111 I PROGRAM PROCEDURE 111 PP REVISION SAFETY … · primer. In the Torus the topcoat is a phenolic resin paint (Keeler & Long #7230 Submarine White Enamel). As early as 1972, there

VERMONT YANKEE NUCLEAR POWER STATION

- E-Plan 1 OCFR50.54(q) Security lOCFR50.54(p)

PROGRAM PROCEDURE 111 I 111

No No

PP 7037

REVISION 1

SAFETY-RELATED COATINGS PROGRAM

Probable Risk Analysis (PRA) Reactivity Management

USE CLASSIFICATION:

RESPONSIBLE PROCEDURE OWNER:

No No

REFERENCE

Manager, Design Engineering

LPC No.

I REOUIRED REVIEWS I Yes/No I

Affected Pages Effective Date

Implementation Statement: N/A I

Effective Date: 06/16/05

PP7037Rev. 1 Page 1 of 15

TABLE OF CONTENTS

1.0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

PURPOSE. SCOPE. AND DISCUSSION ........................................................................................ 3

DEFINITIONS .................................................................................................................................... 7

PRIMARY RESPONSIBILITIES .................................................................................................. 10

PROCEDURE .................................................................................................................................... 10

4.1

4.2

4.3 Physical Application and Inspection Requirements ............................................................... 11

REFERENCES AND COMMITMENTS ...................................................................................... 13

FINAL CONDITIONS ..................................................................................................................... 14

ATTACHMENTS ............................................................................................................................. 15

Coatings Condition AssessmenVChange ................................................................................ 10

Specifying Coatings Requirements ......................................................................................... 11

QA REQUIREMENTS CROSS REFERENCE ............................................................................ 15

PP 7037 Rev . 1 Page 2 of 15

1.0 PURPOSE, SCOPE, AND DISCUSSION

1.1. Purpose

The Entergy Vermont Yankee Coatings Program is established to delineate the design configuration and the controls in place to maintain the design of the plant in regards to coatings. The Vermont Yankee Safety-Related Coatings Program is the document that is used to select and review the suitability of use for the coatings applied to systems, structures, and components (SSCs) and it is meant to control essential coatings program elements to meet the intent of EPRI TR- 1003 102, Guideline on Nuclear Safety-Related Coatings (which captures ANSI N101.4). This document supports the painting procedures by delineating those coating systems and maintenance touch-up materials that are approved for use at Vermont Yankee.

The program provides coating system information for pre-qualified safety-related and special coating systems. The Vermont Yankee SR Coatings Program is meant to specify Service Level I and 111, qualified coating systems used on specific safety-related SSC, to achieve economic, protective, and durable finishes under defined service conditions.

Safety-related coatings work is a "special process" as described in Criterion IX of 1 OCFR.50, Appendix B. The basis for declaring this kind of coating work as a special process is that the quality of the finished product cannot be verified without qualification processes, in-process controls, and inspections. This special process control is accomplished by using qualified personnel working with qualified procedures in accordance with applicable codes and standards and other special requirements. Mixing, su face preparation, application and drying and curing are typical elements of this special process.

Control of safety-related coatings is required in order to maintain a high degree of confidence that applied coatings will not cause deleterious effects to safety-related SSCs. Control of coatings also allows for maintaining the design of Vermont Yankee and to protect the financial investment that has been made.

Coatings are used at Vermont Yankee for one or more of the following reasons:

0

0 For ease in decontamination, 0

For beautification, and 0

To inhibit and mitigate the corrosion process on susceptible steel,

For protection of the substrate surface from erosion, corrosion, or wear,

For 1 igh t enhancements .

PP 7037 Rev. 1 Page 3 of 15

1.2. Scope

This program lists a limited number of coatings that are suitable for use in the Primary Containment, for safety-related coating activities. Selection of a coating system for use in the Primary Containment that is not listed in the attachments requires an approved Engineering Request or Technical Evaluation prior to its specification and procurement.

This program controls Qualified Safety-Related Service Level I coatings within Primary Containment and Safety-Related Service Level I11 coating activities such as internal coatings of:

e Safety-Related Storage Tank Internals e Safety-Related Pump Internals e Safety-Related Heat Exchanger Internals e Safety-Related Pressure Boundary Internals

This program does not apply to non-safety-related painting activities that typically include the following:

e

e

e

e

e

e

e

e

0

e

e

e

Coatings applied on NNS SSC. Painting in office and ’work spaces.’ Painting in the Admin Building (with exception of Control Room, Cable Vault, and Switchgear Rooms). Painting in the Construction Office Building (COB) and other ‘out’ buildings. Painting wood with fire retardant paint. Touchup painting of plant components following maintenance with spray paint (ex. MOV operators, motors, valves, etc.) and painting of electrical insulation with Glyptal or equal. Painting vehicles. Painting signs. Painting temporary buildings (trailers, Sea-vans, sheds, etc.). Painting ‘temporary equipment’ that is used anywhere in the plant for a particular work effort and is removed at the completion of the work effort (ex., shadow shields used in primary containment). Striping parking lots or painting information of roadways. Painting outside the Protected Area fence - with the exception of Cooling Towers.

The above mentioned non-safety-related applications are not controlled by this program and should be addressed by specific work orders per Ap 0021 for the specific painting activity. These coating systems should be specified and selected based on the application and applied in accordance with the manufacturer’s instructions. Contact the Facilities Supervisor for coating recommendations.


1.3. Discussion

Vermont Yankee was originally designed and built to standards and commercial work practices that were in use during the construction period. Vermont Yankee subsequently committed to ANSI N 10 1.4- 1972, "Quality Assurance for Protective Coatings Applied to Nuclear Facilities," as endorsed by Regulatory Guide 1.54. Coatings were selected for various applications throughout the plant based upon good commercial work practices and paint vendor's recommendations. These recommendations were based on their successful use of coatings in similar plant applications in addition to the data obtained from ongoing testing for effects from radiation, chemical resistance, wear abrasion, and immersion service, if applicable. Vermont Yankee's response to GL 98-04 states that procedures are consistent with the intent of ANSI N101.2, N101.4, and Reg. Guide 1.54 for new Service Level I & 111 coating applications. Vermont Yankee has evaluated the aforementioned standards and this coatings program follows the guidelines of EPRI TR- 1003 102. Within this Coatings Procedure are attachments related to the areas and equipment in the plant that are painted. A brief history of the primary containment coatings in use at Vermont Yankee is outlined below.

DRYWELL

Vermont Yankee's design documents for this area (GE Spec A22A1182) specifies a coating that provides rust control for metal parts exposed to high levels of radiation and to which a chemical resistant coating can be added even after a lay-up of several years, such as, Carbo Zinc #11 (CZ-1 l), or equal, and a coating to protect surfaces such as Phenoline 305, or equal. (22-11 was the primer and Keeler & Long #7475 was added as a chemical resistant topcoat.

Vermont Yankee's operational history has shown several instances in the early years of operation of the plant when primary containment upper levels in the Drywell have experienced temperatures above 250'F for extended periods due to periodic loss of Drywell Coolers operation. The Drywell is painted with Keeler & Long #7475 Epoxy over Carboline zinc primer. The high temperature excursions ultimately led to failure of the coating by separation of the epoxy topcoat to the inorganic zinc primer. This separation occurred at the epoxy-zinc interface with the epoxy disbonding and flaking. The zinc primer remains well adhered to the steel substrate.

This coating condition was prevalent in the Drywell from the 284' elevation up to the Drywell Head. Various reviews and evaluations of this coating condition were conducted during the 1980s and it was determined that the coating failure was "localized" to the upper areas of the Drywell. It was also determined that scraping of the loose topcoat each refuel outage would be the best course of action to take and this is the recommended repair to observed peeling or flaking of topcoat. Additionally, it was determined that the loose topcoat would not come off in sufficient quantities to affect ECCS suction strainers and that the absence of the topcoat would not be deleterious to the inorganic zinc primer. During the Refuel Outage in 1998, an extensive coating inspection was conducted by coating inspectors from KTA-TATOR and a condition assessment was made of the coating condition. This condition assessment is the basis from which future evaluations of coating performance and condition will be made.


TORUS

Vermont Yankee's design documents for this area (GE Spec A22A1182) specifies a coating that provides rust control for metal parts exposed to high levels of radiation and to which a chemical resistant coating can be added even after a lay-up of several years, such as, Carbo Zinc #11, or equal, and a coating to protect surfaces such as Phenoline 305, or equal. (22-11 was the primer and Keeler & Long #7230 was added as a chemical resistant topcoat.

