ML20195F421
| ML20195F421 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/11/1998 |
| From: | Hughey W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-98-04, GL-98-4, GNRO-98-00092, GNRO-98-92, NUDOCS 9811190259 | |
| Download: ML20195F421 (11) | |
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EntJ eritions, lnc.
Port Gibson, MS 39150 Tel 601437-6470 W.K.Hughey Director November 11,1998 $'Y * **
i U.S. Nuclear Regulatory Commission Mail Station PI-37 Washington,DC 20555 Attention: Document Control Desk
Subject:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Response to Generic Letter (GL) 98-04 dated July 14,1998
References:
NRC Generic Letter 98-04: Potential for Degradation of the Emergency Core Cooling System and the Containment Spray System After a Loss-of-Coolant Accident Because of Construction and Protective Coating Deficiencies and Foreign Material in Containment GNRO-98/00092
- Gentlemen:
l On July 14,1998, the Nuclear Regulatory Commission issued the referenced generic i letter regarding issues which have generic implications regarding the impact of potential coating debris on the operation of safety related systems, structures, and components (SSC) during a postulated design basis LOCA. Protective coatings are necessary inside
- containment to control radioactive contamination and to protect surfaces from erosion and corrosion. Detachment of the coatings from the substrate may make the ECCS unable to satisfy the requirement of 10 CFR 50.46(b)(5) to provide long-term cooling and may make the safety-related containment spray system (CSS) unable to satisfy the plant-l specific licensing basis of controlling containment pressure and radioactivity releases l following a LOCA. The Generic Letter requests information under 10 CFR 50.54(f) to l evaluate the addressees' programs for ensuring that Service Level 1 protective coatings inside containment do not detach from their substrate during a design basis LOCA and interfere with the operation of the ECCS and the safety-related CSS. The NRC inten6 to use this information to assess whether current regulatory requirements are being correctly implemented and whether these requirements need to be revised.
The generic letter requires, within 120 days, licensees provide the information outlined below for each of their facilities: J
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PDR ADOCR 05000416
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GNRO-98/00092 l ,' Page 2 of 5
. (1) . A summary description of the plant-specific program or programs implement 2d to I ensure that Service Level 1 protective coatings used inside the containment are procured, applied, and maintained in compliance with applicable regulatory requirements and the plant-specific licensing basis for the facility. Include a discussion of how the plant-specific program meets the applicable criteria of 10 1 CFR Part 50, Appendix B, as well as 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, cpplication, surveillance, and maintenance activities for protective coatings. Maintenance activities involve reworking degracled coatings, removing degraded coatings to sound coatings, correctly preparing die surfaces, applying new coatings, and verifying the quality of the coatings.
(2) Information demonstrating compliance with item (i) or Item (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 design basis LOCA, the following information shall be provided to demonstrate compliance:
(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 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 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 l dedicate containment coatings at your facility; or, l (") For plants without the above licensing-basis requirements, information j shall be provided to demonstrate compliance with the requirements of 10 l CFR 50.46b(5), Long-term cooling" ai.d the functional capability of the safety- related CSS 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:
L,- Page 3 of 5 l-(a)- l lf commercial-grade coatings are being used at your facility for Service Level 1 applications, and such coatings are not dedicated or controlled under your Appendix B Quality Assurance Program, provide the regulatory and safety basis for not controlling these coatings in accordance with such a program. Additionally, .
explain why the facility's licensing basis does not require such a
- program.
By this letter, Entergy Operations is providing the required 120-day response.-
i Yours truly, 95 DES /LFD/WKH attachment:
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- Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a)
Mr. L. J. Smith (Wise Carter)(w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. E. W. Merschoff(w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington,TX 76011
! Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation ,
U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington,DC 20555 l
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GNRO-98/00092 Page 5 of 5 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCKET NO. 50-416 IN THE MATTER OF ENTERGY MISSISSIPPI,INC. and SYSTEM ENERGY RESOURCES,INC. and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS,INC.
