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'''XI.M42 INTERNAL COATINGS/LININGS FOR IN-SCOPE PIPING, PIPING | '''XI.M42 INTERNAL COATINGS/LININGS FOR IN-SCOPE PIPING, PIPING | ||
COMPONENTS, HEAT EXCHANGERS, AND TANKS''' | COMPONENTS, HEAT EXCHANGERS, AND TANKS''' | ||
'''Program Description''' | '''Program Description''' |
Latest revision as of 20:59, 4 October 2024
XI.M42 INTERNAL COATINGS/LININGS FOR IN-SCOPE PIPING, PIPING
COMPONENTS, HEAT EXCHANGERS, AND TANKS
Program Description
Proper maintenance of internal coatings/linings is essential to provide reasonable assurance that the intended functions of in-scope components are met. Degradation of coatings/linings can lead to loss of material or cracking of base materials and downstream effects such as reduction in flow, reduction in pressure, or reduction of heat transfer when coatings/linings become debris. The program consists of periodic visual inspections of internal coatings/linings exposed to closed-cycle cooling water (CCCW), raw water, treated water, treated borated water, waste water, fuel oil, and lubricating oil. Where the visual inspection of the coated/lined surfaces determines that the coating/lining is deficient or degraded, physical tests are performed, where physically possible, in conjunction with the visual inspection. Electric Power Research Institute (EPRI) Report 1019157, “Guideline on Nuclear Safety-Related Coatings,” provides information on the American Society for Testing and Materials (ASTM) standard guidelines and coatings. American Concrete Institute (ACI) Standard 201.1R, “Guide for Conducting a Visual Inspection of Concrete in Service,” provides guidelines for inspecting concrete. In addition, this program may be used to manage aging effects associated with coatings on external surfaces.
Evaluation and Technical Basis
- 1. Scope of Program: The scope of the program is internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks exposed to CCCW, raw water, treated water, treated borated water, waste water, fuel oil, and lubricating oil where loss of coating or lining integrity could prevent satisfactory accomplishment of any of the component’s or downstream component’s current licensing basis (CLB) intended functions identified under Title 10 of the Code of Federal Regulations (10 CFR) 54.4(a)(1), (a)(2), or (a)(3). The aging effects associated with fire water tank internal coatings/linings are managed by Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report aging management program (AMP) XI.M27, “Fire Water System,” instead of this AMP. However, where the fire water storage tank internals are coated, the Fire Water System Program and Final Safety Analysis Report (FSAR) Summary Description of the Program should be enhanced to include the recommendations associated with training and qualification of personnel and the “corrective actions” program element. The Fire Water System Program should also be enhanced to include the recommendations from the “acceptance criteria” program element.
- If a coating/lining has a qualified life, and it will be replaced prior to the end of its qualified life without consideration of extending the life through condition monitoring, it would not be considered long lived and therefore, it would not be within the scope of this AMP.
- Coatings/linings are an integral part of an in-scope component. The CLB-intended function(s) of the component dictates whether the component has an intended function(s) that meets the scoping criteria of 10 CFR 54.4(a). Internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks are not evaluated as standalone components to determine whether they meet the scoping criteria of 10 CFR 54.4(a). It is immaterial whether the coating/lining has an intended function identified in the CLB because it is the CLB-intended function of the component that dictates whether the component is in-scope and thereby the aging effects of the coating/lining integral to the component must be evaluated for potential impact on the component’s and downstream component’s intended function(s).
- An applicant may elect to manage the aging effects for internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks in an alternative AMP that is specific to the component or system in which the coatings/linings are installed (e.g., GALL-SLR Report AMP XI.M20, “Open-Cycle Cooling Water System,” for service water coatings/linings) as long as the following are met:
- The recommendations of this AMP are incorporated into the alternative program.
- Exceptions or enhancements associated with the recommendations in this AMP are included in the alternative AMP.
- The FSAR supplement for this AMP as shown in the GALL-SLR Report Table XI-01, “FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging Management Programs,” is included in the application with a reference to the alternative AMP.
- For components where the aging effects of internally coated/lined surfaces are managed by this program, loss of material, cracking, and loss of material due to selective leaching need not be managed for these components by another program.
- This program may be used to manage aging effects associated with external surfaces [e.g., Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR) Section 3.2.2.2.2]. When the external coatings are credited to isolate the external surface of a component from the environment, the following recommendations are met as noted.
- 2. Preventive Actions: The program is a condition monitoring program and does not recommend any preventive actions. However, external coatings can be credited as a preventive action based on the coating isolating the external surfaces of a component from the environment.
