NRC-2016-0192, Comment (1) of Kevin Anstee on Behalf of Entergy Nuclear Operations Inc., on Service Level I, Ii,Iii, and In-Scope License Renewal Protective Coatings Applied to Nuclear Plants
| ML16271A183 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/22/2016 |
| From: | Anstee K Entergy Nuclear Operations |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 81FR62935 00001, NRC-2016-0192 | |
| Download: ML16271A183 (6) | |
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Page 1of1
'i PUBLIC SUBMISSION Docket: NRC-2016-0192 As of: 9/22/16 3 :46 PM Received: September 22, 2016 Status: Pending_Post Tracking No. lk0-8slq-knq7 Comments Due: November 14, 2016 Submission Type: Web Service Level I, II, III and In-Scope License Renewal Protective Coatings Applied to Nuclear Power Plants Comment On: NRC-2016-0192-0001 Service Level I, II, III, and In-Scope License Renewal Protective Coatings Applied to Nuclear Power Plants; Request for Comment on Draft Regulatory Guide Document: NRC-2016-0192-DRAFT-0002 Comment on FR Doc# 2016-21956 cr/1:3/cP-C/?
g Ir.I< tcP-7 60-Submitter Information Name: Kevin Anstee Address:
Indian Point Energy Center, 450 Broadway Buchanan, NY, 10511
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10 CFR Part 50, Appendix A, GDC 4, "Environmental and Dynamic Effects Design Bases,"
requires, in part, that SSCs important to safety be designed for compatibility with the environmental conditions associated with nonnal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents.
I 0 CFR Part 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," establishes QA program requirements for the design, fabrication, construction, and testing of safety-related SSCs iri NPPs.
10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," includes safety-related SSCs that are relied on to remain functional during and following design-basis events with respect to specified functions and nonsafety-related SSCs. To the extent that protective coatings meet these criteria, these coatings are within the scope of the maintenance rule.
10 CFR 52.47, "Contents of Applications; Technical lnfonnation," requires, in part, that applications for standard design certification rules under 10 CFR Part 52 to comply with the principal design criteria in Appendix A to I 0 CFR Part 50.
l 0 CFR 52.79, "Contents of applications; technical information in final safety analysis report,"
requires, in part, that applications for combined licenses under l 0 CFR Part 52 to comply with the principal design criteria in Appendix A to 10 CFR Part 50.
I 0 CFR 52.137, "Contents of applications: technical information," requires, in part, that applications for standard design approvals for nuclear power plants under I 0 CFR Part 52 comply with the principal design criteria in Appendix A to 10 CFR Part 50, to the extent they are applicable to the scope of the design approval.
10 CFR 52.lS}~ontents of applications; technical infol'IIJ,ation in final safety analysis report,\\\\
requires that applications for manufacturing licenses for nuclear power plants under I 0 CFR Part 52 comply with the principal design criteria in Appendix A to 10 CFR Part 50.
10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants,"
establish requirements for obtaining a renewed license for operation beyond its initial 40 year operating license.
Related Guidance RG 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," (Ref. 4) provides further guidance on the maintenance rule and its requirement for each licensee to monitor the effectiveness of maintenance for protective coatings within its scope (as discrete systems or components or as part of any SSC) or to demonstrate that the performance or condition of these coatings is being effectively controlled through the performance of appropriate preventive maintenance, in accordance with 10 CFR 50.6S(a)(l) or 10 CFR 50.65(a}(2), as appropriate.
o NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," (Ref. 5) and/or NUREG-2191, "Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report,"
(Ref. 6) describes the aging management programs (AMPs) to be developed by a licensee and submitted as part of an application for license renewal. The AMP should describe how the aging DG-1331, Page 2
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reapprovcd 2008 Certify Inspection Personnel Condition Assessment of QA Practices for NPP in NPPs Coatings in NPPs ASTM D 3911-08 ASTM D 4227-05 ASTM D 3359-09c2
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reapprovcd 2012 Coating Adhesion Testing Applicator Qualification f-+
Testing by Tape Concrete Surfaces ASTM D 3912-IO ASTM D 4228-05 ASTM D 4541-09.-
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Chemical Resistance of reapproved 2012 Coating Adhesion Coatings Applicator Qualification Testing Steel Surfaces ASTM D 5162-15 ASTM D 4082-10 ASTM D 4286-08 Discontinuity Testing
~ Irradiation of Test f--... Contractor Qualification f----t-of Coating on Metallic Samples NPP Coatings Substrate ASTM D 5498-12a ASTM D 6677-07 ASTM D 5139-12 reapproved 2012 L+ Sample Preparation for
~ Development of a f----t-Knife Adhesion Coating Tests Training Program for Coating Test Coating Work Inspectors av MP\\'i wAr-J"'\\ To" ASTM D 7108-12 ASTM D 7091-13
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C. STAFF REGULATORY GUIDANCE The guidance discussed below describes practices and programs the NRC staff finds acceptable for the selection, application. qualiticntion, inspection, and maintenance of protective coatings applied to NPPs. This guidance may be applicable to Service Level I, JI, and ((( coatings as well as internal coatings and linings on components within the scope of license renewal as described in Section B of this revision (revision 3) of RG 1.54.
