ML20207L954
| ML20207L954 | |
| Person / Time | |
|---|---|
| Issue date: | 02/21/1999 |
| From: | Jerome Murphy NRC - CENTER REVIEW GROUP |
| To: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 9903180329 | |
| Download: ML20207L954 (200) | |
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_ _ - _ _ _
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j NUCLEAR REGULATORY COMMISSION
- WASHINGTON, D.C. 30806-0001
% , ,o February 21, 1999 MEMORANDUM TO: William D. Travers Executive Director for Operations FROM: Joseph A. Murphy, Chairman Committee To Review Generic Require ents
SUBJECT:
MINUTES OF THE CRGR MEETING NUMBER 335 The Committee To Review Generic Requirements (CRGR) met on Tuesday, January 12,1999, from 9:00 a.m. to 12:30 p.m. to hold the Committee's 335* meeting. Attachment 1 contains the list of attendees. J. Murphy presided over the meeting as Acting Chairman.
W. Kane, S. Shankman, W. Hodges, and L. Kokajko - all of NMSS - briefed the Committee on their planned approach to licensing reviews and cask certification reviews which will lead to 10 CFR Part 72 amendments in the near future. Attachment 2A contains the staff's presentation material, and Attachment 2-B is the Spent Fuel Project Office Communications Plan. The latter includes office interfacing information as well as a tentative schedule for various activities. The staff's briefing focused or, issue C.1-7, " Dual Purpose Spent Fuel Cask Reviews," from the Chairman's Tasking Memorandum. The staff plans to issue a storage-related certificate of compliance through Part 72 rulemaking, and a Part 71 transportation certificate of compliance for dual-purpose spent fuel cask designs. Additionally, the staff plans to make the following process modifications to Part 72: (1) revise Section 72.48 (similar to 10 CFR 50.59) to incorporate NRR initiatives; (2) streamline the rulemaking process to allow for direct and final rulemaking for the certified cask design; (3) clarify general versus site-specific license requirements; (4) expand the scope of Part 72 to cover enforcement; (5) revise geologic and seismologic criteria for dry cask storage; and (6) eliminate the 30-day wait between pre-operational testing and fuel load. The staff proposed to brief the CRGR at the final stage of rulemt.bg for the dual-purpose cask designs. The Committee decided that it will review the rulemaking related to the Holtec spent fuel storage cask design to determine the extent of its future involvement.
J. Craig (RES), A. Serkiz (RES), and J. Davis (NRR) presented for CRGR review and endorsement the draft Regulatory Guide PG-1076, " Service L:evel I,11, and 111 Protective )) { p m
Coatings Applied to Nuclear Power P!er.is." Attachment 3A and 3B contain the staff's presentation material. Via thb guide, which is a proposed Revision 1 to Regulatory Guide 1.54, the staff endorses various ASTM standards. This effort is consistent with Public Law 104-113, OMB Circula- A-119, and NRC's Strategic Plan for FY 1997-2002. This draft guide updates the NRC p ance on the selection, qualification, acceptance, application and maintenance of Class I, il acid lli protective coatings, and makes such guidance consistent with industry practice.
The Committee expressed a concern on the backfit aspects of this proposed action.
Consequently, the staff made this proposed guide a forward-fit only and revised the regulatory analysis accordingly. On February 17,1998, a formal CRGR endorsement (Attachment 3-C) for issuance of this draft gu'ide for public comments was relayed to the staff.
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w William D. Travers 1 M. Mayfield (RES), R. Wessman (NRR), and D. Jackson (RES) presented for CRGR review and i endorsement the draft final Regulatory Guide (RG) 1.84, " Design and Fabrication Code Case Acceptability," RG 1.85, " Materials Code Case Acceptability," and RG 1.147, " Inservice inspection Code Case Acceptability." Attachment 4A contains the staff's presentation material.
These guides were r;ot submitied for CRGR review and endorsement prior to issuance for public comments. The Committee offered various comments and recommendations. Most significantly, the Committee noted that various proposed requirements for licensees to submit information to NRC seemed to be inconsistent with other ongoing staff efforts, such as, those related to reducing the bulk of information to be included in the updated FSAR. The Committee also commented on the purpose of the information being sought and the standards to be used in evaluating the licensee-fumished 'information. The Committee has been inft rmed that these documents are currently being revised by the staff. Following NRR and OGC re-concurrence, when the reviced guides are re-submitted, the Committee has instructed the CRGR staff to evaluate these documents in light of the Committee's comments and recQendations, and also prov.ide its assessment and recommended action to the CRGR membsrs. If the revised draft final guides change substantially, they may be re-noticed for public comments.
In accordance with the EDO's July 18,1983 directive conceming " Feedback and Closure of l CRGR Review", a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes. The response is to be I forwarded to the CRGR Chairman and if there is disagreement with the CRGR j recommendations, to the EDO for decision making. l Quest lons concerning these meeting minutes should be referred to Raji Tripathi (415-7584).
Attachments: As stated cc: Commission (5) SECY M. Knapp, DEDE F. Miraglia, DEDO J. Lieberman, OE M. Springer, ADM H. Bell, OlG K. Cyr, OGC J. Larkins, ACRS H. Miller, R-1 L. Reyes, R-il J. Dyer, R-!!!
E. Merschoff, R-IV C. Paperiello, NMSS A. Thadani, RES S. Collins, NRR W. Kane, NMSS J. Craig, RES
= William D. Trev:rs M. Mayfi:Id (RES), R. W:ssman (NRR), and D. Jackson (RES) present d for CRGR review and endorsement the draft final Regulatory Guide (RG) 1.84, " Design and Fabrication Code Case Acceptability," RG 1.85, " Materials Code Case Acceptability," and RG 1.147, " Inservice Inspection Code Case Acceptability." Attachment 4A contains the staff's presentation material.
These guides were not submitted for CRGR review and endorsement prior to issuance for public comments. The Committee offered various comments and recommendations. Most significantly, the Comrnittee noted that various proposed requirements for licensees to submit information to NRC seemed to be inconsistent with other ongoing staff efforts, such as, those related to reducing the bulk of information to be included in the updated FSAR. The Committee also commented on the purpose of the information being sought and the standards to be used in evaluating the licensee-fumished information. The Committee has been informed that these documents are currently being revised by the staff. Following NRR and OGC re-concurrence, when the revised guides are re-submitted, the Committee has instructed the CRGR staff to evaluate these documents in light of the Committee's comments and recommendations, and also provide its assessment and recommended action to the CRGR members. If the revised draft final guides change substantially, they may be re-noticed for public comments.
In accordance with the EDO's July 18,1983 directive concerning " Feedback and Closure of CRGR Review", a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes. The response is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the EDO for decision making.
Questions conceming these meeting minutes should be referred to Raji Tripathi (415-7584).
Attachments: As stated cc: Commission (5) SECY M. Knapp, DEDE F. Miraglia, DEDO J. Lieberman, OE M. Springer, ADM H. Bell, OlG K. Cyr, OGC J. Larkins, ACRS H. Miller, R-l l L. Reyes, R-il J. Dyer, R-ill l E. Merschoff, R-IV C. Paperiello, NMSS I A. Thadani, RES S. Collins, NRR W. Kane, NMSS J. Craig, RES M. Mayfield, RES Distribution:
File Center (w/attch) PDR (NRC/CRGR) (w/o attch. 2-B and 2-C) SShankman, CRGR SF CRGR CF JMurphy DDambly JJohnson, RIV BSheron MVirgilio MFederline JMitchell LKokajko JJohnson, OCM GMillman WHodges FCherny NDudley ASerkiz MMarshall JDavis RCorreia LCampbell Alee CCarpenter YHuang TSullivan EHackett DJackson KWichman RWessman Clauron NOsgood DISK / DOCUMENT NAME: S:\CRGR\DMTS-335.WPD To receive a copv. indicate- *C" a Copy w/o attachment / enclosure: *A's Copy with attachment / enclosure "N" s No copv NO MARK s NO COPYI OFC CRGR C CRGR C C CRGR C NAME G west [ RTnpathi h JMurphy oArc 2. / /9Se 2 //f a 24)m OFFICIAL RECORD COPY
, Attendance List
' CRGR No. 335 Meeting (January 12,1999)
CRGR MEMBERS NRC STAFF J. Murphy (Chairman) S. Shankman, NMSS D. Dambly L. Kokajko, NMSS B. Sheron W. Hodges, NMSS J. Johnson W. Kane, NMSS E. W. Brach for M. Virgilio F. Chemy, RES J. Craig, RES A. Serkiz, RES M. Marshall, RES J. Davis, NRR R. Correia, NRR L. Campbell, NRR A. Lee, NRR C. Carpenter, NRR Y. Huang, NRR T. Sullivan, NRR E. Hackett, RES D. Jackson, RES M. Mayfield, RES K. Wichman, NRR R. Wessman, NRR C. Lauron, NRR CRGR STAFF ACRS STAFF R. Tripathi N. Dudley G. West (on detail)
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., Spent Fuel Project Office Communications Plan VI. TOPIC AREA: Other Aaency Proarams and Areas of Focus C.1-7 SPECIFIC ISSUE: Dual-Purpose Cask Reviews internal Stakeholder Goal Activity Date NMSS/SFPO Ownership This is considered complete with the development of the October 1998 Management & organizational structure (06/98), various internal guidance Staff documents [SRPs (various dates), staff interactions with applicants (06/98), SER guidance (09/98), interim staff guidance (10/98)], and the team approach (07/98) to dual-purpose spent fuel cask reviews. Other internal process procedures have been implemented as well.
SFPO has initiated a lessons learned process and an issues identification program. (Note - supported two Communications Plan strategy meetings.)
Other NMSS Awareness Complete by Communications Plan presentation on October 5, Management October 5,1998. Maintain contact with associated staff 1998 (IMNS, FCSS, members in IMNS (rulemaking, P. Holahan, et al.) and DWM, PMDA) PMDA (budget and contracts, J. Linehan, et al.) on an as-needed basis for support. Contributed article to NMSS quarterly newsletter (published 03/98), "The Licensing Process for Dry Cask Storage Systems;" and contributed article on SFPO interim staff guidance (next newsletter).
