ML20154P467
| ML20154P467 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/27/1988 |
| From: | Fogarty E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8810030072 | |
| Download: ML20154P467 (6) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699
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PHILADELPHI A, PA 19101 (at s) sa t. sono September 27, 1988 i
.. $......" i.""' M..,. m, ' *"
Docket Nos. 50-277 50-278 L
Hr. Jacque P. Durr, Chief l
Engineering Branch Division of Reactor Safety U.S. Nuclear Regulatory Commission j
l ATTN: Document Control Desk Washington. 0.C.
20555
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SUBJECT:
Peach Bottom Atomic Power Station Units 2 and 3 f
Response to Combined Inspection Report L
Nos. 50-277/88-30; 50-278/88 30
Dear Mr. Durr:
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j Your letter dated August 26, 1988 transmitted Combined Inspection Report Hos. 50-277/88-30 and 50-278/88-30 for the routine inspection conducted I
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from August 15, 1988 to August 19, 1988. Appendix A of the letter identified i
one activity which appeared to have not been conducted in full compliance with NRC requirements. Attachment A of this letter provides a restatement of this l
j item followed by the Philadelphia Electric Company's response.
I further, your letter requested that Philadelphia Electric Company 1
(PECo) provide a schedule for implementing the control program to assure that I
walls and blockouts remain in the condition / configuration as analyzed and l
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- modified, in response to this request, a surveillance test will be developed and issued for implementation by December 1, 1988 which will require periodic i
inspection to ensure that masonary walls and blockouts remain in the L
q condition / configuration as analyzed.
lf you have any questions or require additional information, please do f
not hesitate to contact us.
i Very truly yours,
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Attachment
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Addressee 475 Allendale Road i
8 Aing of Prussia, PA 19406 I
I W. T. Russell, Administrator, Region I, USNRC
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- 1. P. Johnson, USNRC Senior Resident inspector
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- 1. E. Magette, State of Maryland j
J. Urban, Delmarva Power J
J. T. Boettger, Public Service Electric & Gas l
j H. C. Schaem. Atlantic Electric g> 1 I
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Attachment A Page 1 of 5 Docket Nos. 50-277 50-278 Violation:
10 CFR bo. Appendi:. B. Criterion X. requires that a program for inspection of activitias affecting quality shall be established and executed by or for the orgar.iention performing the activity to verify conformance with the documented instructions, procedures and drawing for accomplishing the activity.
It also requires that examinations, measurements or tests of material or products processed be performed for each work operation.here necessary to assure quality.
Peach bottom Atomic Power Station. Quality Assurance Manual. Chapter j
- 10. states that inspections shall be performed for each operation (in-process.
end-point, etc.) where necessary to assure quality.
It further specifies that a sampling plan is used for verificatic,n. the plan shall be based on a recognized industry standard, and records shall identify and include justification for the particular sampling plan and sample size used for the inspection.
Contrary to the above, on August 19. 1988 the inspector identified the follc ing:
Item 1 of the violation:
1.
During an independent safety related block wall verification by the NRC, out of a sample of 47 concrete expansion anchors. 22 failed to indicate the specified minimum torque value for the size of anchor
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bolts tested.
The sampling inspection as implemented to verify conformance of concrete expansion anchors with the specified torque l
requirements was inadequate in identifying the above nonconformance, i
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Admission or Denial of item 1 of the Alleged Violat_ ion:
Philadelphia Electric Company acknowledges this portion of the i
violation as stated.
Reason for Violation:
lhe cause of this violation is a procedural deticiency in Construction
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Otvision Procedure CD 5.12 (entitled "Procedure for Installation of Concrete r
Expansion Bolts").
The degree of relaxation in espansion bolts was not recognized. As a result of this NRC investigation, an engineering investigation j
was perfortred anict, considered the relaxation of the bolts.
Specified torque values provided in the procedure are only inst 411ation torque values. Concrete expansion anchor bolts would not be expected to retain this value af ter its I
applicaliCn due to load relaxation.
toad re tuation is expected and is not an indication of a f ailure or impending failure of the bolt to perform its functicn.
The required torque i
auring installation is necessary only to expand the weages of the anchor bolt.
l thereby "setting" (properly anchoring) the anchor bolt in the concrete.
