ML081200882

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Notification of Potential Part 21 on Safety Related Noncompliance Deviation
ML081200882
Person / Time
Site: Hatch, Monticello, Dresden, Peach Bottom, Browns Ferry, Fermi, Oyster Creek, Cooper, Pilgrim, Columbia, Limerick, Vogtle, Duane Arnold, Comanche Peak, Quad Cities, FitzPatrick, LaSalle
Issue date: 04/14/2008
From: Graham C C
Underwater Engineering Services
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML081200882 (21)
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Text

IjdcEwot E ~ t;-fx~~ ESrvn% 1(UNDERWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street Port Saint Lucie, FL 34983

Subject:

Completion of evaluation:

1 OCFR Part 21 Notification of Potential Safety Related Noncompliance Deviation United States Nuclear Regulatory Commission Document Control Desk To: Evaluation Renort Cover Letter: On Wednesday, April 9 t, 2008 UESI repoited an initial notification of potential Part 21 applicability to the USNRC. This notification was faxed to, and confirmation received from, the NRC Operations Center.Please find attached the completed evaluation report of the UESI Part 21-review of its Picco-UT- 15 Service Level I repair coating material, and its impact, if any, on end users of the product. There have been no changes between the initial notification sent to your office, and the final evaluation enclosed with this document.

The evaluation report has been final reviewed and approved by the CEO/Presideht of UESI.UESI has provided a copy of the evaluatio'nifor your information.

Attachment 2 of the evaluation is a copy of the official notification that was faxed to your Operations Center.UESI has notified all applicable facilities ti at may have been impacted by this Part 21, and provided a copy of this report to them. *If you have any questions or need additional information concerning this notification, please feel free to contact me, Regards, Chris C. Graham UESI QA Manager Phone: (772) 337-3116 (x114)Fax: (772) 337-0294 Email: cgraham@uesi.com FJ U (?MB UNDERWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street Port Saint Lucie, FL 34983 Page 1 of 16 Potential 10 CFR 21 Applicability Review UESI Service Level 1 Coating Repair Material Picco UT-15 Evaluation Team: A Review Team was formed as directed by UESI/GPI President Steve Greenman to resolve UESI Nonconformance Report #2008-01 (Reference

1) and the associated findings of NUPIC Audit 08.03.SPAFL.08.1 (Joint Audit # 20119) (Reference 2). The Review Team members responsible for the results entailed in this report are: " Mr. Jon R. Cavallo, PE, Vice President of GPI affiliate Corrosion Control Consultants

& Labs, Inc, UESI Certified Level III Coatings Inspector, registered Professional Engineer, ASTM D-33 Nuclear Coatings Committee Chairman, a SSPC certified Protective Coatings Specialist and industry leader in coatings evaluation and consulting." Mr. Robert Walcheski, UESI Technical Manager, UESI Assistant Vice President, Certified UESI ANSI Level III Coatings Inspector, ASNT SNT-TC-1A

& CP189 VT-1/V-3 (IWE, IWL, IWF) Level II, ASTM D33 committee member, certified NACE CIP Level II, former SGPAI-UES QA Manager, and;* Mr. Chris Graham, UESI Quality Assurance Manager, NQA-l Lead Auditor, NACE CIPI, Certified UESI ANSI Level II Coatings, Certified UESI ANSI Level III Visual Welding, Current API 510 Certified Inspector, CQCM and UESI Part 21 Review Team POC.Report submitted for review and approval to UESI/GPI President by: Chris C, Grahan/Py.

4 EST Quality Assurance Manager Date I have reviewed the results of this evaluation and concur with its evaluations and conclusion.

I have reviewed and approved this report, and authorize applicable determinations made within this internal evaluation to be included in the official Part 2L21 submittal to the Nuclear Regulatory Commission, in accordance with 1OCFR t uality Assurance Manual, 3"d Edition, Rev. 0.Ste--en Greenman- -entCEO Date K-j UNDERWATER ENGINEERING SERVICES, Inc.(1326 S.W. Biltmore Street fPort Saint Lucie, FL 34983 Und.a,,-,-

ýnonew.n- 1ýPage 2 of 16

SUBJECT:

Potential 10 CFR 21 Applicability Review as described in UESI QA Manual, QAP-15, R/5, Section 5.0 DISCUSSION A Review Team was formed as directed by UESI / GPI President and CEO Steve Greenman to resolve UESI Nonconformance Report #2008-01 (Reference

1) and the associated findings of NUPIC Audit 08.03.SPAFL.08.1 (Joint Audit # 20119 -Reference 2). The Review Team members assigned were:* Mr. Jon R. Cavallo, PE, Vice President of GPI affiliate Con-osion Control Consultants

& Labs, Inc, UES1 Certified Level III Coatings Inspector, registered Professional Engineer, ASTM D-3 3 Nuclear Coatings Committee Chairman, a SSPC certified Protective Coatings Specialist and industry leader in coatings evaluation and consulting." Mr. Robert Walcheski, UESI Technical Manager, UESI Assistant Vice President, UESI Certified ANSI Level III Coatings Inspector, ASNT SNT-TC-IA

& CP189 VT-1,/V-3 (IWE, IWL, IWF), ASTM D33 committee member, certified NACE CIP Level II, former SGPAI-UES QA Manager, and;" Mr. Chris Graham, UESI Quality Assurance Manager, NQA- I Lead Auditor, NACE CIPl, Certified UESI ANSI Level II Coatings, Certified UESI ANSI Level III Visual Welding, Current API 510 Certified Inspector and UESI Part 21 Review Team POC.PHASE ONE Evaluation:

The Review Team conducted an initial meeting on March 18, 2008. Dean Reynolds, UESI Vice President and Branch Manager also attended the 3/1 8/08 meeting. The purpose of the meeting was to create a schedule to identify locations of use and determine the acceptability of UT-15 coatings applied in commercial nuclear facilities.