Information provided to Decommissioning Board (11/19/98) and IMNS Licensing Streamlining working group (11/23/98). Will continue to inform staff at NMSS regional conference call (12/11/98) and at other times as deemed appropriate.
NRR/ADPR Awareness Complete by Communications Plan presentation on October 5, Management October 5,1998. SFPO staff has direct contact points - 1998 (DIC4, DRPW C. F. Lyon, DRPW, and P. Ray, DRPM - for
& DRPM) communications and assistance purposes.
OEDO Buy-In Complete by Communications Plan presentation on October 5, October 5,1998. Maintain as-needed contact with OEDO 1998 staff.
OGC Buy-in Complete by Communications Plan presentation on October 5, October 5,1998. Maintain as-needed contact with E. N. 1998 Jenson.
OCA Awareness Complete by Communications Plan presentation on October 5, October 5,1998. 1998 OCFO Awareness Complete by Communications Plan presentation on October 5, October 5,1998. 1998
.' VI. TOPIC AREA: Other Agency Progrcms cnd Arors of Focus C.1-7 SPECIFIC ISSUE: Dual-Purpose Cask Reviews Internal
- Stakeholder Goal Activity Date OCM Ownership Pending until completion of Holtec HISTAR 100 Pending rulemaking and subsequent cask rulemakings. OCM has approved streamline rulemaking process to allow for direct / final rulemaking for certified casks in an SRM dated August 26,1998, regarding SECY-98-188.
Other SRMs related to SFPO activities have been issued; i.e., revise 10 CFR 72.48 (similar to Section 50.59) in SRM dated September 25,1998 (SECY-98-171); clarify general vs. site-specific license requirements in SRM dated July 17,1998 (SECY-98-148); expand scope of Part 72 for enforcement program in SRM dated June 30, 1998 (SECY-98-113); revise geologic and seismologic criteria for dry cask storage in SRM dated June 24,1998 (SECY-98-126); and eliminate 30-day wait between pre-operational testing and fuel load in SRM dated April 27, 1998 (SECY-98-056).
SFPO is considering an information briefing of the OCM Commissioner's Assistants during the first half 1999, l OPA Awareness Complete by Communications Plan presentation on October 5, October 5,1998. Participated in 1998 NRC Media .1998 Briefing on ory cask storage issues and maintain designated storage and transportation media briefing papers for OPA. Assist in press releases as-needed.
Planning to participate in 1999 NRC Media Briefing.
SFPO response to Chairman's Tasking Memorandum on NRC web site; submitted SFPO information on licensing approach for web site to OEDO.
OSP Awareness Complete by Communications Plan presentation on October 5 October 5,1998. 1998 Regions I-IV Awareness Complete by Communications Plan presentation on October 5, Management . October 5,1998. SFPO has designated contact points in 1998 (DRS, DRP & regional offices. SFPO staff will supported the upcoming DNMS) Region lil resident inspector meeting (12/9/98), and will continue with other regional contacts and briefing as appropriate (such as the upcoming 12/11/98 IMNS .
regional call).~
RES Awareness - Complete by Communications Plan presentation on October 5, Management October 5,1998. 1998 (DRA & DET) 2
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VI. TOPIC AREA: Other A9ency Programs cnd Areis of Focus C.1-7 SPECIFIC ISSUE: Dual-Purpose Cask Reviews Internal Stakeholder Goal Activity Date ACNW Awareness Pending until December 15,1998, briefing on SFPO December 15, activities. 1998 Pending CRGR Buy-In Pending until completion of Holtec HISTAR 100 January 12, rulemaking and subsequent cask rulemakings. SFPO will 1999 brief on SFPO activities CRGR on 01/12/98 to raise Pending awareness; subsequent briefings on specific rulemakings will indicate buy-in.
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. VI. TOPIC AREA: Other Agency Programs and Art,cs of Focus C.1-7 SPECIFIC ISSUE: Dual-Purpose Cask Reviews External Stakeholder Goal Activity Date Industry Ownership Pending. Although significant efforts have been made to 1999 Applicants get the message out," at conferences (07/98,09/98),
(including workshops with .NEl, and numerous meetings with v;ndors, applicants and utilities, it remains unclear whether or not f bricators, the message has been fully received. The goal of SFPO licensees & CoC is to receive an initial application for a dual-purpose cask holders) design of high quality that precludes requests for additional information SFPO staff recently supported the ANS conference (11/17/98) and the NEl Decommissioning meeting (12/7/98). SFPO will continue to monitor this activity and support other venues to communicate the SFPO message; e.g., upcoming NRR RIC (3/99) and planned NEl workshop (3/99). [See next two extemal stakeholder items below.]
Industry Owner's Buy-in This is considered complete. This group has the October 1998 Group motivation to grasp the SFPO initiatives as soon as practical since they represent the reactor licensees interest in utilizing the dry storage option. Also, this message has been a theme at the NRC RIC (most recently on 4/15/98), and will be in 1999. [ Considered an important subgroup ofIndustry Applicants.]
NEl Buy-in This is considered complete with the interaction with NEl August 1998 during workshops (04/16/98, 07/01-02/98, 08/26/98) and several NEl-sponsored conferences that SFPO management supports. Informally met with NEl on 12/03/98 (to discuss next workshop in 03/99).
[ Considered an important subgroup of Industry Applicants.]
Congress Awareness This is considered complete as indicated by the budget November testimony, subsequent congressional questions and staff 1998 responses, and legislative language. On an as-needed basis, NRC will apprize ~the Congress of SFPO activities.
Also, held two briefings with J. Cannon of Senator Domenici*s staff, and provided information to K.
Hunsicker of Senator Murkowski's staff in 11/98.
State and Local Awareness This is considered complete. SFPO has supported the September Govemments recent National Association of State Legislators meeting 1998 (09/98), and will continue to do so. On an as-needed basis, SFPO will apprize state and local governments of SFPO activities.
4
. ' . VI. TOPIC AREA: Other Agency Programs and Arers of Focus C.1-7 SPECIFIC ISSUE: Dual-Purpose Cask Reviews i
External Stakeholder Goal Activity Date Public (General Awareness Pending. While information has been disseminated to Continuous Interest Groups) people and groups, it is unclear whether or not public acceptance and confidence in dual-purpose dry cask storage technology has been achieved. SFPO will continue to appropriately respond as needs dictate.
SFPO response to Chairman's Tasking Memorandum on NRC web site; submitted SFPO information on licensing approach for web site to OEDO.
Media Awareness This is considered complete. Participated in 1998 NRC October 1998 Media Briefing on dry cask storage issues and maintain designated storage and transportation media briefing papers for OPA. Assist in press releases as-needed.
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Planning to participate in 1999 NRC Media Briefing.
SFPO response to Chairman's Tasking Memorandum on NRC web site; submitted SFPO information on licensing approach for web site to OEDO. Staff contacts with the trade press have been good.
Intemational Awareness This is considered complete. Staff has increased efforts November in the international community. SFPO supported IAEA 1998 symposium on storage issues in Vienna, Austria (11/98),
and will support future activities as appropriate.
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Designation: D 5144 - 97 i
Standard Guide for Use of Protective Coating Standards in Nuclear Power Plants' Thas standard is issued under u.e fixed designauon D 5144: the number immediately fodomns the designanon indicates the year <
onginal adoption or. to the case of revision. the Scar oflast rension. A number in parentheses indicates the year oflast reapproval. ,
supenenpt epulon (0 indicates an ed3 tonal change since the last rension or reapprosal.
INTRODUCTION Protective coatings (paints) have been used extensively in the nuclear industry to protect the surfaces of facilitics and equipment from corrosion and contamination by radioactive nuclides in accordance with ALARA. In the absence of a standard method of selecting, testing, and evaluating i coatings, many sites evaluated paints by empirical tests to determine which were useful in their particular operation. Understandably, the methods of testing were not uniforrn throughout the J 1
industry, it has been very difficult, consequently, to compare the results obtained at one site with '
those obtained at another, Standard tests whereby inoustrial (nuclear) users of paints systematically prepare specimens and subject them to selected evaluations, thus permitting uniform comparisons, '
are advantageous, internationally as well as domestically.
The designer oflight water-moderated nuclear reactor systems must consider the possibility of a j Design Basis Accident (DBA) and the subsequent events which might lead to the release or i expulsion of a fraction of the fission-product inventory of the core to the reactor containment l
facility. Engineered safety features, principally a reactor containment facility, are provided to !
i prevent the release of fission products to the biological environment during and after this I
i irnprobable event. The design, fabrication, quality assurance, and testing of these engineered safety features ensure reliable operation and safety under all anticipated conditions.
Large areas of the reactor-containment faciiity are painted with a protective coating. If severe delamination, peeling, or flaking causes significant portions of the coating to be discharged into the common water reservoir, the performance of the safety systems could be seriously compromised by the plugging of strainers, flow lines, pumps, spray nozzles, and core coolant channels. ,
/~ The safety requirement for protective coatings is to ensure that failure of the coatings under DBA conditions does not adversely affect the performance of post-accident fluid systems.
Therefore, coatings must be qualified to the environmental exposures anticipated during normal plant operation, and during DBA conditions.
This guide is the result of a comprehensive examination of the experience and data that have been developed on protective coatings in the nuclear industry over approximately 40 years.
Standards pertsining to nuclear coatings have historically been covered by ANSI N5.12, N101.2, and N101.4. Responsibility for updating, rewriting, and issuing appropriate ANSI replacement 3 standards has been transferred to ASTM, specifically ASTM Committee D-33, oo Protective !
Coating and Lining Work for Power Generation Facilities.
