Regulatory guides are issued to describe and make available to the public such information as methods acceptable to the NRC staff for implementing specific

parts of the NRC’s regulations, techniques used by the staff in evaluating specific problems or postulated accidents, and data needed by the NRC staff in its

review of applications for permits and licenses. Regulatory guides are not substitutes for regulations, and compliance with them is not required. Methods and

solutions different from those set out in the guides will be acceptable if they provide a basis for the findings requisite to the issuance or continuance of a permit

or license by the Commission.

This guide was issued after consideration of comments received from the public. Comments and suggestions for improvements in these guides are encouraged

at all times, and guides will be revised, as appropriate, to accommodate comments and to reflect new information or experience. Written comments may be

submitted to the Rules and Directives Branch, ADM, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

Regulatory guides are issued in ten broad divisions: 1, Power Reactors; 2, Research and Test Reactors; 3, Fuels and Materials Facilities; 4, Environmental and

Siting; 5, Materials and Plant Protection; 6, Products; 7, Transportation; 8, Occupational Health; 9, Antitrust and Financial Review; and 10, General.

Single copies of regulatory guides (which may be reproduced) may be obtained free of charge by writing the Distribution Services Section, U.S. Nuclear

Regulatory Commission, Washington, DC 20555-0001, or by fax to (301)415-2289, or by email to DISTRIBUTION@NRC.GOV. Electronic copies of this guide

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Room, as Accession Number ML003714475, along with other recently issued guides, at the same web site.

U.S. NUCLEAR REGULATORY COMMISSION Revision 1

July 2000

REGULATORY

GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 1.54

(Draft was issued as DG-1076)

SERVICE LEVEL I, II, AND III PROTECTIVE COATINGS

APPLIED TO NUCLEAR POWER PLANTS

A. INTRODUCTION

In Appendix A to 10 CFR Part 50, "General Design Criteria for Nuclear Power Plants,"

Criterion 1, "Quality Standards and Records," requires, in part, that structures, systems, and components

important to safety be designed, fabricated, erected, and tested to quality standards commensurate with the

importance of the safety functions to be performed. Criterion 1 also requires that a quality assurance

program be established and implemented in order to provide adequate assurance that these structures,

systems, and components will satisfactorily perform their safety functions.

In Appendix A to 10 CFR Part 50, Criterion 4, "Environmental and Dynamic Effects Design

Bases," requires, in part, that structures, systems, and components (SSCs) important to safety be designed

to be compatible with the environmental conditions associated with normal operation, maintenance,

testing, and postulated accidents, including loss-of-coolant accidents.

Appendix B to 10 CFR Part 50, "Quality Assurance Criteria for Nuclear Power Plants and Fuel

Reprocessing Plants," establishes overall quality assurance program requirements for the design,

fabrication, construction, and operation of safety-related nuclear power plant SSCs.
1.54-2

The maintenance rule, 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants," includes in its scope safety-related SSCs that are relied

upon to remain functional during and following design basis events with respect to specified

functions and non-safety-related SSCs (1) that are relied upon to mitigate accidents or transients or

are used in plant emergency operating procedures, (2) whose failure could prevent safety-related

SSCs from fulfilling their safety-related function, and (3) whose failure could cause a reactor

scram or an actuation of a safety-related system. To the extent that protective coatings meet these

criteria, they are within the scope of the maintenance rule. The maintenance rule requires that

licensees monitor the effectiveness of maintenance for protective coatings within its scope (as

discrete systems or components or as part of any SSC), or demonstrate that their performance or

condition is being effectively controlled through the performance of appropriate preventive

maintenance, in accordance with 10 CFR 50.65(a)(1) or (a)(2), as appropriate. Further guidance is

provided in Revision 2 of Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance

at Nuclear Power Plants" (Ref. 1).

This revision to Regulatory Guide 1.54 is being developed in accordance with Public Law

104-113, OMB Circular A-119, and the NRC’s Strategic Plan for FY 1997 - 2002, which

encourages industry to develop codes, standards, and guides that can be endorsed by the NRC and

carried out by industry. The ASTM standards cited in the Regulatory Position of this guide for the

selection, qualification, application, and maintenance of protective coatings in nuclear power

plants have been reviewed by the NRC staff and found to be acceptable with the exceptions noted.