An evaluation of all available Picco UT- 15 DBA/Irradiation tests was conducted under Phase One to confirm that Picco UT-15 meets the DBA/lrradiation requirements of ASTM D-391 1-95 (Reference

3) on all substrates tested. The Phase One Evaluation confirmed that Picco UT- 15 satisfies the DBA/irradiation qualification requirements for Service Level I coating to the acceptance requirements of ASTM D-3911-95 on all substrates tested.Next, the Phase One evaluation effort focused on the assessment of DBA qualifications tests to determine the acceptability of Picco UT-1 5 as it relates to the ANSI N101.2-1972 (Reference
4) and ANSI N5.12-1974 (Reference
5) (DBA/irradiation and lining test)requirements, establish the level to which the product meets those qualification requirements and identify any limitations that should have been imposed on the product after completion of irradiation and DBA testing in 1996. The 1996 irradiation and DBA testing is reported in Reference
6.

UNDERWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street*Port Saint Lucie, FL 34983 Underwater Eu-i'"neln' Servic". t Page 3 of 16 The 1996 irradiation and DBA test report for UT-15 (Reference

6) states, on page 3 of 7: "Testing was performed in accordance with ANSI N101.2 and ASTM D 3911 for DBA test requirements...

Specific parameters were obtained from anticipated DBA and irradiation conditions of various facilities as described in the applicable FSAR's," On page 5 of 7 of Reference 6, the following statement appears concerning DBA testing: "Examination and evaluation was performed in accordance with ASTM D 3911..." Again on page 5 of 7 of Reference 6, the following statement appears under Acceptance Criteria: "Peeling shall not be permitted.

Delamination shall not be permitted.

Cracking is not considered a failure unless accompanied by delamination or loss of adhesion.Blisters shall be limited to intact blisters which are completely surrounded by sound coating bonded to the surface." These acceptance criteria conform to the 1995 version of ASTM D391 1. These acceptance criteria do not conform to ANSI N1 01.2; specifically, ANSI N1 01.2 limits blistering to a few No. 4 blisters as defined in ASTM D 714 (Reference 7).The review team next identified the following information contained in the 1996 irradiation and DBA test report (Reference 6).1. Review of the 1996 test report revealed that testing of the Picco UT-I5 coating material, Batch I and Batch 2 met or exceeded-the acceptance criteria delineated in ANSI N 101.2-1972 and ASTM when applied on the following substrates; CZ-11SGQ Dimetcote 6N, Ameron 90, Keeler and Long 6548/7107, Valspar/Mobil V78 Series and Plasite 7155.2. Picco UT-15, Batch 3 met or exceeded the acceptance criteria delineated in ANSI N 101.2-1972 for all substrates referenced above with the exception of CZ- 1ISG.3. Simulated pitting defects of 1/16 in (0.0625 in.) were introduced into selected test panels.4, The 1996 test did not include Chemical Resistance Testing as defined in Section 5 of ANSI N5.12.The review team reviewed a 1990 GPU-Oyster Creek DBA/Irradiation Test (Reference 8), which provides the results of testing of Brutem- 15 (the predecessor of UT- 15).Testing was performed by application of Brutem 15 over CZ-1 ISG. No post-irradiation and post-DBA defects were noted.

UNDERWATER ENGINEERING SERVICES, Inc.(Mom 1326 S.W. Biltmore Street Port Saint Lucie, FL 34983 U Engn,,,g ,.,,, ... ,n.. Page 4 of 16 The review team reviewed a 2005 Duane Arnold Energy Center DBAilrradiation Test (Reference 9). Testing was performed by application of UT-15 over CZl 1SG. This testing was performed at the Owner's request as a result of a possible increase of the design peak temperature in the torus. Chemical Resistance Testing was not requested by Duane Arnold Site Engineering due to time and financial constraints, even though it was apparently invoked in the contract document.Phase One Summary: The review team, after conducting the Phase One reviews described above, holds the following opinions: 1. UT-I5 coating is qualified per ASTM D39 11-95 and ANSI N101.2-1974 for application as a repair coating over Dimetcote 6N, Ameron 90, Keeler and Long 6548/7 107, Valspar/Mobil V78 Series and Plasite 7155.2. UT-15 coating is qualified per ASTM D391 1-95 for application as a repair coating over CZ I ISG.3. UT-I5 coating is not qualified per ANSI N101.2 for application as a repair coating over CZI t SG.4. UT- I5 is qualified fIr repair of defects up to 1/16 in (0.0625 in.) in depth, subject to the limitations of I, 2and 3 above.Since the completion and evaluation of this 2005 DBA/lrradiation Test the review team concluded that UESt has not provided and installed any Pieco UT-I 5 coating to the DAEC facility.

It was also noted that UEST had takens, corrective action measures related to, the Test Report. Technical errors noted in this 2005 DAEC DBAilrradiation Test were identified and documented on a UESI Nonconformance Report (NCR # 2008-02).