The Torus vapor space has also shown problems with the topcoat adhering to the inorganic zinc primer. In the Torus the topcoat is a phenolic resin paint (Keeler & Long #7230 Submarine White Enamel). As early as 1972, there were problems with the topcoat blistering and cracking. It was felt that this condition was caused by a "dry spray" condition on the surface of the primer in various places. Early on, the remedy was to scrape off the loose cracked and blistered topcoat and to recoat the areas. Later on, the accepted repair was to scrape off the loose topcoat and not to recoat the inorganic zinc primer. This approach has been followed up to present and is the recommended repair to observed peeling or flaking of topcoat. During the 1998 RFO (EDCR 97-423), the lower Torus shell surface was blasted and recoated from one foot above the waterline and included all submerged carbon steel surfaces. The steel was coated with a Coating Service Level I, DBA qualified, inorganic zinc-rich coating (102) to provide corrosion protection and the IOZ was not top coated, except for a belly band at the splash zone, approximately one foot above and below the water line, to prevent tiger-striping.

CONTROLLING DEBRIS LOADING ON THE TORUS SUCTION STRAINERS

Debris accumulated on the ECCS suction strainers as it is filtered from the suppression pool water entering the strainer. The amount of debris that accumulates on the strainers is proportional to the integrated flow through each strainer, among other factors.

Tests to evaluate generic strainer performance under Vermont Yankee conditions were performed at Alden Research Labs (ARL) in Holden, Massachusetts as part of the ECCS suction strainer EDCR. The purpose of the testing was to investigate the properties and effects of paint chips and fiber debris on the performance of the ECCS strainers. The test result uses paint chips with uniform thickness and specific gravity.

During the performance of the tests, when paint chips were added to the debris mixture, both paint and fiber could only be removed from the pool and deposited on the strainer under high flow and high turbulence conditions. For the expected DBA flow rates for Vermont Yankee, no fiber or paint was collected on the strainer due to low approach velocities. Under post-DBNIBA (Intermediate Break Accident) conditions of recirculation flow for Vermont Yankee, only fiber was collected. After the chugging period is over and the turbulence in the pool is driven by recirculation flow, only fiber could be removed from the pool and deposited on the strainer.


2.0

2.1.

2.2.

Based on these tests, at no time were paint chips deposited on the strainers. Therefore, no specific source term of unqualified / indeterminate coatings debris is calculated. These results are not used as a basis to allow uncontrolled coating activities on safety-related SSCs. Rather, these results are used to characterize the specific coatings tested, strainer performance and anticipated debris loading. Control of coating activities is necessary to maintain the validity of supporting calculations and design. The application of unqualified coatings would serve to change the characteristics of post-LOCA debris and impact debris loading assumptions.

ATTACHMENTS

The attachments contain the current design specifications and coatings in use. When the recoating of large areas is anticipated (greater than 150 ft2), the applicable attachment lists those coatings systems that comprise the list of suitable coatings to select from for a given plant application. When maintenance touch-up of the installed coating is to be undertaken, the applicable attachment lists the suitable touch-up coatings that can be used in conjunction with the applied coating system.

Selections of alternate coating systems than those delineated in the attachments must be evaluated via the Technical Evaluation process (ENN-DC- 13 8) or Engineering Request (ENN-DC-115).

The coatings listed have been determined to satisfy plant licensing design basis and are thus suitable for the plant applications provided. As such the respective design of the coating are qualified for Service Level I coatings within primary containment.

Safety-related coatings qualification test reports may be located on the EPRI website at www.epri.com . This site has a comprehensive listing of coatings and test reports compiled from many nuclear utilities. Oftentimes, these test reports were completed for an individual plant but are now available to EPRI members as a result of the efforts of the Plant Support Engineering (PSE) task force. The database is searchable by coating type, substrate, radiation levels and temperature. Use of this database is restricted, for information contact the Design Engineering Coatings Engineer.

DEFINITIONS (Terms Used)

Acceptable Coating System: A safety-related coating system for which a suitability for application review which meets the plant licensing requirement has been completed and there is a reasonable assurance that, when properly applied and maintained, the coating will not detach under normal or accident conditions.

Coating Applicator: An individual or organization responsible for applying a protective or decorative coating system.


http://www.epri.com

2.3.

2.4.

2.5.

2.6.

2.7.

2.8.

2.9.

2.10.

2.11.

2.12.

Coating Service Level I: Terms used to describe areas inside the reactor containment where coating failure could adversely affect the operation of post-accident fluid sys tems and, thereby, impair safe shutdown (from ASTM D5 144-00). Service Level I coating work is safety related. This includes the drywell, suppression chamber, structural and miscellaneous steel, concrete surfaces and exposed, uninsulated carbon steel surfaces.

Coating Service Level 11: Term used to describe areas outside the reactor-containment where coating failure could impair, but not prevent, normal operating performance. The function of Coating Service Level I1 coatings is to provide corrosion protection and decontaiminability in those areas outside the reactor-containment subjected to radiation exposure and radionuclide contamination (from ASTM D5 144-00). Service Level I1 coating work is non-safety-related. Examples include circ water piping linings and main condenser tube sheets and water boxes.

Coating Service Level 111: Term used to describe areas outside the reactor containment where failure could adversely affect the safety function of a safety-related SSC (from ASTM D5 144-00). Service Level I11 coating work is safety related. Examples include internals of safety-related heat exchangers and tanks containing ECCS water sources.

Coating System: A protective film consisting of one or more coats, applied in a predetermined order by prescribed methods to a defined substrate.

I

Coatinn Work: An all-inclusive term to define all operations required to accomplish a complete coating job. The term shall be construed to include materials, equipment, labor, preparation or surfaces, control of ambient conditions, application and repair of coating systems, and inspection. Coating work may be classified as safety-related or non safety-related.

DBA-Qualified Coatinp System: A coating system used inside primary containment that can be attested to having passed the required laboratory testing, including irradiation and simulated Design Basis Accident (DBA), and has adequate quality documentation to support its use and application as DBA qualified.

Design Based Accident (DBA): A generic term for any one of a family of accident conditions which can result from postulated events. These conditions are generally associated with the rupture of high energy piping. The more commonly recognized accident conditions used to evaluate coating systems for primary containment are the Loss Of Coolant Accident (LOCA) or main steam pipe break.

Immersion Service: Use of a coating applied to surfaces that are normally under water or other liquid; in this service, the coating is frequently called a lining.

Indeterminate Coating System: A safety-related coating system for which there is insufficient evidence to demonstrate that it is suitable for its intended use and that it is acceptable.

Paints/Coatings/Lininas: Essentially synonymous terms for liquid-applied materials consisting of pigments and fillers bound in a resin matrix which dry or cure to form a thin, continuous protective or decorative film. Linings indicate an immersion environment.


2.13. Oualified Coating System: A coating system used inside primary containment that can be attested to having passed the required laboratory testing, including irradiation and simulated Design Basis Accident (DBA), and has adequate quality documentation to support its use and application as DBA qualified.

2.14. Safety-Related Coatings Svstem: A coating system used inside or outside of primary containment, the detachment of which could adversely affect the safety function of a safety-related structure, systems, or component.

The safety classification of the coating system is determined NOT by the safety classification of the item to which it is applied, but only by the coating system’s potential adverse effect on any safety-related SSC after the coating system fails (detaches) and becomes foreign material. (e.g., examples of Service Level I11 applications would be storage tanks for reactor grade water, emergency fuel oil systems, Service Water Pump internals and safety-related cooling water s ys tems)

2.15. Substrate: The surface to which a particular coating system will be applied (e.g., steel, concrete, masonry, etc.)

2.16. Surface Preparation: Definitions as follows:

SSPC-SP1 : Solvent cleaning. SSPC-SP2: Hand cleaning, such as wire brush. SSPC-SP3: Power tool cleaning. SSPC-SPS: White metal blast cleaning. SSPC-SP6: Commercial blast cleaning. SSPC-SP10: Near white metal blast cleaning. SSPC-SP11: Power tool cleaning to bare metal.

2.17. Topcoats/Finish Coats: These terms are used interchangeably to reference that coat visible when the intended, overall system is complete, i.e., the final coat. It is this coat that is exposed to the environment. In some paint systems, multiple coats of the same topcoat are used to enhance the resistance of the overall system to the environment. In such instances the terms ‘first finish coat’ and ‘final finish coat’ are used. When the term ‘intermediate coat’ is used, such differentiation implies that the intermediate coat is different from the topcoat/finish coat.

2.18. Unaualified Coating: A coating or coating system used in primary containment that cannot be attested to having passed the required testing, including irradiation and simulated Design Basis Accident (DBA) or lacks adequate quality documentation to support its use as qualified.

