IR 05000271/1986017

Insp Rept 50-271/86-17 on 860909-12.Violations & Deviation Noted:Original Wall Survey Not Performed Utilizing Documented & Controlled Procedures

ML20215M491
Person / Time
Site:	Vermont Yankee
Issue date:	10/21/1986
From:	Varela A, Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215M481	List: IR 05000271/1986017 ML20215M479 ML20215M483 ML20215M486
References
50-271-86-17, IEB-80-11, NUDOCS 8610300283
Download: ML20215M491 (15)

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l U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-17 Docket N License N DPR-28 Priority -

Category C Licensee: Vermont Yankee Nuclear Power Corporation Ferry Road Brattleboro, Vermont 05301 Facility Name: Vermont Yankee Nuclear Power Station Inspection At: Framingham, Massachusetts and Vernon, Vermont Inspection Conducted: September 9-12, 1986 Inspectors:  % kv lb Lj f(f

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A.gVarela,LgReactorgEngineer date NRC Contract Personnel: M. E. Nitzel, EG&G, Idaho V. B. Call, EG&G, Idaho Approved by: 1 a d/

J. T. Mighin~s, Chief) /) date Mat $ials and ProteMes Section, EB, DRS

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Inspection Summary: Inspection on September 9-12, 1986 (Inspection Report No. 50-271/86-17

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Areas Inspected: Special announced inspection by a regional-based inspector and two contractor personnel at the licensee's engineering office and the

, Vermont Yankee plant site. The inspection encompassed review of licensee

! responses and subsequent analysis and modifications of masonry walls in response to IE Bulletin 80-11, Masonry Wall Design. The inspection included a

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walkdown of existing walls affected by safety related equipment, a review of design analyses and a review of work packages on wall modifications.

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l Results: Two violations and one deviation were identifie B3 861023

$dO3MyCK05000271 G

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DETAILS 1.0 Persons Contacted Vermont Yankee Nuclear Power Corporation and Yankee Atomic Electric Company

• P. Donnelly, Maintenance Superintendent

• S. D. Goodwin, Mechanical Engineer

• A. M. Metell, Engineering Support Supervisor R. Martin, QA Supervisor S. Miller, Project Manager

• R. P. Oliver, Lead Mechanical Engineer W. K. Peterson, QA Supervisor R. L. Smith, Project Engineer T. Trask, Plant Mechanical Engineer

• L. Trembley, Senior Engineer Systems

• R. Warnczyk, Technical Services Superintendent

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CYGNA Energy Services P, Baughman, Consultant U.S. Nuclear Regulatory Commission

• W. J. Raymond, Senior Resident Inspector 2.0 Inspection Purpose And Scope The purpose of this inspection was to review with cognizant and responsible licensee representatives at the corporate office and the plant the completeness of the licensee responses to NRC/IE Bulletin 80-11, Masonry Wall Design. The scope of the inspection included a review of engineering design and quality assurance documentation relating to inspection, testing, analysis and modifications satisfying requirements and licensee commitments with respect to the bulletin. A walkdown inspection of the plant verified repairs and/or modifications relating to the bulleti .0 Review Criteria The latest revision of the bulletin was used to define expected actions by the utilit In addition, Temporary Instruction (TI) 2515/37 was used to further define inspection requirements. Applicable sections of the Code of Federal Regulations (10 CFR 50) were use .

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4.0 Review Of Licensee Responses The inspection team reviewed bulletin responses available from NRC files prior to the inspection. These responses included reports addressing the reevaluation methodology, acceptance criteria, wall configurations and functions, structural adequacy, proposed modification plans, and modification schedules. Table 1 lists those documents reviewed prior to the inspection. Any items of noncompliance or those requiring further discussion were noted as items to be addressed while at the corporate office or plant site. Questions relating to licensee responses were forwarded to the licensee in advance of this inspection as a preliminary agenda for discussio The inspection team reviewed additional material provided by the licensee during the inspection. This material consisted of procedures governing the recently performed walkdown of masonry walls, work instructions defined in the Yankee Atomic Electric Corporation (YAEC) Nuclear Services Division (NSD) engineering manual, work requests pertinent to masonry wall modification activities, masonry wall survey sheets resulting from the recently performed (June - August 1986) walkdowns, calculations of wall structural adequacy, work packages for wall modifications, and written procedures regarding QA/QC control. The pertinent documents described above for IEB 80-11 are listed in Tables 2 and .1 Findings:

