ML20195D595

Forwards Response to NRC GL 98-04, Potential for Degradation of ECCS & CSS After LOCA Because of Construction & Protective Coating Deficiencies & Foreign Matl in Containment

ML20195D595
Person / Time
Site:	Three Mile Island
Issue date:	11/11/1998
From:	Langenbach J GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1920-98-20605, GL-98-04, GL-98-4, NUDOCS 9811180103
Download: ML20195D595 (8)

Text

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'l GPL Nuclear, Inc.

A Route 441 South NUCLEAR Post Office Box 480 November 11, 1998 %ddletown, PA 17057-0480 Tal 717-944 7621 1920-98-20605 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555

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Subject:

Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 GPU Nuclear Response to Generic Letter (GL) 98-04, " Potential for Degradation of Emergency Core Cooling System and the Containment Spray System Afler a Loss-Of-Coolant Accident Because of Construction and Protective Coating Deficiencies and Foreign Material in Containment" I

- Generic Letter (GL) 98-04 requested information in order for the NRC to evaluate the licensees' programs for ensuring that Service Level 1 protective coatings inside the Reactor Building (RB) do not detach from their substrate during a design basis Loss of Coolant Accident (LOCA) and interfere with the operation of the Emergency Core Cooling System (ECCS) and the safety-related RB Spray System. The NRC intends to use this information to assess whether current regulatory requirements are being correctly implemented and whether these requirements need to be revised.

Attachment 2 to this letter provides the GPU Nuclear response. If any additional information is required, please contact Mr. Bob Knight of my staff at (717) 948-8554.

Sincerely, 9811100103 981111

~ '& baitJ PDR ADOCK 050 2y9 James W. Langenbach i P

MRK

, , , , _ Vice President and Director, TMI ,, y' g

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cc: NRC Project Manager NRC Region I Administrator NRC Sr. Resident Inspector, TMI File No. 98129

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I Attachment 1

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Page1 of1 METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY  !

PENNSYLVANIA POWER AND LIGHT COMPANY GPU NUCLEAR INCORPORATED i Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License 'No. DPR-50 l Docket No. 50-289 I I

I, James W. Langenbach being duly sworn, state that I am a Vice President of GPU Nuclear, Inc. and that I am duly authorized to execute and file this response on behalf of GPU Nuclear. .To the best of my knowledge and belief, the statements contained in this

' document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information by other GPU Nuclear employees  ;

and/or consultants. Such information has been reviewed in accordance with company l practices and I believe it to be reliable.

P James W. Langenbach Vice President and Director, TMI Signed and sworn before me this ff day of Nou ,1998.

L Notary'Pdblic N

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1920-98-20605 Attachment 2 1 Page1of6 GPU Nuclear Response to Generic Letter 98-04 Item No.1.

A summary description of the plant-specipe program orprograms implemented to ensure that Service Level 1 protective coatings used inside the containment are \

procured, applied, andmaintainedin compliance with applicable regidatory requirements and the plant-specific licensing basisfor thefacility. Include a discussion ofhow the plant-specific program meets the apjdicable criteria of10 CPR Part 50, Appendix B, as wellas information regarding any applicable standards, plant-specific procedures, or other guidance usedfor: (a) controlling the procurement ofcoatings andpaints usedat thefacility, (b) the quahfication testing ofprotective coatings, and (c) surface preparation, application, surveillance, and maintenance l

activitiesforprotective coatings. Maintenance activities involve reworking degraded 1 coatings, removing degraded coatings to sound coatings, correctlypreparing the surfaces, applying new coatings, and verifying the quality of the coatings. 1 GPU Nuclear Response to item No.1:

Three Mile Island Unit 1 (TMI-1) was not originally committed to Regulatoiy Guide 1.54, June 1973, " Quality Assurance Requirements for Protective Coatings Applied to Water Cooled Nuclear Power Plants," because of the stage of plant construction and licensing completed prior to the issuance of this Regulatory Guide. ' The GPU Nuclear commitment to this Regulatory Guide is clarified in the GPU Nuclear Operation Quality Assurance Plan as follows:

"The GPU Nuclear Quality Assurance Program complies with this guide with the following clarification:

1. GPU Nuclear will comply with the Regulatory Position established in this Regulatory Guide in that the QA programmatic / administrative requirements included therein shall 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.

l 2. The quality assurance program for protective coatings includes the planned and I systematic actions necessary to provide adequate confidence that shop or field coating l

work for nuclear facilities will perform satisfactorily in service.

All protective coatings, except those noted in 3 below, applied to surfaces within containment are tested to-demonstrate that they can withstand LOCA conditions. These I

' The Construction Permit (CP) for TMI-l was issued on April 19, 1967; the Operating License (OL) was issued on April 19, 1974; and commercial operation began on September 2,1974.

