ML092310543

Response to Request for Additional Information Fourth Interval Inservice Inspection Program Relief Request No. 24

ML092310543
Person / Time
Site:	Ginna
Issue date:	08/14/2009
From:	Swift P Constellation Energy Nuclear Group, Constellation Generation Group, Ginna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME1364
Download: ML092310543 (33)

Text

Paul Swift R.E. Ginna Nuclear Power Plant, LLC Manager, Engineering Services 1503 Lake Road Ontario, New York 14519-9364 585.771.5226 Paul.Swift@constellation.com Constellation Energy Nuclear Generation Group August 14, 2009 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Docket No. 50-244 Response to Request for Additional Information Re: Fourth Interval Inservice Inspection Program Relief Request No. 24 - (TAC No. ME1364)

Reference 1: Letter to USNRC Document Control Desk from Joseph Pacher (Ginna LLC),

Fourth Interval Inservice Inspection Program Submittal of 10CFR5O.55a Request Number 24, dated May 22, 2009.

Reference 2: Letter to John Carlin (Ginna LLC) from Douglas Pickett (NRC), Request for Additional Information Re: Fourth Interval Inservice Inspection Program Relief Request No. 24 - (TAC No. ME1364), dated July 15, 2009.

On May 22, 2009, R.E. Ginna Nuclear Power Plant (Ginna LLC) submitted Relief Request No.

24 (Reference 1) to the NRC for review and approval. On July 15, 2009, the NRC issued a Request for Additional Information (RAI) (Reference 2) regarding the Ginna LLC submittal.

The Enclosure to this letter provides the Ginna LLC responses to the RAI questions.

Ginna requests that this relief request be approved by August 31, 2009 to support the upcoming Refueling Outage.

Should you have questions regarding this matter, please contact Thomas Harding at 585.771.5219, or Thomas.HardingJr@Constellation.com.

Document Control Desk August 14, 2009 Page 2 Very truly yours, Paul M. Swift PS/MR

Enclosure:

Response to Request for Additional Information cc: S. J. Collins, NRC D.V. Pickett, NRC Resident Inspector, NRC (Ginna)

R.E. Ginna Nuclear Power Plant, LLC

ENCLOSURE Response to Request for Additional Information TABLE OF CONTENTS 1.0 Response to RAI Questions ATTACHMENTS:

1. White Paper, Engineering Evaluation of the Painted Ginna Bottom Mounted Instrumentation (BMI) Nozzles

2. Owners Acceptance Review (White Paper)

3. Koppers Protective Coating Technical Data Sheet (Zinc Rich)

4. Koppers Protective Coating Bitumastic High Heat Gray

5. List of!Regulatory Commitments R.E. Ginna Nuclear Power Plant, LLC August 14, 2009 Page 1 of 10

ENCLOSURE Response to Request for Additional Information Request for Additional Information Regarding R.E. Ginna, Unit 1 Relief Request No. 24 On the Inspection of the Unit's Bottom Mounted Instrumentation Nozzles Recently, the NRC invoked the inspection requirements ofAmerican Society of Mechanical Engineers Code Case N-722, "AdditionalExaminationsfor PWR PressureRetaining Welds in Class ] Components FabricatedWith Alloy 600/82/182,Section XI, Division 1, " via the incorporationof Title 10 of the Code of Federal Regulations 50.55a(g)(6) (E). As a result, pressurizedwater reactor (P WR) licensees are requiredto perform a 100 percent bare vessel inspection of their unit's reactorpressure vessel (RPV)bottom mounted instrumentation(BMI) nozzles during every other refueling outage (RFO) beginningwith the unit 's first RFO after January 1, 2009.

One objective of the bare metal visual inspections is to detect leakage of reactorcoolant through primary water stress corrosioncracking (PWSCC) of the nozzle alloy 600 base material or alloy 82/182 J-groove weld materialbefore the leaked coolant causes consequentialdamage.

Potentialtconsequentialdamage includes 1) corrosion of the RPV alloy steel base materialand

2) PWSCC of the alloy 600 nozzle base materialfrom the outside diameter (OD) of the nozzle.

Such cracking has been observed in RP V upper headpenetrationsto be circumferentialin orientationwhich creates the possibility of nozzle ejection.

In R. E. Ginna, Unit I's case, for some BMI nozzles, a paint or coating has wicked up into and sealedand occluded the annulargap between the alloy 600 nozzle and the alloy steel base material. It is possible that the paint or coating couldprevent egress of the leaked coolantfrom the annulargap, which couldfacilitate the initiationandgrowth of OD circumferentialcracking and inhibit the ability to detect leakage via visual examination. To addressthis, the licensee has proposed to perform a best effort visual inspection of all R. E. Ginna, Unit ] BMI nozzles during the unit's 2009 RFO and volumetric (ultrasonic)examinations of all R.E. Ginna, Unit 1 BMI nozzles during the unit's scheduled 2011 RFO.

Regarding the 2009 visual examination of occluded BMI nozzles:

1. Provide a discussion of how visual examination or leak detection provides a basisfor ensuring circumferentialPWSCC is not occurring on the outside diameter of the alloy 600 nozzles if the annulus is plugged and occluded by paint.

Response

The detailed visual inspection that has been performed at Ginna has been performed unimpeded with insulation on a combination of a bare metal, and coated metal surfaces during post refueling outages. The Ginna site specific procedure EP-VT- 116 "Visual R.E. Ginna Nuclear Power Plant, LLC August 14, 2009 Page 2 of 10

ENCLOSURE Response to Request for Additional Information Examination of Reactor Vessel Head" has been improved to include the requirements to look for coating that is blistering, bulging, or deteriorated in the annulus area. The Ginna procedure also has a VT-I visual resolution requirement which is a higher resolution than the Code Case N-722 VT-3 resolution requirement. Based upon present code case N-722 requirements to perform a bare metal visual inspection every other refueling outage, an improvement to detect potential leakage from reactor vessel Bottom Mounted Instrumentation (BMI) is realized by performing a higher VT-1 resolution inspection and a detailed visual examination during each refueling outage.

Detection of Primary Water Stress Cracking Corrosion (PWSCC) on the outside of the BMI nozzle by visual examination or leakage detection would not be impeded by an annulus that is occluded by coating based upon the following response to question number 2.

2. Provide copies and a discussion of any qualificationor simulation testing that supports your conclusion that "the paint is unlikely to retain a leak " This should include: a discussion of any actual shear strength or adhesion strength test data availablefor the paint/coatingon the bottom of the R. E. Ginna, Unit 1 RPV; copies of the originalpaint/coatingspecification, applicationproceduresand qualificationreport, as necessary to demonstrate the materials characteristicsof the paint/coating;and, an assessment of the load which would be placed on the coating by leakage into the annularregion.