AFFIRMATION I, W. K. Hughey, state that I am Director, Nuclear Safety & Regulatory Affairs, GGNS of
- _ Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy l
Resources, Inc., and South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this
- application; that I signed this application as Di
- ector, Nuclear Safety & Regulatory Affairs, GGNS of Entergy Operations, Inc.; and that the statements made and the matters set forth
! therein are true and correct to the best'of my knowledge, information and belief. 1 N5 W. K. Hughey L STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the County and State above named, this //4 day of Adm/,e ,1998.
A n/YNotary Public
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' MY COMMi3510*4 EWES OCT. 27,2000 toow THFid SIEGEL A0TAhY ELneCE -
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Attachment I to GNRO-98/00092 Page 1 of 7 Attachment I
! Generic Letter 98-04 Requested Information (1) A summary description of the plant-specific program or programs implemented to ensure that Service Lnci I protective coatings used inside the containment are procured, applied, and maintained in compliance with applicable regulatory requirements and the 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 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 l of protective coatings, and (c) surface preparation, application, surveillance, and i 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 coatmgs. i
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RESPONSE
Grand Gulf Nuclear Station (GGNS) 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 GGNS. The i controls are for on-site field painting and coating activities that may involve new applications, l touch-up, rework, repair, or maintenance applications. The requirements of 10 CFR 50 Appendix B are implemented through specification of appropriate technical and quality requirements for the Service Level I coatings program that includes maintenance activities. The appropriate technical and quality requirements are provided in Specification GGNS-A-039.1,
" Specification for Painting (Coatings) Inside Containment - Service Level 1".
For GGNS, Service Level l' coatings are subject to the appropriate requirements of ANSI N101.2, ANSI N101.4, ANSI N45.2.2, ANSI N45.2.6 and USNRC Reg. Guide 1.54, as described in GGUFSAR Section 6.1.2. 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 GGNS Quality Assurance program. l (a) Procurement of Service Level I coatings and/or coating services used for new applications or repair / replacement activities are procured from a vendor (s) with a quality assurance program meeting the applicable requirements of 10 CFR 50 Appendix B. The applicable technical and quality requirements, which the l
' Our response applies to Service Level I coatings used in primary containment that are procured, applied and I maintained by Grand Gulf or their contractor. Consistent with exceptions noted in NUREG 0800 SRP Section 6.1.2, this response does not address the relatively small amount of coatings applied by vendors on supplied equipment and miscellaneous structural supports.
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r Attachment I to -
l GNRO-98/00092 Page 2 of 7 l l
vendor is required to meet, are specified by GGNS 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 documents.
(b) The qualification testing of Service Level I coatings 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.
New, substitute or altemate coatings are evaluated prior to use inside containment, i Evaluation of proposed or subject coatings to be used in Service Level 1 applications is conducted in accordance with Calculation MC-Q1111-91151,
" Design Basis Accident (DBA) Test Review for Coatings Used in Containment".
Coatings that meet the qualification testing requirements are put into Specification I l GGNS-A-039.1, " Specification for Painting (Coatings) Inside Containment -
l Service Level 1" and may be used in Service Level 1 applications. Coatings that do not meet the qualification testing requirements are not approved for use in Service Level 1 applications. The evaluations and inherent controls invoked by I l the specification for Service Level 1 applications do not allow or accommodate the application of unqualified coatings inside containment. Therefore, no other controls are utilized or required at GGNS to manage their amount.
Coatings that have not met the required qualification testing and subsequently been determined to be applied in Service Level 1 applications are deemed j unqualified. Indeterminate coatings are those coatings which may or may not be -
l qualified but have been applied as non-safety related inside the containment.
Unqualified and indeterminate coatings have been identified, documented and are being dispositioned in accordance with the GGNS nonconformance reporting process. When coating nonconformances, resulting from maintenance or surveillance activities, are identified the discrepancies are dispositioned in accordance with the Specification GGNS-A-039.1, " Specification for Painting (Coatings) Inside Containment - Service Level 1" accordingly.
