ML16342B685
| ML16342B685 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/05/1990 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Meza R AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9007120372 | |
| Download: ML16342B685 (16) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 July 5, 1990 Mr. Robert Meza P.O.
Box 480 Morro Bay, California 93442
Dear Mr. Meza:
This is in response to your letter to the Nuclear Regulatory Commission (NRC) dated June 18, 1990, requesting that we send you a list of ingredients for a product called "Mobile Zinc 7," and, if possible, a requisition for all paint products used at the Diablo Canyon Power Plant located in Avila Beach, California.
As the agency responsible for regulation of the nuclear industry in the United
- States, the NRC is concerned primarily with public health and safety and protection of the environment.
In order to obtain a license to operate a
nuclear power plant, the plant owner submits for our review a Final Safety Analysis Report (FSAR), which describes in detail how the plant meets the safety criteria established by the NRC for nuclear plants.
A copy of the Diablo Canyon FSAR is available for public inspection at the Local Public Document Room, located at the California Polytechnic State University Library, Government Documents and Maps Department, San Luis Obispo, California 93407.
After review of the FSAR, the NRC may, if all applicable safety crjteria are
- met, issue an operating license to the plant owner.
The two nuclear plants at Diablo Canyon were issued full power operating licenses in 1984 and 1985, after a determination by the NRC that the appropriate safety criteria had been met.
As with most other decisions about the design of nuclear plants, the type and quantity of paint used at nuclear power plants is selected by the owner of the plant.
Any aspects of the paint that may affect nuclear safety are described in the licensee's FSAR.
The Diablo Canyon FSAR includes, in Table 6.2-28, a
list of the paints used in the interior of the containment building.
We note that "Mobil MZ-7" is listed as being used as a primer coat for a number of components inside containment at Diablo Canyon.
The NRC reviews the paints used at nuclear plants to determine whether or not they will adverseIy affect nuclear safety.
Our acceptance criteria for paints used at nuclear plants are given in our Standard Review Plan for the review of nucIear power plant applications, Section 6.1.2, "Protective Coating Systems (Paints) - Organic Materials,"
and in Regulatory Guide 1.54, "guaIity Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants."
Copies of these two documents are enclosed for your information and use.
A list of the constituents of the paints used in a nuclear plant is not required to be included in the FSAR.
Paint ingredients and requisition information is not needed in our review to ascertain that paints are qualified for use inside containments under accident condition.
As mentioned
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Mr. Robert Meza the owner of the nuclear plant (Pacific Gas and Electr ic Company, in the case of Diablo Canyon) specifies the paints used, and issues any requisition orders that may be associated with purchase of paints.
In summary, we do not have a list of the ingredients of Mobi 1 MZ-7, nor do we have records of requisitions for any of the paints used in Diablo Canyon, and therefore, we are unable to comply with your request.
ltith regard to other sources of the information about the ingredients of a specific paint, we suggest that you,contact the paint manufacturer.
Sincerely, orig ina 1 s igned by:
Enclosures:
As stated Dennis M. Crutchfield, Director Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission DISTRIBUTION.
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n %y*a4 STANDARD REVIEW P&AN OFFlCE OF NUCLEAR REACTOR REGULATlON 6.1.2 PROTECTIVE COATING SYSTEMS (PAINTS) - ORGANIC MATERIALS REVIEW RESPONSIBILITIES Primary - Chemical Engineering Branch (CMEB)
Secondary - None I.
AREAS OF REVIEW 1.
The protective coating systems (paints) used inside the containment are evaluated as to suitability for design basis accident (DBA) conditions.
2.
The stability of materials including protective coatings and organics are examined to determine the potential formation of decomposition products under DBA conditions.
Radiation and chemical effects are considered.
CMEB will coordinate other branches evaluations that interface with the overall review of organic materials - protective coating systems as follows:
The Equipment qualification Branch reviews the radiation and chemical environments-of equipment under DBA conditions as part of its primary review responsibility for SRP Section 3.11, the Accident Evaluation Branch (AEB) as part of its primary review responsibility for SRP Section
- 6. 5. 2 reviews the fission product removal effective-ness of the containment protective coating systems as well as the containment spray
- system, the Containment Systems Branch reviews the control of combustible gases that can potentially be generated'from the coating systems and organic materials,and reviews the consequences of solid debris that can reach the containment recircula-tion sump as part of its primary review responsibility for SRP Sections 6.2.5 and
- 6. 2. 2 respectively, the Reactor Systems Branch as part of its primary review responsibility for SRP Sections 5.4.7 and 6.3 reviews the effects of solid debris on operations of fluid systems during post-accident conditions.