Response

This response has been divided into three parts to address the different components of the question:

"Provide copies and a discussion of any qualification or simulation testing that supportsyour conclusion that "the paint is unlikely to retain a leak. This should include: a discussion of any actual shear strength or adhesion strength test data availablefor the paint/coatingon the bottom of the R. E. Ginna, Unit I RPV,"

Shear strength or adhesion test data is not available for the coatings on the bottom of the Ginna reactor pressure vessel. A best effort attempt to remove a coating sample will be performed during the 2009 RFO. Testing on this coating specimen could lead to the development of actual coating cohesive bond strengths for use in future evaluations and to help to determine the post 2011 options.

Although shear strength or adhesion strength test data is not available, Ginna LLC contracted the services of an independent registered professional engineer who is a coatings consultant to the nuclear industry. An independent assessment of the coating condition on the lower R.E. Ginna Nuclear Power Plant, LLC August 14, 2009 Page 3 of 10

ENCLOSURE Response to Request for Additional Information reactor vessel head was requested. His conclusion combined with the Ginna LLC reviewer comments of the expected current state of the coating condition on the Ginna reactor vessel lower head annulus area provides new insights into the less than optimal adhesion strength of the coating in the annulus area. The consultant's findings are documented in Attachment 1.

The review of the consultant conclusions by the Ginna Coatings Program Owner is included in Attachment 2.

The conclusions of the consultant and reviewer are that several factors are expected to influence the coating adherence to the substrate in the annulus area as summarized below:

The manufactured surface finish of the nozzle outside diameter (OD) (as specified in the design drawings) and the as-machined bore diameter of the lower head would not be expected to promote good bonding of the coating to these materials without additional surface preparation. Therefore, there is reasonable assurance that the bond (adhesion) between the coating and substrate is weak in the annulus area compared to the remainder of the lower head. It is expected that the surface preparation on the remainder of the lower head was better prepared based on the coating manufacturer specifications and accessibility, as compared to the annulus area.

• The product data sheet for the Koppers product discusses that "all of the organic binder (resin) in the coating is burned off when the material is heated," which was accomplished "during initial startup testing of Ginna." From this the consultant concluded that "the coating film will exhibit very low cohesive and adhesive strengths [and] ... if the coating film was to see reactor coolant system pressure

(-2200 psig), it would immediately disintegrate." This would allow the "hot, high pressure water to leak out of the annulus space. This leakage and attendant crystallization of boric acid would be readily evident during the periodic visual inspections performed by qualified personnel."

If any organic binder did remain, zinc type coatings would not form a uniform matrix of cohesive bonds between individual zinc particles as compared to other types of coatings such as epoxy. Due to the unequal size and spacing of the zinc particles, the structure of the coating would not be expected to be a matrix or a uniform structure, which results in a non-uniform bonding in the coating and a weaker internal cohesion of the coating. Blisters form when a fluid under the coating film exerts a pressure stronger than both the adhesion and internal cohesion of the coating. Blisters typically form from osmosis of water through the coating film, which may only require pressures of "several ounces/sq in".

The references provided by the Ginna LLC reviewer also document the potential effect of water on coating in the annulus area. Assuming that the J-groove weld is cracked and providing a source of water to the annulus region, and given the expected poor bonding conditions described above, the effects of the water on the coating R.E. Ginna Nuclear Power Plant, LLC August 14, 2009 Page 4 of 10

ENCLOSURE Response to Request for Additional Information would cause the coating to "disintegrate," or at the very least blister. The Ginna station NDE procedure used for lower head inspections call for the VT- 1 type inspections of the annulus region and include a specific inspection step to inspect for "bulging" at the annulus. These inspections are being performed during each RFO at a frequency which exceeds the requirements for a bare metal visual exam of every other refueling outage required by Code case N-722.

Assuming a crack in the annulus area, the 2235 psi normal RCS operating pressure will exert approximately five pounds of force on the coating in the annulus area. The expected five pounds of force in the annulus area is larger than the force that is required to initiate a blister, which is typically "several ounces/sq. in". If "disintegration" does not occur, the formation of blisters and "bulging" at the annulus-head interface is expected to occur and be detected during inspections performed using the Ginna Station Lower head NDE inspection procedure.

"...copies of the originalpaint/coatingspecification, applicationproceduresand qualification report,as necessary to demonstrate the materials characteristicsof the paint/coating;"

Specific information on the Ginna BMI coating is not available. However, Attachment 3 provides available Technical data for a product that is specified for coating in the original Westinghouse E-specification 676206, for the reactor vessel, Koppers, Bitumastic Hi-Heat Gray. Attachment 4 provides additional Koppers, Bitumastic Hi-Heat Gray product descriptive information.

"...an assessment of the load which would be placed on the coating by leakage into the annular region."

An assessment of the load which would be placed on the coating by leakage into the annular region was estimated at approximately five (5) pounds force by dividing RCS pressure by the circumferential area of the annular region. Information on coating coverage of the annular region of each bottom mounted instrument and the inspection of the coating is provided below.

Coating occlusions vary at each penetration. A review conducted by the Ginna Station NDE Level III examiner on 1-26-09, documents that per his review, 10 of the 36 penetrations are 100% occluded. Other penetrations that are occluded vary from a low of 8.5% occluded to high of 94.5 % occluded. The NDE examiner summarizes his findings as 10 penetrations being 100% occluded, 21 penetrations greater than 50% occluded and 5 that are less than 50% occluded.

Comparisons of previous year photographs are included in the reviews by the VT level 3 examiner following each RFO inspection in order to judge changes in appearance of the R.E. Ginna Nuclear Power Plant, LLC August 14, 2009 Page 5 of 10

ENCLOSURE Response to Request for Additional Information overall head and annulus conditions. These comparisons provide reasonable assurance that there will be detection of any bulges or blistering.

As requested in the alternative to code case N-722, Ginna is currently scheduled to perform the lower head visual inspection as described above during the upcoming Fall 2009 RFO, followed by UT inspection of the ID of the penetration material during the 2011 RFO. Ginna LLC has engaged in industry BMI inspection guideline development and applied the appropriate inspection option for the Ginna BMI. This formed the basis for the Ginna BMI UT inspection during the 2011 RFO in that the MRP-206 Guideline included the UT option for 2 loop, 18 month cycle plants. Ginna LLC plans to determine the best path going forward following review of the 2011 RFO results.

