IR 05000329/1982010

IE Insp Repts 50-329/82-10 & 50-330/82-10 on 820602-04,30 & 0701.No Noncompliance Noted.Major Areas Inspected:Followup on 10CFR50.55e Items Re Containment Internal Structures Coating Deficiency

ML20062H155
Person / Time
Site:	Midland
Issue date:	07/22/1982
From:	Hawkins F, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20062H147	List: IR 05000329/1982010 ML20062H144
References
50-329-82-10, 50-330-82-10, NUDOCS 8208130323
Download: ML20062H155 (4)

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U.S. NUCLEAR REGULATOPY COMMISSION

REGION III

Reports No. 50-329/82-10(DETP); 50-330/82-10(DETP)

Docket Nos. 50-329; 50-330 Licenses No. CPPR-81; CPPR-82 Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant, Units 1 and 2 Inspection At: Midland Site, Midland, MI Inspections Conducted: June 2-4, 30 and July 1, 1982

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d Inspector: F. C. Hawkins 7/2.E/8 . ,

Accompsaying Personnel: L. Abramson (June 30 and July 1, 1982)

D. Lurie (June 30 and July 1, 1982)

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Approved By: G. C. VillEm5, Chief '7/LZ/97 Plant Systems Section I /

Inspection Summary Inspection on June 2-4, 30 and July 1, 1982 (Reports No. 50-329/82-10(DETP):

50-330/82-10(DETP))

Areas Inspected: Followup on reported 50.55(e) item regarding Units 1 and 2 containment internal structures coating deficiency. The inspection involved a total of 58 inspector-hours onsite by one Region III inspector and two representatives from the Office of Resource Maragemen Results: No items of noncomplianca or deviations were identifie ,_ PDR ADOCK 05000329 G PDR _

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DETAILS _P,ersons Contacted Consumers Power Company (CPCo)

• M. Curland, Site Quality Assurance Superintendent

• M. Puschel, Staff Engineer

• B. Palmsr, Resident Site Remedial Soils Supervisor

• A. Tselepis, Coatings Specialist Bechtel Power Corporation

• T. Murphy, Architect / Planning

• V. Lands, Resident Architect

• R. Garling, Coatings Specialist

• Snyder, Resident Quality Engineer

• P. Usich, Reliability Engineer

• E. Dutton, Civil Quality Control Engineer Other R. Cook, Resident Inspector

• Denotes those attending the exit intervie . Functional or Program Areas Inspected This inspection was conducted to assess the acceptability and status of corrective actions taken by Consumers Power Company with regard to the identified Unit 1 and 2 containment internal structures coating deficiencies. The inspection on June 2-4, 1982 focused on: (1) dis-cussion of investigations to identify the cause of the identified coating deficiencies, (2) discussion of the Unit 1 and 2 reactor building mapping / testing program, (3) review of DBA environmental test results, (4) review of pertainent Bechtel coating specifications, subcontractor procedures and quality records, and (5) observation of inprocess coatings removal. The June 30 and July 1, 1982 inspection effort was directed toward the assessment of Consumer Power Company's statistical approach to the testing of the potentially defective coating In 1979, a Consumers Power Company representative identified a loss of adhesion between successive coats of the System 9 coating in the Unit 2 reactor building. As a result, Management Corrective Action Report (MCAR) No. 35 was written on November 13, 1979, to properly identify the deficiency and assure.its proper dispositio The identified loss of adhesion between successive coats of System 9 had the potential to allow paint material to be carried into the con-tainment sump as a result of a reactor accident followed by initiation of the containment spray system. This scenario of containment coatings

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failure represented the potential to exceed the allowable 50% blockage of the inner sump screen (reference NRC Regulatory Guide 1.82),In Consumers Power Company's estimation, the delamination represented a significant construction deficiency and was therefore reportable per 10 CFR 50.55(e).