Two violations, one deviation, and four unresolved items, resulted from the reviews described above. Further details regarding the

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findings are given belo . Control Procedure For Wall Surveys Criterion V of Appendix B to 10 CFR 50 states, in part, that

" Activities affecting quality shall be prescribed by documented instructions, procedures....." The licensee's Quality Assurance (QA) program incorporated 10 CFR 50, Appendix B, during the period of performance of the original masonry wall surveys conducted in 1980. However, contrary to the requirements stated above, the original wall surveys were not performed utilizing documented and controlled procedures to define the scope, extent of survey and to establish criteria for disposition of all masonry walls affected by the bulletin. Apparently, as a result of this omission, four walls in the turbine building that should have been included in the original bulletin coverage were missed. These walls have been recently reanalyzed as required by the bulletin and modifications are planned.

I Also, the engineering disposition of the adequacy of the masonry walls during the 1980-81 walkdowns was performed without the benefit of a procedure which provided accep-tance criteria for the walls. This lack of procedural control is a violation of 10 CFR 50, Appendix B, Criterion V (50-271/86-17-01).

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4. Control of Records Criterion XVII of Appendix B to 10 CFR 50 states is part that " Sufficient records shall be maintained to furnish evidence of activities affecting quality." Furthermore, this criterion states, " Records should be identifiable and retrievable." Contrary to this the licensee's representatives stated that complete documentation of the results of the 1980 wall survey could not be found. Thus, it was not possible to independently verify that all walls that should have been subject to bulletin action were appropriately considered in the original bulletin responses. The inability to identify and retrieve appropriate documentation is a violation of 10 CFR 50, Appendix B, Criterion XVII (50-271/86-17-02).

4. Use of Type S Mortar Action Item 3, IEB 80-11, states that " Existing test data or conservative assumptions may be used to justify the reevaluation criteria . . . .

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Contrary to this, the licensee relied solely upon mortar properties found in their construction specificatio These strength values were for type S mortar. The licensee stated that no construction records proving the use of type S mortar could be found. However, the licensee representatives stated a belief that the construction specification had been followed. No apparent additional attempts were made during the bulletin response program to verify that type S mortar was indeed used throughout the construction of all safety-related masonry walls. No documentation was provided to show evidence of the actual use of type S morta No test program was undertaken to demonstrate the strength values of the mortar used and, with the exception of one calculation, no effort was made to assume lower strength properties to demonstrate structural adequacy by reanalysis. This is a deviation from the licensee's commitment to fulfill Action Item 3 of IEB 80-11 (50-271/86-17-03).

4. Licensee Intended Actions During the inspection, the licensee stated that a plan was being developed to control future modifications to safety-related masonry walls. This procedure is intended to prevent the alteration of any masonry

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wall that could invalidate the structural analysis or, as an alternative, provide proper notification so an engineering evaluation can be completed. As part of the notification, the licensee indicated that signs will be stenciled in various locations on or adjacent to masonry walls which would alert personnel to the procedur . During the inspection, the licensee was asked what measures were being taken to assure that the physical condition (absence of cracks, boundary conditions, etc.) of the walls would be maintained. The licensee stated that periodic surveillance of the subject masonry walls would be performed to ensure that the physical conditions assumed during the recent reanalysis effort remain valid. The licensee indicated that the surveillance procedure would include accurate base-line data such as as-built drawings showing boundary conditions, existing cracks, equipment locations, etc. for each masonry wall subject to bulletin actio . As noted above, the licensee is developing a plan to control future modifications to masonry walls subject to bulletin action. The licensee stated that this plan consists of modifying pertinent sections of the YAEC NSD engineering manual to incorporate procedures which control additions to or changes in the configur-ations of the subject masonry wall .1.5. Use of Strain Criteria During the inspection it was noted that strain criteria were utilized to qualify masonry wall G-191627-2 However, the acceptance criteria submitted by the licensee and reviewed by NRC headquarters staff (NRR and their contractor, Franklin Research Center) did not include the use of strain criteria as a basis for qualifying masonry walls subject to Bulletin 80-11. The licensee should provide information demonstrating the structural adequacy of this wall based upon the working stress criteria as specified in the licensee's acceptance criteria and the NRC staff position which has been previously communicated to the licensee or submit the new analytical approach to NRR