PP 7037 Rev. I Page 9 of 15

3.0

3.1.

3.2.

4.0

4.1.

PRIMARY RESPONSIBILITIES

Coatings Program Coordinator

Designated individual responsible for developing and maintaining the Coatings Program. Responsible for defining the strategic objectives and an outline of the design and process controls that are used to obtain those objectives. Responsible for the design bases, specifications, training, and procedures necessary to effectively enact the program.

Responsible Coatings Applicator

Approved individuals responsible for adhering to the requirements of the Vermont Yankee Safety-Related Coatings Program and to performing coating activities using the approved materials and methods contained in Vermont Yankee approved procedures.

PROCEDURE

The Vermont Yankee Coatings Program is broken down into three distinct sections:

1. Coatings condition assessment 2. Specifying coating requirements 3. Application and inspection requirements

Coatings Condition AssessmentlChange

4.1.1.

4.1.2.

4.1.3.

4.1.4.

Coatings to be assessed at Vermont Yankee are those that have been classified as qualified, Service Level I and I11 safety-related. The process of determining coating requirements is a formal process utilized by Vermont Yankee for the maintenance of the coatings already installed at Vermont Yankee and inspected per IWE or other assessment programs. For those coatings not classified as safety-related, once the need for coatings or coatings related work has been identified, the next step is to implement the work via Vermont Yankee Work Orders (AP 0021) and Work Order Planning (AP 0048).

A prioritized approach has been developed to the coatings assessment that considers many, if not most, of the factors recommended in EPRI TR- 1003 102. A representative sample of all types of coatings within the program scope is used. The goal of prioritization is to gain an early indication of the conditions and to use this information for refining the coating assessment prioritization process.

In conjunction with safety impact, any potential problem areas that can be identified via a review of prior inspections, specifications, procedures, and quality control records have a high priority. Factors such as availability of and accessibility to the coated equipment or surfaces, ALARA considerations, and outage schedules are factored into the prioritization process.

Coating condition assessment frequencies primarily consider the coating’s safety functions. Coating condition assessment frequencies also take into consideration a review of documentation regarding the existing coatings.

PP 7037 Rev. 1 Page 10 of 15

4.1.5. Linings within safety-related fluid systems are selected by the nature of the environment. Linings in areas where erosion, cavitation, or impingement may exist are inspected on a high priority.

4.1.6. The coatings assessment program is coordinated with existing inspection programs and maintenance activities, when possible. The containment liner inspection, for example, includes a requirement for inspection of the coating when assessing the existing wall thickness under the IWE program. Various types of other inspections, such as Maintenance Rule walkdowns, snubber surveillance activities, diesel fuel storage tank inspections, and heat exchanger inspections are also coordinated.

4.1.7. In addition, design changes may install structures and components not currently within this Program. In the event the coating application is not defined for safety-related applications, the Coatings Program Coordinator will be contacted and responsible for specifying the requirements to be used.

4.1.8. Whenever Service Level I or I11 coatings work is to be done in house, the work will be implemented through the Vermont Yankee Work Control Process through the work order system.

4.1.9. Whenever Service Level I or I11 coating work is done off-site, the work will be done LAW this program and Vermont Yankee procurement processes.

4.2. Specifying Coatings Requirements

4.2.1. The coating systems approved for Service Level I (safety-related, inside primary containment) and Service Level I11 (safety-related, outside primary containment) at Vermont Yankee are contained in Table 1 and 2.

4.2.2. A work order will be used to specify the coating requirements and provide a permanent record for paint configuration control. By utilizing the work order system, a record of the coatings work performed will be maintained with the package via DZNPS PP-O958P, Attachment 1 or DZNPS PP-O959P, Attachment 1 or equivalent which meets the requirements of ANSI N101.4.

4.3. Physical Application and Inspection Requirements

4.3.1. The process used at Vermont Yankee for physically applying and inspecting coatings involves a vendor procedure that has been reviewed and approved for use at Vermont Yankee. This procedure provides information and instructions for the documentation and techniques to be used for the physical application of coatings in Vermont Yankee.

PP 7037 Rev. 1 Page 11 of 15

4.3.2. Service Level I coating work at Vermont Yankee shall be performed IAW (or alternate Vermont Yankee approved procedure that meets the requirements of ANSI N101.4):

e DZNPS PP-0958P Rev 0 “Painting and Protective Coating Application” for maintenance, touch-up and repairs of Service Level I Coating Applications under 12 ft sq.

OR

a DZNPS PP-0959P Rev 0 “Service Level I Painting and Protective Coating Application” for new Service Level I Coating Applications above 150 ft sq.

4.3.3. In general, the procedure shall provide information and instructions for the documentation and techniques to be used for the application of coatings at Vermont Yankee. All personnel qualification records, application records, and inspection records will be maintained as part of the work order package for record retention. The scope for the physical application and inspection includes:

a

e

a Pre-inspection of areas, e

a Control of ambient conditions, a Inspection e

General Requirements for the Field Work Package (FWP) including personnel qualification, scope of work, safety precautions, and method of application, Preparation of surfaces to be coated,

Mixing and application of coating materials,

Storage and dispensing of coating materials.

4.3.4. Use inspection form VYPPF 7037.01 or other Vermont Yankee approved primary containment surface inspection form when performing a coating inspection or documenting a deteriorated coating condition. Information on the inspection form shall include, but not be limited to, the following:

e

a

e

a

e

a

e

e

e

e

Date of Inspection Inspected By Location Service Level Substrate Description of Deterioration Sketch or Photo of effected area Condition of Substrate Trending Information (if any) Approximate surface area in square feet

4.3.5. Service Level I and 111 coatings shall be applied per coating manufacturer guidelines and shall consider DZNPS PP-0958P Section 5.8 when painting surfaces.

PP 7037 Rev. 1 Page 120f 15

5.0

5.1.

5.2.

5.3.

4.3.6. For coating that contains Volatile Organic Compounds (VOC) in excess of 1.5 lbslgal, such as epoxies, polyurethanes and other coatings containing organic solvents, Stand By Gas Treatment shall be secured per OP 21 17 for surfaces greater than 50 ft2 when primary containment is required. When primary containment is not required (cold shut down and no fuel moves), larger surfaces can be covered. Allow at least 24 hours after the coating system has been applied prior to declaring SBGT operable. This is to ensure the charcoal in the filters is not effected by the VOCs.

Alternative methods to ensure the SBGT charcoal filters are not effected by VOCs include the following:

Seal off the area where painting will occur and provide a suitable-sized supplemental charcoal filtration system or use a coating system with low VOCs.

e Directly route and exhaust the VOC vapors out of the Reactor Building by exhausting through RB ventilation exhaust. This will route the vapors to the stack. Ensure AOG is not operating to ensure the charcoal beds are not poisoned by the VOC vapor.

4.3.7. Coating System Data Sheets (CSDS) for approved Service Level I coating systems are included in the procedure as Appendix A.

REFERENCES AND COMMITMENTS

Technical Specifications and Site Documents

5.1.1. VY Safety Manual 5.1.2. Environmental Qualification of Electrical Equipment Manual, Rev. 35, Table A-15 5.1.3. UFSAR, Section 14.9.1.6 5.1.4. QAPM, Quality Assurance Program Manual

Administrative Limits

5.2.1. None

Codes, Standards, and Regulations

5.3.1.

5.3.2.

5.3.3.

5.3.4.

5.3.5. 5.3.6. 5.3.7.

ANSI N101.2 Rev 1, Protective Coatings (paints) for Light Water Nuclear Reactor Containment Facilities ANSI N101.4 Rev 1, Quality Assurance from Protective Coatings Applied to Nuclear Facilities ASTM D3911-89 Evaluating Coatings used in Light-Water Nuclear Power Plants & Simulated Design Based Accident (DBA) Conditions ASTM D4082-89 Effect of Gamma Radiation on Coatings for use in Light-Water Nuclear Power Plants Reg. Guide 1.54 ASTM D5144-00, Use of Protective Coating Standards in Nuclear Power Plants lOCFR50, Appendix B

PP 7037 Rev. 1 Page 13 of 15

5.4. Commitments

5.4.1. BVY 98-147 dated Nov 12, 1998, Response to GL 98-04, BVY 98-147 5.4.2. ER-980056-02 5.4.3. 5.4.4. INF-97013-00, -01, -02

REG- 12796-00, -0 1, -02, -03

5.5. Supplemental References

5.5.1. 5.5.2. 5.5.3. 5.5.4. 5.5.5. 5.5.6. 5.5.7.

5.5.8.

