ML20195C720
| ML20195C720 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/11/1998 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1940-98-20665, GL-98-04, GL-98-4, NUDOCS 9811170201 | |
| Download: ML20195C720 (9) | |
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GPU Nuclear, Inc.
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U.S. floute #4 Seth NUCLEAR Post Office Bw. 3 Forked ber, NJ 08731-0388 Tel 609-9714000 November 11,1998 1940-98-20665 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
Subject:
Oyster Creek Nuclear Generating Station Docket Number. 50-219 Response to Generic Letter 98-04 dated July 14,1998
References:
(1) NRC Generic Letter 98-04: Potential for Degradation of Emergency Core Cooling System and the Containment Spray System After a Loss-of-Coolant Accident because of Construction and Protective Coating Deficiencies and Foreign Materialin Containment (2) EPRITR-109937: Guidelines on the Elements of a Nuclear Safety Related Coatings Program, dated April 1998 On July 14,1998, the Nuclear Regulatory Commission issued the referenced letter addressing issues having generic implications regarding the impact of potential coating debris on the
- operation of safety related systems, structures, and components during a postulated design basis Loss of Coolant Accident. Protective coatings are necessary inside containment to limit radioactive contaminations and to protect surfaces from erosion and corrosion. Detachment of the coatings from the substrate may render the Emergency Core Cooling System unable to satisfy the requirements of 10 CFR 50.46(b)(5) to provide long-term cooling and core spray functions following a Loss of Coolant Accident. The generic letter requested infonnation under 10 CFR 50.54(f) to evahtate the addressees' programs for ensuring that Service Level 1 protective coatings inside containment would not detach from their substrate during a design basis LOCA and interfere with the operation of the ECCS. Attachment I to this letter provides the required GPU Nuclear, Inc.120-day response.
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If any assistance or additional information is required, please contact Mr. John Rogers of my staff at (609)-971-4893.
Very truly yours, i
b Michael B. Roche Vice President and Director Oyster Creek I
MBR/JJR l
cc:
Administrator, Region i NRC Project Manager i
Senior Resident Inspector Sworn to and subscribed before me this
// 6v day of M1998.
ubb Notary Public My commission expires: la -i k>0 0 I
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Item No.1 l
(Provide) a summary description of the plant-specific program or programs implemented to l
ensure that Service Level I protective coatings used inside the containment are procured, l
applied, and maintained in compliance with applicable regulatory requirements and the l
plant-specific licensing basis for the facility. Include a discussion of how the plant-specific program meets the applicable criteria of 10 CFR Part 50, Appendix B, as well as l
information regarding any applicable standards, plant-specific procedures, or other guidance used for: (a) controlling the procurement of coatings and paints used at the facility, (b) the qualification testing of protective coatings, and (c) surface preparation, application, surveillance, and maintenance activities for protective coatings. Maintenance activities involve reworking degraded coatings, removing degraded coatings to sound coatings, correctly preparing the surfaces, applying new coatings, and verifying the quality of the l
1 GPU Nuclear Response to item No.1 Oyster Creek Nuclear Generating Station (OCNGS) was not originally committed to Regulatory Guide 1.54, " Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Power Plants", because the plant was licensed prior to the issuance of this Regulatory Guide in 1974. Currently, GPU Nuclear, Inc. (GPUN) is committed to a modified version of this Regulatory Guide. Our commitment is detailed in the GPUN Corporate Policy and Procedure Manual Number 1000-PLN-7200.01. Specifically, the GPUN Operational Quality Assurance (OQA) Program has committed to Regulatory Guide 1.54 with the following clarifications:
(1) GPU Nuclear will comply with the Regulatory Position established in this Regulatory Guide in that the QA programmatic / administrative requirements included therein shall l
apply to maintenance and modification activities even though such requirements were not in effect originally. Technical requirements associated with maintenance and modifications (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements) shall be the original requirements or better.
(2) The quality assurance program for protective coatings includes the planned and l
systematic actions necessary to provide adequate confidence that shop or field coating work for nuclear facilities will perform satisfactorily in service.
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l All protective coatings, except those noted in 3 below, applied to surfaces within containment are tested to demonstrate that they could withstand LOCA conditions.
These tests are performed in accordance with Section 4 of ANSI N101.2," Protective Coatings (Paints) for Light Water Nuclear Reactor Containment Facilities", under l
LOCA conditions which equal or exceed those described in the FS AR.
L The quality assurance program is applied for Protective Coatings consistent with the nature and scope of work specified in the technical specifications. The following elements are included:
(a) Preparation of coatings specification and procedures for generic coating materials / systems.
(b) Review and evaluation of coating manufacturers' demonstration test data and quality l
assurance measures for control of manufacture, identification, and performance verification of applied coating systems.
(c) Review and evaluation of supplier quality assurance measures to control storage and handling, surface preparation, application, touch-up, repair, curing and inspection of the coating systems.
(d) Training and qualification ofinspection personnel in coatings inspection requirements.
(e) Supplier surveillance inspection.