The information collections contained in this regulatory guide are covered by the

requirements of 10 CFR Part 50, which were approved by the Office of Management and Budget,

approval number 3150-0011. If a means used to impose an information collection does not

display a currently valid OMB control number, the NRC may not conduct or sponsor, and a

person is not required to respond to, the information collection.

B. DISCUSSION

Protective coatings (paints) have been used extensively in nuclear power plants to protect

the surfaces of facilities and equipment from corrosion and contamination from radionuclides and

for wear protection during plant operation and maintenance activities. For plants that have a

design basis that includes a commitment to Regulatory Guide 1.54, the regulations cited above

require that protective coatings be qualified and capable of surviving a design basis accident

(DBA) without adversely affecting safety-related SSCs needed to mitigate the accident.

In July 1973, Regulatory Guide 1.54, “Quality Assurance Requirements for Protective

Coatings Applied to Water-Cooled Nuclear Power Plants,” was issued to describe an acceptable

method for complying with the NRC's quality assurance requirements with regard to protective

coatings applied to ferritic steels, stainless steel, zinc-coated (galvanized) steel, concrete, or

masonry surfaces of water-cooled nuclear power plants. The presumption was that protective

coatings that met these guidelines would not degrade over the design life of the plant. However,

operating history has shown that undesirable degradation, detachment, and other types of failures

of coatings have occurred (Ref. 2). Detached coatings from the substrate that are transported to
1.54-3

emergency core cooling system intake structures may make those systems unable to satisfy the

requirement in 10 CFR 50.46(b)(5) to provide long-term cooling.

Regulatory Guide 1.54 conditionally endorsed ANSI N101.4, "Quality Assurance for

Protective Coatings Applied to Nuclear Facilities," and indirectly endorsed guidance provided in

ANSI N101.2, “Protective Coatings (Paints) for Light Water Nuclear Reactor Containment

Facilities.” ANSI N101.4 and N 101.2 were formally withdrawn in 1988; responsibility for

updating, rewriting, and issuing appropriate replacement standards was transferred to the

American Society for Testing and Materials (ASTM), specifically ASTM Committee D-33 on

Protective Coating and Lining Work for Power Generation Facilities. However, Regulatory

Guide 1.54 was not revised as new ASTM Standards were developed for the application and

maintenance of nuclear power plant protective coatings.

ASTM D 3843-00, "Standard Practice for Quality Assurance for Protective Coatings

Applied to Nuclear Facilities" (Ref. 3), was approved and issued by ASTM as a partial

replacement for ANSI N101.4. ASTM D 3911-95, "Standard Test Method for Evaluating

Coatings Used in Light-Water Nuclear Power Plants at Simulated Design Basis Accident (DBA)

Conditions" (Ref. 4), has been approved and issued by ASTM to replace the DBA test standard

that was referenced in ANSI N101.4 and Regulatory Guide 1.54.

ASTM D 5144-00, "Standard Guide for Use of Protective Coating Standards in Nuclear

Power Plants" (Ref. 5), has been developed and issued by the ASTM to provide a common basis

on which protective coatings for the surfaces of nuclear power generating facilities may be

qualified and selected by reproducible evaluation tests. This ASTM standard provides guidance

for the application and maintenance of protective coatings under the expected environmental,

operating, and postulated accident conditions for pressurized water reactors (PWRs) and boiling

water reactors (BWRs). The additional ASTM standards, shown in Figure 1, provide applicationspecific guidance and are discussed below.

C. REGULATORY POSITION

1. GUIDANCE IN ASTM STANDARDS

ASTM D 5144-00 (Ref. 5) and the other ASTM standards discussed below provide

guidance on practices and programs that are acceptable to the NRC staff for the selection,

application, qualification, inspection, and maintenance of protective coatings applied in nuclear

power plants. However, the ASTM Committee has revised definitions of Service Level I, II, and

III coatings locations to include both safety-related and non-safety-related regions as set forth

below.