UESI Quality Assurance initiated QA records corrections and submitted to Mr. Eric Sorenson of the DAEC facility as an amendment to the existing DBA/Irradiation Test, and the NCR was closed.This concludes Phase One of the review.

Underwatr Eng]-ordrlg ir l aqm , PHASE TWO Evaluation:

UNDERWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street Port Saint Lucie, FL 34983'Page 5 of 16 Phase Two of the evaluation began with a review of Final Engineering Reports, contract documents, job start and Order Entry Review forms of Nuclear Project work to determine the extent of use of Picco UT-I5 on Nuclear Safety related projects.UESI identified all nuclear coating project work involving Picco UT-15 performed since the 1996 DBA Test (Reference 6). This information is summarized in Table 1.TABLE 1 UT-15 Coating Phase 3 UESI Project # Repairs (Prefix) NUC- Client/ Facility Scope of Services Perlormed Evaluation

___ ___Required (YIN)Tor us desludging 2008101 SNC -Hatch Touspectin.

N N_____and inspection.

Torus desludging, 2007106 DTE -Fermi inspection

& YES YES Plasite 7155 repairs _________2007105 GPC -Branch Plant discharge N N 2007105__

GP -Branchrepairs NN ENW -Wetwell / drywell N 2007104 Columbia coatings N N Station inspection 2007103 ENW -Inspect Circ. N N Columbia Water Pump .....Torus desludge, 2007102 Wntry -inspection

& YES YES Pilgrim Station repairs CZ-ll D3911 2007101 SNC -: Hatch Torus desludge & N N inspection NN 2006105 INEEL Isolation pool N N TXU -Staff 2006104 NN Comanche Peak augmentation N.Vendor support 2006103 NPPD -Cooper Vno N N______________

CST _ _ _ _ _ _ _2006102 SNC -Hatch CST Plug removal N N Torus desludge & YES 2006101 SNC -Hatch Ameron YES inspection Dimetcote TXU -Staff 2005103 NN Comanche Peak augmentation TXU -Staff 200510O2 NN Comanche Peak augmentation 2005101 SNC -Hatch Torus desludge & N N inspection wtr uS Unde-~tur 1Engin-Ing Serriter.

In..UNDERWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street Port Saint Lucie, FL 34983 Page 6 of 16 TABLE 1 UT-15 Coating Phase 3 UESI Project # Client/Facility Scope of Services Repairs (Prefix) NUC- Performed Evaluation Required (Y/N)~(Y/79 2004109 NMC -DAEC DBA /Irradiation N N of UT-15 2004108 NPPD -Cooper Stafft N N_____________

augmentation

_______2004107 ENW -Dive inspections, N N Columbia clean & removal BioDur 561 2004106 NMC -Duane Coating repair and YES YES Arnold inspections 200,4.105 DTE -Fermi Torus desludge YES YES and inspection Plasite 7155 2004104 TXU -Staff N Comanche Peak augmentation 20043 TVA -Browns Subcontract to 2004103 Ferry UCC -Desludge YES YES______e_____y__&

coating repairs ____pr_78 2004102 [NEEL Underwater N N cleaning 2004101 SNC -Hatch Desludge and N N inspection TXU -Staff 2003106 N N Comanche Peak augmentation NMC -Qualification of 2003105 Monticello U/W coating N N repair systems 2003104 SNC -Hatch Steam dryer N N diving services 200 3ENW -Torus desludge, N 2003103 Columbia inspection and BioDur repair as needed Torus desludge, 2003101 SNC -Hatch inspection and N N RHR / CS dive 2002106 SNC -Vogtle Fire Water Storage Tank Insp. N N 2002105 TXU -Staff N Comanche Peak Augmentation 2002104 GPU -Oyster Sub to UCC YES YES Creek Coating repairs Valspar 78 Underwater Enrgin-erng Serri, Ic.UNDERWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street Port Saint Lucie, FL 34983 Page 7 of 16_ _TABLE I UT-15 Coating Phase 3 UESI Project # Client/ Facility Scope ofServices Repairs Evaluation (Prefix) NUC- Performed Required (Y/N)2002103 TXQ -Staff N N Comanche Peak Au2mentation Torus desludge, 2002102 SNC -Hatch inspection and N N repair as needed ENW -Torus desludge, 2002101 Columbia inspection and N N repair as needed Coatings N N 2001107 NPPD -Cooper inspection Carboline 890 Torus desludge, YES 2001106 DTE -Fermi inspection and Part B -00D063 YES_ _repair as needed Plasite 7155 Torus desludge, 2001105 SNC -Hatch inspection and N N repair as needed, EN W -Torus desludge, N 2001104 Columbia inspection and Amercoat 90 N repair as needed Ae.t.Torus desludge, YES 2001103 Alliant -DAEC inspection and Part B -00D063 YES repair as needed cz-11 N101.2 TVA -Browns Torus U2 inspect, 2001102 Ferry desludge, repair YES YES Torus desludge, Entergy -Tr d YES 2001101 inspection and YES Pilgrim repair as needed CZ-1 I D-3911 NYPA -SFP Interference 2000106 N N Fitzpatrick removal _ _ _2000105 NYPA -Torus desludge, N N Fitzpatrick inspection, strainer Torus desludge, 2000104 SNC -Hatch inspection and N N repair as needed 2000103 NPPD -Cooper Drywell coating N N 2000103_________

