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 COMMISSIONJune 1975REGULATORY GUIDEOFFICE OF STANDARDS DEVELOPMENTREGULATORY GUIDE 3.30SELECTION, APPLICATION, AND INSPECTION OF PROTECTIVE COATINGS(PAINTS) FOR FUEL REPROCESSING PLANTS

A. INTRODUCTION

Appendix B, "Quality Assurance Criteria for NuclearPower Plants and Fuel Reprocessing Plants," to 10 CFRPart 50, "Licensing of Production and UtilizationFacilities," establishes quality assurance programrequirements for the design, construction, and operationof structures, systems, and components of fuelreprocessing plants. Criterion III, "Design Control," ofAppendix B requires assurance that appropriate qualitystandards are specified and that measures be establishedfor selecting appropriate materials for such structures,systems, and components; Criterion IX, "Control ofSpecial Processes," requires that special processes becontrolled and accomplished by qualified personnelusing qualified procedures in accordance with applicablecodes and standards; and Criterion X, "Inspection,"defines requirements for inspecting activities affectingquality.Protective coatings (paints) are used in fuel reproces-sing plants to preserve from corrosion and erosion thesurfaces of structures, systems, and components impor-tant to safety and to facilitate the removal of radioactivecontamination from all such plant surfaces during plantoperation, maintenance, and decommissioning. Manyacceptable practices for the selection, application, andinspection of protective coatings are available and havebeen used. These practices can differ significantlybecause there has not been sufficient guidance towardstandardization. In the interest of standardization, thisguide describes practices acceptable to the NRC staff forthe selection, application, and inspection of protectivecoatings for fuel reprocessing plants.

B. DISCUSSION

Subcommittee N46-5 of American NationalStandards Committee N46, "Nuclear Reactor-Fuel.Cycle," under the sponsorship of the American Instituteof Chemical Engineers, has developed a standard forevaluating and selecting protective coatings (paints) forUSNRC REGULATORY GUIDESnuclear plants by using reproducible tests. The standardalso provides guidance for preparing the surfaces to becoated and for applying and inspecting the coatingsunder both shop and field conditions. The standarddefines the performance requirements of coatings andprovides tests for radiation tolerance, decontamination,chemical resistance, and physical properties. Thisstandard, identified as ANSI N512-1974,I was approvedby American National Standards Committee N46 and,subsequently, on June 21, 1974, by the AmericanNational Standards" Institute.This standard may be used for structures, systems,and components of fuel reprocessing plants and shouldbe used in conjunction with Regulatory Guide 3.21,"Quality Assurance Requirements for ProtectiveCoatings Applied to Fuel Reprocessing and to PlutoniumProcessing and Fuel Fabrication Plants," which refers toANSI N101.4-1972, "Quality Assurance for ProtectiveCoatings Applied to Nuclear Facilities."Section 1.2.2 of ANSI N512-1974 makes reference toAmerican National Standard N101.2-1972, "ProtectiveCoatings (Paints) for Light Water Nuclear ReactorContainment Facilities," as a standard for the selectingand evaluating of protective, coatings specifically fornuclear reactor containment facilities. The exposureconditions and corresponding test conditions giventherein, in particular the Design Basis Accident (DBA)conditions, are not necessarily applicable to anyconditions expected to be found in a fuel reprocessingplant or to the appropriate tests for coatings for fuelreprocessing plant structures, systems, and components.Most polymers such as those now used in paintformulation are subject to radiation damage with theproduction of hydrogen gas and methane, among otherradiolysis products. Normally this is of no greatconsequence since the production rate is very low even1 Copies may be obtained from the American Institute ofChemical Engineers, 345 East 47th Street, New York, NY10017.Comments should be sent to the Secretary of the Commission. U.S. NuclearRegulatory Guides are issued to describe and make available to the public Regulatory Commission. Washington. D.C. 20555. Attention: Docketing andService Section.methods acceptable to the NRC staff of implementing specific parts of theCommission'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. Productswith them is not required. Methods and solutions different from those set out in 2. Research and Test Reactors 7. Transportationthe guides will be acceptable if they provide a basis for the findings requisite to 3. Fuels and Materials Facilities 8. Occupational Healththe issuance or continuance of a permit or license by the Commission. 4. Environmental and Siting 9. Antitrust ReviewComments and suggestions for improvements in these guides are encouraged 5. Materials and Plant Protection 10, Generalat 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 thethis 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 Developmen in severe radiation environments. However, ifunventilated enclosed spaces having a highcoated-surface-to-volume ratio were subjected to highradiation levels over long periods, combustible gasesfrom radiolysis could become significant, and control ofpossible ignition sources or provision of sufficientventilation to avoid such hazards may be warranted.