(c) The surface preparation, application and surveillance requirements during i installation of Service Level I coatings used for new applications or
- i. repair / replacement activities inside containment are delineated in Specification GGNS-A-039.1, " Specification for Painting (Coatings) Inside Containment -
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I Attachment I to GNRO-98/00092 Page 3 of 7 Service Level 1" and Procedure 07-S-07-200," Nuclear Coating Application and Inspection - Safety Related". These documents meet the applicable portions of the standards and regulatory commitments referenced above.
The surface preparation for Service Level I coatings is performed to the standards specified in SSPC-SP1, SSPC-SPS, SSPC-SP10 and SSPC-SPl1 as apprcpriate for the specific coating application. Painters must be trained and qualified for each Service Level I coating system prior to its application.
GGNS Quality Programs (QP) is responsible for performing required inspections of newly applied Service Level 1 coatings. These inspections include surface preparation, material verification, environmental conditions, mixing, application, film thickness, cure, and final acceptance of the applied coating. Documentation of completion of these activities is performed consistent with the applicable requirements. The Service Level I coatings records are maintained in accordance with Procedure 01-S-05-1," Nuclear Records Procedure".
In addition to other inspections, QP has periodically walked down Containment and Drywell to monitor the physical condition of the construction coatings.
Monitoring was performed as a prudent oversight function because of known NRC coating concerns at other plants and ECCS Suction Strainer issues.
Monitoring walk downs were also performed because of deficient coating conditions observed in the Containment and Drywell during routine inspections.
Procedure 07-S-07-200, " Nuclear Coating Application and Inspection - Safety Related" was revised in April 1998 to require visual inspection of Containment l and Drywell during outage periods, not to exceed 24 months, by qualified Coating Inspectors.
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4 Attachment I to GNRO-98/00092 Page 4 of 7 (2) Information demonstrating compliance with item (i):
l 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 design basis LOCA, the 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.
GGNS RESPONSE:
l Grand Gulf has a licensing-basis requirement for tracking and minimizing the amount of unqualified coatings inside the containment. This requirement stems from concerns dealing with hydrogen generation and implicitly, the potential impact on ECCS operation.
The latest coating condition evaluation at Grand Gulf was performed during RFO9 (April /May 1998). The identified degraded coatings conditions had been previously documented and dispositioned for resolution in accordance with plant procedures. The next scheduled coating condition evaluation at Grand Gulfis planned for RF010 (3dQuarter 1999).
Grand Gulf periodically conducts condition evaluations of Service Level I coatings inside containment. Coating condition evaluations are conducted as part of Procedure 07-S-07-200,
" Nuclear Coating Application and Inspection - Safety Related" which requires visual inspection of Containment and Drywell during outage periods by qualified Coating Inspectors. As localized areas of degraded coatings are identified, those areas are evaluated and scheduled for repair or replacement, as necessary. The periodic condition evaluations, and the resulting repair / replacement activities, assure that the amount of Service Level I coatings that may be susceptible to detachment from the substrate during a LOCA event is minimized.
The scope of monitoring consisted of thorough inspections in Containment and Drywell of construction coating on walls, floors and equipment. Monitoring began in 1993 and was last done during RF09 in 1998. Periodic QP Monitoring Reports were issued to document the deficient coating material conditions and programmatic problems found during walk downs. The reports describe some deficient conditions of Service Level I coatings and presented recommendations to correct the conditions. Examples of the deficient coatings conditions included mechanical damage of coating films, rusted unpainted welds, inorganic zine failures due to surrounding rust, and some minor loss of adhesion on epoxy coatings. GGCR 1997-0203-00 was issued to document the coating failures and describe examples of the rusted items needing coating. No other nonconformance documents have been initiated as a result of these walk downs. The Design Engineering disposition states to repair all items identified and other subsequent items found.
