IR 05000293/1986031

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Insp Rept 50-293/86-31 on 860908-12.No Noncompliance Noted. Major Areas Inspected:Ie Bulletins 79-07 Re Seismic Stress Analysis of safety-related Piping & 80-11 Re Masonry Wall Design.Unresolved Item Re Mod of Fuel pool-HX Remains Open
ML20211D905
Person / Time
Site: Pilgrim
Issue date: 10/09/1986
From: Kamal Manoly, Wiggins J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20211D895 List:
References
50-293-86-31, IEB-79-07, IEB-79-7, IEB-80-11, NUDOCS 8610220300
Download: ML20211D905 (17)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

. Report N /86-31 j Docket N License No. DPR-35 Priority --

Category C Licensee: Boston Edison Company 800 Boylston Street

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Boston, Massachusetts 02199

! Facility Name: Pilgrim Nuclear Generating Station

! Inspection At: Braintree and Plymouth, Massachusetts

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Inspection Conducted: September 8-12, 1986

Inspectors: b K. A. Manoly, Lead f(acto Engineer, date M&PS, EB R j i'

Approved by:

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J.. T. Wigf ns, Ch1%Y Materials and date Process Section, EB, DRS l Inspection Summary: Inspection on September 8-12, 1986 (Report No. 50-293/86-31)

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i t Areas Inspected: Special, announced inspection by a region-based inspector at

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BEC0's Nuclear Engineering Office in Braintree and at the Pilgrim Station in Plymouth. The inspection covered the following areas:

IE Bulletin 79-07: Seismic Stress Analysis of Safety Related Pipin *

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IE Bulletin 80-11: Masonry Wall Desig *

! Unresolved Item 50-293/83-26-02: Modification of fuel pool heat

exchanger (Hx) E-206-A support structur i i Results
No items of non-compliance were identified and one unresolved item was noted. Unresolved item 50-293/83-26-02 remains open.

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I i 8610220300 861014 PDR

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0 ADOCK 05000293 PDR

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, Details Persons Contacted

Boston Edison Company

] *T. Tracy, Acting Deputy Manager, Civil / Structural

  • T. Ferris, Licensing Engineer

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  • J. Jerg, Senior Engineer, Civil / Structural
  • S. Chugh, Senior Engineer, Civil / Structural

)l *J. Roberts, Principal Mechanical Engineer

  • S. Bibo, Audit Group Leader, QA Department i E. Hunter, Senior QA Engineer .

J. Sutton, Senior Construction Engineer, Construction Management Group Impe11 Coporation l

f-i *J. McWilliam, Structural Section Manager a

i U.S. Nuclear Regulatory Commission i

  • McBride, Senior Resident Inspector
  • Denotes personnel present at the exit meeting.

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2. Licensee Action On Outstanding Open Items

(0 pen) Unresolved Item (50-293/83-26-02)

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This item is related to concerns identified in the design and modification

of the fuel pool heat exchanger (Hx) E206-A support structure. The item I was open pending licensee' response to several questions identified during the review of the design calculation for the existing support and the modification (Calculation No. 114-C2 and 114-C3). The questions addressed

, the following concerns:

The basis for using 500 lbs. to account for the contribution of loads from four (4) pipe nozzles in the design of the HX support in place of actual piping load I i

The calculation of slenderness ratio for the Hx support cross brac-

{ ing angle (member #4) did not consider the minimum radius of gyra-

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a The calculation of allowable bending stress for an angle shape (mem-i ber #1) utilized a maximum allowable equal to (0.6 Fy) without veri-

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fication of the length to flange width and flange width to thickness 4 ratios as specified in the AISC manual of steel construction.

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The allowable tension capacity of Cinch anchors connecting the sup-port frame to the wall were increased by a factor of 1.5 without justificatio Discussion of the above issues with the licensee resulted in the resolu-tion of the last three concerns based on lower design stresses and loads versus allowable values. However, the basis provided for using 500 lb as a bounding value for piping nozzle loads was not justified since the actual loads for the RBCCW inlet and outlet piping were already available from piping analyses and the nozzle loads for the fuel pool cooling piping could have been conservatively estimated from piping geometr The licensee acknowledged the inspector's concern and agreed to a more accurate determination of piping nozzle loads based on available dat This unresolved item will therefore remain open pending licensee evalua-tion and NRC revie . Masonry Wall Design (IE Bulletin 80-11)

