IR 05000219/1986009
| ML20215F069 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/06/1986 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 8610160069 | |
| Download: ML20215F069 (2) | |
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GCT 0 G 1986 Docket No. 50-219 GPU Nuclear Corporation ATTN: Mr. P. B. Fiedler Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388 Forked River, NJ 08731 Gentlemen:
Subject:
Inspection Report No. 50-219/86-09 This refers to your letter dated August 6,1986, in response to our letter dated June 30, 1986 and to the subsequent phone conversation between Mr. D.
Croneberger of your staff and Mr. J. Wiggins of my staff on September 18, 1986.
Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.
From the September 18, 1986 phone conversation, we understand that:
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If a wall is identified as suspect during your reverification pro-gram, continued plant operation would be permitted if a seismic failure consequence analysis verified the existence of at least one path to cold shutdown assuming all nonseismic walls fail. We note that this analysis should not rely on non-seismically qualified system or equipment to effect this shutdown.
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The mortar verification program results thus far have been inconclusive and you are engaged in further efforts, including possible alternate means to the petrographic and chemical analyses described in your letter, to resolve this concern. However, your commitment date of December, 1986 for resolution of the Deviation discussed in our inspection report is still valid.
If the understandings described above are incorrect, please notify me promptly.
Your cooperation with us is appreciated.
Sincerely, 0610160069 861006 Original Signed By:
DR ADOCK 0500
Jacque P. Durr Stewart O. Ebneter, Director Division of Reactor Safety 0FFICIAL RECORD COPY RL OYC 86-09 - 0001.0.0
Y(;o 10/02/86
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GPU Nuclear Corporation
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cc w/ encl:
M. Laggart, BWR Licensing Manager Licensing Manager, Oyster Creek Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New Jersey bec w/ encl:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP Robert J. Bores, DRSS RI:URS RI:DRS RI:DRS AVarela/ca JWiggins JDurr 9/N/86 9#r/86
/d/! /86 O /
M fn 1sv 0FFICIAL RECORD COPY RL OYC 86-09 - 0002.0.0 09/23/86
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QPU Nuclear
g gf 100 Interpace Parkway Parsipoany. New Jersey 07054 201 263-6500 TELEX 136-482 August 6, 1986 Writer's Direct Dial Number-5000-86-0975 Mr. Stewart D. Ebneter, Director Division of Reactor Safety Region I U.S. Nuclear Regulatory Comission
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631 Park Avenue King of Prussia, PA 19406
Dear Mr. Ebneter:
Subject: Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection 86-09 re: Bulletin 80-11 Pursuant to 10CFR2.201, the attachment to this letter contains our response to the Notice of Violation in Appendix A and the Notice of Deviation in Appendix B of your letter dated June 30, 1986.
On July 14, 1986, a response time extension request to 30 days from 20 days was granted by Mr. J. T. Wiggins, Region I, via telephone.
Again on July 29, 1986, additional response time was requested to August 6,1986 which was granted by Mr. J. P. Durr, Region I.
The additional time was needed due to a delay in receipt of your letter and to allow for the final preparation and management review of our response.
Should you have any questions concerning infonnation in the attachment, please contact Mr. Paul F. Czaya at (201) 299-2542.
Y yt ly yours,
'. f. h b Vice Pres' dent Technical Functions RFW/PC/pa cc: Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA.
19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, N.J.
08731 i
J. Donohew 9b r
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Phillips Building, Hail Stop 3.0 I
Dethesda, Maryland 20014
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GPU No:! ear is a part et the General Pubiic Utihties System i
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i ATTAC WENT Violation 1
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10 CFR 50, Appendix 8, Criterion VII requires that the purchase of materials, i
equipment or services be procedurally controlled and documentary evidence be maintained to assure source evaluation, evidence of quality furnished,
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inspection at the contractor and examination of product upon delivery.
The GPUN Operational Quality Assurance Plan, Section 5.1.1.1 also requires
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evaluation of procurement sour 1:es, monitoring of consultants, vendors and contractors and confirmation that purchased items and services meet procurement documents.
Contrary to the above, on May 9,1986, documentary evidence was not available
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to demonstrate that source evaluation or oversight of quality furnished or i
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j delivered was made for Computech Engineering Services, Inc. insofar as this organization's involvement in IE Bulletin 80-11.
This is a Severity Level V violation.
(Supplement I)
Response GPU Nuclear concurs with the above violation, as stated.
