you propose to take with the inspection documents currently stored i_n the PPRV to address the above three problem areas.

RESPONSE

An extensive review of concrete coatings inspection documentation is now in process. The problems which we have identified are similar in nature to those identified in Concern No.1.

We share your concern that these documentation problems could have a detrimental impact on the final acceptance process of subject documentation, j

I Corrective Action:

i As indicated above, we have begun a review of all concrete coatings inspection documentation.

Based upon problems noted in a preliminary review, we have i

initiated NCR numbers C-81-01613, R.1 and C-81-01823. These NCR's identify i

the fact that a majority of concrete coatings inspection reports issued prior to 11/11/81 exhibit omissions of various entries including dry film thickness, final acceptance signature and date, applicable inspection instruction, M&TE number for test equipment used, visual defects and continuity inspection i

results, names of qualified applicators, etc. We will attempt to complete entries in subject documentation based upon infomation available from cor-responding inspection reports which contain the missing infomation or from l

field books and sketches maintained by QC Inspectors. All records for which j

missing entries cannot be obtained shall be presented to Civil Engineering for evaluation and inclusion as part of disposition to the above mentioned NCR.

In some cases it may be necessary to perfom destructive testing on concrete coatings to verify conformance to Specification AS-31 and Quality i

Instructions.

i Action to Prevent Recurrence:

As previously noted in our preliminary response to prevent recurrence of conditions noted in Concern No.1, the following action has been taken:

1) Quality Instructions describing coatings application on concrete substrate have been incorporated into a single Inspection Instruction QI-QP-11.4-10, i

" Inspection of Concrete Substrate Surface Preparation and Coatings Applica-I tion and Repair", which was issued 11/11/81.

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2) All Protective Coating inspection personnel were indoctrinateo in the new QI-QP-11.4-10 including explicit instructions on completion of new j

inspection reports.

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O..N. Chapnen Page 4 Decentber 30, 1981 Date Corrective Action to be Fully Implemented:

. As noted above corrective action is presently.in process of being implemented.

We anticipate that corrective action on concrete coatings documentation will be fully implemented by April 30, 1982.

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R. G. 'Tolson

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cc: -H. Williams R. A. Cumings l

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.._ _ ___. c t e n ntwe. Texn, Noventbe_r_1L._19B1.

TUGC0 QA Audit TCP-24 sui.jeci _

" Action to Prevent Recurrence"

Reference:

TUQ-992 and QTQ-96 Attached find preliminary response to prevent recurrence of findings /

concerns expressed in TCP-24 As stated in TUQ-992, formal response to this audit will be provided on or before January 4,1982.

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j( h(W R. G. Tolson TUGC0 Site QA Supervisor RGT/CTB/bil '

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I PRELIMINARY RESPONSE TO PREVENT RECURRENCE Preliminary action to prevent recurrence is conplete. Quality Procedure CP-QP-11.4 was revised 10/29/81 to require documentation be completed and submitted to the Permanent Plant Records Vault in a timely fashion.

Quality Instructions concerning inspection of surface preparation of steel substrate, primer application and repair have been consolidated into a single inspection instruction QI-QP-11.4-1, " Inspection of Steel Substrate Surface Preparation and Primer Application and Repair". This procedure was issued 10/23/81.

Quality Instructions describing appl'ication and repair of seal and finish coat were combined into a single instruction QI-QP-11.4-5, " Inspection of Steel Substrate Seal and Finish Coat Application and Repair", which is to be issued this date.

Quality Instructions describing coating application on concrete substrate have been incorporated into a single Inspection Instruction Ql-QP-11.4-10,

" Inspection o_f Concrete Substrate Surface Preoaration and Coatings

"- -)g - Application and Repair", which was issued 11/11/81.

All Protective Coating inspection personnel were indoctrinated in new procedures / instructions, including explicit instructions on completion of new inspection reports.

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QTQ 96 TEXho UTILITIES GENERATING CO.ilrANY OFFICE MEMOR A N DU M To R. G. Tolson Dallas, Texas November 13, 1981 Subject TUGC0 OA AUDIT TCP-24 e

The extension requested for additional time to provide response to audit TCP-24 will be conditional. The extended time requested for response to corrective action is acceptable; however, it is necessary that your response to prevent recurrence be submitted by November 23, 1981.

W b.N.Chapan Manager, Ouality Assurance DNC/AV/DLA/RHS:med RECEgygg NOV 17 793;

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Chapman ci.., i t..,...

r..sn October 30, 1981 sia i..i TUGC0 QA Audit TCP-24 Due to the anount of program restructuring in the area of protective coatings as a result of the NRC citation on the subject, we are requesting an extension until January 4,1981 to provide response to the subject audit.

Additional tirne is necessary to evaluate -the program before providing response, f.$%)

R. G. Tolson TUGC0 Site OA Supervisor RGT/ #p1 i

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