In regard to the path forward following the 2011 RFO inspections, it should be noted that additional discussions have been and continue to be held with EPRI to determine if it is possible to devise a test plan utilizing an existing EPRI mock-up presently in use at an EPRI sub-contractor location. The preliminary discussions include a concept to apply a similar coating and determine if the coating inhibits leakage detection on that mockup. Discussions are still ongoing as to how to determine the test objectives and definition of success.

Additional discussions are also ongoing to determine any additional alternatives that may be available for coating removal adjacent to the penetration area.

3. Provide a timeline and descriptionof the qualificationof ultrasonictest equipment that will be used during the volumetric examination of the nozzles proposedfor the 2011 RFO.

Include a descriptionof the probes and mockups and the dates that the mockups andprobes were, or will be, procured. This information is necessaryfor the staff to assess the status of qualificationactivities to date. If no qualificationactivities have yet been completed, please identify what kind of administrativeactions have been put in place to ensure thatyou will not discover, during the qualificationactivities, any impediments to volumetric inspection that would necessitate any additionalsubmittals requesting delay, deferral or relieffrom the commitment to complete the volumetric examination.

Response

Ginna LLC has committed to build blind two (2) loop specific samples and to perform a two (2) loop specific BMI qualification for preparation of the 2011 outage. The funding for all qualification and 2011 examination work has been approved. The general project plan is outlined below:

• Determine and finalize alternative examination requirements - 5/15/2009. Complete.

• Ginna LLC to procure EPRI NDE center support for conceptual drawings 5/15/2009.

Complete R.E. Ginna Nuclear Power Plant, LLC August 14, 2009 Page 6 of 10

ENCLOSURE Response to Request for Additional Information

" Submit conceptual drawings to vendors for the manufacture of mockups - 7/1/2009.

Complete

" Vendors to submit proposals to fabricate 2 loop BMI mockups - 8/15/2009.

Complete.

• Initiate a purchase order to the mockup vendor for manufacturing 2 loop BMI mockups - 9/1/2009.

• A formal request for quote will be submitted to the inservice inspection vendors for the various phases of qualification and 2011 RFO examination - 11/1/2009.

" Mockup vendor to complete 3 blind mockup samples and 1 open mockup sample -

12/1/2009.

• Ginna LLC and EPRI personnel will establish qualification requirements 1/15/2010.

• Perform receipt inspection and mockup characterization - 1/15/2010.

• Provide open mockup to inservice inspection vendors for off peak outage technique validation - 2/1/2010 to 6/1/2010.

• Inservice inspection vendor to perform blind procedure qualification and personnel qualification - 6/1/2010.

• Work with the vendor to prepare for bottom mounted instrumentation examination implementation.- 3/1/2011.

• Document examination results and perform data evaluation - 4/30/2011.

The probe designs have been discussed with the inservice inspection vendors. The two (2) loop probe designs will be sensitive to ID connected as well as OD connected flaws in both the axial and circumferential orientations. Existing probe designs will be adjusted to the Ginna two (2) loop BMI design. The probes are expected to consist of forward scatter time of flight ultrasonic transducers and an eddy current coil. The vendors are in a state of readiness and are expected to have probes for the anticipated June 2010 qualification timeframe.

The BMI two (2) loop mockup design will be manufactured under a quality program using the Ginna BMI design. The mockup will consist of an alloy 600 tube material that is welded with Alloy 82/182 weld metal to a stainless steel clad carbon steel simulated vessel block, using various weld angles. The simulated flaws will be manufactured in accordance Reference 1 page 4 specifications. A blind sample matrix of simulated flaws has been established that covers ID connected, as well as OD connected flaws in both the axial and circumferential orientations. The specific probes will not be purchased but will be provided as part of the examination service.

The qualification process will provide an assessment of the two (2) loop BMI examination capability. If qualification is not successful, it is anticipated that there will be enough time for procedure or hardware improvements by the April 2011 RFO timeline.

R.E. Ginna Nuclear Power Plant, LLC August 14, 2009 Page 7 of 10

ENCLOSURE Response to Request for Additional Information

4. Discuss how 2011 volumetric examinationof the volume of the nozzle alloy 600 base material,as detailedin figure 1 on your submittal, will ensure that PWSCC through the J-groove weld has not resulted in leakage of reactor coolant into the annularregion between the alloy 600 nozzle and the alloy steel RPV bottom headfor those nozzles that have paint/coatingplugging and occluding the outer portion of the annulus.

Response

The examination volume described in Reference 1, Figure 1 provides a full volume of inspection of the nozzle base metal and to the extent possible weld interface. Industry experience has shown volumetric examination of the nozzle base material provides insights to J weld material condition. The following discussion is a comparison of cracking behavior of Alloy 82/182 weld with Alloy 600 base material.

There are a large number of examples of service experience where Alloy 600 base metal and Alloy 82/182 welds were exposed to the same environment. Experience has shown that the base metal nearly always cracks in a shorter time than the weld metal. The following discussion and review of these cases will provide a basis for this rationale.

Reactor vessel upper head penetrations were first observed to be cracking in service as a result of a 1991 leak at Bugey Unit 3. Since that time some upper head cracking incidents have been reported. Most cases involved base metal cracking, but there have been a few instances of weld metal cracking as well. Examples of cases where base metal cracked in the upper head penetrations, but not welds, are in INPO reports for Millstone 2, Beaver Valley 1, and ANO 1.

This topic has been studied in depth, both experimentally and through destructive examination of parts from service. Westinghouse reviewed the service experience of these materials in 2003 and has published several papers in this area (References 2 and 3). They concluded that welds will typically require at least twice as long as the base metal to crack.

Reference 3 reported that EDF has examined the replaced heads from 11 different units, with 754 welds, and found no cracks. These findings are significant, since each of these heads were replaced because of cracks in the base metal. The service times for these heads ranged from 60,000 to 140,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

More specific to the bottom head, the only cracking incident which has occurred is at South Texas (Reference 4), where a manufacturing anomaly led to PWSCC of the head penetration tubes. In these two tubes, the cracks occurred in the base metal around the attachment welds, again supporting the conclusion that the PWSCC prefers base metal over weld metal.

Additional evidence is obtained through industry examination data for upper and lower heads as documented in Reference 5.