1.0 Use of Protective Coating Standards in Nuclear Power Plants 1.1 ASTM D 5144-0sr.* provides a common basis on which protective coatings for the surfaces of nuclear power generating facilities may be qualified and selected through reproducible evaluation tests. ASTM D 5144-0Scl should be viewed as a top-level ASTM International standard that provides detailed requirements through reference to other key ASTM International stapdards.
I 1.2 ASTM D 4538-13, "Standard Tenninology Relating to Protective Coating and Lining Work for Power Generation Facilities," (Ref. 15) defines standard terms related to protective coating and lining work for power generation facilities that the NRC staff finds acceptable and that arc also relevant to protective coatings applied to NPPs.
2.0 QA Requirements for Protective Coatings 2.1 ASTM D 3843-00 (reapproved 2008), "Standard Practice for Quality Assurance for Protective Coatings Applied to Nuclear Facilities" (Ref. 16). The ASTM International approved and issued ASTM International Standard D 3843-00 as a partial replacement for ANSI NI 01.4-1972. ASTM D 3843-00 provides QA practices that are acceptable to NRC staff and are applicable to safety related protective coating work in_ coating Service Level I areas of nuclear facilities. Service Level 11 coatings as defined above are not safety related, but they are qualified by testing for their particular application by the manufacturer. Licensees and applicants may use applicable portions '
of the QA practices described in ASTM 0 3843-00 as the basis for limited QA for protective coating work in coat~ing S~pp~~~ l~~s of nuclear facilities.
2.2 ASTM D 3911-08,'
<lard Test Method for Evaluating Coatings Used in Light-Water Nuclear Reactor Power Plan Simulated Design ccidcnt (OBA) Conditions" (Ref. 17). The ASTM International and issued ASTM D.;J 11-95 "Standard Test Method for Evaluating Coatings Used in Light-Water Nuclc* _ owcr ants at Si1t1ulatcd Design-Basis Accident (OBA)
Conditions" {Ref. 18), to rep la~
ic OBA test standard referenced in l l'll 10 l. -
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revision 0 of RO 1.54. A
, International then revised ASTM 3911-95 as ASTM D 3911-08.
Licensees and applic may use the test methods described in A 1-or eva ua mg test spcCimcris_-n ____ rofoctivc-coatiitg systems under simulated OBA conditions.
ASTM D 39
-08 also provides guidance on conditions and test apparatus for tempera * -pressure testing; on conditions for radiation testing; and on procedures for preparing.
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- mg, and evaluating samples. ASTfvl D 3911-08 docs not specify minimum acceptance c
- ria. For Service Level I coatings, the licensees or applicants should meet the following inimum acceptance criteria:
- a.
Peeling and delamination should not be pcm1itted.
- b.
Cracking should not be considered a failure unless it is accompanied by dclamination or loss of adhesion.
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3.0 Training and Qualification of Nuclear Coating Specialists, Protective Coatin Inspectors, '/
and Coating Applicators 3.1 ASTM D 4537-12, "Standard Guide for Establishing Procedures to Qualify a d Certify Personnel Performing Coating and Lining Work Inspection in Nuclear facilities," (Ret: 22) offers guidance that the NRC staff finds acceptable on the qualification and certification of p so
- nspect protective coatings in nuclear facilities. This standard provides guidance on he in ction ol the education, training, experience, qualifications, and certification of Service Levell, ll, and lll coatings inspectors.
3.2 ASTM D 4227-05 (reapprovcd in 2012), "Standard Practice for Qualification of Coating Applicators for Application ofCoatings\\to Concrete Surfaces," (Ref. 23) provides guidance that the NRC staff finds acceptable for the qualification of coating applicators to verify that they arc proficient and can attain the quality required for the application of specified coatings to concrete surfaces, including those in a nuclear facility.
