ML20202E715

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Insp Rept 50-219/86-09 on 860505-09.Violation Noted:Records Verifying That Initial Masonry Wall Survey Conducted in Response to IE Bulletin 80-11 Not Retained or Retrievable Through Document Control Sys
ML20202E715
Person / Time
Site: Oyster Creek
Issue date: 05/29/1986
From: Varela A, Wiggins J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20202E701 List:
References
50-219-86-09, 50-219-86-9, IEB-80-11, NUDOCS 8607150006
Download: ML20202E715 (13)
v • d • e


See also: IR 05000219/1986009

Text

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                              U.S. NUCLEAR REGULATORY COMMISSION
                                             REGICN I

     Report No.   50-219/86-09
     Docket No.   50-219
     License No. DPR-16
     Licensee: GPU Nuclear Corporation
i
                 Oyster Creek Nuclear Generating Station
l                P. O. Box 388

l Forked River, NJ 08731 

i
     Facility Name: Oyster Creek Nuclear Generating Station
     Inspection At: GPU-Parsippany, New Jersey and Oyster Creek Plant
     Inspection Conducted: May 5-9, 1986
     Inspectors:       I              N       N                          Jc; P6 _
                   A,7. ~Varela, Lead Reactor Engineer                 ' da'te
     NRC Contract Personnel:     M. E. Nitzel, EG&G Idaho, Inc.
                                 V. B. Call, EG&G Idaho, Inc.          -
     Approved by:              1.,                                       '
 l
                    J. gT, 'W ggins[[Cfief, Materials and                 date
                     Process Sectun", EB, DRS
     Inspection Summary:    Inspection on May 5-9, 1986 (Report No. 50-219/86-09).
     Areas Inspected: Special announced inspection by a region-based inspector and
     two contractor personnel at the GPU, Parsippany, New Jersey engineering office
     and at the Oyster Creek Plant.     The inspection encompassed review of licensee
     responses and subsequent as-built inspection, analysis and modifications of

, masonry walls in response to IE Bulletin 80-11, Masonry Wall Design. This 

     inspection included a walkdown of existing walls affected by safety related
     equipment, a review of design analyses and a review of werk packages on wall
     modifications necessary to preclude jeopardy to safety related equipment.
     Results: Two violations and 1 deviation were identified.

     g7150006860630
     0      ADOCK 05000219

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                         PDR

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                                                                     DETAILS
    1.  Persons Contacted

! 

       GPU Nuclear Corporation

i) *R. Armstrong, Engineer E&D 

       *D. K. Croneberger, Director-Engineering and Design
       *T. H. Chang, Senior Engineer
       *P. E. Czaya, Licensing Engineer
         P. B. Fiedler, Vice President
;      *L. Gariblan, Engineering & Design
;
         D. Grace, Engineering Projects - Director

i *L. R. Hillman, Senior Project Engineer 3 R. E. Hudoy, QA Auditor 

       *L. W. Harding, Manager, Q&E

i M. Laggart, Manager, BWR Licensing 

       *R. S. Markowski, Manager, QA Prog. Dev./ Audit                                                                                                       i
!      *G. J. Mencinsky, QA Engineer
       *A. P. Rochino, Manager, Engineering Mechanics
       *R.  F. Wilson, Technical Functions Vice President
c
       Impell Corporation (contractor or A/E)
       S. D. Costello, Supervising Engineer
       E. Fishman, Lead Senior Engineer
    2. Inspection Purpose and Scope
       The purpose of this inspection was to review with cognizant and respon-
       sible licensee representatives at the corporate office and the plant, the
       completeness of the licensee's 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, test-
       ing, 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 Bulletin.
    3. Review Criteria
       The Bulletin was used to define actions expected of the utility. 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 provide f,rther guidance,
i
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:          4.   Review of Licensee Responses
I

' 

                The inspection team reviewed the licensee's Bulletin responses prior to          '
!               the inspection. This activity consisted of comparing the pertinent

] information presented in the submittals to the Bulletin requirements and 

,               licensee commitments to verify, to the extent possible, that all Bulletin
i               requirements were met. The responses reviewed included reports addressing

' 

                the reevaluation methodology, acceptance criteria, wall configurations and
                functions, structural adequacy, proposed modification plans, and modifi-

i cation schedules. Table 1 lists those documents reviewed prior to the 

                inspection.
                                                           .
                Any items of noncompliance or those requiring further discussion were

- 

I               noted as items to be addressed while at the corporate office or plant            ,

i site. Questions relating to the response were forwarded to the licensee ' i in advance of this inspection as preliminary agenda for discussion. 

