IR 05000277/1987016

Insp Rept 50-277/87-16 & 50-278/87-16 on 870616-19.Violation & Unresolved Item Noted.Major Areas Inspected:Review of Licensee Responses & Subsequent Analysis & Mods of Masonry Walls Re IE Bulletin 80-11

ML20236P145
Person / Time
Site:	Peach Bottom
Issue date:	07/31/1987
From:	Gregg H, Varela A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236P121	List: IR 05000277/1987016 ML20236P119 ML20236P133
References
50-277-87-16, 50-278-87-16, IEB-80-11, NUDOCS 8708120233
Download: ML20236P145 (15)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No /87-16 and 50-278/87-16 Docket No and 50-278

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License Nos. DPR-45 and DPR-65 Category C Licensee: Phila.delphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Units 2 and 3 Inspection At: Philadelphia and Delta, Pennsylvania Inspection Conducted: June 16 - 19, 1987 Inspectors: .

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Afd 7/3 o 97 A. A.\Varbia, Lead Reactor Engineer, DRS date NRC Contract Personnel:  !

M. E. Nitzel, EG&G Idaho, In '

M. J. Russell, EG&G Idaho, In <

Approved by- AA/r larold I.Trsgg, Acting Chfef eq/ 7!3//'7

/ dat'e Material and Processes Section, EB, DRS Inspection Summary: Inspection on June 16-19, 1987, (Inspection Report Nos. 50-277/87-16 and 50-278/87-16)

Areas Inspected: A special announced inspection by a regional-based inspector and two contractor personnel was conducted at the licensee's engineering office i and the Peach Bottom plant sites. The inspection encompassed review of licensee responses and subsequent analysis and modifications of masonry walls related to IE Bulletin 80-11, Masonry Wall Design. The inspection included a walkdown of existing walls affecting safety related equipment, a review of design analyses and a review of work packages on wall modification Results: One violation and one unresolved item were identifie i e708120233g{$$oh77_

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DETAILS 1.0 Persons Contact-Philadelphia Electric Company, (PECO)

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• W..M. Alden, Nuclear Support, Licensing

• M. J. Cooney, Manager, Nuclear Support

• D. W. Baldwin, Engineer, Civil-

• W. T. Baxter, Quality Assurance Engineer  ?

i' *W. Birely, Senior Engineer Licensing  !

• C. Barnand, Licensing Engineer B. Clark

• R. Hutt, Quality Assurance Division, Section Head

• J. M. Madara, Assistant Chief Mechanical Engineer ]

D. Marano, Supervising Civil Engineer j

' *D. O'Rourke, Engineer, Civil D. C. Smith, Superintendent, Operations H. W. Vollmer, Supervising Structural Engineer

• C..W. Alden, Nuclear Support, Licensing Bechtel Corporation (BC)

V. K. Aggarwal, Supervising Engineer US Nuclear Regulatory Commission Contractor, EG&G Idaho, In * E. Nitzel, Engineering Specialist

• J. Russell, Engineering Specialist

• Attendees at Exit Meeting June 19, 198 .0 Inspection-Purpose And Scope The purpose of this inspection was to review the adequacy of the licensee's responses to NRC/IE Bulletin 80-11, Masonry Wall Desig 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 bulleti The inspection plan also included plant site and corporate office reviews

. with walkdown inspections at the site to verify acceptability of repairs and/or modifications relating to the bulleti . _ - _ _ - _ _ - -

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3.0 Review Criteria The latest revision of the bulletin was used to define required 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 used to verify the licensee's adherance to regulatory requirement .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 modif-ication schedules. Table 1 lists those documents reviewed prior to the inspection. The commitments made by the licensee in these responses were reviewed against the actions required by the bulletin and the other review criteria of Section 3.0. 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's responses were forwarded to the licensee in advance of the inspection as preliminary agenda for discussion. These questions are presented in Table The inspection team reviewed additional material provided by the licensee during the inspection. This material consisted of engineering procedures used to perform field surveys of masonry walls, completed field survey sketches, reevaluation calculations assessing the structural integrity of masonry walls, design information and field work packages, Quality Control (QC) reports, and results of testing of block and mortar material samples I used in masonry wall construction. The pertinent documents reviewed