N Cinspection Carboline 890 Torus desludge, 2000102 SNC -Hatch inspection and N N repair as needed Underwater Enginer ng Service n UN)E RWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street Port Saint Lucie, FL 34983 Page 8 of 16 TABLE 1I Ti otn hs UT-15 Coating Phase 3 UESI Project # Client / Facility Scope of Services Repairs Evaluation (Prefix) NUC- Performed_(Y/N) Required (YN)Torus deshudge, YES 2000101 DTE -Fermi inspection and Plasite 7155 YES repair as needed 0990110 SGPAI QPS Development N N 0990109 CornEd -Quad Torus desludge, N N Citie tinspection and Cities rear as needed UT 790 0990108MPC

-D.C. AEP Concrete N N____ _Cook Coatings 0990107 TXU -Coatings N N Comanche Peak InspectionN 0990106 ENW -WNP 2 Wetwell diving N N (Columbia) services BioDur 9 'CornEd -Torus desludge N 0990105 Dred and ECCS strainer N N Dresden UT 790 -inspection Carboline DBA 0990104 Carboline Korea coordination N N Boston Ed -Torus desiudge, YES 0990103 inspection and Part B -98E084 YES____ Pgepair as needed CZ-11 D3911 Tomus desludge, 019900 102 SNC -Hatch inspection and N N repair as needed SCornEd -U2 Strainer* 0990101 ! LaSalle replacement N N 0 12 CornEd -Desludge and N N Dresden coating inspection UT 790 098 CornEd -U1 Strainer N N LaSalle replacement NN 0980110 TVA -Browns Desludge, coating N N Ferry Unit 3 inspection, strainer Torus desludge, 0980109 SNC -Hatch inspection and N N repair as needed Torus desludge, 0980108 DTE -Fermi inspection and YES_ _._repair as needed Plasite 7155 0980107 GPU -Oyster Strainer , YES YES Creek replacements Part B -98E084 Underwatr Englneartng Ser.lc", inc.UNDERWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street Port Saint Lucie, FL 34983 Page 9 of 16 TABLE I UT-15 Coating Further UESI Project # Client! Facility Scope of Services Repairs Evaluation (Prefi~x)

NUC- Performed (Y/N) Required (/N)0980106 WPPSS -Strainer N (Columbia) installation 0980105 SNC -Hatch Mock-up strainer N N 0980104 IEU -DAEC Desludge, YES YES inspection, strainer Part B -96H023 Torus desludge, 0980103 SNC -Hatch inspection and N N repair as needed 0980102 CornEd -Desludge, N N LaSalle insoection.

strainer UT 790 0980101 GE Morris Fuel basin liner N N COM 097 CornEd -Desludge, coating, N (7328) Dresden strainer Plastite 790 COM 097 CornEd -ECCS Strainer N N (7321) LaSalle installation COM 097 WPPSS -Destudge, inspect, N N (7320) (Columbia) renair coatings COM 097 SNC -Hatch Desludge, inspect, N N (7315) ECCS strainer COM 097 TVA -Browns Diver services, N N (7314) .Ferry ECCS strainer N_ __COM 097 PECO -Peach U/W Torus YES (7311) Bottom inspection Part B -9511023 COM07 NPPD-Cooper Desludge, inspect, YES (7301) repair as needed Part B -96H023 COM 097 SNC -Hatch Desludge, inspect, N N (7299) repair as needed COM 097 CornEd -Inspection and N (7298) LaS alle debris removal C790 COM 097 ComEd -Quad Torus desludge, N N (7292) Cities Unit t inspect, repair C790 COM 096 CornEd -Quad Torus desludge, N (7291) Cities Unit 2 inspect, repair C790 COM 096 Boston Ed -Desludge, inspect, YES Part B -96F077 YES (7290) Pilgrim repair as needed CZ-Pr B-3916 COM 096 Desludge, inspect, YES IES -DAEC Part B -96F077 YES (7287) repair as needed -NO.CZ-11 N101.2 COM 096 Boston Ed -Strainer walk N N (7286) Pilgrim down Undelater Engineei.ng S.rvce, Inc.UNDERWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street Port Saint Lucie, FL 34983 Page 10 of16 TABLE 1 UT-15 Coating Further UESI Project # Client / Facility Scope of Services Repairs (Prefix) NUC- Performed Required (Yon)(_ie(Y(N)

_COM 096 ECCS Strainer (7285) inspection NN COM 096 PECO -Suppression pool N N (7278) Limerick desludge, inspect COM 096 TVA -Browns Material sent to site (7277) 0e Browns Diving services UT-15 Issued 3job. but no recurd of use.COM 096 GPU -Oyster Torus destudge, YES YES (7275) Creek inspect, repair Part B -96F077 COM 096 NYPA -Coating inspection N N (7273) Fitzpatrick 096 (7270) CornEd -Desludgc, inspect LaSalle suppression poo1 N __096(7269)

WPPSS Desludge, inspect N N (Columbia) supp. pool TVA -Browns Torus desludge, N 096 (7256) Ferry inspect, repair 096(7255)

SNC -Hatch Desludge, inspect, N N__96__(72__5_

SN____ _h repair as needed Plastite C790 096(7253)

WPPSS -WTNP-2 FME N N 096_______3) (Columbia)

Suppression pool NN 096(7252)

ComEd -Quad Unit I Torus N N Cities desludge Plastite C790 Phase Two Summary: As depicted by Table 1, UESI reviewed all available documentation related to the issue, storage and installation of its Picco UT-15 in SErvice Level I coating applications to commercial nuclear facility clients / purchasers.