For those areas of review identified above as being reviewed as part of the primary review responsibility of other branches, the acceptance criteria necessary for the review and their methods of application are contained in the referenced SRP section(s) of the corresponding primary branch.
Rev.
2 - July 1981 USNRC STANDARD REVIEW PLAN Standard review plans are prepared for the guidance of the Office of Nuclear Reactor Regulation staff responsible for the review of applications to construct and operate nuclear power plants. These documents are made available to the public as part of the Commission's policy to inform the nuclear industry and the general public of regulatory procedures and policies. Standard review plans are not substitutes for regulatory guides or the Commission's regulations and compliance with tham is not required. The standard review plan sections are keyed to the Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants.
Not all sections of the Standard Format have a corresponding review plan.
Published standard review plans willbe revised periodically, as appropriate, to accommodate comments and to reflect new informa-tion and experience.
Comments dnd suggestions for improvement will be considered and should be sent to the U.S. Nuclear Regulatory Commission.
Office of Nuclear Reactor Regulation, Washington, O.C. 20555.
II:
ACCEPTANCE CRITERIA 4
CMEB acceptance criteria are based on meeting the relevant requirements of Appendix B to 10 CFR Part 50 as it relates to the quality assurance require-ments for the design, fabrication and construction of safety-related structures, systems and components.
A coating system to be applied inside a containment is acceptable if it meets the regulatory positions of Regulatory Guide 1.54 and the standards of ANSI N101.2.
III. REVIEW PROCEDURES The reviewer selects and emphasizes aspects of the areas covered by this review plan section as may be appropriate for a particular case.
The judgment on the areas to be given attention and emphasis in the review is based on an inspection of the material presented to see whether or not it is similar to that recently reviewed on other plants and whether items of special safety significance are involved.
At the construction permit review stage, the reviewer verifies that the applicant has committed to using prntective coating systems which meet the acceptance criteria.
At the operating license review stage, the reviewer determines the types and quantities of radiation and chemical decomposition products that can be produced from all the paints and organic materials which are exposed to the containment atmosphere.
The paints and organic materials to be considered include those paints that are specified in the Safety Analysis Report (SAR),
unspecified protective coatings on small machinery and equipment, and organic materials such as cable insulation.
The determination is based on documented test data provided by the applicant.
If test data are unavailable, a conserva-tive analysis is required.
The environmental conditions for the test and analysis must be comparable to those specified in Section 3.11 of the SAR.
In the absence of test data on specific coating systems and organic materials, the data in Reference 3 may be used to estimate the rates of hydrogen formation from zinc primers and from zinc. primers plus topcoats.
Cable insulation is assumed to generate hydrogen by radiolysis with a yield comparable to that of polyethylene (Reference 4).
Unqualified paints (organic or inorganic), those that do not meet the acceptance criteria of this Standard Review Plan section, are assumed to form solid debris under DBA conditions.
Unqualified paints that contain only organic materials and that do not meet the acceptance criteria of this Standard Review Plan section, are assumed to generate hydrogen by radiolytic decomposition with a yield comparable to that of organic polymers (Reference 4).
If combustible gases such as hydrogen and methane can be generated, the reviewer notifies the Containment Systems Branch if this source is not included in Section 6.2.5 of the SAR. If a system to control combustible vapors is not provided, then the release of volatile alkanes to form organic iodides is of additional concern.
The yield of organic iodides relative to the total iodine released after a DBA is estimated using the data of Reference 5
and any applicable experimental results submitted by the applicant.
The Accident Evaluation Branch should be notified of the estimated organic iodide formation.
6.1. 2"2 Rev.
2 - July 1981
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If solid debris can be produced, the Containment Systems'ranch and Reactor Systems Branch should be notified of the quantity of debris that can result from decomposition of unqualified materials.
If the Containment Systems Branch determines that the solid debris can reach the containment recirculation
- sump, the Reactor Systems Branch determines the effects of the debris on the operation of post-accident fluid systems.
