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Nuclear Operating Company

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November 11 1998NOC-AE-00035dFile No.: G3.0810CFR50.54(f)

U. S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, DC 20555

South Texas ProjectUnits 1 and 2

n'ocket Nos. STN 50-498, STN 50-499

Response to Generic Letter 98-04," Potential for Degradation of the Emergency Core CoolingSystem and the Containment Sp ay Spem After a Loss-of-Coolant Accident Because of

|Construction and Protective Coatine Deficiencies and Foreign Material in Containment" |

Pursuant to Generic ktter 98-04, the South Texas Project submits the requested informationregarding programs for ensuring that Service Level 1 protective coatings inside containment do |not detach from their substrate during a design basis Loss of Coolant Accident (LOCA) andinterfere with the operation of the Emergency Core Cooling System and the Contaimnent SpraySystem. The attached report describes: (1) programs implemented to ensure that Service Level 1protective coatings used inside containment are procured, applied, and maintained in compliancewith applicable regulatory requirements; and (2) means for identifying the impact of potentialcoating debris on plant response to a LOCA.

If there are any questions, please contact either Mr. P. L. Walker at (512) 972-839' or me at(512) 972-8787.

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/'fhf0Vice P s' ent,Engin .e ng & Technical Services

PLWAttachments: (1. Affidavit2. Response to Generic Letter 98-04

''9811230146 981111PDR ADOCK 05000498P PDR

200098

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NOC-AE-000350File No.: G3.08"

Page 2.

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Ellis W. Merschoff Jon C. WoodRegional Administrator, Region IV' Matthews & BranscombU. S. Nuclear Regulatory Commission ' One Alamo Center611 Ryan Plaza Drive, Suite 400 . 106 S. St. Mary's Street, Suite 700

. Arlington,TX 76011-8064 ' San Antonio,TX 78205-3692

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Thomas W. Alexion : Institute of Nuclear PowerProject Manager, Mail Code 13H3 Operations - Records Center i

U. S. Nuclear Regulatory Commission 700 Galleria Parkway ;

Washington, DC 20555-0001 Atlanta, GA 30339-5957

. Comelius F. O'Keefe ' Richard A. Ratliff i

Sr. Resident Inspector . Bureau of Radiation Controlc/o U. S. Nuclear Regulatory Commission . Texas Department of Health '

P. O. Box 910 - 1100 West 49th StreetBay City, TX 77404-0910 Austin, TX 78756-3189.

' - J. R.- Newman, Esquire D. G. Tees /R. L. Balcom> Morgan, Lewis & Bockius Houston Lighting & Power Co.' I800 M. Street, N.W. P. O. Box 1700. . Washington, DC 20036-5869 Houston,TX 77251

;

M. T. Hardt/W. C. Gunst Central Power and Light Company -City Public Service ATTN: G. E. Vaughn/C. A. JohnsonP. O. Box 1771 P. O. Box 289, Mail Code i15012 +

San Antonio,TX 78296 Wadsworth,TX 77483

A._ Ramirez/C. M. Canady U. S. Nuclear Regulatory CommissionCity of Austin Attention: Document Control DeskElectric Utility Department Washington, D.C. 20555-0001721 Barton Springs Road <

Austin,TX 78704

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UNITED STATES OF AMERICA.

-'NUCLEAR REGULATORY COMMISSION

i: In the Matter of ))

STP Nuclear Operating ) Docket Nos. 50-498 :Company, et al., ) 50-499) i

South Texas Project )Units 1 and 2 ) i

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AFFIDAVIT i

' I, T. H. Cloninger, being duly sworn, hereby depose and say that I am Vice President,.

Engineering & Technical Services, of STP Nuclear Operating Company; that I am duly authorized '

to sign and file with the Nuclear Regulatory Commission the attached response to Generic Letter98-04,~" 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"; that I am familiar with content thereof;. and that the matters set forth therein are true and correct to the best of my ledge and belief.

V ^^A/ff/ - ,' f-

'' lo'ninge[ !C

ice Presid ,.

ngineerin chnical rvices

STATE OFTEXAS .))

COUNTY OF MATAGORDA )

Subscribed and sworn to before me, a Notary Public in and for the State of Texas, this //r.bday of Wo /c m be r ,1998.