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1920-98-20605 Attachment 2 ,

Page 2 of 6 -

' test's are performed in accordance with Section 4 of ANSI N101.2 Protective Coatings (Paints) for Light Water Nuclear Reactor Containment Facilities, under LOCA conditions which' equal or exceed those described in the FSAR.

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 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 personnelin coatings inspection requirements.

1 (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 not imposed for:

(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:

e Cut ends or otherwise damaged galvanizing.

. 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, loud speakers, etc. where special painting requirements would be impracticable.

l. (e) Stainless steel or galvanized smfaces.

. (f) Coating used for the banding of piping.

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- (g) Strippable coatings used for cleanup.-

4c Quality Assurance documentation may not be similar to records and documents listed in Section 7.4 through 7.8 of ANSI N101.4 but will be evaluated to assure that they provide at least the same degree of documentation as required by this standard."

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l 1920-98-20605 Attachment 2 Page 3 of 6 S

GI U Nuclear has implemented controls for the procurement, application, and maintenance of Sert ce Level 1 protective coatings used inside the TMI-l Reactor Building in a manner that )

- is consistent with the licensing basis and applicable regulatory requirements in TMI-l Specifications and Corrective Maintenance Procedures as referenced below. The requirements of 10 CFR 50 Appendix B are implemented through specifkstion of appropriate technical and quality requirements for the Service Level I coatings program which includes ongoing maintenance activities.

2 Service Level 1 coatings are subject to the requirements of ANSI N101.2 and N101.4 as I modified by the GPU Nuclear OQA Plan Adequate assurance that the applicable I requirements for the procurement, application, inspection, and maintenance are implemented is provided by procedures and programmatic controls, approved under the TMI-l OQA Plan.

GPU Nuclear is evaluating the guidance provided in EPRI TR-109937 " Guideline on Nuclear Safety-Related Coatings," dated April 1998. As appropriate, improvements to our existing programs and procedures for Service Level I coatings will be implemented following completion of the evaluation which is scheduled for July 1,1999.

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- (a) Procurement of Service Level I coatings used for new applications or repair / replacement activities are procured from a vendor (s) with a quality assurance program that meet the applicable requirements of 10 CFR 50 Appendix B. The applicable technical and quality requirements that the vendor is required to meet are specified by GPU Nuclear in procurement documents. 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 i documents.

I L (b) The qualification testing of Service Level I coatings (including design basis accident j tests) used for new applications or repair / replacement activities inside containment meets 1 the applicable requirements contained in the standards and regulatory commitments referred to above. Deviation from any acceptance limits are addressed in a documented evaluation.

(c) The surface preparation, application, and surveillance during installation of Service l Level I coatings used for new applications or repair / replacement activities inside the i

Reactor Building meet the applicable portions of the standards and regulatory commitments as referenced above. Documentation of the 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 2

This response applies to Service Level I coatings used inside the Reactor Building that are procured, applied, and maintained by GPU Nuclear or its contractors with the exceptions provided for by the GPU Nuclear Quality Assurance Plan.

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1920-98-20605 Attachment 2 Page 4 of 6 brga'niz'ations issued subsequent to those to which GPU Nuclear has a regulatory commitment. GPU Nuclear 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.

l L GPU Nuclear periodically conducts condition assessments of Service Level I coatings inside l the TMI-l Reactor Building. In addition GPU Nuclear conducts Maintenance Rule l inspections of stnictural features and major components in the Reactor Building during which l time any significant degradation is identified. Results from condition assessments and I

inspection findings are used to develop the scope of coating repair work for future outages.

In summary, as localized areas of degraded coatings are identified, those areas are evaluated ,

and scheduled for repair er replacement, as necessary. The periodic coating condition assessments, and the resulting repair / replacement activities, assure that the amount of Service l Level I coatings which may be susceptible to detachment from the substrate during a LOCA event is minimized. As previously noted, GPU Nuclear is evaluating the guidance contained in the EPRI coatings guideline in the area of coating condition assessments.

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References:

1. SP-1101-06-001, " Painting of Ferrous Metal Surfaces for Class I Service Level," Revision 5,

2. SP-110lX-005," Surface Preparation and Recoating of Concrete Surfaces Inside Containment," Revision 3.

3; 1440-Y-2, " Qualifications and Certifications of TMI-l Painting Applicators," Revision 4.

4. 1440-Y-5, " Preparation and Painting of Ferrous Metal Surfaces," Revision 12.

l L 5. 1440-Y-19, " Preparation and Painting of Concrete Surfaces inside the Reactor Building,"

Revision 1.

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.- 21920-98-20605 Attachment 2

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. Itbm'No.'2.

