ML003739156

Draft Regulatory Guide DG-1076 (Proposed Revision 1 to Regulatory Guide 1.54), for Comment, Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants

ML003739156
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Issue date:	03/31/1999
From:	Office of Nuclear Regulatory Research
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DG-1076 RG-1.054, Rev. 1
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U.S. NUCLEAR REGULATORY COMMISSION March 1999

• OFFICE OF NUCLEAR REGULATORY RESEARCH Division 1 10, "2 *Draft DG-1076 DRAFT REGULATORY GUIDE

Contact:

A.W. Serkiz (301)415-6563 DRAFT REGULATORY GUIDE DG-1076 (Proposed Revision 1 to Regulatory Guide 1.54)

SERVICE LEVEL I, II, AND III PROTECTIVE COATINGS APPLIED TO NUCLEAR POWER PLANTS A. INTRODUCTION In Appendix A to 10 CFR Part 50, "General Design Criteria fu;, ea. . 6wer Plants,"

lms, and components Criterion 1, "Quality Standards and Records," requires that structyr6slsy andards commensurate important to safety be designed, fabricated, erected, and testes tW,!Yi.:t S a quality with the importance of the safety functions to be performed. p,en also requires thatthat assurance program be established and implemented in ord r to r ide adequate assurance safety functions.

these structures, systems, and components will satisfac rii pfoin their In Appendix A to 10 CFR Part 50, Criterion 4, viromental and Dynamic Effects Design Bases," requires that structures, systems, and t (SSCs) important to safety be designed to maintenance, be compatible with the environmental conditions sts. oied with normal operation, testing, and postulated accidents, includin os -of-olant accidents.

In 10 CFR Part 50, Appendxi Criteria for Nuclear Power Plants and for the design, Fuel Reprocessing Plants," estabis~s, ove.ll quality assurance program requirements fabrication, construction, and opera of afety-related nuclear power plant SSCs.

Effectiveness of The maintenance rule,10 CFR 50.65, "Requirements for Monitoring the SSCs and those non Maintenance at Nuclear ov er Plants," includes in its scope all safety-related safety-related SSCs: (t  :

,h*I relied upon to mitigate accidents or transients or are used in plant emergency operatipg ,dures;(2) whose failure could prevent safety-related SSCs from fulfilling uro their safety-rel t fitn nd (3) whose failure could cause a reactor scram or an actuation of a within the safety-related y mer ,b the extent that protective coatings meet these criteria, they are scope of th** t '*ence rule. The maintenance rule requires that licensees monitor the of a regulatory position in this area. As a draft being This regulatory guide is being issued in draft form to involve the public in the development issued for public comment, It does not represent an official NRC staff position.

schedule) and its associated regulatory analysis or Public comments are being solicited on the draft guide (including any implementation Comments should be accompanied by appropriate supporting data. Written comments may be submitted to the Rules value/impact statement.

U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Copies of comments and Directives Branch, Office of Administration, L Street NW., Washington, DC. Comments will be most helpful if received received may be examined at the NRC Public Document Room, 2120 by July 30, 1999.

or for placement on an automatic distribution list for Requests for single copies of draft or active regulatory guides (which may be reproduced) draft guides in specific divisions should be made in writing to the U.S. Nuclear Regulatory Commission, Washington, DC single copies of future Distribution Services Section, or by fax to (301)415-2289; or email to DISTRIBUTION@NRC.GOV.

20555-0001, Attention: Reproduction and

effectiveness of maintenance for these protective coatings (as discrete systems or components or as part of any SSC) in accordance with 10 CFR 50.65(a)(1) or (a)(2), as appropriate. Further guidance is provided in Revision 2 of Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" (Ref. 1).

This revision to Regulatory Guide 1.54 is being developed in accordance with Public Law 104-113, OMB Circular A-1 19, and NRC's Strategic Plan for FY 1997 - 2002, which encourages industry to develop codes, standards, and guides that can be endorsed by the NRC and carried out by industry. The ASTM standards cited in the Regulatory Position of this guide for the selection, qualification, application, and maintenance of protective coatings in nuclear power plants have been reviewed by the NRC staff and found to be acceptable with the exceptions noted.

Regulatory guides are issued to describe to the public methods acceptable to the NRC staff for implementing specific parts of the NRC's regulations, to explain techniques used by the staff in evaluating specific problems or postulated accidents, and to provide guidance to applicants. Regulatory guides are not substitutes for regulations, and compliance with regulatory guides is not required. Regulatory guides are issued in draft form for public comment to involve the public in developing the regulatory positions and, therefore, such draft regulatory guides do not represent official NRC staff positions.