UNDA RiiTENBERRY, -

. % % sme Wreme AM cWIm*

hp Notary Public in and for the VState of Texas

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Attachment 2,

NOC-AE-030350,

Page 1 of 8

SOUTH TEXAS PROJECT'

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UNITS 1 & 2RESPONSE TO GENERIC LETTER 98-04

(1) [ Submit] a summary description of the plant-specific program or programsimplemented to ensure that Senice Level 1 protective coatings used inside thecontainment are procured, applied, and maintained in compliance with applicableregulatory requirements and the plant-specific licensing basis for the facility. Includea discussion of how the plant-specific program meets the applicable criteria of 10 CFRPart 50, Appendix B, as well as information regarding any applicable standards, plantspecific procedures, or other guidance used for: (a) controlling the procurement ofcoatings and paints used at the facility, (b) the qualification testing of protectivecoatings, and (c) surface preparation, application, surveillance, and maintenanceactivities for protective coatings. Maintenance activities involve reworking degradedcoatings, removing degraded coatings to sound coatings, correctly preparing thesurfaces, applying new coatings, and verifying the quality of the coatings.

RESPONSE:

The South Texas Project has implemented controls for the procurement, application, andmaintenance of Service Level 1 protective coatings used inside containment in a manner that isconsistent with the licensing basis and regulatory requirements applicable to the South TexasProject. The requirements of 10 CFR 50 Appendix B are implemented through specification ofappropriate technical and quality requirements for the Service Level I coatings program whichincludes ongoing maintenance activities.

For the South Texas Project, Service Level I coatings have been tested, selected, and applied toassure that they will withstand nuclear, chemical, and physical conditions of a Design BasisAccident, as required by Regulatory Guide (RG) 1.54 and ANSI N101.2-1972. Coatings usedinside the containment have been established as safety-related, thus imposing the quality assurancerequirements of Appendix B to 10 CFR Part 50.

Steel and concrete surfaces inside the Reactor Containment Building with protective coatings canbe grouped into three categories:

1. Major surfaces: This category includes large surfaces such as the Containment liner,structural steel, large uninsulated equipment and equipment supports, pipe whip restraints,polar crane, and concrete surfaces receiving epoxy surface systems.

Coatings for major surfaces are selected in accordance with the requirements of Section 4 ofANSI N101.2 and applied per RG 1.54, thus assuring that the majority of protective coatingsinside the Reactor Containment Building will remain intact in the post-accident environment.

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* -Attachment 2NOC-AE-030350Page 2 0f 8

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; 2.- Minor surfaces: This category includes such areas as routine touchup of damaged'

; . qualified coatings less than 30 in.2, spot pruning of bare areas, bolt heads / threads, nuts, -

i miscellaneous fasteners, tack and . stud welds, and coating of surfaces with limitedaccessibility for optimal performance of coating work. l

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? Coating products that have been tested and approved for use inside Containment are applied I

i to 'such minor surfaces :in accordance with . the' paint' manufacturer's instructions.j

| Enforcement of proper application and . inspection procedures, as' stated in project ;

L specifications, provide a high degree of assurance of post-LOCA film integrity for such cases -!where total compliance with RG 1.54 is impracticable.

; . 3. ' Miscellaneous surfaces: This category includes surfaces of limited square: footageconsisting primarily of smaller, off-the-shelf equipment and' components supplied .with |

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- manufacturers' standard finishes'(unknown or unqualifiable coating products). Examples of '

such items are electrical cabinetry, control panels, loudspeakers, light fixtures, small standard '

product line pumps, motors, and valves. This category also includes such field applicationsas repairs to galvanizing and identification painting (e.g., stenciling, pipe banding, etc.).

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In addition to the above general criteria, it should be noted that the requirements of RG 1.54 are jL not imposed in the following applications:

|- ~1.- Coating of surfaces that are insulated or otherwise enclosed in normal service; e.g.,| interiors of cabinets, heating, ventilating, and air-conditioning (HVAC) ducts.

2. Concrete receiving a non-film forming clear sealer coat only.

For equipment in Westinghouse's scope of supply, coatings quality assurance meets the intent ofRG.1.54 as described in letter NS-CE-1352 from Westinghouse to the Nuclear. Regulatory !

. Commission (NRC) dated February ~ 1,1977, as accepted and approved by the NRC in!

cormspondence dated April 27,1977 (C. J. Heltemes, Jr. to C. Eicheldinger).

