L-98-217, Forwards 120-day Response to NRC GL 98-04, Potential for Degradation of ECCS & CSS After LOCA Because of Construction & Protective Coating Deficiencies & Foreign Matl in Containment

Forwards 120-day Response to NRC GL 98-04, Potential for Degradation of ECCS & CSS After LOCA Because of Construction & Protective Coating Deficiencies & Foreign Matl in Containment

ML20195D536
Person / Time
Site:	Beaver Valley
Issue date:	11/11/1998
From:	Jain S DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-98-04, GL-98-4, L-98-217, NUDOCS 9811180090
Download: ML20195D536 (12)

Text

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d i d i

g aver Valley Power Station SNppmgport, PA 15077-0004 j

' i SUSHIL C. JAIN (412) 393-5512

e Pr dent Fax (724) 643 8069 Seyr., , November 11, 1998 Nuclear Power Division L-98-217 i

, U. S. Nuclear Regulatory Commission Attention: Document Control Desk

' Washington, DC 20555-0001 i

l'

Subject:

Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 l

! Response to Generic Letter 98-04 l

e This submittal forwards the Duquesne Light Company response to NRC Generic Letter 98-04, " Potential for Degradation of the Emergency Core Cooling System and the

Containment Spray System After a Loss-of-Coolant Accident Because of Construction and Protective Coating Deficiencies and Foreign Material in Contaimnent" dated July 14, 1998. Licensees were required to submit a response within 120 days of the date of the generic letter.

. The attachment provides a restatement of each of the NRC questions followed by the i response to the question. The information regarding Beaver Valley Unit'No.1 is presented in its entirety first and the information for Beaver Valley Unit No. 2 follows the Unit No. I presentation.

i 1

If you have any questions regarding this submittal, please contact Mr. M. S. Ackerman

at (412) 393-5203.

l Sincerely, be1Y 4 Sushil C. Jain AMO'  ;

c: Mr. D. S. Brinkman, Sr. Project Manager Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator OE tlVElllN G

.en QUAlliY 9811100090 9gygg'g- ) , E*ERGV yDR ADUCK 05000334.

PDR

AFFIDAVIT l

COMMONWEALTH OF PENNSYLVANIA)  !

) SS:

COUNTY OF BEAVER )  ;

l l

Subject:

Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Response to NRC Generic Letter 98 Potential for Degradation of i the Emergency Core Cooling System and the Containment Spray System l After a Loss-of-Coolant Accident Because of Construction and Protective Coating Deficiencies and Foreign Material in Containment 1 i

Before me, the undersigned notary public, in and for the County and )

Commonwealth aforesaid, this day personally appeared Sushil C. Jain, to me known, j 1

who being duly sworn according to law, deposes and says that he is Senior Vice i President, Nuclear Services of the Nuclear Power Division, Duquesne Light Company, he is duly authorized to execute and file the foregoing submittal on behalf of said Company, and the statements set foith in the submittal are true and correct to the best of his knowledge, information and belief.

Sushil C. Jain I

Subscribed and sworn to before me j on thif///f day of bilN41&, / hV '

Wp /)) < WU' Nntant DnhL Shona M. F , ry Pubic o,WTe" ":"s"JTJ' * .

Member,Finnsylvane Associatonof Notanes 1 l

Attachment ResDonse to NRC Generic Letter 98-04 BVPS Unit 1:

1. A summary description of the plant-specific program or programs implemented to ensure that Service Level 1 protective coatings used inside the containment are procured, applied, and maintained in compliance with applicable regulatory requirements and the plant-specific licensing basis for the facility. Include a i discussion of how the plant-specific program meets the applicable criteria of i 10 CFR Part 50, Appendix B, as well as information regarding any applicable standards, plant-specific procedures, or other guidance used for: (a) controlling the procurement of coatings and paints used at the facility,(b) the qualification testing i of protective coatings, and (c) surface preparation, application, surveillance, and l maintenance activities for protective coatings. Maintenance activities involve reworking degraded coatings, removing degraded coatings to sound coatings, correctly preparing the surfaces, applying new coatings, and verifying the quality of the coatings.

RESPONSE

Duquesne Light Company (DLC) has implemented controls for the procurement, application, and maintenance of Service Level 1 protective coatings used inside the containment in a manner consistent with the licensing basis and regulatory requirements applicable to BVPS Unit 1. The requirements of 10 CFR Part 50 Appendix B are implemented through specification of appropriate technical a .d quality requirements for Service Level I coatings program which includes ongoing maintenance activities.