C. REGULATORY POSITION

ANSI N512-1974, "Protective Coatings (Paints) forthe Nuclear Industry,"1 when used in conjunction withRegulatory Guide 3.21, "Quality AssuranceRequirements for Protective Coatings Applied to FuelReprocessing and to Plutonium Processing and FuelFabrication Plants," provides a generally acceptable basisfor complying with the pertinent requirements ofCriteria III, IX, and X of Appendix B to 10 CFR Part 50with respect to the selection, application, and inspectionof protective coatings in fuel reprocessing plants forstructures, systems, and components important to healthand safety, subject to the following:1. Sections 1.4 and 1.5 of ANSI N512-1974 refer toother ANSI standards and to standards of otherorganizations that are referenced in ANSI N512-1974.The specific applicability or acceptability of these otherlisted guides and standards has been or will be coveredseparately in other regulatory guides or in appropriateCommission regulations.2. Instead of Sample Forms 2.1 and 5.1, alternativedocumentation consistent with the requirements ofAppendix B to 10 CFR Part 50 is also acceptable to theNRC staff.3. Section 11, "Glossary of Terms," of ANSIN512-1974 states that quality assurance is theverification of the conformance of materials andmethods of application to the governing specification inorder to achieve the desired result. This definitionshould be expanded because Appendix B to 10 CFR Part50 also considers organizational structure, procedures,and other matters not implied by verification ofconformance of materials and methods of application toa specification. Consequently, the term "qualityassurance" as used in ANSI N512-1974 should beconsidered to comprise all those planned and systematicactions necessary to provide adequate confidence thatshop or field coating work for nuclear facilities willperform satisfactorily in service.The "Glossary of Terms" of ANSI N512-1974 alsodefines "inspection agency" as a person or personsempowered to act for the owner to verify performanceof the coating work with documented specifications,instructions, and procedures, and states that theinspection agency may be a part of the owner's, or hisrepresentative's, organization; a representative of thecoating manufacturer or the coating applicator; or anindependent organization, provided the inspectionpersonnel do not report directly to the immediatesupervisor responsible for the coating work. Criterion Iof Appendix B to 10 CFR Part 50 requires persons andorganizations having authority and responsibility forverifying, as by checking and inspecting, the correctperformance of activities affecting the safety-relatedfunctions of structures, systems, and components toreport to a management level such that they areprovided with sufficient organizational freedom to iden-tify quality problems; to initiate, recommend, or providesolutions; and to verify implementation of solutions.The organizational freedom may take various forms butshould provide sufficient independence from cost andschedules where they conflict with safety considerations,and should provide direct access to such levels ofmanagement as may be necessary to perform thesefunctions adequately. Assurance that the inspectionagency processing these authorities and responsibilitieshas the required organizational freedom is of particularimportance if the inspection agency is a representative ofthe coating manufacturer or the coating applicator.

D. IMPLEMENTATION

The purpose of this section is to provide informationto applicants and licensees regarding the NRC staff'splans for utilizing this regulatory guide.Except in those cases in which the applicant proposesto use an acceptable alternative method for complyingwith specified portions of the Commission's regulations,the method described herein will be used in theevaluation of submittals for construction permit oroperating license applications docketed on or afterOctober 1,1975.If an applicant wishes to use this regulatory guide indeveloping submittals for applications docketed prior toOctober 1, 1975, the pertinent portions of theapplication will be evaluated on the basis of this guide.3.30-2 UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON. D. C. 20555OFFICIAL BUSINESSPENALTY FOR PRIVATE USE. $300POSTAGE AND FEES PAIDUNITED STATES NUCLEARREGULATORY COMMISSION