5.5.9. 5.5.10. 5.5.1 1.

5.5.12.

5.5.13. 5.5.14. 5.5.15. 5.5.16. 5.5.17.

5.5.18. 5.5.19.

DZNPS PP-0958P Rev 0 Painting & Protective Coating Application DZNPS PP-0959P Rev 0 Service Level I Painting & Protective Coating Application EDCR 97-423, ECCS Suction Strainers EPRI TR- 1003 102, Guideline on Nuclear Safety-Related Coatings EPRI TR-106160, Coatings Handbook for Nuclear Power Plants GE Specifications 22A1182 Rev 0, Protective Coatings-Special ITSNY-98-01 Rev 2, VYC-1959 Rev 0 (Alden Research Lab DBA Test Report), Analysis of Tests for Investigating the Effect of Coating Debris on ECCS Strainer Performance for Vermont Yankee GE Nuclear Energy, Fer PO# 52897039179, Evaluation of Paint Loading on Vermont Yankee's ECCS Strainers During LOCA Conditions Rev. 1 dated June 1997, including estimated Primary Containment Coatings submitted by J. Todd of VY Maintenance Coatings submitted by J. Todd of VY Maintenance KTA-Tator Inc. Report 9803 11 Prepared April 30,1998 KTA-Tator Inc. Report 980468 Prepared June 25,1998 Memo from A.D. Hodgdon to M.S. Marion, Radiation Qualification of Torus Coatings, dated August 6, 1996, WO# 4551, File #REG 127.96 Memo from D, Grimes to J. Callaghan, "Drywell Protective Coating Qualifications", dated May 3 1,2000 VYM 2000/043 SSPC Steel Structures Painting Manual, Volume 2, Systems and Specifications TE2001-057, Bounding Parameters for Determining Appropriate Drywell Coatings VYC-193, B.8 Rev. 2, Bounding Radiation Dose Specifications by Plant Location VYC- 1498, Radiation Dose for the Qualification of Submerged Torus Coating VYC-1677, Rev. 0, Debris Source Terms For Sizing Of Replacement Residual Heat Removal And Core Spray Strainers AP 0021, Work Orders AP 0048, Work Planning

6.0 FINAL CONDITIONS

6.1. None

PP 7037 Rev. 1 Page 14of 15

7.0 ATTACHMENTS

7.1.

7.2.

7.3. 7.4.

7.5.

8.0

Figure 1

Table 1

Table 2 Appendix A

VYPPF 7037.01

Service Level I Qualified Coating Requirements Inside Primary Containment for Painted Safety-Related Components and Surfaces Qualified Coatings Application Matrix for Safety-Related Inside Primary Containment (SLI) Coating Application Matrix for Safety-Related Outside PC (SLIII) Completed Coatings Specification Data Sheets for Service Level I (Safety-Related Within Primary Containment) Vermont Yankee Coating Program As-Found SLI or SLIII Inspection Record Sheet

QA REQUIREMENTS CROSS REFERENCE

Source Document Section Procedure Section 8.1 QAPM All All

PP 7037 Rev. 1 Page 15 of 15

FIGURE 1

YERMONT YANKEE POWER STATION FIGURE 1

SERVICE LEVEL 1 QUALIFIED COATINGS REQUIREMENTS INSIDE PRIMARY CONTAINMENT FOR PAINTED SAFETY RELATED COMPONENTS AND SURFACES

?AD LIMITS (SEE NOTE 2 )

9 1x10’ PER UFSAR 14.9.1~6

INSIDE DRYWELL SURFACES a COATINGS

NOTES : 1. SEE UFSAR 14.9.1.6 c z ) - CLOgACT:TN100N 2. REFER TO GENERAL NOTES PAGES 2 a 3 OF TABLE 1 FOR

DOCUMENTATION TO VERSFY THE COATINGS CAN WITHSTAND THE DOSE IN THE REGION.

PP-7037 REV1 SI ON-0

Figure 1 PP 7037 Rev. 1 Page 1 of 1

TABLE 1

CZ-11 SG SSPC-SP 11 CARBOLINE CARBO ZINC 11 I COAT 3-5 MILS SSPC-SP 10

Qualified Coatings Application Matrix for Safety-Related Inside Primary Containment (SLI)

PWR TOOL 1,2,11 1-3 MILS &13


KEELER & LONG SURFACE ENAMEL 4500 (1 COAT) PER COAT SSPC-SP6, SPlO EPOXY SELF-PRIMER 4-9 MILS SSPC -s P3

PWR TOOL 1,2,11 1-3 MILS &13 PWR TOOL 1,4,10 1.5-3 MILS &13

6548/7107 4-9 MILS ss PC- SP3 PWR TOOL

4-6 MILS ss PC- SP2 HAND TOOL CARBOLINE CARBO 890 890 (2 COATS) PER COAT ss PC- SP3 PWR TOOL

KEELER & LONG EPOXY WHITE PRIMER (2 COATS) PER COAT SSPC-SP6, SPlO 1.5-3 MILS 1,4,10 &13

1,5,10 &13

Table 1 PP 7037 Rev. I Page I of 3

KEELER & LONG EPOXY SELF-PRIMER 4500 (1 COAT) 10-50 MILS CLEAN & DRY SURFACE ENAMEL OVER

4129 (1COAT) OVER 0.5-1.75 CLEAN & DRY NO MILS CONTAMINANTS

SURFACED 1&3

80 GRIT SANDPAPER

KEELER & LONG 5000 (1 COAT) EPOXY SELF-LEVELING OVER FLOOR COATING OVER 6129 (1COAT)

EPOXY CLEAR PRIMER/SEALER

35-50 MILS CLEAN & DRY SEALED 1&6

OVER

MILS CONTAMINANTS SANDPAPER 1.5-2.5 CLEAN & DRY NO 8 0 GRIT

CARBOLINE CZ-11 SG SSPC-SP 11 PWR TOOL 1,2,11

CARBO ZINC 11 I COAT 3-5 MILS SSPC-SP 10 1-3 MILS &13

6548/7107 KEELER & LONG EPOXY WHITE PRIMER (2 COATS)

4-9 MILS SSPC -s P3 PWR TOOL 1,4,10 PER COAT SSPC-SP6,SPlO 1.5-3 MILS &13


PWR TOOL 1,7,11 1-3 MILS &13

TFT/ UNDERWATER CONSTRUCTION BIO-DUR 561

PICCO COATINGS/ UT-790 (0LD:PLASITE

ENG SERVICES WI COATINGS UT-15) UNDERWATER C-790

RTO-DUR 561 (1 COAT) 10-40 MILS SSPC-11 PWR TOOL 1,8&12

10-25 MILS ss PC- s P11 PWR TOOL UT-790 (1 COAT) UT-15 (1 COAT) 10-25 MILS SSPC-s P11 PWR TOOL 1,9&12

1.

2.

3.

4.

5.

6.

7.

8.

9.

TABLE 1 (Continued)

Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per Design Basis Accident (DBA) conditions in accordance with ANSI N101.2-1972, ANSI N5.12-1974 or ASTM D-39 11. Ensure that a Coating Manufacturer's Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P Attachment 1.

Carbo Zinc 11 was the original coating applied to the Primary Containment shell as a primer paint. Carboline Test Report W2182 documents Nuclear Service Level I qualifications at 1E9 rads.

K&L 4500 for steel and concrete was approved for use under EE 95-1621. Nuclear Service Level I qualification is documented in K&L Test Report #85-0404 at 1E9 rads. K&L 4500 was approved for use as a DBA qualified repair coating over K&L 7475 (and 6548/7107) as documented in Keeler & Long report, "DBA Qualification Testing of Systems S-1 and KL-2 Repaired with No. 4500", dated Aug. 4, 1986. The latter report did not include irradiation testing, however, the coating was subjected to a 340°F, 118 psi test that is more conservative than values in Test Report #85-0404).

K&L 6548/7 107 was approved for use under EE 95-0227- 1621 and EDCR 80- 1 1. Nuclear Service Level I qualification is documented in K&L Test Report #79-0810-1 at E9 rads.

Carboline 890 was approved for use under EDCR 97-0423. Nuclear Service Level I qualification is documented in Carboline Test Report #02927 at 2E8 rads. Carboline Test Report M285 11 tested 890 to 1E9 rads: there were blisters and most cracked, but all remained intact.

K&L 5000 over K&L 6129 was approved for use as a Nuclear Service Level I qualified coating and is documented in K&L Test Report #90-0227 at 1E9 rads.

Carbo Zinc cannot be applied as an underwater coating.

