ML19263A635

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COL Docs - Uin 195 Draft 20190912 and Power Point Presentation
ML19263A635
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Site: Vogtle  Southern Nuclear icon.png
Issue date: 09/19/2019
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NRC
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NRC/NRO/DLSE/LB4
References
Download: ML19263A635 (28)
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Vogtle PEmails From: Patel, Chandu Sent: Thursday, September 19, 2019 3:08 PM To: Vogtle PEmails

Subject:

UIN 195 draft 20190912 and power point presentation Attachments: UIN 195 draft 20190912 Attachment only.docx; 195 PowerPoint 20190912-1446.pptx Chandu Patel, Senior Project Manager U.S. NRC, Office of New Reactors NRC/NRO/DNRL/LB4, Washington, DC 20555-0001 301.415.3025 MS T6C20M 1

Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 479 Mail Envelope Properties (SN6PR09MB323215D750204D05F33861D382890)

Subject:

UIN 195 draft 20190912 and power point presentation Sent Date: 9/19/2019 3:07:46 PM Received Date: 9/19/2019 3:07:51 PM From: Patel, Chandu Created By: Chandu.Patel@nrc.gov Recipients:

"Vogtle PEmails" <Vogtle.PEmails@nrc.gov>

Tracking Status: None Post Office: SN6PR09MB3232.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 171 9/19/2019 3:07:51 PM UIN 195 draft 20190912 Attachment only.docx 67190 195 PowerPoint 20190912-1446.pptx 883672 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

U.S. Nuclear Regulatory Commission ND-19-0245 Enclosure Page 1 of 6 Southern Nuclear Operating Company ND-19-0245 Enclosure Vogtle Electric Generating Plant (VEGP) Unit 3 and Unit 4 Completion Plan for Uncompleted ITAAC 2.2.03.08c.x [Index Number 195]

U.S. Nuclear Regulatory Commission ND-19-0245 Enclosure Page 2 of 6 ITAAC Statement Design Commitment:

8.c) The PXS provides RCS makeup, boration, and safety injection during design basis events.

Inspections, Tests, Analyses:

x) Inspections will be conducted of the as-built nonsafety-related coatings or of plant records of the nonsafety-related coatings used inside containment on walls, floors, ceilings, and structural steel except in the CVS room. Inspections will be conducted of the as-built nonsafety-related coatings or of plant records of the nonsafety-related coatings used on components below the maximum flood level of a design basis LOCA or located above the maximum flood level and not inside cabinets or enclosures.

Inspections will be conducted on caulking, tags, and signs used inside containment below the maximum flood level of a design basis LOCA or located above the maximum flood level and not inside cabinets or enclosures.

Inspections will be conducted of ventilation filters and fiber-producing fire barriers used inside containment within the ZOI or below the maximum flood level of a design basis LOCA.

Acceptance Criteria:

x) A report exists and concludes that the coatings used on these surfaces have a dry film density of 100 lb/ft3. If a coating is used that has a lower dry film density, a report must exist and conclude that the coating will not transport. A report exists and concludes that inorganic zinc coatings used on these surfaces are Safety - Service Level I or have been quantified and justified in a program for management of unqualified coatings to demonstrate the unqualified coatings are acceptable for use.

A report exists and concludes that tags and signs used in these locations are made of steel or another metal with a density 100 lb/ft3. In addition, a report exists and concludes that caulking used in these locations or coatings used on these signs or tags have a dry film density of 100 lb/ft3. If a material is used that has a lower density, a report must exist and conclude that there is insufficient water flow to transport lightweight caulking, signs, or tags.

A report exists and concludes that the ventilation filters and fire barriers in these locations have a density of 100 lb/ft3.

ITAAC Completion Description Multiple ITAAC are performed to demonstrate that the Passive Core Cooling System (PXS) provides Reactor Coolant System (RCS) makeup, boration, and safety injection during design basis events. The subject ITAAC requires inspections to verify that:

1. Coatings - Nonsafety-related coatings used inside containment on walls, floors, ceilings and structural steel (except in the Chemical and Volume Control System (CVS) room),

and components below the maximum flood level (MFL) of a design basis Loss of Coolant Accident (LOCA), or located above the MFL and not inside cabinets or

U.S. Nuclear Regulatory Commission ND-19-0245 Enclosure Page 3 of 6 enclosures, have a dry film density of 100 lb/ft3, and inorganic zinc (IOZ) coatings used on these surfaces are Safety - Service Level I or have been quantified and justified in a program for management of unqualified coatings to demonstrate the unqualified coatings are acceptable for use.

