ML20082C068

Interim Deficiency Rept,Item S-11 Re Structural Steel Bolting.Initially Reported on 830513.Comprehensive Reinsp Program for Accessible Connections Developed.Procedures Governing Rework Program Under Development

ML20082C068
Person / Time
Site:	Zimmer
Issue date:	11/09/1983
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-83-0165, LOZ-83-165, S-11, NUDOCS 8311210423
Download: ML20082C068 (9)

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TIIE CINCINNATI GAS & ELECTRIC COMI'ANY M" CINCINN ATI. OHIO 4 5201 November 9, 1983

s. wm.uaus a LOZ-83-0165 SENtCap vict PotssogN NUCLE *# O.ER Af sche Docket No. 50-358 Mr. J.G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT 1 10CFR50.55(e), ITEM S-ll, STRUCTURAL STEEL BOLTING W.O. 57300, JOB E-5590, FILE #956C, S-11 This letter constitutes an interim report concerning the subject condition initially reported to the Commission on May 13, 1983 as a potentially reportable deficiency under the requirements of 10CFR50.55 (e) . Based on a November 1, 1983 telephone conversation between Messrs J. Harrison (NRC) and R.

Wrucke (CG&E), it was agreed that an extension would be granted for the submittal of this report from November 1, 1983 to November 15, 1983.

On August 11, 1983, a meeting was held at the Wm. H. Zimmer site between the Nuclear Regulatory Commission (NRC) and The Cincinnati Gas & Electric Company (CG&E). The NRC was represented 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 Bolting was presented and is summarized below. Program details are provided in Attachment A to this letter.

REINSPECTION AND REWORK OF STRUCTURAL STEEL HIGH STRENGTH BOLTING -

SUMMARY

In order to resolve the concern of inadequate inspection documentation for high strength bolting, a comprehensive reinspection program for accessible connections has been developed. This program is part of the expansion of the Quality Confirmation Program (QCP), as addressed in our letter LOZ-83-0038, dated June 13, 1983. The reinspection program includes sampling for hole size which is a g%

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Mr. J.G. Kepplet_ Regional Administrator November 9, 1983 , LOZ-83-0165 Page 2 modification to the Bolting Task Description which was attached to that letter. This program is in conformance with the design and construction requirements cited in the FSAR except for bolt length acceptability criteria; verification of contact surfaces and hole alignment of friction-type . connections; and the use of sampling. An FSAR revision will be submitted indicating these exceptions'to the design and construction requirements cited in the FSAR. As part of the reinspection program, connections.not meeting ~ acceptance criteria will be documented as unacceptable. CG&E intends to disposition nonconformances concurrent with inspections 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 efficient to perform this type of rework in' conjunction with the inspection. 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, the ~ procedures and QA program to be applied to this rework would be the same as~if the work were being performed under the organization proposed in our Course of Action document submitted to Region III on October 5,~1983. l 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 ' l w y3 + --e- e r - 7 * --,e+ w . - - - ,- " -

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4 Mr. J.G. Keppler Regional Administrator November 9, 1983 LOZ-83-0165 Page 3 We trust this letter will be found acceptable as an interim report under 10CFR50.55 (e) . Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY

                                               .             Rd ENIOR VICE PRESIDENT RRW/sfr cc:    NRC Office of Inspection & Enforcement Washington, D.C. 20555 NRC Resident Site Inspector ATTN: W.M. Hill NRC Zimmer Project Inspector, Region III ATTN: E. R. Schweibinz h

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i.* . i-LOZ-83-0165 f ATTACHMENT'A 1 l 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) Item S-11. In order to resolve the concern of inadequate inspection documentation for high strength bolting, a comprehensive reinspection program for accessible connections has been 4- developed. In addition to reinspection, the program also. calls l 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 Elevation 627' - 0" and Diesel Generator Building. t 4 (2) Service Water Pump Structure 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 areas because 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 are i 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, i ncluding-bracing and trolley' beams.-                       ,

(2) Seismic-block wallicolumnslattached'to the exterior surfacefof:blockwalls'as shown-on'S&L architectural-drawings.

                ' (3)- Mechanical gallery framing.

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

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LOZ-83-0165

       " ATTACHMENT A" Page 2 The extent of reinspection for the identified Class I structures is described below. The use of sampling for hole size is a modification to the task description for QCP Task XII which was previously sent to NRC Region III (LOZ-83-0038, June 13, 1983).