Quality assurance in the nuclear industry is a mandatory requirement for all aspects of safety related nuclear coatings work. The objective of this guide is to provide a common basis on which to define and speci6 the performance requirements for the coatings which will be used in Service j Level I and II areas of a nuclear facility. Regulation 10CFR50.65 defines the requirements for an effective program for maintenance of nuclear power plants. This guide may be used both for ,
coatings applied to new nuclear power plants and to facilitate irnplernentation of the coating !
as A. pects of 10CFR50.65. s 1, Scope evaluation tests. This guide also provides guidance for 1.1 This guide provides a common basis on which protec- application and maintenance of protective coatings. Under tive coatings for the surfaces of nuclear power generating the environmental operating and accident conditions of facilities may be qualified and selected by reproducible nuclear power generation facihties, encornpassing pressur-tzed water reactors (PWR's) and boihng water reactors (BWR's), coating performance may be affected by exposure
- This guide is under the junsdicuon of ASTM Commsttee D43 on Protectve to any one, ali, or a combination of the foilowing conditions:
Coating and uning Work for Power Generanon Facihtaes and is the direct l responsbility of Subcommmee D33.02 on service and Matenal Parameters. ionizing radiation; contamination by radioactive nuclides and subsequent decontamination processes; chemical and cuneet edition appwved Mareb so.1997. Published september 1997. Onsi-I nally pubhshed as o 5:44 91. Last previous ediuon o si44. 9i. water sprays; high-temperature high-pressure steam; and 461
Dnignation: D 3843 - 93 d
i:
Star.dard Practice for fi ,
I n-Quality Assurance for Protective Coatings Applied to Nuclear r' Facilities' t i g.
Tha standard as issued under the Gaed designauon D 3843. the number immediately rollomos the designauon mdicates the year of onginal adopuon or to the case of revmon, r.: year oflast revmon. A nutaber in parentheses andacates the year of tast reapproval A supencnpt epsdon 6) mdscates an editonal change ance the laa revtsion or reapproval r1 1 2.4 Code ofFederal Regulations.'
- 1. Scope f 10 CFR 50, Appendix B: Title 10, Chapter 1. Energy, Part I l.1 This practice prov es a common basis for, and 50, Domestic Licensing of Prod = tion and Utilization ,
rpecifically comprises qualiW assurance requirements appli- Facihties, Appendix B, Quality Assurance Criteria for cable to, safety-related protective coating work in Coating Nuclear Power Plants and Fuel Reprocessmg Plants Service Level I areas of nuclear facilities. 10 CFR 21 Reponing of Defects and Noncompliances I 1.2 Applicable ponions of this practice may be used as the
- 3. Terminology j basis for limited quality assurance for protective coating work in Coating Service Level 11 areas of nuclear facilities. 3.1 Description of Terms Spec (/lc to This Standard 1.3 This standard does not purport to address-all of the , I s 3.1.1 certification-the written documentation of the safety problems, if any, associated with its use. It is the qualit; cation of personnel or material. I responsibihty of the user of this standard to establish appr& 3.1.2 coating applicator-an organization or individual .
priate safety and health practices and determine the applica- responsible for app)ying a protective or decorative coating bihty of regulatory limitations prior to use. system.
3.1.1 coating (paint)-a liquid, liquifia' ole, or mastic com-position that is convened to a solid protective or functional
- 2. Referenced Documents adherent film after application as a thin layer.
3.1.4 coating manufacturer-an organization responsible 2.1 ASTM Standards: for manufactunng coating materials.
D 3842 Guide for Selection of Test Methods for Coatings 3 l.5 coating system-a polymeric protective film con-2 for Use in Light Water Nuclear Power Plants sistmg of one or mon coats, applied in a predetermined D4227 Practice for Qualification of Coating Applicators rder by presenbed methods.
for Application of Coatings to Concrete Surfaces of 3.1.6 coating work-an all-inclusive term to define a'J Safety-Related Areas in Nuclear Facilities: operations required to accomplish a complete coating job.
D4228 Practice for Qualification of Coating Applicators The term shall be construed to include neaterials, equipment, for Application of Coatings to Steel Surfaces of Safety, labor, pmparation of surfaces, control of ambient conditions.
Related Areas in Nuclear Facilities: application and repair of coating systems, and inspection. ,
D4537 Guide for Establishing Procedures to Qualify and 3.1.7 Code of Federal Regulations (CFR)-the rules and Cenify inspection Penonnel for Coating %,ork m. Nu- regulations of the United States Federal Government. The clear Facilities code is subdivided into titles, with Title 10 (10 CFR) 2.2 /NSIStandards- applying 9 energy.
N45.2 Quality Assurance Program Requirements for Nu- 3.1.8 deviation-a departure of a characteristic from et clear Power Plants' tablished procedures or from specified requirernents.
NQA 1 (86) Quality Assurance Program Requirements for 3,g,9 documentation-any written or pictorial informa-Nuclear Facilities 2 tion describing, defining, specifying, reponing, or cenifying
2.3 ASMEStandard
activities, requirements, procedures, or results.
NQA-1 (89) Quality Assurance Program Requirements for 3.1.10 inspection-a phase of quality control which by Nuclear Facilities
- means of examination, cbservation, or measurement deter-mines the conformance of materials, supplies, components, pans, appunenances, systems, processes, or structures to 8 This pracuee is under the junsdiction of ASTM Committee D33 on p crmined WG re@immem Protecuve Comung and L.imns work for Power Generauon Facdines and is the 3.1.1I inspection agency-a person or persons authorized direct tesponubdity of D33 03 on Quahty Systems.
Cunem edmon approved Feb. 15. 1993 Pubhshed Apnl 1993. Onginally by the owner or owner's designee to verify conformance of '
pubhshed as D 3843 - 80 Last previous edit.ca D 3843 - 89. Il$e coating work.
3 Annual book of AsTAI standards. Vol 06 C2.
8 Avadable from Amencan Nauonal Standards insutute 13th Door, il W.
42nd St., New York, NY 10036.
' kallable frosn .he Supenntendent of Documents. U.S Government Pnnuns
- Avadable from the Amencen sociery of Mecharucal Engmeers. 345 E. 47th
$t., NY 10017. Jra. Washmston. DC 20402.
e 4
m Designation: D 3911 - 95 Standard Test Method for Evaluating Coatings Used in Light-Water Nuclear Power Plants at Simulated Design Basis Accident (DBA) Conditions'
, onginal adopuon or,in the case et revison. the ) car oflast nvision. A supersenpt epstion (e) indicates an editonal change since the last revision or reapprosal. .
INTRODUCTION '
During a design basis accident (DBA) in nuclear power plants, conditions in the reactor containment will be characterized by elevated temperature and pressure, as well as the pres a radiation environment. Water sprays, with or without chemical additives, may be used in the primary containment to suppress the consequences of the incident, to scavenge radioactive products, and to return the containment to near-ambient conditions.
- 1. Scope
' , than the steam turbme pressure.
l.l This test method establishes procedures for evaluating 3.1.3 chemical spray-a solution of chemicals, such as protective coating systems test specimens under simulated DBA conditions. Included are a description of conditions those contained in Table 1, which could be used during a loss of coolant accident (LOCA) to suppress the incident, to and apparatus for temperature-pressure testing, conditions for radiation testing, vnd procedures for preparing, exam. scavenge fission products, and to return the facility to near-ambient conditions.
ining, and evaluating the samples.
3.1.4 coating (paint) system-a polymeric protective film 1.2 The values stated in inch-pound units are to be consisting of one or more coats applied in a predetermined regarded as the standard. The s alue; given in parentheses are for information only. order by prescribed methods to a defined substrate.
j 3.1.5 cracking-a break or a split in the coating (paint) 1.3 This standard does not purport to address all of the sqfety concerns, if any, associated with its use. It is the system extending through the film or to the substrate. .
responsibility ofthe user of this standard to establish appro- 3.l.6 curing-the transformation of a coating or other material into a solid phase or film. ,
priate safety and health practices and determine the applica.
bility of regulatory limitations prior to use. 3.l.7 DBA-a generic term for any one of a family of accident conditions which can result from postulated events.
- 2. Referenced Documents These conditions are generally associated with the rupture of high energy piping. The more commonly recogmzed acci-2.1 ASTM Standards dent conditions used to evaluate coatmg systems for primary D714 Test Method for Evaluating Degree of Blistering of c ntainment are the LOCA or main steam pipe break.
Paints:
3.1.8 deionized water-water prepared by an ion ex-D4082 Test Method for Effects of Radiation on Coatings change process meeting the requirements of Specification Used in Light-Water Nuclear Power Plants' D !193, Types Il and Ill.
D $139 Specification for Sample Preparation for Qualifica- 3.1.9 delamination-separation of one coat or layer from tion Testing 3
of Coatings to be Used in Nuclear Power another coat or layer, or from the substrate.
Plants 3.1.10 engineered safety system-a system designed to
- 3. Terminology mitigate the effects of a design basis accident.
3.1.11 irradiation-exposure to ionizing radiation.
