ML18016A711

Forwards 120-day Response to GL 98-04, Potential for Degradation of ECCS & CSS After LOCA Because of Construction & Protective Coating Deficiencies & Foreign Matl in Containment.

ML18016A711
Person / Time
Site:	Harris
Issue date:	11/09/1998
From:	Scarola J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-98-04, GL-98-4, HNP-98-155, NUDOCS 9811160130
Download: ML18016A711 (9)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTIO SYSTEM (RIDS)ACCESSION NBR:9811160130 DOC.DATE: 98/11/09 NOTARIZED:

YES FACIL:5Q-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH'.P~AML, AUTHOR AFFILIATION SCAROLA,J'arolina Power 6 Light Co.RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document.Control Desk)DOCKET I 05000400

SUBJECT:

Forwards 120-day response to GL 98-04,"Potential Degradation of ECCS&CSS After LOCA Because of Construction Protective Coating Deficiencies E Foreign Matl in Containment." A DISTRIBUTION CODE: A080D COPIES RECEIVED:LTR ENCL SIZE: T TTTLE: Generic Letter 98-04-Potential for the Degradation of the Emergency NOTESApplication for permit renewal filed.05000400 G RECIPIENT ID CODE/NAME FLANDERS,S INTERNA R 01 NRR/DSSA SC EXTERNAL: NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME NRR/DE/EMCB COPIES LTTR ENCL 1 1 D 0 U N NOTE TO ALE"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 5 ENCL 5 f0d" j P r 8~Q i 4, I~'I r',~f JP;r Carolina Power&Light Company PO Box 165 New Hill NC 27562 James Scarola Vice President Harris Nuclear Plant NOV-9 1998 SERIAL: HNP-98-155 10 CFR 50.54(f)United States Nuclear Regulatory Commission ATI'ENTION:

Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO.50-400/LICENSE NO.NPF-63 120-DAY RESPONSE TO NRC GENERIC LETI'ER 98-04,"POTENTIAL FOR DEGRADATION OF THE EMERGENCY CORE COOLING SYSTEM AND THE CONTAINMENT SPRAY SYSTEM AFTER A LOSS-OF-COOLANT ACCIDENT BECAUSE OF CONSTRUCTION AND PROTECTIVE COATING DEFICIENCIES AND FOREIGN MATERIAL IN CONTAINMENT"

Dear Sir or Madam:

This letter responds to NRC Generic Letter 98-04,"Potential for Degradation of the Emergency Core Cooling System and the Containment Spray System After a Loss-of-Coolant Accident Because of Construction and Protective Coating Deficiencies and Foreign Material in Containment," for the Harris Nuclear Plant (HNP).Genetic Letter 98-04, dated July 14, 1998, requested each licensee provide a written report within 120 days of the date of the Generic Letter that includes a discussion of the plant-specific program implemented to ensure that Service Level 1 protective coatings used inside the containment are procur:d, applied and maintained in compliance with applicable regulatory requirements and the plant-specific licensing basis.In addition, licensees are requested to provide information regarding tracking the amount of unqualified coatings inside the containment and assessing the impact of potential coating debits during a postulated design-basis loss-of-coolant accident.A wiitten report providing the requested information for HNP is provided in the Enclosure to this letter.Please refer any questions regarding this submittal to Mr.J.H.Eads at (919)362-2646.Sincen:ly,)035'P8iii60i30 98ifQ'Fl PDR ADGCK 05000400 P PDR 5dl 3 Shearon Harris Road New Hill, NC Tel 919 362-2502 Fax 919 362-2095 Document Control Desk SERIAL: HNP-9,8-155 Page 2 AEC/aec Enclosure James Scarola, havirig been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief;and the sources of his information are employees, contractors, and agents of Carolina Power&Light Company.My commission expires: P-Q-+~c: Mr.J.B.Brady (NRC Senior Resident Inspector)

Mr.L.A.Reyes (NRC Regional Administrator, Region II)Mr.S.C.Flanders (NRR Project Manager, HNP)Notary e)~g<Qf SFdggp~gorAa)+a~.aK~si:g 6)j<tsitcpst<<

