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'''XI.S8 PROTECTIVE COATING MONITORING AND MAINTENANCE''' | '''XI.S8 PROTECTIVE COATING MONITORING AND MAINTENANCE''' | ||
'''Program Description''' | '''Program Description''' | ||
Latest revision as of 21:00, 4 October 2024
XI.S8 PROTECTIVE COATING MONITORING AND MAINTENANCE
Program Description
Proper maintenance of protective coatings inside containment (defined as Service Level I in the U.S. Nuclear Regulatory Commission (US NRC) Regulatory Guide (RG) 1.54, Rev. 1, or latest version) is essential to the operability of post-accident safety systems that rely on water recycled through the containment sump/drain system. Degradation of coatings can lead to clogging of Emergency Core Cooling System (ECCS) suction strainers, which reduces flow through the system and could cause unacceptable head loss for the pumps.
Maintenance of Service Level I coatings applied to carbon steel and concrete surfaces inside containment (e.g., steel liner, steel containment shell, structural steel, supports, penetrations, and concrete walls and floors) also serve to prevent or minimize loss of material due to corrosion of carbon steel components and aids in decontamination. Regulatory Position C4 in US NRC RG 1.54, Revision 2, describes an acceptable technical basis for a Service Level I coatings monitoring and maintenance program that can be credited for managing the effects of corrosion for carbon steel elements inside containment. American Society for Testing and Materials (ASTM) D 5163-08 and endorsed years of the standard in US NRC RG 1.54 are acceptable and considered consistent with the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report. In addition, Electric Power Research Institute Report 1019157, “Guideline on Nuclear Safety-Related Coatings,” provides additional information on the ASTM standard guidelines.
A comparable program for monitoring and maintaining protective coatings inside containment, developed in accordance with US NRC RG 1.54, Revision 2, is acceptable as an aging management program (AMP) for subsequent license renewal (SLR).
Service Level I coatings credited for preventing corrosion of steel containments and steel liners for concrete containments are subject to requirements specified by the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI, Subsection IWE ( GALL-SLR Report AMP XI.S1). However, this program (GALL-SLR Report AMP XI.S8) reviews Service Level I coatings to ensure that the protective coating monitoring and maintenance program is adequate for SLR.
Evaluation and Technical Basis
- 1. Scope of Program: The minimum scope of the program is Service Level I coatings applied to steel and concrete surfaces inside containment (e.g., steel liner, steel containment shell, structural steel, supports, penetrations, and concrete walls and floors), defined in US NRC RG 1.54, Revision 2, as follows: “Service Level I coatings are used in areas inside the reactor containment where the coating failure could adversely affect the operation of post-accident fluid systems and thereby impair safe shutdown.” The scope of the program also should include any Service Level I coatings that are credited by the licensee for preventing loss of material due to corrosion in accordance with GALL-SLR Report AMP XI.S1.
- 2. Preventive Action: The program is a condition monitoring program and does not recommend any preventive actions. However, for plants that credit coatings to minimize loss of material, this program is a preventive action.
- 3. Parameters Monitored or Inspected: ASTM D 5163-08 provides guidelines that are acceptable to the US NRC staff for establishing an inservice coatings monitoring program for Service Level I coating systems in operating nuclear power plants, and identifies the parameters monitored or inspected to be “any visible defects, such as blistering, cracking, flaking, peeling, rusting, and physical damage.”
- 4. Detection of Aging Effects: ASTM D 5163-08, paragraph 6, defines the inspection frequency to be each refueling outage or during other major maintenance outages, as needed. ASTM D 5163-08, paragraph 9, discusses the qualifications for inspection personnel, the inspection coordinator, and the inspection results evaluator. ASTM D 5163-08, subparagraph 10.1, discusses development of the inspection plan and the inspection methods to be used. It states that a general visual inspection shall be conducted on all readily accessible coated surfaces during a walk-through. After a walk-through, or during the general visual inspection, thorough visual inspections shall be carried out on previously designated areas and on areas noted as deficient during the walk-through. A thorough visual inspection shall also be carried out on all coatings near sumps or screens associated with the ECCS. This subparagraph also addresses field documentation of inspection results. ASTM D 5163-08, subparagraph 10.5, identifies instruments and equipment needed for inspection.