) during the inspection are listed in Tables 2 and The above information was also compared to the review criteria of Section Findings: It was determined from the review of the documentation l described above that, in general, most aspects of the work done in I response to the subject bulletins were acceptable. However, one violation was identified during the reviews described above. Further details re-garding this violation are given belo Violation:

The licensee responded to the bulletin in a letter dated July 2,198 This letter was submitted within the 60 day response time and provided a listing of masonry walls in their facility which are in proximity to or have attachments from safety-related piping or equipment such that wall failure could affect a safety-related system. However the determination of the list of safety-related walls was apparently done without any pro-I cedural control or formal documentation. The result was a listing without l any substantiating back up of how the list was generated.

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The only documentation that the licensee was able to produce during the inspection was the final list of safety-related walls included in the July 2, 1980, submittal. No documentation was available that would enable an audit to confirm that no safety-related walls had been omitted from consideration. This lack of procedural control is considered a violation of 10 CFR 50, Appendix B, Criterion V, requirements (50-277/87-16-01)

and(50-278/87-16-01).

5.0 Verification Walkdown Inspection A physical inspection of a sample of masonry walls subject to bulletin action was conducted. The walls included in this sample were chosen by the inspection team and are listed in Table Walkdown activities con-centrated on determining if the physical characteristics of the walls as observed in the plant reasonably matched those data used in the licensee's wall reevaluation calculations. Examples of those items spot checked during the walkdown include overall dimensions, bond type, number of wythes, boundary conditions, attached equipment, equipment in proximity, et Findings: One unresolved item resulted fro. the plant walkdow Further details regarding this item are given belo Unresolved Item:

It was found that several masonry walls in the Reactor Building and the Emergency Cooling Tower had what appeared to be through cracks at the

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boundary interface with reinforced concrete wall The licensee's con-struction detail drawing (620-5-246, Rev. 5) specified concrete expansion anchor bolts to provide a positive connection at this type of boundar The inspector was unable to confirm the existence of positive connections through visual observations or from the licensee's QC documentation. All of the noted crack locations were at wall boundaries where simply sup-ported boundary conditions utilizing positive connections had been assumed 3 in the reevaluation calculations. The postulated omission of the speci-fied anchor bolts coupled with an apparent through crack would invalidate the reevaluation calculations and raises questions regarding the licensee's conclusion that the walls are structurally adequat The licensee was requested to provide additional information describing their resolutions and a proposed schedule for actions. This item is unresolved pending licensee's submittal and NRC review of the additional information described above (50-277/87-16-02 and 50-278/87-16-02).

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6.0 ' Additional Inspection Details 6.1 Surveillance Plan IEB 80-11 required the inspection and reevaluation of safety related masonry walls to assure structural adequacy. In order to assure continued compliance with bulletin requirements, surveillance of physical conditions of masonry walls is necessary to assess mortar cracking in un-reinforced walls and to assure that assumed boundary conditions are maintained. During the inspection, it was determined that no plan to assure continued bulletin coinpliance was currently in existence. The licensee stated that periodic surveillance of the subject masonry walls would be performed in the future to ensure that the physical conditions assumed for the reanalyses effort remain vali The licensee also stated that a procedure for periodic sur-veillance of masonry walls was being prepare .2 Procedural Control for Additions or Changes During the inspection, the licensee was asked to describe the pro-cedure(s) used to control additions to or changes in the configu-rations of masonry walls so that continued compliance with IEB 80-11 could be maintained. The inspector determined that no such proce-dural control was in existence. The licensee stated that a procedure to provide the necessary control was being written and that interim measures in the form of a memorandum to engineering, design, con-struction, and maintenance personnel had been undertaken and would be available for subsequent NRC revie .3 Amplified Response Spectra A review of selected amplified response spectra (ARS) curves developed for the PBAPS was included as an integral part of the audit of the reevaluation calculations. The licensee provided the response spectra information during and subsequent to the inspection. The inspectors concluded that the ARS curve data were satisfactor .0 Licensee Administrative Controls And Assurance of Quality A review was made of the licensee's administrative controls and assurance of quality relating to NRC/IE Bulletin, 80-11, Masonry Wall Design. The pertinent documents reviewed are listed in Table The inspector deter-mined that the licensee had not performed a QA audit of the contractor's (Bechtel) 1980 survey of masonry walls and that more QA/QC involvement in the subject activities possibly could have prevented the situation that led to the violations stated in Appendix _ _