Attachment 1 to GNRO-98/00092 Page 5 of 7 A'dditionally, GGNS is currently developing a Containment Inservice Inspection I,;ogram to meet the requirements of the 1992 Edition and 1992 addenda of ASME Section XI, Subsections IWE and IWL, as modified in 10CFR50.55a. Sections IWE-3510.2 and IWE-3512.1 require that "The inspected area, when painted or coated, shall be examined for evidence of flaking, blistering, peeling, discoloration, and other signs of distress." The purpose of these examinations is to detect conditions indicative of degradation of the liner or other MC components to the extent that the structural / leak-tight integrity of the containment might be impaired. Ilowever, for those coated surfaces on the containment boundary, they will also effectively serve as supplemental examination of the coatings. Preliminary walk downs associated with this program have already been performed. GGCR 1998-0253-00 was initiated to document numerous small areas where minor liner corrosion was noted, however, corrosion is attributed to removal of the coatings by mechanical means during plant modifications. Instances of coating failure were not noted on the boundaries governed by Section XI. As required by 10CFR50.55a, first period examinations of MC components of the containment boundary will be examined prior to September 9,2001. Included in the first period examinations will be a General Visual of the accessible containment boundary surfaces, including those welds, penetrations, and embedded plates which are essentially a part of the containment boundary. The IWE General Visual 2
examination will encompass approximately 60,800 ft of coated surfaces, which represents approximately 86% of coated surfaces on the boundary.
Similar examinations are currently performed on the Containment and Drywell interior and exterior surfaces per Procedure 06-ME-lM10-0-0001," Primary Containment and Drywell Structural Integrity Check - Safety Related". These examinations are performed to meet 10CFR50 Appendix J requirements, and the requirements of T.S. 3.6.1.1.1 and T.S. 3.6.5.1.2 They are also credited in Program Plan GGNS-C-399.0," Maintenance Rule for Structures Inspections - Safety Related" as meeting the requirements of 10CFR50.65 for monitoring the maintenance of structures. Inspection data sheets contained as attachments II, III, and IV of procedure 06-ME-lM10-0-0001, " Primary Containment and Drywell Structural Integrity Check
- Safety Related" require coatings to be checked for cracking or peeling on the interior surface of the Containment and on the interior and exterior surfaces of the Drywell, as a possible indication of structural distress. While examination of the interior surface of the Containment will be performed under the ASME Containment ISI program previously described, examination of the Drywell surfaces will continue to be performed as described in procedure 06-ME-lM10-0-0001,
" Primary Containment and Drywell Structural Integrity Check - Safety Related". Thus, for those surfaces described these two programs serve as supplemental examinations of the coatings.
On a programmatic level, a one-time assessment was performed for the unqualified / indeterminate coatings program. This assessment, identified inadequate controls within earlier revisions of the Specification GONS-A-039.1," Specification for Painting (Coatings) Inside Containment - Service Level 1". Subsequent to this assessment the Specification GGNS-A-039.1, " Specification for Painting (Coatings) Inside Containment -
Service Level 1" has been revised to ensure stricter controls. There are no future assessments of this nature scheduled for Service Level 1 applications. The potential concerns identified were
N Attachment 1 to GNRO-98/00092 Page 6 of 7 documen'ted in GGCR 1997-0368-00. The disposition of this nonconformance required a detailed assessment to be performed. The detailed assessment for unqualified / indeterminate coatings at GGNS was conducted between January 1997 and August 1998.
This detailed assessment included review and research of plant design drawings, specifications, plant coating application / installation records and documentation, available coating qualification reports, coating product test data, and GGNS environmental parameters as applicable to coatings within the containment. The type and quantities of unqualified / indeterminate coatings identified were established using recorded and/or documented surface areas and/or applied average coating l- thickness. The detailed assessment did not encompass any aspects in the context of maintenance activities or assessment ofin-service condition of existing coatings.
i From the detailed assessment, the amount of unqualified inorganic zine coatings found inside the containment was approximately 4290 ft' with a total volume of approximately 1.2 ft' and a total weight of approximately 535 lbs. This condition was documented in GGCR 1997-0368-01.