1
i               The inspection team reviewed additional material provided by the licensee
l               during the inspection. This material consisted of documentation of
 j              masonry wall identification used in recent utility walkdowns and proce-
:               dures and specifications for repair, wall modifications, and configuration
j               control. Reevaluation calculations for sample masonry walls and wall
                modification calculations, both of which were performed by the licensee's

j consultants (Impell Corp.) were also reviewed. The review of these docu- i , 

                ments consisted of comparing pertinent information to Bulletin require-         '

j ments to verify compliance, and a review of the assumptions, boundary j conditions, physical properties, and other analysis parameters to the t 

                conditions existing in the plant to assure that appropriate results had
been obtained in the reanalysis effort. The pertinent c'ocuments described "
;               above for IEB 80-11 are listed in Tables 2 and 3.

1 

                4.1 Findings:
l                     Two violations, one deviation, and two unresolved items resulted
                      from the reviews described above. Further details regarding the
                                                                                                ,
                                                                                                i

i findings are given below. ~ 

                     4.1.1 Control of Vendor Services

J 

i                           The licensee engaged Computech Engineering Services, Inc., to
!                           develop acceptance criteria applicable to masonry walls at
                            Oyster Creek and to assist in responding to questions posed by      '

lf 

j
                            the NRC staff. These engineering activities formed an integral
                            part of the licensee's reevaluation program since, in its ulti-     i
l
                           mate use, the criteria document would directly affect safety-
                            related systems and/or components by defining acceptance limits
!                           on structural adequacy. Thus, these activities are subject to
                                                                                                ,
l                           the requirements of 10 CFR 50, Appendix 8. Computech prepared
                            the 180 day Bulletin response to the NRC for GPU for the crt-
l                           teria for the reevalution of Masonry Walls at Oyster Creek.

1 l. . 

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                                                                                  4

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;                                   They also prepared for GPU the additional information, requested

i by the NRC June 8,1983, concerning masonry wall design at i Oyster Creek. However, the licensee produced no evidence , indicating Quality Assurance oversight of Computech to assure its ! control of quality for the engineering services provided to GPU. l The licensee provided documentation demonstrating quality assur- i ance (QA) oversight of all vendors or consultants involved in. l Bulletin activities except Computech. This lack of QA oversight j of Computech was determined to be an apparent violation of 

1
                                    Criteria VII (Control of Purchased Material and Services) of 10

i CFR 50, Appendix B (50-219/86-09-01). 

                    4.1.2 Control of Records
I

j The licensee stated that approximately 200 masonry walls exist 

                                    throughout the plant; 45 walls were addressed by Bulletin
                                    responses. A review process, possibly including the review of
                                    existing drawings and an in plant walkdown was required to
,                                   arrive at this reduced number of walls. The activity of deter-                                           ,
mining which walls supported safety-related equipment or had the '
                                    potential for impacting safety-related equipment if they failed

, during a seismic event directly affected the safety status of ! the subject equipment. Therefore, this activity would also be j governed by the requirements of 10 CFR 50, Appendix B. The - 

 ;                                  licensee was asked to provide documentation resulting from the                                           !'

{ masonry wall survey so that verification of the reduced number . could be performed. The licensee was also asked to provide ! documentation demonstrating that this original activity was i performed using controlled procedures and/or instructions. The i licensee was not able to provide this information. Due to the ' 

                                    lack of documentation the inspectors were not able to verify
                 '

l 1 that Action Item 1 of IEB 80-11 was performed correctly and was j controlled. j Failure to maintain adequate records of the activities described j above is an apparent violation of 10 CFR 50, Appendix B, i 

                                    Criteria XVII (50-219/86-09-02).
                    4.1.3 Use of Type M Mortar

i Action Item 3 of Bulletin IEB 80-11 states that " Existing test 

                                    data or conservative assumptions may be used to justify the
                                    reevaluation criteria...." Contrary to this, the licensee
i                                   relied upon mortar properties found in the construction spect-
!                                   fication as input to wall reevaluations.                              Thase strength values

j were for high strength type M mortar. No apparent attempt was j made to verify, by testing or by documentation other than the

specification, that type M mortar was actually used throughout

j the construction of all safety-related masonry walls. The I 4 

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                        inspectors also noted that lower mortar strength properties were

} not assumed to demonstrate structural adequacy by reanalysis. . 