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8.0 Conclusion Based on the results of this inspection and pending the licensee's

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response to the violation and the unresolved item identified in this report, IEB 80-11 remains open.

l 9.0 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 during this inspection are discussed in paragraph .0 Exit Meeting An exit meeting was conducted on June 19, 1987, by the NRC inspecto Attendees at the meeting are listed in paragraph The NRC inspector summarized the inspection findings and the licensee acknowledged these l findings. No written material, other than that described in paragraph 4 l (prelimir.ary agenda for discussion) was furnished to licensee personnel.

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TABLE 1 - DOCUMENTATION REVIEWED PRIOR TO INSPECTION

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S. L. Daltroff (Philadelphia Electric Col, PECO) letter to H. Grier (NRC) dated 7/2/80 transmitting responses to Action Items 1, 2a, and 3 of IEB 80-11.

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S. L. Daltroff letter to B. H. Grier dated 11/3/80 trans-l mitting responses to Action Item 2b of IEB 80-1 S. L. Daltroff letter to B. H. Grier dated 5/4/81 trans-mitting Licensee Event Report LER-2-81-32/IT- M. J. Cooney (PEC-0) letter to B. H. Grier dated 6/4/81 transmitting Licensee Event Report LER-2-81-32/IT- Franklin Research Center (FRC) interim Technical Evaluation 50-278 Report (TER), dated 2/26/82, regarding reevaluation methods for masonry walls at Peach Bottom Units 2 & J. F. Stolz (NRC) letter to E. G. Bauer (PECO) dated 3/10/82 transmitting requests for additional information regarding IEB l

80-11 activities at Peach Bottom Atomic Power Station (PBAPS)

Units 2 & J. W. Gallagher (DECO) letter to J. F. Stolz dated 4/29/82 providing information regarding the schedule for providing additional information requested in the 3/10/82 NRC lette J. W. Gallagher letter to J. F, Stolz dated 5/26/82 trans- 1 mitting additional information in response to the requests l made by the NRC in their 3/10/82 lette l 50-277/83-26 NRC Region I inspection report of bulletin response  !

activities at PBAPS. Report dated 10/14/8 J. F. Stolz letter to E. G. Bauer dated 2/7/84 requesting additional information and clarification regarding l information contained in the PECO submittal dated 5/26/8 i

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S. L. Daltroff letter to J. F. Stolz dated 3/21/84 providing response to the 2/7/84 NRC request for additional  ;

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D. G. Eisenhut (NRC) letter to E. G. Bauer dated 10/30/84 transmitting Safety Evaluation Report (SER) regarding IEB 80-11 activities at P8AP I l

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S. L. Daltroff letter to D. G. Eisenhut dated 1/9/85 transmitting information regarding followup activities by PECO required by the NRC SER transmitted in the NRC's 10/30/84 lette J. F. Stolz letter to E. G. Bauer dated 6/20/85 transmitting a Supplemental Safety Evaluation Report (SSER) regarding IEB 80-11 activities at PBAPS.

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FRC TER regarding masonry wall reevaluation methods used at the PBAPS. Report dated 9/12/84.