The review identified eight commercial nuclear facilities (Fermi, Pilgrim, Hatch, Duane Arnold, Oyster Creek, Browns Ferry, Peach Bottom and Cooper Stations) where Picco UT-i 5 repair coating had been applied to suppression pools/tori after the 1996 DBA / Irradiation Test results. The Phase 3 review (scheduled to commence on April 3d thru 5'h timeframe based on availability of team members) was planned by the Review Committee to evaluate substrates applied, acceptability to defined site specific criteria and whether a Part 21 notificationis required.This concludes Phase Two of the review.

ut ,l Underwter E=g~gel .ng Harmicos, Inm.UNDERWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street Port Saint Lucie, FL 34983 Page 11 ofl6 PHASE THREE Evaluation:

Review Team members convened as previously scheduled.

After review of the previous charts; related Final Engineering Reports, Purchase Orders, Contract requirements, Order Entries and other associated documentation with the Phase 2 evaluation, UESI identified eight commercial nuclear facilities (Fermi, Pilgrim, Hatch, Duane Arnold, Oyster Creek, Browns Ferry, Peach Bottom and Cooper Stations) where Picco UT- 15 repair coating had been applied to the suppression pools/tori after 1996. Table 2 below lists these facilities and indicates the review team recommendation for filing a 1 OCFR Part 21 report: TABLE 2 UESI Project Substrate UT-15 Material Code Part 21 Recommended?

Job Start !FER Client Facility Applied Referenced Yes/No Numbers Over (Contractual) (See Phase 3 Summary)2004106 YES -Product supplied 2013Coatings to meet iavretya N!N0.2001103 Duane Arnold CZ-11 ASTM D 3911, ANSI inadvertently as ANSINI01.2 0980104 N101.2 & ANSI N5.12 qualified, but only met ASTM D-096 (7287) 3911.Indeterminate-Pit depth repairs Contract 96-75 exceeded DBA qualification Unavailable

-FER limits for UT-1 5 at direction of 097(7301)

Cooper CZ-11 noted repairs facility nersonnel.

Repair Station performed as directed I P by facility.

No final C material was reviewcd and of C issued. evaluated "unqualified" according to client program.Indeterminate

-See Summary -097(7311)

Peach Bottom Product was deemed unqualified Unit 3 CZ-11 P.O. 00270469 R!A due to no final examination performed per PECO directive.

2007102 2003102 Pi!:in Contract specifies NO -Product'conmplies with D-2001101 CZ-11 Coatings to meet 3911 when applied to CZ-l I 0990103 Station ASTM D-3911-95 substrate 096 (7290)Browns Ferry Valspar Coatings to meet NO -Product complies to D-2 Unit 2&ASTM D 3911 and 3911 and N 101.2 on substrate 200 110 24nt2 37 ANSI N101.2 _ _ _ _ _ _ _ _ _ _ _2002104 Coatings to meet NO -Product complies to D-0980107 Oyster Creek Valspar ASTM D 3911 and 3911 and N 101.2 on substrate 096 (7275) 78 ANSI N101.2 2006101 Amero Coatings to meet NO -Product complies to D-080103 mHatch neo ASTM D 3911 and 0980103 Dimetcote ANSIN .2 3911 and N 101.2 on substrate 2007106 Plasite Coatings to meet NO -Product complies to D-2004105 Fermi 7155 ASTM D 3911 and 3911 and N 101.2 on substrate 2001106 ______ _____ ANSI N101.2 UNDERWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street Port Saint Lucie, FL 34983 U , E ,,ngn..,ig-.,n , S..vjG.. Inc- Page 12 of 16 Phase Three Summary: As determined by review team evaluation during the Phase One evaluation, the 1996 DBA/Irradiation Test revealed that Picco UT- 15 met the qualification and acceptance requirements of ANSI N 101.2 / ANSI N5.12 (both DBA/Irradiation and DBA criteria), when applied and tested on substrates Dimetcote 6N, Ameron 90, K&L 6548/7107, Valspar/Mobil V78 Series and Plasite 7155. On this basis, UESI is confident that there is no potential impact to safety with regard to Service Level I protective coating Picco UT-15 provided and installed at nuclear facilities Fermi, Hatch, Oyster Creek and Browns Ferry meets the acceptance requirements (ANSI N 10 1.2 1 ASTM D-3911) defined by contractual documents.

Affected plants with CZ-1 I Substrate are addressed as follows: FPL- Duane Arnold Enerpy Center The Duane Arnold Energy Center facility has been determined to contain CZ- 11 substrate and Picco UT-15 material was installed under the auspices of ANSI N101.2 / N5. 12, and therefore it is determined that the potential Part 21 applies to this facility.FPL-DAEC's Garth Dolderer is aware of finding, as he was the NUPIC member that made UESI aware that the potential for a Part 21 existed. At conclusion of Phase Three evaluation a potential Part 21 notification was placed to FPL-DAEC's Eric Sorenson.Follow up email notification to be sent.NPPD- Cooper Station The Cooper Station facility has been determined to contain CZ-1 I substrate, however a review of the Final Engineering Report (097) 7301 supplied to Cooper at the completion of UT- 15 Coating Repairs does not specify the code requirements the product was required to satisfy (ANSI NI01.2 and/or ASTM D-391 1). The review team attempted to review the Nebraska Public Power Contract (# 96-75) referenced in the report, but was unable to locate the business record's copy (over 10 years sent to alternate storage and not considered permanent QA records).A review of the FER indicates that UESJ personnel were directed by Cooper Station personnel to perform repairs to pit depths in the torus vapor and UA/ regions in excess of 60 mils (0.060").