                       The inspectors concluded that the licensee had deviated from the

l actions it had committed to regarding Bulletin Action Item 3 

*
                       without adequate justification. An assumption was made regard-

) ing mortar strength where records were not found to substantiate 

                       that high strength type M mortar was used in the initial masonry

- 

                       wall construction. This item is a deviation from commitments
                       made in response to IE Bulletin 80-11. (50-219/86-09-03).

j Unresolved Items: i i 

                       During the inspection the licensee stated that a complete
 ;                     resurvey of all 200 masonry walls is planned to reestablish
l                      the baseline data (physical dimensions, boundary conditions,
!                      attached equipment, etc.) which will be used for any future
'
                       plant modifications which might affect safety-related masonry
'
                       walls. This new data will also be used as input to indicate            4
                       which masonry walls are categorized as safety-related and to           '

, provide documentation, and verification of the original survey. 

                       The inspectors requested a schedule for the completion of the          i
                                                                                              '
                       resurvey effort and a copy of the procedure (s) or instructions

i which will be used to control the resurvey effort. This area { will remain unresolved pending review of the above and of the j results of the resurvey effort (50-219/86-09-04). 

I
During the inspection the licensee stated that a plan was being
developed to control future modifications to safety-related

i masonry walls. This procedure is intended to prevent the ! alteration of any masonry wall that could invalidate the struc- 

!                      turai analysis or, as an alternative, provide proper notifi-

! 

                       cation so an engineering evaluation can be completed. It was
;                      noted that a final approved version of this procedure was not
                       available for review. The licensee also stated that periodic

! surveillance of the subject masonry walls would be performed to j ensure that the physical conditions assumed during the reanal- , 

j                      ysis effort remain valid. This iterr is unresolved pending
                                                                                              i
                       implementation of these procedures and review by the NRC              !
                       (219/86-09-05).

^ 

;       5. Verification Walkdown Inspection                                                  i
           A physical inspection of certain masonry walls subject to Bulletin action         I

!' was conducted. The walls included in this sample were chosen by the 

           inspection team. The purpose of this walkdown was to verify samples of
                                                                                              ,
                                                                                              ;
           inspections and/or modifications required by the Bulletin. The walls

j shown in Table 4 were examined. The modification status of these walls 

           is shown in Table 5.

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        5.1 Findings:

! One unresolved item resulted from the plant walkdown. Further , a details regarding this item are given below. ~ ! i During the walkdown-inspection it was noted that wall 22 had incurred ! a through-wall crack. It was also noted that wall 23 had incurred j ' 

             a similar crack; however, due to the location of equipment it could
             not be verified if this crack extended through the wall.      Several
             other, less extensive cracks were noted to exist in these two walls.

., The licensee was requested to provide the following information ! regarding these walls: 

I
!            1.    An analysis of the probable cause of these cracks,
!
             2.    Documentation of the repair efforts for these cracks or a

] 3 demonstration of the structural adequacy of the walls including j the effects of the cracked block and mortar. 

<
l            This area is considered unresolved pending NRC review of the licen-
!
             see's actions (50-219/86-09-06).
!
;   6. Review of Licensee Administrative Controls and Quality Assurance
1
l       In determining the adequacy of administrative controls in assuring quality
i
       work, the inspector requested records of GPU quality assurance documen-

, tation relating to activities affected by IE Bulletin 80-11. Although no ] quality assurance documentation of audits of the initial engineering 

       surveys of all as-built walls and their effect on safety related equipment
       was produced, there was evidence of QA/QC involvement in Bulletin-related
,
       activities. These audit records were reviewed and discussed with cogni-
'
       zant personnel,

i 1 Masonry wall modification packages were also sampled for QA/QC interface 

:
'      activities. Wall numbers 21, 22 and 23, modified during 1984, were adequa-
       tely signed-off by quality control personnel. Documentation of quality

I assurance in plant modifications, as required by procedure number 124, 

I
       was observed to have adequately satisfied system walkdown documentation
!      requirements prior to turnover for operation.