2. Caulking, Tags, and Signs - Tags and signs used below the MFL of a design basis LOCA or located above the MFL and not inside cabinets or enclosures are made of steel or another metal with a density of 100 lb/ft3, including coatings used on these signs and tags, and that caulking in these areas has a density of 100 lb/ft3.
3. Ventilation Filters and Fiber-producing Fire Barriers - Ventilation filters and fiber-producing fire barriers used inside containment within the Zone of Influence (ZOI) of a LOCA pipe break or below the MFL of a design basis LOCA have a density of 100 lb/ft3.
1. - Coatings Containment equipment design specifications require that the selected coating system meets the minimum dry film density requirement of 100 lb/ft3, and that inorganic zinc coatings used on containment equipment surfaces are Safety - Service Level I (SLI). The minimum dry film unit weight is specified by the coating manufacturers conformance documentation. The applied coatings are limited to those approved in the design specification (Reference 1), where the dry film density is an intrinsic property of each coating that is determined by testing prior to approval of that coating.

The acceptance criteria of this ITAAC was modified (Reference 2) to allow for a quantity of unqualified SLI coating areas to be administratively controlled under SNCs quality assurance program. An unqualified coating is one that has not passed the required laboratory testing or lacks adequate quality documentation to support its use as qualified. Each instance of unqualified coatings is documented and dispositioned and is consolidated into a unit-specific tracking log (Unit 3 and Unit 4 Unqualified Coatings Logs (UCL), (References 3 and 4)). Use of the unit-specific tracking log for unqualified SLI coatings facilitates compliance with the design specification requirements and provides a means for tracking and retaining a record of these unqualified coatings as a quality record throughout the operational life of the plant in compliance with ASTM D 7491-08 (Reference 5).

For coatings applied off-site at a vendor facility prior to shipment of items to the site, Quality Assurance Data Packages (QADPs) are generated in accordance with the vendors approved Quality Plan and include documentation of the dry film density of the selected coating system, as well as application / inspection certifications for SLI coating applications. Independent personnel review application and inspection records of ITAAC-related coatings by performing an inspection of the QADPs using the guidance of EPRI TR-017218-R1 (Reference 6). This review is expanded to include all ITAAC-related commodity codes present in containment.

Records of all QADPs for ITAAC-related off-site coated components are identified and contained in Unit 3 and Unit 4 Coating Receipt Inspection Reports (References 7 and 8).

This inspection confirms that vendor QADPs for the applied coatings include documentation of the dry film density for the selected coating system, as well as application / inspection certifications for SLI coating applications. Any unqualified coatings are tracked within the UCL for each unit.

U.S. Nuclear Regulatory Commission ND-19-0245 Enclosure Page 4 of 6 The basis for inspecting coatings of as-built SSCs at other than their final installed locations is provided in NEI 08-01, Section 9.5, As-built Inspections. Installation of coated walls, floors, ceilings, structural steel and piping is performed in accordance with applicable procedures to assure that coatings are not adversely impacted during installation.

For coatings applied on-site, the Construction Work Packages (CWPs) include documentation of the dry film density of the selected coating system, as well as application / inspection certifications for SLI coating applications.

The coating contractor QC personnel review application and inspection records of ITAAC-related coatings by performing an inspection of the CWPs; these are identified and contained in Unit 3 and Unit 4 On-Site Coating Inspection Reports (References 9 and 10). This inspection confirms that CWPs for the applied coatings include documentation of the dry film density for the selected coating system, as well as application / inspection certifications for SLI coating applications. Any unqualified coatings are tracked within the UCL for each unit.

Inspection of on-site application of coatings includes repairs or touch-ups applied following the initial application, as well as following installation of SSCs coated at the vendor facility. No coatings of lower density are used in these applications.

Inspections of the QADPs for SSCs coated at the vendor facility and CWPs associated with on-site application of coatings conclude that the coatings used on these surfaces have a dry film density 100 lb/ft3, and that IOZ applications are Safety - Service Level I or are quantified and justified in a program for management of unqualified coatings to demonstrate the unqualified coatings are acceptable for use.

2. - Caulking, Tags, and Signs Prior to application of tags, signs or caulking inside containment, design specifications require that the selected material is either steel or another material with a density of 100 lb/ft3. Signs or tags that are coated are also required to have approved coatings with a dry film density of 100 lb/ft3.

For tags, signs, and caulking used, the CWPs include documentation of the material and the density, and the dry film density of the selected coating system used on any tags or signs.