1 Service Level 1 coatings are subject to the requirements of ANSI N 101.2 as described in Section 5.2.7.2 of the UFSAR. Adequate assurance that the applicable requirements for procurement, application, inspection, and maintenance are implemented is provided by procedures and programmatic controls, approved under the DLC Quality Assurance j program. The DLC QA program follows the guidance of Regulatory Guide 1.54, per l section 1.3.4.2 of the Beaver Valley Unit 1 UFSAR. l 1

' Our response applies to Service Level 1 coatings usedin containment that are procured, applied and maintained by Duquesne Light Company or their contractor.

l (a) Service Level I coatings used for new applications or repair / replacement activities are procured from qualified vendors with a quality assurance program meeting the applicable requirements of 10 CFR 50 Appendix B. The applicable technical and quality requirements that the vendor is required to meet are specified by DLC in procurement documents and Plant Installation Process Standard (PIPS)

S15.3, " Procurement, Receipt, Storage, and Handling of Coating Materials - BVPS

1. 1 and #2" and the procurement documents specify requirements for procurement of Service Level I coatings. Acceptance activities are conducted in accordance I

Attachment Response to NRC Generic Letter 98-04

! Page 2 with procedures that are consistent with ANSI N 45.2 requirements (e.g., receipt inspection, source surveillance, etc.). This specification ofrequired technical and quality requirements combined with app opriate acceptance criteria provides adequate assurance that the coatings received meet the requirements of the procurement documents.

(b) The qualification testing of Service Level I coatings used inside containment meet the applicable requirements contained in the standards and regulatory commitments referenced above. Coatings are evaluated to meet the applicable standards and regulatory requirements previously referenced. Use of unqualified coatings, including vendor components supplied with unqualified coatings, are limited in use and must be approved before being used inside containment. l (c) Surface preparation, application and surveillance during installation of Service Level I coatings used for new applications or repair / replacement activities inside containment meet the applicable portions of the standards and regulatory commitments referenced above. Documentation of completion of these activities is I performed consistent with the applicable requirements. Plant-specific requirements, including inspection requirements, are contained in Plant Installation Process

Standard (PIPS) S11.3, " Painting for Containment Interior." Service Level I coating work inside containment is performed in accordance with PIPS S11.3.

! Service Level I coatings inside' containment are assessed as part of containment l walkdowns, maintenance activities, and the " Containment Structural Integrity Test" (IBVT 1.47.1). The containment liner is inspected in accordance with the Containment Structural Integrity Test approximately every three years. As localized areas of degraded coatings are identified, those areas are evaluated and scheduled for repair or replacement, as necessary. This assessment and resulting repair / replacement activity assure that the amount of Service Level I coatings which may be susceptible to detachment from the substrate during a LOCA event is minimized.

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. Attachment i

' Response to NRC Generic Letter 98-04 l Page 3

2. Information demonstrating compliance with item (i) or item (ii):

(i) For plants with licensing-basis requirements for tracking the amount of l unqualified coatings inside the containment and for assessing the impact of potential coating debris on the operation of safety-related SSCs during a ,

postulated design basis LOCA, the following information shall be provided to l demonstrate compliance:

RESPONSE

BVPS Unit I has no licensing basis requirement for tracking the amount of unqualified coatings inside the containment nor for assessing the impact of potential coating debris on i the operation of Safety-Related SSCs during a postulated design basis LOCA. l l

(a) The date and findings of the last assessment of coatings, and the planned date of the next assessment of coatings. i l

RESPONSE- l BVPS Unit I has no licensing basis requirement for tracking or assessing protective i coatings inside the containment. Service Level I coatings inside containment are assessed l l

as part of containment walkdowns, maintenance activities, and the " Containment i Structural Integrity Test" (IBVT 1.47.1). The containment liner is inspected in accordance with the Containment Structural Integrity Test approximately every three years. This test was last performed in April 1996 for BVPS Unit 1. The next perfonnance of the test for BVPS Unit 1 is currently scheduled for the spring of the year 2000.

(b) The limit for the amount of unqualified protective coatings allowed in the containment and how this limit is determined. Discuss any conservatism in the method used to determine this limit.