) Documentation reviewed included: ' 

       -
             Design / Modification Control audit May 4, 1984 of GPU Tech Function
;            Division (follow-up/ corrective actions for NRC construction
             assessment inspection April 1984)
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     -
               Audit Report No. 0-0C-86-01 of Burns & Roe, Inc. February 12-14,
               1986/ B&R Quality Assurance Program
     -
               Audit Report No. 0-0C-85-05 of Stone & Webster Engineering Corp.
               July 22-24,1985/SWEC QAP-Engineering Services
     -
               Audit Report No. 0-COM-84-04 of Impell Corp. , February 22-24 and
               March 14-15, 1984/ Masonry Wall design / Implementation of QAP
     -
               Audit Report No. 0-COM-03 of SWEC, February 13-14, 1984/QAP relatir.g
               to design of plant modifications
     -
               Various vendor computer software and services, audit of QAP versus
               10 CFR Appendix B 1983
    Additionally the inspector verified pertinent documents such as the
     following:
               Notification, dated April 26, 1985, to all AEs, to document in
               writing that modifications they design for GPU facilities must be
               reviewed to determine what relationship (if any) these modifications
               have with respect to the masonry walls at each facility. Guidelines
               are attached to this notification for submittal by each AE for evalu-
               ation by GPUN's project engineer prior to performing specific modi-
               fication.
     Findings:
    No violations were identified.
 7. Summary
    Based on the information examined during this inspection and the field
    walkdowns which resulted in violations and deviations, IEB 80-11 remains
    open pendirg licensee responses, corrective actions and completion of the
    reverification survey identified in Paragraph 4.
 8. Definition of Unresolved Items
    Unresolved items are matters about which more information is required in
    order to ascertain whether they are acceotable, violations, or deviations
    relative to the bulletin requirements. Unresolved items identified during
    this inspection are discussed in paragraphs 4 and 5 above.
 9. Exit Meeting
    The inspection team conducted an exit meeting attended by licensee repre-
    sentatives (denoted in paragraph 1). The NRC inspector summarized the
    inspection findings and the licensee acknowledged these comments. At no
    time during the inspection was written material other than the preliminary
    agenda described in paragraph 4 provided to licensee personnel.
        _ - ..          - - _ _

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l Table 1 - DOCUMENTATION REVIEVED PRIOR TO INSPECTION 

        Document             Description
!
        ----
                            Gr ; Nuclear (GPUN) letter to NRC dated 7-7-80 containing
;                           60 day response to IE8 80-11
;
        ----
                            GPUN letter to NRC dated 9-19-80 containing revisions to

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                            60 day response
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       ----
                            GPUN letter to NRC dated 11-14-80 containing 180 day
;                           response

       ----
                            GPUN letter to NRC transmitting reevaluation results
1
       ----
                            GPUN letter to NRC dated 4-15-83 requesting deferment of IEB
                            80-11 modifications                                                                           .
       ----
                            NRC letter to GPUN dated 6-8-83 requesting additional informa-
                            tion regarding IFB 80-11 submittals                                                           ,
       ----
                            GPUN letter to NRC dated 7-15-83 transmitting proposed schedule
                            for additional responses to IEB 80-11
       ----
                            GPUN letter to NRC dated 8-11-83 containing additional responses
       ----
                            GPUN letter to NRC dated 11-2-83 containing additional responses
                            to IEB 80-11
       ----
                            GPUN letter to NRC dated 3-14-84 containing consequence analysis
                            of masonry wall failures
      ----
                            NRC letter to GPUN dated 3-27-84 transmitting formal concurrence
'
                            with delays for masonry wall nodifications scheduled for outage
                            10R
      ----
                            GPUN letter to NRC dated 5-11-84 trasmitting revisions to
                            masonry wall failure consequence analysis report
      ----
                            GPUN letter to NRC dated 7-26-84 transmitting revision 0 to
                            Topical Report TR-019 regarding masonry wall reanalyses
;
      ----
                            NRC letter to GPUN dated 9-18-84 transmitting conc m rerice with
                            GPUN request to delay modifications to wall 21 to the cycle 11
                            refueling outage

      ----
                            GPUN letter to NRC dated 3-21-85 containing a status report on
                            IEB 80-11 activities at Oyster Creek

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                                              --         ---e , -----r -   ~ - - - - - --- -' + - - - -- ' - "-- ~ T

