3F0986-03, Forwards Addl Info Clarifying Proposed Change to FSAR Section 1.7 QA Program Description,Per Rev 0 to Reg Guide 1.54 & ANSI Std N101.4-1972.Rev 1 to Requirement Outline RO-3147, Painting & Protective Coatings..., Also Encl
| ML20215K355 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/05/1986 |
| From: | Widell R FLORIDA POWER CORP. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20215K358 | List: |
| References | |
| RTR-REGGD-01.054, RTR-REGGD-1.054 3F0986-03, 3F986-3, NUDOCS 8610280138 | |
| Download: ML20215K355 (7) | |
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%RQ Florida Power C O R P O R A T I O te September 5, 1986 3F0986-03 Dr. J. Nelson Grace Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Change to the Quality Program Description - Additional Information
Dear Sir:
Florida Power Corporation (FPC) provides this response to the NRC letter dated July 25, 1986 requesting additional i n formation regarding the proposed change to the Crystal River Unit 3 (CR-3)
Quality Program Description (FSAR Section 1.7).
In accordance with 10 CFR 50.54(a)(3), FPC resubmits this additional information for NRC approval of the proposed change to the FSAR which is cl a ri fication of our commitment to comply wi th Regulatory Guide 1.54, Revision 0, and the ANSI Standard N101.4-1972, as presented in Table 1-3 of the FSAR.
ANSI N101.4-1972 was written to address the protective coating requirements for the construction phase of nuclear power plants.
It does not adequately address the more frequently required small amount of painting that is necessary during the operational phase of a pl an t 's life.
To meet all the specific requirements of ANSI N101.4 for the small quantities of paint used during the operational phase is impractical.
FPC meets all of the sections of the ANSI 101.4-1972 with the clarifications provided herewith.
The attached pages provide the detailed information as requested by your letter and by Mr. G. A. Belisle in a July 19, 1986 telecon with Mr. G. R. Westafer, and supersedes the previous clarification in our ___ _... E-et 8610280138 860905 1_*M QRCIALCOPV 3
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a September 5, 1986 3F0986-03 Page 2 submittal dated May 30, 1986.
FPC.'s clarifications to ANSI N101.4-1972 are contained in the FPC specification for Painting A Protective Coatings, R0-3147 that provides detailed requirements for protective coatings at Crystal River linit 3.
This specification is also attached for information only.
Sincerely, j
Rolf h. Widell Manager, Nuclear Operations Licensing and Fuel Management JWT/ feb Attachment xc:
Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Resident Inspector U.S. Nuclear Regulatory Commission Rt. #3, Box 717 Crystal River, FL 32629 L
1 I
l FSAR, CHAPTER 1.7, QUALITY PROGRAM (P. 1-136, REV. 5) i NRC Regulatory Guide 1.54 - " Quality Assurance Requirements for l
Protective Coatings Applied to Water-Cooled Nuclear Power Plants" (Rev. O, 6/73) - Endorses ANSI N101.4-1972.
The Quality Program meets the general intent of this guide.
The j
l program concerning protective coatings is further delineated in the i
project specification for Painting & Protective Coatings, R0-3147, q
and all appropriate plant procedures.
ANSI N101.4-1972 was wri tten to address the protective coating requirements for the construction phase of nuclear power plants.
It does not adequately address the more frequently required small j
amount of painting that is necessary during the operational phase of a plant's life.
I R0-3147 meets the requirements of ANSI N101.4-1972 except for the l
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following clarifications.
i REQUIREMENT:
Section 1.2.2.1
" Class I Service Level applies to j
those systems and components of. nuclear facilities.
1 CLARIFICATION: FPC considers " Class I Service Level" to be those i
systems and components which may be exposed to a LOCA j
atmosphere (i.e., those items in, or to be installed, inside the primary containment building).
This definition of "Cl ass I
Service Level" items is consistent wi th the ASTM Committee D.1 " Manual of Coating Work for Li gh t-Water Nuclear Power Pl ant Primary Containment Other Safety-Rel ated l
Facil i ties."
-R0-3147, Section 3:02 details the
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requirements for these items and is consistent j
with ANSI N101.2-1972.
REQUIREMENT:
Section 2.3.3.4 "The coating manufacturer shall j
furnish application procedures
. specification.
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This shall include the maximum and minimum ambient l
conditions at which application can be properly made."
CLARIFICATION: R0-3147, Section 5:03.6 requires the Contractor to l
l submit all fabrication, special processes, i
inspection, and test procedures for work to be performed on-site.
R0-3147, Section 3:02.2 also i
outlines precautions to be
- taken, such as not
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painting metal on concrete surfaces when the surface temperature is below 500F; and primer and finish coatings shall not be applied when the surface j
temperature of the item to be coated is within SoF of wet bulb temperature.
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l REQUIREMENT:
Section 2.5.2 "Before the start of the coating work in the shop /or in the field, there shall be a shop meeting..."
i CLARIFICATION: Approved pl ant procedures at Crystal River Unit 3 require pre-planning for all work requests, and personnel briefings are conducted before the start of all work. This pre-planning activities and briefings cover such items as personnel safety, radiological l
exposure, and work practices for job involved.
This i
approach to a task meets the intent of this section's requirement for a shop meeting.
REQUIREMENT:.
Section 3.3.1 "The manufacturer shall certify that the product identities of the materials...
This j
certification shall include at least the information l
i requested in Sample Form 1, Section 7."
l Section 3.4 "Each container shall be labeled with
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... the date of manufacture."
CLARIFICATION: The FPC Quality Program for a vendor to be an approved nuclear supplier requires that the supplier maintain a program which will allow traceability of materials supplied to CR-3.