(1) Auxiliary Building, Reactor Building below Elevati 627' - 0" and Diesel Generator Building:

a. 100% of all' slotted hole connections and all blockwall seismic columns located on the exterior surf ace of the wall .

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

c. Connections where bearing capacity is greater than the f riction capacity will be reinspected for all attributes of " Bearing Connections" as identified later in this attachment, and will be initially sampled and reinspected as follows:

1. After an initial sampling of a statistically adequate number of connections for hole sizes has been completed, an evaluation will be made to justify the use of bearing load allowables.

If the initial hole sampling is not acceptable, the sample size will be expanded or the connection design allowables.will revert back to friction load allowables. The sampling will be of sufficient size'to obtain a 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 Specification for Structural Joints using ASTM A-325 or A-490 Bolts (2 bolts-per connection) contained within the 7th Edition of the Manual -for Steel Construction by the American Institute of Steel Construction (AISC), for all items except hole size. (2) Service Water Pump Structure l

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

[ LOZ-83-Ol65 4

             " ATTACHMENT A"

Page 3 f

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b. Connections where bearing capacity is greater.than the f riction capacity will be reinspected for all attributes of " Bearing Connections" as identified later in this attachment, and will.be initially sampled 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 to i 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 friction load allowables. The sampling will be of sufficient size to obtain a 95/95 (Confidence /Reliabi,lity) based on MIL-STD-105D sampling procedure. ,

2. Af ter hole sampling has been completed,

! 100% of all connections shall continue to be 3 reinspected in accordance with the . Specification for Structural Steel Joints using ASTM A-325 or A-490 bolts (2 bolts per connection) 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

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a. 1004.of

all Mechanical. Gallery Steel. .

j (5) Intake Flume: - a._100% of all bracing. t l < l 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 type

b. Edge distance

c. Hole size

d. Torque

e. Nut and washer

f. Hole condition

g. Thread projection 1 (2) Friction Connections

a. Bolt type

b. Edge distance

c. Nut and washer

d. Torque

e. Exposed holes 3

f. Thread projection (3) Slotted Hole Connections With Member Axial T.oad l a.- Bolt type

b. Edge distance

! c. Nut and washer

d. Torque

e. Thread projection (4) Sliding Connections

a. Bolt type

b. Torque 50-100 ft-lbs.

c. Bolt - Slot. position d.- Beam and clearance i e. Jam nut

f. Hole size and condition

g. Thread projection -

h.- Edge distance

1. Nut andLwasher.

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

               . (1)   ConnectionsL which are in conformance with specifications, approved design drawings ~(or other 4

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a LOZ-83-0165

                 " ATTACHMENT A" Page 5 J

approved design documents), and referenced codes shall be considered acceptable and documented as such. This reinspection program is in conformance with FSAR commitments with the following exceptions: Bolt Length i FGAR Table 3.8-2 " List of Specifications, Codes and Standards" references ANSI N45.2.5-1972. This ANSI standard specifies inspection of bolting for correct length "as indicated by at least two threads extending beyond the nut." The reinspection program specifies inspection of bolting for correct length based on the end of the bolt being flush with, or extending beyond the face of the nut. This reinspection criteria is consistent 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 of the condition of contact surfaces of friction type connections and bolt hole alignment." The reinspection program does not specify verification of thene attributes. However, the reinspection criteria is consistent with the Seventh Edition of the AISC, 1973 Issue. Contact surfaces for friction connections are generally uncoated. Connections which may have been coated will be in conformance with AISC requirements based on a contact surface having an approved inorganic zinc coating._ verification of bolt hole alignment for friction type connections is not.being conducted since 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 reinspection program 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 be prepared 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 the inspection program to correct certain deficiencies found. Concurrent rework shall be limited to changing bolts, nuts, washers and retorquing. Deficiencies which can not be corrected by the. rework mentioned above will be dispositioned appropriately on' Nonconformance 4 Reports (NR's). If the as-found condition of .tdue connection has the capacity to support the design loads within ATSC code allowable stresses, no rework will be required and the NR disposition shall be " Accept-As-Is". As stated above, all deficiencies found will be documented. CG&E-intends to support the reinspection program with suf ficient engineering and construction personnel so that non-conformances can be identified and dispositioned immediately to allow rework to be accomplished. concurrent with the inspection. After a connection has been inspected,.dispositioned and appropriately reworked (if applicable), - the connection shall. be documented as acceptable and further reinspection shall not be considered necessary.  ; 4 f d 4 I 4 r e * + ~ - - ~ '

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