ML052020025

Project Number: 689 - Fire Protection Issue Management Evaluation of Epoxy Coatings in Nuclear Plants

ML052020025
Person / Time
Site:	Nuclear Energy Institute
Issue date:	08/08/2005
From:	Lyons J Division of Systems Safety and Analysis
To:	Marion A Nuclear Energy Institute
Wolfgang R, NRR/DSSA/SPLB, 415-1624
References
Download: ML052020025 (6)

Text

August 8, 2005 Mr. Alexander Marion Senior Director, Engineering Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

SUBJECT:

PROJECT NUMBER: 689 Fire Protection Issue Management Evaluation of Epoxy Coatings in Nuclear Plants

Dear Mr. Marion:

This letter is in response to your June 28, 2004, letter in which you offered an industry evaluation on the combustibility of epoxy coatings in nuclear plants. The staff comments on the specific points in your evaluation are appended below.

NEI Point 1: The use of epoxy coatings at nuclear plants do[es] not, in general, present a significant fire risk and should be removed from further consideration as a generic fire protection issue.

Staff Response: In light of the low probabilities and frequencies of fire scenarios that could lead to core damage as a result of epoxy, we agree that epoxy coatings at nuclear plants do not, in general, present a significant fire risk. However, if unusual epoxy configurations lead to non-compliances with regulatory requirements, the licensees must take appropriate actions to re-establish compliance.

At this time, since the findings on epoxy have been limited to only two plants, the staff plans to address any findings on epoxy on a plant specific basis rather than treating it as a generic fire protection issue.

NEI Point 2: Generally, epoxy floor coatings should be considered non-combustible, since their combustible properties are less severe than other floor finish materials for which the Nuclear Regulatory Commission (NRC) currently requires no evidence of test and listing by a recognized testing laboratory.

Staff Response: The staff agrees that epoxy coatings have been considered non-combustible when installed in accordance with NRC guidance and independent testing laboratory listings.

Per the National Fire Protection Association (NFPA) Fire Protection Handbook, epoxy coatings less than 0.9 mm thick can have Class A, B, or C (per NFPA 101) ratings. Per Regulatory Guide 1.189, a noncombustible material is a material having a structural base of noncombustible material (e.g., epoxy coating on concrete), with a surfacing not over 1/8 in.

thick that has a flame spread index not higher than 50 when measured in accordance with American Society for Testing and Materials (ASTM) E-84, Standard Test Method for Surface Burning Characteristics of Building Materials.

A. Marion 3 NEI Point 3: Inspection guidance should reflect the fact that this is a low fire risk concern and is within the uncertainty band of the Fire Hazards Analysis.

NEI Point 4: Only plants that have unusual epoxy coating configurations that substantially increase the fire hazard or are outside the plant licensing basis should be subject to inspection findings.

Staff Response to Points 3 and 4: NRC inspection procedures (IP) 71111.05T, Fire Protection (Triennial) and IP 71111.05AQ, Fire Protection (Annual/Quarterly), provide high-level guidance to the inspectors on verification of combustible controls. This high-level guidance addresses unusual epoxy configurations as well as other combustibles. In light of the low risk significance of issues relating to the epoxy issue, we have concluded that additional specific guidance to inspect epoxy is unnecessary. We have communicated this conclusion to the Inspections Programs Branch (IIPB) of NRC and they have agreed with our conclusion.

Only unusual epoxy coating configurations will be examined for compliance with the approved fire protection program.

Summary The staff will examine the compliance aspects only for findings of unusual epoxy coating configurations. Unusual configurations are those configurations that do not meet NRC guidance or do not meet their independent testing laboratory listing. During inspections, inspectors follow the current guidance provided for them by IIPB. The fire protection inspection procedure has been prepared to risk-inform the inspections. However, in cases where the inspectors identify epoxy coating applications that do not appear to meet NRC requirements, the inspectors may choose to pursue the issue in accordance with the guidance provided by IIPB.

Deviations from the applicable codes and standards may cause non-compliances from the applicable regulations. If a plant is not in compliance with NRC guidance, the licensee should take the appropriate compensatory measures to return to compliance. Plants transitioning to NFPA 805 can address this issue within the NFPA 805 licensing basis without prior regulatory approval.

Thank you for your input into this matter. If you have any questions regarding this letter, please contact Robert Wolfgang of my staff at (301) 415-1624.

Sincerely,

/RA/

James E. Lyons, Director Division of Systems Safety and Analysis Office of Nuclear Reactor Regulation

ML052020025 NRR-106 OFFICE SPLB:DSSA:NRR SC:SPLB:DSSA:NRR BC:SPLB:DSSA:NRR IIPB NAME RWolfgang SWeerakkody JHannon RGibbs DATE 07/ 29 /05 07/ 29 /05 07/ 29 /05 08 / 02 /05 OFFICE OGC D:DSSA:NRR NAME OGC JLyons DATE 08 / 02 /05 8 / 08 /05