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. Updated Final Safety Analysis Report (UFSAR) Table 6.1-4 (attached) provides a coatingschedule for painted surfaces inside the Reactor Containment Building including equipment in theSouth Texas Project scope of supply. The quantity of paint that does not meet the requirementsof RG 1.54 is estimated and verified as work progresses during plant maintenance activities.Quantities of qualified coatings are not similarly tracked. This table estimates the total quantity of

R ' coating systems to indicate that the majority of surfaces have qualified coatings (i.e., provide arelationship of qualified vs. unqualified coatings)..

Adequ' ate assurance that the applicable requirements for procurement, application, inspection, andmaintenance are implemented is provided by procedures and programmatic controls approved.

L under the South Texas Project Quality Assurance Program.L

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Attachment 2 !,_

NOC-AE-000350,

Page 3 of 8

. (a); Service Level I coatings used for new applications or repair / replacement activities areprocured from vendors with a quality assurance program meeting the applicable requirements ;

of 10 CFR Part 50 Appendix B. The applicable technical and quality requirements that the ,

vendor is required to meet are specified by the South Texas Project in design specificationsand associated procurement documents. The design specification states that all material

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furnished shall meet the requirements of Section 4.0 of ANSI N101.2-1972. Acceptance I

activities are conducted in accordance with procedures that are consistent with ANSI N45.2requirements _ (e.g., receipt inspection, source surveillance, etc.). This specification ofrequired technical and quality requirements combined with appropriate acceptance activitiesprovides adequate assurance that the coatings received meet the requirements of theprocurement documents.

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(b) The qualification testing of Service Leyel I coatings used for new applications orrepair / replacement activities inside containment meets the applicable requirements contained

;in the standards and regulatory commitments referenced above. These coatings have beenevaluated to meet the applicable standards and regulatory requirements previouslyreferenced. For new applications or repair / replacement activities for the coating categorydefined as." miscellaneous surfaces", coatings that have not met the required qualificationtesting have been applied in containment. These activities do not add to the amount ofungealified coating previously addressed in the safety analysis report because the existingcoatig has been addressed as unqualified.

(c) The surface preparation, application, surveillance, and maintenance activities duringinstallation of Service level I coatings used for new applications or repair / replacementactivities inside containment meet the applicable portions of the standards and regulatorycommitments referenced above. Documentation of completion of these activities isperformed consistent with the applicable requirements. Where the requirements of thestandards _ and regulatory commitments do not address or are not applicable to,

repair / replacement activities, these activities are performed in a manner consistent withgenerally accepted practices for coating repair / replacement.

- The South Texas Project periodically conducts condition assessments of Service Level I coatings3

inside containment. Coating condition assessments are conducted as part of the structures |: monitoring program. The structures monitoring program covers the baseline inspection and !subsequent inspections that are conducted at intervals not exceeding five years. Additional linspections may be necessary depending on inspection results. Visual inspection of coatings incontainment is intended to characterize the condition of the coating ,pems. In some cases, af

complete inspection is not possible due to inaccessibility. For these ca m we coating systems are' characterized based on an inspection of coating systems that are reasonably accessible or based ona representative sample. If localized areas of degraded coatings are identified, those areas areevaluated and scheduled for repair / replacement, as necessary. The periodic conditionassessments, and the resuhing repair / replacement activities, assure that the amount of Service,

'~ Level I coatings which may be susceptible to detachment from the substrate during a LOCAevent is minimized.

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Attachment 2,;

NOC-AE-000350.,

Page 4 of 8 i

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, (2) [ Submit] information demonstrating compliance with item (i):

(i) For plants with licensing-basis ' requirements for tracking the amount of- unqualified coatings inside the _ containment and for assessing the impact ofpotential coating debris on the operation of safety-related SSCs during apostulated design basis LOCA, the following information shall be provided todemonstrate compliance:

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.(a) ' The date and findings of the last assessment of coatings, and the planneddate of the next assessment of coatings.

