Information Notice 1997-13, Deficient Conditions Associated with Protective Coatings at Nuclear Power Plants

Deficient Conditions Associated with Protective Coatings at Nuclear Power Plants
	ML031050357
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	03/24/1997
From:	Martin T; Office of Nuclear Reactor Regulation
To:	;
References
	IN-97-013, NUDOCS 9703200231
	Download: ML031050357 (9)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, DC 20555-0001 March 24, 1997 NRC INFORMATION NOTICE 97-13: DEFICIENT CONDITIONS ASSOCIATED WITH

PROTECTIVE COATINGS AT NUCLEAR POWER

PLANTS

Addressees

All holders of operating licenses or construction permits for nuclear power reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert

addressees about several instances in which protective coatings have not been properly

applied, maintained, or qualified for their intended use and have jeopardized the operability of

safety-related equipment. It is expected that recipients will review this information for

applicability to their facilities and consider actions, as appropriate, to avoid similar problems.

However, suggestions contained in this information notice are not NRC requirements;

therefore, no specific action or written response is required.

Background

Protective coatings are used in many applications at nuclear power plants. For example, coatings may be used to protect the inside surfaces of storage tanks and containment liners

from corrosion, to protect the inside surfaces of piping systems from erosion and corrosion, or to seal exposed concrete surfaces. Additionally, coatings may be applied to provide a

skid-resistant surface to walk on or to control contamination.

Description of Circumstances

Several instances have been reported to the NRC recently in which protective coatings have

either not been properly applied and maintained or have not been adequately qualified for

their intended use. The following are examples:

1. Pipe Coating Material Found in the A-Train Recirculation Spray Heat Exchangers at

Millstone Unit 3 On July 25, 1996, Northeast Nuclear Energy Company reported in Licensee Event

Report (LER)96-025 (Accession Number 9608270262) that about 20 pieces of Arcor

were found in the "A" train recirculation spray heat exchangers at Millstone Unit 3.

Arcor is a coating material that was applied to the inside surfaces of the service water

system piping at Millstone Unit 3. The licensee stated that Arcor chips were swept

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IN 97-13 March 24, 1997 into the recirculation spray heat exchanger channel heads during engineered safety

features/loss of power testing that had been conducted. The licensee also found 40

to 50 mussel shell fragments in the heat exchangers. Although the Arcor chips and

mussel fragments were relatively small (on the order of 1 inch by 1 inch), the licensee

determined that the number and size of Arcor chips and mussel fragments could have

prevented the "A" train recirculation spray heat exchangers from performing their

specified safety function.

The licensee determined that the Arcor chips were from a second coat of Arcor that

was applied in the field (as opposed to being applied in the shop) to the internal

diameter of the "A" train service water system piping. The licensee concluded that the

plant's procedures for field application of the Arcor coating were not adequate to

ensure proper bonding of the second coat. As corrective actions, the licensee

planned to revise the procedure for the application of the Arcor to more adequately

ensure proper bonding between the first and second coatings, and to visually inspect

the "A" train service water system to determine the location and extent of Arcor

delamination. Repairs to any affected areas of the "A" train service water system

piping would use the revised procedure for Arcor application. A flushing and

inspection of the "B" train recirculation spray heat exchangers did not disclose

additional Arcor chips or mussel fragments.

2. Degradation of Protective Coatings Used Inside Containment

Zion Unit 2 In November 1996, Commonwealth Edison Company found that 40 percent to

50 percent of the concrete floor coatings at Zion Unit 2 showed extensive failure as a

result of mechanical damage and wear and that about 5 percent of the coating

associated with the concrete wall and liner plate was.degraded. Although adhesion

tests showed acceptable adhesion strength in most of the locations tested, one test

that was made on an unqualified coating system did not satisfy the acceptance

criteria. Unqualified coatings had been applied to various surfaces, including

instrument racks, struts, charcoal filter housings, valve bodies, and piping. Also, documentation was not found for overcoating (i.e., touch-up work) that had been

applied to many of the liner plates and concrete wall surfaces.