It should be noted that the depth of coating qualification per the DBA Test (induced defects) for Picco UT- 15 is 0.0625" and may explain why a post installation Certificate of Conformance was not issued with this Final Engineering Report. Records indicate that UESI (S.G. Pinney at the time) performed a total of 1,454 repairs (approximately 40 sq. ft) within all 16 bays of the Cooper Station Torus. As a courtesy, UESI has notified NPPD-Cooper personnel (Russ Wenzl and Joshua Swele via phone and email confirmation) of a potential Part 21 that they will need to evaluate to see if it is applicable to their facility.

UNDERWATER ENGINEERING SERVICES, Inc.(000 1326 S.W. Biltmore Street f1Port Saint Lucie, FL 34983 Eng,.io.atn

....Is. Inc- Page 13 of 16 Exelon- Peach Bottom Unit 3 A review of the Coatings Material Certificate of Conformance issued to Peach Bottom Unit 3 revealed that the coatings were not designated a "Qualified Repair" due to the fact that PECO Management made a determination to eliminate the UESI (SG Pinney at the time) Final Visual Examination (DFT and defects inspection of final coat) due to time constraints.

UESI contacted Dan Testa and Paul Macuiba of Exelon and informed them of finding and evaluation results via phone conversation and email confirmation.

On the basis that the coating repairs perfonned were not considered qualified repairs by UESI, Exc[on should evaluate to validate whether coatings were properly documented according to their quality program.Phase Three summary: The review team determined that the only plant definitively affected by a potential Part 21 is the Duane Arnold Energy Center facilities.

3 other facilities where Picco UT-t 5 was installed over a Carboline Carbo-Zine CZ-1 I substrate either met the contractual scope (ASTM D-39 11) or should have been included in plant inventory of unqualified coatings, and should be evaluated by those affected facilities to validate.Further information that may be helpful to these affected facilities will be found in the next section of this evaluation report titled "Review Teamn Conclusions and Recommendation" This concludes Phase Three of the review.Added Note: On the basis of the Phase One, Two and Three evaluations, an official notification of-a Part 21 was issued to the Nuclear Regulatory Commission via facsimile op. Wednesday.

April 9. 2008 and validated as received by telephone concurrence to the NRC Operations Center. A copy of this correspondence has been attached (see Attachment

2) to this report.

UNDERWATER ENGINEERING SERVICES, Inc.1326 S.W. Biltmore Street Port Saint Lucie, FL 34983 Undoto Engin.,o ng S,, e, .Inc. Page 14 of 16 REVIEW TEAM CONCLUS1IONS AND RECOMAMENDA TIONS Review of Design Basis Accident Reports revealed that the post DBA/lrradiation test acceptance criteria for blistering was exceed on 4 of 16 test panels tested on CZ- II substrate, when evaluated to the requirements of AN SI N101 .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. Picco UT-15 satisfactorily passed all other acceptance criteria established in ANSI N101.2-1972 (flaking, cracking, delamination, peeling and chalking).Hazard: On the basis of the UESI evaluation, while the Picco UT-15 coating was inadvertently presented as ANSI N101.2/N5.12 qualified over Carboline Cabo-Zine 1 substrate, the results of the irradiation aid DBA testing confirm that UT- 15 remained sound and fully intact with no other coating failures noted. UESI is confident in assessing that UT-1 5 poses no substantial safety hazard, as it is highly unlikely to contribute to the ECCS debris source tenn inventory of coatings debris.Recommendations:

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 informing licensees (within 5 days of this determination) where Picco UT-I 5 was sold and installed on CZ-l I substrate under the auspices of ANSI N 101.2 so that they may properly evaluate in accordance with their IOCFR50 App. B quality program. Again it is emphasized that the ke, elements of a Service Level I repair coating, adhesion and intact, were acceptable tributes of all DBA tests conducted on Picco UT-15.UESI work procedures shall be revised to reflect maximum pit depth allowable to be considered "qualified" coating. Amended records to the DBA/Irradiation Test results should include maximum pit depth data also.The final draft of the evaluation was completed on Tuesday, April 8, 2008 and forwarded to the UESI / GPI president, as defined in the UESI QA Manual and 10 CFR 21.Based on the evaluation performed by the review team as described herein, a report in accordance with 10 CFR PART 21 --REPORTING OF DEFECTS AND NONCOMPLIANCE should be transmitted to the US Nuclear Regulatory Commission by Mr. Steve Greenman, President, Greenman-Pedersen, Inc. or his designee concerning the findings related to UESI Nonconformance Report #2008-01 and NUPIC Audit Finding 08.03.SPAFL.08.1 Finding No. 1.The notification requirements of 10 CFR Part 21 related to a director of corporate officer are reproduced on Attachment 1.This concludes the Conclusion and Recommendations Section of the review.