Enclosure to Serial: HNP-98-155 Page 1 of 4 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO.50-400/LICENSE NO.NPF-63 120-DAY RESPONSE TO NRC GENERIC LETI'ER 98-04,"POTENTIAL FOR DEGRADATION OF THE EMERGENCY CORE COOLING SYSTEM AND THE CONTAINMENT SPRAY SYSTEM AFTER A LOSS-OF-COOLANT ACCIDENT BECAUSE OF CONSTRUCTION AND PROTECTIVE COATING DEFICIENCIES AND FOREIGN MATERIAL IN CONTAINMENT" Generic Letter 98-04, dated July 14, 1998, requested each licensee provide a written report within 120 days of the date of the Generic Letter.For the Harris Nuclear Plant (HNP), Carolina Power&Light Company (CP&L)provides the requested information below.Re nested Item 1 A summary description of the plant-specific program or programs implemented to ensure that Service Level 1 protective coatings used inside the containment are procured, applied and maintained in compliance with applicable regulatory requirements and the plant-specific licensing basis for the facility.Include a discussion of how the plant-specific program meets the applicable criteria of 10 CFR Part 50, Appendix B, as well as information regarding any applicable standards, plant-specific procedures or other guidance used for: (a)controlling the procurement of coatings and paints used at the facility, (b)the qualification testing of protective coatings, and (c)surface preparation, application, surveillance, and maintenance activities for protective coatings.Maintenance activities involve reworking degraded coatings, removing degraded coatings to sound coatings, correctly preparing the surfaces, applying new coatings, and verifying the quality of the coatings.Res onse to Re nested Item 1 HNP has implemented controls for the procurement, application, and maintenance of Service Level 1 protective coatings used inside the containment in a manner that is consistent with the licensing basis and regulatory requirements applicable to HNP.The requirements of 10 CFR 50 Appendix B are implemented through specification of appropriate technical and quality requirements for the Service Level 1 coatings program which includes ongoing maintenance activities.

As specified in HNP Final Safety Analysis Report (FSAR)Sections 1.8 and 3.8.1.2, Service Level 1 coatings at HNP are subject to the requirements of ANSI N101.2-1972,"Protective Coatings (Paints)for Light Water Nuclear Reactor Containment Facilities," ANSI N101.4-1972,"Quality Assurance for Protective Coatings Applied to Nuclear Facilities," ANSI N512-1974,"Protective Coatings (Paints)for the Nuclear Industry," and NRC Regulatory Guide 1.54, Revision 0,"Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants." Adequate assurance that the applicable requirements for the procurement, application, inspection, and maintenance are implemented is provided by procedures and programmatic controls, approved under the HNP Quality Assurance Program.HNP has considered the guidance provided in EPRI TR-109937,"Guideline on Nuclear Safety-Enclosure to Serial: HNP-98-155 Page2of 4 Related Coatings" and has made appropriate improvements to existing HNP programs and procedures for Service Level 1 coatings.(a)Service Level 1 coatings used for new applications or repair/replacement activities are procured from vendors with quality assurance programs meeting the applicable requirements of 10 CFR 50 Appendix B.The applicable technical and quality requirements that the vendors are required to meet are specified in HNP procurement documents.

Acceptance activities are conducted in accordance with procedures that are consistent with ANSI N 45.2-1971,"Quality Assurance Program Requirements for Nuclear Power Plants" requirements (e.g., receipt inspection, source surveillance, etc.).This specification of required technical and quality requirements, combined with appropriate acceptance activities, provides adequate assurance that the coatings received meet the requirements of the procurement documents.(b)The qualification testing of Service Level 1 coatings used for new applications or repair/replacement activities inside containment meets the applicable requirements contained in the standards and regulatory commitments referenced above.The exception to these qualified Service Level 1 coatings are unqualified coatings that are applied in limited quantities inside containment.

These un'qualified coatings are tracked by the use of an unqualified coatings log that is maintained as a permanent plant record.Unqualified coating quantities are documented in this log only after the coating surface areas have been prepared and coated in the best possible manner using manufacturer recommendations and industry standards as guidelines.(c)The surface preparation, application and surveillance during installation of Service Level 1 coatings used for new applications or repair/replacement activities inside containment meet the applicable portions of the standards and regulatory commitments referenced above.Documentation of completion of these activities is performed consistent with the applicable requirements.

Where the requirements of the standards and regulatory commitments did not address, or were not applicable to, repair/replacement activities, these activities were performed in a manner consistent with the generally accepted practices for coatings repair/replacement.

These practices are described in various ASTM standards and coating practice guidelines by industry organizations issued subsequent to those that HNP has a regulatory commitment.

It is recognized that the NRC has not formally endorsed many of the more recent ASTM standards or industry guidelines.

Nonetheless, these standards and guidelines provide useful information which can be appropriately applied to assure that repair/replacement activities on Service Level 1 coatings are effective in maintaining the acceptability of the coatings.HNP invokes the quality assurance criteria requirements utilized in ANSI N101.4 to Service Level 1 protective coating installations.