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. RESPONSE:

| The latest condition assessment at the South Texas Project for Unit IL Containment wasL ' performed during refueling outage IREO7 in September 1997. The latest assessment for Unit 2

Containment was performed during refueling outage 2RE06 in October 1998. These condition .'

assessmente, did not identify any cases of degraded coatings where delamination between thecoating and the substrate had occurred. The scheduled date of the next condition assessmentcoincides with the next refueling outage for each individual unit. The next Unit I refueling

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outage,1RE08,'is scheduled to start in March 1999. The next Unit 2 refueling outage,2RE07, is'

! scheduled to startin October 1999.i.

(b) The limit for the amount of unqualified protective coatings allowed in thei

containment and how this limit is determined. Discuss any conservatism inthe method used to determine this limit.

-RESPONSE: -

The limit for unqualified coatings for the South Texas Project is documented in UFSAR Table6.1-4. This was developed during initial plant licensing. Table 6.1-4 gives estimates of the a

various categories of surface areas protected with paints that do not comply with the_ quality,

standards of ANSI N101.2 (1972) or that were applied in ways not providing the level of quality'

L assurance outlined in Regulatory Guide 1.54. The reported amount for unqualified coatings! includes an allowance for future additions which is tracked by the South Texas Project.

UFSAR Table 6.1-4 also provides the qualification information for coating materials used inside.. containment. As shown by the table, only a small fraction of these coatings is not qualified to thei:requirements of Regulatory Guide 1.54.

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The expected debris generated under Design Basis Accident conditions are pieces of insulationand paint chips. Evaluation of the transport of debris to the emergency sumps showed that the-possibility of debris reaching the sump screens is remote. The evaluation concluded that fibrous

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Attachment 2NOC-AE-000350,

Page 5 of 8

insulation inaterial should be considered as sump screen blockage, but that paint chips could beexcluded from consideration for sump screen blockage material. Therefore, the amount ofunqualified coatings was not explicitly used in the calculations for the Emergency Core CoolingSystem sump head loss.

(c) If a commercial grade dedication program is being used at your facility fordedicating commercial-grade coatings for Service Level 1 applications insidethe containment, discuss how the program adequately qualifies such acoating for Service Level 1 service. Identify which standards or otherguidance are currently being used to dedicate containment coatings at yourfacility:

RESPONSE:

The South Texas Project does not currently employ commercial grade dedication for ServiceLevel I coatings used inside containment.

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| Attachment 2 .

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iNOC-AE-0003501t . Page 6'_ofJ8 <

TAetE6U1-4*

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COATING SCHEDULE FOR SURFACES INSIDE CONTAIINENT *.

(EXCLUDING NS$$ SCOPE OF SUPPLY)-,

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Estimated Meets .Anticipateif : I

S@ strate . Generic Total Res. 'Hominst- DFT (mits) -!or

._

Type of Square Ft Guide Mfe. Inittet After- !

Cat a i Item n u ristian Costina Per Unit (II 1.54 Std. DFT toits)I4I 40 wrs ,

10Z + Epoxy 35,340 Yes 8-10 8-10Carborn Steel Dome - Unit I .

10Z- 35,340 Yes 2-5 2-5~;

Liner Plate ~ Dome - Unit IIWatts - Unit I. Epony + Epoxy 77,400. Yes. 10-12 10-18 ,

Watts - Unit 11' 10Z + Epoxy 77,400 Yes 8-10 8-16-., '

Concrete Wells Epoxy System 109,250 Yes 10-40- 10-46''

Celtings Epoxy System 5,650 Yes 10-25 10-25-

Celtings Cteer Seeter 14,290 - No (2) N.A. N.A. i

Floors Epoxy System 38,140 Yes '15-40. 18-52K5) .;

Reactor Cavity Epoxy System 4,050 No 37 (everage)toStructural,HSteet '

to ,

Primary &

7.Second Stl. 102 64,750 Yes 2-5. 2-5 @,

3.

H Second Stt. 10Z + Epoxy 34,860 Yes 8-10 8-10 hPrimary &r

. Pipe Whip Restraints 102 + Epoxy 48,560 Yea 8-10 8-10 to I#

bMatches (Equipment 10Z + Epoxy 740 Yes 8-10 14-16 ;

and Personnel) i

Crane Spts. & RailUnit I Epoxy + Epoxy. 11,240. Yes 7-14 7-14 :

,iCrane S gts. & RaftUnit II 10Z 11,240 Yes 2-5 2-5 .