- 5. Monitoring and Trending: ASTM D 5163-08 identifies monitoring and trending activities in subparagraph 7.2, which specifies a pre-inspection review of the previous two monitoring reports, and in subparagraph 11.1.2, which specifies that the inspection report should prioritize repair areas as either needing repair during the same outage or as postponed to future outages, but under surveillance in the interim period. The assessment from periodic inspections and analysis of total amount of degraded coatings in the containment is compared with the total amount of permitted degraded coatings to provide reasonable assurance of post-accident operability of the ECCS.
- 6. Acceptance Criteria: ASTM D 5163-08, subparagraphs 10.2.1 through 10.2.6, 10.3, and 10.4, contains one acceptable method for the characterization, documentation, and testing of defective or deficient coating surfaces. Additional ASTM and other recognized test methods are available for use in characterizing the severity of observed defects and deficiencies. The evaluation covers blistering, cracking, flaking, peeling, delamination, and rusting. ASTM D 5163-08, paragraph 11, addresses evaluation. It specifies that the inspection report is to be evaluated by the responsible evaluation personnel, who prepare a summary of findings and recommendations for future surveillance or repair, and prioritization of repairs.
- 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 Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B. Appendix A of the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 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.
- A recommended corrective action plan is required for major defective areas so that these areas can be repaired during the same outage, if appropriate.
- 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: US NRC Information Notice 88-82, US NRC Bulletin 96-03, US NRC Generic Letter (GL) 04-02, and US NRC Generic Letter 98-04 describe industry experience pertaining to coatings degradation inside containment and the consequential clogging of sump strainers. US NRC RG 1.54, Rev. 1, was issued in July 2000. Monitoring and maintenance of Service Level I coatings conducted in accordance with Regulatory Position C4 is expected to be an effective program for managing degradation of Service Level I coatings and, consequently, an effective means to manage loss of material due to corrosion of carbon steel structural elements inside containment.
- The program is informed and enhanced when necessary through the systematic and ongoing review of both plant-specific and industry operating experience 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.
ASTM. ASTM D 5163-05, “Guide for Establishing Procedures to Monitor the Performance of Coating Service Level I Coating Systems in an Operating Nuclear Power Plant.” West Conshohocken, Pennsylvania: American Society for Testing and Materials. 2005.
_____. ASTM D 5163-08, “Standard Guide for Establishing a Program for Condition Assessment of Coating Service Level I Coating Systems in Nuclear Power Plants.” West Conshohocken, Pennsylvania: American Society for Testing and Materials. 2008.
_____. ASTM D 5163-96, “Standard Guide for Establishing Procedures to Monitor the Performance of Safety Related Coatings in an Operating Nuclear Power Plant.” West Conshohocken, Pennsylvania: American Society for Testing and Materials. 1996.
EPRI. EPRI 1003102(Archived), “Guideline on Nuclear Safety-Related Coatings.” Revision 1. (Formerly TR-109937). Palo Alto, California: Electric Power Research Institute. November 2001.
_____. EPRI 1019157, “Guideline on Nuclear Safety-Related Coatings.” Revision 2. (Formerly TR-109937and 1003102). Palo Alto, California: Electric Power Research Institute. December 2009.
US NRC. Bulletin 96-03, “Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling-Water Reactors.” Washington, DC: U.S. Nuclear Regulatory Commission. May 1996.
_____. Generic Letter 04-02, “Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors.” Washington, DC: U.S. Nuclear Regulatory Commission. September 2004.
_____. 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.” Washington, DC: U.S. Nuclear Regulatory Commission. July 1998.
_____. Information Notice 88-82, “Torus Shells with Corrosion and Degraded Coatings in BWR Containments.” Washington, DC: U.S. Nuclear Regulatory Commission. November 1988.
_____. Information Notice 97-13, “Deficient Conditions Associated With Protective Coatings at Nuclear Power Plants.” Washington, DC: U.S. Nuclear Regulatory Commission. March 1997.
_____. Regulatory Guide 1.54, “Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants.” Revision 0. Washington, DC: U.S. Nuclear Regulatory Commission. June 1973.
_____. Regulatory Guide 1.54, “Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants.” Revision 1. Washington, DC: U.S. Nuclear Regulatory Commission. July 2000.
_____. 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.