3.1 Definitions.
3.1.12 light-water nuclear reactor-an apparatus, using 3.1.1 blistering-the formation of bubbles in a coating (paint) film. light water as a moderator, in which fissionable material is arrayed so that controlled nuclear fission may be sustained in ,
3.1.2 boiling water reactor / SWR)-a reactor in which the a self-supporting chain reaction.
water moderator-coolant is boiled directly within the reactor 3.1.13 LOCA-the :pecific conditions anticipated fol-core. The pressure in the reactor vessel is only slightly greater I wing a loss of coolant accident that would expose the TABLE 1 Typical Spray Solutions 8 This method is underorthe Junndiction et ASTM Committee D Cc.mp 13 oniion Cnc. -ncal Compound Protective Coanns and Lan ng w k for Power Generation racihues and is the Concentration (in Desorued Water) direct responubihty of subcommmee D33 02 orr Service and Matenal Parameters. # * #
EP*
Current edition approved Oct. 10.1995. Puthshed Demmber 1995. Onsinally published as D 3911 - 80. tast previous edition D 3911 - 89. g
- h"'"," "
3 Annual Book QfASTAf Standards, Vol 06.0L. '"
3 Annual Book ofASTAf Standards. Vol 06.02. , {,[,y,, ,, ,n n 212
r )
Designation: D 4537 - 91 (Reapproved 1996)
I rneasures a trator of Test te levei orihe Standard Guide for E*[heD Es'ablishing Procedures to Qualify and Ceftify inspection
""Q scope for the Personnel for Coating Work in Nuclear Facilities '
methods in
@ and for This standard is issued under the fixed desisnauon D 453t the number immed2ately follomas the demsn J taile% the onginal adoption or. in the case of revtuon. the year oflast revimon. A number to parentheses mdicates the year o Ithe tape or superscnpt epsdon M :ndicates an ednonal change unce the last revison or reapproval. j
- 1. Scope w
execute the responsibilities of the appropriate certification f 1.1 This guide delineates the requirements for develop. level, tiern; su'-
nient of procedures for the qualification of personnel who 3.1.4 training-the program developed to ensuit that perform inspection of coating work. These activities are personnel receive the knowledge and skills necessary fer {
accomplished to verify conformance to specified require. qualification.
rents for nuclear facility coatings work whose satisfactory {
perforrnance is required in order not to compromise systems cance and W used to mitigate the consequences of postulated accidents.
4.1 The requirements of this guide apply to personnel 1.2 This guide provides a uniform interpretation of the who perfor.n inspections of coating work during (1) fabrica-requirements in ANSI /ASME N45.2.6-1978 for the inspec, tion. (2) receipt of items at the constru+n site, (3) tion of coating work in nuclear facilities. ,
construction, (4) pre-operational and startup asting, and (5) 1.3 This guide meets the intent of ANSI /ASME NQA 1. operational phases of nuclear facilities.
1.4 It is the intent of this guide to provide a recommended 4.2 It is the responsibility of each organization partici-basis for qualification, not to mandate a singular basis for alj pating in the project to ensure that only those personnel qualifcations. Variations or simplifications of the qualifica. within their respective organizations who meet the require-tions described in this guide are appropriate for special ments of this guide are permitted to perform inspection coating work outside of safety-related areas. activities covered by this guide.
1.5 This standard does not purport to address all of the 4.3 The organization (a) responsible for establishing the sqfety concerns, if any, associated with its use. It is the applicable requirements for activities covered by this taide responsibility of whoever uses this standard to consult and shall be identified, and the scope of their responsibility shall establish appropriate safety and health practices and deter-be documented. Delegation of this responsibility to other mine the applicability ofregulatory firnitations prior to use. qualifled organizations is permitted and shall be docu-mented.
- 2. Referenced Documents 4.411 is the responsibility of the organization performing 2.1 ANS//ASAIEStandards; these activities to specify the detailed methods and proce-ANSI /ASME N45.2.6 Qualifications ofInspection. Exam- dures for meeting the requirements of this guide, unless they are otherwise specified in the contract documents.
ination, and Testing Personnel for Nuclear Power Plants 2 ANSI /ASME NQA 1 Quality Assurance Program Re. 5. General Requirements for Inspection Perncenel quirements for Nuclear Facilities.:
5.1 Provisirms shall be made for the indoctrination of personnel a:, to the technical objectives of the project, the
- 3. T"
- codes and standards that are to be used, and the quality 3.1 Definitions of Terms Specific to This Standard: assurance elements that are to be employed.
3.1.1 certylcation-written documentation of qualifica- 5.2 The need for formal tra.ning programs shall be tion. determined, and such training activities shall be conducted 3.1.2 coating work inspection-a phase of quality control as required to qualify personnel who perform inspections.
which, by means of examination, observation, or measure- On-the-job panicipation shall also be included in the pro-ment, determines the conformance of coating work to gram, with ernphasis on first-hand experience gained through predetermined quality requirements. actual performance ofinspections.
3.I.3 qualpications-skills, training, and experience re- 5.3 A candidate's qualifications for cenification shall be quired for personnel to perform properly the duties and initially determined by a suitable evaluation of the candi-date's education, experience, training, examination results, and capability demonstration.
i'Dus smde is under the junsdicuoc of ASTM Comnuttee Ek33 on Protecove 5.4 The job performance of coating work inspection Comung and lining work for Power Generanon Facibnes and as the darect mpanadihty nt submmnunee p33.04 on taspecuen. personnel shall be reevaluated at periodic interva.ls not to cuneni edioon approved Aus.15. ten. Pubhshed ociober tut. onsinany exceed three years. Reevaluation shall be by evidence of pubimbed as D 4537- 86. Im previous edinos D 4537 - 86. continued satisfactory performance or redetermination of 8A Nanona! standards losutute. i t w. 42nd snet, capability in accordance with 5.3. If, during this evaluation or at any other time, it is determined by the responsibile organization that the capabilities of an individual are not in 315
Ff Designation: D 5163 - 91 (Reapproved 1996) i Standard Guide for l Establishing Procedures to Monitor the Performance of Safety i Related Coatings in an Operating Nuclear Power Plant This standard is issued under the Ened designatiot D $163 : the number immediately following the designauon indicates the year of onginal adopuon or. in the case of revision. the year oflast revision. A number in parentheses indicates the year oflast reapprovat A supersenpt epulon W todicates an ednonal change since the last revision or reapproval.
1
- 1. Scope O F 1133 Practice for Inspecting the Coating System of a k 1.1 This guide covers procedures for establishing a pro. Ship's Underwater Hull and Boottop During gram to monitor Senice I.evel I coating systems in operating Drydocking5 cuclear power plants. Monitoring is an on going process of 2.2 ANSIStandard:
evaluating the condition of the in-senice coating systems. N45.2.6-Qualification of Inspection, Examination, and 1.2 It is the intent of this guide to provide a recommended Testing Personnel for Nuclear Power Plants' l
' basis for establishing a coatings tnonitoring program, not to 2.3 SSrCStandard:
mandate a singular basis for all programs. Variations or SSPC-PA2-Measurement of Dry Paint Thickness With simplificatioos of the program described in this guide may be Magaetic Gages' appropriate for each operating nuclear power plant de. 2.4 NACEStandarde pending on their licensing commitments. Similar guidelines RP0188-88-Standard Practice Discontinuity (Holiday) may be applicable for Senice level 11 and other areas Testing of Protective Coatings outsi& containment.
Q l.3 This standard does wt purport to address all of the *' 3. Significance mod Use s4fety concerns. (any. associated with its use. It is the responsibihty ofthe user of this standard to estabhsh appro~ 3.1 Establishment of an in-senice coatings monitoring priate safety and heahh practices and determine the apphca- program permits planning and prioritization of coatings bility of regsdatory hmitatwns prwr to use. maintennoce work as needed to maintain coat integrity and performance in nuclear Senice Level I coating systems. For
- 2. Referenced Documents additional information on nuclear maintenance . coating 2.1 ASTMStandards-
- ' ^ ' ' " * * ' **'E"E' '
D610 Test Methods for Evaluating Degree of Rusting on
. Nuclear Power Plants.f*""*' *"
Painted Steel Surfaces 2 3.2 A coatings monitoring program enables early identifi-D7 T Method for Evaluating Degree of Blistering of cation and detection of potential problerns in coating sys-tems. Son e Senice Level I coating systems may be known in advance to be suspect, deficient, or unqualified. Monitoring D l!86 Test Metholis for Nondestructive Measurement of Dry Film Thickness of Nonmagnetic Coatings Applied coating performance will assist in developing follow-up to a Ferrous Base procedures to resolve any significant deficiency relative to coating work D3359, Test Methods for Measuring Adhesion by Tape 3.3 Degraded coatings may generate debris under design D4121 Practice for Photographic Documentation of basis accident conditions that could adversely affect the Coating aud Lining Failures and Defects
- performance of the post-accident safety systems. A coatings D4537 Guide for Establishing Procedures to Qualify and monitoring program may be required to fulfill safety analysis Certify inspection Personnel for Coating Work in Nu- report commitments for Senice Level I coating work in a nuclear power plant facility.
clear Facilities:
D4541 Test Method for Pull-Off Strength of Coatings '
Usit.g Portable Adhesion Testers 4. Responsibility F 1130 Practice for lospecting the Coating System of a 4.1 The owner / operator shall identify the department or Ship5 group within the organization to be responsible for estab.
F 1131 Practice for Inspecting the Coating System of a lishing the applicable requirements for actisities or proce-Ship's Tanks and Voids 5 dures covered by this guide and shall document the scope of F 1132 Practice for Inspecting the Coating System of a their responsibility. Owner / operator delegation of this re-Ship's Decks and Deck Machinery 5 sponsibility to other outside qualified organizations is cer.
8 Ttus guade is under the junndarsson of ASTM Communee D 33 on Protecuve l'
- Avaihble from Amencan Nauonal Standards lasutute. I1 w. 42nd sueet.
Comung and 1.snmg Work for Power Generanon Facihues and is the direct 13th Floor. New York. NY 10036.
responsbibty of Sutumnunee D33.04 on Inspecuon.
' Available from Steel Structures Paanung Council. 4400 Fifth Ave. Pittsburgh, Current edition approved Oct. 3.1991. Pubbshed December 1991. PA 15213 1
8tannal Aook q(ASTM $tandards. Vol 06.02.
- Available from Nanonal Associauon of Corrosion Engmeers P. O. Box 3 Annual Aook ofASTM 5tnadards. Voi 06.0t. 218340. Houston. TX 77218.
- Ducomanned. sec t992 Assual Aook ofASTM Standards. Vol 06.01. ' Avaulable from ASTM Headquaners, 100 Barr Harbor Dr., west
- Annual Aook ofASTMStandards. Vol 01.01 Conshobacken. PA !9428-2959.
