DG

, " xm : .

".

TIIE CINCINNATI GAS & ELECTRIC COMI'ANY M"CINCINN ATI. OHIO 4 5201

November 9, 1983LOZ-83-0165s. wm.uaus a

SENtCap vict PotssogN

NUCLE *# O.ER Af sche

Docket No. 50-358

Mr. J.G. KepplerRegional AdministratorU.S. Nuclear Regulatory CommissionRegion III799 Roosevelt RoadGlen Ellyn, Illinois 60137

Dear Mr. Keppler:

RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT 110CFR50.55(e), ITEM S-ll, STRUCTURAL STEELBOLTINGW.O. 57300, JOB E-5590, FILE #956C, S-11

This letter constitutes an interim report concerning thesubject condition initially reported to the Commission on May 13,1983 as a potentially reportable deficiency under therequirements of 10CFR50.55 (e) . Based on a November 1, 1983telephone conversation between Messrs J. Harrison (NRC) and R.Wrucke (CG&E), it was agreed that an extension would be grantedfor the submittal of this report from November 1, 1983 toNovember 15, 1983.

On August 11, 1983, a meeting was held at the Wm. H. Zimmersite between the Nuclear Regulatory Commission (NRC) and TheCincinnati Gas & Electric Company (CG&E). The NRC wasrepresented by Messrs. L. Kintner, C. Scheibelhut, D. Keating,and W. Christianson. During this meeting, CG&E's program for,

'Reinspection and Rework of Structural Steel High Strength Boltingwas presented and is summarized below. Program details areprovided in Attachment A to this letter.

REINSPECTION AND REWORK OF STRUCTURAL STEEL HIGH STRENGTHBOLTING - SUMMARY

In order to resolve the concern of inadequate inspectiondocumentation for high strength bolting, a comprehensivereinspection program for accessible connections has beendeveloped. This program is part of the expansion of theQuality Confirmation Program (QCP), as addressed in ourletter LOZ-83-0038, dated June 13, 1983. The reinspectionprogram includes sampling for hole size which is a g%

h8311210423 831109 \FDR ADOCK 05000358

_}}t __

S PDR ,

- . , . -- . , - .- -- - -- - .

. .,

.

Mr. J.G. Kepplet_Regional AdministratorNovember 9, 1983 ,

LOZ-83-0165Page 2

!

modification to the Bolting Task Description which wasattached to that letter. This program is in conformance withthe design and construction requirements cited in the FSAR

,

except for bolt length acceptability criteria; verificationof contact surfaces and hole alignment of friction-type .

connections; and the use of sampling. An FSAR revision willbe submitted indicating these exceptions'to the design and

,

construction requirements cited in the FSAR.

As part of the reinspection program, connections.not meetingacceptance criteria will be documented as unacceptable. CG&E

~

'

intends to disposition nonconformances concurrent withinspections so rework can be accomplished immediately. On-'

the-spot 1 rework shall be limited to changing bolts, nuts,washers, and retorquing.- .It is considerably more efficientto perform this type of rework in' conjunction with theinspection.'

Procedures governing the reinspection / rework-program are.currently being developed by CG&E and the proposed Project

! Director (Bechtel). Upon' completion _of procedure development,I the .NRC will be notified and a ' review meeting scheduled. As

requested in NRC Region IIIfletter of, October 4, 1983, theprocedures and QA program to be applied to this rework would

~

be the same as~if the work were being performed under theorganization proposed in our Course of Action documentsubmitted to Region III on October 5,~1983.

|CG&E-intends ~to request' relaxation of:the-Show:Cause Order in'

association with-the reworkfdefined above, contingent upon an .

acceptable-procedural review by the NRC.

,

w

w

a

j ' |

w y3 + --e- e r - 7 * --,e+ . - - - ,- " - --3's-.- --e, , _ a#w

4

. .,

Mr. J.G. KepplerRegional AdministratorNovember 9, 1983LOZ-83-0165Page 3

We trust this letter will be found acceptable as an interimreport under 10CFR50.55 (e) .

Very truly yours,

THE CINCINNATI GAS & ELECTRIC COMPANY.

Rd.

ENIOR VICE PRESIDENT

RRW/sfr

cc: NRC Office of Inspection & EnforcementWashington, D.C. 20555

NRC Resident Site InspectorATTN: W.M. Hill

NRC Zimmer Project Inspector, Region IIIATTN: E. R. Schweibinz

.

h'

e

N > p

? r

__ _ ._ _ _ _ _ _ _ _ _ _ _ _ .

i.* .