- 3. Parameters Monitored or Inspected: Visual inspections are intended to identify coatings/linings that do not meet acceptance criteria, such as peeling and delamination. Aging mechanisms associated with coatings/linings are described as follows:
- Blistering–formation of bubbles in a coating/lining
- Cracking–formation of breaks in a coating/lining that extend through to the underlying surface
- Flaking–detachment of pieces of the coating/lining itself either from its substrate or from previously applied layers
- Peeling–separation of one or more coats or layers of a coating/lining from the substrate
- Delamination–separation of one coat or layer from another coat or layer, or from the substrate
- Rusting–corrosion of the substrate that occurs beneath or through the applied coating/lining
- Loss of material and cracking is managed for cementitious materials. See the term “Cracking due to chemical reaction, weathering, settlement, or corrosion of reinforcement (reinforced concrete only); loss of material due to delamination, exfoliation, spalling, popout, scaling, or cavitation,” in the GALL-SLR Report Chapter IX.F.
- Physical damage consists of removal or reduction of the thickness of coating/lining by mechanical damage. For the purposes of this AMP, this would include damage such as that which could occur downstream of a throttled valve as a result of cavitation or erosion. It does not include physical damage caused by actions such as installing scaffolding or assembly and disassembly of flanged joints.
- Physical testing is intended to identify the extent of potential degradation of the coating/lining.
- 4. Detection of Aging Effects: If a baseline has not been previously established, baseline coating/lining inspections occur in the 10-year period prior to the subsequent period of extended operation. Subsequent inspections are based on an evaluation of the effect of a coating/lining failure on the in-scope component’s intended function, potential problems identified during prior inspections, and known service life history. Subsequent inspection intervals are established by a coating specialist qualified in accordance with an ASTM International standard endorsed in Regulatory Guide (RG) 1.54. However, inspection intervals should not exceed those in Table XI.M42-1, “Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers.”
- The extent of baseline and periodic inspections is based on an evaluation of the effect of a coating/lining failure on the in-scope component’s intended function(s), potential problems identified during prior inspections, and known service life history; however, the extent of inspection is not any less than the following for each coating/lining material and environment combination.
- All tanks–all accessible internal surfaces (and external surfaces when credited to isolate the external surfaces of a component from the environment).
- All heat exchangers–all accessible internal surfaces (and external surfaces when credited to isolate the external surfaces of a component from the environment.)
- Piping–either inspect a representative sample of seventy-three 1-foot axial length circumferential segments of piping or 50 percent of the total length of each coating/lining material and environment combination, whichever is less at each unit. The inspection surface includes the entire inside (or outside when applicable) surface of the 1-foot sample. If geometric limitations impede movement of remote or robotic inspection tools, the number of inspection segments is increased in order to cover an equivalent of seventy-three 1-foot axial length sections. For example, if the remote tool can only be maneuvered to view one-third of the inside surface, 219 feet of pipe is inspected.
Table XI.M42-1. Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers1, 6 | |
---|---|
Inspection Category2 | Inspection Interval |
A | 6 years3 |
B4,5 | 4 years |
|
- Where documentation exists that manufacturer recommendations and industry consensus documents (i.e., those recommended in RG 1.54, or earlier versions of those standards) were complied with during installation, the extent of piping inspections may be reduced to the lesser of twenty-five 1-foot axial length circumferential segments of piping or 20 percent of the total length of each coating/lining material and environment combination at each unit.
- For multiunit sites where the piping sample size is not based on the percentage of the population, it is acceptable to reduce the total number of inspections at the site as follows:
- For two-unit sites, fifty-five 1-foot axial length sections of piping (19 if manufacturer recommendations and industry consensus documents were complied with during installation) are inspected per unit.
- For a three-unit site, forty-nine 1-foot axial length sections of piping (17 if manufacturer recommendations and industry consensus documents were complied with during installation) are inspected per unit.
- In order to conduct the reduced number of inspections, the applicant states in the subsequent license renewal application the basis for why the operating conditions at each unit are similar enough (e.g., flowrate, temperature, excursions) to provide representative inspection results.
- The coating/lining environment includes both the environment inside (and outside when applicable) the component and the metal to which the coating/lining is attached.
- Inspection locations are selected based on susceptibility to degradation and consequences of failure.
- Coating/lining surfaces captured between interlocking surfaces (e.g., flange faces) are not required to be inspected unless the joint has been disassembled to allow access for an internal coating/lining inspection or other reasons. For areas not readily accessible for direct inspection, such as small pipelines, heat exchangers, and other equipment, consideration is given to the use of remote or robotic inspection tools.