Caulking contractor personnel review application and inspection records of signs, tags and caulking by performing an inspection of the CWPs; these are identified and contained in Unit 3 and Unit 4 Caulking Inspection Reports (References 11 and 12), and in Unit 3 and Unit 4 Tag and Sign Inspection Reports (References 13 and 14).

This inspection confirms that CWPs include documentation of the material and the density of the tags, signs, and caulking, and the dry film density of the selected coating system used on any tags or signs. No materials of lower density are utilized for caulking, tags, and signs in these locations.

Inspection of the CWPs concludes that the tags and signs are made of steel or other metal with a density of 100 lb/ft3 and that caulking used in these locations, or coatings used on these tags or signs, have a dry film density 100 lb/ft3.

U.S. Nuclear Regulatory Commission ND-19-0245 Enclosure Page 5 of 6

3. - Ventilation Filters and Fiber-producing Fire Barriers By design, there are no ventilation filters installed within the AP1000 containment; filters for the containment air filtration system (VFS) are located in the auxiliary building.

Prior to installation of fire barriers inside containment that are within the ZOI or below the MFL, design specifications require that the fire barriers are either non-fiber-producing type barriers, or fiber-producing barriers that have a density of 100 lb/ft3.

For fire barriers installed, the CWPs include documentation of the material and the density.

Site fire protection personnel review application and inspection records of fire barriers by performing an inspection of the CWPs; these are identified and contained in Unit 3 and Unit 4 Ventilation Filter and Fire Barrier Inspection Reports (References 15 and 16). This inspection confirms that CWPs include documentation of the material and the density of the fire barrier.

Inspection of the CWPs concludes that fire barriers have a density 100 lb/ft3.

Together, these inspections, tests, and reports (References 3 through 16) provide evidence that the ITAAC Acceptance Criteria requirements are met:

  • x) A report exists and concludes that the coatings used on these surfaces have a dry film density of 100 lb/ft3. If a coating is used that has a lower dry film density, a report must exist and conclude that the coating will not transport. A report exists and concludes that inorganic zinc coatings used on these surfaces are Safety - Service Level I or have been quantified and justified in a program for management of unqualified coatings to demonstrate the unqualified coatings are acceptable for use;
  • A report exists and concludes that tags and signs used in these locations are made of steel or another metal with a density 100 lb/ft3. In addition, a report exists and concludes that caulking used in these locations or coatings used on these signs or tags have a dry film density of 100 lb/ft3. If a material is used that has a lower density, a report must exist and conclude that there is insufficient water flow to transport lightweight caulking, signs, or tags; and
  • A report exists and concludes that the ventilation filters and fire barriers in these locations have a density of 100 lb/ft3.

References 3 through 16 are available for NRC inspection as part of the ITAAC 2.2.03.08c.x Completion Package (References 17 and 18).

List of ITAAC Findings In accordance with plant procedures for ITAAC completion, Southern Nuclear Operating Company (SNC) performed a review of all findings pertaining to the subject ITAAC and associated corrective actions. This review found one (1) open Licensee Identified Violation associated with this ITAAC.

U.S. Nuclear Regulatory Commission ND-19-0245 Enclosure Page 6 of 6

1.05200025/2016007-01, 05200026/2016007-01 (Licensee Identified Violation (LIV), Open Failure to Provide Adequate Procurement Specifications for Coatings (ML16245A895)

References (available for NRC inspection)

1. SV3/4-GW-Z0-604 Rev 9, Application of Protective Coatings to Systems, Structures and Components for the AP1000 Reactor Plant
2. Unqualified Service Level I Coatings Program (LAR 17-039) submitted by Southern Nuclear Operating Company (SNC) for the Vogtle Electric Generating Plant (VEGP), Units 3 and 4, on November 3, 2017, and supplemented March 28, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML17307A201 and ML18087A147, respectively).
3. SV3-AX01-GEC-000001 Rev. 0, Vogtle Unit 3 Unqualified Coatings Log
4. SV4-AX01-GEC-000001 Rev. 0, Vogtle Unit 4 Unqualified Coatings Log
5. ASTM D 7491-08, Standard Guide for Management of Non-Conforming Coatings in Coating Service Level I Areas of Nuclear Power Plants,
6. TR-017218-R1, Guideline for Sampling in the Commercial-Grade Item Acceptance Process, January 1999
7. Unit 3 Coating Receipt Inspection Reports
8. Unit 4 Coating Receipt Inspection Reports
9. Unit 3 On-Site Coating Inspection Reports
10. Unit 4 On-Site Coating Inspection Reports
11. Unit 3 Caulking Inspection Reports
12. Unit 4 Caulking Inspection Reports
13. Unit 3 Tag and Sign Inspection Reports
14. Unit 4 Tag and Sign Inspection Reports
15. Unit 3 Ventilation Filter and Fire Barrier Inspection Reports
16. Unit 4 Ventilation Filter and Fire Barrier Inspection Reports
17. 2.2.03.08c.x-U3-CP-Rev0, "ITAAC Completion Package"
18. 2.2.03.08c.x-U4-CP-Rev0, "ITAAC Completion Package"
19. NEI 08-01, Industry Guideline for the ITAAC Closure Process under 10 CFR Part 52