Any exception to Regulatory Guide 1.54 involving quality assurance and quality control requirements should be referred to the guality Assurance Branch for review and resolution.
Adverse interactions, if any, under DBA conditions, between the potential decomposition products, namely hydrogen and solid debris, and the engineered safety features are evaluated 'under SRP Sections 6.2.5 and 6.2.2, respectively.
IV.
EVALUATION FINDINGS The reviewer verifies that sufficient information has been provided and the review and calculations support conclusions of the following types, to be included in the staff's safety evaluation report:
The staff concludes that the protective coating systems and their applications are acceptable and meet the requirements of Appendix B to 10 CFR Part 50.
This conclusion is based on the applicant having met the quality assurance requirements of Appendix B to 10 CFR Part 50 since the coating systems and their applications meet the positions of Regulatory Guide 1.54, "guality AssuranCe Requirements for Protective Coatings Applied to Mater-Cooled Nuclear Power Plants" and the quality assurance standards of ANSI N101.2, "Protective Coatings (Paints) for Light Water Nuclear Reactor Containment Facilities".
Also, the containment coating systems have been evaluated as to their suita-bility to withstand a postulated design basis accident (DBA) environment.
The coating systems chosen by the applicant have been qualified under conditions which take into account the postulated DBA conditions.
V.
IMPLEHENTATION The following is intended to provide guidance to applicants and licensees regarding 'the NRC staff's plans for using this SRP section.
Except in those cases in which the applicant proposes an acceptable alternative method for complying with specified portions of the Commission's regulations, the method described herein will be used by the staff in its evaluation of conformance with Commission regulations.
Implementation schedules for conformance to parts of the method discussed herein are contained in the referenced regulatory guide.
VI.
REFERENCES 1.
Regulatory Guide 1.54, "guality Assurance Requirements for Protective Coatings Applied to Mater-Cooled Nuclear Power Plants."
2.
ANSI N101.2, "Protective Coatings (Paints) for Light Water Nuclear Reactor Containment Facilities," American National Standards Institute (1972).
6.1.2-3 Rev.
2 - July l981
I
3."
H.
E. Zittel, "Post-Accident Hydrogen Generation from Protective Coatings in Power Reactors,"
Nuclear Technology, Volume 17, pp.
143-146 (1973).
4.
R. 0. Bolt and J.
G. Carroll, "Radiation Effects on Organic Materials,"
Academic Press, New York (1963).
5.
A.
K, Postma and R.
W. Zavadoski, "Review of Organic Iodide Formation Under Accident Conditions in Mater-Cooled Reactors,"
WASH"1233 (1972).
6.
10 CFR Part 50, Appendix B, guality Assurance Criteria For Nuclear Power Plants and Fuel Reprocessing Plants.
- 6. 1. 2-4 Rev.
2 - July 1981
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R EGULATORY DIRECTORATE OF REGULATORY STANDARDS June 1973 GUIDE REGULATORY GUIDE 1.54 QUALITYASSURANCE REQUIREMENTS FOR PROTECTIVE COATINGS APPLIED TO WATEROOLED. NUCLEAR POWER PLANTS A. INTRODUCTION Appendix B to 10 CFR Part 50, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,"
establishes overall quality assurance program requirements for the design, fabrication, construction, and operation of safety. related nuclear power plant structures,
- systems, and components.
'Ibis guide describes an acceptable method of complying with the Commission's quality assurance requirements with regard to protective coatings applied to ferritic steels, aluminum, stainless steel, zinc-coated (galvanized) steel,
- concrete, or masoiuy surfaces of water-cooled nuclear power plants.
The Advisory Committee on Reactor Safeguards has been consulted concerning this guide and has concurred in the regulatory position.
B. DISCUSSION Subcommittee N101.5.7 of the American National Standards Institute (ANSI) Standards Committee N101, Atomic Industry Facility Design, Construction, and Operation
- Criteria, under the sponsorship of the American Institute ofChemical Engineers, has developed a
standard which includes quality assurance requirements for protective coatings applied to ferritic steels, aluminum, stainless steel, zinc-coated (galvanized) steel, concrete, or masonry surfaces of nuclear facilities.
This standard was approved by the American National Standards Committee N101 and its Secretariat. It was subsequently approved and designated N101.4-1972 by the American National Standards Institute on November 28, 1972.