3.1 Inspection Purpose and Scope The purpose of this inspection was to review with cognizant and res-ponsible licensea representatives the completeness of their responses to NRC/IE Bulletin 80-11, Masonry W311 Desig The scope of the inspection included a review of engineering design and quality assur-ance 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 .2 Review Criteria l The criteria used for the evaluation of licensee actions associated with the Bulletin were:

l Code of Federal Regulations 10 CFR 50 i

IE Bulletin No. 80-11

Temporary Instructions (TI) 2515/37 Final Safety Analysis Report (FSAR)

Building Code Requirements for Concrete Masonry Structures (ACI 531/79)

3.3 Documents Reviewed Revicw of documents related to licensee activities in response to the Bulletin was conducted prior to and during the inspection. A trans-mittal was forwarded to the licensee, one week prior to the inspec-tion, containing general questions and a request for making available documents and personnel. The transmittal is included as Attachment 1 l to this report.

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Documents reviewed included applicable administrative, engineering and licensing procedures which established the requirements for carrying out the Bulletin activities. Selected evaluation and modification packages were also examined to verify their conformance to established procedures and criteri The documents reviewed in this inspection covered the following activities:

Procedures and work instructions for the walkdown survey of block walls, attachments and equipment in proximity of these walls

Procedures for block wall failure effect evaluation Design criteria specification for the civil and structural disciplines

Generic criteria for concrete masonry wall evaluation Generic calculations for determination of wall properties and allowable moments Design criteria for re-evaluation of masonry walls Design calculations for re-evaluation and modification of block walls Testing program and results Statistical analysis of boundary strengths for masonry walls j from field test data

Procedure for preparation, review verification, approval and revision of design documents for plant design changes.

i Safety evaluations for changes and modifications Plant Design Change Requests (PDCR) for masonry wall modifica-tions

Project quality plan for masonry wall re-evaluation l

Records related to the above documents are included in Attachment 2 to this report No items of non-compliance were identified l 3.4 Overview of Block Wall Related Activities at Pilgrim Station l After IE Bulletin 80-11 was issued, the licensee's initial walkdown i identified over 400 masonry block walls at the Pilgrim Statio Approximately 220 walls were classified as safety related in the l

initial phase ~of the projec In general these walls function as

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shielding barriers, pressure containments, enclosures, and supports for small amounts of piping, cable tray, conduct, instrumentation and control panel Detailed analysis criteria were developed by EES (later. named as Cygna Energy Services). The original analysis was based on wall properties determined from the original construction drawings. The validity of these drawings became questionable to the licensee, however, upon identification of discrepancies during implementation of wall modification. In-situ testing of wall material and anchorage was instituted on a sampling basis. The testing program (phase I)

identified: 1) significant deviations in boundary anchorage between walls and the building structure, 2) reduction in horizontal rein-forcing in single-wythe walls; and 3) reduction or lack of in plane shear reinforcing ip multi-wythe wall Reanalysis of walls was redone based on actual test results. Since the analysis approach was based on considering full anchorage or reinforcing where it coulo be established, many of the walls could no longer be qualified without the need for extensive modifications. Some walls were modified during Refueling Outage'(RFO)-5 and some were downgraded to "non-safety related" based on system reviews, and the remaining walls were desig-nated as requiring further- evaluation. Wall modifications during the RFO-5 were performed by three contractors: Crouse Group, Mercury Corporation and Reactor Controls Incorporated (RCI).

The licensee instituted a second series of in-situ tests (phase II)

during RFO-5 which included verification of boundary anchorage on walls which were inaccessible during operation. A statistical analysis was performed to account for the probabilistic presence of partial anchorage based on the enlarged sample of walls and the length of boundaries which were testec. The testing involved the top boundary which included metal Q-decking, structural steel W-shapes and reinforced concrete in addition to the side boundary which encompassed structural steel columns, concrete walls and intersecting masonry in L and T configurations. The total number of walls tested from those identified as safety related was 50. These walls were selected from the Auxiliary, Diesel Generator, Intake, Radwaste, Reactor and Turbine building The statistical analysis which provided the basis for developing modified allowable boundary shear loads was performed by Bechtel/

Computec and approved by the NRC Office of NRR in the Safety Evaluation Report of May 29, 1986. The remaining walls were reeval-uated by Bechtel/Computec using the original criteria (by Cygna) and supplemented by the boundary shear criteria. This final reevaluation resulted in additional wall qualification by analysis with the