ITAAC 195 - Minimize Containment Debris ITAAC 2.2.03.08c.x 1

ITAAC 195 - Minimize Containment Debris ITAAC 195 Appendix C Wording Design Commitment Inspections, Tests, Analyses Acceptance Criteria 8.c) The PXS x) Inspections will be conducted of the as-built nonsafety-related x) A report exists and concludes that the coatings used on these surfaces have provides RCS coatings or of plant records of the nonsafety-related coatings a dry film density of 100 lb/ft3. If a coating is used that has a lower dry film makeup, boration, used inside containment on walls, floors, ceilings, and structural density, a report must exist and conclude that the coating will not transport. A and safety injection steel except in the CVS room. Inspections will be conducted of report exists and concludes that inorganic zinc coatings used on these surfaces during design basis the as-built nonsafety- related coatings or of plant records of the are Safety - Service Level I or have been quantified and justified in a program events. non-safety-related coatings used on components below the for management of unqualified coatings to demonstrate the unqualified coatings maximum flood level of a design basis LOCA or located above are acceptable for use.

the maximum flood level and not inside cabinets or enclosures.

Inspections will be conducted on caulking, tags, and signs used A report exists and concludes that tags and signs used in these locations are inside containment below the maximum flood level of a design made of steel or another metal with a density 100 lb/ft3. In addition, a report basis LOCA or located above the maximum flood level and not exists and concludes that caulking used in these locations or coatings used on inside cabinets or enclosures. these signs or tags have a dry film density of 100 lb/ft3. If a material is used that has a lower density, a report must exist and conclude that there is insufficient water flow to transport lightweight caulking, signs, or tags.

Inspections will be conducted of ventilation filters and fiber- A report exists and concludes that the ventilation filters and fire barriers in these producing fire barriers used inside containment within the ZOI or locations have a density of 100 lb/ft3.

below the maximum flood level of a design basis LOCA.

2

ITAAC 195 - Minimize Containment Debris Potential sources of ITAAC debris are Coatings, Tags/Signs, Caulking, Ventilation Filters, and Fiber Producing Fire Barriers (see UFSAR Sections 6.1.2 and 6.3.2.2.7.1)

  • Each contributing debris source is evaluated:

- Coatings have requirements of

  • minimum density, or must show will not transport, or
  • Safety-service level, which determines failure potential

- Remainder of items have a requirement of minimum density, or must show will not transport 3

ITAAC 195 - Minimize Containment Debris Evaluate ITAAC debris sources by location:

  • Inside containment* and

- Below maximum flood level (MFL) of a DB LOCA (Elevation 110.2) but not in CVS room #11209 (drains to sump, bypassing screen); or

- Above MFL but not in cabinets or enclosures; or

- Within the zone of influence (ZOI) of an analyzed pipe break

  • The actual CV inner/outer surface is handled separately in ITAAC 138 4

ITAAC 195 - Minimize Containment Debris The Uncompleted ITAAC Notification (UIN) methodology addresses the contributing debris sources as follows:

  • Tags and Signs
  • Caulking

ITAAC 195 - Minimize Containment Debris Off-Site Applied Coatings

  • Prequalified vendors are used for off-site coating work
  • Each vendor documents their coated components with a Quality Assurance Data Package (QADP)
  • QADP documentation varies with coating type:

- Inorganic Zinc (IOZ) on 250°F surfaces are Safety - Service Level I (SLI) - not dense enough to settle, so engineered to remain attached on LOCA

- Epoxy surfaces are Safety - Service Level II (SLII) - their failure does not prevent functioning of the engineered safety features

  • The Unqualified Coating Log (UCL) maintained for each unit tracks unqualified coatings (cannot be qualified in category) 6

ITAAC 195 - Minimize Containment Debris Off-Site Applied Coatings

  • Documentation is provided for

- each batch of coating material

- each coating application

  • Documentation includes these or equivalents:

-

  • Certificate of Conformance (CoC) - indicates coating batch meets the coating specification requirements

-

  • Product Identity Certificate (PIC) - indicates a passing grade of coating batch test results