R.E. Ginna Nuclear Power Plant, LLC August 14, 2009 Page 8 of 10

ENCLOSURE Response to Request for Additional Information This leads to the conclusion that the inspections of the BMI nozzles by ultrasonic examination provide a reasonable approach to maintaining the integrity of the BMI nozzle region. The planned Reference 1, Figure 1 nozzle volumetric examination volume is considered to provide additional assurance as compared to the present N-722 visual examination requirements for detection of bottom mounted nozzle degradation. The ultrasonic examination is also considered to provide a predictive examination since it will detect a crack prior to its appearance at the external surface.

The ultrasonic examination is not impacted by whether the nozzle annulus contains coating or not. Neither an open nozzle annulus, nor a coated nozzle annulus will transmit the sound energy from an ultrasonic examination and thus the coatings would have no impact on the ability to inspect the planned nozzle base material volume.

Ginna LLC has also committed to perform the detailed visual examination during the 4/2011 outage.

5. Discuss any additionaloperator trainingthat may be implemented regardingoperator response to BMI failure scenariosfor the interimperiodfrom now until the volumetric examinations of all R.E. Ginna, Unit I BMI nozzles will be completed in 2011.

Response

The Ginna simulator does not currently model a Reactor Coolant System (RCS) break at the bottom of the vessel location. However, the Ginna Emergency Operating Procedures (EOPs) are based on the Westinghouse Emergency Response Guidelines (ERGs). As such, they are symptom based and are not tied directly to a specific event or break location except for the general event category such as Loss of Coolant (LOCA), Steam Generator Tube Rupture (SGTR), etc. We believe that this event would be properly diagnosed as a LOCA based on Reactor Coolant System (RCS), Containment Pressure, and Radiation Monitor indications.

The operator response would be driven within the appropriate procedures by current parameters rather than break location. The Operators will perform the response and recovery actions necessary to maintain the core covered, regardless of the break location. To validate this scenario, Ginna LLC will model a RCS break at the bottom of the vessel during the next simulator upgrade, scheduled for completion before the end of the Fall 2009 outage. The scenario will be tested, and if there are significant differences in the required response, all operating crews will be trained during the first training cycle following startup from the September 2009 Refueling Outage.

R.E. Ginna Nuclear Power Plant, LLC August 14, 2009 Page 9 of 10

ENCLOSURE Response to Request for Additional Information References

1. Letter to USNRC Document Control Desk from Joseph Pacher (Ginna LLC), Fourth Interval Inservice Inspection Program Submittal of 10CFR50.55a Request Number 24, dated May 22, 2009:

2. W.H. Bamford and J. Hall, 'A Review of Alloy 600 Cracking in Operating Nuclear Plants: Historical Experience and Future Trends', in Proceedings of the 11th International conference on Environmental Degradation of Materials in Nuclear Power Systems -

Water Reactors, Stevenson, WA, August 2003, ANS 2003

3. W.H. Bamford and N.A. Palm, 'Service Experience with Alloy 600 and Associated Welds in Operating Pressurized Water Reactors, Including Repair Activities.

4. Materials Reliability Program: South Texas Project Unit 1 Bottom Mounted Instrumentation Nozzles (#1 and #46) Analysis Reports and Related Documentation (MRP-102).

5. Materials Reliability Program: Inspection Data Survey Report MRP-219 Rev.2 R.E. Ginna Nuclear Power Plant, LLC August 14, 2009 Page 10 of 10

Attachment 1 White Paper, Engineering Evaluation of the Painted Ginna Bottom Mounted Instrumentation (BMI) Nozzles

WHITE PAPER ENGINEERING EVALUATION OF THE PAINTED GINNA BOTTOM MOUNTED INSTRUMENTATION (BMI) NOZZLES Prepared by' Jon R. Cavallo, PE, PCS Senior Consultant Enercon Services, Inc.

August.6, 2009

,6inna ReviY4 by: Title. Date INTRODUCTION 4This White paper has been prepared to provide an engineering evaluation of the painted Ginna Bottom Mounted Instrumentation (BMI) nozzles. The information provided in this White Paperwilbe used to r-espond to. USNRC Requests' forAdditionial inforuiation (RAI) Nos..i and,2 in its letter~dated July 15, 2009 (

Subject:

Request for Additional Informnation RE: Fourth Ifterval Inservice Inspectio Programi Relief Request No., 24 - ["TAG No. ME 1364]1).

USNRC RAI'S The two USNRC RAI's addressed inthis White Paper are contained in a letter dated July 15, '2009 (

Subject:

Request for Additional Information RE: Fourth.Interval fiser,,ice Inspection Program Relief Request No. 24 - [TAG No. ME 1364]):

"41.. Provide a discussion.of how visual examination or leak detection'provides a basis: for ensuring a circumferential PWSCC js not occurring on the OD of the.Alloy 600 nozzles if the annulus i§ plugged and occluded by-paint."'

"2. Provide copies and a discussion of any qualification or simulation testing that supports your conclusionthat "the paint is unlikely to retaina leak.". This should includes: a discussion of any actual shear strength or adhesive strength test data availablefor the paint/coating on the bottom of the R.E. Ginna, Unit 1 RPV; copies of the original paint/coating specification, application procedures and qualification report, as necessary to demonstrate the material characteristics of the paint/coating; and, an, assessment of the load which would be placed on the coating by leakage into the annular region."

VALIDATION OF VISUAL INSPECTION OF THE REGION OF THE GINNA BMI NOZZLES Puring work on GSI-191, "Assessment of Debris Accumulation on PWR Sump," the.

USNRC requested that Industry validatethe use of visual examinationo'f coated surfaces to identify precursors of failure of the paint coating system or underlying substrate.

In response to this request, EPRI and NUCC (Nuclear Utility Coating Council) .initiated a field study of paint coating system visual appearance versus paint coatirig system:

adhesion. This study was~published by EP-RI as Report No. 1014883, "Plant Support Engieriing: Adhesion Testing of Nuclear Coating Service Level I Coatings" dated, August 2Q0O7. The conclusions of the report are, in part:

"Review of the adhesion test data .confirms.that aged, visually intact, designrbasis-accident- (DBA-):qualified'coatings (from various manufacturers) that exhibit no6visual anomalies (that is, no flaking, peeling, chipping, blistering, etc) continue :to exhibit systemi piull-off adhesion', at or in excess of the originally specified (ANSI N5.:1 2*annd ASTIM D5444) minimum value of 200 psi.?'.

"Based on this testing, it is, concluded that ihe: containment.coatings monitoring'approach contaihed in ASTM D5163, as implemefited by license&79, and endorseed by USNRC.in kG 1.5,4 Rev.1: and NUREG .1801 Volume.2, Appendix XIS.8, is valid."