The information collections contained in this draft regulatory guide are covered by the requirements of 10 CFR Part 50, which were approved by the Office of Management and Budget, approval number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

B. DISCUSSION Protective coatings (paints) have been used extensively in nuclear power plants to protect the surfaces of facilities and equipment from corrosion and contamination from radionuclides and for wear protection during plant operation and maintenance activities. For plants that have a design basis that includes a commitment to Regulatory Guide 1.54, the regulations cited above require that protective coatings be qualified and capable of surviving a design basis accident (DBA) without adversely affecting safety-related SSCs needed to mitigate the accident.

In July 1973, Regulatory Guide 1.54, "Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants," was issued to describe an acceptable method for complying with the NRC's quality assurance requirements with regard to protective coatings applied to ferritic steels, aluminum, stainless steel, zinc-coated (galvanized) steel, concrete, or masonry surfaces of water-cooled nuclear power plants. The presumption was that protective coatings that met these guidelines would not degrade over the design life of the plant. However, operating history has shown that undesirable degradation, detachment, and other types of failures of coatings have occurred (Ref. 2).

Detached coatings from the substrate that are transported to emergency core cooling system intake structures may make those systems unable to satisfy the requirement in 10 CFR 50.46(b)(5) to provide long-term cooling.

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"Quality Assurance for Regulatory Guide 1.54 conditionally endorsed ANSI N101.4, endorsed guidance provided Protective Coatings Applied to Nuclear Facilities," and indirectly Water Nuclear Reactor Containment in ANSI N101.2, "Protective Coatings (Paints) for Light responsibility for in 1988; Facilities." ANSI N101.4 and N 101.2 were formally withdrawn standards was transferred to the updating, rewriting, and issuing appropriate replacement specifically ASTM Committee D-33 on American Society for Testing and Materials (ASTM),

Facilities. However, Regulatory Protective Coating and Lining Work for Power Generation were developed for the application and Guide 1.54 was not revised as new ASTM Standards maintenance of NPP protective coatings.

for Protective Coatings ASTM D 3843-93, "Standard Practice for Quality Assurance issued by ASTM as a partial Applied to Nuclear Facilities" (Ref. 3), was approved and Test Method for Evaluating replacement for ANSI N101.4. ASTM D 3911-95, "Standard Simulated Design Basis Accident Coatings Used in Light-Water Nuclear Power Plants at by ASTM to replace the DBA test (DBA) Conditions" (Ref. 4), has been approved and issued Guide 1.54.

standard that was referenced in ANSI N101.4 and Regulatory Coating Standards in ASTM D 5144-97, "Standard Guide for Use of Protective issued by the ASTM to provide a Nuclear Power Plants" (Ref. 5), has been developed and of nuclear power generating common basis on which protective coatings for the surfaces evaluation tests. This ASTM standard facilities may be qualified and selected by reproducible protective coatings under the provides guidance for the application and maintenance of conditions for pressurized water expected environmental, operating, and postulated accident reactors (PWRs) and boiling water reactors (BWRs).

C. REGULATORY POSITION

1. GUIDANCE IN ASTM STANDARDS below provide ASTM D-5144-97 (Ref. 5) and the other ASTM standards discussed the NRC staff for the selection, guidance on practices and programs that are acceptable to protective coatings applied in application, qualification, inspection, and maintenance of nuclear power plants.

in the standards in this The quality assurance provisions and guidance contained methods acceptable to the NRC Regulatory Position are generally acceptable and provide of Appendix B to 10 staff for complying with the pertinent quality assurance requirements CFR Part 50 subject to the following two exceptions.

meet the quality assurance (1) When using this regulatory guide, NRC licensees should guide and must provisions and guidance contained in the standards in this regulatory Quality Assurance also meet the commitments and provisions contained in their Program Description.

(2) Service Level I, II, and III coatings are defined as:

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Service Level I coatings are used in areas where the coating failure could adversely affect the operation of post-accident fluid systems and thereby impair safe shutdown.

With few exceptions, Service Level 1 applies to coatings inside primary containment.

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Service Level II coatings are used in areas where coatings failure could impair, prevent, normal operating performance. The functions of Service Level 2 coatings but not )

are to provide corrosion protection and to improve the ability to decontaminate those areas outside primary containment that are subject to radiation exposure and radionuclide contamination.

Service Level III coatings are used on any exposed surface area located outside containment whose failure could adversely affect normal plant operation or orderly and safe plant shutdown.