Bio-Dur 561 was approved for use under EE 150. Nuclear Service Level I qualification is documented in Rust Utility Services, Inc. Underwater Construction Division report, "Underwater Coating Design Basis Accident Specimen Evaluation Report", dated Dec. 18, 1995, at 2.43E8 rads.

C-790 and UT-15 were approved for use under EE 95-0227-1628. Nuclear Service Level I qualification for UT-15 is documented in S.G. Pinney & Associates, Inc. report, "Design Basis Accident and Irradiation Testing of Coating Repair Materials for Use in Boiling Water Reactor Suppression Chamber Immersion Areas", dated Nov. 30, 1992 at 6E8 rads. Nuclear Service Level I qualification for C-790 is documented in S.G. Pinney & Associates, Inc. report, "Coating Systems Tested on Steel Panels for Irradiation and Design Basis Accident Criteria Requirements", dated Jan. 19, 1990 at 5.78E9 rads. (The latter report was prepared for Duane Arnold Plant). C-790 was manufactured by Wisconsin Protective Coatings. UES purchased the formula for C-790 and changed the name to UT-790 and has it manufactured for them by Picco Coatings Co.

Table 1 PP 7037 Rev. 1 Page 2 of 3

10.

11.

12.

13.

TABLE 1 (Continued)

Use of these coatings, with surface preps of SSPC SP-2, SP-3, or SP-11, are for Maintenance or Touch-up coating activities only. Individual areas for Maintenance or Touch-up coating should be limited to e150 ft sq. Areas larger than 450 ft sq. should have consideration given to a complete recoat activity, where the surface to be coated will be blast cleaned and have a surface profile re-established.

Use of Carbo Zinc 1 1 with a surface prep of SSPC SP- 1 1 is for Maintenance/Repair/Touch-up coating activities only. Although this surface prep has been satisfactorily DBA and rad tolerance tested, it has been decided to limit any single coating area to <12 ft sq.

Use of underwater curing epoxies for Maintenance/Repair/Touch-up coating activities will be restricted to individual coating spots, only as large as necessary to repair the identified defect. Underwater cured epoxies are not to be used as coating material for general (large) coating activities.

Clean prep work with SSPC-1 and allow to dry prior to applying coating.

Table 1 PP 7037 Rev. I Page 3 of 3

COMPONENT

Safety-Related Pump Internals

Safety-Related Heat Exchanger Head

Safety-Related Storage Tanks

Misc. Structural Steel

Misc. Structural Steel

Safety-Related Storage Tanks

TABLE 2

COATING APPLICATION MATRIX FOR SAFETY-RELATED OUTSIDE PC (SLIII)

ACTIVITY

New I Repair / Touch-up

~

New I Repair I Touch-up





SUBSTRATE

Carbon Steel

Carbon Steel

Carbon Steel

Carbon Steel

Carbon Steel

Carbon Steel

EXPOSURE ' Water immersion services up to 250 deg F max; Spikes to 300 deg F

Water immersion services up to 250 deg F max; Spikes to 300 deg F

Ambient Water Immersion

Ambient Water Immersion Underwater Cure

~~

Ambient Water Immersion

Petroleum

Radiation Levels up to 8x10' REM See Product Data sheets for selection and additional information on the Coating System See Product Application sheets for additional information on Surface Preparation

VERMONT YANKEE APPROVED COATING SYSTEM

Carboline -Phenolhe 368WG at 4 to 6 mils Arcor - S-30 PRLME Belzona - 1391

Carboline -Phenolhe 368WG at 4 to 6 mils Arcor - S-30 PRIME Belzona - 1391

Carboline -Phenoline 368WG at 4 to 6 mils Arcor - S-30 PRIME Belzona - 1391

Bio-Dur 561

Belzona - 11 1 I

Carboline - Phenoline 187 Primer at 4 to 6 mils. Arcor - S-30 PRIME Belzona - 1391

SURFACE PREP

Abrasive blasted with chloride free abrasive to SSPC-5 or mechanical clean to SSPC-I 1. White metal 3 to 5 mil profile. Prime immediately after SSPC- 1 prep dries. Abrasive blasted with chloride free abrasive to SSPC-IO or mechanical clean to SSPC-I 1. White metal 3 to 5 mil profile. Prime immediately after SSPC-I prep dries. Abrasive blasted with chloride free abrasive to SSPC-5 or mechanical clean to SSPC-11. White metal 3 to 5 mil profile. Prime immediately after SSPC- 1 preD dries. High pressure jetting with or without abrasive.

Abrasive blasted with chloride free abrasive to SSPC-5 or mechanical clean to SSPC-11. White metal 3 to 5 mil profile. Prime immediately after SSPC-1 prep dries. Abrasive blasted with chloride free abrasive to SSPC-5 or mechanical clean to SSPC-11. White metal 3 to 5 mil profile. Prime immediately after SSPC- 1 prep dries.

Table 2 PP 7037 Rev. 1 Page 1 of 1

APPENDIX A COMPLETED COATINGS SPECIFICATION DATA SHEETS FOR SERVICE LEVEL I

(SAFETY-RELATED WITHIN PRIMARY CONTAINMENT)

Type of Coating Activity: MaintenancejTouchup < 12 ft2 Substrate: Steel

Coating Type: Self-Curinrr, Solvent Based. Inorganic Zinc Silicate

Coating Manufacturer: Carboline Surface: DrvwelYTorus Shell or Head

Service Exposure: Non-Immersion CSDS NO.: CZIl-MlT

Notes:

1. Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per Design Basis Accident (DBA) conditions in accordance with ANSI NlOl.2-1972, ANSI N5.12- 1974, or ASTM D-3911. Ensure that a Coatings Manufacturer's Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P Attachment 1.

2. Carbo Zinc 11 was the original coating applied to the Primary Containment shell as a primer paint. Carboline Test Report #02182 documents Nuclear Service Level I qualification at 1E9 rads.

11. Use of Carbo Zinc 11 with a surface prep of SSPC SP-11 is for MaintenanceRepairEouchup coating activities only. Although this surface prep has been satisfactorily DBA and rad tolerance tested, it has been decided to limit any single coating area to <12 ft2.

Appendix A PP 7037 Rev. 1 Page 1 of 13

APPENDIX A (Continued)

Type of Coating Activity: Repair or General >12 ft2 Substrate: SteeI

Coating Type: Self-curinn, Solvent Based, Inorganic Zinc Silicate

Coating Manufacturer: Carboline Surface: DrvwelVTorus Shell or Head

Service Exposure: Non-immersion CSDS NO.: CZ1 1-RG

Notes: 1 . Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per Design

Basis Accident (DBA) conditions in accordance with ANSI N101.2-1972, ANSI N5.12-1974, or ASTM D-3911. Ensure that a Coatings Manufacturer's Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P Attachment 1.

2. Carbo Zinc 11 was the original coating applied to the Primary Containment shell as a primer paint. Carboline Test Report #02182 documents Nuclear Service Level I qualification at lE9 rads.


~~ ~


[CharacteristicsData 1st Coat 2nd Coat 3rd Coat Comments Product 6548/7107 6548/7 107 N/A

Type of Coating Activity: Repair Substrate: Steel Service Exposure: Non-Immersion Coating Type: High Solids, Polyamide Epoxy

WFT (mils) DFT (mils) Recoat Time Max. Recoat Time Cure Time

Coating Manufacturer: Keeler & Long PPG Surface: Any except Drywell Head CSDS NO.: 6548107-R

6 - 13 6 - 13 N/A Depends on thinning 4 - 9 4 - 9 N/A Qual range is 8 - 18 mils

48 hrs 48 hrs NJA None None NfA

24 - 72 hrs 24 - 72 hrs N/A Depends on temp.; See APG-2

Notes: 1. Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per Design

Basis Accident (DBA) conditions in accordance with ANSI NlO 1.2- 1972, ANSI N5.12- 1974, or ASTM D-39 1 1. Ensure that a Coatings Manufacturer’s Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P attachment 1 .

2. K&L 6548/7 107 was approved for use under EE 95-0227- 162 1 and EDCR 80- 1 1. Nuclear Service Level I qualification is documented in K&L Test Report #78-08 10-1 at E9 rads.

1 1. Use of these coatings, with surface preps of SSPC SP-2, SP-3, or SP- 1 I , are for Maintenance or Touch-up coating activities only. Individual areas for Maintenance or Touch-up coating should be limited to <150ft2. Areas larger than 150ft2 should have consideration given to a complete recoat activity, where the surface to be coated will be blast cleaned and have a surface profile re-established.