The USNRC concurred with the EPRI/NUCC findings concerningcthe useof visuaI inservicee ifispection 'f paint coatings. In its docruient entitled "NRC-Staff Review Guidance Regarding Generic Letter 2004-02 Closure in the Area of Coatings E*valuation (March.2008)," USNRC states:

"The staff hasreviewed this report (EPRI Report No. 1014883, ed.) and determined that it-provides adequate supporting evidence. that the containment coatings-monitoring approach contained in ASTM D5163, as implemented by licensees, and* endorsed by USNRC in.Regulatoty Guide 1:54, Rev. 1, and NUREG 180I1 (the ý'GALL' Report," ed.),

Vol. 2, Appendix XI.*S, is Valid."

Additionally, visual inspection is the primary screening protocol for ASME Section X.I, Subsections IWEand IWL containment liner inspections, which also involves carefully examining, coated liner plate for any anomalies which might be precursors to paint coating failure or indicators of substrate failures.

Based on current Industry practices endorsed by USNRC, visual examination in accordance with written procedures by trained and qualified personnel of the paint coating onthe reactor vessel in the.BMInozzle region is appropriate. and technically acceptable.

WILL THE PAINT COATING ON THE BMI NOZZLE REGION EXHIBIT VISUAL INDICATIONS OF A LEAK DUE, FORINSTANCE, TO A CIRCUMFERENTIAL PWSCC CRACK ON THE OD OF THE ALLOY 600 BMI NOZZLES?

1. What is the paint coating which was applied to the.BMn Nozzle region of the reactor vessel durin2 fabrication?

Review of available documentation concerning the Ginna reactor vessel reveals two references to'the paint:,coating which was applied to, the. BMI Nozzle:region of the reactor vessel during fabrication.

A. The. Addendum to Westinghouse specificationJ6,7626 for the Ginna reactor vessel states, in Sectioni'4.3.7, "The specific'type.of paint used for the vessel will be chosen by the Supplier and approved by WAPD."

B. The ApproVed Venid6r-drawingg for-the reacto-r vesseli 117802E (see-FSAR Figure 8-2,"Arrangement of Reactor Vessel Logitudinal Section (117802E),"'

contains aGeneral Notes No. 5, "5. All Carbon Steel.Surfaces are painted with two coats HiHeat Gray _Paint..."

C. A Technical Data Sheet for Kopoers ProtectiVe Coating Zinc Rich Bitumastic Hi,-Heat Gray is included. (Attachment~l).

2. What are the properties-of.Koppers Protective Coatimwg Zic Rich Bitumastice Hi-Heat Gray?

A. The Koppers Protective:Coatings Technical Data Sheet'for Zinc Rich Biiumastic Hi-HeatGray does not specifically state ihe: formulation of the paint coating material. Also; in the 1960's, Material Safety Data Sheetsý (MSDS) were not required. Parts of the Koppers organization was sold to Carboline Company in the early 1990's and no records concerning Koppers Zinc Rich Bituinastic Hi-Heat Gray arernow available from either Carboline or Kop-Coat (the successor to Koppers). As' such, all technical

.statements below are based on.the expertise ofthe writer of this White Paper and historical information obtained' from various sources.

B. Based on the Koppers Technical Data Sheet, the existing appearance of the:paint coating on the BMI Nozzles region, (see attached Photograph 1),

and the state of paint coating technology in the mid- 1960's When: the paint coating was manufactured and applied, it is evident that the Koppers Zinc Rich Bitumastic Hi-Heat Gray can be genericAlly classified as an inorganic metallic zinc film. The Koppers Zinc Rich Biturnastic Hi-Heat Gray product data sheet, in the section entitled,""Cring time," states:

"Once the coating has dried, the unit's temperature should be raised gradually and evenly over a.6 to 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period, to 500 0 F, then maintained at.that temperature for a period of 24 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. (Do not raise the-temperature'above 150'F until. the:oating has dried.)

This will bupr off the organic vehicle and fusethe-zinc to the surface:"

In the case of the Ginna reactor vessel, the paint coating.would. have achieyedfull, cure when the vessel was heated during the plant startup process.

The melting, temperature of zinc is 7546F, therefore the.term "fuse" as.

used by K*oppers in Attachment 1, Section "F, "Drying Time',, is a misnomer, since the metallic zinc filler in the paintfcoating will not melt at 500.'F.Rather, 4th paint coating film is an agglpmerati~onof 10 kmjto .20 Am particles of metallic zinc and zinc oxide; Since the binder is burned off duringcure of the coating, the resultant coating film will exhibit very low coh~esive strength afid,. s such, will readily disintegratif pressureis applied.

C.. In the 160's and 1970's, it was common for manufacturers to paint ýcoat.

steam generators, pressurizers and reactor Vesýels',,ith high -termperature coatings, either zinc or aluminum filled, as a temporarynMeasure to preVent.c6rrosion duringtr*`ansportation-ahnd'storage of these items during plantconstruction. The.high.temperature.paint coatings served no purpose

afterlthe plant was put into operation and, as such, the adhesiVe and cohesive strengths of the paint coating applied to-the.various machined/smooth metallic' surfaces on, foi-instance, a reactor Vessel, were

,not a consideration. Modern-plant practice is to eliminate these paint coatings and protect vessels using plastic Wrap ('shrink wvrap").

D; In the tim'eframe of Ginna constirction, the selectinwof K6oppersZinc Rich Biiumastic HiIHeat Gray was appropriate and technically acceptable for its':intended purpose (temporaryc*ofrosioh protecti6n of the reactor vessel during plant construction). Construction of Ginna pre-dated the ANSI Standards for DBA-qualification of nuclear containment coatings (ANSI N.i1 :-2, ANSI N101.4 and ANSI N 5.12). As such, no DBA testing

of this paint coating material exists nor would have been required by the Ginna. licensing basis.

3. If a primary system leak occurred due to Circumferential PWSCC on the OD of the Alloy 600 BMI nozzles, would the Koppers Zinc Rich Bitunastic Hi-Heat Gray coating provide-a visual indication of the primary coolant: ieaka!e into the annulus between the Alloy 600 BMJ nozzle and the steel reactor vessel?

The answer*to this question is a defuinte "yes," based on the f01lowing considerations.

A., A primary coolant leak into the annulus space between any given Inconel 600 BMI nozzle and the carbon steel reactor vessel would produce an environment of borated water at -2200 psig and -540 degrees F if it is assumed that the

!existing paint coating acts as a seal of theannulus spacez Since water is an

,incompressible fluid, all surfaces in the annulus (steel, Inconel 600 and paint coating) would be uniformly exposed to this high pressure (-2200 psig).