C. REGULATORYPOSITION The requirements and guidelines included in ANSI N10 1.4-1972, "Quality Assurance for Protective Coatings Applied to Nuclear Facilities,"'or protective coatings applied to ferritic steels, aluminum, stainless steel, zinc coated (galvanized) steel, concrete, or masonry surfaces of watereooled nuclear power plants are generally acceptable and provide an adequate basis for complying with the pertinent quality assurance requirements of Appendix B to 10 CFR Part 50 subject to the following:
1.
ANSI N101.4-1972 should be used in conjunction with ANSI N45.2-1971, "Quality Assurance Program Requirements for Nuclear Power Plants."2 2.
Subdivision 2.7 of ANSI N101.4-1972 states that when references are made to other standards, these references shall imply the most recent or current editions of the referenced standards.
The specific applicability or acceptability of referenced standards will be covered separately in other regulatory guides, where appropriate.
3.
Subdivision 1.1.2 of ANSI N101.4-1972 states that quality assurance, as covered by this standard, comprises all those planned and systematic actions necessary to provide specified documentation and adequate confidence that shop or field coating work for nuclear facilities will perform satisfactorily in service.
This statement should not be interpreted as implying that the end product of quality assurance actions is the production of specified documentation.
The term
'Copies may be obtained from the American Institute of Chemical Engineers, 345 East 47th Sitcci, New York, N.Y.
10017.
sCopics may be obtained from the American Society of Mechanical Enginccts, United Enginccting Center, 345 East 47th Sttcctr New York, N.Y. 10017.
USAEC REGULATORYGUIDES Regubtory Guides ore loved to descril>> snd make ovsl4bl ~ to tt>> public methods acccptsbl ~ to the ASC Regulatory staff of implcmentlny specific pans of the Commbsion's regulations, to delineate tachnkives used by the staft In evslwtiny specific problems or postulated sccbbnts, or to provkte guidance to
~pplicsnts. Reyvlstory Guides sro not subctitutes for regulations end compl4nco with them b not required. Methods ond solutions different from thou set out In the guides willI>> acceptable if they provkta ~ basis for tt>> findings rooublte to tt>> bsusnco or continuance ot e permit or license by the Commbsksn.
Publbhed guides will be revbed periodically, osoppropr4te,to accommodate comments ond to reflect new information or expcrfsnc>>.
- f. Power Reactors
- 1. Research ond Test Reactors S. Fuels ond Materials Facilities
- 4. Environmental snd Sltiny S. Mstsr4ls and Plant Protection S. Products T. Traruponstlon
- a. OccupstionslHealth
- y. Antitrun Revbw
- 10. General Copies of pubgshed yvtdes may I>> obtained by request Indicstlny the divisions desired to the US. AtorrHc Energy Comminlon, Washington, DE. 20545, Anontion: Olroctor of Regulatory Standards.
Comments ond suggestions for Improvements In tt>>u gvktes oro encovroycd ond should be sent to tt>> Secretary of tt>> cornmlssbrn, Us. Atomic Energy commission, washington, oc. 20sss, Anent ion: Chief, Public Procasdinys Staff.
II Tt>> guides oro bawd In the followinytsn brood tyvlslons:
"quality assurance" as used in ANSI NI01.4-1972 should be considered to comprise all those planned and systematic actions necessary to provide adequate confidence that shop or field coating work for nuclear facilities will perform satisfactorily in service. In this connection it is emphasized that records and documents listed in Subdivisions 7.4 through 7.8, and included in the
- standard, are suggested forms only.
Alternate documentation consistent with the requirements of Appendix B to 10CFR Part 50 is also considered acceptable.
4.
Sections 3 and 4 of ANSI NIOIA-1972 delineate quality assurance requirements for coating materials and surface preparation of substrates.
Coatings and cleaning materials used with stainless steel should not be compounded from or treated with chemical compounds containing elements that could contribute to corrosion, intergranular
- cracking, or stress corrosion cracking.
Examples of such chemical compounds are those containing chlorides, fluorides, lead, zinc, copper, sulfur, or mercury where such elements are leachable or where they could be released by breakdown of the chemical compounds under expected environmental conditions (e.g., by radiation). This limitation is not intended to prohibit the use oftrichlorotrifluoroethane which meets the requirements of Military Specification MiLC41302b for cleaning or degreasing of austenitic stainless steel provided adequate removal is assured prior to painting.
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