, remainder requiring modifications. The conceptual design of these modifications was done by Bechtel/Computec and the detailed design was performed by BEC0's engineering staff. Bechtel's craft performed wall modifications after the RF05 outage. The modifications included two general categories: Structural and Boundar _ __

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Some of the structural modifications involved the addition or streng-thening of members along the wall faces or the addition of vent open-ings to reduce environmental pressure loads.' The majority of modifica-tions, however, involved the addition of boundary supports. The total number of walls modified in both phases was 88. The activity was implemented under a parent Plant Design Change package PDC 81-53 and associated sub package It is worth noting that the licensee had conducted another walkdown in 1984 to determine if any significant loadings had been added to already identified walls and to access the safety related status of the walls. This walkdown was initiated upon the. identification of other safety related walls and blockouts which were not addressed in the initial walkdow The licensee indicated that the total number of block walls at the Pilgrim Station is 466 walls with 242 classified as safety relate The design criteria specification (Master Document No. 848) provided an administrative control for masonry wall interfaces such that new class I components (e.g. conduits, junction boxes, piping, equipment supports, etc.) could not be attached to or located within the wall height envelope without prior approval from the Civil / Structural group leade At the time of the inspection all physical modifications were com-plete. However, only 63% of all PDC packages were closed. Remaining Bulletin related activities include: 1) closeout of remaining open maintenance requests; 2) incorporation of field revision notices (FRN's) and NCR's into draw.ngs; 3) incorporation of all drawings, correspondence and calculations into BEC0's system; 4) updating the data base; and 5) preparation of work instructions for future work involving blockwall The licensee reiterated its long term commitment to the NRC of com-pleting all Bulletin related analyses, modifications and closeout of all PDC packages by end of the current outage (RF07).

3.5 Evaluation Methodology The working stress design method was used for the evaluation of masonry wall The determination of internal forces and moments was based on an orthotopic plate analysis. The evaluation of walls for seismic loads was performed at two levels. The results of the analysis from the first level were compared to the acceptance criteria before proceeding to the second level:

Level 1: The natural frequency of the masonry wall was determined assuming fully cracked section properties through-out the transformed section and using a lower

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bound value of Modules of Elasticity of masonry (Ec)

= 600 f Equipment static analysis was performed using building accelerations from corresponding response spectra curves at 2% and 5% of critical damping for design and maximum earthquakes respectivel The spectral acceleration values were increased by a factor of 1.3 to account for the effect of multi-mode Level 2 If the level 1 analysis failed to meet the acceptance criteria, a level 2 analysis was performed. The analysis approach utilized the finite element method in an ite-rative procedure in which walls were initially assumed uncracked: Wall properties were based on a Modules of Elasticity of Masonry (Ec) = 1000 fm. Response spec-trum modal analyses were performed for the first twelve (12) modes and using curves for 4% and 7% of critical damping for design and maximum earthquakes respectively. Where the resultant moments exceeded the uncracked moment capacity, the cracks were monitor-ed as they propagated in the finite element model and the cracked moments in each element were used to cal-culate the affective moment of inertia in each ele-ment. The walls were then reanalyzed using the effec-tive moments of inertia. The solution was considered to have converged when the maximum moments from two successive iterations were within 10%.

Evaluation of boundary anchorage (shear capacity) to the building structure was considered based on results of the statistical analysis described in Section of this repor No items of non-compliance were identifie .6 Walkdown Verification of Masonry Walls and Modifications A physical inspection of certain masonry walls subject to the Bulle-tin action was conducted by the inspector. The inspection included visual examination and independent verification of selected wall modifications and component attachment The purpose of the inspector's walkdown was two fol The first was to verify the level of detail in the licensee's walkdown inspections in 1980 and 1984 with regard to depicting the type and 1ccation of wall attachments. The second was to examine the conformance of wall modifications to the design drawing requirements. The walkdown included walls in the Reactor, Radwaste and Turbine Buildings. The sample included walls modified during and post RF0 . .- - - -

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Attachment No. 3 provided a listing of walls verifie'd during the walkdown inspectio No items of non-compliance were identifie .7 Review of Licensee Administrative Controls (QA/QC inerface)