485 l
' l
]
m 1
1 i l
1
$ D 5163 l mitted and shall be documented. l trolled, and vital areas, and escorted or unescorted clearance 4.2 It is the responsibility of the owner / operator or his as required, , ,
designee performing these activities to specify the detailed gp I 7.2.2 Radiological history including prior radiation expo. i methods and procedures for meeting the applicable require- sure for aH personnel involved, ,'"
ments of this guide. " l 7.2.3 Health physics classroom training in the use of c ,'
4.3 The owner / operator or his designee shall assign a radiation detection and ruonitoring devices and procedures coordinator to be responsible for supervising coating inspec. for wearing anticontamination clothing, me tion activities, data collection and doeurnentation, and for tior -
7.2.4 A radiation work permit based on health physics 1 ensuring that inspection personnel are adequately trained radiological survey of the work location, 9 and qualified.
7.2.5 Compliance with radiation work pennit require-4.4 The owner / operator shah assign responsibility for evaluating the results of inspection activities carried out ments and other special radiation controls unique to each $f work location, and the under the coatings performance monitoring program. 7.2.6 issuance of dosimetry. j"E 7.3 The safety requirements of the facility owner / operator 9
- 5. Frequency must be met when performing all inspection operations. Ted )
5.1 Frequency ofin-service coating inspection monitoring to d shall be determined by the owner / operator. In operating 8. Personnel Requirements, Qualifications, and Training caus nuclear power plants certain monitoring activities may be aum 8.1 The facility owner! operator shaU specify the require- and restricted to major maintenance outages or refueling outages.
It is a good practice to perform inspections during each ments and guidelines for qualification and training of 9..
inspection personnel i:volved in the program. However, Defe refueling outage or during other major maintenance outages as needed. -
inspectors and the coordinator shall be knowledgeable coat- 9.;
ings personnel meeting the requirements of ASTM Guide the -
- 6. Records and Past History D4537 or ANSI N45.2.6. The coordinator shaU, as a alonj minimum be a 1.evel 11 Coatings Inspector.
6.1 Coating performance wiH depend on the operating ducte i 8.2 The evaluator shall be a person knowledgeable and j conditions experienced by the coating systems. Records of experienced in nuclear coatings work. 9.:
these conditions shall be obtained for each operating unit. coati i These may include, but not be limited to, ambHt condi. 9. Inspection Plan and ,
tions, tempemtures, humidity, immersion, s Ash and facili-spillage, chemical exposures, radiation exposures, previous 9.1 The owner / operator shall develop a plant specific inspe inspection plan to accomplish the objectives of the moni. F 11.2 decontamination procedures, abrasion and physical abuse, toring program. A general visual inspection shall be con. Pract cnd start-up/ shutdown frequency. Any change in service criteria or modifications of the physical design must be ducted on aH readily accessible coated surfaces during a comp )
identified and dated. walk-through. After the walk-through, thorough visual in- j 9.4 i spections shall be carried out on presiously designated areas tive o 6.2 The last two performance monitoring reports per-taining to the coating systems shah be reviewed prior to the and on areas noted as deficient during the walk-through. A thick thorough visual inspec* don shall also be carried out on au (Test monitoring process. Other past coatings history data to be -l reviewed may include: coatings near sumps or screens associated with the Emer- RP01 6.2.1 Copies of coating specifications, manufacturer's gency Core Cooling System (ECCS). The inspection plan ator.
shall addras the following based on specific owner / operator defect I product data sheets, and application procedures for in-place requirernents. '
coatings. i 9.5 9.1.1 A pre-inspection briefir.7 to familiarize all inspec-6.2.2 Quality control documentation for the existing in- may i place coating systems and their application. tion personnel with objectives of the inspections, procedures , marke to be followed, and precautions to be taken, 35-mr 6.2.3 Copies of previous inspection or monitoring reports.
9.1.2 Monitoring team (s) assignments to specific areas for ylene 6.2.4 Documentation pertaining to any maintenance inspection (s), and w:rk performed on existing coating systems.
9.1.3 Location maps dividing the plant into identifiable 10. R4
- 7. Premonitoring Procedure areas for inspection activities to be issued to inspection teams. The maps shall also identify items / areas requiring 10.1 7.1 Prior to conducting an inspection of the coating special testing, if any. The locations of all defects and of au uation systems, the responsible organization shall ensure that the tests performed shall be recorded on the maps so that ments necer.sary services and equipment required for inspection are additional testing, recoating, and further monitoring may be Coatin .
provided. Factors that must be considered while planning the performed. inform l i
inspection activities include, but are not limited to, lighting, j o, j 9.2 During walk-through, visuaHy examine coated sur-access to coated surfaces, cleaning surfaces of any deposit or ration' !
faces for any visible defects, such as blistering, cracking.
build up, ventilation and, where necessary, special unders flaking / peeling, rusting. and physical damage. 10.l water inspection requirements. repaire 9.2.1 Bhstenng-Compare any blistering found to the '
7.2 Station access procedures for Service Level I coating blistering pictorial standards of coatings defects (refer to Test be m systems monitoring shall be followed. While access proce. Method D 714) and record size and frequency. If the blisters survein dure, may vary from plant to plant, specific station access are larger than those on the comparison photographs. 10.1 procedures may include: Eiven i$
measure, record size and extent, and photograph. Report if 7.2.1 Security clearance for protected, radiation con- blistered portim are intact. 10.1 '
mapfo 486
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s,
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' $ D 5163
"""C' 9.2.2 Cracking-Cracking can be limited to the one layer
- P* of soaang or extend through to the substrate. Measure the ecm cs ==ca=a ca uomoa c caoca.=
i length of the crack or if extensive cracking has occurred. '~ * * ' ' "*"~
5' OI measure the size of the area affected. Determine if the * ~ ' ' **~~
dures cracking is isolated or is part of a pattern. Record measure. ' ~ '
- ments and describe crack depth and pattern on the irspec. >= c s= = == 1 ysics '
tion report. Photograph the area affected. ~ ' ' '
9.2.3 Flaking / Peeling / Delamination-Measure the ap-
- "I#C"
{
proximate size of the peels and note the pattern formed. f ,,, ,,, M y,~~;.,= =,= ,,
each - Carefully test to see iflifting can be easily achieved beyond the obvious peeled area. Note all observations on the { I inspection report and photograph the area affected.
i rator 9.2.4 Rusting-Compare with the pictorial standanis of Test Method D 610 to determine the degree of rusting. Try to determine the source of rusting (that is, is it surface stain 8 caused by rusting elsewhere, or is it a failure of the coating allowing the substrate to rust). Photograph the affected area m e-I of and record observations on the inspection report.
wr, 9.2.5 If no defects are found, mark " Coating Intact, No Defects" on the inspection report.
cat-ude 9.2.6 If portions of the coating cannot be inspected, note sa i the specific areas on the location map-inspection report, along with the reason why the inspection cannot be con-ducted.
and 9.3 Written or photographic documentation, or both of coating inspection areas, failures, and defects shall be made and the process of documentation standardized by the facility owner / operator. Written documentation practice for ific inspection of coating system as given in Practices F1130. FIG.1 inspecton Data Sheet
.ni-F 1131, F 1132, and F 1133 may be adopted as a guideline.
m-
,a Practice D4121 provides one method to obtain consistent.
comparable close-up photographs.
in. ,
9.4 For coating surfaces determined to be suspect, defec- ,,,,, , , , , , ,, %,, _ , , , -
as . , ,
onn tive or deficient, one or more physical tests, such as dry film A
thickness (Test Methods D 1186 and SSPC-PA-2), adhesion
-a
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iiiiiei# # #i i i i i r-all =
g , , , , , , , , , , _
(Test Methods D 3359 and D 454 I), and continuity (NACE- ;
lllt#l q r-RP0188-88), may be performed when directed by the evalu- " " " " " - " " " " " "
sn ator, Samples may be gathered, and the size and extent of or defective patterns may be described.
a
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- I N4l i
c-9.5 Instruments and equipment needed for inspection f may include, but not be limited to, flashlights, spotlights, , ,p./ * ,7.% e ""
y-es marker pen, minor, measuring tape, magnifier, binoculars.
=
%" _Qf "r ""'
L ,[
a 35-mm camera with or without wide angle lens, and polyeth- 3 v+
u (
ylene zip lock sample bags. N N le
- 10. Reportmg and Documentation
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, (,
g ' .r: -
E 10.1 Inspection reports for submittal to responsible eval- [ -"
Il uation personnel based on specific owner / operator require- c
.$ ,,, g !
j
- t ments should be prepared by a qualified Level II or Level Ill ,
v;. j ,,
~~
- Coatings inspector and should incl;de at least the following -
information: ' . I, ,J.
~ 10.1.1 A list and location of all areas evidencing deterio- ,M ration, n V . .
- ~
10.1.2 Prioritize the repair areas into areas that must be ,
,% % m ,.,
repaired during the same outage and areas where repair can E ,,,, ,
N- f be postponed to future outages, keeping the coating under ' ; grgg~,g'ft ** [ O g g.,..,.-, ,7 surveillance in the interim period, '
10.1.3 Inspection Data Sheets-A typical data sheet is given in Fig.1, and 10.1.4 Photographic Documentation-A typical location ""
map for photographic identification is given in Fig. 2. The FIG. 2 ma W m L.ocation map
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@ D 5163 location and direction of all photographs shall be recorded would include an analysis of the reasons or suspected reasons 1 on the maps for comparison with past and future photo- for failure. The repair work should be prioritized into major graphs and to record existing conditions. Numbers 3-1 !
and minor defective areas. A recommended corrective plan '
through 3-13 in Fig. 2 depict the location of the photogra- of action must be provided for the rnajor defective areas so pher and the directions of the view.
that the plant can repair these areas, if appropriate, during the same outage.