- Either of the following options [i.e., item (a) or (b)] is an acceptable alternative to the inspections recommended in this AMP for internal coatings when all of the following conditions exist:
- Loss of coating or lining integrity cannot result in downstream effects such as reduction in flow, drop in pressure, or reduction of heat transfer for in-scope components,
- The component’s only CLB intended function is leakage boundary (spatial) or structural integrity (attached) as defined in SRP-SLR Table 2.1-4(b),
- The internal environment does not contain chemical compounds that could cause accelerated corrosion of the base material if coating/lining degradation resulted in exposure of the base metal,
- The internal environment would not promote microbiologically influenced corrosion of the base metal,
- The coated/lined components are not located in the vicinity of uncoated components that could cause a galvanic couple to exist, and
- The design for the component did not credit the coating/lining (e.g., the corrosion allowance was not zero).
- A representative sample of external wall thickness measurements can be performed every 10 years commencing 10 years prior to the subsequent period of extended operation to confirm the acceptability of the corrosion rate of the base metal. For heat exchangers and tanks, a representative sample includes 25 percent coverage of the accessible external surfaces. For piping, a representative sample size is defined above.
- In lieu of external wall thickness measurements, use GALL-SLR Report AMP XI.M36, “External Surfaces Monitoring of Mechanical Components,” and GALL-SLR Report AMP XI.M38, “Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components,” or other appropriate internal surfaces inspection program (e.g., GALL-SLR Report AMP XI.M20, AMP XI M21A) to manage loss of coating or lining integrity.
- In addition, where loss of internal coating or lining integrity cannot result in downstream effects such as reduction in flow, drop in pressure, or reduction of heat transfer for in-scope components, a representative sample of external wall thickness measurements can be performed every 10 years commencing 10 years prior to the subsequent period of extended operation to confirm the acceptability of the corrosion rate of the base metal in lieu of visual inspections of the coatings/linings. For heat exchangers and tanks, a representative sample includes 25 percent coverage of the accessible external surfaces. For piping, a representative sample size is described above.
- The training and qualification of individuals involved in coating/lining inspections and evaluating degraded conditions is conducted in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with a particular standard, except for cementitious materials. For cementitious coatings/linings inspectors should have a minimum of 5 years of experience inspecting or testing concrete structures or cementitious coatings/linings or a degree in the civil/structural discipline and a minimum of 1 year of experience.
- 5. Monitoring and Trending: A preinspection review of the previous two inspections, when available (i.e., two sets of inspection results may not be available to review for the baseline and first subsequent inspection of a particular coating/lining location), is conducted that includes reviewing the results of inspections and any subsequent repair activities. A coatings specialist prepares the post-inspection report to include: a list and location of all areas evidencing deterioration, a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where repair can be postponed to the next refueling outage, and where possible, photographic documentation indexed to inspection locations.
- Where practical, (e.g., wall thickness measurements, blister size and frequency), degradation is projected until the next scheduled inspection. Results are evaluated against acceptance criteria to confirm that the sampling bases (e.g., selection, size, frequency) will maintain the components’ intended functions throughout the subsequent period of extended operation based on the projected rate and extent of degradation.
- 6. Acceptance Criteria: Acceptance criteria are as follows:
- There are no indications of peeling or delamination.
- Blisters are evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate. Blister size or frequency should not be increasing between inspections (e.g., ASTM D714-02, “Standard Test Method for Evaluating Degree of Blistering of Paints”).
- Indications such as cracking, flaking, and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard.
- Minor cracking and spalling of cementitious coatings/linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.
- As applicable, wall thickness measurements, projected to the next inspection, meet design minimum wall requirements.
- Adhesion testing results, when conducted, meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coating/lining and substrate.
- 7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in the applicant’s corrective action program under those specific portions of the quality assurance (QA) program that are used to meet Criterion XVI, “Corrective Action,” of 10 CFR 50, Appendix B. Appendix A of the GALL-SLR Report describes how an applicant may apply its 10 CFR 50, Appendix B, QA program to fulfill the corrective actions element of this AMP for both safety-related and nonsafety-related structures and components (SCs) within the scope of this program.
- Coatings/linings that do not meet acceptance criteria are repaired, replaced, or removed. Physical testing is performed where physically possible (i.e., sufficient room to conduct testing) or examination is conducted to ensure that the extent of repaired or replaced coatings/linings encompasses sound coating/lining material.