Personnet Doors Atkyd 750 No . X 3-5 10-15 -|

Esbedded Plates IOZ + Epoxy 13,240 Yes. 7-14 7 18'

Embedded Plates 10Z . 3,570 Yes 2-5 2-5 .;**

Misc. Steel 10Z' 2,000 No (3,6)10Z + Epoxy 2,500 No (3'03

I80I. Epoxy 2,500 No

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HVAC Air Mandling Units IOZ + Epoxy 820 Yes 8-10 8-10 :

h Ring Duct & R. A..

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$ Risers 10Z . 63,170 Yes 2-5 2-5

Ducts (RCFC) 102 3,040 Yes 2-5 2-5se

7 Carbon Units 10Z + Epoxy 2,300 Yes 8-10 8-10

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Page 7 of 8. - .;- -

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' TASLE 6.1-4.(Contfrused) .>

*COATIgg emsms_m F FOR SURFACES INSIDE CONTAIINNENT ,

.(EXCLtDING NS$$ SCOPE OF SUPPLY)~-

Estimated- Meets ...

Anticipated -

Substrate Generic Totet . Reg. Nominst DFT (efts)

or Type of Square Ft . Guide- Mfg. .Inittet After

Cata v Item 7,w -slotten Coetins Per Unit (II 1.54 Std. DFT taita)I'I 40 m \!

Electrical Control Panels Intssnescent 350 No 12-14 12-14 !

f' Terminst sexes,Light Fixtures, etc. Baked Enemel 11,100 No X 2-4 2-4 4

Carbon Steel Pipe Uninsulated' IOZ 1,200 Yes 2-5 2-5 ~!

: Piping Systems - Pipe uninsulated 102 11,600 No X 2-5 2-5 ;

Pipe Sipports 10Z 5,340 .Yes- 2-5 2-5 . ;-I$I . 1-1/2 (5)Pipe Sipports Epoxy 2,670 Yes 1-1/2

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Yes 8-10 10-16Vatwes & Operators IOZ + Epoxy. 1,280 ('INo x 3-6 8-12 iSmall Pumps & Motors -- taked Enemet 250 ('I No X 2-5 ' 2-5 m

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Velves & Operators 10Z 600 (0)Valves & Operators unknoin 250 No x Unknoim Q j

R~* Mechanicet ,..

' Equipment-[ Polar Crane IOZ + Epoxy 16,000 Yes 8-10 8-10 %e* i

'N Monorails & Noists Zinc-Rich 665 No .x 4-6 8-10 M *

Equip. Supports 10Z + Epoxy- 7,200 Yes 8-10 10-16' % !Yes 2-5 2-5 t

Equip. Supports 10Z 3,880 (63Misc. Equip. & Items unknoin 2,000 No X Unknoem ,

Firehose Cabinets Baked Enamel 500 No X Unknote i

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Page 8.'of 81 >

e'' Notes for Table 6.1-4

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*(1)' Not used.

(2) Seater is a nonfilm-forming surface conditioner to minimize concrete dusting. 6

(3) Paint materiets used ere quotified to Aust N101.2, but were applied without complete OA documentation.,

(4) - For multiple costsi the stated Mrs represent the typical totet film thickness range expected. In tocet erees, higher or_ towerthicknesses are expected as a result of variations within the specified ranges for individual coets.

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; (5). One to four addittonet topcoats of 8 mits (less weardown of 5 miis) assumed.

(6) The quantity of point that does not meet the requirements of RG 1.54 is estimated and will be verified as work progresses during plantmaintenance activities. ouentities of qualified coatings are not simiterly tracked. |

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(7) The total estimated surface area pointed with inorganic zine silicate (102) is 159,815 f t' (825 lbs) for Unit 1 and 206,395 f t' (900 lbs)-

for Unit 2...nt g

(8) this table estimates the totet quantity of coating systems to indicate that the mejority of surfaces have quellffed coetings (i.e. provide e *ts

e relationship of quotified vs. saiquellfied coatings). febte 6.2.5-5 provides a conservative value for zine used inside containment for the E .

(A'. hydrogen generation calculatinn..

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%Abbreviations used in Table 6.1-4 .

DFT = Dry Film Thickness ;

f

102 = Inorganic Zine Coating

Epoxy System = Migh' solids water-borne epoxy surfacer with polysmide-cueed epoxy topcoat.

Intumescent = Fire-retardent, solvent-based modified epoxy coating.

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