- 11. Evaluation 11.1 The inspection rvort shall be evaluated by the 12. Keywords responsible evaluation personnel. The evaluator shall pre- 12.1 coatings rnonitoring program; coating performance; pare a report that incbdes a summary of findings and inspection; maintenance; nuclear power plant; safety related recommendations for future surveillance or repair; this coatings; Service Level I; surveillance the Amercan socnety for restmg and Marenas takes noposem respectmo the valodity of anypatent ryhts asserted a cennectm weh any nem mentwed a trus standard users of the standard are expressly advised that cotarmmata at the vatodey of any such patent ryhts. and the rak at mtnngement or such nghts. are entsrety trwor own responsitutey. .
rtus standard a subrect to revacn at any tune by the responsite tectmcal commeree and must be revowed everylove years and n not revaad ether renoproved or wendrawn. Your comments are mveed eener for revaa of the standard or tar additaanat standards and should be addressed to A5rM Headquaners. your Comments well racerve carefut consode'at@ at a meetmg of the responslNe tectmeal commetee. whch you may attend. If you feel that your comments have not recorved a teor heartng you shou 6d ineke yos vows known to the ASrM Commerne on stancards.100 Barr Harbor Drrve. West Conshohocken. PA tg428.
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PRESENTATION MATERIAL USED BY THE STAFF ATTACHMENT 3-B
f RELATIONSHIP BETWEEN GENERIC LETTER 98-04 (COATINGS AND DEBRIS IN CONTAINMENT)
AND DG-1076 Presented by J. A. Davis EMCB/DE/NRR
{
Generic Letter 98-04 I Team J. A. Davis and C. L. Lauron, EMCB/DE/NRR I L. L. Campbell, HQMB/DRCH/NRR R. M. Lobel, SCSB/DSSA/NRR
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RELATIONSHIP BETWEEN GENERIC LETTER 98-04 (COATINGS AND DEBRIS IN CONTAINMENT)
AND DG-1076 The GL Requests information on Current Coatings Programs Relative to Design Licensing Basis The Staff has Started the Review on about 10 Submittals About Half of the Submittals State that the Licensee has Committed to RG 1.54 All Meet Their Licensing Basis Almost all Have Committed to 10 CFR 50, Appendix B for all Future Containment Coating Work Use of DG-1076 is an Acceptable Method for Complying With NRC Regulations The Staff has not Determined if Design / Licensing Bases are Adequate l
- i. t 3
NRR USES FOR DG-1076 Future Updates of the SRP for Coatings Can be Referenced in new Applications for Construction Permits and Operating Licenses Can be used to Satisfy 10 CFR 50, Appendix B Requirements for Future Coating Work if Used With the Owners OA Program Potential use in NRC Oversight of DOE
t Minutes of CRGR Meeting No. 335, January 12,1999 CRGR ENDORSEMENT OF DG-1076 ATTACHMENT 3-C
1 I } Raji Tripathi- CRGR ENDORSEMENT OF DG-1076 Page 1 l From: Raji Tripathi i To: Jack Strosnider, John Craig Date: Wed Feb 17,19991:13 PM 1
Subject:
CRGR ENDORSEMENT OF DG-1076 On January 12,1999, the Committee To Review Generic Requirements (CRGR), at its 335th meeting reviewed the subject draft guide presented for the Committee's endorsement. Subsequently, Al. Serkiz (RES) provided a revised version of the guide which appears to have addressed the Committee's comments and recommendations. Specifically, we note that the guide now is forward-fit only; the Reg.
Analysis has been modified accordingly and duly concurred by the sponsoring Division Directors and OGC. Furthermore, the implementation section has been revised to include the applicability of tha guide to the applicants for combined licenses. Additionaily, the CRGR staff made one minor editorial change to the wording used in the Regulatory Analysis, as noted in the (red-line/ strike-out) text in the attached file.
The CRGR Chairman has determined that there is no need for circulation of the revised proposal to the Committee members, and has endorsed this guide for issuance for public comments.
Please call me if you have any questions... Raji (415-7584)
CC: Aleck Serkiz, Brian Sheron, Dennis Dambly, Garm..
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- m \ U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REGULATORY RESEARCH February 1999 Division 1
[f j Draft DG-1076 i ,i, DRAFT REGULATORY GUIDE
~% e , , , , **
Contact:
A.W. Serkiz (301)415-6563 1 DRAFT REGULATORY GUIDE DG-1076 (Proposed Revision 1 to Regulatory Guide 1.54)
S5RVICE LEVEL I, ll, AND 111 PROTECTIVE COATINGS APPLIED TO NUCLEAR POWER PLANTS A. INTRODUCTION in Appendix A to 10 CFR Part 50, " General Design Criteria for Nuclear Power Plants,"
Criterion 1, " Quality Standards and Records," requires that structures, systems, and components important to safety be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed. Appendix A also requires that a quality assurance program be established and implemented in order to provide adequate assurance that these structures, systems, and components will satisfactorily perform their safety functions, in Appendix A to 10 CFR Part 50, Criterion 4, " Environmental and Dynamic Effects Design Bases," requires that structures, systems, and components (SSCs) important to safety be designed to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents.
in 10 CFR Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," establishes overall quality assurance program requirements for the design, fabrication, construction, and operation of safety-related nuclear power plant SSCs.
The maintenance rule,10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," includes in its scope all safety-related SSCs and those non-safety-related SSCs: (1) that are relied upon to mitigate accidents or transients or are used in plant This regulatory guide es being issued in draft form to involve the public in the development of a regulatory position in this area. As a draft being issued for public comment, it does not represent an official NRC staff position.
Public comments are being solicited on the draft guide (including any implementation schedule) and its associated regulatory analysis or value/ impact statement. Comments should be accompanied by appropriate supporting data. Written comments may be submitted to the Rules and Directives Branch, office of Administration, U.s. Nuclear Regulatory Commission, Washington, DC 20555 0001. Copies of comments received may be examined at the NRC Pubhc Document Room,2120 L street NW., Washington, DC. Comments will be most helpful if rt ceived by Requests for single copies of draft or active regulatory guides (which may be reproduced) or for placement on an automatic distnbution hst for single copies '.sf future draft guides in specific divisions should be made in writing to the u.s. Nuclear Regulatory Commission, Washington, DC
.20555 0001, Attention: Reproduction and Distribution services section, or by f ax to 4301)415 2289; or email to DISTRIBUTION @NRC. Gov.
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emergency operating procedures; (2) whose failure could prevent safety-related SSCs from fulfilling their safety-related function and (3) whose failure could cause a reactor scram or an actuation of a safety-related system. To the extent that protective coatings meet these criteria, they are within the scope of the maintenance rule. The maintenance rule requires that licensees monitor the effectiveness of maintenance for these protective coatings (as discrete systems or components or as part of any SSC) in accordance with 10 CFR 50.65(a)(1) or (a)(2), as appropriate. Further guidance is provided in Revision 2 of Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" (Ref.1).
This revision to Regulatory Guide 1.54 is being developed in accordance with Public Law 104-113, OMB Circular A-119, and NRC's Strategic Plan for FY 1997 - 2002, which encourages industry to develop codes, standards, and guides that can be endorsed by the NRC and carried out by industry. The ASTM standards cited in the Regulatory Position of this guide for the selection, qualification, application, and maintenance of protective coatings in nuclear power plants have been reviewed by the NRC staff and found to be acceptable with the exceptions noted.
Regulatory guides are issued to describe to the public rr,ethods acceptable to the NAC staff for implementing specific parts of the NRC's regulations, to explain techniques u ed by the staff in evaluating specific problems or postulated accidents, and to provide guidance to applicants. Regulatory guides are not substitutes for regulations, and compliance with regulatory guides is not required. Regulatory guides are issued in draft form for public comment to involve the public in developing the regulatory positions and, therefore, such draft regulatory guides do not represent official NRC staff positions.
The information collections contained in this draft regulatory guide are covered by the requirements of 10 CFR Part 50, which were approved by the Office of Management and Budget, approval number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.
B. DISCUSSION Protective coatings (paints) have been used extensively in nuclear power plants to protect the surfaces of facilities and equipment from corrosion and contamination from 2
lt radionuclides and for wear protection during plant operation and maintenance activities. For platits that have a design basis that includes a commitment to Regulatory Guide 1.54, the regulations cited above require that protective coatings be qualified and capable of surviving a design basis accident (OBA) without adversely affecting safsty-related SSCs needed to mitigate the accident.
In July 1973, Regulatory Guide 1.54, " Quality Assurance Requirements for Protective Coatings Applied to Water Cooled Nuclear Power Plants," was issued to describe an acceptable method for complying with the NRC's quality assurance requirements with regard to protective coatings applied to ferritic steels, aluminum, stainless steel, zinc-coated (galvanized) steel, concrete, or masonry surfaces of water-cooled nuclear power plants. The presumption was that protective coatings that met these guidelines would not degrade over the design life of the plant. However, operating history has shown that undesirable
' degradation, detachment, and other types of failures of coatings have occurred (Ref. 2).
Detached coatings from the substrate that are transported to emergency core cooling system intake structures may make those systems unable to satisfy the requirement in 10 CFR 50.46(b)(5) to provide long-term cooling.
Regulatory Guide 1.54 conditionally endorsed ANSI N101.4, " Quality Assurance for Protective Coatings Applied to Nuclear Facilities," and indirectly endorsed guidance provided in ANSI N101.2, " Protective Coatings (Paints) for Light Water Nuclear Reactor Containment Facilities." ANSI N101.4 and N 101.2 were formally withdrawn in 1988; responsibility for updating, rewriting, and issuing appropriate replacement standards was transferred to the American Society for Testing and Materials (ASTM), specifically ASTM Committee D-33 on Protective Coating and Lining Work for Power Generation Facilities. However, Regulatory Guide 1.54 was not revised as new ASTM Standards were developed for the application and maintenance of NPP protective coatings.
ASTM D 3843-93, " Standard Practice for Quality Assurance for Protective Coatings Applied t) Nuclear Facilities" (Ref. 3), was approved and issued by ASTM as a partial replacemer.t for ANSI N101.4. ASTM D 3911-95, " Standard Test Method for Evaluating Coatings Used m 1.ight-Water Nuclear Power Plants at Simulated Design Basis Accident (DBA)
Conditions" (Ref. 4), has been approved and issued by ASTM to replace the DBA test standard that v... 0ferenced in ANSI N101.4 and Regulatory Guide 1.54.
