Information Notice 2009-14, Painting Activities and Cleaning Agents Render Emergency Diesel Generators and Other Plant Equipment Inoperable
| ML091980474 | |
| Person / Time | |
|---|---|
| Issue date: | 08/17/2009 |
| From: | Mcginty T Division of Policy and Rulemaking |
| To: | |
| Mark King, NRR, 301-415-1150 | |
| Shared Package | |
| ML092010047 | List: |
| References | |
| IN-09-014 | |
| Download: ML091980474 (5) | |
ML091980474 UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NEW REACTORS
WASHINGTON, DC 20555-0001
August 17, 2009
NRC INFORMATION NOTICE 2009-14:
PAINTING ACTIVITIES AND CLEANING AGENTS
RENDER EMERGENCY DIESEL GENERATORS
AND OTHER PLANT EQUIPMENT INOPERABLE
ADDRESSEES
All holders of operating licenses and construction permits for nuclear power reactors under the
provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing
of Production and Utilization Facilities, except those who have permanently ceased operations
and have certified that fuel has been permanently removed from the reactor vessel.
All current and potential applicants for an early site permit, combined license, or standard
design certification for a nuclear power plant under the provisions of 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform
addressees of operating experience in which painting or cleaning activities rendered plant
equipment inoperable, particularly a recent event at Comanche Peak in which an emergency
diesel generator (EDG) was rendered inoperable. The NRC expects that recipients will review
the information for applicability to their facilities and consider actions, as appropriate, to avoid
similar problems. Suggestions contained in this IN are not NRC requirements; therefore, no
specific action or written response is required.
DESCRIPTION OF CIRCUMSTANCES
Comanche Peak Unit 1Paint Renders EDG Inoperable
On November 21, 2007, the train B EDG at Comanche Peak Unit 1 failed to start because of
what appeared to be paint residue from a small drop of paint on one of the fuel pump metering
rods. The location of the paint residue prevented movement of the fuel racks from their normal
standby (closed) position in response to a governor demand signal, and the train B EDG was
declared inoperable. The lack of movement of the mechanical linkage precluded the admission
of sufficient fuel to all of the cylinders, which prevented the engine from starting. The residue
was removed and the EDG was successfully started, declared operable, and returned to
service. Licensee corrective actions for this event included the following:
Manipulated the fuel racks on the other three EDGs manually to determine their
condition and to verify that no common-mode failure state existed.
Revised the general plant painting procedure to do the following:
-
Require a post-maintenance pull test of the fuel pump control rack mechanisms
to ensure that they are free to operate (in addition to visual inspections of the
diesel engine area).
-
Require as you go inspection and cleanup when painting around sensitive
components.
-
Add an attachment capturing the pictures and information presently contained in
the pre-job briefing notebook used by painters.
Included this event in the pre-job briefing for painters to heighten their sensitivity to the
problems that paint drops and spatter can cause for mechanical linkages.
Had system engineering staff review the information in the painters pre-job briefing
notebook to ensure that it references all sensitive areas on the EDG that should not be
painted.
Additional information appears in the Comanche Peak Steam Electric StationNRC Special
Inspection Report 05000445/2007008, dated February 29, 2008, available on the NRCs public
Web site in the Agencywide Documents Access and Management System (ADAMS) under
Accession No. ML080600164. This event was also the subject of Comanche Peak Licensee
Event Report (LER) 50-445/2007-001, dated January 17, 2008 (ADAMS Accession
No. ML080240252).