The utilization of these ANSI criteria provides an adequate basis for complying with the peitinent quality assurance requirements of 10 CFR 50 Appendix B, as described in NRC Regulatory Guide 1.54.HNP routinely conducts condition assessments of Service Level 1 coatings inside containment.

Coating condition assessments are conducted as part of HNP's periodic Enclosure to Serial: HNP-98-155 Page3of 4~, maintenance program that requires a Service Level 1 coating assessment walkdown every refueling outage.These walkdowns encompass a floor by floor inspection of both concrete and steel suiface areas.As localized areas of degraded coatings are identified, those areas are evaluated and scheduled for repair or replacement, as necessary.

The peiiodic condition assessments, and the resulting repair/replacement activities, assure that the amount of Service Level 1 coatings which may be susceptible to detachment from the substrate during a loss-of-coolant accident (LOCA)event is minimized.

Re uested Item 2 Information demonstrating compliance with item (i)or item (ii): (i)For plants with licensing-basis requirements for tracking the amount of unqualified coatings inside the containment and for assessing the impact of potential coating debris on the operation of safety-related SSCs during a postulated DB LOCA, the following information shall be provided to demonstrate compliance: (a)The date and findings of the last assessment of coatings, and the planned date of the next assessment of coatings.(b)The limit for the amount of unqualified protective coatings allowed in the containment and how this limit is determined.

Discuss any conservatism in the method used to determine this limit.(c)If a commercial-grade dedication program is being used at your facility for dedicating commercial-grade coatings for Service Level 1 applications inside the containment, discuss how the program adequately qualifies such a coating for Service Level 1 service.Identify which standards or other guidance are currently being used to dedicate containment coatings at your facility;or, (ii)For plants without the above licensing-basis requirements, information shall be provided to demonstrate compliance with the requirements of 10 CFR 50.46b(5),"Long-term cooling" and the functional capability of the safety-related CSS as set forth in your licensing basis.If a licensee can demonstrate this compliance without quantifying the amount of unqualified coatings, this is acceptable.

The following information shall be provided: (a)If commercial-grade coatings are being used at your facility for Service Level 1 applications, and such coatings are not dedicated or controlled under your Appendix B Quality Assurance Program, provide the regulatory and safety basis for not controlling these coatings in accordance with such a program.Additionally, explain why the facility's licensing basis does not require such a program.

Enclosure to Serial: HNP-98-155 Page 4 of 4 R s onsetoRe uested Item2 i As stated in HNP FSAR Section 1.8, Regulatory Guide 1.54, Revision 0, endorses ANSI N101.4-1972.HNP complies with the requirements of ANSI N101.4-1972, as it is endorsed by this regulatory guide (Revision 0)for protective coatings for containment surfaces (steel and concrete)and exposed surfaces of large equipment and pipe.ANSI N101.4-1972 notes"that any significant deviation or defective work and the recommended coiTective action shall be recorded by the coating inspection agency on a coating exception record." This coating exception record requirement is fulfilled at HNP by the maintenance of an unqualified coatings log.As stated in HNP FSAR Section 6.2.2.2,"Piping and equipment insulation is considered to be the primary source of post accident debris inside Containment which could potentially clog the sump screening.

The possibility of paint chips peeling off has been minimized by requiring proper surface preparation and by painting larger surface components with coatings which have been qualified under design basis accident condition." HNP's unqualified coatings have been prepared and coated in the best possible manner using manufacturer recommendations and industry standards as guidelines.(a)The latest coatings condition assessment was performed during the HNP Refueling Outage (RFO)7 in April-May 1997.Several areas on the containment concrete floors were identified as requiiing repairs.Coating upgrades were performed on several structural steel surfaces and piping valves.Degraded coatings identified in the RFO 7 assessment were repaired and documented in accordance with plant procedures.

The next coatings condition assessment at HNP is scheduled for RFO 8 in October-November 1998.(b)The limit for unqualified coatings at HNP has not been documented.

No limit was established duiing initial plant licensing.

Piping and equipment insulation is considered to be the primary source of post accident debris inside containment which could potentially clog the sump screening.

The possibility of paint chips peeling off has been minimized by requiring proper surface preparation and by painting larger components with coatings which have been design-basis accident qualified.

HNP's unqualified coatings have been prepared and coated in the best possible manner using manufacturer recommendations and industry standards as guidelines.

The possibility of establishing a limit for unqualified coatings in containment at HNP is currently being evaluated.(c)HNP does not currently employ commercial grade dedication for Service Level 1 coatings used inside containment at HNP.

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