.

i-

fLOZ-83-0165

ATTACHMENT'A 1

|

: 'I

Reinspection and Rework of Structural Steel'High Strength Bolting

The inadequate inspection of safety-related high strength steel-bolting was initially reported to the Commission on May 13, 1983>

; as a potentially reportable-deficiency-under 10CFR50.55(e) ItemS-11. In order to resolve the concern of inadequate inspectiondocumentation for high strength bolting, a comprehensivereinspection program for accessible connections has been

4 - developed. In addition to reinspection, the program also. calls| for immediate rework of nonconforming bolts, nuts and washsrs.' - This program is a part of the expansion of the Quality

Confirmation Program (OCP)' addressed in CGEE letter LOZ-83-0038,dated June 13, 1983.

Class I Structures included in the program are as follows:

(1) Auxiliary Building, Reactor Building below Elevation627' - 0" and Diesel Generator Building.

t

(2) Service Water Pump Structure4

i

; - (3) Reactor Building at and' Above E,levation 627' -- 0";

'

(4) Gallery Steel in Class I Structures 1

(5) Intake Flume+

The Reactor Building _has been divided into two reinspection areasbecause El'. 627' -0" is the refueling floor:and a restricted;

'

area. The reinspection scope proposed at El. 627' - 0" and above.

differs from that below so as not-to be detrimental,to the.. cleanliness ' of the restricted area.

Bolted connections of the-following' accessible framing arei included in this~ program for Class I structures referenced:'

(1) Structural steel framing as shown on Sargent--&1Lundy. .(S&L) structural drawings,'2 fabricated and' erected-per

Specification H-2174,~ Sections 5-2-andL5-3, ibracing and trolley' beams.-

'

ncluding-,

,

(2) Seismic-block wallicolumnslattached'to the exterior'

surfacefof:blockwalls'as shown-on'S&L architectural-drawings.

' (3)- Mechanical gallery framing.-

| (4) Bolted connections?in the ServiceLWater Pump. Structure:and Intake Flume'.

-

4

-. e *--a 9 wl,-=-- 9 g- p 4 + e d- s- wve ,i-w r e+w,'7v T- r - v- v 't 9 -

*.

LOZ-83-0165" ATTACHMENT A"Page 2

The extent of reinspection for the identified Class I structuresis described below. The use of sampling for hole size is amodification to the task description for QCP Task XII which waspreviously sent to NRC Region III (LOZ-83-0038, June 13, 1983).

(1) Auxiliary Building, Reactor Building below Elevati627' - 0" and Diesel Generator Building:

,

a. 100% of all' slotted hole connections and allblockwall seismic columns located on the exteriorsurf ace of the wall .

b. 100% of all' connections when bearing capacity isless than friction capacity,

c. Connections where bearing capacity is greater thanthe f riction capacity will be reinspected for allattributes of " Bearing Connections" as identifiedlater in this attachment, and will be initiallysampled and reinspected as follows:

1. After an initial sampling of a statisticallyadequate number of connections for hole sizeshas been completed, an evaluation will be madeto justify the use of bearing load allowables.If the initial hole sampling is notacceptable, the sample size will be expandedor the connection design allowables.willrevert back to friction load allowables. Thesampling will be of sufficient size'to obtaina 95/95 (Confidence / Reliability) based on MIL-STD-105D sampling procedure.

2. After hole sampling has been completed, 100%of all connections shall continue to be~inspected in accordance with the Specificationfor Structural Joints using ASTM A-325 or A-490 Bolts (2 bolts-per connection) containedwithin the 7th Edition of the Manual -for SteelConstruction by the American Institute ofSteel Construction (AISC), for all itemsexcept hole size.

(2) Service Water Pump Structure|

.a. 100% of all ' slotted. hole connections.

:!

, -

_ _ . _ _ _ _ . _ . . .. .. _ __.. - _ .. _ ..__ ._ _ _. _ __ _

.

' ' '.

[

,

LOZ-83-Ol65'

" ATTACHMENT A"4

Page 3:

;

,

f,

i |

b. Connections where bearing capacity is greater.thanthe f riction capacity will be reinspected for allattributes of " Bearing Connections" as identifiedlater in this attachment, and will.be initiallysampled and reinspected as.follows: -

1. After an initial sampling of a. statistically ,

adequate number of connection hole sizes has'

been completed, an evaluation will be made toi justify-the use of bearing load.allowables.i If the initial.saupling is not acceptable, the ,

_

sample size will be expanded or the connection'

design allowables will revert'back to frictionload allowables. The sampling will be ofsufficient size to obtain a 95/95(Confidence /Reliabi,lity) based on MIL-STD-105Dsampling procedure. ,

,

2. Af ter hole sampling has been completed,! 100% of all connections shall continue to be3 reinspected in accordance with the .

Specification for Structural Steel Jointsusing ASTM A-325 or A-490 bolts (2 bolts perconnection) for f all -items except hole ' size.