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                                           Table 1                             1
                                           ----
                                                   GPUN letter to NRC dated 6-14-85 transmitting revisions to
                                                   topical report TR-019
                                           ----
                                                   GPUN letter to NRC dated July 26, 1985 requesting delays is
                                                   scheduled modifications to masonry walls.
                                           ----
                                                   GPUN letter to NRC dated 8-14-85 transmitting final eval::ation
                                                   of masonry walls (revision 1 to TR-019)
                                           ----
                                                   NRC summary (dated 10-29-85) by J. Donohew of a meeting held at
                                                   Oyster Creek on 9-18-85. Attachment I contains proposed masonry
                                                   wall modifications for cycle 11R outage.
                                           ----
                                                   NRC letter to GPUN dated 12-23-85 transmitting the NRC (NRR)
                                                   safety evaluation of the licensee responses for IEB 80-11
                                                                                                                   d
                                                                                                                   .

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    Table 2 - DOCUMENTATION REVIEWED DURING INSPECTION
    Document        Description
   ----
                    GPUN internal memo regarding information to be collected in
                    block wall surveys (not original survey procedure)
   ----
                    GPUN wall survey forms (not original survey data) for walls
                    25, 26, and 27
   0370-108-1641    Impell Corp. design review report regarding masonry wall
                    reanalysis -checklist for completeness
   0370-108-PI-002 Impell project instruction for phase II of the masonry wall
                    modification program
   ----
                    Supplier evaluation report - a detailed QA audit performed for
                    license agreement for the ANSYS computer program
   SP-1302-23-001 GPUN specification for repair of cracks in masonry walls at
                    Oyster Creek Nuclear Generating Station (OCNGS)
   OCIS 402240-003 GPUN installation specification for control room paneling
                    (part of modification to wall 2)
   509-80-1         GPUN modification proposal for the removal of masonry walls
   1.8. 509.01-2 GPUN installation specification for boundary supports of
                    masonry walls

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 Table 3 - Calculation Packages Reviewed
 Calc. No.         Wall         Elev. (ft.) Field Inspection
 C-1302-150
 5320-005          5,6,7        46'-6"           No
 37-108-022        8            46'-6"           No
 37-108-002        31,32,33,45  23'-6"           Yes
 37-108-021        31,32,33,45* 23'-6"           Yes
 * Includes redesigned pipe support.
           _   ___

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 Table 4 - MASONRY WALLS FIELD VERIFIED
    Wall         Elevation (ft.)                Location
 9                    46'-6"                    Computer Room
 17,18,53*            35'                       Battery Room
 21                   23'-6"                    480V Switchgear Room
 22                   23'-6"                    480V Switchgear Room
 23                   23'-6"                    480V Switchgear Room
 24                   3'-6"                     Turbine Bldg.
 25                   35'                       Cable Spreading Room
 26                   35'                       Cable Spreading Room
 27                   35'                       Cabie Sprecding Room
 43                   51'                       Reactor Bldg.
 29,30                -19'-6"                   Reactor Bidg.
 31,32,33,45          23'-6"                    Reactor Bldg.
 * Walls shown in groups were analyzed in one combined model.
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                            Table 5 - MODIFICATION STATUS OF MASONRY WALLS FIELD VERIFIED

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                                 Wall                                                        Drawing Number        Status

l 1 9 Preemptive 2 Complete i 

                            17,18,532                                                        0370-108-005,6,73     To Be Completed
                           21                                                               3E-153-38-003          Completed
                           22                                                               3E-153-38-005          Completed
                           23                                                               3E-153-38-006          Completed
                           24                                                               0370-108-001,3         To Be Completed
                           25                                                               N/A"                   No Mod. Required
                           26                                                               N/A                    No Mod. Required

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                           27                                                               N/A                    No Mod. Required
;                          43                                                               0370-108-009,10        To Be Completed
29,30 0370-108-002 To Be Completed
                           31,32,33,45                                                     0370-108-008            To Be Completed
.
                           Note:

1 2 

                           1
                                          -
                                                           Preemptive modifications were made to some walls. This consisted
,                                                          of removing portions of walls to remove the potential for impact
                                                           following failure during a seismic event.
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                          2               -
                                                          Walls shown in groups were analyzed in one combined model.

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                          3               -
                                                          All drawing numbers beginning with 0370 indicate Impell Corp. drawings.
                          4               -
                                                          N/A = Not Applicable.

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