The coatings qualification program and the associated quality assurance requirements are necessary only for coatings whose failure or failure mechanism would have a significant effect on safety.
(3) Regulatory Guide 1.54 is 203 imposed for:
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(a) Surfaces to be insulated.
(b) Surfaces " contained" within a cabinet or enclosure (for example, the interior surfaces of ducts).
(c) Field repair on any Q-class coated item less than 30 square inches of surface area such as:
Cut ends or othenvise damaged galvanizing.
L Bolt heads, nuts, and miscellaneous fasteners.
Damage resulting from spot, tack, or stud welding.
Field touch-up and repair oflarger areas shall be in accordance with item (1).
(d) Small " production line" items such as small motors, handwheels, electrical cabinets, control panels, loudspeakers, etc., where special painting requirements would be impracticable.'
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1940-98-20665 Page 3 (e) Stainless steel or galvanized surfaces.
(f) Coating used for the banding of piping.
(g) Strippable coatings used for cleanup.
(4) Quality Assurance documentation may not be similar to records and documents listed in Section 7A through 7.8 of ANSI N101.4, but will be evaluated to ensure that they provide at least the same degree of documentation as required by this standard.
GPUN has implemented controls for the procurement, application, and maintenance of Service Level 1 protective coatings used inside the containment in a manner that is consistent with the licensing basis and regulatory requirements applicable to OCNGS. The requirements of 10 CFR 50 Appendix B are implemented through specification of appropriate technical and quality requirements for the Service Level I coatings maintenance activities. For OCNGS Service Level l' program which includes ongoing coatings are subject to the requirements of ANSI N 101.2 and N 101.4 as modified by the GPU OQA Program. Adequate assurance that the applicable requirements for the procurement, application, inspection, and maintenance are implemented is provided by procedures and programmatic controls, approved under the OCNGS OQA Program. GPUN is evaluating the guidance provided in EPRI TR-109937 " Guideline on Nuclear Safety-Related Coatings" and, as appropriate, improvements to our existing programs and procedures for Service Level I coatings will be implemented upon completion of the evaluation. Completion of this evaluation is scheduled for July 1,1999.
(1) Procurement of Service Level I coatings used for new applications or repair / replacement activities from a vendor (i.e. coating manufacturer) with a quality assurance program that meet the applicable requirements of 10 CFR 50 A opendix B are allowed. The applicable technical and quality requirements which the vendor is required to meet are specified by GPUN in procurement documents. When a contractor is permitted to work under the GPUN approved contractor QA program (meeting the requirements of 10 CFR 50, Appendix B), the procurement requirements (including a Commercial Dedication plan) of the contractor QA program apply.
Acceptance activities are conducted in accordance with procedures which are consistent with ANSI N 45.2 requirements (e.g., receipt inspection, source surveillance, etc.). This specification of required technical and quality requirements combined with appropriate acceptance activities provides adequate assurance that the coatings received meet the requirements of the procurement documents.
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' This response applies to Service Level I coatings used in primary containment that are procured, applied, and maintained by GPUN or its contractor, with the exceptions provided in the GPU Nuclear Operational Quality l
Assurance Plan.
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1940-98-20665 Attaclunent 1 Page 4 (2) The qualification testing of Service Level I coatings, including DBA used for new applications or repair / replacement activities inside containment, meets the applicable requirements contained in the standards and regulatory commitments referenced above. These coatings, including any substitute coatings, have been evaluated to meet the applicable standards and regulatory requirements previously referenced.
(c) The surface preparation, application and surveillance during installation of Service Level I coatings used for new applications or repair / replacement activities inside containment meet the applicable portions of the standards and regulatory commitments referenced above. Documentation of completion of these activities is performed consistent with the applicable requirements. Where the requirements of the standards and regulatory commitments did not address or were not applicable to repair / replacement activities, these activities were performed in a manner consistent with the generally accepted practices for coatings repair / replacement. These practices are described in various ASTM standards and coating practice guidelines by industry organizations issued subsequent to those to which GPUN has a regulatory commitment. GPUN recognizes that the NRC has not formally endorsed many of the more recent ASTM standards or industry guidelines, but nonetheless, they provide useful information which can be appropriately applied to provide assurance that repair / replacement activities on Service Level I coatings are effective in maintaining the acceptability of the coatings.
2 GPUN periodically conducts condition assessments of Service Level I coatings inside containment, as directed by Engineering. Coating condition assessments have been conducted for the OCNGS torus and drywell. These inspections were driven by industry events / engineering concerns about strainer blockage or structural corrosion damage. As localized areas of degraded coatings are identi6ed, those areas are evaluated and scheduled for repair or replacement, as necessary. The periodic condition assessments, and the resulting repm eplacement activities, assure that the amount of Service Level I coatings which may be susceptible to detachment from the substrate during a LOCA event is minimized. As previously noted, GPUN is evaluating the guidance contained in the EPRI coatings guideline in the area of coating condition assessments.