A review of the interface of various Quality Assurance (QA) and Qua-l lity Control (QC) organizations in the various activities associated with the Bulletin was conducted during this inspection. Identifica-tion of these organizations and their specific involvement was summarized by the licensee as follows:

BECO - QA Walkdown of accessible and inaccessible walls Assembly of PDC packages for issue to field i Design of boundary modifications Re-walkdown of masonry walls

Audit of contractors (EES, Cygna, RCI and Bechtel)

Audit of BECO's QC organization BECO - QC Wall modifications performed by Crouse Group (During RF0 5)

Wall modifications performed by Mercury Corp. (During RF0 5)~

In-situ testing of masonry walls (phase I and II)

Reactor Controls Inc. (RCI)-QC

Modifications during RF0 5 Cygna - QA Development of re-evaluation criteria and finite element

analyses.

I Modification design Bechtel - QA

Development of supplemental boundary criteria Bechtel -~QC Wall modifications post RF0 5 The inspector examined the licensee's project quality plan for masonry wall re-evaluation in addition to reports by BECO's QA of audits of contractors. The inspector also examined QC inspection l

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records of wall modifications verified during his walkdown inspectio A listing of the records examined is provided in Attachment 4 to this repor <

No items of non-compliance were identifie .8 Findings and Conclusion Based on the review and observation of activities associated with IE Bulletin 80-11, at Pilgrim Station, it was concluded that these activities were performed substantially in conformance with Bulletin requirements and licensing commitments. However, based on the status of activities and work remaining (Section 3.4), the Bulletin will remain open pending completion of these activitie In conjunction with the discrepancies identified between block wall installations and original construction drawings which led to both phases of in-situ testing (Section 3.4), a concern arose regarding the potential for similar discrepancies in rebar reinforcing for safety related concrete wall The licensee was requested to evaluate this concern, during the current outage, due to its impact on the capacity of safety related concrete walls in resisting design basis accident loads. The licensee acknowledged the concern and indicated that an action will be undertaken for its resolution. This item is therefore unresolved pending licensee's action and NRC review (50-293/86-31-01). Seismic Stress Analysis of Safety Related Piping (IE Bulletin 79-07)

An evaluation of the licensee's action in response to IE Bulletin 79-07 was conducted by reviewing the NRC and licensee correspondence, NRC documented evaluations and other Bulletin related records. BEC0's letters No. 79-78,79-100 and 79-103 documented the response to the Bulletin actity item The UAFS computer program, used by General Electric for the seismic analysis of Main Steam and Recirculation piping inside the containment, was identified to have utilized the algebraic summation in the combination of directional seismic responses. Other piping connected to the above systems included the High Pressure Core Spray, Reactor Core Isolation Cooling, Reactor Water Cleanup and Residual Heat Removal System It was also identified that the seismic analysis of piping systems outside the containment was performed using the STARDYNE computer code which utilized summation techniques consistent with Regulatory Guide 1.92 in the combination of spatial components and intermodel response ,

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The NRC's Safety Evaluation Report of May 25, 1979 indicated the require-ments set.forth in IE Bulletin 79-07 were adequately satisfied at the Pilgrim Station upon completion of modifications identified in Attach-ment B of the licensee's letter # 79-100 (May 23, 1979) and as-built verification on the Recirculation system and Main Steam Line (D) (SRV dis-charge). The NRC staff's acceptance of the licensee's action was based on results of reanalyzes of the Recirculation system and attached lines by GE using the PISYS computer code, and of the Main Steam lines by Teledyne, Eng. Services (TES) using the STARDYNE computer cod In conjunction with the NRC's safety evaluation identified above the inspector verified the following licensee activities in response to the Bulletin:

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Reanalysis of the Recirculation and attached piping (RHR, RWCU and Core Spray) inside the Drywell by GE in connection with the Recircu-lation piping replacement during the 1983 refueling outage (RF0 #6).

The analysis was documented in Calculation No. 23A4096, Rev. 1 (Loop A) and Calculation No. 23A4097, Rev.1 (Loop B) and utilized GE's as built piping walkdown dat Reanalysis of the Main Steam which was based on as-built walkdowns conducted in conjunction with IE Bulletin 79-14. The Main Steam Line (D) was further verif.ied during the Pilgrim Mark I modificatio The SRV discharge lines B&C and the steam supply to the HPCI turbine are connected to the Main Steam line (D) identified in the NRC's Safety Evaluation. As-built drawings of Main Steam Piping were generated by Bechtel (Dwgs. No. 6498-602, 6498-603 and 6498-700-4).