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for review and approval. Both the licensee's criteria and the NRC staff position utilize the working stress criteria consistent with the ACI 531-79 Code; however, the NRC staff position incorporates slightly lower allowable stress increase factors for tension parallel to the bed joint and

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for shear and tension normal to the bed joint. A strain criteria appears inappropriate to qualify this wall under the bulletin requirements. The item described above is unresolved pending reanalysis of the wall using stress criteria or acquiring NRR approval of the strain criteria (50-271/86-17-04).

4. Licensee Response To Above Inspection Findings:

The licensee's representatives acknowledged the findings stated above. The licensee also reiterated the corrective actions that would be taken to prevent recurrence of the violations and agreed to provide information needed to close out the unresolved items and to follow up on his intended actions identified in paragraph 4. .0 Verification Walkdown Inspection A physical inspection of certain masonry walls subject to bulletin action was conducted by the NRC inspecto The walls included in this sample were chosen by the inspection team. The purpose of this walkdown was to ver4fy samples of inspections and/or modifications required by the bulletin. The walls shown in Table 4 were examine Findings: One unresolved item resulted from the plant walkdown. Further details regarding this item are given belo During the walkdown inspection it was noted that three unreinforced masonry walls had incurred cracks: Wall G-191149-18 was found to contain numerous mortar cracks in various location . Wall G-191627-22 was found to contain a crack at the west boundary extending the full height of the wal . Wall G-191627-20 was found to contain cracks at the corners extending the full height of the wal None of the cracks noted above appeared to be through wall cracks. A further review of the detail included in the reevaluation calculations revealed that the loads and stresses in each of these walls was sufficiently low and would be acceptable even when considering the cracks. The licensee was requested to provide the following information regarding these walls:

> A determination of the cause of these crack , ->

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.. Copies of revised record clearly noting the existence and extent of the cracking accounted for in the calculations and the resulting revised analysi This is unresolved item number (50-271/86-17-05).

6.0 Review of Licensee Administrative Controls and Quality Assurance In determining the adequacy of administrative controls in assuring quality of design engineering by YAEC, in verifying quality control of wall modifications by Vermont Yankee plant maintenance personnel and the Mercury Company, the inspector reviewed the following:

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Yankee Nuclear Services, Instruction WE-100, Engineering Design Change Request, revisions #12 and #1 VY Plant Alteration Requests Procedure Number AP.6003, revision #1 VY Plant Modifications to Resolve NRC I&E Bulletin 80-11 Concerns, Fabrication and Installation Procedure for EDCR 84-423, approved November 26, 198 Memorancum, File 3.2, Drawing Closecut of EDCR 84-423, July 18, 1986.

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Plant Operations QA Group Inspection Checklist /EOCR 84-42 ;

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The above criteria were used as references by the NRC inspector in his

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review of the following YAEC audits of engineering activities and VY 00A's approval for closeout of plant maintenance requests and EDCR 84-423 for masonry wall modification YAEC Internal Audit No. NSD-86-13, August 18-22, 1986

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YAEC Internal Audit No. 14052VP004, October 15-25, 1985

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YAEC Internal Audit No. 14028VP002, October 29 to November 2, 1984

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YAEC Internal Audit No. 14009VP001, October 19 and November 8 and 30, 1983

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YAEC Vendor Evaluation, No. 84-77-1 on July 30 and August 2,1984

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for approved Vendors List of Mercury Company

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YAEC Vendor Audit Report No. 85-33 of Mercury Company on July 18 and August 1, 1985 to verify Mercury's implementation of YAEC -

approved QA Program at the new offsite fabrication facilit The annual YAEC Internal Audits for 1983, 84 and 85, respectively,

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identify: (1) verification of the adequacy and implementation of the