UNDERWATER ENGINEERING SERVICES, Inc, 1326 S.W. Biltmore Street-Port Saint Lucie, FL 34983 U.d.morHngl...nso.g 5 o..I ... Page 15 of 16 REVIEW TEAM

REFERENCES:

1. UESI Nonconformance Report (VCR) # 2008-0I 2. NUPIC Audit 08.03.SPAFL.O8.1I (Joint Audit # 20119)3. ASTM D-391 1-95, "Standard Test Method for Evaluating Coatings Used in Light-Waler Nuclear Power Plants at Simulated Design Basis Accident (DBA)Conditions" 4. ANSI N t 01.2-1972, "Protective Coatings (Paints) Jr Light Water Nuclear Reactor Containment Facilities" 5. ANSI N5.12-1974, "Protective coalings (paints)jotr the nuclear indus!n."'
6. Final Engineering Report "Final Report for Design Basis Accident (DBA) and Irradiation Testing ofCoating Repair Materials Jbr Use in Boiling Water Reactor Suppression Chamber Immersion Areas" dated 16 December 1996 7. ASTM D714-87(1994) el "Standard Test Method for Evaluating Degree of Blistering of Paints" 8. Final Engineering Report "Coating Systems Tested on Steel Panels for irradiation and Design Basis Accident (DBA) Criteria Requirements

/ Duane Arnold Ene-yv Center /Joowa Electric Light and Power Company / Cedar Rqapid.s'l Iowa / Report No. 2" dated 1/16/1990 9. Final Engineering Report No. NUC2004109, "Irradiation and Desig- Basis Accident (DBA,) Qualification Testing of Repair Coatings fro Duane lrnold Energy Center" daied December 20, 2005.

UNDERWATER ENGINEERING SERVICES, Inc.U ( 1326 S.W. Biltmore Street-M Port Saint Lucie, FL 34983 Underwater Engineering Servic., Inc. Page 16 of 16 ATTACHMENT 1"Notification requirements of 10 CFR Part 21 related to a director of corporate officer" (3) Notification required by paragraph (d)(1) of this section must be made as follows --(i) Initial notification by facsimile, which is the preferred method of notification, to the NRC Operations Center at (301) 816 -5151 -or by telephone at (301) 816 -5 100 within two days following receipt of information by the director or responsible corporate officer under paragraph (a)(1) of this section, on the identification of a defect or a failure to comply. Verification that the facsimile has been received should be made by calling the NRCf Operations Center. This paragraph does not apply to interim reports described in§ 21.2 1(a)(2).(ii) Written notification to the NRC at the address specified in '. 21.5 within 30 days following receipt of infornation by the director or responsible corporate officer under paragraph (a)(3) of this section, on the identification of a defect or a failure to comply.(4) The written report required by this paragraph shall includc, but need not be limited to, the following infonmation, to the extent known: (i) Name and address of the individual or individuals irfortning the Commission.(ii) Identification of the facility, the activity, or the basic component supplied for such facility or such activity within the Unlited States which fails to comply or contains a defect.(iii) Identification of the firm constructing the facility or supplying the basic component which fails to comply or contains a detect.(iv) Nature of the defect or failure to comply and the safety hazard which is created or could be created by such defect or failure to comply.(v) The date on which the information of such defect or failure to comply was obtained.(vi) In the case of a basic component which contains a defect or fails to comply, the number and location of these components in use at, supplied for, being supplied for, or may be supplied for, manufactured, or being manufactured for one or more facilities or activities subject to the regulations in this part.(vii) Tthe corrective action which has been, is being, or will be taken; the name of the individual or organization responsible for the action; and the length oftime that has been or will be taken to complete the action.(viii) Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees.

(.ix) In the case of an early site permit, the entities toa whom an early site permit was transferred.

(5) '[he director or responsible officer may authorize an individual to provide the notification required by this paragraph, provided that, this shall not relieve the director or responsible officer of his or her responsibility tunder this paragraph.(e) Individuals subject to this part may be required by the Commission to supply additional information related to a defect or failure to comply. Conmmission action to obtain additional information may be based on reports of defects from other reporting entities.

TRANSTIISSION VERTFICATION REPORT TIME i-AME FAX TEL SER. 0 04/09/2008 10:55 BROM5J390260 GREENMAN-PEDERSEN, LNC.UNDERWATER ENGINZERNG SERVICES INC.INSTRUMENT SALES INC. a GPI. Company Malila Addres 1326 SW Biltmore St Port St. Lutie, FL 34983-2958 Ph. 772-337-3080 tax: 772-13730294 FACSIMILE COVER SHEEET COMPANY: 4( f e4.e? 0~~Lrg FAX:3i 4-ij FROM: 6ehP/S'. e,,9A0,4lPZ~A f DATE: _"____/ _________PAGES COVAPR PAGE' A MESSAGE;_73L 4/orLf/c -/O4 "Apo'f4 6#t UNDERWATER ENGLNEERING SERVICES, Inc. --C1326 S.W. Biltmore Street-Port Saint Lucie, FL 34983 Engi..... ,od , Se.... ,nc. Page I of 3

Subject:

I0CFR 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) 337-3116 (xi 14 Chris Graham), Fax: (772) 337-0294 Based on NUPIC Audit No. 08.03SPAFL.08.

1, Finding No. I 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 UESI Proprietary Underwater Coating Picco UT-l 5, when applied over the substrate Carboline CZ- II 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 innediately, UESI will cease to market and install its product as ANSI Ni01.2-1972 / N5.12-1974 irradiation and DBA qualified when applied as a repair material over" Carboline CZ-l I substrate.

The followins information is provided as required by 10 CFR 2 1.21(d) (4): (i) Name and address of individual informing the commission.