-

  • Applicator Certification Records (for SLI applications only)

-

  • Inspector Certification Records (for SLI applications only) 7

ITAAC 195 - Minimize Containment Debris Off-Site Applied Coatings

  • NEI-08-01 Section 9.5 covers vendor coating inspections performed not in their final location
  • Document SV0-GW-ITR-001 QADP Inspection Report Summary is the basis for the off-site coatings principal closure document (PCD) 8

ITAAC 195 - Minimize Containment Debris Off-Site Applied Coatings

  • An independent review is performed on the off-site coated QADP documentation with guidance from EPRI TR-017218-R1

- Document developed for use of commercial grade items (CGIs) for safety-related applications

- SNC is applying this review methodology to nonsafety-related coatings in containment with the indicated additional up front acceptance activities:

Technical evaluation of specification requirements Prescreened suppliers are qualified Use of appropriate clear specifications Assessment of vendor production controls and quality checks 9

ITAAC 195 - Minimize Containment Debris Off-Site Applied Coatings

  • EPRI TR-017218-R1 guidance is applied to the QADP review by commodity type
  • Lessons learned from the initial QAPD screening is used to adjust the application of the EPRI TR methodology 10

ITAAC 195 - Minimize Containment Debris On-Site Applied Coatings

  • Location, type and density are documented in Construction Work Packages (CWPs), with application detail qualifiers
  • The UCL is used to track unqualified coating areas
  • A summary of the CWPs is provided as the on-site coatings PCD by the coating contractor QC personnel 11

ITAAC 195 - Minimize Containment Debris Caulking, Tags, and Signs

  • Location and density are documented in CWPs. Any tag/sign coating must also be dense.
  • A summary of the caulking CWPs are provided as the caulking PCD by the caulking contractor personnel
  • A summary of the tag/sign CWPs are provided as the tag/sign PCD by the site labeler 12

ITAAC 195 - Minimize Containment Debris Ventilation Filters and Fiber-producing Fire Barriers

  • No ventilation filters are installed in containment; the PCD will document that containment air filters are in the Aux building

ITAAC 195 - Minimize Containment Debris The UIN references five PCDs per Unit

  • Tags and Signs
  • Caulking

ITAAC 195 - Minimize Containment Debris Additional backup information

15

ITAAC 195 - Minimize Containment Debris Containment components are coated for multiple reasons:

Nonsafety Service Level II Coatings in Safety reason for coating Non-safety reason for coating Containment (Ref.

UFSAR Table 6.1-2)

Prevent dusting (concrete)

Ensure settling if detached Inhibit corrosion (metallic)

Structural Heat conduction Protect from chemical attack Enhance radioactive decontamination Components Ensure settling if detached Inhibit corrosion 16

ITAAC 195 - Minimize Containment Debris Containment components are coated with multiple coatings:

Typical coating (Ref. UFSAR Sect.

Material Reason 6.1.2.1.2)

Self-priming high solid epoxy (SPHSE) Protection, decontamination Temperature too high for Carbon steel Inorganic zinc (IOZ)

SPHSE Galvanized Where practical Uncoated Situation dependent Stainless steel Uncoated Self protecting Concrete SPHSE Protection, decontamination 17

ITAAC 195 - Minimize Containment Debris

Background

  • Post-LOCA core cooling water recirculates in containment
  • Recirculation is through screens without pumps
  • Dense debris is ITAAC material weighing greater than 100 lb/ft3
  • Low recirculation velocity enhances dense debris settling 18

ITAAC 195 - Minimize Containment Debris Coating Safety-Service Levels

  • Coatings are primarily Service Level II (SLII) because their failure does not prevent functioning of the engineered safety features
  • IOZ coatings are only used where epoxy fails on normal temperature, and are required to be Safety-Service Level I (SLI) to prevent LOCA detachment since such debris is not likely to settle out
  • LAR 17-039 provided the Unqualified Coating Log (UCL) for tracking unqualified coatings (cannot be qualified as SLI) within SLI areas.
  • The total inventory of unqualified coatings and coating debris fines generated by LOCA jet is restricted to 70 lbs 19

ITAAC 195 - Minimize Containment Debris AP1000 design features facilitating use of SLII coatings:

  • Long delay between LOCA and start of recirculation allows time for settling of debris
  • High level flooding allows tall recirculation screens
  • Volume is provided for accumulation of debris without plugging
  • Screens are shielded from debris by a surrounding plate
  • Coatings are not used under plate near screens The protective plate, together with low flow, approach velocity and screen size, preclude postulated coating debris above the plate from reaching the screens.

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