ASTM D-5144-97 (Ref. 5) addresses by reference the preparation of test specimens, radiation tolerance testing, decontaminability of coatings, physical properties, chemical resistance tests, fire evaluation tests, DBA testing, surface preparation, coating application and inspection, and thermal conductivity testing. Therefore, ASTM D 5144-97 viewed as a top-level ASTM standard that incorporates by reference other key can be ASTM standards as shown in Figure 1.

2. QUALITY ASSURANCE ASTM D 3843-93 (Ref. 3) provides quality assurance practices that are acceptable to the NRC staff and are applicable to safety-related protective coating work in coating Service Level I areas of nuclear facilities. Applicable portions of practices described may be used as the basis for limited quality assurance for protective coating work in coating Service Level II areas of nuclear facilities.

ASTM D 5139-96 (Ref. 6) provides guidance that is acceptable to the NRC the size, composition, and surface preparation for test samples of protective staff on coatings for use in qualification testing of coatings to be used in nuclear power plants as described in ASTM D 3911-95 and D 4082-95 (Refs. 4 and 7).

ASTM D 3911-95 (Ref. 4) provides guidance that is acceptable to the procedures for evaluating protective coating systems test specimens under NRC staff on simulated DBA conditions. ASTM D 3911-95 also provides guidance on conditions and test apparatus for temperature-pressure testing, conditions for radiation testing, and procedures for preparing, examining, and evaluating samples.

ASTM D 4082-95 (Ref. 7) provides a standard test method that is acceptable NRC staff for evaluating the effects of gamma radiation on the lifetime radiation to the tolerance of Service Level I and II coatings.

ASTM D 4537-96 (Ref. 8) provides guidance that is acceptable to the NRC staff on the qualification and certification of personnel who inspect protective coatings in nuclear facilities. This standard provides guidance on inspection of the education, training, experience, qualifications, and certification of Level I, II, and III coating inspectors.

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AND

3. TRAINING AND QUALIFICATION OF PROTECTIVE COATINGS INSPECTORS COATING APPLICATORS for persons ASTM D 5498-94 (Ref. 9) provides guidance acceptable to the NRC staff of personnel responsible for developing a training program for the indoctrination and training of proficiency for inspecting coating work in nuclear facilities and also recommends areas 1 in ASTM D 5498-94.

that are embodied in the ASTM standards shown in Table for the ASTM D4227-95 (Ref. 10) provides guidance acceptable to the NRC staff to attain the qualification of coatings applicators to verify that they are proficient and able including those in a quality required for applying specified coatings to concrete surfaces, nuclear facility.

the ASTM D4228-95 (Ref. 11) provides guidance acceptable to the NRC staff for and able to attain the qualification of coatings applicators to verify that they are proficient in a nuclear quality required for applying specified coatings to steel surfaces, including those facility.

ASTM D4286-96 (Ref. 12) provides criteria and methods that are acceptable to the the NRC staff to assist utility owners, architects, engineers, and contractors in determining primary overall qualifications of a coatings contractor to execute coating work for the power plants. The criteria and containment and other safety-related facilities of nuclear capability to execute requirements for contractors address the contractor's essential basic nuclear coating work.

4. MAINTENANCE OF COATINGS ASTM D 5163-96 (Ref. 13) provides guidelines that are acceptable to the NRC staff systems for establishing an in-service coatings monitoring program for Service Level I coating in operating nuclear power plants and for Service Level II and other areas outside containment (as applicable).

ASTM D 4541-95 (Ref. 14) provides guidance acceptable to the NRC staff for a procedure for evaluating the pull-off strength of coatings using fixed-alignment adhesion testers.

ASTM D 3359-95, Revision A (Ref. 15), provides guidance that is acceptable to the NRC staff on test methods for measuring adhesion using tape tests.

on ASTM D 5962-96 (Ref. 16) provides guidance that is acceptable to the NRC staff maintaining unqualified coatings (paints) within Level I areas of a nuclear power facility.

5. ASTM STANDARD TERMINOLOGY and ASTM D4538-95 (Ref. 17) defines standard terms related to protective coating are lining work for power generation facilities that are acceptable to the NRC staff and that also applicable to protective coatings employed in nuclear power plants.

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6. ADDITIONAL INFORMATION Additional information on the selection, application, inspection, and maintenance of nuclear plant safety-related protective coatings is provided in EPRI Report TR-1 09937 (Ref.

18), which provides a detailed discussion of important considerations related to protective coatings and can be used to supplement the ASTM Standards guidelines as deemed necessary.