TES had bench-marked and verified the STARDYNE computer code by comparison with the ADLEPIPE code. An audit of TES and the proce-dures used for the stress analysis of the Pilgrim Main Steam Piping was performed by BECO's QA (letter #QPI-856 on May 24, 1979).

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Records of modifications, on the Recirculation and Main Steam Piping, identified in the NRC's Safety Evaluation and Attachment B of BECO's letter No.79-100 that were documented in PDCR Nos.79-07A, 79-078 and 79-07 Based on review of the documents identified above, the inspector concluded that the licensee had met the requirements set forth in IE Bulletin 79-0 The Bulletin is therefore closed at the Pilgrim Statio . 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. An unresolved item identified d

during this inspection is discussed in paragraph 3.8.

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6. Exit Meeting The NRC inspector conducted an exit meeting with licensee representa-tives (denoted in paragraph 1). .The NRC inspector summarized the inspec-tion findings and the licensee acknowledged his comments. At no time during the inspection was written material, other than that described in

< paragraph 3.3, provided to licensee personne i

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'I i Attachment 1 I&E USNRC REGION I BULLETIN AUDITS GUIDANCE FOR LICENSEES REF. IEB 80-11 All aspects of work related to the audited bulletins will be subject to review at the discretion of the .spection team. Therefore, the licensee should have the following infor.mation readily available: Engineering procedures and instructions governing organization and direction of engineering efforts. This includes design control,

verification and all QA aspect QA procedures for design and modification control plus any special i QA procedures specific to the subject bulletin Specific engineering or test procedures relating to the subject

~ bulletin Complete documentation covering all bulletin wor Examples are:

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Walkdown inspection data sheets or marked up drawings Any generic or topical reports used as a basis for response

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Descriptions of the loads and load combinations l

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Maintenance orders or design change packages for modifications

] required by bulletins (systems selected by inspection team)

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Sample calculations and/or computer analyses used for modification design . Cognizant management, engineering and QA personnel should be available as

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! documentation being reviewed.

I i Responsible engineering and/or maintenance personnel should be available j as requested by the inspection team or required by plant procedures to l act as escorts during walkdown verification.

l Additional information pertinent to the reviews may be requested by the

inspection team.

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GENERAL QUESTIONS APPLICABLE TO

IE BULLETIN RESPONSE WORK BY LICENSEES l How was QA/QC involved in overall effort to satisfy bulletin requirements.

[ How was overall engineering effort organized, coordinated and directed.

What AE/ consultant firms (if any) were used to develop bulletin i responses. What was the extent of their involvement (scope of work).

4 What personnel qualifications and/or special training was provided (or i required) for personnel involved in bulletin work I Licensee

{ AE/ Consultants.

l Describe overall design control & QA procedures (i.e., how does QA interact with engineering). Describe overall plant modification procedures.

! Maintenance Work j Design Changes

! Major Modifications.

j Describe procedure followed to incor'porate new loads or other design

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changes in AE/ consultant work in progress or completed (design cont ol related to questions 3 and 5 above).

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1 of 2 DOCUMENTS EXAMINED Attachment 2 ITEM TYPE OF N DOCUMENT DOCUMENT N REV. DATE DOCUMENT TITLE / SUBJECT 1 LTR 80-146 -

7/14/80 Response to IEB 80-11 2 PROC 13984.44-1 1 10/30/81 Procedure for Block Wall Fa i lure effect eva luat ion, BECO - Pilgrim Station 3 CRT BM-0105 1 3/3/81 Generic Criteria for Concrete Masonry Wall Evaluation 4 RPRT 1742 0 10/19/84 50.59 Safety Eva luation: Technical Basis for Full Powe r Ope ra t i on During Completion of Masonry Wall Modification 5 PROC 075-1 0 4/3/80 Procedure for Masonry Wa l l Survey for Unit #1, Pilgrim Station l 6 INST - -

5/18/84 Work Instruction for Deta iled Wa lkdown of Additiona l Masonry Walls 7 INST Wi-6 3 1/14/82 Work Instruction for Testing of Masonry Walls 8 RPRT 560-02 1 9/83 Statistical Ana l ys i s of Bounda ry St reng ths fo r Ma son ry Wa l l s F rom Field Data 9 PROC J.02 15 6/6/86 Prepa ra t ion, Review Verification, Approval and Revision of Design Documents for Plant Design Changes 10 INST 4/18/84 Work Instruction for 1984 Wa lkdown for Update of 1980 Wa lkdown Data Base 11 CRT DC-1 0 9/4/81 Design Criteria for Re-evaluation of Masonry Walls (By EES)