Appendix A PP7037Rev. 1 Page 3 of 13


lCharacteristics/Data 1st Coat 2nd Coat 3rd Coat Comments Product 654817 107 654817 107 NIA Color White tint White NIA Different colors are recommended Thinner 4093 4093 NIA If Temp. 86 - 120 deg F, use #2200 Surface Prep. Sp 6 Clean dry NIA Min. surface prep Surface Profile (mils) 1 - 3 NIA NIA

Type of Coating Activity: General Substrate: Steel Service Exposure: Non-Immersion Coating Type: High Solids, Polvamide Epoxy

WFT (mils) DFT (mils) Recoat Time Max. Recoat Time Cure Time

Coating Manufacturer: Keeler & Long PPG Surface: Anv except Drywell Head CSDS NO.: 6548107-G

6 - 13 6 - 13 NIA Depends on thinning 4 - 9 4 - 9 NIA Qual range is 8 - 18 mils

48 hrs 48 hrs NIA None None NIA

24 - 72 hrs 24 - 72 hrs NIA Depends on temp.; See APG-2

Notes: 1.

4.

10.

Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per Design Basis Accident (DBA) conditions in accordance with ANSI N101.2-1972, ANSI N5.12-1974, or ASTM D-3911. Ensure that a Coatings Manufacturer's Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P Attachment 1.

K&L 654817 107 was approved for use under EE 95-0227- 162 1 and EDCR 80- 1 I . Nuclear Service Level I qualification is documented in K&L Test Report #78-08 10-1 at E9 rads.

Use of these coatings, with surface preps of SSPC SP-2, SP-3, or SP-11, are for Maintenance or Touch-up coating activities only. Individual areas for Maintenance or Touch-up coating should be limited to < 1 50ft2. Areas larger than 150ft2 should have consideration given to a complete recoat activity, where the surface to be coated will be blast cleaned and have a surface profile re-established.



lCharacteristics/Data 1st Coat 2nd Coat 3rd Coat Comments I Product 654817 107 N/A NIA Color White tint NIA NJA

Type of Coating Activity: Maintenance Touch-uD Substrate: Steel Service Exposure: Non-Immersion Coating Type: High Solids. Polyamide EPOXY

lCharacteristics/Data 1st Coat 2nd Coat 3rd Coat Comments I Product 654817 107 N/A NIA Cnlar White tint NJ A NIA

Coating Manufacturer: Keeler & Long PPG Surface: Any except Drvwell Head CSDS NO.: 6548/07-M/T

Thinner 4093 NIA N/A If Temo. 86 - 120 dee F. use #2200 NIA- I N/A IIf Temo. 86 - 120 dee F. use #2200 I

DFT (mils)

Recoat Time Max. Recoat Time Cure Time

Notes: 1. Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per

Design Basis Accident (DBA) conditions in accordance with ANSI NlOl.2-1972, ANSI N5.12-1974, or ASTM D-3911. Ensure that a Coatings Manufacturer's Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P Attachment I .

8 - 9.5 NIA NIA Qual range is 8 - 18 mils;

48 hrs N/A NIA None NIA NIA

Single coat max is 9.5 mils

24 - 72 hrs NIA N/A Depends on temp.; See APG-2

4. K&L 6548/7 107 was approved for use under EE 95-0227-1621 and EDCR 80-1 1. Nuclear Service Level I qualification is documented in K&L Test Report #78-0810-1 at E9 rads.

10. Use of these coatings, with surface preps of SSPC SP-2, SP-3, or SP-11, are for Maintenance or Touch-up coating activities only. Individual areas for Maintenance or Touch-up coating should be limited to <I 50ft2. Areas larger than 150ft2 should have consideration given to a complete recoat activity, where the surface to be coated will be blast cleaned and have a surface profile re-established.



DFT (mils) Recoat Time Max. Recoat Time Cure Time

5 - 1 8 N/A NIA Max coating system mils

None NIA NIA 12 - 72 hrs NIA NIA Depends on temp.

48 - 72 hrs NIA N/A Depends on temp.

Notes: 1 . Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per

Design Basis Accident (DBA) conditions in accordance with ANSI NlOl.2-1972, ANSI N5.12-1974, or ASTM D-39 1 1. Ensure that a Coatings Manufacturer's Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P Attachment 1.

3. K&L 4500 for steel and concrete was approved for use under EE 95-162. Nuclear Service Level I qualification is documented in K&L Test Report #85-0404 at 1E9 rads. K&L 4500 was approved for use as a DBA qualified repair coating over K&L 7475 (and 654817107) as documented in Keeler & Long report, "DBA Qualification Testing of Systems S-1 and KL-2 Repaired with No. 4500", dated Aug. 4, 1986. (The latter report did not include irradiation testing, however, the coating was subjected to a 340°F, I 18 psi test that is more conservative than values in Test Report #85-0404.)



Type of Coating Activity: Maintenanceflouchur, Substrate: Steel Service Exposure: Non-Immersion Coating Type: High Solids, Polvamide Epoxv

Coating Manufacturer: Keeler & Long PPG Surface: Any except Drywell Head CSDS NO.: 4500-IWT


Design Basis Accident (DBA) conditions in accordance with ANSI N101.2-1972, ANSI N5.12-1974, or ASTM D-39 1 1. Ensure that a Coatings Manufacturer's Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P Attachment 1 .

3. K&L 4500 for steel and concrete was approved for use under EE 95-1621. Nuclear Service Level I qualification is documented in K&L Test Report #85-0404 at 1E9 rads. K&L 4500 was approved for use as a DBA qualified repair coating over K&L 7475 (and 6548/7107) as documented in Keeler & Long report, "DBA Qualification Testing of Systems S-1 and KL-2 Repaired with No. 4500", dated Aug. 4, 1986. (The latter report did not incIude irradiation testing, however, the coating was subjected to a 340"F, 1 18 psi test that is more conservative than values in Test Report #85-0404.)

Appendix A PP7037Rev. I Page 7 of 13


Type of Coating Activity: MaintenanceITouchudRewiir Substrate: Service Exposure: Non-Immersion

Coating Manufacturer: Carboline Surface: Any in Drvwell below 274’ Elev.

And any in Vent Header Coating Type: High Solids, Self-Priming, Cross-linked Epoxy CSDS NO.: 4500-WT-R

Notes: 1.

5.

IO.

Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per Design Basis Accident (DBA) conditions in accordance with ANSI NlOl.2-1972, ANSI N5.12-1974, or ASTM D-39 1 I . Ensure that a Coatings Manufacturer’s Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P Attachment I .

Carboline 890 was approved for use under EDCR 97-423. Nuclear Service Level I qualification is documented in Carboline Test Report #02927 at 2E8 rads. Carboline Test Report W285 1 1 tested 890 to lE9 rads: there were blisters and most cracked, but all remained intact.

Use of these coatings, with surface preps of SSPC SP-2, SP-3, or SP-11, are for Maintenance or Touch-up coating activities only. Individual areas for Maintenance or Touch-up coating should be limited to c 1 50ft2. Areas larger than I50ft’ should have consideration given to a complete recoat activity, where the surface to be coated will be blast cleaned and have a surface profile re-established.

Appendix A PP 7037 Rev. I Page 8 of 13


Type of Coating Activity: MaintenanceITouchuplRepair Substrate: Concrete

Coating Type: High Solids, Polvamine EPOXY over a Polyamide Epoxy Sealer/Curing Compound

Coating Manufacturer: Keeler & Long PPG Surface: Drvwell Floor or Pedestal Walls

Service Exposure: Non-Immersion and Immersion CSDS NO.: 4500-C-IWT-R

Notes: 1.

3.

Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per Design Basis Accident (DBA) conditions in accordance with ANSI NlOl.2-1972, ANSI N5.12-1974, or ASTM D-3911. Ensure that a Coatings Manufacturer's Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P Attachment 1.

K&L 4500 for steel and concrete was approved for use under EE 95- 1621. Nuclear Service Level I qualification is documented in K&L Test Report #85-0404 at lE9 rads. K&L 4500 was approved for use as a DBA qualified repair coating over K&L 7475 (and 6548/7107) as documented in Keeler & Long report, "DBA Qualification Testing of Systems S- 1 and KL-2 Repaired with No. 4500", dated Aug. 4, 1986. (The latter report did not include irradiation testing, however, the coating was subjected to a 340"F, 1 18 psi test that is more conservative than values in Test Report #85-0404.)



