ML19256F337

Interim Deficiency Rept Re in-containment Coatings Which Have Loss of Adhesion Between Successive Layers of Coating Sys.Approx 600 Square Ft of Surface Under Investigation

ML19256F337
Person / Time
Site:	Midland
Issue date:	12/13/1979
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
References
MCAR-1, NUDOCS 7912180526
Download: ML19256F337 (6)

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Consumers H (,7,,9 '

iPOVier CO@W Senior Vice Presadent General Offices: 1943 West Parnell Road, Jackson, Michigan 49201 e (517) 788-0453 December 13, 1979 Hove-309-79 Mr J G Keppler Regional Director Office of Inspection & Enforce =ent US Nuclear Regulatory Consission 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 CONTAINEIT INTERNAL STRUCTURES COATING DEFICIENCY In accordance with the require =ents 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 syste=. The attach =ents to this letter provide a = ore conplete 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 0 'ML WRB/1r Attachments: 1. Quality Assurance Program, Management Corrective Action Report, MCAR-1, Report 35, dated Nove=ber 13, 1979

2. MCAR-35,' Interim Report #1, dated November 30, 1979

'CC : Director of.0ffice 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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QUALITY ASSURANCE PROGRAM

• MANAGEMENT CORRECTIVE ACTION REPORT Attachment 1 MCAR1 Hove-309-79 REPORT NO. 35 JOB NO. 7220 0028c)Nb. 2.20 DATE November 13. 1979 i

• DESCRIPTION (including references): Epoxy deconcaminative 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. I.. Manta in accordance with 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 f t01-4-9-132 (attached). (Continued on page 2)

' RECOMMENDED ACTION (Optional)

I. Determine Root Cause:

A. Quantify by =apping 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 wita 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 D ENGIN4ERING O CONSTRUCTION OOA MANAGEMENT O O PROCUREMENT ISSUED BY O tu Project GA Engineer cl lH3% l Oate ,

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I 11 REPORTABLE DEFICIENCY l

Potentially Reportable NOTIFIED CUENT j

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,Date O NO O YES P. ,ec

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CORRECTIVE ACTION TAKEN AUTHORIZED BY Date STANDARD DISTRIBUTION ADDITIONAL DISTRIBUTION AS APPROParATE

" " FORMAL REPORT TO CLIENT _

R "c'NTE PROJECT EYGNY" (If Section 11 Applies) Date GPQ . QA M ANAGER AAO PROCURE VENT $UPPUE R QUAUTV MGR L APO C A M AN AGE R CONSTRUCTON MANAGER PROJ T R EF ST EER CutNT ProCE AAo PROJECT OPERATON$ MANAGER 8 OfVtSON PROCURELENT MGR CORRECTIVE ACTION IMPLEMENTED A&O PROCURE ME NT M ANAGE R PROJ PROCUREMENT MGR aAO MGR OF ENGINEER *NG DfV $UPPtIER QUAUTY MGR AAO MGR QF CON 31RUCION VERIFIED BY 0 eceee a sosce yo.ee we enacn.ar. ace om Project OA Engineer Date

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MCAR 35 Noven.ber 13, 1979 Page 2 QQ2Qll DESCRIPTICN: (Cont'd)

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

_ REC 0!ffENDED ACTION: (Cont'd)

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

IV. Take appropriate steps to preclude recurrence. m V. Provide report to QA by Nover.ber 30, 1979 (interim or final).

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• Attachment 2 Howe 309 Bechtel Power dor-79poration

SUBJECT:

MCAR 35 (issued 11/13/79)

Containment Internal Structures Coating INTERIM REPORT 1 DATE: Novembc- 30, 1979 PROJECT: Consumers Power Company Midland Plant Units 1 & 2 Bechtel Job 7220 Introducticn As requested in MCAR 35, this report sumnarizes 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 Aceron 117 (surfacer) followed by two coats of Ameron 90 (topcoat). The specification, allows. a second coat of Ameron 117 as

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necessary to encure the required coverage. It was noted in Consumers Power Company Nonconfor=ance Report (NCR) M01-4-9-132 that there was a loss of adhesion between coats of this system on Unit 2 containmn.nt 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 o coatings, an evaluation 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 ef fect on plant safety, and therefore is reportable under 10 CFR 50.55(e).

The bases for thi~s determination16 are as 0'o4

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MCAR 35 INT m M RrPonT i Bechtel Power Corporation Page 2

1. This deficiency, were it to have remained uncorrected, could have adversely affected the safety of operations of the Midland plant at any time throughout the expected lifetine 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 systen. 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 velocities to the inner screen to approximately 0.2 ft/see to facilitate settling out of debris. However, it cannot be conclusively determined that the failure of the containment coatings described in MCAR 35 would result in less than 50% hlockage of the inner sump screen. Therefore,

, adequate npsh for the spray pumps and decay heat pumps could potentially hhve been adversely affected, were this deficiency to have remained uncorrected.

2. This deficiency represents a significant deviation from performance specifiestians which will require either extensive evaluation, ex-tensive redesign, or extensive repair to establish the adequacy of the conponent 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 demonstrated to withstand the design basis accident conditions and to ceeply 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 time, the extent of the delamination indicates that it nay not be restricted to a localized area or justified by a single isolated cause.,

corrective Action  !

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

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

2. Review design specifications, subcontractor procedures, and quality records for acceptability of techniques, procedures, equipment, and materials used.

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

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MCAR 35 INTEP.IM DEPORT 1 Bechtel Power Corporation Page 3

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

Results from the napping, testing, docunent review, and naterial analysis will be evaluatee' by Bechtel. Evaluation will include the determination of root carsc(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 progran.

Subnittert by . 'bMM7

\ Approved by: 8 Concurrence by: .

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