The concrete espansion anchor bolts holding the structural steel members on walls 16.10 and 16.1 (.hich were identified in this Inspecticn Report and are a part
Attachment A Page 2 of 5 Docket Nos. 50-277 50-278 i
of plant Modification 2235) were torqued and inspected in accordance with the approved Construction Division Procedure CD 5.12.
This procedure permits the Quality Control Inspector to inspect bolts after installation by sampling the retained torque of the bolts; however, for the walls identified above, the QC
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Inspectors witnessed the application of the specified installation torque to all the concrete expansion anchor bolts.
The practice of witnessing 100% of this
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l torquing is conservative and acceptable and its use was verified by interviews with the PECo inspectors. The QC inspection documented only a sample number of 3
j tnis torquing on the Concrete Expansion Bolt (CEB) form as required by Procedure CD 5.12.
There is no requirement by PECo or the manufacturer of the bolts to i
reinspect the ancnor bolts after acceptable installation.
1 The concrete expansion anchor bolts in wall 16.6, which were also inspected by the NRC Inspector and identified in the Inspection Report, were j
found to be only hand tightened because the installation had not been completed I
at the time of the hRC's inspection. This was later determined by a review of l
the QC inspection reports which indicated that only the opposite side of the all nad been torqued and inspected at that time, J
i tutent of Significarice of the Violation:
I As stated above, an additional engineering investigation has been performea which considered the relaxation of the bolts and concludes that l
l properly ',et anchor t,olts will perform their safety function.
References I
utilized in this investigation are as follo.s:
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Meinneit, D. F and Heidbrink. F.
D., "Behavior of Orilled-In i
Expansion Anchors," Concrete International, American Concrete Institute (ACl), April, lH 5, pp. 6f36.
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o LinJauist, H.
R., "final Report, USNRC Anchor Bolt Study, Data f
l Survey and Dynamic festing," huREG/CR-2999. HEDL-MISC-7246,
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Hanford Engineering Development taboratory, pp. 17, 23.
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Burdette, E. G., et al "Load Relaxation lests of Anchors in Concrete," Presented at the Symposium on Anchorage to Concrete, 5ponsored by ACl Comittee 355 - Anchorage to Concrete. ACl Annual 1
tonvention, Atlante, GA, January, 1982.
lhe inititi torquing of the ccncrete anchor bolts is necessary to set the 50its and ensure that they perf orm their saf ety function.
The relaxation of the cecrr,te expansion anchor bolts is eApected.
This relaxation would not affect the structural integrity of the installation during a seismic event, Therefore, plant safety would not be affected.
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!mealate Correc y,e Actions Taken and Results Achieved:
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No imediate corrective actions were necessary.
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Attachment A Page 3 of 5 i
Docket Nos. 50-277 50 278 Action laken to Prevent Recurrence:
As a long-term additional measure to ensure that the concrete anchor bolts are properly set on the initial torquing, Construction Division Procedure CD 5.12 will be revised to require QC Inspectors to witness the application of the specified installation torque for 100% of new concrete anchor bolt installations.
In the interim, QC Inspectors have been directed to continue to altress 100% of this torquing, which is in conformance with the procedure change stated aDose.
bate _When full Ccepliance Will Be Achieved:
Construction Division Procedure CD 5.12 will be revised by October 17 I
- 1988, i
item ? of tne violatten:
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No inspection or verification was performed to establish the acceptability of bolt holes in structural steel members for size of hole, shape of hole, method by which holes aere made (punching, drilling, burning), and the location of the holes to match the installed anchors.
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Admissten or Denial of item 2 of the Violation:
Philadelphia Electric Company acknowledges this tortion of the
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violaticn as stateJ.
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1 teas;n fer_the J1olation:
f lhe cause for this violation was a procedural deficiency in that the Quality Control iorm ("Structural Steel Installation Fcrm". CD-5.6-!!!) utilized to document the inspection of the structural steel members for Modification 223t, did not require bolt hole inspection of the structural steel. This form is a part of the Construction Division Procedure CD b.6, Revision 5 ("Procedure for installation and inspection of Pipe Supports and Structural Steel").