• Information demonstrating compliance with item (i) or (ii)

(. ' (i) Forplants with licensing-basis requirementsfor tracking the amount of l'

unquahfied coatings inside the containment andfor assessing the impact of potential coating debris on the operation ofsafety-related SSCs during a postulated DB LOCA, thefollowing information shall be provided to demonstrate compliance:

(a) The date andfindings of the last assessment ofcoatings, and the planned date of the next assessment of coatings.

(b) The limitfor the amount of unquahfiedprotective coatings allowedin the

\ containment andhow this limit is determined. Discuss any consen'atism in the method used to determine this limit.

(c) If a commercial-grade dedication program is being used atyourfacilityfor dedicating commercial-grade coatingsfor Service Level 1 applications inside the containment, discuss how the program adequately quahfies such a coatingfor Service Level 1 service. Identify which standards or other guidance are currently being used to dedicate containment coatings atyour facility; or, .

(ii) Forplants without the above licensing-basis requirements, information shall be

( provided to demonstrate compliance with the requirements of10CFR50.46b(5),

"Long-term cooling" and thefunctional capability of the safety-related CSS as l_ setforth inyour licensing basis. Ifa licensee can demonstrate this compliance b without quantifying the amount of unquahfied coatings, this is acceptable. 1he following information shall be provided:

l l (a) Ifcommercial-grade coatings are being used atyourfacilityfor Service

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Level I applications, andsuch coatings are not dedicated or controlled under your Appendix B Quality Assurance Program, provide the regidatory and safety l basisfor not controlling these coatings in accordance with such aprogram.

Additionally, explain why thefacility's licensing basis does not require such a program.

' GPU Nuclear Response to Item No. 2 (iik i

The TMl-1 licensing basis does not require tracking of unqualified coating inside the Reactor Building.

The system responsible for maintaining core temperature at an acceptably low value is the Decay Heat Removal (DHR) system. This system consists of two independent strings including 1) their separate power supplies during normal power operation and Loss of Offsite l Power (LOOP) using the emergency diesel generators, 2) separate coolers and 3) separate o cooling loops to the river. The DHR pumps and coolers are installed in separate vaults for I

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. 1920-98-20605 L Attachment 2 l Page 6 of 6 i phys} cal isotation. A separate recirculation pipe for each loop mns from the RB sump directly to each DHR vault to allow long term recirculation of cooling water from the RB sump. Each loop is capable of providing adequate long term cooling by itself. The DHR system draws j water from the Borated Water Storage Tank (BWST) for injection into the Reactor Coolant 3

System (RCS). When the BWST is drawn down to a predetermined level, the DHR pumps l are realigned to draw suction from the RB sump. l If RCS pressure is greater than the DHR pump head, then the discharge of the DHR pumps is realigned to supply suction to the High Pressure Injection (HPI) pumps for injection into the RCS. During recirculation the DHR pumps are throttled to insure adequate Net Positive .

Suction Head (NPSH). The analysis of available NPSH includes the effects of debris clogging sump screens, minimum RB sump water level, head loss due to flow, and instrument error.

.NRC GL 85-02, " Potential for Loss of Post-LOCA Recirculation Capability due to Insulation Debris Blockage," discusses the need for use of the revised guidance in Regulatory Guide 1.82, Revision 1 and Standard Review Plan section 6.2.2. The GL states that those plants with small debris screen areas (less than 100 ft sg), high ECCS recirculation pumping requirements (greater than 8,000 gpm), and small NPSH margins (less than I to 2 ft of water) l would benefit the most from performing assessments in accordance with the revised guidance for a modification or changeout of thermal insulation. Based on this comparison, it is apparent that the TM1-1 design is not particularly sensitive to sump clogging concerns since L the TMI-l plant design uses an RB sump debris screen area greater than 100 sq ft, ECCS l recirculation pumping requirements less than 8,000 gpm, and ECCS pump NPSH margin j i greater than 1 or 2 ft.

( The licensing basis for TMI, as accepted by the NRC's July 11,1973 Safety Evaluation i Report (SER), provides both the regulatory and safety basis for safety system performance.

Coatings are not treated separately in the licensing basis for TMI, because the sump screen blockage assumption does not distinguish among the source terms for the LOCA.-generated debris. As the NRC noted in GL 85-02, a change in regulatory guidance for the basis for j sump screen blockage would constitute a generic backfit. Accordingly, a separate demonstration of the regulatory and safety basis for safety system performance is not needed.

j in response to item (ii), (a), any use of commercial grade coating in Service Level 1 applications inside the TMI-l RB is controlled under the TMI-l Appendix B Quality Assurance Program and thus must meet the provisions of the GPU Nuclear Quality Assurance Plan as discussed response to Item No. I above. GPU Nuclear does not employ commercial grade dedication for Service Level I coatings used inside the RB since as stated earlier, all

. Service Level I coatings are controlled by GPU Nuclear and its contractors under an Appendix B Quality Assurance Program and procured from a vendor with a QA program that meets 10 CFR 50, Appendix B.

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