D. IMPLEMENTATION The purpose of this section is to provide information to applicants and licensees regarding the NRC staff's plans for using this regulatory guide.

This proposed revision has been released to encourage public participation in its development. Except in those cases in which an applicant proposes an acceptable alternative method for complying with the portions of the NRC's regulations specified in this guide, the methods and guidance to be described in the final guide will reflect public comments received and will be used in the evaluation of submittals in connection with applications for construction permits, operating licenses, and combined licenses. Current licensees may, at their option, comply with the guidance in this regulatory guide. Any applicable requirements for changing the licensing basis to reflect the change must be followed.

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Figure 1, ASTM Standards Relevant to NPP Class I, II and III Protective Coatings 7

REFERENCES

1. USNRC, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

Regulatory Guide 1.160, Revision 2, March 1997.

2. USNRC, "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 Containment," Generic Letter 98-04, July 14, 1998.

3. American Society for Testing and Materials, "Standard Practice for Quality Assurance for Protective Coatings Applied to Nuclear Facilities," ASTM D 3843-93.

4. American Society for Testing and Materials, "Standard Test Method for Evaluating Coatings Used in Light-Water Nuclear Power Plants at Simulated Design Basis Accident (DBA) Conditions," ASTM D 3911-95.

5. American Society for Testing and Materials, "Standard Guide for Use of Protective Coating Standards in Nuclear Power Plants," ASTM D 5144-97.

6. American Society for Testing and Materials, "Standard Specification for Sample Preparation for Qualification Testing of Coatings To Be Used in Nuclear Power Plants," ASTM D 5139-90 (Reapproved 1996).

7. American Society for Testing and Materials, "Standard Test Method for Effects of Gamma Radiation on Coatings for Use in Light-Water Nuclear Power Plants," ASTM D4082-95.

8. American Society for Testing and Materials, "Standard Guide for Establishing Procedures To Qualify and Certify Inspection Personnel for Coating Work in Nuclear Facilities," ASTM D 4537-91 (Reapproved 1996).

9. American Society for Testing and Materials, "Standard Guide for Developing a Training Program for Coating Work Inspectors in Nuclear Facilities," ASTM D 5498 94.

10. American Society for Testing and Materials, "Standard Practice for Qualification of Coating Applicators for Application of Coatings to Concrete Surfaces," ASTM D4227-95.

11. American Society for Testing and Materials, "Standard Practice for Qualification of Coating Applicators for Application of Coatings to Steel Surfaces." ASTM D4228-95.

12. American Society for Testing and Materials, "Standard Practice for Determining Coating Contractor Qualifications for Nuclear Powered Electric Generation Facilities,"

ASTM D4286-90 (Reapproved 1996).

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13. American Society for Testing and Materials, "Standard Guide for Establishing Procedures To Monitor the Performance of Safety Related Coatings in an Operating Nuclear Power Plant," ASTM D5163-96.

14. American Society for Testing and Materials, "Standard Test Method for Pull-Off Strength of Coatings Using Portable Adhesion Testers," ASTM D 4541-95.

15. American Society for Testing and Materials, "Standard Test Methods for Measuring Adhesion by Tape Test," ASTM D-3359-95, Revision A.

16. American Society for Testing and Materials, "Standard Guide for Maintaining Unqualified Coatings (Paints) Within Level I Areas of a Nuclear Power Facility," ASTM D 5962-96.

17. American Society for Testing and Materials, "Standard Terminology Relating to Protective Coating and Lining Work for Power Generation Facilities," ASTM D 4538 95.

18. Electric Power Research Institute, "Guidelines on the Elements of a Nuclear Safety Related Coatings," EPRI Report TR-109937, March 1998.

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REGULATORY ANALYSIS The guidance in Regulatory Guide 1.54, "Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants,"

has become outdated because the ANSI standards endorsed by the guide have been withdrawn and replaced by ASTM standards. Public Law 104-113, OMB Circular A-1 19, and NRC's Strategic Plan for FY 997-2002 encourage the use of codes, standards, and guides that have been developed by industry and that can be endorsed by the NRC and carried out by industry.

The most cost-beneficial method to update the guidance in Regulatory Guide 1.54 would be to issue a revision of Regulatory Guide 1.54 that endorses updated ASTM standards.

BACKFIT ANALYSIS The proposed regulatory guide does not require a backfit analysis as described in 10 CFR 50.109(c) because this regulatory guide will not require backfitting as described in 10 CFR 50.109(a)(1); rather, this regulatory guide will provide guidance that the licensee may choose to use.

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