The quality assurance provisions and guidance contained in the standards in this

Regulatory Position are generally acceptable and provide methods acceptable to the NRC staff for

complying with the pertinent quality assurance requirements of Appendix B to 10 CFR Part 50

subject to the following two exceptions.
1.54-4

(1) When using this regulatory guide, NRC licensees should meet the quality assurance

provisions and guidance contained in the standards in this regulatory guide and must also

meet the commitments and provisions contained in their Quality Assurance Program

description.

(2) Service Level I, II, and III coatings are defined as:

Service Level I coatings are used in areas inside the reactor containment where the coating

failure could adversely affect the operation of post-accident fluid systems and thereby

impair safe shutdown.

Service Level II coatings are used in areas where coatings failure could impair, but not

prevent, normal operating performance. The functions of Service Level 2 coatings are to

provide corrosion protection and decontaminability in those areas outside the reactor

containment that are subject to radiation exposure and radionuclide contamination.

Service Level II coatings are not safety-related.

Service Level III coatings are used in areas outside the reactor containment where failure

could adversely affect the safety function of a safety-related structure, system, or

component.

ASTM D 5144-00 (Ref. 5) addresses by reference the preparation of test specimens,

radiation tolerance testing, decontaminability of coatings, physical properties, chemical resistance

tests, fire evaluation tests, DBA testing, surface preparation, coating application and inspection,

and thermal conductivity testing. Therefore, ASTM D 5144-00 can be viewed as a top-level

ASTM standard that incorporates by reference other key ASTM standards as shown in Figure 1.

2. QUALITY ASSURANCE

ASTM D 3843-00 (Ref. 3) provides quality assurance practices that are acceptable to the

NRC staff and are applicable to safety-related protective coating work in coating Service Level I

areas of nuclear facilities. Applicable portions of practices described may be used as the basis for

limited quality assurance for protective coating work in coating Service Level II areas of nuclear

facilities.

ASTM D 5139-96 (Ref. 6) provides guidance that is acceptable to the NRC staff on the

size, composition, and surface preparation for test samples of protective coatings for use in

qualification testing of coatings to be used in nuclear power plants as described in ASTM D 3911-

95 and D-4082-95 (Refs. 4 and 7).

ASTM D 3911-95 (Ref. 4) provides guidance that is acceptable to the NRC staff on

procedures for evaluating protective coating systems test specimens under simulated DBA

conditions. ASTM D 911-95 also provides guidance on conditions and test apparatus for

temperature-pressure testing, conditions for radiation testing, and procedures for preparing,

examining, and evaluating samples.
1.54-5

ASTM D 4082-95 (Ref. 7) provides a standard test method that is acceptable to the NRC

staff for evaluating the effects of gamma radiation on the lifetime radiation tolerance of Service

Level I and II coatings.

ASTM D 4537-96 (Ref. 8) provides guidance that is acceptable to the NRC staff on the

qualification and certification of personnel who inspect protective coatings in nuclear facilities.

This standard provides guidance on inspection of the education, training, experience,

qualifications, and certification of Level I, II, and III coatings inspectors.

3. TRAINING AND QUALIFICATION OF PROTECTIVE COATINGS

INSPECTORS AND COATINGS APPLICATORS

ASTM D 5498-94 (Ref. 9) provides guidance acceptable to the NRC staff for persons

responsible for developing a training program for the indoctrination and training of personnel for

inspecting coating work in nuclear facilities and also recommends areas of proficiency that are

embodied in the ASTM standards shown in Table 1 in ASTM D 5498-94.

ASTM D 4227-95 (Ref. 10) provides guidance acceptable to the NRC staff for the

qualification of coatings applicators to verify that they are proficient and able to attain the quality

required for applying specified coatings to concrete surfaces, including those in a nuclear facility.

ASTM D 4228-95 (Ref. 11) provides guidance acceptable to the NRC staff for the

qualification of coatings applicators to verify that they are proficient and able to attain the quality

required for applying specified coatings to steel surfaces, including those in a nuclear facility.

ASTM D 4286-96 (Ref. 12) provides criteria and methods that are acceptable to the NRC

staff to assist utility owners, architects, engineers, and contractors in determining the overall

qualifications of a coatings contractor to execute coating work for the primary containment and

other safety-related facilities of nuclear power plants. The criteria and requirements for

contractors address the contractor’s capability to execute nuclear coating work.