Type of Coating Activity: Repair or General Substrate: Concrete Surface: Drvwell Floor onlv

Coating Type: 99% Solids. Self-Leveling, Epoxv/Amine over an Epoxv/Amido-Amine PrimedSealer

Coating Manufacturer: Keeler & Long PPG

Service Exposure: Non-Immersion and Immersion CSDS NO.: 5000-C-RG

kharacteristics/Data 1st Coat I 2ndCoat 1 3rdCoat (Comments


Design Basis Accident (DBA) conditions in accordance with ANSI N101.2-1972, ANSI N5.12-1974, or ASTM D-39 1 1. Ensure that a Coatings Manufacturer's Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PP0958P or PPO959P Attachment 1 .

6 . K&L 5000 over K&L 6129 is approved for use as a Nuclear Service Level I qualified coating and is documented in K&L Test Report #90-0227 at 1E9 rads.



Type of Coating Activity: Repair or General Substrate: Steel Surface: Torus Shell

Coating Type: Self-Curing, Solvent Based, Inorganic Zinc Silicate

Coating Manufacturer: Carboline

Service Exposure: Immersion CSDS NO.: CZ11 -RG( 1 )

Notes: 1 .

2.

7.

11.

Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per Design Basis Accident (DBA) conditions in accordance with ANSI N101.2-1972, ANSI N5.12-1974, or ASTM D-391 I . Ensure that a Coatings Manufacturer's Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P Attachment 1.

Carbo Zinc 1 1 was the original coating applied to the Primary Containment shell as a primer paint. Carboline Test Report #02182 documents Nuclear Service Level I qualification at lE9 rads.

Carbo Zinc cannot be used unless the Torus is dewatered.

Use of Carbo Zinc 11 with a surface prep of SSPC Sp-1 1 is for Maintenance/Repair/Touchup coating activities only. Although this surface prep has been satisfactorily DBA and rad tolerance tested, it has been decided to limit any single coating area to <12 ft2.



Recoat Time Max. Recoat Time Cure Time

Type of Coating Activity: MaintenanceITouchup or General Substrate: Steel

Underwater Coating Type: 100% Solids, Special Formulated Epoxy Polyamine that cures underwater

Coating Manufacturer: Thin Film Technologies Surface: Torus Shell - Submerged

Service Exposure: Immersion-Coating is Applied & Cured CSDS NO.: BD-561 -M/T-R(U)

12 - 24 hrs N/A NIA None NIA NIA 14 hrs NIA NIA

Notes: 1 .

8.

12.

Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per Design Basis Accident (DBA) conditions in accordance with ANSI N101.2-1972, ANSI N5.12-1974, or ASTM D-3911. Ensure that a Coatings Manufacturer’s Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or PPO959P Attachment 1.

Bio-Dur 561 was approved for use under EE 150. Nuclear Service Level I qualification is documented in Rust Utility Services, Inc. Underwater Construction Division report, “Underwater Coating Design Basis Accident Specimen Evaluation Report, dated Dec. 18, 1995, at 2.43E8 rads.

Use of underwater curing epoxies for Maintenance/Repair/Touchup coating activities will be restricted to individual coating spots, only as large as necessary to repair the identified defect. Underwater cured epoxies are not to be used as coating material for general (large) coating activities.

Appendix A PP 7037 Rev. 1 Page 120f 13


IC haracteristicsmata 1st Coat 2nd Coat 3rd Coat Comments Product UT-790 * N/A NIA *Supplied by Underwater Engineering

Color Light Gray NIA NIA Thinner None NIA NIA Surface Prep. SP 11 N/A NfA Surface Profile (mils) N/A N/A N/A Surface must be rough

Ser.

Cure Time I 7days * I NIA NIA I* At 70°F Notes: 1. Paints to be used in the Primary Containment are to be procured as qualified for Coating Service Level I per Design Basis

Accident (DBA) conditions in accordance with ANSI N101.2-1972, ANSI N5.12- 1974, or ASTM D-39 11. Ensure that a Coatings Manufacturer's Product Identity Certification has been supplied for each batch. Attach a copy of the Product Identity Certification to PPO958P or 0959P Attachment 1.

9. C-790 and UT-15 were approved for use under EE 95-0227-1628. Nuclear Service Level I qualification for UT- 15 is documented in S.G. Pinney & Associates, Inc. report, "Design Basis Accident and Irradiation Testing of Coating Repair Materials for Use in Boiling Water Reactor Suppression Chamber Immersion Areas", dated Nov. 30, 1992 at 6E8 rads. Nuclear Service Level I qualification for C-790 is documented in S.G. Pinney & Associates, Inc. report, "Coating Systems Tested on Steel Panels for Irradiation and Design Basis Accident Criteria Requirements", dated Jan, 19, 1990 at 5.78E9 rads. (The latter report was prepared for Duane Arnold Plant). C-790 was manufactured by Wisconsin Protective Coatings. UES purchased the formula for C-790 and changed the name to UT-790 and has it manufactured for them by Picco Coatings Co.

12. Use of underwater curing epoxies for MaintenanceAXepairlTouchup coating activities will be restricted to individual coating spots, only as large as necessary to repair the identified defect. Underwater cured epoxies are not to be used as coating material for general (large) coating activities.


VERMONT YANKEE COATING PROGRAM AS-FOUND SLI OR SLIII INSPECTION RECORD SHEET

lWO# ]Date 1Pag.e of ~

Bld&El& ~ /Room or Area SERVICE LEVEL SUBSTRATE & CONDITION

Items Coated INSPECTOR NAME WORK PARTY LEADER

DESCRIPTION OF DETERIORATION r

SKETCH OR PHOTO

SKETCH OR PHOTO OF EFFECTED AREA

COATING COORD. NOTIFIED BY

VYPPF 7037.0 1 PP 7037 Rev. 1 Page 1 of 1

___ ~.

x - . , i:*= 'i 7 7"' January 20,1998 $G ,;=: # I

8 n .LL, TO:

FROM:

ENRICO BETTI - DESIGN ENGINEERING

JON T. TODD - MAINTENANCE I

SUBJECT: EDCR 97-423: ADDITIONAL INFORMATION YOU REQUESTED REF, FAX OF

1. Existing containment coating design basis. briefly. - Ans.: G E Design Specification for Protective Coatings - Special

#22A1182, Rev. I, MPL #1-155, June 12,1967 (InfomatiorVFinal):

2.0 Obiective The objective In using protective coatings is to minimize equipment, piping, and building surface damage from process fluids and decontamination procedures.

4- Coatings listed in SchedUl8 B of the Appendix shall be used. The coatings listed are not necessarily intended to be of aesthetic value. The floors, walls, and ceilings to be coated shall be in accordance with Schedule A of the Appendix. In all cases, the coatings shall pe applied in accordance with the manufacturer's written instructions.

Amendjx - Schedule 9 A.1 .d)(4): The interior surfaces of the Torus. Coating "G". A.l .d)(5):

Coating "G" A.I .9:

The interior 4, exterior surfaces of the downcomers & header and the exterior surfaces of their support structure. Torus - A strip 24" Wide, Extending 12" Above & 12" Below Normal Water Line. Coating "I"

Amendix - Schedule 8 Coating "G": Resistant to Radioactive Decomposition. A coating to provide rust control for metal

parts exposed to high levels of radiation and to which a chemical resistant coating can be added even after a lay-up of several years, such as: Carbo Zinc I 1 DFT = 2.5 mils. A coating to protect surfaces, such as the inside of the dryweII where they are subject to high level radioactive elements, decontaminafion procedures or continuous emersion in water, such as: Amercoat 3786 Primer & Amercoat #66 Finish DFT' = 7.5 mils. Alternate: Phenoline 305, DFT = 6 mils.

Coating "I":

CB&I Cleaning and Painting Instructions Contract # 9-6202: Shop Paint: Inside: 1 Coat Carbo Zinc 11.2.5 mils Dry.

Outside - All Header Plates, All Vent Line Plates Inside SupDression Chamber, All Downcorner Pipes: 1 Coat Carbo Zinc 11, 2.5 mils Dry.

Field Paint: Inside - On All Other Parts of Vessel ShoD Painted with Carbo Zinc 11 : 1 Patch Coat Carbo Zinc 11,2.5 mils Dry.

EBASCO Services Letter, GR Latham to DJ Stephens, January 14,1969: Enclosed is a painting instruction sheet 5920-AS-Pl with recommended procedure for painting the primary containment vessels ... Torus and Intemals ... The finish paint is #7230 Subnarine White Enamel as manufacttired by Keeler & Long Co., Inc. of Waterbury, CT.

2. What are deemed the appropriaie requirements for new paint to meet or exceed design basis. Acceptability for WS-049 chemistry, temperature and radiatioo conditions.