(3) Reactor Building at and above Elevation 627' 0":,

a. 100% of all connections (bolt, nut,washer type and torque attributes only).

,

(4) Gallery Steel in Class I Structures

; a. 1004.of:all Mechanical. Gallery Steel..

~

j (5) Intake Flume: -

; a._100% of all bracing.

'

,

t

| <.

|

t . -

(.. ,-

_

-; ., ;

--

S y a'

. . . _ ___.- __._ _ . . . _ _ _ .. . .- - .__

*.

,

a

s

LOZ-83-0165" ATTACHMENT A" ,

Page 4

The Reinspection Scope of applicable connections is as follows:

(1) Bearing Connections,

a. Bolt typeb. Edge distancec. Hole sized. Torquee. Nut and washerf. Hole conditiong. Thread projection 1

(2) Friction Connections

a. Bolt typeb. Edge distancec. Nut and washerd. Torquee. Exposed holesf. Thread projection

3

(3) Slotted Hole Connections With Member Axial T.oad

| a.- Bolt typeb. Edge distance

! c. Nut and washerd. Torquee. Thread projection

(4) Sliding Connections

a. Bolt type; b. Torque 50-100 ft-lbs.'

c. Bolt - Slot. positiond.- Beam and clearance

i e. Jam nutf. Hole size and conditiong. Thread projection -

h.- Edge distance1. Nut andLwasher.

The adequacy of bolted connections.will be determined.by.the-following criteria:

. (1) ConnectionsL which are in conformance withspecifications, approved design drawings ~(or other

- :4

,

, ,

.

N y 1 w - 4

. . - - _ - . .- - . .. - .. .

. ,,

a

LOZ-83-0165" ATTACHMENT A"Page 5

J

approved design documents), and referenced codes shallbe considered acceptable and documented as such.

,

This reinspection program is in conformance with FSARcommitments with the following exceptions:

'

Bolt Length'

i

FGAR Table 3.8-2 " List of Specifications, Codes andStandards" references ANSI N45.2.5-1972. This ANSIstandard specifies inspection of bolting forcorrect length "as indicated by at least twothreads extending beyond the nut." Thereinspection program specifies inspection ofbolting for correct length based on the end of thebolt being flush with, or extending beyond the faceof the nut. This reinspection criteria isconsistent with ANSI N45.2.5-1978, and the" Specification for Structural Joints using ASTM A-325 or A-490 Bolts", of AISC dated 1976.-

Contact Surf ace Condition and Hole ' Alignment '

ANSI N45.2.5-1972 also requires "... verification ofthe condition of contact surfaces of friction typeconnections and bolt hole alignment." Thereinspection program does not specify verificationof thene attributes. However, the reinspectioncriteria is consistent with the Seventh Edition ofthe AISC, 1973 Issue. Contact surfaces forfriction connections are generally uncoated.'

Connections which may have been coated will be inconformance with AISC requirements based on acontact surface having an approved inorganic zinccoating._ verification of bolt hole alignment forfriction type connections is not.being conductedsince the 1973 issue of AISC allowed' oversize.' holes.

Sampling

AISC requires in-process inspection of bolt holes,

for ASTM A-325 and A-490 bolts._ The reinspectionprogram specifies sampling of a' statistically _adequate number of bearing type connections for-bolt hole size in accordance- with MIL-STD-105D.

,, . -- . - . . , ,

. . - - .- . . . . . - . - . , - _ - . . -- . - .

. . . ,

0

1

'

LOZ-83-0165: " ATTACHMENT A"

Page .

;

!

An FSAR revision addressing the exceptions will beprepared and submitted to the NRC Of fice of Nuclear

! Reactor Regulation.

(2) Connections not meeting the above criteria shall be' considered unacceptable and documented on NonconformanceL

Reports. . These connections.shall be reworked during theinspection program to correct certain deficienciesfound. Concurrent rework shall be limited to changing

,

bolts, nuts, washers and retorquing.!'

Deficiencies which can not be corrected by the. rework mentionedabove will be dispositioned appropriately on' NonconformanceReports (NR's). If the as-found condition of .tdue connection has4

the capacity to support the design loads within ATSC codeallowable stresses, no rework will be required and the NRdisposition shall be " Accept-As-Is".

' As stated above, all deficiencies found will be documented. CG&E-intends to support the reinspection program with suf ficientengineering and construction personnel so that non-conformancescan be identified and dispositioned immediately to allow reworkto be accomplished. concurrent with the inspection. After aconnection has been inspected,.dispositioned and appropriatelyreworked (if applicable), - the connection shall. be documented asacceptable and further reinspection shall not be considerednecessary. ;

.

4

f

,

d

4

I

.

4

r

e * + ~ v - - ~ ' + b i w v