ML091980474 

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

OFFICE OF NUCLEAR REACTOR REGULATION 

OFFICE OF NEW REACTORS 

WASHINGTON, DC 20555-0001 

August 17, 2009 

NRC INFORMATION NOTICE 2009-14: PAINTING ACTIVITIES AND CLEANING AGENTS 

RENDER EMERGENCY DIESEL GENERATORS 

AND OTHER PLANT EQUIPMENT INOPERABLE 

ADDRESSEES 

All holders of operating licenses and construction permits for nuclear power reactors under the 

provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, “Domestic Licensing 

of Production and Utilization Facilities,” except those who have permanently ceased operations 

and have certified that fuel has been permanently removed from the reactor vessel. 

All current and potential applicants for an early site permit, combined license, or standard 

design certification for a nuclear power plant under the provisions of 10 CFR Part 52, “Licenses, 

Certifications, and Approvals for Nuclear Power Plants.” 

PURPOSE 

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform 

addressees of operating experience in which painting or cleaning activities rendered plant 

equipment inoperable, particularly a recent event at Comanche Peak in which an emergency 

diesel generator (EDG) was rendered inoperable. The NRC expects that recipients will review 

the information for applicability to their facilities and consider actions, as appropriate, to avoid 

similar problems. Suggestions contained in this IN are not NRC requirements; therefore, no 

specific action or written response is required. 

DESCRIPTION OF CIRCUMSTANCES

Comanche Peak Unit 1—Paint Renders EDG Inoperable

On November 21, 2007, the train B EDG at Comanche Peak Unit 1 failed to start because of 

what appeared to be paint residue from a small drop of paint on one of the fuel pump metering 

rods. The location of the paint residue prevented movement of the fuel racks from their normal 

standby (closed) position in response to a governor demand signal, and the train B EDG was 

declared inoperable. The lack of movement of the mechanical linkage precluded the admission 

of sufficient fuel to all of the cylinders, which prevented the engine from starting. The residue 

was removed and the EDG was successfully started, declared operable, and returned to 

service. 
IN 2009-14 

Page 2 of 4 

Licensee corrective actions for this event included the following: 

• Manipulated the fuel racks on the other three EDGs manually to determine their 

condition and to verify that no common-mode failure state existed. 

Revised the general plant painting procedure to do the following: 

– Require a post-maintenance “pull test” of the fuel pump control rack mechanisms 

to ensure that they are free to operate (in addition to visual inspections of the 

diesel engine area). 

– Require “as you go” inspection and cleanup when painting around sensitive 

components. 

– Add an attachment capturing the pictures and information presently contained in 

the pre-job briefing notebook used by painters. 

• Included this event in the pre-job briefing for painters to heighten their sensitivity to the 

problems that paint drops and spatter can cause for mechanical linkages. 

• Had system engineering staff review the information in the painters’ pre-job briefing 

notebook to ensure that it references all sensitive areas on the EDG that should not be 

painted. 

Additional information appears in the Comanche Peak Steam Electric Station—NRC Special 

Inspection Report 05000445/2007008, dated February 29, 2008, available on the NRC’s public 

Web site in the Agencywide Documents Access and Management System (ADAMS) under 

Accession No. ML080600164. This event was also the subject of Comanche Peak Licensee 

Event Report (LER) 50-445/2007-001, dated January 17, 2008 (ADAMS Accession 

No. ML080240252). 

Other Examples of Painting or Cleaning Activities Impacting Plant Equipment

The NRC Operating Experience Branch reviewed other events in which painting or cleaning 

activities impacted plant equipment that were the subject of NRC inspection findings since 2000 

and of LERs since 1991. These LER and NRC inspection finding data describe painting or 

cleaning activities that adversely impacted various plant equipment, such as EDGs, turbinedriven auxiliary feedwater pumps, a high-pressure coolant injection pump, control room 

emergency ventilation, radiation monitors, charcoal iodine filters, the control room pressure 

boundary, welding activities, standby or station blackout diesel generators, and fire doors/fire 

protection equipment. Additionally, at least three reactor trips were attributed, in part, to 

painting activities. 
IN 2009-14 

Page 3 of 4 

A listing and brief description of each of these NRC inspection findings and LERs is publically 

available in ADAMS under Accession No. ML091600446. This listing shows that events often 

involved one or more of the following causal factors: 