This I
deficiency was identified by PECo prior to this NRC inspection and a request for a revision to tne procedure had been 'nitiated. Ho.ever, the procedure revision i
requiring the use of this revised form had not been ccmpleted and in use at the time of the NRC inspection, r
t$ tent er Significance of the Violation:
Improper bnit hole size could affect the transfer of lateral seismic loads f rom the block walls to the supporting concrete mall in that the resulting loads en the bolts and structural steel members could be dif ferent from design loads.
These resulting loads could ultimately result in a failure of the i
affected block noll.
The structural steel members utilized in this modification which act as an interf ace bet een the block and structural concrete walls are being reinspected for bolt hole size.
The bolt holes hich exceed the design I
Attachment A Page 4 of 5 Docket Nos. 50-277 50-278 requircrents are being documented and dispositioned on nonconformance reports (NCR).
Immediate Corrective Actions Taken and Results Achieved:
lhe structural steel installation form (CD-5.6 !!!) used for Modification 2235 has been revised to require the inspection of bolt holes in the structural steel members and has been included in the Construction Job Memorandum.
This revision will extend the existing inspection for hanger base j
plates to all structural steel bolt holes.
This inspection will include the size of the hole, the shape of the hole, the method by which the holes were made, and the location of the holes to match the installed anchors.
Interim guidance to construction engineers and site lead men has been issued to invoke this inspection criteria prior to procedure CD 5.6 being revised.
Acticns Taken tu Prevent Recurrence:
Construction Olvision Procedure CD 5.6 is being revised to incorporate the revised Structural Steel Installation Form CD-5.6-Ill.
l_ ate When Full Conpliance Will Be Achieved:
The bolt holes which exceed the design requirements will be documented and dispositioned on nonconformance reports by November 1, 1988.
Construction Division Procedure CD 5.6 will be revised by October 17, It_em 3 of the Violation:
3.
lhere was no objective evidence to substantiate any examinations, c.easurenents or tests were performed to verify the acceptability of grout or the grouting operation used in block wall modifications.
7 Admission or Denial of item 3 of the Violation:
Philadelphia Electric Company acknowledges this portion of the violation as stated.
c'eason f or t he Violation:
(cnstruction Division Proceaure CD 5.13 (entitled "Procedure for Grout P'acement at Nuclear Power Plants") is designed to provide the necessary I
objective evidente of the acceptability of a grouting operation in the form of an inspection of the surface preparation, presoaking, mixing, placing and curing l
of the grout used in the block wall modification.
In the example cited by the NRC Inspector, the Construction Jeb Henorandum (CJM), which provides the Quality i
Control procedures to be utilized in performing the identified modifications to the block walls (Modification 2235), did not reference Construction Division t
Procedure CD 5.13.
This deficiency had been identified in a nonconformance
Attachment A Page 5 of 5 Occket Nos. 50-277 50-278 report (NCR CD.P-1469) and a disposition of "use-as-is" was recommended by the engineer performing the grouting operation.
The cause for this violation was that the final "use-as-is" disposition, supplied by the engineer assigned to reviewing and dispositioning the nonconformance report (NCR CO-P-1469), did not provide objective evidence in the form of an independent, direct inspection, examination or test to demonstrate the adequacy of the grouting operation, t xtent er Signjfjcance of the Violaticn:
An inspection of the subject grout for the walls identified in the nonconformance report (CO-P-1469) was performed by removing the structural steel trembers associated with the grouting.
The reinspection determined that the grouting was acceptable.
Therefore, this failure to provide a sufficient "use-as-is" justification.vould not have adversely affected the safe operation of the i
- plant, limediate Corrective. Actions Taken and Results Achieved; two ncnconformance reports (NCR CD-P-1569 and NCR CD-P-1564) have been issued to include the necessary objective evidence to demonstrate the grouting l
operation was acceptable. These NCRs will be completed by October 17, 1988, 1
Actions Taken to Prevent Recurrence:
The Installation Engineer and construction personnel have been instructed to use Construction Division Procedure CD 5.13 in conjunction with the manuf acturer's instructions for all Modification 2235 grouting work unless stated otherwise in an approved Engineering Review Request (ERR).
This corrective action to prevent recurrence was stated in the disposition of the original NCR (CD P-1469).
The responsible Engineer. Independent Reviewer and Section Head responsible for the original disposition of the NCR have been reinstructed in the need to provide objective evidence when performing "use-as-is" disposition of grouting operations.
Date When full (cmpliance Will Be Achieved:
All act tons have been corrpleted.
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