To resolve the coating discrepancies that were identified in the Zion Unit 2 containment, all of the loosely adherent coatings were removed and material transport

calculations were performed for the coated surfaces inside containment. These

calculations were used to define a "zone of influence" relative to the containment

sump, and the licensee has removed all of the unqualified coatings that existed within

this zone, except for small amounts that might be present on items such as

identification tags, signs, and lighting fixtures. The licensee estimated that about

110m 2 [1200 ft2] of unqualified coatings existed in the Unit 2 containment. In addition

IN 97-13 March 24, 1997 to these immediate actions, the licensee was establishing a long-term corrective

action plan and a coating maintenance program to fully resolve the coating

discrepancies at the Zion station.

Indian Point Unit 2 On March 10, 1995, the Consolidated Edison Company reported in LER 95-005 (Accession Number 9503210115) that paint was peeling from a floor in the Indian

Point Unit 2 containment. The licensee found that the following factors contributed to

the delamination of the paint: (1) the paint thickness exceeded the manufacturer's

specifications by up to twice the allowed thiukness; (2) there was excessive paint

shrinkage caused by using too much paint thinner; (3) the surface had not been

properly cleaned and prepared before the paint was applied; and (4) inspection and

documentation requirements conforming to American National Standards Institute

(ANSI) N101.4, "Quality Assurance for Protective Coatings Applied to Nuclear

Facilities," which was invoked by the existing specification for the activity, were not

implemented. The licensee concluded that the root cause of the observed condition

resulted from the failure of personnel to follow approved procedures for painting

applications.

Sequoyah Units 1 and 2 On October 18, 1993, the Tennessee Valley Authority reported in LER 93-026 (Accession Number 9310260116) that unidentified coatings were used on the exterior

surfaces of reactor coolant pump motor support structures at Sequoyah Units 1 and 2.

These support structures are located completely within the containment sump "zone of

influence" at both of the Sequoyah units. The surface area of unqualified coating

found on each of these support structures involved about 13m2 [143 ft2] of material, whereas the maximum amount of uncontrolled coatings allowed to exist in the zone of

influence at the Sequoyah units without affecting the operability of the emergency core

cooling and spray systems was set at 5m 2 [56.5 ft2]. As corrective action, the licensee

modified the motor support structures to include "catch" screens to prevent coatings

on the motor support structures from reaching the strainers in the containment sumps.

Discussion

The failure of coatings to adhere to exposed surfaces inside containment and to the internal

surfaces of fluid systems can result in clogged strainers, filters, and nozzles and can

compromise the ability of safety-related equipment to function (e.g., the service water system, the containment spray system, and the emergency core cooling systems). It is important that

coating systems remain adherent and intact during normal operating and transient conditions, as well as during the most extreme environmental conditions that can exist during design- basis accident conditions, especially if coating system failure can jeopardize the operability of

safety-related equipment. Industry standards provide certification and qualification

requirements for coatings that are used in these applications. Additionally, industry standards

for coatings as well as vendor instructions and recommendations provide guidance pertaining

IN 97-13 March 24 , 1997 to such things as surface preparation and cleanliness requirements, temperature control, humidity control, timing requirements for multiple coat applications, application methods, and

personnel qualification and training requirements. Depending on the specific application, a

combination of in situ testing and periodic inspection of coatings may be necessary to ensure

that the coating has been adequately applied and remains intact over time.