In 1980, Computech i
Engineering Services, Inc. was contracted to provide design criteria for revaluating masonry walls at Oyster Creek based upon the state-of-the-art at that time utilizing the generic methodology Computech developed in conjunction
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Quality Assurance requirements were not imposed.
l In order to ensure that the criteria remain valid and represent a quality effort, an in-house verification, perfomed subsequent to the inspection, was
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recently completed in accordance with Technical Functions Procedure EP-009 l
" Design Verification". No unacceptable findings resulted. Documentation of the verification has been entered into the document control system.
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Subsequent to the initial effort in response to Bulletin 80-11, well defined ;
procedural controls have been established to ensure vendor qualification for j
l perfoming nuclear safety-related work. GPU Nuclear Procedure TAP-11 j
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" Purchase Requisitions" provides adequate guidance for the procurement of
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Regarding vendor-provided items and services during the Bulletin 80-11 effort,
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we believe this is an isolated instance.
Full compliance has been achieved.
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Violation 2 j
Criterion XVII, Appendix B, 10 CFR 50 requires sufficient records shall be maintained to furnish evidence of activities affecting quality, and records jl shall be identifiable and retrievable.
GPUN's Quality Assurance Program l
Section 3.3 requires that quality assurance records for items and activities covered under the scope of the GPUN QA Program, and records generated by contractors shall be controlled, accepted, retained and retrievable.
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Contrary to the above, on May 9,1986, records which would verify that the licensee's initial masonry wall survey conducted in response to IE Bulletin 80-11, was performed using controlled procedures and/or instructions were either not retained or were not retrievable through the document control system.
This is a Severity Level IV violation.
(Supplement 1)
Response GPU Nuclear concurs with the above violation, as stated. Although a masonry wall survey was originally performed, documentation could not be located.
Currently, GPU Nuclear is in the process of reverifying masonry walls at Oyster Creek which have the potential for having nuclear safety-related (NSR)
i equipment either attached or in their immediate vicinity. The reverification program includes a review of structural and architectural drawings and walkdowns. As part of the walkdown, a data sheet is used to document components attached to or in the imediate vicinity of masonry walls.
In certain cirtumstances, photographs of the walls are taken. The components are then identified to determine if they are NSR or impact NSR equipment.
Reverification documentation is to be entered into the' document control system.
To date, approximately 125 masonry walls of the 265 known walls have been walked down.
Since 48 masonry walls have been previously documented as NSR, 92 walls remain to be walked down. Of the 125 walls walked down during the
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current refueling outage, one additional wall has been identified as impacting
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NSA components. A preliminary evaluation indicates these components were installed during the current Appendix R modifications.
This evaluation is
continuing.
Those walls which are accessible _during the current refueling outape, but not during power operation, are being walked down.
The remaining walls are scheduled to be walked down in the fall and winter of 1986. Assessment of the
walkdown results is scheduled for March 30, 1987 completion.
Should additional masonry walls not currently considered NSR be identified as l
having NSR components attached or in their imediate vicinity, the walls will
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be entered into the action plan as was done for the 48 walls already documented as NSR. This will include a structural integrity analysis and, if
deficiencies are found, a wall failure consequence analysis.
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Deviation i
j IE Bulletin 80-11, Masonry Wall Design, dated May 8,1986, informed licensees
that existing test data or conservative assumptions could be used to justify
the reevaluation criteria to be applied to existing safety-related walls, f
In letters dated November 14, 1980, the licensee responded to Bulletin 80-11 and indicated its commitment to complete the actio% delineated in the
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Contrary to the above, the licensee solely relied upon mortar properties found in the construction specification to determine the strength value for type M mortar.
No documentation was provided which verified that type M mortar was actually used to construct the walls, no test program was undertaken to quantify the mortar strength, nor were conservative assumptions used for the reevaluation criteria.
Response GPU Nuclear concurs with the above deviation, as stated. Documentation of as-built mortar type and strength could not be located.,; -
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A test program has been initiated to determine mortar type.
Due to the difficulty in obtaining samples for a compressive strength test, it has been decided to utilize a combination of a petrographic test and chemical
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analysis.
To date, only two testing lab' oratories have been found which are A _.
both capable and willing to perform these tests. Mortar' :amples have been'
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~~ collected from one masonry wall.
Additional mortar samples will be obtained prior to restart from th' current (Cycle llR) refueling outage.
Preliminary e
test results are expected prior to restart. Complete documentation with respect to confirmation of mortar type is planned to be available by December, 1986.
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