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Operational project procedures for the VY project; (2) verification of compliance with the YAEC engineering manual for the Vermont Yankee project group; (3) verification of personnel compliance to and the adequacy of the QA program and implementing procedure .1 Findings 1) The YAEC Internal Audit No. NSD 86-13 performed August 18-22, 1986 is the only YAEC internal audit that explicitly refers to engineering activities associated with IEB 80-11. The inspector was informed by YAEC's QA supervisor that previous annual audits of YAEC engineering were conducted generically, i.e., not project oriented; therefore, IEB 80-11 engineering design activities relating to the original 1981 to 1984 masonry wall modifications were not identifie ) The inspector reviewed VY P00A masonry wall modification records and observed that following NRC inspection findings in I.R. number 83-22 of July 11-15 and 18-20, 1983 at the VY plant and YAEC's Framingham office, corrective actions were undertaken in 1984 to provide independent QA surveillance records of masonry wall modification work by enlarging the P0QA staff and revising plant maintenance QA procedure Based on the above reviews, it appears that the findings identified in paragraph #4 were caused by a deficiency in YAEC QA and VY plant operation's QA programs prior to 1984. Licensee responses to this report's paragraph #4 findings will be reviewed to assess accepta-bility of existing QA/QC administrative control .0 Summary i Based on the information examined during this inspection and the results

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of the field walkdowns, IEB 80-1? remains open pending licensee response,

and corrective actions.

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8.0 Definition Of Unresolved Items Unresolved items are matters about which more information is required in

, order to ascertain whether they are acceptable, violations, or deviations relative to the bulletin requirements. Unresolved items identified

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during this inspection are discussed in pr.ragraphs 4 and 5 abov .0 Exit Meeting The NRC inspector conducted an exit meeting, participated in by EG&G contract personnel, with licensee representative (denoted in paragraph 1). The NRC inspector summarized the inspection findings and the licensee acknowledged these comments. No written material, other than that described in paragraph 4, provided to licensee personnel.

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TABLE 1 - DOCUMENTATION REVIEWED PRIOR TO INSPECTION DOCUMENT DESCRIPTION WVY 80-97 7/7/80 L.H. Heider (VYNPC) - B.H. Grier (USNRC,RI)

letter transmitting 60 day response WVY 80-126 9/4/80 R.L. Smith (VYNPC) - B.H. Grier letter requesting extension to 180 day report date WVY 80-167 10/10/80 L.H. Heider - B.H. Grier letter transmitting additional information regarding IEB 80-11 activities FVY 81-37 3/4/81 L.H. Heider - B.H. Grier letter transmitting additional information regarding IEB 80-11 activities

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8/11/82 S. Pandey (Fra'nklin Research Center) - S. Bajwa (USNRC) letter transmitting interim technical

. evaluation report regarding VY responses to IEB 80-11 50-271 8/30/82 D. Vassallo (USNRC) - J. Sinclair (VYNPC)

letter transmitting a request for additional information regarding IEB 80-11 activities at VY FVY 82-113 10/21/82 J. Sinclair - D. Vassallo Jetter transmitting response to request for additional information dated 8/30/82 FVY 83-91 8/16/83 J. Sinclair - D. Vassallo letter regarding joint reinforcement in masonry walls at VY

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9/14/83 S. Pandey - M. Carrington (USNRC) letter transmitting technical evaluation report for VY

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TABLE 1 - DOCUMENTATION REVIEWED PRIOR TO INSPECTIONS (Cont'd)

DOCUMENT DESCRIPTION

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9/21/83 J. Knight (USNRC) - G. Lainas (USNRC) memo forwarding safety evaluation report for VY for review FVY 83-126 12/22/83 W. Murphy (VYNPC) - D. Vassallo letter describing schedule for reanalysis of those masonry walls originally qualified by arching action FVY 84-23 3/15/84 W. Murphy - D. Vassallo letter describing necessity for delay in completion of reanalysis program FVY 84-72 6/28/84 W. Murphy - D. Vassallo letter describing the results of the reanalysis of 10 masonry walls originally qualified by arching action

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10/25/85 R. Bosnak (USNRC) - G. Lainas internal NRC memo forwarding supplement to VY safety evaluation report incorporating reanalysis of 10 walls 50-271 11/18/85 D. Vassallo - R. Capstick (VYNPC) forwarding safety evaluation regarding IEB 80-11 activities at VY

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TABLE 2 - DOCUMENTATION REVIEWED DURING INSPECTION DOCUMENT DESCRIPTION VYP-2 YAEC procedure for the resurvey of masonry walls VYP-007 Draft YAEC procedure for routine surveillance of walls subject to IEB 80-11 action WE-100 YAEC engineering manual section covering the preparation of engineering design change requests (EDCR's)