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- Item No. 2 Information ' nonstiating compliance with Item (i) or (ii)
(i) For plants with licensing-basis requirements for tracking the amount of unqualified coatings inside the containment and for assessing the impact of potential coating debris on the operation of safety-related SSCs during a postulated DBA LOCA, the l
following information shall be provided to demonstrate compliance :
l (a) The date and findings of the last assessment of coatings, and the planned date of the next assessment of coatings.
(b) The limit for the amount of unqualified protective coatings allowed in the l
containment and how this limit is determined. Discuss any conservatism in the method used to determine this limit.
(c) If a commercial-grade dedication program is being used at your facility for l
dedicating commercial-grade coatings for Service Level 1 applications inside the containment, discuss how the program adequately qualifies such a coating for Service Level 1 service. Identify which standards or other guidance are currently being used to dedicate containment coatings at your facility; or (ii) For,. ants without the above licensing-basis requirements, information shall be provided to demonstrate compliance with the requirements of 10CFR50.46(b)(5),
"Long Term Cooling" and the functional capability of the safety-related ECCS as set forth in your licensing basis. If a licensee can demonstrate this compliance without quantifying the amount of unqualified coatings, this is acceptable. The following information shall be provided :
(a) If commercial grade coatings are being used at your facility for Service Level 1 applications, and such coatings are not dedicated or controlled under your j
Appendix B Quality Assurance Program, provide the regulatory and safety basis l
for not controlling these coatings in accordance with such a program.
I GPU Nuclear Response to Item No. 2(ii) l In response to NRC Bulletin 96-03, large passive replacement ECCS strainers have recently been l
installed at OCNG9. Cecsequently, the following discussion addresses the anticipated licensing basis pending resolution of NRC Bulletin 96-03.
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1940-98-20665 Att..chment 1 Page 6 The design input to 11 e ECCS strainer calculations for the amount of unqualified coatings, L
qualified coatings in steam /waterjet zone ofimpingement, and degraded qualified coatings in the containment (as identified from periodic visual inspections) is documented in the new ECCS L
strainer hydraulic calculations. Consequently, the amount of these coating materials must be managed, in addition to the quantity of fibrous, particulate, and other miscellaneous debris, to assure that the analyzed functional capability of the ECCS is not compromised.
L The new ECCS pump suction strainers have been designed to perform satisfactorily in the
. presence of 100% of the containment coatings which are installed in the LOCA pipe break steam /waterjet impingement zone. This amount of coating debris is determined in accordance with the methodology documented in the BWR Owners' Group Utility Resolution Guidance (URG) document NEDO-32686, Section 3.2.2.2.2.1.1. The conservative methodology used to establish the amount ofcow ing debris has been accepted by the NRC, as documented in the NRC Safety Evaluation Report (SER), Safety Evaluation by the Office of NRC related to NRC Bulletin 96-03, BWROG Topical Report NEDO - 32686, " Utility Resolution Guidance for ECCS Suction Strainer Blockage" dated August 20,1998.
l An additional amount of coating debris is added to the debris from the zone ofimpingement.
l This amount accounts for potential debris which may result from coatings which are unqualified l
and/or degraded. Results of BWR Owners' Group LOCA testing of coupons representing l
. unqualified coating systems provide compelling evidence that failure of typical unqualified j
coating systems, which pass a visual inspection, is highly unlikely in the first 30 minutes of the LOCA. Only for the first 2 to 15 minutes of the LOCA event, depending upon the pipe break size, the suppression pool turbulence levels are adequate to maintain coating debris in suspension in the pool where it would be available for accumulation on the ECCS strainers. Since the L
coating debris will quickly settle to the bottom of the suppression pool after the turbulence subsides, none of the coating debris (if eventually released sometime after the first 30 minutes of the LOCA) would be available to accumulate on the strainers. In sizing the replacement ECCS strainers for OCNGS, no credit was taken for the delayed release of coating debris; therefore, these designs are conservative with respect to the limit on this coating debris source. GPUN is participating in the BWR Owners' Group Containment Coatings Committee and activities in progress are expected to result in an increase in the quantity of containment coating debris that can be accommodated on the strainers without challenging their functional capability.
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.Therefore, as a result ofinstallation of new and improved strainers and BWROG Containment l
Coating Committee findings as detailed above, OCNGS is in compliance with requirements of:
(1) 10CFR50.46(b)(5), and (2) functional capability of the safety related ECCS as set forth in our licensing basis.
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Page 7 In response to Item (ii)(a), it should be noted that GPUN has not employed commercial grade dedication for Service Level I coatings used inside primary containment. As stated earlier, all Service Level I coatings are controlled by GPUN under Appendix B Quality Assurance Program 1
and procured from a vendor (i.e. coating manufacturer) with a QA program that meets 10CFR50, j
Appendix B requirements. However, when coating is procured and applied under the coating contractor's QA program, commercial grade dedication has been permitted for application within containment structures. The use of such coating is controlled by the GPUN approved contractor's Quality Assuranca program, under 10 CFR 50, Appendix B.
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