ASTM D 5144 97, " Standard Guide for Use of Protective Coating Standards in Nuclear l'ower Plants' (Ref. 5), has been developed and issued by the ASTM to provide a 3
i common bsis on which pratective coatings for the surfaces of nuclear power generating facnities may be qualified and selected by reproducible evaluation tests. This ASTM standard provides guidance for the apptculon and maintenance of protective coatings under the expected environmental.'cperat:ng, and postulated accident condit: ' for pressurized water reactors (PWRs) and boiling water reactum '0WRs).
C. REGULATORY POSITION
- 1. GUIDANCE IN ASTM STANDARDS ASTM D-5144-97 {Ref. 5) and the other ASTM standards discussed below provide guidance on practices and programs that are acceptable to the NRC staff for the selection, application, qualification, inspection, and maintenance of protective coatings applied in nuclear power plants.
The quality assurance provisions and guidance contained in the standards in this Regulatory Position are generally acceptable and provide methods acceptable to the NRC staff for complying with the pertinent quality assurance requirements of Appendix B to 10 CFR Part 50 subject to the following two exceptions.
(1) When using this regulatory guide, NRC licensees should meet the quality assurance provisions and guidance contained in the standards in this regulatory guide and must also meet the commitments and provisions contained in their Quality Assurance Program Description.
(2) Service Level I,11, and lil coatings are defined as:
Service Level I coatings are used in areas where the coating failure could adversely affect the operation of post accident fluid sv;tems and thereby impair safe shutdown.
With few exceptions, Service Level 1 applies to coatings inside primary containment.
Service Level !! coatings are used in areas where coatings failure could impair, but not prevent, normal operating performance. The functions of Service Level 2 coatings are to provide corrosion protection and to improve the ability to decontaminate those areas outside primary containment that are subject to radiation exposure and radionuclide contamination.
Service Level lil coatings are used on any exposed surface area located outside containment whose failure could adversely affect normal plant operation or orderly and safe plant shutdown.
4
a ASTM D-5144-97 (Ref. 5) addresses by reference the preparation of test specimens, radiation tolerance testing, decontaminability of coatings, physical properties, chemical resistance tests, fire evaluation tests, DBA testing, surface preparation, coating application and inspection, and thermal conductivity testing. Therefore, ASTM D 5144-97 can be viewed as a top-level ASTM standard that incorporates by reference other key ASTM standards as shown in Figure 1.
- 2. QUALITY ASSURANCE ASTM D 3843 93 (Ref. 3) provides quality assurance practices that are acceptable to the NRC staff and are applicable to safety-related protective coating work in coating Service Level I areas of nuclear facilities. Applicable portions of practices described may be used as the basis for limited quality assurance for protective coating work in coating Service Level 11 areas of nuclear facilities.
ASTM D 5139-96 (Ref. 6) provides guidance that is acceptable to the NRC staff on the size, composition, and surface preparation for test samples of protective coatings for use in qualification testing of coatings to be used in nuclear power plants as described in ASTM D 3911-95 and D 4082-95 (Refs. 4 and 7).
ASTM D 3911-95 (Ref. 4) provides guidance that is acceptable to the NRC staff on procedures for evaluating protective coating systems test specimens under simulated DBA conditions. ASTM D 3911-95 also provides guidance on conditions and test apparatus for ternperature-pressure testing, conditions for radiation testing, and procedures for preparing, examining, and evaluating samples.
ASTM D 4082-95 (Ref. 7) provides a standard test method that is acceptable to the NRC staff for evaluating the effects of gamma radiation on the lifetime radiation tolerance of Service Level I and 11 coatings. l ASTM D 4537-96 (Ref. 8) provides guidance that is acceptable to the NRC staff on the qualification and certification of personnel who inspect protective coatings in nuclear facilities. This standard provides guidance on inspection of the education, training, experience, qualifications, and certification of Level I, il, and 111 coating inspectors.
5
a
- 3. TRAINING AND QUAllFICATION OF PROTECTIVE COATINGS INSPECTORS AND COATING APPLICATORS l
ASTM D 5498-94 (Ref. 9) provides guidance acceptable to the NRC staff for persons responsible for developing a training program for the indoctrination and training of personnel for inspecting coating work in nuclear facilities and also recommends areas of proficiency that are embodied in the ASTM standards shown in Teble 1 in ASTM D 5498-94.
ASTM D4227-95 (Ref.10) provides guidance acceptable to the NRC staff for the qualification of coatings applicators to verify that they are proficient and able to attain the quality required for applying specified coatings to concrete surfaces, including those in a nuclear facility. ,
ASTM D4228-95 (Ref.11) provides guidance acceptable to the NRC staff for the qualification of coatings applicators to verify that they are proficient and able to attain the quality required for applying specified coatings to steel surfaces, including those in a nuclear facility.
ASTM D4286-96 (Ref.12) provides criteria and methods that are acceptable to the NRC staff to assist utility owners, architects, engineers, and contractors in determining the overall qualifications of a coatings contractor to execute coating work for the primary containment and other safety-related facilities of nuclear power plants. The criteria and requirements for contractors address the contractor's essential basic capabilhy to execute nuclear coating work.
- 4. MAINTENANCE OF COATINGS ASTM D 5163-96 (Ref.13) provides guidelines that are acceptable to the NRC staff for establishing an in-service coatings monitoring program for Service Level I coating systems in operating nuclear power plants and for Service Level 11 and other areas outside containment (as applicable).
ASTM D 4541-95 (Ref.14) provides guidance acceptable to the NRC staff for a procedure for evaluating the pull-off strength of coatings using fixed-alignment adhesion testers.
6
1 ASTM D 3359 95, Revision A (Ref.15), provides guidance that is acceptable to the NRC staff on test methods for measuring adhesion using tape tests.
ASTM D 5962-96 (Ref.16) provides guidance that is acceptable to the NRC staff on maintaining unqualified coatings (paints) within Level I areas of a nuclear power f acility.
- 5. ASTM STANDARD TERMINOLOGY ASTM D4538-95 (Ref.17) defines uandard terms related to protective coating and fining work for power generation facilities that are acceptable to the NRC staff and that are also applicable to protective coatings employed in nuclear power plants.
- 6. ADDITIONAL INFORMATION Additional information on the selection, application, inspection, and maintenance of nuclear plant safety-related protective coatings is provided in EPRI Report TR-109937 (Ref.
18), which provides a detailed discussion of important considerations related to protective coatings and can be used to supplement the ASTM Standards guidelines as deemed necessary.
D. IMPLEMENTATION The purpose of this section is to provide information to applicants and licensees regarding the NRC staff's plans for using this regulatory guide.
This proposed revision has been released to encourage public participation in its development.' Except in those cases in which an applicant proposes an acceptable alternative method for complying with the portions of the NRC's regulations specified in this guide, the methods and guidance to be described in the final guide will reflect public comments received and will be used in the evaluation of submittals in connection with applications for construction permits, operating licenses, and combined licenses. Current licensees may, at their option, comply with the guidance in this regulatory guide. Any applicable requirements for changing the !! censing basis to reflect the change must be followed.
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ASTM D5144 97 A S TM'I 45'38-U' Protective Coating l4 i Protective Coatings Standards in NPPs l l Terminology L ) '
?
)
-- Y ',
' y ASTM D3843-93 ASTM D4537 96 Procedures to Qualify & ASTM D5163 96 QA Practices for NPP Establishing Procedures to Protective Coatings ,
Certify inspection
' 2 l '
_ . . ASTM D5139-96 4 [ ASTM D5498 94 _ _ . . .
> Sample Preparation ] Developing a Training for Coatir g Tests k' Program for Coating Work ASTM D454195
( Inspectors in NPPs Coatings Adhesion
' Testing
' ASTM D3911-95 ASTM D4286-96 3'
q Simulated DBA Contractor Qualif, ,
Coatings Teshng , >l' NPP Coatings '
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ASTM D3359 95, A S T M 'D408"279 5'
. , , e Rev. A , Tape Adhesion
> Irradiation of ASTM D4227-95 Coatings Tests Test Samples > l Applicator Qualif. - i
- i Concrete Surfaces . l l ASTM D5962 96 ASTM D4228 95 >! Maintaining Level 1 l { Applicator Qualif.. Unqualified Coatings
>{ Steel Surfaces _ ;
Figure 1, ASTM Standards Relevant to NPP Class I, il and ill Protective Coatings 8
o REFERENCES
- 1. USNRC, " Monitoring the Effectiveness of Maintenance at Nuclear Power P; ants,"
Regulatory Guide 1.160, Revision 2, March 1997.
- 2. USNRC, " 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," Generic Letter 98-04, July 14,1998.
- 3. American Society for Testing and Materials, " Standard Practice for Quality Assurance for Protective Coatings Applied to Nuclear Facilities," ASTM D 3843-93.
- 4. American Society for Testing and Materials, " Standard Test Method for Evaluating Coatings Used in Light-Water Nuclear Power Plants at Simulated Design Basis Accident (DBA) Conditions," ASTM D 3911-95.
- 5. American Society for Testing and Materials, " Standard Guide for Use of Protective Coating Standards in Nuclear Power Plants," ASTM D 5144-97.
- 6. American Society for Testing and Materials, " Standard Specification for Sample Preparation for Qualification Testing of Coatings To Be Used in Nuclear Power Plants,"
ASTM D 5139-90 (Reapproved 1996).
- 7. American Society for Testing and Materials, " Standard Test Method for Effects of Gamma Radiation on Coatings for Use in Light-Water Nuclear Power Plants," ASTM D4082-95.
- 8. American Society for Testing and Materials, " Standard Guide for Establishing Procedures To Qualify and Certify inspection Personnel for Coating Work in Nuclear Facilities," ASTM D 4537-91 (Reapproved 1996).
- 9. American Society for Testing and Materials, " Standard Guide for Developing a Training Program for Coating Work inspectors in Nuclear Facilities," ASTM D 5498-94.
- 10. American Society for Testing and Materials, " Standard Practice for Qualification of Coating Applicators for Application of Coatings to Concrete Surf aces," ASTM D4227-95.