• inadequate supervisory oversight (mentioned for more than half of these events) 

• lack of self-verification 

• lack of adherence to procedures 

• lack of training 

• inexperience 

• procedural problems 

• poor pre-job briefings 

• communication issues 

• program weaknesses 

• poor scheduling/planning 

• other work control issues 

Licensee corrective actions have included the following: 

• improved tools and techniques that painters can use to minimize and/or control paint 

drops and paint spatter 

• periodic and post-maintenance verification of any safety-related equipment potentially 

impacted by the painting or cleaning activity 

BACKGROUND

The NRC has previously issued the following related generic communications: 

• IN 93-76, “Inadequate Control of Paint and Cleaners for Safety-Related Equipment,”

dated September 21, 1993, describes an EDG that was rendered inoperable by a 

cleaning agent that removed the lubricating oil and left a white residue that prevented 

fuel rack movement. It also describes a cleaning agent containing a solvent that 

caused the plastic parts of 16 safety-related control switches to bond together, making 

the switches inoperable. 

 

• IN 91-46, “Degradation of Emergency Diesel Generator Fuel Oil Delivery Systems,”

dated July 18, 1991, describes EDGs that were rendered inoperable by paint on fuel 

rack components or on exciter commutator rings. 

DISCUSSION

The improper control of materials and processes for painting and cleaning activities near safetyrelated equipment can result in systems required by the technical specifications being rendered 

inoperable. Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel 

Reprocessing Plants,” to 10 CFR Part 50 establishes quality assurance requirements for safetyrelated equipment at nuclear power plants. The pertinent requirements of Appendix B apply to 

all activities affecting the safety-related functions of equipment, including painting and cleaning. 
IN 2009-14 

Page 4 of 4 

CONTACT

This IN requires no specific action or written response. Please direct any questions about this 

matter to the technical contact listed below or the appropriate Office of Nuclear Reactor 

Regulation (NRR) project manager. 

/RA/ Theodore R. Quay for 

Glenn Tracy, Director Timothy J. McGinty, Director 

Division of Construction Inspection Division of Policy and Rulemaking 

 and Operational Programs Office of Nuclear Reactor Regulation 

Office of New Reactors 

Technical Contact: Mark King, NRR 

 301-415-1150 

 E-mail: Mark.King@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site, 

http://www.nrc.gov, under Electronic Reading Room/Document Collections. 
IN 2009-14 

Page 4 of 4 

CONTACT

This IN requires no specific action or written response. Please direct any questions about this 

matter to the technical contact listed below or the appropriate Office of Nuclear Reactor 

Regulation (NRR) project manager. 

/RA/ Theodore R. Quay for 

Glenn Tracy, Director Timothy J. McGinty, Director 

Division of Construction Inspection Division of Policy and Rulemaking 

 and Operational Programs Office of Nuclear Reactor Regulation 

Office of New Reactors 

Technical Contact: Mark King, NRR 

 301-415-1150 

 E-mail: Mark.King@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site, 

http://www.nrc.gov, under Electronic Reading Room/Document Collections. 

ADAMS Accession Number: ML092010047 (Package); ML091980474 (IN); ML091600446 (IN Painting Activities) TAC ME0725 

OFFICE DIRS/IOEB *TECH EDITOR BC/DCI/CPTB AC/DIRS/IOEB D/NRR/DIRS

NAME MKing KAzariah-Kribbs JMcHale EThomas FBrown 

DATE 07/28/09 07/28/09 e-mail 08/04/09 07/29/09 08/05/09 for by RElliot 

OFFICE DPR/PGCB DPR/PGCB BC/DPR/PGCB D/NRR/DPR D/DCIP/NRO

NAME DBeaulieu CHawes CMH MMurphy TMcGinty TRQ for GTracy 

DATE 08/06/09 08/11/09 08/14/09 8/17/09 08/12/09 

OFFICIAL RECORD COPY