RESPONSE

BVPS Unit I has no licensing basis requirement for the amount of unqualified protective coatings allowed in containment. Therefore, Unit I has no specified limit for the amour,t of unqualified protective coatings permitted in containment.

(c) If a commercial-grade dedication program is being used at your facility for l dedicating commercial-grade coatings for Service Level I applications inside l the containment, discuss how the program adequately qualifies such a i coating for Service Level 1 service. Identify which standards or other guidance are currently being used to dedicate containment coatings at your j facility; or,  !

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. Attachment Response to NRC Generic Letter 98-04

, Page 4

RESPONSE

Duquesne Light Company'does not currently employ commercial grade dedication for Service Level I coatings used inside containment at Beaver Valley Power Station Unit 1.

(ii) For plants without the above licensing-basis requirements, information shall be provided to demonstrate compliance with the above requirements of 10 CFR 50.46b(5),"Long-term cooling" and the functional capability of the safety-related CSS as set forth in your licensing basis. If a licensee can demonstrate this compliance without quantifying the amount of unqualified coatings, this is acceptable.

i

RESPONSE

d Unit I licensing basis for long-term cooling conforms to AEC Safety Guide 1, as described in section 1.3.3.1 of the UFSAR. Sections 6.3 and 6.4 of the Unit 1 UFSAR

, describe the ECCS and Containment Depressurization System, respectively. The containment sump and protective bars and screens are described in section 6.4.2 of the Unit 1 UFSAR. The analysis of the worst case pressure drop through the screens

assumes 50% of the screen area is blocked. This methodology is consistent with the guidance of Regulatory Guide (RG) 1.82, Revision 0 although Unit I licensing basis predates RG 1.82. l

) The emergency core cooling system design and analysis were reviewed for conformance

to 10 CFR 50.46 subparagraph b in Beaver Valley Unit 1 SER and SSER 1 and approved in SSER 2, section 6.3

The licensing basis for Beaver Valley Unit 1, as accepted by the NRC's SER, provides both the regulatory and safety basis for safety system performance. Coatings are not

g treated separately in the licensing basis for Beaver Valley Unit 1 because the sump screen 4 blockage assumption does not distinguish among the source terms for LOCA generated debris.

The following information shall be provided:

2 (a) If commercial grade coatings are being used at your facility for Service Level 1 applications, sad such coatings are not dedicated or controlled under your Appendix B Quality Assurance Program, provide the regulatory and safety basis for not controlling these coatings in accordance with such a program. Additionally, explain why the facility's licensing basis does not l require such a program.

4 e

Attachment Response to NRC Generic Letter 98-04 Page 5

RESPONSE

Duquesne Light Company does not use commercial grade coatings for Service Level 1 applications unless specifically approved by the BVPS Engineering Department. When approved for such applications, the coatings are considered unqualified paint and controlled under the Appendix B QA program. Duquesne Light Company does not currently employ commercial grade dedication for Service Level I coatings used inside containment at Beaver Valley Power Station Unit 1.

l Atte'chment l Response to NRC Generic Letter 98-04 l Page 6 1

i BVPS Unit 2:

I

1. A summary description of the plant-specific program or programs implemented to ensure that Scavice Level 1 protective coatings used inside the containment are procured, applied, and maintained in compliance with applicable regulatory requirements and the plant-specific licensing basis for the facility. Include a discussion of how the plant-specific program meets the applicable criteria of ,

10 CFR Part 50, Appendix B, as well as information regarding any applicable l

standards, plant-specific procedures, or other guidance used for: (a) controlling the '

procurement of coatings and paints used at the facility, (b) the qualification testing of protective coatings, and (c) surface preparation, application, surveillance, and maintenance activities for protective coatings. Maintenance activities involve i reworking degraded coatings, removing degraded coatings to sound coatings, l correctly preparing the surfaces, applying new coatings, and verifying the quality of the coatings.

RESPONSE

Duquesne Light Company (DLC) has implemented controls for the procurement, application, and maintenance of Service Level 1 protective coatings used inside the

containment in a manner consistent with the licensing basis and regulatory requirements applicable to BVPS Unit 2. The requirements of 10 CFR Part 50 Appendix B are implemented through specification of appropriate technical and quality requirements for  !

Service Level I coatings program which includes ongoing maintenance activities.

