Regulatory Guide 3.30

Selection, Application, and Inspection of Protective Coatings (Paints) for Fuel Reprocessing Plants

ML12220A060
Person / Time
Issue date:	06/30/1975
From:	Office of Nuclear Regulatory Research, NRC/OSD
To:
References
RG-3.030
Download: ML12220A060 (3)

U.S. NUCLEAR REGULATORY COMMISSION June 1975 REGULATORY GUIDE

OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 3.30

SELECTION, APPLICATION, AND INSPECTION OF PROTECTIVE COATINGS

(PAINTS) FOR FUEL REPROCESSING PLANTS

A. INTRODUCTION

nuclear plants by using reproducible tests. The standard also provides guidance for preparing the surfaces to be Appendix B, "Quality Assurance Criteria for Nuclear coated and for applying and inspecting the coatings Power Plants and Fuel Reprocessing Plants," to 10 CFR under both shop and field conditions. The standard Part 50, "Licensing of Production and Utilization defines the performance requirements of coatings and Facilities," establishes quality assurance program provides tests for radiation tolerance, decontamination, requirements for the design, construction, and operation chemical resistance, and physical properties. This of structures, systems, and components of fuel standard, identified as ANSI N512-1974,I was approved reprocessing plants. Criterion III, "Design Control," of by American National Standards Committee N46 and, Appendix B requires assurance that appropriate quality subsequently, on June 21, 1974, by the American standards are specified and that measures be established National Standards" Institute.

for selecting appropriate materials for such structures, This standard may be used for structures, systems, systems, and components; Criterion IX, "Control of and components of fuel reprocessing plants and should Special Processes," requires that special processes be be used in conjunction with Regulatory Guide 3.21, controlled and accomplished by qualified personnel "Quality Assurance Requirements for Protective using qualified procedures in accordance with applicable Coatings Applied to Fuel Reprocessing and to Plutonium codes and standards; and Criterion X, "Inspection," Processing and Fuel Fabrication Plants," which refers to defines requirements for inspecting activities affecting ANSI N101.4-1972, "Quality Assurance for Protective quality. Coatings Applied to Nuclear Facilities."

Protective coatings (paints) are used in fuel reproces- Section 1.2.2 of ANSI N512-1974 makes reference to sing plants to preserve from corrosion and erosion the American National Standard N101.2-1972, "Protective surfaces of structures, systems, and components impor- Coatings (Paints) for Light Water Nuclear Reactor tant to safety and to facilitate the removal of radioactive Containment Facilities," as a standard for the selecting contamination from all such plant surfaces during plant and evaluating of protective, coatings specifically for operation, maintenance, and decommissioning. Many nuclear reactor containment facilities. The exposure acceptable practices for the selection, application, and conditions and corresponding test conditions given inspection of protective coatings are available and have therein, in particular the Design Basis Accident (DBA)

been used. These practices can differ significantly conditions, are not necessarily applicable to any because there has not been sufficient guidance toward standardization. In the interest of standardization, this conditions expected to be found in a fuel reprocessing guide describes practices acceptable to the NRC staff for plant or to the appropriate tests for coatings for fuel the selection, application, and inspection of protective reprocessing plant structures, systems, and components.

coatings for fuel reprocessing plants.

Most polymers such as those now used in paint

B. DISCUSSION

formulation are subject to radiation damage with the production of hydrogen gas and methane, among other Subcommittee N46-5 of American National radiolysis products. Normally this is of no great Standards Committee N46, "Nuclear Reactor-Fuel. consequence since the production rate is very low even Cycle," under the sponsorship of the American Institute 1 Copies may be obtained from the American Institute of of Chemical Engineers, has developed a standard for Chemical Engineers, 345 East 47th Street, New York, NY

evaluating and selecting protective coatings (paints) for 10017.

USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Commission. U.S. Nuclear Regulatory Guides are issued to describe and make available to the public Regulatory Commission. Washington. D.C. 20555. Attention: Docketing and Service Section.

methods acceptable to the NRC staff of implementing specific parts of the Commission's regulations, to delineate techniques used by the staff in evalu- The guides are issued in the following ten broad divisions:

ating specific problems or postulated accidents, or to provide guidance to appli- cants. Regulatory Guides are not substitutes for regulations. and compliance 1. Power Reactors 6. Products with them is not required. Methods and solutions different from those set out in 2. Research and Test Reactors 7. Transportation the guides will be acceptable if they provide a basis for the findings requisite to 3. Fuels and Materials Facilities 8. Occupational Health the issuance or continuance of a permit or license by the Commission. 4. Environmental and Siting 9. Antitrust Review Comments and suggestions for improvements in these guides are encouraged 5. Materials and Plant Protection 10, General at all times, and guides will be revised, as appropriate, to accommodate com- ments and to reflect new information or experience. However. comments on Copies of published guides may be obtained by written request indicating the this guide. if received within about two months after its issuance, will be par divisions desired to the U.S. Nuclear Regulatory Commission. Washington. D.C.

ticularly useful in evaluating the need for an early revision. 20566, Attention: Director. Office of Standards Development.

in severe radiation environments. However, if The "Glossary of Terms" of ANSI N512-1974 also unventilated enclosed spaces having a high defines "inspection agency" as a person or persons coated-surface-to-volume ratio were subjected to high empowered to act for the owner to verify performance radiation levels over long periods, combustible gases of the coating work with documented specifications, from radiolysis could become significant, and control of instructions, and procedures, and states that the possible ignition sources or provision of sufficient inspection agency may be a part of the owner's, or his ventilation to avoid such hazards may be warranted. representative's, organization; a representative of the coating manufacturer or the coating applicator; or an

C. REGULATORY POSITION

independent organization, provided the inspection personnel do not report directly to the immediate ANSI N512-1974, "Protective Coatings (Paints) for supervisor responsible for the coating wor

k. Criterion I

the Nuclear Industry," 1 when used in conjunction with of Appendix B to 10 CFR Part 50 requires persons and Regulatory Guide 3.21, "Quality Assurance organizations having authority and responsibility for Requirements for Protective Coatings Applied to Fuel verifying, as by checking and inspecting, the correct Reprocessing and to Plutonium Processing and Fuel performance of activities affecting the safety-related Fabrication Plants," provides a generally acceptable basis functions of structures, systems, and components to for complying with the pertinent requirements of report to a management level such that they are Criteria III, IX, and X of Appendix B to 10 CFR Part 50 provided with sufficient organizational freedom to iden- with respect to the selection, application, and inspection tify quality problems; to initiate, recommend, or provide of protective coatings in fuel reprocessing plants for solutions; and to verify implementation of solutions.

structures, systems, and components important to health The organizational freedom may take various forms but and safety, subject to the following: should provide sufficient independence from cost and schedules where they conflict with safety considerations,

1. Sections 1.4 and 1.5 of ANSI N512-1974 refer to and should provide direct access to such levels of other ANSI standards and to standards of other management as may be necessary to perform these organizations that are referenced in ANSI N512-1974. functions adequately. Assurance that the inspection The specific applicability or acceptability of these other agency processing these authorities and responsibilities listed guides and standards has been or will be covered has the required organizational freedom is of particular separately in other regulatory guides or in appropriate importance if the inspection agency is a representative of Commission regulations. the coating manufacturer or the coating applicator.

2. Instead of Sample Forms 2.1 and 5.1, alternative documentation consistent with the requirements of

D. IMPLEMENTATION

Appendix B to 10 CFR Part 50 is also acceptable to the NRC staff.

The purpose of this section is to provide information

3. Section 11, "Glossary of Terms," of ANSI to applicants and licensees regarding the NRC staff's N512-1974 states that quality assurance is the plans for utilizing this regulatory guide.

verification of the conformance of materials and methods of application to the governing specification in Except in those cases in which the applicant proposes order to achieve the desired result. This definition to use an acceptable alternative method for complying should be expanded because Appendix B to 10 CFR Part with specified portions of the Commission's regulations,

50 also considers organizational structure, procedures, the method described herein will be used in the and other matters not implied by verification of evaluation of submittals for construction permit or conformance of materials and methods of application to operating license applications docketed on or after a specification. Consequently, the term "quality October 1,1975.

assurance" as used in ANSI N512-1974 should be considered to comprise all those planned and systematic If an applicant wishes to use this regulatory guide in actions necessary to provide adequate confidence that developing submittals for applications docketed prior to shop or field coating work for nuclear facilities will October 1, 1975, the pertinent portions of the perform satisfactorily in service. application will be evaluated on the basis of this guide.

3.30-2

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