Ans: The original design of the Torus coating system was a primer coat of inorganic zinc (IOZ) at a DFT of 2,5 mils and a belly-band at the spIash zone, one foot above and one foot below waterline, of an epoxy-phenolic paint. During the construction phase, the management determined that a general

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%.

topcoat would be applied over the primer. A phenoi!c mating was selected because of the hard surface film that it develops, which makes it less permeable.

EDCR 97-423 is returning half of the Torus interior surfaces to the original design specification: an inorganic zinc primer and a belly-band of epoxy-phenolic paInt. The IO2 being applied Is similarly identical to the original IOZ, with the exceptlon that the asbestos fibers in the original paint have now been removed. The absence of the asbestos fibers limits the amount of "build" that can be made with the 102 without incurring mudcracking: dry film thicknesses in excess of 6 mils increase the potential for mudcracking. The lead content in the "newer" paint has afso been reduced, however this element does not detract from the qualification of the origlnal paint. The EDCR 97-423 coating system selected for the Torus is a qualified coating system:

The paint repairs, to be made in the interlor of the Vent Header, are equal to the corrosion prevention of the original paint, however, they will be of a barrier method to prevent corrosion rather than a sacrificial anodic coating. Because the original coating system in the Vent Header consisted of a primer coat only of 102, to remove the primer coat and prepare the surface for recoating will incur an asbestos hazard that is not warranted. The 890 epoxy that has been chosen as a repair coating was selected due to its ability to be surface tolerant which means that it can be applfed to marginally prepared surfaces and still exhibit excellent adhesion qualities. The 890 epoxy has been DBA and rad tolerance tested for use at other nuclear facilities. VY has decided to call the Vent Header repafr an unqualified coating system because only a SSPC-SP-2 surface cleaning will be performed, vs. the SSPGSP-3 process that was used for the qualification tests, of whjch we,have a copy. The definition of acceptable condiff ons for SSPC-SP-2 is identical as SSPC-SP-3; the difference is in the tools used to produce the same resutt. SSPC-SP-2 uses hand took, whereas SSPC-SP-3 uses power tools, The use of power tools in the Vent Header at W would constitute an asbestos hazard and this is deemed to be unwarranted. Note: Carboline (FAX) has indicated that 890 epoxy applied over a surface prepped to SSPC- SP-2 is a qualified coating system.

Toms Environment "New" Coating

Accident Dose: Kat #7230: Unknown (22-1 1 SG1368WG: 2E8 Rads

(Drywell: 7E8 Rads) (Vent Hdr: 1E9 Rads)

COATINGS -SUMMARY OF TESTS

ANSI N5.12-1974 Resistance ASTM D 3912-80

Area] - 1

CONDITION RESULTS

3OO0F/48 PSIG Acceptable 302OF/11 days (ORNL) Acceptable

lE9 Rads Acceptable

Per Test Method and 90.0% , ORNL Drocedures 5 day immersion Acceptable

except for nitric acid

Taber Abrasion

Longer cure enhances results.

PARAMETERS

ASTM D 4541-85

CONDITION RESULTS

281'F 33 PSIG Acceptable

2E8 Rads Acceptable

Per Test Method and 77.a%% ORNL procedures

1 5OoF / 126 days No Effect

1000 cycles 36.6 mg loss 1 OOOg weight CS-17 wheel

Per test method 472 PSI**

~~~~ ~~~

Per test method Flame Spread 0

lone]

3.

'arboline 8 9 a o x y Went Header Repair Coating1

TEST METHOD CONDITION PARAMETERS

RESULTS

DBA

~~ ~~

Rad Tolerance

Decontamination

Chemical Resistance

Taber Abrasion

Elcorneter Adhesion

Fire Evaluation

ANSI Nl 01.2-1 972 I ASTM D 3911-89 2E9 Rads 32ODF/5O PSIG

ANSI N5.12-1974 1-01 E9 Rads

ANSI N5.12-1974 ASTM D 4258-83 ORNL procedures

ANSI N5.12-1974 5 day immersion

ASTM D 4082-83 - Per Test Method and

ASTM D 3912-80

ANSI N5.12-1974 1000 cycles 1 OOOg weight

61 92 CS-17 wheel ' Fed. STD 141 Method

ANSI N5.12-1974 Per test method

' ANSI NlO1.2-1972 Per test method

ASTM D 4541-85

1 ASTM E-84

~

Acceptable

Accept a bte

99.96%

Acceptable except for nitric

acid and potassium

permanganate

1 85mgloss

I 1 98OPSI

Flame Spread 5 i

Include update to FSAR affected sections including 14.9.1.6, page 14.9-6.

Ans: FSAR 14.9.1.6 [No changes were made to the 1st and 3rd paragraph of the current revisionl

2nd Para: Replace the 2nd paragraph with the following:

The interior pressure boundary surfaces of the drywell and torus have been prime coated with an inorganic zinc paint primer that will withstand the accident environment without failure (Carboline CZ- 11). This coating was radiation and DBA tested at Oak Ridge National Laboratory (ORNL Log Book No. A 7562; 11-294 and Log Book No. A9675, A1 0-1 3-3) and tolerated radiation doses of 1 E9 rads without failure. The total integrated 40 years normal operation and accident dose for the drywell is 7E8 rads.' The total integrated 40 years non'nal operation and accident dose for the torus is 8E7 rads?

The drywell surfaces were painted with a Keeler Long epoxy (No. 7475) to increase the illumination of the area and to provide for easy decontamination of the surfaces. The topcoat was the best available coating at the time, but it did not remain adhered to the primer in most of the upper levels of the drywell where temperature excursions have exceeded 250 O F . Approximately 75% of the surface area in the drywell (including structural Steel) is topcoated and, although the exact amount of coating that will disbond during an accident is not known, this total amount of paint has been used in calculating the amount that can transport to the torus during a DBA and this data has been used in sizing the ECCS strainers.

The torus surfaces were painted with a Keeler g Long phenolic resin paint (No. 7230) to increase the illumination of the area and to provide for easy decontamination of the surfaces. The phenolic paint was selected for its extremely hard surface and low permeability to water. Approximately 9% of the total vapor space surface area experienced a coating disbondment problem and these areas were scraped to remove the loose topcoat. The immersion area has withstood many years of immersion

5 - >

n ; . f I 1 1 - ---- .;-- -= j

Ref, W EQ Manual, Appendix B, Table 7.5.3 (No Beta Shield)

Ref. W EQ Manual, Appendix 6, Table 7.5.3 (Beta Shield)

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2 10 FILE

.a , ' * 1

service, however the three draindowns of the torus over theyears from 1972 to 1983 ha've caused the phenolic coating to become damaged: the coating drying out, mechanical damage from foot traffic and work activities, scaffolding, etc.. AIthough the exact amount of coating that will disbond durlng an accident is not known, the total amount of topcoat on the toms interior surfaces has been used in calculating the amount of paint that can affect the ECCS strainers during a DBA and this data has been used in sizing the ECCS strainers. During RFO XXI (1998), the immersion areas were recoated with an inorganic zinc paint and a belly-band of phenolic paint was applied at the splash zone to prevent tiger striping. The coating system used.is a qualified Nuclear Service Level 1 coathg in accordance with ANSI N l 01.2-1972 and was applied under an approved quality assurance program to ensure compliance with ANSI NlOl.4-1972. -

4. Address other program issues including; Fire Load, Personnel Hazards.

Ans: Prior to and during the application period, storage of the coatings and associated thinners have the potential to increase the fire loading in the Reactor Building. The potential fire hazards are being mitigated by the proper storing of these chemicals. The Fire Protection Coordinator and Fire Protection Engineer, as well as the Safety Coordinator, have been notified of the various chemicals that will be brought on-site and their input into the proper storage, use, and waste collection of these materials has been taken into account. Following the application and cure of the coatings, there is no additional tire burden added to the Torus or Vent Header than there was with the original coatings applied.

The personnel hazards associated with the removal of the "old"coating and the application of the "new" coating have also been taken into account. Due to the thickness of the "old" topcoat (K&L #7230) over the CZ-11 primer in the Torus, there is not an asbestos hazard involved with the removal of the "old" coa8ng because the asbestos content in the work area atmosphere will be 4%. Whereas, the same type of surface preparation in the Vent Header, as in the Torus, would cause an asbestos hazard, it was deemed unwarranted to use the Same type of coating; to eliminate this hazard, a surface tolerant coating was selected that is a qualified coating for non-immersion areas. Again, the Safety Coordinator has been involved in the planning stages of this project and the contractor is staffing Safety Personnel on each of the work shifts to provide adequate monitoring for safety concerns.

cc: Jim Cafchera - Project Manager [By VAX E-Mail] [By VAX E-Mail] Bill Wittmer - Maintenance Project's Manager

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