Coating activities that can affect safety-related equipment are governed in general by Title 10

of the Code of Federal Regulations, Part 50, Appendix B, "Quality Assurance Criteria for

Nuclear Power Plants and Fuel Reprocessing Plants." Criterion IX of Appendix B, "Control of

Special Processes," is especially relevant and requires that "Measures shall be established to

assure that special processes...are controlled and accomplished by qualified personnel using

qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements." Regulatory Guide 1.54, "Quality Assurance Requirements

for Protective Coatings Applied to Water-Cooled Nuclear Power Plants," provides guidance

on a way to comply with these quality assurance requirements as they relate to protective

coating systems that are applied to ferritic steel, aluminum, stainless steel, zinc-coated

(galvanized) steel, and masonry surfaces.

This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact one of the technical contacts

listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Thomas T. Martin, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: James Medoff, NRR

(301) 415-2715 E-mail: jxmenrc.gov

James Tatum, NRR

(301) 415-2805 E-mail: jetl @nrc.gov

Attachment: List of Recently Issued NRC Information Notices

Attachment

IN 97-13 March 24, 1997 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

97-12 Potential Armature 03124/97 All holders of OLs

Binding in General or CPs for nuclear

Electric Type HGA power reactors

Relays

92-27, Thermally Induced 03/21/97 All holders of OLs

Supp. 1 Accelerated Aging or CPs for nuclear

and Failure of ITE/ power reactors

Gould A.C. Relays

Used in Safety-Related

Applications

97-11 Cement Erosion from 03/21/97 All holders of OLs

Containment Subfaunda- or CPs for nuclear

tions at Nuclear Power power reactors

Plants

97-10 Liner Plate Corrosion 03/13/97 All holders of OLs

in Concrete Containments or CPs for power

reactors

97-09 Inadequate Main Steam 03/12/97 All holders of OLs

Safety Valve (MSSV) or CPs for nuclear

Setpoints and Perform- power reactors

ance Issues Associated

with Long MSSV Inlet

Piping

97-08 Potential Failures 03/12/97 All holders of OLs

for General Electric or CPs for nuclear

Magne-Blast Circuit power reactors

Breaker Subcomponents

OL = Operating License

CP = Construction Permit

a -,* KJ

IN 97-13 March 24 ,1997 to such things as surface preparation and cleanliness requirements, temperature control, humidity control, timing requirements for multiple coat applications, application methods, and

personnel qualification and training requirements. Depending on the specific application, a

combination of in situ testing and periodic inspection of coatings may be necessary to ensure

that the coating has been adequately applied and remains intact over time.

Coating activities that can affect safety-related equipment are governed in general by Title 10

of the Code of Federal Regulations, Part 50, Appendix B, "Quality Assurance Criteria for

Nuclear Power Plants and Fuel Reprocessing Plants." Criterion IX of Appendix B, "Control of

Special Processes," is especially relevant and requires that "Measures shall be established to

assure that special processes.. .are controlled and accomplished by qualified personnel using

qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements." Regulatory Guide 1.54, "Quality Assurance Requirements

for Protective Coatings Applied to Water-Cooled Nuclear Power Plants," provides guidance

on a way to comply with these quality assurance requirements as they relate to protective

coating systems that are applied to ferritic steel, aluminum, stainless steel, zinc-coated

(galvanized) steel, and masonry surfaces.

This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact one of the technical contacts

listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

original signed by M.M. Slosson

Tomas T. Martin, Director

O Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: James Medoff, NRR

(301) 415-2715 E-mail: jxm@nrc.gov

James Tatum, NRR

(301) 415-2805 E-mail: jeti@nrc.gov

Attachment: List of Recently Issued NRC Information Notices

Tech Editor has reviewed and concurred on 2/6/97

[OFFICE

DOCUMENT NAME: G:TJCCOATINGS.RV1 *SEE PREVIOUS CONCURRENCES

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DATE

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TECH CONTS

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JTatum*IVW

03/04/97 02/10/97 CPECB

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03/04/97 D:DRPM

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CFFICIAL RECORD COPY

IN 97-xx

March , 1997 to such things as surface preparation and cleanliness requirements, temperature control, humidity control, timing requirements for multiple coat applications, application methods, and