- As an alternative, internal coatings exhibiting indications of peeling and delamination may be returned to service if: (a) physical testing is conducted to ensure that the remaining coating is tightly bonded to the base metal; (b) the potential for further degradation of the coating is minimized, (i.e., any loose coating is removed, the edge of the remaining coating is feathered); (c) adhesion testing using ASTM International standards endorsed in RG 1.54 (e.g., pull-off testing, knife adhesion testing) is conducted at a minimum of 3 sample points adjacent to the defective area; (d) an evaluation is conducted of the potential impact on the system, including degraded performance of downstream components due to flow blockage and loss of material or cracking of the coated component; and (e) follow-up visual inspections of the degraded coating are conducted within 2 years from detection of the degraded condition, with a reinspection within an additional 2 years, or until the degraded coating is repaired or replaced.
- If coatings/linings are credited for corrosion prevention (e.g., corrosion allowance in design calculations is zero, the “preventive actions” program element of a SLRA AMP credited the coating/lining) and the base metal has been exposed or it is beneath a blister, the component’s base material in the vicinity of the degraded coating/lining is examined to determine if the minimum wall thickness is met and will be met until the next inspection.
- When a blister does not meet acceptance criteria, and it is not repaired, physical testing is conducted to ensure that the blister is completely surrounded by sound coating/lining bonded to the surface. Physical testing consists of adhesion testing using ASTM International standards endorsed in RG 1.54. Where adhesion testing is not possible due to physical constraints, another means of determining that the remaining coating/lining is tightly bonded to the base metal is conducted such as lightly tapping the coating/lining. Acceptance of a blister to remain inservice should be based both on the potential effects of flow blockage and degradation of the base material beneath the blister.
- Additional inspections are conducted if one of the inspections does not meet acceptance criteria due to current or projected degradation (i.e., trending) unless the cause of the aging effect for each applicable material and environment is corrected by repair or replacement for all components constructed of the same material and exposed to the same environment. The number of increased inspections is determined in accordance with the site’s corrective action process; however, there are no fewer than five additional inspections for each inspection that did not meet acceptance criteria, or 20 percent of each applicable material, environment, and aging effect combination is inspected, whichever is less. When inspections are based on the percentage of piping length, an additional 5 percent of the total length is inspected. The timing of the additional inspections is based on the severity of the degradation identified and is commensurate with the potential for loss of intended function. However, in all cases, the additional inspections are completed within the interval in which the original inspection was conducted, or if identified in the latter half of the current inspection interval, within the next refueling outage interval. These additional inspections conducted in the next inspection interval cannot also be credited towards the number of inspections in the latter interval. If subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis is conducted to determine the further extent of inspections. Additional samples are inspected for any recurring degradation to provide reasonable assurance that corrective actions appropriately address the associated causes. At multi-unit sites, the additional inspections include inspections at all of the units with the same material, environment, and aging effect combination.
- 8. Confirmation Process: The confirmation process is addressed through those specific portions of the QA program that are used to meet Criterion XVI, “Corrective Action,” of 10 CFR 50, Appendix B. Appendix A of the GALL-SLR Report describes how an applicant may apply its 10 CFR 50, Appendix B, QA program to fulfill the confirmation process element of this AMP for both safety-related and nonsafety-related SCs within the scope of this program.
- 9. Administrative Controls: Administrative controls are addressed through the QA program that is used to meet the requirements of 10 CFR 50, Appendix B, associated with managing the effects of aging. Appendix A of the GALL-SLR Report describes how an applicant may apply its 10 CFR 50, Appendix B, QA program to fulfill the administrative controls element of this AMP for both safety-related and nonsafety-related SCs within the scope of this program.
- 10. Operating Experience: The inspection techniques and training of inspection personnel associated with this program are consistent with industry practice and have been demonstrated effective at detecting loss of coating or lining integrity. Not to exceed inspection intervals have been established that are dependent on the results of previous plant-specific inspection results. The following examples describe operating experience (OE) pertaining to loss of coating or lining integrity for coatings/linings installed on the internal surfaces of piping systems:
- In 1982, a licensee experienced degradation of internal coatings in its spray pond piping system. This issue contains many key aspects related to coating degradation. These include installation details such as improper curing time, restricted availability of air flow leading to improper curing, installation layers that were too thick, and improper surface preparation (e.g., oils on surface, surface too smooth). The aging mechanisms included severe blistering, moisture entrapment between layers of the coating, delamination, peeling, and widespread rusting. The failure to install the coatings to manufacturer recommendations resulted in flow restrictions to the ultimate heat sink and blockage of an emergency diesel generator governor oil cooler. (Information Notice 85-24, “Failures of Protective Coatings in Pipes and Heat Exchangers.”)