Since:the existing paint coatinig has essentially no cohesive strength, the paint coating film would disintegrate, allowing hot, high pressure water to leak out of the annulus space. This leakage and aitendant crystallization of boric acid would be readily evident during the:periodic visual inspections by qpalified personnel.

B., TheK Koppers; Zinc Rich Bittimasfic.Hi-Heat Gray paint coating material, according to the manufacturer's technical data sheet, is rated-for continuous exposure at 800 degrees F-and thus would not .bedamaged by the eleyated temperature alone. This premiseis validated becauseno heat-produiced anomalies-in the existing paint,coaiing have been idenjified to date during periodic visual inspections of the BMI nozzle area.

C. As described in the Koppers Zinc Rich BitumaStic Hi-Heat:Gray prodUct

,data sheet, allofthe organi~cbinder (resin) in the paintoating i§'burned off When the material is-heated to5,00 0 F.for 6 to,8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This.conditidn would have occurred during: initial startup testing0of Ginna. The remaining paint coating film thus consists of 10 [am to 20 ptm discrete particles of metallic zinc and zinc oxides. Sinceall binder (resin) was burned off during the.curing process, the~resultant zinc / zinc oxides paint coating film will exhibit',very low cohesive and adhesive strengths: since no binder remains to provide cohesive strength to the paint coating-film. If the paint coating film were to see reactor coolant system pressure (--2200 psig), it would immediately disintegrate. This disintegration and associated boric acid deposits fromn reactor coolant leakage wouldIbe readily identified by visual. inspection of the.

affected area.

Please note that cohesive failure of the Koppers Zinc Rich Bitumastic Hi-Heat Gray paint coating material has already spontaneously occurred during' noral plant operation due to the Veiy low paint coating film cohesive.strength (See red circle on Photograph 1)..

D. The steel reactor vessel annulus surface, if exposed to,hot~borated water in the verit -of a primary coolant leak, would corrode. The corrosion product produced, iron oxide, would expand to 5 to 10 times the volume which had been occupied by the metallic iron prior to oxidation. This expansion of corrosion product would produce blisters, sometimes referred to as caibuncles, in the coating fIlm, which would be readily evident during visual inrspection of the coating.

ATTACHMENTS

1. Koppers Protective Coatings Bitumastic Hi-Heat Gray manufacturer.'s technical data sheet.RC2-039 - March,. 1969 PHOTOGRAPHS

1. 661 _12.jp

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PHOTOGRAPH NO. 1 Attachment 2 Owners Acceptance Review (White Paper)

Owner's Acceptance Review Prepared by: Damon J. Peters, Ginna Coating Engineer White Paper "Engineering Evaluation of the Painted Ginna Bottom Mounted Instrumentation (BMI) Nozzles," which was prepared by Jon R. Cavallo, PE, PCS.

Extent of Review:

The review encompasses checking the references of the section "Validation of Visual Inspection of the Region of the Ginna BMI Nozzles." In particular, the review of references is specific to the GSI-191 discussion.

The review also includes the discussion on "the properties of Koppers Protective Coating..." In general the review of this section was not to validate the statements, but to ensure that the statements are reasonable from a coatings perspective.

The final section, #3, in response to the NRC RAIs was also reviewed. It has been deemed prudent to elaborate on the engineering basis for why there will be visual indication in the coating if RCS leakage was to occur at the reactor lower head BMI nozzle region.

Discussion:

The references used in the discussion on GSI-191, have been reviewed and determined to be

,acceptable. That is the references comply with Ginna's design basis, and are in compliance with regulatory requirements for the Ginna's Containment Coatings Program. Specifically, the coatings program visually inspects containment coatings to ensure that the condition of the coatings systems are not degraded, and continue to satisfy their design requirements of protecting the substrate to which they have been applied. This is an NRC supported conclusion, as quoted from the "NRC Staff Review Guidance Regarding Generic Letter 2004-02 Closure in the Area of Coatings Evaluation" in the white paper.

A review of the summary provided by the independent coatings consultant on "the properties of Koppers Protective Coating..." was performed to determine if the conclusion that the coating will exhibit visual indication of a primary coolant leakage was reasonable. As discussed in the white paper, the Zinc rich coatings following the organic solvents "burn"-ing off will be made up of zinc particles on the order of 10 to 20 ýt m with a minimal amount of organic binder remaining.

After the initial series of reactor startups that applied heat beyond the specified duration in the Koppers technical data sheet, it can be safely concluded that a majority of the vehicle was "bum"-ed off. Therefore, the remaining cured (hardened) vehicle and zinc particulate, based on engineering judgment, will exhibit a non-uniform structure., The expected total thickness of a single coat of the coating would be 3 mils, or 0.003" compared to a single zinc particle thickness of 0.0004" (10 [tm) to 0.0008" (20 tm). Also, even though the zinc particles will be dispersed throughout the coating, there is no means of ensuring the particles are evenly spaced from one another. This lends to a non-uniform coating structure. Due to the unequal size and spacing of the zinc particles, the structure of the coating cannot be a matrix or a uniform structure, which results in a non uniform bonding in the coating and weakens the strength of the coating. In

addition to the non-uniform structure, the apparent intention of the coating was to protect the steel surface during vessel transportation. This fact is expected to have some influence on the final condition of the coating. That is, the apparent intent of the coating was for transportation only. Since the coating was not considered to have a critical function (see white paper), the applicators may not have completely followed the application and curing schedules. We know that the nozzles could not have had appropriate surface preparation for the coating, because the drawings for these had a specific surface finish called out that is very smooth in comparison to the surface that would be required to establish a proper bond (adhesion) between the coating and substrate. From inspection photos (see photograph #1 of white paper) examples of sags can be seen on the nozzles. This is an indication of poor surface preparation and application in the area of the nozzles that is, the paint was applied in some cases over the annulus in what appears to be a non-uniform distribution. Therefore, it is expected that the coating is weaker than what a proper surface preparation, application and cure would have produced.

If a primary water leak was to occur and the annulus space was pressurized, it would be expected to break the coating ("disintegrate"); if not at the very least it would form blisters.

From Steel Structures Painting Council (SSPC) now known as SSPC: The Society for Protective Coatings Good Painting Practice, [1] page 501, "blistering most often results from surface preparation or applying a coating over a dirty, greasy, moist or contaminated surface."