Other Examples of Painting or Cleaning Activities Impacting Plant Equipment
The NRC Operating Experience Branch reviewed other events in which painting or cleaning
activities impacted plant equipment that were the subject of NRC inspection findings since 2000
and of LERs since 1991. These LER and NRC inspection finding data describe painting or
cleaning activities that adversely impacted various plant equipment, such as EDGs, turbine- driven auxiliary feedwater pumps, a high-pressure coolant injection pump, control room
emergency ventilation, radiation monitors, charcoal iodine filters, the control room pressure
boundary, welding activities, standby or station blackout diesel generators, and fire doors/fire
protection equipment. Additionally, at least three reactor trips were attributed, in part, to
painting activities. A listing and brief description of each of these NRC inspection findings and LERs is publically
available in ADAMS under Accession No. ML091600446. This listing shows that events often
involved one or more of the following causal factors:
inadequate supervisory oversight (mentioned for more than half of these events)
lack of self-verification
lack of adherence to procedures
lack of training
inexperience
procedural problems
poor pre-job briefings
communication issues
program weaknesses
poor scheduling/planning
other work control issues
Licensee corrective actions have included the following:
improved tools and techniques that painters can use to minimize and/or control paint
drops and paint spatter
periodic and post-maintenance verification of any safety-related equipment potentially
impacted by the painting or cleaning activity
BACKGROUND
The NRC has previously issued the following related generic communications:
IN 93-76, Inadequate Control of Paint and Cleaners for Safety-Related Equipment, dated September 21, 1993, describes an EDG that was rendered inoperable by a
cleaning agent that removed the lubricating oil and left a white residue that prevented
fuel rack movement. It also describes a cleaning agent containing a solvent that
caused the plastic parts of 16 safety-related control switches to bond together, making
the switches inoperable.
IN 91-46, Degradation of Emergency Diesel Generator Fuel Oil Delivery Systems, dated July 18, 1991, describes EDGs that were rendered inoperable by paint on fuel
rack components or on exciter commutator rings.
DISCUSSION
The improper control of materials and processes for painting and cleaning activities near safety- related equipment can result in systems required by the technical specifications being rendered
inoperable. Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel
Reprocessing Plants, to 10 CFR Part 50 establishes quality assurance requirements for safety- related equipment at nuclear power plants. The pertinent requirements of Appendix B apply to
all activities affecting the safety-related functions of equipment, including painting and cleaning.
CONTACT
This IN requires no specific action or written response. Please direct any questions about this
matter to the technical contact listed below or the appropriate Office of Nuclear Reactor
Regulation (NRR) project manager.
/RA/
Theodore R. Quay for
Glenn Tracy, Director
Timothy J. McGinty, Director
Division of Construction Inspection
Division of Policy and Rulemaking
and Operational Programs
Office of Nuclear Reactor Regulation
Office of New Reactors
Technical Contact:
301-415-1150
E-mail: Mark.King@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
CONTACT
This IN requires no specific action or written response. Please direct any questions about this
matter to the technical contact listed below or the appropriate Office of Nuclear Reactor
Regulation (NRR) project manager.
/RA/
Theodore R. Quay for
Glenn Tracy, Director
Timothy J. McGinty, Director
Division of Construction Inspection
Division of Policy and Rulemaking
and Operational Programs
Office of Nuclear Reactor Regulation
Office of New Reactors
Technical Contact:
301-415-1150
E-mail: Mark.King@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
ADAMS Accession Number: ML092010047 (Package); ML091980474 (IN); ML091600446 (IN Painting Activities) TAC ME0725 OFFICE
DIRS/IOEB
- TECH EDITOR
BC/DCI/CPTB
AC/DIRS/IOEB
D/NRR/DIRS
NAME
MKing
KAzariah-Kribbs
JMcHale
EThomas
FBrown
DATE
07/28/09
07/28/09 e-mail
08/04/09
07/29/09
08/05/09 for by RElliot
OFFICE
DPR/PGCB
DPR/PGCB
BC/DPR/PGCB
D/NRR/DPR
D/DCIP/NRO
NAME
DBeaulieu
CHawes CMH
MMurphy
TMcGinty TRQ for
GTracy
DATE
08/06/09
08/11/09
08/14/09
8/17/09
08/12/09 OFFICIAL RECORD COPY