ML20077H684

Interim Deficiency Rept Re Inadequate Svc Level I Coatings. Initially Reported on 820928.Program for Coating Removal & Replacement Being Developed.Also Requests Relaxation of 821112 Show Cause Order Suspending Const

ML20077H684
Person / Time
Site:	Zimmer
Issue date:	08/08/1983
From:	Williams J CINCINNATI GAS & ELECTRIC CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
10CFR-050.55E, 10CFR-50.55E, LOZ-83-0099, LOZ-83-99, NUDOCS 8308110211
Download: ML20077H684 (3)

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i Lii e THE CINCINNATI GAS & ELECTRIC COMPANY n & ?=? ?

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CINCINN AT1, OHIO 45201 August 8, 1983 LOZ-83-0099 J. WILLIAME JR i SENIOR WCE PRESIDEh?

i NUCLEAR OPERAftONS

., Docket No. 50-358 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. J.G. Keppler Regional Administrator 1

i Gentlemen:

i RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT 1 10CFR50.55 (e) , ITEM S-5, INADEQUATE SERVICE LEVEL I COATINGS W.O.'57300, JOB E-5590, FILE NO. 956C, S-5 i

This letter constitutes an interim report concerning the

! subject condition, initially reported to the commission on

! September 28, 1982'as a potentially reportable deficiency under

] 10CFR50.55 (e) . This' report describes the program being developed i to correct coating deficiencies. This report also requests j relaxation of the NRC November 12, 1982, " Order to Show Cause and

[ Order Immediately Suspending Construction" (CLI-82-33) in

, accordance with Section IV.B (3) to allow coatings removal 4 activities to be conducted at this time for the reasons set forth I herein.

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! Our previous interim report, LOZ-83-0070, dated June 23, 1983

concluded that due to the extent and type of non-conformances observed, a total rework of Service Level I Coatings will be necessary. This is with the exception of a small percentage of the total surface- area which is inaccessible without removal of j -installed components. CG&E is currently developing a comprehensive program for the removal and replacement of coatings in the Drywell and Suppression Pool. The' removal and replacement

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of coatings will be performed by a qualified contractor experienced in large scale coating reworks in nuclear power 4

plants. All~ work.will be conducted under approved Quality

' Assurance programs, and controlled according to the procedures outlined in this report. A specialty consultant on coatings will

assist and' advise CG&E in the development and performance of the coatingsLrework program. The major program aspects are summarized,below.

8308110211 e30 sos PDR ADOCK 05000358 8 PDR ggg Q Q jhN g

-u- x Mr. J.G. Keppler Regional Administrator August 8, 1983 LOZ-83-0099 Page 2

1. Selection of Coating Systems Various coating systems are being evaluated. Important considerations include; a) environmental design requirements, b) decontaminability, c) system life, d) compatibility with resulting surface profile after coating removal, e) compatibility with residual coatings remaining within the pores of the prepared surface (for concrete substrates), f) ability to interface with the original coating systems at inaccessible areas, and g) application considerations regarding structural shapes and containment configuration.

In association with a number of the above considerations, the coating system for concrete substrates cannot be selected prior to coatings removal and investigation of the resulting surface.

FSAR revisions to reflect the system selected will be prepared, as required, and submitted to the NRC Office of Nuclear Reactor Regulation.

2. Coatings Removal Before the removal of any coatings, a program will be established to record and document any surface markings necessary for the completion of inspection programs and for permanent retention. A program to document existing hold tags will also be conducted prior to their removal. Coatings will subsequently be removed from accessible steel and concrete surfaces in the containment by a rough blast using a qualified blast media.

Ottawa Silica Flint has been recently tested and qualified as a blast media by CG&E. Investigations included blasting uncoated weld coupons with documented defects. The coupons

'were inspected by a qualified inspector before and'after blasting to determine the effect on welds. Test results demonstrate that controlled blasting will not mask weld defects. Test results have been documented and are available for NRC review. Other blast media are currently being c qualified. Using test program results, a program for personnel training is currently being developed.

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Mr. J.G. Keppler Regional Administrator

. August 8, 1983 LOZ-83-0099 Page 3

3. Completion of Inspection Programs

! Many ongoing inspection programs require the removal of coatings for completion. For example, QCP Tasks I, III, and XII include requirements for field visual examinations to

, determine weld and bolting deficiencies and material traceability. Following completion of the rough blast, the ongoing inspections could proceed. It is anticipated that the inspection programs will identify noncomformances. The corrective action required to resolve these nonconformances

. could result in significant rework in the containment. Since rework could be a major constraint on the reapplication of coatings, the results of inspection programs in the containment are necessary to finalize the coatings 4

replacement program.

4. Coatings Reapplication Coating reapplication will be immediately preceded by final surface preparation. The timing of final surface preparation will be governed by restrictions imposed by uncompleted construction tasks and rework. CG&E is currently identifying construction tasks and potential rework resulting from key inspection programs which are associated with significant containment surface areas. The objective is to determine when coating reapplication should be scheduled relative to other containment activities. The schedule will be finalized when the scope of containment. rework has been determined.

5. Quality Program I

Procedures to be utilized for removal and replacement of coatings, including consideration of the interface with other cor. .truction quality programs and construction completion i

activities, are being developed. The procedures will provide for protection of all equipment during the removal of the existing coatings and application of the replacement system.

Appropriate Quality. Assurance Program elements are also being developed to assure ' these activities are conducted in accordance with applicable regulations and the provisions of the. construction permit.. The complete program will be.

provided to your representatives for review.

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f Mr. J.G. .Keppler Regional' Administrator August 8, 1983 LOZ-83-0099 Page 4 Removal of the coatings will permit finalizing the selection of coatings, facilitate conduct of major inspection programs, and provide an optimum environment for rework during the completion of construction program; also, until the commencement of implementation of the plan to verify the quality of construction, there will be no interference with other work in the drywell or the suppression pool. Accordingly, it is requested that CG&E be permitted to proceed as soon as possible with the removal of coatings.

We trust this will be found acceptable as as interim report under 50.55 (e) and would appreciate your approval of the above request for relaxation of the NRC November. 12, 1983 " Order to Show Cause and Order Immediately Suspending Construction" (CLI-82-33).

Very truly yours, 1 1

THE CINCINNATI GAS & ELECTRIC COMPANY By _%#[2;;Ar

{ CLIAMS, JR/

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ENIOR VICE PRE DENT PEB/sfr cc: NRC Office of Inspection & Enforcement Washington, D.C. 20555 NRC Senior Resident Inspector ATTN: W.F. Christianson NRC Zimmer Project Inspector, Region III ATTN: E. R. Schweibinz i