Furthermore, blisters typically form from osmosis of water through the coating film, which may only require pressures of "several ounces/sq. in" ([1] page 500).

Therefore, if the 2235 psi were applied to the annulus area, and the resulting approximate 5 lbs force was considered on the annulus area, the paint would be expected to be visibly degraded in the area of the annulus region.

Blisters form when a gas or liquid under the coating film exerts a pressure stronger than both the adhesion and internal cohesion of the coating ([1] page 499). The bonding strength between the coating and the nozzles is expected to be very low, because of the lack of proper surface preparation. The curing is expected to have burned off much of the binder in the coating (see white paper). Both of these factors can lend to the formation of blisters. Based on the likelihood of blister formation and/or coating breaks, combined with engineering judgment based on the above observations, the conclusions of the white paper entitled "Engineering Evaluation of the Painted Ginna Bottom Mounted Instrumentation (BMI) Nozzles" provides reasonable assurance that the coating will exhibit visual indication of primary coolant leakage into the annulus if RCS leakage were to occur.

References:

1. Good Painting Practice, Steel Structures Painting Manual Volume 1, Steel Structures Painting Council (SSPC) 1982.

Attachment 3 Koppers Protective Coating Technical Data Sheet (Zinc Rich)

TECHNICAL DATA SHEET

\Protective Coatings TYPE OFVCOATING iiiecie o tig ZINC RICH Product; BITUMASTIC HI-HEAT GRAY DESCRIMON: A two-component, zinc-filled, polymeric coating having Eelf-priming characteristics. After incorpyratio*ni- ofthezinc powder in the vehcle, the coating has about the same consistency as ordinary paint USE: FOR INDUSTRL4L USE .ONLY. NOT INTENDED FOR USE IN THE HOME.

A protective coaptng espccially, forml4ated for use on metal surfaces subjectcd to high temperatures. '(8000F Continuous; 1,200.F In-

• termi tteiit)

'TECHNICAL DATA:

Number of coats: One only SNI Volume.solids, 63%

'Theoreical coverage: 1,,010 mai sq. ft,/ga.X Coverage to achieve minimum diry filim'thickness: 270 to 400. sq.ft.lgpd. (allows for an appr'ximate hiplieation 16ss of 20%.

Filmibuild ratio-

ýMinimum dry film required:, 2.0 tO ,..Omils Wet film required: 832 to 4.8 mils Drying time at 70oF.:

and-50% relative humidity:..

To.,touch:! 18 to 24hours Curing time: Oncc the coating has dried,,the unit's temperature .Shouldbe raised gradually and evenly over a 6 to 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period, to 500 0 F, then maintained at that temperature for a period of 24 to 48*hours. (Do not raxse the temperature above 1.50 0 F. until the coating.has dried)

This will burn off the o6ranic vehicle and fuse thezine to ihe.surface.

Note L the coated surface: must not.be sjected to- Weathering for any longer than one week before eurmg, otherwise maximum pro-,

( tCeivcqualities'wil not be obtained.

Color:, Zinc metal gray Koppers Company, Inc., Pittsburgh, Pennsylvanla 15219

TECHNICALUDATA Thinner': .'KoppersThinner4000., Normally, thinningdis not 4t- reduce the consistency in cold weather, up to required, however, 1/2, pi)ntof thinner, per gallon can be, usc4 10 Cleaner:. Koppers Thinner 400a" Surface preparation:

Steel: Surface must be dry, and free of -drt, loose mill scale, welding scaEe, rust, oil, grease, Old p'ant, residual acids, alkalies or other foreign matter. Rernoye these,interference materials by sand or grit blas"tng, flame cleaning, hand or p0wer. wire .brumsing a.dler scraping.

Primer: None Mixing instrutionS: Stir the vehOýic well, Add sufficient vehicle to the powdered make a heavy, -rooth paste. Add balance of vehicle slowly,zine'to while

.stirring. thepaste. After all vehicle is added, stir thioroughly to obtain a homogeneous .mixturCe Mix only, is, imuch naterial aswill be used during an 8-hour p'riod;Do not attempt to store the mixed*materi-al Methods of application:"

The best method of applicatibr is by brushing. The coating should he spread evenly taking care to brushit into pits, cracks and:,re*ices thoroughly to obtain a uniform thin film. Conventional air spr:aying can be used bot will have slightly.leis efficiency. Airless'sprAying is K~)

not -recommended.

Iwhe Do not apply at -temiperatures-bewd 352;54;or

<the surface: is aboye 1509F. Do not apply to surfaces thatvwill be' exposed to raim before the co'ating is dry.

dry%: 800 ho,,entinuoiuS; l,2OOOF.,intermittent.

Temperature litnationS:

Storage life: One year minimum Pot lifh: 8 Thours,,

Packagng:J1gallon ,amd 15-ganolo kits. Each kit has tocnanr.Te1glo kit has oneccontiiner with approximately- 8 pounds of vehicle and one co IntIainier wt approximately 11 pounds of zinc powder. The 5'gal..

ton kit has one contaner withn aPproximately 40 pounds of vehicle and one codtainer. with ppromately 50 pounds of'zinc powder.

PREFCAUTTONS: Take these precautions during ipplication and before the coating dries:

Liquid vehicle component and ra;ed paint:

WAR NIN G!

flarmnful 6r fatal if, swalliowed.

Vapor harmful. Combustible.

CONTAINS PETROLEUMADSTILLAt'

TECHNICAL DATA (Continvied):

'PRECAUTIONS Avoid prolonged breathing of vapor or spray mist. Avoid prolonged Keep (Continued): or repeated contact *ith skin. Keep away from heait and flame.closed closures tight and upright to prevent leakage. Keep container accord-when not in use.. In ciase of pllage, absorb and dispose of in ance with local applicable regulatiois. Do not take internally.

KEEP OVT OF REACH OF CHILDREN.

Use Only With Adequate Ventilation.

In cofifined areas, use adequate forced ventilation continuously during- application and drying. Use fresh air mnasks, clean protectiye clothing and exPo0si0n-propf equiiprnent. Prevent: flames, sparks, welding and si0n9ng.

FIRST AID- In case of ski contact, wash thoroughly with soap and water; for eyes, flush immmediatdy.wAith plenty of water for 15 nin-utes and cl a physician. !f inhaled, remove to, fresh 'air. jf, swallowed, CALL A PHYSICIAIK IMMEDLATELY. DO NOT.

induce vomiting, IN CASE OF FIRE: Use dry cheerilcal, foam, ,water fog or C02.

-Cool closed cintainers with water.

Non-Photochemically Reantivc..