Service Level I coatings are subject to the requirements of ANSI N 101.2 as described  ;

in Section 6.1.2.1 and Table 1.8-1 of the UFSAR. Adequate assurance that the applicable requirements for procurement, application, inspection, and maintenance are implemented i is provided by procedures and programmatic controls, approved under the DLC Quality Assurance program. The DLC QA program conforms to the QA guidelines of Regulatory Guide (RG) 1.54 with the exceptions noted in Section 6.1.2 and Table 1.8-1 of the BV-2 UFSAR. The QA requirements of ANSI N 101.4 and ANSI N 5.12 are also applicable as delineated in Table 1.8-1 of the UFSAR.

' Our response applies to Service Level 1 coatings usedin containment that are procured, applied and maintained by Duquesne Light Company or their contractor except as notedin the BVPS Unit 2 UFSARfor Westinghouse supplied equipment.

i Westinghouse-supplied components located inside the containment building were coated

. in accordance with Westinghouse's own protective coatings program. The Westinghouse program and scope of supply is summarized in section 6.1.2.2 of the UFSAR. Table 4

6.1-3 of the BV-2 UFSAR lists the Westinghouse-supplied components and estimated painted surface area. The Westinghouse alternative to RG 1.54, (Westinghouse letter

'NS-CE-1352, dated Feb.1,1977) for the protective coating systems on the NSSS i

Attrohment Response to NRC Generic Letter 98-04 Page 7 equipment inside containment, was reviewed and accepted by the NRC staff. (Ref. BV-2 SER, [NUREG 1057], section 6.1.2, page 6-3.)

(a) Service Level I coatings used for new applications or repair / replacement activities are procured from qualified vendors with a quality assurance program meeting the applicable requirements of 10 CFR 50 Appendix B. The applicable technical and quality requirements that the vendor is required to meet are specified by DLC in procurement documents. Plant Installation Process Standard (PIPS) S15.3, " Procurement, Receipt, Storage, and Handling of Coating Materials - BVPS #1 and #2" and procurement documents specify requirements for procurement of Senice Level I coatings. Acceptance activities are conducted in accordance with procedures that are consistent with ANSI N 45.2 requirements (e.g'., receipt inspection, source surveillance, etc.) This specification of required l technical and quality requirements combined with appropriate acceptance criteria i provides adequate assurance that the coatings received meet the requirements of the procurement documents. <

(b) The qualification testing of Service Level I coatings used inside containment meet the applicable requirements contained in the standards and regulatory commitments referenced above. Coatings are evaluated to meet the applicable standards and regulatory requirements previously referenced. Use of unqualified coatings, including vendor components supplied with unqualified coatings, are limited in use and must be approved before being used inside containment. The total estimated surface area of unqualified coatings applied inside containment up to initial plant stan-up was recorded in 2BVM-037. The amount of unqualified coatings used to date is small relative to the total surface area coated. ,

(c) Surface preparation, application and surveillance during installation of Sewice Level I coatings used for new applications or repair / replacement activities inside containment m::t the applicable portions of the standards and regulatory commitments referenced above. Documentation of completion of these activities is performed consistent with the applicable requirements.' Plant-specific requirements, including inspection requirements, are contained in Plant Installation Process Standard (PIPS) S11.3, " Painting for Containment Interior."

Service Level I coating work inside containment is performed in accordance with PIPS S11.3.'

Service Level I coatings inside containment are assessed as part of containment walkdowns, maintenance activities, and the " Containment Stmetural Integrity Test" (2BVT 1.47.1). The containment liner is inspected in accordance witi: the Containment StructuralIntegrity Test approximately every three years. As localized areas of degraded coatings are identified, those areas are evaluated and scheduled for repair or replacement, as necessary. This assessment and resulting repair / replacement activity assure that the amount of Service Level I coatings

1

. Atta'chment Response to NRC Generic Letter 98-04 Page 8 which may be susceptible to detachment from the substrate during a LOCA event is minimized.

2. Information demonstrating compliance with item (i) or item (ii):

(i) For plants with licensing-basis requirements for tracking the amount of unqualified coatings inside the containment and for assessing the impact of potential coating debris on the operation of safety-related SSCs during a postulated design basis LOCA, the following information shall be provided to demonstrate compliance:

RESPONSE

BVPS Unit 2 has no licensing basis requirement for tracking the amount of unqualified coatings inside the containment nor for assessing the impact of potential coating debris on the operation of Safety-Related SSCs during a postulated design basis LOCA.