WE-101 YAEC engineering manual section covering the preparation of plant design change requests (PDCR's)

WE-103 YAEC engineering manua'l section covering preparation of engineering calculations and analyses 86-0444 Work request for the stenciling of walls for IEB 80-11 notification A.P. 6000 YAEC procedure for the preparation, review, approval, implementation, and control of PDCR's

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Cygna Energy Services (Cygna) computer program manual for the computer code EWALL, version Cygna computer program verification report for EWALL, version EDCR 84-423 YAEC EDCR for modifications to wall G-191513-35 EDCR 81-0171 YAEC work package for the modification of walls G-191149-8,9,10 l

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TABLE 2 - DOCUMENTATION REVIEWED DURING INSPECTION (Cont'd)

DOCUMENT DESCRIPTION EDCR 81-0505 YAEC work package for the modification of walls G-191149-18 and G-191149-17 EDCR 81-1016 YAEC work package for the modification of walls G-191145-2,4

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Amplified response spectra (ARS) used in the i reevaluation of masonry block walls

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1986 masonry wall survey sheets for walls:

G-191513-35

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G-191494-5

- G-191149-17 G-191149-8 G-191149-9 G-191149-10 G-191149-11 G-191145-2 G-191145-4

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TABLE 3 - CALCULATION PACKAGES REVIEWED ,

[ CALC. N WALL ELEV. (ft) FIELD INSPECTION

VYC-65 G-191627-15 25 Yes i G-191627-16 25 Yes

G-191627-17 25 Yes i G-191627-18 25 Yes

} G-191627-19 25 Yes l G-191627-20 25 Yes

G-191513-35 22 No

. G-191494-5 25 Yes t G-191149-8 28 Yes i G-191149-9 28 Yes G-191149-10 28 Yes j G-191149-11 28 Yes G-191149-18 30 Yes i G-191650-14 31 Yes G-191149-17 30 Yes i VYC-245 G-191513-35 22 No

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G-191494-5 25 Yes i

G-191149-11 25 Yes I VYC-514 G-191627-15 25 Yes G-191627-16 25 Yes

G-191627-17 25 Yes

! .G-191627-18 25 Yes i G-191627-19 25 Yes j G-191145-8 27 No i G-191627-9 25 , Yes j G-191627-10 25 Yes

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G-191627-11 25 Yes G-191627-12 25 Yes l G-191650-13 31 Yes

{ G-191650-14 31 Yes

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TABLE 3 - CALCULATION PACKAGES REVIEWED (Cont'd)

Note: Walls included in calculation VYC-65 are original calculations resulting from the 1980 wall survey . Walls covered in calculation VYC-245 were included in the reanalysis effort of 1984 that eliminated the use of arching action as a i qualification technique.

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Walls covered in calculation VYC-514 are walls recently reanalyzed by i the use of the computer programs EWALL and SAP IV.

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TABLE 4 - MASONRY WALLS FIELD VERIFIED WALL ELEVATION (ft) LOCATION G-191511-8 23 Torus W. Wall G-191513-35 22 Torus N.E. Wall G-191627-9 25 Reactor Bld G-191627-10 25 Reactor Bld G-191627-11 25 Reactor Bld G-191627-12 25 Reactor Bld G-191494-5 25 Reactor Bld G-191149-8 28 Reactor Bld G-191149-9 28 Reactor Bld G-191149-10 28 Reactor Bld G-191149-11 28 Reactor Bld G-191149-18 30 Reactor Bld G-191650-13 31 Reactor Bld G-191650-14 31 Reactor Bld G-191149-17 30 Reactor Bld G-191145-2 27 Turbine Bld G-191145-4 27 Turbine Bld G-191627-20 25 Turbine Bld G-191630-8 26 Cable Vault G-191630-9 26 Cable Vault G-191627-22 25 Turbine Bld G-19162/-15 25 Turbine Bld G-191627-16 25 Turbine Bld G-191627-17 25 Turbine Bld G-191627-18 25 Turbine B1d G-191627-19 25 Turbine Bld G-191145-8 27 Turbine Bld G-191494-2 25 Reactor Bldg.