- During an U.S. Nuclear Regulatory Commission inspection, the staff found that coating degradation, which occurred as a result of weakening of the adhesive bond of the coating to the base metal due to turbulent flow, resulted in the coating eroding away and leaving the base metal subject to wall thinning and leakage. [Agencywide Documents Access and Management System (ADAMS) Accession No. ML12045A544].
- In 1994, a licensee replaced a portion of its cement lined steel service water piping with piping lined with polyvinyl chloride material. The manufacturer stated that the lining material had an expected life of 15–20 years. An inspection in 1997 showed some bubbles and delamination in the coating material at a flange. A 2002 inspection found some locations that had lack of adhesion to the base metal. In 2011, diminished flow was observed downstream of this line. Inspections revealed that a majority of the lining in one spool piece was loose or missing. The missing material had clogged a downstream orifice. A sample of the lining was sent to a testing lab where it was determined that cracking was evident on both the base metal and water side of the lining and there was a noticeable increase in the hardness of the in service sample as compared to an unused sample. (ADAMS Accession No. ML12041A054).
- A licensee has experienced multiple instances of coating degradation resulting in coating debris found downstream in heat exchanger end bells. None of the debris had been large enough to result in reduced heat exchanger performance. (ADAMS Accession No. ML12097A064).
- A licensee experienced continuing flow reduction over a 14 day period, resulting in the service water room cooler being declared inoperable. The flow reduction occurred due to the rubber coating on a butterfly valve becoming detached. (ADAMS Accession No. ML073200779).
- At an international plant, cavitation in the piping system damaged the coating of a piping system, which subsequently resulted in unanticipated corrosion through the pipe wall. (ADAMS Accession No. ML13063A135).
- A licensee experienced degradation of the protective concrete lining which allowed brackish water to contact the unprotected carbon steel piping resulting in localized corrosion. The degradation of the concrete lining was likely caused by the high flow velocities and turbulence from the valve located just upstream of the degraded area. (ADAMS Accession No. ML072890132).
- A licensee experienced through-wall corrosion when a localized area of coating degradation resulted in base metal corrosion. The cause of the coating degradation is thought to have been nonage related mechanical damage. (ADAMS Accession No. ML14087A210).
- A licensee experienced through-wall corrosion when a localized polymeric repair of a rubber lined spool failed. (ADAMS Accession No. ML14073A059).
- A licensee experienced accelerated galvanic corrosion when loss of coating integrity occurred in the vicinity of carbon steel components attached to AL6XN components. (ADAMS Accession No. ML12297A333).
- The program is informed and enhanced when necessary through the systematic and ongoing review of both plant-specific and industry OE including research and development such that the effectiveness of the AMP is evaluated consistent with the discussion in Appendix B of the GALL-SLR Report.
References
10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.
10 CFR 54.4(a), “Scope.” Washington, DC: U.S. Nuclear Regulatory Commission. 2016.
ACI. ACI Standard 201.1R-08, “Guide for Conducting a Visual Inspection of Concrete in Service.” Farmington Hills, Michigan: American Concrete Institute. 2008.
_____. ACI Standard 349.3R-02, “Evaluation of Existing Nuclear Safety-Related Concrete Structures.” Farmington Hills, Michigan: American Concrete Institute. 2002.
ASTM. ASTM 6677-07, “Standard Test Method for Evaluating Adhesion by Knife.” West Conshohocken, Pennsylvania: ASTM International. 2013.
_____. ASTM D714-02, “Standard Test Method for Evaluating Degree of Blistering of Paints.” West Conshohocken, Pennsylvania: ASTM International. 2009.
_____. ASTM D4538-05, “Standard Terminology Relating to Protective Coating and Lining Work for Power Generation Facilities.” West Conshohocken, Pennsylvania: ASTM International. 2006.
_____. ASTM D4541-09, “Standard Test Method for Pull-Off Strength of Coatings Using Portable Adhesion Testers.” West Conshohocken, Pennsylvania: ASTM International. 2011.
_____. ASTM D7167-12, “Standard Guide for Establishing Procedures to Monitor the Performance of Safety-Related Coating Service Level III Lining Systems in an Operating Nuclear Power Plant.” West Conshohocken, Pennsylvania: ASTM International. 2012.
EPRI. EPRI 1019157, “Guideline on Nuclear Safety-Related Coatings.” Revision 2. (Formerly TR-109937 and 1003102). Palo Alto, California: Electric Power Research Institute. December 2009.
US NRC. Information Notice 85-24, “Failures of Protective Coatings in Pipes and Heat Exchangers.” Washington, DC: U.S. Nuclear Regulatory Commission. March 1985.
_____. Regulatory Guide 1.54, “Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants.” Revision 2. Washington, DC: U.S. Nuclear Regulatory Commission. October 2010.