Additional precautions for Zinc: Powder; Avoid breathing, dust; keep away from feed and food produicts. Wash thoroughhy after handling dust jbefore eating' or s .oking. 'Wear a reepiiatof when .adding.powdec to. vehicle. Po must be kept dry kdet t6 .Avoid fire. Keep container tightly closud wh~n not in use, Store in a cool dry, place. Keep sýepaate from acids; halogenated hydro6-carbons and ýtrong alkali hydro,xides.

IN CASE OF, FIRE: Smother ith suitabli dry p0wder..*Wear,.eif-cohtained breathing. appaatus, Any mixtureof the liquid vehicle component and zinc powder coin-ponent Aill have hazards of bo6th components. Observe all applicable prkCautions.

VfARRANTY All technkcaI dvicv, reomnacn n ~.fe r edndb. h~Seler'gevlb, They are baijrdon fjvchsaai d4 10 icb'th~eSeiat beli*e*vesto be reliable and are inrandcd for uo* by-persons haiing *kil! and ksio'how, ao rhair aiscretloi':and-adrik Seilersmsouneo i,-ponsibi . r*,ul, atoifted for ". or damages irwertd'ýfom ih. r as aIeby naoe r'her s recmmded *'uereino rie' o.tch recommrndations, techncol advwce orpices are artnoto b --as ""no as . unr . . r.. f

.any existing patent.

jnuary 1980 Supeseaas asilpravious dath shoetl prltnto of, thtis peoduct.

Attachment 4 Koppers Protective Coating Bitumastic High Heat Gray

BITUMASTIC HI-HEAT rotective Coatings GRAY BITUMASTIC HI-HEAT GRAY A. GENERAL CHARACTERISTICS E. RATE OF APPLICATION Bitumastic Hi-Heat Gray is applied only by.

Bitumastic Hi-Heat Gray is a self-priming, brushing. One coat should be applied at a gray colored protective coating especially for- rate of 400 - 450 square feet per gallon. This mulated for use on metal surfaces subjected to will give a dry film thickness of 2 - 3 mils, high temperatures (800WF. Continuous; 1200'F. The coating should be spread evenly taking care Intermittent). As received,, it consists of a con-to brush it into pits, cracks or crevices thoroughly tainer of vehicle and another of metallic zinc to obtain a uniform Ithin film. If thinning is powder. After incorporation of the zinc powder necessary to reduce the consistency in cold in the vehicle the product has about the same weather, use no more than 1/2 pint of mineral consistency as ordinary paint. spirits or turpentine per gallon. The coating should be stirred frequently during application.

B. COMPOSITION Bitumastic Hi-Heat Gray is composed of a F. DRYING TIME special base vehicle, proper driers and pigmented Bitumastic Hi-Heat Gray dries to touch in

"* with, netallic filler. 18 - 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; the actual rate. of drying is de-

.pendent upon operating temperatures, of the sur-C. PREPARATION OF SURFACES faces to which tilecoating is applied. Once the coating has d ried, the temperature of the unit Before applying Bitumastic Hi-Heat Gray to should be raised gradually to 500'F. for a period metal surfaces, all dust, dirt, loose mill scale, of 24 - 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This will burn off the organ-ic welding scale, rust, oil, unbonded or incompatible solvents and fuse ithe metallic zinc..to the sur-paint, grease, residual acids, alkalies or other fade. Provisions should be made to bring the foreign matter must be removed as completely as painted surface to 500°F. minmimum within one possible from the surfaces to be coated. It is week, after application.

recommended that rust, scale and paint be removed by sand or grit *blasting, flame cleaning, hand or power brush ing, and/or scraping. All surfaces G. TEMPERATURE OF SURFACES must be dry before the coating is applied.

The temperature of the surface being coated should not be below 35°F. nor above 150'F. during D. MIXING application and should not be, increased until the coating is thoroughly dry.

The)vehicle should be stirred first until the pigment and filler tare thoroughly dispers'ed. Suf- The coated surface, should not be subjected ficient vehicle should then be added and mixed to' weathering for any longei than one week-prior with the metallic zinc powder to make a heavy to reaching the minimum "temperature of 500'F.

paste. Finally, the remainder of the vehicle should be added to the paste and the mixture thoroughly stirred to prodhuce a uniform product. H. CLEANING EQUIPMENT NIix only as much material as will be used during the day.- Do not attempt to store the coating in a Brushes and `other equipment should be inixed ,condition. cleaned using turpentine or mineral spirits.

wippers Companiy, Inic., PittP.>srqli, Pennsylvania 1521'

~. ..-,. -

IL PACKAGING gallon kit of 2 containers (approx vehicle, approximately 50 lbs. f*,'

1 gillon kit of 2 containers (approximately 8 lbs. vehicle, approximately 11 lbs. filler). 5 J. PRECAUTIONS

'CAUTION  !

Combustible Harmful or fatal if swallowed.

CONTAINS PETROLEUM DISTI.LLATE In confined areas, provide adequate forced ventilation during application and drying. Use air masks, clean clothing and explosion-proof equipment. Pre-vent .flames, sparks, welding and smoking.

5-A WARRANTY "All technicol advice, recomusendations unud services orc re, dcrcs by tlhe, Seller gratis. They. ore hosrd.on the.Seller believe. to be reliable Ind ore in*endedl for useby persons horing skill (ond knowhow. cit their 1!

Seller ossumes no responsibility f or resolts ohtohinewd or dornamges inrurred fromn thpir use hy B3otyer whetdt herein or otherwiise. Sudh re c tnmen dations, technical advice or services; cre not to he t kten (is ( license intended to sulggest infringement of noy existing patent."

RC-2-039-Moich, 1969 Supeisetdes otllprevious dolo sheets ptnied on 1his poduc*.

Attachment 5 List of Regulatory Commitments

Attachment 5 List of Regulatory Commitments The following table identifies actions committed to in this document by R.E. Ginna NPP. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Thomas Harding at 585.771.5219, or Thomas.HardingJr(@)Constellation.com.

Regulatory Commitment Due Date A best effort attempt to remove a coating October 31, 2009 sample from the reactor vessel lower head will be performed during the 2009 RFO Model a Reactor Coolant System Break September 30, 2009 location at the bottom of the Reactor Vessel for the Ginna Simulator and determine if significant differences in operator response for

.a bottom of vessel break and a traditional cold leg break exist. If so, schedule additional simulator training during the first training cycle following startup from the Fall 2009 refueling outage.

Complete additional simulator training, if November 30, 2009 required.