ML19211A425

Interim Deficiency Rept Re Containment Internal Structures Coatings W/Loss of Adhesion.Evaluation of Corrective Action Being Undertaken by Bechtel.Next Rept Will Be Submitted by 800215.Mgt Correction Action Rept Encl

ML19211A425
Person / Time
Site:	Midland
Issue date:	12/13/1979
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
References
HOWE-309-79, NUDOCS 7912180176
Download: ML19211A425 (6)

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, COIISumBIS a(iQ U Parler Stephen H. Howell Senior Vice President I

i General offices: 1945 West Parnati Road, Jackson, Michigan 49201 * (517) 788-0453 December 13, 1979 Howe-309-79 B

Mr J G Keppler Regional Director Office of Inspection & Enforcement

' US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

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MIDLAND NUCLEAR PLANT UNIT NO 1, DOCKET NO 50-329 UNIT NO 2, DOCKET NO 50-330 CONTAINMENT INTERNAL STRUCTURES COATING DEFICIENCY In accordance with the requirements of 10 CFR 50.55(e), this letter constitutes an interim report on in-containment coatings which have a loss of adhesion between successive layers of the coating system. The attachments to this letter provide a more complete description of the condition and the status of the actions being taken.

Another report, either interin or final, vill be sent on or before February 15, 1979 b

WRB/lr Attachments: 1. Quality Assurance Program, Management Corrective Action Report, MCAR-1,~ Report 35, dated November 13, 1979

2. MCAR-35, Interim Report #1, dated November 30, 1979 CC: Director of Office of Inspection and Enforcement Att: Mr Victor Stello, USNRC (15)

Director of Office of Management Information and Program Control, USNRC (1) ,

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. . n MANAGEMENT CORRECTIVE ACTION REPORT Attachment 1 MCAR-1 Howe-309-79

. REPORT NO. 30 JOBNO. 7220 0 0_2 80Nl b. 2.20 DATE November 13, 1979 1

• DESCRIPTION (including references): Epoxy decontaminative surfacer applied to Unit 2 containment, northwest primary shield wall and incore tunnel exterior faces from elevation 593'-6" to about 603'-0" exhibits a loss of adhesion between the Nu-Klad 117 (N) surfacer and Amercate 90 (N) top coat.

This surfacer was applied by subcontractor J. L. Manta in accordance uith requirements of subcontract No. A-15 and specification 7220-A-15(Q) utilizing system no. 9 thin coat application.

This condition was first noted by CPCo resulting in issuance of CPCo NCR M01-4-9-132 (attached). (Continued on page 2)

• RECOMMENDED ACTION (Optional)

I. Determine Root Cause:

A. Quantify by mapping and testing coated areas to determine extent of physical problem.

B. Review design specification, subcontractor procedures and Quality records for .

acceptability of techniques, procedures, equipment, and materials used.

C. Perform analysis of materials used for compliance with design and quality require-ments.

II. Determine reportability under 10CFR50.55(e) and advise QA no later than Nov. 30, 1979.

(Continued on page 2)

REFERRED TO O ENGINEERING s O CONSTRUCTION OOA MANAGEMENT O O PROCUREMENT ISSUED BY 40 cb Project GA Eng.neer MNl Date 11 REPORTABLE DEFICIENCY Potentially Reportable NOTIFIED CLIENT /_ / _[

} A 0 NO l

O YES _

P. .,ec anager

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Date Ml 111 CAUSE CORRECTIVE ACTION TAKEN -

I AUTHORIZED BY Date STANDARD DISTRIBUTION ADDITIONAL DISTRIBUTION - AS APPROPRIATE

" '" " FORMAL REPORT TO CLIENT S$R [ "ONP > $"r'C7$GNt?" (if Sectico 11 Applies) Daie GPD 04 M ANAGEN AAO PROCURE MENT SUPPLIER QUALITY MGR LAPO OA M ANAGER CON $7HUCTON man AGE R 4AO CA MANAGER PROJ SUPT PHOJ CONSTR MANAGER PnOJECT MANAGER CHIEF CONSTR OC ENG.NEER CLIE NT AAO PROJECT OPERATIONS MANAGER PF OCE 8 DeviS#Oed PROCUREMENT MGR CORRECTIVE ACTION IMPLEMENTED AAO PROCURE MENT M ANAGER PROJ PHOCUREMENT MGR AAO MGH OF ENGINE E H*NG OlV SUPPLIER OUAliTY MGR A40 MGR OF CONSTRUCTON

• Dewu e space momeo ead Anach ee s e..nce cocene ProicCt OA Engineer Date

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r MCAR 35 November 13, 1979 Page 2 0028II DESCRIPTION: (Cont'd)

Approximately 600 sq. ft. of surfacer is currently in question on primary shield and incore tunnel with 10-12 sq. ft. already removed during current investigation.