- 11. Ainerican Society for Testing and Materials, " Standard Practice for Qualification of Coating Applicators for Application of Coatings to Steel Surfaces." ASTM D4228-95.
- 12. American Society for Testing and Materials, " Standard Practice for Determining Coating Contractor Qualifications for Nuclear Powered Electric Generation Facilities,"
ASTM D4286-90 (Reapproved 1996).
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- 13. American Society for Testing and Materials, " Standard Guide for Establishing Procedures To Monitor the Performance of Safety Related Coatings in an Operating Nuclear Power Plant," ASTM D5163-96.
- 14. American Society for Testing and Materials, " Standard Test Method for Pull-Off Strength of Coatings Using Portable Adhesion Testers," ASTM D 4541-95.
- 15. American Society for Testing and Materials, " Standard Test Methods for Measuring Adhesion by Tape Test," ASTM D-3359-95, Revision A.
- 16. American Society for Testing and Materials, " Standard Guide for Maintaining Unqualified Coatings (Paints) Within Level ! Areas of a Nuclear Power Facility " ASTM D 5962-96.
- 17. American Society for Testing and Materials, " Standard Terminology Relating to Protective Coating and Lining Work for Power Generation Facilities," ASTM D 4538-95.
- 18. Electric Power Research Institute, " Guidelines on the Elements of a Nuclear Safety-Related Coatings," EPRI Report TR-109937, March 1998.
10 l
- n j r-REGULATORY ANALYSIS l
The guidance in Regulatory Guide 1.54, " Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants," has become outdated because the ANSI standards endorsed by the guide have been withdrawn and rep! aced by ASTM standards. Public Law 104-113, OMB Circular A-119, and NRC's Strategic Plan for FY1997-2002 encourage the use of industry developed consensus codes, standards, and guides that heve been de.e:eped by lndeet.i end thet can be endorsed by the NRC-end eerc;ed set by induetri. The most cost-beneficial method to update the guidance in Regulatory Guide 1.54 would be to issue a revision of Regulatory Guide 1.54 that endorses updated ASTM standards.
BACKFIT ANALYSIS The proposed regulatory guide does not require a backfit analysis as described in 10 CFR 50.1091c) because this regulatory guide will not require backfitting as described in 10 CFR 50.109(a)(1); rather, this regulatory guide will provide guidance that the licensee may choose to use.
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\.m,/ February 21, 1999 MEMORANDUM TO: William D. Travers Executive Director for Operationc FROM: Joseph A. Murphy, Chairman Committee To Review Generic Require ents
SUBJECT:
MINUTES OF THE CRGR MEETING 'JMBER 335 The Committee To Review Generic Requirements (CRGR) met on Tuesday, January 12,1999, from 9:00'a.m. to 12:30 p.m to hold the Committee's 335* meeting. Attachment 1 contains the list of attendees. J. Murphy presided over the meeting as Acting Chairman.
W. Kane, S. Shankman, W. Hodges, and L. Kokajko - all of NMSS - briefed the Committee on their planned approach to licensing reviews and cask certification reviews which will lead to 10 CFR Part 72 amendments in the near future. Attachment 2A contains the staffs presentation material, and Attachment 2-B is the Spent Fuel Project Office Communications Plan. The latter includes office interfacing information as well as a tentative schedule for various activities. The staffs briefing focused on issue C.1-7, " Dual Purpose Spent Fuel Cask Reviews," from the Chairman's Tasking Memorandum. The staff plans to issue a storage-related certificate of compliance through Part 72 rulemaking, and a Part 71 transportation certificate of compliance for dual-purpose spent fuel cask designs. Additionally, the staff plans to make the following process modifications to Part 72: (1) revise Section 72.48 (similar to 10 CFR 50.59) to incorporate NRR initiatives; (2) streamline the rulemaking process to allow for direct and final rulemaking for the certified cask design; (3) clarify general versus site-specific license requirements; (4) expand the scope of Part 72 to cover enforcement; (5) revise geologic and seismologic criteria for dry cask storage; and (6) eliminate the 30-day wait between pre-operational testing and fuel load. The staff proposed to brief the CRGR at the final stage of rulemaking for the dual-purpose cask designs. The Committee decided that it will review the rulemaking related to the Holtec spent fuel storage cask design to determine the extent of its future involvement.
l J. Craig (RES), A. Serkiz (RES), and J. Davis (NRR) presented for CRGR review and endorsement the draft Regulatory Guide DG-1076," Service Level I,11, and 111 Protective Coatings Applied to Nuclear Power Plants." Attachment 3A and 3B contain the staffs ,
presentation material. Via this guide, which is a proposed Revision 1 to Regulatory Guide 1.54. l the staff endorses various ASTM standards.. This effort is consistent with Public Law 104-113, OMB Circular A-119, and NRC's Strategic Plan for FY 1997-2002. This draft guide updates the NRC guidance on the selection, qualification, acceptance, application ar d maintenance of Class I, il and lil protective coatings, and makes such guidance consistent with industry practice.
The Committee expressed a concem on the backfit aspects of this proposed action.
Consequently, the staff made this proposed guide a forward-fit only and revised the regulatory i analysis accordingly. On February 17,1998, a formal CRGR endorsement (Attachment 3-C) for l issuance of this draft guide for public comments was relayed to the staff.
l PDR I 1
l j
William D. Trav:rs l M. Mayfi:Id (RES), R. Wessman (NRR), and D. Jackson (RES) pres:nt d for CRGR review and {
endorsement the draft final Regulatory Guide (RG) 1.84, " Design and Fabrication Code Case !
Acceptability," RG 1.85, " Materials Code Case Acceptability," and RG 1.147, " Inservice inspection Code Case Acceptability." Attachment 4A contains the staff's presentation materia!.
These guides were not submitted for CRGR review and endorsement prior to issuance for public comments. The Committee offered various comments and recommendations. Most significantly, the Committee noted that various proposed requirements for licensees to submit information to NRC seemed to be inconsistent with other ongoing staff efforts, such as, those related to reducing the bulk of information to be included in the updated FSAR The Committee also commented on the purpose of the information being sought and the standards to be used in evaluating the licensee-fumished information. The Committee has been informed that these a documents are currently being revised by the staff. Following NRR and OGC re-concurrence, I when the revised guides are re-submitted, the Committee has instructed the CRGR staff to evaluate these documents in light of the Committee's comments and recommendations, and
. also provide its assessment and recommended action to the CRGR members. If the revised draft final guides change substantially, they may be re-noticed for public comments.
In accordance wim the EDO's July 18,1983 directive concerning " Feedback and Closure of CRGR Review", a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes. The response is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the EDO for decision making.
Questions concerning these meeting minutes should be referred to Raji Tripathi (415-7584).
Attachments: As stated cc: Commission (5) SECY M. Knapp, DEDE F. Miraglia, DEDO J. Lieberman, OE M. Springer, ADM H. Bell, OlG K. Cyr, OGC J. Larkins, ACRS H. Miller, R-l L. Reyes, R-Il J. Dyer, R-Ill E. Merschoff, R-IV C. Paperiello, NMSS A. Thadani, RES S. Collins, NRR W. Kane, NMSS J. Craig, RES M. Mayfield, RES Distribution:
File Center (w/attch) PDR (NRC/CRGR) (w/o attch. 2-B and 2-C) SShankman, CRGR SF CRGR CF JMurphy DDambly JJohnson, RIV BSheron MVirgilio MFederline JMitchell LKokajko JJohnson, OCM GMillman WHodges FCherny NDudley ASerkiz MMarshall JDavis RCorreia LCampbell Alee CCarpenter YHuang TSullivan EHackett DJackson KWichman RWessman Clauron NOsgood DISK / DOCUMENT NAME: S:\CRGR\DMTS-335.WPD To recerve a copy. indecate "C" o Copy w/o attachment / enclosure. "A* a Copy with attachment / enclosure. Y a No copo NO MARK = NO COPYi OFC CRGR C CRGR C C CRGR C NAME GWest [ RTnpathi h JMurphy DATE 2. / /Q/99 2 /) [ 199 1 / 7 \ /99 OFFICIAL RECORD COPY
y William D. Travers M. Mayfield (RES), R. Wessman (NRR), and D. Jackson (RES) presented for CRGR review and endorsement the draft final Regulatory Guide (RG) 1.84, " Design and Fabrication Code Case Acceptability," RG 1.85, " Materials Code Case Acceptability," and RG 1.147, " Inservice inspection Code Case Acceptability." Attachment 4A contains the staff's presentation material.
These guides were not submitted for CRGR review and endorsement prior to issuance for public comments. The Committee offered various comments and recommendations. Most significantly, the Committee noted that various proposed requirements for licensees to submit information to NRC seemed to be inconsistent with other ongoing staff efforts, such as, those related to reducing the bulk of information to be included in the updated FSAR. The Committee also commented on the purpose of the information being sought and the standards to be used in evaluating the licensee-fumished information. The Committee has been informed that these documents are currently being revised by the staff. Following NRR and OGC re-concurrence, when the revised guides are re-submitted, the Committee has instructed the CRGR staff to evaluate these documents in light of the Committee's comments and recommendations, and also provide its assessment and recommended action to the CRGR members. If the revised draft final guides change substantially, they may be re-noticed for public comments.
In accordance with the EDO's July 18,1983 directive conceming " Feedback and Closure of CRGR Review", a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes. The response is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the EDO for decision making.
Questions conceming these meeting minutes should be referred to Raji Tripathi(415-7584).
Attachments: As stated cc: Commission (5) SECY M. Knapp, DEDE F. Miraglia, DEDO J. Lieberman, OE M. Springer, ADM H. Bell, OlG K. Cyr, OGC J. Larkins, ACRS H. Mille', R-l L. Reyes, R-ll J. Dyer, R-lli E. Merschoff, R-IV C. Paperiello, NMSS A. Thadani, RES S. Collins, NRR W. Kane, NMSS J. Craig, RES