12 CRT BM-0105 1 3/2/81 Generic Criteria for Concreto Masonry Wall Evaluation (By ESS)

13 PKG PDCR 81-53R Plant Design Change Package for Wa ll No. 6 PKG PDCR 81-53R Plant Design Change Package for Wall No. 6 PKG PDCR 81-53AD.1 & A Plant Design Change Package for Wall No. 18 PAC PDCR 81-53R Plant Design Change Package for Wall No. 6 CALC .C2200 Ceneric Calculation - STD. Set on Data for Level il Analysis Based on Ec=1000 rm

  • TYPE OF DOCUMENT DWG - DRAWING INM - INTERNAL MEMO PKG - PACKAGE SrEC - SPECIFICATION LTR - LETTER CALC - CALCULATION faOC - PROCEDURE RPRT - REPORT QAM - QA MANUAL CRT - CRITERIA P. O. - PURCHASE ORDER INST - INSTRUCTION

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2 Of 2 DOCUMENTS EXAMINED Attachment 2 ITEM * TYPE OF N DOCUMENT DOCUMENT N REV. DATE DOCUMENT TITLE / SUBJECT 18 CALC C2100 Generic Ca lcula tion,- STD. Set of Data For Level I Analysis Based on Ec=600 fm I

19 CALC 1244 & 2244 EES Calculations for Wall No. 183.3/18 CALC T2-14 CYCNA Calculations for Wall No. 184.3

21 CALC 10394-116-C12 BECHTEL Calculations for Wall No. 183.3/18 CALC 1104, 2104, ESS Calculations For Wa ll No. 6 & 5104 j 23 CALC 1070 & 2070 ESS Calculations for Wall No. 6 CALC 10394-116-C2 Bechtel Calculations for Wall No. 6 CALC C15.0.1417 BECO Ca l cu l a t ions fo r Wa l l No. 66.2
26 CALC 1006 & 5006 ESS Ca lculations for Wa ll No. 6 CALC 1295 & 2295 ESS Calculations for Wall No. 20 * TYPE OF DOCUMENT DWC - DRAWING INM - INTERNAL MEMO PKG - PACKAGE SPEC - SPECIFICATION LTR - LETTER CALC - CALCULATION PROL - PROCEDURE RPRT - REPORT QAM - QA MANUAL CRT - CRITERIA P.O. - PURCHASE ORDER INST - INSTRUCTION

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Attachment 3 Walkdown Verification of Masonry Wall Wall N Building Elevation Modification 20 Turbine 23'-0" RF0 5 195.8 E Radwaste 37'-0" RF0 5 195.9 S Radwaste 37'-0" RF0 5 67.1 N&S Reactor 91'-3" RF0 5 64.12 Reactor 51'-0" Post RF0 5 66.9 N Reactor 74'-3" Post RF0 5 66.2 N&S Reactor 74'-3" Post RF0 5 6 Reactor 51'-0" Post RF0 5

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Attachment 4 Review of QA and QC Recoras

BEC0's audit report No. 83-33 of Bechtel (San Francisco)

BECO's audit report No. 81-21 of BECO's QC organization

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BEC0's audit report No. 81-17 of Earthquake Engineering Systems, Inc. (EES)

BEC0's audit report No. 82-3 of BEC0's Nuclear Organization, Cygna Energy Services and Reactor Controls Incorporate *

Inspection report No. 85.56.160 of Block Wall Modification No. 64.12

Inspection report No. 85.56.158B of Block Wall Modification No. 6 Inspection report No. 86.56.21 of Block Wall Modification No. 6 *

Inspection report No. 85.56.133 of Block Wall Modification No. 6 *

Inspection report No. 85.56.145 of Block Wall Modification No. 6 *

Inspection report No. 82.56-30 of Block Wall Modification No. 20 *

Inspection report No. 82.56-26 of Block Wall Modification No. 6 *

Inspection report No. 81.56.289 of Block Wall Modification No. 19 *

Inspection report No. 81.56.304 of Block Wall Modification No.19 .