FPC only requires the paint vendor to supply the batch number with the material. Any additional information can be obtained j
from the vendor through batch number traceability.
i REQUIREMENT:
Section 3.6.1 "The owner may require in tha project speci fication, that a DBA exposure test
. be performed on specimens of each coating...".
CLARIFICATION: This data may be obtained at any time per request to the manufacturer and, therefore, is not included in R0-3147.
i REQUIREMENT:
Section 4.2.3 "The proj ect specification shall include Inspection methods to temperature of substances."
CLARIFICATION: R0-3147, Section 5:03 requires the Contractor to submit fabrication, special process, inspection, and test procedures.
R0-3147, Section 5:04 addresses assurance of quality by verification of product conformance.
Crystal River 3 plant procedures also t
have independent inspections performed by Quality i
Control inspectors in accordance with FSAR Section 1.7.1.10.
REQUIREMENT:
Section 4.4
" Removal of Contaminants.
To avoid j
contamination of substrates, the project j
i specification shall... curing compounds."
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CLARIFICATION: R0-3147, Section 3:02.3 addresses preparation of surfaces to be painted including removal of weld splatter, degreasing, use of solvents for cleaning, removal of grit and dust, etc.
REQUIREMENT:
Section 4.5 -
"The coating applicator shall report daily on surface preparation conditions encountered during each shift.
CLARIFICATION: The precautions and surface preparations stated in R0-3147, Sections 3:02.2 and 3:02.3, respectively, meet the intent of Section 4.5 of ANSI N101.4-1972 to ensure adequate surface preparation conditions for applying protective coatings.
i REQUIREMENT:
Section 5.2.2 "These application procedures shall be approved by the coating applicator, the coating manufacturer, and the owner or his representative."
CLARIFICATION: Manufacturer recommendations presented in the form of technical bulletins are reviewed by FPC for l
applicability and inclusion into specific plant procedures used by the coating applicator.
When 4
painting is to be done by an outside contractor, he may use FPC generated painting procedures or his procedures which must be approved by FPC in accordance with R0-3147, Section 3:05.
REQUIREMENT:
Section 5.4.3 "The coating applicator shall report daily on the application work for each area of work CLARIFICATION: FPC meets the intent of the controls described in 4
Section 5.4.3 through requirements detailed in R0-3147, Section 3:02.6 for documentation of activities performed and inspection of those activities. The paint application procedure requires quality control inspection of painting at specific points in the procedure.
This approach meets the intent of the daily reporting requirements.
REQUIREMENT:
Section 6.2.3
" Inspection agencies shall provide the services of one or more qualified inspectors.."
CLARIFICATION: All final inspections at CR-3 are performed by Quali ty Control inspectors of Florida Power Corporation or approved contractors.
These inspectors meet the requirements of ANSI N45.2.6-1978 and are trained to perform coating inspections in accordance with FPC's approved Quality Program.
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J REQUIREMENT:
Section 6.2.4
" Inspection shall conform to all the applicable requirements of Section 7, Inspection, of ANSI N5.9...".
CLARIFICATION: FSAR Section 1.7.1.10 provides FPC's overall requirements for inspections.
R0-3147, Section 3:02.6 further details specific inspection requirements and procedures.
REQUIREMENT:
Section 6.3.2 - "The project specification shall state whether this training is required."
CLARIFICATION: All inspections are performed by Quality Control inspectors who are qualified to ANSI N45.2.6-1978.
Inspectors are also trained on coating requirements, procedures, and inspection techniques.
Further inspection program requirements are described in FSAR Section 1.7.1.10 REQUIREMENT:
Section 6.4
" Scope of Inspections..."
CLARIFICATION: FPC does not utilize any inspection agencies for performing inspections.
However, FPC has independent Quality Control inspectors who are qualified in accordance with ANSI N45.2.6-1978 and trained to perform coating inspections and meet the requirements l
of FSAR Section 1.7.1.10.
Detailed inspections are pre-planned and are delineated in the approved plant i
procedures.
REQUIREMENT:
Section 6.5 - "The maximum thickness may also be critical and..."
4 CLARIFICATION: R0-3147, Section 3:02.6 limits the maximum thickness to 18 mil dry film thickness.(DFT).
REQUIREMENT:
Section 6.6
" Coating inspection equipment..."
CLARIFICATION: FPC utilizes calibrated and approved equipment and gauge indicators.
No wet film thickness (WFT) equipment is used since WFT is only a guide.
FPC considers the measurement of dry film thickness sufficient to meet the intent of Section 6.6.7 of 1
Paint industry practice is to specify dry film thickness for protective coatings.
R0-3145, Sections 3:02.4 and 3:04 discuss the dry film thickness requirements.
REQUIREMENT:
Section 6.8.1 - "A written daily coating-inspection record shall be submitted by the coating-inspection agency."
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CLARIFICATION: Approved plant procedures require quality assurance i
documentation to meet record requi rements for i
specific inspections.
Further, detailed inspections are conducted to ensure requi rements in accordance wi th FSAR Section 1.7.1.10.
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REQUIREMENT:
Section 7
" Quality Assurance Documentation..."
CLARIFICATION: R0-3147, Sections 3:02.6 and 5:03 address Quali ty Assurance documentation deemed necessary for painting at CR-3.
These are in accordance with ANSI N45.2.9.
FPC utilizes forms which are developed to. meet the painting program, i
The painting program delineated in R0-3147 will ensure that all i
protective coatings used inside the primary containment will be proper coatings, applied by qualified personnel and in accordance I
with manufacturers' instructions, and will be inspected and have proper documentation.
This program will meet the intent of Regulatory Guide 1.54.
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