RECOMMENDED ACTION: (Cont'd)

III. Based upon the results of I, provide recommended fix and accomplish repair of defec'tive areas.

IV. Take appropriate steps to preclude recurrence. .

V. Provide report to QA by November 30, 1979 (interim or final).

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• Attachment 2 Howe 309

. Bechtel Power Cor-79poration

SUBJECT:

MCAR'35 (issued 11/13/79)

Containment Internal Structures Coating INTERIM P.EPORT 1 DATE: November 30, 1979 PROJECT: Consumers Power Company Midland Plant Units 1 & 2 Bechtel Job 7220 Introduction.

As requested in MCAR 35, this report summarizes project engineering's evaluation and action regarding the failure of coatings on concrete, as applied by subcontractor J.L. Manta, in the containment building to maintain adhesion between successive laye,rs of the coating system.

Descri tion of Deficiency Specification 7220-A-15(Q) requires an application of a three-coat epoxy decontaminable surfacer, designated as System 9 in Specification 7220-A-15(Q), on certain concrete walls. The three-coat system consists of one coat of Ameron 117 (surfacer) followed by two costs of Ameron 90 (topcoat). The specification, allows a second coat of Ameron 117 as necessary to ens'ure the required coverage. It was noted in Consumers Power Company Nonconformance Report (NCR) M01-4-9-132 that there was a loss of adhesion between coats of this system on Unit 2 containment interior concrete walls. Preliminary examination of these walls by Bechtel revealed that the second coat of Aneron 117 surfacer had de-laminated from the first coat of Ameron 117 surfacer.

Investigation Investigation revealed that the deficiencies were noted mostly between elevations 595' and 650'. At this early stage of examination, there was no apparent cause identified nor war it possible to make an accurate estimate of the extent of the deficiencies.

Therefore, to establish the adequacy of the System 9 coatings, an evaluati.on program will be undertaken as described under Corrective Action.

Safety Implications Project engineering's investigation of the deficiency shows an impli-cation of an adverse effcet on plant safety, and therefore is reportable under 10 CFR 50.55(e). The bases for this determination are as follow.

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1. This deficiency, were it to have remained uncorrected, could have adversely af fected the saf ety of operations of the Midland plant at any time throughout the expected lifetime of the plant.

The loss of adhesion between the first and second layers of coating Systen 9 has the potential for causing paint material to be carried into the containment sump as a result of a reactor accident followed by initiation of the containnent spray system. The containment sump is a safety-related structure, the function and design of which are described in FSAR Subsection 6.2.2.1.2.2. In accordance with NRC Regulatory Guide 1.82, the sump is designed to allow 50%

clogging of the fine inner screen without degrading spray pump or decay heat pump npsh, and to limit hydraulic approach velecities to the inner screen to approximately 0.2 ft/see to facilitate settling out of debris. However, it cannot he conclusively determined that the failure of the containment coatings described in MCAR 35 would result in less than 50% blockage of the inner sump screen. Therefore,

, adequate npsh for the spray pumps and decay heat pumps could potentially h'qve been adversely af fected, were this deficiency to have remained uncorrected.

2. This deficiency represents a significant deviation from performance specifications which will require either extensive evaluation, ex-tensive redesign, or extensive repair to establish the adequacy of the component to meet the criteria and bases stated in the safety analysis report or construction pernit, or to otherwise establish the adequacy of the component to perform its intended safety function.

FSAR Subsection 6.1.2 states that the protective coatings used inside containnent have been denonstrated to withstand the design basis accident conditions and to comply with Regulatory Guide 1.54,

.. except in certain cases where non-LOCA qualified coatings are used on small components with a limited painted surface. At this tine, the extent of the delanination indicates that it nay not be restricted to a localized area or justified by a single isolated cause.

Corrective Action  !

Project engineering is implementing a program to acconplish the action recomnended by MCAR 35, as follows.

1. Quantify, by mapping and testing coated areas to determine the extent of the physical problem.

Review design specifications, subcontractor procedures, and quality

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records for acceptability of techniques, procedures, equipment, and naterials used.

3. Perform analysis of naterials used for compliance with design and quality requirements. .

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- nCan as INTERIM rep 0RT 1 Bechtel Power Corporation Page 3

4. Establish and implement an acceptance test procedure to demon-strate that adhesion requirenents are net.

Results from th'e napping, testing, docunent review, and naterial analysis will be evaluated by Bechtel. Evaluation will include the determination of root cause(s), steps necessary to preclude recurrence, and corrective action to put the coating system into compliance with Regulatory Guide 1.54.

The next report is scheduled for January 30, 1980, and will provide a status report on the testing program.

Subnitted by . (k7% M A.7

\ Approved by: /'/

Concurrence by: . 3 JSC/sg 11/30/8

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