Indeterminate coatings are those coatings which mt.y or may not be qualified but have been applied as non-safety related inside the containment. A minimal amount of these indeterminate l coatings (organic) has been determined to exist inside comainment. The amount of
( : indeterminate organic coatings has been established as approximately 15 ft' The acceptance of L these coatings is currently based on being bounded by the estimated quantity of unqualified f
organic coatings currently identified in the GGUFSAR. The total volume (ft') and weight (lbs.)
of the indeterminate organic coating has nm been estimated due to the uncertainties involving Non-Safety Related applications.
l l It has been concluded that the above quantities of unqualified inorganic zinc and indeterminate l organic coatings are considered to fail or detach from the surface during a LOCA and therefore, j could contribute to the postulated debris quantity transported to the suppression pool and subsequently pose a potential source of debris for the ECCS suction strainers.
(b) The limit for the amount of unqualified protective coatings allowed in the
, containment and how this limit is determined. Discuss any conservatism in l the method used to determine this limit.
t GGNS RESPONSE:
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The current limit for unqualified organic coatings is 6224 ft2 with a total volume of 2 ft' and a total weight of 160 lbs. as documented in the GGUFSAR Section 6.1.2.1. This limit was established during initial plant licensing. Consistent with applicable regulatory requirements, the
- type and quantity of debris were not explicitly considered when the original calculations for the i ECCS strainers head loss were performed.
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I' Attachment I to GNRO-98/00092
- Page 7 of 7 in' resporise to NRC Bulletin 96-03, a large passive replacement ECCS strainer has recently been l installed at GONS. The new ECCS pump suction strainer has been designed to perform satisfactorily in the presence of 100% of the containment coatings which are installed in the LOCA pipe break steam /waterjet zone ofinnuence. 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 NRC, as documented in the Safety Evaluation Report (SER) on the URG, has accepted the methodology l used for coating debris quantiGcation. I 4
The design input to the ECCS strainer calculations for the amount of unqualified / indeterminate coatings, qualified coatings in steam /waterjet zone ofinfluence, and degraded qualiGed coatings in the containment (as identified from periodic visual inspections) is documented in the new ECCS strainer hydraulic calculations. In sizing the replacement ECCS strainer for GGNS no credit was taken for the delayed release of coating debris. Scale testing performed by GONS '
indicates a relative insensitivity, with respect to head loss, to particulate debris; therefore, this strainer design should be conservative with respect to the limit on coating debris.
GGNS is currently evaluating the impact of unqualified and indeterminate coatings that have been used in Service Level 1 applications and exist inside containment. These coatings were l applied inside containment before 1989 during the construction and early operational phases of l GGNS. The nonconformances are documented in GGCR 1997-0368-00 and GGCR 1997-0368-01.
(c) If a commercial-grade dedication program is being used at your facility for dedicating commercial-grade coatings for Service Level 1 applications inside the containment, discuss how the program adequately qualifies such a coating for Service Level I service. Identify which standards or other guidance are currently being used to dedicate containment coatings at your facility:
GGNS RESPONSE:
Entergy Operations does not currently employ commercial grade dedication for Service Level I coatings used inside containment at Grand Gulf. There have been no Commercial Grade Dedication packages written (performed) at GGNS for these type coatings. However,if there was a specific r.eed, the Commercial Grade Dedication program as described in DEAM PE-P-002-00," Commercial Grade Item Evaluation" would be used. This procedure utilizes the guidance contained in EPRI Report NP-5652," Guideline for the Utilization of Commercial Grade Items in Nuclear Safety Related Applications (NCIG-07), as conditionally endorsed by NRC Generic Letters 89-02 and 91-05.