ML20214R377

Requests Info Re FSAR (NUREG-0797,Suppl 9) Eliminating Commitment That Coatings Inside Containment Bldg Be Qualified for Plant

ML20214R377
Person / Time
Site:	Comanche Peak
Issue date:	10/21/1986
From:	Guzman G MEXICO, GOVT. OF
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20214R357	List: ML20214R377
References
RTR-NUREG-0797, RTR-NUREG-797 NUDOCS 8612050447
Download: ML20214R377 (4)

Text

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instituto nacional de investigaciones nucleares L OhTOBER 21,1986.

I HEAD OF THE DIVISION OF LICENSING OFFICE OF NUCLEAR REGULATION U.S. NUCLEAR REGULATORY COMMISSION, WA'SHINGTON,'D.C. 20555 U.S.A.

TO WHOM IT MAY CONCERN:

WITH RESPECT TO THE U.S. REGULATORY ACTION FOR THE COMAN-CHE PEAK PROJECT BASED ON THE FINAL SAFETY ANALYSIS . REPORT

( NUREG-0797-SUPPL.9, MARCH 1985 ) TO ELIMINATE THE COMMITMENT THAT C0ATINGS INSIDE THE CONTAINMENT BUILDING BE QUALIFIED .FOR UNITS 1 AND 2, I WOULD LIKE TO ASK THE FOLLOWING QUESTIONS i.

1. SHOULD THE STAFFS OF THE NRC AND TUEC HAVE NOT TAKEN INTO ACCOUNT THE APPROVAL OR OPINION OF THE ASTM COMMITTEE D-1 AND D-33 ?

2. SHOULD " THE COST OF SAFETY RELATED C0ATED SYSTEMS AND THE REDUCE LEVEL OF THE NEW PLANT CONSTRUCTION AND THEREFORE ORDERS FOR C0ATING BE AN IMPORTANT OR DECISIVE FACTOR IN -

LOWERING OR NOT USING THE C0ATING QUALIFICATION STANDARDS

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AND THEREFORE THE QUALITY ASSURANCE PROGRAM" ?

3. WOULD YOU CONSIDER THAT A THEORETICAL ANALYSIS OF WHAT IS OR IS NOT LIKELY TO HAPPEN DUE TO PAINT DEBRIS INSIDE THE NUCLEAR POWER STATION, CAN SUBSTITUTE FOR ACTUAL TESTING DR OK 5 5

.2-instituto nacional de investigaciones nucleares 0F BLOCKAGE IN SUMPS OR FLOW PASSAGES DURING A DBA AND -

POST-DBA CONDITIONS ?

4. SHOULD THE CONTAMINATION AND DECONTAMINATION OF A C0ATING FROM FISSION PRODUCTS, NOT BE CONSIDERED AS PART OF NUCLEAR SAFETY AND THEREFORE FOR QUALITY ASSURANCE PROGRAM AND QUALIFICATION TESTS ?

5. SHOULD NUCLEAR PLANT MANAGEMENT BE WELL ADVISED TO FOLLOW

" THE PATTERN USED AT COMANCHE PEAK.TO EVALUATE THE~ SAFETY SIGNIFICANCE .0F CONTAINMENT FAILURE. ." ?

i

6. DOES THE DIVISION OF LICENSING OF THE US NRC CONSIDER THAT

[ A C0ATING IS SUFFICIENTLY QUALIFIED UPON COMPLYING ONLY i WITH THE REQUIREMENTS OF THE REGULATORY GUIDE NRC RG 1,54 AND THE STANDARD ANSI 101.2 ?.

4 WHAT IMPORTANCE SHOULD BE GIVEN TO ELEMENT UNMENTIONED IN THE AB0VE SUCH AS THE FOLLOWING :

6.1 MANUAL OF C0ATING WORK FOR LIGHT-WATER NUCLEAR POWER

PLANT PRIMARY CONTAINMENT AND OTHER - RELATED FACILITIES ASTM, 1979.

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6.2 GUIDE FOR SELECTION OF IESTING COATINGS USED IN LIGHT

- WATER NUCLEAR POWER PLANTS, ASTM D 3842 - 80 4

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6.3 AGEING :

6.3.1 LIGHT AND TEMPERATURE : ASTM D 822-60 6.3.2 WEAR AND MECHANICAL STRESS ASTM G 14-77 FTMS 141 6.3.3 GAMMA RADIATION, ANSI N 512-74 6.3.4 CHEMICAL RESISTANCE OF COATINGS USED IN LIGHT WATER NUCLEAR POWER PLANTS, ASTM D 3912-80.

6.4 DBA 6.4.1 RADIATION IEST : ANSI N 512-74 6.4.2 STEAM IEST: ' EVALUATING COATINGS USED IN LIGHT WATER NUCLEAR POWER PLANTS AT SIMULATED TOSS OF COOLANT ACCIDENT ( LOCA ) CONDITIONS" ASTM D 3911 - 80.

6.5 POST-DBA 6.5.1 "ETERMINATION OF THE DECONTAMINABILITY OF COATINGS USED IN LIGHT-WATER NUCLEAR POWER PLANTS" ASTM D 4256,

7. SHOULD SEQUENCE OF THE TESTS MENTIONED ABOVE " FOLLOW A SPECIFIC PATTERN ?

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8. WHEN DO YOU CONSIDER THf.T A C0ATING IS OUALIFIED AND WHEN IT IS NOT NECESSARY. ?

, . . ~

instituto nacional de investigaciones nucleares

9. WHAT.IS THE PROCEDURE OR THE REQUIREMENTS TO UPDATE THE.

REGULATORY GUIDE NRC RG 1.5f4.?

! WHILE PERHAPS, THE STUDIES CARRIED OUT AT THE COMANCHE i PEAK, HAVING BEEN CONVINCINGLY JUSTIFIED IN THEIR PARTICULAR i CIRCUNSTANCES, HERE, WHERE NUCLEAR ENERGY IS JUST BEING INITIATED, THEY HAVE PROV0KED GREAT CONFUSION, DOUBTS AND CONTROVERSY-ABOUT THE IMPORTANCES OF QUALITY ASSURANCE AND

. EQUIPMENT -AND MATERI AL QUALIFICATION -FOR A NUCLEAR POWER STATION FOR THAT REASON I WOULD GREATLY' APPRECIATE AN ANSWER TO THIS LETTER.

IN AUGUST 1986 I DIRECTED FSSENTIALLY THE SAME INQUIRY TO MR VINCENT S. N0ONAN WHO I NOW UNDERSTAND WAS NOT THE PERSON TO WHOM THE LETTER SHOULD HAVE BEEN SENT.

HOPING TO RECEIVE YOUR KIND CONSIDERATION TO MY INQUIRY AT AN EARLY DATE.

SINCE3EL-Y YOIJRS 7

UI RMO 4N GERE CI A DE MATERIALES COPY TO :

- ASTM COMMITTEE D-1 AND D-33: AMERICAN SOCIETY FOR TESTING AND MATERI ALS,1916 RACE ST. , PHILADELPHI A, PA.19103, U.S. A.

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