Chris Graham, UES I Quality Assurance Manager Robert J. Walcheski, UESI Assistant Vic President and Technical Manager Jon R. Cavallo. P.E. PCS, Vice President of GPI affiliate Corrosion Control Consultants

&Labs, Inc, UESI Certified Level Ill Coatings Inspector, registered Professional Engineer, ASTM D-33 Nuclear Coatings Committee Chairmran, SSPC certified Protective Coatings Specialist.

Underwater Engineering Services, Inc. (formerly SG Pinney & Associates-UES) 1326 SW Biltmore St.Port Saint Lucie, FL 34983 Ph. 772-337-3116 (ii) Idertification of the facility, the activity, or the basic compionent supplied for such facility or such activity within the United States which fails to comply or contains the defect.Duane Arnold Energy Center -Picco UT-I 5 stating ANSI N101.2 coating repairs performed in CZ-1 I 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-I 1 substrate and repairs performed with Picco UT-15, but may be exempt from Part 21 impacts are as Noted:

UNDERWATER ENGINEERING SERVICES, Inc. 1 9 A1 e. r 1326 S.W. Biltmore Street Port Saint Lucie, FL 34983 Undowa.tr E.nnoof...g Scoso, Inc. Page 2 of 3 (ii) Identification (continued)

Note 1: Cooper Nuclear Station- Picco UT-15 stating coating repairs performed in CZ- 1I Torus per SGPAI (Final Engineering Report) FER 097 (7301) -Contract # 96-75. Code compliance not referenced in Final Engineering Report nor C of C issued stating ANSI NI 01.2 conformance.

Per NPPD Cooper station personnel, coatings were classified"unqualified" based on revised Drywell and Wetwell curves. NPPD (Joshua Swele. Russ Wenzl) has been advised of finding as a courtesy.Note 2: LUESI (under the name of S.G. Pinney and Associates

-UES) has provided UT-15 coating repairs for the 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: UESI (under the name of S.G. Pinney and Associates

-UES) has provided UT-15 coating repairs for the Peach Bottom Nuclear facility, but the coatings material was determined to be considered not a "Qualified Repair" due to the SGPAI-UES Inspectors not being provided opportunity to perform a final visiual examination of the applied coatings due to time constraints.

On this basis, PECO must evaluate impact of this Part 21 notification, and have been advised (Dan Testa, Paul Macuiba) of the finding as a courtesy.(iii) Identification of the firm constructing the flacility or supplying the basic component which fails to comply with or contains the defect.Underwater Engineering Services, hIc 1326 SW Biltmore St.Port Saint Lucie, FL 34983 Ph. 772-337-311,6 (iv) Nature of the defect or failure 0to comply and the safety hazard which is created by such a defect or failure 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 1 substrate, when evaluated to the requirements of ANSI N101.2-1972.

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 doctunented as size #2 and larger. ANSI N101 .2-1972 requires that blister size be limited to few, size #4 and smaller. Picco UT- 15 satisfactorily passed all other acceptance criteria established in ANSI NI 01.2-1972 (flaking, cracking, delamination, peeling and chalking).

Safety Hazard: On the basis of the UJESI evaluation, while the Picco UT-i5 coating was incorrectly presented as ANSI N101 .2/N5.12 qualified over Carboline Carbo-Zinc 11 substrate, the results of the irradiation and DBA testing confirm that UT-15 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 willnot contribute to the ECCS debris source term inventory of coatings debris. As the seller and installer of the UT-I 5 coating material, UESI camnot 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 ENGINEERING SERVICES, Inc. .'4 1326 S.W. Biltmore Street Port Saint Lucie, FL 34983, S.... ,o. IPage 3 of 3 informing licensees (within 5 days of this detennination) where Picco UT-15 was sold and installed on CZ-l 1 substrate under the auspices of ANSI N101.2 so that they may properly evaluate in accordance with their IOCFR50 App. B quality program.(v) The date on which the information of such defect or failure to comply Was obtained.NUPIC identified that a potential problem of unqualified coatings exists with results of the 1996 DBA/JInadiation Test on Februai-y 29, 2008. UESI initiated Nonconformance Report NCR # 2008-0 1, insured that no coating applications was 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.(vi) In the case of a basic coinponent which contains a defect or fails to comply, the number and location of all such components in use at. supplied for. or being supplied for one or more facilities or activities subject to the regulations in this part.Duane Arnold Energy Center: undetermined sq. ft.(vii) The corrective action which has been, is being, or will be taken: the name of the individual or ormanization responsible for the action: and the length of time that has been or will be taken to complete the action.UESI 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- 15 on substrate material Carboline Carbo-Zinc 1 under the auspices of ASTM D-3911-95 only.The records correction shall also amend the report to indicate acceptance of product test to ANSI NI 01.2 for other DBAilrradiation Tested substrates.

This action item is planned to be completed within 60 days of this report.(viii) Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees.

Picco UT-15 is DBA qualified for Service Level I coatings applications in accordance with ASTM D-391 1-95 and subsequent revisions to date.Picco UT-i5 is DBA qualified for Service Level I coatings applications in accordance with ANSI N101.2-1972, excluding application on Carboline CZ-1 I substrate.

Picco UT-15 maintains excellent adhesion and resistance to peeling, cracking, flaking and delarmination, and, based on irradiation and DBA test results, will not contribute to the coatings component of the ECCS debris source terni 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.

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