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TABLE 2 - DOCUMENTATION REVIEWED DURING INSPECTION

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Document Description 11187 Bechtel Power Corporation (Bechtel) field survey procedure for concrete masonry walls dated 6/3/8 Philadelphia Electric Company (PECO) procedure, dated 9/5/80 for the verification survey of non-safety related masonry wall QC-101 PECO receipt inspection QC form indicating shipment of concrete block, cement, etc. received on 4/14/71 was in conformance with specification 6280-A- Test report from Ambrick Testing & Engineering regarding test results for three specimens of concrete bloc Test results for mortar cement provided by MEDUSA Portland Cement Compan QC-5C Bechtel field inspection report for job 628 A-1 Revision 1 to Bechtel specification for furnishing, delivery, and erection of masonry at PBAP Masonry wall field survey sketches for walls 40.2, 32.4, 76.6, 32.3, 532.1, 418.10, and 3 PECG internal memorandum from A. Diederich to J. Gotzis dated 3/23/81 regarding the engineering work letter for modification 621, Revision PECO internal memorandum from A. Diederich to J. Gotzis dated 3/26/81 regarding the engineering work letter for modification 621, Revision Revision 5 of masonry wall construction detail drawin _ _ _ - _ _ - _

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TABLE 3 - CALCULATION PACKAGES REVIEWED

CALC. N WALL FIELD INSPECTION IE8011-ACI-53 .1 Yes IE8011-ACI-3 .3 No IE8011-ACI-4 .2 Yes IE8011-ACI-3 .4 No IE8011-ACI-7 .6 Yes IE8011-ACI-418.10 418.10 Yes IE8011-ACI-3 .1 No l

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TA8LE 4 - MASONRY WALLS FIELD VERIFIED WALL ELEVATION (ft) LOCATION 418.10 234'-0" Reactor Bld .11 234'-0" Reactor Bld .9 234'-0" Em. C19 . Tower t

l 53 '-0" Em. Cig. Tower 53 '-0" Em. C19 . Tower 53 '-0" Em C19 . Tower 76.10 165'-0" Reactor Bld .6 165'-0" Reactor Bld .6 165'-0" Reactor Bld .2 135'-0" Turbine Bld .9 135"-0" Turbine Bld .15 135'-0" Turbine Bld .23 135'-0" Turbine Bld .1 150'-0" Turbine Bld .4 150'-0" Turbine Bld .2 150'-0" Turbine Bld c.. _ _ _ _ _ _ _ . . _ - _ _ - _ _ _ _ - _ _ - - _ _ - - _ _ _

l TABLE 5 - REQUEST FOR INFORMATION

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The following is_ a list. of preliminary requests for information pertinent to-

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- actions - taken in response to the subject bulleti It is planned that the responses to these reque'sts will -be reviewed and discussed during the

_ inspectio . How was the overall engineering effort for response -to bulletin require-ments organized, coordinated, and directed? How 'was QA/QC involved in the overall effort to satisfy bulletin -require-l, ments? What AE/ consultant firms (if any) were used to develop bulletin responses?

l What was:the extent of their involvement (scope of work)?  !

! What personnel qualifications and/or special trainir g was provided (or  !

required) for licensee and/or consultant personnel involved in bulletin ~

i response work? What procedure was used to identify masonry walls subject to bulletin action? . Provide a copy for revie . The 7/2/80- submittal states that field surveys were use Provide the procedure used and marked up drawings or other first generation field C umentation showing results obtained for each safety-related wal . Were significant differences between the construction drawing and the wall survey results found? If so, indicate which walls and describe the discrepancie ' Do any safety related piping systems have supports attached to the subject walls? If so,. indicate: The identification of the individual piping system The pipe size of each syste The identification of the piping supports on each system that are attached to masonry wall .The identification of the individual masonry walls to which the piping supports are attache ; The piping support loads (all load cases) which are applied to the masonry wall . Provide documentation of QA over:-ight/ audits of all contract organizations involved in bulletin action __________ _ _-__ _ ______ -_ _ _ -

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2 Table 5 10. Clarify the meaning of tiie notation -D0- in Appendices A and B of the ;

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7/2/80 submitta !