4. MAINTENANCE OF COATINGS

ASTM D 5163-96 (Ref. 13) provides guidelines that are acceptable to the NRC staff for

establishing an in-service coatings monitoring program for Service Level I coating systems in

operating nuclear power plants and for Service Level II and other areas outside containment (as

applicable).

ASTM D 4541-95 (Ref. 14) provides guidance acceptable to the NRC staff for a

procedure for evaluating the pull-off strength of coatings using fixed-alignment adhesion testers.

ASTM D 3359-95, Revision A (Ref. 15), provides guidance that is acceptable to the NRC

staff on test methods for measuring adhesion using tape tests.
1.54-6

ASTM D 3912-95 (Ref. 16), provides guidance that is acceptable to the NRC staff on

evaluation of the chemical resistance of coatings used in light-water nuclear power plants.

ASTM D 5962-96 (Ref. 17) provides guidance that is acceptable to the NRC staff on

maintaining unqualified coatings (paints) within Level I areas of a nuclear power facility.

5. ASTM STANDARD TERMINOLOGY

ASTM D 4538-95 (Ref. 18) defines standard terms related to protective coating and lining

work for power generation facilities that are acceptable to the NRC staff and that are also

applicable to protective coatings employed in nuclear power plants.

6. ADDITIONAL INFORMATION

Additional information on the selection, application, inspection, and maintenance of

nuclear plant safety-related protective coatings is provided in EPRI Report TR-109937 (Ref. 19),

which provides a detailed discussion of important considerations related to protective coatings

and can be used to supplement the ASTM Standards guidelines as deemed necessary.

D. IMPLEMENTATION

The purpose of this section is to provide information to applicants and licensees regarding

the NRC staff’s plans for using this regulatory guide.

Except in those cases in which an applicant proposes an acceptable alternative method for

the condition monitoring and maintenance of safety-related containment coatings, unless different

regulatory requirements apply, the ASTM standards endorsed in this guide will be used in the

evaluation of the effectiveness of maintenance activities of licensees who are required to comply

with 10 CFR 50.65. Current licensees may, at their option, comply with the guidance in this

regulatory guide.
1.54-7
1 Single copies of regulatory guides, both active and draft, and draft NUREG documents may be obtained free of charge by

writing the Reproduction and Distribution Services Section, OCIO, USNRC, Washington, DC 20555-0001, or by fax to

(301)415-2289, or by email to <DISTRIBUTION@NRC.GOV>. Active guides may also be purchased from the National

Technical Information Service on a standing order basis. Details on this service may be obtained by writing NTIS, 5285 Port

Royal Road, Springfield, VA 22161; telephone (703)487-4650; online <http://www.ntis.gov/ordernow>. Copies of certain

guides and many other NRC documents are available electronically on the internet at NRC’s home page at <WWW.NRC.GOV>

in the Reference Library. Documents are also available through the Electronic Reading Room (NRC’s ADAMS document

system, or PARS) at the same web site.

2 Copies are available electronically at NRC’s home page <WWW.NRC.GOV> in the Reference Library. Copies are also

available for inspection or copying for a fee from the NRC Public Document Room at 2120 L Street NW., Washington, DC; the

PDR’s mailing address is Mail Stop LL-6, Washington, DC 20555; telephone (202)634-3273 or (800)397-4209; fax (202)634-

3343; email <PDR@NRC.GOV>.

3 ASTM documents may be purchased from ASTM at 100 Barr Harbor Drive, West Conshohocken, PA 19428; email to

<SERVICE@ASTM.ORG> .