The System 9 coating is a decontaminabic system which was applied to approximately 50,000 square feet in each containment. The ideal three coat System 9 consisted of one coat of Ameron Nu-Klad 117 filler /

surfacer and two coats of Ameron Amercoat 90 topcoat. Nu-Klad 117 is an epoxy coating used to fill and seal the concrete surfac Amercoat 90 is a modified phenolic epoxy coating which provides the decontaminable finish coat. Ameron's technical data sheet allows a second coat of Nu-Klad 117, as required to fill and seal the concrete surface. The majority of completed System 9 coatings at Midland consists of two coats of Nu-Klad 117 and two coats of Amercoat 9 To establish the extent of the delamination, the completed System 9 coatings in the Unit 1 and 2 reactor buildings were subdivided into 100 square foot grids and knife adhesion tests 5:ere performed on each grid. The results of this testing indicated that approximately 5% of Unit 1 and 18% of the Unit 2 System 9 coating exhibited inadequate intercoat adhesion between the two coats of Nu-Klad 11 Concurrent with these activities, coating samples from completed field work were taken in accordance with Bechtel Specification A-5 The samples were taken from areas which were known to pass the knife adhesion test and tested at simulated design basis accident (DBA)

conditions in accordance with Bechtel Specification A-45, ANSI N101.2-1972 and ANSI N5.12-1974. The intent of the program was to correlate the results of the DBA coating performance tests with the results of the knife adhesion test method. Limited testing was also performed to establish correlation between the E1cometer 106 Adhesion Tester and the knife adhesion test method. The combination of the results from these two test programs clearly establish the validity of the knife adhesion test for determining the acceptability of the System 9 coating Additionally, Consumers Power Company and several independent laboratories conducted extensive investigations into the Ameron product and those application variables with potential effect on the performance of the System 9 coating. The variables which were evaluated included (1) batch and mixing variations, (2) addition of solvent, (3) surface and intercoat contamination, (4) relative humidity and temperature, (5) application variables, and (6) pack-aging variables. The results of these investigations identified several factors which could singly, or in cocbination with other factors, cause the observed loss of adhesion between successive coats of Nu-Klad 117. They are as follows:

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Variations of relative humidity and temperature during application and curin _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ ________

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Addition of Amercoat 6 thinner to the batch to extend the apparent pot lif Application of Nu-Klad 117 near or af ter the end of the effective pot lif Time between application of successive Nu-Klad 117 coat Based on the results of the knife adhesion tests, which were performed on each 10 square foot grid, coatings which failed the test were removed. Bechtel Specifications A-56, which governs the removal and repair of defective System 9 coatings, was reviewed. A-56 contained the appropriate provisions to control the work activitie Bechtel Specification A-57, which contains provisions for the prepara-tion and testing of panels to qualify the various coating repair systems, was also reviewed. Samples from the panels were tested at simulated DBA conditions and the results of the tests were reviewed. The test results clearly qualified the coating systems as Service Level I as defined by ANSI N5.12-1974. It is our conclusion that the controls and tests required by Specifications A-56 and A-57 are adequate to prevent recurrence of the coating deficienc In order to qualify the unremoved System 9 coatings, the remaining coatings are being tested against a 95/95 statistical criterion. This criterion provides that with 95 percent assurance, no more than five percent of the unremoved coatings in each containment will delaminat To implement the 95/95 critorion, Consumers Power Company divided each containment into eight sections and subdivided each section into two foot by two foot grids. The sampling plan adopted by Consumers Power requires that 59 grids in each section be tested. Further, should a single grid fail the knife adhesion test, the coatings in the entire section will be remove It is our view that this plan will more than satisfy the 95/95 criterion adopted by Consumers Powe The testing program is currently in progress at the Midland sit Licensee personnel stated that completion was tentatively scheduled for October 1, 1982. Agreement was reached during this inspection that Consumers Power Company would submit a Final report on the resolution of this 50.55(e) item upon completion of the testing program and removal of all defective coatings. Final acceptance is pending the issuance of the Final report and its subsequent review by the NR . Exit Interview The Region III inspectors met with licensee representatives at the conclusion of the inspection. The results of the inspection were summarized during the exit intervie