(a) The date and findings of the last assessment of coatings, and the planned

< date of the next assessment of coatings.

RESPONSE

BVPS Unit 2 has no licensing basis requirement for tracking or assessing protective coatings inside the containment. Service Level I coatings inside containment are assessed as part of containment walkdowns, maintenance activities, and the " Containment Structural Integrity Test" (2BVT 1.47.1). The containment liner is inspected in accordance with the Containment StructuralIntegrity Test approximately every three years. This test was last performed for BVPS Unit 2 in September 1996. Currently the next scheduled performance of the test is planned for the spring of the year 1999.

(b) The limit for the amount of unqualified protective coatings allowed in the containment and how this limit is determined. Discuss any conservatism in the method used to determine this limit.

RESPONSE

BVPS Unit 2 has no licensing basis requirement for the amount of unqualified protective coatings allowed in containment. Therefore, Unit 2 has no specified limit for the amount of unqualified protective coatings permitted in containment.

{

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. Atta'chment Response to NRC Generic Letter 98-04 Page 9 (c) If a commercial-grade dedication program is being used at your facility for dedicating commercial-grade coatings for Service Level 1 applications inside the containment, discuss how the program adequately qualifies such a conting for Service Level 1 service. Identify which standards or other guidance are currently being used to dedicate containment coatings at your facility; or,

RESPONSE

Duquesne Light Cc>mpany does not currently employ commercial grade dedication for  :

Service Level I coatings used inside containment at Beaver Valley Power Station Unit 2.

(ii) For plants without the above licensing-basis requirements, information shall be provided to demonstrate compliance with the above requirements of  :

10 CFR 50.46b(5), "Long-term cooling" and the functional capability of the safety-related CSS as set forth in your licensing basis. If a licensee can )

demonstrate this compliance without quantifying the amount of unqualified l coatings, this is acceptable.

RESPONSE

1 l

Per section 6.2.2 of the UFSAR, Unit 2 is committed to conform with Regulatory Guide ,

(RG) 1.82, Revision 0, " Sumps for Emergency Core Cooling and Containment Spray l Systems." Exceptions or deviations to RG 1,82 are stated in UFSAR section 6.2.2.3.1 and Table 1.8-1. Under this commitment, Unit 2 has assumed that the systems that draw from the sumps for the emergency core cooling and containment spray systems may experience sump blockage of up to 50% of the effective sump area from debris generated as a result of a loss of coolant accident (LOCA). At the time Unit 2 was licensed, no distinction was made between the various potential sources for post-LOCA debris; these systems were intended to function, even with debris partially (50%) obstructing the sump screens or trash rack, from whatever source derived. The analyses demonstrate that, l even with this blockage, the emergency core cooling and containment spray systems will continue to provide suflicient cooling flow as to fulfill the long-term cooling functions required to conform with 10 CFR 50.46(b)(5). l Beaver Valley Unit 2 SER (NUREG 1057) Section 6.2.2 stated " System design allows for 50% blockage of the sump screening without loss of function." The NRC staff concluded "that the 50% blockage assumption is acceptable for the Beaver Valley Unit 2 containment sump design" in Section 6.2.2, NUREG 1057, Supplement 5.

The licensing basis for Beaver Valley Unit 2, as accepted by the NRC's SER, provides both the regulatory and safety basis for safety system performance. Coatings are not treated separately in the licensing basis for Beaver Valley Unit 2 because the sump screen

c . .

, Attachment Response to NRC Generic Letter 98-04 Page 10 blockage assumption does not distinguish among the source terms for LOCA-generated debris.

The following information shall be provided:

(a) If commercial grade coatings are being used at your facility for Service Level 1 applications, and such coatings are not dedicated or controlled under your Appendix B Quality Assurance Program, provide the regulatory and safety basis for not controlling these coatings in accordance with such a program. Additionally, explain why the facility's licensing basis does not require such a program.

RESPONSE

Duquesne Light Company does not use commercial grade coatings for Service Level 1 applications unless specifically approved by the BVPS Engineering Department. When approved for such applications, the coatings are considered unqualified paint and controlled under the Appendix B QA program. Duquesne Light Company does not currently employ commercial grade dedication for Service Level I coatings used inside containment at Beaver Valley Power Station Unit 2.