1 From 11/3/80 submittal it is understood that a grouping technique was used to reduce. the scope of the reevaluation effor For the purposes of l auditing the " grouping" effort and results, please provide a table showing j the following information for each safety-related masonry wall: l Wall identification or desigr,ation Location Elevation Wall dimension (length, height, thickness)

Number of wythes Boundary conditions Reinforced or unreinforced Bond type (stacked or running)

i 12. Provide a table summari:.iag the structural analysis results for each wall group. As a minimum, th s table should contain:

Group representative wall identification Calculated frequency.

l Maximum calculated stresses Allowable values Analysis technique (beam strip, plate, FEM, etc.)

1 Provide the calculation packages used as a basis for the qualification of all masonry wall groups included ir the reevaluation effor . The complete modification packages for the four walls modified should be available for review during the inspection. Modification packages should include all stress calculations, design / construction drawings, QC documentation and any other pertinent information such as nonconformance reports (NRC's) and their dispositions that may exis . Provide the surveillance plan for routine inspection to assure the continued validity of assumed boundary conditions, physical condition (sucn as absence of cracks) and continued structural adequac . Describe the procedure (s) used to control additions to or changes in the configurations of the masonry walls subject to bulletin actio Provide copies for revie . Have any recent resurveys been undertaken to ascertain that plant modifications or regulatory requirements made in the intervening time since 1980 have not changed the status or classification of any masonry walls?

1 List all computer codes used in the wall reevaluations? Also, identify which groups or organizations used the . .Were all computer codes used " benchmarked?" If so, provide documentatio . What procedure (s) were used to assure that computer codes were used properly to obtain accurate results? Provide copies for review.

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2 The 11/3/80 submittal did not satisfy the 180 day reporting requirement in that the reevaluation effort was not complete. Did the NRC agree to a schedule extension? If so, provide documentation.

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2 Provide a legible copy of the cover letter to the 5/4/81 submittal.

l l 2 Section 2.3 of the 5/4/81 submittal includes test results for masonry l wall material Provide: The testing procedures use Describe what QA/QC oversight was applied to these test Provide samples of the QA/QC documentation of these test . Provide samples of the construction QC documentation for the safety-related masonry wall . In Section 2.0 of the 1/9/85 submittal it is stated that the three walls represented by wall number 532.1 are " fire resistant bearing walls."

Previous submittals (e.g. 5/26/82) state that "all Category I masonry walls at Peach Bottom are non-bearing...." Clarify the function and loading conditions for these three wall . Provide a more detailed comparison of the analysis techniques used and stress results obtained for the " original" elastic reevaluation calcula-tions (prior to use of energy balance for qualification) and the " current"

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results reported for the five walls addressed in the 1/9/85 submittal .

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TABLE 6 - DOCUMENTATION OF LICENSEE ADMINISTRATIVE CONTROLS

Document Description PECO Audit #0P-84 Bechtel, San Francisco, December 1979, to evaluate implementation and effectiveness of Bechtel 'each Bottom Project QA program as applied to mod 4 fication activities of containment suppression chambt .

PECO Audit #0P-127 Bechtel, San Francisco, February 1981, to verify compliance with BC Nuclear QA Manual for Peach Bottom and implementing procedures related to PEC0 requests for engineering services under PEC0/Bechtel General Services Agreement, dated April 24, 197 PECO Finding Report Corrective actions taken to resolve findings and

1. 0P-127-03 and 04 acceptably close out the audit findings related to IEB-80-1 PECO Audit #0P-1.50 BC, San Francisco, July 1981, to verify compliance (as identified in OP-127).

BC Audit #PA-68/3.2.5 BC Project Engineer, San Francisco, June 1982, and 1983 to evaluate BC compliance with the requirements for preparation, review, approval and control of design calculations for their consistency with design criterta ,

relative to Peach Bottom projec l l

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