1.54-8

REFERENCES

1. USNRC, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

Regulatory Guide 1.160, Revision 2, March 1997.1

2. USNRC, “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,” Generic Letter

98-04, July 14, 1998.2

3. American Society for Testing and Materials, "Standard Practice for Quality Assurance for

Protective Coatings Applied to Nuclear Facilities," ASTM D 3843-00.3

4. American Society for Testing and Materials, "Standard Test Method for Evaluating

Coatings Used in Light-Water Nuclear Power Plants at Simulated Design Basis Accident

(DBA) Conditions," ASTM D 3911-95.3

5. American Society for Testing and Materials, "Standard Guide for Use of Protective

Coating Standards in Nuclear Power Plants," ASTM D 5144-00.3

6. American Society for Testing and Materials, "Standard Specification for Sample

Preparation for Qualification Testing of Coatings To Be Used in Nuclear Power Plants,"

ASTM D 5139-90 (Reapproved 1996).3

7. American Society for Testing and Materials, "Standard Test Method for Effects of Gamma

Radiation on Coatings for Use in Light-Water Nuclear Power Plants," ASTM D 4082-95.3

8. American Society for Testing and Materials, “Standard Guide for Establishing Procedures

To Qualify and Certify Inspection Personnel for Coating Work in Nuclear Facilities,"

ASTM D 4537-91 (Re-approved 1996).3
1.54-9

9. American Society for Testing and Materials, "Standard Guide for Developing a Training

Program for Coating Work Inspectors in Nuclear Facilities," ASTM D 5498-94.3

10. American Society for Testing and Materials, "Standard Practice for Qualification of

Coating Applicators for Application of Coatings to Concrete Surfaces," ASTM

D 4227-95.3

11. American Society for Testing and Materials, "Standard Practice for Qualification of

Coating Applicators for Application of Coatings to Steel Surfaces," ASTM D 4228-95.3

12. American Society for Testing and Materials, "Standard Practice for Determining Coating

Contractor Qualifications for Nuclear Powered Electric Generation Facilities," ASTM

D 4286-90 (Re-approved 1996).3

13. American Society for Testing and Materials, "Standard Guide for Establishing Procedures

To Monitor the Performance of Safety Related Coatings in an Operating Nuclear Power

Plant," ASTM D 5163-96.3

14. American Society for Testing and Materials, “Standard Test Method for Pull-Off Strength

of Coatings Using Portable Adhesion Testers,” ASTM D 4541-95.3

15. American Society for Testing and Materials, “Standard Test Methods for Measuring

Adhesion by Tape Test,” ASTM D 3359-95, Revision A.3

16. American Society for Testing and Materials, “Standard Test Method for Chemical

Resistance of Coatings Used in Light-Water Nuclear Power Plants,” ASTM D 3912-95.3

17. American Society for Testing and Materials, “Standard Guide for Maintaining Unqualified

Coatings (Paints) Within Level Areas of a Nuclear Power Facility,” ASTM D 5962-96.3

18. American Society for Testing and Materials, “Standard Terminology Relating to

Protective Coating and Lining Work for Power Generation Facilities,” ASTM D 4538-95.3

19. Electric Power Research Institute, “Guidelines on the Elements of a Nuclear SafetyRelated Coatings,” EPRI Report TR-109937, March 1998.
1.54-10

REGULATORY ANALYSIS

The guidance in Regulatory Guide 1.54, “Quality Assurance Requirements for Protective

Coatings Applied to Water-Cooled Nuclear Power Plants” (June 1973), has become outdated

because the ANSI standards endorsed by the guide have been withdrawn and replaced by ASTM

standards. Public Law 104-113, OMB Circular A-119, and NRC’s Strategic Plan for FY1997-

2002 encourage the use of codes, standards, and guides that have been developed by industry and

that can be endorsed by the NRC and carried out by industry. The most cost-beneficial method to

update the guidance in Regulatory Guide 1.54 would be to issue a revision of Regulatory Guide

1.54 that endorses updated ASTM standards.

BACKFIT ANALYSIS

The regulatory guide does not require a backfit analysis as described in 10 CFR 50.109(c)

because it does not impose a new or amended provision in the NRC’s rules or a regulatory staff

position interpreting the NRC’s rules that is either new or different from a previous applicable

staff position. In addition, this regulatory guide does not require the modification or addition to

systems, structures, components, or design of a facility or the procedures or organization required

to design, construct, or operate a facility. Rather, a licensee or applicant can select a preferred

method for achieving compliance with a license or the rules or the orders of the NRC as described

in 10 CFR 50.109(a)(7). This regulatory guide provides an opportunity to use industry-developed

standards, if that is a licensee’s or applicant’s preferred method.