3.3 ASTM D 4228-05 (rcapproved in 2012), "Standard Practice for Qualification of Coating Applicators for Application of Coatings to Steel Surfaces," (Ref. 24) provides guidance that the NRC staff finds acceptable for the qualification of coating applicators to vcri fy that they arc proficient and can attain the quality required for applying specified coatings to steel surfaces, including those in a nuclear facility.
3.4 ASTM D 4286-08, "Standard Practice for Determining Coating Contractor Qualifications for Nuclear Powered Electric Generation Facilities," (Ref. 25) offers criteria and methods that the NRC staff finds acceptable to assist utility owners, architects, engineers, and contractors in detennining the overall qualifications of a coating contractor to perform coating work for the primary containment and other safety-related facilities of NPPs. The criteria and requirements for coating contractors address their capabilities to perfonn nuclear coating work.
3.5 ASTM D 5498-12a, "Standard Guide for Developing a Training Program for Personnel Performing Coating Work Inspection for Nuclear Facilities," (Ref. 26) provides guidance that the NRC staff finds acceptable for developing a training program for personnel who perform coating work inspection at nuclear facilities.
3.6 ASTM D 7108-12, "Standard Guide for Establishing Qualifications for a Nuclear Coatings Specialist," (Ref. 27) provides guidance thnt the NRC staff finds acceptable for establishing qualifications for a nuclear coatings specialisl A nuclear coatings specialist should meet one of the combinations of qualification attributes provided in Table 2 of ASTM D 7108-12 prior to performing inspections at nuclear facilities.
4.0 Maintenance of Coatings 4.1 ASTM D 5163-08, "Standard Guide for Establishing a Program for Condition Assessment of Coating Service Level I Coating Systems in Nuclear Power Plants," (Ret: 28) provides guidelines the NRC staff finds acceptable for establishing an in-service coating monitoring program for Service Level I coating systems in operating NPPs and for Service Leyel H and other ureas outside containment (us applicable) with the following conditions:
- a.
Licensees should establish an acceptable condition assessment program using qualified personnel and should perfonn condition assessments over a time interval that would
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DG-1331, Page 10
4.9 4.10 5.0 5.1 5.2 ASTM D 7234-12, "Standard Test Method for Pull-Off Adhesion Strength ofCo'1tings on Concrete Using Portable Pull-Off Adhesion Testers" (Re[ 36). provides guidance that the NRC staff finds acceptable for a test method used to evaluate the pull-off strength of co'1tings on concrete using portable pull-off adhesion testers.
ASTM D 7491-08,(re'1pproved 2015) "Standard Guide for Management ofNon-Confonning Coatings in Coating Service Level I Areas of Nuclear Power Plants," (Ref. 37) offers guidance that the NRC staff finds acceptable for managing nonconforming-coatings within the Service Levell areas ofa NPP.
112..- \\ 0 9. 931 Electric Power R arch Institute (EPRI) Report No. 1019157, "Guideline on Nuclear Safe -Reial oatings," Revision 2, issued December 2009 (formerly EPRI Topical Report Nos. 10993 and I 003102), (Ref. 38) provides additional information on the selection, application, inspection, and maintenance of safoty-related protective coatings applied to NPPs.
EPRI Report No. 1019157 discusses, in detail, the important considerations related to protective coatings and can be used to supplement the ASTM International standards as deemed necessary.
The NRC staff approves the use ofEPRI Report No. 1019157 with the exception of Section 3.4.2, which discusses the application of specialized coatings for restoring the structural integrity of a component. The NRC staff does not approve the use of specialized coatings for restoring
- structural integrity.
Thermal conductivity is a material property of a coating system that is used in evaluating NPP containment performance. In particular, it is used in calculations of containment peak temperature and pressure for accident analyses. The applicable regulatory requirements and guidance used to evaluate NPP containment performance can be found in the following:
10 CFR Part 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors";
10 CFR Part 50, Appendix A, GDCs 38 and 50; I 0 CFR Part 50, Appendix K; and NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: L WR Edition," (Ref. 39) Sections 6.1.2, 6.2.1, 6.2. I. I.A, 6.2.1.1.C, and 6.2.1.5.
EPRI Report No. 1019157 provides further discussion on the significance ofthennal conductivity of coating systems. ASTM D 5 I 44-08c1 lists test methods for determining thermal conductivity of a coating and a table of thermal conductivity values for coatings used in NPP containments. The coating types and the thermal conductivity values provided in the table are described as "typical."
The NRC staff accepts the use of ASTM D 5144-081:1 for thermal conductivity with the following exceptions:
In reviews of activities involving safety-related coatings, the staff may find it acceptable to determine thermal conductivity by methods other than those listed in ASTM D 5144-08&1 if adequate technical justi ti cation is provided.
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